EPA
United
States
Environmental
Protection
Agency
Office
of
Air
and
Radiation
Office
of
Air
Quality
Planning
and
Standards
Innovative
Strategies
and
Economics
Group
Operating
Permits
Group
January,
2000
INFORMATION
COLLECTION
REQUEST
FOR
PART
70
OPERATING
PERMIT
REGULATIONS
prepared
by
Daniel
Charles
Mussatti,
Senior
Economist
Innovative
Strategies
and
Economics
Group
Air
Quality
Strategies
and
Standards
Division
and
Roger
Powell,
Environmental
Scientist
Operating
Permits
Group
Information
Transfer
and
Program
Integration
Division
EPA
#
1587.05
The
approved
burden
level
in
the
previous
ICR
was
3.5
million
hours
per
year
for
sources,
1.7
million
burden
hours
per
year
for
permitting
authorities
(
PAs),
and
64
thousand
hours
for
the
Federal
government;
for
a
total
of
5.2
million
hours
each
year.
The
current
ICR
predicts
3.2
million,

1.6
million,
and
44
thousand
hours,
respectively,
for
each
respondent
group,
for
a
total
of
4.8
million
hours.
Overall,
this
is
an
expected
reduction
in
burden
of
400
thousand
hours.
For
sources,
this
is
a
decrease
in
burden
of
284
thousand
hours
primarily
due
to
having
completed
their
permit
applications.
The
concomitant
burden
increases
in
monitoring
recordkeeping,
and
reporting
somewhat
offset
this
decrease.
The
Agency
predicts
States
and
other
permitting
authorities
will
benefit
from
a
burden
reduction
of
about
97
thousand
hours
per
year.
The
Federal
government
will
receive
an
expected
19
thousand
hour
reduction
in
burden.

TABLE
E­
1
BURDEN
CHANGE
FROM
2­
28­
97
ICR
TO
CURRENT
ICR
Average
Annual
Burden
in
2­
28­
1997
ICR
Average
Annual
Burden
in
ICR
Renewal
Difference
Sources
3,478,333
3,194,557
(
283,776)

PAs
1,682,000
1,585,063
(
96,937)

Federal
63,667
44,297
(
19,370)

TOTAL
5,224,000
4,823,917
(
400,083)

Table
E­
1
displays
the
expected
annual
burden
and
the
expected
change
in
annual
burden
for
sources,
permitting
authorities,
and
the
Federal
government
for
implementation
of
the
title
V
Operating
Permits
Program
between
March
2000
and
March
2003.
Of
the
4.8
million
hours
the
Agency
anticipates
it
will
take
to
perform
all
the
functions
required
each
year,

about
two­
thirds
of
the
burden
applies
to
sources.
However,
the
magnitude
of
the
total
expected
burden
can
be
misleading,
due
to
the
number
of
permitted
sources.
For
the
20,924
sources
included
in
this
analysis,
the
average
expected
burden
is
relatively
small
­
about
one
month
of
a
full
time
employee's
time.
Executive
Summary
CONCLUSION:

This
ICR
represents
a
DECREASE
IN
BURDEN,
relative
to
the
Operating
Permits
Program's
prior
ICR.
1
United
States
Environmental
Protection
Agency,
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations,
February
1997,
p.
A­
4.
Permitting
authorities
incur
about
a
third
of
the
burden
of
part
70
management,
with
the
total
burden
spread
between
a
significantly
smaller
number
of
entities
than
that
for
sources.
On
average,
the
Agency
estimates
the
burden
associated
with
the
title
V
Operating
Permits
Program
will
be
about
14,000
hours
per
year
per
PA.
On
average,
each
PA
can
expect
to
expend
about
76
hours
of
effort
per
source
each
year,
at
a
cost
of
about
$
2,800
per
permit.
However,
PA
burden
cannot
be
considered
an
Unfunded
Mandate
because
the
net
cost
to
permitting
authorities
for
their
management
of
an
operating
permits
program
must,
by
law,
be
passed
on
to
the
PA's
sources
through
the
permit
fee.
The
cost
of
permits
to
sources
must
be
of
sufficient
magnitude
to
fully
offset
all
permit
management
costs.

Hence,
the
true
annual
cost
to
permitting
authorities
under
title
V
is
zero,

and
the
true
annual
cost
to
sources
is
$
160.9
million,
approximately
$
7,700
per
source
per
year.

The
burden
and
cost
savings
represented
in
this
ICR
for
Federal
oversight
derives
from
a
reduction
in
the
overall
level
of
effort
expected
in
most
burden
categories.
For
instance,
the
1997
ICR
anticipated
the
EPA
would
review
all
permits.
1
This
ICR,
however,
estimates
the
Agency
will
probably
review
no
more
than
a
quarter
of
all
proposed
permits
it
receives
during
the
ICR
period.

