1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emissions
Standards
for
Hazardous
Air
Pollutants
for
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
Operations."
This
is
a
new
information
collection
request
(
ICR),

and
the
U.
S.
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
ICR
is
2056.01.

(
b)
Short
Characterization
This
ICR
is
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
proposed
rulemaking
being
developed
under
authority
of
Section
112
of
the
Clean
Air
Act
(
Act).
The
proposed
rulemaking
would
amend
title
40,
chapter
I,
part
63
of
the
Code
of
Federal
Regulations
(
CFR)
by
adding
a
new
subpart
MMMM­­

National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Category:
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
Operations.
The
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
Operations
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAP).

(
i)
Applicability:
Respondents
are
owners
and
operators
of
2
new
and
existing
facilities
that
engage
in
the
surface
coating
of
miscellaneous
metal
parts
and
products
and
emit
hazardous
air
pollutants
(
HAP's).
Fifteen
hundred
existing
facilities
are
expected
to
meet
the
applicability
criteria
defined
in
the
proposed
rule.
Forty
five
new
facilities
are
expected
to
be
constructed
in
each
of
the
next
5
years.

(
ii)
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
Operations:
Owners
or
operators
of
facilities
engaged
in
the
surface
coating
of
miscellaneous
metal
parts
and
products
to
which
this
regulation
is
applicable
must
choose
one
of
the
compliance
options
described
in
the
proposed
rule,
which
may
include
1)
using
compliant
materials,
2)
averaging
materials,
3)

installing
and
monitoring
a
specific
control
system
that
reduces
HAP
emissions
to
the
compliance
level,
or
4)
a
combination
of
these
options.
The
respondents
would
be
subject
to
those
sections
of
subpart
A
of
40
CFR
part
63
that
relate
to
NESHAP.

These
requirements
include
those
associated
with
the
notification
of
compliance
status
for
the
first
monthly
compliance
period,
and
semiannually
thereafter.

(
iii)
Record
Retention:
Owners
or
operators
of
facilities
that
are
engaged
in
the
surface
coating
of
miscellaneous
metal
parts
and
products
must
maintain
a
copy
of
all
specified
records
for
a
minimum
of
five
years.
Each
record
must
be
kept
onsite
for
at
least
the
first
two
years
after
the
date
of
each
occurrence,
3
measurement,
maintenance,
corrective
action,
report,
or
record.

The
records
can
be
kept
offsite
for
the
remaining
three
years.

All
records
are
to
be
submitted
upon
request
to
EPA
or
the
respondent's
State
or
local
agency,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
or
not
facilities
subject
to
the
NESHAP
are
achieving
the
standards.

(
iv)
Reports:
The
proposed
rule
relies
in­
part
on
the
provisions
of
subpart
A
of
40
CFR
part
63.
A
table
included
in
the
proposed
rule
designates
certain
sections
of
subpart
A
that
apply
to
the
proposed
rule.
Specific
recordkeeping
and
reporting
requirements
for
each
type
of
emission
compliance
option
are
also
included
in
the
proposed
rule.

The
following
reports
must
be
submitted
to
the
Administrator
as
appropriate:
(
1)
Initial
notification,
(
2)
Notification
of
Compliance
Status
Report,
(
3)
Semiannual
Compliance
Reports,
and
(
4)
Other
Reports
as
requested
by
the
Administrator.
The
requirements
for
each
of
the
four
reports
are
summarized
in
the
proposed
rule.

2.
Need
For
and
Use
of
the
Collection
The
EPA
is
required
under
section
112(
d)
of
the
Clean
Air
Act
(
the
Act)
to
regulate
emissions
of
HAP's
listed
in
section
112(
b).
The
predominant
HAP's
emitted
from
miscellaneous
metal
parts
and
products
surface
coating
operations
include
4
xylenes,
toluene,
methyl
ethyl
ketone,
phenol,
and
cresols/
cresylic
acid.

In
the
Administrator's
judgement,
the
pollutants
emitted
from
miscellaneous
metal
parts
and
products
surface
coating
operations
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.

Therefore,
this
source
category
was
listed
for
regulation
under
section
112.

Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
facilities
subject
to
the
standard
and
to
ensure
that
the
standard,
which
is
based
on
maximum
achievable
control
technology
(
MACT)
specific
to
miscellaneous
metal
parts
and
products
surface
coating
operations,
is
being
achieved.

These
records
and
reports
are
required
under
the
General
Provisions
of
40
CFR
part
63,
subpart
A
(
as
authorized
under
sections
101,
112,
114,
116,
and
301
of
the
Act
as
amended
by
Pub.
L
101­
549
[
42
U.
S.
C.
7401,
7412,
7414,
7416,
7601]).

(
a)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
Agency
enforcement
personnel
to
(
1)
identify
new,
modified,
reconstructed,
and
existing
facilities
subject
to
the
standards;
and
(
2)
ensure
that
MACT
is
being
properly
applied
and
that
compliance
is
being
maintained
and
documented.

In
addition,
records
and
reports
are
necessary
to
enable
the
5
Agency
to
identify
facilities
that
are
not
in
compliance
with
the
standards.
Based
on
reported
information,
the
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
operations
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
would
indicate
to
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
standards.

Much
of
the
information
the
EPA
would
need
to
determine
compliance
would
be
recorded
and
compiled
monthly.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection.

3.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Code
Respondents
are
owners
or
operators
of
facilities
that
perform
surface
coating
of
miscellaneous
metal
parts
and
products
and
that
are
classified
as
major
sources
under
section
112
of
CAA.
In
general,
facilities
that
coat
miscellaneous
metal
parts
and
products
are
covered
under
the
North
American
Industrial
Classification
System
(
NAICS)
and
Standard
Industrial
Classification
(
SIC)
codes
listed
in
the
table
below.
However,

facilities
classified
under
other
NAICS
or
SIC
codes
may
be
subject
to
the
proposed
standard
if
they
meet
the
applicability
criteria.
Not
all
facilities
classified
under
the
NAICS
and
SIC
codes
in
the
table
will
be
subject
to
the
proposed
standard
PRODUCT
EXAMPLES
AND
CORRESPONDING
NAICS
AND
SIC
CODES
FOR
MISCELLANEOUS
METAL
PARTS
AND
PRODUCTS
SOURCE
CATEGORY
(
Continued)

6
because
some
of
the
classifications
cover
products
outside
the
scope
of
the
NESHAP
for
miscellaneous
metal
parts
and
products.

