1

Information Collection Request for Requirements for Control 

Technology Determinations from Major Sources in Accordance 

with Clean Air Act Sections, Sections 112(g) and 112(j). 

Supporting Statement 
2

PART A OF THE SUPPORTING STATEMENT 

1. IDENTIFICATION OF THE INFORMATION COLLECTION

(a) Title and Number of the Information Collection

 

ICR: Control Technology for Equivalent Emissions Limitations by Permit under section 112(j) 

of the Clean Air Act. 

OMB Control Number: 2060-0266, EPA ICR # 1648.06. 

(b) Short Characterization

 Section 112(j) of the Clean Air Act as amended in 1990 (CAAA) requires that if EPA 

fails to promulgate a standard for a category or subcategory of major sources within 18 months 

after its scheduled date of promulgation, then sources must submit a title V permit application 

beginning on that date. States (with approved Title V operating permit programs) or EPA will 

issue permits containing MACT emission limitations determined on a case-by-case basis to be 

equivalent to what would have been promulgated by EPA. EPA has promulgated regulations 

implementing section 112(j). 

 This ICR supports the regulations to implement section 112(j) (40 CFR part 63, subpart 

B, §§63.50-56). It addresses the information collection burden (hours and costs) to industry 

respondents subject to these provisions; State and Local agencies that review applications made 

and permits issued under these provisions; and the EPA oversight review of a percentage of 

State/Local decisions. 

 This ICR includes about 20,000 major sources (see Table 1) contained in 4 source 

categories for which MACT standards have been vacated by the United States Court of Appeals 

for the District of Columbia Circuit. We estimate up to about 20,000 existing and new sources 

may have to participate in the development of case-by-case MACT permit applications. The 

average administrative cost per source to these activities is estimated to be $5,613.80 per source. 

Total estimated administrative costs may be up to $198,003,260 for all sources in all 4 source 

categories over the next three years. However, we expect revised MACT standards to be 

promulgated within the next three years, which will reduce the total burden associated with this 

ICR. 

2. NEED FOR AND USE OF THE COLLECTION

(a) Need/Authority for the Collection

 Section 112(j) of the Clean Air Act as amended in 1990 contains the need and authority 
3

for this information collection. [42 U.S.C. 7401 (et.seq.) as amended by Public Law 101-549] 

(b) Practical Utility/Users of the Data

The information collected in the application documents will be used for the purposes of 

permit approval, compliance determination, and the selection of particular control technology on 

a case-by-case basis. The Federal or State administrator of the operating permits program will 

use the information for the case-by-case emission limit determinations. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

 CRITERIA

3(a) Nonduplication

The information collection activities required under the section 112(j) regulations are not 

routinely collected elsewhere by EPA. However, in this situation, the permitting authority may 

likely have collected much, if not all, of the information items previously in support of other 

applications in the course of implementing or preparing to implement the MACT standards that 

have been vacated. Most permitting authorities, though, will likely accept references to 

previously submitted information in lieu of significant duplication, in accordance with 

§63.53(b)(1). 

3(b) Public Notice Required Prior to ICR Submission to OMB

 

 A public review and comment period will occur after proposal of the revised ICR renewal 

in the Federal Register. 

3(c) Consultations 

 

 EPA did not consult with anyone since the previous ICR renewal. 

3(d) Effects of Less Frequent Collection

 Each applicant would submit the required information only once (a permit application) 

over the term of this ICR. There is no less frequent collection. 

3(e) General Guidelines

 The recordkeeping and reporting requirements contained in the section 112(j) regulations 

do not violate any of the Paperwork Reduction Act guidelines contained in 5 CFR 1320.6. 

3(f) Confidentiality
4

 Any information submitted to a permitting authority with a claim of confidentiality will 

be safeguarded according to that agency’s policies set forth prior to approval of the agency’s 

operating permit program by EPA. Any confidential information submitted to EPA will be 

safeguarded according to policies in 40 CFR, Chapter 1, Part 2, Subpart B -- Confidentiality of 

Business Information. 

