PART
A
OF
THE
SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83
STATIONARY
RECIPROCATING
INTERNAL
COMBUSTION
ENGINES
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
(
a)
Title
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Stationary
Reciprocating
Internal
Combustion
Engines."

ICR1975.01
(
b)
Short
Characterization
This
supporting
statement
addresses
information
collection
activities
that
would
be
imposed
by
the
proposed
"
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Stationary
Reciprocating
Internal
Combustion
Engines,"
40
CFR
part
63,
subpart
ZZZZ.

These
standards
fulfill
the
requirements
of
section
112
of
the
Clean
Air
Act
(
CAA)
as
amended
in
1990,
which
requires
the
EPA
to
promulgate
standards
for
stationary
reciprocating
internal
combustion
engines
(
RICE).

The
information
collection
activities
in
this
ICR
include:
continuous
emission
monitoring,
stack
tests,
continuous
operating
parameter
monitoring,
one­
time
and
periodic
reports,
and
the
maintenance
of
records.
The
information
collection
activities
will
enable
the
EPA
to
determine
initial
and
continuous
compliance
with
emission
standards
for
the
regulated
pollutants.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
Need/
Authority
for
the
Collection
2
The
EPA
is
required
under
section
112
of
the
CAA
to
establish
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
that
reflect
the
maximum
achievable
control
technology
(
MACT)
for
achieving
continuous
emission
reductions.
Section
112(
d)
states:

Emissions
standards
promulgated
under
this
subsection
and
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
shall
require
the
maximum
degree
of
reduction
in
emissions
of
the
hazardous
air
pollutants
subject
to
this
section
that
the
Administrator,
taking
into
consideration
the
cost
of
achieving
such
emission
reduction,
and
any
non­
air
quality
health
and
environmental
impacts
and
energy
requirements,
determines
is
achievable
for
new
or
existing
sources
in
the
category
or
subcategory
to
which
such
emission
standard
applies
.
.
.
.

Section
112(
i)
further
states:

After
the
effective
date
of
any
emissions
standard,
limitation
or
regulation
promulgated
under
this
section
and
applicable
to
a
source,
no
person
may
operate
such
source
in
violation
of
such
standard,
limitation
or
regulation
.
.
.
.

In
addition,
section
114(
a)(
1)
states
that:

.
.
.
the
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source
or
who
is
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
or
methods,
(
D)
sample
such
emissions
(
in
accordance
with
such
methods,
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
E)
provide
such
other
information,
as
he
may
reasonably
require.

Certain
reports
are
necessary
to
enable
the
Administrator
to
identify
stationary
RICE
subject
to
the
proposed
regulation
and
to
determine
if
the
standards
are
being
achieved.

(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
the
EPA
to
identify
sources
subject
to
the
standards
and
ensure
that
the
emission
standards
are
being
met.
Records
and
reports
are
3
necessary
to
enable
the
EPA
to
identify
facilities
that
may
not
be
in
compliance
with
the
standards.
Based
on
reported
information,
EPA
will
decide
which
facilities
should
be
inspected
and
what
records
or
units
should
be
inspected
at
the
facilities.
The
records
that
facilities
maintain
will
indicate
to
EPA
whether
facility
personnel
are
operating
and
maintaining
the
equipment
properly.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
(
a)
Nonduplication
Duplication
in
the
reporting
of
stationary
RICE
information
is
not
anticipated.
If
the
standard
has
not
been
delegated,
the
information
is
sent
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
their
own
similar
regulation
to
implement
the
Federal
regulation,
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
standard.
Therefore,

no
duplication
exists.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
A
public
notice
of
this
collection
will
be
provided
in
the
notice
of
proposed
rulemaking
for
the
NESHAP.

(
c)
Consultations
In
September
1996,
the
EPA
chartered
the
Industrial
Combustion
Coordinated
Rulemaking
(
ICCR)
advisory
committee
under
the
Federal
Advisory
Committee
Act
4
(
FACA).
The
committee's
objective
was
to
develop
recommendations
for
regulations
for
several
combustion
source
categories
under
sections
112
and
129
of
the
CAA.
The
ICCR
advisory
committee,
known
as
the
Coordinating
Committee,
formed
Source
Work
Groups
for
the
various
combustor
types
covered
under
the
ICCR.
One
work
group,
the
RICE
Work
Group,
was
formed
to
research
issues
related
to
stationary
RICE.
The
RICE
Work
Group
submitted
recommendations,
information,
and
data
analysis
results
to
the
Coordinating
Committee,
which
in
turn
considered
them
and
submitted
recommendations
and
information
to
the
EPA.
The
Committee's
recommendations
were
considered
by
the
EPA
in
developing
these
regulations
for
stationary
RICE.

The
public
will
also
have
the
opportunity
to
review
and
comment
on
the
proposed
NESHAP
and
this
ICR
during
the
specified
comment
period.

(
d)
Effects
of
Less
Frequent
Data
Collection
The
frequency
of
the
proposed
data
collection
requirements
was
chosen
by
the
EPA
to
provide
reasonable
assurance
that
a
facility
is
in
compliance
with
the
standard.

Less
frequent
collection
could
result
in
long­
term
exceedances
of
the
applicable
emission
standards.

(
e)
General
Guidelines
With
the
exception
of
requiring
records
to
be
maintained
for
more
than
3
years,

none
of
the
guidelines
in
CFR
1320.5
are
being
exceeded.
This
rule
requires
all
records
to
be
maintained
for
a
period
of
5
years,
which
is
consistent
with
the
General
Provisions
under
40
CFR
part
63.

