**INFORMATION COLLECTION REQUEST RENEWAL**

**FOR THE NO**  **x BUDGET TRADING PROGRAM TO REDUCE THE REGIONAL**  **TRANSPORT OF OZONE SUPPORTING STATEMENT**  EPA I CR No. 1857. 0 6 , OMB Control No. 2060

- 0445 **1. IDENTIFICATION OF THE INFORMATION COLLECTION**  **1 (a** **) Background** This Information Collection Request (ICR) addresses the labor hour burden and costs of State reporting requirements contained in the U.S. Environmental Protection Agency' s (EPA) rule to control regional transport of ozone season NO x emissions contributing to exceedances of the Ozone National Ambient Air Quality Standard (NAAQS) in the eastern United States , which was published on October 27, 1998 (63 FR 57350). This rule is known informally as the NO x SIP Call . These provisions are incorporated in 40 CFR 51.121 and 51.122. The reporting requirements of this rule under §51.122 are imposed directl y on the States, not on industry

. However, in order to meet the requirements of this rule, States will of necessity have to impose requirements on industry for installation of continuous emission monitors and for recordkeeping and reporting. Therefore, there will be an indirect record keeping and reporting burden on industry as a result of this rule , and this IC R estimates th os e burden hours and costs incurred b y industry

. The focus of this ICR is the monitoring and reporting burden for S tates and sources that remain affected by

the NO x SIP Call and that are not subject to subsequent rulemaking and addressed in other ICRs

. The rule originall y encouraged an emissions trading program for fossil fuel

- fired NO x sources serving electrical generators (EGUs) with a nameplate capacity greater than 25 MW or boilers, combustion turbines , or combined cycle units with maximum design heat input greater than 250 mm BTU/hr. Under the NO x SIP Call , many S tates elected to meet much of the required emission reductions through the NO x Budget Trading Program (NBP), a federally administered emissions trading program. Most of the units that originally participated in the NBP now participate in an expanded emissions trading program established in conjunction with the Clean Air Interstate Rule ( CAIR) , and the burdens and costs for those units are covered under EPA I CR #2152.04 , OMB Control Number 2060

- 0570

. The only units still subject to this I CR are certain industrial combustion sources and EGUs that participated in the NBP but are not participatin g in CAIR. As part of the NO x SIP Call, States are required to report certain data to EPA on an annual or triennial basis. However, both the A ir Emission Reporting Rule (AERR) for the national emission inventory and CAIR include similar reporting requirements, and all State burdens associated with this ty pe of reporting are now addressed in either the AERR or CAIR ICR s . Thus, the onl y burdens and costs addressed in this I CR are for the former NBP units that are not participating in CAIR as discussed above in this section (affected units)

.2

**1 (b**  **) Information to b**  **e Collected** To meet the emissions monitoring recordkeeping and reporting requirements, the affected units are required to : (1) submit a monitoring plan and certification of monitors ; (2) monitor and record hourly

pollutant and flow monitor data; and (3) submit electronic quarterl y reports of their emissions data to EPA. In addition, while many

sources have already

installed necessary

emissions monitoring equipment due to requirements under other regulations, some sources will need to either install new monitors or upgrade existing monitors. Capital costs also usually include the cost of initial certification of new or upgraded monitors as part of start

- up costs. The respondent reporting burden for the collection of information under the NO x SIP Call is estimated to be 57,586 hours each ye ar for the years 2013 through 2015 . The burden to EPA is estimated to be 848 hours i n each ye ar for the years 2013 through 2015

. **1 (c** **) Terms**  **of Clearance** Terms of Clearan ce for the previous ICR renewal: None. **2 .**  **NEED FOR AND USE OF THE COLLECTION** This section describes EPA ' s need for the information collections described above and the legal authority for conducting collections. The users of collected information are also described. **2 (a** **) Need /Authority for t**  **he Collection** The State reporting requirements included in the NO x SIP Call are necessary for EPA to carry out properl y its evaluation of each State ' s compliance with its ozone season NO x emissions budget. The legal authority for the reporting requirements resides in Sections 110(a) and 301(a) of the Clean Air Act. Specificall y, the requirement in Section 110(a)(2)(D) that SIPs include
" adequate provisions " to mitigate certain transp ort effects on other States implicitly authorizes emissions inventory

reporting to EPA, as needed and appropriate to verify that a State is in fact meeting its NO x budget. Section 110(a)(2)(F) provides additional authority for requiring that SIP call subm issions include provisions for emissions reporting by sources to a State, correlation of source information by

the State, and steps by

the State to make the correlated information available to the public. Section 110(a)(2)(K), in turn, requires a State to submit to EPA as requested data related to modeling the effect of NO x and other emissions on ambient air quality

