_________________________________________________________________ ____________

_ Supporting Statement Am bient Oxides of Sulfur Monitoring Regulations: Revisions to Network Design Requirements

EPA ICR # 2370.01
PART A 1. Identification of the Information Collection (a) Title of the Information Collection “Ambient Oxides of Sulfur Monitoring Regulations: Revisions to Network Design Requirements

– Proposal” (b) Short Characterization/Abstract This Information Collection Request (ICR) includes ambient air monitoring data reporting and recordkeeping activities associated with the 40 CFR part 58 Ambient Air Quality Surveillance regulations. These data and information are collected b y State and local air quality management agencies and reported to the U.S. Environmental Protection Agency (EPA). The EPA is proposing to revise the network design requirements for the oxides of sulfur ( S O X ) , specificall y sulfur dioxide ( S O 2 ) , to support the proposed changes to the primary National Ambient Air Quality

Standards (NAAQS) for S O 2 . Presently , state agencies, and local agencies when delegated b y the s tate , are required to operate minimum numbers of EPA

- approved S O 2 monitors based on (1) the population of each of their Core Based Statistical Ar eas (CB SA) and the amount of SO 2 emissions within those CBSAs and (2) the amount of SO 2 emissions emitted within each state. EPA is proposing a two

- pronged monitoring network design. The two prongs are designed to : 1) monitor in CBSAs where there is an increased coincidence of population and SO 2 emissions and 2 ) to proportionally require monitors in states corresponding to the amount of SO 2 emissions that state contributes to the national emissions inventory

. The proposed network design corresponds to the proposal of the new NAAQS based on peak 1

- hour daily maximum concentrations, or 1

- hour NAAQS, and the associated proposed range of levels from 5 0 to 100 parts per billion (ppb )

. The introduction of the 1

- hour NAAQS and the range of levels are i ntend ed t o protect against peak, shorter term exposure risks

. In the first prong of the S O 2 network design, EPA is proposing minimum S O 2 monitoring requirements which call for monitors in CBSA by developing a Population Weighted E missions Index (PWEI) that uses population and emissions inventory data at the CBSA 1 level to assign required monitoring for a given CBSA (population and emissions being obvious relevant factors in prioritizing numbers of required monitors). The PWEI for a particular CBSA is calculated by

1 CBSAs are defined by the U.S. Census Bureau, and are comprised of both Metropolitan Statistical Areas and Micropolitan Statistical Areas ( http://www.census.gov ).2

multiplying the population (using the latest Census Bureau estimates) of a CBSA by the total amount of SO 2 emissions in that CBSA. The CBSA emission value is in tons per year, and is calculated b y aggregating the county level emissions for each count y i n a CBSA. We then normalize by

dividing the resulting product of CBSA population and CBSA SO 2 emissions by 1,000,000 to provide a PWEIvalue, the units of which are millions of people

- tons per ye ar . Those CBSAs with a PWEIvalue of 1,000,000 or more woul d be required to operate three monitors within that CBSA. Those CBSAs with a PWEIvalue between 1,000,000 and 10,000 would be required to operate two monitors within that CBSA. Those CBSAs with a PWEIvalue between 10,000 and 5,000 would be required to op erate one monitor within that CBSA. In summary , EPA estimates that this first prong of the proposed S O 2 network design will require 231 m onitoring sites in 132 CBSAs. In the second prong of the proposed monitoring network design, EPA is proposing to requ ire a monitor or monitors in each state, allocated by state

- level SO 2 emissions. In this prong, EPA proposes to distribute approximately 114 sites, based on the corresponding percent contribution of each individual state to the national anthropogenic SO 2 emission inventory . This prong of the network design is intended to allow a portion of the overall required monitors to be placed where needed, independent of the PWEI, inside or outside of CBSAs. EPA proposes to require monitors, using states as the geo graphic unit for allocation purposes, in proportion to a state’s SO 2 emissions, i.e., a state with higher emissions will be required to have a proportionally higher number of monitors. The proposed percent contribution of individual states is based on the most recent National Emissions Inventory , with SO 2 emissions being aggregated b y state. Each one percent (after rounding) would correspond to one required monitor. Further, EPA proposes that each state have at least one monitor required as part of this second prong, even if a particular state contributes less than 0.5% of the total anthropogenic, non

