1 

# Part A of the Supporting Statement 1. IDENTIFICATION OF THE INFORMATION COLLECTION 1(a) Title of the Information Collection This Information Collection Request (ICR) is entitled "Application Requirements for the Approval and Delegation of Federal Air Toxics Programs to State, Territorial, L ocal, and Tribal Agencies" and numbered as EPA I CR Number 1643. 0 7 and Office of Management and Budget ( OMB ) Control Number 2060

- 0264. This is a revision of OMB

- approved EPA I CR Number 1643. 0 6 . 1(b) Short Characterization This information collection is an application from State, territorial, local, or tribal agencies (S/L/Ts) for delegatio n of regulations developed under section 112 of the Clean Air Act (Act). In the time frame for this submittal, we, the Environmental Protection Agency (EPA) estimate that the majority

of the delegated regulations will be those developed under section 112( d) of the Act. The procedures and requirements that the S/L/Ts will use to request the delegations are codified as 40 CFR 63, subpart E, in accordance with section 112(l) of the Act. The subpart E regulations contain the following five options for de legation:

• Straight delegation

• Rule adjustment

• Rule substitution

• Equivalency

by permit

• State program approval. Straight delegation is the option where the respondents, S/L/Ts, choose to accept delegation of a section 112 provision and to implement and enforce the provision as written. The S/L/Ts may use the rule adjustment option when they want to substitute a rule and/or requirement that is unequivocall y no less stringent than the otherwise applicable section 112 standard, such as part 63 national emi ssion standards for hazardous air pollutants (NESHAP). They may use rule substitution when they

wish to substitute individual rules and/or requirements in place of the otherwise applicable section 112 standard. They may use the equivalency

by permit opti on when they wish to substitute operating permit terms and conditions for a section 112 standard; this option is only

applicable to a limited number of sources using title V permit terms and conditions. Finally , S/L/Ts may

use the State program approval o ption if they want to substitute their overall air toxics program for the Federal air toxics program; i.e., the section 112(d) standards. The delegation options vary in the ty pes of changes allowed, the level of demonstration required, and the amount of time and process needed to implement them. Respondents must submit any

packages requesting delegation to their EPA Regional office. We must then review and approve, partiall y approve, or disapprove the request based on the subpart E approval criteria.2



### T he request may

onl y take effect after our approval (or partial approval of a subset of the request), public notice, and, in some cases, public comment. Subpart E also contains provisions for delegating accidental release prevention program authorities ( 40 CFR part 68) under the authority of section 112(r) of the Act. In addition, we also reserve the right to review and withdraw an approved S/L/T rule, program, or requirement if we decide it is n ot as stringent as the otherwise applicable Federal standard or if the S/L/T is failing to adequatel y implement or enforce it. Subpart E includes the procedures for this the review and withdrawal process. OMB approved the currently active IC R without any “ Terms of Clearance. ” 2. NEED FOR AND USE OF THE COLLE CTION 2(a) Need / Authority for the Collection The information is needed and used to determine if the entity submitting an application has met the criteria established in the subpart E rule. This information is necessary for the Administrator to deter

mine the acceptability

of approving the S/L/T’s rules, requirements, or programs in lieu of the Federal section 112 rules or programs. The collection of information is authorized under 42 U.S.C. 7401

- 7671q. 2(b) Practical Utility / Users of the Data T his information is necessary for the proper performance of our functions. The information will have practical utility because we will use the information generated from the collection to ensure that the subpart E approval criteria have been met. 3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a) Nonduplication This information collection is not unnecessaril y duplicative of information otherwise reasonabl y accessible to us. Rather, for instances where other reports required b y u s would duplicate information required by this rule (for example, the part 70 operating permits rule), it is possible to use information previously submitted to the EPA to meet the requirements of this information collection. 3(b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this I CR was published in the Federal Register on October 20, 2010 (75 FR 64722 ). No comments were received on the burden published in the Federal Register. 3(c) Consultations3



### The final rule amendments for subpart E were promulgated on September 14, 2000 (65 FR 55810). Since then, we have gained extensive experience in working with the S/L/Ts in delegating section 112(d) NESHAP. We have consulted with know ledgeable EPA staff in the Office of Air Quality

Planning and Standards (OAQPS), and Office of Enforcement and Compliance (OECA) as well as each of the EPA Regional Office Air Toxics Coordinators to assess their experience in the ty pe of delegations used b y the S/L/Ts, the overall number of delegations granted, and the level of effort expended. We used this information to prepare this ICR renewal package. 3(d) Effects of Less Frequent Collection Applicants are onl y required to submit information when they wish to receive delegation of a promulgated section 112 standard. Subpart E specifies the minimum information we require to determine whether their request is approvable. The rule clarifies that the respondent onl y needs to submit material demonstrat ing it meets the up

- front approval requirements one

- time, unless circumstances change at the S/L/T, which would require an updated submittal. The intent of this voluntary program is to encourage S/L/Ts to accept delegation of the Federal section 112 standards, and to allow them to adjust or substitute S/L/T requirements when they can be shown to be at least as stringent as the Federal requirements. These provisions for alternatives will help preserve existing S/L/T programs and prevent dual regulation of sources. We also reserve the right to review and withdraw an approved S/L/T rule, program, or requirement if we decide it is not as stringe nt as the otherwise applicable Federal standard or if the S/L/T is failing to adequatel y implement or enforce it. In this case, the S/L /T would be asked to submit information regarding permits, monitoring, resources, etc. We will use this information to decide if the rule, program, or requirement should be withdrawn. Our ability to review and withdraw approval is needed to ensure we can satisfy our obligations under the Act to implement and enforce the section 112 standards. 3(e) General Guidelines T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 b e 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20 , 1978; 44 FR 17674, March 23, 1979). 3(g) Sensitive Questions4



### 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 Respondent s are S/L/Ts participating in this voluntary program. These government establishments are classified as Air and Water Resource and Solid Waste Management Programs under Standard Industrial Classification (SI C) code 9511 and North American Industry Classif ication Sy stem (NAI CS) code 92411. No industries under any SIC or NAICS codes will be included among respondents. 4(b) Information Requested (i ) Data Items, Including Recordkeeping Requirements The information requirements will vary depending upon the t ype of option an S/L/T chooses for accepting delegation of the Federal standards. The information requirements are as follows: For overall approval to receive delegation (§63.91)

• Confirmation letter from the State Attorney General.

• Demonstration o f respondent’s resources.

• Copy

of the respondent’s statutes, regulations and other requirements that contain appropriate provisions granting authority to implement and enforce the respondent’s rule or program upon approval us.

• Respondent’s implementation s chedule.

• Respondent’s compliance plan.

