INFORMATION COLLECTION REQUEST 

UPDATE FOR THE 40 CFR PART 64 

COMPLIANCE ASSURANCE 

MONITORING PROGRAM 

EPA ICR No. 1663.07 

OMB Control No. 2060-0376 

Prepared by: 

United States Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sectors, Policies, and Programs Division 

Measurement Policy Group 

Research Triangle Park, NC 27711 

January 2010 
Contents 

1. IDENTIFICATION OF THE INFORMATION COLLECTION ............................................. 3 

1(a) TITLE OF THE INFORMATION COLLECTION ...................................................... 3

1(b) SHORT CHARACTERIZATION/ABSTRACT .......................................................... 3

2. NEED FOR AND USE OF THE COLLECTION .................................................................... 5

2(a) NEED/AUTHORITY FOR THE COLLECTION ........................................................ 5

2(b) PRACTICAL UTILITY/USERS OF THE DATA ....................................................... 7

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA ...... 8

3(a) NONDUPLICATION ................................................................................................... 8

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB ............... 8

3(c) CONSULTATIONS ..................................................................................................... 8

3(d) EFFECTS OF LESS FREQUENT COLLECTION ...................................................... 8

3(e) GENERAL GUIDELINES ........................................................................................... 9

3(f) CONFIDENTIALITY ................................................................................................. 10

3(g) SENSITIVE QUESTIONS ......................................................................................... 10

4. THE RESPONDENTS AND THE INFORMATION REQUESTED .................................... 10

4(a) RESPONDENTS/SIC CODES ................................................................................... 10

4(b) INFORMATION REQUESTED ................................................................................ 11

4(b)(i) DATA ITEMS .......................................................................................... 11

4(b)(ii) RESPONDENT ACTIVITIES .................................................................. 14

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT ............................................ 14

5(a) AGENCY ACTIVITIES ............................................................................................. 14

5(b) COLLECTION METHODOLOGY AND MANAGEMENT .................................... 14

5(c) SMALL ENTITY FLEXIBILITY .............................................................................. 15

5(d) COLLECTION SCHEDULE ...................................................................................... 15

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION ................................ 15

6(a) ESTIMATING TOTAL RESPONDENT BURDEN .................................................. 15

6(b) ESTIMATING TOTAL RESPONDENT COSTS ...................................................... 16

6(b)(i) Estimating Labor Costs ............................................................................. 16

6(b)(ii) Estimating Capital and Operations and Maintenance Costs ..................... 18

6(c) ESTIMATING AGENCY BURDEN AND COST .................................................... 18

6(d) REASONS FOR CHANGE IN BURDEN ................................................................. 18

6(e) BURDEN STATEMENT ........................................................................................... 18
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1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) TITLE OF THE INFORMATION COLLECTION 

This document fulfills the Agency's requirements under the Paperwork Reduction Act 

(PRA) with regards to determining the regulatory burden associated with the Compliance 

Assurance Monitoring (CAM) Rule, codified at 40 CFR part 64. It has been assigned EPA 

tracking number 1663.07 and OMB Control Number 2060-0376. The title of this Information 

Collection Request (ICR) is “Information Collection Request Update for the 40 CFR Part 64 

Compliance Assurance Monitoring Program.” 

1(b) SHORT CHARACTERIZATION/ABSTRACT 

Part 64 of the Code of Federal Regulations (CFR), as defined in the CAM Rule, requires 

monitoring, compliance certification, periodic reporting, and record keeping information 

collections by owners and operators of title V sources [57 Fed. Reg. 32250-32312] (1992) 

(codified at 40 C.F.R. part 70) 1 with controlled pollutant specific emissions units that have a 

pre-control potential to emit major amounts of regulated air pollutants. 

CAM identifies two categories of emissions units: 

(1) “Large” pollutant-specific emissions units (PSEU): units that have the 

potential to emit, with controls, the applicable regulated air pollutant in an amount 

equal to or greater than the amount required for a source to be classified as a 

major source, and 

(2) “Other” pollutant-specific emissions units: the set of remaining affected 

pollutant specific emission units. 

These two types of units are subject to different monitoring frequency requirements, but 

not to different reporting or recordkeeping requirements, which are the subject of this ICR. 

Additionally, “large” and “other” units are subject to different implementation timetables under 

part 64. However, this analysis assumes that no units had yet submitted their monitoring 

approaches to their permitting authorities as of January 2007, so all existing units would submit 

their monitoring approaches at permit renewal, in which case the implementation timetables are 

the same for both types of units. For these reasons, this analysis does not differentiate between 

“large” and “other” units. 

Upon approval by the permitting authority (PA) of the monitoring proposed by the 

source, the source uses the approved monitoring method to collect data. These data provide the 

basis on which owners or operators can certify, in accordance with the requirements of the 

operating permit program, the compliance of their emissions units with the applicable 

 

1 For purposes of simplicity, this ICR applies the terms “owners and operators”, “firm”, and “sources” interchangeably. References to 

actions or responsibilities of sources or firms should be interpreted as referring to the owners and operators of that source or firm.
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requirements. In addition, these data provide the basis on which owners or operators submit 

monitoring reports on no less than a semi-annual basis. Consistent with the recordkeeping 

period established in the operating permit program, CAM requires sources to store and maintain 

these data for at least five years. 

In the next three years, the information collection and capital investment requirements of 

the CAM program will involve all of the affected pollutant points. When fully implemented, the 

Agency estimates the CAM program will involve approximately 25,000 emissions units. This 

ICR estimates the expected average annual burden over the next three years to be about 7.4 

million hours, at an expected cost of $260 million (2008 dollars). The activities at sources 

leading to these impacts include: 

• Determination of a monitoring approach; 

• Installation and operation of monitoring equipment, if necessary; 

• Administrative burden for record keeping and reporting; 

• Upgraded operating/maintenance activities; 

• Improved quality assurance; and 

• Permit fees to cover regulatory costs of the program. 

For this ICR and the previous ICR issued in 2007, we have used updated emissions 

inventory data (draft 2002 NEI) that reflect current information on units that may be subject to 

the CAM rule. 

In addition, we reviewed and updated, where necessary: 

• labor rates; 

• estimates of labor hours needed for each monitoring activity and monitoring practice 

(parameter monitoring, CEMS, work practices); and 

• the implementation schedule for CAM using current Title V data for both existing 

and new sources. 

We make specific assumptions about permit approvals and renewals in order to project 

when sources would submit their proposed monitoring approaches. We make the following 

assumptions to develop an implementation schedule that is consistent with the part 64 language: 

 

• Sixty percent of owners of affected PSEUs submitted their proposed monitoring 

approaches during the July 2007 through January 2010 time period addressed by the 

previous ICR, leaving the remaining 40 percent to submit their proposed monitoring 

approaches during the three-year time period addressed in this current ICR (July 2010 

through January 2013). 

