Burden Calculation Tables

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Overview

Table 1
Table 2
Capital and O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart LLLLL) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person‑Hours per occurrence	Number of occurrences per year	Person‑Hours per respondent per year (C=A*B)	Respondents per year a	Technical person‑hours per year (E=C*D)	Management person‑hours per year (F=E*0.05)	Clerical person‑hours per year (G=E*0.1)	Annual costs ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$153.55
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A									Technical	$122.20
4. Reporting Requirements										Clerical	$61.51
A. Familiarization with regulatory requirements
New Respondents	25	1	25	0	0	0	0	$0
Existing Respondents	1	1	1	8	8	0.4	0.8	$1,088.23
B. Required activities:
New Respondents c, d
i. Initial performance test	24	1	24	0	0	0	0	$0
ii. Repeat of initial performance test e	24	0.2	4.8	0	0	0	0	$0
Existing Respondents
i. Monitoring of operating parameters and equipment: f	Included in 5E
ii. Periodic 5-year performance testing g	24	1	24	1	24	1.2	2.4	$3,265
C. Gather Existing Information	Included in 5D, 5E
D. Write report c, d
i. Notification of compliance status	4	1	4	0	0	0	0	$0
ii. Notification of intent to construct a major source and review application	4	1	4	0	0	0	0	$0
iii. Notification of initial construction/ reconstruction a	4	1	4	0	0	0	0	$0
iv. Notification of actual startup	4	1	4	0	0	0	0	$0
v. Notification of performance test	4	1	4	0	0	0	0	$0
vi. Reports of performance test results	Included in 4B, 5E
vii. Notification of periodic 5-year performance test g	4	1	4	1	4	0.2	0.4	$544
viii. Reports of periodic 5-year performance test results g	Included in 4B, 5E
ix. Semiannual compliance reports d	12	2	24	8	192	9.6	19.2	$26,117.47
Subtotal for Reporting Requirements					262			$31,014
5. Recordkeeping Requirements
A. Read instructions	Included in 4A
B. Plan activities	10	1	10	0	0	0	0	$0
C. Implement activities	Included in 4B
D. Develop record system h	NA
E. Time to enter and transmit all information into record system
i. Record performance tests	4	1	4	0	0	0	0	$0
ii. Record of periodic performance tests g	4	1	4	1	4	0.2	0.4	$544
iii. Record operating parameters i	1	365	365	8	2,920	146	292	$397,203.22
iv. Record deviations j	2	1	2	1	2	0.1	0.2	$272.06
v. Continuous parameter monitoring calibration and maintenance i	4	5	20	8	160	8	16	$21,764.56
vi. Store, file, and maintain records	20	1	20	8	160	8	16	$21,764.56
F. Time to train personnel i	16	1	16	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,733			$441,549		222
Total Labor Burden and Costs (rounded) k					4,000			$473,000
Total Capital and O&M Cost (rounded) k								$84,900		hr/response
GRAND TOTAL (rounded) k								$558,000
Assumptions:
a There is an average of 8 existing respondents per year over the next three years of this ICR. In addition, we assume that no new facilities will become subject to this regulation during the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $153.55 ($73.12+ 110%); Technical $122.20 ($58.19 + 110%); and Clerical $61.51 ($29.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c New respondents would have to comply with the initial rule requirements including notifications and performance tests for add-on control devices. There are no new respondents anticipated over the next three-year period of this ICR, therefore, there is no anticipated burden associated with these activities.
d We have assumed that the initial performance tests and reports are conducted by an emissions testing contractor, however, facility personnel will also work on-site to assist the contractor.
e We have assumed that 20 percent of new respondents will have to repeat the performance tests due to failure. Since there are no new respondents estimated, this requirement does not apply.
f Monitoring and recordkeeping of operations for respondents with add-on control devices include: 1) specific operating parameters for each control device established during the performance test, 2) deviations, and 3) work practices.
g The rule requires periodic testing every 5 years. Based on a review of permit data collected during the recent RTR (2598.02, 85 FR 14526), 3 of the 4 asphalt roofing manufacturing facilities and 1 of the 4 asphalt processing facilities already perform all periodic performance testing under State Agency permits. Therefore, this ICR only includes the cost for the 4 remaining facilities not currently required to conduct periodic testing under State Agency permits (1 asphalt roofing manufacturing facility and 3 asphalt processing facilities). We assume that 20 percent of respondents will repeat the performance tests due to failure. (4 respondents test once every five years (4/5=0.8), plus 20% retest (0.8*1.2 = 1 respondent/year, rounded)). Therefore, this testing occurs for one respondent each year. We assume that the testing and reporting are conducted by an emissions testing contractor, and facility personnel will work on-site to assist the contractor. We assume 4 asphalt roofing manufacturing facilities would conduct an EPA Method 5A test of the PM control device, an EPA Method 25A test of the thermal oxidizer, and an EPA Method 9 opacity test; and 4 asphalt processing facilities would conduct an EPA Method 25A test of the thermal oxidizer and an EPA Method 9 opacity test.
