INFORMATION COLLECTION REQUEST

FOR THE COMPLIANCE ASSURANCE

MONITORING PROGRAM (40 CFR PART 64)

EPA ICR No. 1663.08

OMB Control No. 2060-0376

Prepared by:

United States Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

Measurement Policy Group

Research Triangle Park, NC 27711
Contents

1. IDENTIFICATION OF THE INFORMATION COLLECTION............................................. 1

1(a) TITLE OF THE INFORMATION COLLECTION ..................................................... 1

1(b) SHORT CHARACTERIZATION/ABSTRACT.......................................................... 1

2. NEED FOR AND USE OF THE COLLECTION.................................................................... 3

2(a) NEED/AUTHORITY FOR THE COLLECTION........................................................ 3

2(b) PRACTICAL UTILITY/USERS OF THE DATA....................................................... 5

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA ..... 5

3(a) NONDUPLICATION................................................................................................... 5

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB............... 6

3(c) CONSULTATIONS ..................................................................................................... 6

3(d) EFFECTS OF LESS FREQUENT COLLECTION ..................................................... 6

3(e) GENERAL GUIDELINES ........................................................................................... 6

3(f) CONFIDENTIALITY................................................................................................... 7

3(g) SENSITIVE QUESTIONS ........................................................................................... 8

4. THE RESPONDENTS AND THE INFORMATION REQUESTED...................................... 8

4(a) RESPONDENTS/SIC CODES..................................................................................... 8

4(b) INFORMATION REQUESTED .................................................................................. 8

4(b)(i) DATA ITEMS, INCLUDING RECORDKEEPING REQUIREMENTS .. 8

4(b)(ii) RESPONDENT ACTIVITIES.................................................................. 11

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT............................................ 13

5(a) AGENCY ACTIVITIES............................................................................................. 13

5(b) COLLECTION METHODOLOGY AND MANAGEMENT.................................... 13

5(c) SMALL ENTITY FLEXIBILITY .............................................................................. 13

5(d) COLLECTION SCHEDULE...................................................................................... 13

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION................................ 14

6(a) ESTIMATING RESPONDENT BURDEN................................................................ 14

6(b) ESTIMATING RESPONDENT COSTS.................................................................... 16

6(b)(i) Estimating Labor Costs............................................................................. 16

6(b)(ii) Estimating Capital and Operations and Maintenance Costs..................... 16

6(b)(iii) Capital/Start-up vs. O&M Costs............................................................... 17

6(b)(iv) Annualizing Capital Costs ........................................................................ 17

6(c) ESTIMATING AGENCY BURDEN AND COST.................................................... 17

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

COSTS........................................................................................................................ 17

6(e) BOTTOM LINE BURDEN HOURS AND COST TABLES .................................... 20
6(e)(i) Respondent Tally ...................................................................................... 20

6(e)(ii) The Agency Tally ..................................................................................... 20

6(e)(iii) Variations in the Annual Bottom Line...................................................... 21

6(f) REASONS FOR CHANGE IN BURDEN ................................................................. 21

6(g) BURDEN STATEMENT ........................................................................................... 21
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE OF THE INFORMATION COLLECTION

This document fulfills the agency's requirements under the Paperwork Reduction Act

with regards to determining the regulatory burden associated with the Compliance Assurance 

Monitoring (CAM) Rule, codified at 40 CFR part 64. It has been assigned EPA tracking number 

1663.08 and OMB Control Number 2060-0376. The title of this Information Collection Request 

(ICR) is “Compliance Assurance Monitoring Program (40 CFR Part 64).”

1(b) SHORT CHARACTERIZATION/ABSTRACT

In keeping with the requirements of the title V operating permit program (codified at 

40 CFR parts 70 and 71), the CAM Rule requires monitoring, compliance certification, periodic 

reporting and recordkeeping information collections by owners and operators of title V sources1

with controlled pollutant-specific emissions units (PSEUs) that have a pre-control potential to 

emit major amounts of regulated air pollutants. In addition, where the permitting authority has 

determined that the source has not used acceptable procedures in response to an excursion or 

exceedance, the CAM Rule allows permitting authorities (PAs) to require sources to prepare and 

implement Quality Improvement Plans (QIPs) and keep records of, and submit reports on,

corrective actions taken under QIPs. 

The CAM Rule identifies two categories of emissions units: 

(1) “Large” PSEUs: units that have the potential to emit, with controls, the 

applicable regulated air pollutant in an amount equal to or greater than the amount 

required for a source to be classified as a major source, and 

(2) “Other” PSEUs: the set of remaining affected PSEUs.

These two types of units are subject to different monitoring frequency requirements, but 

not to different reporting or recordkeeping requirements, which are the subject of this ICR. 

Additionally, “large” and “other” units were initially subject to different implementation 

timetables under part 64. However, this program has been in place long enough that all existing 

“large” and “other” PSEUs that became subject to the CAM Rule at the time of its promulgation 

have been integrated into the program as their title V permits have been renewed. New PSEUs of 

both types are covered under the CAM program in the same manner; both types of units become 

subject to the CAM program at the time that a new title V permit is issued for a new facility or 

an existing permit is revised to add the new unit(s). For these reasons, this analysis does not 

differentiate between “large” and “other” units.

Upon approval by the PA of the monitoring proposed by the source, the source uses the 

approved monitoring method to collect data. These data provide the basis on which owners or 

operators can certify, in accordance with the requirements of the title V operating permit 

 

1

For purposes of simplicity, this ICR applies the terms “owners and operators,” “firm,” and “sources” 

interchangeably. References to actions or responsibilities of sources or firms should be interpreted as referring to 

the owners and operators of that source or firm.
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program, the compliance of their emissions units with the applicable requirements. In addition, 

these data provide the basis on which owners or operators submit monitoring reports on no less 

than a semi-annual basis, as required by the title V operating permit program. Consistent with the 

recordkeeping period established in the title V operating permit program, CAM requires sources 

to store and maintain these data for at least 5 years. 

In the next 3 years, the information collection requirements of the CAM program will 

impact all new affected pollutant points (i.e., new PSEUs at new facilities and new PSEUs 

constructed at existing facilities) and any new and existing affected pollutant points for which 

QIPs must be developed. The EPA estimates that the CAM program currently applies to

approximately 23,000 existing emissions units. This ICR estimates the expected average annual 

burden over the next 3 years to be about 50,000 hours, at an expected cost of $2 million (2012

dollars). The activities at sources leading to these impacts include:

Determination of a monitoring approach for new affected PSEUs;

Preparation of a QIP, if necessary;

Administrative burden for recordkeeping and reporting of corrective actions 

associated with a QIP;

Installation and operation of monitoring equipment, if necessary;

Administrative burden for recordkeeping and reporting;

Upgraded operating/maintenance activities;

Improved quality assurance; and

Permit fees to cover regulatory costs of the program.

For this ICR, we have used data from the 2012 ICR for the title V operating permit 

program implemented by state agencies (i.e., the part 70 program) that reflect current 

information on the number of existing and new title V permits that may include units that are 

subject to the CAM Rule.

In addition, we reviewed and updated, where necessary:

Labor rates; 

Estimates of labor hours needed for each activity associated with CAM monitoring 

(CAM approach development and review, QIP development and review, 

recordkeeping and reporting); and 

The implementation schedule for CAM using current title V data for both existing 

and new sources.

We make specific assumptions about permit approvals and renewals in order to project 

when sources would submit their proposed monitoring approaches. We make the following 

assumptions to develop an implementation schedule that is consistent with the part 64 language: 

All existing affected PSEUs submitted their proposed monitoring approaches during 

the July 2007 through January 2012 time period addressed by the previous two ICRs.

Approximately 20 percent of existing title V permits are renewed during each year. 

Each year, title V permits will be issued for 100 new facilities. These facilities will 

have the same average number of PSEUs as in the full CAM database.
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There is homogeneity between sources and PSEUs. Therefore, if 10 percent of all 

title V permits are renewed at a given time, 10 percent of all affected PSEUs will be 

subject to renewal of their CAM plans on that date.

The recordkeeping and reporting requirements for the CAM Rule for existing PSEUs 

are met by the requirements set forth in title V, unless a QIP is required. Therefore, in 

this ICR we are only attributing the recordkeeping and reporting requirements for 

those existing sources that are required to conduct a QIP. 

Additionally, we assume that some new PSEUs would be built each year at existing permitted 

facilities, thus requiring a permit revision. We assume that 230 facilities nationwide would build 

additional PSEUs each year. 

