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 Statement2 

## 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 Emissi ons 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 sour ces within 18 months after its scheduled date of promulgation, then sources must submit a title V permit application beginning on that date. States (with appr oved 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 promulga ted by EPA. EPA has promulgated regulations implementing section 112(j).

This ICR supports the regulations to implem ent section 112(j) (40 CFR part 63, subpart B, §§63.50-56). It addresses the information co llection burden (hours and costs) to industry respondents subject to thes e provisions; State and Local agencies that review applications made and permits issued under these provisions; and th e EPA oversight review of a percentage of

State/Local decisions.

This ICR includes about 20,000 major sour ces (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 ac tivities 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. Howeve r, 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 ame nded in 1990 contains the need and authority3 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 th e 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, CONSULTATION S, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication

The information collection activ ities required under the section 112(j) re gulations are not routinely collected elsewhere by EPA. However, in this situation, the permitting authority may likely have collected much, if not all, of the in formation 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 authoriti es, 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 Prio r 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 in formation 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 secti on 112(j) regulations do not violate any of the Paperwork Reduction Act guidelines contained in 5 CFR 1320.6.

3(f) Confidentiality4 Any information submitted to a permitting au thority with a claim of confidentiality will be safeguarded according to that agency’s policie s 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, Chap ter 1, Part 2, Subpart B -- Confidentiality of

Business Information.

3(g) Sensitive Questions

This section is not applicable. This ICR does not contain any sens itive questions relating to sexual behavior or attitudes, religious beliefs, or other ma tters usually considered private.

4. THE RESPONDENTS AND TH E INFORMATION REQUESTED

4(a) Respondents/SIC Codes

Respondents include owners/operators of major sources of hazardous air pollutants (HAPs) in the following source categories: polyv inyl 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 y ear 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 cate gory cuts across a wide variet y of industries, including both manufacturing and nonmanufacturing sources.

4(b) Information Requested

(i) Data items, including recordkeeping requirements

Implementation of the section 112(j) progr am 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 c onditions. 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 informati on and develop case-by-case MACT, followed by the permitting process and incorporation into th e permit. EPA will provide oversight to the

process.

(ii) Respondent Activities5 Activities (see Table 2) that the ow ner 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 applic ations 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 a ffected by these regulations will have the responsibility of submitting Part 1 and Part 2 appl ications to the permitting authority. It is the responsibility of the permitting authority to pr ovide 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 submitte d by the applicant on a case-by-case basis. The6 permitting authority’s employees will handle confidential information submitted by the applicant according to the permitting authority’s conf idential 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 burde n for all sizes of organizations is a continuing effort on EPA’s part. EPA has redu ced 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 sour ce affected by the sect ion 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 secti on 112(j) permitting process for major sources, each respondent must submit the permit a pplication in two parts as specifi ed in section 4( b)(i) of this Supporting Statement. Most, if not all, of the information require d in the Part 2 application will have already been submitted to the permitting author ity 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 applic ations) and compliance costs. The permit will be developed and issue duri ng the term of this ICR.

6(b) Estimating Respondent Costs

(i) Labor costs

Wage rates for industry respondents were retr ieved 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-ti me and part-time status, June 2007). The7 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 associat ed costs per occurrence for each activity in each part of the applic ation process for existing and new sources.

(ii) Capital and Operati on and Maintenance Costs

Though difficult to determine because of the case-by-case nature of 112(j) determinations, we do not anticipate that capita l or operation and mainte nance 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 activit ies for State/Local agen cies are divided into the activities that would take place for both part s of the application pr ocess 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 sub categories and emission points that had none (a major issue in the vacaturs); on ce 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 pe rcent of total compensation: State and local government workers, by occupational group and fu ll-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 th e 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 wo rker. 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/Tribal8 agencies for existing sources and new sources, respectively.

6(d) Estimating Agency Burden and Cost

Under the section 112(j) regul ations, 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 cleri cal personnel. We divided the annual pay rate by 2080, the amount of working hours during a calenda r 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 occurren ce 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 promul gated 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 boile rs rule, the court indicated that EPA had inappropriately

included certain faci lities 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 cost9 associated with the section 112(j) regulations are 1,134,067 hours and $6 6,001,087 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 botto m 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 th e 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 co vered by the MACT standards that have been vacated by the United States Court of Appeals for th e 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 perm it review and approval process.

This ICR also estimates the number of re sponses 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 st andards, we have not calculated compliance costs for the ICR. Finally, EPA has updated the labor ra tes for respondents, Stat e, 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 th e 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 pe rmit 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 a nd $364,887 for the EPA. Table 5 presents the annual burden for respondents, State/Local ag encies, and the EPA over the next 3 years.

Burden means the total time, effort, or financial resources expended by persons to10 generate, maintain, retain, or disc lose 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, valida ting, and verifying information, processing and ways to comply with any previously applicable instructions and requireme nts; train personnel to be able to respond to a collection of information; search data sources; co mplete and review the collection of information; and transmit or otherw ise disclose the information. An agency may not conduct or sponsor, and a person is not requi red to respond to, a collection of information unless it displays a currently valid OMB contro l number. The OMB control numbers for EPA’s regulations are listed in 40 CF R 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 co llection techniques to the Di rector, 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. In clude the EPA ICR number and OMB control number in any correspondence.



## Part B of the Sup porting Statement

This section is not applicable because st atistical methods are no t used in the data

collection associated with th e section 112(j) regulations.11 

### TABLES12Table 1. Source Categories for which MACT Standards have been vacatedSource Category Estimated# of sources atpromulgationEstimated growth rate Years sincepromulgation Total estimated numberof sourcesPolyvinyl chloride and copolymersproduction (Part 63, Subpart J)28 – 5 28Brick and structural clay productsmanufacturing (Part 63, Subpart JJJJJ)68 3/yr 4 80Clay ceramics manufacturing (Part 63,Subpart KKKKK)8 1/yr 4 12Industrial, Commercial, andInstitutional Boilers and ProcessHeaters (Part 63, Subpart DDDDD)58,000 boilers(~19,000 facilities)800/yr 3 60,400 boilers(~20,000 facilities)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 EP A 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)16Table 5. Administrative Burden and Cost Estimatesfor Respondents, State and Local Agencies, and the EPANumber of112(j)OccurrencesTotalRespondentBurden HoursTotalRespondentCostsTotalState/LocalBurden HoursTotalState/LocalCostsTotal EPABurden HoursaTotal EPACostscTotal BurdenHours112(j)AdministrativeCosts(hr) (hr) (hr) (hr)Existing 19,000 1,647,300 $106,662,200 1,565,600 $80,400,970 19,190.0 $1,039,927 3,232,090 $188,103,097New 1,000 86,700 $5,613,800 82,400 $4,231,630 1,010.0 $54,733 170,110 $9,900,1633- Year Total 20,000 1,734,000 $112,276,000 1,648,000 $84,632,600 20,200 $1,094,660 3,402,200 $198,003,260Annual Average 6,667 578,000 $37,425,333 549,333 $28,210,867 6,733 $364,887 1,134,067 $66,001,087aEPA only reviews 10% of permit applications.Table 6. Bottom Line Burden and Cost Estimate for the Section 112(j) ProgramNumber ofRespondentsaTotal HoursRequested Total Costs(hr)3-Year Total20,000 3,402,200$198,003,260Annual Average 6,667 1,134,067 $66,001,087aNumber 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.