• Respondent’s enforcement plan. Once respondents have demonstrated they meet the overall approval criteria, they may request straight delegation (§63.91) of the unchanged section 112 standards. This request may be automatic, i.e., the overall delegation established that the respondent agreed to accept delegation of all future NESHAP. Alternatively , the overall delegation may establish a procedure where the respondent requests delegation of individual standards when they are promulgated. Respondents choosing to utilize any of the other options to demonstrate the equivalency of their requirements to the Federal requirements must supply the following information: For the rule adjustment option (§63.92):

• Stringency

and compliance demonstration. For the rule substitution option (§63.93):5



### • Demonstration of S/L/T rule equivalency with the otherwise applicable Federal standard. For the equivalency by permit option (§63.94):

• A list of affected sources and st andards within the respondent’s jurisdiction.

• Draft permit terms and conditions.

• Demonstration of the equivalency of S/L/T permit terms and conditions to the otherwise applicable Federal standard. For the State program approval option (§63.97):

• Source cat egories for submission within the respondent’s jurisdiction.

• Description of enforcement measures for area sources (if the otherwise applicable Federal standard applies to area sources).

• Collection of the respondent’s rules, regulations, permits, implementation plans, or other enforceable mechanisms.

• Equivalency

demonstration of respondents’ alternative rules to the otherwise applicable Federal standard. For the accidental release prevention program (§63.95):

• Demonstration of adequate resources.

• Demonstration of adequate enforcement authority.
• Description of coordination mechanisms. We also have the option of withdrawing a program if we decide that the S/L/T is not properl y implementing its rule or program in lieu of the otherwise applicable Fed eral standard. Under the EP A review and withdrawal option (§63.96), the respondents must submit the following:

• In formation regarding permits, monitoring, resources, etc. (ii) Respondent Activities The respondent activities required b y the rule are li sted in the Table 1a through 1g. These activities vary

by option because of the different ty pes of information required under each option. To the maximum extent practicable, these activities were developed to allow the S/L/Ts to respond in way s that are consistent and compatible with their existing reporting and recordkeeping practices. Note that we onl y anticipate activities related to delegation options described in Tables 1a through 1d during the 3

- ye ar approval period.6



### 5. THE INFORMATION COLLECTED - - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5(a) Agency Activities This section addresses the activities to review the applications submitted by the S/L/Ts under subpart E. The activities vary according to the option used by the S/L/T and are as follows: For the overall approval to receive delegation (§63.91):

• Create a Federal Register notice seeking public comment.

• Review public comments.

• Evaluate the S/L/T submittal.

• Create a Federal Register notice announcing approval or disapproval of the S/L/T submittal. For the straight delegation of individual standards, the Agency will either automatically delegate them to the S/L/T or delegate them in response to a written request, depending on the mechanism established via the o verall approval. If the S/L/T decides to use any of the other options listed within subpart E to demonstrate the equivalency of their rules to the Federal rule, then we will complete both the following activities listed in the applicable option below. For the rule adjustment option (§63.92):

• Create a Federal Register notice seeking public comment.

• Review public comments and S/L/T responses.

• Evaluate the S/L/T submittal.

• Create a Federal Register notice announcing the approval or disapproval of the S/L/ T submittal. For the rule substitution option (§63.93):

• Create a Federal Register notice seeking public comment.

• Review public comments and S/L/T responses.

• Evaluate the S/L/T submittal.

• Create a Federal Register notice announcing approval or disapproval of the S/L/T submittal. For the equivalency by permit option (§63.94):

• Create a Federal Register notice seeking public comment on the up

- front approval of the S/L/T submittal.

• Review public comments and S/L/T responses.

• Create a Federal Register notice announcing approval or disapproval of the S/L/T up

- front submittal.

• Evaluate the draft permit terms and conditions submitted by the S/L/T.7



### • Create a final Federal Register notice announcing approval or disapproval of the draft permit terms and condi tions. For the State program approval option (§63.97):

• Create a Federal Register notice seeking public comment on the up

- front approval of the S/L/T submittal.

• Review public comments and S/L/T responses.

• Create a Federal Register notice announcing approv al or disapproval of the S/L/T submittal.

• Create a Federal Register notice seeking public comment on the specific alternative rule submitted by

the S/L/T.

• Review public comments and S/L/T responses.

• Evaluate the equivalency demonstration submitted by the S /L/T.

• Create a final Federal Register notice announcing approval or disapproval of the alternative rules submitted by the S/L/T. For the accidental release prevention program (§63.95):

• Evaluate and approve or disapprove the S/L/T submittal. Furthermor e, we reserve the right to review and withdraw a S/L/T rule or program if we decide that the program is not as stringent as the otherwise applicable Federal standard. During the EPA review and withdrawal option (§63.96), we conduct the following activities:

• Request information from the affected S/L/T.

• Evaluate technical information, data, and results of an y site visits within the jurisdiction of the S/L/T.

• Create a Federal Register notice announcing our intent to withdraw the S/L/T program or rule.

• Evaluate public comments and S/L/T responses.

• Create a Federal Register notice announcing the final decision. The EPA activities required by the rule and the technical hours associated with them are found in Tables 2a through 2g . Note that we onl y anticipate activities related to delegation options described in Tables 2a through 2d during the 3

- year approval period. 5(b) Collection Methodology and Management All S/L/Ts using subpart E to accept delegation of Federal standards must submit the proper application to us for review and evaluation. They should prepare their applications using guidance we issued in April 2001 to facilitate subpart E implementation. This guidance is available on the internet at www.epa.gov/ttn/atw/112(l)/112

- lpg.html. The regulations contain no forms.8



### Qualified staff that work for the EPA Regional offices as well as EPA Headquarters will review the subpart E applications. The S/L/Ts must supply any calculations and assumptio ns supporting the technical portion of the application, and we will review these supporting materials to verify them. In regard to information management, we have planned and allocated resources for the efficient and effective use of the information, including the processing of the information in a manner which enhances the utility of the information to us and to the public. For example, in most cases, existing S/L/T part 70 operating permit program approvals may be used to meet the up - front approval crit eria in §63.91. The subpart E regulations do not require the request of information through any typ e of survey . Most delegation requests are submitted in hard copy . Submitting agencies are encouraged to work with their applicable EPA Regional office to determine if there are procedures to follow if they wish to use an electronic format. Approvals still have to be sent to the Federal Register for publication, but courtesy copies can be sent to S/L/Ts via e

