SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Grain Elevators (40 CFR part 60, subpart DD) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NSPS for Grain Elevators (40 CFR part 60, subpart DD) (Renewal)

	1(b)  Short Characterization/Abstract	

	The New Source Performance Standards (NSPS), for the regulations
published at 40 CFR part 60, subpart DD were proposed on January 18,
1977, and promulgated on August 3, 1978, and amended on October 17, 2000
(65 FR 61759).  These regulations apply to the following facilities in
grain elevators: each truck unloading station, truck loading station,
railcar unloading station, railcar loading station, grain dryer, and all
grain handling operations commencing construction, modification or
reconstruction after August 3, 1978.  This information is being
collected to assure compliance with 40 CFR part 60, subpart DD.

	In general, all NSPS standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They are also required to maintain records of the
occurrence and duration of any startup, shutdown, or malfunction in the
operation of an affected facility, or any period during which the
monitoring system is inoperative.  These notifications, reports, and
records are essential in determining compliance, and are required of all
affected facilities subject to NSPS.  An annual summary report is also
required.

	Any owner/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.

	Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

	Approximately 200 respondents are currently subject to the regulation,
and it is estimated that no additional respondents per year will become
subject to the regulation over the next three years.

	The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

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

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

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years.

	In addition, section 114(a) states that the Administrator may require
any owner/operator subject to any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

	In the Administrator's judgment, particulate matter emissions from
facilities in grain elevators cause or contribute to air pollution that
may reasonably be anticipated to endanger public health or welfare. 
Therefore, the NSPS were promulgated for this source category at 40 CFR
part 60, subpart DD.

	2(b)  Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard are used to inform the
Agency or delegated authority when a source becomes subject to the
requirements of the regulations.  The reviewing authority may then
inspect the source to check if the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

3.  Nonduplication, Consultations, and Other Collection Criteria

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

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

	3(c)  Consultations

	For the information collection, we referenced the most recent ICR,
consulted with the preparer of the active ICR, and used other resources
to obtain the most recent data available.  We reviewed information
available from the United States Census Bureau, the Air Facility System
(AFS), and websites covering grain elevators.  We also consulted with
the EPA’s Office of Air Quality Planning and Standards, Information
Transfer, the Program Integration Division, the National Grain and Feed
Association, Mr. Randy Gordon, (202) 289-0873, and the North Carolina
Department of Agriculture and Consumer Services, Mr. Nick Lassiter,
(919) 733-7139.

	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 that 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 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

	None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

	The respondents to the recordkeeping and reporting requirements are
lime manufacturing plants.  The United States Standard Industrial
Classification (SIC) codes for the respondents affected by the
standards, which corresponds to the North American Industry
Classification System (NAICS) codes, are listed below for source
category descriptions.

Standard (40 CFR part 60, subpart DD)	SIC Codes	NAICS Codes

Farm Product Warehouse and Storage	4221	493130

Grain and Field Beans (Agents and Brokers)	5153	425120

Grain and Field Beans (Business to Business Electronic Markets)	5153
425110



	4(b)  Information Requested

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

		(i)  Data Items

	All data in this ICR that are recorded and/or reported are required by
NSPS Grain Elevators (40 CFR part 60, subpart DD).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Notification of construction/reconstruction	60.7(a)(1)

Notification of actual startup	60.7(a)(3)

Initial performance test	60.8(d)

Initial performance test results	60.8(a)

Repeat performance tests 	60.7(a)(4)



	A source must make the following reports:

Recordkeeping and Reporting

Record of startup, shutdown, and malfunctions	60.7(b)

Records are required to be retained for two years and kept onsite
60.7(f)

Annual summary report	60.7(d)



Electronic Reporting

	At the present, respondents are using 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 10 percent of the respondents use
electronic reporting.

		(ii)  Respondent Activities	

Respondent Activities

Read instructions.

Perform initial performance test, Reference Method 2, 5, 7, and 9 test,
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.

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

Transmit, or otherwise disclose the information.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources still need
to evaluate the data, this type of monitoring equipment has
significantly reduced the burden associated with monitoring and
recordkeeping.

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).



	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.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs

	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
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 its delegated Authorities can edit,
store, retrieve and analyze the data.

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

	5(c)  Small Entity Flexibility

	A majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these 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.

	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
Grain Elevators (40 CFR part 60, subpart DD) (Renewal).

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  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 2,070
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
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 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 percent
to account for the benefit packages available to those employed by
private industry.

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

	The only costs to the regulated industry resulting from information
collection activities required by the subject standard are labor costs. 
There are no capital/startup or operation and maintenance.

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

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

	6(c)  Estimating Agency Burden and Cost

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

	The average annual Agency cost during the three years of the ICR is
estimated to be $35,297.  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.  Details upon
which this estimate is based appear in Table 2: NSPS for Grain Elevators
(40 CFR part 60, subpart DD) (Renewal).

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

	Based on our research for this ICR, on average over the next three
years, approximately 200 existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject.  The overall average number of respondents, as shown in
the table below is 200 per year.

