Supporting
Statement
for
the
Review
of
New
Sources
and
Modifications
in
Indian
Country
Rule
Prepared
by
Office
of
Air
Quality
Planning
and
Standards
May
29,
2003
Based
upon
our
evaluation
of
current
Tribal
emission
inventories
and
the
application
of
updated
growth
rates,
we
have
determined
that
the
analysis
has
not
changed
significantly
to
date;
therefore,
the
May
2003
analysis
for
the
period
2004 
2010
remains
valid
for
the
EIA
and
the
associated
ICR
supporting
statement.
This
analysis
will
be
updated
for
the
final
rulemaking.
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection.
"
Review
of
New
Sources
and
Modifications
in
Indian
Country."
The
tracking
number
is
EPA
ICR
number
2111.01.
(
Proposed
rule)

(
b)
Short
Characterization/
Abstract.
The
proposed
action
would
establish
nationally
applicable
regulations
to
implement
a
permitting
program
in
Indian
country,
which
would
regulate
the
construction
and
modification
of
stationary
sources
of
air
pollution
and
allow
certain
new
and
existing
stationary
sources
to
voluntarily
accept
federally
enforceable
emission
limits
in
order
to
avoid
major
source
regulations.
With
this
action,
EPA
is
proposing
regulations
to
regulate
new
minor
stationary
sources
and
minor
modifications
in
Indian
country,
i.
e.,
a
federal
minor
NSR
rule.
However,
no
specific
language
is
included
for
the
federal
major
nonattainment
NSR
rule
because
it
is
already
provided
in
40
CFR
51.

Potential
respondents
are
owners
or
operators
of
all
new
minor
stationary
sources
and
minor
modifications
(
to
both
minor
and
major
sources)
in
Indian
country,
and
those
major
stationary
sources
and
major
modifications
located
in
portions
of
Indian
country
that
are
not
in
attainment
of
the
National
Ambient
Air
Quality
Standards
(
NAAQS),
i.
e.,
nonattainment
areas.

The
minor
source
regulations
set
forth
the
procedures
and
terms
under
which
the
Administrator
will
issue
new
source
review
(
NSR)
construction
permits
for
stationary
sources
of
air
pollution
in
Indian
country,
pursuant
to
Title
I
of
the
Clean
Air
Act
as
amended
in
1990
(
CAA).
These
regulations
will
apply
to
all
new
minor
stationary
sources
and
modifications
in
Indian
country
that
are
not
subject
to
regulation
as
major
new
sources
and
major
modifications
under
parts
C
or
D
of
Title
I
of
the
CAAA
and
are
not
de
minimis
as
defined
in
the
proposed
regulation.
All
respondents
to
the
federal
minor
NSR
rule
would
be
required
to
prepare
a
NSR
construction
permit.
Respondents
would
be
required
to
use
the
new
best
available
Minor
Source
Control
Technology
(
MSCT)
to
control
air
emissions.
Respondents
with
different
types
of
processes
would
be
required
to
study
alternatives
and
adopt
minor
source
MSCT,
depending
on
the
type
of
process,
unless
technically
or
economically
infeasible.
Initial
compliance
would
be
demonstrated
through
performance
tests
and
compliance
certifications.
Continuous
compliance
would
be
demonstrated
through
inspections
and
monitoring
of
emissions
or
control
device
operating
parameters.

Respondents
would
keep
records
and
submit
one­
time
notifications
as
required
by
the
rules,
and
scheduled
periodic
reports
of
deviations
from
the
rule
requirements.
In
some
cases,
an
immediate
report
would
be
required
if
actions
taken
in
response
to
the
startup,
shutdown,
or
malfunction
were
not
consistent
with
the
startup,
shutdown,
and
malfunction
plan.
Respondents
would
maintain
records
of
specific
information
to
ensure
2
that
the
rule
requirements
are
being
achieved
and
maintained.
These
requirements
are
listed
in
Attachment
1.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.
The
EPA
is
authorized
to
protect
air
quality
by
directly
implementing
provisions
of
the
Clean
Air
Act
throughout
Indian
country.
In
the
preamble
to
the
CAA
Tribal
Authority
Rule,
EPA
stated
the
intention
to
draft
nationally
applicable
regulations
to
implement
a
permitting
program
in
Indian
country
which
would
regulate
construction
and
modification
of
stationary
sources
of
air
pollution
(
63
FR
7254,
February
12,
1998).

Certain
records
and
reports
are
necessary
for
the
Tribal
agency
(
or
EPA
Administrator
in
non­
delegated
areas),
for
example,
to:
(
1)
identify
any
stationary
sources
not
subject
to
the
NSR
standards,
identify
new
or
modified
major
and
minor
sources
in
Indian
country
subject
to
the
rules,
and
confirm
the
compliance
status
of
major
and
minor
sources
in
Indian
country
subject
to
the
rules;
and
(
2)
ensure
that
the
major
and
minor
source
control
requirements
are
being
achieved.

(
b)
Practical
Utility/
Users
of
the
Data.
The
information
will
be
used
by
EPA
or
Tribal
enforcement
personnel
to:
(
1)
identify
major
and
minor
sources,
new
or
modified,
subject
to
the
rules,
(
2)
ensure
that
minor
source
MSCT
is
being
properly
applied,
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.
Based
on
the
reported
information,
the
Tribes
can
decide
which
plants,
records,
or
processes
should
be
inspected.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.
A
search
of
the
EPA's
existing
regulations
and
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts.
However,
should
certain
reports
required
by
Tribal,
State
or
local
agencies
duplicate
information
required
by
the
Review
of
New
Sources
and
Modifications
in
Indian
Country
rule,
a
copy
of
the
report
submitted
to
the
Tribal,
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
rule.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.
An
announcement
of
a
public
comment
period
for
this
initial
rule
related
ICR
will
be
published
in
the
Federal
Register,
along
with
the
proposed
rule.

(
c)
Consultations.
In
undertaking
this
rulemaking
effort,
EPA
wanted
to
ensure
that
the
tribes
were
included
in
the
rulemaking
process
from
the
beginning
of
the
rule
development
effort.
To
that
end,
on
June
24,
2002,
EPA
sent
letters
to
tribal
leaders
seeking
their
input
on
how
we
could
best
consult
with
the
tribes
on
the
rulemaking
effort.
3
The
EPA
received
responses
from
75
tribes.
Of
these
75
tribes,
69
designated
an
environmental
staff
member
to
work
with
EPA
on
developing
the
rule.
As
a
result
of
this
feedback,
EPA
developed
a
consultation/
outreach
plan
which
included
three
national
meetings
held
at
the
Menominee
Tribe
in
Wisconsin,
the
Mohegan
Tribe
in
Connecticut,
and
the
Chehalis
Tribe
in
Washington.
A
fourth
meeting
was
held
in
conjunction
with
the
Institute
of
Tribal
Environmental
Professionals'
(
ITEP)
anniversary
meeting
in
Flagstaff,
Arizona.
In
addition
to
conducting
these
national
meetings,
EPA
also
visited
tribal
environmental
staff
in
Indian
country,
where
time
and
travel
permitted.
Over
30
tribes
attended
these
meetings.
In
addition
to
the
meetings,
there
is
also
has
an
on
going
workgroup
of
tribal
environmental
staff
that
has
worked
with
EPA
on
developing
these
rules.
The
EPA
also
has
a
website
dedicated
to
facilitating
outreach
and
providing
another
vehicle
for
comments
on
this
rule.