• Approximately 20 percent of existing part 70 permits are renewed each year, with 

half being renewed in January and half in July. The exact percentages have been 

calculated based on nationwide projections of part 70 permit renewals. 
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• Each year, part 70 permits will be issued for 20 new facilities, with half being issued 

in January and half in July. These facilities will have the same average number of 

PSEUs as in the full CAM database. 

• There is homogeneity between sources and PSEUs. Therefore, if 10 percent of all 

part 70 permits are renewed at a given time, than 10 percent of owners of all affected 

PSEUs will schedule their CAM activities around that date. 

Additionally, we assume that some new PSEUs would be built each year at existing 

permitted facilities, thus requiring a permit revision. We assume that 230 facilities nationwide 

would build additional PSEUs each year, with half being issued permit revisions in January and 

half in July. 

2. NEED FOR AND USE OF THE COLLECTION 

2(a) NEED/AUTHORITY FOR THE COLLECTION 

EPA decisions in both the operating permit and CAM programs require this information. 

 The operating permit program requires owners or operators of units that emit air pollutants to 

submit annual compliance certifications, to submit monitoring results at least semiannually, and 

to report deviations promptly, but no implementation guidance is provided within the operating 

permit program. CAM provides the vehicle to implement operating permits program 

requirements in a cost-effective manner.2 

The Clean Air Act (Act) Amendments of 1990, Public Law 101-549, enacted on 

November 15, 1990, establish the legal authority for this information collection. Section 502(b) 

directs EPA to promulgate regulations that will require the owners or operators of certain 

stationary sources of air pollution to conduct monitoring and to make compliance certifications. 

These provisions are set forth in both title V (operating permits provisions) and title VII 

(enforcement provisions) of the 1990 Amendments. 

Title V directs the Agency to implement monitoring and compliance certification 

requirements through the operating permits program. Section 503(b)(2) requires at least annual 

certifications of compliance with permit requirements and prompt reporting of deviations from 

permit requirements. Section 504(a) mandates that owners or operators submit to the PA the 

results of any required monitoring at least every six months. This section also requires permits 

to include “such other conditions as are necessary to assure compliance with applicable 

requirements” of the Act. Section 504(b) of the Act also allows the Agency to prescribe, by rule, 

methods and procedures for determining compliance, and states that continuous emission 

monitoring systems need not be required if other methods or procedures provide sufficiently 

reliable and timely information for determining compliance. Under section 504(c), each 

 

2 Efforts are currently underway to propose revisions to the 1997 CAM Rule. The proposed revisions address the: 

(1) conditions under which the CAM rule requirements would apply, and (2) development of monitoring of such 

emissions control measures not addressed in the current CAM rule. 
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operating permit must “set forth inspection, entry, monitoring, compliance certification, and 

reporting requirements to assure compliance with the permit terms and conditions.” 

Title VII of the 1990 Amendments added 114(a)(3) – a new section that requires EPA to 

promulgate rules on enhanced monitoring and compliance certifications. This paragraph 

provided, in part: 

“The Administrator shall in the case of any person which is the owner or operator 

of a major stationary source, and may, in the case of any other person, require 

enhanced monitoring and submission of compliance certifications. Compliance 

certifications shall include (A) identification of the applicable requirement that is 

the basis of the certification, (B) the method used for determining the compliance 

status of the source, (C) the compliance status, (D) whether compliance is 

continuous or intermittent, (E) such other facts as the Administrator may require.” 

The 1990 Amendments also revised section 114(a)(1) of the Act to provide additional 

authority concerning monitoring, reporting, and record keeping requirements. As amended, that 

section provides the Administrator with the authority to require any owner or operator of a 

source, on a one-time, periodic or continuous basis to: 

• establish and maintain such records; 

• make such reports; 

• install, use, and maintain such monitoring equipment; 

• sample such emissions (in accordance with such procedures or methods, at such 

locations, at such intervals, during such periods and in such manner as the 

Administrator shall prescribe); 

• keep records on control equipment parameters, production variables, or other indirect 

data when direct monitoring of emissions is impractical; 

• submit compliance certifications in accordance with section 114(a)(3); and 

• provide such other information as the Administrator may reasonably require. 

Obtaining ongoing compliance is a two-step process. First, the Agency must assure 

properly designed control measures are installed or otherwise employed. These measures 

include control devices, process modifications, operating limitations and other control measures 

as applicable. Furthermore, the Agency must assure the control measures are proven to be 

capable of achieving applicable requirements. In the past, this step has been addressed through 

new source review permitting, initial stack testing, compliance inspections and similar mechanisms. The title V permit application and review process, including the applicant’s initial compliance certification and compliance plan obligations, will add another tool for assuring that 

source owners or operators have adopted proper control measures for achieving compliance. 

The second step involves monitoring by sources to determine continued assurance that 

the source’s control measures, once installed or otherwise employed, are properly operated and 

maintained so that they do not deteriorate to the point where the owner or operator fails to 

remain in compliance with applicable requirements. The Agency believes that monitoring, 
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reporting, record keeping and ongoing or recurring compliance certification requirements under 

titles V and VII should be designed so that owners or operators carry out this second step in 

assuring ongoing compliance. The Agency has adopted the CAM approach to assure the proper 

operation and maintenance of control measures employed by sources. CAM establishes 

monitoring to: 

• document continued operation of the control measures within ranges of specified 

indicators of performance (such as emissions, control device parameters and process 

parameters) that are designed to provide a reasonable assurance of compliance with 

applicable requirements; 

• indicate any excursions from these ranges; and 

• respond to the data so that excursions are corrected. 

This type of monitoring is an appropriate approach to enhanced monitoring in the context 

of title V permitting for significant emission units that use control devices to achieve compliance 

with emission limits. In particular, CAM: 

• provides cost-effective achievement of air pollution emission reductions; 

• establishes voluntary compliance and self-certification by owners or operators; and 

• holds owners or operators accountable for regulated air pollutants emitted by units. 

2(b) PRACTICAL UTILITY/USERS OF THE DATA 

Owners or operators of affected emissions units will use the information as the basis for 

the compliance certification required by the operating permit program, and as the basis for 

compliance assurance monitoring reports. Sources will also use the information to determine 

and maintain the efficiency of the process or emissions control devices. 

PAs will use the information collected and submitted in permit applications in 

determining acceptability of proposed compliance assurance monitoring. The PAs will use 

source monitoring data to assess compliance, as input into reports to other agencies, and, when 

necessary, as evidence in enforcement proceedings. PAs will use the information on excursions 

and exceedances collected from owners or operators to require the development and 

implementation by source operators of a Quality Improvement Plan (QIP). The QIP will address 

the timetable, methods, and procedures for dealing with these excursions and exceedances. 