3(g) Sensitive Questions

 

 This section is not applicable. This ICR does not contain any sensitive questions relating 

to sexual behavior or attitudes, religious beliefs, or other matters usually considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) Respondents/SIC Codes

 Respondents include owners/operators of major sources of hazardous air pollutants 

(HAPs) in the following source categories: polyvinyl chloride and copolymers production, brick 

and structural clay products manufacturing, clay ceramics manufacturing, and industrial, 

commercial, and institutional boilers and process heaters (Table 1). A major source is one that 

has the potential to emit more than 10 tons per year of any HAP, 25 tons per year for the total of 

all HAP, or amounts exceeding any lesser quantity cutoff established pursuant to §112(a)(1) of 

the CAA. The boilers source category cuts across a wide variety of industries, including both 

manufacturing and nonmanufacturing sources. 

4(b) Information Requested

(i) Data items, including recordkeeping requirements

 Implementation of the section 112(j) program involves information submitted with the 

application for a section 112(j) determination and development of permit terms and conditions. 

Section 112(j) does not contain recordkeeping requirements per se but will require them to 

determine compliance with permit terms and conditions. Implementation of permit terms and 

condition is estimated to occur after the term of this ICR. 

 The section 112(j) regulations require a 2-part application. Sources will participate in 

development of the permit and maintain a file of the permit. State and local agencies that 

develop the permit will review the information and develop case-by-case MACT, followed by 

the permitting process and incorporation into the permit. EPA will provide oversight to the 

process. 

(ii) Respondent Activities
5

 

Activities (see Table 2) that the owner or operator must perform are: 

Develop and submit Part 1 and Part 2 applications 

File and maintain the permit application 

Work with the permitting authority to develop the permit 

Participate in the public hearing 

File and maintain the final permit

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

 METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

 This section addresses the activities of State and Local agencies, as the permitting 

authority, and EPA, in an oversight capacity. The permitting authority, typically the State or 

Local air agency, will perform the following activities (see Table 3.): 

Review Part 1 and Part 2 applications and deny or approve them 

Develop the emission limitations for the source 

Prepare the draft permit 

Conduct a public hearing 

Interact with EPA 

Review and analyze the public comments 

Issue the permit 

File and maintain the permit 

Acting in an oversight capacity, EPA will perform the following activities (see Table 4): 

Review Part 1 and Part 2 applications 

Review draft permits 

Interact with the permitting authority 

File and maintain the permit 

5(b) Collection Methodology and Management

 The owners or operators of the sources affected by these regulations will have the 

responsibility of submitting Part 1 and Part 2 applications to the permitting authority. It is the 

responsibility of the permitting authority to provide information necessary for EPA oversight 

review. 

 Qualified staff that work for the permitting authority will perform the permit application 

reviews and check the quality of data submitted by the applicant on a case-by-case basis. The 
6

permitting authority’s employees will handle confidential information submitted by the applicant 

according to the permitting authority’s confidential information handling procedures. 

 The section 112(j) regulations do not require the request of information through any type 

of survey. 

5(c) Small Entity Flexibility

 Minimizing the information collection burden for all sizes of organizations is a 

continuing effort on EPA’s part. EPA has reduced the information required by requiring only 

basic information needed by the permitting authority to make a case-by-case MACT 

determination. 

 5(d) Collection Schedule

This ICR does not require surveys. Each source affected by the section 112(j) regulations 

is required to submit a permit application. The permitting authority must then develop a permit 

that contains terms and condition to maintain case-by-case MACT, including recordkeeping and 

reporting. 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

 This ICR requires the calculation of the amount of burden hours associated with each 

activity for each respondent. In the section 112(j) permitting process for major sources, each 

respondent must submit the permit application in two parts as specified in section 4(b)(i) of this 

Supporting Statement. Most, if not all, of the information required in the Part 2 application will 

have already been submitted to the permitting authority in previous permit submittals; we expect 

the burden to be relatively low for this activity. 

 For the section 112(j) regulations, burden for the respondents is a combination of 

administrative costs (preparing the permit applications) and compliance costs. The permit will 

be developed and issue during the term of this ICR. 

6(b) Estimating Respondent Costs

(i) Labor costs

 

 Wage rates for industry respondents were retrieved from the Bureau of Labor Statistics. 