- mail. 5(c) Small Entity Flexibility Mini mizing the information collection burden for all sizes of organizations is a continuing principle for our efforts. The subpart E regulations only include the application, recordkeeping and reporting requirements we need to determine compliance with the rule. We have reduced the collection burden to the extent practicable and appropriate, including consideration of the resources available to the respondents and clarifying, consolidating, and simplifying the requirements. Furthermore, we do not anticipate that any small entities will be participating in this program. 5(d) Collection Schedule The schedule is tied to the promulgation of Federal section 112 standards. As these are issued, S/L/Ts may

request delegation. Each S/L/T may submit an application under one of the five options discussed in section 1(b). Preparation of an application in compliance with subpart E is a one

- time per standard activity . The subpart E regulations do not require periodic reporting or survey s. 6. ESTIMATING TH E BURDEN AND COST OF THE COLLECTION 6(a) Estimating Respondent Burden This I CR requires the calculation of the amount of burden hours associated with each activity for each respondent (S/L/T) when compl ying with the subpart E regulations. In calculati ng the burden hours for subpart E, we made assumptions about the number of S/L/Ts that would use each option as well as the total number of Federal standards delegated b y each option. We also made assumptions about the ty pe and level of regulatory activity that would result in delegations. During this ICR collection period ( 2011

– 201 4 ), there are three t ypes of section 112 standards potentially

relevant to subpart E delegation. First, the section 112(d) maximum9



### achievable control technology standards (M ACT) that predominantly apply to major source emitters have all been promulgated, and the majority of MACT standards have been delegated to those S/L/Ts willing to accept delegation. In the upcoming clearance period we anticipate that there will be 40 del egation requests for the remaining standards. For example, in EPA Region 6, most States still need to adopt the boiler MACT standards. We are currentl y working to propose and promulgate several standards under the section 112(k) area source program. We anticipate that 11 of these standards will be promulgated during the next I CR collection period, but there is less certainty regarding the number of S/L/Ts that will accept delegation of these standards. In some cases, the S/L/Ts have automatic delegatio n for all section 112(l) standards (e.g., Region VIII S/L/Ts), but other Regions have indicated there may be cases where because of resource constraints, a limited number of affected sources, and/or a sense that the State rules are more restrictive than th e Federal rules, not all S/L/Ts will accept delegation of these rules. For purposes of this anal ys is, we estimate that 80 percent of the S/L/Ts will accept delegation of the area source rules. Based on our consultations as described in section 3(c) and information on the status of the regulatory

development efforts, we assumed that 1 19 S/L/Ts will continue to maintain their subpart E program for the MACT standards

. Thus, the annual effort for all S/L/T results in a total of 3 57 occurrences during the 3

- ye ar clearance period. As described earlier, we assumed that there will be 40 delegation requests (occurrences) for MACT standards during the clearance period by each of the 119 S/L/Ts

. Therefore, it is expected that there will be a total of 4,760 del egation requests. Based on input from the Regional coordinators, we think that 2 of these will be equivalency by permit, 36 of these will be rule substitutions, and 3 will be a rule adjustment. The number of straight delegations was estimated by subtracti ng the other delegation options from the total number of delegation requests. As a result, it is estimated that there will be a total of 4,719 straight delegation requests during the 3

- ye ar clearance period. Figure 1 illustrates the number of occurrences for each option. One reason that these remaining MACTs are still pending is that the S/L/Ts and Regions are still working on the alternative in rules or permits. The total number of occurrences shown in Figure 1 is 5,119

. In the case of area source standards, we assumed that 11 will be promulgated during the 3

- ye ar clearance period and that 80 percent ( 7 9) of the S/L/Ts will take delegation. We assumed the same distribution of delegation options as in 2007 for this group of s tandards, i.e., 80 percent straight delegation, 3 percent rule adjustment, 5 percent rule substitution, 12 percent equivalency by permit. Of these, we assumed half (6 percent) would need to obtain initial approval to use the equivalency

by permit options. The percent of MACT standards delegated per option was multiplied by

the total number of S/L/T taking delegation ( 79 ). The Equivalency by Permit Option is a two

- step process. We assumed participates of this option that are undergoing step two of the del egation process lacked initial approval. We also assumed that one S/L/T might seek to use the program approval option during the 3

- ye ar period. Using this methodology , as illustrated in Figure 2, we calculated the number of occurrences for each option, res ulting in an average number of responses per year of 306

.10



### The average number of responses per ye ar for both, MACT and Area Source standards is 2,013

. Table 3 below summarizes the number of occurrences of delegated request by MACT and Area Source standards. In calculating the burden hours associated with each delegation option, we retained the same activities and burden hour estimates used in the previous ICR (ICR Number 1643. 06 ) for subpart E The total hours associated with each option in ta bles 1a through 1g are for technical hours only . Consistent with the previous ICR, we calculated management hours as 5 percent of technical hours and clerical hours as 10 percent of technical hours. Table 4a contains the results of the burden hours calcu lation for each activity during each ye ar of this I CR. Overall, the promulgated subpart E regulations contain an average burden of 37,107 hours per ye ar. 6(b) Estimating Respondent Cost (i ) Estimating Labor Costs This I CR uses the following labor rates: Managerial $ 60.99 ($ 38.12 + 60 %) Technical $ 35.41 ($ 22.13 + 6 0%) Clerical $ 2 6.17 ($ 16. 36 + 6 0%) Labor rates, on a per

- hour basis, are from the United States Department of Labor, Bureau of Labor Statistics, Oc cupational Employ ment Statistics, May

2009. The occupational category that is the most similar to State and local personnel affected by this rule is assumed to be an average (mean) of “ State Government ” and “ Lo cal Government .” This ICR uses the labor rat es for the following occupations within this category : for technical labor, e nvironmental s cience and p rotection t echnicians ; for managerial labor, all other managers; for clerical labor, secretaries . The hourly mean wage rates plus 6 0% of the hourl y rate for overhead and benefits are included in the per - hour labor rates used to estimate respondent costs

. The resulting rates used are $ 60.99 for management, $ 35.41 for technical personnel, and $ 26.17 for clerical personnel. The respondent labor costs are found b y multiplying the burden hours associated with each activity

by the hourly

rate associated with each labor ty pe. In total, the subpart E regulations contain an average labor cost of $ 1,352 ,000 per ye ar. Table 4a cont ains the results of the calculation of labor costs for the respondents. (ii) Capital / Start

- up Costs This I CR does not require any capital or start

- up costs for equipment, machinery , and construction. (iii) Operating and Maintenance (O&M) Costs11



### Respondents who choose to request delegation under subpart E must submit a complete application, which results in photocopying and postage costs. We determined that two ty pes of documents would be both copied and mailed: 2