PRODUCT
EXAMPLES
AND
CORRESPONDING
NAICS
AND
SIC
CODES
FOR
MISCELLANEOUS
METAL
PARTS
AND
PRODUCTS
SOURCE
CATEGORY
Segment
Description
Example
Products
Example
SIC
Example
NAICS
Aerospace
Equipment
Engines
and
Turbines,
Aircraft
Engines
and
Engine
Parts,
Aircraft
Parts
and
Auxiliary
Equipment
Aircraft
Engines,
Aircraft
Parts,
Aerospace
Ground
Equipment
3724,
3728,
376X,
336413,
336414,
336415,
54171
Automobile
Parts
Motor
Vehicles
and
Motor
Vehicle
Equipment
Engine
Parts,
Vehicle
Parts
and
Accessories,
Brakes,
Axles,
etc.
3711,
3713,
3714,
3292,
3429,
3465,
3694,
3829
335312,
336111,
336211,
336312,
33632,
33633,
33634,
33637,
336399
Extruded
Aluminum
Rolling,
Drawing,
and
Extruding
of
Nonferrous
Metals
Extruded
Aluminum,
Architectural
Components,
Coils,
Rod,
and
Tubes
3354,
3365,
3442,
3446
331316,
331524,
332321,
332323
Heavy
Equipment
Farm
and
Garden
Machinery
and
Equipment,
Construction
Machinery
and
Equipment
Tractors,
Earth
moving
machinery
3511,
3519,
352X,
353X,
33312,
333611,
333618
PRODUCT
EXAMPLES
AND
CORRESPONDING
NAICS
AND
SIC
CODES
FOR
MISCELLANEOUS
METAL
PARTS
AND
PRODUCTS
SOURCE
CATEGORY
(
Continued)

Segment
Description
Example
Products
Example
SIC
Example
NAICS
7
Job
Shops
Coat
Products
by
Job
and
Customer
Rather
than
Coating
the
One
Product
or
Group
of
Products
Any
of
the
Products
from
the
MMPP
Segments
3441,
3471,
3499,
3999
332312,
332722,
332813,
332991,
332999,
334119,
336413,
339999
Large
Trucks
and
Buses
Motor
Vehicles
and
Motor
Vehicle
Equipment
Large
Trucks,
Buses
3711,
3713,
3716
33612,
336211
Magnet
Wire
Rolling,
Drawing,
and
Extruding
of
Nonferrous
Metal
Wire
Magnet
Wire
3351,
3357
331319,
331422,
335929
Metal
Buildings
Prefabricated
Metal
Buildings
and
Components
Prefabricated
Metal:
Buildings,
Carports,
Docks,
Dwellings,
Greenhouses,
Panels
for
Buildings
3448
332311
Metal
Containers
Metal
Shipping
Barrels,
Drums,
Kegs,
and
Pails
Drums,
Kegs,
Pails,
Shipping
Containers
2655,
3089,
3325,
3412,
3443,
5085
33242,
81131,
322214,
326199,
331513,
332439
Metal
Pipe
and
Foundry
Primary
Metal
Industries
Plate,
Tube,
Rods,
Nails,
Spikes,
etc.
331X,
332X,
336X,
3399
331111,
331513,
33121,
331221,
331511
Rail
Transportation
Transportation
Equipment
Brakes,
Engines,
Freight
Cars,
Locomotives
3731,
3743,
4011,
4741
33651,
336611,
482111
Recreational
Vehicles
Transportation
Equipment
Motorcycles,
Motor
Homes,
Semitrailers,
Truck
Trailers
3083,
3354,
3713,
3714,
3716,
375X,
3792
3369,
331316,
336991,
336211,
336112,
336213,
336214,
336399
Rubber
to
Metal
Products
Fabricated
Rubber
Products
(
applied
to
metal)
Engine
Mounts,
Rubberized
Tank
Tread,
Harmonic
Balancers
3061,
3069,
3479
326291,
326299
PRODUCT
EXAMPLES
AND
CORRESPONDING
NAICS
AND
SIC
CODES
FOR
MISCELLANEOUS
METAL
PARTS
AND
PRODUCTS
SOURCE
CATEGORY
(
Concluded)

Segment
Description
Example
Products
Example
SIC
Example
NAICS
8
Structural
Steel
Fabricated
Structural
Metal
Products
Joists,
railway
bridge
sections,
highway
bridge
sections
3441,
3448
332311,
332312
Other
Transportation
Equipment
Transportation
Equipment
Not
Listed
Otherwise
Miscellaneous
Transportation
Related
Equipment
and
Parts
3711,
3519,
3714,
3715,
3795,
3621,
336212,
336999,
33635,
56121,
8111,
56211
(
b)
Information
Requested
(
i)
Data
items:
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
activities:
The
respondent
activities
required
by
the
standards
in
the
first
3
years
following
the
effective
date
are
described
in
Attachment
2.
The
assumptions
used
to
develop
the
estimated
burden
on
affected
facilities
are
presented
in
Attachment
3.
The
respondent
activities
and
corresponding
burden
estimates
are
listed
in
the
first
two
columns
of
Tables
1
through
11,
which
are
presented
in
Attachment
4.
Tables
12
through
14
also
show
the
calculated
burden
for
the
entire
industry
for
each
year
after
the
effective
date
of
the
rule.
Individual
tables
for
existing
and
for
new
facilities
for
each
of
the
first
3
years
after
the
effective
date
were
developed
9
because
the
annual
burden
varied
during
each
of
the
first
3
years.
Tables
were
also
developed
for
the
second
3­
year
period
after
the
effective
date
of
the
rule
because
existing
facilities
will
not
be
required
to
comply
with
the
rule
until
three
years
after
the
rule
is
final.
Therefore,
on
an
industrywide
basis,

most
of
the
recordkeeping
and
reporting
burden
is
not
required
until
the
fourth
year
after
the
effective
date
of
the
rule.

4.
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
Agency
activities
for
the
first
3
years
following
the
effective
date
of
the
standards
are
provided
in
Tables
15
through
17
in
Attachment
4,
and
are
discussed
in
section
6c.
Individual
tables
for
each
of
the
first
3
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
each
year.
Tables
18
through
20
show
the
Agency
burden
for
the
second
three
year
period
after
the
rule
is
in
effect,
and
Table
21
shows
a
summary
of
the
burden
by
year.