- fire national emissions inventory

. In addition to the two prongs of the proposed SO 2 network design, we propose that the Regional Administrator will have discretion to require monitoring above these minimum requirements under prongs 1 and 2, as necessary to address situations where the minimum monitoring requirements are not sufficient to meet monitoring objectives noted above. EPA recognizes that the minimum required monitors in the proposed network design under the two prongs described above are based on indicators that may not provide for all the monitoring that may be necessary

in an area. EPA anticipates that there will likely be a need for capital fun ding to allow for up to two

thirds of the minimally

required monitors to be established as new monitoring sites or cause some existing sites to be relocated under the proposed network design. The establishment costs of monitoring sites can include property access or leasing fees, power and telecom services, site securit y, a climate controlled monitoring shelter, pollutant analyzers, supporting quality assurance hardware and consumables, and data collection and dissemination hardware and software. EPA has a lso proposed the requirement that State and local air quality management agencies shall report the 1

- hour average and the maximum 5

- minute average concentration of the twelve 5

- minute block averages in each hour. The requirement to report the maximum 5

- mi nute3

average that exist in an hour impose an increased burden by increas ing the data quality assurance and validation workload and by through increased data processing in the field , which may not be a large burden for those S tate and local agencies utilizi ng digital data acquisition methods

. EPA and others (e.g., State and local air quality management agencies, environmental groups, academic institutions, and industrial groups) use the collected monitoring data for man y purposes. Some of the more promine nt uses include informing the public and other interested parties of an are a’ s air quality , judging an area = s (e.g., count y, city , neighborhood) air quality in comparison with the established health or welfare standards (including both national and local s tandards), evaluating an air quality management agency ’ s progress in achieving or maintaining air pollutant levels below the national and local standards, developing and revising State Implementation Plans (SIPs) in accordance with 40 CFR part 51, evaluati ng air pollutant control strategies, developing or revising national control policies, providing data for air quality model development and validation, supporting enforcement actions, documenting episodes and initiating episode controls, air quality trends assessment, and air pollution research. The State and local air quality management agencies with responsibility for reporting ambient air quality

data and information as requested in this I CR submit these data electronicall y to the EPA ’ s Air Quality

Sy st em (AQS) and AIRNow databases. Quality assurance/quality control records and monitoring network documentation are also maintained by each State and local agency , in AQS electronic format where possible. Although the State and local air qualit y management agencies are responsible for the operation of the air monitoring networks, the EPA funds a portion of the total costs through federal grants. Some of these grants require an appropriate level of contribution, or match , from the State/local air quality m anagement agencies. The costs shown in this ICR are the total costs incurred for the monitoring program regardless of the source of the funding. For the purpose of this ICR, we have estimated the maximum potential burden for the options being consider ed. The I CR estimates for the final rule will present the burden estimate based on the requirements contained in the final rule. The burden estimates are for the 3

- ye ar period of 201 1 through 201 3

. This Information Collection is estimated to involve 93 respondents for a total approximate cost of $ 13,8 63 , 950 (total capital, and labor and non

- labor operation and maintenance) and a total burden of 172, 449 hours. The labor costs associated with the se hours is $ 9,24 7, 885 . Included in the $ 13,8 6 3, 950 total ar e other costs of non

- labor operations and maintenance of $ 903,787 and equipment and contract costs of $ 3,712,278 . In addition to the costs at the State and local air quality management agencies, there is a burden to EPA of total of 5,431 hours and $ 382,78 6

