**EC/R DRAFT 11/18/11** 

i 

### INFORMATION COLLECTION REQUEST

**FOR PREVENTION OF SIGNIFICANT DETERIORATION**  **AND NONATTAINMENT NEW SOURCE REVIEW**

**( 40 CFR PART**  **S 49,**  **51 AND 52 )** 

Prepared for: New Source Review Group Air Quality

Policy Division Office of Air Quality

Planning and Standards Office of Air and Radiation United States Environmental Protection Agency Research Triangle P ark , North Carolina 27711

Prepared b y: EC/R Incorporated 501 Eastowne Driv e, Suite 250 Chapel Hill, NC 27514

November 2011**EC/R DRAFT 11/18/11** 

ii 

### INFORMATION COLLECTION REQUEST

**FOR PREVENTION OF SIGNIFICANT DETERIORATION**  **AND NONATTAINMENT NEW SOURCE REVIEW** 

**( 40 CFR PART**  **S 49, 51 AND 52**  **) TABLE OF CONTENTS**  **Page** 1

. IDENTIFICAT ION OF THE INFORMATION COLLECTION
................................ ................................ .......... 1 1(a) TITLE OF THE INFORMATION COLLECTION REQUEST (ICR)
................................ ................... 1 1(b) ABSTRACT/EXECUTIVE SUMMARY
................................ ................................ .............................. 1 1(c) PAPERWORK REDUCTION ACT REQUIREMENTS
................................ ................................ ....... 2 2
. NEED FOR AND USE OF THE COLLECTION
................................ ................................ ................................ .. 2 2(a) NEED/AUTHORITY FOR THE COLLECTION
................................ ................................ .................. 2 2(b) PRACTICAL UTILITY/USERS OF THE DATA
................................ ................................ ................. 3 3
. NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA
................................ ... 4 3(a) NONDUPLICATION
................................ ................................ ................................ ............................. 4 3(b) PUBLIC NOT ICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB
................................ ......... 4 3(c) CONSULTATIONS
................................ ................................ ................................ ................................ 4 3(d) EFFECTS OF LESS FREQUENT COLLECTION
................................ ................................ ................ 5 3(e) GENRAL GUIDELINES
................................ ................................ ................................ ........................ 5 3(f) CONFIDENTIALITY
................................ ................................ ................................ ............................. 5 3(g) SENSIT IV E QUESTIONS
................................ ................................ ................................ ..................... 6 4
. THE RESPONDENTS AND THE INFORMATION REQUESTED
................................ ................................ .... 6 4(a) RESPONDENTS/STANDARD INDUSTRIAL CLASSIFICATION (SIC) CODES
............................ 6 4(b) INFORMATION REQUESTED
................................ ................................ ................................ ............ 8 4(b)(1) DATA ITEMS, INCLUDING RECORDKEEPING REQUIREMENTS
................................ .. 8 4(b)(2) RESPONDENT ACTIVIT IES
................................ ................................ ................................ .. 8 5
. THE IFNORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECT ION METHODOLOGY, AND INFORMATION MANAGEMENT
................................ ................................ ................................ ..................... 9 5(a) AGENCY ACTIVIT IES
................................ ................................ ................................ ......................... 9 5(b) COLLECTION METHODOLOGY AND MANAGEMENT
................................ ................................ 9 5(c) SMALL ENTITY FLEXIBILITY
................................ ................................ ................................ .......... 9 5(c)(1) MEASURES TO AVERT IMPACTS ON SMALL ENTITIES
................................ ............. 10 5(c)(2) MEASURES TO MITIGATE IMPACTS ON SMALL ENTITIES
................................ ....... 10 5(d) COLLECTION SCHEDULE
................................ ................................ ................................ ................ 10 6
. ESTIMATING THE BURDEN AND COST OF THE COLLECTION
................................ .............................. 1 1 6(a) ESTIMATING RESPONDENT BURDEN
................................ ................................ .......................... 1 1 6(b) ESTIMATING RESPONDENT COSTS
................................ ................................ .............................. 1 2**EC/R DRAFT 11/18/11** 

iii 6(b)(i) ESTIMATING LABOR COSTS
................................ ................................ ............................. 1 2 6(b)( ii) ESTIMATING CAPITAL AND OPERATIONS AND MAINTENANCE COSTS
.............. 1 3 6(b)(iii) CAPITAL/START

-UP OPERATING AND MAINTENANCE (O&M) COST
.................... 1 3 6(b)(iv)ANNUALIZING CAPITAL COSTS
................................ ................................ ....................... 1 3 6(c) ESTIMATING AGENCY BURDEN AND COST
................................ ................................ .............. 1 4 6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND COST
................ 14 6(e) BOTTOM LINE BURDEN HOURS AND COST TABLES
................................ ............................... 15 6(e)(i) RESPONDENT TALLY
................................ ................................ ................................ ........... 1 5 6(e)(ii) THE AGENCY TALLY
................................ ................................ ................................ ........... 1 5 6(f) REASONS FOR CHANGE IN BURDEN
................................ ................................ ............................ 1 5 6(g) BURDEN STATEMENT
................................ ................................ ................................ ...................... 16 

### Appendix A: IN FORMATION REQUIREMENTS
................................ ................................ ................. 21 Appendix B : CAL CULATIONS AND INFORMATION REQUIREMENTS FOR THE MINOR NSR PROGRAM I

N INDIAN COUNTRY
................................ ................................ ................................ ....... 25

**LI ST OF TABLES**  **Page** 4
- 1 Most Numerous Industrial Respondents by Industrial Group
................................ .............................. 6 4
- 2 Most Numerous Industrial Respondents by Industrial Group in Indian Country
................................ 7 6
- 1 Industry

Respondent Burden and Cost (Annual)
................................ ................................ ............... 17 6
- 2 State and Local Reviewing Authority Burden and C ost (Annual)
................................ ..................... 18 6
- 3 A gency

Burden and Cost (Annual)
................................ ................................ ................................ .... 19 6
- 4 NSR Program Information Collection Burden Summary
................................ ................................ .. 20**EC/R DRAFT 11/18/11** 

1 

### 1. ID ENTIFICATION OF THE INFORMATION COLLECTION 1(a) TITLE OF THE INFORMATION COLLECTION REQUST (I CR) This report is entitled Prevention of Significant Deterioration and Nonattainment New Source Review , EPA I CR No. 1230.2 9 , OMB C ontrol No. 2060
- 0003. 1(b) ABSTRACT/EXECUTIVE SUMMARY The anal ys es in this document have been performed in support of a renewal of the New Source Review (NSR) Program Information Collection Request (ICR) (Office of Management and Budget (OMB) Control Number 2060
- 0003 ; EPA Number 1230.2 9 ) . The regulations covered under this ICR are contained in parts 49, 51 and 52 of Title 40 of the Code of Federal Regulations ( CFR). These requirements govern the s tate and f ederal programs for preconstruction review and permitting of major new and modified sources pursuant to p art C “Prevention of Significant Deterioration” (PSD) and p art D “Program Requirements for Nonattainment Areas” (nonattainment major NSR or NA NSR) of the Clean Air Act (CAA) , which together are commonl y referred to as “major NSR.” In addition, these requirements govern the state and federal programs for preconstruction of minor new and modified sources pursuant to CAA section 110 (a)(2)(C), which is commonly referred to as “minor NSR
. ” The ty pes of information collection activities addressed in this I CR are those necessary for the preparation and submittal of construction permit applications and the issuance of final permits. Thus, the respondents addressed in this I CR are (1) the pollutant - emitting sources that must apply for and obtain permits, and (2) the state and local reviewing authorities that must review the permit applications and issue the permits. Specific burden

-producing activities are listed in Appendix A. The administrative , reporting and recordkeeping burden for industry respondents (permit applicants), s tate and local implementing agencies and the Environmental Protection Agency (EPA) are summarized in Table 6
- 4. The NSR Program I CR was last renewed in October 200 8 (EPA ICR No. 1230.23)
. Since this renewal of this I CR, there have been a number of actions that have resulted in changes or revisions to the ICR:
 Flexible Air Permitting Rule (EPA ICR No. 1230.26)

– overall reduction in burden based on poli cy encouraging flexible permits.
 Change Worksheet for Tailoring Rule and SIP Fix Implementation Rule ( EPA I CR No. 1230.28)

– addition of greenhouse gases (GHGs) to the program.
 Final Rule for Review of New Sources and Modifications in Indian Country ( EPA I CR No. 1230.2 7 )

– addition of an NSR program for Indian country
.  Final Rule for PM 2.5 

### In crements, Significant Impact Levels (SILs) and Significant Monitoring Concentration (SMC) (EPA I CR No. 1230.31)

– transfer of the burden for this NSR rule change that was originally

approved under EPA ICR No. 2276.02, OMB Control No. 2060

- 0609. As a result of these changes and revisions, the currently approved respondent burden for the NSR program stands at over 6.7 million hours per year for nearl y 162 ,000 respon se s (with associated labor costs of about $603 million) , plus about $11 .5 million in capital and one

- time start

- up costs. This renewal IC R for the NSR program estimate s the annual respondent burden at approximately 7.9 million hours (with labor costs of about $695 million) for over 162 ,000 responses , plus capital and one - time start

- up costs of about $12.6 million

. The change (net increase) in the burden estimate is due largel y to the expected progress in the implementation of the minor NSR program in Indian country and**EC/R DRAFT 11/18/11** 

2 

### the phased integration of GHGs into the PSD program. In both cases, the period covered b y this ICR renewal is expected to include a significant increase in the number of permits iss ued. An additional factor in the increase of labor and capital/start

- up costs is that we have updated labor wage rates and adjusted the capital/start

- up costs for inflation. The estimated annual burden in this renewal ICR consists of approximately 5.2 million hours for industry respondents (with labor costs of about $476 million and capital/start