h We have assumed that new respondents already have the technology and recordkeeping systems in place to monitor its daily operations and to comply with existing regulations.
i We have assumed that it takes respondents the following approximate times to meet recordkeeping requirements: 1) one hour per day for recording operating parameters, 365 days per year; 2) four hours to calibrate and provide maintenance to continuous parameter monitors, five times per year; and 3) and 16 hours per year to train new employees on add-on control devices, continuous parameter monitoring technology, and requirements.
j We assume 15% of sources will have a deviation from an emission limitation. (8*0.15=1.2, rounded to 1)
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart LLLLL) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. Of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
New Respondents: c										Labor Rates
i. Notification of compliance status	4	1	4	0	0	0	0	$0		Management	$69.04
ii. Notification of intent to construct a major source and review application	4	1	4	0	0	0	0	$0		Technical	$51.23
iii. Notification of start of construction	2	1	2	0	0	0	0	$0		Clerical	$27.73
iv. Notification of actual startup	2	1	2	0	0	0	0	$0
v. Notification of initial performance test and test plan	4	1	4	0	0	0	0	$0
vi. Report of performance test results including operating parameters	20	1	20	0	0	0	0	$0
Existing Respondents
i. Notification of periodic 5-Year performance testing d	4	1	4	1	4	0.2	0.4	$230
ii. Report of periodic 5-Year performance testing d	20	1	20	1	20	1.0	2.0	$1,149
ii. Review of semiannual compliance reports	8	2	16	8	128	6.4	12.8	$7,354.24
TOTAL (rounded) e					175			$8,730
Assumptions:
a There is an average of 8 existing respondents per year over the next three years of this ICR. In addition, we assume that no new facilities will become subject to this regulation during the three-year period of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $69.04 (GS-13, Step 5, $43.15 + 60%); Technical $51.23 (GS-12, Step 1, $32.02 + 60%); and Clerical $27.73 (GS-6, Step 3, $17.33 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c New respondents are required to submit initial notifications and conduct a performance test for add-on control equipment. There are no new respondents anticipated over the next three-year period of this ICR, therefore, there is no anticipated burden associated with these activities.
d The rule requires periodic performance testing once every 5 years. We assume review of the notification will take 4 hours and review of the periodic performance test report will take 20 hours. We assume that 20 percent of periodic performance tests will be repeated due to failure. There are four sources that do not already have testing requirements in their state permits and require testing under this rule. (4 respondents test once every five years (4/5=0.8), plus 20% retest (0.8*1.2 = 1 respondent/year, rounded)). Therefore, this testing occurs for one respondent each year.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital and O&M

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Notification of compliance status	0	1	0	0
Notification of intent to construct a major source and review application	0	1	0	0
Notification of initial construction/ reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of performance test and test plan	0	1	0	0
Report of performance test results	0	1	0	0
Notification of periodic performance test	1	1	0	1
Report of periodic performance test results	1	1	0	1
Report of semiannual compliance reports	8	2	0	16
			Total	18
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents a	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M
Asphalt Roofing Manufacturing
PM control device - Testing b, c	$83,100	0	$0	$83,100	0.2	$16,620
Thermal oxidizer - Testing b, d	$55,000	0	$0	$55,000	0.2	$11,000
Opacity - Testing b, e	$1,500	0	$0	$1,500	0.2	$300
PM control device - Replace filters f		0	$0	$7,415	4	$29,662		CEPCI Index
Asphalt Processing								2020	2003
Thermal oxidizer - Testing b, g	$44,000	0	$0	$44,000	0.6	$26,400		596.2	402
Opacity - Testing b, e	$1,500	0	$0	$1,500	0.6	$900
Asphalt Roofing Manufacturing and Asphalt Processing
CPMS for control device(s) h	N/A	0	$0	N/A	0	$0
Total (rounded) i			$0			$84,900
a We assume no new sources will construct during the three-year period of this ICR.