. 2. Need for and Use of the Collection (a) Need/Authority for the Collection4

The information requirements included within this I CR are necessary to provide the EPA with ambient air quality

surveillance data to determine the United States air quality status, to make attainment decisions with respect to the NAAQS, to assist in developing necessary control strategies to ensure attainment of the NAAQS, to assess national trends in air pollution, to inform the public of air quality, and to determine the p opulation ’ s exposure to various ambient air pollutants. The EPA ’ s goal of attaining the NAAQS in all areas of the United States is directly dependent upon the availability of ambient air quality

data requested in this information collection. Additionally , the EPA, State, and local air quality management agencies, environmental groups, industrial groups, and academic organizations use these data to study atmospheric chemistry , e.g., the formation and fate of S O 2 , to determine the most appropriate and effec tive control strategies necessary to reduce air pollution. The principal legal authority for this information collection is the Clean Air Act 42 U.S.C. 7403, 7410, and 7511a, from which the 40 CFR part 58 regulations were promulgated. Under 7403 (c), the Administrator is required to conduct a program of research, testing, and development of methods for sampling, measurement, monitoring, analysis, and modeling of air pollutants, specifically including a requirement to establish a national network to monito r, collect, and compile data with quantification of certainty in the status and trends of air emissions and air qualit y. This program will also include the development of improved methods and technologies to increase understanding of the sources of nitrog en oxides , its formation, transport, regional influences and trends, and interactions with other pollutants. Section 7410 (a) contains the SIP requirements, which include a requirement that each State submit a SIP that provides for the establishment and operation of appropriate devices, methods, sy stems, and procedures necessary to monitor, compile, anal yz e, and make available to the Administrator data on ambient air quality

. 2(b ) Practical Utility/Users of the Data The EPA Office of Air Quality Planning and Standards (OAQPS) uses the ambient air quality data included within this collection to make attainment decisions with respect to each air pollutant subject to NAAQS. For those areas that do not attain the NAAQS for one or more pollutants, the OA QPS, the affected EPA Regional Office, and the affected State or local air quality management agency

will work to develop an appropriate SIP to address how the area = s air quality

can be improved to meet the applicable NAAQS. To identify

how the nation is progressing in improving air quality , the OAQPS prepares annually the National Air Quality and Emissions Trends report (http://www.epa.gov/airtrends) using the ambient air quality data collected through this I CR. The State and local air qualit y management agencies use these data for multiple purposes including tracking their progress toward achieving and maintaining air quality within the established NAAQS and any statewide standards they

have established. For example, the State of California has establis hed a separate statewide ozone air quality standard that is more stringent than the NAAQS for ozone; therefore, they use ambient air data to determine compliance with both standards.5

3. NON
- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a ) Non
- duplication This collection is not unnecessarily duplicative of information otherwise reasonably accessible to the agency . The AQS and AIRN o w sy stems, which contain information based solely on this collection, are the onl y national air quality data repositories available to the EPA. The ambient air quality

surveillance data and related information collected through this information collection are not otherwise reasonably accessible to the EPA. A few State and local air quality management agencies have their own data storage sy stems (e.g., the California Air Resources Board); however, most State and local air qualit y management agencies use the AQS and AIRNow as their primary repositories for all air quality data. 3(b ) Public Notice Required Prior to ICR Submission to OMB The 1995 Paperwork Reduction Act requires that any agency developing a non

- rule related ICR must solicit public comments for a 60

- day period prior to submitting the I CR to OMB. This section is not applicable to this I CR because this is a rule

- related I CR. 3(c ) Consultations Through the course of planning, monitoring, and improving upon this collection and its associated regulation, the EPA regularl y consults with affected State and local air qualit y manage ment agencies through various methods including the regulatory process, regular meetings, and training courses. The EPA conducts annual work shops and training on the AQS reporting s ys tem, e.g., the annual AQS Conferenc e. The EPA Regional Offices conduct annual ambient air monitoring meetings with their affected State and local air quality management agencies to assist these affected agencies with this collection and its a ssociated regulation. The EPA’s OAQPS also meets regularl y with leading State and l ocal air monitoring managers to discuss the N ation’s ambient air monitoring program and this collection, via large monthl y phone calls and smaller in person meeting two or three times per ye ar. Starting in 1999, the Clean Air Scientific Advisory

Committee (CASAC) established the subcommittee on fine particle monitoring to provide advice to EPA on various implementation aspects of the PM monitoring networks. In addition, CASAC also has established a monitoring strategy subcommittee to extend consultation t o the entire network