- ounce letters and 1

- pound packag es. The 2

- ounce letter would contain 5 pages, and the 1

- pound package would contain 200 pages. Based on the ty pical price to cop y a page, we used $0.0 6 a page as our price per unit cost of copying . The cost for mailing a 2

- ounce letter and 1

- pound packa ge via the United States Postal Service is $0. 61 and $4. 75 , respectivel y. We also assumed that a total of three copies would be made for each letter or package. Tables 5a through 5d show the activities that would require cop ying and postage. Table 6 summarizes the total copying and mailing costs per year. For respondents, the average cost for copying and postage is $3, 1 00 per year. Therefore, the average total cost to respondents, including labor cost of $ 1,352,000 per ye ar and copying/postage cost is $ 1, 355 , 1 00 per ye ar. Table 7 shows this breakdown by year. 6(c) Estimating Agency Burden and Cost Under the subpart E regulations, we must review and evaluate the subpart E applications submitted by

the S/L/Ts. In reviewing and evaluating these appli cations, we will carry out the activities listed in section 5(a) of this ICR. Managerial activities are considered 5 percent of the technical hours while clerical activities are considered 10 percent of the technical hours. This cost is based on the fo llowing hourl y labor:

Managerial $ 86.56 (GS

- 1 5 , Step 5, $ 54.10 + 60%) Technical $ 52.37 (GS

- 12, Step 5 , $ 32.73 + 60%) Clerical $ 26.56 (GS

- 6, Step 5 , $ 16.60 + 60%) These rates are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality rates of pay . The rates have been increased 60 percent to account for the benefit packages available to government employees. The EPA labor costs are found by multiplying the burden hours associated with each activity by the hourl y rate associated with each labor ty pe. Overall, the average burden hours for EPA is 26,067 hours per year. Table 4b contains a breakdown of EPA burden hours per ye ar. The average labor cost for the EPA is $ 1,3 45 ,000 dollars per ye ar. Table 4b contains a breakdown of EPA labor costs per year. Cop yi ng and postal costs for the EPA were calculated in the same manner as described in the last paragra ph of section 6(b). Tables 5a through 5d contain a detailed listing of EPA copying and postal costs. Table 6 presents the total EPA copying and postal costs. The EPA would spend an average of $ 77,5 00 on copying and postage. The total cost for EPA, including labor and cop yi ng/postal costs would be an average of $ 1 ,423 , 0 00 per ye ar. Table 7 shows a breakdown of the total cost for the EPA by year. 6(d) Estimating the Respondent Universe and Total Burden Costs In order to estimate the number of S/L/Ts participating in the subpart E program, we obtained information from the EPA’s Regional Air Toxic Coordinator contacts regarding subpart E delegation activit y in their Regions. We determined that 1 19 agencies are participating in the12



### subpart E program. T he breakdown of these agencies is as follows: 49 State agencies, 2 territorial agencies, and 66 local agencies. 6(e) Bottom Line Burden Hours and Cost (i ) Respondent Tally Over the 3

- ye ar period of this I CR, the total average annual burden and labor cost for the respondents resulting from the subpart E regulations are 37,107 hours and $ 1,352 ,000, respectivel y. Table 4a contains the bottom line estimate of burden hours and labor cost associated with the subpart E regulations. There is no capital start

- up costs associated with this collection. Operation and maintenance costs result from photocopying and postage expenses, which are a total of $ 3,1 00 per ye ar. Table 6 shows the O&M costs. The total average annual cost to respondents is $ 1,355,1 00. Table 7 contains the total estimate of costs associated with the subpart E regulations. (ii) Agenc y Tally Over the 3

- ye ar period of this I CR, the total average annual burden and labor cost for the EPA is 26,067 hours and $ 1,345 , 0 00 , respectivel y. Table 4b contains the bottom line estimate of burden hours and labor cost associated with the subpart E regulations. Operation and maintenance costs result from photocopying and postage expenses, which are a total of $ 7 7, 5 00 per year. Table 6 shows the O&M costs. The total average annual cost to EPA is $ 1,423 , 0 00

. Table 7 contains the total estimate of c osts associated with the subpart E regulations. 6(f) Reasons for Change in Burden The currently

approved reporting and recordkeeping hour burden, based on I CR Number 1643.0 6 , is 62,844 hours per year. We are requesting a de crease in burden to 37,107 hours per ye ar. The change in burden results from: (1) a decrease in the number of S/L/Ts taking delegation, (2) an increase number of occurrences related to the number of NESHAP delegated and ( 3 ) a change in the distribution of S/L/Ts using each option when delegating MACTs . These changes are discussed below. The total number of occurrences increased from 399 to 5,119 for MACT standards partially due to the number of MACT standards being delegated increasing from 24 to 40. However, the number of delegations decreased from 124 to 119. The significant increase was largel y due to a calculation error in determining the number of straight delegations in the previous ICR. The previous ICR estimated 12 occurrences of straight delegations during the c learance period while we calculated 4,719 occurrences for the upcoming 3

- ye ar period. The total number of occurrences decreased for area source standards from 4,177 to 920 due to the number of area source standards decreasing from 40 to 11 and number of de legations dropping from 99 to 79. Second, based on the experience the EPA’s Regional Air Toxics Coordinators have had with the subpart E program, S/L/Ts’ use of the various delegation options has changed for13



### MACTs . Straight Delegation is still the primary delegation mechanism and has significantly increased in frequency

since the previous I CR . However, we found that S/L/Ts are using the Rule Adjustment Option and the Rule Substitution Option with greater frequency than previously assumed. Generall y, sources do not use the State Program Approval Option

. Overall, the respondent hour burden has de creased

. Table 8 below breaks down these changes by

option. While the re is an overall increase in the amount of occurrences, the overall burden de creases by 41 percent due to the significant increase in use of the straight delegation option which requires less hours than the other options

. Similarly , the respondent average total labor c ost per year decreased by $1,6 0 8 ,000 (or 54 percent). The breakdown by option within the subpart E program is shown in table 9 below. In creases or decreases in the total average annual cost for the options reflect the change in the amount of burden for that particular option. The amount of change differs from the change hours, which is largel y due to increases in the average labor wage rates. These rates were updated to reflect current estimates. While mailing costs have increased, we are requesting a decrease in the reporting and recordkeeping cost burden due to an error in the postal costs reported in the previous I CR. Some of the EPA mailing costs were incorrectly included in the sums for Respondent costs, thu s decreasing the overall costs. Our assumptions for copying and postage costs are discussed in section 6(b). The total copying and postage cost for S/L/Ts is $ 3,100 per year, of which 80 percent is associated with obtaining straight delegation of the NESHAP. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of in formation is estimated to average 18 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time need ed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust th e existing way s to comply with an y 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 display s a currently valid OMB control number. The OMB control numbers for EPA’s regulation are listed in 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 t his I CR under Docket ID Number EPA

- HQ

- OAR

- 2004

- 0 065 . An electronic version of the public docket is14



### 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 t he index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search,” then key in the docket ID number identified in this document. The documents are als o available for public viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Air and Radiation Docket Information Center is (202) 566

- 1742

. Also, you can send comments to the Of fice of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OAR

- 2004

- 0 065 and OMB Control Number 2060

- 0264 in an y correspondence. 

# Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.15 

# FIGURES16 Figure 1. Allocation of Subpart E Delegation Options - MACT Standards

a Each MACT is delegated to one S/L/T. The number of agencies taking delegation is equal to the number of MACTs. b Equivalency by Permit is a two

- step process. We assumed S/L/Ts taking delegation under the second step do not already have initial approval. To tal S/L/Ts taking delegation: 119 Total MACT to be delegated over 3

- year period: 40

Straight Delegation (Per MACT) (§63.91) Rule

Adjustment Option (§63.92) Equivalency by Permit Option (I nitial Approval) Equivalency

by Permit Option (Per MACT) (§63.94) Rule Substitution Option (§63.93)

No. Taking Delegation a

Year 1: 1,573 No. Taking

Delegation a No. Taking

Delegation a No. Taking

Delegation b No. Taking

Delegation a

Year 1: 1 Year 1:

12 Year 1:

1 Year 1:

1

Year 2: 1,573

Total: 4,719 Year 3: 1,573 Year 3:

1

Total: 3 Year 2: 1

Year 3:

12

Total: 36 Year 2: 12

Year 3:

0

Total: 2 Year 2: 1

Year 3:

0

Total: 2 Year 2: 1

Total No. of Occurrences: 5,119 Year 1: 119

Year 2: 119

Total: 357 Year 3: 119 Initial Program Approval (§63.91)

No. Maintaining Program17 Figure 2. Allocation of Subpart E Delegation Options - Area Source Standards

a Each MACT is delegated to all 7 9 agencies. The percent of MACT standards delegated per option is multiplied by 7 9

. b Equivalency by Permit is a two

- step process. We assumed that half of the S/L/Ts taking delegation under the second step do not already have initial approval C We assumed no agency would seek State Program Approval during the clearance period. Total S/L/Ts taking delegation: 7 9 Total area source standards to be delegated over 3

- ye ar period: 11

Straight Delegation (Per Standard) (§63.91) Rule

Adjustment Option (§63.92) Equivalency by Permit Option (I nitial Approval) Equivalency

by Permit Option (Per Standard) (§63.94) Rule Substitution Option (§63.93)

% of MACT Standards Delegated: 80

Year 1: 232 Year 1:

9 Year 1:

15 Year 1:

18 Year 1:

36

Year 2: 232

Total: 69 5 Year 3: 231 Year 3:

8

Total: 26 Year 2: 9

Year 3:

14

Total: 43 Year 2: 14

Year 3:

17

Total 52 Year 2: 17

Year 3:

34

Total: 104 Year 2: 34

Total No. of Occurrences: 920 State Program Approval Option (§63.97)

Year 1: 0

Year 3: 0

Total: 0 Year 2: 0 % of MACT Standards Delegated: 3 a % of MACT

Standards Delegated: 5 a % of MACT

Standards Delegated: 6 b % of MACT

Standards Delegated:12 a Number of

Program Approvals: 0 c18 

# TABLES19 Activity A. Read Rule 0 B. Receive Training on Rule 0 C. Plan Process 0 D. Create Confirmation Letter from Attorney General 0 E. Create Adequate Resources Demonstration/ Legal Authority 0 F. Supply a Copy of State Statutes, Regulations, and Requirements 0 G. Create Expeditious Implementation Schedule and Compliance Plan 0 H. Compile, Process, and Review Information 0 I. Create Overall Cover Letter 0 J. Fill Out Completeness Checklist 0 K. Send Submittal to EPA 0 L. Store, File, and Maintain Information 20 Total (hr/yr) 20 M. Request Straight Delegation of NESHAP 10 Table 1a. Activity and Burden for the Overall Approval to

Receive Delegation/Straight Delegation

(§63.91) † Technical Hours

per Occurrence

† For this renewal period, we assumed that all agencies have already completed activities A

- K and have received up

- front delegation.20 Activity Technical Hours per Occurrence
A. Conduct State Rulem ak ing 35 B. Collect Alternative Rule and NESHAP for Analysis and Dem onstrate Stringency 15
C. Fill out Completeness Checklist 1 D. Send Submittal to EPA 1.5 E. Store, File, and Maintain Inform ation 20 Total (hr/yr) 72.5 Table 1b. Activity and Burden for the Rule Adjustm ent Option (§63.92)

Activity A. Conduct Rulemaking and Respond to Public Com ments 45
B. Prepare Equivalency Demonstration Table 60 C. Prepare Narrative Text for Equivalency Demonstration Table 60
D. Prepare Cover Letter and Completeness Checklist for Submittal Package 10

E. Send Submittal to EPA 1.5 F. Respond to Public Comments 25

Total (hr/yr) 221.5 Table 1c. Respondent Activity and Burden for the Rule Substitution Option (§63.93) Technical Hours per Occurrence

G. Store, File, and Maintain Information 2021 Activity Technical

Hours per Occurrence A. Preparation of List of Affected Sources and Affected 112 Standards 20

A. Collection of Draft Terms and Conditions to Submit to EPA 20
B. Alteration of Draft Terms and Conditions 26 C. Preparation of Side-by-Side Comparison of Alternative Requirements 30 D. Preparation of Narrative to Side-by-Side Comparison 30 E. Com pletion of Cover Letter and Com pleteness Checklist for Submittal to EPA 10
F. Send Submittal to EPA 1.5 G. Incorporation of Alternative Requirements into Permits 20 H. Store, File, and Maintain Information 20 Total (hr/yr) 158 Table 1d. Respondent Activities and Burden for the Equivalency by Perm it Option (§63.94)

One-Time Activities

Activities per Standard22 Activity A. Collection of Source Categories for Submission 0 B. Description of Enforcement Measures for Area Sources 15 C. Preparation of Up-front Submittal to EPA 40 A. Participation in the Reviewof Public Comments and Consultations 20
B. Collection of State Rules, Regulations, Permits, Implementation Plans, or Other Enforceable Mechanisms and State Rulemaking 60

C. Preparation of Equivalency Demonstration Table 40 D. Preparation of Narrative to Accompany Equivalency Demonstration Table 40 E. Preparation of Submission to EPA and Completeness Checklist 5
F. Submittal to EPA 1.5 G. Store, File, and Maintain Information 20 Total (hr/yr) 241.5 Table 1e. Respondent Activities and Burden for the State ProgramApproval Option ( § 63 . 97 )
Technical Hours per Occurrence One-time activities

Activities per Standard23 Activity A. Resource Demonstration 5 B. Demonstration of Adequate Enforcement Authority 20 C. Description of Coordination Mechanism 15 D. Preparation of Package for Submission to the EPA 25 Total (hr/yr) 65 Table 1f. Respondent Activities and Burden for the Accidental Release Prevention

Program (§63.95)† Technical

Hours per Occurrenc

†Not expected to use this option during 3

- year period.

