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 2352.04, 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, promulgated on December 2, 2009, and amended 

on March 18, 2010. 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 notification reports, 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.

There are approximately 75 area sources that process asphalt or manufacture asphalt 

roofing products facilities (the “Affected Public”), which are owned and operated by the asphalt 

industry. None of the 75 facilities in the United States are owned by either state, local, tribal or 

the Federal government. They are all owned and operated by privately-owned, for-profit 

businesses. We assume that they will all respond to EPA inquiries. 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 government contractors and may be 
2

found 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).

Based on our consultations with industry representatives, there is an average of 1

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, approximately 75 respondents per year will be subject to 

these standards, and no additional respondents per year will become subject to these same

standards. The projected industry growth rate is based on the Agency’s estimate from a previous 

renewal. 

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

without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 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 either cause or contribute to air 

pollution that may reasonably be anticipated to endanger public health and/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
3

The recordkeeping and reporting requirements in these standards 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 these standards 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 these standards 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 standards 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. 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 (80 FR 32116) on June 5, 2015. 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 the Integrated Compliance Information System (ICIS). ICIS is 

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

and government-owned facilities. 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 and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. 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.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal, as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

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 with 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 
5

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 

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)
6

Notifications

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)

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.

(ii) Respondent Activities

Respondent Activities
7

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate a CPMS for opacity.

Perform initial performance test 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 the Enforcement and Compliance History Online (ECHO) 

and ICIS. 

5(b) Collection Methodology and Management
8

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. 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 five

years.

5(c) Small Entity Flexibility

Approximately 47 per cent 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. 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 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
9

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 

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 3,020 hours (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 $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 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 regulations. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitors and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
10

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 $6,000 0 $0 NA NA NA

Photocopying 

and postage c NA NA NA $15 75 $1,125

Total $0 $1,130

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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 $1,130. 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 $1,130. These are 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

$7,960.

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%)
11

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 – 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 these 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 respondents 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. 

The total number of annual responses per year is calculated using the following table:
12

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 $304,000. 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 3,020 hours. 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).

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.

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 20 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,130. 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
13

labor hours at a cost of $7,960. See 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).

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 a small adjustment increase in the respondent labor hours and the total O&M 

costs as currently identified in the OMB Inventory of Approved Burdens. The increase in labor 

hours is due to a change in assumption. In this ICR, we assume all existing sources will take 

some time each year to re-familiarize themselves with the regulatory requirements. The increase 

of five dollars in total O&M cost is due to rounding of all calculated values to three significant 

figures. 

6(g) Burden Statement

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

is estimated to average 20 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), WJC West, 
14

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) 566-1752. 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)

Hours per 

occurrence

(B)

No. of 

occurrences

per 

respondent 

per year

(C)

Hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E)

Technical 

hours per 

year

(E=CxD)

(F)

Management 

hours per 

year

(F=Ex0.05)

(G)

Clerical 

hours per 

year

(G=Ex0.1)

(H)

Total costs per 

year ($)b

1. Acquire and install recordkeeping 

technology and systems c 4 1 4 0 0 0 0 $0 

2. Familiarize with regulatory requirements c2 1 2 75 150 7.5 15 $17,346.83 

3. Required activities

A. Initial performance tests d8 1 8 0 0 0 0 $0 

B. Engineering calculations d8 1 8 0 0 0 0 $0 

C. Continuous parameter monitoring e0 0 0 0 0 0 0 $0 

4. Reporting requirements

A. Initial notification that existing facilities 

are subject to the standard d N/A

B. Notifications for new area sources 

 (1) Notification of intent to 

construct/reconstruct d 4 1 4 0 0 0 0 $0 

 (2) Notification of commencement of 

construction/reconstruction d 4 1 4 0 0 0 0 $0 

 (3) Notification of startup d4 1 4 0 0 0 0 $0 

C. Request for compliance extension f4 1 4 0 0 0 0 $0 

D. Notification of initial performance tests d2 1 2 0 0 0 0 $0 

E. Notification of compliance status d2 1 2 0 0 0 0 $0 

F. Gather information for semi-annual reports 4 2 8 75 600 30 60 $69,387.30 

G. Semiannual compliance reports 4 2 8 75 600 30 60 $69,387.30 
16

Subtotal for Reporting Requirements 1,553 $156,121 

5. Recordkeeping requirements

A. Plan activities d4 1 4 0 0 0 0 $0 

B. Implement activities

 (1) Record performance tests d1 1 1 0 0 0 0 $0 

 (2) Record malfunctions 0.5 2 1 75 75 3.75 7.5 $8,673.41 

 (3) Continuous parameter monitoring 

calibration and maintenance 1 12 12 75 900 45 90 $104,080.95 

C. Store, file, and maintain records 4 1 4 75 300 15 30 $34,693.65 

Subtotal for Recordkeeping Requirements 1,466 $147,448 

TOTAL ANNUAL BURDEN (rounded)g3,020 $304,000 

Capital and O&M Cost $1,130

GRAND TOTAL $305,000

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 year-period of this ICR.

b

This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and 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. This ICR assumes that 

Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

c

This ICR assumes all respondents will take 2 hours to familiarize with the regulatory requirements

d

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.

e

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.

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

g

Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding
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)

EPA hours 

per 

occurrence

(B)

No. of 

occurrence

per plant 

per year

(C)

EPA 

hours 

per 

plant 

per year

(C=AxB)

(D)

Plants 

per year

a

(E)

EPA 

technical 

hours 

per year

(E=CxD)

(F)

EPA 

managerial 

hours per 

year

(F=Ex0.05)

(G)

EPA 

clerical 

hours per 

year

(G=Ex0.1)

(H)

Total 

cost per 

year ($)b

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 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 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 c 1 1 1 0 0 0 0 $0 
18

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 $7,956 

TOTAL ANNUAL BURDEN (rounded) 175 $7,960 

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 year-period of this ICR.

b

. This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 

(GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 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, 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.

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. In addition, we assume the Agency staff are familiar with the NESHAP requirements. 

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.