Although
much
of
EPA's
effort
was
in
the
form
of
outreach
to
the
tribes,
EPA
also
felt
it
was
important
to
ensure
that
the
State
and
local
air
pollution
control
agencies
and
small
business
concerns
had
an
opportunity
to
interact
with
EPA
during
development
of
this
rule.
To
that
end,
EPA
had
two
meetings
with
the
State
and
Territorial
Air
Pollution
Program
Administrators
and
the
Association
of
Local
Air
Pollution
Control
Officers
(
STAPPA/
ALAPCO)
to
present
the
draft
preamble
and
rule.
The
EPA
also
met
with
the
National
Federation
of
Independent
Business
and
provided
outreach
material
through
the
small
business
ombudsman's
office
to
get
input
from
the
small
businesses
that
might
be
affected
by
this
rule.

(
d)
Effects
of
Less
Frequent
Collection.
If
results
were
collected
less
frequently,
there
would
be
little
assurance
that
each
source
was
in
continuous
compliance
with
the
NSR
requirements.
Also,
the
EPA's
authority
to
take
administrative
action
would
be
reduced.

(
e)
General
Guidelines.
None
of
the
recordkeeping
or
reporting
requirements
contained
in
the
Review
of
New
Sources
and
Modifications
in
Indian
Country
rule,
40
CFR
Parts
49
and
51,
or
otherwise
pertinent
to
this
request,
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

(
f)
Confidentiality.
Confidential
business
information
will
be
handled
using
Agency
guidelines
on
confidentiality,
set
forth
in
Title
40
Chapter
1,
Part
2
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
Part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

(
g)
Sensitive
Questions.
Information
to
be
reported
consists
of
emissions
data
and
other
information
that
are
not
of
a
sensitive
nature.
No
sensitive
personal
or
proprietary
data
are
being
collected.
4
4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes.
Potential
respondents
are
owners
or
operators
of
all
new
minor
stationary
sources
and
minor
modifications
in
Indian
country,
and
those
major
stationary
sources
and
major
modifications
located
in
portions
of
Indian
country
that
are
in
nonattainment
areas.
It
is
estimated
that
288
new
minor
sources
of
varying
types
would
be
subject
to
the
rule
requirements
during
the
analysis
period
(
i.
e.,
2004
to
2010).
The
SIC
and
NAICS
codes
for
these
various
minor
source
types
are
included
in
the
economic
impact
analysis
cost
tables.
Twenty­
three
new
major
sources
are
estimated
to
be
built
in
Indian
country
during
the
analysis
period;
however,
only
one
new
major
source
in
a
nonattainment
area
is
expected
in
Indian
country
during
the
analysis
period.

Entities
potentially
affected
by
this
proposed
action
include
sources
in
all
industry
groups.
The
majority
of
sources
potentially
affected
are
expected
to
be
in
the
following
groups.

SIC
NAICS
Sector
Description
0711
115112
Repellent
and
fertilizer
applications
1021
212234
Copper
mining
and
processing
1221,
1222,
1231
21211
Coal
mining
1311
211111
Oil
and
gas
production
1321
211112
Fractionation
of
natural
gas
liquids
1422
212312
Stone
quarrying
and
processing
1423
212313
Stone
quarrying
and
processing
1442
212321
Sand
and
gravel
production
2295
31332
Surface
coating
operations
2421
321113
Lumber
saw
mill
­
check
this
one
also
2431
321911
Window
&
door
molding
manufacturer
2511
33712
2752
323110
Furniture
manufacture
Printing
operations
(
lithographic)
2754
323111
Gravure
printing
2759
323113
Commercial
screen
printing
2819
325188
Elemental
phosphorus
plant
2819
325188
2951
324121
Sulfuric
acid
plant
Asphalt
hot
mix
plant
3341
331314
Secondary
aluminum
production
and
extrusion
3341
331492
Cobalt
and
tungsten
recycling
3411
332431
Surface
coating
operations
3479
332812
Surface
coating
operations
4612
486110
Crude
oil
storage
and
distribution
4911
221112
Power
plant
­
coal­
fired
4911
221119
Power
plant
­
biomass
fueled
4911
221119
Power
plant
­
landfill
gas
fired
4922
221210
Natural
gas
collection
4922
486210
Natural
gas
compressor
station
4953
56221
Medical
waste
incinerators
4953
562212
Solid
waste
landfill
5032
421320
Concrete
batching
plant
5153
422510
Grain
elevator
5171
422710
Crude
oil
storage
and
distribution
5171
422710
Gasoline
bulk
pant
5
SIC
NAICS
Sector
Description
5541
4471
Gasoline
station
storage
tanks
and
refueling
7216
812320
Dry
cleaner
7389
5614
Lumber
manufacturer
support
7532
811121
Automobile
refinishing
shop
 
Boilers
(
natural
gas)
 
Boilers
(
oil)
a
Standard
Industrial
Classification
b
North
American
Industry
Classification
System.

Entities
potentially
affected
by
this
proposed
action
also
would
include
tribal
governments
that
are
delegated
administrative
authority
to
implement
these
Federal
regulations.

(
b)
Information
Requested.
(
i)
Data
items,
including
recordkeeping
requirements.
All
data
in
this
ICR
that
are
recorded
and/
or
reported
as
required
by
the
Review
of
New
Sources
and
Modifications
in
Indian
Country
rule
are
identified
in
Attachment
1
and
characterized
in
section
6.
The
rules
also
require
5
years
of
record
retention.

(
ii)
Respondent
Activities.
The
respondent
activities
required
by
the
Review
of
New
Sources
and
Modifications
in
Indian
Country
rule
are
identified
in
Attachment
1
and
characterized
in
section
7.
These
include
preparation
and
planning
activities,
submittal
of
a
permit
application,
and
various
reporting
activities.

5.
The
Information
Collected
­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.
A
list
of
Agency
activities
is
provided
in
Attachment
2
and
introduced
in
section
5(
c).

(
b)
Collection
Methodology
and
Management.
It
is
expected
that
this
information
collection
(
i.
e.,
all
permit
applications
and
reports)
will
involve
hard­
copy
submittals
by
the
respondents,
although
electronic
filing
is
an
option.
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
any
monitoring
systems
(
CEMS
or
CPMS)
are
properly
installed
and
operated.
Performance
evaluation
reports
are
used
by
the
Agency
to
determine
the
capability
of
the
source
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
Reports
of
compliance
monitoring
and
deviation,
and
startup,
shutdown,
and
malfunction
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
5
years.
6
(
c)
Small
Entity
Flexibility.
The
recordkeeping
and
reporting
burden
is
the
same
for
all
entities,
regardless
of
size.
The
requirements
are
viewed
by
the
Agency
as
the
minimum
needed
to
ensure
compliance
and
cannot
be
reduced
further
for
small
entities.

