SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I)
(Renewal), EPA ICR 1127.09, OMB Control Number 2060-0083

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations (40 CFR
part 60, subpart I) were proposed on June 11, 1973, and promulgated on
July 25, 1977.  These regulations apply to hot mix asphalt facilities
comprised only of a combination of the following: dryers; systems for
screening, handling, storing, and weighing hot aggregate; systems for
loading, transferring, and storing mineral filler; systems for mixing
hot mix asphalt; and the loading, transfer, and storage systems
associated with emission control systems.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports.  Owners or operators of the
affected facilities described must make the following on-time only
reports: notification of the date of construction or reconstruction;
notification of the anticipated and actual dates of startup;
notification of any physical or operational change to an existing
facility which may increase the regulated pollutant emission rate;
notification of the date of the initial performance test; and the
results of the initial performance test.  Owners or operators 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.  In general, these notifications, reports, and records are
required of all sources subject to NSPS.

	This information is being collected to assure compliance with 40 CFR
Part 60, Subpart I.  Any owner or operator subject to the provisions of
this part will maintain a file of these records, and retain the file for
at least two years following the date of such records.  The reporting
requirements for this industry currently include only the initial
notifications and initial performance test report listed above.  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 EPA regional office. 

In the development of this Information Collection Request (ICR), we
reviewed the Office of Management and Budget (OMB) “Terms of
Clearance” (TOC) section on the active ICR. There were no comments in
the TOC section.

We have determined that approximately 95 percent (i.e., 3800) of 4,000
existing hot mix asphalt facilities in the United States are currently
subject to NSPS subpart I.  In addition, we are expecting an average net
growth of 105 facilities per year for this sector, and that an average
of 3.5 percent (i.e. 140) of the existing facilities would be conducting
modifications of their facilities, such that they will be required to
comply with the initial rule requirements.  This information has been
gathered through consultation with the National Asphalt Pavement
Association and the EPA Office of Air Quality Planning and Standards.

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR
Part 60, Subpart I) (Renewal), attached.  The burden to the “Federal
Government” is attributed entirely to work performed by federal
employees or government contractors; this burden may be found in Table
2: Annual Burden and Cost for the Federal Government: NSPS for Hot Mix
Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal), attached.  

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: 

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 hot
mix asphalt facilities 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 category at 40 CFR
part 60, subpart I.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations that 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
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 the standard 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 standard is
being met.        The performance test may also be observed.

The required semiannual compliance certifications are used to determine
periods of excess emissions, identify problems at the facility, verify
operation and 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 I.

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, no duplication
exists.

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 (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

In previous renewals of this ICR, the information available on the
active ICR, the standard and on the Agency databases was reviewed; the
sector contact at the EPA’s Office of Air, Quality Planning and
Standards (OAQPS), the Director of Environmental and Safety Services at
the National Asphalt Pavement Association (NAPA) were also contacted.  

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 that emission limitations are met.  If the information
required by these standards was collected less frequently, the
likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

3(e)  General Guidelines

Neither the reporting nor recordkeeping requirements violate the
regulations established by Office of Management and Budget (OMB) at 5
CFR part 1320, section 1320.5.  However, most NESHAP standards and a few
NSPS standards require records be kept more than three years.  In
general, these standards require the respondents to maintain all
records, including reports and notifications, for five years.  The
five-year record retention requirement is consistent with the Permit
program at 40 CFR part 70, 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 the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. If
records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting noncompliance 

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, Part 2, Subpart B -
Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are hot
mix asphalt facilities commencing construction, modification or
reconstruction after June 11, 1973.  The SIC code for the respondents
affected by the standards is SIC (United States Standard Industrial
Classification) 2951 which corresponds to the NAICS (The North American
Industry Classification System) 324121 for hot mix asphalt facilities.

 

4(b)  Information Requested

(i)  Data Items

	All data in this ICR that is recorded and/or reported is required by
NSPS for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I). 