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED/AUTHORITY FOR THE COLLECTION

EPA decisions in both the operating permit and CAM programs require this information. 

The operating permit program requires owners or operators of units that emit air pollutants to 

submit annual compliance certifications, to submit monitoring results at least semi-annually and 

to report deviations promptly, but no implementation guidance is provided within the operating 

permit program. The CAM program provides the vehicle to implement operating permits 

program requirements in a cost-effective manner. 

The Clean Air Act (Act) Amendments of 1990, Public Law 101-549, enacted on 

November 15, 1990, establish the legal authority for this information collection. Section 502(b) 

directs EPA to promulgate regulations that will require the owners or operators of certain 

stationary sources of air pollution to conduct monitoring and to make compliance certifications. 

These provisions are set forth in both title V (operating permits provisions) and title VII 

(enforcement provisions) of the 1990 Amendments.

Title V directs the agency to implement monitoring and compliance certification 

requirements through the operating permits program. Section 503(b)(2) requires at least annual 

certifications of compliance with permit requirements and prompt reporting of deviations from 

permit requirements. Section 504(a) mandates that owners or operators submit to the PA the 

results of any required monitoring at least every 6 months. This section also requires permits to 

include “such other conditions as are necessary to assure compliance with applicable 

requirements” of the Act. Section 504(b) of the Act also allows the agency to prescribe, by rule, 

methods and procedures for determining compliance, and states that continuous emission 

monitoring systems need not be required if other methods or procedures provide sufficiently 

reliable and timely information for determining compliance. Under section 504(c), each 

operating permit must “set forth inspection, entry, monitoring, compliance certification, and 

reporting requirements to assure compliance with the permit terms and conditions.”

Title VII of the 1990 Amendments added 114(a)(3) – a new section that requires EPA to 

promulgate rules on enhanced monitoring and compliance certifications. This paragraph 

provided, in part:

“The Administrator shall in the case of any person which is the owner or operator 

of a major stationary source, and may, in the case of any other person, require 
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enhanced monitoring and submission of compliance certifications. Compliance 

certifications shall include (A) identification of the applicable requirement that is 

the basis of the certification, (B) the method used for determining the compliance 

status of the source, (C) the compliance status, (D) whether compliance is 

continuous or intermittent, (E) such other facts as the Administrator may require.”

The 1990 Amendments also revised section 114(a)(1) of the Act to provide additional 

authority concerning monitoring, reporting and recordkeeping requirements. As amended, that 

section provides the Administrator with the authority to require any owner or operator of a 

source, on a one-time, periodic, or continuous basis to:

Establish and maintain such records;

Make such reports;

Install, use, and maintain such monitoring equipment;

Sample such emissions (in accordance with such procedures or methods, at such 

locations, at such intervals, during such periods and in such manner as the 

Administrator shall prescribe);

Keep records on control equipment parameters, production variables, or other indirect 

data when direct monitoring of emissions is impractical;

Submit compliance certifications in accordance with section 114(a)(3); and

Provide such other information as the Administrator may reasonably require.

Obtaining ongoing compliance is a two-step process. First, the agency must assure 

properly designed control measures are installed or otherwise employed. These measures include 

control devices, process modifications, operating limitations and other control measures as 

applicable. Furthermore, the agency must assure the control measures are proven to be capable of 

achieving applicable requirements. In the past, this step has been addressed through new source 

review permitting, initial stack testing, compliance inspections and similar mechanisms. The title 

V permit application and review process, including the applicant’s initial compliance 

certification and compliance plan obligations, add another tool for assuring that source owners or 

operators have adopted proper control measures for achieving compliance.

The second step involves monitoring by sources to determine continued assurance that 

the source’s control measures, once installed or otherwise employed, are properly operated and 

maintained so that they do not deteriorate to the point where the owner or operator fails to 

remain in compliance with applicable requirements. The agency believes that monitoring, 

reporting, recordkeeping and ongoing or recurring compliance certification requirements under 

titles V and VII should be designed so that owners or operators carry out this second step in 

assuring ongoing compliance. The agency has adopted the CAM approach to assure the proper 

operation and maintenance of control measures employed by sources. The CAM Rule establishes 

monitoring to: 

Document continued operation of the control measures within ranges of specified 

indicators of performance (such as emissions, control device parameters and process 

parameters) that are designed to provide a reasonable assurance of compliance with 

applicable requirements;
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Indicate any excursions from these ranges; and

Respond to the data so that excursions are corrected. 

This type of monitoring is an appropriate approach to enhanced monitoring in the context 

of title V permitting for significant emission units that use control devices to achieve compliance 

with emission limits. In particular, the CAM Rule:

Provides cost-effective achievement of air pollution emission reductions;

Establishes voluntary compliance and self-certification by owners or operators; and

Holds owners or operators accountable for regulated air pollutants emitted by units.

2(b) PRACTICAL UTILITY/USERS OF THE DATA

Owners or operators of affected emissions units will use the information as the basis for 

the compliance certification required by the operating permit program, and as the basis for 

compliance assurance monitoring reports. Sources will also use the information to determine and 

maintain the efficiency of the process or emissions control devices.

The PAs will use the information collected and submitted in permit applications in 

determining acceptability of proposed compliance assurance monitoring. The PAs will use 

source monitoring data to assess compliance, as input into reports to other agencies, and, when 

necessary, as evidence in enforcement proceedings. The PAs will use the information on 

excursions and exceedances collected from owners or operators to require the development and 

implementation by source operators of a QIP, when necessary. The QIP will address the 

timetable, methods and procedures for dealing with these excursions and exceedances.

The PAs will also collect summaries of information on compliance and will review the 

information as part of their permitting responsibilities and ongoing compliance activities. The 

information may be entered into local, regional or national databases for review and action by air 

pollution control agencies. Other federal entities, such as the Department of Energy, may request 

and use the information collected to fulfill specific mission objectives. Citizens may request the 

information collected in order to determine the compliance status of any emissions unit or 

particular group of emissions units.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER 

COLLECTION CRITERIA

3(a) NONDUPLICATION

For approval of a proposed ICR, the agency must ensure that it has taken every 

reasonable step to avoid duplication in its paperwork requirements in accordance with 5 CFR 

1320.4. The part 64 rulemaking is mandated by the Act and supports the title V permit program 

under 40 CFR part 70 as well as title VII enforcement provisions. Recognizing that many sources 

have already implemented monitoring strategies to fulfill their part 70 requirements, the part 64 

monitoring guidelines were carefully crafted by the agency and OMB to minimize any 

unnecessary duplication. The part 64 CAM Rule has also been carefully designed to function, as

much as possible, in a manner complementary to that of the part 70 operating permit program 

managed by PAs.
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3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

The EPA has complied with the public notice requirement set forth in 5 CFR 

1320.8(d)(1) by publishing a notice of proposed information collection in the Federal Register

on June 13, 2013 (78 FR 35631). This notice provided a 60-day public comment period. The 

EPA received one question. The question asked us to explain how we came to the reduction in 

the number of annual labor numbers. We prepared an explanation regarding reductions in burden 

and responded back to the inquirer and posted this document to the docket. A notice of proposed 

information collection will be published concurrently in the Federal Register with the 

submission of this information collection request, followed by a 30-day comment period.

3(c) CONSULTATIONS

In our first Federal Register notice the agency asked for comments on this current ICR. 

We have not received any comments on the burden that has been calculated. Additionally, in 

order to derive our burden estimates in the past, the agency discussed the CAM requirements

with stakeholders through a series of workshops and public meetings. The workgroups at these 

meetings discussed and reviewed CAM requirements and reviewed extensive public input 

concerning the development and implementation of CAM. For example, we conducted multiple

workshops with state and local agency staff in over a dozen states since promulgating the rule

and other monitoring related to the operating permits program. Those workshops focused on the 

implementation of the rule. Much of the information exchange was in our describing the 

regulatory requirements in 40 CFR part 64, other requirements that apply (e.g., part 70, operating 

permits), operating permits content and supporting documentation requirements, and case studies 

as technical examples. The participants shared experiences in implementing the regulatory 

requirements including the number of staff involved in permit reviews, level of effort, and 

burden. Information we received in conjunction with the workshops also include additional case 

study examples.

