SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU)

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU) 

(Renewal), EPA ICR Number 0661.11, OMB Control Number 2060-0002.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Asphalt Processing and Roofing 

Manufacture were proposed on November 18, 1980, promulgated on August 6, 1982, and 

amended on October 17, 2000. These regulations apply to each existing and new saturator and 

asphalt storage facilities at asphalt roofing plants, and to asphalt storage tanks and blowing stills 

at asphalt processing plants, petroleum refineries, and asphalt roofing plants. 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 60, subpart 

UU.

In general, all NSPS standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NSPS. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least two years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

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

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, an average of 144 respondents per year will be subject to these

standards, and 2 respondents per year will undergo reconstruction and become new sources 

subject to these same standards.

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

without any “Terms of Clearance.”
2

The respondents are asphalt processing and roofing manufacture plants in the United 

States, all which are privately-owned, for-profit businesses. None of the facilities are owned 

either by state, or local, or tribal entities, or by the Federal government. The “burden” to the 

“Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NSPS 

for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU) (Renewal). The 

Federal Government “burden” is attributed entirely to work performed by either Federal 

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

Burden and Cost – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, 

Subpart UU) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every

four years. In addition, section 114(a) states that the Administrator may require any 

owner/operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, particulate matter emissions from asphalt processing and 

roofing manufacture cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, the NSPS were promulgated for this source 
3

category at 40 CFR part 60, subpart UU.

2(b) Practical Utility/Users of the Data

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 standards. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in 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 60, subpart

UU.

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 (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal Register.
4

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 EPA's Office of Compliance. OTIS is EPA’s database for the 

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

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

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

comment on the burden associated with these standards as they were being developed and these

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the Asphalt Roofing 

Manufacturers Association (ARMA), at (202) 207-0917; and 2) the Energy Information 

Administration (EIA), at (202) 586-1134.

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.

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).
5

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 asphalt processing 

and roofing manufacture facilities. The United States Standard Industrial Classification (SIC)

codes for the respondents affected by the standards and the corresponding North American 

Industry Classification System (NAICS) codes are listed in the table below:

Standard (40 CFR Part 60, Subpart UU) SIC Codes NAICS Codes

Petroleum Refineries 2911 324110

Asphalt Paving Mixtures and Block Manufacturing 2951 324121

Asphalt Felts and Coatings 2952 324122

4(b) Information Requested

(i) Data Items

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

Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU). 

A source must make the following reports:

Notifications/Reports

Notification of construction/reconstruction 60.7(a)(1)

Notification of actual startup date 60.7(a)(3)

Notification of physical or operational change which may increase the 

emission rate

60.7(a)(4)

Notification of demonstration of continuous monitoring system 60.7(a)(5)

Notification of initial performance test 60.8(d)

Report of initial performance test 60.8(c)

A source must keep the following records:
6

Recordkeeping

Startup, shutdown, malfunctions, periods where the continuous 

monitoring system is inoperative 60.7(b)

Operating temperature measurements of pollution control devices as 

appropriate, and the initial performance test results including 

temperature measurements

60.7(d)

Continuously monitor and record the temperature of the gas at the inlet 

of the control device 60.473(a)

Continuously monitor and record the temperature in the combustion 

zone of the afterburner 60.472(b)(1)

For control devices not mentioned in paragraphs (a) and (b) of this 

section, describing the operation of the control device and the process 

parameter(s)

60.473(c)

Records are required to be retained for two years 60.7(f)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

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

a plant site. 

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 temperature monitoring device. 

Perform initial performance test, Reference Method 5A, 9, and 22 tests, and repeat 

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.
7

Respondent Activities

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. 

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

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

was achieved. Data and records maintained by the respondents are tabulated and published for 

use in compliance and enforcement programs. The semiannual reports are used for problem 
8

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

determinations.

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 two

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown below in Table 1: Annual Respondent Burden and Cost – NSPS for Asphalt Processing 

and Roofing Manufacture (40 CFR Part 60, Subpart UU) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

concept of burden under the Paperwork Reduction Act. Wherever 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 33,912 hours (Total Labor Hours from 
9

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 NSPS program, the 

previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

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

2013, “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 incurred 

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.

