1058.09 Supporting Statement for Incinerators

Supporting Statement for NSPS for Incinerators (40 CFR part 60, subpart E)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Incinerators (40 CFR part 60, subpart E)

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Incinerators were promulgated on July 25, 1977. These standards apply to incinerators that charge more than 45 metric tons per day (50 tons per day) of solid waste for the purpose of reducing the volume of the waste after promulgation of NSPS. Solid waste is defined as refuse that is more than 50 percent municipal wastes. This information is being collected to assure compliance with 40 CFR part 60, subpart E.

Owners or operators of the affected facilities described must make one‑time‑only notifications including: (1) notification of any physical or operational change to an existing facility which may increase the regulated pollutant emission rate; (2) notification of the initial performance test, including information necessary to determine the conditions of the performance test; and (3) performance test measurements and results. Owners or operators are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction (SSM) in the operation of an affected facility, or any period during which the monitoring system is inoperative. Monitoring requirements specific to NSPS subpart E, provides information on daily charging rates and the hours of operation.

Approximately 82 sources are currently subject to the regulation. It is estimated that no new sources will become subject to 40 CFR part 60, subpart E in the next three years, as new sources will be subject to 40 CFR part 60, subpart Eb or 40 CFR part 60, subpart AAAA. Large Municipal Waste Combustors (MWC) with a capacity greater than 250 tons per day that are constructed, modified, or reconstructed after September 20, 1994 are subject to 40 CFR part 60, subpart Eb. Small MWCs with capacities of 35 to 250 tons per day of municipal solid waste that commenced construction after August 30, 1999, or commenced reconstruction or modification after June 6, 2001, are subject to 40 CFR part 60, subpart AAAA. While it is not anticipated that new sources will be subject to reporting requirements, existing sources will still need to comply with the recordkeeping requirements of the regulations. The average annual labor cost to industry over the next three years of this Information Collection Request (ICR) is estimated to be $530,926. Annual operation and maintenance costs are estimated to be $205,000 and there are no capital/startup costs associated with this ICR renewal.

Any owner or operator subject to the provisions of this part will 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.

OMB approved the currently active ICR without any ATerms 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 the Administrator's judgment, particulate matter emissions from municipal incinerators 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 E.

2(b) Practical Utility/Users of the Data

The control of emissions of particulate matter from municipal incinerators requires not only the installation of properly designed equipment, but also the operation and maintenance of that equipment. Emissions of particulate matter from municipal incinerators are the result of operation of the affected facilities. The subject standards are achieved by the reduction of particulate matter emissions using control technology and leak detection and repair procedures. The notifications required in the applicable regulations 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 and leaks are being detected and repaired and the regulations are being met.

Performance test reports are needed as these are the Agency's records of a source's initial capability to comply with the emission standards, and serve as a record of the operating conditions under which compliance was achieved. The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the Agency to ensure that facilities that are affected by the NSPS continue to operate the control equipment in compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable regulations, 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 E.

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 their own similar standards to implement the Federal standards, a copy of the report submitted to the state or a 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 October 5, 2006 (71 FR 58853). No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the AFS (Air Facility System) which is operated and maintained by EPA's Office of Compliance. AFS is EPAs database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 82 respondents will be subject to the standard over the three year period covered by this ICR.

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.

It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the First Federal Register Notice. In this case, no comments were received.

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(d)(2).

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 incinerators. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards, which corresponds to the North American Industry Classification System (NAICS) codes, are listed below for source category description.

Standard (40 CFR part 60, subpart E)	SIC Codes	NAICS Codes
Air and Water Resource and Solid Waste Management	9511	924110
Refuse Systems (hazardous waste treatment and disposal)	4953	562211
Refuse Systems (material recovery facilities)	4953	562920
Refuse Systems (other nonhazardous waste treatment and disposal)	4953	562219
Refuse Systems (solid waste combustors and incinerators)	4953	562213
Refuse Systems (solid waste landfills)	4953	562212

Data from a 2000 inventory of large municipal waste combustors (MWCs) and a 2001 inventory of small MWCs indicated that on average 75.5 percent of large and small MWCs are publicly owned, while the remaining 24.5 percent are privately owned.