. The reported emissions inventory data will be used by

EPA in air quality

modeling to assess the effectiveness of the transport rulemaking ' s regional strategy . Finall y, Section 301(a) grants EPA broad authority to prescribe such regulations as are necessary to carry out its functions under the Clean Air Act. **2 (b**  **) Practical Utility/Users of the Data**  The EPA believes it is essential that compliance with the regional control strategy be verified. Tracking emissions is the principal mechanism to ensure compliance with the budget3

and to assure the downwind affected States and EPA that the ozone transport problem is being mitigated. If tracki ng and periodic reports indicate that a State is not implementing all of its NO x control measures or is off track to meet its statewide budget, EPA will work with the State to determine the reasons for noncompliance and what course of remedial action is ne eded. The EPA will expect the State to submit a plan showing what steps it will take to correct the problems. Noncompliance with the NO x transport SIP may lead EPA to make a finding of failure to implement the SIP and potentiall y to implement sanctions, if the State does not take corrective action within a specified time period. The information collected by the industry

sources subject to this I CR provide s necessary input data to the State emission inventory needed for tracking regional control strategy compliance. **3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA**  This section describes : (1) efforts by EPA to learn whether the information requested is available from other sources; (2) consultations with respondents and data users to plan collections, monitor their usefulness, and minimize the collection burden; (3) effec ts of less frequent collections; and (4) justification for deviations from OMB ' s general guidelines. **3 (a** **) Nonduplication**  To minimize the reporting burden on State agencies, the reporting requirements for 40 CFR 51.122 are based on existing annual and periodic emission inventory reporting requirements as much as possible. In large part, the emission inventory requirements under the NO x SIP Call are now met through the comparable requirements associated with CAIR, and the direct State burdens associated with inventory reporting for the regional control program are now included in the CAIR ICR. The onl y burdens remaining under this I CR reflect emissions reporting under the NOx SIP Call for sources not covered under CAIR that are part of the NO x SIP Call control strategy
. Almost all information requested from respondents under this I CR renewal is not available from other sources. Where EPA needs information that has already been submitted, EPA is simply

requiring the retransmission of stored electronic data. **3 (b**  **) Public Notice Required Prior to ICR Submission to OMB**  For the renewal ICR, a public n otice was published in the Federal Register on September 17 , 201 3 on availability

of the draft supporting statement for the I CR renewal. A 60 day comment period for public comments was provided in the notice. EPA received no comments in response to the p ublic notice that was published in the Federal Register (see Docket ID No. EPA

HQ

- OAR

- 2006

- 0947 ).

**3 (c** **) Consultations**4

As part of updating the previous I CR in 2010, EPA contacted via telephone three affected sources for comment on the respondent costs/burdens detailed in this I CR renewal. Specificall y, EPA contacted Spring O’Mara with the Conoco Philips Trainer Refinery at 610

- 364

- 8058 , Jennifer Marshall with the Tate and Lyl e Facility at 217

- 421

- 2620, and Catherine Lanter with the Conoco Philips Wood River Refinery at 618

- 255

- 2505. Spring O’Mara and Jennifer Marshall responded and were provided a cop y of the IC R supporting statement for review. Neither Jennifer Marshall nor Spring O’Mara had any comments regarding the costs/burdens detailed in this I CR renewal. No response was received from Catherine Lanter. Additionally , EPA held numerous consultations during initial development of the NBP , during development of CAIR, and during the ongoing development of a replacement rule for CAIR. The reduced burdens accounted for under this renewal ICR reflect that most of the reporting burden under the NO x SIP Call is now addressed under CAIR (or its replacement rule in the future). For the initial rule development, on January 13, 1998, EPA held a one

