1

**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for Hot Mix Asphalt Facilities (40 CFR**  **P art 60,**  **S ubpart I)**  **(Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NSPS for Hot Mix Asphalt Facilities (40 CFR p art 60, s ubpart I) (Renewal) , EPA I CR 1127. 10 , OMB Control Number 2060

- 0083

. **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Hot Mix Asphalt Facilities ( 40 CFR part 60, subpart I ) were proposed on June 11, 1973, promulgated on July 25, 1977 , and amended on February

14, 1989 (54 FR 6667) . These regulations apply to hot mix asphalt facilities comprised only

of a combination of the following: dryers; sy stems for screening, handling , storing, and weighing hot aggregate; sy stems for loading, transferring, and storing mineral filler; s ys tems for mixing hot mix asphalt; and the loading, transfer, and storage s ys tems associated with emission control sy stems. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 60, subpart I

. In general, all NSPS standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS

. Any owner / operator subject to the provisions of this part wil l maintain a file of these records, and retain the file for at least two years following the date of such measurements, maintenance reports, and records . All reports are sent to the delegated state or local authority

. In the event that there is no suc h delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 4, 325 respondents per ye ar will be subject to the standard, and an additional 105 respondents per year will become subject to the standard. In addition, we are expecting on average 140 of the existing facilities would be conducting modifications of their facilities, such that they will be required to comply with the initial rule requirements. Thi s information was gathered through consultation with the National Asphalt Pavement Association and the Asphalt Pavement Alliance during a previous renewal

.2

All of the hot mix asphalt facilities in the United States are owned and operated b y the H ot M ix A sphalt industry

( the “Affected Public” ) , which is a privatel y- owned , for

- profit business. None of these facilities in the United States are owned b y state, local, tribal or the Federal government. The burden to the “Affected Public” is listed below in Table 1: Annual Respondent Burden and Cost : NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal). The burden to the “Federal Government” is attributed entirel y to work performed by federal employees or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden and Cost : NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal). The Office of Management and Budget (OMB) approved the current Information Collection Request (I CR) without any “Terms of Clearance.”
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirement s) the Administrator determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revis e such standards every four years. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any

requirement of this Act to: Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) p rovide such other information as the Administrator may3 reasonabl y require. In the Administrator's judgment, particulate matter emissions from hot mix asphalt facilities cause or contribute to air pollution that may reasonabl y be anticipated to endanger pu blic health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart I. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applica ble regulations that were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test, a record of the operating parameters under which compliance was achieved m ay be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations . The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated, leaks are being detected and repaired, and the standard is being met. The performance test may also be observed. The required semiannual compliance certifications are used to determine periods of excess emissions, identify

problems at the facility , verify operation and maintenance procedures and for compliance determinations.
**3. Non**
**- duplication, Consultations, and**  **Other Collection Criteria** The requested recordkeeping and reporting are required under 40 CFR part 60, subpart I. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional o ffice. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency ca n be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in4

the Federal Register (7 6 FR 26900 ) on May 9 , 20 11 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously

reviewed to determine the minimum information needed for compliance purposes. In the development of this I CR, EPA consulted the National Asphalt Pavement Association at ( 301) 731

- 4748 , and the Asphalt Pavement Alliance at ( 301) 731

- 4748. No comments were received. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were rec eived. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techni ques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the poss ibility of detecting violations would be less likely

. **3(e) General Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5

. **3(f) Confidentiality** Any infor mation submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** The reporting or recordkeeping requirements in the standard do not include sensitive questions.5

**4. The Respondents and the Information Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are hot mix asphalt facilities. The SI C code for the respondents affected by the standards is United States Standard Industrial Classification (SI C ) 2951 , which corresponds to the North American Industry Classification System (NAI CS ) 324121 for hot mix asphalt facilities. **4(b) Information Requested (i) Data Items**  In this ICR, all the data that is recorded or reported is required b y NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I). A source must make the following reports: **Notification Reports** Notification of construction or reconstruction 40 CFR 60.7(a)(1) Notification of actual date of initial startup 40 CFR 60.7(a)(3) Notification of ph ys ical or operational change 40 CFR 60.7(a)(4) Notification of performance test 40 CFR 60.8(d) **Reports** Report of performance tests 40 CFR 60.8(a) A source must maintain the following records: **Recordkeeping** Record of startups, shutdowns, and malfunctions 60.7(b) Records are required to be retained for two ye ars 60.7(f)

Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must evaluate the data, internal6

automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Al so , regulatory

agencies, in cooperation with the respondents, continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 perce nt of the respondents use electronic reporting. **(ii) Respondent Activities** Respondents must conduct the following activities: **Respondent Activities** Read instructions Perform initial performance test, Reference Methods 5 for particulate matter and Method 9 to determine opacity , and repeat performance tests if necessary Write the notifications and reports listed above Enter information required to be recorded above Submit the required reports developing, acquiring, installing, and utilizing technology and s ys tems for the purpose of collecting, validating, and verifying information Developing, acquiring, installing, and utilizing technology and s ys tems for the purpose of processing and maintaining information Developing, acquiring, installin g, and utilizing technology and s ys tems for the purpose of disclosing and providing information Adjust the existing way s to comply with an y previously applicable instructions and requirements Training personnel to be able to respond to a collection of in formation Transmitting, or otherwise disclosing the information **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information

