______________________________________________________________________________ Supporting Statement Ambient Oxides of Sulfur Monitoring Regulations: Revisions to Network Design Requirements

EPA ICR # 2370.02

PART A

1. Identification of th e 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 inform ation are collected by Stat e and local air quality management agencies and reported to the U.S. Environmental Protection Agency (EPA).

The EPA is finalizing the network design re quirements for the oxides of sulfur (SO X ), specifically sulfur dioxide (SO 2 ), to support the revised National Ambient Air Quality Standards (NAAQS) for SO 2

. Presently, state agencies, and local agen cies when delegated by the state, are required to operate minimum numbers of EPA-approved SO 2 monitors based on the population

of each of their Core Based Statisti cal Areas (CBSA) and the amount of SO 2 emissions within

those CBSAs.

EPA is finalizing requirements to require mon itors in CBSAs where there is an increased coincidence of population and SO 2 emissions. The final network design corresponds to the proposal of the new NAAQS based on peak 1-h our daily maximum concentrations, or 1-hour NAAQS, and the associated level of 75 parts per billion (ppb). The introduction of the 1-hour NAAQS and the range of levels are intended to protect against peak, shorter term exposure risks.

In the final SO 2 monitoring network design, EP A has finalized minimum SO 2 monitoring requirements which call for monitors in CBSA ba sed on a Population Weighted Emissions Index (PWEI) that uses population and emi ssions inventory data at the CBSA 1 level to assign required monitoring for a given CBSA (population and em issions being obvious relevant factors in prioritizing numbers of required monitors). Th e PWEI for a particular CBSA is calculated by multiplying the population (using the latest Cens us 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 by aggregating the county level emissi ons for each county in a CBSA as maintained in

1 CBSAs are defined by the U.S. Office of Management and Budget, which are used by the U.S. Census Bureau in providing population information, and are comprised of both Metropolitan Statistical Areas and Micropolitan Statistical Areas ( http://www.census.gov ).2 the latest edition of the National Emissions Invent ory. We then divide the resulting product of CBSA population and CBSA SO 2 emissions by 1,000,000 to provide a PWEI value, the units of which are millions of people-tons per year. Those CBSAs with a PWEI value of 1,000,000 or more are required to operate three monitors within that CBSA. Those CBSAs with a PWEI value between 1,000,000 and 100,000 are required to ope rate two monitors within that CBSA. Those CBSAs with a PWEI value between 100,000 and 5,000 are required to operate one

monitor within that CBSA. In summ ary, EPA estimates that this final SO 2 network design will require 163 monitoring sites in 131 CBSAs, a nd that a large majority of existing SO 2 sites will satisfy these minimum monitoring requirements..

In addition to the minimally re quired monitoring in the final SO 2 network design, EPA finalized that the Regional Administrator will have discretion to require monitoring above the minimum requirements, as necessary to addr ess situations where the minimum monitoring requirements are not sufficient to meet monitori ng objectives. EPA rec ognizes that the minimum required monitors in the final network design de scribed above are based on indicators that may not provide for all the monitoring th at may be necessary in an area.

EPA anticipates that there will likely be a n eed for capital funding for approximately 41 monitors of the minimally require d 163 monitors to be establishe d as new monitoring sites or for relocation of some existing monitors. The estab lishment costs of monitoring sites can include property access or leasing fees, pow er and telecom services, site security, a climate controlled monitoring shelter, pollutant analyzers, supporting quality assurance hardware and consumables,

and data collection and dissemi nation hardware and software.

EPA has also finalized 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-minute average that exist in an hour impose an increased burden by increas ing the data quality assurance and validation workload and by th rough increased data processing in the field, which may not be a large burden for those State a nd local agencies utilizing dig ital data acquisition methods.

EPA and others (e.g., State and local air qua lity management agencies, environmental groups, academic institutions, and industrial groups) use the collected monitoring data for many purposes. Some of the more prominent uses in clude informing the public and other interested parties of an area’s air qualit y, judging an area’s (e.g., county, c ity, neighborhood) air quality in comparison with the established health or welf are standards (including both national and local standards), evaluating an air quali ty management agency’s progre ss in achieving or maintaining air pollutant levels below the national and lo cal standards, developing and revising State Implementation Plans (SIPs) in accordance with 40 CFR part 51, evaluating air pollutant control strategies, developing or revisi ng national control policies, provi ding data for air quality model development and validation, supporting enfo rcement actions, documenting episodes and initiating episode controls, ai r 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 request ed in this ICR submit these data electronically to the EPA’s Air Quality System (AQS) and AI RNow databases. Quality assurance/quality3 control records and monitoring network documen tation are also maintained by each State and local agency, in AQS electronic format where possible.