- up costs of about $12.6 million) and 2.7 million hours for state and local reviewing authority respondents (with labor costs of about $219 million). The estim ated annual burden for the EPA is about 85,000 hours and $6.4 million. 1(c) PAPERWORK REDUCTION ACT REQUIREMENTS For any existing rule, section 3507(g) of the Paperwork Reduction Act (PRA) limits the amount of time for which a Direc tor may approve a collection of information to 3 ye ars . The existing ICR (EPA ICR No. 1230.23) expires on April 30, 2012. Consequently , the annual burden estimates are calculated for the 3
- ye ar period beginning May 1 , 20 12 and ending April 30 , 201 5
. Except for information collections in notices of proposed rules or those exempted under the emergency processing provisions of 44 U.S.C. § 3507(j), the PRA requires EPA to solicit comments on each proposed information collection, including the renewal or modif ication of any

existing ICR
. This ICR renewal and its supporting statement will be publicly noticed in the Federal Register to solicit comments on the data, analyses, and conclusions. Revisions to this supporting statement will be made based on any comments received, if warranted, and the revised ICR will be submitted to OMB for approval. The information that this ICR covers is required for the submittal of a complete permit application for the construction or modification of all major new stationary sources of pollutants in attainment and nonattainment areas, as well as for applicable minor stationary sources of pollutants
. The EPA certifies that the information collection is necessary for the proper performance of EPA’s functions, and that it has practical utility ; is not unnecessaril y duplicative of information EPA otherwise can reasonabl y access; and reduces, to the extent practicable and appropriate, the burden on persons providing the information to or for EPA. 2. NEED FOR AND USE OF THE COLLE CTI ON 2(a) NEED/AUTHORITY FOR THE COLLECTION Section 110 of the CAA requires all s tates to submit an implementation plan which contains a preconstruction review program for all major new or modified stationary sources, including any provisions necessary

for this program to meet the specific requirements of p arts C and D of title I of the CAA related to major construction
. Section 110(a)(2)(C) of the CAA requires that no new or modified stationary source, in conjunction with existing source emissions in the same area, can interfere with the attainment or maintenance of the National Ambient Air Quality Standards (NAAQS)
. It further requires that no source can construct without securing a permit to ensure that the objectives of p arts C and D of title Iof the CAA are met
. Part C of title Iof the CAA outlines specific construction requirements for new and modified sources constructing in areas that do not violate the NAAQS
. These requirements are more commonly referred to as the prevention of significant deterioration (PSD) rules, which require a prospective major new or modified source to: (1) demonstrate that the NAAQS and increments will not be exceeded, (2) ensure**EC/R DRAFT 11/18/11** 

3 

### the application of best available control techno logy (BACT) and (3) protect Federal Class I areas from adverse impacts, including adverse impacts on air quality related values (AQRVs). Similarly, part D of title I of the CAA specifies requirements for major new and modified sources constructing in areas de signated as nonattainment for a NAAQS pursuant to s ection 107 of the CAA
. The p art D provisions also apply to major source permitting in the Northeast Ozone Transport Region as established under s ection 184 of the CAA
. The p art D rules generall y require a prospective major construction project to: (1) ensure the application of controls which will achieve the lowest achievable emission rate (LAER), (2) certify that all major sources in a s tate which are owned or controlled by

the same person (or person s) are in compliance with all air emissions regulations and (3) secure reductions in existing source emissions to comply with specific statutory

offset ratios and are otherwise, equal to, or greater than those reductions necessary to show attainment and maintenance of the applicable NAAQS (offsets). 2(b) PRACTI CAL UTILITY/USERS OF THE DATA Before the owner or operator of a facility can commence construction or modification of its source, it must comply

with all applicable construction permit requirements
. The owner or operator of a stationary source must develop or collect all relevant information not otherwise available to the f ederal, state or local reviewing authority (RA)
. The RA reviews the application materials submitted by the owner or operator and either declares the permit application complete for processing or provides the owner or operator guidance on how to correct the deficiencies in the application
. If the application has deficiencies, the applicant collects any additional data identified b y the RA so that the permit application can be deemed “complete.” Although sufficient information must be submitted by the applicant before its permit can be classified as complete, some additional clarifyinginformation can b e submitted at a later date b y the applicant to assist the RA in processing the permit application. For major sources to be constructed or modified in attainment areas, the RA uses the permit application information to determine: (1) whether the source will cause or contribute to a violation of the NAAQS and air quality increments, (2) if the technology the sourc e is proposing is BACT and (3) whether the source's emissions will adversel y affect any Federal Class Iareas, including AQRVs in these areas
. Fo r major sources to be constructed or modified in nonattainment areas, the permit application information is used by the RA to determine whether: (1) the source will appl y LAER, (2) the source will have secured the required emissions offsets and (3) the source has demonstrated that all other of its major sources in the same s tate are in compliance with all applicable air emissions regulations
. For minor sources that are large enough to be subject to minor NSR to be constructed or modified in attainment and nonattainment areas, the RA uses the permit application information to determine whether the source will cause or contribute to a violation of the NAAQS . Minor NSR programs may include a control technology

requirement or require ambient air quality modelin g to protect the NAAQS. Once the application is complete, the RA makes a preliminary determination regarding the approvability of the permit application
. For major NSR, this determination, along with the application and supporting information, is made available to the public for at least 30 days . The RA must then respond to public comments and take action on the final permit
. Ty pically a final major NSR action must be taken on a permit by the RA within 1 ye ar of receipt of a complete application
. For minor NSR, the public comment period and deadline for a final permit action may be shorter.**EC/R DRAFT 11/18/11** 

4 

### In addition, the public and other permit applicants may use some of the data collected
. The EPA operates a RACT/BACT/LAER Clearinghouse (RBL C) 1 

### which contains many BACT and LAER determinations to aid applicants and reviewers in identifying reasonable and available control technologies
. The Clean Air Act Amendments require that the BACT or LAER information in each permit must be gathered by the RA and submitted for entry into the RBLC database as a reference for making future control technology determinations
. Annual reports containing RBL C update information are also available to the public through the National Technical Information Service. 3. NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA 3(a) NONDUPLICATION The information collection activities required under the NSR regulations are not routinely performed elsewhere b y the EPA
. However, similar information may be collected during the development of certain environmental impact statements (EIS)
. In such cases, regulations and policies require that information collected for EI S' s and NSR programs be coordinated to the maximum extent possible so as to minimize duplicating the collection of data
. Some of the required information also may already be available from s tates or other federal agencies
. However, even when these data are available, they are not generall y adequate to address completel y the relevant NSR re quirements. 3(b) PUBLIC NOTICE REQUIRED PRIOR TO IC R SUBMI SSI ON TO OMB The first public notice of this ICR renewal will be published in the F ederal Register (FR)
. If any comments are received by the closing date, the EPA will consider the comments and revise this ICR accordingl y . 3(c) CONSULTAT IONS This ICR is a renewal of the existing ICR for the NSR program
. Itincorporates the base elements of the program which have not been changed for this renewal
. However, since the previous renewal, the EPA has filled regulatory

voids that existed in Indian country (where state NSR programs do not appl y) by promulgating a part D program and a minor NSR program for Indian country . (The EPA was already implementing the part C PSD program in Indian country .) The implementing regulations for these programs are located in 40 CFR part 49 at 40 CFR 49.151 through 49.173 , so these part 49 regulations have been brought under this I CR . The EPA acts as the reviewing authority for these programs. In addition, GHGs have come under the PSD program since the last renewal as a result of actions under the CAA unrelated to NSR. P rovisions also have been added to the PSD regulations that allow for full implementation of the program for PM 2.5 

### , which has resulted in an increase in the modeling required for PSD permits. The Flexible Air Permitting Rule also established policies that reduce total burden because of the reduction in the number of permit actions. Extensive consultation through public hearings with environmental groups; industry ; and state, local, and federal agency

representatives were conducted previously for all these actions that have affected the NSR rules covered b y this I CR
. Extensive consultation with Indian Tribes w as carried out during the development of the NSR programs for Indian country
. Also, prior to the previous I CR renewal, the EPA

1 

### The RBLC is available on the EPA Technology Transfer Network. Access to the RBL C on the TTN is via a computer through Internet access

– http://cfpub.epa.gov/RBL C/
.**EC/R DRAFT 11/18/11** 

5 

### contacted the National Association of Clean Air Agencies (NACAA), and received comments from three of its members. Consistent with NACAA’s input during that consultation period, changes were made to the burden estimates for certain activities performed b y RAs, and these changes have been carried over in this renewal
. 3(d) EFFECTS OF LESS FREQUENT COLLECTION The CAA defines the rate of reporting b y sources, states and local entities
. Consequently , less frequent collection is not possible. 3(e) GENERAL GUIDELINES The OMB's general guidelines for information 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 1320.5, the EPA believes: 1. The NSR regulations do not require periodic reporting more frequently than semi

- annuall y. 2. The NS R regulations do not require respondents to participate in any statistical survey
. 3. Written responses to EPA inquiries are not required to be submitted in less than 30 days. 4. Special consideration has been given in the design of the NSR program to ensure that the requirements are, to the greatest extent possible, the same for f ederal requirements and those RA s who already have preconstruction permitting programs in place. 5. 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 CAA
. 6. The NSR regulations do not require more that one original and two copies of the permit application, update or revisi on to be submitted to the EPA
. 7. Respondents do not receive remuneration for the preparation of reports required by the CAA or part 49, 51 or 52. 8. To the greatest extent possible, the EPA has taken advantage of automated methods of reporting. 9. The EPA believes the impact of NSR regulations on small entities to be insignificant and not disproportionate. The recordkeeping and reporting requirements contained in the NSR program do not exceed any of the P RA guide lines contained in 5 CFR 1320.5, except f or the guideline which limits retention of records by respondents to 3 years . The CAA requires both respondents and s tate or local agencies to retain records for a period of 5 ye ars . The justification for this exception is found in 28 U.S.C
. 2462, which specifies 5 ye ars 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
- 1916
- E (W.D
. Okla., January 23, 1984) found that the 5
- ye ar general statute of limitations applied to the C AA
. 3(f) CONFIDENTIALITY Confidentiality

is not an issue for the NSR program
. Inaccordance with title V, s ection 503 (e), the information that is to be submitted by sources as a part of their permit application and update, applications for revisions and applications for renewals is a matter of public record
. To the extent that the information required for the completeness of a f ederal permit is proprietary , confidential or of a nature that it could impair the ability of the source to maintain its market position, that information is**EC/R DRAFT 11/18/11** 

6 

### collected and handled according to EPA's policies set forth in Title 40, Chapter 1, Part 2, Subpart B

-- Confidentiality

of Business Information (see 40 CFR 2)
. States ty pically have similar provisions. 3(g) SENSITIVE QUESTIONS The consideration of sensitive questions, (i.e., sexual, religious, personal or other private matters), is not applicable to the NSR program
. The information gathered for purposes of establishing an NSR permit for a source do not include personal data on any owner or operator. 4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4(a) RESPOND ENTS/STANDARD INDUSTRIAL CLASSIFI CATION (SI C) CODES Table 4

- 1 lists the industrial groups the EPA expects will contain the majority of the industrial respondents affected b y the NSR program
. These categories were chosen because of their historic relative incidence in seeking NSR permits as established in prior I CRs and confirmed by a nationwide air pollutant emission inventory developed by

the EPA in 1986

- 87
. These industries have been used as the basis for impact analysis since that inventory
.