(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time
only
reports
will
be
entered
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
operated
and
maintained
by
the
Agency's
Office
of
Air
Quality
Planning
and
Standards.
Data
obtained
10
during
periodic
visits
by
Agency
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
regulation
does
not
require
the
use
of
automated,
electronic,
mechanical,
or
other
technological
collection
techniques
or
other
forms
of
information
technology.
Although
many
of
the
large
companies
have
elaborate
collection
methods,
automated
systems
are
not
required
to
comply
with
the
Monitoring,
Recordkeeping,
and
Reporting
requirements
of
this
rule.

(
c)
Small
Entity
Flexibility
Approximately
162
of
the
1500
affected
facilities
in
this
source
category
are
owned
by
small
businesses
as
defined
by
the
Small
Business
Administration
(
SBA).
The
Agency
does
not
expect
that
any
miscellaneous
metal
parts
and
products
surface
coating
operation,
including
the
small
businesses,
would
experience
more
than
minimal
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

(
d)
Collection
Schedule
For
all
existing
facilities,
the
Initial
Notification
must
be
submitted
within
12
months
after
the
effective
date
of
the
standard
and
the
initial
Notification
of
Compliance
Status
must
be
submitted
within
30
days
after
the
end
of
the
initial
11
compliance
period.
Records
necessary
to
determine
compliance
would
be
compiled
on
a
monthly
basis
and
notifications
of
compliance
status
would
be
submitted
to
the
Administrator
on
a
semiannual
basis.

5.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
rule.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
rule.

(
b)
Consultations
The
EPA
advised
interested
parties
on
July
16,
1992
(
57
FR
31576)
of
the
categories
considered
as
sources
of
HAP's,
and
"
Miscellaneous
Metal
Parts
and
Products
Surface
Coating
Operations"
was
listed
as
a
category
of
major
sources.
No
specific
information
was
provided
with
respect
to
burden
estimates
at
that
time.

Representatives
from
other
interested
EPA
offices
and
programs,
including
State
and
Regional
environmental
agency
personnel,
participated
in
the
regulatory
development
and
were
given
opportunities
to
review
and
comment
on
the
rule
before
proposal.
Therefore,
the
EPA
believes
that
the
implication
to
other
EPA
offices
and
programs
was
adequately
considered
during
12
the
development
of
the
proposed
rule.
In
addition,
the
EPA
has
met
with
many
members
of
industry
concerning
the
proposed
rule.

Finally,
industry,
regulatory
authorities,
and
environmental
groups
will
have
the
opportunity
to
comment
on
the
rule
and
provide
additional
information
during
the
public
comment
period
following
proposal.

(
c)
Effects
of
Less
Frequent
Collection
If
the
relevant
information
were
collected
less
frequently
by
the
owner
or
operator,
the
EPA
would
not
be
reasonably
assured
that
a
facility
is
in
compliance
with
the
standards.
Less
frequent
collection
could
result
in
long­
term
exceedances
of
the
applicable
emission
limits.
This
reporting
frequency
is
consistent
with
the
requirements
of
title
V
permit
programs.

Consequently,
less
frequent
reports
would
not
result
in
a
lower
burden.

(
d)
General
Guidelines
This
ICR
requires
that
miscellaneous
metal
parts
and
products
surface
coating
operations
retain
records
of
control
device
monitoring
or
HAP
emissions
calculations
records
at
facilities
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.5;

however,
the
5­
year
period
is
consistent
with
the
General
Provisions
to
40
CFR
part
63
and
the
permit
requirements
under
40
CFR
part
70.
All
facilities
subject
to
this
rule
will
be
13
required
to
obtain
operating
permits
either
through
the
Stateapproved
permitting
program
or,
if
one
does
not
exist,
in
accordance
with
the
provisions
of
40
CFR
part
71,
when
promulgated.
None
of
the
other
guidelines
in
4
CFR
1320.6
are
being
exceeded.

(
e)
Confidentiality
All
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
(
see
40
CFR
part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,

1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,

1979).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
reporting
and
recordkeeping
activities
are
presented
in
Tables
1
through
14
in
Attachment
4.

Individual
tables
for
the
first
3
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
each
of
the
first
3
years.
The
1500
major
source
facilities
that
exist
as
of
the
effective
date
of
the
rule
are
not
required
to
come
into
compliance
with
the
rule
until
three
after
the
effective
date.
Forty
five
new
facilities
are
projected
to
be
constructed
each
year
after
the
effective
date
of
the
rule,
and
must
comply
14
when
they
begin
operating.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
the
Agency's
experience
with
other
standards.
These
costs
represent
the
average
burden
that
will
be
incurred
by
facilities
and
the
entire
industry
in
the
first
3
years
after
the
standards
go
into
effect.
Tables
are
also
presented
in
Attachment
4
showing
the
burden
for
the
second
3­
year
period
because
the
burden
is
significantly
higher
then.

(
b)
Estimating
Respondent
Costs
Labor
rates
and
associated
costs
are
based
on
estimated
hourly
rates
of
technical
at
$
54.92,
management
at
$
78.10,
and
clerical
at
$
36.16.

No
capital/
startup
costs
have
been
assigned
because
the
recordkeeping
and
reporting
requirements
of
the
standards
are
not
expected
to
result
in
the
need
for
purchasing
any
additional
equipment,
or
the
expenditure
of
any
startup
costs.
Facilities
are
expected
to
comply
with
the
standards
by
reformulating
their
coating
materials
rather
than
purchasing
add­
on
control
devices.

Thus,
the
purchase
of
monitoring
or
recording
devices
is
not
anticipated.

The
annual
operating
and
maintenance
costs
included
the
costs
to
copy
and
mail
each
response,
and
was
estimated
to
be
$
20
per
response.
Over
the
first
three
years
after
the
effective
date
of
the
standards,
45
new
facilities
are
projected
each
year.

During
this
period,
the
135
affected
facilities
will
submit
a
15
total
of
540
reports
(
90
in
year
1;
180
in
year
2;
270
in
year
3)

at
a
cost
of
$
10,800.00
(
540
*
$
20
=
$
10,800).
The
annualized
operating
and
maintenance
cost
over
the
3
years
is,
therefore,

$
3600
per
year.

(
c)
Estimating
Agency
Burden
and
Costs
Because
the
information
collection
requirements
were
estimated
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
Act,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
AIRS,
with
the
result
that
no
Federal
costs
can
be
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
Agency's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.

