                                       
                                       
                             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 1127.10, OMB Control Number 2060-0083. 

      1(b)  Short Characterization/Abstract

      The New Source Performance Standards (NSPS) for Hot Mix Asphalt Facilities (40 CFR part 60, subpart I) were proposed on June 11, 1973, promulgated on July 25, 1977, and amended on February 14, 1989 (54 FR 6667).  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. 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 I.

      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 will maintain a file of these records, 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. 

      Over the next three years, an average of 4,325 respondents per year will be subject to the standard, and an additional 105 respondents per year will become subject to the standard.  In addition, we are expecting on average 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 was gathered through consultation with the National Asphalt Pavement Association and the Asphalt Pavement Alliance during a previous renewal.
      
	All of the hot mix asphalt facilities in the United States are owned and operated by the Hot Mix Asphalt industry (the "Affected Public"), which is a privately-owned, for-profit business.  None of these facilities in the United States are owned by state, local, tribal or the Federal government.   The burden to the "Affected Public" is listed below in Table 1: Annual Respondent Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal).  The burden to the "Federal Government" is attributed entirely to work performed by federal employees or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal). 
      
      The Office of Management and Budget (OMB) approved the current Information Collection Request (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 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 (76 FR 26900) on May 9, 2011.  No comments were received on the burden published in the Federal Register.
      
      3(c)  Consultations

      The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years.  

      Industry trade association(s) 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 the development of this ICR, EPA consulted the National Asphalt Pavement Association at (301) 731-4748, and the Asphalt Pavement Alliance at (301) 731-4748.  No comments were received.

      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).
      
      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 hot mix asphalt facilities.  The SIC code for the respondents affected by the standards is United States Standard Industrial Classification (SIC) 2951, which corresponds to the North American Industry Classification System(NAICS) 324121 for hot mix asphalt facilities.
 
      4(b)  Information Requested

      (i)  Data Items
            
	In this ICR, all the data that is recorded 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

      Some of the respondents are using monitoring equipment that automatically records parameter data.  Although personnel at the affected facility must 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	

	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
Adjust 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 required information.

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 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.  Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.  The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

--------------------------------------------------------------------------------
      Information contained in the reports is entered into the 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

      The 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 Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (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 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 18,284 hours (Total Labor Hours from Table 1).  These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS, the previously approved ICR, and any comments received.
      
      6(b)  Estimating Respondent Costs

            (i)  Estimating Labor Costs 
 
      This ICR uses the following labor rates: 

		Managerial	$121.42   ($57.82 + 110%) 
            Technical	$99.14   ($47.21 + 110%)
            Clerical	$49.81   ($23.72 + 110%)
            
These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, "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 costs to the regulated industry resulting from information collection activities required by the subject standard are labor costs.  There are no capital/startup or operation and maintenance costs.

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

      The only type of industry costs associated with the information collection activity in the regulations is labor costs.  There are no capital/startup or operation and maintenance costs.

      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, 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 $188,641.

--------------------------------------------------------------------------------
      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), 2011 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 EPA Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal).
      
      6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately 4,220 existing respondents will be subject to the standard.  It is estimated that an additional 105 respondents per year will become subject.  The overall average number of respondents, as shown in the table below is 4,325 per year.  

--------------------------------------------------------------------------------
      The number of respondents is calculated using the following table that addresses the three years covered by this ICR.  
--------------------------------------------------------------------------------
      
--------------------------------------------------------------------------------
      
--------------------------------------------------------------------------------
      
--------------------------------------------------------------------------------
      
--------------------------------------------------------------------------------
      
--------------------------------------------------------------------------------
      
--------------------------------------------------------------------------------
      
--------------------------------------------------------------------------------
      

                             Number of Respondents

                        Respondents That Submit Reports
                  Respondents That Do Not Submit Any Reports

Year
                                      (A)
                         Number of New Respondents [1]
                                      (B)
                        Number of Existing Respondents
                                      (C)
  Number of Existing Respondents That Keep Records but Do Not Submit Reports
                                      (D)
         Number of Existing Respondents That Are Also New Respondents
                                      (E)
                             Number of Respondents
                                  (E=A+B+C-D)
                                       1
                                      245
                                       0
                                     4,115
                                      140
                                     4,220
                                       2
                                      245
                                       0
                                     4,220
                                      140
                                     4,325
                                       3
                                      245
                                       0
                                     4,325
                                      140
                                     4,430
                                    Average
                                      245
                                       0
                                     4,220
                                      140
                                     4,325
      [1] New respondent 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.

      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 4,325.
      
      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
                                       
                                       
                                     4,220
                                     4,220
Total
                                       
                                       
                                       
                                     5,158

      The number of Total Annual Responses is 5,158.  

      The total annual labor costs are $1,751,943.  Details regarding these estimates may be found below below in Table 1: Annual Respondent Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (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 (below), respectively, and summarized below.

