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 Emission 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 apply to existing facilities and new facilities that are area sources 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 information 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/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 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 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 U. S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 75 respondents per year 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 currently 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 Federal employees or 
2

government contractors, 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. 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, 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 information 
3

obtained under the testing, monitoring, recordkeeping, and reporting will be used by EPA to: 

(1) identify existing and new HAP emission points subject to the NESHAP; (2) ensure that 

GACT is being properly applied; and (3) ensure that add-on control devices are being properly 

operated and maintained on a continuous basis 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 procedures and for compliance 

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart 

AAAAAAA.

3(a) Non-duplication

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, 

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 ICR 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 by 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 collection, 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 ICR, 

EPA contacted: 1) the Asphalt Roofing Manufacturers Association, at (202) 591-2450; and 

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 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.

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-year records retention requirement is consistent the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years 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 has found that the most flagrant violators have violations extending beyond five 

years. 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 operators 
5

of HAP emitting area sources in the asphalt processing and asphalt roofing manufacturing 

industry. The United States Standard Industrial Classification (SIC) 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 by the NESHAP for Area 

Sources: Asphalt Processing and Asphalt Roofing Manufacturing (40 CFR Part 63, Subpart 

AAAAAAA). 

A source must make the following reports:

Notifications

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 system (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 systems 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 CPMS 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 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.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. 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, analyze, and maintain data in the Online Tracking Information System (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 properly installed and operated. 
8

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.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS 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 five 

years.

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. We have limited the testing, monitoring, recordkeeping, and 

reporting requirements for all facilities, including those owned by small businesses, to the 

minimum necessary to ensure compliance. Additionally, it 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 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 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 ICR. The 
9

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 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 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 previously 

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83+ 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 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 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 type 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 such as photocopying and postage.
10

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

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 

monitoring 

systems a

$144 0 $0 NA NA NA

Performance 

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 costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR 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 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. 

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 hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)
11

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 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 – NESHAP for Area 

Sources: Asphalt Processing 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 ICR, on average over the next three years, approximately

75 existing respondents will be subject to the standards. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as 

shown in the table below, is 75 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 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 respondents submit initial notifications.

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 75.
12

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

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, respectively, 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 

information 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 Change in Burden

There is an adjustment increase in labor costs for the respondents from the most recently 

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 years and the requirements are different during initial compliance as compared to ongoing compliance. The previous ICR reflected those burdens and costs associated with the initial 

activities for subject facilities. This includes purchasing monitoring equipment, conducting 

performance tests and establishing recordkeeping systems. This ICR, by in large, reflects the ongoing 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 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.

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-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 Public 
14

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) 566-1752. 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-2012-0496 and OMB Control Number 2060-0634 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable 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 yeara

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 c4 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 c4 1 4 0 0 0 0 $0

(2) Notification of commencement of 

construction/reconstruction c4 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 $66,811.80

G. Semiannual compliance reports 4 2 8 75 600 30 60 $66,811.80

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 yeara

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 c1 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

Assumptions:

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 yearperiod 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, “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. 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 new facilities only. No new facilities are expected over the three-year period of 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 existing 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 hours 

per 

occurrence

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 c2 1 2 0 0 0 0 $0

2. Required activities

A. Observe initial performance tests c8 1 8 0 0 0 0 $0

B. Review initial performance test reports, 

engineering calculations, and operating 

parameters c4 1 4 0 0 0 0 $0

C. Enter and update information into agency 

recordkeeping system c1 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 c1 1 1 0 0 0 0 $0

B. Notifications for new area sources 

(1) Review notification of intent to 

construct/reconstruct c4 1 4 0 0 0 0 $0

(2) Review notification of commencement 

of construction/reconstruction c2 1 2 0 0 0 0 $0

(3) Review notification of startup c2 1 2 0 0 0 0 $0

C. Review request for compliance extension e2 1 2 0 0 0 0 $0

D. Review notification of initial performance 

tests c1 1 1 0 0 0 0 $0

E. Review notification of compliance status c4 1 4 0 0 0 0 $0

5. Review semiannual compliance reports f4 2 8 19 152 7.6 15.2 $7,877.32

TOTAL ANNUAL BURDEN (rounded) 175 $7,877
18

Assumptions:

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 yearperiod 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 packages available to government employees.

c.

 This burden item is a one-time activity that applies to new facilities only. No new facilities are expected over the three-year period of this ICR.

d.

 We have assumed that no enforcement activities will be conducted over the three-year period of this ICR.

e

. We have assumed that compliance extensions will not be necessary during the three-year period of this ICR.

f.

 We have assumed that EPA technical personnel will review 25% of the semiannual compliance reports.