**Table 4 -**  **1 .**  **Most Numerous Industrial Respondents by Industrial Group** Industry Group SI C NAI CS † 

### Steam Electric Plants 491 221111, 22112, 22113, 221119, 221121, 221122 Petroleum Refining 291 32411 Chemical Processes 281 325181, 32512, 325131, 325182, 211112, 325998, 331311, 325188 Natural Gas Transport 492 48621, 22121, 48621 Pulp Mills 261 32211, 322121, 322122, 32213 Paper Mills 262 322121, 322122 Automobile Manufacturing 371 336111, 336112, 33612, 336211, 336992, 336322, 33633, 33634, 33635, 336399, 336212, 336213 Pharmaceuticals 283 325411, 325412, 325413, 325414 † 

### North American Industry Classification S ys tem The respondents also include s tate and local air regulatory agencies that serve as the reviewing authorities for the NSR program
. Because of the national scope of the NSR program, these**EC/R DRAFT 11/18/11** 

7 

### governmental respondents are in all 50 s tates. In total, we recognize 112 such state and local reviewing authorities. An exception to the list of affected industries in Table 4

- 1 applies to the minor NSR program in Indian country . For that program, the industrial groups expected to be most affected are listed in Table 4

- 2. **Table 4 -**  **2. Most Numerous Industrial Respondents by Industrial Group in Indian Country** Industry Group NAI CS Animal food manufacturing 311119 Asphalt hot mix 324121 Auto body

refinishing 811121 Beef cattle complex, slaughter house, and meat

-packing plant 3116 Casting foundry

(iron) 331511 Chemical preparation 3251 Clay and ceramics operations (kilns) 32711 Concrete batching plant 327320 Crude petroleum and natural gas extraction 211111 Electric power generation 22111 Fabricated metal products 3329 Fabricated structural metal 3323 Fiber glass operations 3279 Gasoline bulk plant 424710 Gasoline station (storage tanks, refueling) 4471 Grain elevator 424510 Machinery

manufacturing 33311 Millwork (wood products manufacturing) 32191 Natural gas

- distribution systems 221210 Natural gas liquid extraction (major source) 211112 Oil and gas production/operations (minor Oil & Gas) 21111 Other (natural gas

- fired boilers) 72112 a 

### Printing operations (lithographic) 323110 Professional, scientific, and technical services 54171 b 

### Sand and gravel mining 212321 Sand

- and shot

-blasting operations 238990 Sawmills (minor source) 321113 Sawmills (major source) 321113 Sewage treatment facilities 221320 Softwood veneer and pl ywood manufacturing 321212 Solid waste landfill 562212 Surface coating operations 332812 Wood kitchen cabinet manufacturing 337110 a NAICS associated with “other” facilities is that for casino

- hotels, which was the most frequently mentioned type of “other” facility. b T his sector included based on natural gas

- fired boilers.**EC/R DRAFT 11/18/11** 

8 

### 4(b) IN FORMAT ION REQUESTED 4(b)(1) DATA IT EMS, INCLUDI NG RECORDKEEPING REQUIREMENTS Tables A

- 1 and A

- 2 of Appendix A summarize the industry respondent data and information requirements which owners or operators of major sources must include in PSD and NA NSR construction permit application s . The tables also include the appropriate references in 40 CFR part 51 for the data and information requirements that govern the way s tates implement NSR programs
. For each reference in p art 51, corresponding language will be found in part 52
. In this ICR anal ys is, the minor NSR burden is for owners or operators of minor sources to submit information to demonstrate that they are exempt from the major source construction permit requirements and that they will not cause or contribute to a violation of any NAAQS and that they will meet all requirements of the applicable implementation plan
. Because state minor NSR programs vary widely in form and requirements, it is not practical to list specific requirements for these programs other than the general requirements found in 40 CFR 51.160. The specific items required b y the minor NSR program for Indian country are listed in Appendix B. Table A

- 3 of Appendix A summarizes the data and information requirements which s tate and local reviewing authority respondents mu st meet for major NSR permits
. Table A

- 3 also shows the p art 51 references for the data and information requirements specified
. Because of the variability of minor NSR programs, it is not practical to list specific requirements for these programs other than the general requirements found in 40 CFR 51.160 and 51.161. The EPA is the reviewing authority for the minor NSR program in Indian country . Thus, state and local agencies are not respondents for that program. 4(b)(2) RESPONDENT ACTIVITIES Table 6

- 1 lists the activities, burden and estimated costs for industry respondents under the N SR program under 40 CFR parts 49, 51 and 52
. For the part C and D programs, these activities include three broad categories: Preparation and P lanning; Data Collection and Analysis; and Permit Application. Within each of these categories, further subdivision of a source’s activities can be found. The EPA anticipates it will take 1,610 p art C major sources an average of approximately 1,00 6 hours to complete each PSD application, for a total of 1,619,660 hours
. Each of the 486 p art D NSR sources will require an average of 642 hours, or a total of approximately 312,012 hours each ye ar , to complete p art D NSR applications. Each minor source will require a weighted average of approximately 39 hours to complete its application requirements, f or a total of 2, 822,885 hours for state and local minor NSR programs and 479,435 hours for minor NSR program in Indian country
. Table 6

- 2 lists the activities, burden and estimated costs for state and local reviewing authority respondents under the NSR program. We estimate that it will take these agencies approximately 33 6 hours to complete each of the estimated 1,610 PSD application s , for a total of 540,960 hour s annually
. For e ach of the 486 p art D NSR applications, we believe an average of 128 hours will be required , total ing approximately 6 2, 208 hours each year. Each minor NSR application will require a weighted average of approximately 2 9 hours, f or an annual total of 2, 095,140 hours . S tate and local agencies do not act as reviewing authorities for minor NSR program in Indian country
. In addition, state and local reviewing authority respondents are expected to submit state implementation plan (SIP) revisions to conform their rules to amendments to the major NSR regulations in part 51. We estimate an average of 51 SIP revisions per year, each requiring 40 hours to prepare for a total of 2,040 hours annually
.**EC/R DRAFT 11/18/11** 

9 

### 5. THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION METHODOLOGY AND INFORMATION MANAGEMENT 5(a) AGENCY ACTIVITIES Table 6

- 3 lists EPA’s activities associated with NSR permitting. These activities generall y involve oversight review of state and local reviewing authorities’ major NSR permitting actions and more complicated minor NSR actions to verify that the requirements of the CAA and the implementing part 51 and 52 regulations are being met. In addition, EPA will have to review the SIP revisions submitted by

the reviewing authorities. Finall y, the EPA serves as the reviewing authority for the minor NSR program in In dian country
. 5(b) COLLE CTION METHODOLOGY AND MANAGEMENT The owners and operators of new or modified stationary sources affected by

the N SR regulations will be responsible for submitting construction permit applications to the RA
. The RA will log in permit applications, store applications in a central filing location at the RA , notify the Federal Land Manager (FLM) and provide a copy of the application (if applicable), and transmit copies of each application to EPA
. Once construction permits have been approved, the RA will submit control technology information to EPA's RBLC database
. Because the construction permits and associated control te chnology

determinations are performed on a case

-by

- case basis, the regulations will not contain additional forms that owners or operators would have to fill out and submit to the RA
. States will likely use their current permit application forms for NSR pur poses. Qualified personnel who work for the RA will perform permit reviews and check the quality of data submitted by

the applicant on a case

-by

- case basis
. The applicant will be required to submit information on how the data were obtained ( e.g. , indicate whether emissions data were obtained through the use of emissions factors or test data) and how the calculations were performed
. The RA personnel will check data quality

by reviewing test data and checking engineering calculations, and by reviewing control technology

determinations for similar sources
. The RBLC and other sources will be reviewed for information on control technology deter minations made for sources similar to the sources included in the permit application
. Confidential information submitted by the applicant will be handled b y the permit reviewing authority's confidential information handling procedures
. The public will be p rovided the opportunity

to review a permit application and other materials relevant to the RA ’s decision on issuing the permit, including FLM findings, b y obtaining a cop y from the RA or by attending the public hearing
. The NSR regulations will not require information through any ty pe of survey
. 5(c) SMALL ENT ITY FLEXIBILITY The Regulatory

Flexibility

Act (RFA) requires regulatory agencies, upon regulatory action, to assess that actions potential impact on small entities (businesses , governments, and small non

- governmental organizations) and report the results of the assessments in (1) an Initial Regulatory Flexibility

Analysis (IRFA), (2) a Final Regulatory Flexibility

Analysis (FRFA), and (3) a Certification. For I CR approval, the Agency

must demonstrate that it "has taken all practicable steps to develop separate and simplified requirements for small businesses and other small entities" (5 CFR 1320.6(h))
. In addition, the agencies must assure through various mechanisms that small entities are given an opportunity to participate in the rulemaking process
.**EC/R DRAFT 11/18/11** 

10 

### A Regulatory

Flexibility

Act Screening Anal ys is (RFASA) developed as part of a 1994 draft Regulatory Impact Anal ys is (RIA) and incorporated into the September 1995 ICR renewal analysis reported an initial regulatory

flexibility

screening anal ys is showed that the changes to the NSR program due to the 1990 Clean Air Act amendments would not have an adverse impact on small entities. 2 

### This analysis encompassed the entire universe of applicable major sources that were likely to also be small

businesses. The Agency

estimates there are approximately 50 “small business” major sources. 3 

### Because the administrative burden of the NSR program are the primary source of the NSR program’s regulatory costs, the anal ys is estimated a negligible “cost to sales” (regulatory cost divided by

the business category mean revenue) ratio for this source group. Currently , there is no economic basis for a different conclusion at this time. 5(c)(1) MEASURES TO AVERT IMPACTS ON SMALL ENTITIES The Agency

may not, under any ci rcumstances, exempt a major source of air pollution
. Since the impacts of NSR regulations which may impact small entities are predominantly to major sources, little room exists for regulatory flexibility to avert the impact of the proposed rulemaking on small entities through exemption
. 5(c)(2) MEASURES TO MITI GATE IM PACTS ON SMALL ENTITIES Even though the NSR program is not anticipated to have an adverse impact on a significant number of small businesses, measures are in place to assist in those incidental exceptions
. Implementation of small business stationary

source technical and environmental compliance assistance programs, as called for in section 507 of the CAA (at the f ederal and s tate levels) can reduce the reporting burden of small entities which are subject to major NSR
. These programs may significantly

alleviate the economic burden on small sources b y establishing: ( 1) programs to assist small businesses with determining what CAA requirements appl y to th eir sources and when they apply and ( 2) guidance on alternative control technology

and pollution prevention for small businesses. 5(d) COLLECTION SCHEDULE Respondents are not subjected to a collection schedule per se under NSR permitting regulations of parts 49, 51 and 52
. Ingeneral, each affected source is required to submit an application as a prerequisite to receiving a construction permit
. Preparation o f a construction permit application is a one

time

- only activity for each project involving construction of a new source or modification of an existing source . The applicable SIP ty picall y states the time period that is necessary to process a permit application and issue a permit; consequentl y, a prospective source would be obliged to work backward from the hopeful commencement of construction to determine the optimum submittal date for the application
. The NSR permit regulations will not require periodic reporting or surveys.

