**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 2352.0 4 , 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 appl y 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 report s, performance tests, and periodic reports b y 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 mea surements, 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 directl y 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 b y either state, local, tribal or the Federal government. They are all owned and operated by privatel y- 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 F ederal employees or government contractors and may be2

found in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Area Sources: Asphalt Proces sing 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 ye ars, approximately 75 respondents per ye ar will be subject to the se standard s , and no additional respondents per year will become subject to the se same standard s . The projected ind ustry growth rate is based on the Agency ’s estimate from a previous renewal. The Office of Management and Budget ( OMB ) approved the currentl y 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. 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, 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 Admini strator may reasonabl y 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 the se standard s ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard . Continuous emission monitors are used to ensure compliance with the se standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the se standard s are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated , leaks are being detected and repaired, and the standard s 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 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 b y 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 ( 8 0 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 ye ars. 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 (ICI S). IC IS 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 renew al , as well as those submitted in response to the f irst 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 b y these standards was collected less frequentl y, 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 with the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars all ow s 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 ye ars. In addition, EP A 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 made5

will be safeguarded according to the A gency 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 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)6
**Notification s**  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 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. **(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, anal yz e, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICI S. **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comply

with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. In formation contained in the reports is reported b y state and local governments in the IC I S Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollutio n 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) Sm**  **all 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. W e 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 Tab le 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 requirement s 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 $1 2 9

. 93 ($ 61.87 + 110%) Technical $ 10 3

. 97 ($4 9

. 51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 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 b y 110 perc ent 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 s . The annual operation and maintena nce costs are the ongoing costs to maintain the monitors and other costs such as photocop yi ng 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 mo nitoring 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 o f 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 IC R 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 anal ys is of the reported info rmation. 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. Th e average annual Agency cost during the three years of the ICR is estimated to be $7,960

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

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )11

These rates are from the Office of Personnel Management (OPM) , 20 1 4 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 ye ars, approximately 75 existing respondents will be subject to the se s tandard 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 year. The number of respondents is calculated 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 respondents include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondents submit initial notifications

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 75

. The total number of annual responses per ye ar 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 Respo nses 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, respectivel y, 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 ty

pical 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 ty pical 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 17513

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 ty

pical 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 ty pical 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 ye ar 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 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 infor mation. 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 t his ICR under Docket ID Number EPA

- HQ

- OECA

- 201 2

- 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 Do cket 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 i s (202) 566

- 17 52

. Also, you c an 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 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 c 2 1 2 75 150 7.5 15 $17,346.83 3. Required activities A. Initial performance tests d 8 1 8 0 0 0 0 $0 B. Engineering calculations d 8 1 8 0 0 0 0 $0 C. Continuous parameter monitoring e 0 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 d 4 1 4 0 0 0 0 $0 C. Request for compliance extension f 4 1 4 0 0 0 0 $0 D. Notification of initial performance tests d 2 1 2 0 0 0 0 $0 E. Notification of compliance status d 2 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 $69,387.3016

**Subtotal for Reporting Requirements 1,553**  **$156,121** 5. Recordkeeping requirements A. Plan activities d 4 1 4 0 0 0 0 $0 B. Implement activities (1) Record performance tests d 1 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)**  **g 3,020**  **$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 ye ar will become subject over the 3 ye ar -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 b y 110 percent to account for the benefit packages available to those employed b y 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

- ye ar 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

- ye ar period of this ICR. g Totals have been rounded to 3 significant figures. Figures may not add exactly

due to rounding17

**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 occur**  **rence 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 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 $018

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 $7,956 **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 ye ar will become subject over the 3 ye ar -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 1 0 percent of Technical hours. These rates are from the OPM, 201 4 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

- ye ar 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

- ye ar period of this ICR. f

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