(http://stats.bls.gov/news.release/archives/ecec_09202007.pdf, Table 11. Employer costs per 

hour worked for employee compensation and costs as a percent of total compensation: Private 

Industry workers, by occupational group and full-time and part-time status, June 2007). The 
7

hourly rates are listed as follows: $51.93 for management labor, $44.98 for technical labor, and 

$22.63 for clerical labor. These labor rates were multiplied by 1.5 to account for overhead costs. 

Therefore, we estimated the hourly cost of labor for industry sources submitting permit 

applications to be $77.90 for management labor, $67.47 for technical labor, and $33.94 for 

clerical labor. Table 2 provides a breakdown of labor hours and associated costs per occurrence 

for each activity in each part of the application process for existing and new sources. 

(ii) Capital and Operation and Maintenance Costs

Though difficult to determine because of the case-by-case nature of 112(j) 

determinations, we do not anticipate that capital or operation and maintenance costs associated 

with application of section 112(j) limits will be significantly different than such costs that have 

been expended or were to be expended by sources to comply with the vacated MACT standards. 

6(c) Estimating State/Local Agency Burden and Cost

 Similar to sections 6(a) and 6(b), the activities for State/Local agencies are divided into 

the activities that would take place for both parts of the application process as described in 

section 4(b)(i) of this Supporting Statement. Although the MACT standards were entirely 

vacated, much of those standards can be used as case-by-case MACT. We expect emission 

limitations can be easily developed for those subcategories and emission points that had none (a 

major issue in the vacaturs); once developed, they can easily be applied across the board, and 

thus the burden can be spread across thousands of permits, minimizing the burden for each 

permit. Wage rates for State/Local employees were retrieved from the Bureau of Labor Statistics 

(http://stats.bls.gov/news.release/archives/ecec_09202007.pdf, Table 4. Employer costs per hour 

worked for employee compensation and costs as a percent of total compensation: State and local 

government workers, by occupational group and full-time and part-time status, June 2007) and 

are as follows: $33.11 per hour for management labor, $33.22 per hour for technical labor, and 

$16.39 per hour for clerical labor. We added in the value of total benefits in BLS Table 4. We 

chose 20 percent of the base rate as the percentage of salary that constitutes overhead. The 

addition of benefits and overhead to the hourly rate produces a pay rate that reflects the true cost 

to employ a State, Local, or Tribal agency worker. Following is a summary of the computed 

hourly wages for State, Local, and Tribal agency employees. 

 Hourly Labor Rates for State, Local and Tribal Respondents

Labor Type Hourly Rate Benefits Overhead 

(20 % Salary)

Adjusted Hourly 

Rate

Management $33.11 $14.18 $6.62 $53.91 

Technical $33.22 $13.79 $6.64 $53.65 

Clerical $16.39 $10.21 $3.28 $29.88

 Table 3 provides a breakdown of labor hours and associated costs for State/Local/Tribal 
8

agencies for existing sources and new sources, respectively. 

6(d) Estimating Agency Burden and Cost

 Under the section 112(j) regulations, EPA would serve in an oversight capacity and audit 

approximately 10 percent of all applications processed by State/Local agencies. As 

recommended in the ICR Handbook, wage rates for EPA employees are based upon the Federal 

government pay scale. We calculated the hourly rates for EPA employees using information on 

annual salaries from the Internet site for the Office of Personnel Management. 

(http://www.opm.gov/oca/07tables/pdf/rus_h.pdf; January 2007) . We used the appropriate pay 

grade levels for management, technical, and clerical personnel. We divided the annual pay rate 

by 2080, the amount of working hours during a calendar year, to get the hourly wage rate. We 

then multiplied this rate by 1.6 to produce a pay rate that reflects the true cost to the Federal 

government to employ a worker. The value of 1.6 incorporates the addition of benefits at 40 % 

of salary and the addition of overhead at 20% of salary to the hourly rate. Following is a 

summary of the computed wages for EPA personnel. 

 Hourly Labor Rates for EPA

Labor Type Pay 

Grade

Annual 

Salary

Hourly 

Rate

Benefits 

(40 % Salary)

Overhead 

(20 % Salary)

Adjusted 

Hourly Rate

Management GS-15 $104,826 $50.23 $20.09 $10.05 $80.37 

Technical GS-12 $63,417 $30.39 $12.16 $6.08 $48.63 

Clerical GS-6 $32,172 $15.42 $6.17 $3.08 $24.67

 Table 4 provides a breakdown in the amount of hours associated with each activity and 

the total burden hours and cost per occurrence for existing and new sources, respectively. 