(
f)
Confidentiality
5
The
type
of
data
that
would
be
required
is
principally
emissions
data
and
would
not
be
confidential.
If
any
information
is
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made,
the
information
would
be
safeguarded
according
to
the
Agency
policies
set
forth
in
title
40,
chapter
1,
part
2,
subpart
B
­­
Confidentiality
of
Business
Information.

(
g)
Sensitive
Questions
This
section
is
not
applicable
because
the
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
(
a)
Respondents/
NAICS
Codes
Respondents
are
owners
or
operators
of
existing,
new
or
reconstructed
stationary
RICE
that
have
a
manufacturer's
nameplate
rating
greater
than
500
brake
horsepower
(
HP)
and
are
located
at
a
major
source
of
hazardous
air
pollutant
(
HAP)
emissions.
A
major
source
of
HAP
emissions
is
a
plant
site
that
emits
or
has
the
potential
to
emit
10
tons
or
more
per
year
of
any
single
HAP
or
25
tons
or
more
per
year
of
any
combination
of
HAPs.
These
standards
affect
any
industry,
State,
local,
or
tribal
government
using
a
stationary
RICE
as
defined
in
the
regulation.
The
North
American
Industrial
Classification
System
(
NAICS)
codes
for
facilities
using
stationary
RICE
affected
by
the
proposed
regulation
include:
2211
(
Electric
Power
Generation,
Transmission,
or
Distribution),

48621
(
Natural
Gas
Transmission),
211111
(
Crude
Petroleum
and
Natural
Gas
Production),
2111112
(
Natural
Gas
Liquids
Producers),
and
92811
(
National
Security).
6
(
b)
Information
Requested
(
i)
Data
Items:
Attachment
1,
Source
Data
and
Information
Requirements,

summarizes
the
recordkeeping
and
reporting
requirements
of
this
proposed
regulation.

(
ii)
Respondent
Activities:
The
respondent
activities
required
by
the
proposed
regulation
are
provided
under
the
first
column
of
Tables
2
through
4,
introduced
in
section
6(
a).

(
iii)
Summary
of
Monitoring
Requirements:
The
monitoring
activities
in
this
ICR
include:
continuous
emission
monitoring,
stack
tests,
and
continuous
operating
parameter
monitoring.
The
monitoring
requirements
are
dependent
on
engine
subcategory
and
size.
There
are
four
stationary
RICE
subcategories
that
have
monitoring
requirements:
spark
ignition,
two­
stroke
lean
burn
(
2SLB);
spark
ignition,
four­
stroke
lean
burn
(
4SLB);
spark
ignition,
four­
stroke
rich
burn
(
4SRB);
and
compression
ignition.

These
subcategories
are
then
further
divided
into
two
HP
ranges:
stationary
RICE
with
a
manufacturer's
nameplate
rating
less
than
5,000,
and
stationary
RICE
with
a
manufacturer's
nameplate
rating
greater
than
or
equal
to
5,000.
After
evaluating
the
ratio
of
total
control
and
monitoring
costs
to
the
equipment
costs,
the
EPA
determined
that
requirements
that
are
economically
feasible
for
larger
size
stationary
RICE
might
be
prohibitive
for
smaller
size
stationary
RICE.
Thus,
a
distinction
was
made
between
stationary
RICE
size,
and
less
burdensome
compliance
requirements
were
selected
for
smaller
size
stationary
RICE.

Spark
ignition,
2SLB
and
4SLB
stationary
RICE
and
compression
ignition
stationary
RICE
must
reduce
carbon
monoxide
(
CO)
emissions
by
a
specified
percentage
7
using
an
oxidation
catalyst.
Sources
in
these
subcategories
that
are
less
than
5,000
HP
must
conduct
an
initial
stack
test
for
CO
and
then
conduct
subsequent
stack
tests
quarterly.
These
sources
will
also
be
required
to
continuously
monitor
the
catalyst
pressure
drop
and
catalyst
inlet
temperature.
Sources
in
these
subcategories
that
are
greater
than
5,000
HP
must
conduct
continuous
monitoring
of
CO
emissions
at
the
inlet
and
outlet
of
the
oxidation
catalyst
using
a
continuous
emission
monitoring
system
(
CEMS).
Sources
must
conduct
a
performance
evaluation
of
the
CEMS
as
part
of
the
initial
compliance
demonstration,
and
conduct
an
annual
relative
accuracy
test
audit
(
RATA)
of
the
CEMS
.

Spark
ignition,
4SRB
stationary
RICE
must
reduce
formaldehyde
emissions
by
a
specified
percentage.
Facilities
must
conduct
an
initial
performance
test
for
formaldehyde
and
then
continuously
monitor
catalyst
pressure
drop
and
temperature
rise.
Facilities
greater
than
5,000
HP
must
also
conduct
annual
stack
tests
for
formaldehyde
to
demonstrate
compliance
with
the
standard.

Two
other
subcategories
of
stationary
RICE,
stationary
RICE
that
fire
landfill
and
digester
gas
as
primary
fuel
and
emergency
power/
limited
use
stationary
RICE,
are
required
to
submit
a
one­
time
initial
notification
but
have
no
monitoring
requirements.

The
following
stationary
RICE
do
not
have
to
meet
the
requirements
of
subpart
ZZZZ:

existing
spark
ignition
2SLB
and
4SLB
stationary
RICE,
existing
compression
ignition
stationary
RICE,
stationary
RICE
with
a
manufacturer's
nameplate
rating
of
500
HP
or
less,
and
stationary
RICE
located
at
area
sources
of
HAP
emissions.