. 3(d ) Effects of Less Frequent Collection State and local air quality management agencies would collect and report ambient air quality data without the 40 CFR 58 regulations associated with this collection. Sanctions do not automat ically

accrue to State or local air quality management agencies that fail to meet these requirements. The 40 CFR part 58 regulations and this associated collection do provide for a consistent sy stem for reporting and record keeping that would not exist wi thout these6

requirements. The effects of less frequent collection include:

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

• Less timel y attainment designations with respect to the NAAQS;

• More difficult ly

in identifying and repairing problems with an ambient air monitor

-- i.e., data are used as to check a monitor’s operating condition, and reporting data less frequentl y would delay

a State or local agency ’s ability to recognize a problem with a monitor or a laboratory

procedure; and

• The EPA would not be able to consistently answer questions from the public in a timely fashion regarding air quality in various areas of the country

. 3(e ) General Guidelines All of the OMB ’ s general guidelines for information collections in 5 CFR 1320.6 are met by this ICR. None of the guidelines are exceeded.

• Data reporting on a quarterly basis is the requirement. Nearl y all respondents voluntarily

report on a monthly

basis.

• Record retention is for no more than 3 years (most records are kept by the EPA data repository , not the affected State and local air quality management agencies)

• In formation is maintained and reported in the standardized electronic AQS format. 3(f ) Confidentiality In formation that is considered personal, private, proprietary , or confidential is not required for this collection. One purpose of collecting ambient air data through AQS and AIRNow is to inform the public of general air quality in ambient air (air consider ed generall y accessible to the public), and as such, does not present a need for maintaining a confidential nature. Security

measures are taken to prevent tampering with the AQS electronic database b y limiting the access to the AQS mainframe onl y to autho rized users 3(g ) Sensitive Questions This section is not applicable to this I CR because no information involving matters of a sensitive nature is collected. 4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4(a ) Respondents /SIC C odes7

This I CR affects State and local governments (SIC code 951, Administration of Environmental Quality

Program) that are currently operating and maintaining established ambient air quality

networks. The 40 CFR part 58 regulations associated with this r equest require that State and local air quality management agencies conduct the ambient air quality surveillance and report the data to the EPA ’ s AQS. Although industrial, environmental, and research organizations may use the data available through the AQ S, they are not required to report an y information for this information collection. Data submittal to AIRNow is voluntary for all organizations, but most State and local agencies reporting to AQS also report to AIRNow. 4(b ) Information Requested (i ) Da ta items, including record keeping requirements These data items are submitted electronicall y to EPA ’ s AQS as required b y 40 CFR part 58. Th e se data are stored electronically within the EPA ’ s AQS, and separate records kept b y the State or local air qua lity management agency are not required

.

• Hourly and sub

- hourl y (5

- minute) ambient air pollutant concentrations of S O 2 collected at SLAMS /PAMS sites.

• Precision and accuracy data for all SLAMS sites, PAMS, and Special Purpose Monitors (SPM).

• SLAMS m onitoring network description information, including the site AQS identification number, site location, sampling and anal ys is method, operating schedule, monitoring objective, site ’ s scale of representation, identity of the urban area represented, and qual ity assurance plan.

• Results of the annual ambient air monitoring network and quality assurance plan review.

• Annual SLAMS summary report which includes the location, date, pollution source, and duration of each incident of air pollution during which ambient levels of a pollutant reached or exceeded the significant harm levels as defined in 40 CFR 51.151, the certification of the report ’ s accuracy by a designated State air pollution control officer, and various other summary statistics as provided b y th e AQS sy stem.
( ii) Respondent Activities A model respondent would engage in the following activities to comply with this information request:

• Read the 40 CFR part 58 regulatory provisions and other EPA guidance (for example, please reference our Internet site at www.epa.gov/ttn/amtic.)8

• Plan ambient air monitoring activities, such as developing a quality assurance plan for the network operation and maintenance, developing and reviewing the ambient air quality surveillance network design, planning where to locate sites, plan how to maintain and operate each site, develop a data reporting and validation plan.