            (i) Respondent Tally

      The total annual labor hours are 18,284.  Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost: NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal).
      
      Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 4 hours per response.
      
      There are no capital/startup or operation and maintenance costs.  

             (ii)  The Agency Tally

      The average annual Agency burden and cost over next three years is estimated to be 4,186 labor hours at a cost of $188,641.  See below Table 2:  Average Annual EPA Burden and Cost:  NSPS for Hot Mix Asphalt Facilities (40 CFR Part 60, Subpart I) (Renewal).

      6(f)  Reasons for Change in Burden

There is an increase in burden hours to the respondent in this ICR as compared to the most recently approved ICR.  The increase is due to industry growth in the past three years, resulting in additional number of respondents that are subject to this standard.  In addition, there is an increase in burden costs to both the respondent and the Agency due to an adjustment in labor rates.  This ICR uses the most recent labor rates from the Bureau of Labor Statistics in calculating the labor costs. 

6(g)  Burden Statement

--------------------------------------------------------------------------------
      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 4 hours per response.  Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
      An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number.  The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA - HQ - OECA - 2011 - 0241.  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) 566-1752.  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 - 2011 - 0241 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
                                     12.25
                                     24.5
                                                                     $26,997.03
  B.  Required activities:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
   i.  Initial performance tests  [c]    
                                      24
                                       1
                                      24
                                      245
                                     5,880
                                      294
                                      588
                                                                    $647,928.96
   ii.  Repeat performance tests  [c]  
                                      24
                                      0.2
                                      4.8
                                      245
                                     1,176
                                     58.8
                                     117.6
                                                                    $129,585.80
   iii.  Reference Method 9
                                       4
                                       1
                                       4
                                      245
                                      980
                                      49
                                      98
                                                                    $107,988.16
   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
                                     10.5
                                      21
                                                                     $23,140.32
   ii.  Notification of construction/ reconstruction   
                                       2
                                       1
                                       2
                                      105
                                      210
                                     10.5
                                      21
                                                                     $23,140.32
   iii.  Notification of physical or operational change   
                                       2
                                       1
                                      2.
                                      140
                                      280
                                      14
                                      28
                                                                     $30,853.76
   iii.  Notification of  performance test [c]
                                       2
                                      1.2
                                      2.4
                                      245
                                      588
                                     29.4
                                     58.8
                                                                     $64,792.90
   iv.  Reports of performance test results  
                                Included in  4B
                                       
                                       
                                       
                                       
                                       
                                                                              
  v.  Periodic reports [d]      
                                      N/A
 
                                       
                                       
                                       
                                       
                                       
                                                                              
SUBTOTAL Reporting
                                       
                                       
                                       
                                   11,004.35
                                                                               
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
                                     4,220
                                     6,330
                                     316.5
                                      633
                                                                    $697,515.36
F.  Time to train personnel
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
G. Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
SUBTOTAL Recordkeeping
                                       
                                       
                                       
                                       
                                    7,279.5
                                                                               
TOTAL LABOR BURDEN AND COST  (Rounded)
                                       
                                       
                                       
                                       
                                   18,283.85
                               18,284 (rounded)
                                                                     $1,751,943

Assumptions:
[a]   We have determined that approximately 95 percent of 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 140 existing facilities would be conducting modifications of their facilities.            
[b]   This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 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:  Average Annual EPA Burden and Cost: 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 (Ex0.10)
                                      (H)
                                   Cost, $ b
Notification of actual  startup date  
                                       2
                                       1
                                       2
                                      105
                                      210
                                     10.5
                                      21
                                                                     $10,883.14
Notification of construction/ reconstruction
                                       2
                                       1
                                       2
                                      105
                                      210
                                     01.5
                                      21
                                                                     $10,883.14
Notification of physical or operational change   
                                       2
                                       1
                                       2
                                      140
                                      280
                                      14
                                      28
                                                                     $14,510.86
Notification of performance 
test 
                                       2
                                      1.2
                                      2.4
                                      245
                                      588
                                     29.4
                                     58.8
                                                                     $30,472.81
Reports of performance test results [c]
                                       8
                                      1.2
                                      9.6
                                      245
                                     2,352
                                     117.6
                                     235.2
                                                                    $121,891.22
Periodic reports [d]
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
Subtotal Burden and Cost
                                       
                                       
                                       
                                       
                                     3,640
                                      182
                                      364
                                                                    $188,641.17
TOTAL ANNUAL BURDEN AND COST (rounded)
                                       
                                       
                                       
                                       
                                     4,186
                                                                       $188,641
            

Assumptions:
 a    We have determined that approximately 95 percent of 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 140 of the existing facilities 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  $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $15.63 x 1.6).  These rates are from the Office of Personnel Management (OPM) "2011 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. 