PAs will also collect summaries of information on compliance and will review the 

information as part of their permitting responsibilities and ongoing compliance activities. The 

information may be entered into local, regional, or national databases for review and action by 

air pollution control agencies. Other Federal entities, such as the Department of Energy, may 

request and use the information collected to fulfill specific mission objectives. Citizens may 

request the information collected in order to determine the compliance status of any emissions 

unit or particular group of emissions units. 
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3. NONDUPLICATION, CONSULTATIONS, AND OTHER 

COLLECTION CRITERIA 

3(a) NONDUPLICATION 

For approval of a proposed ICR, the Agency must ensure that it has taken every 

reasonable step to avoid duplication in its paperwork requirements in accordance with 5 CFR 

1320.4. The proposed part 64 rulemaking is mandated by the Act, and supports the title V 

permit program under 40 CFR part 70 as well as title VII enforcement provisions. Recognizing 

that many sources have already implemented monitoring strategies to fulfill their part 70 

requirements, the part 64 monitoring guidelines were carefully crafted by the Agency and OMB 

to minimize any unnecessary duplication. The part 64 CAM Rule has also been carefully 

designed to function, as much as possible, in a manner complementary to that of the part 70 

operating permit program managed by PAs. 

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB 

EPA has complied with the public notice requirement set forth in 5 CFR 1320.8(d)(1) by 

publishing a notice in the Federal Register. This notice opened a 60-day public comment period. 

3(c) CONSULTATIONS 

The Agency has continued discussions with stakeholders through a series of workshops 

and public meetings. The workgroups at these meetings discussed and reviewed CAM 

requirements and reviewed extensive public input concerning the development and 

implementation of CAM. For example, we conducted multiple workshops with state and local 

agency staff in over a dozen states since promulgating the rule and other monitoring related to 

the operating permits program. Those workshops have focused on the implementation of the 

rule. Much of the information exchange was in our describing the regulatory requirements in the 

40 CFR part 64, other requirements that apply (e.g., part 70, operating permits), operating 

permits content and supporting documentation requirements, and case studies as technical 

examples. The participants shared experiences in implementing the regulatory requirements 

including the number of staff involved in permit reviews, level of effort, and burden. 

Information we received in conjunction with the workshops also include additional case study 

examples. 

3(d) EFFECTS OF LESS FREQUENT COLLECTION 

As part of the permit application required under the operating permit program, an owner 

or operator must submit to the PA monitoring that satisfies the design requirements in 64.3. In 

addition, it must be demonstrated that the proposed monitoring is sufficient to provide 

compliance status information. Without such information, PAs will be unable to issue complete 

permits. Furthermore, owners or operators will be unable to certify compliance with emissions 
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limitations or standards unless costly reference test methods are employed. Part 64 requires 

semi-annual reports because the statute requires all monitoring reports to be submitted at least 

semiannually (section 504(a)). In addition, without timely evaluation of the reports, excess 

emissions of regulated air pollutants could rise. Consequently, less frequent collection of 

monitoring information is not permissible under the statute and could result in a net loss of 

environmental quality and was not considered for this rulemaking. 

3(e) GENERAL GUIDELINES 

OMB’s general guidelines for information collections must be adhered to by all Federal 

Agencies for approval of any rulemaking’s collection methodology. In accordance with the 

requirements of 5 CFR 1320.6, the Agency believes: 

• Part 64 regulations do not require periodic reporting more frequently than semiannually. 

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

survey. 

• Responses to Agency inquiries are not required to be submitted in less than thirty 

days. 

• Special consideration has been given in the design of part 64 to ensure that the 

requirements are, to the greatest extent possible, the same for Federal requirements 

and those permitting authorities who already have monitoring programs in place. 

• Confidential, proprietary, and trade secret information necessary for the completeness 

of the respondent’s permit are protected from disclosure under the requirements of 

'503(e) and '114(c) of the Act. 

• The part 64 regulations do not require more that one original and two copies of the 

permit application, update, or revision to be submitted to the Agency. 

• Respondents do not receive remuneration for the preparation of reports required by 

the Act or part 64. 

• To the greatest extent possible, the Agency has taken advantage of automated 

methods of reporting. 

• The Agency believes the impact of part 64 on small entities to be insignificant and 

not disproportionate. 

The record keeping and reporting requirements contained in the CAM program 

regulations do not exceed any of the Paperwork Reduction Act guidelines contained in 5 CFR 

1320.6, except for the guideline which limits retention of records by respondents to three years. 

The CAM program and the operating permit program require both respondents and State or local 

agencies to retain records for a period of five years. The justification for this exception is found 

in 28 U.S.C. 2462, which specifies five years as the general statute of limitations for Federal 

claims in response to violations by regulated entities. The decision in U.S. v. Conoco, Inc., 

No. 83-1916.E (W.D. Okla., January 23, 1984) found that the five year general statute of 

limitations applied to the Clean Air Act. 
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3(f) CONFIDENTIALITY 

Confidentiality is not an issue for this rulemaking. In accordance with the Clean Air Act 

Amendments of 1990, monitoring information must be submitted by sources as a part of their 

permit application and update; and revisions – all of which are a matter of public record. To the 

extent that the information required is proprietary, confidential, or of a nature that could impair 

the ability of the source to maintain its market position, that information is collected and handled 

subject to the requirements of sections 503(e) and 114(c) of the Act. Information received and 

identified by owners or operators as confidential business information (CBI) and approved as 

CBI by EPA, in accordance with Title 40, Chapter 1, Part 2, Subpart B, shall be maintained 

appropriately (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999, 

September 8, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). 

3(g) SENSITIVE QUESTIONS 

Sensitive questions (i.e., sexual, religious, personal or other private matters) are not 

applicable to this rulemaking. The information gathered for purposes of establishing an 

operating permit for a source do not include personal data on any owner or operator. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) RESPONDENTS/SIC CODES 

CAM applies to most Standard Industrial Classification (SIC) code groups and to certain 

service industries regulated under the Act. 

As applies to sections 4(a) and 5(a) of this document, this rule affects the owners of 

facilities in most Standard Industrial Classification code groups and all permitting authorities. 

We surveyed a subset of the sample States’ inspectors to determine baseline monitoring practices 

and to verify sample State database accuracy. We used the results of these surveys to establish 

the incremental impact of CAM for the surveyed PSEUs; these impacts are then projected to the 

remaining PSEU population in the sample States. 