	A source must make the following reports:

Notification Reports

Notification of construction or reconstruction	40 CFR 60.7(a)(1)

Notification of actual date of initial startup			40 CFR 60.7(a)(3)

Notification of physical or operational change		40 CFR 60.7(a)(4)

Notification of performance test			40 CFR 60.8(d)



Reports

Report of performance tests				40 CFR 60.8(a)



A source must maintain the following records:

Recordkeeping

Record of startups, shutdowns, and malfunctions	60.7(b)

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



Electronic Reporting

At the present, many respondents to CAA standards use monitoring
equipment that automatically records parameter data.  Although personnel
at the affected facility must evaluate the data, this internal
automation has significantly reduced the burden associated with
monitoring and recordkeeping at the plant site.

In addition, 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	

	Respondents must conduct the following activities:

Respondent Activities

Read instructions

Perform initial performance test, Reference Methods 5 for particulate
matter and Method 9 to determine opacity, 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

Developing, acquiring, installing, and utilizing technology and systems
for the purpose of processing and maintaining information

Developing, acquiring, installing, and utilizing technology and systems
for the purpose of disclosing and providing information

Adjusting the existing ways to comply with any previously applicable
instructions and requirements

Training personnel to be able to respond to a collection of information

Transmitting, or otherwise disclosing 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 information
required under 40 CFR part 60, subpart I:

Agency Activities

Observes initial performance tests and repeat performance tests if
necessary

Reviews notifications and reports, including performance test reports,
and excess emissions reports, required to be submitted by industry

Audits facility records

Inputs and maintains data in the Aerometric Information Retrieval System
(AIRS) database



5(b)  Collection Methodology and Management

The required data and reports can be evaluated on-site by conducting a
partial compliance evaluation, full compliance evaluation or inspection,
or thru an off-site review of compliance monitoring records and reports.
 Evaluation reports and inspection results are maintained by the Agency
or delegated authority.

The results of these evaluations are entered into the Air Facility
Subsystem (AFS) which is operated and maintained by EPA's Office of
Compliance.  AFS 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 AFS for tracking air
pollution compliance and enforcement by local and state regulatory
agencies, EPA regional offices and EPA headquarters. EPA and delegated
authorities can retrieve and analyze the data.

5(c)  Small Entity Flexibility

The recordkeeping and reporting requirements were selected within the
context of this specific subpart and the specific process equipment and
pollutant.  The requirements reflect the burden on small businesses.  To
the extent that larger businesses can use economies of scale to reduce
their burden, the overall burden will be reduced.  Although the
recordkeeping and reporting requirements are the same for small and
larger businesses, the Agency considers these requirements to be the
minimum needed to ensure compliance and, therefore, cannot reduce them
further for small businesses.

The number of small entities affected by this rule could not be
determined, based on review of the following sources: the promulgated
rule notice in the Federal Register; the Background Information for New
Source Performance Standards: Asphalt Concrete Plants, Petroleum
Refineries, Storage Vessels, Secondary Lead Smelters and Refineries,
Brass or Bronze Ingot Production Plants, Iron and Steel Plants, Sewage
Treatment Plants; Volume 3, Promulgated Standards (1974); and a search
of publicly available current data sources.  The Background Information
document states: “In 1970, there were 1,846 concrete firms operating
an estimated 4,500 plans in the United States. Approximately one-third
of the firms operated a single plant and most of the remainder operated
less than five plants.”

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1, attached.

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. 
The individual burdens are expressed under standardized headings
believed to be consistent with the concept of burden under the Paperwork
Reduction Act.  Where it was appropriate, specific tasks and major
assumptions have been identified in the burden calculations.  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

Over the next three years, the average annual burden to industry for
these recordkeeping and reporting requirements is estimated to be 17,740
hours (Total Labor Hours from Table 1).  The respondent burden is shown
in Table 1, attached.  The labor hours in Table 1 are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the standard, 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	$97.46   ($46.41 + 110%) 

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “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 only type of industry costs associated with the information
collection activities in the subject standards is labor costs which are
addressed elsewhere in this ICR.  There are no capital/startup and
operation and maintenance costs associated with continuous monitoring
equipment.  The capital/startup costs are one-time costs when a facility
becomes subject to the regulation.  The annual operation and maintenance
costs are the ongoing costs to maintain the monitor(s) and other costs
such as photocopying and postage.

