Burden Calculations Table

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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	114
Number of Respondents	144
Total Estimated Burden Hours	34,100
Total Estimated Costs	$11,700,000
Annualized Capital O&M	$7,430,000
Total Annual Responses	300
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Reporting requirements										Labor Rates
A. Familiarization with regulatory requirements c	1	1	1	144	144	7.2	14.4	$20,881.37		Managerial	$163.17
B. Required activities										Technical	$130.28
Initial performance tests d	72	1	72	2	144	7.2	14.4	$20,881.37		Clerical	$65.71
Repeat of performance test d, e	72	1	72	0.4	28.8	1.44	2.88	$4,176.27
C. Create Information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/ reconstruction f	2	1	2	2	4	0.2	0.4	$580.04
Notification and demonstration of CMS g	40	1	40	2	80	4	8	$11,600.76
Notification of actual startup	2	1	2	2	4	0.2	0.4	$580.04
Notification of initial performance test	2	1	2	2	4	0.2	0.4	$580.04
Report of performance test	See 3B
Notification of physical or operational change h	2	1	2	2	4	0.2	0.4	$580.04
Semiannual reports	24	2	48	144	6,912	345.6	691.2	$1,002,305.66
Subtotal for Reporting Requirements					8,424			$1,062,166
4. Recordkeeping requirements
A. Familiarize with the regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of daily production rate and hours of operation i	0.13	250	32.5	144	4680	234	468	$678,644.46
Records of operating parameters of CMS j	0.25	250	62.5	144	9000	450	900	$1,305,085.50
Records of startup, shutdown, and malfunctions k	60	1	60	144	8640	432	864	$1,252,882.08
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					25,668			$3,236,612		114	hr/response
Total Labor Burden and Costs (rounded) i					34,100			$4,300,000
Total Capital and O&M Cost (rounded) i								$7,430,000
GRAND TOTAL (rounded) i								$11,700,000
Assumptions:
a We have assumed that the average number of respondents that are subject to the regulation will be 144, with two sources undergoing reconstruction per year over the three-year period of this ICR.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 We have assumed that all existing respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take 72 hours for each respondent to perform the initial performance test.
e We have assumed that 20 percent of respondents will fail the performance test and will have to repeat it.
f We have assumed that each respondent will take two hours to write the notification of construction/reconstruction report.
g We have assumed that each respondent will take 40 hours to write the notification and demonstration of CMS report.
h We have assumed that each respondent will take 2 hours to write the notification of physical or operational change.
i We have assumed that each respondent will enter information of daily production rate and hours of operation 250 times per year.
j We have assumed that each respondent will take 15 minutes 250 times per year to record the operating parameters of CMS.
k We have assumed that each respondent will take 60 hours to record startup, shutdown, and malfunction information.
l 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 – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU) (Renewal)
Activity	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
Performance tests										Labor Rates
New or modified facility c	24	1	24	2	48	2.4	4.8	$2,934.49		Management	$73.46
Repeat performance test										Technical	$54.51
New or modified facility d	24	1	24	0.4	9.6	0.48	0.96	$586.90		Clerical	$29.50
Report review
Notification of construction/reconstruction e	2	1	2	2	4	0.2	0.4	$244.54
Notification of physical/operational changes f	2	1	2	2	4	0.2	0.4	$244.54
Notification of actual startup	0.5	1	0.5	2	1	0.05	0.1	$61.14
Notification of performance test	0.5	1	0.5	2	1	0.05	0.1	$61.14
Review of performance test results g	8	1	8	2	16	0.8	1.6	$978.16
Notification of demonstration of CMS	0.5	1	0.5	2	1	0.05	0.1	$61.14
Semiannual reports	8	2	16	144	2304	115.2	230	$140,855.50
TOTAL (rounded) h					2,750			$146,000
Assumptions:
a We have assumed that the average number of respondents will be 144 with two sources undergoing reconstruction per year over the three-year period of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 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), 2023 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 We have assumed that it will take the agency 24 hours to review performance tests.
d We have assumed that 20 percent of respondents will fail the performance test and will have to repeat it.
e We have assumed that it will take the agency two hours one-time per year to review notification of construction/reconstruction report.
f We have assumed that it will take the agency two hours one-time per year to review notification of physical/operation changes.
g We have assumed that it will take the agency eight hours one-time per year to review the performance test results report.
h 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	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)				2008 Average CEPCI	2022 CEPCI
Temperature Monitors a	$141,814	2	$283,629	$49,635	144	$7,147,445				575.4	816
Totals (rounded) b			$284,000			$7,150,000		$7,434,000
a Costs have been increased from 2008 to 2022 $ using the CEPCI Equipment Cost Index.
b Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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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
Notification and application of construction/reconstruction	2	1	0	2
Notification of actual startup	2	1	0	2
Notification of physical or operational change which may increase the emission rate	2	1	0	2
Notification of demonstration of continuous monitoring system	2	1	0	2
Notification of initial performance test	2	1	0	2
Report of initial performance test	2	1	0	2
Semiannual report	144	2	0	288
			Total	300

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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	2	144	0	2	144
2	2	144	0	2	144
3	2	144	0	2	144
Average	2	144	0	0	144
a New respondents include sources with constructed and reconstructed affected facilities.