• Write the quality

assurance plan for network operation and maintenance, the ambient air quality

surveillance network plan, and the data repo rting and validation plan. Submit these plans to the EPA Regional or Headquarters office for review, and approval if appropriate.

• Obtain on

- site leases or agreements to locate ambient air quality surveillance equipment.

• Investigate vendors, and proc ure equipment necessary to meet the ambient air quality network plan.

• Receive training for site operation and maintenance, quality assurance procedures, and data processing and reporting.

• Make arrangements for appropriate utility hookups for each amb ient air quality surveillance site, i.e., electricity , telephones, data lines for electronic submission of concentrations from automated anal yz ers.

• Install ambient air quality surveillance equipment and equipment shelter. Ensure securit y of the site.

• Conduct ambient air quality monitoring, incorporating all appropriate quality assurance procedures such as calibrations, precision and accuracy checks, and, if necessary , concurrent monitoring.

• Validate the ambient air data for quality assurance consi derations.

• Electronicall y submit the complete and validated ambient air data to the AQS and/or AIRNow data repositories.

• Prepare and submit to EPA annuall y the SLAMS sites summary report. Each of these activities are conducted using existing repor ting and recordkeeping practices, including electronic submittal to the AQS and to AIRNow . If the 40 CFR part 58 regulations did not exist, and presumabl y the related AQS and AIRNow, the quality assurance procedures, and the siting guidance did not exist , the State and local air quality management agencies would in a majority of cases conduct monitoring; however, methods used by each agency would vary

and data would not be readily available to EPA and the public. The influence of the 40 CFR part 58 regul ations has been to provide a nationall y consistent mechanism for collecting ambient air quality data including uniform quality assurance procedures, data9

collection and storage mediums (AQS), and uniform methodology . Without this regulations and associate d ICR, managing and maintaining a national air quality program would be extremely difficult, if possible.

5. THE INFORMATION COLLECTED
-- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 5(a ) Agency Activities The EPA conducts the following activities to implement this I CR and associated regulation:

• Periodically

review the 40 CFR part 58 regulations to update the information collection and monitoring requirements in light of new technological developments or new air pollutant st andards. Develop revisions to the regulations in response to legislative action and program changes.

• Establish, maintain, and support the AQS and AIRNow as the national repositories for all State and local air quality management agency

ambient air qual ity

data and monitoring information. Periodically evaluate and improve upon this sy stem as new technologies, and new regulatory requirements would dictate.

• Answer respondent (generally State and local air quality management agencies, but also industria l organizations, environmental groups, and others) questions about ambient air monitoring, the 40 CFR part 58 regulatory requirements, and the AQS and AIRNow. This includes the establishment of the Ambient Monitoring Technology

Information Center bulletin board, the AQS toll

- free hotline, and other written or verbal communication.

• Support the quality

assurance program b y working within the EPA and with the respondents to evaluate precision and accuracy data, oversee the National Performance Audit Program, participate in s ys tems audits, and conduct data validation checks on the AQS data submittal.

• Provide within the AQS mechanisms for statistical calculations, such as the number of times a particular ambient air quality monitoring site exceeds the NAAQ S. Distribute the AQS data in various way s including upon written request, by Freedom of Information Act request, by press release, and in the annual National Air Quality and Emissions Trends Report.

• Provide adequate electronic storage space within th e AQS for all ambient air quality surveillance data and information.

• Provide various reports and graphics for users of AIRNow.10

5(b ) Collection Methodology and Management All State and local ambient air monitoring networks have access to and use well

established quality

assurance procedures as defined in the Quality Assurance Handbook for Air Pollution Measurement Sy stems, Volumes I and II, EPA/600/R