3(d) EFFECTS OF LESS FREQUENT COLLECTION

As part of the permit application required under the title V operating permit program, an 

owner or operator must submit to the PA monitoring that satisfies the design requirements in 

40 CFR 64.3. In addition, it must be demonstrated that the proposed monitoring is sufficient to 

provide compliance status information. Without such information, PAs will be unable to issue 

complete permits. Furthermore, owners or operators will be unable to certify compliance with 

emissions limitations or standards unless costly reference test methods are employed. Part 64 

requires semi-annual reports because the statute requires all monitoring reports to be submitted at 

least semi-annually (section 504(a)). In addition, without timely evaluation of the reports, excess 

emissions of regulated air pollutants could rise. Consequently, less frequent collection of 

monitoring information is not permissible under the statute and could result in a net loss of 

environmental quality and was not considered for this rulemaking.

3(e) GENERAL GUIDELINES

The OMB’s general guidelines for information collections must be adhered to by all 

federal agencies for approval of any rulemaking’s collection methodology. In accordance with 

the requirements of 5 CFR 1320.6, the agency believes:
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Part 64 regulations do not require periodic reporting more frequently than semiannually.

The part 64 regulations do not require respondents to participate in any statistical 

survey.

Responses to agency inquiries are not required to be submitted in less than 30 days.

Special consideration has been given in the design of part 64 to ensure that the 

requirements are, to the greatest extent possible, the same for federal requirements 

and those permitting authorities who already have monitoring programs in place.

Confidential, proprietary and trade secret information necessary for the completeness 

of the respondent’s permit are protected from disclosure under the requirements of 

section 503(e) and section 114(c) of the Act.

The part 64 regulations do not require more that one original and two copies of the 

permit application, update, or revision to be submitted to the agency.

Respondents do not receive remuneration for the preparation of reports required by 

the Act or part 64.

To the greatest extent possible, the agency has taken advantage of automated methods 

of reporting.

The agency believes the impact of part 64 on small entities to be insignificant and not 

disproportionate.

The recordkeeping and reporting requirements contained in the CAM program 

regulations do not exceed any of the Paperwork Reduction Act guidelines contained in 5 CFR 

1320.6, except for the guideline which limits retention of records by respondents to 3 years. The 

CAM program and the operating permit program require both respondents and state 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 federal claims in 

response to violations by regulated 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 

Clean Air Act.

3(f) CONFIDENTIALITY

Confidentiality regarding CAM program measurement information, as well as monitoring 

data, is not an issue for this rulemaking. In accordance with the Clean Air Act Amendments of 

1990, each permit issued under the title V operating permit program is to contain monitoring

requirements to assure compliance with permit terms and conditions; generally, these terms and 

conditions are submitted by sources as a part of their permit or renewal applications but they are 

all a matter of public record. To the extent that the information required is proprietary, 

confidential or of a nature that could impair the ability of the source to maintain its market 

position, that information is collected and handled subject to the requirements of sections 503(e) 

and 114(c) of the Act. Information received and identified by owners or operators as confidential 

business information (CBI) and approved as CBI by EPA, in accordance with Title 40, Chapter 

1, Part 2, Subpart B, shall be maintained appropriately (see 40 CFR 2; 41 FR 36902, September 

1, 1976; amended by 43 FR 39999, September 8, 1978; 43 FR 42251, September 28, 1978; 44 

FR 17674, March 23, 1979).
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3(g) SENSITIVE QUESTIONS

Sensitive questions (i.e., sexual, religious, personal or other private matters) are not 

applicable to this rulemaking. The information gathered for purposes of establishing an operating 

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

4. THE RESPONDENTS AND THE INFORMATION 

REQUESTED

4(a) RESPONDENTS/SIC CODES

The CAM Rule applies to most North American Industry Classification System (NAICS) 

code groups (and their predecessors, the Standard Industrial Classification (SIC) code groups), as 

well as certain service industries regulated under the Act. All PAs also are affected because they 

must review CAM plans, as well as any QIPs and associated reports.

4(b) INFORMATION REQUESTED

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

The following matrices display the types of data required by the part 64 CAM Rule, 

along with the location of the requirement in the rule. 

FIGURE 4-1

DATA REQUIRED BY THE INFORMATION COLLECTION

Additional Requirements for Permit Applications

Regulation 

Reference

For all major source pollutant-specific emission units that satisfy the applicability 

criteria outlined in 64.2, the owner or operator shall submit a proposed monitoring 

approach to the PA. The monitoring approach shall be submitted as part of the 

initial, revised, or renewed part 70 or 71 permit application.

64.5

Consistent with the design requirements in 64.3, the submission shall include the following 

information:

the indicators to be monitored to satisfy 64.3(a)(1)-(2). 64.4(a)(1)

either (i) the ranges or designated conditions for such indicators or (ii) the process 

by which such indicator ranges or designated conditions shall be established.

64.4(a)(2)

the performance criteria for the monitoring to satisfy 64.3(b). 64.4(a)(3)

if applicable, the indicator ranges and performance criteria for a CEMS, COMS, or 

PEMS pursuant to 64.3(d).

64.4(a)(4)

As part of the information submitted, the owner or operator shall submit:
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FIGURE 4-1

DATA REQUIRED BY THE INFORMATION COLLECTION

Additional Requirements for Permit Applications

Regulation 

Reference

a justification for the proposed elements of monitoring. The justification shall include 

any supporting data and may refer to any generally available sources of information 

such as air pollution engineering manuals or EPA or PA publications. In addition, 

the owner or operator may base the required justification exclusively on the 

regulatory precedents cited in 64.4(b)(1)-(5). If the performance specifications 

proposed to satisfy 64.3(b)(2) or (3) include differences from manufacturer 

recommendations, the owner or operator shall explain the reasons for the 

differences.

64.4(b)

control device (and process and capture system, if applicable) operating parameter 

data obtained during the conduct of applicable compliance or performance tests. 

Such data may be supplemented, if desired, by engineering assessments and 

manufacturer’s recommendations to justify the indicator ranges.

64.4(c)(1)

documentation to certify that no changes to the pollutant-specific emissions unit, 

including the control device and capture system, have taken place.

64.4(c)(2)

If existing data from unit-specific compliance or performance testing specified in 64.4(c) are 

not available, the owner or operator:

shall submit a test plan and schedule for obtaining such data; or 64.4(d)(1)

may submit indicator ranges (or procedures for establishing indicator ranges) that 

rely on engineering assessments and other data, provided that the owner or 

operator demonstrates that factors specific to the type of monitoring, control device, 

or pollutant-specific emissions unit make compliance or performance testing 

unnecessary to establish indicator ranges at levels that satisfy the criteria in 

64.3(a).

64.4(d)(2)

If the monitoring submitted by the owner or operator requires installation, testing, or other 

necessary activities prior to use for the purposes of part 64, the owner or operator shall 

include:

an implementation plan and 64.4(e)

schedule for installing, testing, and performing any other appropriate activities prior 

to the use of the monitoring.

64.4(e)
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Reporting Requirements

Regulation 

Reference

Submit monitoring reports in accordance with 70.6(a)(3)(iii). In addition the monitoring report 

shall include:

summary information of the number, duration and cause (including unknown cause, 

if applicable) of excursions or exceedances and the corrective actions taken.

64.9(a)(2)(i)

summary information of the number, duration and cause (including unknown cause, 

if applicable) for monitor downtime incidents (other than downtime associated with 

zero and span or other daily calibration checks, if applicable).

64.9(a)(2)(ii)

a description of the actions taken to implement a quality improvement plan (QIP) 

specified in 64.8. Upon completion of a QIP, the owner or operator shall include in 

the next summary report documentation that the implementation of the plan has 

been completed and reduced the likelihood of similar levels of excursions or 

exceedances occurring.

64.9(a)(2)(iii)

Recordkeeping Requirements

Regulation 

Reference

Records shall be maintained in accordance with the requirements specified in 70.6(a)(3)(ii). In 

addition the records shall include:

any written QIP required pursuant to 64.8 64.9(b)

any corrective actions taken to implement a QIP 64.9(b)

Additional Requirements for Compliance Certification

Regulation 

Reference

For all affected pollutant-specific units, an annual compliance certification is required. As part 

of the compliance certification, it is necessary to identify:

each term or condition of the permit that is the basis of the certification. 70.6(c)(5)(iii)(A)

71.6(c)(5)(iii)(A)

the method(s) or other means used by the owner or operator for determining the 

compliance status with each term and condition during the certification period.

70.6(c)(5)(iii)(B)

71.6(c)(5)(iii)(B)

the status of compliance with the terms and conditions of the permit for the period 

covered by the certification, including whether compliance during the period was 

continuous or intermittent.

