Supporting Statement For NSPS for Flexible Vinyl and Urethane 

Coating and Printing (40 CFR part 60, subpart FFF)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR part
60, 

subpart FFF)

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for subpart FFF were
proposed on January 18, 1983, and promulgated on June 29, 1984.  These
standards apply to the following facilities in subpart FFF: each
rotogravure printing line used to print or coat flexible vinyl or
urethane products, and for which construction, modification or
reconstruction commenced after January 18, 1983.  This information is
being collected to assure compliance with 40 CFR part 60, subpart FFF.

Owners or operators of the affected facilities described must make
one-time-only notifications.  Owners or operators are also required to
maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of an affected facility, or
any period during which the monitoring system is inoperative. 
Monitoring requirements specific to this rule provide information on the
operation of emissions control devices.  Semiannual reports of excess
emissions or exceedances of standards are required.  These
notifications, reports, and records are essential in determining
compliance, and are required, in general, of all sources subject to
NSPS.

Any owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated State or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) Regional Office.

Approximately 20 sources are currently subject to the regulation, and it
is estimated that one additional source will become subject to the
standard in the next three years, for an average of 0.33 new sources per
year.  These figures are based on queries conducted in the EPA’s Air
Facility System (AFS) through the Online Tracking Information System
(OTIS).  The cost of this Information Collection Request (ICR) will be
$36,535.

OMB approved the currently active ICR without any “Terms of
Clearance.”

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect:

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(1).

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

Section 111 also required that the Administrator review and, if
appropriate, revise such standards every four years.

2(b)  Practical Utility/Users of the Data

The control of emissions of volatile organic compounds (VOC) from
printing and coating flexible vinyl and urethane products requires not
only the installation of properly designed equipment, but also the
operation and maintenance of that equipment.  Emissions of volatile
organic compounds are the result of operation of the printing on
flexible vinyl and urethane coating.  These standards rely on the
reduction of volatile organic compounds emissions by using inks with low
VOC content or on the capture of those compounds by solvent recovery
systems, thermal incinerators or catalytic incinerators.

The required notifications are used to inform the Agency or delegated
authority when a source becomes subject to the standard.  The reviewing
authority may then inspect the source to check if the pollution control
devices (if this method is chosen to comply with the regulation) are
properly installed and operated and the standard is being met. 
Performance test reports are needed as these are the Agency’s record
of a source’s initial capability to comply with the emission standard,
and serve as a record of the operating conditions under which compliance
was achieved.  For facilities using control equipment to meet this
standard, the operating conditions may include temperature or volatile
organic compound concentration.

The semiannual reports are used for problem identification, as a check
on source operation and maintenance, and for compliance determinations. 
The information generated by the monitoring, recordkeeping and reporting
requirements described in this ICR is used by the Agency to ensure that
facilities affected by the NSPS continue to operate the control
equipment and achieve compliance with the regulation.  Adequate
monitoring, recordkeeping, and reporting are necessary to ensure
compliance with these standards, as required by the Clean Air Act.  The
information collected from recordkeeping and reporting requirements is
also used for targeting inspections, and is of sufficient quality to be
used as evidence in court.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, 

subpart FFF.

3(a)  Nonduplication

 If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA Regional Office.  Otherwise, the
information is sent directly to the delegated State or local agency.  If
a State or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
State or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register on June 21, 2006 (71 FR 35652). 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

For this information collection, the previous ICR renewal was used to
obtain burden estimates since this ICR renewal was processed under the
“renew without change” option.  Per this guidance, all data and
assumptions from the previous ICR renewal were used as the basis for
estimating the hourly and cost burdens associated with this renewal.  

Based on this information there will be an estimated 20 respondents with
one industry growth expected over the next three years. In the previous
ICR renewal   SEQ CHAPTER \h \r 1  several different resources were used
to obtain the most recent data available for the flexible vinyl and
urethane coating and printing sources.  We referenced the most recent
ICR, and accessed the data (April 14, 2003) available on the Air
Facility System (AFS) database maintained by the Office of Compliance. 
We also retrieved data from the Toxic Release Inventory System (TRIS)
maintained by the Office of Environmental Information.  In addition, we
contacted all the facilities listed in our queries for confirmation.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance would decrease.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR 1320.5.