- day pre - proposal workshop with the States to discuss tracking issues. The objective of the workshop was to determine what type and frequency of invento ry

reporting is feasible for the different source sectors (power generating sources, other point sources, area sources, nonroad mobile, and highway mobile sources), to identify key reporting issues related to each sector, and to develop recommendations on reporting requirements to ensure compliance with the NO x budgets. The goal was to share information and ideas rather than to reach consensus. A summary of the meeting is contained in the docket (docket no. A

- 96

- 56, item V

- B

- 18) for the NO x SIP Call rulem aking. The reporting requirements included in 40 CFR 51.122 are based, in part, on the suggestions of participants in the workshop. The recordkeeping and reporting requirements in §51.122 were included in the supplemental proposal (63 FR 25902, May 11, 1998) on which public comments were solicited. Comments received were reviewed and where appropriate were incorporated into the rule requirements as currently given in 40 CFR 51.122. Finally , as part of updating the ICR for the Acid Rain Program (Part 7 5) monitoring requirements, EPA also contacted various affected parties to gather information on CEM capital costs, CEM operation and maintenance costs, fuel meter capital costs, and CEM/fuel meter testing costs. That information has been used in this I CR where appropriate. **3 (d**  **) Effects of Less Frequent Collection**  If this information collection were not carried out annually for sources being controlled to meet the NO x budgets, EPA would not be able to verify that NO x emission reductions necessary to meet each State ' s NO x emission budget were being achieved. Quarterl y collection of emissions data for the affected units allow s the opportunity to check data for errors and provide rapid feedback on needed adjustments to data collection sy stems, and thereby promoted accurate and reliable emissions data. For this same reason, existing Federal and S tate emission monitoring programs often require quarterl y reporting, or in some cases, monthly . Less frequent collection, s uch as semi

- annually or annually , would increase the amount of preparation and review time at the end of the reporting period both for5

regulated sources and for EPA. This would slow down the process for the verification of compliance. As an option for this program, EPA will allow for ozone season reporting instead of quarterl y reports for the entire calendar ye ar. Under this option, units would only be required to submit two reports per ye ar (covering the second and third calendar quarters). However, b ecause the Agency

believes that full

- ye ar quarterl y reporting will be beneficial for both the source and the Agency , this ICR assumes most units will elect to comply with the standard quarterl y reporting requirement. **3 (e**  **) General Guidelines**  This I CR do es not violate any of OMB ' s guidelines for information collections. **3 (f**  **) Confidentiality** As required b y Section 114 of the Clean Air Act, estimates or measurements of emissions must be treated as nonconfidential. Under Agency procedures, data items relating to the computation of emissions may be identified as sensitive by a State and are then treated as " State

sensitive " by

EPA. The potentially

State

- sensitive items include the following: p rocess rate, boiler design capacity, emission estimation codes, percent space heat, operating rate, and maximum operation rate/hour. Where Federal and State requirements are inconsistent, EPA Regional Office should be consulted for final reconciliation. **3 (g** **) Sensitive Questions**  Not applicable. This information collection does not ask any questions concerning sexual behavior or attitudes, religious be liefs, or other matters usually considered private.

**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  This section lists the major categories of businesses that formerl y participate d in the NO x Budget Trading Program and that continue to have reporting obligations under their states’ NOx SIP Call rules that are not duplicated under other rules , the data items requested from program participants, and the activities in which the participants must engage to assemble or submit the required data items. **4 (**  **a ) Respondents**  **/SIC Codes** This I CR estimates the burden for affected industry sources to monitor NO x mass emissions so that states and EPA can track compliance with state emission budgets and NO x control measures. Sources may report data directly

to EPA if a source is required to meet the monitoring and reporting requirements of Subpart H of Part 75. Electric utility combustion sources are generall y cl assified as either SIC 4911

- Electric Servi ces, or 4931

- Electric and Other Services Combined [NAI CS 221112 Electric Power Distribution]. Large industrial combustion sources (e.g., boilers, turbines, and internal combustion engines) are expected to fall6

under SI C codes for the manufacturing sec tor, i.e., SI C Major Groups 29

- 40 [NAI CS 31

- 33 Manufacturing]. **4 (b**  **) Information Requested**  This section describes the industry reporting requirements needed to enable state agencies to meet their reporting and recordkeeping requirements in §51.122. St ates must report NO x emissions data as specified in 40 CFR §51.122. (i ) Data Items, Including Recordkeeping Requirements The affected units will continue to monitor NO x mass emissions, and record and report emissions data using the requirements of 40 CFR Part 75. The emissions monitoring requirements specify