6(e) The Respondent Universe 

 In order to estimate the number of sources subject to the section 112(j) regulations, EPA 

reviewed information in the originally promulgated MACT standards for the 4 source categories 

and allowed for a small amount of growth in the industries. For the boiler source category, EPA 

estimates there are approximately 60,000 boilers at about 20,000 facilities (sources) that would 

be affected. However, for the boilers source category, this estimate is likely high because in the 

court decision vacating the boilers rule, the court indicated that EPA had inappropriately 

included certain facilities in the category. At this time, though, without additional information, 

we are unable to determine a more appropriate estimate. 

6(f) Bottom Line Burden Hours and Cost 

 Over the three-year period of this ICR, the estimated average annual burden and cost 
9

associated with the section 112(j) regulations are 1,134,067 hours and $66,001,087 respectively. 

Table 5 contains the total estimated burden and cost breakdown associated with the section 

112(j) regulations. Table 6 provides a summary of the estimated bottom line burden hours and 

costs associated with the section 112(j) regulations. 

6(g) Reasons for Change in Burden 

 The ICR 1648.04 spanned the period in which the section 112(j) rule would have applied 

to any of the 59 source categories covered by the 2000 MACT standards (the 10-year bin). This 

ICR would affect only the 4 source categories covered by the MACT standards that have been 

vacated by the United States Court of Appeals for the District of Columbia Circuit (see Table 1). 

Unlike ICR No. 1648.04, which estimated the burden from the Part 1 application only (because 

all the MACT standards were promulgated before Part 2 applied), this ICR estimates burden for 

preparing and submitting the Parts 1 and 2 permit applications, developing the title V permit 

terms and conditions, and the permit review and approval process. 

 This ICR also estimates the number of responses on a facility basis instead of an 

individual boiler basis as the previous ICR did, because each facility will submit one application 

for the facility, not each boiler. 

 Because we believe that most, if not all, sources subject to the vacated MACT standards 

have already installed controls to meet those standards, we have not calculated compliance costs 

for the ICR. Finally, EPA has updated the labor rates for respondents, State, Local, and Tribal 

agencies, and the EPA as discussed in sections 6(b), (c), and (d) of this ICR. These adjustments 

were made to more accurately reflect the true cost of an hour of labor for the respondents, State, 

Local, and Tribal agencies, and the EPA The unloaded hourly rates are different because they 

are based on the latest available rates from the BLS and the OPM. Table 7 provides a summary 

of the differences between burden hours and costs associated with each occurrence for the 

previous and current ICR. 

 The difference in the burden estimate is due to the adjustments discussed above, 

including number of respondents, submittal of permit applications, development of the permit, 

and updated labor rates. 

6(h) Burden Statement

 This estimate includes all activities associated with the respondents or government 

agencies. Overall, the section 112(j) program will have the following average annual burden: 

578,000 hours and $37,425,333 for respondents; 549,333 hours and $28,210,867 for 

State/Local/Tribal agencies; and 6,733 hours and $364,887 for the EPA. Table 5 presents the 

annual burden for respondents, State/Local agencies, and the EPA over the next 3 years. 

 Burden means the total time, effort, or financial resources expended by persons to 
10

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 

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 currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 

 Send comments on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including 

through the use of automated collection techniques to the Director, Collection Strategies 

Division, Office of Environmental Information, U.S. Environmental Protection Agency (2822), 

1200 Pennsylvania Avenue, NW, Washington, DC 20460; and 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. Include the EPA ICR number and OMB control 

number in any correspondence. 

