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Supporting Statement

Restructuring of the Stationary Source Audit Program

EPA ICR # 2355.01

PART A

1. Identification of the Information Collection

 (a) Title of the Information Collection

 “Restructuring of the Stationary Source Audit Program”

(b) Short Characterization/Abstract

This final rule will allow accredited private audit sample providers to supply regulated 

emission sources with audit samples to verify the results of emissions testing that demonstrates 

compliance with emission limits. A regulated emission source conducting a compliance test, 

would purchase an audit sample from an accredited audit sample provider(AASP). The AASP 

would report the true value of the audit sample to the compliance authority (State, local or EPA 

Regional Office). This is a new reporting requirement. The AASP would in most cases make 

the report by electronic mail. A report would be made for each audit sample that the AASP sold 

to a regulated emission source that was conducting an emissions test to determine compliance 

with an emission limit. Based on historic data, EPA estimates that there will be about 832 audit 

samples sold each year generating the need for about 832 reports. 

2. Need for and Use of the Collection

(a) Need/Authority for the Collection

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

that the restructured audit sample program is operating in a way that protects the integrity of the

audit samples. The integrity of an audit sample depends on its being distributed as a “blind 

sample.” This means that the true value of the audit sample is known by the provider but not the 

user. The flow of information about the audit sample in the current program is slightly different 

than that of the restructured program. In the current system, EPA supplies the audit sample to 

the appropriate compliance authority who then gives it to the user. After measuring the audit

sample, the user reports the result to the compliance authority who then reports it to EPA and 

receives the true value in return. In the restructured program, the accredited audit sample 

provider (AASP) supplies the audit sample to the user. Just as in the current program, the user 

reports the measured result to the appropriate compliance authority an to the AASP. The 

restructured program then requires the AASP to report the true value of the sample to the 

compliance authority before or at the same time as the true value is reported to the user. This is a 

new reporting requirement that does not exist under the current program. This requirement is 
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necessary to help the compliance authority insure that the audit samples are provided as blind 

samples to the user.

The principal legal authority for this information collection is 23 U.S.C. § 101 and 42

U.S.C. ' 7410-7671q.

2(b) Practical Utility/Users of the Data

Local, State and EPA regional offices who have been delegated authority to enforce 

emission limits will use the data from the audit samples to assure that regulated sources are 

correctly measuring their pollutant emissions when they perform compliance tests. The results 

from the audit samples are an objective measure of testing performance during a compliance test. 

If the emissions tester produces results that are within the allowable range for the audit sample, 

the compliance authority has objective evidence to show that the tester‘s performance was within 

the normal range for a well qualified tester.

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 compliance authorities. There is no other source for this information.

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

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

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

OMB. This section is not applicable to this ICR because this is a rule-related ICR.

3(c) Consultations

Through the course of planning this collection and its associated regulation, the EPA 

regularly consulted with affected AASPs, and State and local compliance authorities through 

regular public meetings. 

3(d) Effects of Less Frequent Collection

The reporting under this information collection is event driven. There is no regular 

schedule for reporting. Information is collected only when an audit sample is supplied to a user 

during a compliance test. A report must be submitted for each event. 

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.
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• There is no data reporting schedule.

• There is no requirement to retain records for more than three years.

3(f) Confidentiality

Information that is considered personal, private, proprietary, or confidential is not 

required for this collection. 

3(g) Sensitive Questions

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

sensitive nature is collected.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes

This ICR affects laboratories that supply audit samples. The SIC is 8734.

4(b) Information Requested

AASPs must report to the appropriate compliance authority the true value of any audit 

sample supplied for quality assurance purposes to a regulated emission source or the source’s 

authorized representative for use during a compliance test. The AASP must also maintain for 

three years a record of the recipient of the sample, the date the sample was provided, and the true 

value of the sample.

(i) Data items, including record keeping requirements

Audit sample number;

Name of the recipient of the sample; and

True value of the sample.

(ii) Respondent Activities

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

information request:

▪ Produce an audit sample and verify it’s true value.

▪ Ship the audit sample to the source that is conducting a compliance test.

• Generate an electronic message showing the audit sample number, the sample 

recipient’s name, and the true value of the sample.
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• Transmit the message electronically to the appropriate compliance authority.

• Record electronically the audit sample number, the sample recipient’s name, the date 

the sample was shipped, and the true value of the sample.

Each of these activities is part of the customary and usual business practice (CBP) of the 

AASP because the same information must be provided to the recipient of the audit sample. 

Development of the database and system to handle the recordkeeping and reporting are attributed 

to the CBP of the AASP. The activities related to the ICR are only the incremental activity 

needed to produce and distribute the audit sample and to transmit a copy of the results of the 

audit sample to the appropriate compliance authority.

