**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Area Sources:**  **Asphalt Processing and Asphalt Roofing Manufacturing (40**  **CFR Part 63, Subpart AAAAAAA)**  **(Renewal**) **1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal), EPA ICR Number 2352.03 , OMB Control Number 2060

- 0634 **1(b) Short Characterization/Abstract** The National Emi ssion Standards for Hazardous Air Pollutants (NESHAP) for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR part 63, subpart AAAAAAA) were proposed on July 9, 2009 , and promulgated on December 2, 2009 . These regulations appl y to existing facilities and new facilities that are area source s and that process asphalt or manufacture asphalt roofing products . New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This infor mation is being collected to assure compliance with 40 CFR part 63 , subpart AAAAAAA

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

the owners/operato rs 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 sy stem is inoperative. These notifications, reports, and records are ess ential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years followin g 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 directl y to the U

. S

. Environmental Protectio n Agency (EPA) regional office. Over the next three ye ars, an average of 75 respondents per ye ar will be subject to the standard , and no additional respondents per year will become subject to the standard. The Office of Management and Budget ( OMB ) approved the currentl y active ICR without any

Terms of Clearance. The burden to the “Affected Public” may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal)

. The burden to the “Federal Government” is attributed entirely to work performed by either F ederal employees or2

government contractor s , and may be found below in 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)

. **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, 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, us e, 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 reasonabl y require. In the Administrator's judgment, hazardous air pollutants (HAP) emissions from asphalt processing or from asphalt roofing products manufacturing cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63 , subpart AAAAAAA. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where 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. 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 information3

obtained under the testing, monitoring, recordkeeping, and repor ting will be used by EPA to: (1) identify

existing and new HAP emission points subject to the NESHAP; (2) ensure that GACT is being properl y applied; and (3) ensure that add

- on control devices are being properl y operated and maintained on a continuous ba sis to reduce HAP emissions from blowing stills, saturators, wet loopers , coating mixers, and coaters. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance proc edures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are re quired under 40 CFR part 63, subpart AAAAAAA

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. 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 can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **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 in the Federal Register ( 77 FR 47631 ) on August 9, 2012 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary

source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS), which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the co llection, maintenance, and retrieval of all compliance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply . In developing this I CR, EPA contacted : 1) the Asphalt Roofing Manufacturers Association , at (202) 591

- 2450 ; an d 2) the Asphalt Institute at ( 859 ) 288

- 4960

.4

It is our policy

to respond after a thorough review of comments received since the last I CR 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. I f 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 b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statut e of limitations on which the permit program is based. The retention of records for five ye ars allows EPA to establish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA ha s found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **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 (CBI) (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**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are owners or operators5

of HAP emitting area sources in the asphalt processing and asphalt roofing manufacturing industry . The United States Standard Industrial Classification (SI C) codes and associated North American Industry

Classification System (NAICS) codes for the respondents affected by the standards are listed in the following table.

**Standard (40 CFR Part**  **63, Subpart AAAAAAA) SIC Codes**  **NAICS Codes** Asphalt Shingle and Coating Materials Manufacturing 2952 324122 Petroleum Refineries 2911 324110 **4(b) Information Requested**  **(i) Data Items** In this ICR , all the data that is recorded or reported is required b y the NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR P art 63 , S ubpart AAAAAAA). A source must make the following reports:

**Notification s**  Initial notification 63.9(b)(2), 63.9(b)(4), 63.9(b) (5) Notification of compliance test 63.11564(a)(4) Notification of initial performance test 63.7(b) (1) , 63.9(b), 63.9(e) , 63.10(d)(2) Notification of performance evaluation 63.8(e)(2), 63.9(g)(1) Notification of compliance status 63.9(h), 63.11564(a)(5)

**Reports** Semiannual compliance reports 63.11564(b)6

A source must keep the following records: **Recordkeeping** Records of submitted reports, notifications, and plans 63.11564(c)(1), 63.11564(c)(8), 63.11564(c)(9), 63.10(b)(2)(xiv),
Records of emission tests used to demonstrate compliance or for performance evaluations 63.7(g), 63.11564(c)(2), 63.11564(c)(3), 63.11564(c)(6), 63.10(b)(2)(vii)