2 

### “Economic Assessment of the Impacts of Part C and D Regulatory Changes,” June 2, 1994. 3 

### The definition for “small business” employed for all SI C categories in this analysis was any business employing fewer than 500 employees.**EC/R DRAFT 11/18/11** 

11 

### 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6(a) ESTIMATING RESPONDENT BURDEN Burden means the total time, effort, or financial resources expended b y persons to generate, 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 s ys tems 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
. The burden estimate should be composed of (1) a total capital and start - up cost component annualized over its useful life; (2) a total operation, maintenance and purchases of services component
. Each component should be divided into burden borne directl y b y the respondent and any services that are contracted out
. Table 6

- 1 identifies the average burden by activity for the industrial respondents
. The average burden for several PSD tasks have increased since the last 2008 renewal , primaril y as a result of the incorporation of GHGs into the program (EPA I CR No. 1230.28) and the addition of additional PM 2.5 

### requirements (EPA I CR No. 1230.31). As a result, the avera ge burden for an industrial respondent has increased from 866 hours per PSD permit to 1,006. The Flexible Air Permitting Rule (EPA I CR No. 1230.26) also caused a small increase to PSD permit burden, but that was more than offset by the reduction in the number of permits that resulted. Thirty

- four of the 1,610 p art C (PSD) permit applications require pre

construction air quality monitoring
. More specifically , these 34 sources represent about 12 percent of the 274 sources that are expected to be subject to PS D each ye ar for non

- GHG pollutants. (Pre

- construction monitoring is never required for GHGs.) This direct start

- up cost is estimated at $366,006 per source. This value was derived by appl ying the Bureau of Labor Statistics ’ (BLS’) online inflation calculator to the value used in the 2008 renewal ( $ 335,165 ). 4 

### The industry respondent burden for a part D permit remains unchanged from the 2008 renewal. In previous renewals, the average burden for preparing and submitting minor NSR permit applications under state/local programs has reflect ed a range of estimated burden from 8 to 12 0 hours, depending on the nature of the permit action required
. The average assume d the following average burdens for different types of permit actions (percent of total action s in parentheses): 4 0 hours for new minor sources, new sy

nthetic minor sources, and s ynthetic

-based modifications ( 30 percent); 8 hours for true minor modifications ( 30 percent); 120 hours for netting

-based minor modifications ( 20 percent); and 8 hours for minor/administrative permit revisions ( 20 percent). However, since the last renewal, EPA promulgated the Flexible Air Permitting Rule which encouraged the use of flexible permitting techniques which tend to require additional burden in the initial permit, but reduce the need for subsequent permits and permit revisions. As calculated in the revised IC R prepared for that rulemaking (EPA I CR No. 1230.26) , the overall burden for minor NSR permitting in state/local programs fell to 2,822,885 hours per ye ar and the number of permits was reduced to 72,841 annually . Based on these final numbers, which are unchanged in this renewal, the weighted average burden for each minor NSR permit is about 39 hours.

4 

### http://data.bls.gov/cgi

-bin/cpicalc.pl?cost1=335165&year1=2007&year2=2011 . This online calculator provides the inflation in the Consumer Price Index between any two years . In this case, we entered the amount in 2007 dollars ( $335,165 ) and retrieved the inflated value in 2011 dollars ($ 366,006 ).**EC/R DRAFT 11/18/11** 

12 

### The burden for industry

respondents for the minor NSR program in Indian country was similarly calculated in an ICR revision prepared for that rulemaking (EPA ICR No. 1230.27). For this ICR renewal we have used the burdens and costs developed for that ICR, although we have updated the number of sources subject to each type of action to reflect the progress that has been made in implementing the rule. The Indian country NSR rule also addressed the NA NSR part D program in Indian country , but we estimated in th e IC R revision for th at rule that an average of onl y one source subject to th e rule would require permitting annually . Rather than calculate that small burden as separate line item , for this renewal we have simply included that single source in the overal l part D program calculations. Table 6

- 2 identifies the average burden by activity for the s tate and local reviewing authority respondents. C hanges that were made for the 2008 renewal pursuant to consultation with NACAA to more accurately

reflect the burdens of the se activities have been retained in this renewal
. The per

-permit burden for a PSD permit has increased since the 2008 renewal from 301 hours to 336 hours as a result of the same factors noted above for the industry respondents. The burden for a part D permit has increased marginally

(from 127 to 128 hours) as a result of the Flexible Air Permitting Rule , although the overall burden went down as a result of that rule because of a decrease in the number of permits required annually . The burden f

or reviewing a minor NSR permit application and issuing the permit fell to a weighted average of about 29 hours. 6(b) ESTIMATING RESPONDENT COSTS 6(b)(i) ESTIMATING LABOR COSTS In this ICR, nearly the entire burden for all respondents (and the EPA) is treated as a labor cost
. The explanation for the absence of capital and operations and maintenance costs appears below in sections 6(b)(ii) and 6(b)(iii)
. Consequently , there is only an annual value of the costs of the ICR burden, which is equal to the cost of the first yearly outlay
. The same annual ICR burden and cost are reported for each ye ar because the EPA projects that the yearly average number of permit applications will be constant over the ter

m of the ICR
. In order to improve the accuracy of burden estimates, this renewal ICR updates the wage rates to values in 2011 dollars. The labor rate used to calculate the industrial respondents’ labor cost is $ 9 9 /hr . The industrial labor rate was obtain ed from Table 2 in the Bureau of Labor Statistics (BLS) survey “Employer Costs for Employee Compensation,” June 20 11, for “professional and related” workers . To determine the rate per hour, a 110% overhead was assumed. The resultant rate was rounded to the nearest dollar, yi elding $ 99 /hr. Following the same assumptions as the 2008 IC R renewal, 34 of the industrial respondents submitting p art C (PSD) permit applications will conduct pre

- construction ambient air quality monitoring
. The average cost for this activity is estimated to be $ 366.006 , which is the inflation

- adjusted figure based o n the value of $335,165 included in the 2008 IC R renewal
. As note previously , this inflation adjustment was made using the BL S’ online inflation calculator
.**EC/R DRAFT 11/18/11** 

13 

### The labor rat e used to calculate the s tate and local respondents’ labor cost is $ 81 /hr. This rate was also obtained from the BL S survey
. 5 

### We a ssume d 100% overhead for s tate and l ocal a gency l abor. Table 6

- 2 presents the tate and local agency respondents’ burden and costs
. Their annual cost is equal to the cost of the first year outlay , which recurs each year. 6(b)(ii) ESTIMATING CAPITAL AND OPERATIONS AND MAINTENANCE COSTS Even if an applicant is a brand new company and the prospective source is a “greenfield” source (the EPA estimates less than 1 percent of the combined number of major and minor industrial respondents fit that description) most, and perhaps all, of the equipment needed to prepare permit applications (for example, the computers and basic software) will be part of the source’s business operation inventory
. Furthermore, much of the data and regulatory and policy

information for making technology determinations and even models for performing ambient air impact anal ys es are available in electronic form from several different EPA web sites for just the communication charges, which are typicall y absorbed in routine business overhead expenses. Since the purchase of capital equipment is believed to be an insignifi cant factor in permit application preparation, the EPA assumes the operation, maintenance, or services for same are negligible
. Further, once a permit is issued, there is no operations and maintenance cost associated with it
. Itremains unaltered unless th e source or the permitting authority discovers specific reasons to reexamine it and change any conditions or specifications
. If purel y administrative, the changes are handled exclusively b y the permitting authority . If changes have the potential for environmental consequences, the action may be significant enough to be counted as a separate and new application, to which a new burden and cost may be ascribed. 6(b)(iii) CAPITAL/START

- UP OPERATI NG AND MAINTENANCE (O&M) COSTS Capital/start

- up and O&M costs are non - labor related costs
. One
- time capital/start

- up costs are incurred with the purchase of durable goods needed to provide information
. According to the P RA , capital/start

up cost should include among other items, preparations for collecting information such as purchasing computers and software, monitoring, sampling, drilling, and testing equipment
. As a practical matter, these costs are not ty

pical of the costs associated with preparing a major source permit application
. For the same reason, the O&M cos ts associated with start

- up capital equipment are zero for most of the sources for this I CR. However, as shown in Table 6

- 1, 34 of the 1,610 p art C (PSD) permit applications require preconstruction air quality monitoring , which costs $ 12,444,204
. This one

- time cost includes pre - application monitoring of air quality via contract services. In addition, Table 6

- 1 also shows small capital/start

- up costs for industry respondents in the Indian country minor NSR program. Many of the sources subject to th at program have never been subject to any ty pe of air regulations before, and we believe that there may

be some costs for such sources. 6(b)(iv) ANNUALIZING CAPITAL COSTS Ty pically annualized capital cost would be derived from a discounted net present v alue of the stream of costs that would occur over the life of the permit, or the I CR, whichever is shorter
. However, in the case of NSR, there are onl y labor costs for preparing and processing permit applications
. Labor costs are

5 

### State/Local rates obtained from "Employer Costs for Employee Compensation, Table 4: Employ ment Costs for State and Local Governm ent Workers" U.S. Dept. of Commerce, BL S, June 2011. (http://www.bls.gov/news.release/ecac.t04.htm accessed 9/19/11)**EC/R DRAFT 11/18/11** 

14 

### expensed when incurred and not amortized
. Therefore, the capital costs for NSR permitting are zero. A minor exception is the capital/start

- up costs noted above for the minor NSR program in Indian country , which were annualized to derive the annual costs reported in Table 6

- 1. 6(c) ESTIMATING AGENCY BURDEN AND COST Staff in EPA’s Regional O ffices typically review major NSR permits and more complicated minor NSR permits issued by state and local reviewing authorities
. Inaddition, Regional Office staff will now also serve as the reviewing authority for the minor NSR program in Indian country
. The EPA expects its review of NSR permits to comprise the tasks listed in Table 6

- 3. The cost estimate uses a “loaded” labor rate of $ 46 /hr
. The rate reflects the assumption that the staff reviewing permits are classified as Grade 12 Step 1
. The corresponding salary is loaded with benefits at the rate of 60 percent
. 6 

### 6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND COST For the purpose of estimating burden in this ICR, the respondent universe is defined b y the annual number of permit applications prepared b y major and minor sources, and the annual number of permit applications processed by s tat e and local reviewing authorities
. These numbers are based on the currentl y approved ICR for the NSR program, which is a revision to add the impact of the PM 2.5 

