EPA
United
States
Environmental
Protection
Agency
Office
of
Air
and
Radiation
Office
of
Air
Quality
Planning
and
Standards
Innovative
Strategies
and
Economics
Group
Integrated
Implementation
Group
November,
2002
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
EPA
#
1713.04
Executive
Summary
This
rulemaking
takes
final
action
on
several
changes
to
the
major
NSR
program
by
providing:

$
a
new
method
for
determining
baseline
emissions,

$
a
new
actual­
to­
projected­
actual
methodology
for
determining
whether
a
major
modification
will
occur,

$
a
new
applicability
provisions
for
emission
units
designated
as
Clean
Units
or
that
participate
in
pollution
control
projects
(
PCPs),

$
changes
to
let
major
stationary
sources
manage
facility
wide
air
emissions
through
a
Plant­
wide
Applicability
Limit
(
PAL)
without
requiring
a
preconstruction
major
NSR
permit.

Table
E.
1
Aggregate
Change
in
Source,
RA,
and
Federal
Burden
and
Cost
a
for
this
Rulemaking
Regulatory
Change
Number
of
Affected
Entities
Annual
Burden
Hours
Annualized
Cost
Average
Cost
per
Entity
SOURCES
Baseline
Determination
Avoided
Major
Source
NSR
3
(
2,517)
($
188,775)
($
62,925)

New
Monitoring
Requirements
3
300
$
225,000
$
7,500
Actual­
to­
projected­
actual
Determination
8
(
6,712)
($
503,400)
($
62,925)

Plant­
wide
Applicability
Limits
(
PALs)

Avoided
Major
Source
NSR
1
(
839)
($
62,925)
($
62,925)

New
Monitoring
Requirements
1
100
$
7,500
$
7,500
Clean
Units
Test
1
(
839)
($
62,925)
($
62,925)

Pollution
Control
Projects
1
(
839)
($
62,925)
($
62,925)

Source
Total
14
(
11,346)
($
648,450)
($
46,318)

RAs
112
8,960
$
331,520
$
2,960
FEDERAL
1
0
$
0
$
0
a
In
2002
dollars.

While
the
overall
effect
of
this
rulemaking
is
a
relaxation
of
the
burden
currently
imposed
on
sources,
there
are
several
factors
that
dampen
that
effect.
First
of
all,
while
eventually
this
rulemaking
will
potentially
apply
to
all
sources
in
attainment
and
nonattainment
areas,
in
the
three
years
immediately
following
the
promulgation
of
this
rulemaking,
the
Agency
anticipates
the
following
Federally
controlled
areas
will
be
affected
immediately
by
the
changes
discussed
above.
Affected
entities
within
the
life
of
this
ICR
revision
include:

·
Federal
Permitting
Authorities:
including
Regional
and
Office
of
Air
and
Radiation
environmental
officers
·
States
where
the
management
of
the
program
has
been
delegated
back
to
the
State
1
Office
of
the
President
of
the
United
States,
Office
of
Management
and
Budget,
Office
of
Information
and
Regulatory
Affairs;
April
2002;
Managing
Information
Collection
and
Dissemination;
http://
www.
whitehouse.
gov/
omb/
inforeg/
paperwork_
policy_
report_
fin
al.
pdf
·
Federally
controlled
areas
such
as
outer
continental
shelf
drilling
platforms,
Tribal
lands,
and
Federal
territories
and
holdings
(
e.
g.,
American
Samoa)
·
Sources
of
air
pollution
within
attainment
areas
within
the
affected
States,
Tribal
lands,
and
other
Federally
controlled
areas
From
the
data
available
for
this
analysis,
10
to
12
percent
of
all
permitted
sources
are
in
states
that
have
Federally
managed
programs.
Among
these
states,
approximately
one
third
(
about
3
to
4
percent
of
all
permitted
sources
nationally)
are
in
PSD
areas.
These
are
the
sources
potentially
affected
by
this
ICR
revision.
Therefore,
just
over
one­
thirtieth
of
any
potential
full­
time
reductions
from
most
of
this
rulemaking
are
evident
during
the
time
frame
of
this
ICR.

Second,
along
with
the
elements
of
this
rulemaking
that
constitute
a
reduction
in
burden,
the
Agency
determined
it
was
prudent
to
include
a
formal
requirement
for
sources
to
demonstrate
their
post­
change
emissions
do
not
exceed
the
preconstruction
projection.
To
do
this,
EPA
decided
some
sources
should
keep
and
maintain
actual
emission
records
for
at
least
five
years
if
there
is
a
reasonable
possibility
that
a
project
that
is
not
part
of
a
major
modification
may
result
in
a
significant
emissions
increase
of
a
regulated
NSR
pollutant.
While
most
of
the
emission
monitoring
and
recordkeeping
tasks
should
already
be
part
of
the
operations
of
each
facility,
some
sources
may
have
to
undertake
new
monitoring
and
recordkeeping
tasks,
and
most
sources
will
have
some
de
minimis
change
in
their
reporting
practices.
The
additional
burden
of
these
small
changes
dampens
the
effect
of
the
other
elements
of
this
rulemaking.

Since
the
aggregate
effect
of
the
individual
parts
of
this
rulemaking
constitute
a
reduction
in
the
burden
imposed
by
the
Federal
government
on
sources
and
State
and
local
environmental
management
organizations,
this
rulemaking
is
consistent
with
the
Office
of
Management
and
Budget's
(
OMB's)
guidance
for
the
reduction
of
burden
when
and
wherever
possible.
1
CAVEAT:
Nothing
in
this
analysis
should
be
construed
as
constituting
the
full
effect
of
any
of
the
program
elements
discussed.
This
analysis
pertains
to
only
a
subset
of
the
full
effect
­
to
those
affected
sources
located
in
areas
attaining
the
appropriate
air
quality
standard
and
that
are
also
Federally
managed.
The
full
effect
of
these
programs,
while
discussed
briefly
in
this
analysis,
lags
the
promulgation
of
this
rulemaking
due
to
the
time
needed
for
States
to
modify
their
SIPs.
The
Agency
expects
the
full
effect
of
this
rulemaking
will
be
included
in
the
next
ICR
update
in
2004.
CONCLUSION:

This
rulemaking
represents
a
POTENTIAL
DECREASE
IN
BURDEN
to
sources.

This
rulemaking
represents
an
INCREASE
IN
BURDEN
to
States
and
other
Reviewing
Authorities
for
all
parts
of
this
rulemaking.

Because
this
rulemaking
represents
a
decrease
in
burden,
the
Agency
determined
there
is
NO
SIGNIFICANT
IMPACT
ON
A
SUBSTANTIAL
NUMBER
OF
SMALL
ENTITIES.
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
1
This
document
fulfills
the
Agency's
requirements
under
the
Paperwork
Reduction
Act
(
PRA)
with
regards
to
determining
the
regulatory
burden
associated
with
the
promulgation
of
new
applicability
requirements
for
modifications
at
sources
subject
to
parts
C
and
D
of
title
I
of
the
Clean
Air
Act
(
the
Act,
or
CAA),
Prevention
of
Significant
Deterioration
(
PSD)
and
Nonattainment
New
Source
Review
(
NSR).
It
has
been
assigned
EPA
tracking
number
2074.01.
The
title
of
this
Information
Collection
Request
(
ICR)
is
"
Information
Collection
Request
for
Changes
to
the
40
CFR
Parts
51
and
52
PSD
and
NSR
Applicability
Requirements
for
Modifications
to
Existing
Sources"

Historically,
the
program
called
the
"
major
NSR
program"
derives
its
authority
from
parts
C
and
D
of
Title
I
of
the
Act
and
is
a
preconstruction
review
and
permitting
program
applicable
to
new
or
modified
major
stationary
sources
of
air
pollutants.
In
areas
not
meeting
National
Ambient
Air
Quality
Standards
(
NAAQS)
and
in
ozone
transport
regions
(
OTR),
the
program
is
the
"
nonattainment"
NSR
program,
implemented
under
the
requirements
of
part
D
of
title
I
of
the
Act.
In
attainment
areas
(
areas
meeting
NAAQS)
or
in
areas
where
there
is
insufficient
information
to
determine
whether
they
meet
the
NAAQS
("
unclassifiable"
areas),
this
Prevention
of
Significant
Deterioration
(
PSD)
program
is
implemented
under
the
requirements
of
part
C
of
Title
I
of
the
Act.
Applicability
of
the
major
NSR
program
must
be
determined
in
advance
of
construction
and
is
pollutant­
specific.
When
a
source
triggers
major
NSR
in
attainment
areas,
it
must
install
best
available
control
technology
(
BACT)
and
conduct
modeling
and
monitoring
as
necessary.
If
the
source
is
located
in
a
nonattainment
area,
it
must
install
technology
that
meets
the
lowest
achievable
emission
rate
(
LAER),
secure
emission
reductions
to
offset
any
increases
above
baseline
emission
levels,
and
perform
other
analyses.

In
its
current
form,
the
NSR
program
is
a
combination
of
air
quality
planning
and
air
pollution
control
technology
program
requirements
for
new
and
modified
stationary
sources
of
air
pollution.
In
brief,
section
109
of
the
Act
requires
us
to
promulgate
primary
NAAQS
to
protect
public
health
and
secondary
NAAQS
to
protect
public
welfare.
Once
the
Agency
set
these
standards,
states
must
develop
State
Implementation
Plans
(
SIPs)
which
contains
emission
limitations
and
other
control
measures
to
attain
and
maintain
the
NAAQS
and
to
meet
the
other
requirements
of
section
110(
a)
of
the
Act.
1
Identification
of
the
Information
Collection
1.1
Title
EPA
TRACKING
NUMBER:
2074.01
1.2
Description
2
These
provisions
also
let
States
make
similar
changes
in
their
major
NSR
programs.

3
The
regulations
define
electric
utility
steam
generating
units
(
EUSGUs),
which
have
special
rules
for
physical
and
operational
changes
that
employ
an
actual­
to­
projected­
actual
methodology
for
all
changes
(
but
not
replacement)
at
an
existing
electric
utility
steam
generating
units.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
2
The
provisions
in
section
110
of
the
Act
include
a
requirement
for
States
to
have
a
preconstruction
review
program
to
manage
the
emissions
from
the
construction
and
modification
of
any
stationary
source
of
air
pollution
to
assure
that
the
NAAQS
are
achieved
and
maintained.

