Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	20
Number of Respondents	59
Total Estimated Burden Hours	2,370
Total Estimated Costs	$286,000
Annualized Capital O&M	$885
Total Annual Responses	118
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal)
Burden Item	(A) Hours per occurrence	(B) No. of occurences per respondent per year	(C) Hours per respondent per year (C=AxB)	(D) Respondents per yeara	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total costs per year ($)b
1. Acquire and install recordkeeping technology and systems c	4	1	4	0	0	0	0	$0		Labor Rates:
2. Familiarize with regulatory requirements d	2	1	2	59	118	5.9	11.8	$16,292.56		Management	$157.61
3. Required activities										Technical	$123.94
A. Initial performance tests c	8	1	8	0	0	0	0	$0		Clerical	$62.52
B. Engineering calculations c	8	1	8	0	0	0	0	$0
C. Continuous parameter monitoring e	0	0	0	0	0	0	0	$0
4. Reporting requirements
A. Initial notification that existing facilities are subject to the standard c	N/A
B. Notifications for new area sources
(1) Notification of intent to construct/reconstruct c	4	1	4	0	0	0	0	$0
(2) Notification of commencement of construction/reconstruction c	4	1	4	0	0	0	0	$0
(3) Notification of startup c	4	1	4	0	0	0	0	$0
C. Request for compliance extension f	4	1	4	0	0	0	0	$0
D. Notification of initial performance tests c	2	1	2	0	0	0	0	$0
E. Notification of compliance status c	2	1	2	0	0	0	0	$0
F. Gather information for semi-annual reports	4	2	8	59	472	23.6	47.2	$65,170.22
G. Semiannual compliance reports	4	2	8	59	472	23.6	47.2	$65,170.22
Subtotal for Reporting Requirements					1,221			$146,633
5. Recordkeeping requirements
A. Plan activities c	4	1	4	0	0	0	0	$0
B. Implement activities
(1) Record performance tests c	1	1	1	0	0	0	0	$0
(2) Record malfunctions	0.5	2	1	59	59	2.95	5.9	$8,146.28
(3) Continuous parameter monitoring calibration and maintenance	1	12	12	59	708	35.4	70.8	$97,755.33
C. Store, file, and maintain records	4	1	4	59	236	11.8	23.6	$32,585.11
Subtotal for Recordkeeping Requirements					1,153			$138,487		118	responses
Total Labor Burden and Cost (rounded) g					2,370			$285,000		20	hrs/response
Total Capital and O&M Cost (rounded) g								$885
Grand TOTAL (rounded) g								$286,000
Assumptions:
a We have assumed that there are 59 existing sources that are subject to the rule, and that no new area sources per year will become subject over the 3 year-period of this ICR.
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This burden item is a one-time activity that applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
d This ICR assumes all respondents will take 2 hours to familiarize with the regulatory requirements.
e There is no additional burden for monitoring equipment because add-on control devices are not expected to be needed to demonstrate compliance with emission limits and facilities are already equipped with equipment to monitor process and existing control device parameters.
f We have assumed that compliance extensions will not be necessary during the three-year period of this ICR.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal)
Burden Item	(A) EPA hours per occurrence	(B) No. of occurences per plant per year	(C) EPA hours per plant per year (C=AxB)	(D) Plants per yeara	(E) EPA technical hours per year (E=CxD)	(F) EPA managerial hours per year (F=Ex0.05)	(G) EPA clerical hours per year (G=Ex0.1)	(H) Total cost per year ($)b
1. Read and understand rule requirements c	2	1	2	0	0	0	0	$0		Labor Rates:
2. Required activities										Management	$70.56
A. Observe initial performance tests c	8	1	8	0	0	0	0	$0		Technical	$52.37
B. Review initial performance test reports, engineering calculations, and operating parameters c	4	1	4	0	0	0	0	$0		Clerical	$28.34
C. Enter and update information into agency recordkeeping system c	1	1	1	0	0	0	0	$0
3. Excess emissions - enforcement activities d	N/A
4. Notification requirements
A. Review initial notification that existing facilities are subject to the standard c	1	1	1	0	0	0	0	$0
B. Notifications for new area sources
(1) Review notification of intent to construct/reconstruct c	4	1	4	0	0	0	0	$0
(2) Review notification of commencement of construction/reconstruction c	2	1	2	0	0	0	0	$0
(3) Review notification of startup c	2	1	2	0	0	0	0	$0
C. Review request for compliance extension e	2	1	2	0	0	0	0	$0
D. Review notification of initial performance tests c	1	1	1	0	0	0	0	$0
E. Review notification of compliance status c	4	1	4	0	0	0	0	$0
5. Review semiannual compliance reports f	4	2	8	15	120	6	12	$7,048
TOTAL (rounded) g					138			$7,050
Assumptions:
a We have assumed that there are 59 existing sources that are subject to the rule, and that no new area sources per year will become subject over the 3 year-period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for the benefit packages available to government employees: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.17 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
c This burden item is a one-time activity that applies to new facilities only. No new facilities are expected over the three-year period of this ICR.
d We have assumed that no enforcement activities will be conducted over the three-year period of this ICR.
e We have assumed that compliance extensions will not be necessary during the three-year period of this ICR.
f We have assumed that EPA technical personnel will review 25% of the semiannual compliance reports.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

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 b	Total O&M, (E X F)
Pressure drop monitoring systems a	$144	0	$0	NA	NA	NA
Performance test b	$6,000	0	$0	NA	NA	NA
Photocopying and postage c	NA	NA	NA	$15	59	$885
Total			$0			$885		$885
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
a The capital cost associated with pressure drop monitoring systems were estimated based on equipment vendor costs annualized over a 10-year period using an interest rate of 7 percent to obtain a capital recovery cost of 0.1424.
b Assumes initial performance tests are conducted by an emissions testing contractor at a cost of $6,000 per piece of process equipment or PM control device.
c Costs for photocopying and mailing semi-annual reports (assumed to be $7.50 per report)

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Semiannual compliance report	59	2	0	118
			Total	118

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Sheet 6: Respondents

Number of Respondents
Respondents That Submit Reports			Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	59	0	0	59
2	0	59	0	0	59
3	0	59	0	0	59
Average	0	59	0	0	59
a New respondents include sources with constructed and reconstructed affected facilities.