In
accordance
with
the
analytical
requirements
established
under
the
Regulatory
Flexibility
Act
(
RFA)
and
the
Small
Business
regulatory
enforcement
Fairness
Act
(
SBREFA),
the
Agency
has
determined
that,

because
this
ICR
represents
regulatory
relief
relative
to
its
predecessor,

there
are
no
adverse
effects
to
be
identified
vis
a
vis
small
entities
and
small
businesses.
Because
this
ICR
represents
a
decrease
in
burden,
the
Agency
determined
there
is
NO
SIGNIFICANT
IMPACT
ON
A
SUBSTANTIAL
NUMBER
OF
SMALL
ENTITIES.
Table
of
Contents
Executive
Summary
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
E­
1
1.
Identification
of
the
Information
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
1
2.
Need
and
Use
of
the
Collection
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2
3.
Non­
Duplication,
Consultation,
and
Other
Collection
Criteria
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
4.
The
Respondents
and
the
Information
Requested
.
.
.
.
.
.
.
.
6
5.
The
Information
Collected
­
Collection
methodology,
and
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
9
6.
Estimating
the
Burden
and
Cost
of
the
Collection
.
.
.
.
.
.
.
11
Attachment
1
Title
V
of
the
Clean
Air
Act,
The
Statutory
Requirements
for
Respondent
Information
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
29
Attachment
2
October
18,
1999
Federal
Register
Notice
.
.
.
.
.
.
.
.
.
.
.
.
.
.
35
Attachment
3
Assumptions
for
Part
70
ICR
Renewal
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
38
Attachment
4
Worksheets
for
Burden
Estimates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
45
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
1
11
January
2000
This
analysis
is
titled:
"
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations".
It
fulfills
the
Agency's
requirements
under
the
Paperwork
Reduction
Act
(
PRA)
to
determine,
report,
and
periodically
update
the
regulatory
burden
associated
with
the
Operating
Permits
Program,
codified
in
section
40
of
the
Code
of
Federal
Regulations
(
40
CFR)
part
70.
This
report
has
been
assigned
EPA
tracking
number
ICR
#

1587.05.
The
OMB
tracking
number
for
this
ICR
is
2060­
0243.

Title
V
of
the
Clean
Air
Act
requires
States
to
develop
and
implement
a
program
for
issuing
operating
permits
to
all
sources
that
fall
under
any
Act
definition
of
major
and
certain
other
non­
major
sources
that
are
subject
to
Federal
air
quality
regulations.
The
Act
further
requires
EPA
to
develop
regulations
that
establish
the
minimum
requirements
for
those
State
operating
permits
programs
and
to
oversee
their
implementation.
The
EPA
regulations
setting
forth
requirements
for
the
operating
permits
programs
were
codified
at
40
CFR
part
70
on
July
21,
1992.

The
activities
that
will
occur
during
the
period
of
this
ICR
include:

°
permitting
authorities
issuing
the
remaining
permits;

°
sources
submitting
semi­
annual
monitoring
and
annual
compliance
certification
reports;

°
permitting
authorities
reviewing
those
reports;

°
sources
submitting
applications
for
permit
revisions;

°
permitting
authorities
processing
permit
revisions;

°
sources
applying
for
permit
renewal;

°
permitting
authorities
renewing
permits;

°
newly
subject
sources
submitting
permit
applications;
and
°
permitting
authorities
issuing
new
permits.

All
of
these
data
are
made
available
for
public
review
and
comment.
The
activities
to
carry
out
these
tasks
are
considered
mandatory
and
necessary
for
implementation
of
title
V
and
the
proper
operation
of
the
operating
1
Identification
of
the
Information
Collection
1.1
Title
EPA
TRACKING
NUMBER:
1587.05
OMB
TRACKING
NUMBER:
2060­
2043
1.2
Description
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
2
11
January
2000
permits
program.
The
information
will
also
be
available
for
public
inspection
at
any
time
in
the
offices
of
the
permitting
authorities.

The
Agency
anticipates
annualized
direct
costs
of
the
part
70
permit
program
for
the
three
years
of
the
ICR
to
subject
sources
to
be
approximately
$
306.7
million.
These
represent
the
direct
administrative
costs
for
20,924
sources,
or
approximately
$
4,900
per
source
per
year
(
153
hours
per
source
per
year).
The
Agency
estimates
the
cost
of
the
part
70
permit
program
for
the
three
years
of
the
ICR
to
permitting
authorities
to
be
approximately
$
175.9
million
($
2,800
and
76
hours
per
source
per
year).
The
Agency
expects
Federal
costs
for
the
three
years
of
the
ICR
will
be
approximately
$
4.9
million
(
2
hours
and
$
78
per
source
per
year).

In
implementing
title
V
of
the
Act
and
EPA's
part
70
operating
permits
regulations,
State
and
local
permitting
authorities
must
develop
programs
and
submit
them
to
EPA
for
approval
(
section
502(
d)).
Sources
subject
to
the
program
must
prepare
operating
permit
applications
and
submit
them
to
the
permitting
authority
within
1
year
after
approval
of
the
program
by
EPA
(
section
503).
Permitting
authorities
will
then
issue
permits
(
section
503(
c))
and
thereafter
enforce,
revise,
and
renew
those
permits
at
no
more
than
5­
year
intervals
(
section
502(
d)).
Permit
applications
and
proposed
permits
will
be
provided
to,
and
are
subject
to
review
by,
EPA
(
section
505(
a)).
The
permit
and
all
information
submitted
by
a
source
shall
be
available
for
public
review
except
for
confidential
information
which
will
be
protected
from
disclosure
(
section
503(
e))
and
the
public
shall
be
given
public
notice
of,
and
an
opportunity
for
comment
on,
permit
actions
(
section
502(
b)(
6)).
Sources
will
semi­
annually
submit
compliance
monitoring
reports
to
the
permitting
authorities
(
section
504(
a)).
The
EPA
has
the
responsibility
to
oversee
implementation
of
the
program
(
section
502(
d)(
3)).
A
copy
of
sections
502
through
504
of
title
V
of
the
Act
are
in
Attachment
1.
2
Need
and
Use
of
the
Collection
2.1
Need
/
Authority
for
the
Collection
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
3
11
January
2000
The
burden
estimates
included
in
this
ICR
include
the
total
burden
of
implementing
the
part
70
operating
permits
program.
For
the
3­
year
period
covered
by
this
ICR,
all
State
programs
(
including
those
portions
of
States
for
which
an
operating
permits
program
is
being
implemented
by
a
local
agency)
have
been
submitted
to
EPA
and
have
been
granted
either
full
or
interim
approval.
All
permit
applications
have
been
submitted
to
State
or
local
permitting
authorities
except
for
sources
that
will
newly
be
subject
to
the
program.

