## INFORMATION COLLECTION REQUEST

FOR THE COMPLIANCE ASSURANCE

MONITORING PROGRAM (40 CFR PART 64)

EPA ICR No. 1663. 0 8

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

### C ontents

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) CONFIDENTIAL ITY

................................ ................................ ................................ ... 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 MANAGEME NT

................................ .... 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

................................ .... 206(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

................................ ................................ ........................... 21Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 1 

## 1. IDENTIFICATION OF THE INF ORMATION COLLECTION

1(a) TITLE OF THE INFORMATION COLLECTION

This document fulfills the a gency's requirements un der 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

1663.0 8 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 part s 70 and 71 ), the CAM Rule requires monitoring, compliance certification, periodic reporting and recordkeeping information collection s by owners and operators of title V sources 1
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 th e 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 Plan s (QIP s ) and keep records of

, and submit report s on
, corrective actions taken under QIP s

.
The CAM Rule identifies two categories of emission s units:

( 1 ) “ Large ” PSEU s : 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 ” PSEU s: the set of remaining affected PS EU s

.

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 we re initially subject to d ifferent 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 t heir 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 pe rmit 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 use s 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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 2 program, the compliance of their emissions units with the appli cable requirements. In addition, these data pro vide the basis on which owners or opera tors submit monitoring reports on no less

than a semi

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

record keeping period estab lished 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

. T he EPA estimates that the CAM program currently applies to approximately 2 3 ,000 exis ting 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 (20 12 dollars). The activities at sources leading to these impacts include :

Determination of a mon itoring 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 R ule.

In addi tion , we reviewed and updated, where necessary :

L abor rates;

E stimates of labor hours needed for each activity associated with CAM monitoring ( CAM approach development and review, QIP development and review, recordkeeping and reporting ); and

T he implemen tation schedule for CAM using current t itle V data for both existing

and new sources

.

We ma ke specific assumptions about permit approvals and renewals in order to project when sources would submit their proposed monitoring approaches. We ma ke the followin g 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 t wo ICR s

. 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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 3 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 requir ements for the CAM R ule 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 U SE 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 c ompliance certifications, to submit monitoring results at least semi

- annually and to report deviations promptly, but no implemen tation guidance is provided within the operating permit program. The CAM program provides the vehicle to implement operating pe rmits 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 (e nforcement provisions) of the 1990 Amendments.

Title V directs the a gency 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 a gency to prescribe, by rule, methods and procedures for determining compliance, and states that continu ous e mission monitoring systems need not be required if other methods or proce dures provide sufficiently reliable and timely information for determining compliance. Under section 504(c), each operating permit must “ set forth inspection, entry, monitoring, comp li ance 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 certi fications. 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, requirePart 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 4 enhanced monitoring and submission of compliance certifications. Com pliance certifications shall include (A) identification of the applicable re quirement that is the basis of the certification, (B) the method used for deter mining the compliance status of the source, (C) the compliance status, (D) whet her 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 requirem ents. 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:

E stablish and maintain such records;

M ake such reports;

I nstall, use, and maintain s uch monitoring equipment;

S ample 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);

K eep records on control equipment parameters, production variables, or other indirect data when direct monitoring of emissions is impractical;

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

P rovide such other information as the Administrator may reasonably requi re.

Obtaining ongoing compliance is a two

- step process. First, the a gency must assure properly designed control measures are installed or otherwise employed. These measures include control devices, process modifications, operating limitations and other co ntrol mea sures as applicable. Furthermore, the a gency 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, co mpliance inspections and similar mecha nisms. The title V permit application and review process, including the applicant ’ s initial com pliance 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 tha t they do not deteriorate to the point where the owner or operator fails to remain in compliance with appli cable requirements. The a gency believes that monitoring, reporting, recordkeeping and on going or recurring compliance certifi cation requirements u nder titles V and VII should be designed so that owners or operators carry out this second step in assuring ongoing compliance. The a gency has adopted the CAM approach to assure the proper operation and maintenance of control measures employed by sources. The CAM Rule establishes monitoring to:

D ocument continued operation of the control measures within ranges of specified indicators of performance (such as emissions, con trol device parameters and process parameters) that are designed to provide a reasona ble assurance of compliance with applicable requirements;Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 5 I ndicate any excursions from these ranges; and

R espond 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 :

P rovides cost

- ef

fective achievement of air pollution emission reductions;

E stablishes voluntary compliance and self

- certification by owners or operators; and

H olds 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 th e 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 com pliance, as input into reports to other agencies, and, when necessary, as evidence in enforcement proceedings. The PAs will use the infor mation on

excursions and exceeda nces collected from owners or op erators to require the development and implementation by source operators of a QIP , when necessary . The QIP will address the timetable, methods and pro cedures for dealing with these excursions and exceedances.