In
response
to
comments,
discussions,
and
recommendations
from
the
public
and
stakeholders,
the
EPA
is
revising
regulations
governing
major
NSR
programs.
These
revisions
include
changes
in
NSR
applicability
requirements
for
modifications
to
allow
sources
additional
avenues
for
determining
when
a
preconstruction
permit
is
required.
2
The
previous
regulations
define
baseline
actual
emissions
as
"
the
average
rate,
in
tpy,
at
which
the
unit
actually
emitted
the
pollutant
during
a
2­
year
period
which
precedes
the
particular
date
and
which
is
representative
of
normal
source
operation."
The
permitting
authorities
would
allow
use
of
a
different
time
period
"
upon
a
determination
that
it
is
more
representative
of
normal
source
operation."
Historically,
we
generally
used
the
2
years
immediately
preceding
the
proposed
change
to
establish
the
baseline.
However,
in
some
cases
we
have
allowed
use
of
an
earlier
period.

EPA
defines
a
"
net
emissions
increase"
as
the
increase
in
"
actual
emissions"
from
the
particular
physical
or
operational
change
(
taking
into
account
the
use
of
emissions
control
technology
and
restrictions
on
hours
of
operation
or
rates
of
production
where
such
controls
and
restrictions
are
federally
enforceable),
together
with
the
source's
other
contemporaneous
increases
or
decreases
in
actual
emissions.

Each
source
seeking
an
NSR
permit
must
predict
whether
or
not
the
proposed
change
will
result
in
a
significant
net
increase
in
the
source's
actual
emissions.
Under
our
prior
rules,
when
a
source
unit
(
other
than
an
electric
utility
steam
generating
unit)
3
"
has
not
begun
normal
operations,"
that
unit's
post­
change
actual
emissions
are
equal
the
units
Potential
To
Emit
(
PTE).
This
is
referred
to
as
the
"
actual­
to­
potential"
test.
Sources
could
avoid
this
presumption
by
agreeing
to
limit
the
unit's
PTE
through
the
use
of
practically
enforceable
restrictions.
The
net
result
of
this
process
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
3
lets
sources
ensure
no
increase
in
their
actual
emissions
above
baseline
levels
following
the
change.

This
rulemaking
takes
final
action
on
several
changes
to
the
major
NSR
program
by
providing:

$
a
new
method
for
determining
baseline
emissions,

$
a
new
actual­
to­
projected­
actual
methodology
for
determining
whether
a
major
modification
will
occur
(
which
also
allows
to
continue
to
sue
the
historical
approach
of
using
potential
emissions
to
estimate
postchange
emissions),

$
a
new
applicability
provision
for
emission
units
designated
as
Clean
Units
and
for
emissions
units
that
are
part
of
pollution
control
projects
(
PCPs),

$
changes
to
let
major
stationary
sources
manage
facility
wide
air
emissions
through
a
Plant­
wide
Applicability
Limitation
(
PAL)
without
requiring
a
preconstruction
major
NSR
permit.
4
The
term
"
reviewing
authority"
is
synonymous
with
the
term
"
permitting
authority"
used
in
previous
permit­
related
analyses.
The
reader
should
consider
these
terms
interchangeable
for
comparison
purposes.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
4
Title
I
of
the
Act
authorizes
EPA
to
collect
this
information.
Through
the
NSR
program
it
requires
owners
or
operators
of
emissions
units
that
emit
air
pollutants
to
submit
an
application
for
a
permit
to
construct,
modify,
or
significantly
alter
the
operations
of
each
source
of
criteria
pollutants.

For
EPA
to
carry
out
its
required
oversight
function
of
reviewing
preconstruction
permits
and
assuring
adequate
implementation
of
the
program,
it
must
have
available
to
it
information
on
proposed
construction
and
modifications.
The
burden
estimates
included
in
this
ICR
provides
emissions,
source,
and
control
information
for
the
PSD/
NSR
program.

The
information
in
this
ICR
is
based
upon
the
best
data
available
to
the
Agency
at
this
time.
However,
inconsistencies
in
reviewing
authority
(
RA)
reporting
techniques,
and
incomplete
data
sets,
and
sampling
limitations
imposed
upon
the
Agency
by
the
Paperwork
Reduction
Act
necessitated
a
certain
amount
of
extrapolation
and
"
best­
guess"
estimations.
4
Consequently,
the
reader
should
not
consider
the
conclusions
to
be
an
exact
representation
of
the
level
of
burden
or
cost
that
will
occur.
Instead,
this
ICR
should
be
considered
a
directionally
correct
assessment
of
the
impact
the
programmatic
changes
included
in
this
rulemaking
may
have
over
the
next
three
years.

Throughout
this
ICR,
the
reader
will
observe
estimated
values
that
show
accuracy
to
the
single
hour
or
dollar.
However,
reporting
values
at
the
single
unit
level
can
be
misleading.
In
most
situations,
the
proper
way
to
present
estimated
data
would
be
to
determine
an
appropriate
level
of
precision
and
truncate
values
accordingly,
usually
in
terms
of
thousands
or
millions
of
units.
For
instance,
a
spreadsheet
generated
estimation
of
$
5,456,295
could
be
presented
in
the
text
as
$
5.5
(
millions)
or
$
5,456
(
thousands).
One
problem
with
such
an
approach
is
the
loss
of
data
richness
when
the
report
contains
a
mixture
of
very
large
and
very
small
numbers.
Such
was
the
case
with
this
ICR,
where
source
values
are
consistently
in
the
millions
and
Federal
values
in
the
tens
of
thousands.
Consequently,
to
avoid
the
loss
of
information
through
rounding,
this
ICR
reports
all
values
at
the
single
unit
level
and
reminds
the
reader
that
there
is
no
implied
precision
inherent
in
this
style
of
reporting.
2
Need
and
Use
of
the
Collection
2.1
Need
/
Authority
for
the
Collection
2.2
Practical
Utility
/
Users
of
the
Data
2.3
Caveats
and
Considerations
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
5
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
1320.9.
The
Administrator
asserts
that,
while
the
Clean
Units
portion
of
this
rulemaking
requires
data
reporting
that
is
similar
to
that
already
being
performed
by
sources
for
Operating
Permit
and
Compliance
Assurance
Monitoring
purposes,
the
data
collected
for
this
rulemaking
is
more
specific
than
those
other,
similar,
collections
and
constitutes
a
necessary
component
of
the
NSR
program
to
ensure
the
protection
of
the
environment.

For
any
existing
rule,
§
3507(
g)
of
the
PRA
limits
how
long
a
Director
may
take
to
approve
a
collection
of
information
to
3
years.
The
ICR
for
the
40
CFR
Part
51
and
52
Prevention
of
Significant
Deterioration
and
New
Source
Review
Program
was
renewed
last
in
February
of
2001.
This
ICR
analysis
presents
an
update
to
that
renewal,
based
upon
programmatic
changes
completed
since
February,
2001.
For
all
of
the
elements
of
this
rulemaking,
significant
public
comment
periods
were
given.

Following
the
1996
proposal
of
changes
to
the
NSR
program,
EPA
held
two
public
hearings
and
more
than
50
stakeholder
meetings
with
environmental
groups;
industry;
and
state,
local,
and
federal
agency
representatives.

The
Act
defines
the
rate
of
reporting
by
sources,
states,
and
local
entities.
Consequently,
less
frequent
collection
is
not
possible.

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
1320.5,
the
Agency
believes:

1.
The
NSR
regulations
do
not
require
periodic
reporting
more
frequently
than
semi­
annually.

2.
The
NSR
regulations
do
not
require
respondents
to
participate
in
any
statistical
survey.

3.
Written
responses
to
Agency
inquiries
are
not
required
to
be
submitted
in
less
than
thirty
days.
3
Non­
Duplication,
Consultation,
and
Other
Collection
Criteria
3.1
Non­
Duplication
3.2
Public
Notice
Requirements
3.3
Consultations
3.4
Effects
of
Less
Frequent
Collection
3.5
General
Guidelines
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
6
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
Federal
requirements
and
those
reviewing
authorities
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
§
503(
e)
and
§
114(
c)
of
the
Act.

6.
The
NSR
regulations
do
not
require
more
that
one
original
and
two
copies
of
the
permit
application,
update,
or
revision
to
be
submitted
to
the
Agency.

7.
Respondents
do
not
receive
remuneration
for
the
preparation
of
reports
required
by
the
Act
or
parts
51
or
52.

8.
To
the
greatest
extent
possible,
the
Agency
has
taken
advantage
of
automated
methods
of
reporting.

9.
The
Agency
believes
the
impact
of
NSR
regulations
on
small
entities
to
be
insignificant
and
not
disproportionate.

The
recordkeeping
and
reporting
requirements
contained
in
the
current
NSR
program
and
the
changes
made
in
this
rulemaking
do
not
exceed
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.5,
except
for
the
guideline
which
limits
retention
of
records
by
respondents
to
three
years.
The
Act
requires
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.

Confidentiality
is
not
an
issue
for
this
rulemaking.
In
accordance
with
the
Clean
Air
Act
Amendments
of
1990,
the
monitoring
information
to
be
submitted
by
sources
as
a
part
of
their
permit
application
and
update;
applications
for
revisions
and
renewals
is
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
§
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
3.6
Confidentiality
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
7
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).

The
consideration
of
sensitive
questions,
(
i.
e.,
sexual,
religious,
personal
or
other
private
matters),
is
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.
3.7
Sensitive
Questions
5
The
database
does
not
include
AK,
AR,
AZ,
ID,
KS,
KY,
MT,
NJ,
NM,
PA,
SD,
TN,
TX,
UT,
WA,
and
WY.
While
several
of
these
states
contain
many
sources
subject
to
NSR,
EPA
believes
the
lack
of
their
information
in
this
database
does
not
harm
this
analysis.

6
Information
Collection
Request
for
40
CFR
Part
51
and
52
Prevention
of
Significant
Deterioration
and
Nonattainment
New
Source
Review,
Office
of
Management
and
Budget
(
OMB)
Control
Number
2060­
0003;
EPA
Form
Number
1230.09.