70.6(c)(5)(iii)(C)

71.6(c)(5)(iii)(C)
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such other facts as the PA may require. 70.6(c)(5)(iii)(D)

71.6(c)(5)(iii)(D)

4(b)(ii) RESPONDENT ACTIVITIES

The following list displays typical activities sources will have to perform to meet the 

permit application, recordkeeping and reporting requirements of the CAM Rule:

Review Requirements: Review the part 64 requirements to determine applicability. 

This is a one-time task for each newly-permitted facility, rather than each PSEU. This 

is assumed to require the same level of effort for each new title V facility with 

potentially subject PSEUs, regardless of the type of PSEUs (“Large” or “Other”) at 

the facility or the type of monitoring approach (instrumental or work practice) 

required for each.

Determine Monitoring Approach: Determine a CAM monitoring approach for each 

control device for which a facility is required to propose a specific monitoring 

approach for PSEUs [per §§64.4(g) and (f)]. Each monitoring approach should 

specify the proposed technique (e.g., continuously recording combustion temperature 

at the incineration point of effluent gases in a thermal oxidizer), identify the 

frequency and method of data collection, establish performance criteria and 

recommend a quality assurance program.

Specify Monitoring Plan Elements: Specify the CAM monitoring elements for each 

PSEU; that is, identify how the proposed monitoring approach will be implemented. 

This activity requires the facility to select performance indicators for each subject 

control device. The indicators establish monitoring performance characteristics and 

must provide reliable data for detection of significant adverse changes in control 

equipment performance. For the selected indicators, the design criteria must also: 

(1) specify operating ranges that reflect normal operating conditions, and (2) propose 

data collection sufficient to document continued operation of the control device in a 

satisfactory manner. 

Design Documentation: Develop and submit justification that supports the proposed 

monitoring approach for each PSEU. The type of documentation required could 

reference generally available information, existing applicable requirements, or sitespecific data, if available. The documentation should demonstrate the adequacy of 

proposed indicator ranges to detect significant adverse changes in control 

performance. The language of the CAM Rule requires site-specific testing to be used 

in establishing indicator ranges unless the facility can justify using other information, 

such as manufacturer’s data or engineering assessments. Generally, existing sitespecific test data will be applicable.

CAM Renewal: At the time of title V permit renewal, prepare and submit the 

information required by the permitting authority for PSEUs with previously 

established CAM monitoring. Any desired revisions to the established CAM 

monitoring should also be addressed in the permit renewal application. The burden 

assumed for this activity reflects the effort incurred for CAM in addition to the 

general title V permit renewal burden (which is addressed in the ICRs for the title V 

program).
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Prepare QIP: Prepare a QIP if required to do so by the PA because an affected

PSEU is not consistently maintaining compliance with the applicable emission 

limitation. The QIP initially includes procedures for evaluating the control 

performance problems and, based on the results of the evaluation procedures, the 

source modifies the plan to include procedures to improve the performance of the 

control system.

Records of Corrective Actions: Record activities undertaken to implement a QIP to 

bring a PSEU back into compliance after an excursion outside the normal control 

system operating range or exceedance of the applicable limitation.

Reporting of Corrective Actions: Along with the semi-annual reports required 

under the title V operating permit program, report the corrective actions taken to 

implement a QIP. 

Facility Certification: As part of the annual compliance certification required under 

the title V operating permit program for the entire source, include any PSEUs subject 

to the CAM Rule.

State and local PA respondents perform the following activities in administering the 

CAM Rule:

Rule Familiarization: Read the CAM Rule and associated EPA guidance materials 

to become familiar with the requirements.

Determine Applicability: Review applicability determinations submitted by sources.

Initial CAM Review: Review the CAM plans submitted by sources and approve or 

require revisions.

Evaluate CAM Renewals: As part of the review of title V permit renewal 

applications under the title V operating permit program, review the portions related to 

PSEUs subject to the CAM Rule.

Review QIPs: Review the QIPs prepared by sources to determine if they are 

acceptable.

Review Reports of Corrective Actions: As part of the review of the semi-annual 

reports required under the title V operating permit program, review any reports of 

corrective actions taken under a QIP to determine whether they are adequate to assure 

compliance on an ongoing basis. 

Review Annual Facility Certifications: As part of the review of the annual 

compliance certification required under the title V operating permit program for the 

entire source, review any compliance certifications for PSEUs subject to the CAM 

Rule.
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5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT

5(a) AGENCY ACTIVITIES

The EPA performs the following activities:

Review the CAM Rule to become familiar the requirements;

Provide oversight and guidance to state and local agencies;

Assess requests for alternative monitoring.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

The CAM Rule does not mandate the use of standardized forms for reporting 

information. Section 64.9(b)(2) allows recordkeeping in a variety of media as long as all records 

are available for inspection and there are no conflicts with other recordkeeping requirements.

5(c) SMALL ENTITY FLEXIBILITY

The agency assessed the impacts of the CAM Rule on small businesses, governments and 

organizations in Chapter V of the rule’s Regulatory Impact Analysis in 1997. This assessment 

still holds true, indicating the CAM Rule will not have a significant impact on a substantial 

number of small entities (SISNOSE). For additional discussion on this assertion, the agency 

invites the reader to review the CAM Rule RIA and ICR from 1997.

5(d) COLLECTION SCHEDULE

During initial implementation of the CAM Rule, the timing for submission of the initial 

CAM plans required under part 64 depended on whether existing affected units were classified as 

“large” or “other.” However, the CAM program has been has been fully implemented for these 

existing PSEUs. Going forward, initial CAM plans for affected new “large” and “other” PSEUs

must be submitted with the title V permit application for the new or modified facility at which 

the new PSEU is located.

Upon approval of the permit and consistent with the requirements of the title V operating 

permit program, sources must collect the information specified in their permits in accordance 

with the collection frequency specified, maintaining these data for at least 5 years. Sources must 

also submit semi-annual monitoring reports and annual compliance certifications as required by 

the title V operating permit program.

If the approved CAM monitoring results show that a PSEU is not consistently 

maintaining compliance as indicated by excursions or exceedances, the PA may require the 

source to develop and implement a QIP. The source must subsequently record and report on the 

corrective actions taken to implement the QIP.
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6. ESTIMATING THE BURDEN AND COST OF THE 

COLLECTION

This section discusses the development of burden estimates and their conversion 

estimates into costs, which are separated into burden costs and capital and O&M costs. 

According to the latest guidance for ICRs, capital and O&M costs display the cost of any new 

capital equipment the source or PA may have to purchase solely for information collection, 

assimilation, and storage purposes. For example, if a source had to purchase a new computer to 

store and manipulate CEMS data, that computer would be a cost of administration subject to 

reporting in the ICR. In addition, the latest guidance instructs the Agency to differentiate the 

burden associated with a source’s labor and that which it hires through outside contractors.

However, a sensitivity analysis of the effect of contracted labor on the CAM Rule reveals that, if 

all of the affected sources were to employ contractors to perform as much as half of the work 

necessary for full compliance with the rule, overall costs would increase by less than 5 percent. 

Consequently, this analysis assumes sources will not employ contracted labor.

6(a) ESTIMATING RESPONDENT BURDEN

This section presents estimates of the burden hours expected to be incurred at sources 

with emission units affected by the CAM Rule in carrying out the activities identified above in 

section 4(b)(ii). Results are contained in Tables 6.1a, b, and c for each of the 3 years covered by 

this ICR, respectively. Columns A through E in these tables summarize annual burden impacts 

that an individual PSEU will incur for each activity. 

Columns A and B represent the estimated burden hours for clerical and technical 

personnel, respectively. These burden estimates reflect the expert judgment of EPA staff, 

contractors, and industry experts. Column C represents the management labor hours associated 

with each activity, computed at a rate of 5 percent of the total clerical and technical labor. All 

burden estimates represent the increment over part 70 requirements.

For the activities associated with developing and documenting a CAM plan, we estimate 

different burdens for PSEUs depending on whether they are “without existing monitoring” or 

“with existing monitoring.” For the new PSEUs that become subject to the CAM Rule going 

forward, this is defined as follows:

“Without existing monitoring” denotes PSEUs that are subject to emission limits and 

therefore must control emissions, but the applicable requirements do not specify 

monitoring requirements. For these PSEUs, the source must develop the entire 

monitoring program and documentation required by the CAM Rule.

“With existing monitoring” denotes PSEUs whose applicable requirements include 

monitoring requirements, but these requirements are insufficient to meet the 

requirements of the CAM Rule. For these PSEUs, some of the monitoring elements 

are already present, and the source need only upgrade the monitoring program and 

documentation to meet the CAM Rule requirements.