.7 **Agency Activities** Observes initial performance tests and repeat performance tests if necessary Reviews notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry Audits facility

records Inputs and maintains data in the Online Tracking Information Sy stem ( OTIS ) **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comply

with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identificat ion, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA’s database for the collectio n, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/ope rator for two ye ars. **5(c) Small Entity Flexibility** The majority

of the resp ondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process opera tions and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot re duce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in Table 1 : Annual Respondent Burden and Cost : NSPS for Hot Mix Asphalt Facilities (408

CFR Part 60, Subpart I) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR . The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden unde r the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified in the burden calculations. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** Over the next three ye ars, the average annual burden to industry for these recordkeeping and reporting requi r ements is estimated to be 18, 284 hours (Total Labor Hours from Table 1 ). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NSPS , the previously approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%) These rate s are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2. Civilian Workers, by O ccupational and Industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Cost** s The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital/startup or operation and maintenance costs.9 **(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only type of industry costs associated with the information collection activity in the regulations is labor costs. There are no capital/startup or operation and maintenance costs. **6(c) Estimating Agency Burden and Cost** s The only costs to the Agency are those associated with analy sis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents , periodic inspection of sources of emissions, and the pu

blication and distribution of collected information

. The average annual Agency cost during the three years of the ICR is estimated to be $188,641. This cost is based on the average hourl y labor rate as follows: Managerial $6 2.27 (GS

- 13, Step 5, $38. 92 + 60%) Technical $4 6

. 21 (GS

- 12, Step 1, $28. 88 + 60%) Clerical $2 5.01 (GS

- 6, Step 3, $15. 63 + 60%) These rates are from the Office of Personnel Management (OPM), 2011 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
. Details upon which this estimate is based appear below in Table 2: Average EPA Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 4, 220 existing respondents will be subject to th e standard. It is estimated that an additional 105 respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below is 4, 325 per year. The number of respondents is calculated using the following table th at addresses the three ye ars covered b y this ICR.10 **Number of Respondents Respondents That Submit**  **Reports Respondents That** 

**Do Not Submit Any Reports** 

**Year (A)** 

**Number of New**  **Respondents 1**  **(B)**

**Number of Existing**  **Respondents (C)** 

**Number of Existing Respondents That**  **Keep Records but Do Not Submit**  **Reports (D)** 

**Number of Existing**  **Respondents That Are Also New**  **Respondents (E)** 

**Number of Respondents**  **(E=A+B+C**
**- D)** 

1 245 0 4, 115 140 4, 220 2 245 0 4, 220 140 4, 325 3 245 0 4, 325 140 4, 430 Average 245 0 4, 220 140 4, 325

1 New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard, existing respondents that conduct operational changes submit initial notifications and conduct performance tests. Column D is subtracted to avoid double

- counting respondents. As shown above, the average number of respondents over the three

- ye ar period of this ICR is 4, 325

. The total number of annual responses per ye ar is calculated using the following table:
**Total Annual Responses**  **(A) Inform**  **ation Collection Activity (B)**  **Number of Respondents**  **(C)**

**Number of Responses**  **(D)**

**Number of Existing Respondents That Keep**  **Records But Do Not Submit Reports**  **(E) Total**  **Annual Responses**  **E=(BxC)+D** Notification of initial startup 105 1 105 Notification of contraction/reconstruction 105 1 105 Notification of operational change 140 1 140 Notification of performance test 245 1.2 294 Performance test reports 245 1.2 294 Recordkeeping 4, 220 4, 220 Total 5, 158 The number of Total Annual Responses is 5, 158

. The total annual labor costs are $ 1,751,943 . Details regarding these estimates may be found below below in Table 1 : Annual Respondent Burden and Cost : NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the11

Agency are shown in Tables 1 and 2 (below), respectivel y, and summarized below. **(i) Respondent T ally**  The total annual labor hours are 18, 284

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost : NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 4 hours per response
. There are no capital/startup or operation and maintenance costs

. **(ii) The Agency Tally**  The average annual Agency burden and cost over next three years is estimated to be 4,186 labor hours at a cost of $188,641 . See below Table 2 : Average Annual EPA Burden and Cost : NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)

. **6(f) Reasons for Change in Burden**  There is an increase in burden hours to the respondent in this I CR as compared to the most recentl y approved ICR. The increase is due to industry growth in the past three ye ars, resulting in additional number of respo ndents that are subject to this standard. In addition, there is an increase in burden costs to both the respondent and the Agency due to an adjustment in labor rates. This ICR uses the most recent labor rates from the Bureau of Labor Statistics in calcul ating the labor costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 4 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquir e, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with an y previously

a pplicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the A gency's need for this information, the accuracy of the provided12

burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docke t ID Number EPA

–HQ

–OECA

–2011

– 0241

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a cop y of the draft collection of information, submit or view public comments, access the index listing o f the contents of the docket, and to access those documents in the public docket that are available electronicall y. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for pu blic viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 1 752 . Also, you can send comments to the Office of Information and Regulatory Affai rs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