(
d)
Collection
Schedule.
Data
collection
will
begin
after
the
promulgation
date
of
rule,
tentatively
scheduled
for
2004.
The
average
total
agency
burden
per
affected
source,
provided
in
Attachment
2,
is
48
hours.
The
schedule
for
reports
required
by
the
regulations
is
detailed
below.

(
i)
All
stationary
sources
that
are
subject
to
the
rule
must
obtain
a
NSR
permit
before
they
begin
actual
construction.

(
ii)
Annual
submittal
of
reports
of
any
required
monitoring,
including
the
type
and
frequency
of
monitoring,
and
summary
of
results
obtained
by
monitoring.

(
iii)
Prompt
reporting
of
deviations
from
permit
requirements,
including
those
attributable
to
upset
conditions
as
defined
in
the
permit,
the
probable
cause
of
such
deviations,
and
any
corrective
actions
or
preventive
measures
taken.
Within
a
permit,
the
Administrator
shall
define
"
prompt"
in
relation
to
the
degree
and
type
of
deviation
likely
to
occur
and
the
applicable
requirements,
provided
that
no
report
requested
solely
under
this
provision
of
the
rule
shall
be
due
sooner
than
2
days
after
the
upset
event,
and
that
all
deviation
reports
shall
be
due
within
10
days
of
the
event.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.
(
i)
Minor
sources.
The
minor
NSR
permitting
rule
proposed
in
this
action
would
apply
to
all
new
stationary
sources
and
modifications
in
Indian
country
that
are
not
subject
to
regulation
as
new
major
stationary
sources
or
major
modifications
under
parts
C
or
D
of
Title
I
of
the
Act,
and
are
not
de
minimis
as
defined
in
the
proposed
regulation.

New
minor
sources.
The
annual
burden
estimates
are
based
on
an
estimated
288
new
minor
source
facilities
coming
online
over
the
study
period
of
2004
to
2010.
There
are
expected
to
be
123
new
minor
sources
during
the
first
3
years
following
promulgation
of
the
rule.
Modifications
to
existing
minors.
The
EPA
estimates
that
there
are
3,169
existing
minor
sources
in
Indian
country.
Assuming
that
a
minor
source
makes
a
modification
every
10
years,
each
year
there
would
be
an
estimated
317
facilities
making
modifications
to
their
operations.
However,
it
is
anticipated
that
of
these
minor
source
process/
operational
modifications
only
5
percent
will
result
in
greater
than
de
minimis
emissions
increases.
This
group
(
16
facilities
per
year)
will
be
required
to
get
a
minor
source
NSR
permit.
As
EPA
noted
in
their
memorandum
on
"
New
Source
Review
Year
2000
Adjustments,"
September
6,
2000,
"...
industry
has
been
able
to
build
major
new
plants
or
make
physical
and
operational
changes
at
major
existing
sources
without
exceeding
the
major
source
7
and
major
modification
thresholds."
The
same
situation
holds
for
minor
sources.
Sources
are
expected
to
avoid
the
minor
NSR
thresholds
for
same
three
reasons
as
noted
for
major
sources:
(
1)
installation
of
state­
of­
the­
art
control
technologies;
(
2)
replacement
or
better
control
of
older,
more
polluting
processes;
and
(
3)
engaging
in
effective
pollution
prevention
efforts.
All
of
these
actions
result
in
significant
reductions
in
air
emissions
beyond
the
baseline
case.
Therefore,
during
the
first
3
years
following
promulgation,
it
is
estimated
that
there
will
be
48
minor
sources
requiring
permits
as
a
result
of
minor
modifications.
Of
these
minor
source
facilities
undergoing
a
minor
modification,
it
is
estimated
that
half
will
incur
control
device
costs.

With
regard
to
the
minor
NSR
permitting
rule,
the
information
burden
estimates
for
monitoring,
testing,
reporting
and
recordkeeping
are
presented
in
Attachment
1.
These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.
See
section
7
for
the
assumptions
regarding
the
frequency
of
occurrence
for
the
various
respondent
activities
and
their
associated
costs.

(
ii)
Major
sources.
The
NSR
permitting
regulations
apply
to
all
minor
modifications
to
major
stationary
sources
in
Indian
country
and
those
new
major
stationary
sources
and
major
modifications
to
existing
major
sources
located
in
portions
of
Indian
country
that
are
not
in
attainment
of
the
National
Ambient
Air
Quality
Standards
(
NAAQS),
i.
e.,
nonattainment
areas.

New
major
sources.
The
rule
will
only
result
in
an
administrative
change
for
new
major
sources
in
Indian
country;
this
is
because,
although
the
regulatory
mechanism
to
issue
permits
is
not
yet
available
either
in
the
form
of
a
federal
nonattainment
NSR
rule
or
a
TIP,
the
EPA
would
be
required
to
implement
the
program
in
Indian
country,
and
would
otherwise
have
to
do
source­
specific
Federal
implementation
plans.
As
a
result,
there
would
be
no
new
or
additional
burden
on
industry.
The
EPA
estimates
that
at
most
one
new
major
source
will
locate
in
a
nonattainment
area
in
Indian
country
during
the
analysis
period
(
i.
e.,
2004
to
2010).
None
are
expected
during
the
3
years
following
promulgation.

Major
modifications
in
nonattainment
areas.
The
EPA
data
show
that
there
are
8
existing
major
sources
located
in
nonattainment
areas
in
Indian
country.
The
NSR
rules
will
have
little
impact
on
these
existing
major
stationary
sources
in
Indian
country
because
they
will
only
affect
such
sources
if
they
propose
a
major
or
minor
modification.
EPA
projects
at
most
one
major
modification
in
a
nonattainment
area
in
Indian
country
during
the
analysis
period
(
i.
e.,
2004
­
2010);
none
are
expected
during
the
3
years
following
promulgation.

Minor
modifications
to
major
sources.
There
are
currently
a
total
of
83
major
sources
located
throughout
Indian
country.
A
portion
of
these
sources
would
choose
to
make
minor
modifications
over
the
study
period;
it
is
assumed
that
each
major
source
does
a
process
or
operational
modification
every
10
years.
However,
it
is
anticipated
that,
of
these
major
source
process/
operational
modifications,
only
10
percent
will
result
in
8
greater
than
de
minimis
emissions
increases.
This
group
(
1
facility
per
year)
will
be
required
to
get
a
minor
source
NSR
permit.
As
previously
noted
above,
"...
industry
has
been
able
to
build
major
new
plants
or
make
physical
and
operational
changes
at
major
existing
sources
without
exceeding
the
major
source
and
major
modification
thresholds."
The
same
situation
holds
for
minor
modifications
to
major
sources.
Sources
avoid
the
major
and
minor
NSR
thresholds
for
three
reasons:
(
1)
installation
of
state­
of­
the­
art
control
technologies;
(
2)
replacement
or
better
control
of
older,
more
polluting
processes;
and
(
3)
engaging
in
effective
pollution
prevention
efforts.
All
of
these
actions
result
in
significant
reductions
in
air
emissions
beyond
the
baseline
case.
Under
this
scenario,
it
is
estimated
that
there
would
be
one
minor
modification
to
a
major
source
in
Indian
country
per
year
or
7
total
over
the
seven­
year
study
period.
During
the
first
3
years
following
promulgation,
it
is
estimated
that
there
will
be
3
minor
modifications
to
major
sources
in
Indian
country.
The
burden
costs
and
impacts
are
based
on
sources
incurring
costs
associated
with
the
respondent
activities
required
by
the
Review
of
New
Sources
and
Modifications
in
Indian
Country
rule.
The
burden
costs
and
impacts
are
identified
in
Attachment
1
and
characterized
in
section
6.