7
The
RBLC
does
not
contain
a
complete
record
of
all
PSD
and
NSR
permits.
Approximately
450
permit
determinations
are
missing
from
Texas
and
50
from
Louisiana,
and
as
many
as
1,000
are
missing
from
Region
VI.
From
Region
IX,
the
Agency
believes
California
has
not
entered
any
information
into
the
RBLC
for
at
least
the
past
3
years.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
8
There
are
over
14,500
sources
subject
to
Title
I
operating
permits
requirements
in
the
EPA's
Operating
Permits
Database,
encompassing
all
industry
classifications
in
34
states
and
the
District
of
Columbia.
5
This
comprises
the
majority
of
the
universe
of
potentially
affected
sources
for
the
NSR
program
and
for
this
ICR.
Table
4­
1
in
the
current
ICR
displays
the
industry
classifications
most
commonly
affected
by
NSR
permitting
requirements.
6
Table
4.1,
below,
recreates
that
table
for
this
analysis.

Table
4.1
Potentially
Affected
Entities
Industry
Group
SIC
NAICS
Pulp
and
Paper
Mills
261
32211,
322121,
322122,
32213
Paper
Mills
262
322121,
322122
Chemical
Processes
281
325181,
32512,
325131,
325182,
211112,
325998,
331311,
325188
Pharmaceuticals
283
325411,
325412,
325413,
325414
Petroleum
Refining
291
32411
Automobile
Manufacturing
371
336111,
336112,
336712,
336211,
336992,
336322,
336312,
33633,
33634,
33635,
336399,
336212,
336213
Electric
Services
491
221111,
221112,
221113,
221119,
221121,
221122
Natural
Gas
Transport
492
48621,
22121
The
New
Source
Review
Program
maintains
its
own
separate
database,
the
RACT
/
BACT
/
LAER
Clearinghouse
(
RBLC)
that
gathers
data
on
preconstruction
permits
for
new
and
existing
sources
of
pollution.
7
While
incomplete,
these
data
are
the
source
selected
by
the
EPA
for
the
estimates
4
The
Respondents
and
the
Information
Requested
4.1
Respondents
8
While
the
Federal
government
has
changed
its
classifications
system
to
the
North
American
Industry
Classification
System
(
NAICS),
the
reporting
process
that
supports
the
Agency's
database
for
sources
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
9
in
this
ICR.
The
RBLC
contains
1,142
PSD
and
NSR
permits
between
1992
and
the
present.
From
the
RBLC
database,
there
are
11
three­
digit
SIC
code
classifications
that
comprise
half
of
the
permit
determinations
made
since
1992,
five
of
which
appear
on
the
current
ICR
list
as
comprising
"
most"
of
the
determinations
made.
It
takes
27
three­
digit
SIC
code
classifications
to
make
up
75
percent
of
the
determinations
since
1992,
and
there
are
59
three­
digit
classifications
in
the
set
that
makes
up
90
percent
of
the
determinations
since
1992.
The
energy
industry
comprise
almost
a
quarter
of
all
permit
determinations,
with
almost
20
percent
in
the
491
Electric
Services
classification
and
almost
five
percent
in
the
492
Natural
Gas
Transport
classification.
Table
4.2
displays
the
distribution
of
RBLC
determinations
for
the
11
three­
digit
SIC
classifications
that
make
up
half
of
all
determinations
in
the
database.

Table
4.2
RBLC
Distribution
of
Permit
Determinations
Since
1992
Industry
Group
SIC
RBLC
Count
NAICS
Electric
Services
491
223
221111,
221112,
221113,
221119,
221121,
221122
Natural
Gas
Transport
492
52
48621,
22121
Steel
works,
blast
furnaces,
electrometallurgical
products,
steel
wiredrawing
331
44
324199,
331221,
331111,
331112,
331222,
332618
Gray
and
ductile
iron
foundries,
steel
foundries
332
42
331511,
331512
Electric
and
other
Services,
Service
Utilities
493
38
261111,
261112,
261112,
261119,
261121,
261122
Pulp
and
Paper
Mills
261
34
32211,
322121,
322122,
32213
Nitrogen
Fertilizers,
Phosphatic
Fertilizers,
and
Pesticides
and
Agricultural
Chemicals
NEC
287
33
325311,
325312,
32532
Motor
Vehicle,
Passenger
Car,
and
Truck
Bodies,
Motor
Vehicle
Parts
and
Accessories,
Truck
Trailers
371
33
336111,
336112,
33612,
336211,
336212,
336312,
336322,
33633,
33634,
33635,
336399,
336992
Sewerage
Systems,
Refuse
Systems,
and
Sanitary
Services
NEC
495
27
22132,
56292,
562212,
562213,
562219,
488119,
56291,
56171,
562998
Petroleum
Refining
291
26
32411
Rubber
and
Miscellaneous
Plastic
Products
308
25
326113,
326121,
32615,
32614,
325991,
326191,
326121,
326215,
326199
Among
all
potentially
affected
sources
in
the
Title
I
database,
4,700
sources
(
32.6
percent)
have
Standard
Industrial
Classification
(
SIC)
codes
designated
as
999
­
indicating
the
source
did
not
identify
a
specific
industry
within
which
it
operated.
8
The
remaining
9,800
sources
subject
to
Title
I
subject
to
Operating
Permits
requirements
has
not
fully
changed
to
the
new
system.
Therefore,
this
report
will
continue
employing
the
SIC
system
and
simultaneously
report
the
NAICS
classification
for
each
affected
source
category
for
future
comparison
purposes.

9
The
EPA
is
currently
reviewing
major
NSR
programs
for
approval
into
the
SIP
for
the
States
of
Indiana
and
Ohio.
These
States
may
have
fully­
approved
SIP
programs
by
the
time
this
ICR
takes
effect;
however,
for
purposes
of
this
analysis,
we
have
assumed
that
these
States
will
remain
under
the
Federal
program.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
10
operating
permits
requirements
report
specific
source
classifications
within
the
EPA's
Operating
Permits
Database.
Of
the
260
three­
digit
SIC
codes
with
Title
I
sources,
only
15
have
more
than
one
percent
of
the
total
Title
I
sources
(
including
the
999
classification).
Including
the
999
classification,
it
takes
the
seven
classifications
with
the
most
sources
in
them
to
account
for
half
of
the
Title
I
sources.
Without
the
999
classification,
it
takes
the
top
19
three­
digit
SIC
classifications
to
accumulate
half
of
all
Title
I
sources
in
the
database.
According
to
the
analyses
performed
for
the
most
recent
ICR
for
the
NSR
program,
1,694
sources
in
eight
three­
digit
SIC
code
categories
(
40
NAICS
categories)
account
for
most
of
the
source
categories
subject
to
NSR
each
year.
Table
4.1
displays
these
source
SIC
and
North
American
Industry
Classification
System
(
NAICS)
categories.

Eventually,
this
rulemaking
will
affect
all
States,
territories,
and
possessions
of
the
United
States,
as
well
as
all
local
and
Tribal
governments,
but
for
the
first
three­
year
period
of
this
rulemaking
(
the
period
covered
by
this
ICR),
most
states
will
not
be
affected
by
this
regulation
due
to
the
regulatory
lag
necessary
for
SIP
review,
revision,
and
approval.
During
this
period,
the
only
entities
potentially
affected
by
this
final
action
will
be
located
in
areas
where
the
Federal
government
has
direct
regulatory
authority.
These
"
Federally
controlled
areas"
include,
but
are
not
limited
to,
Guam,
Puerto
Rico
and
the
Virgin
Islands;
Washington
D.
C.;
Hawaii,
Illinois,
Indiana,
Michigan,
Minnesota,
North
Dakota,
Nevada,
New
Hampshire,
New
Jersey,
New
York,
Ohio,
and
South
Dakota.
9
The
Federal
government
also
has
authority
in
Texas
and
Washington
State,
but
only
for
one
source
category
in
each
SIP,
so
this
analysis
will
treat
Texas
and
Washington
State
as
though
their
SIPs
were
fully
approved.
Of
the
states
in
the
Operating
Permits
Database,
only
New
Jersey
and
South
Dakota
are
not
available
for
this
analysis.

The
EPA
estimated
there
are
about
5,545
sources
(
about
38
percent
of
the
total)
in
the
12
Federally
controlled
states,
the
District
of
Columbia,
and
in
Indian
Country
­
representing
222
different
three­
digit
SIC
code
The
universe
of
potentially
affected
sources
for
this
ICR
update
includes
only
sources
in
attainment
areas
in
Federally
controlled
States,
(
Hawaii,
Illinois,
Indiana,
Michigan,
North
Dakota,
Nevada,
New
Hampshire,
New
Jersey,
New
York,
Ohio,
and
South
Dakota),
other
Federally
controlled
areas,
and
95
sources
in
Indian
country.
10
Because
of
a
lack
of
information
about
the
nature
of
sources
in
Indian
Country,
this
analysis
distributed
the
95
affected
sources
over
the
database's
SIC
categories
according
to
the
distribution
of
sources
in
that
database.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
11
classifications.
10
About
16
percent
of
the
estimated
sources
had
a
999
SIC
code
­
about
half
of
that
for
the
Operating
Permits
Database.
When
the
999
classifications
is
included,
it
takes
13
SIC
classifications
to
account
for
half
of
the
sources
in
the
Federally
controlled
states.
Without
the
999
classification,
it
takes
26
three­
digit
SIC
classifications
to
account
for
half
of
the
sources.
For
the
eight
SIC
classifications
reported
in
the
current
ICR
(
Table
4.1),
the
Agency
estimated
884
sources
would
fall
into
those
categories
­
about
16
percent
of
the
total.
Based
upon
these
characteristics,
the
Agency
determined
the
proxy
methodology
for
estimating
potentially
affected
sources
in
the
Federally
controlled
states
was
a
reasonable
approximation
of
the
true
number
and
distribution
of
sources
in
those
states.