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

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents	

(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	0	200	0	0	200

2	0	200	0	0	200

3	0	200	0	0	200

Average	0	200	0	0	200



	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 200.  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	0	1	0	0

Notification of actual startup	0	1	0	0

Notification of initial performance test	0	1	0	0

Report of performance tests results	0	1.2	0	0

Annual Summary Report	200	1	0	200



	Total	200



	The number of Total Annual Responses is 200.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

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

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

		(i) Respondent Tally

	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The total annual labor costs are $167,108.  The annual labor costs are
not shown on the OMB 83-I form.  Details regarding these estimates may
be found in Table 1. Annual Respondent Burden and Cost - NSPS for Grain
Elevators (40 CFR part 60, subpart DD).  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 10.35 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $0.  This number is shown on the OMB 83-I form in block 14(c), Total
annualized cost requested.  The cost calculations are detailed in
Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M)
Costs.

		(ii) The Agency Tally

	The average annual Agency burden and cost over next three years is
estimated to be 920 labor hours at a cost of $35,297.  See Table 2.
Annual Agency Burden and Cost - NSPS for Grain Elevators (40 CFR part
60, subpart DD) (Renewal).

	

	6(f)  Reasons for Change in Burden

	The increase in burden hours from the most recently approved ICR is due
primarily to a more accurate accounting of existing sources, an annual
summary report that was inadvertently left out, a revised labor rate,
and to the fact that we are currently accounting for management and
clerical person hours per year which was not shown in the previous ICR.

	After a thorough analysis by the National Grain and Feed Association,
they arrived at two hundred as the number of sources that are subject to
subpart DD, as compared to one hundred and thirty-two in the previous
ICR.

	There is no capital or operations and maintenance costs since there is
no continuous monitoring.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 10.35 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-2005-0026, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  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 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 is (202) 566-1752.  An
electronic version of the public docket is available through FDMS at
www.regulations.gov.  Use FDMS 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.  Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725
17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. 
Please include the EPA Docket ID Number EPA-HQ-OECA-2005-0026 and OMB
Control Number 2060-0082 in any correspondence.

Part B of the Supporting Statement

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

Table 1:  Annual Respondent Burden and Cost - NSPS for Grain Elevators
(40 CFR part 60, subpart DD) (Renewal)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

Occurrences/respondent

per year	

(C)

Person-

Hours/ 

respondent

per year

(C=AxB)	

(D)

Respondent/

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours/year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting Requirements	

	

	

	

	

	

	

	





  A.  Read instructions	

1	

1	

1	

0	

0	

0	

0	

$0



  B.  Required activities:	

	

	

	

	

	

	

	





        Initial performance tests c	

28	

1	

28	

0	

0	

0	

0	

$0



        Repeat of performance test d	

28	

0.2	

5.6	

0	

0	

0	

0	

$0



 C.   Create information	

Included in 3B



	

	

	

	





 D.   Gather existing information	

Included in 3B



	

	

	

	





 E.  Write report











      Notification of construction /            reconstruction	

2	

1	

2	

0	

0	

0	

0	

$0

      

      Notification of actual startup	

2	

1	

2	

0	

0	

0	

0	

$0



      Notification of initial                         performance test
results	

2

	

1	

2	

0	

0	

0	

0	

$0



      Notification of repeat                        performance test
results	

Included in 3B	

	

	

	

	

	



      

     Report of performance test                results	

8	

1.2	

9.6	

0	

0	

0	

0	

$0



     Annual summary report	

8	

1	

8	

200	

1,600	

80	

160	

$148,540.80



  3.  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







 E.  Time to enter information

Records of startup, shutdown,        malfunction	

1	

1	

1	

200	

200	

10	

20	

$18,567.60



F.  Time to train personnel	

N/A	

	

	

	

	

	

	





G. Time for audits	

N/A	

	

	











Subtotals Labor Burden and Cost  	

	

	

	

	

1,800	

90	

180	

$167,108.40



TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	

2,070	

$167,108



Assumptions:

a   There are an estimated total of 200 respondents nationwide which are
subject to this standard.  We have further assumed that there will be no
new net growth for this industry over the three year period of this ICR.


b   This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

c  We have assumed that it will take twenty-eight hours to complete the
initial performance test, which includes Method 9.

d  We have assumed that 20 percent of respondents will have to repeat
the performance test.

e  We have assumed that it will take one hour to record information on
startup, shutdown, malfunction



Table 2.  Average Annual EPA Burden - NSPS for Grain Elevators (40 CFR
part 60, subpart CC) (Renewal)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

per

year  a

	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per

year

(Ex0.1)

	

(H)

Cost, $ b



Initial  performance tests	

24	

1	

24	

0	

0	

0	

0	

$0



Repeat  performance test	

24	

0.2	

4.8	

0	

0	

0	

0	

$0



Report Review:	

	

	

	

	

	

	

	





   Notification of construction	

2	

1	

2	

0	

0	

0	

0	       

 $0



   Notification of actual startup	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



   Notification of initial test	

0.5	

1.2	

0.6	

0	

0	

0	

0	

$0



   Review test results	

8	

1.2	

9.6	

0	

0	

0	

0	

$0



    Review annual summary report	

4	

1	

4	

200	

800	

40	

80	

$35,296.80



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	920	

          $35,297



Assumptions:

a   We have assumed that there are approximately 200 respondents
currently operating in the United States which are subject to the
regulation.  It is estimated that no additional respondents will become
subject to the regulation in the next three years based on information
available on the sector.  Therefore, the average number of respondents
per year is estimated to be 200.

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $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.

 PAGE   14 

 PAGE   15 