The
only
costs
that
the
Federal
Government
will
incur
are
user
costs
associated
with
the
analysis
of
the
information
reported
semiannually
by
the
sources,
(
unless
the
semiannual
reports
indicate
a
violation,
thereby
triggering
an
enforcement
16
action)
as
presented
in
Tables
15
through
21
in
Attachment
4.

Labor
rates
and
associated
costs
are
based
on
estimated
hourly
rates
of
technical
at
$
54.92,
management
at
$
78.10,
and
clerical
at
$
36.16.

(
d)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables
(
i)
Respondent
Tally:
The
annual
bottom
line
respondent
burden
hours
and
costs
are
calculated
by
adding
the
total
personhours
and
labor
costs
for
1500
existing
facilities
during
the
first
3
years
to
the
total
person­
hours
and
labor
costs
for
the
45
new
facilities
in
each
of
the
first
3
years,
and
then
dividing
by
the
3­
year
review
period.
The
total
annual
burden
hours
and
labor
costs
are
shown
on
the
following
table.

Year
Total
burden,

hours
Total
costs,
$

1
97,359
5,286,255
2
49,680
2,697,451
3
271,101
14,719,841
Total
418,140
22,703,548
Bottom
line
annual
burden
139,380
7,567,849
(
ii)
The
Agency
Tally:
The
annual
bottom
line
Agency
burden
hours
and
costs
are
calculated
by
adding
the
total
personhours
and
labor
costs
from
each
of
the
first
three
years,
and
17
then
dividing
by
the
3­
year
review
period.
The
annual
number
of
hours
averaged
over
the
first
3
years
is
7,912
at
a
cost
of
$
429,594
per
year.
The
Agency
burden
is
shown
on
the
following
table.

Year
Total
burden,
hours
Total
costs,
$

1
15,870
861,686
2
3,312
179,830
3
4,554
247,266
Total
23,736
1,288,782
Bottom
line
annual
burden
7,912
429,594
(
iii)
Variations
in
the
annual
bottom
line:
The
annual
burden
hours
and
costs
vary
over
the
course
of
the
3­
year
review
period
because
of
the
burden
associated
with
initial
reports
and
other
one­
time
activities
(
e.
g.,
developing
the
recordkeeping
system).
Also,
because
existing
sources
are
not
required
to
comply
for
three
years,
there
is
only
a
relatively
low
level
of
burden
during
this
period.
Hours
for
reading
and
understanding
the
rule
and
preparing
the
Initial
Notification
are
assigned
to
the
first
year
and
hours
for
planning
activities
and
training
personnel
are
allotted
for
the
third
year.
For
existing
sources,

the
actual
recordkeeping
and
reporting
activities
begin
in
the
fourth
year,
and
will
be
ongoing
each
year
thereafter.

The
Agency
burden
hours
and
costs
will
also
vary
over
the
18
3­
year
review
period
because
the
number
of
respondents
increases
by
45
new
facilities
each
year.
Tables
15
through
17
present
the
Agency
burden
hours
and
costs
of
each
of
the
3
years
following
the
effective
date
of
the
rule.
The
overall
Agency
burden
after
the
first
three­
year
period
will
increase
significantly
as
existing
facilities
begin
semi­
annual
reporting
during
the
fourth
year.

(
e)
Reasons
for
Change
in
Burden
This
section
does
not
apply
because
this
is
a
new
collection.

(
f)
Burden
Statement
(
i)
The
EPA
is
required
under
section
112(
d)
of
the
Clean
Air
Act
to
regulate
emissions
of
HAP
listed
in
section
112(
b).

(
ii)
The
information
is
needed
as
part
of
the
overall
compliance
and
enforcement
program.

(
iii)
The
total
annual
reporting
and
recordkeeping
burden
for
this
collection
averaged
over
the
first
3
years
is
estimated
to
be
139,380
hours
per
year
for
the
entire
source
category.
The
average
burden
for
the
facilities
that
exist
as
of
the
effective
date
of
the
rule
is
about
60
hours
per
year
for
reading
the
rule
and
preparing
to
comply
with
the
rule.
For
each
of
the
45
new
sources
that
are
projected
each
year,
the
burden
is
about
548
hours
in
the
first
year
(
Table
6)
and
about
412
hours
in
subsequent
years
(
Table
7).
The
rule
requires
a
one­
time
initial
19
notification
and
a
notification
of
compliance
status
from
each
respondent
and
subsequent
notification
every
6
months
to
indicate
their
compliance
status.
A
respondent
would
also
be
required
to
keep
necessary
records
of
data
to
determine
compliance
with
the
standards
in
the
regulation.
The
data
would
be
recorded
monthly.

There
would
be
an
estimated
1500
respondents
initially
applicable
to
the
proposed
collection
requirements,
and
45
additional
respondents
each
year
thereafter.
This
burden
estimate
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.

iv)
The
respondents
would
be
subject
to
applicable
recordkeeping,
reporting,
and
other
requirements
in
40
CFR
63.9
and
63.10,
as
specified
in
the
proposed
rule.

(
v)
All
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
Information
(
see
40
CFR
part
2;
20
41
FR
36902,
September
1,
1076;
amended
by
43
FR
39999,

September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,

March
23,
1979).

(
vi)
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
a
table
in
40
CFR
part
9.
The
EPA
will
amend
part
9
when
the
ICR
is
approved.
21
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
a
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
Ms
Susan
Auby,

Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­

0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,

Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,

D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
2056.01.

PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
regulation.
22
23
ATTACHMENT
1
Source
Data
and
Information
Requirements
24
REQUIREMENT
CITATION
NOTIFICATIONS
Initial
Notification
63.3910
Notification
of
Compliance
Status
63.3910
Notification
of
construction
or
reconstruction
63.9
Notification
of
anticipated
date
of
initial
startup
63.9
Notification
of
actual
date
of
initial
startup
63.9
Notification
of
modification
63.9
Notification
of
intent
to
conduct
a
performance
test
63.7;
63.8;
63.9;
63.3910
RECORDKEEPING
Material
formulation
data
63.3930
Records
of
HAP
content
calculations
63.3930
Copies
of
Notifications
and
Reports
63.3930
Records
of
names
of
materials
used
63.3930
HAP
fractions
in
each
material
used
63.3930
Coating
solids
fraction
in
each
material
used
63.3930
Density
of
materials
used
63.3930
Documentation
of
waste
material
shipped
offsite
63.3930
Start­
up,
shutdown,
and
malfunction
plan/
records
63.6;
63.3930
Documentation
of
control
device
performance
tests
63.10;
63.3930
Values
measured
by
continuous
monitoring
systems
63.3930
Monitoring
system
calibrations,
maintenance
63.3930
Periods
of
monitoring
system
failure/
shutdown
63.3930
REPORTING
Periodic
reports
(
semiannual)
63.3920
statement
of
compliance
(
if
no
exceedances
occurred)
63.3920
average
monitoring
data
for
any
periods
where
exceedances
or
excursions
occur
63.3920
periods
of
monitoring
system
downtime
63.3920
results
of
any
performance
tests
63.3920
start­
up,
shutdown,
malfunction
reports
63.3920
25
ATTACHMENT
2
Description
of
Respondent
Activities
26
Description
of
Respondent
Activities
(
1)
Read
Rule
and
Instructions
are
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standard
and
understanding
how
they
apply
to
the
respective
points
at
a
facility.