that affected sources must: (1) submit a monitoring plan for each affected unit at a source; (2) submit data for certification of each monitor; and (3) record hourl y operational, pollutant monitor, and flow monitor data for each affected unit and submit quarterl y reports of their emissions data to EPA. Appendices A and B to the CAIR ICR (EPA I CR # 2152.04) contain a list of the data items required by the recordkeeping and reporting provisions of Part 75. Respondents are required by 40 CFR 75.64 to submit the quarterl y NO x mass emissions data electronicall y, b y direct electronic submission to EPA, and must also inc lude a certification statement by

the designated representative of the unit. All monitoring records are to be kept for three ye ars, with one possible exception under a voluntary option for fuel flowmeter calibration testing. (ii) Respondent Activities The affected units will (1) complete and submit appropriate monitoring plan forms for each affected source and each affected unit at a source; (2) conduct tests to certify the operation of monitors, and submitting test results to EPA; (3) record hourl y emissions data (this activity generall y is performed electronicall y); (4) conduct operation and maintenance activities associated with the monitoring, including quality assurance activities; (5) assure data quality, prepare quarterl y reports of emissions data and submit these reports to EPA; and (6) respond to error messages generated by EPA. In addition, respondents will have to purchase the necessary monitoring hardware and purchase the electronic data reporting software (or software upgrades).

**5. THE INFORMATION COLLECTED** 
**-- AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT** The first part of this section describes Agency (EPA) activities related to the acquisition, anal ys is, storage, and distribution of the information collec ted from sources that are required to submit moni toring and test data . The second part describes the information management techniques emplo yed to increase the efficiency of collections. The third part discusses the burden or benefits of the collection activities described in this I CR to small entities. The last part outlines the schedule for collecting information.7

**5 (a** **) Agency Activities**  The tasks that will be performed b y EPA include processing, reviewing, and evaluating e missions data reports subm itted by the affected units, and conducting appropriate audit activities to verify

the information provided. **5 (b**  **) Collection Methodology and Management**  Several computer sy stems and associated databases have been developed to record quarterl y emissions monitoring data under Part 75. The sy stems and databases are designed to coordinate the information for eas y access and use by the Agency , States , regulated community , and the public. The EPA also has established a Clean Air Markets Home Page on the i nt ernet, which includes detailed information collected from emissions reports. The Data and Maps section of the EPA ' s Clean Air Markets Home Page on the internet includes detailed information collected from emissions reports, and facility or source data. Those without access to the Internet may use the Clean Air Markets Hotline to request information. **5 (c** **) Small Entity Flexibility**  The rulemaking, which EPA published by notice in 63 FR 57356 (October 8, 1998), would simply

require States to develop, ad opt, and submit SIP revisions. Pursuant to 5 U.S.C. 605(b), in the rulemaking, the Administrator certified that the rule will not have a significant economic impact on a substantial number of small entities. In addition, under Part 75, there are options for reduced monitoring that may assist smaller sources. The low mass emitter exception (40 CFR 75.19), allows optional reduced monitoring, quality

assurance, and reporting requirements for units that combust natural gas and/or fuel oil and that emit no m ore than 50 tons of NO x annually (or, at the source ' s election, 25 tons per ozone season) and that calculate no more than the same amount based on specified procedures for calculating and reporting emissions. Qualifying sources are not required to keep monitoring equipment installed on (or conduct fuel sampling for) low mass emissions units, nor are they required to perform quality assurance or quality

control tests. Moreover, emissions reporting requirements are significantly simplified for these units. Even if a gas

- or oil

- fired unit does not qualify for the " low mass emissions unit " exception, the monitoring provisions of Part 75 do allow for the use of alternative methods to determine emissions. As discussed in the Regul atory Impact Analy sis (RIA) of the final Acid Rain Implementation Regulations (October 19, 1992), smaller utilities are more likely to be dependent on these oil

- and gas

- fired units, especially very small utilities (see p. 5

– 14 of that RIA document). **5 (d**  **) Collection**  **Schedule** Affected units conduct ongoing monitoring, with quarterl y reporting.8

**6. ESTIMATING THE BURDEN AND COST OF COLLECTIONS**  **6( a** **) Determining Wage Rates**  Inestimating labor costs for industry , EPA used the following amounts: $ 99

. 75 per hour for managers and $ 6 9

. 03 per hour for technicians. These rates were updated from the previous NBP ICR rates based on the Current Employ ment Cost Index , June 2013 (http://www.bls.gov/schedule/archives/eci_nr.htm#2013 ). Federal Agency

labor rates were assumed to be $ 50.12 per hour. This l abor rate was derived from the F ederal government ' s 20 12 U.S. Office of Personnel Management General Schedule " Salary

Table 20 12

- GS " (http://archive.opm.gov/oca/12tables/pdf/gs.pdf ) using the factors in the following table.

