1128ss10

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal), EPA ICR Number 1128.10, OMB Control Number 2060-0080

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Secondary Lead Smelters were proposed on June 11, 1973, promulgated on March 8, 1974, and amended October 6, 1975, July 25, 1977, February 14, 1989, and October 17, 2000. These regulations apply to both existing and new secondary lead smelting facilities: any pot furnace of more than 250 kg (550 lb.) charging capacity, blast (cupola) furnaces, and reverberatory furnaces. The affected facilities include any facility producing lead from a lead bearing scrap material by smelting to the metallic form. Blast furnace means any furnace used to recover metal from slag. Reverberatory furnaces include furnaces of various types, e.g., stationary, rotating, rocking and tilting. New facilities include those that commenced construction, modification, or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 60, subpart L.

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.

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 U.S. Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 25 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.

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

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal). The burden to the “Federal Government” burden is attributed entirely to work performed by federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal).

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 emissions from secondary lead smelting facilities 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 L.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where 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(s) 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, leaks are being detected and repaired, and the standard(s) are being met. The performance test may also be observed.

The required reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

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

3(a) Non-duplication

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, duplication does not exist.

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 (77 FR 47631) on August 9, 2012. 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 Online Tracking Information System (OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA 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.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this ICR, we contacted: 1) TRG – Hot Springs, L.L.C., at (501) 262-3420; and 2) Exide Technologies, at (678) 566-9316.

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.

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 proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 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 (CBI) (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 reporting or recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are secondary lead smelting facilities. The SIC code for the respondents affected by the standards is United States Standard Industrial Classification (SIC) 3341, which corresponds to the North American Industry Classification System (NAICS) code 331492 for secondary lead smelters.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L).

A source must make the following reports:

Notifications
Notification of construction/reconstruction.	60.7(a)(1)
Notification of actual startup.	60.7(a)(3)
Initial performance test results	60.8(a)
Initial performance test	60.8(d)
Notification of demonstration of continuous monitoring system.	60.7(a)(5)
Notification of physical or operational change.	60.7(a)(4)
Notification of anticipated date for conducting the opacity observations.	60.7(a)(6)

A source must keep the following records:

Recordkeeping
Startups, shutdowns, and malfunctions, periods where the continuous monitoring system is inoperative.	60.7(b)
Performance test records.	60.7(d)
Records are required to be retained for two years.	60.7(f)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a 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.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure for control device.

Perform initial performance test, Reference Method 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.

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring system. 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

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 Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could 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. 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 OTIS which is operated and maintained by EPA's Office of Compliance. OTIS 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 OTIS 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 to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

The number of small entities potentially affected by this information collection request is estimated to be 48 percent of the respondent universe, or 12 sources. This estimate is based on the distribution of small entities in the industry, which was provided during the development of the NESHAP for Hazardous Air Pollutants at Secondary Lead Smelters. The distribution of small entities subject to the NESHAP is expected to be similar to the distribution at small entities subject to the NSPS.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (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. Wherever 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 37 hours (Total Labor Hours from Table 1 below). 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 $121.44 ($57.83 + 110%)

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “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 costs.

(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 costs. 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 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 $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (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 25 existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject to the standard. The overall average number of respondents, as shown in the table below, is 25 per year.

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

Number of Respondents
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	25	0	0	25
2	0	25	0	0	25
3	0	25	0	0	25
Average	0	25	0	0	25

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

.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 25.

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
Initial notification reports	0	4	0	0
Records of startup, shutdown, and malfunctions	25	0	25	25
			Total	25

The number of Total Annual Responses is 25.

The total annual labor costs are $3,631. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal).

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, and summarized below.

(i) Respondent Tally

The total annual labor hours are 37 at a cost of $3,631. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 hour per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. 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 0 labor hours at a cost of $0. See below Table 2: Average Annual EPA Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment decrease of one burden hour for the respondents due to differences in mathematical rounding. Additionally, there is an increase in burden costs from the most recently approved ICR, which is due to an adjustment in the labor rates. This ICR uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 hour 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 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-2012-0535. 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 docket center is (202) 566-1752. 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-2012-0535 and OMB Control Number 2060-0080 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 Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal)

Burden Item		(A) Respondent Hours per Occurrence (Technical hours)	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (C=A x B)	(D) Number of Respondents per Year a	(E) Technical Hours per Year (E=C x D)	(F) Management Hours per Year (F= E x 0.05)	(G) Clerical Hours per Year (G= E x 0.1)	(H) Total Labor Costs per Year, $ b
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
New sources
a. Read instructions		1	1	1	0	0	0	0	$0
b. Required activities
	Initial performance tests	21	1	21	0	0	0	0	$0
	Repeat of performance tests c	21	0.2	4.2	0	0	0	0	$0
	Method 5 or 9 Testing	3	1.2	3.6	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 d	2	1	2	0	0	0	0	$0
	Notification of initial performance test e	2	1	2	0	0	0	0	$0
	Report of initial performance test	------------------------Included in 3b----------------------------							$0
Subtotal Reporting Requirements						0			$0
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
e. Time to enter information
	Records of startup, shutdown, and malfunctions (SSM) f	1.3	1	1.3	25	32.5	1.63	3.25	$3,631.08
f. Audits		N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Subtotal Recordkeeping Requirements						37			$3,631.08
TOTAL ANNUAL LABOR BURDEN AND COST (rounded)						37			$3,631

Assumptions

^a We have assumed that the average number of respondents that will be subject to the rule will be 25. There will be no additional new source that will become subject to the rule over the three-year period of this ICR.

^b This ICR uses the following labor rates: $121.44 per hour for Executive, Administrative, and Managerial labor; $100.23 per hour for Technical labor, and $50.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 “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 20 percent of respondents will have to repeat initial performance tests.

^d We have assumed that each respondent will take two hours once per year to write construction/reconstruction report.

^e We have assumed that each respondent will take two hours once per year to write the initial performance test report.

^f We have assumed that each respondent will be required to enter SSM information.

Table 2: Average Annual EPA Burden and Cost – NSPS for Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal)

Activity		(A) EPA Hours per Occurence (Technical hours)	(B) Number of Occurences per Plant per Year	(C) EPA Hours per Year (C=A x B)	(D) Plants per Year a	(E) Technical Hours per Year (E=C x D)	(F) Management Hours per Year (F= E x 0.05)	(G) Clerical Hours per Year (G= E x 0.1)	(H) Costs per Year b ($)
Initial Performance Test
	New plant	21	1	21	0	0	0	0	$0
Repeat Performance Test
	New plant	21	0.2	4.2	0	0	0	0	$0
Report Review
	New plant
	Notification of construction c	2	1	2	0	0	0	0	$0
	Notification of initial startup d	0.4	1	0.4	0	0	0	0	$0
	Notification of actual startup d	0.4	1	0.4	0	0	0	0	$0
	Notification of initial test d	0.4	1	0.4	0	0	0	0	$0
	Review Test results f	7	1	7	0	0	0	0	$0
TOTAL ANNUAL BURDEN and COST						0			$0

Assumptions

^a We have assumed that the average number of respondents will be subject to the rule will be 22. There will be no additional new source that will become subject to the rule over the three years of this ICR.

^b We have assumed that the average number of respondents that will be subject to the rule will be 22.

There will be no additional new source that will become subject to the rule over the three

^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 $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM), “2011 General Schedule” which excludes locality rates of pay.

^c We assumed that it will take two hours once per year to review construction report.

^d We assume that it will take 0.4 hours once per year to review report.

^e We assume that it will take seven hours once per year to review results.