Although the State and local air quality mana gement agencies are responsible for the operation of the air monitoring networks, the EPA funds a portion of the total co sts through federal grants. Some of these grants require an appropriate level of c ontribution, or match, from the State/local air quality management agencies. The costs shown in this ICR are the total costs incurred for the monitoring program rega rdless of the source of the funding.

For the purpose of this ICR, we have estimated the maximum potential burden for the options being considered. The ICR 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-year period of 2011 through 2013.

This Information Collection is estimate d to involve 102 resp ondents for a total approximate cost of $15,203,762 (total capital, and labor and non-labor operation and maintenance) and a total burden of 207,662 hours. Th e labor costs associated with these hours is $11,130,409. Included in the $15,203,762 total are ot her costs of non-labor operations and maintenance of $1,104,377 and equipment and cont ract costs of $2,968,975. In addition to the costs at the State and local air qua lity management agencies, there is a burden to EPA of total of 14,749 hours and $ 1,060,621.

2. Need for and Use of the Collection

(a) Need/Authority for the Collection

The information requirements included within this ICR are necessary to provide the EPA with ambient air quality surveillance data to determine the Un ited States air quality status, to make attainment decisions with respect to the N AAQS, 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 th e population’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 EP A, State, and local air quality management agencies, environmental groups, industrial groups, and acad emic organizations use these data to study atmospheric chemistry, e.g., the formation and fate of SO 2 , to determine the most appropriate and effective control strategies necessary to re duce air pollution.

The principal legal authority for this info rmation 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, measur ement, monitoring, anal ysis, and modeling of air pollutants, specifically includ ing a requirement to establish a national network to monitor, collect, and compile data with quant ification of certainty in the stat us and trends of air emissions and air quality. This program will also include the development of improved methods and4 technologies to increase understandi ng of the sources of nitrogen oxides, its formation, transport, regional influences and trends, and inte ractions with other pollutants.

Section 7410 (a) contains the SIP requirements, which include a requirement that each State submit a SIP that provides for the estab lishment and operation of appropriate devices, methods, systems, and procedures necessary to m onitor, compile, analyze, and make available to the Administrator data on ambient air quality.

2(b) Practical Utilit y/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 d ecisions with respect to each air pollutant subject to NAAQS. For those areas th at do not attain the NAAQS for one or more pollutants, the OAQPS, the affect ed EPA Regional Office, and th e affected State or local air quality management agency will work to develo p 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 throug h this ICR. The State and local air quality management agencies use these data for mu ltiple purposes including tracking their progress toward achieving and maintaining air quality wi thin the established NAAQS and any statewide standards they have established. For example, th e State of California has established a separate statewide ozone air quality standard that is mo re stringent than the NAAQ S for ozone; therefore, they use ambient air data to determin e compliance with both standards.

3. NON-DUPLICATION, CONSULTATION S, AND OTHER COLLECTION CRITERIA

3(a) Non-duplication

This collection is not unnecessarily duplica tive of information ot herwise reasonably accessible to the agency. The AQS and AIRNow systems, which contain information based solely on this collection, are the only national air quality data repos itories available to the EPA. The ambient air quality survei llance data and related inform ation collected through this

information collection are not otherw ise reasonably accessible to the EPA.

A few State and local air quality management agencies have their own data storage systems (e.g., the California Air Resources Board) ; however, most State and local air quality management agencies use the AQS and AIRNow as their primary repositor ies for all air quality

data.

3(b) Public Notice Required Pr ior to ICR Submission to OMB5 The 1995 Paperwork Reduction Act requires th at 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 th is ICR because this is a rule-related ICR.

3(c) Consultations

Through the course of planning, monitori ng, and improving upon this collection and its associated regulation, the EPA re gularly consults with affected State and local air quality management agencies through various methods including the regulatory process, regular meetings, and training courses. The EPA conduc ts annual work shops and training on the AQS reporting system, e.g., the annual AQS Conferen ce. The EPA Regional Offices conduct annual ambient air monitoring meetings with their aff ected State and local air quality management agencies to assist these affected agencies with this collection a nd its associated regulation. The EPA’s OAQPS also meets regularly with leadin g State and local air monitoring managers to discuss the Nation’s ambient air monitoring prog ram and this collection, via large monthly phone calls and smaller in person mee ting two or three times per year . Starting in 1999, the Clean Air Scientific Advisory Committee (CASAC) esta blished the subcommitt ee 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 to the entire network.