We believe that sources with PSEUs “with existing monitoring” will experience less 

uncertainty about what is needed for adequate monitoring and, thus, developing a CAM plan and 

the necessary documentation for these units will require less effort than for PSEUs “without 
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existing monitoring.” As a result, the estimated per-PSEU burden is greater for PSEUs “without 

existing monitoring.”

For one source activity, recordkeeping for corrective actions under a QIP, we estimate 

different burdens for PSEUs depending on whether the CAM monitoring relies on an 

instrumental system or uses work practices. We believe that there will be less recordkeeping 

burden for PSEUs monitored with instrumental systems because those systems employ electronic 

capturing and monitoring information that previously was attributed to manual labor. Automated 

processes can collect hundreds of data points per second; whereas humans require considerably 

longer to accurately collect and process the same information. Column D of Tables 6.1a, b, and c 

gives the annual occurrences of each source activity for each PSEU. There will be one 

occurrence of each activity per year except for reports of corrective actions, for which we project 

two occurrences consistent with the title V operating permit program requirement for semiannual reporting. Finally, Column E totals the burden hours incurred by a source for each PSEU.

Tables 6.2a, b, and c present estimates of the burden hours expected to be incurred by 

PAs in carrying out the activities identified in section 4(b)(ii) in each of the 3 years covered by 

this ICR, respectively. The burden estimates are based on the expert knowledge of EPA staff.

The technical labor estimates for these activities in Column A generally reflect the PA hours 

required to complete the activities for one PSEU. For review of CAM plans, the estimated level 

of effort is greater for sources “without existing monitoring” than for those “with existing 

monitoring” because we believe that PAs will need to apply greater scrutiny to CAM 

submissions from sources that must develop their entire monitoring program and documentation

absent applicable monitoring requirements.

Column B in Tables 6.2a, b, and c shows the number of occurrences of each PA activity 

per year. In most cases, these numbers reflect the numbers of units expected to be submitting 

CAM plans, renewals, QIPs or certifications each year and, thus, are based on the numbers of 

PSEUs carrying out the analogous activities listed in Column I of source Tables 6.1a, b, and c (as 

discussed below in section 6(d)). Consistent with the title V operating permit semi-annual 

reporting requirement, the “number of occurrences” for the PA activity “review corrective action 

reports” is twice the number of units that will be expected to submit such reports each year. For 

Tables 6.2a, b, and c, the management burden hours in Column D are computed at a rate of 

5 percent of the total annual technical labor for each PA activity that appears in Column C.

As noted, the estimated burden and number of occurrences for the PAs’ activities in 

Columns A and B of Tables 6.2a, b, and c are generally based on individual PSEUs. The 

exception is the estimates for “rule familiarization” listed under the first activity in these tables, 

which are presented for each PA rather than each PSEU. Because the CAM program is now a 

mature, fully implemented program, the PAs are generally familiar with the CAM Rule. 

Accordingly, we have assumed that the technical labor burden (Column A) for each PA is 

limited to 12 hours for new staff to familiarize themselves with the rule. Column B reflects the 

number of PAs (112) rather than the number of PSEUs. 
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6(b) ESTIMATING RESPONDENT COSTS

6(b)(i) Estimating Labor Costs

Tables 6.1a, b, and c show the sources’ per-PSEU annual labor costs associated with each 

activity for each year covered by this ICR. This annual labor cost appears in Column F of each 

table.

This ICR identifies three labor categories: management, technical, and clerical. Labor 

rates, on a per-hour basis, are taken from the Bureau of Labor Statistics (BLS) Occupational 

Employment Statistics website (http://www.bls.gov/oes/) as posted for May 2012. For each type 

of personnel, the median hourly wage was averaged across the following sectors: 

(1) Manufacturing; (2) Professional, Scientific and Technical Services; (3) Administrative and 

Support and Waste Management and Remediation Services; (4) Educational Services;

(5) Healthcare and Social Assistance; and (6) Federal, State and Local Government. For 

managerial labor, an “All Other Managers” occupation was selected with a base hourly labor rate 

of $46.65; for technical personnel, “Environmental Engineering Technician” was selected with a 

base rate of $23.39; and for clerical personnel, “Secretaries, Except Legal, Medical, and 

Executive” was selected with a base rate of $15.48. The labor rates were then adjusted by an 

overhead and profit rate of 167 percent. Therefore, the total “loaded” wage rates are calculated 

by the following equation:

 base labor rate x 1.67 = loaded wage rate

Given the overhead cost adjustments, the final total loaded wage rates are $77.90 for 

managerial personnel, $39.06 for technical personnel, and $25.85 for clerical personnel. All 

labor rates are in 2012 dollars.

For each source activity, Column F in Tables 6.1a through 6.1c displays the total labor 

cost per year assumed necessary to complete each required activity. For each activity, the 

appropriate wage rate is multiplied by the number of labor hours in that category from Columns 

A, B, and C, the three values are added together, and then that cost is multiplied by the number 

of annual occurrences from Column D.

Tables 6.2a, b, and c show the costs for state and local agency PAs for all activities. The

methodology used to derive the State and Local costs parallels the procedures used in the 

original CAM RIA and the previous ICRs. The hourly wage rates for state and local personnel 

are derived from the rates paid to federal workers who carry out such activities. 

For technical labor, the hourly wage rate is based on 2012 wages at a pay grade of GS-12, 

Step 5 ($32.73); managerial labor is based on a pay grade of GS-15, Step 5 ($54.10). In each 

case, the base hourly wage rate was adjusted by a factor of 1.67 to “loaded” wage rates of $54.66 

for technical labor and $90.35 for managerial labor.

6(b)(ii) Estimating Capital and Operations and Maintenance Costs

Tables 6.1a, b, and c and Tables 6.2a, b, and c show the capital and operations and 

maintenance (O&M) costs as zero for all activities over the next 3 years. As explained above, the 

only capital costs to be included in an ICR are those for any new capital equipment the source or 

PA may have to purchase solely for information collection, assimilation, and storage purposes. 
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However, EPA assumes that any such equipment needed by sources to comply with part 64 

would be purchased as part of a monitoring equipment purchase and could not be separately 

estimated. Therefore, O&M costs for operating such capital equipment also could not be 

separately estimated. Other possible O&M costs associated with reporting and recordkeeping 

include such things as postage fees for submitting reports. However, part 64 does not require any 

new reports to be submitted; rather, it provides that information related to CAM be included in 

reports otherwise required under the title V program codified at 40 CFR part 70. Therefore, 

postage costs for these reports are attributable to part 70 and not to part 64.

6(b)(iii) Capital/Start-up vs. O&M Costs

As discussed in the previous section, EPA estimates that there will be no capital/start-up 

costs or O&M costs attributable to the CAM Rule for sources or PAs.

6(b)(iv) Annualizing Capital Costs

As discussed in the previous section, EPA estimates that there will be no capital/start-up 

costs attributable to the CAM Rule for sources or PAs. As a result, there are no annualized

capital/start-up costs included in this ICR.

6(c) ESTIMATING AGENCY BURDEN AND COST

Table 6.3 shows the burden and costs for EPA. Based on input from the EPA regional 

offices, we assume that each regional office devotes a total of approximately 0.1 of a “full-time 

equivalent” to CAM each year, or about 200 hours per regional office per year. Across the 

10 EPA regional offices, this totals 2,000 hours per year. We assume that the majority of this

time (1,880 hours) is spent reviewing CAM plans; the remaining time (120 hours) is allocated to

rule familiarization for new staff.

We assume that 5 percent of the EPA’s total labor associated with the CAM Rule is 

managerial labor and the remaining 95 percent is technical labor. The cost of this effort is 

calculated using the same loaded labor rates discussed above for PAs. Based on these 

assumptions, the total estimated cost to the EPA is a bit under $113,000 per year for each of the 

3 years covered by this ICR.

6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL 

BURDEN AND COSTS

In Tables 6.1a, b, and c, each PSEU that is subject to the CAM Rule is considered a 

respondent, except as otherwise indicated in the tables. The number of respondents in each row 

of these tables was estimated based on information on the number of new and existing title V 

permits taken from the 2012 ICR for the part 70 operating permit program2and on data

developed for the Regulatory Impact Analysis (RIA) that was prepared in 2008 for planned 

 

2 The ICR for the part 70 program has been assigned EPA tracking number 1587.12 and OMB Control Number 

2060-0243. This ICR expires on October 31, 2015.
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revisions to the CAM Rule that were never finalized.

3

Those revisions would have added

requirements for additional units that are not subject to the current CAM Rule, but would not 

have modified the existing requirements for units subject to the existing part 64. Therefore, the 

data pertaining to units subject to the existing part 64 can be used in this ICR, as they were in the 

2007 and 2010 ICR updates.