The criteria for selecting States, in order of priority, were: 

• the availability of reasonably current, complete and electronically accessible pollutant- specific emissions unit data for all facilities in the State potentially subject to 

regulation under title V; 

• the willingness of State managers to allow their data to be used in the analysis and to 

commit their compliance program staff to a sample survey; 

• States that, altogether, would provide a reasonable representation of industry types 

throughout the United States; and 

• States that, altogether, would provide a reasonable representation of air quality 

problems throughout the United States. 
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We applied the draft 2002 National Emissions Inventory (NEI) and the Air Facility 

System (AFS) as the sources of data for the sample States. We discussed the availability and 

quality of data for individual States within these databases with other EPA staff who maintain 

these databases. From those select states we identified as reporting complete facility-level 

information, we selected a subset of sample States based on geographic distribution and diversity 

of industry type and size. Based on these discussions, we selected the following nine States as 

the sample States: Arkansas, Colorado, Illinois, Maine, Missouri, North Carolina, Texas, 

Virginia, and Wyoming. 

4(b) INFORMATION REQUESTED 

4(b)(i) DATA ITEMS 

The following matrices display the types of additional data required by the part 64 CAM 

Rule, along with the location of the requirement in the rule. 

FIGURE 4-1 

DATA REQUIRED BY THE INFORMATION COLLECTION

Additional Requirements for Permit Applications 

Regulation 

Reference 

For all major source pollutant-specific emission units that satisfy the applicability 

criteria outlined in 64.2, the owner or operator shall submit a proposed monitoring 

approach to the PA. The monitoring approach shall be submitted as part of the 

initial, revised, or renewed part 70 or 71 permit application. 

64.5

Consistent with the design requirements in 64.3, the submission shall include the following 

information:

the indicators to be monitored to satisfy 64.3(a)(1)-(2). 64.4(a)(1) 

either (i) the ranges or designated conditions for such indicators or (ii) the process 

by which such indicator ranges or designated conditions shall be established. 

64.4(a)(2) 

the performance criteria for the monitoring to satisfy 64.3(b). 64.4(a)(3) 

if applicable, the indicator ranges and performance criteria for a CEMS, COMS, or 

PEMS pursuant to 64.3(d). 

64.4(a)(4)

As part of the information submitted, the owner or operator shall submit:

a justification for the proposed elements of monitoring. The justification shall 

include any supporting data and may refer to any generally available sources of 

information such as air pollution engineering manuals or EPA or PA publications. In 

addition, the owner or operator may base the required justification exclusively on the 

64.4(b) 
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FIGURE 4-1 

DATA REQUIRED BY THE INFORMATION COLLECTION

Additional Requirements for Permit Applications 

Regulation 

Reference 

regulatory precedents cited in 64.4(b)(1)-(5). If the performance specifications 

proposed to satisfy 64.3(b)(2) or (3) include differences from manufacturer 

recommendations, the owner or operator shall explain the reasons for the 

differences. 

control device (and process and capture system, if applicable) operating parameter 

data obtained during the conduct of applicable compliance or performance tests. 

Such data may be supplemented, if desired, by engineering assessments and 

manufacturer’s recommendations to justify the indicator ranges. 

64.4(c)(1) 

documentation to certify that no changes to the pollutant-specific emissions unit, 

including the control device and capture system, have taken place. 

64.4(c)(2)

If existing data from unit-specific compliance or performance testing specified in 64.4(c) are 

not available, the owner or operator:

shall submit a test plan and schedule for obtaining such data; or 64.4(d)(1) 

may submit indicator ranges (or procedures for establishing indicator ranges) that 

rely on engineering assessments and other data, provided that the owner or 

operator demonstrates that factors specific to the type of monitoring, control device, 

or pollutant-specific emissions unit make compliance or performance testing 

unnecessary to establish indicator ranges at levels that satisfy the criteria in 64.3(a). 

64.4(d)(2)

If the monitoring submitted by the owner or operator requires installation, testing, or other 

necessary activities prior to use for the purposes of part 64, the owner or operator shall 

include:

an implementation plan and 64.4(e) 

schedule for installing, testing, and performing any other appropriate activities prior 

to the use of the monitoring. 

64.4(e)

Reporting Requirements 

Regulation 

Reference

Submit monitoring reports in accordance with 70.6(a)(3)(iii). In addition the monitoring 

report shall include:
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summary information of the number, duration and cause (including unknown cause, 

if applicable) of excursions or exceedances and the corrective actions taken. 

64.9(a)(2)(i) 

summary information of the number, duration and cause (including unknown cause, 

if applicable) for monitor downtime incidents (other than downtime associated with 

zero and span or other daily calibration checks, if applicable). 

64.9(a)(2)(ii) 

a description of the actions taken to implement a quality improvement plan (QIP) 

specified in 64.8. Upon completion of a QIP, the owner or operator shall include in 

the next summary report documentation that the implementation of the plan has 

been completed and reduced the likelihood of similar levels of excursions or 

exceedances occurring. 

64.9(a)(2)(iii)

Record Keeping Requirements 

Regulation 

Reference

Records shall be maintained in accordance with the requirements specified in 70.6(a)(3)(ii). 

In addition the records shall include: 

records of monitoring data 64.9(b) 

monitor performance data 64.9(b) 

any written QIP required pursuant to 64.8 64.9(b) 

any corrective actions taken to implement a QIP 64.9(b) 

data used to document the adequacy of monitoring 64.9(b) 

records of monitoring maintenance. 64.9(b)

Additional Requirements for Compliance Certification 

Regulation 

Reference

For all affected pollutant-specific units, an annual compliance certification is required. As 

part of the compliance certification, it is necessary to identify: 

each term or condition of the permit that is the basis of the certification. 70.6(c)(5)(iii)(A) 

the method(s) or other means used by the owner or operator for determining the 

compliance status with each term and condition during the certification period, and 

whether such methods or means provide continuous or intermittent data. 

70.6(c)(5)(iii)(B) 

the status of compliance with the terms and conditions of the permit for the period 

covered by the certification 

70.6(c)(5)(iii)(C) 

such other facts as the PA may require. 70.6(c)(5)(iii)(D)
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4(b)(ii) RESPONDENT ACTIVITIES 

The following list displays typical activities sources will have to perform to meet the 

additional permit application, record keeping, and reporting requirements of CAM: 

• Review requirements; 

• Determine monitoring approach; 

• Specify monitoring plan elements; 

• Prepare documentation; 

• Revise CAM, as applicable; 

• Renew CAM at permit renewal; 

• Maintain records; 

• Submit reports; and 

• Certify facility compliance. 

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT 

5(a) AGENCY ACTIVITIES 

State and local agencies will perform the following activities: 

• Rule familiarization; 

• Determine applicability; 

• Review and approve/disapprove monitoring chosen by owners/operators; 

• Respond to requests for reviews/revisions to CAM; 

• Review reports; 

• Evaluate CAM renewals; 

• Review annual facility certifications. 

The EPA will perform the following activities: 

• Provide oversight and guidance to State and local agencies; 

• Assess requests for alternative monitoring. 