To
carry
out
the
remaining
activities
of
the
program
(
listed
above
in
section
1.2),
permitting
authorities
must
obtain
the
required
information
from
sources
subject
to
the
program
and
they
must
then
carry
out
their
functions
(
e.
g.,
permit
issuance,
renewal,
and
revision
and
report
review)
based
on
the
information.
For
EPA
to
carry
out
its
required
oversight
function
of
reviewing
proposed
permits
and
permit
revisions
and
assuring
adequate
implementation
of
the
program,
information
on
permit
applications,
permit
revision
and
renewal
applications,
issued
permits,
and
source
data
reports
must
be
available
to
the
Agency.

The
information
included
in
this
ICR
is
based
upon
the
best
data
sources
available
to
the
Agency
at
this
time.
However,
inconsistencies
in
PA
reporting
techniques,
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
by
permitting
authority
and
Agency
experts.
Consequently,
the
reader
should
not
consider
the
conclusions
to
be
an
exact
representation
of
the
level
of
burden
or
cost
that
will
occur
during
the
three
years
of
this
ICR.
Instead,

this
ICR
should
be
considered
a
directionally
correct
assessment
of
the
impact
the
Operating
Permits
Program
will
have
over
the
next
three
years.

Throughout
this
ICR,
the
reader
will
observe
estimated
values
that
show
accuracy
to
the
single
hour
or
dollar.
Because
this
ICR
estimates
the
expected
impact
of
the
Operating
Permits
Program,
reporting
values
at
the
single
unit
level
may
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
2.2
Practical
Utility
/
Users
of
the
Data
2.3
Caveats
and
Considerations
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
4
11
January
2000
$
5,456,295
would
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.

While
much
of
the
information
requested
under
this
ICR
existed
prior
to
the
creation
of
the
operating
permits
program,
an
operating
permit
is
a
compilation
of
existing
requirements;
the
purpose
being
to
bring
all
requirements
applicable
to
a
source
into
one
document.
The
intent
of
this
compilation
is
to
(
1)
resolve
any
questions
of
applicability
at
the
time
of
permit
issuance,
(
2)
provide
certainty
to
sources
as
to
their
obligations,
and
(
3)
provide
the
public
access
to
a
source's
obligations
and
compliance
status.
The
Agency
has
no
leeway
to
not
require
such
previously
existing
information
under
this
ICR
since
consolidation
of
the
information
into
the
operating
permit
and
providing
public
access
is
the
whole
purpose
of
the
statute.
To
the
extent
that
similar
information
was
previously
collected
(
e.
g.,
State
permits
under
State
implementation
plans),
the
part
70
program
may
replace
those
activities
thus
avoiding
duplication
of
efforts.

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
1992
ICR
for
part
70
expired
in
July
1995
and
was
granted
an
extension
to
September
30,
1996
to
accommodate
changes
that
had
occurred
to
the
program
since
the
approval
of
the
1992
ICR.
On
February
28,
1997,
OMB
approved
the
renewed
ICR
for
part
70
(
OMB
number
2060­
0243,
EPA
tracking
number
1587.04).
That
ICR
expired
on
February
28,
2000.
This
ICR
is
a
renewal
of
the
February
28,
1997
ICR.

Except
for
information
collection
in
notices
of
proposed
rules
or
those
exempted
under
the
emergency
processing
provisions
of
44
U.
S.
C.
3
Non­
Duplication,
Consultation,
and
Other
Collection
Criteria
3.1
Non­
Duplication
3.2
Public
Notice
Requirements
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
5
11
January
2000
§
3507(
j),
the
PRA
requires
EPA
to
solicit
comment
on
each
proposed
information
collection,
including
the
renewal
or
modification
of
any
existing
ICR.
On
October
18,
1999,
(
64
FR
56207)
EPA
published
a
notice
soliciting
comment
on
an
analysis
of
burden
for
the
part
70
program
for
the
3­
year
period
of
this
ICR
(
i.
e.,
February
28,
2000,
to
February
28,
2003).

A
copy
of
the
October
1999
notice
is
attached
as
Attachment
2.

In
preparing
this
ICR,
EPA
contacted
the
following
permitting
authorities
to
obtain
estimates
of
the
burden
of
the
various
activities
associated
with
the
part
70
program:

°
Tom
Micai,
New
Jersey
DEP,
609­
292­
0834
°
Lisa
McClung,
West
Virginia
DEP,
304­
558­
0885
°
Wayne
Anderson,
Mississippi
DEQ,
601­
961­
5153
°
Rick
McVaigh,
San
Joaquin
UAPCD,
209­
497­
2000
Geri
O.
Sullivan
of
the
State
and
Territorial
Air
Pollution
Program
Administrators
and
the
Association
of
Local
Air
Pollution
Control
Officers
(
STAPPA/
ALAPCO)
contacted
the
following
and
provided
their
responses
to
EPA:

°
Jim
Ross,
Illinois
EPA,
217­
782­
4651
°
Brian
Fitzgerald,
Vermont
ANR,
802­
241­
3848
°
Phil
Davis,
Alabama
DEM,
334­
271­
7875
°
Curt
Marshall,
Regional
Air
Pollution
Control
Agency
(
Dayton,
OH),

937­
225­
4435
°
Renee
Bashel,
Wisconsin
DNR,
608­
266­
7718
In
general,
the
information
collections
included
in
this
ICR
are
one­
time
submittals
per
activity
(
e.
g.,
permit
application,
permit
issuance,
permit
revision).
Exceptions
are
the
semi­
annual
compliance
monitoring
data
report
and
the
annual
compliance
certification.
These
two
reports
are
required
by
section
503(
b)(
1)
and
(
2),
respectively,
of
the
Act
and
EPA
has
no
leeway
to
require
less
frequent
reporting.
3.3
Consultations
3.3
Effects
of
Less
Frequent
Collection
2
All
definitions
of
"
major"
in
the
Act.

Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
6
11
January
2000
Part
70
requires
retention
of
all
monitoring
data
and
support
information
and
all
permit
applications,
proposed
permits,
and
final
permit
records
for
a
period
of
5
years.
These
records
are
necessary
to
fulfill
the
intent
of
title
V
to
assure
compliance
with
applicable
requirements.
Questions
regarding
the
obligations
of
a
source
and
its
status
of
compliance
can
be
resolved
through
such
records.

All
information,
other
than
confidential
business
information,
relating
to
the
permitting
of
sources
under
this
program
and
related
to
compliance
monitoring
are
required
by
section
503(
e)
of
the
Act
to
be
subject
to
public
review
at
all
times.
Section
70.4(
b)(
3)(
viii)
requires
the
permitting
authority
to
make
available
to
the
public
any
permitting
information
except
that
entitled
to
protection
from
disclosure
under
section
114(
c)
of
the
Act.

Protected
information
may
be
required
to
be
submitted
directly
to
EPA.

Such
information
will
be
stored
in
EPA's
Confidential
Business
Information
office.

Respondents
to
this
information
collection
come
from
two
groups:

permitting
authorities
(
PAs)
and
sources
required
to
obtain
an
operating
permit.

All
States
are
required
by
title
V
to
develop
a
part
70
operating
permits
program.
In
many
instances,
local
agencies
administer
a
program
in
their
jurisdiction
in
lieu
of
the
State
and
are
thereby
subject
to
the
same
program
requirements
as
States.
In
total,
there
are
112
State,
territorial,
and
local
agencies
administering
operating
permits
programs.

Under
title
V,
all
major
stationary
sources
must
obtain
an
operating
permit.
2
Some
non­
major
sources
may
also
be
subject
to
the
program
if
they
are
subject
to
a
Federal
standard
such
as
a
New
Source
Performance
Standard.
Most
of
these
sources
have
been
exempted
from
the
program
or
3.4
General
Guidelines
3.5
Confidentiality
4
The
Respondents
and
the
Information
Requested
4.1
Respondents
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
7
11
January
2000
the
applicability
of
the
program
requirements
are
deferred
until
some
future
date.
Information
provided
to
the
EPA
by
permitting
authorities
indicate
20,660
sources
are
now
subject
to
the
program,
representing
more
than
500
SIC
codes.

All
activities
associated
with
the
operating
permits
program
are
considered
information
collection
activities
and
are
reflected
in
the
ICR
for
part
70.

Following
are
lists
of
the
operating
permits
program
data
items
submitted
by
sources
and
permitting
authorities
and
program
activities
performed
by
permitting
authorities
and
sources.
These
lists
differ
from
those
included
in
previous
part
70
ICRs
because
experience
gained
in
implementing
the
program
allows
a
more
realistic
breakout
of
activities.
The
Agency
believes
the
list
of
tasks
below
more
accurately
represents
the
burdens
experienced
by
sources
and
permitting
authorities
and
allows
a
more
accurate
estimate
of
burden.

Permitting
Authorities
(
submitted
to
EPA):

°
Application
for
permits,
permit
revisions,
and
permit
renewals
°
Draft/
proposed
permits,
permit
revisions,
or
permit
renewals
°
Final
permit
°
Annual
report
of
enforcement
activities
Sources
(
submitted
to
permitting
authority):

°
Application
for
permits,
permit
revisions,
and
permit
renewals
°
Semi­
annual
periodic
monitoring
report
°
Annual
compliance
certification
report
PERMITTING
AUTHORITY
ACTIVITIES
°
Program
administration:
Responding
to
inquiries
about
the
program,

developing
internal
and
external
program
guidance,
planning,
attending
program
training,
permit
fee
collection,
providing
source
training,

attending
EPA
meetings
and
conferences,
providing
public
education,

and
other
program
related
activities
°
Permit
review:
including
discussions
with
a
source
concerning
the
permit
application
4.2
Information
Requested
4.2.1
Data
Items
Submitted,
including
Recordkeeping
Requirements
4.2.2
Respondent
Activities
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
8
11
January
2000
°
Draft
permit
preparation:
including
contact
with
the
source
°
Comment
period
notification:
Providing
notice
to
the
public,
EPA,

and
affected
States
of
the
comment
period
on
a
draft
permit
°
Public
hearing
administration
°
Interaction
with
EPA
on
a
proposed
permit,
including
negotiations,

re­
drafting,
and
formal
EPA
objections
(
including
those
attributable
to
public
petitions)