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

There are no average annual costs for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR
because the rule does not require the use of continuous monitoring
equipment.

6(c)  Estimating Agency Burden and Costs

The only costs to the Agency are those 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 and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $169,700.  This burden is shown in Table 2: Annual
Burden and Cost for the Federal Government: NSPS for Hot Mix Asphalt
Facilities (40 CFR Part 60, Subpart I) (Renewal), attached.

This cost is based on the average hourly labor rate as follows:

Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2005
General Schedule( which excludes locality rates of pay.

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

Number of respondents is calculated using the following table which
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	245	0	3,800	140	3,905

2	245	0	3,905 	140	4,010

3	245	0	4,010	140	4,115

Average	245	0	3,905	140	4,010

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.  In this standard, existing respondents
that conduct operational changes submit initial notifications and
conduct performance tests.

To avoid double-counting, column D is subtracted.  As shown above, the
average Number of Respondents over the three-year period of this ICR is
4,010.

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 of initial startup	105	1

105

Notification of contraction/reconstruction	105	1

105

Notification of operational change	140	1

140

Notification of performance test	245	1.2

294

Performance test reports	245	1.2

294

Recordkeeping

	3,905	3,905

Total



4,843



The number of Total Annual Responses is 4,843, as shown in column E.

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, attached.

(i) Respondent Tally

The Total Hours Requested is 17,740.  Details regarding these estimates
may be found in Table 1.  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 4 hours (rounded) per response

There are no total annual capital/startup and O&M costs to the regulated
entity.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Cost.

(ii) The Agency Tally

The average annual Agency burden hours and cost over next three years is
shown in Table 2, attached.

6(f)  Reasons for Change in Burden

There is no change in the estimation methodology for labor hours or cost
to the respondents 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.  Secondly, the growth rate for respondents is very low,
negative, or non-existent.  

The previous approved ICR renewal indicated 17,318 annual labor hours;
after review of the burden tables, we have determined that the number of
indicated hours was based on a calculation error.  The slight increase
in burden is due to a correction in the labor hours from 17,318 to
17,740 per year.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 4 hours (rounded) per response. 
Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, disclose, or provide information
to or for a Federal agency.  This includes the time needed to review
instructions; to 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; to adjust the existing ways to comply with any
previously applicable instructions and requirements; to train personnel
to be able to respond to a collection of information; to search data
sources; to complete and review the collection of information; and to
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’s 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-2008-0376.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public 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) 566-1927.  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-2008-0376 and OMB Control Number 2060-0083 in any
correspondence.

Part B of the Supporting Statement

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

Table 1.  Annual Respondent Burden and Cost:  NSPS for Hot Mix Asphalt
Facilities (40 CFR Part 60, Subpart I) (Renewal)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Acquisition, Installation,         and Utilization of  Technology
and  Systems	

N/A	

	

	

	

	

	

	





4.  Reporting Requirements	

	

	

	

	

	

	

	





  A.  Read instructions	

1	

1	

1	

245	

245.0	

12.3	

24.5	

$22,750.18



  B.  Required activities:	

	

	

	











   i.  Initial Performance tests   c    	

24	

1	

24	

245	

5,880.0	

294.0	

588.0	

$545,887.44



   ii.  Repeat Performance tests   c  	

24	

0.2	

4.8	

245	

1,176.0	

58.8	

117.6	

$109,177.49

   

   iii.  Reference Method 9	

4	

1	

4	

245	

980.0	

49.0	

98.0	

$90,981.24

  

   iii.  Monitoring of operations         and equipment:  	Included in
`5E









C.  Gather Existing Information	

Included in 4B and 5E	

	

	

	

	

	





D.  Write report   a, c 	

	

	

	

	

	

	