(
2)
Plan
Activities
represents
such
burdens
as
design,

redesign,
scheduling,
and
selecting
methods
of
compliance.

(
3)
Training
represents
the
portion
of
activities
from
(
1)

Read
Rule
and
Instruction
for
which
an
average
facility
would
elect
to
provide
classroom
instruction.
The
standard
does
not
require
specific
training
itself.

(
4)
Create,
Test,
and
Research
and
Development
are
the
activities
involving
testing,
retesting,
establishing
parameter
monitoring
levels
and
determining
emission
point
applicability.

(
5)
Gather
Information,
Monitor,
and
Inspect
are
the
activities
involving
collection
of
monitored
data
and
other
related
activities.

(
6)
Process/
Compile
and
Review
are
the
activities
that
involve
analysis
of
the
information
collected
during
the
compliance
period
for
accuracy
and
completeness,
and
include
generation
of
appropriate
internal
reports
and
records
required
as
a
result.
27
(
7)
Complete
Reports
represents
the
activities
normally
associated
with
filling
out
required
forms.
Because
the
rule
requires
no
standardized
forms,
these
activities
relate
to
the
preparing
of
formal
reports
and
cover
letters
as
appropriate.

(
8)
Record/
Disclose
are
activities
that
are
solely
recordkeeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
These
activities
involve
software
translation,
duplication,
or
archival
processes
normally
associated
with
data
management
and
storage
common
to
this
industry.

(
9)
Store/
File
are
again
activities
that
are
solely
recordkeeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
The
activities
involve
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
stored,
to
the
time
they
are
disposed.

(
10)
LDAR
Reporting
and
Recordkeeping
is
the
burden
that
is
associated
with
requirements
to
develop
and
implement
a
leak
detection
and
repair
plan.
(
This
rule
has
no
LDAR
requirements)

(
11)
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
is
the
cost
for
purchasing
automated
monitoring
and
recording
devices
that
are
required
by
the
standards.
28
ATTACHMENT
3
Assumptions
Used
in
Cost
Estimates
29
ATTACHMENT
3a
Assumptions
Used
in
Burden
Estimates
30
Assumptions
Used
in
Burden
Estimates
(
a)
There
are
1500
major
(
or
"
affected")
sources
and
all
are
assumed
to
come
into
compliance
three
years
after
the
effective
date
of
the
rule,
as
required
by
the
rule.

(
b)
There
are
expected
to
be
135
new,
modified,
or
reconstructed
sources
during
the
first
three
years
(
45
in
each
year).

(
c)
A
total
of
40
hours
were
estimated
for
obtaining,

reading,
and
understanding
the
requirements
of
the
standard.(
Burden
Item
1)

(
d)
An
estimated
40
hours
would
be
required
for
communication
and
coordination
with
materials
suppliers
to
ensure
that
all
needed
information
relative
to
HAP
and
solids
content
of
materials
is
provided
with
each
purchase
or
shipment.(
Burden
Item
2)

(
e)
A
total
of
76
hours
were
estimated
for
training
an
additional
employee
in
the
preparation
of
records
and
reports,
as
well
as
creating
a
"
template"
for
the
reports.(
Burden
Items
3
&
4)

(
f)
A
total
of
30
hours
per
month
were
assumed
for
gathering
or
retrieving
the
inventory
data
from
which
the
monthly
compliance
determination
will
be
made
and
for
the
analysis
of
the
data.(
Burden
Items
5&
6)

(
g)
An
estimated
8
hours
would
be
required
for
each
of
the
31
semi­
annual
compliance
reports
submitted
to
EPA.(
Burden
Item
7)

(
h)
A
total
of
8
hours
were
estimated
for
managing
(
copying,
distributing,
storing,
etc).
each
of
the
semi­
annual
reports.(
Burden
Items
8&
9)

(
i)
Average
labor
costs
per
hour
are;
technical
­
$
54.92,

management
­
$
78.10,
clerical
­
$
36.16.

(
j)
In
addition
to
the
technical
hours
described
above,

management
hours
equal
to
5
percent
and
clerical
hours
equal
to
10
percent
of
the
technical
hours
are
included
in
the
total
burden
estimate.

For
the
second
year
(
and
subsequent
years)
after
facilities
begin
complying
with
the
rule,
the
following
estimates
were
included:

(
a)
A
total
of
20
hours
were
assumed
annually
for
rereading
portions
of
the
standards,
coordination
with
suppliers,
and
training
additional
employees.

(
b)
A
total
of
30
hours
per
month
were
assumed
for
completing
the
compliance
determination.

(
c)
An
estimated
8
hours
were
assumed
for
preparing
each
semi­
annual
compliance
report.

(
d)
An
estimated
8
hours
were
assumed
for
"
managing"
each
semi­
annual
report.
32
(
e)
Average
labor
costs
per
hour
are;
technical
­
$
54.92,

management
­
$
78.10,
clerical
­
$
36.16.

(
f)
Management
hours
equal
to
5
percent
and
clerical
hours
equal
to
10
percent
of
the
technical
hours
are
included
in
the
total
burden
estimate.
33
ATTACHMENT
3b
Assumptions
Used
in
Monitoring,
Recordkeeping,

and
Reporting
Estimates
34
35
Monitoring,
Recordkeeping,
and
Reporting
Burden
Estimation
Methodology
1.
The
number
of
coating
materials
used
was
selected
as
the
measure
of
the
Monitoring,
Recordkeeping,
and
Reporting
Burden
placed
on
facilities
represented
in
the
Miscellaneous
Metal
Parts
and
Products
MACT
Database
(
321
facilities).
This
approach
assumes
that
the
number
of
materials
used
is
a
better
indicator
of
reporting
burden
than
facility
size
based
on
coating
usage
(
volume).