The
data
required
by
sources
for
a
complete
major
NSR
preconstruction
permit
application
can
be
found
in
the
various
parts
of
Title
40
of
the
Code
of
Federal
Regulations
(
40
CFR).
40
CFR
50.166
specifies
the
minimum
requirements
that
a
PSD
air
quality
permit
under
Part
C
of
the
Act
must
contain
to
warrant
approval
as
a
revision
to
a
State
Implementation
Plan
(
SIP).
40
CFR
52.21
delineates
the
Federal
PSD
permit
program
which
applies
to
all
Federal
holdings
other
than
States,
delegated
Tribal
lands,
outer
continental
shelf
sources,
and
States
that
have
not
submitted
a
PSD
program
meeting
the
requirements
of
40
CFR
51.166.
40
CFR
51.165
specify
the
elements
of
an
approvable
State
permit
for
preconstruction
review
in
nonattainment
areas
under
Part
D
of
the
Act.
40
CFR
Part
51,
Appendix
S
(
Offset
Ruling)
and
40
CFR
52.24
(
construction
moratorium)
apply
when
a
nonattainment
area
SIP
has
not
been
fully
approved
by
EPA
as
having
met
the
requirements
of
Part
D
of
the
Act.
These
citations
can
be
found
on
the
EPA
website
at:

http://
www.
epa.
gov/
docs/
epacfr40/
chapt­
I.
info/
subch­
C.
htm
4.2
Information
Requested
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
12
Table
4.3
Industry
Data
and
Information
Requirements
for
PSD
Permit
Applications
Current
Requirements
Regulation
Reference
Description
of
the
nature,
location,
design
capacity,
and
typical
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
system,
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)

A
demonstration
that
the
benefits
of
the
proposed
source
significantly
outweigh
the
environmental
and
social
costs
imposed
as
a
result
of
its
location,
construction,
or
modification
Not
a
current
requirement
a
Information
necessary
to
determine
impact
on
AQRVs
in
Class
I
areas
40
CFR
51.166(
n)(
4)

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)(
4)(
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
a
A
1990
Act
Requirement

173(
a)(
5
Tables
4.3
summarizes
the
respondent
data
and
information
requirements
which
owners
or
operators
of
major
sources
must
include
in
PSD
construction
permit
applications.
The
tables
also
include
the
appropriate
references
in
40
CFR
part
51
for
the
data
and
information
requirements
that
govern
the
way
States
implement
NSR
programs.
For
each
reference
in
Part
51,
corresponding
language
will
be
found
in
part
52.
Table
4.4
summarizes
the
data
and
information
requirements
imposed
by
40
CFR
Parts
51
and
52
on
States
and
other
reviewing
authorities.

Table
4.4
RA
Data
and
Information
Requirements
Requirement
Regulation
Reference
Early
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
11
"
Economic
Assessment
of
the
Impacts
of
Part
C
and
D
Regulatory
Changes,"
June
2,
1994.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
13
Respondents
are
not
subjected
to
a
collection
schedule
per
se
under
NSR
permitting
regulations
of
parts
51
and
52.
In
general,
each
major
stationary
source
is
required
to
submit
an
application
as
a
prerequisite
to
receiving
a
construction
permit.
Preparation
of
a
major
source
construction
permit
application
is
a
one­
time­
only
activity
for
each
project
involving
construction
of
a
new
major
stationary
source
or
major
modification
of
an
existing
major
stationary
source.
The
applicable
SIP
typically
states
the
time
period
that
is
necessary
to
process
a
permit
application
and
issue
a
permit;
consequently,
a
prospective
source
would
be
obliged
to
work
backward
from
the
hopeful
commencement
of
construction
to
determine
the
optimum
submittal
date
for
the
application.
However,
while
the
current
system
does
not
require
periodic
reporting
or
surveys
(
with
the
exception
that
electric
utility
steam
generating
units
are
required
to
submit
annual
emission
reports
in
some
circumstances),
the
provisions
of
this
rulemaking
requires
some
sources
to
maintain
records
of
emissions
for
five
years
and
report
if
there
is
a
significant
emissions
increase
and/
or
if
emissions
are
inconsistent
with
preconstruction
projections.
These
requirements
are
in
addition
to
similar
(
but
not
as
detailed)
requirements
for
emissions
tracking
and
reporting
under
Title
V
Operating
Permits
regulations
and
Part
64
Compliance
Assurance
Monitoring
rules.

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
ICR
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.

A
Regulatory
Flexibility
Act
Screening
Analysis
(
RFASA)
developed
as
part
of
a
1994
draft
Regulatory
Impact
Analysis
(
RIA)
and
incorporated
into
the
September
1995
ICR
renewal
analysis
reported
an
initial
regulatory
flexibility
screening
analysis
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.
11
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
4.3
Collection
Schedule
4.4
Small
Entity
Flexibility
12
The
definition
for
"
small
business"
employed
for
all
SIC
categories
in
this
analysis
was
any
business
employing
fewer
than
500
employees.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
14
sources.
12
Because
the
administrative
burden
of
the
NSR
program
are
the
primary
source
of
the
NSR
program's
regulatory
costs,
the
analysis
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.

The
Agency
may
not,
as
a
general
rule,
exempt
a
major
source
of
air
pollution.
Since
the
impacts
of
NSR
regulations
which
may
impact
small
entities
occur
predominantly
at
major
sources,
little
room
exists
for
regulatory
flexibility
to
avert
the
impact
of
the
proposed
rulemaking
on
small
entities
through
exemption.
However,
even
though
the
Title
V
program
does
not
have
an
adverse
impact
on
a
significant
number
of
small
businesses,
EPA
takes
measures
to
assist
sources
in
affected
small
entities
through
the
implementation
of
small
business
stationary
source
technical
and
environmental
compliance
assistance
programs,
as
called
for
in
section
507
of
the
Act.
These
programs
can
reduce
the
reporting
burden
of
small
entities
which
are
subject
to
major
NSR
and
may
significantly
alleviate
the
economic
burden
on
small
sources
by
establishing
programs
to
assist
small
businesses
with
determining
what
Act
requirements
apply
to
their
sources
and
when
they
apply,
and
guidance
on
alternative
control
technology
and
pollution
prevention
for
small
businesses.

Generally,
EPA
has
several
methods
by
which
it
can
minimize
the
disproportionate
effect
of
a
rulemaking
on
small
entities.
Net
costs
an
be
reduced
through
the
use
of
small
business
stationary
source
technical
and
environmental
compliance
assistance
programs,
the
Agency
can
defer
applicability
for
one
or
several
source
categories,
and
mitigation
can
be
achieved
by
discretion
of
the
Federal
government.
However,
these
avenues
do
not
apply
to
the
NSR
program.

The
President's
priorities
in
promoting
environmental
justice
(
EJ)
are
contained
in
Executive
Order
#
12898.
Because
the
NSR
program
operates
nation­
wide
and
across
all
industry
classifications,
the
Agency
does
not
believe
there
is
a
disproportionate
environmental
justice
effect
in
the
NSR
program.
4.4.1
Measures
to
Avert
Impacts
on
Small
Entities
4.4.2
Measures
to
Mitigate
Impacts
on
Small
Entities
4.5
Environmental
Justice
Considerations
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
15
Tables
6­
1,
2,
and
3
in
the
current
NSR
ICR
lists
the
activities,
burden,
and
estimated
costs
of
NSR
activities
required
for
sources,
reviewing
authorities
(
RAs),
and
the
EPA,
respectively.
These
estimates
form
the
baseline
for
this
ICR.
For
convenience,
Tables
5.1,
2,
and
3,
below,
recreate
the
information
for
PSD
sources
(
those
affected
by
this
ICR
revision).

Table
5.1
Baseline
Annual
Source
Burden
and
Costsa
from
the
Current
ICR
Activity
Units
Hours
per
Unit
Annual
Hours
Annual
Cost
I.
Part
C
(
PSD)

A.
Preparation
and
Planning
Determination
of
Compliance
Requirements
320
170
54,400
$
3,471
Obtain
guidance
on
Data
Needs
320
120
38,400
$
2,450
Preparation
of
BACT
Engineering
Analysis
320
85
27,200
$
1,735
B.
Data
Collection
and
Analysis
Air
Quality
Modeling
320
200
64,000
$
4,083
Determination
of
Impact
on
Air
Quality
Related
Values
320
100
32,000
$
2,042
Post­
construction
Air
Quality
Monitoring
320
50
16,000
$
1,021
C.
Permit
Application
Preparation
and
Submittal
of
Permit
Application
320
50
16,000
$
1,021
Public
Hearings
320
24
7,680
$
490
Revisions
to
Permit
320
40
12,800
$
817
D.
Subtotal
burden
839
268,480
$
17,129
E.
Direct
cost
for
Pre­
construction
Air
Quality
Monitoring
34
$
7,099
F.
Total
cost
$
24,228
a
In
thousands
of
2000
dollars
Table
5.2
Baseline
Annual
State
and
Local
RA
Respondent
Burden
and
Costa
Activity
Units
Hours
Per
Unit
Annual
Hours
Annual
Cost
I.
PART
C
(
PSD)

A.
Attend
Pre­
application
Meetings
320
36
11,520
$
477
B.
Answer
Respondent
Questions
320
20
6,400
$
265
C.
Log
In
and
Review
Data
Submissions
320
16
5,120
$
212
D.
Request
Additional
Information
320
8
2,560
$
106
E.
Analyze
for
and
Provide
Confidentiality
Protection
320
24
7,680
$
318
F.
Prepare
Completed
Applications
for
Processing
320
32
10,240
$
424
G.
File
and
Transmit
Copies
320
8
2,560
$
106
H.
Prepare
Preliminary
Determination
320
24
7,680
$
318
I.
Prepare
Notices
for
and
Attend
Public
Hearings
320
40
12,800
$
530
J.
Application
Approval
320
40
12,800
$
530
K.
Notification
of
Applicant
of
RADetermination
320
8
2,560
$
106
L.
Submittal
of
Information
on
BACT
/
LAER
to
RBLC
320
16
5,120
$
212
M.
Total
272
87,040
$
3,607
a
In
thousands
of
2000
dollars
5
The
Information
Collected
­
Baseline,
Methodology,
and
Management
5.1
Determination
of
Baseline
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
16
According
to
the
current
ICR,
the
Agency
expects
320
PSD
applications
per
year,
each
requiring
about
839
hours
to
complete,
for
a
total
of
over
268,000
hours.
The
ICR
also
estimates
590
nonattainment
NSR
permits
per
year,
each
requiring
557
hours,
for
a
total
of
over
340,000
hours
per
year.
The
current
ICR
also
predicts
each
minor
source
(
56,500
total
minor
NSR
sources)
will
require
40
hours
to
complete
its
NSR
application
requirements,
for
a
total
of
2,260,000
hours.

