i 

### INFORMATION COLLECTION REQUEST

FOR

PREVENTION OF SIGNIFICANT DETERIORATION

AND NONATTAINMENT NEW SOURCE REVIEW

( 40 CFR PART S 49, 51 AND 52 )

Prepared for:

New Source Review Group

Air Quality Policy Division

Office of Air Quality Planning and Standards

Office of Air and Radiation

United States Environmental Protection Agency

R esearch T riangle P ark , North Carolina 27711

Prepared by:

EC/R Incorporated

501 Eastowne Driv e, Suite 250

Chapel Hill, NC 27514ii 

### INFORMATION COLLECTION REQUEST

FOR

PREVENTION OF SIGNIFICANT DETERIORATION

AND NONATTAINMENT NEW SOURCE REVIEW

( 40 CFR PART S 49, 51 AND 52 )

TABLE OF CONTENTS

Page

1

. IDENTIFICATION OF THE INFORMATION COLLECTION

................................ ................................ .......... 1

1(a) TITLE OF THE INFORMATION COLLECTION REQUEST (ICR)

................................ ................... 1

1(b) ABSTRACT/EXECUTIVE SUMMARY

................................ ................................ .............................. 1

1(c) PAPERWORK REDUCTION ACT REQUIREMENTS

................................ ................................ ....... 2

2

. NEED FOR AND USE OF THE COLLECTION

................................ ................................ ................................ .. 2

2(a) NEED/AUTHORITY FOR THE COLLECTION

................................ ................................ .................. 2

2(b) PRACTICAL UTILITY/USERS OF THE DATA

................................ ................................ ................. 3

3

. NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA

................................ ... 4

3(a) NONDUPLICATION

................................ ................................ ................................ ............................. 4

3(b) PUBLIC NOTICE REQUIRED PRIOR T O ICR SUBMISSION TO OMB

................................ ......... 4

3(c) CONSULTATIONS

................................ ................................ ................................ ................................ 4

3(d) EFFECTS OF LESS FREQUENT COLLECTION

................................ ................................ ................ 5

3(e) GENRAL GUIDELINES

................................ ................................ ................................ ........................ 5

3(f) CONFIDENTIALITY

................................ ................................ ................................ ............................ 5

3(g) SENSITIVE QUESTIONS

................................ ................................ ................................ ..................... 6

4

. THE RESPONDENTS AND THE IN FORMATION REQUESTED

................................ ................................ .... 6

4(a) RESPONDENTS/STANDARD INDUSTRIAL CLASSIFICATION (SIC) CODES

............................ 6

4(b) INFORMATION REQUESTED

................................ ................................ ................................ ............ 8

4(b)(1) DATA ITEMS, INCLUDING RECORDKEEPING REQUIREMENTS

................................ .. 8

4(b)( 2) RESPONDENT ACTIVITIES

................................ ................................ ................................ .. 8

5

. THE IFNORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND

INFORMATION MANAGEMENT

................................ ................................ ................................ ..................... 9

5(a) AGENCY ACTIVITIES

................................ ................................ ................................ ......................... 9

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

................................ ................................ 9

5(c) SMALL ENTITY FLEXIBILITY

................................ ................................ ................................ .......... 9

5(c)(1) MEASURES TO AVERT IMPACTS ON SMALL ENTITIES

................................ ............. 10

5(c)(2) MEASURES TO MITIG ATE IMPACTS ON SMALL ENTITIES

................................ ....... 10

5(d) COLLECTION SCHEDULE

................................ ................................ ................................ ................ 10

6

. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

................................ .............................. 1 1

6(a) ESTIMATING RESPONDENT BURDEN

................................ ................................ .......................... 1 1

6(b) ESTIMATING RESPONDENT COSTS

................................ ................................ .............................. 1 2

6(b)(i) ESTIMATING LABOR COSTS

................................ ................................ ............................. 1 2iii



### 6(b)(ii) ESTIMATING CAPITAL AND OPERATIONS AND MAINTENANCE COSTS

.............. 1 3

6(b)(ii i) CAPITAL/START

- UP OPERATING AND MAINTENANCE (O&M) COST

.................... 1 3

6(b)(iv)ANNUALIZING CAPITAL COSTS

................................ ................................ ....................... 1 3

6(c) ESTIMATING AGENCY BURDEN AND COST

................................ ................................ .............. 1 4

6(d) ESTIMATING THE RESPO NDENT UNIVERSE AND TOTAL BURDEN AND COST

................ 14

6(e) BOTTOM LINE BUR DEN HOURS AND COST TABLES

................................ ............................... 15

6(e)(i) RESPONDENT TALLY

................................ ................................ ................................ ........... 1 5

6(e)(ii) THE AGENCY TALLY

................................ ................................ ................................ ........... 1 5

6(f) REASONS FOR CHANGE IN BURDEN

................................ ................................ ............................ 1 5

6 (g ) BURDEN STATEMENT

................................ ................................ ................................ ...................... 16



### Appendix A: INFORMATION REQUIREMENTS

................................ ................................ ................. 21

Appendix B : CALCULATIONS AND INFORMATION REQUIREMENTS FOR THE MINOR NSR

PROGRAM IN INDIAN COUNTRY

................................ ................................ ................................ ....... 25

LIST OF TABLES

Page

4

- 1 Most Numerous Industrial Respondents by Industrial Group

................................ .............................. 6

4

- 2 Most Numerous Industrial Respondents by Industrial Group in Indian Country

................................ 7

6

- 1 Industry Res pondent Burden and Cost (Annual)

................................ ................................ ............... 17

6

- 2 State and Local RA Burden and C ost (Annual)

................................ ................................ ................. 18

6

- 3 A gency Burden and Cost (Annual)

................................ ................................ ................................ .... 19

6

- 4 NSR Program Information Collection Burden Summary

................................ ................................ .. 201



### 1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE OF THE INFORMATION COLLECTION REQUST (ICR)

This report is entitled Prevention of Significant Deterioration and Nonattainment New Source Review

, EPA ICR No. 1230.2 9 , OMB C ontrol No. 2060

- 0003.

1(b) ABSTRACT/EXECUTIVE SUMMARY

The analyses in this document have been performed in support of a renewal of the New Source Review

(NSR) Program Information Collection Request (ICR) (Office of Management and Budget (OMB)

Control N o. 2060

- 0003 ; EPA ICR No. 1230.2 9 ). The regulations covered under this ICR are contained

in parts 49, 51 and 52 of Title 40 of the Code of Fede ral Regulations ( CFR ). These requirements govern

the s tate and f

ederal programs for preconstruction review and permitting of major new and modified

sources pursuant to p art C “Prevention of Significant Deterioration” (PSD) and p art D “Program

Requirements for Nonattainment Areas” (nonattainment major NSR or NA NSR) of the Clean Air Act

(CAA) , which together are commonly referred to as “major NSR.” In addition, these requirements

govern the state and federal programs for preconstruction of minor new and modi fied sources pursuant

to CAA section 110 (a)(2)(C), which is commonly referred to as “ minor NSR

. ” The types of information

collection activities addressed in this ICR are those necessary for the preparation and submittal of

construction permit applications and the issuance of final permits. Thus, the respondents addressed in

this ICR are (1) the pollutant

- emitting sources that must apply for and obtain permits, and (2) the state

and local reviewing authorities (RAs) that must review the permit applications and issue the permits.

Specific burden

- producing activities are listed in Appendix A. The administrative, reporting and

recordkeeping burden for industry respondents (permit applicants), s tate and local implementing

agencies and the Environmental Protection Agency (EPA) are summarized in Table 6

- 4.

The NSR Program ICR was last renewed in Octo ber 200 8 (EPA ICR No. 1230.23)

. Since th at renewal

of this ICR, the re have been a number of actions that have resulted in changes or revisions to the ICR:

 Flexible Air Permitting Rule (EPA ICR No. 1230.26)

– overall reduction in burden based on

policy encouraging flexible permits.

 Change Worksheet for Tailoring Rule and SIP Fix Implementation Rule ( EPA ICR

N o. 1230.28)

– addition of greenhouse gases (GHGs) to the program.

 Final Rule for Review of New Sources and Modifications in Indian Country ( EPA ICR

No. 1230.2 7 )

– addition of an NSR program for Indian country.

 Final Rule for PM 2.5 

### Increments, Significant Impact Levels (SILs) and Significant Monitoring

Concentration (SMC) (EPA ICR No. 1230.31)

– transfer of the burden for this NSR rule change

that was originally approved under EPA ICR No. 2276.02, OMB Control No. 2060

- 0609.

As a re sult of these changes and revisions, the currently approved respondent burden for the NSR

program stands at over 6.7 million hours per year for nearly 162 ,000 respon se s (with associated labor

costs of about $603 million ) , plus about $11 .5 million in capita l and one

- time start

- up costs.

Th is renewal ICR for the NSR program estimate s the annual respondent burden at approximately

7.9 million hours (with labor costs of about $695 million) for over 162 ,000 responses , plus capital and

one

- time start

- up costs of about $12.6 million

. The change (net increase) in the burden estimate is due

largely to the expected progress in the implementation of the minor NSR program in Indian country and2



### the phased integration of GHGs into the PSD progra m. In both cases, the period covered by this ICR

renewal is expected to include a significant increase in the number of permits iss ued. An additional

factor in the increase of labor and capital/start

- up costs is that we have updated labor wage rates and

ad justed the capital/start

- up costs for inflation.

The estimated annual burden in this renewal ICR consists of approximately 5.2 million hours for

industry respondents (with labor costs of about $476 million and capital/start

- up costs of about $12.6

millio n) and 2.7 million hours for state and local reviewing authority respondents (with labor costs of

about $219 million). The estimated annual burden for the EPA is about 85,000 hours and $6.4 million.

1(c) PAPERWORK REDUCTION ACT REQUIREMENTS

For any existing rule, section 3507(g) of the Paperwork Reduction Act (PRA) limits the amount of time

for which a Director may approve a collection of information to 3 years

. The existing ICR (EPA ICR

No. 1230.23) expires on April 30, 2012. Conseq uently, the annual burden estimates are calculated for

the 3

- year period beginning May 1 , 20 12 and ending April 30

, 201 5

.

Except for information collections in notices of proposed rules or those exempted under the emergency

processing provisions of 44 U.S.C. § 3507(j), the PRA requires the EPA to solicit comments on each

proposed information collection, including the renewal or modification of any existing ICR

. This ICR

renewal and its supporting statement w ere publicly noticed in the Federal Register ( 76 FR 72700

, November 25

, 2011 ) to solicit comments on the data, analyses and conclusions. No comments were

received

. T he ICR will be submitted to the OMB for approval.