(
iii)
Synthetic
minor
sources.
The
minor
NSR
permitting
rule
will
also
allow
new
and
existing
stationary
sources
in
Indian
country
to
accept
federally
enforceable
limits
on
their
potential
to
emit
any
regulated
air
pollutant.
These
enforceable
permit
limits
will
enable
sources
to
avoid
regulation
as
new
major
stationary
sources,
and
instead
be
regulated
under
this
proposed
rule,
and
other
applicable
rules,
as
minor
sources
or
minor
modifications.
Sources
which
voluntarily
accept
enforceable
emission
limits
in
order
to
avoid
major
NSR
regulations
are
often
referred
to
as
"
synthetic
minor"
sources.
The
EPA
believes
that
facilities
could
choose
to
do
this
to
avoid
Title
V
permitting
or
avoid
being
classified
as
a
major
source
under
the
NSR
or
MACT
(
NESHAP)
programs;
thus,
only
the
existing
83
major
sources
would
be
candidates.
Because
this
action
is
completely
optional,
EPA
believes
a
facility
would
only
choose
to
do
it
if
it
resulted
in
cost
savings.
Thus,
EPA
estimates
no
costs
for
this
type
of
affected
source
but
instead
expects
them
to
incur
a
cost
savings.
None
are
expected
during
the
3
years
following
promulgation;
therefore,
no
burden
is
projected.

(
b)
Estimating
Respondent
Costs.
(
i)
Estimating
labor
costs.
Labor
rates
and
associated
costs
are
based
on
Bureau
of
Labor
Statistics
(
BLS)
data.
Technical,
management,
and
clerical
average
hourly
rates
for
civilian
workers
were
taken
from
the
March
2002
Employment
Cost
Trends
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t02.
htm).
Wages
for
civilian
workers
(
white­
collar
occupations)
are
used
as
the
basis
for
the
labor
rates,
with
a
total
compensation
of
$
28.49/
hour
for
technical,
$
42.20/
hour
for
managerial
and
legal,
and
$
18.41/
hour
for
clerical.
These
rates
represent
salaries
plus
fringe
benefits
and
do
not
include
the
cost
of
overhead.
An
overhead
rate
of
110
percent
is
used
to
account
for
these
costs.
The
fullyburdened
wage
rates
used
to
represent
respondent
labor
costs
are:
technical
at
$
59,
management
and
legal
at
$
89,
and
clerical
at
$
39.
These
labor
rates
are
used
in
Attachment
1
to
estimate
total
labor
costs.
9
(
ii)
Estimating
Capital/
Startup
Operating
and
Maintenance
(
O&
M)
Costs.
Several
of
the
monitoring,
testing,
recordkeeping,
and
reporting
(
MRR)
activities
associated
with
the
minor
source
NSR
rule
occur
one­
time
only.
These
costs
for
affected
minor
sources
are
considered
as
capital
cost
in
this
analysis.
The
estimate
of
facility
capital
costs
associated
with
the
NSR
permit
program
is
shown
in
Attachment
1;
activities
in
the
attachment
are
noted
as
one­
time
or
capital
costs.
The
average
total
capital
cost
per
facility
is
estimated
over
the
analysis
period
as
$
13,088
per
affected
source.
Of
this
amount,
$
1,396
are
non­
labor
related
capital
costs
for
such
one­
time
activities
as
air
quality
modeling
analysis
and
emission
source
test
averaged
over
the
frequency
of
occurrence.
Total
capital
costs
are
presented
in
Table
1.
The
O&
M
costs
for
affected
minor
sources
are
considered
zero
for
this
rule.
For
example,
no
continuous
emission
monitoring
is
required.
Existing
process
parameter
records
will
be
used
to
determine
continuous
compliance;
therefore
no
additional
costs
are
incurred
for
continuous
monitoring.

There
are
no
capital
and
O&
M
costs
associated
with
the
NSR
rule
for
MRR
activities
for
new
major
sources
in
nonattainment
areas.
During
the
3
years
following
promulgation,
no
new
major
sources
in
nonattainment
areas
in
Indian
country
are
expected.
In
addition,
there
are
no
MRR
costs
estimated
for
major
modifications
to
existing
major
sources
in
nonattainment
areas,
because
none
are
expected.
The
minor
modifications
to
existing
major
sources
in
attainment
and
nonattainment
areas,
which
are
impacted
by
the
NSR
rule,
would
incur
the
same
MRR
cost
associated
with
the
NSR
permit
program
as
shown
in
Attachment
1.
The
average
capital
cost
per
facility
is
estimated
over
the
analysis
period
as
$
13,088
per
affected
source.

(
iii)
Estimating
annual
costs.
The
annualized
cost
of
capital
for
the
capital
costs
and
one­
time
activities
(
i.
e.,
$
13,088)
shown
in
Attachment
1
is
$
1,863
per
year.
Of
this
amount,
$
198
are
attributable
to
the
annualized
non­
labor
capital
costs.
This
is
based
on
a
payment
period
of
10
years
and
an
interest
rate
of
7
percent.
The
annual
and
reoccurring
costs
as
shown
in
Attachment
1
amount
to
a
burden
cost
of
$
5,735
per
year;
there
are
no
direct
O&
M
costs
associated
with
the
rule.
The
total
annual
burden
cost
is
estimated
at
$
7,598
per
year
per
affected
source,
i.
e.,
$
1,863
plus
$
5,735.