°
Response
to
public
comments:
Analyzing
public
comments
and
revising
the
permit
accordingly
°
Permit
issuance:
including
web
activities
and
source
notification
°
General
permits
administration
(
Burden
for
issuing
general
permits
included
with
other
permit
issuance
burden)

°
Permit
revision
°
Permit
renewal:
(
reviewing
application,
drafting
any
changes,
public
notice,
issuance)

°
Monitoring
and
compliance
certification:
Reviewing
semiannual
monitoring
reports
and
annual
compliance
certification
°
Annual
reporting:
Preparing
and
submitting
to
EPA
annually
a
report
of
the
State's
enforcement
activities
SOURCE
ACTIVITIES
°
Permit
application
preparation,
including
internal
meetings,

permitting
authority
discussions,
management
and
legal
department
involvement,
responsible
official
certification,
contractor
services
°
Draft
permit
development:
Interaction
with
the
permitting
authority
on
draft
permit
development
°
Gap­
filling
development:
Development
of
periodic
monitoring
gapfilling
°
Public
hearing
participation
°
Operate
gap­
filling
periodic
monitoring
(
annual
burden
to
operate
monitors,
keep
records,
etc.)

°
Monitoring
reports:
Preparing
semi­
annual
monitoring
data
reports,

including
data
analysis,
responsible
official
certification,
and
report
submission
(
annual
burden
for
both
reports).
Include
preparing
and
submitting
annual
compliance
certification
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
9
11
January
2000
°
Permit
revisions
°
Permit
renewal
°
Other
activities
associated
with
permit
renewal,
including
discussions
with
permitting
authority
and
public
hearing
participation.

EPA
ACTIVITIES
°
Review
proposed
permits
and
permit
revisions
to
determine
if
they
provide
for
compliance
with
all
applicable
requirements.

°
Review
periodic
monitoring
provisions
of
proposed
permits
or
permit
revisions
to
see
if
they
are
adequate
to
demonstrate
compliance
with
applicable
requirements.

°
Consult
with
the
permitting
authority
on
any
problems
detected
in
the
proposed
permit
or
permit
revision.

°
Review
annual
reports
of
enforcement
activities.

The
Agency
will
receive
proposed
permits
or
permit
revisions
in
hard
copy
or
electronically,
depending
on
permitting
authority
capability.
Each
EPA
Regional
Office
has
determined
with
their
permitting
authorities
the
most
efficient
system
to
exchange
information.
Each
Regional
Office
maintains
files
of
permit
information
only
to
the
extent
that
the
office
determines
the
need
for
file
retention.
This
will
vary
depending
on
factors
such
as
the
source
(
e.
g.,
large,
complicated
sources
vs.
small),
the
type
of
permit
(
general
vs.
full),
the
number
of
actions
occurring
at
a
source,
or
the
record
of
the
source
with
respect
to
compliance.
There
is
no
need
to
maintain
complete
files
of
permit
actions
for
public
access
since
these
are
maintained
by
permitting
authorities.

Title
V
provides
few
ways
to
mitigate
the
effects
of
operating
permit
regulations
on
small
entities.
Under
section
502(
a)
of
the
Act,
the
Agency
has
exempted
or
deferred
applicability
of
title
V
to
most
non­
major
source
categories
for
which
compliance
with
title
V
will
be
impracticable,
5
The
Information
Collected
­
Collection
Methodology,
and
Information
Management
5.1
Collection
Methodology
and
Management
5.2
Small
Entity
Flexibility
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
10
11
January
2000
infeasible,
or
unnecessarily
burdensome.
The
Agency
has
not
analyzed
how
many
of
these
non­
major
sources
will
be
small
businesses,
but
believes
that
a
large
percentage
may
fall
under
that
definition.

For
industries
with
a
large
number
of
identical
sources
(
e.
g.,
dry
cleaners,

bulk
gasoline
distribution
terminals),
general
permits
may
be
used
to
meet
the
requirements
of
title
V
instead
of
a
source­
specific
permit.
General
permits
can
reduce
the
burden
of
the
program
on
small
businesses.

In
accordance
with
the
analytical
requirements
established
under
the
Regulatory
Flexibility
Act
(
RFA)
and
the
Small
Business
regulatory
enforcement
Fairness
Act
(
SBREFA),
the
Agency
has
determined
that,

because
this
ICR
represents
regulatory
relief
relative
to
its
predecessor,

there
are
no
adverse
effects
to
be
identified
vis
a
vis
small
entities
and
small
businesses.

Items
identified
in
section
4.2.1
are
listed
below
with
their
schedule
for
submission.

Permitting
Authorities
(
submitted
to
EPA):

°
Application
for
permits,
permit
revision,
and
permit
renewal
should
be
submitted
to
EPA
with
the
proposed
permit
or
permit
revision.

°
Draft/
proposed
permits,
permit
revisions,
or
permit
renewals
should
be
submitted
when
the
State
wants
to
commence
EPA
review
period
of
the
proposed
permit
or
permit
revision.

°
The
final
permit
should
be
submitted
to
EPA
soon
after
it
is
issued,
but
there
is
no
deadline
in
part
70
for
this
submission.

°
The
annual
report
of
enforcement
activities
is
submitted
to
EPA
annually,
but
part
70
does
not
specify
a
date.

Sources
(
submitted
to
permitting
authority):

°
New
permit
applications
are
due
within
1
year
after
a
source
becomes
subject
to
the
program.

