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Supporting Statement

Implementation of Ambient Air Protocol Gas Verification Program

EPA ICR # 2375.01

PART A

1. Identification of the Information Collection

 (a) Title of the Information Collection

Implementation of Ambient Air Protocol Gas Verification Program, EPA ICR number 

2375.01, OMB Control Number 2060-NEW

(b) Short Characterization/Abstract

This Information Collection Request (ICR) includes ambient air monitoring data 

reporting and recordkeeping activities associated with the 40 CFR part 58, appendix A, Quality

Assurance Requirements for SLAMS, SPMs and PSD Air Monitoring. These data and 

information are collected by State, local, and Tribal air quality management agencies and 

reported to the U.S. Environmental Protection Agency (EPA). 

The EPA Ambient Air Quality Monitoring Program’s QA requirements 40 CFR part 58, 

appendix A require:

2.6 Gaseous and Flow Rate Audit Standards. Gaseous pollutant concentration 

standards (permeation devices or cylinders of compressed gas) used to obtain test 

concentrations for CO, SO2, NO, and NO2 must be traceable to either a National 

Institute of Standards and Technology (NIST) Traceable Reference Material (NTRM), 

NIST Standard Reference Materials (SRM) and Netherlands Measurement Institute 

(NMi) Primary Reference Materials (valid as covered by Joint Declaration of 

Equivalence) or a NIST-certified Gas Manufacturer's Internal Standard (GMIS), 

certified in accordance with one of the procedures given in reference 4 of this appendix. 

Vendors advertising certification with the procedures provided in reference 4 of this 

appendix and distributing gases as “EPA Protocol Gas” must participate in the EPA 

Protocol Gas Verification Program or not use “EPA” in any form of advertising.

These requirements give assurance to end users that all specialty gas producers selling EPA 

Protocol Gases are participants in a program that provides an independent assessment of the 

accuracy of their gases' certified concentrations. In 2010 EPA will develop an Ambient Air 

Protocol Gas Verification Program (AA-PGVP) that will provide end users with information 

about participating producers and verification results.

This program is considered a verification program because its current implementation level does 

not allow for a large enough sample of EPA Protocol Gases from any one specialty gas producer 

to be measured to yield a statistically rigorous assessment of the accuracy. It will not provide 
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end users with a scientifically defensible estimate of whether gases of acceptable quality can be 

purchased from a specific producer. Rather, the results provide information to end users that 

may inform their purchasing decisions. The final verification results will be reported with an 

explanation on how the results should be interpreted.

Each year, EPA will attempt to compare gas cylinders from every specialty gas producer being 

used by ambient air monitoring organizations. EPA Regions 7 and 2 have agreed to provide 

analytical services to provide verifications of 40 cylinders/lab or 80 cylinders total/year. 

Cylinders will be verified at a pre-determined time each quarter.

The selection goal in the following order would be:

1) Minimum one gas standard from every specialty gas vendor being used by the monitoring 

community

2) Selection of a minimum of 3 standards per specialty gas vendor

3) Weight additional standards by vendor market share in ambient air monitoring 

community. 

In order to make the appropriate selection, EPA needs to know what specialty gas producers 

are being used by the monitoring organizations. Therefore EPA needs to collect information 

from each primary quality assurance organization every year on specialty gas producers being 

used and whether the monitoring organization would like to participate in the verification for the 

upcoming calendar year.

The burden estimates are for the 3-year period of 2011 through 2013. This ICR burden 

estimates are associated with the current monitoring portion of ICR #0940.22 (2060-0084).

This 3-year information collection is estimated to involve approximately 211 respondents 

for a total cost of approximately $13,750 (labor) which equates to 211 hours. The estimate is 

only labor hours since EPA is asking the State, local, and Tribal air quality management agencies

to complete an annual form that should take approximately 20 minutes to complete. In addition 

to the costs at the State, local, and Tribal air quality management agencies, there is a burden to 

EPA a total of 120 hours which equates to approximately $17,309. 

2. Need for and Use of the Collection

(a) Need/Authority for the Collection

The information requirements included within this ICR are necessary to provide the EPA 

with ambient air quality surveillance data in order to meet the code of federal regulation 

requirements to implement an Ambient Air Protocol Gas Verification Program. This program is 

integral to ensure the quality of the data that is used to determine the United States' air quality

status, to make attainment decisions with respect to the NAAQS, to assist in developing 

necessary control strategies to ensure attainment of the NAAQS, to assess national trends in air 

pollution, to inform the public of air quality, and to determine the population's exposure to 

various ambient air pollutants. The EPA's goal of attaining the NAAQS in all areas of the 
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United States is directly dependent upon the availability of quality ambient air data and the use 

of protocol gas calibration standards helps ensure this quality. 

