SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I) (Renewal), EPA ICR Number 

1127.11, OMB Control Number 2060-0083.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Hot Mix Asphalt Facilities were 

proposed on June 11, 1973, promulgated on July 25, 1977, and most recently amended on 

February 14, 1989. These regulations apply to hot mix asphalt facilities that commenced 

construction or modification after June 11, 1973. A hot mix asphalt facility is comprised only of 

any combination of the following: dryers; systems for screening, handling, storing, and weighing 

hot aggregate; systems for loading, transferring, and storing mineral filler; systems for mixing 

hot mix asphalt; and the loading, transfer, and storage systems associated with emission control 

systems. 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 system 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 shall maintain a file of these 

measurements, 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 such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 4,535 respondents per year will be subject to the 

standard, and 105 additional respondents per year will become subject to the standard. In

addition, we expect 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. 

This information was gathered through consultation with the National Asphalt Pavement 

Association and the Asphalt Pavement Alliance during a previous renewal.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any ”Terms of Clearance.” 
2

All of the hot mix asphalt facilities in the United States are owned and operated by the 

Hot Mix Asphalt industry (the “Affected Public”), which is a privately-owned, for-profit 

business. None of these facilities in the United States are owned by state, local, tribal or the 

Federal government. The burden to the “Affected Public” may be found in Table 1: Annual 

Respondent Burden and Cost – NSPS for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I)

(Renewal). The “Federal Government” burden is attributed entirely to work performed by 

federal employees or government contractors and may be found in Table 2: Average Annual 

EPA Burden and Cost – NSPS for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I)

(Renewal). 

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 system 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 requirements) the 

Administrator determines has been adequately 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, revise 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: 

(A) 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) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, particulate matter emissions from hot mix asphalt 

facilities cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 
3

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

applicable regulations which 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 may 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 properly 

installed and operated, leaks are being detected and repaired, and the standard are being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 60, Subpart I.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly 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 copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by 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 ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations
4

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted both the National Asphalt Pavement Association at (301) 731-4748, and 

the Asphalt Pavement Alliance at (303) 918-8391.

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.

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 techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

3(f) Confidentiality

Any information 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 (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 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.

4. The Respondents and the Information Requested
5

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are hot mix asphalt 

facilities. The United States Standard Industrial Classification (SIC) code for the respondents 

affected by the standards is SIC 2951, which corresponds to the North American Industry

Classification System (NAICS) 324121 for Asphalt Paving Mixture and Block Manufacturing.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Hot Mix 

Asphalt Facilities (40 CFR Part 60, Subpart I).

A source must make the following reports:

Notifications

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 physical 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 keep the following records:

Recordkeeping

Record of startups, shutdowns, and malfunctions 60.7(b)

Records are required to be retained for two years 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 still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

(ii) Respondent Activities
6

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

Perform initial performance test, Reference Method 5 and 9 tests, 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 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose 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, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO.
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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 properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard, and note the operating conditions under which compliance was 

achieved. 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 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by 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 by this regulation must be retained by the owner/operator for two 

years.

5(c) Small Entity Flexibility

A majority of the respondents 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 operations 

and the types 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 reduce 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 in below Table 1: Annual Respondent Burden and Cost – NSPS for Hot Mix Asphalt 

Facilities (40 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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 
8

major assumptions have been identified. 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

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 18,827 (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 program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “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.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs.

(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

The only costs to the Agency are those costs associated with analysis 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 publication and distribution of collected information. 
9

The average annual Agency cost during the three years of the ICR is estimated to be 

$191,000. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 Annual 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 ICR, on average over the next three years, approximately

4,535 existing respondents will be subject to the standard. It is estimated that an additional 105

respondents per year will become subject. Further, 140 existing facilities will conduct 

modifications and become subject to the initial requirements of the standard. The overall 

average number of respondents, as shown in the table below, is 4,640 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

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 4,430 140 4,535

2

245 0 4,535 140 4,640

3

245 0 4,640 140 4,745

Average 245 0 4,535 140 4,640

1

New respondents include sources with constructed, reconstructed and modified affected facilities. In this standard, 

existing respondents that conduct operational changes submit notifications of operational changes and conduct 
10

performance tests.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 4,640. 

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information 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 

construction/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 4,535 4,535

Total 5,473

The number of Total Annual Responses is 5,473. 