The
proposed
NESHAP
allow
sources
to
meet
a
formaldehyde
emission
limitation
8
as
an
alternative
to
the
requirement
to
reduce
CO
or
formaldehyde
emissions
by
a
specified
percentage.
Sources
meeting
the
alternative
standard
would
have
different
monitoring
requirements
than
sources
meeting
the
requirement
to
reduce
CO
or
formaldehyde
emissions.
However,
the
EPA
does
not
expect
any
sources
to
meet
the
alternative
standard
for
5
to
10
years.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,

COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
(
a)
Agency
Activities
A
list
of
Agency
activities
for
the
first
3
years
following
the
effective
date
of
the
standard
is
provided
in
Tables
5
through
7,
which
are
introduced
in
section
6(
c).

(
b)
Collection
Methodology
and
Management
Data
obtained
during
periodic
visits
by
EPA
personnel,
from
records
maintained
by
the
respondents,
and
from
information
provided
in
semiannual
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.
The
proposed
rule
allows
records
to
be
retained
in
hard
copy
or
electronic
format
to
allow
flexibility
and
minimize
burden.

(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
for
the
EPA.
The
Stationary
RICE
NESHAP
is
applicable
only
to
major
sources.
The
RICE
MACT
does
not
apply
to
stationary
RICE
below
500
HP.
The
monitoring
and
compliance
requirements
for
stationary
RICE
between
500
HP
and
5000
9
HP
are
less
stringent
than
the
monitoring
requirements
for
stationary
RICE
above
5000
HP.
These
regulatory
provisions
provide
flexibility
in
compliance
and
monitoring
for
all
stationary
RICE
including
RICE
operated
by
small
entities.

We
do
not
believe
that
the
NESHAP
will
have
a
significant
impact
on
a
substantial
number
of
small
entities.
Furthermore,
although
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
these
requirements
are
considered
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
be
reduced
further
for
small
businesses.

(
d)
Collection
Schedule
Existing
sources
must
submit
an
initial
notification
that
the
source
is
subject
to
the
standard
within
120
days
after
the
source
becomes
subject
to
the
relevant
standard.
New
sources
for
which
construction
or
reconstruction
has
commenced
and
initial
startup
occurs
before
the
effective
date
of
this
standard
must
submit
an
initial
notification
no
later
than
120
days
after
the
effective
date
of
the
standard.
New
sources
for
which
the
construction
or
reconstruction
commenced
after
the
effective
date
of
the
standard
must
submit
the
following:
notification
of
construction/
reconstruction;
notification
of
anticipated
startup,

delivered
or
postmarked
not
more
than
60
days
or
less
than
30
days
before
anticipated
startup;
and
notification
of
actual
startup,
delivered
or
postmarked
within
15
days
after
actual
startup.

Sources
who
are
required
to
conduct
a
performance
test
or
performance
evaluation
must
submit
a
notification
60
days
prior
to
each
performance
test
or
performance
evaluation.
Sources
who
must
conduct
performance
testing
to
demonstrate
10
initial
compliance
must
submit
an
initial
notification
of
compliance
within
180
days
after
completion
of
the
initial
compliance
demonstration.
Sources
whose
initial
compliance
demonstration
does
not
include
performance
testing
must
submit
an
initial
notification
of
compliance
within
30
days
of
the
initial
compliance
demonstration.
All
facilities
must
submit
to
the
EPA
a
semiannual
compliance
report
that
includes
any
exceedances
and
malfunctions.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
(
a)
Estimating
Respondent
Burden
It
is
estimated
that
514
new
affected
facilities
will
come
online
in
each
of
the
next
3
years.
A
breakdown
of
the
number
of
new
facilities
each
year,
by
subcategory
and
horsepower
range,
is
given
in
Table
1.
Of
the
514
new
facilities
each
year,
407
will
have
four
stationary
RICE
per
facility
(
the
stationary
RICE
at
these
facilities
are
greater
than
500
HP
and
less
than
5,000
HP).
Two
facilities
will
have
only
one
stationary
RICE
per
facility
(
the
stationary
RICE
at
these
facilities
are
greater
than
or
equal
to
5,000
HP).

Three
other
facilities
will
have
digester
or
landfill
gas
stationary
RICE,
and
102
facilities
will
have
emergency
power
stationary
RICE.
The
digester
gas,
landfill
gas,
and
emergency
power
stationary
RICE
facilities
will
have
no
requirements
except
for
an
initial
notification.
No
reconstructed
stationary
RICE
are
projected
in
the
next
3
years.
The
impact
on
existing
facilities
was
not
included
because
these
facilities
do
not
have
to
comply
with
the
regulation
until
3
years
after
the
effective
date.
11
TABLE
1.
NUMBER
OF
NEW
STATIONARY
RICE
FACILITIES
PER
YEAR
Subcategory
Number
of
New
Facilities
Per
Year
Number
of
Stationary
RICE
Per
Facility
Spark
ignition,
2SLB
501
­
4999
HP

5000
HP
10
­­
4
­­

Spark
ignition,
4SLB
501
­
4999
HP

5000
HP
111
1
4
1
Spark
ignition,
4SRB
501
­
4999
HP

5000
HP
86
1
4
1
Compression
ignition
501
­
4999
HP

5000
HP
200
­­
4
­­

Landfill
and
digester
gas
3
1
Emergency
power
102
3
An
itemized
breakdown
of
the
reporting
and
recordkeeping
requirements
with
the
annual
cost
and
labor
requirements
for
the
respondents
subject
to
the
NESHAP
for
the
3­

year
period
following
promulgation
is
presented
in
Tables
2
through
4.
The
annual
cost
and
labor
respondent
burden
estimates
for
the
first
year
after
promulgation
are
provided
in
Table
2.
The
burden
estimates
for
years
2
and
3
are
presented
in
Tables
3
and
4,

respectively.
These
numbers
were
derived
from
the
EPA's
experience
with
other
standards
and
from
discussions
with
industry
representatives.