(
c)
Estimating
Agency
Burden
and
Cost.
The
only
costs
that
the
Federal
government
will
incur
as
a
result
of
this
action
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Attachment
2.
This
action
imposes
no
direct
burden
on
State,
local,
or
Tribal
agencies.
However,
should
a
Tribal
agency
choose
to
accept
delegated
authority
for
the
minor
NSR
rule,
the
only
costs
that
the
Tribal
agency
or
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Attachment
2.
Labor
rates
and
associated
costs
for
the
agency
are
assumed
to
be
the
same
as
the
respondent's
hourly
rates
rather
than
the
US
Government
labor
rates
and
associated
costs,
such
as
those
based
on
labor
rates
from
the
U.
S.
Office
of
Personnel
Management
(
OPM).
These
rates
are
considered
more
appropriate,
assuming
Tribal
agencies
may
adopt
the
rules.
Therefore,
agency
labor
rates
are
estimated
as
follows:
technical
at
$
59,
management
and
legal
at
10
$
89,
and
clerical
at
$
39.
The
occurrence
of
agency­
related
activities
is
based
on
the
same
frequency
of
occurrence
as
used
for
respondent
activities.
The
average
total
agency
burden
per
affected
source,
provided
in
Attachment
2,
is
48
hours
per
affected
source
including
technical,
management,
legal,
and
clerical
hours.
The
average
total
annual
cost
to
the
agency
per
affected
source
is
calculated
by
determining
the
total
labor
cost
for
all
the
various
respondent
activities.
The
costs
for
those
activities
are
then
added
to
any
associated
costs
(
e.
g.,
total
travel
expenses
for
tests
attended)
to
get
the
average
agency
burden
per
facility
per
year.
The
average
total
annual
cost
to
the
agency
per
affected
source
given
in
Attachment
2,
including
the
cost
of
labor,
materials,
operation,
and
maintenance,
is
$
3,110
per
year.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs.
Stationary
sources
subject
to
this
rulemaking
will
be
required
to
file
a
NSR
construction
permit,
conduct
a
compliance
analysis,
and
provide
the
various
one­
time
notifications
required
by
the
rules.
Compliance
reports
also
must
be
submitted.
In
addition,
some
of
these
minor
sources
will
be
required
to
install
the
minor
source
MSCT
equipment;
install
required
monitoring
equipment;
conduct
initial
performance
tests;
conduct
air
impacts
modeling;
prepare
startup,
shutdown,
and
malfunction
plans,
and
operation
and
maintenance
plans;
and
provide
the
various
notifications
and
reports
on
a
routine
basis.
Costs
also
will
be
incurred
for
inspections
of
control
devices
and
continuous
parameter
monitoring
systems.
Details
on
the
number
and
percentage
of
respondents
affected
by
each
individual
burden
activity/
item
are
provided
in
assumptions
listed
below
in
section
7.
The
weighted
average
total
burden
per
affected
source,
provided
in
Attachment
1,
is
296
hours
per
affected
source
including
technical,
management,
legal,
and
clerical
hours.
The
weighted
average
total
annualized
cost
per
affected
source
given
in
Attachment
1,
including
the
cost
of
labor,
capital,
materials,
and
operation
and
maintenance,
is
$
7,598
per
year.

The
EPA
estimates
that
288
new
minor
sources
of
varying
types
will
be
constructed
in
Indian
country
during
the
analysis
period,
with
123
new
minor
sources
during
the
first
3
years
of
the
rule
(
41/
yr).
It
is
estimated
that
112
existing
minor
sources
will
require
permits
as
a
result
of
minor
modifications;
during
the
first
3
years,
there
will
be
48
(
16/
yr)
existing
minor
sources
requiring
permits
as
a
result
of
minor
modifications.
The
EPA
estimates
that
at
most
one
new
major
source
will
locate
in
a
nonattainment
area
in
Indian
country
during
the
analysis
period;
none
are
expected
during
the
3
years
following
promulgation.
During
the
first
3
years
following
promulgation,
it
is
estimated
that
there
will
be
3
(
1/
yr)
minor
modifications
to
major
sources
in
Indian
country,
with
a
total
of
8
minor
modifications
over
the
entire
study
period.
In
addition,
EPA
projects
at
most
one
major
modification
in
a
nonattainment
area
in
Indian
country
during
the
analysis
period;
none
are
expected
during
the
3
years
following
promulgation.
No
synthetic
minors
are
expected
to
be
processed
under
the
rule
during
the
three
years
following
promulgation.
The
nationwide
total
annual
recordkeeping
and
reporting
burden
hours
and
costs
shown
in
Tables
2
and
3.
11
(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.
(
i)
Respondent
tally.
The
bottom
line
respondent
burden
capital
costs,
presented
in
Table
1,
are
calculated
by
taking
the
capital
cost
for
the
one­
time
monitoring,
compliance
testing,
recordkeeping,
and
reporting
costs
associated
with
the
minor
source
NSR
permit
program
for
each
affected
source
type
and
then
multiplying
that
value
by
the
number
of
affected
sources
of
that
type
that
are
expected
to
occur
in
Indian
country
each
year
for
the
first
3
years
following
promulgation
of
the
rule.
The
totals
for
each
source
type
are
then
added
to
get
the
nationwide
total
capital
costs
shown
in
Table
1.
Total
capital
costs
are
$
759,104
per
year
for
a
3
year
total
of
$
2,277,312.
These
values
include
the
total
non­
labor
capital
costs
of
$
80,968
per
year
($
242,904
over
the
3
year
period).

The
nationwide
total
annual
compliance
costs
are
the
annualized
costs
of
monitoring,
testing,
recordkeeping,
and
reporting
associated
with
the
NSR
rule
multiplied
by
the
number
of
affected
source
types
that
are
expected
to
occur
in
Indian
country
each
year
for
the
first
3
years
following
promulgation
of
the
rule.
The
totals
for
each
source
type
are
then
added
to
get
the
nationwide
total
annual
recordkeeping
and
reporting
burden
costs
shown
in
Table
2.
The
total
annual
costs
are
$
440,684
per
year
for
a
3
year
total
of
$
1,322,052.
These
values
include
the
total
annualized
non­
labor
capital
costs
of
$
11,484
per
year
($
34,452
over
the
3
year
period)
which
is
the
product
of
the
annualized
nonlabor
costs
of
$
198
per
source
and
the
total
number
of
affected
sources
per
year
(
i.
e.,
58).

(
ii)
The
Agency
tally.
The
bottom
line
Agency
total
annual
burden
costs
are
calculated
by
taking
the
average
cost
to
the
Agency
per
facility
($
3,110)
and
multiplying
by
the
number
of
affected
sources
in
Indian
country
during
the
first
3
years
following
promulgation.
The
nationwide
total
annual
cost
to
the
EPA
or
Tribal
agencies
as
shown
in
Table
3
is
$
180,380
per
year
for
a
3
year
total
of
$
541,140.

(
iii)
Variations
in
the
Annual
bottom
Line.
Litigation.
Although
not
typically
included
directly
in
the
agency
burden
estimates,
it
is
possible
that
EPA
or
Tribal
agencies
will
be
involved
in
periodic
litigation
related
to
the
minor
source
NSR
permit
program.
To
characterize
these
costs,
it
is
assumed
that
a
Tribal
agency
will
be
involved
with
a
facility
litigation
on
average
of
once
every
3
years.
The
estimated
annual
cost
of
these
activities,
as
shown
in
Attachment
2,
is
73
hours
and
$
4,885
per
year
per
Tribal
agency
litigation.

(
f)
Reasons
for
Change
in
Burden.
This
not
a
renewal
or
modification
of
an
existing
ICR.

(
g)
Burden
Statement.
The
annual
pubic
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
296
hours
per
respondent.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Tribal
or
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
12
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
requirement;
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
0075,
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0075)
in
any
correspondence.