2.
The
facilities
in
the
MACT
database
were
ranked
and
divided
into
ranges
based
on
the
number
of
Materials
they
must
track.

The
MMPP
contains
groups
of
similar
materials
as
one
entry.

In
order
to
count
the
total
number
of
materials
these
groups
had
to
be
accounted
for.
Since
it
was
not
always
noted
how
many
materials
were
in
each
group,
an
assumption
was
needed
to
determine
how
many
materials
were
represented
by
the
group.
A
random
sampling
of
the
materials
contained
in
the
groups
of
data
was
taken.
The
sample
results
indicated
that
the
average
group
of
coatings
represents
7
materials.

3.
Facilities
were
grouped
based
on
the
following
ranges
of
materials:
36
Group
I
<
25
Materials
(
183
facilities,
57%)

Group
II
25
to
100
Materials
(
114
facilities,
36%)

Group
III
>
100
Materials
(
23
facilities,
7%)

4.
The
maximum
number
of
materials
for
a
facility
was
288.

5.
It
was
assumed
that
the
Group
II
Facilities
would
require
2
times
the
effort
that
Group
I
would
require.
In
addition,
it
was
assumed
that
Group
III
facilities
would
require
3
times
the
effort
that
Group
I
would
require.
This
is
based
on
the
assumption
that
as
the
number
of
materials
increase,

automation
and
increased
efficiency
would
allow
the
larger
facilities
to
perform
tasks
at
a
faster
rate.

6.
The
number
of
facilities
in
each
group
nationwide
was
then
projected
from
the
distribution
of
facilities
in
the
MACT
database.
This
was
based
on
our
previous
assumption
of
1500
existing
facilities
and
45
new
facilities
per
year.

7.
Below
is
the
projection
of
facilities
for
each
group
across
the
MMPP
industry:

Group
I
855
existing
facilities;
26
new
facilities
37
Group
II
540
existing
facilities;
16
new
facilities
Group
III
105
existing
facilities;
3
new
facilities
8.
We
then
adjusted
burden
items
5
(
Gather
Information,
Monitor
and
Inspect)
and
6
(
Process/
Compile
Review)
from
the
list
in
Attachment
2
because
they
were
the
activities
that
would
be
affected
by
the
number
of
materials
used.

9.
We
assumed
that
for
Item
5
Group
I
would
require
12
hours.

10.
The
following
is
a
summary
of
the
burden
for
Item
5
by
Group:

Group
I
(
12
hours
effort
per
facility)

855
facilities
X
12
hours
per
facility
=
10,260
hours
Group
II
(
2x
the
effort
for
Group
I)

540
facilities
X
24
hours
per
facility
=
12,960
hours
Group
III
(
3x
the
effort
for
Group
I)

105
facilities
X
36
hours
per
facility
=
3,780
hours
38
Total
for
all
groups
=
27,000
hours
Average
burden
(
1500
facilities)
=
18
hours
11.
We
assumed
that
for
Item
6
Group
I
would
require
8
hours.

12.
The
following
is
a
summary
of
the
burden
for
Item
6
by
Group:

Group
I
(
8
hours
effort
per
facility)

855
facilities
X
8
hours
per
facility
=
6,840
hours
Group
II
(
2x
the
effort
for
Group
I)

540
facilities
X
16
hours
per
facility
=
8,640
hours
Group
III
(
3x
the
effort
for
Group
I)

105
facilities
X
24
hours
per
facility
=
2,520
hours
Total
for
all
groups
=
18,000
hours
Average
burden
(
1500
facilities)
=
12
hours
13.
The
average
values
of
18
hours
for
Item
5,
and
12
hours
for
Item
6
were
placed
into
the
OMB
83­
I
spreadsheets.
39
14.
The
5th
year
Monitoring,
Recordkeeping,
and
Reporting
cost
reflecting
the
adjustments
for
facility
size
based
on
number
of
materials
was
$
44,758,958.00.
When
combined
with
the
estimated
5th
year
compliance
cost
of
$
12,568,504.00
results
in
a
total
cost
of
$
57,327,462.00.

ATTACHMENT
4
TABLES
PRESENTING
DETAILED
BURDEN
ESTIMATES
40
TABLE
1.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
1
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
per
year
(
G=
E*
0.1)
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
1,500
60,000
3,000
6,000
3,746.5
2.0
Plan
Activities
40
1
40
0
0
0
0
0.0
3.0
Training
16
1
16
0
0
0
0
0.0
4.0
Create,
Test,
and
Research
and
Development
60
1
60
0
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
0
0
0
0
0.0
6.0
Process/
Compile
and
Review
12
12
144
0
0
0
0
0.0
7.0
Complete
Reports
8
2
16
0
0
0
0
0.0
8.0
Record/
Disclose
4
2
8
0
0
0
0
0.0
9.0
Store/
File
4
2
8
0
0
0
0
0.0
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
202
­­
548
1,500
60,000
3,000
6,000
3,746.5
41
TABLE
2.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
2
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
0
0
0
0
0.0
2.0
Plan
Activities
40
1
40
0
0
0
0
0.0
3.0
Training
16
1
16
0
0
0
0
0.0
4.0
Create,
Test,
and
Research
and
Development
60
1
60
0
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
0
0
0
0
0.0
6.0
Process/
Compile
and
Review
12
12
144
0
0
0
0
0.0
7.0
Complete
Reports
8
2
16
0
0
0
0
0.0
8.0
Record/
Disclose
4
2
8
0
0
0
0
0.0
9.0
Store/
File
4
2
8
0
0
0
0
0.0
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
202
­­
548
1,500
0
0
0
0.0
42
TABLE
3.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
3
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
0
0
0
0
0.0
2.0
Plan
Activities
40
1
40
1,500
60,000
3,000
6,000
3,746.5
3.0
Training
16
1
16
1,500
24,000
1,200
2,400
1,498.6
4.0
Create,
Test,
and
Research
and
Development
60
1
60
1,500
90,000
4,500
9,000
5,619.7
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
0
0
0
0
0.0
6.0
Process/
Compile
and
Review
12
12
144
0
0
0
0
0.0
7.0
Complete
Reports
8
2
16
0
0
0
0
0.0
8.0
Record/
Disclose
4
2
8
0
0
0
0
0.0
9.0
Store/
File
4
2
8
0
0
0
0
0.0
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
­­
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
­­
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
202
­­
548
1,500
174,000
8,700
17,400
10,864.7
43
TABLE
4.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
4
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
1,500
6,000
300
600
374.6
2.0
Plan
Activities
8
1
8
1,500
12,000
600
1,200
749.3
3.0
Training
8
1
8
1,500
12,000
600
1,200
749.3
4.0
Create,
Test,
and
Research
and
Development
0
1
0
1,500
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
1,500
324,000
16,200
32,400
20,230.9
6.0
Process/
Compile
and
Review
12
12
144
1,500
216,000
10,800
21,600
13,487.3
7.0
Complete
Reports
8
2
16
1,500
24,000
1,200
2,400
1,498.6
8.0
Record/
Disclose
4
2
8
1,500
12,000
600
1,200
749.3
9.0
Store/
File
4
2
8
1,500
12,000
600
1,200
749.3
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
66
­­
412
1,500
618,000
30,900
61,800
38,588.5
44
TABLE
5.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
5
AND
YEAR
6
­
EXISTING
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
1,500
6,000
300
600
374.6
2.0
Plan
Activities
8
1
8
1,500
12,000
600
1,200
749.3
3.0
Training
8
1
8
1,500
12,000
600
1,200
749.3
4.0
Create,
Test,
and
Research
and
Development
0
1
0
1,500
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
1,500
324,000
16,200
32,400
20,230.9
6.0
Process/
Compile
and
Review
12
12
144
1,500
216,000
10,800
21,600
13,487.3
7.0
Complete
Reports
8
2
16
1,500
24,000
1,200
2,400
1,498.6
8.0
Record/
Disclose
4
2
8
1,500
12,000
600
1,200
749.3
9.0
Store/
File
4
2
8
1,500
12,000
600
1,200
749.3
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
66
­­
412
1,500
618,000
30,900
61,800
38,588.5
45
TABLE
6.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
1
­
NEW
FACILITIES
(
YEARS
2,
3,
4,
5,
AND
6
WILL
BE
IDENTICAL,
AS
45
NEW
FACILITIES
ARE
CONSTRUCTED
EACH
YEAR)

Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
40
1
40
45
1,800
90
180
112.4
2.0
Plan
Activities
40
1
40
45
1,800
90
180
112.4
3.0
Training
16
1
16
45
720
36
72
45.0
4.0
Create,
Test,
and
Research
and
Development
60
1
60
45
2,700
135
270
168.6
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
45
9,720
486
972
606.9
6.0
Process/
Compile
and
Review
12
12
144
45
6,480
324
648
404.6
7.0
Complete
Reports
8
2
16
45
720
36
72
45.0
8.0
Record/
Disclose
4
2
8
45
360
18
36
22.5
9.0
Store/
File
4
2
8
45
360
18
36
22.5
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
202
­­
548
45
24,660
1,233
2,466
1,539.8
46
TABLE
7.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
2
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
45
180
9
18
11.2
2.0
Plan
Activities
8
1
8
45
360
18
36
22.5
3.0
Training
8
1
8
45
360
18
36
22.5
4.0
Create,
Test,
and
Research
and
Development
0
1
0
45
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
45
9,720
486
972
606.9
6.0
Process/
Compile
and
Review
12
12
144
45
6,480
324
648
404.6
7.0
Complete
Reports
8
2
16
45
720
36
72
45.0
8.0
Record/
Disclose
4
2
8
45
360
18
36
22.5
9.0
Store/
File
4
2
8
45
360
18
36
22.5
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
66
­­
412
45
18,540
927
1,854
1,157.7
47
TABLE
8.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
3
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
90
360
18
36
22.5
2.0
Plan
Activities
8
1
8
90
720
36
72
45.0
3.0
Training
8
1
8
90
720
36
72
45.0
4.0
Create,
Test,
and
Research
and
Development
0
1
0
90
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
90
19,440
972
1,944
1,213.9
6.0
Process/
Compile
and
Review
12
12
144
90
12,960
648
1,296
809.2
7.0
Complete
Reports
8
2
16
90
1,440
72
144
89.9
8.0
Record/
Disclose
4
2
8
90
720
36
72
45.0
9.0
Store/
File
4
2
8
90
720
36
72
45.0
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
66
­­
412
90
37,080
1,854
3,708
2,315.3
48
TABLE
9.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
4
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
135
540
27
54
33.7
2.0
Plan
Activities
8
1
8
135
1,080
54
108
67.4
3.0
Training
8
1
8
135
1,080
54
108
67.4
4.0
Create,
Test,
and
Research
and
Development
0
1
0
135
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
135
29,160
1,458
2,916
1,820.8
6.0
Process/
Compile
and
Review
12
12
144
135
19,440
972
1,944
1,213.9
7.0
Complete
Reports
8
2
16
135
2,160
108
216
134.9
8.0
Record/
Disclose
4
2
8
135
1,080
54
108
67.4
9.0
Store/
File
4
2
8
135
1,080
54
108
67.4
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
66
­­
412
135
55,620
2,781
5,562
3,473.0
49
TABLE
10.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
5
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
180
720
36
72
45.0
2.0
Plan
Activities
8
1
8
180
1,440
72
144
89.9
3.0
Training
8
1
8
180
1,440
72
144
89.9
4.0
Create,
Test,
and
Research
and
Development
0
1
0
180
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
180
38,880
1,944
3,888
2,427.7
6.0
Process/
Compile
and
Review
12
12
144
180
25,920
1,296
2,592
1,618.5
7.0
Complete
Reports
8
2
16
180
2,880
144
288
179.8
8.0
Record/
Disclose
4
2
8
180
1,440
72
144
89.9
9.0
Store/
File
4
2
8
180
1,440
72
144
89.9
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
66
­­
412
180
74,160
3,708
7,416
4,630.6
50
TABLE
11.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
6
­
NEW
FACILITIES
Burden
Item
(
A)

Person­
hours
per
(
B)
Number
of
occurrences
(
C)
Person­
hrs.