–HQ

–OECA

– 2011

– 0241 and OMB Control Number 2060

– 0083 in any correspondence. **Part B of the Supportin g Statement**  This part is not applicable because no statistical methods were used in collecting this information.13

**Table 1 :**  **Annual Respondent Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part**  **60, Subpart I) (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)**

**Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

**Clerical person**  **- hours**  **per year (Ex0.1)**  **(H)**

**Cost, $ (b)**

1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, and Utilization of Technology and Systems N/A 4. Reporting Requirements A. Read instructions 1 1 1 245 245 12.25 24.5 $26,997. 03 B. Required activities: i. Initial p erformance tests c 24 1 24 245 5 , 880 294 588 $647, 928.96 ii. Repeat p erformance tests c 24 0.2 4.8 245 1 , 176 58.8 117.6 $129, 585

. 80 iii. Reference Method 9 4 1 4 245 980 49 98 $107, 988

. 16 iii. Monitoring of operations and equipment Included in 5E C. Gather e xisting i nformation Included in 4B and 5E D. Write report a, c i. Notification of actual startup date 2 1 2 105 210 10.5 21 $23,140. 32 ii. Notification of construction/ reconstruction 2 1 2 105 210 10.5 21 $23,140. 32 iii. Notification of physical or operational change 2 1 2. 140 280 14 28 $30, 853

. 76
iii. Notification of p erformance t est c 2 1.2 2.4 245 588 29.4 58.8 $64, 792

. 90 iv. Reports of performance test results Included in 4B14
**Table 1 :**  **Annual Respondent Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part**  **60, Subpart I) (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)**

**Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

**Clerical person**  **- hours**  **per year (Ex0.1)**  **(H)**

**Cost, $ (b)**

v. Periodic reports d N/A SUBTOTAL Reporting 11,004 .35 5. Recordkeeping Requirements A. Read instructions Included in 4A B. Plan activities Included in 4B C. Implement activities Included in 4B D. Develop record system N/A E. Time to enter and transmit information e 1.5 1 1.5 4, 220 6, 330 3 16.5 633 $ 697 , 515

. 36 F. Time to train personnel N/A G. Time for audits N/A SUBTOTAL Recordkeeping 7, 279.5 TO TAL LABOR BURDEN AND COST (Rounded) 18, 283.85 18,284 (rounded) $1, 751, 94 3

**Assu mptions:**  a We have determined that approximately 95 percent of existing hot mix asphalt facilities in the United States are currently su bject to NSPS subpart I. In addition, we are expecting an average net grow th of 105 facilities per year for this sector and that an average of 140 existing facilities wo uld be conducting modifications of their facilities

. b This ICR uses the following labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 19, 2 005, “ Table 2. C ivilian Workers, by Occupational and I ndustry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.15

c We have assumed that a total of 245 new and modified hot mix asphalt facilities would be required to submit notification and conduct a performance test. We have further assumed that about 20 percent of the sources would repeat performance tests due to f ailure. d The rule does not require existing sources to submit periodic reports. e We have assumed that recordkeeping would take sources an average of 1.5 hours a year.16

**Table 2 :**  **Average Annual**  **EPA Burden**  **and Cost : NSPS**  **for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)** 

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**
  ** hours per** **plant per year**  **(C=AxB) (D) Plants** 

**Per Year a, c**  **(E)**

**Technical person**  **- hours**  **per year (E=CxD)**  **(F)**

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G) Clerical** 

**person -**  **hours per year**  **(Ex0.10) (H)** 

**Cost, $ b**

Notific ation of actual startup date 2 1 2 105 210 10.5 21 $10, 88 3

. 14 Notification of construction/ reconstruction 2 1 2 105 210 01.5 21 $10,883.14 N otification of physical or operational change 2 1 2 140 280 14 28 $14,510. 86 Notification of p erformance t est 2 1.2 2.4 245 588 29.4 58.8 $30, 47 2

. 81 Reports of performance test results c 8 1.2 9.6 245 2,352 117.6 235.2 $121, 8 91

. 2 2 Periodic reports d N/A Subtotal Burden and Cost 3,640 182 364 $188, 6 41

. 17 TO TAL ANNUAL BURDEN AND COST (rounded) 4,186 $188,64 1

**Assu mptions:**  a We have determined that approximately 95 percent of existing hot mix asphalt facilities in the United States are currently su bject to NSPS subpart I. In addition, we are expecting an average net growth of 105 facilities per year for this sector and that 1 40 of the existing facilities would be conducting mo difications of their facilities

. b This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rat e of $ 62.27 (GS

- 13, Step 5, $ 38.92 x 1.6), Technical rate of $ 46.21 (GS

- 12, Step 1, $ 28.88 x 1.6), and Clerical rate of $ 25.01 (GS

- 6, Step 3, $ 15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “ 2011 General Schedule ” which exclu des locality rates of pay. c The 245 new

and modified hot mix asphalt facilities would be required to submit notifications and perform performance tests. d The rule does not require sources to submit periodic reports.