- 94/038a & b. These documents ensure that all ambient air quality data are accurate and reliable. Th e EPA has provided and will continue to provide resources for the maintenance and operation of the AQS and AIRNow national data repositories. All data required by this collection are submitted electronically to reduce the burden of the collection and to i mprove data quality , agency

efficiency , and responsiveness to the public. Various statistical and graphical summaries are also provided by the AQS and AIRNow sy stems which enhance the utility of the information for consumption by the public and all affect ed State and local air quality management agencies. In submitting ambient air data into the AQS and AIRNow national repositories, we ensure that the data are publicl y available, electronicall y stored, and electronically

retrievable. State and local air quality management agencies and the EPA have been submitting data to the AQS since its inception in 1987. 5(c ) Small Entity Flexibility This collection contains a minimum amount of information in order to manage the air quality program for the United States. The smallest entities affected b y this collection are local air quality

management agencies, t ypicall y consisting of the governing agencies for a county or group of counties, or a smaller metropolitan area (e.g., cities with a population of 50,000 ). This collection reduces to the extent practicable and appropriate the burden on entities that provide ambient air quality

data and information to or for the EPA, including with respect to small entities, as defined in the Regulatory Flexibility

Act (5 U.S .C. 601(6)), the use of such techniques as:

• Establishing differing compliance or reporting requirements or timetables that account for the resources available to those who are to respond (e.g., the monitoring and reporting requirements decrease as the p opulation of an area decreases, and various timetables for deploying ambient air monitoring stations are negotiated between the affected State or local air quality management agency

and the EPA with consideration of the respondent ’ s resources);

• Clarif ication, consolidation, or simplification of compliance and reporting requirements (e.g., b y establishing, maintaining, and improving as needed the AQS and AIRNow national repositories for ambient air quality data and information);

• Exemption from covera ge of the collection of information, or any part thereof (e.g., the EPA negotiates with State and local air quality management agencies to determine the most effective and most efficient ambient air quality networks with respect to the monitoring needs, te chnical abilities, and resources available to each affected agency).11

5(d ) Collection Schedule Ambient air quality

surveillance data and precision and accuracy data for criteria air pollutants are submitted according to the schedule defined in 40 CFR 58.1 6. These current regulations require that State and local air quality management agencies report their data within 90 day s after the end of the quarter during which the data were collected. The annual SLAMS report is submitted by May 1 (effective 2010) of each year for data collected from January

1 through December 31 of the previous year in accordance with 40 CFR 58.15. This certification applies to all SLAMS and all SPM monitoring data that have been submitted by May 1. The annual air quality

surv eillance network reviews are conducted and reports are submitted to the EPA on a schedule that is determined by the affected State or local air quality management agency

and the EPA Regional Office. Ambient air quality

data and information are made avai lable to the public at any time in various way s, including:

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

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

• From the State or local ai r quality management agency

responsible for collecting the ambient air quality

data and information;

• By obtaining access, through appropriate EPA channels, to the AQS and AIRNow to obtain the data electronically ;

• Through EPA public reports, such as the annual A National Air Qualit y and Emissions Trends Report @ ; or

• Through the AIRNow data base and the AQI reporting mechanisms which include newspaper, television, Internet and other publicly available notices (see www.epa.gov/airnow).

6. ESTIMATI NG THE BURDEN AND COST OF THE COLLECTION 6(a ) Estimating Respondent Burden All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are presented in Worksheet 1. The detailed burden and cost estimates for the different types of monitors are12

based on information provided in the updated version of Guidance for Estimating Ambient Air Monitoring Costs for Criteria Pollutants and Selected Air Toxic Pollutants (prepared b y Desert Research Institute for the EPA Office of Air Quality Planni ng and Standards, Air Quality Assessment Division, Ambient Air Monitoring Group, January 2005). The cost estimates presented in this guidance document are based on existing literature and direct monitoring experience. The costs for equipment and supplies were verified with vendors. The monitoring costs are based on vendor quotes for the monitor ty pe that EPA expects respondents to use to comply with the requirements

. Costs for level of effort estimates are verified with selected State and local agencies . All cost values presented in the guidance document are adjusted to 2004 dollars. For use in preparing the burden estimates for this ICR, costs for the monitoring requirements were inflated to 20 1 1 , 201 2 , and 201 3

. The cost escalation factors were e stimated based on the appropriate Gross Domestic Product (GDP) price indices as reported in the report available at http://www.jsc. nasa.gov/bu2/inflateGDP.html . Tables showing the detailed burden estimate calculations are presented below . A summary of the average annual respondent burden costs follows. Worksheet 1: Annual Average Respondent Burden Estimates