per
respondent
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.
(
F)
Management
person­
hrs.
(
G)
Clerical
person­
hrs.
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
4
1
4
225
900
45
90
56.2
2.0
Plan
Activities
8
1
8
225
1,800
90
180
112.4
3.0
Training
8
1
8
225
1,800
90
180
112.4
4.0
Create,
Test,
and
Research
and
Development
0
1
0
225
0
0
0
0.0
5.0
Gather
Information,
Monitor,

and
Inspect
18
12
216
225
48,600
2,430
4,860
3,034.6
6.0
Process/
Compile
and
Review
12
12
144
225
32,400
1,620
3,240
2,023.1
7.0
Complete
Reports
8
2
16
225
3,600
180
360
224.8
8.0
Record/
Disclose
4
2
8
225
1,800
90
180
112.4
9.0
Store/
File
4
2
8
225
1,800
90
180
112.4
10.0
LDAR
Reporting
and
Recordkeeping
0
0
0
0
0
0
0
0.0
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
0
0
0
0
0
0
0
0.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
66
­­
412
225
92,700
4,635
9,270
5,788.3
51
TABLE
12.
SUMMARY
OF
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEARS
1,
2,
AND
3
YEAR
EXISTING
SOURCE
COSTS
($
1,000)
EXISTING
SOURCE
BURDEN
(
HOURS)
NEW
SOURCE
COSTS
($
1,000)
NEW
SOURCE
BURDEN
(
HOURS)
TOTAL
NATIONWIDE
ANNUAL
COSTS
($
1,000)
TOTAL
NATIONWIDE
BURDEN
(
HOURS)

1
3,746.5
69,000
1,539.8
28,359
5,286.3
97,359
2
0.0
0
2,697.5
49,680
2,697.5
49,680
3
10,864.7
200,100
3,855.1
71,001
14,719.8
271,101
AVERAGE
COST
4,870.4
89,700
2,697.5
49,680
7,567.8
139,380
52
TABLE
13.
SUMMARY
OF
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEARS
4,
5,
AND
6
YEAR
EXISTING
SOURCE
COSTS
($
1,000)
EXISTING
SOURCE
BURDEN
(
HOURS)
NEW
SOURCE
COSTS
($
1,000)
NEW
SOURCE
BURDEN
(
HOURS)
TOTAL
NATIONWIDE
ANNUAL
COSTS
($
1,000)
TOTAL
NATIONWIDE
BURDEN
(
HOURS)

4
38,588.5
710,700
5,012.8
92,322
43,601.3
803,022
5
38,588.5
710,700
6,170.4
113,643
44,759.0
824,343
6
38,588.5
710,700
7,328.1
134,964
45,916.6
845,664
AVERAGE
COST
38,588.5
710,700
6,170.4
113,643
44,759.0
824,343
53
TABLE
14.
SUMMARY
OF
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
­­
YEAR
1
THROUGH
YEAR
6
YEAR
EXISTING
SOURCE
COSTS
($)
EXISTING
SOURCE
BURDEN
(
HRS)
NEW
SOURCE
COSTS
($)
NEW
SOURCE
BURDEN
(
HRS)
TOTAL
NATIONWIDE
ANNUAL
COST
($)
TOTAL
NATIONWIDE
BURDEN
(
HRS)

1
3,746,460
69,000
1,539,795
28,359
5,286,255
97,359
2
0
0
2,697,451
49,680
2,697,451
49,680
54
3
10,864,734
200,100
3,855,107
71,001
14,719,841
271,101
4
38,588,538
710,700
5,012,763
92,322
43,601,301
803,022
5
38,588,538
710,700
6,170,420
113,643
44,758,958
824,343
6
38,588,538
710,700
7,328,076
134,964
45,916,614
845,664
AVERAGE
21,729,468
400,200
4,433,935
81,662
26,163,403
481,862
55
TABLE
15.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
1
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
45
360
18
36
22.5
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
i)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
initial
notification
8
1545
12,360
618
1,236
771.8
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
56
l)
periodic
reports
of
compliance
status
12
90
1,080
54
108
67.4
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
13,800
690
1,380
861.7
TABLE
16.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
2
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
45
360
18
36
22.5
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
57
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
45
360
18
36
22.5
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
180
2,160
108
216
134.9
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
2,880
144
288
179.8
TABLE
17.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
3
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
58
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
45
360
18
36
22.5
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
45
360
18
36
22.5
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
270
3,240
162
324
202.3
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
3,960
198
396
247.3
59
TABLE
18.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
4
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
1545
12,360
618
1,236
771.8
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
1545
12,360
618
1,236
771.8
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
60
l)
periodic
reports
of
compliance
status
12
4,260
51,120
2,556
5,112
3192.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
75,840
3,792
7,584
4735.5
TABLE
19.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
5
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
45
360
18
36
22.5
61
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
45
360
18
36
22.5
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
4,350
52,200
2,610
5,220
3259.4
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
52,920
2,646
5,292
3304.4
TABLE
20.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
6
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
N/
A
0
0
0
0.0
62
2.0
Repeat
performance
test
N/
A
0
0
0
0.0
3.0
Litigation
N/
A
0
0
0
0.0
4.0
Report
review
0
0
0
0.0
a)
notification
of
const./
reconst.
N/
A
0
0
0
0.0
b)
notif.
of
anticipated
startup
N/
A
0
0
0
0.0
c)
notif.
of
actual
startup
N/
A
0
0
0
0.0
d)
notif.
of
modification
N/
A
0
0
0
0.0
e)
notif.
of
compliance
status
8
45
360
18
36
22.5
f)
notif.
of
performance
test
N/
A
0
0
0
0.0
g)
notif.
of
process
change
N/
A
0
0
0
0.0
h)
notif.
of
inspection
of
storage
vessel
N/
A
0
0
0
0.0
I)
notif.
of
change
in
primary
product
N/
A
0
0
0
0.0
j)
precompliance
report
8
45
360
18
36
22.5
k)
storage
vessel
initial
compliance
demonstration
N/
A
0
0
0
0.0
l)
periodic
reports
of
compliance
status
12
4,440
53,280
2,664
5,328
3326.9
TOTAL
BURDEN
(
HRS)
AND
COSTS
28
­­
54,000
2,700
5,400
3371.8
63
TABLE
21.
SUMMARY
OF
ANNUAL
BURDEN
AND
LABOR
COST
TO
THE
FEDERAL
GOVERNMENT
­­
YEAR
1
THROUGH
YEAR
6
YEAR
BURDEN
(
HOURS)
COST
($
1,000)

1
15,870
861.7
2
3,312
179.8
3
4,554
247.3
ANNUAL
AVERAGE
(
1ST
3
YRS)
7,912
429.6
4
87,216
4,735.5
5
60,858
3,304.4
6
62,100
3,371.8
ANNUAL
AVERAGE
(
2ND
3
YRS)
70,058
3,803.9