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

There are no EPA activities associated with this ICR.

5(b) Collection Methodology and Management

The information will be collected and used by the appropriate compliance authority for 

each regulated source. The AASP will submit the report using the procedures described in a 

publicly available technical criteria document (TCD). The TCD must be developed by a public 

process through a consensus making body. The consensus making body will select a third party

accreditor who will be responsible for insuring that all AASPs operate in accordance with the 

procedures in the technical criteria document.

5(c) Small Entity Flexibility --

This collection requires submittal of the minimum amount of information in order to 

insure that the restructured stationary source audit program continues to operate in a credible 

manner. This collection reduces to a practicable and appropriate level the burden on any small 

entities that are AASPs. 

5(d) Collection Schedule

There is no regular schedule for collecting information. The information is event driven 

and information is collected only when an AASP supplies an audit sample to a user.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden
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All activities listed with section 4 (b) (ii) of this ICR Supporting Statement are presented 

in Worksheet 1. 

Tables showing the detailed burden estimate calculations are presented below. A 

summary of the average annual respondent burden costs follows. The burden for this ICR is 

limited to the incremental activity required to provide a copy of the information generated for the 

audit sample user to the appropriate compliance authority. All the labor expended on behalf of 

this ICR will be expended by the AASPs. However, they will not bear the burden of the ICR 

costs. Their labor costs will be passed to the stationary sources who are required to demonstrate 

compliance with pollutant emission limits and must purchase audit sample as part of the 

demonstration. There are estimated to be a very limited number (a maximum of nine) AASPs 

who will supply the audit samples, but there will be many stationary sources who will buy them. 

The following estimates are believed to be an accurate estimate for each respondent, but the 

actual costs of the respondents will be paid by an estimated 504 stationary sources so that the 

actual cost per stationary source will be on average about $398.66.

Worksheet 1: Annual Average Respondent Burden Estimates

Collection

Activities

Total Labor Hours

Per Respondent Per Year

(9 respondents)

1. Prepare audit samples 136

2. Verify audit sample concentration 95

3. Distribute audit samples 53

4. Generate and transmit audit sample report 7

5. Record audit sample results 4

TOTAL 294

6(b) Estimating Respondent Costs

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

in the Worksheet 2. A summary of the average annual respondent burden costs follows.
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Worksheet 2: Annual Average Respondent Cost Estimates

Collection

Activities

Total Labor Cost 

Per Respondent Per Year 

(9 respondents)

1. Prepare audit samples $10,170

2. Verify audit concentration $8,058

3. Distribute audit samples $3,432

4. Generate and transmit audit sample report $416

5. Record audit sample results $249

TOTAL $22,325

6(c) Estimating Agency Burden and Cost

We estimated the Agency burden and cost to be zero.

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

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

section 6(b) above for the estimated 9 respondents. The total labor burden for the respondents 

was estimated to be 2646 hours at a total cost of $201,091.

Worksheet 3: Annual Total Respondent Labor Burden/Cost Estimates

Collection

Activities

Total Labor Hours

Per Year

Total Labor Cost

Per Year

1. Prepare audit sample 1220 $91530

2. Verify audit sample concentration 853 $72522

3. Distribute audit samples 475 $30888

4. Generate and transmit audit sample report 62 $3906

5. Record audit sample results 36 $2245

TOTAL 2646 $201091

6(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

Respondent Total Annual Burden =294 hours
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Respondent Total Annual Labor Cost = $22,325.

(ii) The Agency Tally

Agency Total Annual Burden = 0 hours

Agency Total Annual Cost = $0.0

(iii) Variations In The Annual Bottom Line.

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

period requested.

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 estimated to average 245 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 systems for the purposes of collecting, 

validating, and verifying information, processing and maintaining information, and disclosing 

and providing information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

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

person is not required to respond to, a collection of information unless it displays a currently

valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 

CFR part 9 and 48 CFR chapter 15. 

To allow comment on the Agency's need for this information, the accuracy of the 

provided burden estimates, and any suggested methods for minimizing respondent burden, 

including the use of automated collection techniques, EPA established a public docket for the 

rulemaking that includes this ICR under Docket ID Number EPA-HQ-OAR-2008-0531 which is

available for online viewing at http://www.regulations.gov, or in person viewing at the Air 

Docket Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution 

Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 

a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for 

the Reading Room is (202) 566-1744, and the telephone number for the Air Docket Center is 

(202) 566-1742. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view public comments, access 

the index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in the 
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Docket ID Number identified above. Also, you may 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. Please include the EPA Docket ID Number EPAHQ-OAR-2008-0531 and OMB Control Number _____-_____ in any correspondence.

PART B OF SUPPORTING STATEMENT

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

data collection associated with the rule amendments.