### In crements, SILs and SMC rule (EPA I CR No. 1230.31) to the NSR program. (This burden was origin all y approved under EPA ICR No. 2276.02, OMB Control No. 2060

- 0609.) The universe of permits was revised from this baseline to account for additional PSD permits that will be required now that GHGs have come under the PSD program and the phase

- in has progressed since that impact was last evaluated (in EPA ICR No. 1230.28). In addition, the number of minor NSR permits in Indian country was revised to reflect the progress that will be made in that program during the term of this ICR renewal. This analysis u ses the 112 reviewing authorities count used by other permitting I CRs and the appropriate source count for individual permit

- related items (e.g., attending pre

- application meetings with the source). The resulting number of respondents for this I CR renewal is then estimated to be as follows: 1. 1,610 p art C (PSD) permit applications prepared by industry
. 2. 486 p art D (nonattainment) permit applications prepared b y industry
. 3. 72,841 minor NSR permit applications prepared by industry in state/local programs
. 4. 12,432 minor source registrations and minor NSR applications prepared b y industry in Indian country 5. 1,610 p art C (PSD) permit applications processed by s tate and local reviewing authorities
. 6. 486 p art D (nonattainment) permit applications processed b y s tate and local reviewing authorities
. 7. 72,841 minor NSR permit applications processed by s tate and local reviewing authorities
. F or each category

of permit application except minor sources in Indian country , the total number of respon se s is twice the number of permit applications. (This is not the case for the minor NSR program in Indian country

because EPA acts as the reviewing authority for that program.) Inaddition, e ach reviewing authority must submit changes to its existing SIP program or demonstrate that its existing program s are at least equivalent to EPA ’s new requirements. Over the next 3 years, w e anticipate that all

6 

### Federal Labor Cost obtained from U.S. Office of Personnel Management 2011 General Schedule Table 2011
- GS. Hourly

labor rate assumed is G S
- 12, Step 1 (Technical Labor).**EC/R DRAFT 11/18/11** 

15 

### 112 reviewing authorities will submit a SIP revision to add PM 2.5 

### to their major NSR program s , 28 will submit a SIP revision for GHG s, and 13 will submit a SIP revision for the NSR Reform rulemaking. This comes to a total of 153 over 3 years, or an average of 51 per ye ar. The total annual effort for industry respondents submitting Part C (PSD) permit applications is 1,619,660 hours, and the correspo nding annual cost is $ 172,790,544
. The total annual effort for industry respondents submitting p art D (nonattainment) permit applications is 312,012 hours, and the corresponding annual cost is $ 30,889,188
. The total annual effort for industry respondents submitting minor NSR permit applications to state/local programs is 2, 822,885 hours, and the corresponding annual cost is $ 2 79,465,615
. The total annual effort for industry respondents submitting registrations and minor NSR permit applications for the Indian country program is 479,435 hours, and the corresponding annual cost is $ 5,353,200. For industry respondents, the overall total annual effort is 5,233,992 hours and $ 488,498,547
. The total annual effort for s tate and local respondents processing p art C (PSD) permit applications is 540,960 hours, and the corresponding annual cost is $ 43,817,760
. The total annual effort for s tate and local respondents processing p art D (nonattainment) permit applications is 62,2 08 hours, and the corresponding annual cost is $ 5,038,848
. The total annual effort for s tate and local respondents processing minor NSR permits is 2, 095,140 hours, and the corresponding annual cost is $ 1 69,706,340
. State and local respondents also will spend approximately 2,040 hours for SIP revisions, for an annual cost of $1 6 5, 240
. For the s tate and local respondents, the overall total annual effort is 2, 700,348 hours and $ 2 18 , 728,188
. 6(e) BOTTOM LINE BURDEN HOURS AND COST TABLES 6(e)(i) RESPONDENT TALLY Table 6

- 4 summarizes the estimated burden and cost to industry respondents, s tate and local agency respondents, and the EPA for submittal and processing of NSR permit applications and the issuance of the permits
. Italso includes the cost to the respective respondents and reviewing agencies for nonapplicability

findings, which preclude sources from further major source requirements
. For industry and s tate and local agency respondents, the overall total annual burden is 7,934,340 h ours and $ 707,226,735
. 6(e)(ii) THE AGENCY TALLY The total annual effort for the EPA for processing p art C (P SD) permit applications is 25,760 hours, and the corresponding annual cost is $ 1,184,960
. The total annual effort for the EPA for processing p art D (nonattainment) permit applications is 7,776 hours, and the corre sponding annual cost is $35 7 , 696
. The total annual effort for the EPA for processing minor NSR permits in state/local programs is 6,964 hours, and the corresponding annual cost is $ 320,344
. The total annual effort for the EPA for serving as the reviewing authority for the minor NSR program in Indian country is 44,568 hours, and the corresponding annual cost is $4,567,077. For the EPA , the overall total annual effort is 85,323 hours and $ 6,441,807
. 6(f) REASONS FOR CHANGE IN BURDEN The burden has changed since the previous renewal due in part to an increase in the number of respon se s and per

-permit burden due to the addition of GHGs to the PSD program. In addition, the extension of**EC/R DRAFT 11/18/11** 

16 

### minor NSR and part D programs to Indian country to fill these regulatory gaps has increased the number of responses and the overall burden. Finall y, the burden has been increased by the addition of provisions in the PSD program that will allow full integration of PM 2.5 

### . Also contributing to the increase in burden has been a change in the labor rates . As explained in section 6(b)(i) , in order to improve the accuracy o f burden estimates, the rates were recalculated using 20 11 values for wages . 6(g) BURDEN STATEMENT The average annual burden on an industrial respondent submitting a p art C (PSD) permit application is 1,006 hours
. The average annual burden on an industrial respondent submitting a p art D (nonattainment) permit application is 642 hours
. The average annual burden on an industrial respondent submitting a minor NSR permit application is about 39 hours in a state/local program and 39 hours in Indian country
. The average annual burden on a s tate or loc al RA respondent processing a p art C (PSD) permit application is 3 36 hours
. The average annual burden on a s tate or local RA respondent processing a part D (nonattainment) permit application is 12 8
. The average annual burden on a s tate or local agency resp ondent processing a minor NSR permit application is about 29 hours
. The average annual burden on a state or local RA submitting a SIP revision is 40 hours. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, verifying, processing, maintaining, disclosing, and providing information; adjust the existing ways to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information
. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number
. The OMB control numbers for EPA’s regulations are listed in 40 CFR part 9 and 48 CFR Chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID No. EPA
- HQ
OAR
- 2011
- 0901 , which is available for online viewing at www.regulations.gov , or in person viewing at the Air and Radiation Docket and In formation Center in the EPA Docket Cent er (EPA/DC), EPA West, Room 3334 , 1301 Constitution Avenue, 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 th e Reading Room is (202) 566
- 1744 , and the telephone number for the Air Docket is (202) 566

- 1742
. An electronic version of the public docket i s available at www.regulations.gov . This s i te can be used to submit or view public comments, acces s the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically
. Once in the s ys tem, 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, DC 20503, Attention: Desk Office for EPA
. Please include the EPA Docket ID No. EPA
- HQ
- OAR**-** 20 11
- 0901 and OMB control number 2060
- 0003 in any correspondence.**EC/R DRAFT 11/18/11** 

17 **Table 6 -**  **1. Industr y**  **Respondent Burden and Cost (A nnual)**  **Activity Units**  **Hours per Unit**  **An nual** 

**Hours An**  **nual Cost I. Part C (PSD)**  A. Preparation and Planning Determination of Compliance Requirements 1,610 170 273,700 $27,096,300 Obtain Guidance on Data Needs 1,610 169 272,090 $26,936,910 Preparation of BACT Analysis 1,610 148 238,280 $23,589,720 B. Data Collection and Analysis Air Quality Modeling 1,610 225 362,250 $35,862,750 Determination of Impact on Air Quality Related Values 1,610 113 181,930 $18,011,070 Post
- construction Air Quality Monitoring 1,610 56 90,160 $8,925,840 C. Permit Application Preparation and Submittal of Permit Application 1,610 60 96,600 $9,563,400 Public Hearings 1,610 25 40,250 $3,984,750 Revisions to Permit 1,610 40 64,400 $6,375,600 D. Subtotal Burden 1,006 1,619,660 $160,346,340 E. Direct Costs for Pre
- construction Air Quality Monitoring 34 $12,444,204 F. Total Costs $172,790,544 **II. Part D (Non -**  **attainment)** A. Preparation and Planning Determination of Compliance Requirements 486 150 72,900 $7,217,100 Obtain Guidance on Data Needs 486 100 48,600 $4,811,400 B. Data Collection and Analysis Preparation of LAER Engineering Analysis 486 52 25,272 $2,501,928 Demonstrate Offsets 486 52 25,272 $2,501,928 Prepare Analysis of Alternative Sites, Processes, etc. 486 60 29,160 $2,886,840 Air Quality Modeling 486 130 63,180 $6,254,820 C. Permit Application Preparation and Submittal of Permit Application 486 49 23,814 $2,357,586 Public Hearings 486 25 12,150 $1,202,850 Revisions to Permit 486 24 11,664 $1,154,736 D. Total 642 312,012 $30,889,188 **III. Minor NSR -**  **State/Local Programs** Preparation and Submittal of Minor NSR Permit Application a 72,841 39 2,822,885 $279,465,615 **IV. Minor NSR -**  **Indian Country Program** A. Preparation and Submittal of Registrations and Permit Applications a 12,432 39 479,435 $5,212,341 B. Capital Costs (Non
- Labor) 12,432 $140,859 C

. Total $5,353,20 0 **V. GR AND TOT**  **AL** 87,369 5,233,992 $488,498,547 a The hours per unit for these activities are weighted averages rounded to the nearest whole number.**EC/R DRAFT 11/18/11** 

18 **Table 6 -** **2. State and Local Reviewing A**  **uthority Respondent Burden and Cost (A**  **nnual)**