5(b) COLLECTION METHODOLOGY AND MANAGEMENT 

CAM does not mandate the use of standardized forms for reporting information. Section 

64.9(b)(2) allows record keeping in a variety of media as long as all records are available for 

inspection and there are no conflicts with other record keeping requirements. 
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5(c) SMALL ENTITY FLEXIBILITY 

The Agency assessed the impacts of the CAM Rule on small businesses, governments, 

and organizations in Chapter V of the rule’s Regulatory Impact Analysis in 1997. This 

assessment still holds true, indicating the CAM Rule will probably not have a significant impact 

on a substantial number of small entities (SISNOSE). For additional discussion on this assertion, 

the Agency invites the reader to review the CAM Rule RIA and ICR from 1997. 

5(d) COLLECTION SCHEDULE 

Submission of initial source information required under part 64 depends on whether the 

unit is classified as “Large” or “Other.” If the source’s permit application has not been filed, is 

being revised, or is not complete, “Large” units must submit monitoring information on or before 

the 180th day after publication of the final rule in the Federal Register. If these conditions are 

not met, sources must submit monitoring design criteria at the first significant permit revision, or 

at permit renewal, whichever occurs first. For all other pollutant-specific emission units subject 

to part 64 (i.e., “Other” units), the owner or operator shall submit the required information upon 

renewal of a part 70 or 71 permit. 

Upon approval of the permit, sources must collect the information specified in their 

permits in accordance with the collection frequency specified, maintaining these data for at least 

five years. Sources must also submit semi-annual monitoring reports and annual compliance 

certifications. 

6. ESTIMATING THE BURDEN AND COST OF THE 

COLLECTION 

This section discusses the development of burden estimates and their conversion 

estimates into costs, which are separated into burden costs and capital and O&M costs. 

According to the latest guidance for ICRs, capital and O&M costs display the cost of any new 

capital equipment the source or PA may have to purchase solely for information collection, 

assimilation, and storage purposes. For example, if a source had to purchase a new minicomputer to store and manipulate CEMS data, that computer would be a cost of administration 

subject to reporting in the ICR. In addition, the latest guidance instructs the Agency to 

differentiate the burden associated with a source’s labor and that which it hires through outside 

contractors. However, a sensitivity analysis of the effect of contracted labor on the CAM Rule 

reveals that, if all of the affected sources were to employ contractors to perform as much as half 

of the work necessary for full compliance with the rule, overall costs would increase by less than 

five percent. Consequently, this analysis assumes sources will not employ contracted labor. 

6(a) ESTIMATING TOTAL RESPONDENT BURDEN 

This section presents estimates of the burden hours expected to be incurred at sources 

with emission units affected by Compliance Assurance Monitoring. Results are contained in 
Part 64 Compliance Assurance Monitoring Rule 

Information Collection Request Renewal 

Page 16

Tables 6.1 through 6.2. These tables summarize burden impacts for all pollutants by activity. 

The burden estimates reflect the expert judgment of EPA staff, contractors, and industry experts. 

 All burden estimates represent the increment over part 70 requirements. 

The respondent data and certain assumptions used in this analysis are taken from the RIA 

that was prepared in 2008 for revisions to CAM which are expected to be proposed in 2010. 

These revisions would add requirements for additional units that are not subject to the current 

CAM rule, but would not modify the existing requirements for units subject to the existing part 

64. Therefore, the data pertaining to units subject to the existing part 64 can be used in this ICR. 

Data on the numbers of units expected to conduct each activity were developed for a nine-State 

sample in the RIA and extrapolated to the nation. Assumptions made in the RIA that are used in 

this ICR analysis include assumptions pertaining to implementation timetables. EPA assumed 

that no units had yet submitted their monitoring approaches to their permitting authorities as of 

January 2007, so all existing units will submit their monitoring approaches at permit renewal, 

beginning in July 2007. The expiring ICR included the startup costs for some units while this 

current renewal ICR includes the startup costs for the remaining existing units. 

Tables 6.1a, b, and c report labor burdens for all units for each of the next three years. 

Table 6.2 presents a summary of the burdens for these three years. Average annual labor burden 

is computed as the arithmetic average of the sum of the annual labor burden across the three 

years of the information collection. Total annual burden for the nine-State sample is computed 

as the product of the annual labor hours per respondent for a specific activity times the number 

of respondents. National totals are extrapolated using the assumption that the nine sample States 

represent 21.4 percent of the Title V facilities nationwide. The national average annual labor 

burden over the first three years for all emissions units, extrapolated from the five sample States, 

is estimated to be about 7.4 million hours. Differences between the prior ICR and the results in 

Tables 6.1 and 6.2 are due to changes in the estimated numbers of units that would have CAM 

monitoring incorporated into their permit during the current three-year period. 

6(b) ESTIMATING TOTAL RESPONDENT COSTS 

6(b)(i) Estimating Labor Costs 

Tables 6.1a, b, and c also show the costs associated with each year. Burden costs in 

Tables 6.1a, b, and c are classified into one of three categories: costs associated with CAM 

design activities, record keeping activities, or reporting activities. 

This ICR identifies three labor categories. Labor rates, on a per-hour basis, are taken 

from the Bureau of Labor Statistics (BLS) Occupational Employment Statistics Web site 

(http://www.bls.gov/oes/) as posted for May 2008. For each type of personnel, the median 

hourly wage was averaged across the following sectors: (1) Manufacturing; (2) Professional, 

Scientific, and Technical Services; (3) Administrative and Support and Waste Management and 

Remediation Services; (4) Educational Services; (5) Healthcare and Social Assistance; and 

(6) Federal, State and Local Government. For managerial labor, an “Engineering Manager” 

occupation was selected with a base hourly labor rate of $51.99; for technical personnel, 
Part 64 Compliance Assurance Monitoring Rule 

Information Collection Request Renewal 

Page 17

“Environmental Engineering Technician” was selected with a base rate of $19.56; and for 

clerical personnel, “Secretaries, Except Legal, Medical, and Executive” was selected with a base 

rate of $14.44. The labor rates include fringe benefits, including paid leave, insurance, etc. The 

labor rates were then adjusted by an overhead and profit rate of 160 percent. Therefore, the total 

"loaded" wage rates are calculated by the following equation: 

 base labor rate x 1.67 = loaded wage rate 

Given the overhead cost adjustments, the final total loaded wage rates are $86.83 for 

managerial personnel, $32.66 for technical personnel, and $24.11 for clerical personnel. All 

labor rates are in 2008 dollars. 

For each response activity, Tables 6.1a, b, and c display the Annual Labor Hours per 

Respondent (by labor category) assumed necessary to complete each required activity. For each 

activity, the nine State total cost is computed by multiplying the appropriate wage rate by the 

number of labor hours in that category, adding the three values together, and then multiplying 

that cost by the number of affected units. National totals are extrapolated using the assumption 

that the nine sample States represent 21.4 percent of the Title V facilities nationwide. From 

Table 6.2, the national total annualized cost ($2008) is $260 million for all units. 