The assumptions underlying the number of respondents for each activity in Tables 6.1a, 

b, and c taken from the 2012 ICR for the part 70 program are as follows:

Each year, 100 new facilities receive title V permits.

In 2014 (the second year of the part 70 ICR and the first year of this ICR) there will 

be 15,204 existing title V permits. Of these, there will be 184 permits that were issued 

solely due to greenhouse gas (GHG) emissions. Because there are currently no 

control devices for GHGs, these permits will not include any PSEUs subject to the 

CAM Rule, leaving 15,020 existing title V permits that may include PSEUs subject to 

the CAM Rule.

To estimate the number of respondents of each type (“large” or “other” PSEUs) for which 

CAM plans must be developed and submitted each year, we used the following equation and 

factors derived from the 2008 RIA:

Where:

Pc is the number of PSEUs in Category c expected to become subject to CAM at a 

given time. The Categories are “large” PSEUs and “other” PSEUs.

RS is the number of relevant title V permits nationwide.

Sc is the percent of sources expected to construct at least one new PSEU in 

Category c. For “large” PSEUs, Sc = 11.5 percent; for “other” PSEUs, Sc = 

34.8 percent.

Pc is the number of new Category c PSEUs expected to be constructed at a facility 

that has at least one Category c PSEU. For new facilities, Pc is 3.15 for “large”

PSEUs and 7.06 for “other” PSEUs. For existing facilities adding new PSEUs, Pc

is 1 for both “large” and “other” PSEUs.

 

3

 In 2006, the EPA began development of a rulemaking intended to broaden the CAM Rule to apply to additional 

PSEUs, without changing the existing requirements for the PSEUs subject to the existing CAM Rule. 

Accordingly, new data-gathering and analysis were undertaken for the required RIA, which included updating the 

information for the PSEUs subject to the existing CAM Rule even though the planned rulemaking would not 

affect them. The EPA selected nine sample states that collected and maintained the data required for analysis, 

reviewed data from these states to determine the number of PSEUs that met CAM applicability and exemption 

criteria, and surveyed a subset of the sample states’ inspectors to determine baseline monitoring practices and to 

verify sample state database accuracy. Based on the results of these surveys, we developed PSEU population 

characteristics that were used estimate the impacts that would result from the planned rulemaking, including 

impacts for the “large” and “other” PSEUs subject to the existing, unchanged CAM Rule.
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Ac is the percent of PSEUs in Category c that are projected to be subject to the CAM

Rule. For “large” PSEUs, Ac = 53.8 percent; for “other” PSEUs, Ac = 

53.6 percent.

Additional assumptions from the 2008 RIA used to estimate the number of respondents 

(PSEUs) for source activities include the following, which were also used in the 2007 and 2010 

ICR updates: 

230 existing title V sources add PSEUs each year.

Of affected “large” PSEUs, 56.3 percent are “without existing monitoring” and 

43.7 percent are “with existing monitoring.”

Of affected “other” PSEUs, 31 percent are “without existing monitoring” and 

69 percent are “with existing monitoring.”

All affected “large” PSEUs meet CAM Rule requirements using instrumental 

monitoring systems.

All affected “other” PSEUs meet CAM Rule requirements using work practice

monitoring approaches.

Additional assumptions used to estimate the number of respondents (PSEUs) for source 

activities include the following:

All existing “large” and “other” PSEUs that became subject to the CAM Rule at the 

time of its promulgation have been integrated into the program as their title V permits 

were renewed.

Thus, the only PSEUs for which CAM approaches and documentation must be 

developed and submitted during the period of this ICR are those at new facilities, 

which are receiving their initial title V permits, and those being constructed at 

existing facilities. As noted above, there are 100 new facilities and 230 existing 

facilities that construct PSEUs each year.

Each new facility must review the requirements of the CAM Rule to determine 

whether its PSEUs are subject to the rule (Activity 1 in Tables 6.1a, b, and c). Note 

that the respondents for this activity facilities, rather PSEUs.

For the activities related to developing and documenting CAM plans, the number of 

respondents is determined using the equation above (Activities 2, 3, and 4).

Each year, 20 percent of all existing title V permits are renewed, and thus CAM plans 

are renewed for 20 percent of all PSEUs each year (Activity 5).

Each year, 0.04 percent of all existing and new PSEUs are required to prepare a QIP

and record information and submit reports about corrective actions (Activities 6, 7, 

and 8). This number is based on the number of enforcement actions taken in a given 

year.

All title V facilities are required to submit annual certifications, so there are no 

additional facilities with affected PSEUs that must submit such certifications 

(Activity 9).

Each facility that has at least one affected PSEU has an average of 4.27 affected 

PSEUs. This factor is used to convert the per-PSEU impacts to per-facility impacts. 

This factor was derived from the data and analyses of the 2008 RIA and replaces a 

factor used in error in the 2007 and 2010 ICRs.
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Tables 6.1a, b, and c present the total burden and costs of the CAM Rule for sources in 

each of the 3 years covered by this ICR, respectively. Table 6.4 presents a summary of the 

burdens for these 3 years. The average annual labor burden reported in Table 6.4 is computed as 

the arithmetic average of the sum of the annual labor burden across the 3 years of the ICR. The 

national average annual labor burden for sources over the 3 years covered by this ICR is 

estimated to be about 44,000 hours at an estimated labor cost of about $1.7 million. There are no 

annualized capital costs or O&M costs to report.

As discussed previously in section 6(a), Column B in PA Tables 6.2a, b, and c gives the 

total number of occurrences of each activity each year, generally reflecting the number of PSEUs 

expected to be submitting CAM plans, renewals, QIPs, or certifications each year, and these 

values are based on the numbers of PSEUs carrying out the analogous activities listed in 

Column I of source Tables 6.1a, b, c. The exception is “rule familiarization” listed under the first 

activity in Tables 6.2a, b, and c, which is based on the number of PAs (112) rather than the 

number of PSEUs. Because the CAM program is now a mature, fully implemented program, the 

PAs are generally familiar with the CAM Rule. Accordingly, we have assumed that the technical 

labor burden (Column A) for each PA is 12 hours for new staff to familiarize themselves with 

the rule.

Tables 6.2a, b, and c present the total burden and costs of the CAM Rule for PAs in each 

of the 3 years covered by this ICR, respectively. Table 6.5 presents a summary of the burdens for 

these 3 years. Again, the average annual labor burden reported in Table 6.5 is computed as the 

arithmetic average of the sum of the annual labor burden across the 3 years of the ICR. The 

national average annual labor burden for PAs over the 3 years covered by this ICR is estimated 

to be less than 7,000 hours at an estimated labor cost of about $375,000. There are no annualized 

capital costs or O&M costs to report

The title V operating permit program requires the cost of administering a state permit 

program to be fully repaid out of the permitting fees collected by that State. Therefore, the true 

cost of the CAM Rule to states and other PAs is zero, and the recorded cost of administration 

should be allocated to sources.

6(e) BOTTOM LINE BURDEN HOURS AND COST TABLES

6(e)(i) Respondent Tally

The total annual burden hours and costs for source and PA respondents are reported in 

Table 6.6. As shown in the table, sources are estimated to incur less than 44,000 labor hours and 

less than $1.7 million per year, while PAs are estimated to incur less than 7,000 labor hours and 

a little under $375,000 annually. Thus, total burden for all respondents comes to about 

50,000 hours and $2 million per year. As noted previously, the title V operating permit program 

requires the cost of administering a title V permit program to be fully repaid out of the permitting 

fees collected by the PA. Therefore, the true cost of the CAM Rule to states and other PAs is 

zero, and the cost of administration should be allocated to sources.

6(e)(ii) The Agency Tally

The total annual burden and costs for the EPA are reported in Table 6.3. As shown in the 

table, the expected annual burden for EPA will be 2,000 hours and about $113,000.
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6(e)(iii) Variations in the Annual Bottom Line

The burden and associated labor costs are not expected to vary significantly over the 

3 years covered by this ICR.