°
Permit
revision
applications
are
submitted
by
a
source
when
it
wishes
to
make
a
change
to
its
permit.
There
is
no
schedule
for
these
submissions
in
that
they
are
at
the
discretion
of
the
source.
5.3
Collection
Schedule
3
Correspondence
with
the
Operating
Permits
Group,
Information
Transfer
and
program
Integration
Division,
United
States
Environmental
Protection
Agency.

4
Conversations
between
Roger
Powell,
U.
S.
EPA
/
OAQPS
/
OPG,
and
Tom
Micai,
New
Jersey
Department
of
Environmental
Protection,
December,
1999.

Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
11
11
January
2000
°
Permit
renewal
applications
are
due
at
least
6
months
prior
to
expiration
of
the
permit.

°
The
semi­
annual
periodic
monitoring
report
is
due
to
be
submitted
to
the
permitting
authority
twice
a
year
on
dates
specified
by
the
permitting
authority.

°
The
annual
compliance
certification
report
is
due
annually
on
a
date
specified
by
the
permitting
authority.

Historically,
the
Agency
has
identified
116
permitting
authorities
for
title
V
purposes.
This
number
includes
several
governmental
agencies
that
do
not
manage
operating
permits
programs.
In
actuality,
there
are
112
permitting
authorities
acting
within
the
United
States.
Forty­
nine
states
operate
as
permitting
authorities,
with
California
employing
34
local
air
quality
management
organizations
in
lieu
of
a
statewide
permitting
authority.

Puerto
Rico,
the
Virgin
Islands,
and
Washington
D.
C.
all
have
operating
permits
programs,
and
there
are
26
county
or
regional
Permitting
authorities
within
states
that
operate
in
a
manner
similar
to
that
of
California.

As
of
November,
1999,
the
Agency
identified
20,660
title
V
sources
in
the
United
States.
3
New
Jersey
anticipates
their
program
will
increase
by
an
additional
114
sources.
However,
permits
for
these
sources
are
not
projected
to
be
issued
until
the
3rd
year
of
this
ICR.
4
During
the
three
years
of
this
ICR,
the
Agency
expects
approximately
50
new
sources
will
become
subject
to
the
permitting
program
each
year.
Due
to
the
backlog
of
pending
permits,
this
ICR
assumes
all
150
new
sources
and
the
114
New
Jersey
sources
will
be
addressed
in
the
third
year
of
this
ICR.
Agency
information
indicates
8,254
sources
will
be
permitted
by
November
1999,
6
Estimating
the
Burden
and
Cost
of
the
Collection
6.1
Estimating
The
Number
of
Respondents
There
are
20,924
sources
represented
in
this
ICR:

20,660
existing
sources
114
additional
sources
to
be
added
by
New
Jersey
150
new
sources
over
the
3
years
of
the
ICR
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
12
11
January
2000
and
an
additional
1,653
sources
are
expected
to
be
permitted
by
March
2000,
for
a
total
of
9,907
permitted
sources
at
the
beginning
of
TABLE
1
IDENTIFICATION
OF
AFFECTED
ENTITIES
AND
PERMIT
ISSUANCE
SCHEDULE
PERMITTING
AUTHORITIES
SOURCES
State
Permitting
Authorities
49
Total
Population
of
Title
V
Sources
20,660
PLUS:
California
Local
Authorities
34
Less:
Sources
Permitted
Before
December
1999
8,254
PLUS:
Territories
and
Possessions
2
Less:
Sources
Permitted
December
1999
to
March
2000
1,653
PLUS:
District
of
Columbia
1
Total
Sources
Expected
to
Be
Permitted
by
March
2000
9,907
PLUS:
Other
Local
PAs
26
Sources
Remaining
to
Be
Permitted
10,753
Total
Permitting
Authorities
112
Percent
of
Sources
Expected
to
Be
Covered
by
General
Permits
20%

Sources
Expected
to
Be
Covered
4,132
Less:
Sources
Covered
by
December
1999
3,128
General
Permitted
Sources
During
this
ICR
1,004
Existing
Sources
to
be
Permitted
in
First
Year
of
this
ICR
7,438
Less:
Expected
General
Permit
Sources
1,004
Plus:
Expected
General
Permits
10
Total
Permits
Expected
to
be
issued
in
Year
1
6,444
Existing
Sources
to
be
Permitted
in
Year
2
of
this
ICR
(
all
remaining)
3,315
New
Jersey
Additional
Sources
114
New
Subject
Sources
During
ICR
Period
(
3
years)
150
Total
Permits
Expected
in
Year
3
264
Total
Permits
Expected
to
Be
Approved
During
This
ICR
10,023
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
13
11
January
2000
this
ICR's
period
of
analysis.
Of
the
remaining
10,753
sources,
the
Agency
expects
7,438
will
be
permitted
during
the
first
year
of
this
ICR,
with
the
remaining
(
3,315
sources)
permitted
in
the
second
year
of
this
ICR.
During
the
third
year
of
this
ICR,
the
Agency
expects
the
114
New
Jersey
sources
and
the
150
new
sources
subject
to
permitting
during
the
ICR
period
will
all
be
permitted.
While
this
assumption
may
be
an
overstatement
of
the
actual
level
of
effort
expended
by
permitting
authorities
over
the
life
of
this
ICR,
it
represents
the
Agency's
efforts
to
bring
to
completion
the
initial
issuance
of
operating
permits.