Tables 6.3a, b, and c show the burden and costs for State and Local Agencies for all 

units. The Agency believes the activities shown in the tables fully define the State and Local 

Agencies’ burden under part 64. The methodology used to derive the State and Local burden 

hours and costs parallels the procedures described in the original CAM RIA and ICR. The 

approach is “bottom-up,” with the estimates of the labor hours needed to perform each activity 

combined with an estimate of the number of respondents. The labor hour estimates for each 

activity are based on the expert knowledge of EPA staff. The labor estimates for these activities 

reflect the PA hours required to complete the activities for one pollutant specific emissions unit. 

Depending on the activity, the labor hours required may be broken out by the type of existing 

monitoring and the type of response. 

Column B in Tables 6.3a, b, and c show the number of occurrences of each PA activity 

per year. In most cases, these numbers reflect the numbers of units expected to be submitting 

CAM approaches, revisions, renewals, or reports each year and are the same as the numbers of 

PSEUs used in Tables 6.1a, b, and c. Because each unit must submit two reports per year, the 

“number of occurrences” for the PA activity “review reports” is twice the number of units that 

will be expected to submit reports that year. The costs are reported in 2008 dollars and reflect a 

time horizon of three years. Total annualized costs for the PAs are $3.5 million for all units, as 

displayed in Table 6.4. 

The operating permits program requires the cost of administering a State permit program 

to be fully repaid out of the permitting fees collected by that State. Therefore, the true cost of 

the CAM Rule to States and other PAs is zero, and the recorded cost of administration should be 

allocated to sources. 
Part 64 Compliance Assurance Monitoring Rule 

Information Collection Request Renewal 

Page 18

6(b)(ii) Estimating Capital and Operations and Maintenance Costs 

Tables 6.1 and 6.2 show the capital and operations and maintenance (O&M) costs as zero 

for all units over the next three years. As explained above, the only capital costs to be included 

in an ICR are those for any new capital equipment the source or PA may have to purchase solely 

for information collection, assimilation, and storage purposes. However, EPA assumes that any 

such equipment needed by sources to comply with part 64 would be purchased as part of a 

monitoring equipment purchase and could not be separately estimated. Therefore, O&M costs 

for operating such capital equipment could also not be separately estimated. Other possible 

O&M costs associated with reporting and recordkeeping include such things as postage fees for 

submitting reports. However, part 64 does not require any new reports be submitted, rather it 

provides additional information that must be included in reports required under part 70. 

Therefore, postage costs for these reports are attributable to part 70 and not to part 64. 

6(c) ESTIMATING AGENCY BURDEN AND COST 

Table 6.5 shows the burden and costs for EPA. 

6(d) REASONS FOR CHANGE IN BURDEN 

The CAM Rule requires affected pollutant points to submit initial information to the PA 

upon renewal of the part 70 or part 71 permit. The burden is expected to increase, in part, due to 

the increased number of permit renewals expected over the next three years. Additionally, this 

means that an increased number of affected pollutant points will be submitting information on a 

periodic ongoing basis. 

6(e) BURDEN STATEMENT 

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 304 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

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

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information. An agency may not conduct or sponsor, and a person is not required to respond 

to, a collection of information unless it displays a currently valid OMB control number. The 

OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

To 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 ICR under 

Docket ID Number EPA-HQ-OAR-2003-0152, which is available for online viewing at 
Part 64 Compliance Assurance Monitoring Rule 

Information Collection Request Renewal 

Page 19

www.regulations.gov, or in person viewing at the Air Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The 

EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the Air Docket is (202) 566-1742. An electronic version of 

the public docket is available at www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the public docket, and to access 

those documents in the public docket that are available electronically. When in the system, 

select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-OAR-2003-0152 and OMB Control Number 

2060-0376 in any correspondence. 
TABLE 6.1a Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2010-11

A B C D EF G H I J 

Clerical hours 

per 

occurrence

Technical hours per 

occurrence

Management 

hours per 

occurence 

([A+B]x0.05)

Annual 

occurences

Annual 

person 

hours

Labor 

cost/year

Annualized 

capital costs

Annualized 

O&M costs

Total 

number of 

respondents

Total 

hours/year 

(E x I)

1 Review Requirementsa 5 15 1 1 21 $697 $0 $0 0 0 

2 Determine Monitoring Approachb

 Units without existing monitoring 0.75 2.25 0.15 1 3.15 $105 $0 $0 407 1,282  Units with existing monitoring 0.25 0.75 0.05 1 1.05 $35 $0 $0 767 805 

3 Specify Monitoring Elementsb

 Units w/o existing monitoring: non CEM/COM responses 4 12 0.8 1 16.8 $558 $0 $0 407 6,838  Units w/o existing monitoring: CEM/COM responses 2 6 0.4 1 8.4 $279 $0 $0 0 0  Units with existing monitoring: non CEM/COM responses 2 6 0.4 1 8.4 $279 $0 $0 767 6,443  Units with existing monitoring: CEM/COM responses 1 3 0.2 1 4.2 $139 $0 $0 0 0 

4 Design Documentation (Management) b

 Units w/o existing monitoring: non CEM/COM responses 0 4 0.2 1 4.2 $148 $0 $0 407 1,709  Units w/o existing monitoring: CEM/COM responses 0 2 0.1 1 2.1 $74 $0 $0 0 0  Units with existing monitoring: non CEM/COM responses 0 2 0.1 1 2.1 $74 $0 $0 767 1,611  Units with existing monitoring: CEM/COM responses 0 1 0.05 1 1.05 $37 $0 $0 0 0 

5 CAM Revisions 

 Units without existing monitoring 0 4 0.2 1 4.2 $148 $0 $0 0 0  Units with existing monitoring 0 2 0.1 1 2.1 $74 $0 $0 0 0 

6 CAM Renewal 2 6 0.4 1 8.4 $279 $0 $0 14 118 7 Recordkeeping Activities

 Incremental recordkeeping burden - Upgrade instrumental systems 0 0.5 0.025 52 27.3 $962 $0 $0 1,989 54,309  Incremental recordkeeping burden - Upgrade work practices 0 0.5 0.025 52 27.3 $962 $0 $0 1,771 48,360  Incremental recordkeeping burden - install VE monitor 0 0.5 0.025 52 27.3 $962 $0 $0 0 0  Daily recordkeeping - Install instrumental monitor 0 1.5 0.075 260 409.5 $14,432 $0 $0 1,531 626,841  Daily recordkeeping - Initiate work practices 0 1.5 0.075 260 409.5 $14,432 $0 $0 1,167 477,961 