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR 1320.5(d)(2).

(i) Data Items

All data in this ICR that is recorded and/or reported is required by New Source Performance Standards, for Incinerators (40 CFR part 60, subpart E).

A source must make the following reports:

Notification Reports	Standard Citation by Section
Notification and application of construction or modification.	60.7(a)(1)
Notification of anticipated date of startup.	60.7(a)(2)
Notification of actual startup.	60.7(a)(3)
Notification of physical or operational change which may increase the regulated pollutant emission rate.	60.7(a)(4)
Notification of initial performance tests.	60.8(d), 60.52(a), and 60.54(a)
Initial performance test results, to determine the conditions of the performance test, and performance test measurements and results.	60.8(d), 60.52(a), and 60.54(a)

A source must keep the following records:

Recordkeeping
Records of the occurrence and duration of any startup, shutdown, or malfunction in operation of an affected facility.	60.7(b)
Records of malfunctions of the air pollution control equipment.	60.7(b)
Records of periods when the system is inoperative.	60.7(b)
Records of daily charging rates and hours of operation.	60.53(a)
Records of the initial performance test and performance test measurements and results.	60.8(c), 60.52(a) and 60.54(a)
Maintain records for two years	60.7(f)

Electronic Reporting

Currently, sources are using monitoring equipment that provides parameter data in an automated way, e.g., gases which contain particulate matter. 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. It is estimated that approximately 10 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate compliance monitoring system (CMS) for opacity, or for pressure drop and liquid supply pressure for wet scrubber.

Perform initial performance test, Reference Method 1, 2, 3B, and 5 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.

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.

Currently, sources are using automated monitoring equipment that provides parameter data. 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.

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.

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 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 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 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.

Data from a 1996 inventory of municipal waste combustors indicated that 21 percent of affected sources were located in an area with less than 50,000 people. This was the basis of our estimate for affected small businesses for this ICR renewal.

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 Incinerators (40 CFR part 60,

subpart E).

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 8,393 (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 the following labor rates:

Managerial $93.09 ($44.33 + 110%)

Technical $64.13 ($30.54 + 110%)

Clerical $39.65 ($18.88 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics,

June 2003, “Table 10. Private industry, 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 cost associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one time cost when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors 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 Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Particulate Matter	$5,000	0	0	$2,500	82	$205,000

The total capital/startup costs for this ICR are $0. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this ICR are $205,000. This is the total of column G.

The total respondent 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 cost to industry over the next three years of the ICR is estimated to be $205,000.

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 emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $0. This cost is based on the average hourly labor rate as follows:

Managerial $54.02 (GS-13, Step 5, $33.76 x 1.6)

Technical $40.08 (GS-12, Step 1, $25.05 x 1.6)

Clerical $21.70 (GS-6, Step 3, $13.56 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2004 General Schedule” which excludes locality rates of pay. Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden - NSPS for Incinerators, (40 CFR part 60, subpart E).

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

Based on our research for this ICR, approximately 82 existing sources are currently subject to the standard. It is estimated that no expected additional sources per year will become subject to the standard in the next three years.

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	82	0	0	82
2	0	82	0	0	82
3	0	82	0	0	82
Average	0	82	0	0	82

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

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

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 reports	0	0	0	0
Compliance reports	0	0	0	0
Recordkeeping:
- Records of SSM, emissions monitoring system, and initial performance test results	0	0	82	82
- Records of daily charging rates and hours of operation	0	0	82	82
Total				164

The number of Total Annual Responses is 164. The total annual labor costs are $530,926. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost, NSPS for Incinerators (40 CFR part 60, subpart E). Note that the total annual capital and O&M costs to the regulated entity are $205,000. These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e) Bottom Line Burden Hours 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 are estimated to average 51 hours per response.

6(f) Reasons for Change in Burden

There is no change in burden from the most recently approved ICR.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information are estimated to average 51 hours per response. Burdens 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-2006-0709. 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-2006-0709 and OMB Control Number 2060-0040 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 Incinerators (40 CFR part 60, subpart E).