7.
Assumptions
Made
in
Estimating
the
Burden
and
Cost
to
the
Facilities
(
Respondents)
and
EPA
and
Tribal
Agencies.

The
burden
and
cost
estimates
are
based
on
the
following
assumptions
for
those
facilities
requiring
NSR
permits
under
the
rule:

(
a)
All
affected
minor
and
major
sources
will
incur
preparation
and
planning
costs.

(
b)
One
in
fifty
facilities
will
be
required
to
conduct
ambient
air
modeling.
Associated
costs
for
an
ambient
modeling
study
are
estimated
at
$
10,000
per
source.

(
c)
One
in
twenty
facilities
will
be
required
to
hold
a
public
hearing.
Associated
costs
for
the
public
hearing
are
estimated
at
$
100
for
the
Agency
and
a
$
25
material
cost
to
the
source.

(
d)
One
in
five
facilities
will
make
revisions
to
their
permits
following
submittal.
13
(
e)
One
in
twenty
facilities
will
be
required
to
acquire
and
install
a
process
parameter
monitoring
system.
No
continuous
emission
monitoring
devices
are
required
or
anticipated;
it
is
expected
that
existing
process
parameter
monitoring
data
will
be
used
to
demonstrate
continuous
compliance.

(
f)
One
in
fifty
facilities
will
be
required
to
conduct
a
control
device
performance
test
and
develop
a
site
test
plan.
Associated
costs
for
conducting
a
performance
test
are
estimated
at
$
50,000
per
source
test.
Travel
cost
to
the
Agency
are
included
at
$
100
per
test.

(
g)
One
in
twenty
facilities
will
request
special
compliance
requirements.

(
h)
One
in
ten
facilities
will
request
a
compliance
extension.

(
i)
All
facilities
must
submit
an
initial
compliance
report.

(
j)
One
in
ten
facilities
will
report
at
least
one
deviation
from
the
established
monitoring
values
during
the
year.

(
k)
One
in
fifty
facilities
will
be
required
to
develop
a
startup/
shutdown/
malfunction
plan
and
only
half
of
these
will
experience
an
event
during
the
year.

(
l)
One
in
twenty
facilities
will
be
required
to
develop
a
control
device
maintenance
plan.

(
m)
One
in
ten
facilities
will
include
minor
sources
that
are
exempt
from
the
control
requirements.

(
n)
All
facilities
will
be
required
to
keep
records
of
some
type
and
to
periodically
enter
data
into
the
files.

(
o)
One
in
ten
facilities
will
train
personnel
and
conduct
audits
of
their
source
during
the
year.

(
p)
One
in
ten
facilities
are
inspected
by
the
agency
annually
and
10
percent
of
the
inspected
facilities
are
found
in
non­
compliance
with
one
or
more
provisions
of
the
rule.
Agency
travel
cost
are
included
in
the
associated
costs
at
$
100
per
inspection.

(
q)
Each
Tribal
agency
may
be
involved
in
litigation
of
a
facility
on
average
of
one
per
3
years.

(
r)
Associated
material
costs
of
$
25
are
included
for
each
report
and
plan
required
for
the
source.
14
PART
B
OF
THE
SUPPORTING
STATEMENT
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1.
Estimated
Total
Capital
Cost
Burden
to
Industry
to
Implement
Reporting
and
Recordkeeping
Requirements
During
Years
1,
2,
and
3.

Affected
Source
Type
Number
of
Affected
Sources
per
Year
Average
Total
Capital
Cost
per
Source
Average
Non­
Labor
Capital
Cost
per
Source
Total
Non­
Labor
Capital
Costs
Total
Capital
Costs
New
Minor
Sources
41
$
13,088
$
1,396
$
57,236
$
536,608
Modifications
to
Minor
Sources
16
$
13,088
$
1,396
$
22,336
$
209,408
New
Major
Sources
in
Nonattainment
Areas
0
$
13,088
$
1,396
$
0
$
0
Major
Modifications
to
Major
Sources
in
Nonattainment
Areas
0
$
13,088
$
1,396
$
0
$
0
Minor
Modifications
to
Major
Sources
1
$
13,088
$
1,396
$
1,396
$
13,088
Synthetic
Minor
Sources
0
$
13,088
$
1,396
$
0
$
0
Totals
58
$
80,968
$
759,104
Notes:
a)
The
capital
costs
and
one­
time
activities
(
i.
e.,
the
sum
of
all
one­
time
costs
shown
in
Attachment
1)
is
$
13,088.
This
value
includes
the
non­
labor
capital
costs
($
1,396),
shown
above.
16
17
Table
2.
Estimated
Total
Annual
Cost
Burden
to
Industry
to
Implement
Reporting
and
Recordkeeping
Requirements
During
Years
1,

2,
and
3.
Affected
Source
Type
Number
of
Affected
Sources
per
Year
Average
Total
Hours
per
Source
per
Year
Total
Hours
per
Year
Annualized
Average
Non­

Labor
Cost
per
Source
Average
Total
Annual
Cost
per
Source
Total
Annualized
Non­
Labor
Capital
Costs
Total
Annual
Costs
New
Minor
Sources
41
296
12,136
$
198
$
7,598
$
8,118
$
311,518
Modifications
to
Minor
Sources
16
296
4,736
$
198
$
7,598
$
3,168
$
121,568
New
Major
Sources
in
Nonattainment
Areas
0
296
0
$
198
$
7,598
$
0
0
Major
Modifications
to
Major
Sources
in
Nonattainment
Areas
0
296
0
$
198
$
7,598
$
0
0
Minor
Modifications
to
Major
Sources
1
296
296
$
198
$
7,598
$
198
$
7,598
Synthetic
Minor
Sources
0
296
0
$
198
$
7,598
$
0
0
Totals
58
17,168
$
11,484
$
440,684
Notes:

a)
The
annualized
cost
of
capital
for
the
capital
costs
and
one­
time
activities
(
i.
e.,
$
13,088,
the
sum
of
all
one­
time
costs
shown
in
Attachment
1)
is
$
1,863
per
year.
The
annualized
non­
labor
portion
of
this
amount
is
$
198.
This
is
based
on
a
payment
period
of
10
years
and
an
interest
rate
of
7
percent.
The
annual
and
reoccurring
costs
as
shown
in
Attachment
1
amount
to
a
burden
cost
of
$
5,735;
the
total
annual
burden
cost
is
estimated
at
$
7,598
per
year
per
affected
source.
19
Table
3.
Estimated
Recurrent
Burden
and
Cost
to
the
Agency
to
Implement
Reporting
and
Recordkeeping
Requirements
During
Years
1,
2,
and
3.