3(d) Effects of Less Frequent Collection

State and local air quality management ag encies would collect and report ambient air quality data without the 40 CFR 58 regulations associated with th is collection. Sanctions do not automatically accrue to State or local air quality management agen cies that fail to meet these requirements. The 40 CFR part 58 regulations a nd this associated collection do provide for a consistent system for reporting and record keeping that would not exist without these requirements. The effects of less frequent collection include:

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

• Less timely attainment designa tions with respect to the NAAQS;

• More difficultly in identifying and repair ing problems with an ambient air monitor-- i.e., data are used as to check a monitor’s operating condition, and reporting data less frequently would delay a State or local agen cy’s ability to recogni ze 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 Guidelines6 All of the OMB’s general guidelines for in formation collections in 5 CFR 1320.6 are met by this ICR. None of the guidelines are exceeded.

• Data reporting on a quarter ly basis is the requirement. Nearly all respondents voluntarily report on a monthly basis.

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

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

3(f) Confidentiality

Information that is considered personal, pr ivate, proprietary, or confidential is not required for this collection. One purpose of collecting ambi ent air data through AQS and AIRNow is to inform the public of general air qu ality in ambient air (air considered generally accessible to the public), and as such, does not present a need for maintaining a confidential nature. Security measures are taken to preven t tampering with the AQS electronic database by limiting the access to the AQS mainfra me only to authorized users

3(g) Sensitive Questions

This section is not applicab le to this ICR because no info rmation involving matters of a

sensitive nature is collected.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes

This ICR affects State and local governm ents (SIC code 951, Administration of Environmental Quality Program) that are curre ntly operating and maintaining established ambient air quality networks. The 40 CFR part 58 regulations associated with this request require that State and local air quality management agenci es conduct the ambient air quality surveillance and report th e data to the EPA’s AQS. Although industrial, environmental, and research organizations may use the data ava ilable through the AQS, they are not required to report any information for this information colle ction. Data submittal to AIRNow is voluntary for all organizations, but most State and local ag encies reporting to AQS al so report to AIRNow.

4(b) Information Requested

(i) Data items, including record keeping requirements

These data items are submitted electronically to EPA’s AQS as required by 40 CFR part

58. These data are stored electronically within the EPA’s AQS, and separate records kept by the State or local air quality manage ment agency are not required.7 • Hourly and sub-hourly (5-minute) ambi ent air pollutant concentrations of SO 2 collected at SLAMS/PAMS sites.

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

• SLAMS monitoring network description information, including the site AQS identification number, site location, sampling and analysis method, operating schedule, monitoring objective, site’s scale of representation, identity of the urban area represented, and qu ality assurance plan.

• Results of the annual ambient air monito ring network and quality assurance plan

review.

• Annual SLAMS summary report which includ es the location, date, pollution source, and duration of each incident of air po llution during which ambient levels of a pollutant reached or exceeded the signifi cant harm levels as defined in 40 CFR 51.151, the certification of the report’s accur acy by a designated State air pollution control officer, and various other summary statistics as provided by the AQS system.

(ii) Respondent Activities

A model respondent would engage in the fo llowing activities to comply with this information request:

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

• Plan ambient air monitoring activities, su ch as developing a quality assurance plan for the network operation and maintenance, developing and reviewing the ambient air quality surveillance network design, planni ng where to locate sites, plan how to maintain and operate each site, devel op a data reporting and validation plan.

• Write the quality assurance plan for netw ork operation and maintenance, the ambient air quality surveillance netw ork 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 procure equipment necessary to meet the ambient air quality network plan.8 • Receive training for site operation and ma intenance, quality assurance procedures, and data processing and reporting.

• Make arrangements for appropriate u tility hookups for each ambient air quality surveillance site, i.e., electr icity, telephones, data lines for electronic submission of concentrations from automated analyzers.

• Install ambient air quality surveillance e quipment and equipment shelter. Ensure security of the site.

• Conduct ambient air quality monitoring, in corporating all appropriate quality assurance procedures such as calibrati ons, precision and accuracy checks, and, if necessary, concurrent monitoring.

• Validate the ambient air data for quality assurance considerations.

• Electronically submit the complete and valid ated ambient air data to the AQS and/or AIRNow data repositories.

• Prepare and submit to EPA annually the SLAMS sites summary report.