**Table 6**
**- 1**  **: Determination of Federal Wage Rates**  Annual Salary of Technical Staff, GS 11 , Step 3 $ 53,639 Annual Cos t of Supervisory Staff, GS 13, S tep 3 $ 76,452 Factor (1/11) 0.09 $6, 881 Annua l Cost of Support Staff, GS 6, S tep 6 $ 35,672 Factor (1/8) 0.13 $4, 637 Annual Applicable Salary of Permit Staff 65157 Benefits 1.6 Total Cost per FTE $ 104,251 Total Hourly Cost (total per FTE dividend divided by 2,080 hours per year) $ 50.12
**6(b) Estimating Respondent Burden for Affected**  **NBP Units** This section estimates the paperwork burden and cost of submitting monitoring plans, obtaining certification of each monitoring s ys tem, conducting monitor quality assurance activities, and recording and reporting data from CEM sy stems (or approved alternatives), and other ancillary

activities (such as responding to EPA generated error messages, or responding to EPA audits). This applies to the affected units that continue to monitor in accordance with Part 75 under the NO x SIP Call. To estimate the burden and/or cost, EPA has relied on the estimates included in the most recent Acid Rain Program I CR (OMB Control Number 2060

- 0258) renewal for labor hour estimates of each activity. Inaddition, the hourly labor rates for managerial, technical, and clerical staff reflect the 2009 labor rates used in the Acid Rain ICR adjusted to 2012 d ollars consistent with Agency

ICR guidance.9

Affected sources are required to complete and submit a monitoring plan and obtain certification of each monitor (on standard forms) for each affected unit at the source. These plans and certifications, which are onl y submitted once, have already been submitted for most units. Sources, however, may need to submit revised plans or even recertify if they change some aspect of their existing plan. New units will still need t o submit plans and certifications for the first time. Inaddition, all affected units are required to submit quarterly reports of their emissions data to EPA . These reports include much of the basic monitoring plan data as well. To develop this renewal ICR, EPA relied primarily on the extensive efforts to identify and calculate burdens for the prior two ICR renewals and the CAIR ICR (OMB Control Number 2060

- 0570)

. **Estimating Respondent Burden** The primary

tasks performed by

owners and operators of affe cted units are : (1) reviewing the regulations, forms and instructions; (2) responding to EPA generated error messages and audits; (3) reprogramming a DAHS and debugging the software; (4) completing and submitting monitoring pl ans for each unit at the source; (5) performing appropriate tests and providing test results to certify each monitor; (6) performing quality assurance testing and maint enance upon monitors; (7) assuring the quality of emissions data, preparing quarterly reports of emissions data, and submitting reports to EPA; and (8) fuel sampling. (i ) Regulatory Review

. The estimate for time to review instructions and requirements remains consistent with the labor estimates used in previous I CRs ( four manager hours and four technician hours) whe re no substantial changes have been made to the Rule. EPA continues to make available online fully searchable versions of the Part 75 Emissions Monitoring Policy Manual and the Emissions Collection and Monitoring Plan Sy stem (ECMPS) Reporting Instructions and searchable version of Part 75. In addition, EPA in 2005 posted online a text version of its Plain English Guide to Part 75. (ii) Response to Error Messages/Audits

. The EPA provides feedback to sources so that suspected errors in submissions by sources are noted and corrected. With the use of the ECMPS software, EPA believes that the burdens for this activity

have decreased over time. At the same time, however, EPA has increased its audit oversight and expects to conduct a number of electronic and field audits of facilities over the next few years. In particular, EPA anticipates making significant use of electronic audits as a means to provide continuous data quality improvement. This effort will result in increased burdens for respondents. (iii) DAHS Debugging