Affected
Source
Type
Number
of
Affected
Sources
per
Year
Average
Total
Hours
per
Source
Total
Hours
per
Year
Average
Cost
per
Source
Total
Annual
Costs
New
Minor
Sources
41
48
1,968
$
3,110
$
127,510
Modifications
to
Minor
Sources
16
48
768
$
3,110
$
49,760
New
Major
Sources
in
Nonattainment
Areas
0
48
0
$
3,110
$
0
Major
Modifications
to
Major
Sources
in
Nonattainment
Areas
0
48
0
$
3,110
$
0
Minor
Modifications
to
Major
Sources
1
48
48
$
3,110
$
3,110
Synthetic
Minor
Sources
0
48
0
$
3,110
$
0
Totals
58
2,784
$
180,380
Notes:
a)
The
average
total
annualized
cost
to
the
agency
per
affected
source
given
in
Attachment
2,
including
the
cost
of
labor,
capital,
operation,
and
maintenance,
is
$
3,110
per
year.
Attachment
1.
(
continued)

20
21
Attachment
1.
Tribal
Minor
Source
NSR
Respondent
(
Facility)
Burden
and
Cost
Facility
NSR
Program
Activity
(
A)

Labor
Hours
per
Activity
per
Labor
Category
(
B)
Activities
per
Respondent
per
Year
(
C)
Total
Number
of
Respondents
(
D)
Total
Hours
(
E)

Labor
Costs
per
Labor
Category
(
A
x
B
x
C
x
Rate)
(
F)
Total
Labor
Costs
(
G)
Associated
Non­
Labor
Costs
(
H)
Total
Costs
(
F+
G)

Legal
Managerial
Technical
Clerical
Legal
$
89
Managerial
$
89
Technical
$
59
Clerical
$
39
1.
Preparation
and
Planning
a.
Determination
of
compliance
requirements
(#)
0
2
8
0
1
1
10
$
0
$
177
$
471
$
0
$
648
$
0
$
648
b.
Obtain
guidance
on
data
needs
(#)
0
0
2
0
1
1
2
$
0
$
0
$
118
$
0
$
118
$
0
$
118
c.
Preparation
of
MSCT
engineering
analysis
(#)
0
4
16
2
1
1
22
$
0
$
354
$
941
$
77
$
1,373
$
0
$
1,373
2.
Data
Collection
and
Analysis
(
Surveys
&

Studies)

a.
Conduct
ambient
air
modeling
(#)
0
2
40
4
1
0.02
1
$
0
$
4
$
47
$
3
$
54
$
200
$
254
3.
Permit
Application
a.
Preparation
and
submittal
of
permit
application
(#)
2
4
40
16
1
1
62
$
177
$
354
$
2,353
$
619
$
3,503
$
25.00
$
3,528
b.
Public
hearing
(#)
4
4
16
8
1
0.05
2
$
18
$
18
$
47
$
15
$
98
$
1.25
$
99
c.
Revisions
to
permit
(#)
1
1
4
2
1
0.2
2
$
18
$
18
$
47
$
15
$
98
$
5.00
$
103
4.
Acquisition,
Installation,
and
Use
of
Technology
and
Systems
a.
Control
device
operating
parameter
(
emission)
monitoring
system
(#)
0
4
20
2
1
0.05
1
$
0
$
18
$
59
$
4
$
80
$
0
$
80
5.
ReportingRrequirements
a.
Read
instructions
(#)
0
2
4
0
1
1
6
$
0
$
177
$
235
$
0
$
413
$
0
$
413
b.
Required
activities
(#)

c.
Create
information
i.
Conduct
control
device
performance
test
(#)
0
8
40
8
1
0.02
1
$
0
$
14
$
47
$
6
$
67
$
1,000
$
1,067
d.
Gather
existing
information
(#)
0
0
8
2
1
1
10
$
0
$
0
$
471
$
77
$
548
$
0
$
548
e.
Write
reports
i.
Initial
notification
of
intent
to
constr/
modify
(#)
1
2
4
2
1
1
9
$
89
$
177
$
235
$
77
$
579
$
25.00
$
604
ii.
Notification
of
anticipated
startup
(#)
0
1
2
1
1
1
4
$
0
$
89
$
118
$
39
$
245
$
25.00
$
270
iii.
Notification
of
actual
startup
(#)
0
0
1
1
1
1
2
$
0
$
0
$
59
$
39
$
97
$
25.00
$
122
iv.
Notification
of
special
compliance
requirements
2
4
16
4
1
0.05
1
$
9
$
18
$
47
$
8
$
81
$
1.25
$
83
v.
Compliance
extension
request
2
2
8
2
1
0.1
1
$
18
$
18
$
47
$
8
$
90
$
2.50
$
93
Attachment
1.
(
continued)

22
Facility
NSR
Program
Activity
(
A)

Labor
Hours
per
Activity
per
Labor
Category
(
B)
Activities
per
Respondent
per
Year
(
C)
Total
Number
of
Respondents
(
D)
Total
Hours
(
E)

Labor
Costs
per
Labor
Category
(
A
x
B
x
C
x
Rate)
(
F)
Total
Labor
Costs
(
G)
Associated
Non­
Labor
Costs
(
H)
Total
Costs
(
F+
G)

Legal
Managerial
Technical
Clerical
Legal
$
89
Managerial
$
89
Technical
$
59
Clerical
$
39
vi.
Performance
test
notification
(#)
0
0
2
1
1
0.02
0
$
0
$
0
$
2
$
1
$
3
$
0.50
$
4
vii.
Site­
specific
test
plan
(#)
0
1
16
8
1
0.02
1
$
0
$
2
$
19
$
6
$
27
$
0.50
$
27
viii.
Initial
compliance
status
determination
(#)
1
4
8
4
1
1
17
$
89
$
354
$
471
$
155
$
1,068
$
25.00
$
1,093
ix.
Performance
test
reports
(#)
0
4
16
4
1
0.02
0
$
0
$
7
$
19
$
3
$
29
$
0.50
$
30
x.
Compliance
report
(#)
1
2
8
4
1
1
15
$
89
$
177
$
471
$
155
$
891
$
25.00
$
916
xi.
Deviation
report
(##)
1
2
4
2
1
0.1
1
$
9
$
18
$
24
$
8
$
58
$
2.50
$
60
xii.
Startup/
shutdown/
malfunction
reports
(##)
0
1
8
1
1
0.01
0
$
0
$
1
$
5
$
0
$
6
$
0.25
$
6
6.
Recordkeeping
Requirements
a.
Read
instructions
(##)
1
2
8
0
1
1
11
$
89
$
177
$
471
$
0
$
737
$
0
$
737
b.
Plan
activities
(##)
0
2
8
2
1
1
12
$
0
$
177
$
471
$
77
$
725
$
0
$
725
c.
Implement
activities
i.
Prepare
startup/
shutdown/

malfunction
plan
(#)
0
2
16
8
1
0.02
1
$
0
$
4
$
19
$
6
$
29
0.5
$
29
ii.
Prepare
maintenance
plan
(#)
0
2
16
8
1
0.05
1
$
0
$
9
$
47
$
15
$
71
1.25
$
73
iii.
Prepare
documentation
for
exempted
sources
(#)
4
2
20
8
1
0.1
3
$
35
$
18
$
118
$
31
$
202
2.5
$
204
iv.
Monitor
control
device
parameters
(##)
0
0
1
0
52
0.1
5
$
0
$
0
$
306
$
0
$
306
$
0
$
306
v.
Inspect
control
device
(##)
0
0
1
0
12
1
12
$
0
$
0
$
706
$
0
$
706
$
0
$
706
d.
Develop
record
system
(#)
0
2
4
16
1
1
22
$
0
$
177
$
235
$
619
$
1,031
25
$
1,056
e.
Time
to
enter
information
(##)
0
0
1
0
52
1
52
$
0
$
0
$
3,059
$
0
$
3,059
$
0
$
3,059
f.
Time
to
train
personnel
(#)
0
0
40
4
1
0.1
4
$
0
$
0
$
235
$
15
$
251
2.5
$
253
g.
Time
to
perform
audits
(##)
0
2
20
0
1
0.1
2
$
0
$
18
$
118
$
0
$
135
$
0
$
135
TOTAL
296
$
1,396
Notes:
#
=
One­
time
costs
that
are
incurred
and
treated
as
capital
costs.