3(f)  Confidentiality

The required information has been determined not to be confidential. 
However, any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, c1, part 2, subpart B - Confidentiality
of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976;
amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,
1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are
subpart FFF that commenced construction, modification, or reconstruction
after January 18, 1983.  They are listed under SIC Codes 2295 and 2679. 
Both of these Codes contain firms that are not covered by this rule. 
This rule does not cover resilient floor covers or flexible packaging. 
The government is in the process of transitioning to the new North
American Industrial Classification System (NAICS).  The NAICS codes for
this industry are 31332, 322222, and 322299 for source category
description.

4(b)  Information Requested, including record keeping requirements

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
New Source Performance Standards for Flexible Vinyl and Urethane Coating
and Printing (40 CFR part 60, subpart FFF).

A source must make the following reports:

Reports for 40 CFR part 60, subpart FFF



Construction/reconstruction	

60.7(a)(1)



Physical or operational change	

60.7(a)(4)



Initial performance test

	

60.8(d)

 61



Delay of/and rescheduled initial performance test(s)	

60.8(d)



Actual startup	

60.7(a)(3)



Initial performance test results	

60.8(a), 60.585(a)



Demonstration of continuous monitoring system	

60.7(a)(5) 



Semiannual reports	

60.7(c) and 60.7(d) 60.585(b)



A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart FFF



Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative.	

60.7(b)

60.584(d)



Records for sources with continuous monitoring systems 	

60.7(d)



Maintain file of all measurements	

60.7(e)

60.583(b) and 60.583(c)



Records of performance test conditions 	

60.8(c)



Records of operating conditions for control equipment (i.e., temperature
or VOC concentration)	

60.584(a)(2)

60.584(b)(2) 60.584(c)(2)



(ii)  Respondent Activities

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate CMS for VOC concentration or
temperature.



Perform initial performance test, Reference Methods 24, 25, 1, 2, 3, and
4 tests, and repeat performance tests if necessary.



Write the notifications and reports listed above.



Enter information required to be recorded above.



Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.



Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.



Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.



Adjust existing ways to comply with any previously applicable
instructions and requirements.



Train personnel to be able to respond to a collection of information.



Transmit, or otherwise disclose the information.



Presently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., volatile organic compounds. 
Although personnel at the source still need to evaluate the data, this
type of monitoring equipment has significantly reduced the burden
associated with monitoring and recordkeeping.  In addition, some
Regulatory Agencies are setting up electronic reporting systems to allow
sources to report electronically, which is reducing the reporting
burden.  However, electronic reporting systems are still not widely used
by the regulatory Agencies.

5.  The Information Collected:  Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities



Observe initial performance tests and repeat performance tests if
necessary.



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



Audit facility records.



Input, analyze, and maintain data in the Air Facility System (AFS)
database.



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect
the source to determine whether the pollution control devices are
properly installed and operated.  Performance test reports are used by
the Agency to discern a source’s initial capability to comply with the
emission standard, and note the operating conditions (VOC concentration
or temperature) under which compliance was achieved.  Data and records
maintained by the respondents are tabulated and published for use in
compliance and enforcement programs.  The semiannual reports are used
for problem identification, as a check on source operation and
maintenance, and for compliance determinations.

Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
and annual emission inventory data for over 100,000 industrial and
government-owned facilities.  EPA uses the AFS for tracking air
pollution compliance and enforcement by local and State regulatory
agencies, and EPA Regional Offices and Headquarters.  EPA and its
delegated Authorities can edit, store, retrieve and analyze the data.

 The records required by this regulation must be retained by the owner
or operator for two years.

5(c)  Small Entity Flexibility

A majority of the affected facilities are large entities (e.g., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.

The number of small entities potentially subject to the requirements of
this ICR is estimated to be five percent of the respondent universe. 
This estimate is based on the discussion of impacts at the affected
small entities during the development of the rule (see BID
EPA-450/3-81-016a).