(
b)
Estimating
Respondent
Costs
The
information
collection
activities
for
sources
subject
to
these
requirements
are
presented
in
Tables
2
through
4.
The
total
cost
for
each
respondent
activity
includes
12
TABLE
2.
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
FOR
THE
FIRST
YEAR
Number
of
Capital/
Startup
Person­
hours
occurrences
Person­
hours
Respondents
Technical
Management
Clerical
Cost
O&
M
Cost
Total
Cost
($)

Burden
Item
per
occurrence
per
year
per
respondent
per
year
person­
hours
person­
hours
person­
hours
(
per
respondent)
(
per
respondent)
Year
1
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
4
1
4
514
2,056
103
206
100,230
B.
Required
Activities
­
Performance
Tests
­
4SRB
<
5000
HP
24
1
24
86
2,064
103
206
6,980,620
­
4SRB
>=
5000
HP
8
1
8
1
8
0
1
20,390
­
quarterly
24
4
96
321
30,816
1,541
3,082
1,502,280
­
Performance
Evaluation
12
1
12
1
12
1
1
12,232
C.
Gather
Existing
Information
Included
in
3D
D.
Write
Report
­
Notification
of
construction/
2
1
2
409
818
41
82
39,878
reconstruction
­
Notification
of
anticipated
startup
2
1
2
409
818
41
82
39,878
­
Notification
of
actual
startup
2
1
2
409
818
41
82
39,878
­
Notification
of
performance
evaluation
2
1
2
1
2
0.1
0.2
98
­
Notification
of
performance
test
­
one
time
per
year
2
1
2
87
174
9
17
8,483
­
quarterly
2
4
8
321
2,568
128
257
125,190
­
Initial
notification
for
exempt
RICE
2
1
2
105
210
11
21
10,238
­
Initial
notification
of
compliance
2
1
2
409
818
41
82
39,878
­
Compliance
report
4
2
8
409
3,272
164
327
159,510
4.
Recordkeeping
Requirements
A.
Read
Instructions
4
1
4
409
1,636
82
164
79,755
B.
Train
personnel
16
1
16
409
6,544
327
654
319,020
C.
Continuous
monitoring
­
Purchase
and
install
CEMS
120
1
120
1
120
6
12
23,421
29,271
­
CEMS
QA/
QC
0.5
365
183
1
183
9
18
2,870
11,767
­
Purchase
and
install
CPM
­
portable
CO
monitor
40
1
40
321
12,840
642
1,284
583
1,873
1,414,326
­
pressure
and
temp.
(
small
RICE)
40
1
40
407
16,280
814
1,628
1,708
1,488,806
­
pressure
and
temp.
(
large
RICE)
30
1
30
1
30
2
3
427
1,890
­
Record
information
0.5
12
6
409
2,454
123
245
119,633
SUBTOTAL
BURDEN
AND
COST
84,541
4,227
8,454
12,543,246
AVERAGE
PER
RESPONDENT
164
8
16
24,403
*
Costs
are
based
on
March
1999
Bureau
of
Labor
Statistics,
Employment
Cost
Trends
total
compensation
index
which
includes
wages,
salaries,
and
benefits.

Costs
are
estimated
using
the
following
hourly
rates:
technical
at
$
43,
management
at
$
59
and
clerical
at
$
28.
13
TABLE
3.
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
FOR
THE
SECOND
YEAR
Number
of
Capital/
Startup
Person­
hours
occurrences
Person­
hours
Respondents
Technical
Management
Clerical
Cost
O&
M
Cost
Total
Cost
($)

Burden
Item
per
occurrence
per
year
per
respondent
per
year
person­
hours
person­
hours
person­
hours
(
per
respondent)
(
per
respondent)
Year
2
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
4
1
4
514
2,056
103
206
100,230
B.
Required
Activities
­
Performance
Tests
­
4SRB
<
5000
HP
24
1
24
86
2,064
103
206
6,980,620
­
4SRB
>=
5000
HP
8
1
8
2
16
1
2
40,780
­
quarterly
24
4
96
642
61,632
3,082
6,163
3,004,560
­
Performance
Evaluation
12
1
12
1
12
1
1
12,232
­
Annual
RATA
12
1
12
1
12
1
1
8,756
C.
Gather
Existing
Information
Included
in
3D
D.
Write
Report
­
Notification
of
construction/
2
1
2
409
818
41
82
39,878
reconstruction
­
Notification
of
anticipated
startup
2
1
2
409
818
41
82
39,878
­
Notification
of
actual
startup
2
1
2
409
818
41
82
39,878
­
Notification
of
performance
evaluation
2
1
2
2
4
0.2
0.4
195
­
Notification
of
performance
test
­
one
time
per
year
2
1
2
88
176
9
18
8,580
­
quarterly
2
4
8
642
5,136
257
514
250,380
­
Initial
notification
for
exempt
RICE
2
1
2
105
210
11
21
10,238
­
Initial
notification
of
compliance
2
1
2
409
818
41
82
39,878
­
Compliance
report
4
2
8
818
6,544
327
654
319,020
4.
Recordkeeping
Requirements
A.
Read
Instructions
4
1
4
409
1,636
82
164
79,755
B.
Train
personnel
16
1
16
409
6,544
327
654
319,020
C.
Continuous
monitoring
­
Purchase
and
install
CEMS
120
1
120
2
120
6
12
23,421
52,692
­
CEMS
QA/
QC
0.5
365
183
2
365
18
37
2,870
23,534
­
Purchase
and
install
CPM
­
portable
CO
monitor
40
1
40
642
12,840
642
1,284
583
1,873
2,202,702
­
pressure
and
temp.
(
small
RICE)
40
1
40
814
16,280
814
1,628
1,708
2,183,962
­
pressure
and
temp.
(
large
RICE)
30
1
30
2
30
2
3
427
2,317
­
Record
information
0.5
12
6
818
4,908
245
491
239,265
SUBTOTAL
BURDEN
AND
COST
123,857
6,193
12,386
15,998,347
AVERAGE
PER
RESPONDENT
134
7
13
17,333
*
Costs
are
based
on
March
1999
Bureau
of
Labor
Statistics,
Employment
Cost
Trends
total
compensation
index
which
includes
wages,
salaries,
and
benefits.