In
the
original
1992
RIA
and
ICR
for
the
Operating
Permits
Regulations,

the
Agency
anticipated
34,324
sources
would
be
required
to
obtain
operating
permits.
Since
that
time,
the
Agency
has
offered
additional
regulatory
relief
to
sources
by
providing
a
vehicle
through
which
sources
defined
as
major
based
upon
their
potential
to
emit
can,
by
contractually
limiting
operations,
reduce
their
potential
to
emit
to
under
the
major
source
threshold
(
generally
100
tons
per
year
of
a
criteria
pollutant,
25
tons
of
a
mixture
of
HAPs,
or
10
tons
of
a
single
HAP).
The
success
of
this
"
synthetic
minor"
program
can
readily
be
seen
by
the
significant
drop
(
over
14,000
sources)
in
the
number
of
affected
major
sources.

Another
example
of
regulatory
relief
incorporated
into
the
operating
permits
program
is
the
general
permit,
which
allows
large
numbers
of
homogenous
major
sources
of
pollution
to
receive
the
same
permit.
This
program
has
been
successful
in
allowing
approximately
15%
(
about
3,000
of
all
existing
part
70
sources)
of
all
part
70
sources
a
cost
effective
alternative
to
single
source
permitting.
Further
use
of
general
permits
will,

in
the
Agency's
estimation,
increase
that
percentage
to
20%.
Consequently,

this
ICR
estimates
the
creation
of
ten
new
general
permits,
covering
1,004
sources.

Between
March
1996
and
March
1997,
1493
sources
were
issued
permits.

Past
data
indicates
239
of
those
sources
were
covered
by
general
permits,

leaving
1,254
permits
subject
to
renewal
during
year
2
of
this
ICR.

Between
March
1997
and
March
1998,
an
additional
1,952
sources
were
issued
permits,
with
312
covered
by
general
permits,
leaving
1,640
permits
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
14
11
January
2000
subject
to
renewal
during
year
3
of
this
ICR.
Finally,
the
Agency
expects
50
new
major
sources
will
apply
for
permits
each
year,
or
an
additional
150
sources
during
the
three
years
of
this
ICR.
While
these
permits
will
arrive
throughout
the
ICR
period,
the
Agency
expects
permitting
authorities
will
be
too
busy
to
issue
them
permits
until
the
last
year
of
the
ICR,
when
all
other
permits
have
been
issued.

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
TABLE
2
AVERAGE
SOURCE
BURDEN
BY
ACTIVITY
ACTIVITY
BURDEN
PER
SOURCE
OR
PERMIT
Prepare
Application
300
hrs
Draft
Permit
Interaction
40
hrs
Gap­
filling
Monitoring
Development
40
hrs
Public
Hearing
Participation
10
hrs
Operate
Gap­
filling
Periodic
Monitoring
200
hrs
Prepare
Monitoring
Reports
80
hrs
Permit
Revisions
Significant
Permit
Modifications
(
10%
of
Permits)

Minor
Permit
Modifications
(
50%
of
Permits)

Administrative
Amendments
(
50
%
of
Permits)
80
hrs
40
hrs
8
hrs
Re­
application
for
General
Permit
2
hrs
Permit
Renewal
200
hrs
Other
Activities
20
hrs
6.2
Estimating
Burden
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
15
11
January
2000
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.
The
Agency
derived
its
estimates
in
Tables
2
and
3
from
consultations
with
fewer
than
nine
respondents
from
the
regulated
community.
The
specific
tasks
included
in
each
activity
are
in
Section
4.2.2,
above,
and
the
worksheets
in
Attachment
4
of
this
ICR.

TABLE
3
PERMITTING
AUTHORITY
BURDEN
BY
ACTIVITY
ACTIVITY
BURDEN
PER
PERMIT
OR
PROGRAM
Program
Administration
3,500
hrs
/
PA
Permit
Application
Review
100
hrs
/
permit
Draft
Permits
Preparation
150
hrs
/
permit
Comment
Period
Notification
10
hrs
/
permit
Hold
Public
Hearings
100
hrs
/
hearing
Interaction
with
EPA
20
hrs
/
permit
Analyze
Public
Comments
40
hrs
/
permit
Permits
Issuance
8
hrs
/
permit
General
Permits
80
hrs
/
PA
Permit
Revision
Significant
Permit
Modification
Minor
Permit
Modification
Administrative
Amendment
60
hrs
/
permit
20
hrs
/
permit
5
hrs
/
permit
Permits
Renewal
60
hrs
/
permit
Renew
General
Permits
10
hrs
/
permit
Review
Monitoring
and
Compliance
Certification
Reports
5
hrs
/
report
/
permit
Annual
Enforcement
Activity
Reporting
40
hrs
/
PA
5
C.
f.
United
States
Environmental
Protection
Agency,
Regulatory
Impact
Analysis
and
Regulatory
Flexibility
Act
Screening
for
Operating
Permits
Regulations,
EPA­
450/
2­
91­
011,
June
1992,
pp.
16
­
17.

Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
16
11
January
2000
Based
upon
its
experience
with
the
operating
permits
program
over
the
past
eight
years,
the
Agency
revised
its
estimations
of
Federal
burden
from
the
categories
discussed
above
in
section
4.2.3.
Table
4
includes
burden
estimates
for
each
of
these
revised
categories.

TABLE
4
EPA
ACTIVITIES
ACTIVITY
BURDEN
PER
PERMIT
OR
PROGRAM
Review
Proposed
Permits
*

New
Permits
(
25%)

Significant
Permit
Modifications
Minor
Permit
Modifications
20
hrs
/
permit
8
hrs
/
revision
1
hrs
/
revision
Consultation
New
Permits
(
25%)

Significant
Permit
Modifications(
25%)

Minor
Permit
Modifications
(
25%)
8
hrs
/
permit
8
hrs
/
permit
1
hr
/
permit
Review
the
Annual
Enforcement
Activity
Reports
10
hrs.
per
report
*
Includes
the
burden
for
review
of
periodic
monitoring.