The PAs will also collect summaries of inform ation 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 age ncies. Other f ederal 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 emissio ns unit or particular group of emissions units.



## 3. NONDUPLICATION , CONSULTATIONS, AND OTHER

COLLECTION CRITERIA

3(a) NONDUPLICATION

For approval of a proposed ICR, the a gency must ensure that it has taken every reasonable step to avoid duplication in its p aperwork 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 implem ented monitoring strategies to fulfill their part 70 requirements, the part 64 monitoring guidelines were carefully crafted by the a gency 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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 6 

### 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 annu al 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 a gency asked for comments on this current ICR. We have not received any co mments on the burden that has been calculated. Additionally, in order to derive our burden estimates in the past

, the a gency discuss ed the CAM requirements with stakeholders through a series of workshops and public meetings. The workgroups at these meeting s discussed and review ed CAM requirements and reviewed extensive public input concerning the develop ment and implementation of CAM. For example, w e con ducted multiple workshops with state and local agency staff in over a dozen states since promulgating t he 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 s taff 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

re quires semi

- annual reports because the statu t e 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. Conseque ntly, 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 info rmation collections must be adhered to by all

f ederal a gencies for approval of any rulemaking ’ s collection methodology. In accordance with the requirements of 5 CFR 1320.6, the a gency believes:Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 7 Part 64 regulations do not require periodic reporting more fre quently tha n semi

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

survey. Responses to a gency 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 f ederal 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 appli cation, update, or revision to be submitted to the a gency. Respondents do not receive remuneration for the preparation of reports required by the Act or part 64. To the greatest extent possible, the a gency has taken advantage of automated methods of report ing.

The a gency believes the impact of part 64 on small entities to be insignificant and not disproportionate.

The recordkeeping and reporting requirements contained in the CAM pro gram regulations do not exceed any of the Paperwork Reduction Act guide li nes con tained in 5 CFR 1320.6, except for the guideline which limits reten tion of records by respondents to 3 years. The CAM program and the operating permit pro gram require both respondents and s tate or local agencies to retain records for a period of 5 years. The justification for this e xception is found in

28 U.S.C. 2462, which specifies 5 years as the general statute of limitations for f ederal claims in response to violations by regu lated entities. The decision in U.S. v. Conoco, Inc. , No. 83

- 191 6. 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 ru lemaking. 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

conditi ons 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 t o 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 opera tors as confidential business information (CBI) and appr oved 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, Septem ber 1, 1976; amended by 43 FR 39999, September 8, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 8 

### 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 inclu de 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 Indu strial 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:Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 9 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 owne r 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 recom mendations 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)Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 10 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 com pleted and reduced the likelihood of similar levels of excursions or exceedances occurring. 64.9(a)(2)(iii)

Record k eeping 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)

7 1 .6(c)(5)(iii)(A)

the method(s) or other means used by the owner or operator for determining the compli ance status with each term and condition during the certification period. 70.6(c)(5)(iii)(B)

7 1 .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)

7 1 .6(c)(5)(iii)(C)Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 11 such other facts as the PA may require. 70.6(c)(5)(iii)(D)

7 1 .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 re quirements of the CAM Rule :

Review R equirements : Review the part 64 requirements to determine applicability.

This is a one

- time task for each newly

- permitted facility , rather than each PSEU. T his 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 M onitoring A pproach : 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 qua lity assurance program. Specify M onitoring P lan E lements : 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 fo r 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 mu st 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 D ocumentation : Develop and submit justificati on that supports the proposed monitoring approach for each PSEU . The type of documentation required could reference generally available information, existing applicable requirements, or site

specific data, if available. The documenta tion should demonstrat e 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 in formation, such as manufacturer’s data or engineering assessments. Generally, e xisting site

specific test data will be applicable.

CAM R enewal : At the time of title V permit renewal, prepare and submit the information required by the permitting authority f or 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 t o the general title V permit renewal burden (which is addressed in the ICRs for the title V program).Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 12 Prepare QIP : Prepare a QIP if required to do so by the PA because a n affected

PSEU is not consistently maintaining compliance with the applicable emission

limitation . The QIP initially include s procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the

source modif

ies the plan to include procedures to improve the perfor mance of the control system

. R ecords of C orrective A ctions : 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

. R eport ing of C orrective A ctions : Along with the semi

- annual reports required under the title V operating permit program, report the corrective actions taken to implement a QIP.