**Activity Units**  **Hours per Unit**  **An nual** 

**Hours An**  **nual Cost I. Part C (PSD)**  A. Attend Preapplication Meetings 1,610 44 70,840 $5,738,040 B. Answer Respondent Questions 1,610 27 43,470 $3,521,070 C. Log In and Review Data Submissions 1,610 22 35,420 $2,869,020 D. Request Additional Information 1,610 10 16,100 $1,304,100 E. Analyze for and Provide Confidentiality Protection 1,610 24 38,640 $3,129,840 F. Prepare Completed Applications for Processing 1,610 39 62,790 $5,085,990 G. File and Transmit Copies 1,610 8 12,880 $1,043,280 H. Prepare Preliminary Determination 1,610 41 66,010 $5,346,810 I. Prepare Notices for and Attend Public Hearings 1,610 41 66,010 $5,346,810 J. Application Approval 1,610 51 82,110 $6,650,910 K. Notification of Applicant of RA Determination 1,610 8 12,880 $1,043,280 L. Submittal of Information on BACT/LAER to RBLC 1,610 21 33,810 $2,738,610 M. Total 336 540,960 $43,817,760 **II. Part D (Non -**  **attainment)** A. Attend Preapplication Meetings 486 7 3,402 $275,562 B. Answer Respondent Questions 486 10 4,860 $393,660 C. Log In and Review Data Submissions 486 10 4,860 $393,660 D. Request Additional Information 486 4 1,944 $157,464 E. Analyze for and Provide Confidentiality Protection 486 4 1,944 $157,464 F. Prepare Completed Applications for Processing 486 16 7,776 $629,856 G. File and Transmit Copies 486 4 1,944 $157,464 H. Prepare Preliminary Determination 486 10 4,860 $393,660 I. Prepare Notices for and Attend Public Hearings 486 19 9,234 $747,954 J. Application Approval 486 21 10,206 $826,686 K. Notification of Applicant of RA Determination 486 2 972 $78,732 L. Submittal of Information on BACT/LAER to RBLC 486 21 10,206 $826,686 M. Total 128 62,208 $5,038,848 **III. Minor NSR -**  **State/Local Programs** Total for Preparation and Submittal of Minor NSR Permit Application a 72,841 29 2,095,140 $169,706,340 **IV. SIP Revisions** Revision of SIP 51 40 2,040 $165,240 **V. GR AND TOT**  **AL** 74,988 2,700,348 $218,728,188 a The hours per unit for these activities are weighted averages rounded to the nearest whole number.**EC/R DRAFT 11/18/11** 

19 **Table 6 -**  **3. Ag**  **ency Burden and Cost ( An**  **nual) Activity**  **Units Hours**  **per Unit**  **An nual** 

**Hours An**  **nual**

**Cost ($1000)**  **I. Part C (PSD)** A. Review and Verify Applicability Determination 1,610 2 3,220 $148,120 B. Review Control Technology Determination 1,610 4 6,440 $296,240 C. Evaluate Air Quality Monitoring 1,610 1 1,610 $74,060 D. Evaluate Alternative and Secondary Im pact Analysis 1,610 5 8,050 $370,300 E. Evaluate Class I Area Analysis 1,610 3 4,830 $222,180 F. Administrative Tasks 1,610 1 1,610 $74,060 G. Total 16 25,760 $1,184,960 **II. Part D (Non -**  **attainment)** A. Review and Verify Applicability Determination 486 2 972 $44,712 B. Review Control Technology Determination 486 4 1,944 $89,424 C. Evaluate Offsets 486 1 486 $22,356 D. Evaluate Air Quality Monitoring 486 5 2,430 $111,780 E. Evaluate Alternative and Secondary Im pact Analysis 486 3 1,458 $67,068 F. Administrative Tasks 486 1 486 $22,356 G. Total 16 7,776 $357,696 **III. Minor NSR –**  **State/Local Programs** Review Synthetic/Netting
- Based Minor NSR Permits 2,957 2 6,964 $320,344 **IV. Minor NSR -**  **Indian Country Program** Review Minor NSR Permits and Registrations a 12,432 4 44,568 $4,567,077 **V. SIP Revisions** Review of SIP revisions 51 5 255 $11,730 **V I**  **. GRA ND TOTA**  **L** 17,536 85,323 $ 6,441,807 a The hours per unit for these activities are weighted averages rounded to the nearest whole number.**EC/R DRAFT 11/18/11** 

20 **Table 6 -** **4. NSR Program Information Collection Burden Summary Total**  **Per Unit**
Part C (PSD) Part D

(Non
attainment) Minor NSR

State/Local Minor NSR

Indian Country Cumulative

Total a+b Part C

(PSD) Part D

(Non
attainment) Minor NSR

State/Local Minor

NSR Indian Country Number of Responses a 3,220 972 145 , 682 12,432 162,357 Respondent Burden Hours Industry 1,619,660 312,012 2, 822,885 479,435 5,233,992 1,006 642 39 39

State/Local 540,960 62,208 2, 095,140 0 2,700,348 336 12 8 29 0 Industry and State/ Local Agency Totals 2,160,620 374,220 4,917,995 479,435 7, 934,340 1, 342 7 70 68 39 Federal (Agency) Burden 25,760 7,776 6,964 44,568 85,323 1 6 16 2 4 Program Grand Total Burden 2,186,380 381,996 4,924,959 524,003 8,019,663

Respondent Annual Cost ($1000 ) c Industry Labord $ 160,346 $ 30,889 $2 79,466 $5,212 $ 475,913 $ 99.59 $ 63.56 $3. 8 4 $0.42

Other Direct Costs e $ 12,444 $0 $0 $141 $1 2,585 $ 366 .01 $0.00 $0.00 $0.01 Total Industry Costs f $ 172,791 $ 30,889 $2 79,466 $5,353 $ 488,499 $ 107

. 3 2 $63.56 $3.8 4 $0.43 State/Local Costs $ 43,817 $5,0 39 $1 69,706 $0 $ 218,728 $2 7 .22 $ 10.37 $2.3 3 $0 Industry and State/Local Agency Totals $ 216,608 $ 35,928 $4 49,172 $5,353 $ 707,227 Agency Annual Costs ($1000) $ 1,185 $358 $ 320 $ 4,567 $ 6,442 $0. 74 $0. 74 $0.00 $0.37 Program Grand Total Costs ($1000) $ 217,793 $ 36,286 $4 49,492 $9,920 $ 713,669 $ 1 35

. 28 $7 4.66 $ 6.17 $0.80 (a) In general, the number of responses is twice the number of permitting actions for a given category due to (1) the applicant preparing the application , and (2) the state/local reviewing authority reviewing and issuing the permit. For the minor NSR program in Indian country the number of responses is the number of permitting actions because the EPA is the reviewing authority. (b) T he 112 reviewing authorities are expected to su bmit an average of 51 SIP revision s per year totaling 2,040 hours and $165,240 to conform their major NSR programs to the revised rules. The EPA will review the 51 SIP revisions per year, totaling 255 hours and $11,730

. These figures are added into the Cum ulative column. (c) In general, costs are in thousands of current ( 2011 ) dollars and represent one - time permit application costs. For the minor NSR program in Indian country, costs are in 2009 dollars. (d) The EPA estimates that 30% of the in
- house hourly burden may be contracted, but because it is at the discretion of the applicant, the cost has not been converted to direct cost. Furthermore EPA assumes the labor rate would remain the same, in which case there is no impact on total annual c osts. (e ) These direct costs are for 34 PSD sources (approximately 12% of the 274 sources that are subject to PSD for pollutants other than greenhouse gases) at $ 366,006 per source, for pre
- application monitoring of air quality via contract services. This cost is not incurred by Part D or minor NSR permit applicants. (f) Per unit cost for PSD permits reflects the direct cost for pre
- application monitoring averaged over all PSD permits. The estimated 34 sources that require preconstruction monitoring are estimate d to incur a n average total cost of $ 465,600 per application. The others will incur an average of $ 99,594

.**EC/R DRAFT 11/18/11** 

21 

### APPENDIX A

IN FORMAT ION REQUIREMENTS**EC/R DRAFT 11/18/11** 

22 

### TABLE A**- 1**  **. INDUSTRY RESPONDENT DATA AND**  **INFORMATION REQUIREMENTS FOR PREPARING PART C (PSD) CONSTRUCTION PERMITS**  Requirement Regulation Reference All information necessary to perform any

anal ys is or make any determination required 40 CFR 51.166(n)( 1 ) Description of the nature, location, design capacity, and ty pical operating schedule 40 CFR 51.166(n)(2)( i )
Detailed schedule for construction 40 CFR 51.166(n)(2)(ii) Description of continuous emission reduction sy stem, emission estimates, and other information needed to determine that BACT is used 40 CFR 51.166(n)(2)(iii) Air quality

impact, meteorological, and topographical data 40 CFR 51.166(n)(3)( i ) Nature and extent of, and air quality impacts of general commercial, residential, industrial, and other growth in area of source 40 CFR 51.166(n)(3)(ii) Use of air quality

models to demonstrate compliance with NAAQS and increment 40 CFR 51.166(k) & (l) Air quality

monitoring data 40 CFR 51.166(m) Impairment of visibility, soils, and vegetation 40 CFR 51.166(o)(1) Air quality

impact resulting from general commercial, residential, industrial, and other growth associated with source 40 CFR 51.166(o)(2) Written notice of proposed relocation from portable source 40 CFR 51.166( i )( 1 )(iii)( d ) Description of the location, design construction, and operation of building, structure, facility , or installation 40 CFR 51.160(c)(2) Description of the nature and amounts of emissions to be emitted 40 CFR 51.160(c)(1) Description of the air quality data and dispersion or other air quality modeling used 40 CFR 51.160(f) Sufficient information to ensure attainment and maintenance of NAAQS 40 CFR 51.160(c)

- (e), 40 CFR 51.161
- 163**EC/R DRAFT 11/18/11** 

23 

### Table A**- 2: INDUSTRY RESPONDENT DATA AND INFORMATION REQUIREMENTS FOR**  **PREPARING PART D (NONATTAINMENT**  **NSR) CONSTRUCTION PERMITS** Requirements Regulation Reference Documentation that LAER is being applied 40 CFR 51.165(a)(2); 40 C FR part 51, Appendix S, section IV.A; 40 CFR 52.24(k) Documentation that all sources owned or operated by same person are in compliance 40 CFR 51.165(a)(2); 40 C FR part 51, Appendix S, section IV.A; 40 CFR 52.24(k) Documentation that sufficient emissions reductions are occurring to compl y with specific offset requirements and to ensure RFP 40 CFR 51.165(a)(3); 40 C FR part 51, Appendix S, section IV.A; 40 CFR 52.24(k) Documentation that benefits of proposed source significantly outweigh the environmental and social costs imposed as a result of its location, construction, or modification 40 CFR 51.165(a)(2)
Description of the location, design construction, and operation of building, structure, facility , or installation 40 CFR 51.160(c)(2) Description of the nature and amounts of emissions to be emitted 40 CFR 51.160(c)(1) Description of the air quality data and dispersion or other air quality modeling used 40 CFR 51.160(f) Sufficient information to ensure attainment and maintenance of NAAQS 40 CFR 51.160(c)