Burden item	(A) Technical Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical Person-hours per respondent per year (C=AxB)	(D) Respondents per year	(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) Total Cost Per Year a
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Read instructions	1	1	1	0b,c	0	0	0	$0
B. Required activities
Initial performance test d	200	1	200	0b,c	0	0	0	$0
C. Create information on performance test	Included in 3B
D. Gather existing information	Included in 3E
E. Write Report
Notification of construction/reconstruction	2	1	2	0b,c	0	0	0	$0
Notification of actual startup	2	1	2	0b,c	0	0	0	$0
Notification of physical and operational changes which may increase emission rates of any regulated pollutants	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0b,c	0	0	0	$0
Report of initial performance test results	4	1	4	0b,c	0	72,980	0	$0
Compliance status reports e	4	1	4	0	0	0	0	$0
4. Recordkeeping Requirements
A. Read instructions	Included in 4E
B. Plan activities	Included in 4E
C. Implement activities	Included in 4E
D. Develop record system	N/A
E. Time to enter information
a. Record of occurrence and duration of startup, shutdown, or malfunction, emissions monitoring system, and initial performance test results.	1.5	1	1.5	82f	123	6.15	12.3	$8,948.19
b. Records of daily charging g rates and hours of operation	.25	350	87.5	82f	7,175	358.75	717.5	$521,977.67
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal Labor Burden					7,298	364.9	729.8	$530,925.86
TOTAL LABOR BURDEN AND COST (rounded)					8,393			$530,926 (rounded)

Assumptions:

^a This ICR uses the following labor rates: $93.09 per hour for Executive, Administrative, and Managerial labor; $64.13 per hour for Technical labor, and $39.65 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2003, ATable 10. Private industry, by occupational and industry group.@

^b Assume that there will be no new, modified or reconstructed facility constructed for the next three years.

^c Assume that this is a one-time-only cost.

^d Assume it takes 60 technical person-hours for pretests/test preparation, 60 hours for testing, and 80 hours for analysis and report preparation.

^e This rule does not require semiannual reporting, just recordkeeping..

^f Assume that there are eighty-two sources subject to this rule.

^g Assume it will take .25 hours per day for 350 days to record daily charging rates.

Table 2: Average Annual EPA Burden - NSPS for Incinerators (40 CFR part 60, subpart E)

Burden Item	(A) Technical Person Hours Per Occurrence	(B) Number of Occurrences Per Year	(C) Technical Person Hours Per Plant Per Year (C=AxB)	(D) Plants Per Year	(E) Technical Hours Per Year (E=CxD)	(F) Management Hours Per Year (F=0.05xE)	(G) Clerical Hours Per Year (G=0.1xE)	(H) Total a Costs Per Year
Initial Performance Test	40	1	40	0b,c	0	0	0	$0
Repeat initial performance test
1. Retesting preparation	16	1	16	0b,c	0	0	0	$0
2. Retesting d	120	1	120	0b,c	0	0	0	$0
Report Review
Notification of construction/ reconstruction	2	1	2	0b,c	0	0	0	$0
Notification of actual startup	2	1	2	0b,c	0	0	0	$0
Notification of physical and operational changes which may increase emission rates of any regulated pollutant	2	1	2	0	0	0	0	$0
Compliance status report e	4	1	4	0	0	0	0	$0
Test results f	8	1	8	0	0	0	0	$0
Audit and review facility records	6	1	6	0	0	0	0	$0
Subtotal								$0
Travel Expenses	(1 person x 1 plant/yr x 2 day/plant x $50 per diem) + ($400/round trip x1round trips/yr) = $0
TOTAL LABOR BURDEN and COST (rounded)								$0

Assumptions:

^a This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $54.02 for Managerial (GS-13, Step 5, $33.76 x 1.6), $40.08 for Technical (GS-12, Step 1, $25.05 x 1.6) and $21.70 Clerical (GS-6, Step 3, $13.56 x 1.6). These rates are from the Office of Personnel Management (OPM) A2003 General Schedule@ which excludes locality rates of pay.

^b Assume that there will be one new, modified or reconstructed facility constructed over the next three years.

^c Assume that this is a one-time-only cost.

^d Assume that it will take 120 technical person-hours for retesting.

^e This rule does not require semiannual reporting, just recordkeeping.

^f Assume that it will take eight hours to review test results.