. Each source must purchase (or create) and install computer software designed to implement the electronic data reporting formats required under the Acid Rain Program. EPA promulgate d revisions to Part 75 in late 2007 to accommodate changes in EPA ' s data s ys tems that manage the data submitted by respondents. These data s ys tem changes were necessary to10

modernize EPA ' s data s ystems and streamline reporting. The costs of the required up grade were anal yz ed in a separate ICR that was issued in conjunction with the Part 75 revisions. For the time period of this I CR, 2013

- 2015 , no other changes would require a DAHS upgrade and therefore there are no burden hours for this activity

. (iv) M onitoring Plans

. Consistent with the existing ICR, completing and submitting monitoring plans is estimated to require an average of about 20 hours per unit initially

. For existing units, initial monitoring plan submissions will be received prior to the time period covered in this renewal ICR, and, consistent with the existing I CR, EPA does not include burden hours for existing units under this initial monitoring plan development task area during 2013

– 2015

. The burden associated with revising the monit oring plan is included in the time for preparing and submitting each quarterl y emissions report. For new units, EPA has used an estimated number of new units as a projection for the average number of new units expected in 2013

– 2015

. These units have a separate line item for initial monitoring plan preparation. (v) Monitor Certification

. For existing units, only

recertifications are included in the estimated activities for 2013

– 2015

. The Agency

estimates a labor burden of 50 hours and a contractor cost of $3,400 per respondent. The cost and burden figures exclude the costs and burdens associated with conducting a RATA as part of the recertification process because those costs are incorporated within the annual QA costs for previousl y certified mon itoring sy stems. Under Part 75, sources are required to recertify the monitoring sy stems whenever the source makes a replacement, modification, or change in a certified CEMS or continuous opacity monitoring sy stem that may significantly

affect the ability of the s ys tem to accuratel y measure or record the NO x concentration, stack gas volumetric flow rate, NO x emission rate, percent moisture, or to meet the QA and QC requirements. Recertification is also necessary whenever the source makes a replacement, modification, or change to the flue gas handling s ys tem or the unit operation that may

significantly

change the flow or concentration profile. Examples of changes which require recertification include: replacement of the anal yz er, change in location or orientation of the sampling probe or site; and complete replacement of an existing CEMS or continuous opacity monitoring s ys tem. For new units, the monitor certification costs are included in the capital/startup costs. (vi) Quality Assurance

. Quality assurance (QA) testing and maintenance upon monitoring sy stems is the largest burden item under the monitoring, reporting and recordkeeping requirements. The requirements include daily , quarterly

and annual QA requirements, depending on the monito ring approach being used. For reporting units that use flow and NO x CEMS , the Agency has developed a per unit labor burden based primarily on information gathered from affected sources. For units that rely on the excepted methods under both Appendix D and E (i.e., units without CEMS), the11

burden estimates are reduced further because no CEMS QA is required. For the relativel y small number of units that require moisture correction, labor burdens for moisture monitoring QA activities have been added based on information supplied by an affected utility

(see Docket A

97

- 35, Item II

- D

- 94). (vii) Quarterly Reports

. Tasks performed b y utilities in preparing quarterl y reports include: (1) a ssuring the quality of the data; (2) preparing the quarterl y report ; (3) revising th e monitoring plan, if necessary ; (4) preparation of hard cop y documentation acc ompanyi ng the quarterl y reports; and (5) managerial review. EPA has been improving electronic file transfer procedures over the past few ye ars and has been dev eloping automated tools that allow sources to quality assure their reports. EPA believes these efforts have reduced the average burdens per report over time. In addition, because the program is maturing, the respondents have developed procedures and meth ods to increase their efficiency with reporting. **Estimating Respondent Costs**  Table 6

- 4 summarizes the annual respondent costs. The following discussion describes how those costs were derived. (i ) Estimating Total Capital and Annual Operations and Maintenance Costs Capital/start

- up costs include the cost of installing required CEMS or alternatives. The Agency developed the capital cost estimates for the CEM and other equipment based on EPA CEM cost models, existing ICRs, and comments from various affected utilities. The cost estimates vary

depending on the number and type of monitors that are required. These annualized capital costs are from the Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule) E PA I CR #2152.0 4 . The annualized costs ranged from $28,879 for units with a full set of CEMS, to $18,750 for a unit that uses NO x CEMS and Appendix D methods, to $2,250 for units that use both Appendix D and Appendix E methods without any