Activity A. Respond to Information Requests (permits, monitoring, meetings, etc.) 30 B. S/L/T attempts to correct deficiencies 30 C. Notification to Sources of Withdrawal 40 To tal (hr/yr) 100 Table 1g. Respondent Activities and Burden for the EPA Review and Withdrawal Option

(§63.96)† Technical

Hours per Occurrence

†Not expected to use this option during 3

- year period.24 Activity
A. Review Submission for Completeness 0 B. Notification to State of Complete/Incomplete Application 0

C. Creation of Federal Register Notice to Seek Public Com me nt 0

D. EPA Review of Public Com me nts and S/L/T Responses 0

E. EPA Evaluation of General Criteria 0 F. Creation of Final Federal Register Notice 0 G. Answer Respondent Questions 10 H. Store, File, and Compile Information 10 Total (hr/yr) 20 I. Send Letter Granting Straight Delegation 5 Table 2a. EPA Activities and Burden for the Overall Approval to Receive Delegation/Straight Delegation (§63.91)† Technical Hours per Occurrence

† For this renewal period, we assumed that all agencies have already completed activities. A

- F and have received up

- front delegation.

Activity Technical Hours

per Occurrence A. Creation of Federal Register Notice to Seek Public Com ment 5 B. EPA Review of Public Comm ents and S/L/T Responses 20 C. EPA Evaluation of General Criteria 5 D. Creation of Final Federal Register Notice 5 E. Answer Respondent Questions 15 F. Store, File, and Com pile Information 10 Total (hr/yr) 60 Table 2b. EPA Activities and Burden for the Rule

Adjustment Option (§63.92)25 Activity A. Review Submission for Completeness 10 B. Creation of Federal Register Notice to Seek Public Comment 5
C. EPA Review

of Public Comments 20 D. EPA Evaluation of Equivalency Demonstrations 80 E. Creation of Final Federal Register Notice 10 F. Answer Respondent Questions 35 G. Store, File, and Compile Information 10 Total (hr/yr) 170 Table 2c. EPA Activities and Burden for the Rule

Substitution Option (§63.93) Technical Hours per Occurrence26 Activity† A. Notification of Whether Alternative Rule Submittal is Complete (Letter and Consultations) 10
B. Creation of Federal Register notice for Public Comment for Up-front Approval 5
C. Review

of Public Comments and S/L Responses for Up-front Approval 30 D. Creation of Federal Register Notice to A

pprove/Disapprove Program 25 Total (hr/yr) 70 E. Notification to Respondent of Complete Package of Alternative Term s and Conditions for Approval 10
F. Evaluation of Draft Permit Terms and Conditions 50 G. Creation of Notification of Approved/Disapproved Draft Permit Term s and Conditions (Letters and Meetings) 20

H. Creation of Final Federal Register Notice for Notification 15 I. Answer Respondent Questions 35 J. Store, File, and Maintain Information 10 Total (hr/yr) 140 Table 2d. EPA Activities and Burden for the Equivalency by

Permit Option (§63.94)

Technical Hours per Occurrence One-Time Activities

Activities per Standard

† Assumes that any up

- dates by the respondent to the list of affected sources and standards will be incorporated as part of any individual requests.27 Activity Technical Hours per Occurrence A. Notification by Letter and Meetings of Whether Alternative Rule Submittal is Complete 10

B. Creation of Federal Register Notice for Public Comment for Up-front Approval 5

C. Review of Public Comments and S/L/T Responses for Up-front Approval 30

D. Creation of Federal Register Notice to Approve/Disapprove Submittal 25

E. Notification of Complete Alternative Requirements 10 F. Creation of Federal Register Notice for Public Comment on Alternative Rules 5

G. Review of Public Comments and State Responses on Alternative Rules 40

H. Evaluation of Equivalency Demonstration 40 I. Creation of Final Federal Register Notice for Notification 25 J. Answer Respondent Questions 35 K. File, Store, and Maintain Information 10 Total 235 Table 2e. EPA Activities and Burden for the State ProgramApproval Option (§63.97)†

†Not expected to use this option during 3

- year period.28 Activity Evaluation of Submission for Approval 25 Total (hr) 25 Table 2f. EPA Burden and Activities for the Accidental Release Prevention Program

(§63.95)† Technical Hours

per Occurrence

†Not expected to use this option during 3

- year period.

Activity A. Creation of Request for Information 15 B. Evaluation of Information Submitted by S/L/Ts (Permits, Site Visits, Monitoring Data) 180 C. Letter Informing S/L/T of Inadequate Program 10 D. Creation of Notice for Proposed Withdrawal 15 E. Evaluation of Public Comments and S/L/T Responses 50 F. Notification of Changes for S/L/Ts to Make to Correct Deficiencies 15 G. Notification of Withdrawal 10 H. Publication of Schedule for Compliance 5 Total (hr) 300 Table 2g. EPA Activities and Burden for the EPA Review

and Withdrawal Option (§63.96)† Technical Hours per Occurrence

†Not expected to use this option during 3

- year period.29 Year 1 Year 2 Year 3 Total Option/Year (occ/yr) (occ/yr) (occ/yr) (occ) Overall Delegation(§63.91) 119 119 119 357 Straight Delegation per Standard (§63.91) 1,805 1,805 1,804 5,414 Rule Adjustm ent (§63.92) 10 10 9 29 Rule Substitution (§63.93) 27 26 26 79 Equivalency by Perm it – Initial Approval (§63.94) 19 18 17 54 Equivalency by Perm it – Per Standard (§63.94) 37 35 34 106 State ProgramApproval (§63.97) 0 0 0 0 Accidental Release Prevention Program (§63.95) 0 0 0 0 Withdrawal (§63.96) 0 0 0 0 Total 2,017 2,013 2,009 6,039 Average (occurrences/yr) 2,013 Table 3. Sum ma ry of Delegations by S/L/Ts
Total Num ber of Occurrences per Year b

b Number of occurrences is the sum of MACT standards delegated and area standards delegated (See Figures 1 & 2).30 Year Year 1 Year 2 Year 3 Total Year 1 Year 2 Year 3 To tal Option (hr/yr) (hr/yr) (hr/yr) (hr/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) Straight Delegation (§63.91) -- Administrative Criteria 2,737 2,737 2,737 8,211 98 98 98 293 Straight Delegation (§63.91) -- Delegation of Standard 20,758 20,758 20,746 62,261 741 741 741 2,224 Rule Adjustment Option (§63.92) 834 834 750 2,418 30 30 27 86 Rule Substitution Option (§63.93) 6,878 6,623 6,623 20,123 246 237 237 719 Equivalency by Permit Option (§63.94) -- One-Tim e Application 437 414 391 1,242 16 15 14 44 Equivalency by Permit Option (§63.94) -- per Standard 5,957 5,635 5,474 17,066 240 227 221 688 State Program