Table
5.3
Baseline
Annual
Federal
Burden
and
Costa
Activity
Units
Hours
Per
Unit
Annual
Hours
Annual
Cost
I.
PART
C
(
PSD)

A.
Review
and
Verify
Applicability
Determination
320
2
640
$
21
B.
Review
Control
Technology
Determination
320
3
960
$
31
C.
Evaluate
Air
Quality
Monitoring
320
4
1,280
$
41
D.
Evaluate
Alternative
and
Secondary
Impact
Analysis
320
2
640
$
21
E.
Evaluate
Class
I
Area
Analysis
320
2
640
$
21
F.
Administrative
Tasks
320
1
320
$
10
G.
Total
14
4,480
$
144
a
In
thousands
of
2000
dollars.

Section
182(
c)(
8)
of
the
Clean
Air
Act
states
in
extreme
ozone
nonattainment
areas
any
increase
is
considered
a
modification,
but
the
source
can
get
"
internal"
offsets
at
a
1.3
to
1
ratio
to
avoid
applying
controls.
Under
this
provision,
affected
sources
in
extreme
ozone
areas
will
have
to
seek
out
internal
offsets
for
any
modification
that
results
in
an
increase
in
emissions.
However,
under
this
ICR
revision,
none
of
the
states
with
Federally
controlled
programs
have
extreme
nonattainment
areas,
so
the
net
effect
of
the
Section
182(
c)(
8)
provision
is
zero.

This
section
discusses
the
development
of
burden
estimates
and
their
conversion
into
costs,
which
are
separated
into
burden
costs
and
capital
and
O&
M
costs.
According
to
the
latest
guidance
for
ICRs
(
EPA
1995),
capital
and
O&
M
costs
display
the
cost
of
any
new
capital
equipment
the
source
or
RA
may
have
to
purchase
solely
for
information
collection,
assimilation,
and
storage
purposes.
For
example,
if
a
source
had
to
purchase
a
new
mini­
computer
to
store
and
manipulate
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.
To
the
extent
a
source
contracts
out
for
administrative
purposes
(
e.
g.,
employing
consultants
to
perform
monitoring
functions),
the
burden
associated
with
those
contracted
tasks
are
not
a
burden
to
the
source
­
but
they
still
remain
a
cost.
The
reader
should
read
this
section
with
the
following
considerations
in
mind:
5.2
Collection
Methodology
and
Management
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Page
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$
The
Agency
believes
the
amount
of
time
necessary
to
perform
a
task
is
independent
of
the
origins
of
its
labor.
In
other
words,
if
a
source
would
employ
X
hours
of
burden
to
fully
perform
a
function,
then
a
contractor
hired
by
the
source
would
also
take
X
hours
to
perform
that
same
task.
Furthermore,
the
Agency
assumes
no
economies
or
diseconomies
of
scale
in
that
the
linear
combination
of
any
amount
of
contractor
and
source
effort
will
also
sum
to
X.
Therefore,
the
burden
estimates
in
this
ICR
act
as
an
accurate
assessment
of
the
total
burden
to
affected
sources
and
RAs,
given
the
affected
entity
does
not
employ
contracted
labor.

$
For
some
burden
categories,
the
Agency
believes
the
hours
assigned
to
them
will
be
divided
between
the
source
and
outside
contractors.
For
these
categories,
the
Agency
established
a
composite
cost
per
hour
by
developing
a
weighted
average
of
the
source
and
contractor
wages,
with
the
weight
defined
by
the
percentage
of
total
effort
each
burden
source
applied.
Consequently,
the
cost
developed
in
this
ICR
should
be
interpreted
as
an
upper
bound
on
the
actual
cost
of
administration
by
the
source
or
RA.
The
methodology
for
determining
cost
per
hour
can
be
found
in
greater
detail
in
section
6.2,
below.

The
owners
and
operators
of
new
or
modified
major
stationary
sources
affected
by
the
major
NSR
regulations
must
submit
construction
permit
applications
to
the
RA,
who,
in
turn,
logs
in
the
permit
applications,
stores
applications
in
a
central
filing
location,
notifies
the
Federal
Land
Manager
(
FLM)
of
the
permit,
and
provides
a
copy
of
the
application
(
if
applicable)
to
the
FLM
and
transmits
copies
of
each
application
to
EPA.
Upon
permit
approval,
the
RA
submits
control
technology
information
to
EPA's
RBLC
database.

The
RA
reviews
the
permit
and
checks
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
determinations
made
for
sources
similar
to
the
sources
included
in
the
permit
application.
Confidential
information
submitted
by
the
applicant
will
be
handled
by
the
permit
reviewing
authority's
(
RA's)
confidential
information
handling
procedures.
The
public
will
be
provided
the
opportunity
to
review
a
permit
application
and
other
materials
relevant
to
the
RA's
decision
on
issuing
the
permit,
including
FLM
findings,
by
obtaining
a
copy
from
the
permit
reviewing
authority
or
by
attending
the
public
hearing.
The
NSR
regulations
will
not
require
information
through
any
type
of
survey.
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Page
18
Table
6­
2
lists
the
State
and
local
agency
burden
and
costs
associated
with
the
major
NSR
permitting
rule,
as
modified
by
the
proposed
Reform
changes
of
this
analysis.
As
is
the
case
with
the
respondents,
State
and
local
agencies
who
approve
NSR
permits
will
only
have
start­
up
costs
for
any
given
permit.
Consequently,
while
the
State
or
local
agency
will
approve
many
permits
each
year,
the
annual
burden
for
that
function
is
simply
equal
to
the
burden
found
in
any
1
year.
13
The
estimated
38%
of
all
potentially
affected
sources
includes
more
than
just
the
sources
found
in
the
Agency's
general
estimate
of
the
number
of
sources
managed
by
the
Federal
government.
In
many
cases
where
a
State
does
not
have
an
approved
SIP,
the
Agency
delegates
authority
for
the
state
program
back
to
the
state.
FOr
this
analysis,
this
delegation
has
been
ignored
and
those
affected
sources
are
included
herein.

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APPLICABILITY
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TO
EXISTING
SOURCES
Page
19
To
determine
the
number
of
potentially
affected
respondents
for
this
rulemaking,
the
EPA
began
with
the
baseline
data
found
in
the
February
2001
(
current)
ICR,
reproduced
for
convenience
in
this
ICR
revision
as
Tables
5.1,
5.2,
and
5.3,
above.
From
that
baseline,
the
EPA
made
several
adjustments
to
separate
out
those
sources
affected
by
this
rulemaking
(
all
major
source
NSR
modifications)
and
those
for
this
ICR
update
(
Federally
controlled
areas).

The
universe
of
potentially
affected
sources
in
Table
5.1
includes
both
new
construction
and
modifications
to
existing
sources.
Since
this
rulemaking
deals
exclusively
with
major
NSR
requirements
for
existing
facilities,
the
Agency
began
with
the
910
annual
NSR
permit
determinations,
subtracted
out
20
percent
for
utilities
(
based
upon
information
in
the
RBLC),
leaving
728
non­
utility
permits
eligible
for
consideration
under
this
rulemaking.
The
Agency
then
estimated
approximately
two­
thirds
of
the
available
NSR
permits
issued
each
year
come
from
existing
sources,
divided
between
PSD
and
NSR
permits
according
to
the
roughly
1:
2
ratio
of
permits
found
in
the
current
ICR.
Therefore,
this
analysis
assumes
485
permit
determinations
(
162
PSD
and
323
nonattainment
NSR)
are
made
each
year
at
existing
non­
utility
sources.
Apportioning
these
sources
according
to
the
distribution
in
the
current
ICR
means
there
are
222
potentially
affected
PSD
sources
each
year
when
this
rulemaking
is
in
full
effect.
During
the
period
of
time
when
this
rulemaking
only
affects
Federally
controlled
areas,
this
analysis
assumes
38
percent
(
from
the
Operating
Permits
database
analysis)
of
the
overall
values
apply.
13
Consequently,
the
results
in
this
ICR
revision
are
based
upon
62
PSD
non­
utility
sources
and
85
PSD
sources,
including
utilities.
Table
6.1,
below
displays
the
distribution
of
sources
assumed
for
this
ICR
analysis.

For
the
number
of
respondent
reviewing
authorities,
this
analysis
uses
the
112
RA
count
used
by
other
permitting
ICRs
for
one­
time
tasks
(
e.
g.,
SIP
revision)
and
the
appropriate
source
count
for
individual
permit­
related
items
(
e.
g.,
attending
pre­
application
meetings
with
the
source).
There
is
only
one
Federal
source
listed
in
this
ICR.
6
Estimating
the
Burden
and
Cost
of
the
Collection
6.1
Estimating
The
Number
of
Respondents
14
United
States
Environmental
Protection
Agency,
April
1999,
The
OAQPS
Economic
Resource
Document,
http://
www.
epa.
gov/
ttn/
ecas/
econdata/
6807­
305.
pdf
15
United
States
Environmental
Protection
Agency,
January
2002,
The
EPA
Air
Pollution
Control
Cost
Manual,
sixth
edition,
Daniel
C.
Mussatti,
ed.,
EPA
­
452/
B­
020­
001
http://
www.
epa.
gov/
ttn/
catc/
products.
html#
cccinfo
INFORMATION
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and
52
PSD
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NSR
APPLICABILITY
REQUIREMENTS
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MODIFICATIONS
TO
EXISTING
SOURCES
Page
20
Table
6.1
Estimated
Number
of
Affected
Respondents
Per
Year
When
Fully
Implemented
Federally
Controlled
Areas
Without
Utilities
162
62
With
Utilities
222
85
This
rulemaking
changes
the
minimum
elements
that
an
NSR
program
must
contain
for
EPA
to
approve
the
program
into
a
SIP.
RAs
must
incorporate
all
these
changes
into
their
SIPs
or
demonstrate
that
an
alternative
approach
is
at
least
equivalent
to
these
minimum
program
elements.
These
minimum
elements
can
be
classified
into
two
types
of
changes
­
mandatory
changes
that
affect
all
sources
seeking
a
preconstruction
permit,
and
voluntary
changes
that
allow
sources
the
opportunity
to
decide
whether
or
not
the
alternative
permitting
requirements
provide
a
net
benefit
to
the
source.
For
sources
deciding
to
opt
into
voluntary
programs,
the
Agency
asserts
that,
for
any
source
that
decides
to
opt
into
such
a
program
the
benefits
from
that
change
must
outweigh
the
cost
of
that
change.
Under
this
assertion,
"
costs"
and
"
benefits"
include
other
than
monetary
measures
and
it
is
the
implicit
revealed
preference
of
the
source
by
its
choice
that
determines
whether
or
not
the
program
is
beneficial.
Tables
6.2
through
6.8,
below,
display
the
expected
number
of
affected
sources
and
the
change
in
burden
and
cost
for
each
of
the
changes
included
in
this
rulemaking
for
all
respondents.
The
reader
should
note
the
estimated
number
of
sources
discussed
below
are
an
order­
of­
magnitude
assessment
of
the
scope
of
each
program.
In
that
context,
the
reported
number
of
affected
sources
should
be
considered
a
probable
outcome
within
a
reasonable
range
around
the
estimate
and
not
an
exact
estimate.