The information that this ICR covers is required for the submittal of a complete permit application for

the construction or modification of all major new stationary sources of pollutants in attainment and

nonatta inment areas, as well as for applicable minor stationary sources of pollutants

. The EPA certifies

that the information collection is necessary for the proper performance of the EPA’s functions, and that

it has practical utility; is not unnecessarily dupli cative of information the EPA otherwise can reasonably

access; and reduces, to the extent practicable and appropriate, the burden on persons providing the

information to or for the EPA.

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED/AUTHORITY FOR THE CO LLECTION

Section 110 of the CAA requires all s tates to submit an implementation plan that contains a

preconstruction review program for all new or modified stationary sources, including any provisions

necessary for this program to me et the specific requirements of p arts C and D of t itle I of the CAA

related to major construction

. Section 110(a)(2)(C) of the CAA requires that no new or modified

stationary source, in conjunction with existing source emissions in the same area, can interfere with the

attainment or maintenance of the National Ambient Air Quality Standards (NAAQS)

. It further requires

that no source can construct without securing a permit to ensure that the objectives of p arts C and D of

title I of the CAA are met

.

Part C of t itle I of the CAA outlines specific construction requirements for new and modified sources

constructing in areas that do not violate the NAAQS

. These requirements are more commonly referred

to as the “ prevention of significa nt d eterioration ” or “PSD” rules, which require a prospective major new

or modified source to: (1) demonstrate that the NAAQS and incre ments will not be exceeded, (2) ensure3



### the application of best available control technology (BACT) and (3) protect Federa l Class I areas from

adverse impacts, including adverse impacts on air quality related values (AQRVs).

Similarly, part D of t itle I of the CAA specifies requirements for major new and modified sources

constructing in areas de signated as nonattainment for a NAAQS pursuant to s ection 107 of the CAA

. The p art D provisions also apply to major source permitting in the Northeast Ozone Transport Region as

established under s ection 184 of the CAA

. The p art D rules , which are often referred to as the

“nonattainmen t major NSR” or “NA NSR” rules, generally require a prospective major construction

project to: (1) ensure the application of controls which will achieve the lowest achievable emission rate

(LAER), (2) certify that all major sources in a s tate which are own ed or controlled by the same person

(or persons) are in compliance with all ai r emissions regulations and (3) secure reductions in existing

source emissions ( “ offsets ” ) that comply with specific statutory offset ratios and are otherwise equal to,

or greate r than

, those reductions necessary to show attainment and maintenance of the applicable

NAAQS.

2(b) PRACTICAL UTILITY/USERS OF THE DATA

Before the owner or operator of a facility can commence construction or modification of its sou rce, it

must comply with all applicable construction permit requirements

. The owner or operator of a stationary

source must develop or collect all relevant information not otherwise available to the f ederal, state or

local RA

. The R A reviews the application materials submitted by the owner or operator and either

declares the permit application complete for processing or provides the owner or operator guidance on

how to correct the deficiencies in the application

. If the application has deficiencie s, the applicant

collects any additional data identified by the RA so that the permit application can be deemed

“complete.” Although sufficient information must be submitted by the applicant before its permit can be

classified as complete, some additional clarifying information can be submitted at a later date by the

applicant to assist the RA in processing the permit application.

For major sources to be constructed or modified in attainment areas, the R A uses the permit application

information to determin e: (1) whether the source will cause or contribute to a violation of the NAAQS

and air quality increments, (2) if the technology the sourc e is proposing is BACT and (3) whether the

source's emissions will adversely affect any Federal Class I areas, includ ing AQRVs in these areas

. For

major sources to be constructed or modified in nonattainment areas, the permit applicat ion information

is used by the R A to determine whether: (1) the source will apply LAER, (2) the source will have

secured the required emis sions offsets and (3) the source has demonstrated that all other of its major

sources in the same s tate are in compliance with all applicable air emissions regulations

. For minor

sources that are large enough to be subject to minor NSR to be constructed or modified in attainment

and nonattainment areas, the RA uses the permit application information to determine whether the

source will cause or contribute to a violation of the NAAQS . Minor NSR programs may include a

control technology requirement or require ambient air quality modeling to protect the NAAQS.

Once the application is complete, the R A makes a preliminary determination regarding the approvability

of the permit application

. For major NSR, t his determination, along with the application and support ing

information, is made available to the public for at least 30 days

. The R A must then respond to public

comments and take action on the final permit

. Typically a final major NSR action must be taken on a

permit by the R A within 1 year of receipt of a com plete application

. For minor NSR, the public

comment period and deadline for a final permit action may be shorter.4



### In addition, the public and other permit applicants may use some of the data collected

. The EPA

operates a RACT/BACT/LAER Clearinghouse (RBL C) 1 

### which contains many BACT and LAER

determinations to aid applicants and reviewers in identifying reasonable and available control

technologies

. The Clean Air Act Amendments of 1990 require that the BACT or LAER information in

each permit must be gathere d by the R A and submitted for entry into the RBLC database as a reference

for making future control technology determinations

. Annual reports containing RBLC update

information are also available to the public through the National Technical Information Ser vice.

3. NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA

3(a) NONDUPLICATION

The information collection activities required under the NSR regulations are not routinely performed

elsewhere by the EPA

. However, similar information may be collected during the development of

certain environmental impact statements (EIS)

. In such cases, regulations and policies require that

information collected for the EIS and NSR programs be coordinated to the maximum extent possible so

a s to minimize duplicating the collection of data

. Some of the required information also may already be

available from s tates or other federal agencies

. However, even when these data are available, they are

not generally adequate to address completely the r elevant NSR requirements.

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

The first public notice of this ICR renewal was published in the Federal Register on November 25

, 2011

( 76 FR 72700 )

. No comments we re received. T he ICR will be submitte d to the OMB for approval.

3(c) CONSULTATIONS

This ICR is a renewal of the existing ICR for the NSR program

. It incorporates the base elements of the

program which have not been changed for this renewal

. However, since the previous renewal, the EPA

has filled regulatory voids that existed in Indian country (where state NSR programs do not apply) by

promulgating a part D program and a minor NSR program for Indian country. (The EPA was already

implementing the part C PSD program in Indian country.) The implementing regulations for these

programs are located in 40 CFR part 49 at 40 CFR 49.151 through 49.173 , so these part 49 regulations

have been brought under this ICR . The EPA acts as the reviewing authority for these programs.

In addition, GHGs have come under the PSD program since the last renewal as a result of actions under

the CAA unrelated to NSR. P rovisions also have been added to the PSD regulations that allow for full

implementation of the program for particulate matter less than 2.5 microns ( PM 2.5 

### ) , which has resulted

in an increase in the modeling required for PSD permits. The Flexible Air Permitting Rule also

established policies that reduce total burden because of the reduction in the number of permit actions.

E xtensive consultation through public hearings with environmental groups; industry; and state, local,

and federal agency representatives were conducted previously for all these actions that have affected the

NSR ru les covered by this ICR

. Extensive consultation with Indian Tribes was carried out during the

development of the NSR programs for Indian country. Also, prior to the previous ICR renewal, the EPA

contacted the National Association of Clean Air Agencies (NACAA) and received comments from three

1 

### The RBLC is available on the EPA Technology Transfer Network (TTN). Access to the RBLC on the

TTN is via a computer through Internet access

– http://cfpub.epa.gov/RBLC/

.5



### of its members. Consistent with NACAA’s input during that consultation period, changes were made to

the burden estimates for certain activities performed by RAs, and these changes have been carried over

in this renewal

. In addition, the EPA con tacted NACAA to solicit input for this renewal of the ICR, but

no comments were received.

3(d) EFFECTS OF LESS FREQUENT COLLECTION

The CAA defines the rate of reporting by sources, states and local entities

. Consequently, less frequ ent

collection is not possible.

3(e) GENERAL GUIDELINES

The OMB's general guidelines for information collections must be adhered to by all f ederal a gencies for

approval of any rulemaking's collection methodology

. In accordance with the requirements of 5 CFR

1320.5, the EPA believes:

1. The NSR regulations do not require periodic reporting more frequently than semi

- annually.

2. The NSR regulations do not require respondents to participate in any statistical survey.

3. Written respons es to EPA inquiries are not required to be submitted in less than 30 days.

4. Special consideration has been given in the design of the NSR program to ensure that the

requirements are, to the greatest extent possible, the same for f ederal requirements and those

RA s who already have preconstruction permitting programs in place.

5. Confidential, proprietary and trade secret information necessary for the completeness of the

respondent's permit are protected from disclosure under the requirements of section 50 3(e) and

section 114(c) of the CAA

. 6. The NSR regulations do not require more tha n one original and two copies of the permit

application, update or revision to be submitted to the EPA

. 7. Respondents do not receive remuneration for the preparation of repo rts required by the CAA or

part 49, 51 or 52.

8. To the greatest extent possible, the EPA has taken advantage of automated methods of reporting.

9. The EPA believes the impact of NSR regulations on small entities to be insignificant and not

disproportionat e.

The recordkeeping and reporting requirements contained in the NSR program do not exceed any of the

P RA guide lines con tained in 5 CFR 1320.5, except for the guideline which limits reten tion of records by

respondents to 3 years

. The CAA requires both respondents and s tate or local agencies to retain records

for a period of 5 years

. The justification for this exception is found in 28 U.S.C

. 2462, which specifies

5 years as the general statute of limitations for f ederal claims in response to violati ons by regu lated

entities

. The decision in U.S

. v

. Conoco, Inc. , No

. 83

- 1916

- E (W.D

. Okla., January 23, 1984) found that

the 5

- year general statute of limitations applied to the C AA

.

3(f) CONFIDENTIALITY

Confidentiality is not an i ssue for the NSR program

. In accordance with t itle V, s ection 503 (e), the

information that is to be submitted by sources as a part of their permit application and update,

applications for revisions and applications for renewals is a matter of public recor d

. To the extent that

the information required for the completeness of a f ederal permit is proprietary, confidential or of a

nature that it could impair the ability of the source to maintain its market position, that information is6



### collected and handled ac cording to the EPA's policies set forth in t itle 40, c hapter 1, p art 2, s ubpart B

-- Confidentiality of Business Information (see 40 CFR 2)

. States typically have similar provisions.

3(g) SENSITIVE QUESTIONS

The consideration of sensitive questions (i.e., sexual, religious, personal or other private matters) is not

applicable to the NSR program

. The information gathered for purposes of establishing a n NSR permit

for a source do not include personal data on any owner or operator.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS/STANDARD INDUSTRIAL CLASSIFICATION (SIC) CODES

Table 4

- 1 lists the industrial groups the EPA expects will contain the majority of the industrial

respondents affected by the NSR program

. These categories were chosen because of their historic

relative incidence in seeking NSR permits as established in prior ICRs and confirmed by a nationwide

air pollutant emission inventory developed by the EPA in 1986

- 87

. These industri es have been used as

the basis for impact analysis since that inventory.