- (e) 40 CFR 51.161 40 CFR 51.162 40 CFR 51.163**EC/R DRAFT 11/18/11** 

24 

### TABLE A**- 3**  **. PERMITTING AGENCY DATA**  **AND INFORMATION REQUIREMENTS** Requirement Regulation Reference Earl y FLM notification and opportunity to participate in meetings 40 CFR 51.166(p)(1)(ii) Submission of all permit applications to EPA 40 CFR 51.166(q)(1) Submission of notice of application, preliminary determination, degree of increment consumption, and opportunity for public comment 40 CFR 51.166(q)(2)(iv)
Submission to FLM of permit applications 40 CFR 51.166(p)(1) Submission of written request to exempt sources from review 40 CFR 52.21( i )(4)(vi) Written request for use of innovative control technology 40 CFR 51.166(s) Establishing and operating a permitting program for all new sources 40 CFR 51.160 Provide notice to EPA of all permits 40 CFR 51.161(d) Provide for public comment for all NSR permits 40 CFR 51.161**EC/R DRAFT 11/18/11** 

25 

### APPENDIX B

CAL CULATIONS AND INFORMAT ION REQUIREMENTS FOR THE MINOR NSR PROGRAM IN INDIAN COUNTRY**EC/R DRAFT 11/18/11** 

26 

### Table B **- 1.**  **Estimated Total Burden and Cost to Industry to Implement Reporting and R** **ecordkeeping Requirements During 3 -** **Year**

**Term of the ICR a** 
Affected Source Type Number of Affected Sources Total Hours

per Source Total Hours

(All Sources, 3 Years) b Annualized

Non
- Labor Capital Cost per Source c Total Cost

per Source d Total

Annualized Non
- Labor Capital Costs Total Costs New Minor Sources (Years 1 and 2)
- Registration 2,536 5 12,680 $4 $62 $10,144 $157,232 New Minor Sources (Year 3)
- Permitting 1,268 286 1,087,944 $191 $9,435 $242,188 $11,963,580 Modifications to Minor Sources (Years 1 and 2)
- Registration 328 5 1,640 $4 $62 $1,312 $20,336 Modifications to Minor Sources (Year 3)
- Permitting 164 286 140,712 $191 $9,435 $31,324 $1,547,340 Ex isting Synthetic Minor Sources
- Permitting 79 65 5,135 $4 $618 $316 $48,822 Ex isting True Minor Sources
- Registration 32,891 5 164,455 $4 $62 $131,564 $2,039,242 Minor Modifications to Major Sources
- Permitting 6 286 5,148 $191 $9,435 $1,146 $56,610 New Synthetic Minor Sources
- Permitting 24 286 20,592 $191 $9,435 $4,584 $226,440 Totals for 3 Years 37,296 1,438,306 $422,578 $16,059,602 Annual averages 12,432 479,435 $140,859 $5,353,201 Annual average labor cost $5,212,341 a Reproduced from EPA ICR No. 1230.27 ; revised to update phases of implementation during the term of this ICR. b Sources only subject to one
-time registration or permitting costs (new minor sources during the first 2 years, modifications to minor sources during the first 2 years, existing minor sources, and existing synthetic minor sources) are only attributed hours for 1 y ear. For the remaining affected sources, hours per year were multiplied by 3 years. c The associated non
- labor capital costs for one
- time and recurring activities for permitting new minor sources, modifications to minor sources, minor modifications to majo r sources, and new synthetic sources is $1,340. Annualized based on a repayment period of 10 years and an interest rate of 7 pe rcent, the amount is $191. For registrations the non
- labor capital costs are $25 and for existing synthetic minor sources these c osts are $31; annualized based on a repayment period of 10 years and an interest rate of 7 percent, both result in $ 4. d Sum of total recurring costs and the annualized non
- labor cost.**EC/R DRAFT 11/18/11** 

27 

### Table B **- 2.**  **Estimated Total Burden and Cost to EPA**  **to Act as Rev** **iewing Authority During 3**  **- Year Term of the ICR** **a**

Affected Source Type Number of Affected Sources (First 3 Years) Average Total

Hours per Source Total Hours Average Cost per Source Total Costs New Minor Sources (Years 1 and 2)
- Registration 2,536 2 5,072 $180 $456,480 New Minor Sources (Year 3)
- Permitting 1,268 42 53,256 $4,932 $6,253,776 Modifications to Minor Sources (Years 1 and 2)
- Registration 328 2 656 $180 $59,040 Modifications to Minor Sources (Year 3)
- Permitting 164 42 6,888 $4,932 $808,848 Ex isting Synthetic Minor Sources
- Permitting 79 10 790 $693 $54,747 Ex isting True Minor Sources
- Registration 32,891 2 65,782 $180 $5,920,380 Minor Modifications to Major Sources
- Permitting 6 42 252 $4,932 $29,592 New Synthetic Minor Sources
- Permitting 24 42 1,008 $4,932 $118,368 Totals for 3 Years 37,296 133,704 $13,701,231 Annual averages 12,432 44,568 $4,567,077 a Reproduced from EPA ICR No. 1230.27; revised to update phases of implementation during the term of this ICR.**EC/R DRAFT 11/18/11** 

28 

### Table B **- 3. New Sources and Modifications in Indian Country Respondent (Facility) Burden and Cost (One**  **- Time and Reoccurring)**  (This table is reproduced verbatim from EPA ICR 1230.27. After it was prepared, the provisions of the rule were chan ged, rendering the cited timing

—i.e., referring to the first 18 months

—incorrect.)

Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical $114 $114 $65 $49 **NEW/MODIFIED MINOR SOURCES AF**  **TER THE FIRST 18 MONTHS** 1. Preparation and Planning a. Determination of compliance requirements (#) 0 2 8 0 1 1 10 $0 $229 $522 $0 $751 $0 $751 b. Obtain guidance on data needs (#) 0 0 2 0 1 1 2 $0 $0 $131 $0 $131 $0 $131 c. Preparation of PTE for NSR pollutants (#) 0 4 16 2 1 1 22 $0 $458 $1,045 $97 $1,600 $0 $1,600 2. Data Collection and Analysis (Surveys & Studies) a. Conduct ambient air modeling (#) 0 2 40 4 1 0.02 0.9 $0 $5 $52 $4 $61 $200 $261 3. P ermit Application a. Preparation and submittal of Permit Application (#) 2 4 40 16 1 1 62 $229 $458 $2,612 $776 $4,075 $25.00 $4,100 b. Public hearing (#) 4 4 16 8 1 0.05 2 $23 $23 $52 $19 $117 $1.25 $119 c. Revisions to permit (#) 1 1 4 2 1 0.2 2 $23 $23 $52 $19 $117 $5.00 $122 4. Acquisition, Installation, and Use of Technology and Systems a. Control device operating parameter (#) (emission) monitoring system 0 4 20 2 1 0.05 1 $0 $23 $65 $5 $93 $0 $93 5. Reporting Requirements a. Read instructions (#) 0 2 4 0 1 1 6 $0 $229 $261 $0 $490 $0 $490 b. Required activities (#) c. Create information i. Conduct control device performance test (#) 0 8 40 8 1 0.02 1 $0 $18 $52 $8 $78 $1,000 $1,078 d. Gather existing information (#) 0 0 8 2 1 1 10 $0 $0 $522 $97 $619 $0 $619 e. Wr ite reports i. Initial notification of intent to constr/modify (#) 1 2 4 2 1 1 9 $114 $229 $261 $97 $702 $25.00 $727 ii. Performance test notification (#) 0 0 2 1 1 0.02 0.1 $0 $0 $3 $1 $4 $0.50 $4**EC/R DRAFT 11/18/11** 

29 Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Manageria l Technical Clerical $114 $114 $65 $49 **NEW/MODIFIED MINOR SOURCES AF**  **TER THE FIRST 18 MONTHS** iii. Site
- specific test plan (#) 0 1 16 8 1 0.02 0.5 $0 $2 $21 $8 $31 $0.50 $31 iv. Initial compliance status determination (#) 1 4 8 4 1 1 17 $114 $458 $522 $194 $1,289 $25.00 $1,314 v. Performance test reports (#) 0 4 16 4 1 0.02 0.5 $0 $9 $21 $4 $34 $0.50 $34 vi. Annual monitoring report (##) 1 2 8 4 1 1 15 $114 $229 $522 $194 $1,060 $25.00 $1,085 vii. Deviation report (##) 1 2 4 2 1 0.1 0.9 $11 $23 $26 $10 $70 $2.50 $73 6. Recordkeeping Requirements a. Read instructions (##) 1 2 8 0 1 1 11 $114 $229 $522 $0 $866 $0.00 $866 b. Plan activities (##) 0 2 8 2 1 1 12 $0 $229 $522 $97 $848 $0.00 $848 c. Implement activities i. Prepare documentation for exempted sources (#) 4 2 20 8 1 0.1 3 $46 $23 $131 $39 $238 $2.50 $241 ii. Monitor control device parameters (##) 0 0 1 0 52 0.1 5 $0 $0 $340 $0 $340 $0.00 $340 iii. Inspect control device (##) 0 0 1 0 12 1 12 $0 $0 $783 $0 $783 $0.00 $783 d. Develop record system (#) 0 2 4 16 1 1 22 $0 $229 $261 $776 $1,267 $25.00 $1,292 e. Time to enter information (##) 0 0 1 0 52 1 52 $0 $0 $3,395 $0 $3,395 $0.00 $3,395 f. Time to train personnel (#) 0 0 40 4 1 0.1 4 $0 $0 $261 $19 $281 $2.50 $283 g. Time to perform audits (##) 0 2 20 0 1 0.1 2 $0 $23 $131 $0 $153 $0.00 $153

**TOTA L**  286 $19,493 $1,340 $20,833 **NEW/MODIFIED MA**

**JOR SOURCES IN NONA** 

**TTA INMENT A** **RE AS**  1. Preparation and Planning a. Determination of compliance requirements (#) 0 2 8 0 1 1 10 $0 $229 $522 $0 $751 $0 $751 b. Obtain guidance on data needs (#) 0 0 2 0 1 1 2 $0 $0 $131 $0 $131 $0 $131 c. Preparation of PTE for NSR pollutants (#) 0 4 16 2 1 1 22 $0 $458 $1,045 $97 $1,600 $0 $1,600**EC/R DRAFT 11/18/11** 

30 Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Manageria l Technical Clerical $114 $114 $65 $49 2. Data Collection and Analysis (Surveys & Studies) a. Conduct LAER analysis (#) 0 4 40 4 1 1.00 48.0 $0 $458 $2,612 $194 $3,264 $10,000 $13,264 Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor C osts per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical $114 $114 $65 $49 **NEW/MODIFIED MA**