8 Incremental reporting 0 0.5 0.025 2 1.05 $37 $0 $0 4,381 4,600 

9 Facility Certificationc 0 39 0 0 020 1 0 41 $11 $0 $0 4 381 1 816 

Hours Tota

d and Costs Per Respondent

Reporting and Recordkeeping Requirements

9 Facility Certificationc 0.39 0 0.020 1 0.41 $11 $0 $0 4,381 1,816 

Total - 9 Sample States 1,232,692 Total - Nationwide 5,760,244 Notes:

aHours are per facility, not per PSEU; number of respondents are facilities, not PSEUsbOne-time activity.c3 hours per facility converted to impact per PSEU by dividing by the average number of Category A pollutant points per facility with at least one PSEU [7.6].dAll hours are per PSEU unless otherwise noted.eCosts are based on the following hourly rates: $86.83 for managerial personnel; $32.66 for technical personnel, and $24.11 for clerical personnel
TABLE 6.1b Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2011-12

A B C D EF G H I J 

Clerical hours 

per 

occurrence

Technical 

hours per 

occurrence

Management 

hours per 

occurence 

([A+B]x0.05)

Annual 

occurences

Annual person 

hours

Labor 

cost/yea

r

Annualized 

capital 

costs

Annualized 

O&M costs

Total 

number of 

respondent

s

Total 

hours/year 

(E x H)

To

1 Review Requirementsa 5 15 1 1 21 $697 $0 $0 0 0 

2 Determine Monitoring Approachb

 Units without existing monitoring 0.75 2.25 0.15 1 3.15 $105 $0 $0 0 0 

 Units with existing monitoring 0.25 0.75 0.05 1 1.05 $35 $0 $0 0 0 

3 Specify Monitoring Elementsb

 Units w/o existing monitoring: non CEM/COM responses 4 12 0.8 1 16.8 $558 $0 $0 0 0  Units w/o existing monitoring: CEM/COM responses 2 6 0.4 1 8.4 $279 $0 $0 0 0  Units with existing monitoring: non CEM/COM responses 2 6 0.4 1 8.4 $279 $0 $0 0 0  Units with existing monitoring: CEM/COM responses 1 3 0.2 1 4.2 $139 $0 $0 0 0 

4 Design Documentation (Management) b

 Units w/o existing monitoring: non CEM/COM responses 0 4 0.2 1 4.2 $148 $0 $0 0 0  Units w/o existing monitoring: CEM/COM responses 0 2 0.1 1 2.1 $74 $0 $0 0 0  Units with existing monitoring: non CEM/COM responses 0 2 0.1 1 2.1 $74 $0 $0 0 0  Units with existing monitoring: CEM/COM responses 0 1 0.05 1 1.05 $37 $0 $0 0 0 

5 CAM Revisions 

 Units without existing monitoring 0 4 0.2 1 4.2 $148 $0 $0 0 0 

 Units with existing monitoring 0 2 0.1 1 2.1 $74 $0 $0 0 0 

6 CAM Renewal 2 6 0.4 1 8.4 $279 $0 $0 21 176 7 Recordkeeping Activities

 Incremental recordkeeping burden - Upgrade instrumental 

systems 0 0.5 0.025 52 27.3 $962 $0 $0 2,522 68,863  Incremental recordkeeping burden - Upgrade work practices 0 0.5 0.025 52 27.3 $962 $0 $0 2,246 61,323  Incremental recordkeeping burden - install VE monitor 0 0.5 0.025 52 27.3 $962 $0 $0 0 0 

 Daily recordkeeping - Install instrumental monitor 0 1.5 0.075 260 409.5 $14,432 $0 $0 1,943 795,739 $ Daily recordkeeping - Initiate work practices 0 1.5 0.075 260 409.5 $14,432 $0 $0 1,480 606,080 $

8 Incremental reporting 0 0.5 0.025 2 1.05 $37 $0 $0 5,555 5,833 9 Facility Certificationc 0.39 0 0.020 1 0.41 $11 $0 $0 5,555 2,302 

Total - 9 Sample States 1,540,317 $Total - Nationwide 7,197,741 $2

Reporting and Recordkeeping Requirements

Hoursd and Costs Per Respondent Tota

Notes:

aHours are per facility, not per PSEU; number of respondents are facilities, not PSEUsbOne-time activity.c3 hours per facility converted to impact per PSEU by dividing by the average number of Category A pollutant points per facility with at least one PSEU [7.6]. dAll hours are per PSEU unless otherwise noted.eCosts are based on the following hourly rates: $86.83 for managerial personnel; $32.66 for technical personnel, and $24.11 for clerical personnel
TABLE 6.1c Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2012-13

A B C D EF G H I J 

Clerical hours 

per 

occurrence

Technical 

hours per 

occurrence

Management 

hours per 

occurence 

([A+B]x0.05)

Annual 

occurences

Annual person 

hours

Labor 

cost/year

Annualized 

capital costs

Annualized 

O&M costs

Total 

number of 

respondent

s

Total 

hours/yea

r (E x H)

To

1 Review Requirementsa 5 15 1 1 21 $697 $0 $0 0 0 

2 Determine Monitoring Approachb

 Units without existing monitoring 0.75 2.25 0.15 1 3.15 $105 $0 $0 0 0  Units with existing monitoring 0.25 0.75 0.05 1 1.05 $35 $0 $0 0 0 

3 Specify Monitoring Elementsb

 Units w/o existing monitoring: non CEM/COM responses 4 12 0.8 1 16.8 $558 $0 $0 0 0  Units w/o existing monitoring: CEM/COM responses 2 6 0.4 1 8.4 $279 $0 $0 0 0  Units with existing monitoring: non CEM/COM responses 2 6 0.4 1 8.4 $279 $0 $0 0 0  Units with existing monitoring: CEM/COM responses 1 3 0.2 1 4.2 $139 $0 $0 0 0 

4 Design Documentation (Management) b

 Units w/o existing monitoring: non CEM/COM responses 0 4 0.2 1 4.2 $148 $0 $0 0 0  Units w/o existing monitoring: CEM/COM responses 0 2 0.1 1 2.1 $74 $0 $0 0 0  Units with existing monitoring: non CEM/COM responses 0 2 0.1 1 2.1 $74 $0 $0 0 0  Units with existing monitoring: CEM/COM responses 0 1 0.05 1 1.05 $37 $0 $0 0 0 

5 CAM Revisions 

 Units without existing monitoring 0 4 0.2 1 4.2 $148 $0 $0 0 0  Units with existing monitoring 0 2 0.1 1 2.1 $74 $0 $0 0 0 

6 CAM Renewal 2 6 0.4 1 8.4 $279 $0 $0 1,215 10,206 7 Recordkeeping Activities

 Incremental recordkeeping burden - Upgrade instrumental 

systems 0 0.5 0.025 52 27.3 $962 $0 $0 2,522 68,863 $ Incremental recordkeeping burden - Upgrade work practices 0 0.5 0.025 52 27.3 $962 $0 $0 2,246 61,323 $ Incremental recordkeeping burden - install VE monitor 0 0.5 0.025 52 27.3 $962 $0 $0 0 0  Daily recordkeeping - Install instrumental monitor 0 1.5 0.075 260 409.5 $14,432 $0 $0 2,969 1,215,886 $4 Daily recordkeeping - Initiate work practices 0 1.5 0.075 260 409.5 $14,432 $0 $0 1,480 606,080 $2