Table 4

- 1

. Most Numerous Industrial Respondents by Industrial Group

Industry Group SIC NAICS †



### Steam Electric Plants 491 221111, 22112, 22113,

221119, 221121, 221122

Petroleum Refining 291 32411

Chemical Processes 281 325181, 32512, 325131,

325182, 211112,

325998, 331311, 325188

Natural Gas Transport 492 48621, 22121, 48621

Pulp Mills 261 32211, 322121, 322122,

32213

Paper Mills 262 322121, 322122

Automobile

Manufacturing 371 336111, 336112, 33612,

336211, 336992,

336322, 33633, 33634,

33635, 336399, 336212,

336213

Pharmaceuticals 283 325411, 325412,

325413, 325414

† 

### North American Industry Classification System

The respondents also include s tate and local air regulatory agencies that serve as the RA s for the NSR

program

. Because of the national scope of the NSR program, these governmental respondents are in all

50 s tates. In total, we recognize 112 such state and local RA s.7



### An exception to the list of affected industries in Table 4

- 1 applies to the minor NSR program in In dian

country. For that program, the industrial groups expected to be most affected are listed in Table 4

- 2.

Table 4

- 2. Most Numerous Industrial Respondents by Industrial Group in Indian Country

Industry Group NAICS

Animal food manufacturing 311119

Asphalt hot mix 324121

Auto body refinishing 811121

Beef cattle complex, slaughter house, and meat

- packing plant 3116

Casting foundry (iron) 331511

Chemical preparation 3251

Clay and ceramics operations (kilns) 32711

Concrete batching plant 327320

Crude petroleum and natural gas extraction 211111

Electric power generation 22111

Fabricated metal products 3329

Fabricated structural metal 3323

Fiber glass operations 3279

Gasoline bulk plant 424710

Gasoline station (storage tanks, refueling) 4471

Grain elevator 424510

Machinery manufacturing 33311

Millwork (wood products manufacturing) 32191

Natural gas

- distribution systems 221210

Natural gas liquid extraction (major source) 211112

Oil and gas production/operations (minor Oil & Gas) 21111

Other (natural gas

- fired boilers) 72112 a



### Printing operations (lithographic) 323110

Professional, scientific, and technical services 54171 b



### Sand and gravel mining 212321

Sand

- and shot

- blasting operations 238990

Sawmills (minor source) 321113

Sawmills (major source) 321113

Sewage treatment facilities 221320

Softwood veneer and plywood manufacturing 321212

Solid waste landfill 562212

Surface coating operations 332812

Wood kitchen cabinet manufacturing 337110

a NAICS associated with “other” facilities is that for casino

- hotels, which was the most frequently

mentioned type of “other” facility.

b T his sector included based on natural gas

- fired boilers.8



### 4(b) INFORMATION REQUESTED

4(b)(1) DATA IT EMS, INCLUDING RECORDKEEPING REQUIREMENTS

Tables A

- 1 and A

- 2 of Appendix A summarize the industry respondent data and information

requirements that owners or operators of major sources must include in PSD and NA NSR construction

permit applications

. The tables also include the appropriate references in 40 CFR part 51 for the data and

information requirements that govern the way s tates implement NSR programs

. For each reference in

p art 51, corresponding language will be found in part 52

. In this ICR analysis, the minor NSR burden is

for owners or operators of minor sources to submit information to demonstrate that they are exempt

from the major source construction permit requirements and that they will not cause or contribute to a

violation of any NAA QS and that they will meet all requirements of the applicable implementation plan

. Because state minor NSR programs vary widely in form and requirements, it is not practical to list

specific requirements for these programs other than the general requiremen ts found in 40 CFR 51.160.

The specific items required by the minor NSR program for Indian country are listed in Appendix B.

Table A

- 3 of Appendix A summarizes the data and information requirements that s tate and local

reviewing authority respondents must meet for major NSR permits

. Table A

- 3 also shows the p art 51

references for the data and information requirements specified

. Because of the variability of minor NSR

programs, it is not practical to list specific requirements for these programs other than the general

requirements found in 40 CFR 51.160 and 51.161. The EPA is the reviewing authority for the minor

NSR program in Indian country. Thus, state and local agencies are not respondents for that program.

4(b)(2) RESPONDENT ACTIVITIES

Table 6

- 1 lists the activities, burden and estimated costs for industry respondents under the N SR

program under 40 CFR parts 49, 51 and 52

. For the part C and D programs, t hese activities include three

broad categories: Preparation and Planning; Data Collection and Analysis; and Permit Application.

Within each of these categories, further subdivision of a source’s activities can be found. The EPA

anticipates it will take 1,6 10 p art C major sources an average of approximately 1,00 6 hours to complete

each PSD application, for a total of 1,619,660 hours

. Each of the 486 p art D NSR sources will require an

average of 642 hours, or a total of approximately 312,012 hours each year

, to complete p art D NA NSR

applications. Each minor source will require a weighted average of approximately 39 hours to complete

its application requirements, f or a total of 2, 822,885 hours for state and local minor NSR programs and

479,435 hours for minor NSR program in Indian country

.

Table 6

- 2 lists the activities, burden and estimated costs for state and local RA respondents under the

NSR program. We estimate that it will take these agencies an average of approximately 33 6 hours to

complete each of the estimated 1,610 PSD application s , for a total of 540,960 hours annually

. For e ach

of the 486 p art D NSR applications, we believe an average of 128 hours will be required , total ing

approximately 6 2, 208 hours each year. Each minor NSR application will requir e a weighted average of

approximately 2 9 hours, f or a n annual total of 2, 095,140 hours . S tate and local agencies do not act as

RA s for minor NSR program in Indian country

. In addition, state and local RA respondents are expected

to submit state implementat ion plan (SIP) revisions to conform their rules to amendments to the major

NSR regulations in part 51. We estimate an average of 51 SIP revisions per year, each requiring 40

hours to prepare for a total of 2,040 hours annually.9



### 5. THE INFORMATION COLLECTE D

– AGENCY ACTIVITIES, COLLECTION

METHODOLOGY AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

Table 6

- 3 lists the EPA’s activities associated with NSR permitting. These activities generally involve

oversight review of state and local RA s’ major NSR permitting actions and more complicated minor

NSR actions to verify that the requirements of the CAA and the implementing part 51 and 52 regulations

are being met. In addition, EPA will have to review the SIP revisions submitted by the RA s. Final ly, the

EPA serves as the RA for the minor NSR program in Indian country.

5(b) COLLE CTIO N METHODOLOGY AND MANAGEMENT

The owners and operators of new or modified stationary sources affected by the NSR regulations will be

responsible for submitting construction permit applications to the RA

. The RA will log in permit

applications, store applications in a central filing loc ation at the RA ’s offices , notify the Federal Land

Manager (FLM) and provide a copy of the application (if applicable), and transmit copies of each

application to the EPA

. Once construction permits have been approved, the RA will submit control

technology information to the EPA's RBLC database

. Because the construction permits and associated

control technology determinations are performed on a case

- by

- case basis, the regulations will not

contain additional forms that owners or operators would have to fill o ut and submit to the RA

. States

will likely use their current permit application forms for NSR purposes. The NSR program in Indian

country is an exception

– the EPA has developed application forms for the registrations and permits

required under that progr am.

Qualified personnel who work for the RA will perform permit reviews and check the quality of data

submitted by the applicant on a case

- by

- case basis

. The applicant will be required to submit information

on how the data were obtained ( e.g.

, indicate whether emissions data were obtained through the use of

emissions factors or test data) and how the calculations were performed

. The RA personnel will check

data quality by reviewing test data and checking engineering calculations, and by reviewi ng control

technology determinations for similar sources

. The RBLC and other sources will be reviewed for

information on control technology determinations made for sources similar to the sources included in the

permit application

. Confidential information submitted by the applicant will be handled according to the

RA 's confidential information handling procedures

. The public will be provided the opportunity to

review a permit application and other materials relevant to the RA ’s decision on issuing the permi t,

including FLM findings, by obtaining a copy from the RA or by attending the public hearing

. The NSR

regulations will not require information through any type of survey

.

5(c) SMALL ENTITY FLEXIBILITY

The Regulatory Flexibility Ac t (RFA) requires regulatory agencies, upon regulatory action, to assess

that action ’ s potential impact on small entities (businesses, governments, and small non

- governmental

organizations) and report the results of the assessments in (1) an Initial Regulat ory Flexibility Analysis

(IRFA), (2) a Final Regulatory Flexibility Analysis (FRFA), and (3) a Certification. For ICR approval,

an a gency must demonstrate that it "has taken all practicable steps to develop separate and simplified

requirements for small bu sinesses and other small entities" (5 CFR 1320.6(h))

. In addition, the agencies

must assure through various mechanisms that small entities are given an opportunity to participate in the

rulemaking process

.10



### A Regulatory Flexibility Act Screening Analysis (RFASA) developed as part of a 1994 draft Regulatory

Impact Analysis (RIA) and incorporated into the September 1995 ICR renewal analysis reported an

initial regulatory flexibility screening analysis showed that the changes to the NSR program due to the

199 0 Clean Air Act A mendments would not have an adverse impact on small entities. 2 

### This analysis

encompassed the entire universe of applicable major sources that were likely to also be small

businesses. The Agency estimates there are approximately 50 “small b usiness” major sources. 3 

### Because

the administrative burden of the NSR program are the primary source of the NSR program’s regulatory

costs, the analysis estimated a negligible “cost to sales” (regulatory cost divided by the business

category mean revenue) ratio for this source group. Currently, there is no economic basis for a different

conclusion at this time.

5(c)(1) MEASURES TO AVERT IMPACTS ON SMALL ENTITIES

The Agency may not, under any circumstances, exempt a major source of ai r pollution

. Since the

impacts of NSR regulations which may impact small entities are predominantly to major sources, little

room exists for regulatory flexibility to avert the impact of the proposed rulemaking on small entities

through exemption

.

5(c)(2 ) MEASURES TO MITIGATE IMPACTS ON SMALL ENTITIES

Even though the NSR program is not anticipated to have an adverse impact on a significant number of

small businesses, measures are in place to assist in those incidental exceptions

. Implementation of small

business stationary source technical and environmental compliance assistance programs, as called for in

section 507 of the CAA (at the f ederal and s tate levels) can reduce the reporting burden of small entities

which are subject to major NSR

. These programs may significantly alleviate the economic burden on

small sources by establishing: ( 1) programs to assist small businesses with determining what CAA

requirements apply to th eir sources and when they apply and ( 2) guidance on alter native control

technology and pollution prevention for small businesses.