This
section
presents
estimates
of
the
number
of
potentially
affected
sources
and
the
burden
hours
expected
to
be
incurred
at
those
sources
subject
to
preconstruction
permitting
under
PSD
and
nonattainment
NSR
regulations
as
set
out
in
the
Act
and
parts
51
and
52
of
Title
40
of
the
Code
of
Federal
Regulations.
Applying
the
methodology
established
for
economic
analyses
established
by
the
Agency
in
The
OAQPS
Economic
Resource
Document
14
and
The
EPA
Air
Pollution
Control
Cost
Manual
15.
The
burden
estimates
in
this
ICR
reflect
the
expert
judgement
of
EPA
staff,
6.2
Estimating
Respondent
Burden
16
United
States
Environmental
Protection
Agency,
February
14,
2002,
Information
Collection
Request
for
40
CFR
part
51
and
52
Prevention
of
Significant
Deterioration
and
Nonattainment
New
Source
Review,
OMB
Control
No.
2060­
0003,
EPA
No.
1230.09
17
This
rate
may
need
to
be
adjusted
to
reflect
current
emissions
factors.

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21
contractors,
and
industry
experts.
All
burden
estimates
represent
the
marginal
cost
of
this
rulemaking,
based
upon
the
baseline
burden
and
costs
described
in
the
NSR
program's
February
14,
2001
ICR
renewal.
16
While
the
overall
effect
of
this
rulemaking
is
a
relaxation
of
the
burden
currently
imposed
on
sources,
there
are
several
mitigating
factors
that
make
that
result
not
apparent
in
the
final
analysis.
First,
while
this
rulemaking
eventually
will
apply
to
all
major
stationary
sources
in
attainment
and
nonattainment
areas,
in
the
three
years
immediately
following
the
promulgation
of
this
rulemaking,
the
Agency
anticipates
the
following
Federally
controlled
areas
will
be
affected
immediately
by
the
changes
discussed
above:

·
Federal
reviewing
authorities:
including
Regional
and
Office
of
Air
and
Radiation
environmental
officers
·
States
where
the
management
of
their
program
has
been
delegated
back
to
the
State
·
Federally
controlled
areas
such
as
outer
continental
shelf
drilling
platforms,
Tribal
lands,
and
Federal
territories
and
holdings
(
e.
g.,
American
Samoa)
·
Sources
of
air
pollution
within
attainment
areas
in
the
affected
States,
Tribal
lands,
and
other
Federally
controlled
areas.

With
this
rulemaking,
the
EPA
amends
the
NSR
rules
to
provide
a
new
"
actual­
to­
projected­
actual"
test
for
determining
the
applicability
of
the
NSR
requirements
for
facilities
seeking
to
make
modifications
at
an
existing
major
stationary
source.
As
described
in
greater
detail
in
the
preamble
to
this
rulemaking,
the
following
are
key
features
of
the
new
methodology:

$
New
methodology
applies
to
any
existing
emissions
unit
at
a
major
stationary
source
undergoing
a
major
modification;

$
Sources
other
than
electric
utility
steam
generating
units
will
determine
pre­
change
(
baseline)
actual
emissions
by
calculating
an
average
annual
emissions
rate,
from
any
24­
consecutive
months
during
the
10­
year
period
(
2
in
10)
preceding
the
change;
17
$
When
there
is
a
reasonable
possibility
that
a
change
will
result
in
a
significant
emissions
increase,
sources
will
either
project
post­
change
(
future)
actual
emissions
to
reflect
the
highest
projected
annual
increase
in
actual
emissions
that
results
from
the
proposed
change
in
the
five
(
or
6.2.1
Baseline
Determination
18
Some
sources
may
also
experience
a
lower
baseline
through
other
parts
of
this
rulemaking,
but
for
simplification
purposes,
that
scenario
was
not
considered.

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ten)
years
following
the
change,
excluding
increases
that
the
existing
emissions
unit
could
have
accommodated
during
the
baseline
period
and
that
is
also
unrelated
to
the
particular
project;
or,
project
post
change
emissions
based
on
the
emissions
unit's
potential
to
emit;
and
$
Sources
who
use
the
highest
projected
highest
annual
value
to
compute
post­
change
emissions
must
maintain
sufficient
emissions
information
for
at
least
5
years
following
physical
or
operational
change
to
demonstrate
that
post­
change
emissions
do
not
result
in
a
major
modification.
Sourcces
who
use
the
emissions
unit's
potential
to
emit
to
estimate
post­
change
emissions
need
not
track
post­
change
emissions.

EPA
is
codifying
the
current
procedures
for
determine
baseline
actual
emissions
for
an
electric
utility
steam
generating
units.
That
is,
such
emissions
unit
may
average
any
24
consecutive
months
in
the
past
five
years
for
calculating
the
baseline
actual
emissions.
Therefore,
this
part
of
the
analysis
uses
85
potentially
affected
non­
utility
sources,
as
described
in
section
6.1,
above.
Because
the
new
baseline
procedures
for
non­
electric
utility
steam
generating
units
require
the
source
to
adjust
the
average
annual
emissions
to
reflect
currently
applicable
requirements,
some
sources
may
have
a
lower
baseline
actual
emissions
under
the
new
requirements
and
consequently
trigger
major
NSR
review.
Balancing
these
sources
against
those
who
may
avoid
the
NSR
program
by
selecting
a
new
twoyear
baseline
period,
the
Agency
anticipates
no
more
than
5
percent
(
3
PSD
and
6
NSR)
­
and
probably
fewer
will
avoid
major
NSR
under
the
new
baseline
actual
emissions
requirements.
For
this
analysis,
only
the
three
PSD
sources
can
be
affected.
18
For
all
non­
utility
sources
permitted
annually,
the
new
rules
require
some
sources
to
keep
a
record
of
annual
emissions,
but
do
not
require
CEMS
or
any
additional
monitoring
equipment.
Although
this
recordkeeping
is
a
new
burden
under
the
NSR
program,
it
is
not
a
new
burden
to
sources
because
most
sources
must
perform
similar
monitoring
under
the
requirements
for
title
V
and
for
emission
inventory
purposes.
Only
for
a
very
few
instances
will
this
new
requirement
require
a
source
to
undertake
new
monitoring.
The
only
"
new"
burden
for
this
recordkeeping
component
will
be
for
the
source
to
keep
the
records
in
a
specific
and
accessible
format
and
to
report
deviations
above
a
certain
level.
Also,
each
source
will
have
to
maintain
records
for
at
least
five
years
to
demonstrate
that
the
actual
emission
projections
are
not
exceeded.
The
Agency
anticipates
these
two
requirements
will
add
about
two
hours
per
week
to
the
burden
for
each
source
affected
­
about
an
extra
100
hours
per
year.
Table
6.2
summarizes
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
23
the
expected
effect
of
the
change
in
baseline
determination
portion
of
this
rulemaking.

Table
6.2
Estimated
Effect
of
new
Baseline
Determination
Activity
Units
Hours
per
Unit
Annual
Hours
Annual
Costa
Reduction
in
Number
of
PSD
sources
from
"
2
in
10"
change
3
(
839)
(
2,517)
($
188,775)

Recordkeeping
and
Reporting
3
100
300
$
12,500
TOTAL
EXPECTED
EFFECT
3
(
739)
(
2,217)
($
168,275)

a
Changes
are
in
2002
dollars
As
described
in
section
I.
C.
1
of
the
preamble,
the
Agency
adopted
an
actual­
to­
projected­
actual
methodology
for
determining
post­
change
emissions
(
which
includes
an
option
for
using
the
"
actual­
to­
potential"
approach),
combined
with
a
revised
process
to
determine
baseline
emissions
to
identify
when
sources
plan
to
make
a
major
modification
subject
to
major
NSR.
This
methodology
allows
certain
emissions
increases
to
be
excluded
from
the
calculation
if
such
increases
could
have
been
accommodated
by
the
emissions
unit
before
the
change
and
are
unrelated
to
the
change.

Although
this
new
emissions
test
is
a
change
from
the
current
"
actual­
topotential
test,
the
practical
difference
is
that
sources
will
not
have
to
obtain
an
enforceable
permit
restriction
on
their
post­
change
emissions
projections
before
beginning
construction
of
a
change.
Under
the
"
actualto
potential"
test
many
sources
relied
on
a
projection
of
post­
change
actual
emissions
by
obtaining
enforceable
restrictions
through
a
minor
NSR
permitting
action.
This
restriction
effectively
made
the
potential­
to­
emit
of
the
source
equal
to
this
post­
change
projection.
Under
the
new
test,
we
are
not
requiring
sources
to
obtain
enforceable
restrictions
to
use
the
postchange
emissions
projection.

Of
the
667
annual
permit
determinations
made
for
existing
sources,
the
Agency
anticipates
the
actual­
to­
projected­
actual
determination
will
allow
about
10
percent
(
67
sources
­
8
PSD
sources
in
Federally
controlled
areas)
to
avoid
major
NSR,
divided
between
PSD
and
NSR
determinations
according
to
the
distribution
in
the
February
2001
ICR.