(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)

Temperature 

Monitors $100,000 2 $200,000 $35,000 144 $5,040,000

TOTAL $200,000 $5,040,000

The total capital/startup costs for this ICR are $200,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $5,040,000. This is 
10

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 $5,240,000. 

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 such activities 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 

$123,788. 

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%)

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

These rates are from the Office of Personnel Management (OPM), 2013 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Asphalt 

Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately 144 existing respondents will be 

subject to the standards on average over the next three years. It is estimated that an additional 

two respondents per year will become subject due to reconstruction of existing sources. The 

overall average number of respondents, as shown in the table below, is 144 per year.

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

years covered by this ICR: 
11

Number of Respondents

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 2 144 0 2

144

2 2 144 0 2 144

3 2 144 0 2 144

Average 2 144 0 2 144

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 144. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That Keep Records 

But Do Not Submit Reports

(E)

Total Annual 

Responses

E=(BxC)+D

Notification and application of 

construction/ reconstruction 2 1 N/A 2

Notification of actual startup 2 1 N/A 2

Notification of physical or 

operational change which may 

increase the emission rate

2 1 N/A 2

Notification of demonstration 

of continuous monitoring 

system.

2 1 N/A 2

Notification of initial 

performance test 2 1 N/A 2

Report of initial performance 

test 2 1 N/A 2

Semiannual reports 144 2 N/A 288

TOTAL 300

The number of Total Annual Responses is 300.
12

The total annual labor costs are $3,317,168. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Asphalt Processing 

and Roofing Manufacture (40 CFR Part 60, Subpart UU).

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 33,912 at a cost of $3,317,168. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost –NSPS for 

Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU). 

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

information is estimated to average 113 hours per response.

The total, annual capital/startup and O&M costs to the regulated entity are $5,240,000. 

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 

2,747 labor hours at a cost of $123,788. See below Table 2: Average Annual EPA Burden and 

Cost – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60, Subpart UU).

6(f) Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the previous ICR. This is 

due to two considerations. First, the regulations have not changed over the past three years and 

are not anticipated to change over the next three years. Second, the growth rate for the 

respondents is very low, negative, or non-existent. Therefore, the burden hours in the previous 

ICR reflect the current burden and are reiterated in this ICR. However, there is an adjustment 

decrease in the respondent cost and an adjustment increase in the Agency cost due to an update 

in labor rates. 

6(g) Burden Statement

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

is estimated to average 113 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, 
13

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-2013-0326. 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, 

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-2013-0326 and OMB Control Number 2060-0002 in any

correspondence. 

Part B of the Supporting Statement

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

information.
14

Table 1: Annual Respondent Burden and Cost – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60,

 Subpart UU) (Renewal)

Burden item

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per 

year 

(Ex0.1)

(H) 

Cost ($) b

1. Applications N/A 

2. Survey and Studies N/A 

3. Reporting requirements 

 A. Read instructions 1 1 1 2 2 0.1 0.2 $224.98 

 B. Required activities

 Initial performance tests c

72 1 72 2 144 7.2 14.4 $16,198.56 

 Repeat of performance test d72 1 72 0.2 14.4 0.72 1.44 $1,619.86 

 C. Create Information See 3B

 D. Gather existing information See 3B

 E. Write report 

 Notification of construction/ reconstruction e 2 1 2 2 4 0.2 0.4 $449.96 

 Notification and demonstration of CMS f40 1 40 2 80 4 8 $8,999.20 

Notification of actual startup 2 1 2 2 4 0.2 0.4 $449.96 

Notification of initial performance test 2 1 2 2 4 0.2 0.4 $449.96 

Report of performance test See 3B 

Notification of physical or operational change g2 1 2 2 4 0.2 0.4 $467.55 

Semiannual reports 24 2 48 144 6,912 345.6 691.2 $777,530.88 

Subtotal for Reporting Requirements 8,243.66 $806,390.91

4. Recordkeeping requirements

 A. Read instructions See 3A

 B. Plan activities See 3B 

 C. Implement activities See 3B 

 D. Develop record system N/A 

 E. Time to enter information

 Records of daily production rate and hours of operation h0.13 250 32.5 144 4,680 234 468 $526,453.20 