- (xii) 63.11564(c)(10), Records of continuous parameter monitoring s ys tem (CPMS) operating parameters and values 63.11564(c)(4), 63.11564(c)(5), 63.11564(c)(7), 63.10(c)(1)

- (14) 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. Also, regulatory

agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate a C P MS for opacity . Perform initial performance test and repeat performance tests if necessary

.7 **Respondent Activities** 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 purpo se 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. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **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, anal yz e, and maintain data in the Online Tracking Information System (OTI S). **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 properl y installed and operated.8

Performance test reports are used b y the Agency to discern a source ’ s initial capab ility 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. In formation contained in the reports is entered into OTI S which is operated and maintained by

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

- owned fa cilities. 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/operator for five ye ars. **5(c) Small Entity Flexibility** Approximately

47 percent of the area source facilities that would be covered by the standards are considered to be small entities (i.e., small businesses )

. Due to the high percentage of companies that are small businesses, it is likely that some small businesses will be affected by this NESHAP. However, the impact on small entities was taken into consideration during the development of the regulation. W e have limited the testing, monitoring, recordkeeping, and reporting requirements for all facilities, including those owned b y small businesses, to the minimum necessary

to ensure compliance. Additionally , i t is estimated that no companies will incur compliance costs in excess of 1 percent of sales. Therefore, the final NESHAP will not have a significant impact on small businesses. 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 neede d 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 below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (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. The9

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 major assumptions have been identified. Responses to this information collecti on 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 ind ustry over the next three years from these recordkeeping and reporting requirement s is estimated to be 2,846 ( Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previousl y approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational 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 Costs** The ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) and other costs su ch as photocop ying and postage.10 **(iii) Capital/Startup vs. Operation and Maintenance (O&M) Cos ts**  **Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F) Pressure drop mo nitoring systems a $ 144 0 $0 NA NA NA
P erformance test b NA NA NA $6,000 0 $0 Photocopying and postage c NA NA NA $15 75 $1,125 **Total $0**  **$1,125**
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) The total capital/startup co sts for this I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 1,125

. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 1,125

. These are the recordkeeping costs

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is 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 emissi ons, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 7,877

. This cost is based on the average hourl y labor rate as follows:

Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% )11 Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 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

– NESHAP for Area Sources: Asphalt P rocessing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (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 75 existing respondents will be subject to the standard s . It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below , is 75 per ye ar. The number of respondents is cal culated using the following table that addresses the three ye ars covered b y this ICR. **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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 0 75 0 0 75 2 0 75 0 0 75 3 0 75 0 0 75 Average 75 1 New respondent include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondent s submit initial notifications. C olumn D is subtracted to avoid double

- counting respondents

. As sh own above, the average Number of Respondents over the three ye ar period of this ICR is 75

.12

The total number of annual responses per ye ar 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

Semiannual compliance report 75 2 0 150 Total 150 The number of Total Annual Responses is 150. The total annual labor costs are $ 275,599

. Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 2,846 at a cost of $272,599

. Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart AAAAAAA) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of inf ormation is estimated to average 19 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 1,125

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 175 labor hours at a cost of $7,877 . See below 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).13

**6(f) Reasons for Cha nge in B**  **urden** There is an adjustment increase in labor costs for the respondents from the most recentl y approved ICR. This increase is not due to any program changes. The adjustment increase reflects a change in labor rates from the Bureau of Labor Statistics as this ICR uses updated labor rates for calculating all burden costs. However, there is an overall decrease in labor hours, capital/startup costs, O&M costs, and Agency costs as currently identified in the OMB Inventory of Approved Burdens. The decrease in burden and cost estimates occurred because the standard has been in effect for more than three ye ars and the requirements are different during initial compliance as compared to on

going compliance. The previous I CR reflected those burdens and costs associated with the initial activities for subject facilities. This includes purchasing monitoring equipment, c onducting performance tests and establishing recordkeeping systems. This ICR, by in large, reflects the on

going burden and costs for existing facilities. Activities for existing source include continuously monitoring of pollutants and the submission of semiannual reports. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 19 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, acquire, 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 ways to compl y 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 inform ation 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 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0496. 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 Public14