Costs
are
estimated
using
the
following
hourly
rates:
technical
at
$
43,
management
at
$
59
and
clerical
at
$
28.
14
TABLE
4.
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
FOR
THE
THIRD
YEAR
Number
of
Capital/
Startup
Person­
hours
occurrences
Person­
hours
Respondents
Technical
Management
Clerical
Cost
O&
M
Cost
Total
Cost
($)

Burden
Item
per
occurrence
per
year
per
respondent
per
year
person­
hours
person­
hours
person­
hours
(
per
respondent)
(
per
respondent)
Year
3
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
4
1
4
514
2,056
103
206
100,230
B.
Required
Activities
­
Performance
Tests
­
4SRB
<
5000
HP
24
1
24
86
2,064
103
206
6,980,620
­
4SRB
>=
5000
HP
8
1
8
3
24
1
2
61,170
­
quarterly
24
4
96
963
92,448
4,622
9,245
4,506,840
­
Performance
Evaluation
12
1
12
1
12
1
1
12,232
­
Annual
RATA
12
1
12
2
24
1
2
17,512
C.
Gather
Existing
Information
Included
in
3D
D.
Write
Report
­
Notification
of
construction/
2
1
2
409
818
41
82
39,878
reconstruction
­
Notification
of
anticipated
startup
2
1
2
409
818
41
82
39,878
­
Notification
of
actual
startup
2
1
2
409
818
41
82
39,878
­
Notification
of
performance
evaluation
2
1
2
3
6
0.3
0.6
293
­
Notification
of
performance
test
­
one
time
per
year
2
1
2
89
178
9
18
8,678
­
quarterly
2
4
8
963
7,704
385
770
375,570
­
Initial
notification
for
exempt
RICE
2
1
2
105
210
11
21
10,238
­
Initial
notification
of
compliance
2
1
2
409
818
41
82
39,878
­
Compliance
report
4
2
8
1,227
9,816
491
982
478,530
4.
Recordkeeping
Requirements
A.
Read
Instructions
4
1
4
409
1,636
82
164
79,755
B.
Train
personnel
16
1
16
409
6,544
327
654
319,020
C.
Continuous
monitoring
­
Purchase
and
install
CEMS
120
1
120
3
120
6
12
23,421
76,113
­
CEMS
QA/
QC
0.5
365
183
3
548
27
55
2,870
35,301
­
Purchase
and
install
CPM
­
portable
CO
monitor
40
1
40
963
12,840
642
1,284
583
1,873
2,991,078
­
pressure
and
temp.
(
small
RICE)
40
1
40
1,221
16,280
814
1,628
1,708
2,879,118
­
pressure
and
temp.
(
large
RICE)
30
1
30
3
30
2
3
427
2,744
­
Record
information
0.5
12
6
1,227
7,362
368
736
358,898
SUBTOTAL
BURDEN
AND
COST
163,174
8,159
16,317
19,453,447
AVERAGE
PER
RESPONDENT
123
6
12
14,605
*
Costs
are
based
on
March
1999
Bureau
of
Labor
Statistics,
Employment
Cost
Trends
total
compensation
index
which
includes
wages,
salaries,
and
benefits.

Costs
are
estimated
using
the
following
hourly
rates:
technical
at
$
43,
management
at
$
59
and
clerical
at
$
28.
15
labor
costs,
capital/
startup
costs,
and
operation
and
maintenance
(
O&
M)
costs.

(
i)
Estimating
Labor
Costs
Labor
rates,
on
a
per­
hour
basis,
are
taken
from
the
Bureau
of
Labor
Statistics
(
BLS)
web
site
(
http://
stats.
bls.
gov/
news.
release)
as
posted
for
March
1999.
The
base
labor
rates
are
$
18.59
for
technical
personnel,
$
25.31
for
management,
and
$
11.90
for
clerical.
The
total
compensation
rate
is
$
25.72
for
technical
personnel,
$
35.18
for
managerial,
and
$
16.63
for
clerical.
This
accounts
for
paid
leave,
insurance,
etc.
The
compensation
rates
were
then
adjusted
by
an
overhead
and
profit
rate
of
167
percent.
The
final
total
wage
rates
are
$
43
for
technical
personnel,
$
59
for
management,
and
$
28
for
clerical.