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NSPS for
Flexible Vinyl and Urethane Coating and Printing (40 CFR part 60,
subpart FFF).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 593
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NSPS program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses a technical labor rate of $61.66 per hour.  This  rate is
from the United States Department of Labor, Bureau of Labor Statistics,
September 2002, “Table 10. Private industry, by occupational and
industry group.”  The rates are from column 1, “Total
compensation.”  The rate has been increased by 110% to account for the
benefit packages available to those employed by private industry.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection
activity in the regulations are for labor and continuous emission
monitoring (CEM).  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

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

The type of industry costs associated with the information collected
activity in the regulations are for labor and continuous emission
monitoring (CEM).  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

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



(A)

Continuous Monitoring Device	

(B)

Startup Cost for One Affected Facility	

(C)

Number of New Affected Facilities to Startup	

(D)

Total Startup 

(B X C)	

(E)

Annual O&M Costs for One Affected Facility	

(F)

Number of Affected Facilities with O&M	

(G)

Total O&M

(E X F)



Temperature or feed rate monitor	

$20,000	

	0.33	

$6,600	

$9,000	

	6	

$54,000

 

The total capital/startup cost for this ICR is $6,600.  This is the
total of column D in the above table.  The total operation and
maintenance (O&M) costs for this ICR are $54,000.  This is the total of
column G.  

The total respondent non-labor costs have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  The average annual cost for capital/startup and
operation and maintenance costs to industry of the next three years of
the ICR are estimated to be $60,600.  

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  Publication and distribution of the
information are part of the AFS program.  Examination of records to be
maintained by the respondents will occur as part of the periodic
inspection of sources, which is part of EPA’s overall compliance and
enforcement program

The average annual Agency cost during the three years of the ICR is
estimated to be $3,896. [see Table 2 in Section 6(e)].  This cost is
based on the average hourly labor rate at a 

GS-12, Step 1, times a 1.6 benefits multiplication factor to account for
government overhead expenses for a total of $39.49.  This rate is from
the Office of Personnel Management (OPM) (2003 General Schedule” which
excludes locality rates of pay.  Details upon which this estimate is
based appear in Table 2, Annual Agency Burden for NSPS for Flexible
Vinyl and Urethane Coating and Printing (40 CFR part 60, subpart FFF)
attached.

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

Respondent Universe and Number of Responses Per Year



Regulation Citation

	

(A)

Average Number of New Respondents per Year	

(B)

Number of Reports for New Source 	

(C)

Number of Existing Respondents	

(D)

Number of Reports for Existing Sources	

(F)

Number of Respondents that keep records but do not submit reports	

(E)

Total Annual  Responses =

(AxB)+(CxD)+F



40 CFR part 60, subpart FFF	

	0.33	

	2	

	20	

	2	

	0	

	40.66



The number of total respondents is 20.33, rounded to 20.  This number is
the sum of column A and column C of the Respondent Universe and Number
of Responses Per Year table.  This represents the number of existing
sources plus the number of new sources averaged over the three-year
period (i.e., the total of the number of new respondents over the
three-year period divided by three years).  

The number of Total Annual Responses is 41.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table.  

The total annual labor costs are $36,535.  Details upon which this
estimate is based appear in Table 1: Annual Respondent Burden and Cost -
NSPS for Flexible Vinyl and Urethane Coating and Printing (40 CFR part
60, subpart FFF).

The total annual capital and O&M costs to the regulated entity are
$61,000.  These costs are detailed in section 6(b)(iii), Capital/Startup
vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 14
(rounded) hours per response.

6(f)  Reasons for Change in Burden

There is no change in burden from the most recently approved ICR.  This
ICR renewal was approved under the “renew without change” option and
reflects no increase in the number of new or modified sources.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 14 (rounded) hours per response. 
Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.

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

	To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2006-0411.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Enforcement and Compliance Docket and Information Center Docket is (202)
566-1514.  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 Number EPA-HQ-OECA-2006-0411 and OMB Control Number
2060-0073 in any correspondence.

Part B of the Supporting Statement

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

TABLE 1:  Annual Industry Burden - NSPS for Flexible Vinyl and Urethane
Coating and Printing (40 CFR Part 60, Subpart FFF)

		Occurrences/	Hours/	

	Hours per	Respondent/	Respondent/	Respondents	Hours	Cost/

	Occurrence	Year	Year	per Year	per Year	Year  a

Reporting/Recordkeeping  	(A)	  (B)	(C=A x B)	(D)	(E = C x D)	   (F=E x
$61.66)

________________________________________________________________________
___________________________________________________
________________________