Table
6.3
Estimated
Effect
of
Actual­
To­
Projected­
Actual
Determination
Activity
Units
Hours
per
Unit
Annual
Hours
Annual
Cost
a
Reduction
in
Number
of
PSD
sources
8
839
(
6,712)
($
503,400)

a
Changes
are
in
2002
dollars
6.2.2
Actual­
To­
Projected­
Actual
Determination
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
24
A
PAL
is
a
voluntary
program
that
lets
sources
manage
facility­
wide
emissions.
The
added
flexibility
provided
under
a
PAL
strikes
an
important
balance
between
the
source's
need
to
respond
rapidly
to
market
changes
and
the
Agency's
mission
to
protect
the
environment.
The
PAL
provisions
of
this
rulemaking
are
based
on
plant­
wide
actual
emissions
such
that
if
a
source
maintains
its
emissions
below
a
plant­
wide
actual
emission
cap,
(
called
an
"
actuals"
PAL),
the
program
lets
the
source
make
changes
to
its
facility
without
triggering
major
NSR.
In
return
for
this
flexibility,
the
source
must
monitor
emissions
from
all
of
its
emission
units
under
the
PAL.
The
level
of
monitoring
will
be
different
under
a
PAL
from
that
required
elsewhere
in
the
Act.
Other
programs
include
monitoring
requirements
to
show
sources
do
not
exceed
a
particular
value,
which
can
be
done
by
showing
it
operated
within
a
certain
range
(
parametric
monitoring).
Under
PALs,
each
source
must
quantify
its
emissions.
The
facility's
existing
monitoring
systems
will
most
likely
be
used,
but
only
after
it
is
customized
to
attain
a
higher
level
of
performance;
and
some
sources
will
have
to
purchase
monitoring
equipment
that
they
may
not
currently
have.
However,
the
Agency
expects
the
cost
of
new
monitors
would
preclude
most
sources
from
choosing
PALs
and
that
only
sources
with
existing
monitoring
systems
will
choose
to
use
the
PALs
program.
Consequently,
the
Agency
also
believes
the
additional
cost
of
monitoring
for
these
sources
will
be
minimal
­
about
100
hours
a
year.

The
PAL
program
applies
to
both
PSD
and
nonattainment
NSR
permitting,
but
for
this
ICR
revision,
it
only
applies
to
PSD
sources
in
Federally
managed
areas.
From
the
database
analysis
supplied
to
the
EPA
by
its
contractors
from
the
RBLC,
EPA
determined
there
were
52
sources
of
air
pollution
that
applied
for
multiple
NSR
permits
between
1992
and
2002,
or,
on
average,
two
sources
per
year.
Among
all
of
the
sources
identified
as
having
more
than
one
permit
within
a
ten­
year
period,
seven
had
three
permits,
six
had
four,
and
two
had
five
major
NSR
permits.
The
remaining
37
all
had
only
two
permits
within
ten
years.
Therefore
the
Agency
determined
the
number
of
avoided
permits
available
within
a
ten­
year
period
for
any
given
source
would
most
likely
be
one.
If
all
of
those
sources
were
to
be
in
Federally
controlled
areas,
this
analysis
would
have
an
upper
bound
on
its
estimated
effect.
Consequently,
for
this
ICR
revision,
EPA
assumed
one
PSD
permit
could
be
avoided
each
year
during
the
life
of
this
ICR.

This
analysis
focuses
on
the
number
of
PSD
permits
avoided
by
sources
that
take
PALs,
and
should
not
be
equated
with
the
number
of
sources
that
will
actually
apply
for
PAL
permits.
The
avoidance
of
major
source
permits
is
just
one
of
the
reasons
a
source
might
take
a
PAL
­
simplified
applicability
and
netting
are
examples
of
others,
even
if
the
underlying
changes
would
not
have
triggered
a
major
source
permit.
Further,
not
6.2.3
Plant­
wide
Applicability
Limits
(
PALs)
19
For
instance,
the
technology
governing
the
removal
of
SO2
from
combustion
flue
gas
streams
has
remained
relatively
unchanged
(
except
for
minor
innovations
to
improve
operations)
since
its
introduction
to
the
pollution
control
community
in
the
early
1980'
s.

INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
25
every
source
with
a
PAL
will
make
changes
that
would
otherwise
trigger
a
major
permit
action
every
year.
The
number
of
sources
that
will
eventually
take
PALs
is
likely
higher
than
the
estimate
made
here
for
the
number
of
permits
avoided
at
sources
covered
by
this
analysis.
However,
it
is
the
latter
figure
that
is
more
appropriate
for
use
in
developing
the
burden
estimate
used
in
this
ICR.

Table
6.4
Estimated
Effect
of
Plant­
wide
Applicability
Limits
Activity
Units
Hours
per
Unit
Annual
Hours
Annual
Cost
a
Reduction
in
Number
of
PSD
sources
1
(
839)
(
839)
($
62,925)

Increase
in
Monitoring
Requirements
at
Sources
Opting
into
PALs
1
100
100
$
7,500
TOTAL
EXPECTED
CHANGE
(
739)
(
739)
($
55,225)

a
Current
ICR
costs
are
in
thousands
of
2001
dollars,
changes
are
in
thousands
of
2002
dollars
This
rulemaking
includes
a
new
type
of
applicability
test
for
emission
units
that
are
designated
as
Clean
Units
(
CU).
Under
this
test,
the
Agency
explicitly
recognizes
that
the
rate
of
technological
change
is
not
smooth
and
continuous.
Instead,
once
a
new
technology
has
been
introduced
for
pollution
control
purposes,
it
may
take
a
significant
number
of
years
for
a
new
control
technology
to
be
developed
that
would
replace
that
BACT
or
LAER.
19
Consequently,
when
a
source
undertakes
a
major
NSR
review
and
installs
BACT
or
LAER,
that
source
(
now
deemed
a
"
Clean
Unit")
may
make
changes
over
a
long
period
of
time
that
could
trigger
major
NSR
under
a
strict
interpretation
of
the
regulation,
but
would
not
result
in
a
control
technology
change
that
would
provide
more
than
de
minimis
improvements
in
the
source's
abatement
efficiency.
The
CU
applicability
test
presumes
the
prior
installation
of
BACT
or
LAER
at
a
source
is
sufficient
to
allow
a
source
use
the
current
permit
limitations
to
estimate
whether
changes
in
the
future
will
result
in
an
emissions
increase.
Emissions
units
that
have
not
been
through
major
NSR
may
still
qualify
for
the
Clean
Unit
designation
if
they
demonstrate
that
the
emission
control
and
associated
permit
conditions
are
comparable
to
BACT
or
LAER.

This
CU
applicability
test
also
allows
minor
NSR
and
voluntary
control
installations
to
qualify
for
Clean
Unit
States,
thereby
providing
incentives
for
sources
to
install
state­
of­
the­
art
controls
to
maximize
their
flexibility
to
make
future
changes
without
triggering
major
NSR
review.
This
new
applicability
test
therefore
protects
air
quality,
creates
incentives
for
6.2.4
Clean
Units
Test
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
26
sources
to
install
state­
of­
the­
art
controls,
provides
flexibility
for
sources,
and
promotes
administrative
efficiency.

The
determination
of
the
number
of
potentially
affected
sources
for
the
Clean
Units
Test
follows
the
same
methodology
as
that
performed
for
PALs,
above.
Consequently,
while
as
many
as
five
sources
beyond
those
already
performing
CUT­
like
practices
after
receiving
a
major
source
permit
may
be
able
to
opt
into
the
Clean
Units
Test
program
under
the
full
coverage
of
this
rulemaking
in
the
short
term,
while
only
Federally
controlled
areas
are
affected,
the
Agency
anticipates
only
one
PSD
source
may
be
able
to
opt
into
the
program
during
the
period
of
time
covered
by
this
ICR
revision.

Table
6.5
Estimated
Effect
of
Clean
Units
Test
Activity
Units
Hours
per
Unit
Annual
Hours
Annual
Cost
a
Reduction
in
Number
of
PSD
sources
1
839
(
839)
($
62,925)

a
Current
ICR
costs
are
in
thousands
of
2001
dollars,
changes
are
in
thousands
of
2002
dollars
EPA
developed
a
comprehensive
list
of
pollution
control
projects
(
PCPs)
believed
to
be
environmentally
beneficial
when
applied
to
most
industrial
processes.
To
provide
incentives
to
sources
for
the
installation
of
these
technologies,
EPA
has
determined
that
sources
installing
a
listed
PCP
will
qualify
for
an
exclusion
from
major
NSR
if
the
project
results
in
an
environmental
benefit
and
does
not
cause
a
violation
of
the
NAAQS
or
PSD
increment,
or
have
an
adverse
impact
on
an
identified
AQRV.
The
Agency's
determination
of
what
presumptively
qualifies
as
a
PCP
is
limited
to
those
technologies
listed
in
this
rulemaking,
but
an
RA
may
allow
other
projects
to
qualify
using
a
case­
by­
case
permitting
process.
Thus,
the
PCP
Exclusion
allows
sources
to
install
emissions
controls
that
are
known
to
be
environmentally
beneficial
without
triggering
major
NSR
for
small,
collateral
pollutant
increases.
These
provisions
thus
offer
flexibility
while
improving
air
quality.

Under
the
provisions
of
the
PCP
exclusion,
sources
may
undertake
projects
that
significantly
increase
emissions
of
a
criteria
pollutant
and
avoid
meeting
the
existing
major
NSR
requirements.
However,
the
source
must
still
obtain
offsets
for
the
significant
increase.
Since
the
offset
requirement
is
a
provision
of
the
current
NSR
rules,
it
produces
no
net
change
in
the
burden
or
cost
to
the
source
and
is
not
considered
a
part
of
the
burden
and
cost
of
this
rulemaking.

There
are
no
empirical
foundations
upon
which
to
base
an
estimate
of
the
number
of
potentially
affected
sources
for
this
element
of
the
rulemaking,
since
the
determination
of
a
specific
number
of
participating
entities
would
6.2.5
Pollution
Control
Projects
(
PCPs)
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
27
involve
the
derivation
of
a
counterfactual
value.
Consequently,
based
upon
informal
polling
of
EPA
regional
offices
and
for
the
purposes
of
this
analysis,
EPA
expects
one
PSD
and
one
NSR
permitted
source
will
participate
in
the
PCP
program
each
year
during
the
life
of
this
ICR
revision.
Currently,
a
number
of
sources
are
already
participating
in
the
PCP
program
as
part
of
the
on­
going
policy
surrounding
major
source
permitting.
However,
the
Agency
believes
this
formalization
of
the
PCP
process
will
provide
greater
certainty
to
sources
and
offer
a
streamlined
methodology
that
will
be
attractive
to
more
sources
and
types
of
sources
than
are
currently
participating.
These
are
the
sources
addressed
in
this
ICR
revision
and
that
will
be
addressed
in
toto
during
the
next
NSR
ICR
update.