5(d) COLLECTION SCHEDULE

Respondents are not subjected to a collection schedule per se under NSR permittin g regulations of

parts 49, 51 and 52

. In general, eac h affected source is required to submit an application as a prerequisite

to receiving a construction permit

. Preparation of a construction permit application is a one

- time

- only

activity for each project involving construction of a new source or modificatio n of an existing source

. The applicable SIP typically states the time period that is necessary to process a permit application and

issue a permit; consequently, a prospective source would be obliged to work backward from the hopeful

commencement of constru ction to determine the optimum submittal date for the application

. The NSR

permit regulations will not require periodic reporting or surveys.

2 

### “Economic Assessment of the Impacts of Part C and D Regulatory Changes,” June 2, 1994.

3 

### The definition for “small business” employed for all SIC categories in this analysis was any business

employing fewer than 500 employees.11



### 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN

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

retain

, or disclose or provide information to or for a f ederal agency

. This includes the time needed to

review instructions; develop, acquire, install, an d utilize technology and systems for the purposes of

collecting, validating and verifying information, processing and maintaining information, and disclosing

and providing information; adjust the existing ways to comply with any previously applicable

instr uctions 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

. The burden estimate should be compos ed of (1) a total capital and start

- up cost component

annualized over its useful life; (2) a total operation, maintenance and purchases of services component

. Each component should be divided into burden borne directly by the respondent and any services th at

are contracted out

.

Table 6

- 1 identifies the average burden by activity for the industrial respondents

. The average burden for

several PSD tasks have increased since the last 2008 renewal , primarily as a result of the incorporation

of GHGs into the pr ogram (EPA ICR No. 1230.28) and the addition of additional PM 2.5 

### requirements

(EPA ICR No. 1230.31). As a result, the average burden for an industrial respondent has increased from

866 hours per PSD permit to 1,006. The Flexible Air Permitting Rule (EPA ICR No. 1230.26) also

caused a small increase to PSD permit burden, but that was more than offset by the reduction in the

number of permits that resulted. An estimated 34 of the 1,610 p art C (PSD) permit applications will

require preconstruction air q uality monitoring

. More specifically, thes e 34 sources represent about

12 percent of the 274 sources that are expected to be subject to PSD each year for non

- GHG pollutants.

( Preconstruction monitoring is never required for GHGs.) This direct start

- up cost is estimated at

$366,006 per source. This value was derived by applying the Bureau of Labor Stat istics ’ (BLS’) online

inflation calculator to the value used in the 2008 renewal ( $ 335,165 ). 4 

### The industry respondent burden

for a part D permit remains unchan ged from the 2008 renewal.

In previous renewals, t he average burden for preparing and submitting minor NSR permit applications

under state/local programs has reflect ed a range of estimated burden from 8 to 12 0 hours, depending on

the nature of the permit action required

. The average assume d the following average burdens for

different types of permit actions (percent of total actions in parentheses): 4 0 hours for new minor

sources, new synthetic minor sources, and synthetic

- based modifications ( 30 percent ); 8 hours for true

minor modifications ( 30 percent ); 120 hours for netting

- based minor modifications ( 20 percent ); and

8 hours for minor/administrative permit revisions ( 20 percent ). However, since the last renewal, the EPA

promulgated the Flexible Air Perm itting Rule which encouraged the use of flexible permitting

techniques which tend to require additional burden in the initial permit, but reduce the need for

subsequent permits and permit revisions. As calculated in the revised ICR prepared for that rulema king

(EPA ICR No. 1230.26) , the overall burden for minor NSR permitting in state/local programs fell to

2,822,885 hours per year and the number of permits was reduced to 72,841 annually. Based on these

final numbers, which are unchanged in this renewal, th e weighted average burden for each minor NSR

permit is about 39 hours.

4 

### http://data.bls.gov/cgi

- bin/cpicalc.pl?cost1=335165&year1=2007&year2=2011 . This online calculator

provides the inflation in the Consumer Price Index between any two years. In this case, we en tered the

amount in 2007 dollars ( $335,165 ) and retrieved the inflated value in 2011 dollars ($ 366,006 ).12



### The burden for industry respondents for the minor NSR program in Indian country was similarly

calculated in an ICR revision prepared for that rulemaking (EPA ICR No. 1230.27). For this ICR

renewal we have used the burdens and costs developed for that ICR, although we have updated the

number of sources subject to each type of action to reflect the progress that has been made in

implementing the rule. The Indian country NSR rule also addr essed the NA NSR part D program in

Indian country, but we estimated in th e ICR revision for th at rule that an average of only one source

subject to th e rule would require permitting annually. Rather than ca lculate that small burden as separate

line item , f

or this renewal we have simply included that single source in the overall part D program

calculations.

Table 6

- 2 identifies the average burden by activity for the s tate and local reviewing authority

respondents. C hanges that were made for the 2008 renewal pursuant to consultation with NACAA to

more accur ately reflect the burdens of the se activities have been retained in this renewal

. Since the 2008

renewal, t he per

- permit burden for a PSD permit has increased from 301 hours to 336 hours as a result

of the same factors noted above for the industry respondents. The burden for a part D permit has

increased marginally (from 127 to 128 hours) as a result of the Flexible Air Permitting Rule , although

the overall burden went down as a result of that rule because o f a decrease in the number of permits

required annually. The burden for reviewing a minor NSR permit application and issuing the permit fell

to a weighted average of about 29 hours.

6(b) ESTIMATING RESPONDENT COSTS

6(b)(i) ESTIMATI NG LABOR COSTS

In this ICR, nearly the entire burden for all respondents (and the EPA ) is treated as a labor cost

. The

explanation for the absence of capital and operations and maintenance costs appears below in

sections 6(b)(ii) and 6(b)(iii)

. Consequent ly, in general, there is only an annual value of the costs of the

ICR burden, which is equal to the cost of the first yearly outlay

. For much of the NSR program, t he

same annual ICR burden and cost are reported for each year because the EPA projects that t he yearly

average number of permit applications will be constant over the term of the ICR

. However, the minor

NSR program in Indian country is an exception in that in the first 2 years of the term of this ICR

renewal, existing, new and modified minor sourc es will only be required to register, while in the third

year new and modified minor sources will be required to obtain permits. The annual values for industry

respondents reported in Table 6

- 1 for this program represent the average annual number of respon dents

and average burden hours per reg i stration/permit

.

In order to improve the accuracy of burden estimates, this renewal ICR updates the wage rates to values

in 2011 dollars. The labor rate used to calculate the industrial respondents’ labor cost is $ 9 9 /hr . The

industrial labor rate was obtained from Table 2 in the Bureau of Labor Statistics (BLS) survey

“Employer Costs for Employee Compensation,” June 20 11, for “professional and related” workers . To

determine the rate per hour, a 110 percent overhead wa s assumed. The resultant rate was rounded to the

nearest dollar, yielding $ 99 /hr.

Following the same assumptions as the 2008 ICR renewal, 34 of the industrial respondents submitting

p art C (PSD) permit applications will conduct preconstruction ambient air quality monitoring

. The

average cost for this activity is estimated to be $366,006, which is the inflation

- adjusted figure based o n

the value of $335,165 included in the 2008 ICR renewal

. As note previously, this inflation adjustment

was made using the BL S’ online inflation calculator

.13



### The labor rate used to calculate the s tate and local respondents’ labor cost is $ 81 /hr. This rate was also

obtained from the BLS survey

. 5 

### We a ssume d 100 percent overhead for s tate and l ocal a gency l abor.

Table 6

- 2 presents the s tate and local agency respondents’ burden and costs

. Their annual cost is equal

to the cost of the first year outlay, which recurs each year.

6(b)(ii) ESTIMATING CAPITAL AND OPERATIONS AND MAINTENANCE COSTS

Even if an applicant i s a brand new company and the prospective source is a “greenfield” source (the

EPA estimates less than 1 percent of the combined number of major and minor industrial respondents fit

that description) most, and perhaps all, of the equipment needed to prepar e permit applications (for

example, the computers and basic software) will be part of the source’s business operation inventory

. Furthermore, much of the data and regulatory and policy information for making technology

determinations and even models for pe rforming ambient air impact analyses are available in electronic

form from several different EPA web sites for just the communication charges, which are typically

absorbed in routine business overhead expenses.

Since the purchase of capital equipment is b elieved to be an insignificant factor in permit application

preparation, the EPA assumes the operation, maintenance, or services for same are negligible

. Further,

once a permit is issued, there is no operations and maintenance cost associated with it

. It r emains

unaltered unless the source or the permitting authority discovers specific reasons to reexamine it and

change any conditions or specifications

. If purely administrative, the changes are handled exclusively by

the permitting authority

. If changes hav e the potential for environmental consequences, the action may

be significant enough to be counted as a separate and new application, to which a new burden and cost

may be ascribed.

6(b)(iii) CAPITAL/START

- UP OPERATING AND MAINTENANCE (O&M) COSTS

Capita l/start

- up and O&M costs are non

- labor related costs

. One

- time capital/start

- up costs are incurred

with the purchase of durable goods needed to provide information

. According to the P RA , capital/start

up cost should include among other items, preparations for collecting information such as purchasing

computers and software, monitoring, sampling, drilling and testing equipment

. As a practical matter,

these costs are not typical of the costs associated with preparing a major source permit application

. For

the same reason, the O&M costs associated with start

- up capital equipment are zero for most of the

sources for this ICR. However, as shown in Table 6

- 1, 34 of the 1,610 p art C (PSD) permit applications

are projected to require preconstruction air quality moni toring , which costs $ 12,444,204

. This one

- time

cost includes pre

- application monitoring of air quality via contract services. In addition, Table 6

- 1 also

shows small capital/start

- up costs for industry respondents in the Indian country minor NSR program.

Many of the sources subject to that program have never been subject to any type of air regulations

before, and we believe that there may be some costs for such sources.

6(b)(iv) ANNUALIZING CAPITAL COSTS

Typically annualized capital cost would be derived from a discounted net present value of the stream of

costs that would occur over the life of the permit, or the ICR, whichever is shorter

. However, in the case

of NSR, there are only labor costs for preparing and processing permit applications

. Lab or costs are

5 

### State/Local rates obtained from "Employer Costs for Employee Compensation, Table 4: Employment

Costs for State and Local Government Workers" U.S. Dep t. of Commerce, BLS, June 2011.

( http://www.bls.gov/news.release/ecec.t04.htm accessed 9/19/11)14



### expensed when incurred and not amortized

. Therefore, the capital costs for NSR permitting are zero. A

minor exception is the capital/start

- up costs noted above for the minor NSR program in Indian country,

which were annualized to derive the an nual costs reported in Table 6

- 1.