b The rule requires periodic testing every 5 years. Based on a review of permit data collected during the recent RTR (2598.02, 85 FR 14526), 3 of the 4 asphalt roofing manufacturing facilities and 1 of the 4 asphalt processing facilities already perform all periodic performance testing under State Agency permits. Therefore, this ICR only includes the cost for the 4 remaining facilities not currently required to conduct periodic testing under State Agency permits (1 asphalt roofing manufacturing facility and 3 asphalt processing facilities). 1 asphalt roofing manufacturing facility tests once every five years (1/5=0.2 respondents/year). 3 asphalt processing facilities each test once every five years (3/5=0.6 respondents/year).
c We assume the contractor cost for PM control device performance testing using EPA Method 5A at an asphalt roofing manufacturing facility with 7 PM filters is $83,100, based on a cost of $16,500 for first filter and an add-on charge of $11,100 for each additional filter.
d We assume the contractor cost for total hydrocarbon (THC) performance testing of a thermal oxidizer using EPA Method 25A at an asphalt roofing manufacturing facility is $55,000.
e We assume the contractor cost for opacity testing using EPA Method 9 is $1,500.
f The ongoing cost for replacement filters and data collection system maintenance is $7,415. This value has been updated from year 2003 to year 2020 using the CEPCI Index.
g We assume the contractor cost for total hydrocarbon (THC) performance testing of a thermal oxidizer using EPA Method 25A at an asphalt processing facility is $44,000.
h EPA assumes that all facilities subject to the standard have or will obtain add-on control devices that are already equipped with continuous parameter monitoring equipment. This monitoring equipment is required not only for compliance purposes but also to operate the control equipment.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Data from RTR ICR 2598.02
5-Year Periodic Testing Costs For Facilities Not Currently Required to Test Under State Permit
Industry Sub-Group	Number of Facilities Not Currently Required to Test Under State Permit a ($)	Average PM Test Cost per Facility ($)	Average VE or Opacity Test Cost per Facility ($)	Average THC Test Cost per Facility ($)	Total Average Test Cost Per Facility ($)	Total Cost for Facilities Not Currently Required to Test Under State Permit a ($)
Asphalt roofing manufacturing facilities	1	$83,100.00	$1,500.00	$55,000.00	$139,600.00	$139,600
Asphalt processing facilities	3	$0.00	$1,500.00	$44,000.00	$45,500.00	$136,500
Total - Asphalt roofing manufacturing facilities and Asphalt processing facilities	4					$276,100
a Includes Hunt Southland Refining Co. - Sandersville, Certainteed Corp. (Oxford, NC),Wynnewood Refining Co., and Valero Refining Co.
Source: Appendix A from memo "Cost Impacts for the Asphalt Processing and Asphalt Roofing Manufacturing Risk and Technology Review Proposal", September 2018
Facility Name	City	State	State Required 5-yr Tests	Asphalt Storage Tanks1	Number of PM Control Devices	Number of Thermal Oxidizers	VE or Opacity Test Cost1 ($)	PM Test Cost2 ($)	THC Test Cost3 ($)	Total Test Cost ($)
Hunt Refining Company	Tuscaloosa	AL	Yes	Yes	0	1	1,500	0	44,000	see footnote 4
Owens-Corning	Minneapolis	MN	Yes	Yes	3	1	1,500	38,700	44,000	see footnote 4
Hunt Southland Refining Co. - Sandersville	Heidelberg	MS	No	Yes	0	1	1,500	0	44,000	45,500
Certainteed Corp.	Oxford	NC	No	Yes	7	2	1,500	83,100	88,000	172,600
Owens-Corning Fiberglass Trumball	Medina	OH	Yes	Yes	4	1	1,500	49,800	44,000	see footnote 4
Wynnewood Refining Co.	Wynnewood	OK	No	Yes	0	1	1,500	0	44,000	45,500
Valero Refining Co.	Ardmore	OK	No	Yes	0	1	1,500	0	44,000	45,500
Certainteed Corp.	Shakopee	MN	Yes	Yes	3	1	1,500	38,700	44,000	see footnote 4
TOTAL COST OVER 5-YR PERIOD										309,100
1 Cost of opacity testing using EPA Test Method 9 is estimated to be $1,500. For each facility that has asphalt storage tanks, it was assumed that the facility would have at least one Method 9 test.
2 Cost of PM performance testing using EPA Test Method 5A is estimated to be $16,500 for first filter and an add-on charge of $11,100 for each additional filter.
3 Cost of THC performance testing using EPA Test Method 25A is estimated to range from $16,200 (concentration) to $44,000 (efficiency). We chose to be conservative and apply the higher cost of $44,000.
4 Costs not included for these facilities because they are already required to test every 5-yrs by the State permitting agency and will not incur additional testing costs with the new testing requirements.