6(f) REASONS FOR CHANGE IN BURDEN

There is decrease of over 7.4 million hours in the total estimated respondent burden 

compared with the ICR currently approved by OMB. This decrease is a result of the fact that 

most facilities are now using electronic monitoring to conduct their recording, thus, resulting in a 

decrease in the number of labor hours needed. Additionally, all facilities with existing permits 

that include approved 40 CFR part 64 monitoring have now submitted the existing monitoring 

approach in their renewal applications, therefore, significantly reducing the costs for new

monitoring development. Also, we reviewed the reporting and recordkeeping requirements of the 

Title V permit program vis-à-vis those required under the CAM program. We found that, with 

the exception of sources required to develop a QIP, sources were meeting the reporting and 

recordkeeping requirements for CAM by complying with the requirements of the Title V 

program. We revised some of our assumptions to account for the additional requirements set 

forth under the CAM rule that are not outlined in the Title V program, while at the same time 

ensuring that requirements met under the Title V program were not being re-counted in this 

assessment. Furthermore, in order to reflect projected trends for the next 3 years, we updated 

some of the formulas used to calculate burden. All of these factors have contributed to the 

decrease in burden.

6(g) BURDEN STATEMENT

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

estimated to average about 2 hours per PSEU that is subject to the CAM Rule and about 59 hours 

per PA for administering the CAM program. 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, 

install, and 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 instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information. An agency may not conduct or sponsor, and a person is not required to respond 

to, a collection of information unless it 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 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 ICR under 

Docket ID Number EPA-HQ-OAR-2003-0152, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Air Docket in the EPA Docket Center 

(EPA/DC), WJC West Building, 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 holidays. The telephone number for the Reading Room is (202) 
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566-1744, and the telephone number for the Air 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-2003-0152 and OMB Control Number 2060-0376 in any 

correspondence.
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TABLE 6.1a Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2014

A B C D E F G H I J K L M

Clerical hours 

per 

occurrence

Technical 

hours per 

occurrence

Management 

hours per 

occurence 

([A+B]x0.05)

Annual 

occurrences

Annual 

person 

hours 

([A+B+C]xD)

Labor 

cost/year

Annualized 

capital costs

Annualized 

O&M costs

Total 

number of 

respondents

Total 

hours/year 

(E x I)

Total labor 

cost

(F x I)

Total 

capital & 

O&M cost 

([G+H] x I)

Total annual 

cost

(K+L)

1 Review Requirementsd 5 15 1 1 21 $793 $0 $0 100 2,100 $79,306 $0 $79,306

2 Determine Monitoring Approache

 Units without existing monitoring 0.75 2.25 0.15 1 3.15 $119 $0 $0 74 233 $8,803 $0 $8,803

 Units with existing monitoring 0.25 0.75 0.05 1 1.05 $40 $0 $0 134 141 $5,314 $0 $5,314

3 Specify Monitoring Plan Elementse

 Units without existing monitoring 4 12 0.8 1 16.8 $634 $0 $0 74 1,243 $46,949 $0 $46,949

 Units with existing monitoring 2 6 0.4 1 8.4 $317 $0 $0 134 1,126 $42,508 $0 $42,508

4 Design Documentatione

 Units without existing monitoring 0 4 0.2 1 4.2 $172 $0 $0 74 311 $12,715 $0 $12,715

 Units with existing monitoring 0 2 0.1 1 2.1 $86 $0 $0 134 281 $11,512 $0 $11,512

5 CAM Renewal 2 6 0.4 1 8.4 $317 $0 $0 4,541 38,144 $1,440,521 $0 $1,440,521

6 Prepare QIP 5 20 1.25 1 26.25 $1,008 $0 $0 9 236 $9,071 $0 $9,071

7 Records of Corrective Actions

 PSEUs with instrumental systems 0 0.15 0.0075 1 0.1575 $6 $0 $0 1 0.16 $6 $0 $6

 PSEUs using work practices 0 0.5 0.025 1 0.525 $21 $0 $0 8 4.20 $172 $0 $172

8 Reporting of Corrective Actions 0 0.5 0.025 2 1.05 $43 $0 $0 9 9.45 $387 $0 $387

9 Facility Certificationf 0.70 0 0.035 1 0.74 $21 $0 $0 0 0 $0 $0 $0

Total 43,829 $1,657,264 $0 $1,657,264

Notes:

aAll hours are per PSEU unless otherwise noted.

bCosts are based on the following hourly rates: $77.90 for managerial personnel; $39.06 for technical personnel, and $25.85 for clerical personnel

cSee section 4(b)(ii) for a description of these activities.

dHours are per facility, not per PSEU; number of respondents are facilities, not PSEUs

eOne-time activity.

f3 hours per facility converted to impact per PSEU by dividing by the average number of PSEUs per facility with at least one PSEU [4.27].

Hours Total Hours and Costs a and Costsb Per Respondent

Reporting and Recordkeeping Requirementsc
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TABLE 6.1b Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2015

A B C D E F G H I J K L M

Clerical hours 

per 

occurrence

Technical 

hours per 

occurrence

Management 

hours per 

occurence 

([A+B]x0.05)

Annual 

occurrences

Annual 

person 

hours 

([A+B+C]xD)

Labor 

cost/year

Annualized 

capital costs

Annualized 

O&M costs

Total 

number of 

respondents

Total 

hours/year 

(E x I)

Total labor 

cost

(F x I)

Total 

capital & 

O&M cost 

([G+H] x I)

Total annual 

cost

(K+L)

1 Review Requirementsd 5 15 1 1 21 $793 $0 $0 100 2,100 $79,306 $0 $79,306

2 Determine Monitoring Approache

 Units without existing monitoring 0.75 2.25 0.15 1 3.15 $119 $0 $0 74 233 $8,803 $0 $8,803

 Units with existing monitoring 0.25 0.75 0.05 1 1.05 $40 $0 $0 134 141 $5,314 $0 $5,314

3 Specify Monitoring Plan Elementse

 Units without existing monitoring 4 12 0.8 1 16.8 $634 $0 $0 74 1,243 $46,949 $0 $46,949

 Units with existing monitoring 2 6 0.4 1 8.4 $317 $0 $0 134 1,126 $42,508 $0 $42,508

4 Design Documentatione

 Units without existing monitoring 0 4 0.2 1 4.2 $172 $0 $0 74 311 $12,715 $0 $12,715

 Units with existing monitoring 0 2 0.1 1 2.1 $86 $0 $0 134 281 $11,512 $0 $11,512

5 CAM Renewal 2 6 0.4 1 8.4 $317 $0 $0 4,541 38,144 $1,440,521 $0 $1,440,521

6 Prepare QIP 5 20 1.25 1 26.25 $1,008 $0 $0 9 236 $9,071 $0 $9,071

7 Records of Corrective Actions

 PSEUs with instrumental systems 0 0.15 0.0075 1 0.1575 $6 $0 $0 1 0.16 $6 $0 $6

 PSEUs using work practices 0 0.5 0.025 1 0.525 $21 $0 $0 8 4 $172 $0 $172

8 Reporting of Corrective Actions 0 0.5 0.025 2 1.05 $43 $0 $0 9 9 $387 $0 $387

9 Facility Certificationf 0.70 0 0.035 1 0.74 $21 $0 $0 0 0 $0 $0 $0

Total 43,829 $1,657,264 $0 $1,657,264

Notes:

aAll hours are per PSEU unless otherwise noted.

bCosts are based on the following hourly rates: $77.90 for managerial personnel; $39.06 for technical personnel, and $25.85 for clerical personnel

cSee section 4(b)(ii) for a description of these activities.

dHours are per facility, not per PSEU; number of respondents are facilities, not PSEUs

eOne-time activity.

f3 hours per facility converted to impact per PSEU by dividing by the average number of PSEUs per facility with at least one PSEU [4.27].