6(c) ESTIMATING AGENCY BURDEN AND COST

Staff in the EPA’s R egional O ffices typically review major NSR permits and more complicated minor

NSR permits issued by state and local reviewing authorities

. In addition, Regional Office staff will now

also serve as the RA for the minor NSR program in Indian country. The EPA expects its review of NSR

permits to comprise the tasks listed in Table 6

- 3. The cost estimate uses a “loaded” labor rate of $ 46 /hr

. The rate reflects the assumption that the staff reviewing permits are classified as Grade 12 Step 1

. The

corresponding salary is loaded with benefits at the rate of 60 percent

. 6



### 6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND COST

For the purpose of estimating burden in this ICR, the respondent universe is defined by the annual

number of permit applications prepared by major and minor sources, and the annual number of permit

applications processed by s tate and local RA s

. These numbers are based on the currently approved ICR

for the NSR program, which is a revision to add the impact of the PM 2.5 

### Increments, SILs and SMC rule

(EPA ICR No. 1230.31) to the NSR program. (This burden was originally approved under EPA ICR

No. 2276.02, OMB Control No. 2060

- 0609.) The universe of permits was revised from this baseline to

account for additional PSD permits that will be required now that GHGs have come under the PSD

program and the phase

- in has progressed since that impact was last evaluated (in EPA ICR No.

1230.28). In addition, the number of minor NSR permits in Indian country was revised to reflect the

progress that will be made in that program during the term of this ICR renewal.

T his analysis uses the 112 RA count use d by other permitting ICRs and the appropriate source count for

individual permit

- related items (e.g., attending pre

- application meetings with the source). The resulting

number of respon ses for this ICR renewal is then estimated to be as follows:

1. 1,610 p a rt C (PSD) permit applications prepared by industry.

2. 486 p art D (nonattainment) permit applications prepared by industry.

3. 72,841 minor NSR permit applications prepared by industry in state/local programs

. 4. 12,432 minor source registrations and minor NSR applications prepared by industry in Indian

country

5. 1,610 p art C (PSD) permit applications processed by s tate and local RA s

. 6. 486 p art D (nonattainment) permit applications processed by s tate and local RA s

. 7. 72,841 minor NSR permit applications processed by s tate and local RA s

.

F or each category of permit application except minor sources in Indian country , the total number of

respon se s is twice the number of permit applications. (This is not the case for the minor NSR program in

Indian country because the EP A acts as the RA for that program.) In addition, e ach RA must submit

changes to its existing SIP program or demonstrate that its existing program s are at least equivalent to

the EPA ’s new requirements. Over the next 3 years, w e anticipate that all 112 RA s will submit a SIP

revision to add PM 2.5 

### to their major NSR program s , 28 will submit a SIP revision for GHGs and 13 will

6 

### Federal Labor Cost obtained from U.S. Office of Personnel Management 2011 General Schedule Table

2011

- GS. Hourly labor rate assumed is G S

- 12, Step 1 (Technical Labor).15



### submit a SIP revision for the NSR Reform rulemaking. This comes to a total of 153 over 3 years, or an

average of 51 per year.

The total annual effort for industr y respondents submitting Part C (PSD) permit applications is

1,619,660 hours, and the correspo nding annual cost is $ 172,790,544

. The total annual effort for industr y

respondents submitting p art D (nonattainment) permit applications is 312,012 hours, and the

corresponding annual cost is $ 30,889,188

. The total annual effort for industr y respondents submitting

minor NSR permit applications to state/local programs is 2, 822,885 hours, and the corr esponding annual

cost is $ 2 79,465,615

. The total annual effort for industr y respondents submitting registrations and minor

NSR permit applications for the Indian country program is 479,435 hours, and the corresponding annual

cost is $ 5,353,200. For industr y respondents, the overall total annual effort is 5,233,992 hours and

$ 488,498,547

.

The total annual effort for s tate and local respondents processing p art C (PSD) permit applications is

540,960 hours, and the corresponding annual cost is $ 43,817,760

. Th e total annual effort for s tate and

local respondents processing p art D (nonattainment) permit applications is 62,208 hours, and the

corresponding annual cost is $ 5,038,848

. The total annual effort for s tate and local respondents

processing minor NSR permi ts is 2, 095,140 hours, and the corresponding annual cost is $ 1 69,706,340

. State and local respondents also will spend approximately 2,040 hours for SIP revisions, for an annual

cost of $1 6 5, 240

. For the s tate and local respondents, the overall total annual effort is 2, 700,348 hours

and $ 2 18

, 728,188

.

6(e) BOTTOM LINE BURDEN HOURS AND COST TABLES

6(e)(i) RESPONDENT TALLY

Table 6

- 4 summarizes the estimated burden and cost to industry respondents, s tate and local agency

respondents, and the EPA for submittal and processing of NSR permit applications and the issuance of

the permits

. It also includes the cost to the respective respondents and reviewing agencies for

nonapplicability findi ngs, which preclude sources from further major source requirements

. For industr y

and s tate and local agency respondents, the over all total annual burden is 7,934,340 hours and

$ 707,226,735

.

6(e)(ii) THE AGENCY TALLY

The total annual effort for the EPA for processing p art C (P SD) permit applications is 25,760 hours, and

the corresponding annual cost is $ 1,184,960

. The total annual effort for the EPA for processing p art D

(nonattainmen t) permit applications is 7,776 hours, and the corre sponding annual co st is $35 7

, 696

. The

total annual effort for the EPA for processing minor NSR permits in state/local programs is 6,964 hours,

and the corresponding annual cost is $ 320,344

. The total annual effort for the EPA for serving as the RA

for the minor NSR program in Indian country is 44,568 hours, and the corresponding annual cost is

$4,567,077. For the EPA , the overa ll total annual effort is 85,323 hours an d $ 6,441,807

.

6(f) REASONS FOR CHANGE IN BURDEN

The burden has changed since the previous renewal due in part to an increase in the number of respon se s

and per

- permit burden due to the addition of GHGs to the PSD program. In addition, the extension of

minor NSR and part D programs to Indian country to fill these regulatory ga ps has increased the number16



### of responses and the overall burden. Finally, the burden has been increased by the addition of provisions

in the PSD program that will allow full integration of PM 2.5



### .

Also contributing to the increase in burden has been a chan ge in the labor rates . As explained in

section 6(b)(i)

, in order to improve the accuracy o f burden estimates, the rates were recalculated using

20 11 values for wages

.

6(g) BURDEN STATEMENT

The average annual burden on an industrial respondent submitting a p art C (PSD) permit applica tion is

1,006 hours

. The average annual burden on an industrial respondent submitting a p art D (nonattai nment)

permit application is 642 hours

. The average annual burden on an industrial respondent submit ting a

minor NSR permit application is about 39 hours in a state/local program and 39 hours in Indian country

.

The average annual burden on a s tate or local RA respondent processing a p art C (PSD) permit

application is 3 36 hours

. The average annual burden on a s tate or local RA respondent processing a

part D (nonattai nment) permit application is 12 8

. The average annual burden on a s tate or local agency

respondent processing a minor NSR permit application is about 29 hours

. The aver age annual burden on

a state or local RA submitting a SIP revision is 40 hours.

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

retain, or disclose or provide information to or for a f ederal agency

. Th is includes the time needed to

review instructions; develop, acquire, install, and utilize technology and systems for the purposes of

collecting, validating, verif ying, processing, maintaining, disclosing and providing information; adjust

the existing ways to comply with any previously applicable instructions and requirements; train

personnel to be able to respond to a collection of information; search data sources; complete and review

the collection of information; and transmit or otherwise disclose the in formation

. 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 the EPA’s regulations

are listed in 40 CFR part 9 and 48 CFR Chapter 15.

For those interested in comment ing 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 techn iques, the EPA has established a public docket for this ICR under

Docket ID No. EPA

- HQ

- OAR

- 2011

- 0901

, which is available for online viewing at

www.regulations.gov , or in person viewing at the Air and Radiation Doc ket and In formation Center in

the EPA Docket Cent er (EPA/DC), EPA West, Room 3334 , 1301 Constitution Avenue, NW,

Washington, DC. The EPA /DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday, excluding legal holidays

. The teleph one number for th e Reading Room is (202) 566

-

1744 , and the telephone number for the Air Docket is (202) 566

- 1742

. An electronic version of the

public docket i s available at www.regulations.gov . This s i te can be used to submit or view public

comments, access the index listing of the contents of the public docket, and to access those documents in

the public docket that are available electronically

. Once in the system, select “search,” then key in the

dock et ID number identified above

. Also, you can send comments to the Office of Information and

Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503,

Attention: Desk Office for EPA

. Please include the EPA Docket ID No. EPA

- HQ

- OAR

- 20 11

- 0901 and

OMB control number 2060

- 0003 in any correspondence.17 Table 6

- 1. Industr y Respondent Burden and Cost (Annual)

Activity Units Hours

per Unit Annual

Hours Annual Cost

I. Part C (PSD)

A. Preparation and Planning

Determination of Compliance Requirements 1,610 170 273,700 $27,096,300

Obtain Guidance on Data Needs 1,610 169 272,090 $26,936,910

Preparation of BACT Analysis 1,610 148 238,280 $23,589,720

B. Data Collection and Analysis

Air Quality Modeling 1,610 225 362,250 $35,862,750

Determination of Impact on Air Quality Related

Values 1,610 113 181,930 $18,011,070

Post

- construction Air Quality Monitoring 1,610 56 90,160 $8,925,840

C. Permit Application

Preparation and Submittal of Permit Application 1,610 60 96,600 $9,563,400

Public Hearings 1,610 25 40,250 $3,984,750

Revisions to Permit 1,610 40 64,400 $6,375,600

D. Subtotal Burden 1,006 1,619,660 $160,346,340

E. Direct Costs for Preconstruction Air Quality

Monitoring 34 $12,444,204

F. Total Costs $172,790,544

II. Part D (Non

- attainment)

A. Preparation and Planning

Determination of Compliance Requirements 486 150 72,900 $7,217,100

Obtain Guidance on Data Needs 486 100 48,600 $4,811,400

B. Data Collection and Analysis

Preparation of LAER Engineering Analysis 486 52 25,272 $2,501,928

Demonstrate Offsets 486 52 25,272 $2,501,928

Prepare Analysis of Alternative Sites, Processes, etc. 486 60 29,160 $2,886,840

Air Quality Modeling 486 130 63,180 $6,254,820

C. Permit Application

Preparation and Submittal of Permit Application 486 49 23,814 $2,357,586

Public Hearings 486 25 12,150 $1,202,850

Revisions to Permit 486 24 11,664 $1,154,736

D. Total 642 312,012 $30,889,188

III. Minor NSR

- State/Local Programs

Preparation and Submittal of Minor NSR Permit

Application a 72,841 39 2,822,885 $279,465,615

IV. Minor NSR

- Indian Country Program

A. Preparation and Submittal of Registrations and

Permit Applications a 12,432 39 479,435 $5,212,341

B. Capital Costs (Non

- Labor) 12,432 $140,859

C. Total $5,353,200

V. GRAND TOTAL 87,369 5,233,992 $488,498,547

a The hours per unit for these activities are weighted averages rounded to the nearest whole number in this table