 Records of operating parameters of CMS i0.25 250 62.5 144 9,000 450 900 $1,012,410.00
15

Burden item

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per 

year 

(Ex0.1)

(H) 

Cost ($) b

 Records of startup, shutdown, and malfunctions j60 1 60 144 8,640 432 864 $971,913.60 

 F. Train personnel N/A

 G. Audits N/A

Subtotal for Recordkeeping Requirements 25,668 $2,510,776.80

TOTAL ANNUAL BURDEN AND COST (rounded) 33,912 $3,317,168

Assumptions:

a.

 We have assumed that the average number of respondents that are subject to the regulation will be 144 with two source undergoing reconstruction per year over 

the three-year period of this ICR.

b.

 This ICR uses the following labor rates: $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and 

$51.18 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “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.

c We have assumed that it will take 72 hours of each respondent to perform initial performance test.

d.

 We have assumed that 20 percent of respondents will fail the performance test and will have to repeat it.

e.

 We have assumed that each respondent will take two hours to write notification of construction/reconstruction report.

f. We have assumed that each respondent will take 40 hours to write notification and demonstration of CMS report.

g.

 We have assumed that each respondent will take 2 hours to write notification of physical or operational change.

h.

 We have assumed that each respondent will enter information of daily production rate and hours of operation 250 times per year.

i.

 We have assumed that each respondent will take 15 minutes 250 times per year to record the operating parameters of CMS.

j.

 We have assumed that each respondent will take 60 hours to record startup, shutdown, and malfunction information.
16

Table 2: Average Annual EPA Burden and Cost – NSPS for Asphalt Processing and Roofing Manufacture (40 CFR Part 60,

 Subpart UU) (Renewal)

Activity

(A) 

EPA personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours per 

plant per 

year 

(C=AxB)

(D) 

Plants per 

year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year 

(H) 

Cost ($) b

Initial performance tests

 New or modified facility c24 1 24 2 48 2.4 4.8 $2,487.58 

Repeat performance test

 New or modified facility d24 0.2 4.8 2 9.6 0.48 0.96 $497.52 

Report review

 New or modified facility

 Notification of construction/reconstruction e2 1 2 2 4 0.2 0.4 $207.30 

 Notification of physical/operational changes f2 1 2 2 4 0.2 0.4 $207.30 

 Notification of actual startup 0.5 1 0.5 2 1 0.05 0.1 $51.82 

 Notification of performance test 0.5 1 0.5 2 1 0.05 0.1 $51.82 

 Review of performance test results g8 1 8 2 16 0.8 1.6 $829.19 

 Notification of demonstration of CMS 0.5 1 0.5 2 1 0.05 0.1 $51.82 

 Semiannual reports 8 2 16 144 2,304 115.2 230.4 $119,403.65 

TOTAL ANNUAL BURDEN AND COST (rounded) 2,747 $123,788 

Assumptions:

a.

 We have assumed that the average number of respondents will be 144 with two source undergoing reconstruction per year over the three-year period of this ICR 

b.

 The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial 

rates of $62.27, Technical rate of $46.21, and Clerical rate of $25.01. These rates are from the Office of Personnel Management (OPM) “2013 General Schedule” 

which excludes locality rates of pay.

c.

 We have assumed that it will take 24 hours of each respondent to perform initial performance test.

d. We have assumed that 20 percent of respondents will fail the performance test and will have to repeat it.

e.

 We have assumed that it will take each respondent two hours one-time per year to review notification of construction/reconstruction report.

f.

 We have assumed that it will take each respondent two hours one-time per year to review notification of physical/operation changes.

g.

 We have assumed that it will take each respondent eight hours one-time per year to review the performance test results report.
17