SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Metal Coil Surface Coating (40 CFR part 60, subpart TT)
(Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NSPS for Metal Coil Surface Coating (40 CFR part 60, subpart TT)
(Renewal)

	1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS) for the regulations
published at 40 CFR part 60, subpart TT were proposed on January 5, 1981
and promulgated on November 1, 1982.  These regulations apply to the
following surface coating lines in the metal coil surface coating
industry: each prime coat operation, each finish coat operation, and
each prime and finish coat operation cured simultaneously where the
finish coat is applied wet on wet over the prime coat.  These
regulations apply to metal coil coating facilities commencing
construction, modification or reconstruction after the date of proposal.
 This information is being collected to assure compliance with 40 CFR
part 60, subpart TT.

	In general, all New Source Performance Standards (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 158 sources are currently subject to the regulation, and
it is estimated that no 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 Air Facility Subsystem (AFS) data base.

	The Office of Management and Budget (OMB) approved the currently active
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 Clean Air Act (Act) 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 TT.

	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 (Air 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 158 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 zero 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.  However, most NESHAP standards and a few
NSPS standards require records to be kept more than three years.  In
general, these standards require the respondents to maintain all
records, including reports and notifications, for five years.  The
five-year record retention requirement is consistent with the permit
program at 40 CFR part 70, and the five-year statute of limitations on
which the permit program is based.  

	The retention of records for five years allows EPA to establish the
compliance history of the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. 
If records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting noncompliance.

	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
facilities that conduct surface coating of metal coils.  The United
States Standard Industrial Classification (SIC) code for the respondents
affected by the standards is SIC 3479 that corresponds to the North
American Industry Classification System (NAICS) 332812 for Metal
Coating, Engraving (Except Jewelry and Silverware), and Allied Services
to Manufacturing.

	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 TT.

	A source must make the following reports:

Reports for 40 CFR Part 60, Subpart TT

Construction/reconstruction	60.7(a)(1)

Anticipated startup 	60.7(a)(2)

Actual startup	60.7(a)(3)

Initial performance test results	60.8(a), 60.465(b) 

Initial performance test	60.8(d), 60.465(b)

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

Physical or operational change	60.7(a)(4)



	A source must maintain the following records:

Recordkeeping for 40 CFR Part 60, Subpart TT

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative	60.7(b)

Excess emissions report 	60.7(c), 60.465(c), 60.465(d)

Monthly performance test of volume-weighted average emissions of VOCs
kg/l of coating solids applied	60.463(b), 60.463(c)

Record average VOC content of coatings applied monthly	60.464(a),
60.464(b)

For thermal incineration: install, calibrate, maintain, and operate
temperature monitoring device	60.464(c)

Records are required to be retained for 2 years.  The first two years of
records must be retained at the facility.	60.7(f), 60.465(e)

For catalytic incineration: maintain daily records of upstream and
downstream gas temperature	60.465(e)

Maintain daily records of incinerator combustion temperature, or amounts
of solvent recovered	60.464(c), 60.465(e)



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 device that continuously
records the combustion temperature of any effluent gases incinerated to
achieve compliance.

Perform initial performance test, Reference Method 24, Reference Method
25, or data provided by the formulator of the coating, 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 one or more of 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 Air 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

	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.

	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 percent
to account for the benefit packages available to those employed by
private industry.

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

	The types of industry costs associated with the information collection
activity in the regulations are labor and Continuous Emission Monitors
(CEMs).  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

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)

Temperature	$8,000	0	$0	$2,100	158	$331,800



	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

	

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 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	0	158	0	0	158

2	0	158	0	0	158

3	0	158	0	0	158

Average	0	158	0	0	158

	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	0	1	0	0

Notification of performance test	0	1.2	0	0

Notification of actual startup 	0	1	0	0

Report of performance test	0	1.2	0	0

Emissions report	158	2	0	316

Temperature variance report	126	0.5	0	63



	Total	379



	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 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.  

		(i)  Respondent Tally

	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The annual labor costs are not shown on the OMB 83-I form.  Details
regarding these estimates may be found in Table 1.  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 41 hours per response. 

	The total annual capital/startup and O&M costs to the regulated entity
are 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) Cost.

		(ii) The Agency Tally

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

	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 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 41 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-2005-0037, which is available for public 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, D.C.  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 is
(202) 566-1752.  An electronic version of the public docket is available
at   HYPERLINK "http://www.regulations.gov"  www.regulations.gov . This
site can be used to submit or view public comments, to 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, N.W., Washington, D.C. 20503, Attention: Desk Officer for
EPA.  Please include the EPA Docket ID Number EPA-HQ-OECA-2005-0037 and
OMB Control Number 2060-0107 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) - METAL COIL SURFACE COATING FACILITIES, 40 CFR PART 60,
SUBPART TT

	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	0	0	0	0	$0

	b.	Required Activities











	Initial Performance Tests	60	1	60	0	0	0	0	$0



	Repeat of Performance Tests	60	0.2	12	0	0	0	0	$0

	c.	Gather Existing Information

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

	d.	Write Report











	Notification of Construction/Reconstruction	2	1	2	0	0	0	0	$0



	Notification of Initial Performance Test	2	1	2	0	0	0	0	$0



	Notification of Actual Startup	2	1	2	0	0	0	0	$0



	Report of Performance Test

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



	Emissions Report	5	2	10	158	1,580	79	158	$146,684



	Temperature Variance Report	4	0.5	2	126	252	12.6	25.2	$23,395

4.	RECORDKEEPING REQUIREMENTS









	a.	Read Instructions

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

	b.	Plan Activities

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

	c.	Implement Activities (Monthly Performance Test)	1	12	12	158	1,896
94.8	189.6	$176,021

	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	250	62.5	158	9,875	493.8	987.5
$916,780

	SUBTOTAL ANNUAL BURDEN



	13,603	680	1,360	$1,262,880

	GRAND TOTAL





15,643





Assumptions

Number of facilities 158

Rate of failed performance tests 20%

Percentage of facilities that use incineration 80%

Each plant files an excess emission report every other year and a no
exceedance report twice a year.

Assume operation 250 days per year as specified in the NSPS review
document.

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) - METAL COIL SURFACE COATING FACILITIES, 40 CFR PART 60,
SUBPART TT

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	0	0	0	0	$0

REPEAT PERFORMANCE TEST









New Plant	24	0.2	4.8	0	0	0	0	$0

REPORT REVIEW









New Plant









	Notification of Construction	2	1	2	0	0	0	0	$0

	Notification of Initial Startup	0.5	1	0.5	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

	Existing Plant









	VOC Emissions Reports	2	2	4	158	632	31.6	63.2	$29,464

	Temperature Reports	2	0.5	1	126	126	6.3	12.6	$5,874











SUBTOTAL ANNUAL BURDEN



	758	37.9	75.8	$35,338

GRAND TOTAL





871.7





Assumptions

Number of new plants (per year) 0

Rate of failed performance tests 20%

Percentage of sources that use incineration 80%

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 initial test notifications (hours)
0.5

Time required to review performance test results (hours) 8

Technical labor rate $56.02

Managerial labor rate $41.57

Clerical labor rate $22.50

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