Reporting and Recordkeeping Requirementsc

Hoursa and Costsb Per Respondent Total Hours and Costs
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TABLE 6.1c Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2016

A B C D E F G H I J K L M

Clerical hours 

per 

occurrence

Technical 

hours per 

occurrence

Management 

hours per 

occurence 

([A+B]x0.05)

Annual 

occurrences

Annual 

person 

hours 

([A+B+C]xD)

Labor 

cost/year

Annualized 

capital costs

Annualized 

O&M costs

Total 

number of 

respondents

Total 

hours/year 

(E x I)

Total labor 

cost

(F x I)

Total capital 

& O&M cost 

([G+H] x I)

Total annual 

cost

(K+L)

1 Review Requirementsd 5 15 1 1 21 $793 $0 $0 100 2,100 $79,306 $0 $79,306

2 Determine Monitoring Approache

 Units without existing monitoring 0.75 2.25 0.15 1 3.15 $119 $0 $0 74 233 $8,803 $0 $8,803

 Units with existing monitoring 0.25 0.75 0.05 1 1.05 $40 $0 $0 134 141 $5,314 $0 $5,314

3 Specify Monitoring Plan Elementse

 Units without existing monitoring 4 12 0.8 1 16.8 $634 $0 $0 74 1,243 $46,949 $0 $46,949

 Units with existing monitoring 2 6 0.4 1 8.4 $317 $0 $0 134 1,126 $42,508 $0 $42,508

4 Design Documentatione

 Units without existing monitoring 0 4 0.2 1 4.2 $172 $0 $0 74 311 $12,715 $0 $12,715

 Units with existing monitoring 0 2 0.1 1 2.1 $86 $0 $0 134 281 $11,512 $0 $11,512

5 CAM Renewal 2 6 0.4 1 8.4 $317 $0 $0 4,542 38,153 $1,440,838 $0 $1,440,838

6 Prepare QIP 5 20 1.25 1 26.25 $1,008 $0 $0 9 236 $9,071 $0 $9,071

7 Records of Corrective Actions

 PSEUs with instrumental systems 0 0.15 0.0075 1 0.1575 $6 $0 $0 1 0.16 $6 $0 $6

 PSEUs using work practices 0 0.5 0.025 1 0.525 $21 $0 $0 8 4 $172 $0 $172

8 Reporting of Corrective Actions 0 0.5 0.025 2 1.05 $43 $0 $0 9 9 $387 $0 $387

9 Facility Certificationf 0.70 0 0.035 1 0.74 $21 $0 $0 0 0 $0 $0 $0

Total 43,838 $1,657,581 $0 $1,657,581

Notes:

aAll hours are per PSEU unless otherwise noted.

bCosts are based on the following hourly rates: $77.90 for managerial personnel; $39.06 for technical personnel, and $25.85 for clerical personnel

cSee section 4(b)(ii) for a description of these activities.

dHours are per facility, not per PSEU; number of respondents are facilities, not PSEUs

eOne-time activity.

f3 hours per facility converted to impact per PSEU by dividing by the average number of PSEUs per facility with at least one PSEU [4.27].

Reporting and Recordkeeping Requirementsc

Hoursa and Costsb Per Respondent Total Hours and Costs
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TABLE 6.2a Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2014

A B C D E

Technical 

hours per 

occurenceb

Occurrences 

per year

Technical 

hours per 

year (AxB)

Management 

hours per year 

(C x 0.05) Total cost per yearc

1 CAM Activities

 Rule Familiarizationd12 112 1,344 67 $79,533

 Determine Applicability 0.67 208 139 7 $8,247

2 Initial CAM Review

 Units without existing monitoring 2 74 148 7 $8,758

 Units with existing monitoring 1 134 134 7 $7,930

3 Evaluate CAM Renewals 1 4,541 4,541 227 $268,720

4 Review QIPs 1 9 9 0.5 $533

5 Review Reports of Corrective Actions 0.5 18 9 0.5 $533

6 Review Annual Facility Certifications 0.33 0 0 0 $0

Total 6,324 316 $374,253

aSee section 4(b)(ii) for a description of these activities.

bAll hours are per PSEU unless otherwise noted.

cCosts are based on the following hourly rates: $90.35 for managerial personnel and $54.66 for technical personnel.

Burden Itema

dBurden for Rule Familiarization is per Permitting Authority (PA), of which there are 112. Because this is a mature program, PAs 

are generally familiar with the CAM Rule, but we include 12 hours/year per PA for new staff to become familiar with the rule.
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TABLE 6.2b Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2015

A B C D E

Technical 

hours per 

occurenceb

Occurrences 

per year

Technical 

hours per 

year (AxB)

Management 

hours per year 

(C x 0.05) Total cost per yearc

1 CAM Activities

 Rule Familiarizationd12 112 1,344 67 $79,533

 Determine Applicability 0.67 208 139 7 $8,247

2 Initial CAM Review

 Units without existing monitoring 2 74 148 7 $8,758

 Units with existing monitoring 1 134 134 7 $7,930

3 Evaluate CAM Renewals 1 4,541 4,541 227 $268,720

4 Review QIPs 1 9 9 0.5 $533

5 Review Reports of Corrective Actions 0.5 18 9 0.5 $533

6 Review Annual Facility Certifications 0.33 0 0 0 $0

Total 6,324 316 $374,253

aSee section 4(b)(ii) for a description of these activities.

bAll hours are per PSEU unless otherwise noted.

cCosts are based on the following hourly rates: $90.35 for managerial personnel and $54.66 for technical personnel.

Burden Itema

dBurden for Rule Familiarization is per Permitting Authority (PA), of which there are 112. Because this is a mature program, PAs 

are generally familiar with the CAM Rule, but we include 12 hours/year per PA for new staff to become familiar with the rule.
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TABLE 6.2c Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2016

A B C D E

Technical 

hours per 

occurenceb

Occurrences 

per year

Technical 

hours per 

year (AxB)

Management 

hours per year 

(C x 0.05) Total cost per yearc

1 CAM Activities

 Rule Familiarizationd12 112 1,344 67 $79,533

 Determine Applicability 0.67 208 139 7 $8,247

2 Initial CAM Review

 Units without existing monitoring 2 74 148 7 $8,758

 Units with existing monitoring 1 134 134 7 $7,930

3 Evaluate CAM Renewals 1 4,542 4,542 227 $268,779

4 Review QIPs 1 9 9 0.5 $533

5 Review Reports of Corrective Actions 0.5 18 9 0.5 $533

6 Review Annual Facility Certifications 0.33 0 0 0 $0

Total 6,325 316 $374,312

aSee section 4(b)(ii) for a description of these activities.

bAll hours are per PSEU unless otherwise noted.

cCosts are based on the following hourly rates: $90.35 for managerial personnel and $54.66 for technical personnel.

Burden Itema

dBurden for Rule Familiarization is per Permitting Authority (PA), of which there are 112. Because this is a mature program, PAs 

are generally familiar with the CAM Rule, but we include 12 hours/year per PA for new staff to become familiar with the rule.
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TABLE 6.3 Federal Labor Hours and Costs for "Large & Other" Sources - All Pollutants, 2014-2016

CAM Activities Annual Burden Three Year Total 

Technical 

Hours

Management 

Hours

Total 

Hours Annual Cost 

Technical 

Hours 

Management 

Hours

Total 

Hours Total Cost

Rule Familiarization 1114 6 120 $6,773 342 18 360 $20,320

Review CAM Plans 11,786 94 1,880 $106,114 5,358 282 5,640 $318,341

Total Cost and Burden: 1,900 100 2,000 $112,887 5,700 300 6,000 $338,661

1

 We assumed 0.1 FTEs, or 200 hours per region per year; 200 hours/region * 10 regions = 2,000 hours/yr.

We assumed the majority of the time is spent reviewing CAM plans; some time was allocated to Rule familiarization for new staff.
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TABLE 6.4 Average Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants

Year Annual total hours Annual labor cost

Annual capital & 

O&M cost Total annual cost

2014 43,829 $1,657,264 $0 $1,657,264

2015 43,829 $1,657,264 $0 $1,657,264

2016 43,838 $1,657,581 $0 $1,657,581

Total 131,496 $4,972,109 0 $4,972,109

Average 43,832 $1,657,370 $0 $1,657,370

Burden per Affected PSEU

Year

# PSEUs subject to 

CAM Annual total hours Hours per PSEU Hours per facilitya

2014 22,915 43,829 2 8

2015 23,123 43,829 2 8

2016 23,331 43,838 2 8

Total 69,369 131,496 6 24

Average 23,123 43,832 2 8

aAssumes 4.27 PSEUs per facility
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Page 31 Year Annual total hours Total annual cost

2014 6,641 $374,253

2015 6,641 $374,253

2016 6,642 $374,312

Total 19,923 $1,122,819

Average 6,641 $374,273

TABLE 6.5 Average Permitting Authority Burden and Labor 

Costs for All "Large" and "Other" Sources - All Pollutants
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Table 6.6 Total Estimated Respondent Burden and Cost Summary

Type of 

respondent

Average 

annual number 

of 

respondents

Average 

annual labor 

hours

Average 

annual labor 

cost

Average 

annual 

capital and 

O&M cost

Average 

total annual 

cost

Average 

annual 

labor hours 

per 

respondent

Average 

annual cost 

per 

respondent

Sourcesa23,123 43,832 $1,657,370 $0 $1,657,370 2 $72

PAs 112 6,641 $374,273 $0 $374,273 59 $3,342

Total 23,235 50,473 $2,031,642 $0 $2,031,642

aFor sources, the number of respondents is the number of PSEUs subject to the CAM Rule. There are an average of 

4.27 affected PSEUs per facility with at least one PSEU.