The principal legal authority for this information collection is the Clean Air Act 42 

U.S.C.A. §§ 7403, 7410, and 7511a, from which the 40 CFR part 58, appendix A QA regulations 

were promulgated.

Under § 7403 (c), the Administrator is required to conduct a program of research, testing, 

and development of methods for sampling, measurement, monitoring, analysis, and modeling of 

air pollutants, specifically including a requirement to establish a national network to monitor, 

collect, and compile data with quantification of certainty in the status and trends of air emissions 

and air quality. The Ambient Air Protocol Gas Verification Program reduce the uncertainty of 

data collected under § 7403 (c),

2(b) Practical Utility/Users of the Data

The EPA Office of Air Quality Planning and Standards (OAQPS) uses the data included 

within this collection to determine what specialty gas producers are selling calibration standards 

to monitoring organizations implementing ambient air monitoring under 40 CFR part 58 that are 

subject to use of protocol gasses. In addition, the information is used to determine the 

monitoring organizations willing to participate in the program by submitting the purchased 

gasses to EPA for verification testing. 

Results for the verification data can provide monitoring organizations with information 

on specialty gas producers that are participating in the Protocol Gas Verification Program and the 

results might also help monitoring organizations with their protocol gas purchasing decisions.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-duplication

This collection is not unnecessarily duplicative of information otherwise reasonably

accessible to the agency. There is currently no nationwide database that would allow EPA to 

gather information of this detail. 

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

The 1995 Paperwork Reduction Act requires that any agency developing a non-rule 

related ICR must solicit public comments for a 60-day period prior to submitting the ICR to 

OMB. EPA published a Federal Register notice soliciting public comment on March 2, 2010 

(75 FR 9407). No comments were received.

3(c) Consultations
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Through the course of planning, monitoring, and improving upon this collection and its 

associated regulation, the EPA regularly consults with affected State, local, and Tribal air quality

management agencies through various methods including the regulatory process, regular 

meetings, and training courses. The EPA has developed an advisory group for this program

made up of OAQPS, EPA Regions and representatives from the State, local, and Tribal air 

quality management agencies to assist in the development of this information collection. This 

Advisory Group meets quarterly to discuss pertinent issues associated with the AA-PGVP. The 

EPA Regional Offices conduct annual ambient air monitoring meetings with their affected State, 

local, and Tribal air quality management agencies to assist these affected agencies with this 

collection and its associated regulation. The EPA’s OAQPS also meets regularly with leading 

State and local air monitoring managers to discuss the Nation’s ambient air monitoring program 

and this collection, via large monthly phone calls and smaller in person meeting two or three 

times per year. 

3(d) Effects of Less Frequent Collection

State, local, and Tribal air quality management agencies would collect and report ambient 

air quality data without the 40 CFR 58 regulation associated with this collection. Sanctions do 

not automatically accrue to State or local air quality management agencies that fail to meet these 

requirements. The 40 CFR part 58 regulations and this associated collection do provide for a 

consistent system for reporting and record keeping that would not exist without these 

requirements. The effects of less frequent collection include:

• A national database that is not consistently updated and available for public 

consumption;

• EPA would not be able to ensure new specialty gas vendors were participating in the 

program and were selling gasses of acceptable quality.

3(e) General Guidelines

All of the OMB's general guidelines for information collections in 5 CFR 1320.6 are met 

by this ICR. None of the guidelines are exceeded.

• Data reporting on a annual basis is the requirement. 

• Record retention is for no more than 3 years (most records are kept by the EPA data 

repository, not the affected State, local, and Tribal air quality management agencies)

• Information is maintained and reported in the standardized electronic format.

3(f) Confidentiality
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Information that is considered personal, private, proprietary, or confidential is not 

required for this collection. 

3(g) Sensitive Questions

This section is not applicable to this ICR because no information involving matters of a 

sensitive nature is collected.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes

This ICR affects State, local, and Tribal governments (SIC code 951, Administration of 

Environmental Quality Program) that are currently operating and maintaining established 

ambient air quality networks. The 40 CFR part 58 regulations associated with this request 

require that State, local, and Tribal air quality management agencies conducting the ambient air 

quality surveillance under this regulation to use protocol gases from specialty gas producers 

participating in the AA-PGVP. 