Each of these activities are conducted using existing reporting and recordkeeping practices, including electronic submittal to the AQS and to AIRNow . If the 40 CFR part 58 regulations did not exist, and presumably 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 regulations has been to provide a nationally consistent mechanism for collecting ambient air quality data including uniform quality assurance procedures, data collection and storage mediums (AQS), and unifo rm methodology. Without this regulations and associated ICR, managing and maintaining a na tional 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 ICR and associated regulation:

• Periodically review the 40 CFR part 58 regulations to update the information collection and monitoring requirements in light of new technological developments or new air pollutant standards. Develop re visions to the regula tions in response to legislative action and program changes.9 • Establish, maintain, and support the AQS and AIRNow as the national repositories for all State and local air quality manageme nt agency ambient air quality data and monitoring information. Periodically evalua te and improve upon this system as new technologies, and new regulatory requirements would dictate.

• Answer respondent (generally State and local air quality management agencies, but also industrial organizations, environmen tal groups, and others) questions about ambient air monitoring, the 40 CFR part 58 regulatory requirements, and the AQS

and AIRNow. This includes the estab lishment of the Ambient Monitoring Technology Information Center bulletin boa rd, the AQS toll-free hotline, and other

written or verbal communication.

• Support the quality assura nce program by working with in the EPA and with the respondents to evaluate precision and accuracy data, oversee the National Performance Audit Program, participate in systems audits, and conduct data validation checks on the AQS data submittal.

• Provide within the AQS mechanisms for st atistical calculations, such as the number of times a particular ambient air qua lity monitoring site exceeds the NAAQS. Distribute the AQS data in various ways including upon written request, by Freedom of Information Act request, by press releas e, and in the annual National Air Quality and Emissions Trends Report.

• Provide adequate electronic storage space w ithin the AQS for all ambient air quality

surveillance data and information.

• Provide various reports and gr aphics for users of AIRNow.

5(b) Collection Methodology and Management

All State and local ambient air monitori ng networks have access to and use wellestablished quality assurance pr ocedures as defined in the Quality Assurance Handbook for Air Pollution Measurement Systems, Volumes I a nd II, EPA/600/R-94/038a & b. These documents ensure that all ambient air quality data are accurate and reliable.

The 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 improve data quality, agency efficiency, and responsiveness to the public. Various statistical and graphical summaries are also provided by the AQS and AIRN ow systems which enhance the utility of the information for consumption by the public a nd all affected 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 publicly available, elect ronically stored, and10 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 smalle st entities affected by th is collection are local air quality management agencies, typically consis ting of the governing agencies for a county or group of counties, or a smaller metropolitan area (e.g., cities with a popu lation of 50,000). This

collection reduces to the extent practicable and appr opriate the burden on en tities that provide ambient air quality data and information to or for the EPA, including with respect to small entities, as defined in the Re gulatory Flexibility Act (5 U.S. C. 601(6)), the use of such techniques as:

• Establishing differing compliance or re porting requirements or timetables that

account for the resources available to thos e who are to respond (e.g., the monitoring and reporting requirements decrease as th e population of an area decreases, and various timetables for deploying ambient ai r monitoring stations are negotiated between the affected State or local air qua lity management agency and the EPA with consideration of the resp ondent’s resources);

• Clarification, consolidation, or simp lification of compliance and reporting requirements (e.g., by establishing, maintain ing, and improving as needed the AQS and AIRNow national repositories for ambient air quality data and information);

• Exemption from coverage 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 need s, technical abilities, and resources available to each affected agency).

5(d) Collection Schedule

Ambient air quality surveillance data and pr ecision and accuracy data for criteria air pollutants are submitted according to the schedu le defined in 40 CFR 58.16. These current regulations require that State a nd local air quality management ag encies report their data within 90 days after the end of the quarter du ring 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 an d all SPM monitoring data that have been submitted by May 1.

The annual air quality survei llance network reviews are conducted and reports are

submitted to the EPA on a schedule that is determin ed by the affected State or local air quality management agency and the EPA Regional Office.11 Ambient air quality data and informa tion are made available to the public at any time in various ways, including:

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

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

• From the State or local air quality manage ment agency responsible for collecting the ambient air quality data and information;

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

• Through EPA public reports, such as the annual “National Air Quality and Emissions Trends Report“; or

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

6. ESTIMATING THE BURDEN AN D 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 es timates for the different types of monitors are based on information provided in the updated version of Guidance for Estimating Ambient Air Monitoring Costs for Criteria Pollutant s and Selected Air Toxic Pollutants (prepared by Desert Research Institute for the EPA Office of Air Quality Planning and Standards, Air Quality Assessment Division, Ambient Air Monitoring Group, January 2005). The cost estimates presented in this guidance document are based on existing literature and direct monitoring experience. The costs for equipment and supplies were verified with vendors. The monitoring costs are based on vendor quotes for the monitor type that EPA expects respondents to use to comply with the requirements. Costs for level of effort estimates are verified with selected State and local agencies. All cost values presented in the guidanc e document are adjusted to 2004

dollars.