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding le gal holidays. 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 In formation 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

- 2012

- 0496 and OMB Control Number 2060

- 0634 in any correspondence. **Part B of the Supporting Statement** This part is not appli cable because no statistical methods were used in collecting this information.15

**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**  **B C**  **D E**  **F G**  **H Hours**  **per occurrence**  **No. of**

**occurrences per respondent**  **per year Hours** 

**per respondent**  **per year Respondents** 

**per year a**  **Technical**

**hours per year**  **Management**

**hours per year**  **Clerical**

**hours per year**  **Total costs**

**per year ($) b** 
**(C = A x B) (E = C x D)**  **(F = E x 0.05) (G = E x 0.10)**  1. Acquire and install recordkeeping technology and systems c 4 1 4 0 0 0 0 $0 2. Read and understand rule requirements c 2 1 2 0 0 0 0 $0 3. Required activities A. Initial performance tests c 8 1 8 0 0 0 0 $0 B. Engineering calculations c 8 1 8 0 0 0 0 $0 C. Continuous parameter monitoring d 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 e 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 75 600 30 60 $ 66,811.8 0 G. Semiannual compliance reports 4 2 8 75 600 30 60 $ 66,811.8 0 **Subtotal for Reporting**  **Requirements 1,380** 16

**Burden Item A**  **B C**  **D E**  **F G**  **H Hours**  **per occurrence**  **No. of**

**occurrences per respondent**  **per year Hours** 

**per respondent**  **per year Respondents** 

**per year a**  **Technical**

**hours per year**  **Management**

**hours per year**  **Clerical**

**hours per year**  **Total costs**

**per year ($) b** 
**(C = A x B) (E = C x D)**  **(F = E x 0.05) (G = E x 0.10)**  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 0.50 2 1 75 75 3.75 7.5 $8,351.48 (3) Continuous parameter monitoring calibration and maintenance 1 12 12 75 900 45 90 $100,217.70 C. Store, file, and maintain records 4 1 4 75 300 15 30 $33,405.90 **Subtotal for Recordkeeping**  **Requirements 1,466**  **TOTAL ANNUAL BURDEN (rounded)**  **2,846 $**  **275,599**
**Assu mptions:**  a. We have assumed that there are 75 existing sources that are subject to the rule, and that no new major sources per year will become subject over the 3 year

period of this ICR. b. This ICR uses the following labor rates: Technical $100.23 ($47.73 + 110%); Managerial $121.44 ($57.83+ 110%); and Clerical $ 50.51 ($24.05 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Tabl e 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c. This burden item is a one

- time activity that applies to ne w facilities only. No new facilities are expected over the three

- year period o f this ICR. d. 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 exi sting control device parameters.
e . We have assumed that compliance extensions will not be necessary during the three

- year period of this ICR.17

**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**  **B C**  **D E**  **F G**  **H**
**EPA h**  **ours per**  **o ccurrence**  **No. of**

**occurrences per plant**  **per year EPA hours** 

**per plant per year**  **Plants**

**per year**  **a EPA** 

**technical hours**  **per year EPA** 

**managerial hours**  **per year**  **EPA**

**clerical hours per year**  **Total cost**

**per year b**  **($) (C = A x B)**  **(E = C x D) (F = E x 0.05)**  **(G = E x 0.10)** 1. Read and understand rule requirements c 2 1 2 0 0 0 0 $0 2. Required activities A. Observe initial performance tests c 8 1 8 0 0 0 0 $0 B. Review initial performance test reports, engineering calculations, and operating parameters c 4 1 4 0 0 0 0 $0 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 19 152 7.6 15.2 $ 7,877.32 **TOTAL ANNUAL BURDEN**  **(rounded) 175**  **$7,877**18

**Assu mptions:**  a. We have assumed that there are 75 existing sources that are subject to the rule, and that no new major sources per year will become subject over the 3 year

period of this ICR. b. This cost is based on the average hourly labor rate as follows: Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%); Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%); and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 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 OPM, 2012 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit package s available to government employees.
c. This burden item is a one

- time activity that applies to ne w facilities only. No new facilities are expected over the three

- year period of this ICR. d. We have assumed that no enforc e ment 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.