Labor
costs
for
formaldehyde
performance
tests
and
the
CEMS
performance
evaluation
and
RATA
were
estimated
through
contact
with
the
testing
industry.
Each
formaldehyde
performance
test
is
assumed
to
cost
$
20,000
per
stationary
RICE,
and
each
CEMS
performance
evaluation
is
$
12,232.
The
cost
of
the
annual
RATA
is
$
8,756
per
year.

(
ii)
Estimating
Capital/
Startup
Costs
Capital
costs
associated
with
this
NESHAP
result
from
the
purchase
and
installation
of
CEMS,
portable
CO
monitors,
and
a
continuous
parameter
monitoring
system
(
CPMS).
The
facilities
that
have
stationary
RICE
greater
than
5,000
HP
are
required
to
have
a
CEMS;
all
other
facilities
will
have
a
CPMS,
and
the
EPA
estimated
that
each
stationary
RICE
will
have
its
own
CPMS.

Capital
costs
are
based
on
consultation
with
equipment
vendors
and
industry
experts.
The
estimated
CEMS
total
annualized
capital
cost
is
$
23,421
per
CEMS.
Portable
CO
monitors
are
expected
to
have
an
annualized
capital
cost
of
$
583.
Each
facility
can
purchase
one
portable
CO
monitor
and
use
it
for
several
stationary
RICE.
The
annualized
capital
cost
of
a
CPMS
for
pressure
drop
and
temperature
monitoring
is
$
427
per
CPMS.
16
(
iii)
Total
Operation
and
Maintenance
Costs
Costs
associated
with
operation
and
maintenance
(
O&
M)
are
the
annual
operating
and
maintenance
costs
of
the
CEMS
and
portable
CO
monitors.
These
costs
were
also
estimated
through
contact
with
equipment
vendors
and
industry
experts.
The
estimated
total
annual
O&
M
cost
of
each
CEMS
is
$
2,870.
The
estimated
total
annual
O&
M
cost
of
each
portable
CO
monitor
is
$
1,873
per
facility.

(
c)
Estimating
Agency
Burden
and
Cost
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Examination
of
records
to
be
maintained
by
the
respondents
would
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.

The
Agency
burden
and
cost
estimates
include
only
those
items
where
the
government
would
incur
additional
costs
as
a
result
of
the
information
collection.
These
costs
include
user
costs
associated
with
the
review
and
analysis
of
the
reported
information.
These
are
presented
in
Tables
5
through
7.
17
TABLE
5.
FEDERAL
GOVERNMENT
BURDEN
AND
COST
FOR
THE
FIRST
YEAR
Technical
Management
Clerical
EPA
hours
Operations
person­
hours
person­
hours
person­
hours
Total
Cost
($)

Activity
per
operation
per
year
per
year
per
year
per
year
Year
1
Report
Review
1.
Notification
of
construction/
reconstruction
1
409
409
20
41
19,080
2.
Notification
of
anticipated
startup
0.5
409
204
10
20
9,540
3.
Notification
of
actual
startup
0.5
409
204
10
20
9,540
4.
Notification
of
performance
evaluation
2
1
2
0.1
0.2
93
5.
Notification
of
performance
test
2
1,371
2,742
137
274
127,914
6.
Initial
notification
for
exempt
RICE
0.5
105
52
3
5
2,449
7.
Initial
notification
of
compliance
2
409
818
41
82
38,160
8.
Compliance
Report
2
818
1,636
82
164
76,319
SUBTOTAL
BURDEN
AND
COST
6,068
303
607
283,096
*
Costs
are
based
on
January
2000
Office
of
Personnel
Management
labor
statistics
for
Federal
Workers.
Costs
are
estimated
using
the
following
hourly
rates:
technical
at
$
41,
management
at
$
67,
and
clerical
at
$
23.
18
TABLE
6.
FEDERAL
GOVERNMENT
BURDEN
AND
COST
FOR
THE
SECOND
YEAR
Technical
Management
Clerical
EPA
hours
Operations
person­
hours
person­
hours
person­
hours
Total
Cost
($)

Activity
per
operation
per
year
per
year
per
year
per
year
Year
2
Report
Review
1.
Notification
of
construction/
reconstruction
1
409
409
20
41
19,080
2.
Notification
of
anticipated
startup
0.5
409
204
10
20
9,540
3.
Notification
of
actual
startup
0.5
409
204
10
20
9,540
4.
Notification
of
performance
evaluation
2
2
4
0.2
0.4
187
5.
Notification
of
performance
test
2
2,656
5,312
266
531
247,805
6.
Initial
notification
for
exempt
RICE
0.5
105
52
3
5
2,449
7.
Initial
notification
of
compliance
2
409
818
41
82
38,160
8.
Compliance
Report
2
1,636
3,272
164
327
152,639
SUBTOTAL
BURDEN
AND
COST
10,276
514
1,028
479,399
*
Costs
are
based
on
January
2000
Office
of
Personnel
Management
labor
statistics
for
Federal
Workers.
Costs
are
estimated
using
the
following
hourly
rates:
technical
at
$
41,
management
at
$
67,
and
clerical
at
$
23.
19
TABLE
7.
FEDERAL
GOVERNMENT
BURDEN
AND
COST
FOR
THE
THIRD
YEAR
Technical
Management
Clerical
EPA
hours
Operations
person­
hours
person­
hours
person­
hours
Total
Cost
($)