For use in preparing the burden estimates for this ICR, costs for the monitoring requirements were inflated to 2011, 2012, and 2013. The cost escalation factors were estimated based on the appropriate Gross Do mestic Product (GDP) price indi ces 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 burden12 costs follows.

Worksheet 1: Annual Average Respondent Burden Estimates

Collection

Activities Total Labor Hours Per Respondent Per Year (102 respondents)

1. Network design 6

2. Site installation 17

3. Sampling & analysis 573

4. Maintenance & repairs 324

5. Data management 493

6. Quality assurance 372

7. Supervision 250

8. Meteorological

Instrumentation 0

TOTAL 2035

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 aver age annual respondent burden costs follows.13 Worksheet 2: Annual Average Respondent Cost Estimates

Collection

Activities Total Labor Cost Per Respondent Per Year (102respondents)

1. Network design $392

2. Site installation $729

3. Sampling & analysis $28,635

4. Maintenance & repairs $17,395

5. Data management $26,353

6. Quality assurance $20,806

7. Supervision $14,811

8. Meteorological

Instrumentation $0

TOTAL $109,121

6(c) Estimating Agency Burden and Cost

We estimated the Agency burden and cost by using current burden and cost of the ambient air monitoring program related to this collection. We included burden and cost for the OAQPS, the ten Regional Offices, and associated contract activities . The in-house activities for this collection are completed by a va riety of individuals with a vari ety of salaries; therefore, we used the actual salary as an average for com puting the program costs. Actual contractor expenses were used for those activities complete d using extramural resources. We estimated a total of 14,749 hours and $1,060,621 total agency burden.

6(d) Estimating the Respondent Un iverse 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 102 responden ts. The total labor burden for the respondents was estimated to be 207,662 hour s at a total cost of $11,130,409.14 Worksheet 3: Annual Total Respondent Labor Burden/Cost Estimates

Collection

Activities Total Labor Hours

Per Year Total Labor Cost

Per Year

1. Network design 628 $39,942

2. Site installation 1,741 $74,379

3. Sampling & analysis 58,424 $2,920,771

4. Maintenance & repairs 33,048 $1,774,320

5. Data management 50,317 $2,688,028

6. Quality assurance 37,990 $2,122,257

7. Supervision 25,515 $1,510,712

8. Meteorological

Instrumentation 0 0

TOTAL 207,662 $11,130,409

6(e) Bottom Line Burden Hours and Cost Tables (i) Respondent Tally

Respondent Total Annual Burden =207,662 hours

Respondent Total Annual Labor Cost for O & M = $11,130,409 Respondent Total Annual Cost for Non-labor O & M = $1,104,377 Respondent Total Equipment/Contract 15,203,762

(ii) The Agency Tally

Agency Total Annual Burden = 14,749 hours

Agency Total Annual Cost = $1,060,621

(iii) Variations In The Annual Bottom Line

.

We do not expect any significant variations in the annual bottom line for the ambient air monitoring networks for the clearance period requested.

6(f) Reasons for Change in Burden

N/A15 6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 193 hours per respondent . Burden means the total time, effort, or financial resources expended by persons to genera te, 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 fo r the purposes of collecting, validating, and verifying information, processi ng and maintaining information, and disclosing and providing information; adjust the existing wa ys 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 a nd 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 nu mbers 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 suggest ed methods for minimizing respondent burden, including the use of automated collection techniques, EPA established 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 Do cket Center (EPA/DC), EPA West, Room B102, 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 Readi ng Room is (202) 566-1744, and the telephone number for the Air and Radiation Docket and Information Center Docket is (202) 566-1742. An electronic version of the public do cket was made available through EPA Dockets (EDOCKET) at http://www.epa.gov/edocket . The public was able to use EDOCKET to submit or view public comments, access th e index listing of the contents of the public docket, and to access those documents in the public docket that ha ve 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 ICR because statistica l methods are not used in the

data collection associated with the rule amendments.