Table
6.6
Estimated
Effect
of
Pollution
Control
Project
Exclusion
Activity
Units
Hours
per
Unit
Annual
Hours
Annual
Cost
a
Reduction
in
Number
of
PSD
sources
1
839
(
839)
($
62,925)

a
Current
ICR
costs
are
in
thousands
of
2001
dollars,
changes
are
in
thousands
of
2002
dollars
The
current
rulemaking
results
in
an
increase
in
the
burden
imposed
upon
RAs.
Each
RA
must
submit
changes
to
their
existing
SIP
programs
or
demonstrate
that
their
existing
programs
are
at
least
equivalent
to
EPA's
new
requirements.
Because
the
changes
needed
for
updating
SIPs
are
small
and
the
state
requirements
for
SIP
development
differ
from
state
to
state,
the
Agency
assumed
it
would
take
no
more
than
eighty
hours
for
each
reviewing
authority
to
fully
incorporate
this
rulemaking
into
its
plan.
This
assumption
includes
legislative
review,
public
comment,
and
all
legal
and
legislative
processes
necessary
for
all
of
the
above
components.
Table
6.7,
below,
displays
the
aggregate
effect
of
this
rulemaking
on
all
RAs.

Table
6.7
Estimated
Reviewing
Authority
Burden
and
Cost
a
Activity
Units
Hours
per
RA
Annual
Hours
Annual
Cost
a
TOTAL
EXPECTED
CHANGE
112
80
8,960
$
331,520
a
Current
ICR
costs
are
in
thousands
of
2001
dollars,
changes
are
in
thousands
of
2002
dollars
The
Federal
change
in
burden
resulting
from
these
changes
will
be
to
review
state
SIPs
to
verify
their
changes
fully
meet
the
requirements
of
the
program.
Due
to
the
nature
of
the
changes
needed,
the
Agency
expects
that,
when
the
rule
is
fully
in
effect,
that
each
SIP
will
require
about
ten
hours
of
review.
However,
for
the
time
period
of
this
rulemaking,
the
Federal
burden
is
limited
to
only
those
tasks
it
would
perform
in
the
maintenance
of
its
oversight
function
in
Federally
controlled
areas.
In
other
6.3
Estimating
Reviewing
Authority
Burden
6.4
Estimating
Federal
Burden
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
28
words,
the
EPA
assumes
there
is
no
additional
Federal
burden
or
cost
derived
from
the
short
term
effects
of
this
rulemaking.

Table
6.8
Estimated
Federal
Burden
and
Cost
a
Activity
Units
Hours
Annual
Hours
Annual
Cost
a
TOTAL
EXPECTED
CHANGE
1
0
0
$
0
a
Current
ICR
costs
are
in
thousands
of
2001
dollars,
changes
are
in
thousands
of
2002
dollars
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
29
Tables
6.2
through
6.8,
above,
include
the
expected
cost
of
the
burden
associated
with
each
of
the
changes
in
the
major
source
NSR
program.
The
cost
to
respondents
for
ICR
purposes
generally
falls
within
two
categories:
the
burden
cost
of
technical
and
administrative
personnel,
and
the
capital
cost
of
collection­
related
equipment.
For
those
elements
of
this
rulemaking
that
constitute
opportunities
for
reductions
in
source
burden,
there
can
be
no
potential
change
in
the
capital
costs
associated
with
this
ICR
update.
When
the
Agency
anticipates
an
increase
in
burden
to
sources,
their
additional
capital
costs
are
considered
below
in
this
section.
Source
burden
costs
are
typically
wage
rates
paid
to
employees
and
costs
incurred
by
the
use
of
consultant
labor.
For
this
analysis,
the
Agency
assessed
source
burden
as
only
internally
generated
wages,
established
at
the
administrative
rate
of
$
75
per
hour
(
fully
loaded)
established
in
the
August
2001
ICR
for
the
Compliance
Monitoring
Rule
(
EPA
Number
1663.03).

During
the
development
of
the
1997
ICR
for
the
part
71
Federal
Operating
Permit
Regulations,
the
Agency
also
determined
the
appropriate
wage
rates
to
apply
to
Federal
burden
categories.
For
this
ICR,
the
Agency
employed
the
same
methodology
to
determine
2002
Federal
and
state
burden
costs
and
established
the
appropriate
rate
at
$
37
per
hour.
Table
6.9
displays
the
calculation
of
this
rate.

Table
6.9
Determination
of
Federal
and
State
Wage
Rates
Annual
Salary
of
Permit
Staff,
GS
11
Step
3
(
FY
02
Schedule)*
$
44,462.00
Annual
Cost
of
Supervisory
Staff,
GS
13
Step
3
(
FY
02
Schedule)*
$
63,369.00
Factor
(
1/
11)
0.09
$
5,703.21
Annual
Cost
of
Support
Staff,
GS
6
Step
6
(
FY
02
Schedule)*
Factor
(
1/
8)
$
29,569.00
0.13
$
3,696.13
Annual
Applicable
Salary
of
Permit
Staff
$
53,861.34
Benefits
(
at
16%)
$
8,617.81
Sick
Leave
/
Vacation
(
at
10%)
$
5,386.13
General
Overhead
$
17,413.37
Total
Cost
Per
FTE
$
85,278.65
Total
Hourly
Cost
(
Total
Per
FTE
divided
by
2,080
hours
per
year)
$
37.12
*
http://
www.
govexec.
com/
pay/
02gs.
htm,
April
11,
2002
The
first
three
years
of
this
rulemaking
have
a
limited
affect
on
sources,
since
it
will
take
several
years
for
reviewing
authorities
to
modify
their
SIPs
and
have
them
approved
by
the
EPA.
During
this
period,
only
Federally
controlled
areas
will
contain
sources
affected
by
this
rulemaking.
Those
areas
can
be
found
listed
in
Section
4.1
of
this
ICR
revision.
During
the
period
covered
by
this
ICR
revision,
this
rulemaking
will
produce
a
minor
decrease
in
source
burden
(
11,346
hours
for
all
affected
sources)
hours
and
6.5
Estimating
Respondent
Costs
6.6
Estimating
Agency
Costs
6.7
Estimating
Costs
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
30
cost
($
648,450
overall,
or
about
$
46,318
per
affected
source).
This
rulemaking
will
also
increase
the
burden
(
8,960
hours)
and
cost
($
331,520
overall,
or
about
$
2,960
per
entity)
for
reviewing
authorities.
Since
the
Agency
already
has
oversight
authority
over
the
major
stationary
sources
in
this
ICR
revision,
the
EPA
anticipates
no
change
to
its
own
burden
and
cost
from
this
rulemaking
over
the
period
of
time
covered
by
this
revision.
Table
6.10,
below,
displays
the
change
in
annual
burden
and
costs
for
sources,
reviewing
authorities,
and
the
Federal
government,
respectively.

In
each
table,
the
second
column
lists
the
number
of
emissions
units
affected,
based
upon
the
methodologies
and
assumptions
discussed
above
in
each
section.
The
third
column
displays
the
change
in
hours
per
emissions
unit
for
each
program
element,
with
negative
numbers
indicating
a
reduction
in
burden,
zero
indicating
no
change,
and
a
positive
value
indicating
an
increased
burden.
The
reader
can
re­
create
the
annual
hours
for
each
burden
category
by
multiplying
the
number
of
emissions
units
affected
by
the
hours
per
unit.
Column
four
displays
the
total
cost
of
the
expected
burden,
and
column
five
displays
the
average
cost,
across
only
affected
sources,
for
each
element
of
the
rulemaking.
The
Source
Total
row
at
the
bottom
of
Table
6.10'
s
source
section
displays
the
average
cost
to
respondents
as
across
all
910
annually
affected
sources.
For
permitting
authorities,
the
burden
categories
listed
are
one­
time
burden
categories
that
each
source
must
incur,
whether
or
not
they
have
a
Federally
imposed
program
in
place.
Consequently,
the
last
column
is
one
third
of
the
product
of
the
number
of
annual
hours
for
each
burden
category
times
the
Federal
and
state
wage
rate.

Table
6.10
Aggregate
Change
in
Burden
and
Cost
a
for
this
Rulemaking
Regulatory
Change
Number
of
Affected
Entities
Annual
Burden
Hours
Annualized
Cost
Average
Cost
per
Entity
SOURCES
Baseline
Determination
Avoided
Major
Source
NSR
3
(
2,517)
($
188,775)
($
62,925)

New
Monitoring
Requirements
3
300
$
225,000
$
7,500
Actual­
to­
projected­
actual
Determination
8
(
6,712)
($
503,400)
($
62,925)

Plant­
wide
Applicability
Limits
(
PALs)

Avoided
Major
Source
NSR
1
(
839)
($
62,925)
($
62,925)

New
Monitoring
Requirements
1
100
$
7,500
$
7,500
Clean
Units
Test
1
(
839)
($
62,925)
($
62,925)

Pollution
Control
Projects
1
(
839)
($
62,925)
($
62,925)

Source
Total
14
(
11,346)
($
648,450)
($
46,318)

RAs
112
8,960
$
331,520
$
2,960
FEDERAL
1
0
$
0
$
0
a
In
thousands
of
2002
dollars.
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
31
Through
years
of
negotiation,
public
meetings,
and
draft
revisions,
the
Information
Transfer
and
Program
Integration
Division
has
strived
to
streamline
and
simplify
the
reporting
and
recordkeeping
requirements
for
the
preconstruction
permit
proceed
mandated
by
the
Act
for
sources
of
criteria
and
hazardous
air
pollutants.
This
rulemaking
represents
the
culmination
of
many
parts
of
that
process.
Because
the
goal
of
this
effort
was
to
reduce
burden
and
costs,
the
reasons
for
the
change
in
burden
displayed
above
the
tables
above
is
self
evident.

The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
40
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
No.
OAR­
2003­
0057,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
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
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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.
Once
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,
DC
20503,
Attention:
Desk
6.8
Reasons
For
Change
In
Burden
6.9
Burden
Statement
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PARTS
51
and
52
PSD
AND
NSR
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES
Page
32
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0057)
in
any
correspondence.