4(b) Information Requested

(i) Data items, including record keeping requirements

These data items are submitted electronically to EPA and are stored electronically within 

the EPA's AA-PGVP data base. 

• Primary quality assurance organization (PQAO) name and code and Reporting 

Agency name and code. Both the name and codes can be found in the EPA Air 

Quality System (AQS) Database.

• Monitoring organization protocol gas point of contact and email address

• Specialty gas producer(s) used, their address and the gas concentrations normally

purchased

• Information on when monitoring organizations might purchase protocol gas in the 

upcoming calendar year, whether they would like to participate in the verification 

activity and whether they have had DOT hazardous materials shipping training.

(ii) Respondent Activities

A model respondent would engage in the following activities to comply with this 

information request:
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• Read the one page instructions on how to fill out the form. 

• Complete the one page Microsoft Excel form each year within the specified time 

period and submit it to OAQPS AA-PGVP Lead.

The influence of the 40 CFR part 58 regulations has been to provide a nationally

consistent mechanism for collecting ambient air quality data including uniform quality assurance 

procedures such as the use of protocol gasses. 

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

The EPA conducts the following activities to implement this ICR and associated 

regulation:

• Periodically review the 40 CFR part 58 regulations to update the information 

collection and monitoring requirements in light of new technological developments 

or new air pollutant standards. Develop revisions to the regulations in response to 

legislative action and program changes.

• Establish, maintain, and support the AA-PGVP data base as the national repositories 

for all State, local, and Tribal air quality management agency ambient air protocol 

gas information. Periodically evaluate and improve upon this system as new 

technologies, and new regulatory requirements would dictate.

• Answer respondent (generally State, local, and Tribal air quality management 

agencies, but also industrial organizations, environmental groups, and others) 

questions about ambient air monitoring, the 40 CFR part 58 protocol gas regulatory

requirements. 

• Support the AA-PGVP by ensuring that the EPA Region 2 and 7 laboratories are able 

to conduct verifications of specialty gas standards each year. 

• Provide annual assessment reports of the protocol gas verifications for posting on the 

AMTIC website or public dissemination.

5(b) Collection Methodology and Management

The EPA has provided and will continue to provide resources for the maintenance and 

operation of the protocol gas database. All data required by this collection are submitted 

electronically to reduce the burden of the collection and to improve data quality, agency

efficiency, and responsiveness to the public. In submitting the information to EPA, we ensure 

that the data are publicly available, electronically stored, and electronically retrievable. 
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5(c) Small Entity Flexibility --

This collection contains a minimum amount of information in order to implement the 

AA-PGVP. The AA-PGVP form is not anticipated to take more than 10 minutes for any entity, 

regardless of size, to complete. The smallest entities affected by this collection are local air 

quality management agencies, typically consisting of the governing agencies for a county or 

group of counties, or a smaller metropolitan area (e.g., cities with a population of 100,000). 

This collection reduces to the extent practicable and appropriate the burden on entities that 

provide ambient air quality data and information to or for the EPA, including with respect to 

small entities, as defined in the Regulatory Flexibility Act (5 U.S.C. 601(6))

5(d) Collection ScheduleThe information will be reported annually from September through November and the 

results will reflect the following calendar year. 

Ambient air quality data and information are made available to the public at any time in 

various ways, including:

• Upon request to the appropriate EPA Regional office, or to the OAQPS;

• By Freedom of Information Act Request to the appropriate EPA Regional Office or 

the OAQPS;

• From the State or local air quality management agency responsible for collecting the 

ambient air quality data and information; 

• By obtaining access, through appropriate EPA channels. 

• Through EPA public reports, such as the annual National Air Quality and Emissions 

Trends Report, or

• through report specifically generated for this program.