**JOR SOURCES IN NONA** 

**TTA INMENT A** **RE AS**  3. Permit Application a. Preparation and submittal of Permit Application (#) 2 4 40 16 1 1 62 $229 $458 $2,612 $776 $4,075 $25.00 $4,100 b. Public hearing (#) 4 4 16 8 1 0.05 2 $23 $23 $52 $19 $117 $1.25 $119 c. Revisions to permit (#) 1 1 4 2 1 0.2 2 $23 $23 $52 $19 $117 $5.00 $122 d. Permit appeal (#) 20 5 10 10 1 0.2 9 $458 $114 $131 $97 $800 $5.00 $805 4. Acquisition, Installation, and Use of Technology and Systems a. Control device operating parameter (#) (emission) monitoring system 0 4 20 2 1 0.05 1 $0 $23 $65 $5 $93 $0 $93 5. Reporting Requirements a. Read instructions (#) 0 2 4 0 1 1 6 $0 $229 $261 $0 $490 $0 $490 b. Required activities (#) c. Create information i. Conduct control device performance test (#) 0 8 40 8 1 0.02 1 $0 $18 $52 $8 $78 $1,000 $1,078 d. Gather existing information (#) 0 0 8 2 1 1 10 $0 $0 $522 $97 $619 $0 $619 e. W rite reports i. Initial notification of intent to constr/modify (#) 1 2 4 2 1 1 9 $114 $229 $261 $97 $702 $25.00 $727 ii. Performance test notification (#) 0 0 2 1 1 0.02 0.1 $0 $0 $3 $1 $4 $0.50 $4 iii.Site
- specific test plan (#) 0 1 16 8 1 0.02 0.5 $0 $2 $21 $8 $31 $0.50 $31 iv. Initial compliance status determination (#) 1 4 8 4 1 1 17 $114 $458 $522 $194 $1,289 $25.00 $1,314 v. Performance test reports (#) 0 4 16 4 1 0.02 0.5 $0 $9 $21 $4 $34 $0.50 $34 vi. Annual monitoring report (##) 1 2 8 4 1 1 15 $114 $229 $522 $194 $1,060 $25.00 $1,085 vii. Deviation report (##) 1 2 4 2 1 0.1 0.9 $11 $23 $26 $10 $70 $2.50 $73 Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor C osts per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical $114 $114 $65 $49 **NEW/MODIFIED MA**

**JOR SOURCES IN NONA** 

**TTA INMENT A** **RE AS** **EC/R DRAFT 11/18/11** 

31 Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Manageria l Technical Clerical $114 $114 $65 $49 6. Recordkeeping Requirements a. Read instructions (##) 1 2 8 0 1 1 11 $114 $229 $522 $0 $866 $0.00 $866 b. Plan activities (##) 0 2 8 2 1 1 12 $0 $229 $522 $97 $848 $0.00 $848 c. Implement activities i. Prepare documentation for exempted sources (#) 4 2 20 8 1 0.1 3 $46 $23 $131 $39 $238 $2.50 $241 ii. Monitor control device parameters (##) 0 0 1 0 52 0.1 5 $0 $0 $340 $0 $340 $0.00 $340 iii. Inspect control device (##) 0 0 1 0 12 1 12 $0 $0 $783 $0 $783 $0.00 $783 d. Develop record system (#) 0 2 4 16 1 1 22 $0 $229 $261 $776 $1,267 $25.00 $1,292 e. Time to enter information (##) 0 0 1 0 52 1 52 $0 $0 $3,395 $0 $3,395 $0.00 $3,395 f. Time to train personnel (#) 0 0 40 4 1 0.1 4 $0 $0 $261 $19 $281 $2.50 $283 g. Time to perform audits (##) 0 2 20 0 1 0.1 2 $0 $23 $131 $0 $153 $0.00 $153

**TOTA L**  342 $23,496 $11,145 $34,641**EC/R DRAFT 11/18/11** 

32 Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Manageria l Technical Clerical $114 $114 $65 $49 **EXISTING SYNTHETIC MINOR SOURCES**  1. Permit Application a. Preparation and submittal of Permit Application (#) 2 4 40 16 1 1 62 $229 $458 $2,612 $776 $4,075 $25.00 $4,100 b. Public hearing (#) 4 4 16 8 1 0.05 2 $23 $23 $52 $19 $117 $1.25 $119 c. Revisions to permit (#) 1 1 4 2 1 0.2 2 $23 $23 $52 $19 $117 $5.00 $122

**TOTA L**  65 $4,310 $31 $4,341**EC/R DRAFT 11/18/11** 

33 Facility NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category (AxBxCxRate) (F) Total Labor Costs (G)

Associated Costs (H)

Total Costs (F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical $114 $114 $65 $49 **EXISTING TRUE M INOR SOURCES**  **AN D NEW TRUE MINOR SOURCES**  **DURING FIRST 18 MONTHS** 1. Registration a. Read instructions (#) 0 1 1 0 1 1 2 $0 $114 $65 $0 $180 $0 $180 b. Minor source facility registration (#) 0 1 1 1 1 1 3 $0 $114 $65 $49 $228 $25.00 $253

**TOTA L**  5 $408 $25 $433 **Notes: # = One**  **- tim**  **e costs that are incurred and treated as capital costs. ## = Annual or reoccurring cost included as an annual cost.**  **For New/Modified Minor Sources after the First 18 Months:**  **Based on the above costs, the average capital cost per facility for the one -** **tim e activities is $13,290 per source (i.e., the sum of those items identified as one**  **- tim**  **e costs [#]); annualized, this cost is $1,892 per year per source. The averag**  **e non -**  **labor capital cost is $1,340 (total of column G); annualized, this cost is $191 per year per source. The total of the various annual and reoccurring costs (##) in colum**  **n H plus the annualized capital cost is an averag e of $9,435 per year per source.**  **For New/Modified Major Sources in Nonattainment Areas: Based on the above costs, the average capital cost per facility for the one**  **- tim**  **e activities is $17,138 per source (i.e., the sum of those items identified as one -**  **tim e costs**  **(#)); annualized, this cos t is $2,440 per year per source. The average non**  **- labor capital cost is $1,185 (total of column G); annualized, this cost is $169 per year per**  **source. The total of the various annual and reoccurring costs (##) in colum n H plus the annualized capital cost**  **is an average of $9,983 per year per source. EC/R DRAFT**  **11/18/11**

34 

### Table B **- 4**  **. New Sources and Modifications in Indian Country Agency**  **Burden and Cost (One -**  **Time and Reoccurring)** (This table is reproduced verbatim from EPA ICR 1230.27. After it was prepared, the provisions of the rule were changed, rendering the cited timing

—i.e., referring to the first 18 months

—incorrect.)

Agency NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F) Total Labor Costs (G)

Associated Annual Costs (H)

Total Costs per year (F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical $114 $114 $65 $49 **NEW/MODIFIED SOURCES (Major and Minor)**  1. Permit Review a. Initial permit review 0 1 8 0 1 1 9 $0 $114 $522 $0 $637 $0 $637 b. Public Hearing 0 1 8 8 1 0.05 0.9 $0 $6 $26 $19 $51 $5 $56 c. Permit Revisions 1 1 4 0 0.2 0 $0 $0 $0 $0 $0 $0 $0 2. Report Review a. Initial notification of intent to constr/modify 0 1 4 0 1 1 5 $0 $114 $261 $0 $376 $0 $376 b. Appeal 1 1 4 0 1 0.1 0.6 $11 $11 $26 $0 $49 $0 $49 c. Performance test notification 0 1 2 0 1 0.02 0.06 $0 $2 $3 $0 $5 $0 $5 d. Site
- specific test plan 0 1 8 0 1 0.02 0.2 $0 $2 $10 $0 $13 $0 $13 e. Initial compliance determination 0 1 8 0 1 1 9 $0 $114 $522 $0 $637 $0 $637 f. Performance test reports 0 2 16 0 1 0.02 0.4 $0 $5 $21 $0 $25 $0 $25 g. Annual monitoring report 0 2 8 0 1 1 10 $0 $229 $522 $0 $751 $0 $751 h. Deviation report 0 2 4 0 1 0.1 0.6 $0 $23 $26 $0 $49 $0 $49 i. Annual monitoring reports 0 1 4 0 1 0.1 0.5 $0 $11 $26 $0 $38 $0 $38 3. Site Compliance Inspections (a,b) a. Pre
- inspection review of facility information 0 1 8 1 1 0.1 1 $0 $11 $52 $5 $69 $0 $69 b. Travel to and from facility (b) 0 0 8 0 1 0.1 0.8 $0 $0 $52 $0 $52 $10 $62 c. Inspection of air control equipment used to comply with rule requirements 0 0 4 0 1 0.1 0.4 $0 $0 $26 $0 $26 $0 $26 d. Review site records 0 0 4 0 1 0.1 0.4 $0 $0 $26 $0 $26 $0 $26 e. Prepare inspection report 0 4 16 4 1 0.1 2 $0 $46 $104 $19 $170 $3 $172**EC/R DRAFT 11/18/11** 

35 Agency NSR Program Activity (A) Labor Hours per Activity per Labor Category (B) Activities per Respondent per Year (C)

Total Number of Respondents (D)

Total Hours (E) Labor Costs per Labor Category

(AxBxCxRate) (F) Total Labor Costs (G)

Associated Annual Costs (H)

Total Costs per year (F+G) Legal Managerial Technical Clerical Legal Managerial Technical Clerical $114 $114 $65 $49 4. E nforcement Actions (c,d) a. Inform facility of noncompliance 4 4 20 8 1 0.01 0.4 $5 $5 $13 $4 $26 $0 $26 b. Follow
- up site inspection 0 4 20 4 1 0.01 0.3 $0 $5 $13 $2 $20 $1 $21 **TOTA L**  **ANNU AL** **COST PER**

**SOURCE** 42 $3,019 $19 $3,037 5. Litigation Cost per Tribal Agency 40 40 100 40 1 0.3 73 $1,525 $1,525 $2,174 $646 $5,871 $17 $5,887

**TOTA L**  115 8,889 35 8,925 6. EPA Overview of Tribal Agency 8 8 40 8 1 1 64 $916 $916 $2,612 $388 $4,832 $100 $4,932 **EXISTING SYNTHETIC MINOR SOURCES**  1. Permit Review a. Initial permit review 0 1 8 0 1 1 9 $0 $114 $522 $0 $637 $0 $637 b. Public hearing 0 1 8 8 1 0.05 0.9 $0 $6 $26 $19 $51 $5 $56 c. Permit revisions 1 1 4 0 0.2 0 $0 $0 $0 $0 $0 $0 $0

**TOTA L**  10 $688 $5 $693 **EXISTING TRUE MINOR SOURCES AN**  **D NEW TRUE MINOR SOURCES DURING FIRST 18 MONTHS**  1. Registration Review a. Minor source facility registration 0 1 1 0 1 1 2 $0 $114 $65 $0 $180 $0 $180

**TOTA L**  2 $180 $0 $180