CEMS. There are no capital/start

- up costs for LME units. A discussion of how the capital/start

- up costs were annualized follows in Section (iii) , below

. In addition to capital/start

- up costs, respondents incur operation and maintenance costs (exclusive of labor costs) that reflect ongoing costs to a unit. These costs include both contractor costs for the required recertification, diagnostic, and quality assurance (QA) testing, and other direct maintenance

- related expenses ( e.g. , spare parts and calibration gases). The cost estimates used in this renewal ICR are generally the same as the Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule) EPA ICR #2152.0 4 , and have been derived from EPA CEM cost models, existing I CRs, Agen cy staff experience under the Acid Rain Program, information gathered during development of the 1999 and 2002 Part 75 revisions, and supplemental estimates provided b y affected utilities and others related to the various cost items (see, e.g., EPA Air Docket A

- 97

- 35, Item II

- D

- 48). The total cost for these operation and maintenance cost items (other than fuel sampling) is estimated at $31,200 for a unit with a full set of CEMS, while units that use alternate methodologies have reduced costs.12

Note that t esting contractor costs for certification, recertification, and annual RATAs also are presented as other direct costs and are not converted to equivalent source labor hours. This approach is consistent with the common business practice for obtaining outsi de contractors to conduct certification/recertification tests and annual relative accuracy test audits. For initial certification, the certification test costs are commonly bundled with equipment purchase contracts, according to information provided b y a range of CEMS equipment vendors. For RATAs that are conducted either as part of the annual quality assurance requirements or as part of recertification, industry contacts have indicated that RATA testing is usually performed under a fixed price contract b asis, except for travel costs that may be billed on an hourly

basis beyond the basic contract cost. For annual RATAs, the sources indicated that an annual contract between a testing company and utility

is often used. One municipal utility representative indicated that the applicable municipal regulations required that outside contracts be on a flat fee, not hourly , basis. (ii) Capital/Start

- up vs. Operating and Maintenance (O & M) Costs Capital costs reflect one

- time costs for purchase of equipment which will be used over a period of ye ars. Conversely , operating and maintenance costs are those costs which are incurred on an annual or other scheduled basis. For instance, costs associated with quality assurance activities, such as spare parts or contractor costs for work, will be incurred on an annual basis. (iii) Annualizing Capital Costs The relevant capital costs for the emissions trading portion of this I CR were annualized at a rate of seven percent (i.e., the annualized capital cost was calculated assuming money to purchase the capital equipment was borrowed at a seven percent annual interest rate). The cost of the loan was amortized over the life of the loan to repay original borrowed amount plus interest. The result is the annualized capit al cost reported.) The annualized cost of the necessary capital purchases varies from $2,250 to $ 28,879, per year, per unit, depending on the type of monitoring methodology . The capital costs are from the Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule) , EPA ICR #2152.02. (iv) Fuel Sampling To calculate heat input where the source is using the fuel flowmeter option for an oil or gas - fired unit, the source must obtain gross calorific value (GCV) data from sampling in accordance with Appendix D of Part 75. For purposes of this I CR, it is assumed that the GCV data would be collected as part of standard business operating procedures to assure compliance with contractual specifications. Thus no additional fuel sampling burdens or costs should be incurred. This is consistent with the Rule to Reduce Interstat e Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule) , EPA I CR #2152.0 4

. **Estimating the Respondent Universe and Total Burden and Costs for**  **Affected NBP Units**  EPA estimates that there are 122 affected units that will continue to con duct monitoring in accordance with Part 75 solely under the NO x SIP Call

. Table 6

- 4 shows the total burden and total cost for this respondent universe.13

**Estimating Agency Burden and Cost** The tasks that will be performed b y EPA include processing, reviewing, and evaluating emissions data reports submitted by the affected units , and conducting appropriate audit activities to verify

the information provided. Assuming that the affected units will submit an average of 1 06 emission reports to EPA per quarter, the total annual burden incurred by the Agency will be 848 hours. ( The annual total of 424 emissions reports is based on 90 quarterl y reporting and an addition al 32 Ozone Season only reporting facility

counts. ) The total annual cost to EPA for processing, reviewing, and evaluating these quarterl y emissions reports will be approximately $ 42,502