Approval Option (§63.97) -- One-Tim e Application 0 0 0 0 0 0 0 0 State Program

Approval Option (§63.97) -- Per Standard a 0 0 0 0 0 0 0 0 Accidental Release Prevention Program (§63.95) 0 0 0 0 0 0 0 0 EPA Review and Withdrawal (§63.96) 0 0 0 0 0 0 0 0 To tal 37,600 37,000 36,721 111,321 1,370 1,347 1,337 4,055 Average 37,107 1,352 Table 4a. Total Annual Burden for Respondents Person-Hours Labor Costs

a Combined with one

- time costs, above.31 Table 4b. Total Annual Burden for EPA Person-Hours Labor Costs Year Year 1 Year 2 Year 3 Total Year 1 Year 2 Year 3 Total Option (hr/yr) (hr/yr) (hr/yr) (hr/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) Straight Delegation (§63.91) -- Adm inistrative Criteria 2,737 2,737 2,737 8,211 141.3 141.3 141.3 424 Straight Delegation (§63.91) -- Delegation of Standard 10,379 10,379 10,373 31,131 535.7 535.7 535.4 1,607 Rule Adjustment Option (§63.92) 690 690 621 2,001 35.6 35.6 32.1 103 Rule Substitution Option (§63.93) 5,279 5,083 5,083 15,445 272.4 262.3 262.3 797 Equivalency by Permit Option (§63.94) -- One-Time Application 1,530 1,449 1,369 4,347 78.9 74.8 70.6 224 Equivalency by Permit Option (§63.94) -- per Standard 5,957 5,635 5,474 17,066 307.5 290.8 282.5 881 State Program

Approval Option (§63.97) -- One-Time Application 0 0 0 0 0 0 0 0 State Program

Approval Option (§63.97) -- Per Standard a 0 0 0 0 0 0 0 0 Accidental Release Prevention Program (§63.95) 0 0 0 0 0 0 0 0 EP A Review and Withdrawal (§63.96) 0 0 0 0 0 0 0 0 Total 26,571 25,973 25,657 78,200 1,371 1,341 1,324 4,036 Average 26,067 1,345

a Combined with one

- time costs, above.32 Send subm ittal to EPA (Respondent) †a Answer

Respondent Questions (EPA) ‡b
Year 1 119 1,805 Year 2 119 1,805 Year 3 119 1,804 Year 1 ($/yr) 72.59 8,574 Year 2 ($/yr) 72.59 8,574 Year 3 ($/yr) 72.59 8,569 Year 1 ($/yr) 107.1 64,980 Year 2 ($/yr) 107.1 64,980 Year 3 ($/yr) 107.1 64,944 Year 1 ($1,000/yr) 0.18 73.55 Year 2 ($1,000/yr) 0.18 73.55 Year 3 ($1,000/yr) 0.18 73.51 Total ($1,000/yr) 0.54 220.6 Average ($1,000/yr) 0.18 73.54OccurrencesPostageCopyingTotal Table 5a. Copying/Postal Costs for the Straight Delegation (§63.91) Activity (Respondent/EPA)

Year

† Falls under maintenance of subpart E program approval. ‡ Falls under the Straight Delegation Option. aAssumes 2

- oz. letter. bAssumes 1

- lb. package.33 Send submittal to EPA (Respondent) a Answer

Respondent Questions (EPA) b
Year 1 10 10 Year 2 10 10 Year 3 9 9 Year 1 ($/yr) 47.5 6.1 Year 2 ($/yr) 47.5 6.1 Year 3 ($/yr) 42.75 5.49 Year 1 ($/yr) 360 9 Year 2 ($/yr) 360 9 Year 3 ($/yr) 324 8.1 Year 1 ($1,000/yr) 0.41 0.02 Year 2 ($1,000/yr) 0.41 0.02 Year 3 ($1,000/yr) 0.37 0.01 Total ($1,000/yr) 1.18 0.04 Average ($1,000/yr) 0.39 0.01OccurrencesPostageCopyingTotal Table 5b. Copying/Postal Costs for the Rule Adjustment Option (§63.92) Activity (Respondent/EPA)

Year

aAssumes 1

- lb. package. bAssumes 2

- oz. letter.34 Send submittal to EPA (Respondent) a Answer

Respondent Questions (EPA) b
Year 1 27 27 Year 2 26 26 Year 3 26 26
Year 1 ($/yr) 128.25 16.47 Year 2 ($/yr) 123.5 15.86 Year 3 ($/yr) 123.5 15.86 Year 1 ($/yr) 972 24.3 Year 2 ($/yr) 936 23.4 Year 3 ($/yr) 936 23.4 Year 1 ($1,000/yr) 1.10 0.04 Year 2 ($1,000/yr) 1.06 0.04 Year 3 ($1,000/yr) 1.06 0.04 Total ($1,000/yr) 3.22 0.12 Average ($1,000/yr) 1.1 0.04CopyingTotal Table 5c. Copying/Postal Costs for the Rule Substitution Option (§63.93) Activity (Respondent/EPA)