	





   i.  Notification of actual                 startup date	

2	

1	

2	

105	

210.0	

10.5	

21.0	

$19,495.98



   ii.  Notification of                          construction/
reconstruction   	

2	

1	

2	

105	

210.0	

10.5	

21.0	

$19,495.98



   iii.  Notification of physical or       operational change   	

2	

1	

2	

140	

280.0	

14.0	

28.0	

$25,994.64



   iii.  Notification of                         Performance Test   c	

2	

1.2	

2.4	

245	

588.0	

29.4	

58.8	

$53,877.75



   iv.  Reports of performance           test results  	

Included in  4B







  

  v.  Periodic reports   d      	

N/A







SUBTOTAL Reporting



11,004.4	$887,660.70 



5.  Recordkeeping Requirements	

	

	

	

	

	

	

	





 A.  Read instructions	

Included in 4A	

	

	

	

	

	





 B.  Plan activities	

Included in 4B	

	

	

	

	

	



 

C.  Implement activities	

Included in 4B









D.  Develop record system	

N/A









E.  Time to enter and transmit    information   e	

1.5	

1	

1.5	

3,905	

5,857	

292.9	

585.7	

$543,794.03



F.  Time to train personnel	

N/A	

	

	









G. Time for audits	

N/A	

	

	









SUBTOTAL Recordkeeping



	6,736	$543,794.03



LABOR  BURDEN AND COST  	

	

	

	

	

15,059.0	

753.0	

1,505.9	

$1,431,454.73



TOTAL LABOR BURDEN AND COST  (Rounded)	

	

	

	

	

17,740	

$1,431,455



Assumptions:

a   We have determined that approximately 95 percent of 4,000 (i.e.,
3800)  existing hot mix asphalt facilities in the United States are
currently subject to NSPS subpart I.  In addition, we are expecting an
average net growth of 105 facilities per year for this sector and that
an average of 3.5 percent of the existing facilities (i.e., 140) would
be conducting  modifications of their facilities.            

b   This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2. Civilian Workers, by 
Occupational and Industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

c  We have assumed that a total of 245 new and modified hot mix asphalt
facilities would be required to submit notification and conduct a
performance test.  We have further assumed that about 20 percent of the
sources would repeat performance tests due to failure.    

d   The rule does not require existing sources to submit periodic
reports.

e We have assumed that recordkeeping would take sources an average of
1.5 hours a year.   

Table 2.  Annual Burden and Cost for the Federal Government: NSPS for
Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

Per              year  a, c 

	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per

year

(Ex0.1)

	

(H)

Cost, $ b



Notification of actual                 startup date  	

2	

1	

2	

105	

210.0	

10.5	

21.0	

$9,790.41



Notification of                          construction/ reconstruction   


2	

1	

2	

105	

210.0	

10.5	

21.0	

$9,790.41



Notification of physical or       operational change   	

2	

1	

2	

140	

280.0	

14.0	

28.0	

$13,053.88



Notification of                         Performance Test 	

2	

1.2	

2.4	

245	

588.0	

29.4	

58.8	

$27,413.15



Reports of performance           test results   c	

8	

1.2	

9.6	

245	

2,352.0	

117.6	

235.2	

$109,652.59

 

Periodic reports   d	

N/A









Subtotal Burden and Cost	

	

	

	

	

3,640.0	

182.0	

364.4	

$169,700.44



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	4,186	

$169,700



Assumptions:

a    We have determined that approximately 95 percent of 4,000 (i.e.,
3800)  existing hot mix asphalt facilities in the United States are
currently subject to NSPS subpart I.  In addition, we are expecting an
average net growth of 105 facilities per year for this sector and that
an average of 3.5 percent of the existing facilities (i.e., 140) would
be conducting modifications of their facilities.   

b   This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of  $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2005 General Schedule” which
excludes locality rates of pay.  

c   The 245 new and modified hot mix asphalt facilities would be
required to submit notifications and perform performance tests.

d   The rule does not require sources to submit periodic reports.  

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