1.  APPLICATIONS		Not Applicable	

2.  SURVEY AND STUDIES		Not Applicable	

3.	REPORTING REQUIREMENTS

New Sources b

A.  Read Instructions c	1	1	1	                                          
  0.33	 0.33	$20.35    

B.	Required Activities	

New Sources 

Initial performance test d  	 280           	 1	 280	0.33	92.4	$5,697.38

Repeat performance test e                 	 280	 1	280	0.07	18.48
$1,139.48

C.  Create Information		Included in 3B

Gather Existing Information		Included in 3B

Write Report

New Sources    

Notification of construction/ f	2	1	2	0.33	0.66	 $40.70

	reconstruction 	 					 

Notification of initial performance g	2	1	2	 0.33	   0.66	$40.70

test

Report of initial performance test		Included in 3B 

Existing Plants

Submit semi-annual report h	 4	  2	 8	20	160	$9,865.60			

SUBTOTAL						272.53	$16,804.21

4.	RECORDKEEPING REQUIREMENTS

A.	Read Instructions		Included in 3A

Plan Activities		Included in 3B

C.	Implement Activities		Included in 3B

Develop Record System	        N/A	N/A	N/A	N/A	N/A	N/A	

Time to Enter Information 		 			

 		Records of startup, shutdown and i	       1.5	    2	3	20	60	$3,699.60

malfunctions

Records of VOC, temperature and j	         0.25	  52	13	20	260
$16,031.60	

CMS maintenance		

Audits	     	         N/A	     N/A	N/A	N/A	N/A	N/A

SUBTOTAL						320	$19,731.20

TOTAL ANNUAL INDUSTRY COST BURDEN (rounded)				593	$36,535

________________________________________________________________________
________________________________________________________________________
____

    Assumptions:

Technical labor rate (Bureau of Labor Statistics) is $29.36 + 110% =
$61.66 

Number of new facilities (per year): 0.33

Time required to read instructions (hours): 1

Time required to compete performance test (hours): 280

Rate of failed performance tests: 20%

Time required for notification preparation (hours): 2

Time required for notification of initial performance test (hours): 2

Time required to compile data for semiannual report (hours): 4

Time required to record startup, shutdown, and malfunction (hours): 1.5

Time required to record VOC, temperature and CMS maintenance (hours):
0.25

TABLE 2:  AVERAGE Annual  EPA Burden - NSPS for Flexible Vinyl and
Urethane Coating and Printing (40 CFR Part 60, Subpart FFF)

			EPA hrs/	Occurrences	EPA hrs/	Plants/		EPA

			Occurrence	Plant/Year	Plant/Year	Year	                Hrs/Year

Burden Items	(A)	(B)	(C=AxB) 	(D)	                  (E=CxD)

________________________________________________________________________
____________________________________________________

Required Activities

New Plant 

	Initial performance tests	   24		1		24	0.33		           7.92

Repeat performance tests b	24	0.2	4.8	0	        .33	1.58		     4

Report Review 

New Plant

Notification of construction c	        2	1		 2	0.33	 	           0.66

Notification of initial startup d	        0.5	1		    0.5	0.33		         
   0.165

Notification of actual startup e	        0.5	1		     0.5	0.33		         
   0.165

Notification of initial test	        0.5	   1.2	     0.6	0.33		         
   0.198

Review test results g	        0.5	   1.2	     9.6	0.33		            
3.168

Existing Plants

Semiannual reports of emission h	     2		2 		 4	20		    80

     exceedances

TOTAL ANNUAL HOURS						 		         93.86

Travel expenses i

(1 person x .33 plant/year x 3 days/plant x $75 per diem) + ($350 round
trip/plant x .33 plant/year) = $189.75

Salary j

(1 person x 93.86 hr/year x $39.49/hrs ) = $3,706.53

TOTAL ANNUAL EPA COST BURDEN = $3,896 (rounded)

________________________________________________________________________
_______________________________________________________

Assumptions:

a.	Time required to participate with performance test (hours per plant):
24

Rate of failed performance tests: 20%

Time required to review construction notification (hours): 2

Time required to review startup and initial test notifications (hours):
0.5

Notification of actual startup (hours): 0.5

Time required to review initial test notification (hours): 0.5

Time required to review test results (hours): 8  

Time required to review semi-annual reports (hours): 2

Round trip airfare to visit plant: $350

EPA(s labor rate at a GS-12, Step 1, times 1.6 government overhead
expenses: $39.49

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