Activity
per
operation
per
year
per
year
per
year
per
year
Year
3
Report
Review
1.
Notification
of
construction/
reconstruction
1
409
409
20
41
19,080
2.
Notification
of
anticipated
startup
0.5
409
204
10
20
9,540
3.
Notification
of
actual
startup
0.5
409
204
10
20
9,540
4.
Notification
of
performance
evaluation
2
3
6
0.3
0.6
280
5.
Notification
of
performance
test
2
3,941
7,882
394
788
367,695
6.
Initial
notification
for
exempt
RICE
0.5
105
52
3
5
2,449
7.
Initial
notification
of
compliance
2
409
818
41
82
38,160
8.
Compliance
Report
2
2,454
4,908
245
491
228,958
SUBTOTAL
BURDEN
AND
COST
14,484
724
1,448
675,702
*
Costs
are
based
on
January
2000
Office
of
Personnel
Management
labor
statistics
for
Federal
Workers.
Costs
are
estimated
using
the
following
hourly
rates:
technical
at
$
41,
management
at
$
67,
and
clerical
at
$
23.
20
The
hourly
burden
for
review
of
reports
was
estimated
through
discussion
with
personnel
from
local
agencies
who
review
these
types
of
reports.
Labor
rates
for
Federal
employees
are
based
on
the
January
2000
Office
of
Personnel
Management
pay
rates
for
General
Schedule
employees
(
see
http://
www.
opm.
gov/
oca/
2000tbls/
GShrly/
html/
GSHRBASE.
HTM).
The
pay
rates
were
multiplied
by
the
standard
government
benefits
multiplication
factor
of
1.6.
The
average
hourly
labor
costs
are
$
41
for
technical
personnel,
$
67
for
management,
and
$
23
for
clerical.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
respondent
universe
was
estimated
through
projected
industry
orders
for
stationary
RICE.
It
is
estimated
that
514
new
facilities
will
come
online
in
each
of
the
next
3
years.
The
proposed
NESHAP
will
therefore
affect
1,542
new
facilities
over
the
next
3
years.
The
total
burden
is
calculated
by
adding
the
total
technical,
management,
and
clerical
hours
per
year.
The
technical
hours
are
calculated
by
multiplying
the
total
hours
per
respondent
by
the
number
of
respondents
per
year
for
each
respondent
activity.
Management
and
clerical
hours
are
assumed
to
be
5
percent
and
10
percent
of
the
technical
hours,
respectively.

The
total
cost
is
calculated
by
summing
the
labor,
capital/
startup,
and
O&
M
costs.
With
the
exception
of
the
costs
for
formaldehyde
performance
tests
and
the
CEMS
performance
evaluation
and
RATA,
the
labor
costs
are
determined
by
multiplying
the
total
labor
hours
by
the
total
wage
rate
for
each
labor
category.
The
total
capital/
startup
and
O&
M
costs
are
calculated
by
multiplying
the
cost
for
each
respondent
by
the
number
of
respondents.
Total
cost
is
presented
in
the
far
right
column
of
each
table.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
A
breakdown
for
each
of
the
collection,
reporting,
and
21
recordkeeping
activities
required
by
the
proposed
NESHAP
is
presented
in
Tables
2
through
4.

The
estimate
of
total
annual
hours
requested
from
the
respondents
was
based
on
the
assumptions
outlined
in
section
6(
d)
of
this
supporting
statement.
The
EPA
estimated
the
respondent
burden
by
totaling
the
hours
for
the
first
3
years
after
the
implementation
of
the
NESHAP
for
technical,

managerial,
and
clerical
staff
at
the
facility,
and
then
dividing
that
total
by
three
to
determine
the
average
annualized
burden.
The
3­
year
summary
results
are
presented
in
Table
8.
For
the
first
3
years
after
the
implementation
of
the
NESHAP,
the
EPA
estimates
that
industry
would
expend
142,436
hours
annually
at
a
cost
of
$
15,998,347
per
year
to
meet
the
monitoring,
recordkeeping,

and
reporting
requirements.

(
ii)
The
Agency
Tally
A
breakdown
for
each
of
the
Agency
activities
required
for
the
NESHAP
is
provided
in
Tables
5
through
7.
The
bottom
line
Agency
burden
hours
and
costs,

presented
in
Table
9,
are
calculated
by
totaling
the
hours
per
year
for
technical,
managerial,
and
clerical
staff,
and
by
totaling
the
cost
column.
The
average
annual
burden
is
calculated
by
dividing
the
3­
year
total
by
three.
The
estimated
average
annual
burden,
over
the
first
3
years,
for
the
Agency
would
be
11,818
hours
at
a
cost
of
$
479,399
per
year.

(
iii)
Variations
in
the
Annual
Bottom
Line
The
total
number
of
respondent
labor
hours
in
the
first
year
for
each
facility
is
189
hours
(
97,222/
514
=
189).
This
represents
a
total
cost
to
this
respondent
of
$
24,403
($
12,543,246/
514
=
$
24,403)
in
the
22
TABLE
8.
SUMMARY
OF
RESPONDENT
BURDEN
AND
COST
Number
of
Technical
Management
Clerical
Total
Year
Respondents
person­
hours
person­
hours
person­
hours
person­
hours
Total
Cost
($)

First
514
84,541
4,227
8,454
97,222
12,543,246
Second
923
123,857
6,193
12,386
142,436
15,998,347
Third
1,332
163,174
8,159
16,317
187,650
19,453,447
Three
Year
Total
371,571
18,579
37,157
427,307
47,995,040
Annual
Average
123,857
6,193
12,386
142,436
15,998,347
*
Costs
are
based
on
March
1999
Bureau
of
Labor
Statistics,
Employment
Cost
Trends
total
compensation
index
which
includes
wages,