.18 Table 6

- 2. State and Local RA Respondent Burden and Cost (Annual)

Activity Units Hours

per Unit Annual

Hours Annual Cost

I. Part C (PSD)

A. Attend Preapplication Meetings 1,610 44 70,840 $5,738,040

B. Answer Respondent Questions 1,610 27 43,470 $3,521,070

C. Log In and Review Data Submissions 1,610 22 35,420 $2,869,020

D. Request Additional Information 1,610 10 16,100 $1,304,100

E. Analyze for and Provide Confidentiality Protection 1,610 24 38,640 $3,129,840

F. Prepare Completed Applications for Processing 1,610 39 62,790 $5,085,990

G. File and Transmit Copies 1,610 8 12,880 $1,043,280

H. Prepare Preliminary Determination 1,610 41 66,010 $5,346,810

I. Prepare Notices for and Attend Public Hearings 1,610 41 66,010 $5,346,810

J. Application Approval 1,610 51 82,110 $6,650,910

K. Notification of Applicant of RA Determination 1,610 8 12,880 $1,043,280

L. Submittal of Information on BACT/LAER to RBLC 1,610 21 33,810 $2,738,610

M. Total 336 540,960 $43,817,760

II. Part D (Non

- attainment)

A. Attend Preapplication Meetings 486 7 3,402 $275,562

B. Answer Respondent Questions 486 10 4,860 $393,660

C. Log In and Review Data Submissions 486 10 4,860 $393,660

D. Request Additional Information 486 4 1,944 $157,464

E. Analyze for and Provide Confidentiality Protection 486 4 1,944 $157,464

F. Prepare Completed Applications for Processing 486 16 7,776 $629,856

G. File and Transmit Copies 486 4 1,944 $157,464

H. Prepare Preliminary Determination 486 10 4,860 $393,660

I. Prepare Notices for and Attend Public Hearings 486 19 9,234 $747,954

J. Application Approval 486 21 10,206 $826,686

K. Notification of Applicant of RA Determination 486 2 972 $78,732

L. Submittal of Information on BACT/LAER to RBLC 486 21 10,206 $826,686

M. Total 128 62,208 $5,038,848

III. Minor NSR

- State/Local Programs

Total for Preparation and Submittal of Minor NSR

Permit Application a 72,841 29 2,095,140 $169,706,340

IV. SIP Revisions

Revision of SIP 51 40 2,040 $165,240

V. GRAND TOTAL 74,988 2,700,348 $218,728,188

a The hours per unit for th is activit y is a weighted average rounded to the nearest whole number in this table

.19 Table 6

- 3. Agency Burden and Cost (Annual)

Activity Units Hours

per

Unit Annual

Hours Annual

Cost

($1000)

I. Part C (PSD)

A. Review and Verify Applicability Determination 1,610 2 3,220 $148,120

B. Review Control Technology Determination 1,610 4 6,440 $296,240

C. Evaluate Air Quality Monitoring 1,610 1 1,610 $74,060

D. Evaluate Alternative and Secondary Impact Analysis 1,610 5 8,050 $370,300

E. Evaluate Class I Area Analysis 1,610 3 4,830 $222,180

F. Administrative Tasks 1,610 1 1,610 $74,060

G. Total 16 25,760 $1,184,960

II. Part D (Non

- attainment)

A. Review and Verify Applicability Determination 486 2 972 $44,712

B. Review Control Technology Determination 486 4 1,944 $89,424

C. Evaluate Offsets 486 1 486 $22,356

D. Evaluate Air Quality Monitoring 486 5 2,430 $111,780

E. Evaluate Alternative and Secondary Impact Analysis 486 3 1,458 $67,068

F. Administrative Tasks 486 1 486 $22,356

G. Total 16 7,776 $357,696

III. Minor NSR

– State/Local Programs

Review Synthetic/Netting

- Based Minor NSR Permits 2,957 2 6,964 $320,344

IV. Minor NSR

- Indian Country Program

Review Minor NSR Permits and Registrations a 12,432 4 44,568 $4,567,077

V. SIP Revisions

Review of SIP revisions 51 5 255 $11,730

V I . GRAND TOTAL 17,536 85,323 $ 6,441,807

a The hours per unit for th is activit y is a weighted average rounded to the nearest whole number in this table

.20 Table 6

- 4. NSR Program Information Collection Burden Summary

Total Per Unit

Part C

(PSD) Part D

(Non

attainment) Minor NSR

State/Local Minor NSR

Indian

Country Cumulative

Total a+b Part C

(PSD) Part D

(Non

attainment) Minor NSR

State/Local Minor

NSR

Indian

Country

Number of Responses a 3,220 972 145

, 682 12,432 162,357

Respondent

Burden

Hours Industry 1,619,660 312,012 2, 822,885 479,435 5,233,992 1,006 642 39 39

State/Local 540,960 62,208 2, 095,140 0 2,700,348 336 12 8 29 0

Industry and

State/ Local

Agency Totals 2,160,620 374,220 4,917,995 479,435 7, 934,340 1, 342 7 70 68 39

Federal (Agency) Burden 25,760 7,776 6,964 44,568 85,323 1 6 16 2 4

Program Grand Total Burden 2,186,380 381,996 4,924,959 524,003 8,019,663

Respondent

Annual Cost

($1000 ) c Industry Labor d $ 160,346 $ 30,889 $2 79,466 $5,212 $ 475,913 $ 99.59 $ 63.56 $3. 8 4 $0.42

Other Direct

Costs e $ 12,444 $0 $0 $141 $1 2,585 $ 366 .01 $0.00 $0.00 $0.01

Total Industry

Costs f $ 172,791 $ 30,889 $2 79,466 $5,353 $ 488,499 $ 107

. 3 2 $63.56 $3.8 4 $0.43

State/Local Costs $ 43,817 $5,0 39 $1 69,706 $0 $ 218,728 $2 7 .22 $ 10.37 $2.3 3 $0

Industry and

State/Local

Agency Totals $ 216,608 $ 35,928 $4 49,172 $5,353 $ 707,227

Agency Annual Costs ($1000) $ 1,185 $358 $ 320 $ 4,567 $ 6,442 $0. 74 $0. 74 $0.00 $0.37

Program Grand Total Costs

($1000) $ 217,793 $ 36,286 $4 49,492 $9,920 $ 713,669 $ 1 35

. 28 $7 4.66 $ 6.17 $0.80

(a) In general, the number of responses is twice the number of permitting actions for a given category due to (1) the applicant p reparing the application

, and (2) the

state/local reviewing authority reviewing and issuing the permit. For the minor NSR program in Indian country the number of responses is the number of permitting

actions because the EPA is the reviewing authority.

(b) T he 112 reviewing authorities are expected to submit an average of 51 SIP revision s per year totaling 2,040 hours and $165,240 to conform their major NSR programs

to the revised rules. The EPA will review the 51 SIP revisions per year, totaling 255 hours and $11,730

. These figures are added into the Cumulative column.

(c) In general, costs are in thousands of current ( 2011 ) dollars and represent one

- time permit application costs. For the minor NSR program in Indian country, costs are in

2009 dollars.

(d) The EPA estimates that 30% of the in

- house ho urly burden may be contracted, but because it is at the discretion of the applicant, the cost has not been converted to

direct cost. Furthermore EPA assumes the labor rate would remain the same, in which case there is no impact on total annual c osts.

(e) These direct costs are primarily for 34 PSD sources (approximately 12% of the 274 sources that are subject to PSD for pollutants other than greenhouse gases) at

$ 366,006 per source, for pre

- application monitoring of air quality via contract services. This cost is not incurred by Part D or minor NSR permit applicants. However,

minor NSR applicants in Indian country, many of whom have never been subject to any type of air r egulations before

, are projected to incur some capital costs.

(f) Per unit cost for PSD permits reflects the direct cost for pre

- application monitoring averaged over all PSD permits. The estimated 34 sources that require preconstruction

monitoring are es timated to incur a n average total cost of $ 465,600 per application. The others will incur an average of $ 99,594

.21 

### APPENDIX A

INFORMATION REQUIREMENTS22 

### TABLE A

- 1

. INDUSTRY RESPONDENT DATA AND

INFORMATION REQUIREMENTS FOR

PREPARING PART C (PSD) CONSTRUCTION PERMITS

Requirement Regulation Reference

All information necessary to perform any analysis or make any

determination required 40 CFR 51.166(n)( 1 )

Description of the nature, location, design capacity, and typical operating

schedule 40 CFR 51.166(n)(2)( i )

Detailed schedule for construction 40 CFR 51.166(n)(2)(ii)

Description of continuous emission reduction system, emission estimates,

and other information needed to determine that BACT is used 40 CFR 51.166(n)(2)(iii)

Air quality impact, meteorological, and topographical data 40 CFR 51.166(n)(3)( i )

Nature and extent of, and air quality impacts of general commercial,

residential, industrial, and other growth in area of source 40 CFR 51.166(n)(3)(ii)

Use of air quality models to demonstrate compliance with NAAQS and

increment 40 CFR 51.166(k) & (l)

Air quality monitoring data 40 CFR 51.166(m)

Impairment of visibility, soils, and vegetation 40 CFR 51.166(o)(1)

Air quality impact resulting from general commercial, residential, industrial,

and other growth associated with source 40 CFR 51.166(o)(2)

Written notice of proposed relocation from portable source 40 CFR 51.166( i )( 1 )(iii)( d )

Description of the location, design construction, and operation of building,

structure, facility, or installation 40 CFR 51.160(c)(2)

Description of the nature and amounts of emissions to be emitted 40 CFR 51.160(c)(1)

Description of the air quality data and dispersion or other air quality

modeling used 40 CFR 51.160(f)

Sufficient information to ensure attainment and maintenance of NAAQS 40 CFR 51.160(c)

- (e),

40 CFR 51.161

- 16323



### Table A

- 2: INDUSTRY RESPONDENT DATA AND INFORMATION REQUIREMENTS FOR

PREPARING

PART D (NONATTAINMENT NSR) CONSTRUCTION PERMITS

Requirements Regulation Reference

Documentation that LAER is being applied 40 CFR 51.165(a)(2);

40 C FR part 51,

Appendix S,

section IV.A;

40 CFR 52.24(k)

Documentation that all sources owned or operated by same person are in

compliance 40 CFR 51.165(a)(2);

40 C FR part 51,

Appendix S,

section IV.A;