YearOccurrencesPostage

aAssumes 1

- lb. package. bAssumes 2

- oz. letter.35 Preparation of a list of affected sources and affected 112 standards †,a Send submittal

to EPA ‡, b Notification of

whether alternative rule submittal is complete †,a Notification to

respondent of complete package of alternative term s & conditions ‡,a Creation of

notification of approved/disap proved draft perm it term s and conditions ‡,a Answer

respondent questions ‡,a

(Respondent) (Respondent) (EPA) (EPA) (EPA) (EPA) Year 1 19 37 19 37 37 37 Year 2 18 35 18 35 35 35 Year 3 17 34 17 34 34 34 Year 1 ($/yr) 11.59 175.75 11.59 22.57 22.57 22.57 Year 2 ($/yr) 10.98 166.25 10.98 21.35 21.35 21.35 Year 3 ($/yr) 10.37 161.5 10.37 20.74 20.74 20.74 Year 1 ($/yr) 17.1 1,332 17.1 1,332 1,332 1,332 Year 2 ($/yr) 16.2 1,260 16.2 1,260 1,260 1,260 Year 3 ($/yr) 15.3 1,224 15.3 1,224 1,224 1,224 Year 1 ($1,000/yr) 0.03 1.51 0.03 1.35 1.35 1.35 Year 2 ($1,000/yr) 0.03 1.43 0.03 1.28 1.28 1.28 Year 3 ($1,000/yr) 0.03 1.39 0.03 1.24 1.24 1.24 Total ($1,000/yr) 4.4 Respondents 11.7 EPA Average ($1,000/yr) 1.5 Respondents 3.9 EPA

Table 5d. Copying/Postal Costs for the Equivalency by Perm it Option (§63.94) Activity

(Respondent/EPA)

YearTotalOccurrencesPostageCopying

† In itial Equivalency by Permit Option approval. ‡ Per Standard Equivalency by Permit Option approval. a Assumes 1

- lb. package. b Assumes 2

- oz. letter36 Send submittal to EPA (Respondent) a Answer

Respondent Questions (EPA) b
Year 1 0 0 Year 2 0 0 Year 3 0 0 Year 1 ($/yr) 0 0 Year 2 ($/yr) 0 0 Year 3 ($/yr) 0 0 Year 1 ($/yr) 0 0 Year 2 ($/yr) 0 0 Year 3 ($/yr) 0 0 Year 1 ($1,000/yr) 0 0 Year 2 ($1,000/yr) 0 0 Year 3 ($1,000/yr) 0 0 Total ($1,000/yr) 0 0 Average ($1,000/yr) 0 0 Table 5e. Copying/Postal Costs for the State Program Approval Option (§63.97)CopyingTotalOccurrencesPostage Activity (Respondent/EPA)

Year

a Assumes 1

- lb. package. b Assumes 2

- oz. letter37 Year Year 1 Year 2 Year 3 Total Year 1 Year 2 Year 3 Total Option ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) Straight Delegation (§63.91) -- Administrative Criteria 0.18 0.18 0.18 0.54 0 0 0 0 Straight Delegation (§63.91) -- Delegation of Standard 0 0 0 0 73.55 73.55 73.51 220.61 Rule Adjustm ent Option (§63.92) 0.41 0.41 0.37 1.19 0.02 0.02 0.01 0.05 Rule Substitution Option (§63.93) 1.1 1.06 1.06 3.22 0.04 0.04 0.04 0.12 Equivalency by Permit Option (§63.94) -- One-Tim e Application) 0.03 0.03 0.03 0.09 0.03 0.03 0.03 0.09 Equivalency by Permit Option (§63.94) -- per Standard 1.51 1.43 1.39 4.33 4.05 3.84 3.72 11.61 State Program

Approval Option (§63.97) -- One-Tim e Application 0 0 0 0 0 0 0 0 State Program

Approval Option (§63.97) -- Per Standard a 0 0 0 0 0 0 0 0 Accidental Release Prevention Program (§63.95) 0 0 0 0 0 0 0 0 EPA Review and Withdrawal (§63.96) 0 0 0 0 0 0 0 0 Total 3.23 3.11 3.03 9.37 77.69 77.48 77.31 232.48 Average 3.1 77.5 Table 6. Total Copying/Postal Costs for Respondents and EPA-Sum mary

Respondents EPA

a Combined with one

- time costs, above.38 Year Year 1 Year 2 Year 3 Total Year 1 Year 2 Year 3 Total Option ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) ($1,000/yr) Straight Delegation (§63.91) -- Administrative Criteria 98.18 98.18 98.18 294.54 141.3 141.3 141.3 424 Straight Delegation (§63.91) -- Delegation of Standard 741 741 741 2223 609.25 609.25 608.91 1827 Rule Adjustment Option (§63.92) 30.41 30.41 27.37 88.19 35.62 35.62 32.11 103.35 Rule Substitution Option (§63.93) 247.1 238.06 238.06 723.22 272.44 262.34 262.34 797.12 Equivalency by Perm it Option (§63.94) -- One-Time Application) 16.03 15.03 14.03 45.09 78.93 74.83 70.63 224.39 Equivalency by Perm it Option (§63.94) -- per Standard 241.51 228.43 222.39 692.33 311.55 294.64 286.22 892.41 State Program Approval Option (§63.97) -- One-Tim e Application 0 0 0 0 0 0 0 0 State Program Approval Option (§63.97) -- Per Standard a 0 0 0 0 0 0 0 0 Accidental Release Prevention Program (§63.95) 0 0 0 0 0 0 0 0 EPA Review and Withdrawal (§63.96) 0 0 0 0 0 0 0 0 Total 1374.23 1351.11 1341.03 4066.37 1449.09 1417.98 1401.51 4268.6 Average 1355 1423 Table 7. Total Costs for Respondents and EPA (Labor and Copying/Postal)

Respondents EPA

a Combined with one

- time costs, above.39 Option 2007 A verage An nual Burden (hr/y r) 2010 A verage An nual Burden (hr/yr) Difference Percent Difference Straight Delegation Option (§63.91) 15,042 23,491 8,448.67 56.17% Rule Adjustment Option (§63.92) 2,779 806 -1,973.17 -71.00% Rule Substitution Option (§63.93) 17,491 6,708 -10,783.33 -61.65% Equivalency

by Permit Option (§63.94) 27,439 6,103 -21,336.33 -77.76% Accidental Release Prevention Program (§63.95) 0 0 0.0 0.00% EPA W ithdrawal (§63.96) 0 0 0.0 0.00% State Program Approval Option (§63.97) 92.67 0.00 -92.7 -100.00% Total 62,844 37,107 -25,737 -40.95% Table 8. Difference in A verage A nnual Burden Hours

Option 2007 A verage A nnual Total Cost ($1,000/yr) 2010 A verage A nnual Total Cost ($1,000/yr) Difference Percent Difference Straight Delegation Option (§63.91) 673 839 166 25% Rule Adjustment Option (§63.92) 124 29 -96 -77% Rule Substitution Option (§63.93) 783 240 -543 -69% Equivalency

by Permit Option (§63.94) 1375 244 -1131 -82% Accidental Release Prevention Program (§63.95) 0 0 0 0% EPA W ithdrawal (§63.96) 0 0 0 0% State Program Approval Option (§63.97) 4 0 -4 -100% Total 2,959 1,351 -1,608 -54% Table 9. Difference in A verage A nnual Total Cost