Due to the nature of the program, information related to what specialty gas cylinders 

were use from individual monitoring organizations will not be published until the cylinder has 

been analyzed and data validated. In this manner specialty gas vendors will not be aware ahead 

of time that a specific cylinder is being used for the verification.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are presented 

in Worksheet 1. The detailed burden and cost estimates for the different types of monitors are 

based on information provided in the updated version of Guidance for Estimating Ambient Air 
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Monitoring Costs for Criteria Pollutants and Selected Air Toxic Pollutants (prepared by Desert 

Research Institute for the EPA Office of Air Quality Planning and Standards, Air Quality

Assessment Division, Ambient Air Monitoring Group, January 2005). The cost estimates 

presented in this guidance document are based on existing literature and direct monitoring 

experience. The costs for equipment and supplies were verified with vendors. The monitoring 

costs are based on vendor quotes for the monitor type that EPA expects respondents to use to 

comply with the requirements. Costs for level of effort estimates are verified with selected State 

and local agencies. All cost values presented in the guidance document are adjusted to 2004 

dollars, based on the average of the first two quarters. 

For use in preparing the burden estimates for this ICR, costs for the monitoring 

requirements were inflated to 2011, 2012, and 2013. The cost escalation factors were estimated 

based on the appropriate Gross Domestic Product (GDP) price indices as reported in the report 

available at http://www.jsc.nasa.gov/bu2/inflateGDP.html . Tables showing the detailed burden 

estimate calculations are presented below. A summary of the average annual respondent burden 

costs follows.

Worksheet 1: Annual Average Respondent Burden Estimates

Collection

Activities

Total Labor Minutes

Per Respondent Per Year

(211 respondents)

1. Read instructions 5

2. Complete Form 15

TOTAL 20 minutes

6(b) Estimating Respondent Costs

All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are included 

in the Worksheet 2. A summary of the average annual respondent burden costs follows.

Worksheet 2: Annual Average Respondent Cost Estimates

Collection

Activities

Total Labor Cost 

Per Respondent Per Year 

(211 respondents)

1. Read instructions $5.43

2. Complete Form $16.28

TOTAL $21.71

Costs in Worksheet 2 were averaged over the 3-year period (2011-2013) 
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6(c) Estimating Agency Burden and Cost 

We estimated the Agency burden and cost by using current burden and cost of the 

ambient air monitoring program related to this collection. We included burden and cost for the 

OAQPS, and the ten Regional Offices. The in-house activities for this collection are completed 

by a variety of individuals with a variety of salaries; therefore, we used EPA payroll averages 

(one estimate for EPA Regions and one estimate for OAQPS) as an average for computing the 

program costs. We estimated a total of 40 hours ($5,770) total agency annual burden.

6(d) Estimating the Respondent Universe and Total Burden and Costs

Worksheet 3 shows the total respondent hourly burdens and costs which was taken from 

section 6(b) above for the estimated 211 respondents. The total labor burden for the respondents 

was estimated to be 70.3 hours ($4,582).

Worksheet 3: Annual Total Respondent Labor Burden/Cost Estimates

Collection

Activities

Total Labor Hours

Per Year

Total Labor Cost

Per Year

1. Read Instructions 17.6 $1145

2. Complete Form 52.7 $3437

TOTAL 70.3 $4582

6(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

Respondent Total Annual Burden = 70 hours

Respondent Total Annual Labor Cost = $4582

(ii) The Agency Tally

Agency Total Annual Burden = 40 hours

Agency Total Annual Cost = $5770

(iii) Variations in The Annual Bottom Line.

We do not expect any significant variations in the annual bottom line for the ambient air 

monitoring networks for the clearance period requested.

6(f) Reasons for Change in Burden
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EPA is proposing to require monitoring organization to submit information to EPA on a 

annual basis on the specialty gas vendors they use in order to ensure specialty gas producer 

participation in the Ambient Air Protocol Gas Verification Program. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 20 minutes per response. 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 Federal agency. This includes the time needed to review instructions; develop, 

acquire and verifying information, processing and maintaining information, and disclosing and 

providing information; complete and review the collection of information; and transmit or 

otherwise disclose the information. An agency may not conduct or sponsor, and a person is not 

required to respond to, a collection of information unless it displays a currently valid OMB 

control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 

and 48 CFR chapter 15. 

To allow 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 established a public docket for this 

ICR under Docket ID No. EPA-HQ-OAR-2010-0050 which has been available for public 

viewing at the Air and Radiation Docket and Information Center Docket in the EPA Docket 

Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the Air and Radiation Docket and Information Center 

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 docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in the 

Docket 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, 

D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number 

EPA-HQ-OAR-2010-0050 and OMB Control Number 2060-NEW in any correspondence.

PART B OF SUPPORTING STATEMENT

This section is not applicable to this ICR because statistical methods are not used in the 

data collection.