SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NSPS for Kraft Pulp Mills (40 CFR Part 60, Subpart BB)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Kraft Pulp Mills (40 CFR part 60, subpart BB)(Renewal)

1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR part 60, subpart BB were proposed on September 24,
1976, and promulgated on February 23, 1978.  Revisions to the standards
were promulgated on May 20, 1986.  These regulations apply to the
following affected facilities at kraft pulp mills: recovery furnaces,
smelt dissolving tanks, lime kilns, digester systems, brown stock washer
systems, black liquor oxidation systems, multiple effect evaporator
systems and condensate stripper systems that were constructed, modified
or reconstructed after the date of proposal.  In pulp mills where kraft
pulping is combined with neutral sulfite semi-chemical pulping, the
provisions of this subpart are applicable when any portion of the
material charged to an affected facility is produced by the kraft
pulping operation.  Facilities may be exempt from the total reduced
sulfur (TRS) standard if the facility can demonstrate that TRS emissions
from a new, modified or reconstructed brown stock washer can be neither
technically nor economically feasibly controlled.  This information is
being collected to assure compliance with 40 CFR part 60, subpart BB.

In general, all NSPS require initial notifications, performance tests,
and periodic reports.  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.  These notifications,
reports, and records are essential in determining compliance, and are
required 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 100 sources are currently subject to the regulation, and
it is estimated that two additional sources per year will become subject
to the regulation in the next three years.  These numbers are based on
previous experience with the industry and a recent search of the
Agency’s AIRS Facility Subsystem (AFS) data base.

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

Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The Clean Air Act (CAA) provides authority to the Agency to establish
standards to control air pollution and to ensure compliance with
promulgated regulations through adequate recordkeeping and reporting by
the affected industries (i.e., respondents).  The regulations include
the New Source Performance Standards (NSPS) under section 111 of the
Act, the National Emission Standards for Hazardous Air Pollutants
(NESHAP) which includes the original NESHAP standards and the more
recent Maximum Achievable Control Technology (MACT) or NESHAP-MACT
standards under section 112 of the Act, and emission guidelines for the
designated types incinerators under section 129 of the Act.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) are used
by regulatory agencies, the public and the regulated community for a
variety of reasons including the determination of the respondent(s)
compliance status, analytical studies to demonstrate compliance trends,
and evaluations regarding the efficacy of the promulgated regulations.

The required recordkeeping and reporting are also used to: 1) certify
compliance with the regulations; 2) determine the respondent(s)
compliance with the designated emission limitation(s); 3) notify
regulatory agencies when a standard is violated; 4) evaluate continuous
compliance through the use of emission or operational parameter
monitors; and 5) ensure that plant personnel are following the required
procedures and are periodically trained, as indicated.

3.  Nonduplication, Consultations, and Other Collection Criteria

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

3(a)  Nonduplication

The standards do not require duplication in the collection and reporting
of information.  If the subject standards have not been delegated, the
information is sent directly to the appropriate Environmental Protection
Agency (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.

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 May 6, 2005 (70 FR 24020).  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

 The Agency has taken a number of steps to determine if consultations
are needed to estimate the burden to industry.  Any comments received
since the last ICR renewal including those submitted in response to the
first federal register notice announcing the renewal of this ICR have
been reviewed.  The Agency’s internal industry experts have been
consulted.  The Agency’s internal data sources and any projections of
industry growth over the next three years have been considered.  Based
on this information, we have concluded that additional consultations
would not change our estimate of burden.

The Agency’s primary source of information as reported by industry, in
compliance with the recordkeeping and reporting provisions in the
standard, is the AFS (AIRS Facility Subsystem) which is operated and
maintained by EPA's Office of Compliance.  AFS is EPA’s database for
the collection, maintenance, and retrieval of all compliance data. 
Approximately 100 respondents are currently subject to the regulation,
and our consultations with Agency industry experts regarding the growth
rate for the industry indicated that an additional two respondents per
year will become subject to the regulation over the next three years.

It should be noted that the respondents, the industry trade
association(s) and other interested parties were provided an opportunity
to comment on the burden associated with the standard as it was being
developed and the standard has been previously reviewed to determine the
minimum information needed for compliance purposes.

3(d)  Effects of Less Frequent Collection

The effect of less frequent collection would be a decrease in the margin
of assurance that facilities are achieving the emission reductions
mandated by the CAA through the promulgation of the applicable
regulations.  In addition, the likelihood of detecting the poor
operation and maintenance of control equipment decreases and the
detection of noncompliance becomes problematic.