Part B of the Supporting Statement

 This section is not applicable because statistical methods are not used in the data 

collection associated with the section 112(j) regulations. 
11

TABLES

 
12

Table 1. Source Categories for which MACT Standards have been vacated

Source Category Estimated # of sources at 

promulgation 

Estimated growth rate Years since promulgation Total estim

of sources 

Polyvinyl chloride and copolymers production (Part 63, Subpart J) 

28 – 5 28 

Brick and structural clay products manufacturing (Part 63, Subpart JJJJJ) 

68 3/yr 4 80 

Clay ceramics manufacturing (Part 63, Subpart KKKKK) 

8 1/yr 4 12 

Industrial, Commercial, and Institutional Boilers and Process Heaters (Part 63, Subpart DDDDD) 

58,000 boilers (~19,000 facilities) 

800/yr 3 60,400 boi

(~20,000 f
13

 Table 2. Summary of Activities, Labor Hours, and Administrative Costs for Respondents

Activity

Management Technical Clerical Total

Wage Rate ($/hr) $77.90 $67.47 $33.94

A. Read applicable regulations to determine 

source applicability 0.5 1.0 0.0 1.5

Cost of A per occurrence $38.95 $67.47 $0.00 $106.42

B. Collect basic information to fulfill 63.53(a) 0.0 1.0 0.0 1.0

Cost of B per occurrence $0.00 $67.47 $0.00 $67.47

C. Prepare and submit Part 1 application 0.5 1.0 0.5 2.0

Cost of C per occurrence $38.95 $67.47 $16.97 $123.39

D. File and maintain Part 1 application 0.0 0.0 0.2 0.2

Cost of D per occurrence $0.00 $0.00 $6.79 $6.79

E. Collect information required by 

63.53(b)(2) 0.0 4.0 0.0 4.0

Cost of E per occurrence $0.00 $269.88 $0.00 $269.88

F. Fulfill any state or local requirements as 

set forth by 63.53(b)(2)(iii) 1.0 4.0 0.0 5.0

Cost of F per occurrence $77.90 $269.88 $0.00 $347.78

G. Process, compile, and review Part 2 

application for accuracy and appropriateness 1.0 8.0 2.0 11.0

Cost of G per occurrence $77.90 $539.76 $67.88 $685.54

H. Complete and submit Part 2 application 1.0 4.0 2.0 7.0

Cost of H per occurrence $77.90 $269.88 $67.88 $415.66

I. Store, file, and maintain application 

information 0.5 1.0 1.0 2.5

Cost of I per occurrence $38.95 $67.47 $33.94 $140.36

J. Draft permit interaction 5.0 30.0 5.0 40.0

Cost of J per occurrence $389.50 $2,024.10 $169.70 $2,583.30

K. Public hearing participation 5.0 5.0 0.0 10.0

Cost of K per occurrence $389.50 $337.35 $0.00 $726.85

L. Store, file, and maintain permit 0.5 1.0 1.0 2.5

Cost of L per occurrence $38.95 $67.47 $33.94 $140.36

Total Hours per Occurrence (hr/occ) 15.0 60.0 11.7 86.7

Total Cost per Occurrence ($/occ) $1,168.50 $4,048.20 $397.10 $5,613.80

Labor Hours per Occurrence (hr/occ)
14

 Table 3. Summary of Activities, Labor Hours, and Administrative Costs for S/L/T Agencies