The total annual labor costs are $1,893,000. 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).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 19,000. Details regarding these estimates may be found 

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 3 hours per response.
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The total annual capital/startup and O&M costs to the regulated entity are $0. The cost 

calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10%% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

(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 $191,000. See Table 2: Average Annual EPA Burden and Cost –

NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10%% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the estimated burden as currently identified in the 

OMB Inventory of Approved Burdens. The increase is not due to any program changes. The 

change in burden occurred because the number of respondents subject to the standard has 

increased since the last ICR renewal period. In addition, the use of more updated labor rates 

results in an increase in total labor costs. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 3 hours per response. Burden means the total time, effort, or financial 

resources expended by 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, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable 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.
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To comment on the Agency's need for this information, the accuracy of the provided 

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 ICR under 

Docket ID Number EPA-HQ-OECA-2014-0040. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, 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-2014-0040 and OMB Control Number 2060-0083 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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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) 

Personhours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

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 $28,333.15 

 B. Required activities:

 i. Initial performance tests c  24 1 24 245 5,880 294 588 $679,995.54 

 ii. Repeat performance tests c 24 1 24 49 1,176 58.8 117.6 $135,999.11 

 iii. Reference Method 9 4 1 4 245 980 49 98 $113,332.59 

 iii. Monitoring of operations and 

equipment See 5E

C. Gather existing information See 4B and 5E

D. Write report a, c

 i. Notification of actual startup date 2 1 2 105 210 10.5 21 $24,285.56 

 ii. Notification of construction/ 

reconstruction 2 1 2 105 210 10.5 21 $24,285.56 

 iii. Notification of physical or 

operational change 2 1 2 140 280 14 28 $32,380.74 

 iii. Notification of performance test c

2 1.2 2.4 245 588 29.4 58.8 $67,999.55 
14

Burden item

(A)

Person-hours 

per 

occurrence

(B)

No. Of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G)

Clerical 

person-hours 

per year 

(Ex0.1)

(H)

Cost, $ b

 iv. Reports of performance test results See 4B

 v. Periodic reports d N/A

SUBTOTAL Reporting 11,004 $1,106,611.79

5. Recordkeeping Requirements

A. Read instructions See 4A

B. Plan activities See 4B

C. Implement activities See 4B

D. Develop record system N/A

E. Time to enter and transmit information 

e 1.5 1 1.5 4,535 6,802.5 340.13 680.25 $786,678.51 

F. Time to train personnel N/A

G. Time for audits N/A

SUBTOTAL Recordkeeping 7,823 $786,678.51

TOTAL LABOR BURDEN AND COST 

(Rounded) 18,827 $1,893,290 

Capital and O&M Costs $0

Grand Total (Labor Cost + Capital/O&M) $1,893,290

Assumptions:

a

 We have determined that approximately 95 percent of existing hot mix asphalt facilities in the United States are currently subject to NSPS subpart I. In addition, we 

are expecting an average net growth of 105 facilities per year for this sector and that an average of 140 existing facilities would be conducting modifications of their 

facilities. 
15

b

 This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per 

hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by 

Occupational and Industry 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.

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 failure. 

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. 

NOTE: Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.
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Table 2: Average Annual EPA Burden and Cost – NSPS for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year 

(C=AxB)

(D) 

Plants 

Per Year 

a, c

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year 

(Ex0.10)

(H)

Cost, $ b

Notification of actual startup date 2 1 2 105 210 10.5 21 $10,991.40 

Notification of construction/ reconstruction 2 1 2 105 210 10.5 21 $10,991.40 

Notification of physical or operational change 2 1 2 140 280 14 28 $14,655.20 

Notification of performance test 2 1.2 2.4 245 588 29.4 58.8 $30,775.92 

Reports of performance test results c

8 1.2 9.6 245 2,352 117.6 235.2 $123,103.68 

Periodic reports d N/A

TOTAL ANNUAL BURDEN AND COST 4,186 $190,517.60 

(rounded) 4,186 $190,518 

Assumptions:

a We have determined that approximately 95 percent of existing hot mix asphalt facilities in the United States are currently subject to NSPS subpart I. In 

addition, we are expecting an average net growth of 105 facilities per year for this sector and that 140 of the existing facilities would be conducting 

modifications of their facilities. 

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 

Managerial rate of $62.90 (GS-13, Step 5, $39.31 + 60%), Technical rate of $46.67 (GS-12, Step 1, $29.17 + 60%), and Clerical rate of $25.25 (GS-6, Step 3, 

$15.78 + 60%). These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes 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.