3(e)  General Guidelines

Neither the reporting nor recordkeeping requirements violate the
regulations established by Office of Management and Budget (OMB) at 5
CFR part 1320, section 1320.5.   

3(f)  Confidentiality

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

3(g)  Sensitive Questions

The recordkeeping and reporting requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are pulp
mills.  The SIC code for the respondents affected by the standards is
SIC (United States Standard Industrial Classification) 2611 which
corresponds to the North American Industry Classification System (NAICS)
322110 for kraft pulp mills.

4(b)  Information Requested

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by 40
CFR part 60, subpart BB.

A source must make the following reports:

Reports for 40 CFR part 60, subpart BB

Construction/reconstruction	60.7(a)(1), 60.15

Actual startup	60.7(a)(3)

Initial performance test results	60.8(a) 

Initial performance test	60.8(d)

Demonstration of continuous monitoring system performance 	60.7(a)(5)

Physical or operational changes	60.7(a)(4)

Opacity or visible emissions observations 	60.7(a)(6)

Semiannual report	60.7(c), 60.284(d)

Excess emissions report	60.7(c), 60.284(d)



	A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart BB



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

60.7(b)



Record continuous monitoring system parameter data.	

60.284(a-c)



Maintain a file of all measurements including, performance test
measurements, and all other information required by this part recorded
in a permanent file suitable for inspection.  The file shall be retained
for at least two years.	

60.7(f)



Electronic Reporting

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

Also regulatory agencies, in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately ten percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate a CMS to monitor and record:
opacity of gases discharged from any recovery furnace; the concentration
of TRS emissions on a dry basis and the percent of oxygen by volume in
the gases discharged from any lime kiln, recovery furnace, digester
system, brown stock washer system, multi-effect evaporator system or
condensate stripper system; the combustion temperature at the point of
incineration of effluent gases which are emitted from a digester system;
the scrubbing liquid supply pressure and pressure loss of the gas stream
to the scrubber emission control device that is discharged from any lime
kiln or smelt dissolving tank.



Perform initial performance tests, use Reference Method 5 test (or
Method 17, if applicable) for particulate matter determination, use
Reference Method 3B for oxygen concentration, use Reference Method 9 for
opacity test, and use Reference Method 16 (or Methods 16A or Method 16B)
for TRS concentration determination, 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 the 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.



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 AIRS (Aerometric Information
Retrieval System) Facility Subsystem (AFS) database.



5(b)  Collection Methodology and Management

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

The results of these evaluations are entered into the AIRS Facility
Subsystem (AFS) which is operated and maintained by EPA's Office of
Compliance.  AFS is EPA’s database for the collection, maintenance,
and retrieval of compliance data for approximately 125,000 industrial
and government-owned facilities.  EPA uses the AFS for tracking air
pollution compliance and enforcement by local and state regulatory
agencies, EPA regional offices and EPA headquarters.  EPA and delegated
authorities can retrieve and analyze the data.

5(c)  Small Entity Flexibility

There are no small businesses affected by this regulation.

5(d)  Collection Schedule

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

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry. 
The individual burdens are expressed under standardized headings
believed to be consistent with the concept of burden under the Paperwork
Reduction Act.  Where 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 respondent burden is shown in Table 1.  The labor hours in Table 1
are based on Agency studies and background documents from the
development of the regulation, Agency knowledge and experience with the
standard, the previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$97.46   ($46.41 + 110%)   

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, Table 2. Civilian Workers, by
occupational and industry group.  The rates are from column 1, Total
compensation.  The rates have been increased by 110% 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 labor and Continuous Emission Monitors
(CEMS).  The capital/start-up 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

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



(A)

Continuous Monitoring Device	

(B)

Capital/Startup Cost for One Respondent	

(C)

Number of New Respondents	

(D)

Total Capital/Startup Costs, 

(B X C)	

(E)

Annual O&M Cost for One Respondent	

(F)

Number of Respondents with O&M	

(G)

Total O&M Costs,

(E X F)



Opacity Monitor	

$40,000	

2	

$80,000	

$8,600	

100	

$860,000



TRS Monitor	

$108,000	

2	

$216,000	

$23,000	

100	

$2,300,000



Incinerator Temperature Monitor	

$8,600	

2	

$17,200	

$4,600	

100	

$460,000



Scrubber Liquid Supply Pressure Monitor	

$350	

2	

$700	

$0	

100	

$0



Scrubber Liquid Flow Rate Monitor	

$15,500	

2	

$31,000	

$0	

100	

$0



Total Cost	

	

	

  =SUM(ABOVE) \# "$#,##0"  $344,900 

	

  =SUM(ABOVE) \# "$#,##0"  $3,620,000 



The total capital/startup costs for this ICR is the total of column D. 
This is shown on the OMB 83-I form in block 14(a), Total annualized
capital/startup costs.