40 CFR 52.24(k)

Documentation that sufficient emissions reductions are occurring to comply

with specific offset requirements and to ensure RFP 40 CFR 51.165(a)(3);

40 C FR part 51,

Appendix S,

section IV.A;

40 CFR 52.24(k)

Documentation that benefits of proposed source significantly outweigh the

environmental and social costs imposed as a result of its location,

construction, or modification 40 CFR 51.165(a)(2)

Description of the location, design construction, and operation of building,

structure, facility, or installation 40 CFR 51.160(c)(2)

Description of the nature and amounts of emissions to be emitted 40 CFR 51.160(c)(1)

Description of the air quality data and dis persion or other air quality

modeling used 40 CFR 51.160(f)

Sufficient information to ensure attainment and maintenance of NAAQS 40 CFR 51.160(c)

- (e)

40 CFR 51.161

40 CFR 51.162

40 CFR 51.16324 

### TABLE A

- 3

. PERMITTING AGENCY DATA

AND INFORMATION REQUIREMENTS

Requirement Regulation Reference

Early FLM notification and opportunity to participate in meetings 40 CFR 51.166(p)(1)(ii)

Submission of all permit applications to EPA 40 CFR 51.166(q)(1)

Submission of notice of application, preliminary determination,

degree of increment consumption, and opportunity for public

comment 40 CFR 51.166(q)(2)(iv)

Submission to FLM of permit applications 40 CFR 51.166(p)(1)

Submission of written request to exempt sources from review 40 CFR 52.21( i )(4)(vi)

Written request for use of innovative control technology 40 CFR 51.166(s)

Establishing and operating a permitting program for all new

sources 40 CFR 51.160

Provide notice to EPA of all permits 40 CFR 51.161(d)

Provide for public comment for all NSR permits 40 CFR 51.16125 

### APPENDIX B

CALCULATIONS AND INFORMATION REQUIREMENTS

FOR

THE MINOR NSR PROGRAM IN INDIAN COUNTRY26



### Table B

- 1. Estimated Total Burden and Cost to Industry to Implement Reporting and R ecordkeeping Requirements During 3

- Year

Term of the ICR a

Affected Source Type Number of

Affected

Sources Total Hours

per Source Total Hours

(All Sources,

3 Years) b Annualized

Non

- Labor

Capital Cost per

Source c Total Cost

per

Source d Total

Annualized

Non

- Labor

Capital Costs Total Costs

New Minor Sources (Years 1 and 2)

- Registration 2,536 5 12,680 $4 $62 $10,144 $157,232

New Minor Sources (Year 3)

- Permitting 1,268 286 1,087,944 $191 $9,435 $242,188 $11,963,580

Modifications to Minor Sources (Years 1 and 2)

- Registration 328 5 1,640 $4 $62 $1,312 $20,336

Modifications to Minor Sources (Year 3)

- Permitting 164 286 140,712 $191 $9,435 $31,324 $1,547,340

Existing Synthetic Minor Sources

- Permitting 79 65 5,135 $4 $618 $316 $48,822

Existing True Minor Sources

- Registration 32,891 5 164,455 $4 $62 $131,564 $2,039,242

Minor Modifications to Major Sources

- Permitting 6 286 5,148 $191 $9,435 $1,146 $56,610

New Synthetic Minor Sources

- Permitting 24 286 20,592 $191 $9,435 $4,584 $226,440

Totals for 3 Years 37,296 1,438,306 $422,578 $16,059,602

Annual averages 12,432 479,435 $140,859 $5,353,201

Annual average labor cost $5,212,341

a Reproduced from EPA ICR No. 1230.27 ; revised to update phases of implementation during the term of this ICR.

b Sources only subject to one

- time registration or permitting costs (new minor sources during the first 2 years, modifications to minor sources du ring the first 2 years,

existing minor sources, and existing synthetic minor sources) are only attributed hours for 1 year. For the remaining affecte d sources, hours per year were multiplied by 3

years.

c The associated non

- labor capital costs for one

- time and recurring activities for permitting new minor sources, modifications to minor sources, minor modifications to major

sources, and new synthetic sources is $1,340. Annualized based on a repayment period of 10 years and an interest rate of 7 pe rcent, the amount is $191. For

registrations the non

- labor capital costs are $25 and for existing synthetic minor sources these costs are $31; annualized based on a repayment period of 10 years and

an interest rate of 7 percent, both result in $ 4.

d Sum of total rec urring costs and the annualized non

- labor cost.27



### Table B

- 2. Estimated Total Burden and Cost to EPA to Act as RA During 3

- Year Term of the ICR a

Affected Source Type Number of

Affected

Sources (First

3 Years) Average Total

Hours per

Source Total Hours Average Cost per

Source Total Costs

New Minor Sources (Years 1 and 2)

- Registration 2,536 2 5,072 $180 $456,480

New Minor Sources (Year 3)

- Permitting 1,268 42 53,256 $4,932 $6,253,776

Modifications to Minor Sources (Years 1 and 2)

- Registration 328 2 656 $180 $59,040

Modifications to Minor Sources (Year 3)

- Permitting 164 42 6,888 $4,932 $808,848

Existing Synthetic Minor Sources

- Permitting 79 10 790 $693 $54,747

Existing True Minor Sources

- Registration 32,891 2 65,782 $180 $5,920,380

Minor Modifications to Major Sources

- Permitting 6 42 252 $4,932 $29,592

New Synthetic Minor Sources

- Permitting 24 42 1,008 $4,932 $118,368

Totals for 3 Years 37,296 133,704 $13,701,231

Annual averages 12,432 44,568 $4,567,077

a Reproduced from EPA ICR No. 1230.27; revised to update phases of implementation during the term of this ICR.28



### Table B

- 3. New Sources and Modifications in Indian Country Respondent (Facility) Burden and Cost (One

- Time and Reoccurring)

(This table is reproduced verbatim from EPA ICR 1230.27. After it was prepared, the provisions of the rule were chan ged, rendering the cited

timing

— i.e., referring to the first 18 months

— incorrect.)

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical

$114 $114 $65 $49

NEW/MODIFIED MINOR SOURCES

AFTER THE FIRST 18 MONTHS

1. Preparation and Planning

a. Determination of compliance

requirements (#) 0 2 8 0 1 1 10 $0 $229 $522 $0 $751 $0 $751

b. Obtain guidance on data needs (#) 0 0 2 0 1 1 2 $0 $0 $131 $0 $131 $0 $131

c. Preparation of PTE for NSR

pollutants (#) 0 4 16 2 1 1 22 $0 $458 $1,045 $97 $1,600 $0 $1,600

2. Data Collection and Analysis (Surveys

& Studies)

a. Conduct ambient air modeling (#) 0 2 40 4 1 0.02 0.9 $0 $5 $52 $4 $61 $200 $261

3. Permit Application

a. Preparation and submittal of Permit

Application (#) 2 4 40 16 1 1 62 $229 $458 $2,612 $776 $4,075 $25.00 $4,100

b. Public hearing (#) 4 4 16 8 1 0.05 2 $23 $23 $52 $19 $117 $1.25 $119

c. Revisions to permit (#) 1 1 4 2 1 0.2 2 $23 $23 $52 $19 $117 $5.00 $122

4. Acquisition, Installation, and Use of

Technology and Systems

a. Control device operating parameter

(#) (emission) monitoring system 0 4 20 2 1 0.05 1 $0 $23 $65 $5 $93 $0 $93

5. Reporting Requirements

a. Read instructions (#) 0 2 4 0 1 1 6 $0 $229 $261 $0 $490 $0 $490

b. Required activities (#)

c. Create information

i. Conduct control device

performance test (#) 0 8 40 8 1 0.02 1 $0 $18 $52 $8 $78 $1,000 $1,078

d. Gather existing information (#) 0 0 8 2 1 1 10 $0 $0 $522 $97 $619 $0 $619

e. Write reports

i. Initial notification of intent to

constr/modify (#) 1 2 4 2 1 1 9 $114 $229 $261 $97 $702 $25.00 $727

ii. Performance test notification (#) 0 0 2 1 1 0.02 0.1 $0 $0 $3 $1 $4 $0.50 $429

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Manageria

l Technical Clerical

$114 $114 $65 $49

NEW/MODIFIED MINOR SOURCES

AFTER THE FIRST 18 MONTHS

iii. Site

- specific test plan (#) 0 1 16 8 1 0.02 0.5 $0 $2 $21 $8 $31 $0.50 $31

iv. Initial compliance status

determination (#) 1 4 8 4 1 1 17 $114 $458 $522 $194 $1,289 $25.00 $1,314

v. Performance test reports (#) 0 4 16 4 1 0.02 0.5 $0 $9 $21 $4 $34 $0.50 $34

vi. Annual monitoring report (##) 1 2 8 4 1 1 15 $114 $229 $522 $194 $1,060 $25.00 $1,085

vii. Deviation report (##) 1 2 4 2 1 0.1 0.9 $11 $23 $26 $10 $70 $2.50 $73

6. Recordkeeping Requirements

a. Read instructions (##) 1 2 8 0 1 1 11 $114 $229 $522 $0 $866 $0.00 $866

b. Plan activities (##) 0 2 8 2 1 1 12 $0 $229 $522 $97 $848 $0.00 $848

c. Implement activities

i. Prepare documentation for

exempted sources (#) 4 2 20 8 1 0.1 3 $46 $23 $131 $39 $238 $2.50 $241

ii. Monitor control device

parameters (##) 0 0 1 0 52 0.1 5 $0 $0 $340 $0 $340 $0.00 $340

iii. Inspect control device (##) 0 0 1 0 12 1 12 $0 $0 $783 $0 $783 $0.00 $783

d. Develop record system (#) 0 2 4 16 1 1 22 $0 $229 $261 $776 $1,267 $25.00 $1,292

e. Time to enter information (##) 0 0 1 0 52 1 52 $0 $0 $3,395 $0 $3,395 $0.00 $3,395

f. Time to train personnel (#) 0 0 40 4 1 0.1 4 $0 $0 $261 $19 $281 $2.50 $283

g. Time to perform audits (##) 0 2 20 0 1 0.1 2 $0 $23 $131 $0 $153 $0.00 $153

TOTAL 286 $19,493 $1,340 $20,833

NEW/MODIFIED MAJOR SOURCES

IN NONATTAINMENT AREAS

1. Preparation and Planning

a. Determination of compliance

requirements (#) 0 2 8 0 1 1 10 $0 $229 $522 $0 $751 $0 $751

b. Obtain guidance on data needs

(#) 0 0 2 0 1 1 2 $0 $0 $131 $0 $131 $0 $131

c. Preparation of PTE for NSR

pollutants (#) 0 4 16 2 1 1 22 $0 $458 $1,045 $97 $1,600 $0 $1,60030

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Manageria

l Technical Clerical

$114 $114 $65 $49

2. Data Collection and Analysis

(Surveys & Studies)

a. Conduct LAER analysis (#) 0 4 40 4 1 1.00 48.0 $0 $458 $2,612 $194 $3,264 $10,000 $13,264