Collection Activities Total Labor Hours Per Respondent Per Year ( 93 respondents) 1. Network design 6 2. Site i nstallation 14 3. Sampling & anal ys is 504 4. Maintenance & repairs 285 5. Data management 491 6. Quality

assurance 334 7. Supervision 220 8. Meteorological Instrumentation 0

TOTAL 1854

6(b ) Estimating Respondent Costs All activities liste d with section 4 (b) (ii) of this ICR Supporting Statement are included in the Worksheet 2 . A summary of the average annual respondent burden costs follows.13 Worksheet 2: Annual Average Respondent Cost Estimates

Collection Activities Total Labor Cost Pe r Respondent Per Year ( 93 respondents) 1. Network design $ 363 2. Site installation $ 617 3. Sampling & anal ys is $ 25,388 4. Maintenance & repairs $ 15,310 5. Data management $ 26,134 6. Quality

assurance $ 18,590 7. Supervision $ 13035 8. Meteorological Instrumentation $ 0

TOTAL $ 99, 437

6(c ) Estimating Agency Burden and Cost We estimated the Agency burden and cost by using current burden and cost of the ambient air monitoring program related to this collection. We included burden and cost f or the OAQPS, the ten Regional Offices, and associated contract activities. The in

- house activities for this collection are completed b y a variet y of individuals with a variety of salaries; therefore, we used the actual salary

as an average for computing the program costs. Actual contractor expenses were used for those activities completed using extramural resources. We estimated a total of 14,147 hours and $ 858,280 total agency burden. 6(d) Estimating the Respondent Universe and Total Burden and Costs Worksheet 3 shows the total respondent hourl y burdens and costs which was taken from section 6(b) above for the estimated 93 respondents. The total labor burden for the respondents was estimated to be 172,449 hours at a total cost of $ 9,247,885

.14 Worksheet 3: Annual Total Respondent Labor Burden/Cost Estimates
Collection Activities Total Labor Hours Per Year Total Labor Cost Per Year 1. Network design 532 $ 33,796 2. Site installation 1,337 $ 57,396 3. Sampling & anal ys is 46,904 $ 2,361,123 4. Maintenance & repairs 26,520 $ 1,423,837 5. Data management 45,637 $ 2,430,494 6. Quality

assurance 31,044 $ 1,728,939 7. Supervision 20,475 $ 1,212,300 8. Meteorological Instrumentation 0 0

TOTAL 172,449 $ 9,247,885

6(e ) Bottom Line Burden Ho urs and Cost Tables (i ) Respondent Tally Respondent Total Annual Burden = 172,449 hours Respondent Total Annual L abor Cost for O & M = $ 9,247,885 Respondent Total Annual Cost for Non

- labor O & M = $ 903,787 Respondent Total Equipment/Contract Dollars = $ 3,712,278 Total Respondent Tally

= $ 13,863,950 (ii) The Agency Tally Agency Total Annual Burden = 14,147 hours Agency Total Annual Cost = $ 858,280 (iii) Variations In The Annual Bottom Line

. We do not expect any

significant variations in the annual bottom line for the ambient air monitoring networks for the clearance period requested.15

6(f ) Reasons for Change in Burden N/A 6(g ) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimat ed to average 193 hours per respondent. 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 sy stems 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 an y 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 infor mation. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 4 8 CFR chapter 15.
To allow comment on the Agency's need for this information, the accuracy of the provided burden estimates, and an y suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA establishe d a public docket for this ICR under Docket ID No. OAR

- 2008

- 0338 which has been available for public viewing at the Air and Radiation Docket and Information Center Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, W ashington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Air and Radiation Docket and In formation Center Docket is (202) 566

- 1742. An electronic version of the public docket was made available through EPA Dockets (EDOCKET) at http://www.epa.gov/edocket

. The public was able to u se EDOCKET to submit or view public comments, acce ss the index listing of the contents of the public docket, and to access those documents in the public docket that have been available electronically

. The public was also advised to send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA.

PART B OF SUPPORTING STATEMENT
This section is not applicable to this I CR because statistical methods are not used in the data collection associated with the rule amendments

.