The total operation and maintenance (O&M) costs for this ICR is the
total of column G.  This is shown on the OMB 83-I form in block 14(b),
Total annual costs (O&M).

The total respondent costs in block 14 have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  The average annual costs for capital/startup and
operation and maintenance costs to industry over the next three years of
the ICR is shown on the OMB 83-I form in block 14(c), Total annualized
cost requested.  The numbers in block 14 of the OMB 83-I form are
rounded to show the cost in thousands of dollars.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those associated with analysis of the
reported information.  EPA's overall compliance and enforcement program
includes activities such as the examination of records maintained by the
respondents and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
shown in Table 2, attached.

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

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

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

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

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

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

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents	

(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

2	

96	

0	

0	

98



2	

2	

98	

0	

0	

100



3	

2	

100	

0	

0	

102



Average	

2	

98	

0	

0	

100

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

To avoid double-counting respondents column D is subtracted.  The
average Number of Respondents over the three-year period of this ICR is
shown in column D.  This number appears on the OMB 83-I form in block
13(a), Number of respondents. 

The total number of annual responses per year is calculated using the
following table:

Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents	

(C)

Number of Responses	

(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	

(E)

Total Annual Responses 

E=(BxC)+D

Notification of construction/

Reconstruction	

2	

1	

0	

2

Notification of performance test	

2	

1.2	

0	

2.4

Notification of actual startup   SEQ CHAPTER \h \r 1 	

2	

1	

0	

2

Notification of CMS demonstration	

2	

1	

0	

2

Notification of physical or operational changes	

2	

1	

0	

2

Notification of opacity or visible emissions observations	

2	

1	

0	

2

Report of performance test	

2	

1.2	

0	

2.4



Semiannual report	

100	

2	

0	

200



Excess emissions report	

100	

2	

0	

200

	





Total	

415



The number of Total Annual Responses is shown in column E.  This number
is shown on the OMB 83-I form in block 13(b), Total annual responses.

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor cost may be found in Table 1.

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

6(e)  Bottom Line Burden Hours Burden Hours And Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.

6(f)  Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to an
adjustment.  The adjustment increase in burden from the most recently
approved ICR is due to an increase in the number of kraft pulp mills
that become subject to subpart BB, and an expansion of the burden and
cost calculations to include managerial and clerical labor rates.  The
increase in O&M costs is due to an increase in equipment maintenance
costs.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 37 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, disclose, or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; to develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating and verifying
information, processing and maintaining information, and disclosing and
providing information; to adjust the existing ways to comply with any
previously applicable instructions and requirements; to train personnel
to be able to respond to a collection of information; to search data
sources; to complete and review the collection of information; and to
transmit or otherwise disclose the information.

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

	To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
 EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2005-0039, which is available for online viewing at 
www.regulations.gov,  or in person viewing at the Enforcement and
Compliance  Docket and  Information Center in the EPA Docket Center
(EPA/DC),  EPA West, Room B102, 1301 Constitution Avenue, 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 is (202)566-1752.  An electronic version of the
public docket is available through EPA Dockets www.regulations.gov. 
This site can be used to submit or view public comments, access the
index listing of the contents of the public 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 above.  You can also send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725
17th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. 
Please include the EPA Docket Number:  EPA-HQ OECA-2005-0039, and OMB
Control Number 2060-0021 in any correspondence.