Costs
are
estimated
using
the
following
hourly
rates:
technical
at
$
43,
management
at
$
59
TABLE
9.
SUMMARY
OF
AGENCY
BURDEN
AND
COST
Number
of
Technical
Management
Clerical
Total
Year
Respondents
person­
hours
person­
hours
person­
hours
person­
hours
Total
Cost
($)

First
514
6,069
303
607
6,979
283,096
Second
923
10,277
514
1,028
11,818
479,399
Third
1,332
14,485
724
1,448
16,657
675,702
Three
Year
Total
30,830
1,541
3,083
35,454
1,438,196
Annual
Average
10,277
514
1,028
11,818
479,399
*
Costs
are
based
on
January
2000
Office
of
Personnel
Management
labor
statistics
for
Federal
Workers.
Costs
the
following
hourly
rates:
technical
at
$
41,
management
at
$
67,
and
23
first
year.
In
the
second
year
the
respondent
hours
and
costs
for
each
facility
would
decrease
to
154
and
$
17,333;
respectively.
In
the
third
year
the
respondent
hours
would
be
141
and
the
costs
would
be
$
14,605.

The
total
burden
and
cost
estimates
for
the
first
3
years
after
the
NESHAP
is
promulgated
are
given
in
Tables
2
through
4
and
Table
8.
The
variation
in
total
activity
and
respondent
burden
and
cost
from
year
to
year
is
shown
in
the
tables.
In
years
1,
2,
and
3,
the
total
costs
are
$
12,543,246;
$
15,998,347;
and
$
19,453,447;
respectively
(
see
Tables
2
through
4
and
8).
In
year
1,
514
facilities
are
in
startup
phase.
In
year
2,
514
facilities
are
in
startup
phase
and
514
are
under
normal
operation.
By
the
third
year,
1,028
facilities
are
under
normal
operation,
while
514
are
in
startup
mode.

The
total
number
of
agency
hours
for
review
of
reports
also
varies
as
more
units
start
up
and
as
the
plants
progress
from
startup
reporting
to
annual
compliance
reporting.
The
total
number
of
agency
hours
for
years
1,
2,
and
3
are
6,979;
11,818;
and
16,657.
The
corresponding
agency
costs
for
activities
during
these
years
are
$
283,096;
$
479,399;
and
$
675,702
(
see
Table
9).

(
f)
Reasons
for
Change
in
Burden
This
is
the
initial
estimation
of
burden
for
this
ICR;
therefore
this
section
does
not
apply.

(
g)
Burden
Statement
Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
20
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
24
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
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
No.
OAR­
2002­
0025,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,

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
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
25
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0025).
26
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Recordkeeping
Requirements
40
CFR
63
Subpart
ZZZZ
5­
year
retention
of
records
63.6660(
b)

Records
of
all
notifications
and
reports
63.6655(
a)(
1)

Records
of
the
occurrence
and
duration
of
each
startup,
shutdown,
or
malfunction
of
the
stationary
RICE
and
each
malfunction
of
the
air
pollution
control
equipment
63.6655(
a)(
2)

Records
of
performance
tests
and
performance
evaluations
63.6655(
a)(
3)

Records
of
any
malfunction
of
the
CEMS
63.6655(
b)(
1)

All
CEMS
calibration
checks
63.6655(
b)(
1)

All
adjustments
and
maintenance
performed
on
CEMS
63.6655(
b)(
1)

Previous
(
i.
e.,
superseded)
versions
of
the
performance
evaluation
plan
63.6655(
b)(
2)

Request
for
alternatives
to
the
relative
accuracy
test
audit
63.6655(
b)(
3)

Records
of
the
date
and
time
that
each
deviation
started
and
stopped,
and
whether
the
deviation
occurred
during
a
period
of
malfunction
or
during
another
period
63.6655(
b)(
4)

Records
of
the
catalyst
pressure
drop
and
catalyst
inlet
temperature/
catalyst
temperature
rise
(
4­
hour
average)
63.6655(
c)

Records
of
the
average
reduction
of
CO
emissions
determined
from
CEMS
measurements
before
and
after
the
oxidation
emission
control
device,
using
a
4­
hour
average,
averaged
every
hour
63.6655(
c)
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Reporting
Requirements
40
CFR
63
Subpart
ZZZZ
Report
the
following
information
semiannually:
­
company
name
and
address
­
name,
title,
and
signature
of
the
responsible
official
certifying
the
accuracy
of
the
report
­
date
of
report
and
beginning
and
ending
dates
of
the
reporting
period
­
if
no
deviations
occurred
during
the
period,
a
statement
that
no
deviations
occurred
­
information
on
deviations,
startup,
shutdown,
and
malfunctions
63.6650
Report
the
following
information
by
fax
or
telephone
within
2
working
days
after
starting
actions
inconsistent
with
the
SSMP:
­
an
immediate
startup,
shutdown,
and
malfunction
report
which
contains
actions
taken
for
the
event
63.6650
Report
the
following
information
by
letter
within
7
working
days
after
the
end
of
the
event,
unless
alternative
arrangements
have
been
made
with
the
permitting
authorities:
­
name,
title,
and
signature
of
the
responsible
official
who
is
certifying
the
accuracy
of
the
report
­
the
circumstances
of
the
event
­
the
reasons
for
not
following
the
startup,
shutdown,
and
malfunction
plan
63.6650