F acility C ertification : As part of the annual compliance certification requi red under the title V operating permit program for the entire source, includ e any PSEUs subject

to the CAM Rule

.

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

CAM Rule:

Rule F amiliarization : Read the CAM Rule and associated EPA guidance materials to become familiar with the requirements.

Determine A pplicability : Review applicability determinations submitted by sources.

Initial CAM R eview : Review the CAM plans submitted by sources and approve or require revisions.

Evaluate CAM R enewals : 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 sou rces to determine if they are acceptable.

Review R eports of C orrective A ctions : As part of the re view 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 wh ether they are adequate to assure compliance on an ongoing basis

. Review A nnual F acility C ertifications : As part of the review of the annual compliance certification required under the title V operating permit program for the entire source, review any com pliance certifications for PSEUs subject to the CAM

Rule.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 13 

## 5

. THE INFORMATION COLLECTED

— AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION

MANAGEMENT

5 (a) AGENCY ACTIVITIES

The EPA perform s the following activities:

Review the CAM Rule to become familiar the requirements; Provide oversight and guidance to s tate 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

informa tion. 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 a gency assessed the impacts of the C AM 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 a gency 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 s ubmission of the initial CAM plans required under part 64 depended on whether existing affected unit s were classified as

“ l arge ” or “ o ther. ” However, the CAM program has been has been fully implemented for these existing PSEUs. Going forward, initial CAM plan s 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 col lect the informa tion specified in their permits in accor dance 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 b y 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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 14 

## 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 se parated 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 s torage purposes. For example, if a source had to purchase a new computer to store and manipulate CEM S data, that computer would be a cost of administration subject to reporting in the ICR. In addition, the latest guidance instructs the Agency to differenti ate 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 t o 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 sec tion presents estimates of the burden hours expected to be incurred at sources with emission units affected by the CAM R ule in carrying out the activities identified above in section 4(b)(ii)

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

this ICR , respectively

. Columns A through E in t hese 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. The se 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 techn ical labor. All

burden esti mates 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 “with out existing monitoring” or “with existing monitoring.” For the new PSEUs that becom e 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 monitorin g program and documentation to meet the CAM Rule requirements.

We believe that sourc es 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 d ocumentation for these units will require less effort than for PSEUs “ withoutPart 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 15 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 th ere will be less recordkeeping burden for PSEUs monitored with instrumental systems bec ause 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 a nd 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 semi

annual reporting. Finally, Column E totals the burden hours incurred by a source for each PSEU.

Tables 6. 2 a , b, and c present estimates of the burden hours expected to b e 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. T he 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 source s “without existing monitoring” than for those “wi th 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 6.2 a, b, and c show s 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 ca rrying 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 “re view corrective action reports” is twice the number of units that will be expected to submit such reports each year. For

Tables 6.2 a, b, and c, the management burden hours in Colum n 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 PSEU s

. 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. Accordingl y, 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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 16 

### 6(b) ESTIMATING RESPONDENT C OSTS

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.

T his ICR i dentifies three la bor categories : management , technical, and clerical

. Labor

rates, on a per

- hour basis, are taken from the Bureau of Labor Statistics (BLS) Occupational Employment Statistics w ebsite (http://www.bls.gov/oes/) as posted for May 20 12

. For each type of personn el, the me di an hourly wage was averaged across the f ollowing sectors: (1) Manufacturing; (2) Professional, Sci entific and Technical Services; (3) Administrative and Support and Waste Mana gement and Remediation Services; (4) Educational Services; (5) Healthcare and Soc ial Assistance; and (6) Federal, State and Local Government . For managerial labor, an “ All Other M anager s ” occupation was selected with a base hourly labor rate

of $ 46.65 ; for technical personnel, “E nvironmental E ngineering T echnician ” wa s selected with a base rate of $ 23.39 ; and for clerical personnel, “ Secretaries, Except Legal, Medical, and

Executive ” w as selected with a base rate of $ 15.48

. The labor rates were then adjusted by an overhead and profit rate of 16 7 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 20 12 dollars.