Part B of the Supporting Statement

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



TABLE 1:  ANNUAL RESPONDENT BURDEN AND COST:  NEW SOURCE PERFORMANCE
STANDARD (NSPS) FOR KRAFT PULP MILLS (40 CFR PART 60, SUBPART BB)

	REPORTING/

RECORDKEEPING REQUIREMENT	Hours/

Occurrence

(A)	Occurrences/  Year 

(B)	Hours/Year   (C=AxB)

 (C)	Respondents/

Year

(D)	Technical

Person Hours

(E=CxD)

	Managerial

Person Hours

(Ex0.05)	Clerical Person Hours

(Ex0.10)	Total Costs/Year    

(F)

1.	APPLICATIONS	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

2.	SURVEY AND STUDIES	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

3.	REPORTING REQUIREMENTS









	a.	Read Instructions	1	1	1	2	2	0.1	0.2	$186

	b.	Required Activities











	Initial Performance Tests	374	1	374	2	748	37.4	74.8	$69,443



	Repeat of Performance Tests	370	0.2	74	2	148	7.4	14.8	$13,740

	c.	Gather Existing Information

------------------------Included in 3b----------------------------

	d.	Write Report











	Notification of Construction/Reconstruction	2	1	2	2	4	0.2	0.4	$371



	Notification of Performance Test	2	1.2	2.4	2	4.8	0.2	0.5	$446



	Notification of Actual Startup	2	1	2	2	4	0.2	0.4	$371



	Notification of CMS Demonstration	2	1	2	2	4	0.2	0.4	$371



















Notification of Physical or Operational Changes	2	1	2	2	4	0.2	0.4	$371



	Notification of Opacity or Visible Emissions Observations	2	1	2	2	4	0.2
0.4	$371



	Report of Performance Test

------------------------Included in 3b----------------------------



	Semiannual Report	8	2	16	100	1,600	80	160	148,541



	Excess Emissions Report	8	2	16	100	1,600	80	160	148,541

4.	RECORDKEEPING REQUIREMENTS









	a.	Read Instructions

------------------------Included in 3a----------------------------

	b.	Plan Activities

------------------------Included in 3b----------------------------

	c.	Implement Activities 

------------------------Included in 3b----------------------------

	d.	Develop Record System	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A



	Records of Operating Parameter	0.25	365	91.25	100	9,125	456	913
$847,147

	SUBTOTAL ANNUAL BURDEN



	13,248	662	1,325	$1,229, 899

	GRAND TOTAL





15,235





Assumptions

Number of facilities = 100

Number of new facilities per year = 2

New facilities are kraft pulp mills that modify their recovery furnace
and become subject to NSPS Subpart BB 

Rate of failed performance tests = 20%

Technical labor rate $83.71

Managerial labor rate $97.46

Clerical labor rate $42.55



TABLE 2:  ANNUAL AGENCY BURDEN AND COST:  NEW SOURCE PERFORMANCE
STANDARD (NSPS) FOR KRAFT PULP MILLS (40 CFR PART 60, SUBPART BB)

REPORTING/RECORDKEEPING REQUIREMENT	EPA Hours/Occurrence    (A)
Occurrences/Plant/Year    (B)	EPA Hours/  Year (C=A*B)	Plants/Year

(D)	Technical Person Hours

(E=CxD)	Managerial Person Hours

(Ex0.05)	Clerical Person Hours

(Ex0.10)	Total Costs/Year

(F)

INITIAL PERFORMANCE TESTS









New Plant	24	1	24	2	48	2.4	4.8	$2,237

REPEAT PERFORMANCE TEST









New Plant	24	0.2	4.8	2	9.6	0.5	1	$448

REPORT REVIEW









New Plants









	Notification of Construction	2	1	2	2	4	0.2	0.4	$186

	Notification of Performance Test	0.5	1.2	0.6	2	1.2	0.1	0.1	$56

	Notification of Actual Startup	0.5	1	0.5	2	1	0.1	0.1	$47

	Notification of CMS Demonstration	0.5	1	0.5	2	1	0.1	0.1	$47

	Notification of Physical or Operational Changes	0.5	1	0.5	2	1	0.1	0.1
$47

	Notification of Opacity or Visible Emissions Observations	0.5	1	0.5	2	1
0.1	0.1	$47

	Review Test Results	8	1.2	9.6	2	19.2	1	2	$895

Existing Plants









	Semiannual Reports	4	2	8	100	800	40	80	$37,297











SUBTOTAL ANNUAL BURDEN



	886	45	89	$41,307

GRAND TOTAL





1,020





Assumptions

Number of new plants (per year) = 2

Rate of failed performance tests = 20%

Time required to participate with performance test (hours per plant) =
24

Time require to review construction notification (hours) = 2

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

Time required to review performance test results (hours) = 8

Technical labor rate $41.57

Managerial labor rate $56.02

Clerical labor rate $22.50

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