. Table 6

- 5 summarizes the Agency burden and costs associated with emis sions reporting.14 **TABLE 6**
**- 4**  **: ANNUAL RESPONDENT BURDEN/COST ESTIMATES FOR**  **AFFECTED UNITS** 
**Information Collection Activity**  **Mgr.**

**$ 99.75**  **/ Hour**  **Tech. $**  **69.03 /**  **Hour Respondent**  **Hours/ Year**  **Labor Cost/Year**  **Cont./**

**O&M Cost**  **Capital/ Startup**  **Cost Number**  **of Respondents**  **Total**

**Hours/ Year**  **Total**

**Cost/Year** 1. Review Instructions and Requirements 4 4 8 $ 6 75 $0 $0 53 424 $ 35,775 2. Respond to EPA Generated Error Messages, Field Audits 6 18 24 $ 1,841 $0 $0 122 2,928 $ 224,602 3. DAHS Debugging 4 12 16 $ 1,227 $0 $0 122 1,952 $ 149,694 4. New Unit Monitoring Plans 10 10 20 $1, 688 $0 $0 12 240 $ 20,256 5. Recertify Monitors 38 12 50 $4, 61 9 $3,400 $0 12 600 $ 96,228 6. Startup/Capital Items and Perform QA Testing and Maintenance (a) NO x and Flow

CEMS 50 480 530 $ 38,122 $31,200 $28,879 0 0 $0 (b) NO x CEM and Fuelmeter 20 375 395 $ 27,881 $17,400 $18,750 101 39,895 6,467,131 (c) App. E and Fuelmeter 5 30 35 $2, 570 $1,800 $2,250 21 735 $ 139,020 7. Assure Data Quality, Prepare Reports (inc. mo nitor plan update), Submit Reports a 20 82 102 $7, 655 $0 $0 122 10,812 $ 933,910 TO TAL: 57,586 $ 8,0 66 , 616

a Based on an assumption of 90 annual reporting and 32 Ozone Season only reporting facilities

.15 **TABLE 6**
**- 5**  **: ANNUAL AGENCY BURDEN/COST ESTIMATES** 

**FOR AFFECTED**  **UNITS**

**Tasks Quarterly Burden** 

**Hours p**  **er Report**  **Quarterly Cost p er**  **Report a**  **Number of**

**Reports b**  **Total Burden p**  **er Year**

**(hours) (2010** 

**– 2012)**  **Total Cost** Process, review, and evaluate quarterly report and issue feedback letter

. 2 $ 10 0 .24 424 848 $ 42,502
a Based on an average total compensation rate of **$ 5**  **0 .12**  per hour

. b Based on an assumption of 90 annual reporting and 32 Ozone Season only reporting facilities

. **6(d) Summary of Burden Hours and Costs** Table 6

- 6 summarizes the annual aggregate burden and cost estimates to both the respondents and the agency for the period of 2013 through 2015

. **TABLE 6**
**- 6**  **: AGGREGATE ANNUAL RESPONDENT AND AGENCY**  **BURDEN AND**

**COST OF COLLECTIONS ( 201**  **3**

**– 201**  **5 )** 

**Program Total Annual**  **Burden (Hours)**  **Total Annual Costs a**  Annual Industry Respondent Burden 57,586 $ 8, 066,616 Annual Agency Burden 848 $ 43,350 TOTAL 58,434 $ 8, 109,966
a 200 9 dollars. **6( d**  **) Reasons for Change in Burden**  Hourly burden estimates in this I CR renewal are the same as those in the previous I CR. Industry and government wage rates are higher based on the Employee Cost Index and G eneral Schedule

. Total annual costs for industry respondents are higher than those in the previous I CR due to corrections to the previous I CR cost summation. **6( e**  **) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 136 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existin g ways to compl y with any previously

applicable instructions and16

requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR par t 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OAR

- 2006

- 0947 , which is available for online viewing at www.regulations.gov, or in person viewing at the Air and Radiation docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephon e number for the Air and Radiation docket is (202) 566

- 1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public d ocket, and to access those documents in the public docket that are available electronicall y. When in the sy stem, select "search," then key in the Docket ID Number identified above. Also, yo u can send comments to the Office of Information and Regulatory A ffairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OAR

- 2006

- 0947 and OMB Control Number 2060

- 0445 any correspondence.