8 Incremental reporting 0 0.5 0.025 2 1.05 $37 $0 $0 5,555 5,833 

Reporting and Recordkeeping Requirements

Hoursd and Costs Per Respondent Total 

p g $ $ $ , , 

9 Facility Certificationc 0.39 0 0.020 1 0.41 $11 $0 $0 5,555 2,302 

Total - 9 Sample States 1,970,493 $6Total - Nationwide 9,207,912 $32Notes:

aHours are per facility, not per PSEU; number of respondents are facilities, not PSEUsbOne-time activity.c3 hours per facility converted to impact per PSEU by dividing by the average number of Category A pollutant points per facility with at least one PSEU [7.6].dAll hours are per PSEU unless otherwise noted.eCosts are based on the following hourly rates: $86.83 for managerial personnel; $32.66 for technical personnel, and $24.11 for clerical personnel
TABLE 6.2 Average Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants

Year Annual total hours Annual labor cost

Annual capital & 

O&M cost Total annual cos

2010-11 5,760,244 $202,784,780 $0 $202,72011-12 7,197,741 $253,571,843 $0 $253,52012-13 9,207,912 $324,318,418 $0 $324,3Total 22,165,896 $780,675,042 0 $780,6Average 7,388,632 $260,225,014 $0 $260,2Burden per Response

Year

# PSEUs submitting 

reports Annual total hours Hours per PSEU Hours per facility

2010-11 20,472 5,760,244 281 2011-12 25,958 7,197,741 277 2012-13 25,958 9,207,912 355 Total 72,388 22,165,896 913 Average 24,129 7,388,632 304 

aAssumes 7.6 PSEUs per facility
TABLE 6.3a Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Polluta

A BC D 

Technical 

hours per 

occurencea

Occurences 

per year

Technical 

hours per 

year (AxB)

Management 

hours per year (

x 0.05) 

1 CAM Activities

 Rule Familiarization 54 0 0  Applicability Determination 0.67 1,174 787 3

2 Initial CAM Review

 Units w/o existing monitoring: non CEM/COM 2 407 814 4 Units w/o existing monitoring: CEM/COM 1 0 0  Units with existing monitoring: non CEM/COM 1 767 767 3 Units with existing monitoring: CEM/COM 0.5 0 0 

3 CAM Revisions

 Units w/o existing monitoring 1 0 0  Units with existing monitoring 0.5 0 0 

4 CAM Renewals 1 14 14 5 Review Reports 1 8,762 8,762 436 Certifications 0.33 4,381 1,446 7

Total 9 Sample States 12 589 62

Burden Item

T

otal - 

9

Sample St

ate

s 12,589 62

Total - Nationwide 58,829 2,94

aAll hours are per PSEU unless otherwise noted.eCosts are based on the following hourly rates: $86.51 for managerial personnel and $52.34 for technical personnel
TABLE 6.3b Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutan

A BC D 

Technical hours per 

occurencea

Occurences 

per year

Technical hours per 

year (AxB)

Management 

hours per year (C 

x 0.05) 

1 CAM Activities

 Rule Familiarization 54 0 0 0  Applicability Determination 0.67 0 0 0 

2 Initial CAM Review

 Units w/o existing monitoring: non CEM/COM 2 0 0 0  Units w/o existing monitoring: CEM/COM 1 0 0 0  Units with existing monitoring: non CEM/COM 1 0 0 0  Units with existing monitoring: CEM/COM 0.5 0 0 0 

3 CAM Revisions

 Units w/o existing monitoring 1 0 0 0  Units with existing monitoring 0.5 0 0 0 

4 CAM Renewals 1 21 21 1 5 Review Reports 1 11,110 11,110 556 6 Certifications 0.33 5,555 1,833 92 

Total - 9 Sample States 12,964 648 

Burden Item

Total - 9 Sample States 12,964 648 Total - Nationwide 60,580 3,029 

aAll hours are per PSEU unless otherwise noted.eCosts are based on the following hourly rates: $86.51 for managerial personnel and $52.34 for technical personnel
TABLE 6.3c Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Polluta

A BC D 

Technical 

hours per 

occurencea

Occurences 

per year

Technical 

hours per 

year (AxB)

Management 

hours per year (

x 0.05) 

1 CAM Activities

 Rule Familiarization 54 0 0  Applicability Determination 0.67 0 0 

2 Initial CAM Review

 Units w/o existing monitoring: non CEM/COM 2 0 0  Units w/o existing monitoring: CEM/COM 1 0 0  Units with existing monitoring: non CEM/COM 1 0 0  Units with existing monitoring: CEM/COM 0.5 0 0 

3 CAM Revisions

 Units w/o existing monitoring 1 0 0  Units with existing monitoring 0.5 0 0 

4 CAM Renewals 1 1,215 1,215 65 Review Reports 1 11,110 11,110 556 Certifications 0.33 5,555 1,833 9

Total 9 Sample States 14 158 70

Burden Item

T

otal - 

9

Sample St

ate

s 14,158 70

Total - Nationwide 66,160 3,30

aAll hours are per PSEU unless otherwise noted.eCosts are based on the following hourly rates: $86.51 for managerial personnel and $52.34 for technical personnel
Year Annual total hours Total annual cost

2010-11 61,770 $3,333,4092011-12 63,609 $3,432,6592012-13 69,468 $3,748,807Total 194,847 $10,514,874Average 64,949 $3,504,958

TABLE 6.4 Average Permitting Authority Burden and Labor 

Costs for All "Large" and "Other" Sources - All Pollutants
TABLE 6.5 Federal Labor Hours and Costs for "Large & Other" Sources - All Pollutants, 2010-2013

CAM Activities Annual Burden Three Year Total 

Technical 

Hours

Management 

Hours Total Hours Annual Cost 

Technical 

Hours 

Management 

Hours Total Hours 

Rule Familiarization 1 380 20 400 $21,618 1,140 60 1,200 

Review CAM Plans 1 5,320 280 5,600 $302,659 15,960 840 16,800 

Total Cost and Burden: 5,700 300 6,000 $324,277 17,100 900 18,000 

1 Based on input from the Regions -- one region said they spent .1 FTE or less and another region said they spent .5 FTE. 

We assumed .3 FTEs, or 600 hours per region per year; 600 hours/region * 10 regions = 6000 hours/yr.We assumed the majority of the time is spent reviewing CAM plans; some time was allocated to Rule familiarization for new staff.