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical

$114 $114 $65 $49

NEW/MODIFIED MAJOR SOURCES

IN NONATTAINMENT AREAS

3. Permit Application

a. Preparation and submittal of

Permit Application (#) 2 4 40 16 1 1 62 $229 $458 $2,612 $776 $4,075 $25.00 $4,100

b. Public hearing (#) 4 4 16 8 1 0.05 2 $23 $23 $52 $19 $117 $1.25 $119

c. Revisions to permit (#) 1 1 4 2 1 0.2 2 $23 $23 $52 $19 $117 $5.00 $122

d. Permit appeal (#) 20 5 10 10 1 0.2 9 $458 $114 $131 $97 $800 $5.00 $805

4. Acquisition, Installation, and Use of

Technology and Systems

a. Control device operating

parameter (#) (emission)

monitoring system 0 4 20 2 1 0.05 1 $0 $23 $65 $5 $93 $0 $93

5. Reporting Requirements

a. Read instructions (#) 0 2 4 0 1 1 6 $0 $229 $261 $0 $490 $0 $490

b. Required activities (#)

c. Create information

i. Conduct control device

performance test (#) 0 8 40 8 1 0.02 1 $0 $18 $52 $8 $78 $1,000 $1,078

d. Gather existing information (#) 0 0 8 2 1 1 10 $0 $0 $522 $97 $619 $0 $619

e. Write reports

i. Initial notification of intent to

constr/modify (#) 1 2 4 2 1 1 9 $114 $229 $261 $97 $702 $25.00 $727

ii. Performance test notification

(#) 0 0 2 1 1 0.02 0.1 $0 $0 $3 $1 $4 $0.50 $4

iii.Site

- specific test plan (#) 0 1 16 8 1 0.02 0.5 $0 $2 $21 $8 $31 $0.50 $31

iv. Initial compliance status

determination (#) 1 4 8 4 1 1 17 $114 $458 $522 $194 $1,289 $25.00 $1,314

v. Performance test reports (#) 0 4 16 4 1 0.02 0.5 $0 $9 $21 $4 $34 $0.50 $34

vi. Annual monitoring report (##) 1 2 8 4 1 1 15 $114 $229 $522 $194 $1,060 $25.00 $1,085

vii. Deviation report (##) 1 2 4 2 1 0.1 0.9 $11 $23 $26 $10 $70 $2.50 $73

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical

$114 $114 $65 $49

NEW/MODIFIED MAJOR SOURCES

IN NONATTAINMENT AREAS31

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Manageria

l Technical Clerical

$114 $114 $65 $49

6. Recordkeeping Requirements

a. Read instructions (##) 1 2 8 0 1 1 11 $114 $229 $522 $0 $866 $0.00 $866

b. Plan activities (##) 0 2 8 2 1 1 12 $0 $229 $522 $97 $848 $0.00 $848

c. Implement activities

i. Prepare documentation for

exempted sources (#) 4 2 20 8 1 0.1 3 $46 $23 $131 $39 $238 $2.50 $241

ii. Monitor control device

parameters (##) 0 0 1 0 52 0.1 5 $0 $0 $340 $0 $340 $0.00 $340

iii. Inspect control device (##) 0 0 1 0 12 1 12 $0 $0 $783 $0 $783 $0.00 $783

d. Develop record system (#) 0 2 4 16 1 1 22 $0 $229 $261 $776 $1,267 $25.00 $1,292

e. Time to enter information (##) 0 0 1 0 52 1 52 $0 $0 $3,395 $0 $3,395 $0.00 $3,395

f. Time to train personnel (#) 0 0 40 4 1 0.1 4 $0 $0 $261 $19 $281 $2.50 $283

g. Time to perform audits (##) 0 2 20 0 1 0.1 2 $0 $23 $131 $0 $153 $0.00 $153

TOTAL 342 $23,496 $11,145 $34,64132

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Manageria

l Technical Clerical

$114 $114 $65 $49

EXISTING SYNTHETIC MINOR

SOURCES

1. Permit Application

a. Preparation and submittal of Permit

Application (#) 2 4 40 16 1 1 62 $229 $458 $2,612 $776 $4,075 $25.00 $4,100

b. Public hearing (#) 4 4 16 8 1 0.05 2 $23 $23 $52 $19 $117 $1.25 $119

c. Revisions to permit (#) 1 1 4 2 1 0.2 2 $23 $23 $52 $19 $117 $5.00 $122

TOTAL 65 $4,310 $31 $4,34133

Facility NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Costs (H)

Total

Costs

(F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical

$114 $114 $65 $49

EXISTING TRUE MINOR SOURCES

AND NEW TRUE MINOR SOURCES

DURING FIRST 18 MONTHS

1. Registration

a. Read instructions (#) 0 1 1 0 1 1 2 $0 $114 $65 $0 $180 $0 $180

b. Minor source facility registration (#) 0 1 1 1 1 1 3 $0 $114 $65 $49 $228 $25.00 $253

TOTAL 5 $408 $25 $433

Notes: # = One

- time costs that are incurred and treated as capital costs.

## = Annual or reoccurring cost included as an annual cost.

For New/Modified Minor Sources after the First 18 Months:

Based on the above costs, the average capital co st per facility for the one

- time activities is $13,290 per source (i.e., the sum of those items identified as one

- time costs

[#]); annualized, this cost is $1,892 per year per source. The average non

- labor capital cost is $1,340 (total of column G); annu alized, this cost is $191 per year per

source. The total of the various annual and reoccurring costs (##) in column H plus the annualized capital cost is an averag e of $9,435 per year per source.

For New/Modified Major Sources in Nonattainment Areas:

Based on the above costs, the average capital cost per facility for the one

- time activities is $17,138 per source (i.e., the sum of those items identified as one

- time costs

(#)); annualized, this cost is $2,440 per year per source. The average non

- labor capital cost is $1,185 (total of column G); annualized, this cost is $169 per year per

source. The total of the various annual and reoccurring costs (##) in column H plus the annualized capital cost is an averag e of $9,983 per year per source.34



### Table B

- 4 . New Sources and Modifications in Indian Country Agency Burden and Cost (One

- Time and Reoccurring)

(This table is reproduced verbatim from EPA ICR 1230.27. After it was prepared, the provisions of the rule were changed, rend ering the cited

timing

— i.e., re ferring to the first 18 months

— incorrect.)

Agency NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Annual

Costs (H)

Total

Costs

per year

(F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical

$114 $114 $65 $49

NEW/MODIFIED SOURCES (Major

and Minor)

1. Permit Review

a. Initial permit review 0 1 8 0 1 1 9 $0 $114 $522 $0 $637 $0 $637

b. Public Hearing 0 1 8 8 1 0.05 0.9 $0 $6 $26 $19 $51 $5 $56

c. Permit Revisions 1 1 4 0 0.2 0 $0 $0 $0 $0 $0 $0 $0

2. Report Review

a. Initial notification of intent to

constr/modify 0 1 4 0 1 1 5 $0 $114 $261 $0 $376 $0 $376

b. Appeal 1 1 4 0 1 0.1 0.6 $11 $11 $26 $0 $49 $0 $49

c. Performance test notification 0 1 2 0 1 0.02 0.06 $0 $2 $3 $0 $5 $0 $5

d. Site

- specific test plan 0 1 8 0 1 0.02 0.2 $0 $2 $10 $0 $13 $0 $13

e. Initial compliance determination 0 1 8 0 1 1 9 $0 $114 $522 $0 $637 $0 $637

f. Performance test reports 0 2 16 0 1 0.02 0.4 $0 $5 $21 $0 $25 $0 $25

g. Annual monitoring report 0 2 8 0 1 1 10 $0 $229 $522 $0 $751 $0 $751

h. Deviation report 0 2 4 0 1 0.1 0.6 $0 $23 $26 $0 $49 $0 $49

i. Annual monitoring reports 0 1 4 0 1 0.1 0.5 $0 $11 $26 $0 $38 $0 $38

3. Site Compliance Inspections (a,b)

a. Pre

- inspection review of facility

information 0 1 8 1 1 0.1 1 $0 $11 $52 $5 $69 $0 $69

b. Travel to and from facility (b) 0 0 8 0 1 0.1 0.8 $0 $0 $52 $0 $52 $10 $62

c. Inspection of air control

equipment used to comply with

rule requirements 0 0 4 0 1 0.1 0.4 $0 $0 $26 $0 $26 $0 $26

d. Review site records 0 0 4 0 1 0.1 0.4 $0 $0 $26 $0 $26 $0 $26

e. Prepare inspection report 0 4 16 4 1 0.1 2 $0 $46 $104 $19 $170 $3 $17235

Agency NSR Program

Activity (A) Labor Hours per Activity per

Labor Category (B)

Activities

per

Respondent

per Year (C)

Total

Number

of

Respondents (D)

Total

Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F)

Total

Labor

Costs (G)

Associated

Annual

Costs (H)

Total

Costs

per year

(F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical

$114 $114 $65 $49

4. Enforcement Actions (c,d)

a. Inform facility of noncompliance 4 4 20 8 1 0.01 0.4 $5 $5 $13 $4 $26 $0 $26

b. Follow

- up site inspection 0 4 20 4 1 0.01 0.3 $0 $5 $13 $2 $20 $1 $21

TOTAL ANNUAL COST PER

SOURCE 42 $3,019 $19 $3,037

5. Litigation Cost per Tribal Agency 40 40 100 40 1 0.3 73 $1,525 $1,525 $2,174 $646 $5,871 $17 $5,887

TOTAL 115 8,889 35 8,925

6. EPA Overview of Tribal Agency 8 8 40 8 1 1 64 $916 $916 $2,612 $388 $4,832 $100 $4,932

EXISTING SYNTHETIC MINOR

SOURCES

1. Permit Review

a. Initial permit review 0 1 8 0 1 1 9 $0 $114 $522 $0 $637 $0 $637

b. Public hearing 0 1 8 8 1 0.05 0.9 $0 $6 $26 $19 $51 $5 $56

c. Permit revisions 1 1 4 0 0.2 0 $0 $0 $0 $0 $0 $0 $0

TOTAL 10 $688 $5 $693

EXISTING TRUE MINOR SOURCES

AND NEW TRUE MINOR SOURCES

DURING FIRST 18 MONTHS

1. Registration Review

a. Minor source facility registration 0 1 1 0 1 1 2 $0 $114 $65 $0 $180 $0 $180

TOTAL 2 $180 $0 $180