Activity

Management Technical Clerical Total

Wage Rate ($/hr) 53.91 53.65 29.88

A. Answer respondents questions about 

submitting applications 0.0 0.2 0.0 0.2

Cost of A per occurrence $0.00 $10.73 $0.00 $10.73

B. Review and file Part 1 applications 0.1 1.0 0.1 1.2

Cost of B per occurrence $5.39 $53.65 $2.99 $62.03

C. Review Part 2 applications for technical 

completeness 0.0 4.0 0.0 4.0

Cost of C per occurrence $0.00 $214.60 $0.00 $214.60

D. Analyze requests for confidentiality and 

provide protection 0.0 1.0 0.0 1.0

Cost of D per occurrence $0.00 $53.65 $0.00 $53.65

E. Approve or disapprove application and 

notify respondents of decision 0.5 2.0 1.0 3.5

Cost of E per occurrence $26.96 $107.30 $29.88 $164.14

F. Set emission limitations on a case-bycase basis 1.0 10.0 2.0 13.0

Cost of F per occurrence $53.91 $536.50 $59.76 $650.17

G. Prepare draft permit 2.0 20.0 2.0 24.0

Cost of G per occurrence $107.82 $1,073.00 $59.76 $1,240.58

H. Public hearing 5.0 5.0 1.0 11.0

Cost of H per occurrence $269.55 $268.25 $29.88 $567.68

I. Interaction with EPA 2.0 5.0 0.0 7.0

Cost of I per occurrence $107.82 $268.25 $0.00 $376.07

J. Analyze public comments 2.0 10.0 0.0 12.0

Cost of J per occurrence $107.82 $536.50 $0.00 $644.32

K. Issue permit 0.5 2.0 1.0 3.5

Cost of K per occurrence $26.96 $107.30 $29.88 $164.14

L. File and maintain permit 0.0 1.0 1.0 2.0

Cost of L per occurrence $0.00 $53.65 $29.88 $83.53

Total Hours per Occurrence (hr/occ) 13.1 61.2 8.1 82.4

Total Cost per Occurrence ($/occ) $706.22 $3,283.38 $242.03 $4,231.63

Labor Hours per Occurrence (hr/occ)
15

 Table 4. Summary of Activities, Labor Hours, and Administrative Costs for the EPA

Activity Management Technical Clerical Total

Wage Rate ($/hr) $80.37 $48.63 $24.67

A. Audit and review applications 0.1 0.2 0.1 0.4

Cost of A per Occurrence $8.04 $9.73 $2.47 $20.23

B. Review draft permits 0.0 0.2 0.0 0.2

Cost of B per Occurrence $0.00 $9.73 $0.00 $9.73

C. Interact with the permitting authority 2.0 5.0 0.0 7.0

Cost of C per Occurrence $160.74 $243.15 $0.00 $403.89

D. Store, file, and maintain permit 0.5 1.0 1.0 2.5

Cost of D per Occurrence $40.19 $48.63 $24.67 $113.49

Total Hours per Occurrence (hr/occ) 2.6 6.4 1.1 10.1

Total Cost per Occurrence ($/occ) $208.96 $311.23 $27.14 $547.33

Labor Hours per Occurrence (hr/occ)
16

Table 5. Administrative Burden and Cost Estimates for Respondents, State and Local Agencies, and t

Number of 

112(j) 

Occurrences

Total 

Respondent 

Burden Hours

Total 

Respondent 

Costs

Total 

State/Local 

Burden Hours

Total 

State/Local 

Costs

Total EPA 

Burden Hoursa

Total EPA 

Costsc

(hr) (hr) (hr) 

Existing 19,000 1,647,300 $106,662,200 1,565,600 $80,400,970 19,190.0 $1,039,927 

New 1,000 86,700 $5,613,800 82,400 $4,231,630 1,010.0 $54,733 

3- Year Total 20,000 1,734,000 $112,276,000 1,648,000 $84,632,600 20,200 $1,094,660 

Annual Average 6,667 578,000 $37,425,333 549,333 $28,210,867 6,733 $364,887 

aEPA only reviews 10% of permit applications.

Table 6. Bottom Line Burden and Cost Estimate for the Section 112(j) Program

Number of 

Respondentsa

Total Hours 

Requested Total Costs

(hr)

3-Year Total 20,000 3,402,200 $198,003,260

Annual Average 6,667 1,134,067 $66,001,087

aNumber of Respondents consists of all existing sources affected by the section 112(j) program.
17

Table 7. Comparison of Burden and Costs for Existing Sources for 2002 ICR and Current 

ICR

Parameter Unit 2002 ICR Current ICR

Percent 

Difference

Respondent Burden Hours per 

Occurrence (hr/occ) 4.7 86.7 1745%

State/Local Burden Hours per 

Occurrence (hr/occ) 1.4 82.4 5786%

EPA Burden Hours per 

Occurrence (hr/occ) 0.6 10.1 1583%

Total Hourly Wage Rate per 

Occurrence (Respondents) ($/hr) 55 65 18%

Total Hourly Wage Rate per 

Occurrence (State/Local 

Agencies) ($/hr) 43 51 19%

Total Hourly Wage Rate per 

Occurrence (EPA) ($/hr) 47 54 15%

Respondent Cost per 

Occurrence ($/occ) 260 5,614 2059%

State/Local Cost per 

Occurrence ($/occ) 61 4,232 6838%

EPA Cost per Occurrence ($/occ) 24 547 2179%

NOTE: Each occurrence is a combined Part 1 and Part 2 application.