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

cost per year assumed necessary to complete each required activity. Fo r 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 6.2 a, b, and c show the costs for s tate and l ocal a genc y 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 ICR s

. The hourly wage rates for state and loca l 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 6.1 a, b, and c and Tables 6.2 a, 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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 17 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 submittin g repo rts. 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 t hese 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)(i v ) 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 i n this ICR.



### 6(c) ESTIMATING AGENCY BURDEN AND COST

Table 6. 3 shows the burden and costs for EPA. B ased on input from the EPA r egion al

o ffices, w e assume that each r egional o ffice devotes a total of approximately 0

. 1 of a “full

- time equivalent” to CAM each year , or about 200 hours per r egion al o ffice per year . Across the

10 EPA r egion al o ffices, this totals 2,000 hours per year. We assume that the majority of th is

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

r ule 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 rate s discussed above for PAs. Based on these assumptions, t he 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

I n 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 o f respondents in each row

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

per mits taken from the 2012 ICR for the part 70 operating permit program 2 and on data developed for the R egulatory I mpact A nalysis (RIA) that was prepared in 2008 for plann ed

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

2060

- 0 243. This ICR expires on October 31, 2015.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 18 revisions to the CAM Rule that were never finalized

. 3 Those revisions would have add ed requirements for additional units that are not subject to the current CAM R ule, but would not

have modif

ied 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 facilitie s 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.

T o 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:

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

given time. The Categories are “l arge ” PSEUs and “o ther ” PSEUs.

RS is the number of relevant title V permits nationwide

.

S

c is the percent of sources expected to construct at least one new PSEU in Category c. For “l ar ge ” PSEUs

, S

c = 11.5 percent ; for “o ther ” PSEUs

, S

c = 34.8 percent

.

P
c 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, P

c is 3.15 for “l arge ”

PSEUs and 7.06 for “o ther ” PSEUs. For existing facilities adding new PSEUs

, P
c is 1 for both “l arge ” and “o ther ” 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 R ule. Accordingly, new data

- gathering and analysis were undertaken for the requi red 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 select ed nine sample s tates that collect ed and maintain ed the data required for analysis

, revi ewed data from these s tates to determine the number of PSEUs that met CAM applicability and exemption

criteria , and surveyed a subset of the sample s tates’ 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 CA M Rule.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 19 A

c is the percent of PSEUs in Category c that are projected to be subject to the CAM

Rule . For “l arge ” PSEUs

, A

c = 53.8 percent ; for “other” PSEUs

, A

c = 53.6 percent

. Additional assumptions from the 2008 RIA use d to estimate the number of respondents (PSEUs) for source activit ies 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. ”

A ll a ffected “ l a rge” PSEUs meet CAM Rule requirements using instrumental monitoring systems.

A ll a ffected “ 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 wh ich CAM approaches and documentation must be develop ed and submit ted 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 respo ndents 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 f

acilities are required to submit annual certifications , so there are no

additional facilities with affected PSEUs that must submit such c ertifications (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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 20 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 a verage 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

esti mated 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 6.2 a, b, and c gives t he total number of occurrences of each activity each year, generally reflect ing the number of PSEU s 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 analog ous activities listed in

Column I of source Tables 6.1a, b, c. The exception is “rule familiarization” listed under the first activity in Tables 6.2 a, b, and c, which is based on the number of PAs (112) rather than the

number of PSEUs. B ecause the CAM prog ram 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 6.2 a, 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, t he 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. The refore, the true

cost of the CAM Rule to s tates 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 fo r 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

5 0 ,000 hours and $2 million per year. As noted previously, t he title V operating permit program requires the cost of administering a title V permit program to be fully repaid out of th e permitting fees collected by th e PA . Therefore, the true cost of the CAM Rule to s tates 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 repo rted in Table 6. 3 . As shown in the table, the expected annual burden for EPA will be 2 ,000 hours and about $ 113 ,000.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 21 

### 6(e)(iii) Variations in the Annual Bottom Line

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

3 year s 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 existin g 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, i n 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 thi s 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 gener ate, maintain, retain, or disclose or provide information

to or for a f

ederal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating and verifyi ng 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 info rmation; 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 dis plays 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 a gency ’ s need for this information, the accuracy of the provided burden estimates, and any sugge sted 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

, w hich 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)Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

Page 22 56 6

- 1 744, and the telephone number for the Air Docket is (202) 56 6

- 1742 . An electronic version of the public docket is av ailable 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 ava ilable 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, A ttention: 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.Part 64 Compliance Assurance Monitoring Rule Information Collection Request Renewal

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