##
=
Annual
or
reoccurring
cost
included
as
an
annual
cost.

Totals
may
equal
sum
of
columns
precisely
due
to
rounding.
For
example,
numbers
in
Column
(
D)
add
to
295
due
to
rounding,
but
actual
value
is
296.
For
Paperwork
Reduction
Act
Submission,
we
used
the
actual
value,
296.
(
Item
6
Recordkeeping
Requirements
adds
to
125
due
to
rounding,
but
is
actually
126).

Based
on
the
above
costs,
the
average
capital
cost
per
facility
for
the
one­
time
activities
is
$
13,088
per
source
(
i.
e.,
the
sum
of
those
items
identified
as
one­
time
costs
(#));
annualized
this
cost
is
$
1,863
per
year
per
source.
The
average
non­
labor
capital
cost
is
$
1,396;
annualized
this
cost
is
$
198
per
year
per
source.
The
total
of
the
various
annual
and
reoccurring
costs
(##)
plus
the
annualized
capital
cost
is
an
average
of
$
7,598
(
i.
e.,
$
1,863
+
$
5,735)
per
year
per
source.
23
Attachment
2.
Tribal
Minor
Source
NSR
Agency
Burden
and
Cost
(
A)

Labor
Hours
per
Activity
per
Labor
Category
(
E)

Labor
Costs
per
Labor
Category
(
A
x
B
x
C
x
Rate)

Agency
NSR
Program
Activity
Lega
l
Manageria
l
Technica
l
Clerical
(
B)
Activities
per
Respondent
per
Year
(
C)
Total
Number
of
Respondents
(
D)
Total
Hours
Legal
($
89/
hr)
Manageria
l
($
89/
hr)
Technica
l
($
60/
hr)
Clerical
($
39/
hr)
(
F)
Total
Labor
Costs
(
H)
Associat
ed
Annual
Costs
(
I)
Total
Costs
per
year
1.
Permit
Review
a.
Initial
permit
review
0
1
8
0
1
1
9
$
0
$
89
$
479
$
0
$
567
$
0
$
567
b.
Public
Hearing
0
1
8
8
1
0.05
1
$
0
$
4
$
24
$
15
$
44
$
5
$
49
c.
Permit
Revisions
1
1
4
0
0.2
0
$
0
$
0
$
0
$
0
$
0
$
0
$
0
2.
Report
review
a.
Initial
notification
of
intent
to
constr/
modify
0
1
4
0
1
1
5
$
0
$
89
$
239
$
0
$
328
$
0
$
328
b.
Notification
of
anticipated
startup
0
1
2
0
1
1
3
$
0
$
89
$
120
$
0
$
208
$
0
$
208
c.
Notification
of
actual
startup
0
1
2
0
1
1
3
$
0
$
89
$
120
$
0
$
208
$
0
$
208
d.
Notification
of
special
compliance
requirements
0
1
4
0
1
0.05
0
$
0
$
4
$
12
$
0
$
16
$
0
$
16
e.
Compliance
extension
request
1
1
4
0
1
0.1
1
$
9
$
9
$
24
$
0
$
42
$
0
$
42
f.
Performance
test
notification
0
1
2
0
1
0.02
0
$
0
$
2
$
2
$
0
$
4
$
0
$
4
g.
Site­
specific
test
plan
0
1
8
0
1
0.02
0
$
0
$
2
$
10
$
0
$
11
$
0
$
11
h.
Initial
compliance
determination
0
1
8
0
1
1
9
$
0
$
89
$
479
$
0
$
567
$
0
$
567
i.
Performance
test
reports
0
2
16
0
1
0.02
0
$
0
$
4
$
19
$
0
$
23
$
0
$
23
j.
Compliance
report
0
2
8
0
1
1
10
$
0
$
177
$
479
$
0
$
656
$
0
$
656
j.
Deviation
report
0
2
4
0
1
0.1
1
$
0
$
18
$
24
$
0
$
42
$
0
$
42
k.
Startup/
shutdown/
malfunction
reports
0
1
4
0
1
0.1
1
$
0
$
9
$
24
$
0
$
33
$
0
$
33
3.
Site
compliance
inspections
(
a,
b)

a.
Pre­
inspection
review
of
facility
information
0
1
8
1
1
0.10
1
$
0
$
9
$
48
$
4
$
61
$
0
$
61
b.
Travel
to
and
from
facility
(
b)
0
0
8
0
1
0.10
1
$
0
$
0
$
48
$
0
$
48
$
10
$
58
c.
Inspection
of
air
control
equipment
used
to
comply
with
rule
requirements
0
0
4
0
1
0.10
0
$
0
$
0
$
24
$
0
$
24
$
0
$
24
d.
Review
site
records
0
0
4
0
1
0.10
0
$
0
$
0
$
24
$
0
$
24
$
0
$
24
e.
Prepare
inspection
report
0
4
16
4
1
0.10
2
$
0
$
35
$
96
$
15
$
147
$
3
$
149
4.
Enforcement
actions
(
c,
d)

a.
Inform
facility
of
noncomplinace
4
4
20
8
1
0.01
0
$
4
$
4
$
12
$
3
$
22
$
0
$
22
b.
Follow­
up
site
inspection
0
4
20
4
1
0.01
0
$
0
$
4
$
12
$
2
$
17
$
1
$
18
TOTAL
ANNUAL
COST
PER
SOURCE
48
$
3,092
$
19
$
3,110
5.
Litigation
Cost
per
Tribal
Agency
40
40
100
40
1
0.33
73
$
1,180
$
1,180
$
1,992
$
515
$
4,868
$
17
$
4,885
TOTAL
121
6.
EPA
Overview
of
Tribal
Agency
8
8
40
8
1
1
64
$
709
$
709
$
2,393
$
309
$
4,120
$
100
$
4,220
Totals
may
equal
sum
of
columns
precisely
due
to
rounding.
For
example,
numbers
in
Column
(
D)
add
to
47
due
to
rounding,
but
actual
value
is
48.
For
Paperwork
Reduction
Act
Submission,
we
used
the
actual
value,
48.