Historically,
the
Agency
had
assumed
70%
of
all
source
burden
categories
would
be
performed
in­
house,
with
the
remaining
30%
delegated
to
contractors.
5
However,
this
ICR
reassesses
that
assumption
and
believes
a
more
appropriate
representation
would
be
to
allocate
contractor
support
for
only
the
permit
application
task.
This
analysis
assumes
one­
third
of
the
source's
permit
application
preparation
would
performed
by
contracted
labor.
The
remainder
of
the
source's
tasks
would
be
done
entirely
in­
house.
6.3
Estimating
Costs
6.3.1
Estimating
Source
Costs
6
United
States
Department
of
Commerce,
Economics
and
Statistics
Administration,
Bureau
of
the
Census;
Statistical
Abstract
of
the
United
States,
1997,
117th
Ed.,
No.
671,
673.

Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
17
11
January
2000
To
calculate
1999
in­
house
wage
rates,
the
Agency
employed
the
same
methodology
used
to
determine
an
appropriate
cost
for
Federal
and
PA
burden.
To
determine
technical,
supervisory,
and
support
staff
rates
for
industry,
this
ICR
started
with
the
appropriate
wage
rates
established
by
the
U.
S.
Bureau
of
the
Census.
6
Since
the
latest
published
wage
rates
were
in
1996
dollars,
the
Agency
adjusted
them
through
the
latest
Employment
Cost
Index
(
ECI).
ECI
figures
were
available
from
the
Bureau
of
the
Census
for
white
collar
occupations
through
1996.
The
Agency
extrapolated
from
1996
to
1999
by
taking
the
average
increase
in
ECI
for
1994,
95,
and
96
and
applying
that
average
to
each
of
the
three
years
between
1997
and
1999,
resulting
in
an
approximation
of
the
true
ECI
of
108.6
for
1999.
Table
6
below
displays
the
calculation
of
the
industry
inhouse
wage
rate
applied
to
this
analysis
of
$
32.

TABLE
5
DETERMINATION
OF
SOURCE
IN­
HOUSE
BURDEN
COSTS
Annual
Salary,
Technical
Support,
(
FY
96,
adjusted
to
1999
)
*
$
36,537.38
Annual
Salary,
Administrative
Staff,
(
FY
96,
adjusted
)*
$
34,786.75
Factor
(
1/
11)
0.09
$
3,162.12
Annual
Cost
of
Admin.
Support
Staff,
(
FY
96
,
adjusted
to
1999
)*

Factor
(
1/
8)
$
22,080.55
0.13
$
2,760.07
Annual
Applicable
Salary
of
Permit
Staff
$
42,459.57
Benefits
(
at
16%)
$
6,793.53
Sick
Leave
/
Vacation
(
at
10%)
$
4,245.96
General
Overhead
$
13,727.18
Total
Cost
Per
FTE
$
67,226.24
Total
Hourly
Cost
(
Total
Per
FTE
divided
by
2,080
hours
per
year)
$
32.32
*
U.
S.
Department
of
Commerce,
Economics
and
Statistics
Administration,
Bureau
of
the
Census;
Statistical
Abstract
of
the
United
States,
1997,
Table
672.
http://
www.
bea.
doc.
gov/
bea/
dn/
aadata.
exe,
December
7,
1999
7
Due
to
the
confidential
nature
of
the
data
employed,
this
ICR
does
not
offer
any
tables
or
appendices
detailing
the
derivation
of
this
contractor
burden
rate.

8
United
States
Environmental
Protection
Agency,
Information
Collection
Request
Analysis
for
Part
71
Federal
Operating
Permits
Program,
December
1995.

Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
18
11
January
2000
For
contracted
labor,
operating
permit
management
and
reporting
require
the
same
skills
employed
by
the
EPA's
consultants.
As
an
estimation
of
a
source's
consulting
costs,
the
Agency
averaged
the
fully
loaded
cost
of
three
environmental
contractors
at
the
PL
2
(
secretarial
support),
PL
3
(
technical),
and
PL
4
(
administration)
levels,
applying
the
methodology
employed
in
Table
5
for
establishing
a
Federal
and
PA
FTE
wage
rate.
The
fully
loaded
hourly
wage
rate
for
Industry­
hired
consultants
is
$
268.7
Therefore,
the
hourly
rate
for
permit
preparation
as
been
set
at
$
111
(
1/
3
of
$
268
plus
2/
3
of
$
32).
All
other
source
tasks
are
estimated
at
$
32
per
hour.

Historically,
the
Agency
has
applied
a
$
34
per
hour
rate
for
Federal
and
State
full
time
employee
(
FTE)
wage
rates,
and
a
$
45
rate
for
source
FTE
wages.
During
the
development
of
the
ICR
for
the
part
71
Federal
Operating
Permit
Regulations,
the
Agency
was
instructed
by
the
Office
of
General
Council
(
OGC)
to
compute
more
accurate
estimations
of
these
hourly
costs.
To
determine
the
appropriate
hourly
wage
to
apply
to
each
respondent
burden
estimation,
OGC
instructed
the
Agency
to
assume
the
appropriate
FTE
rate
to
apply
would
be
a
GS­
11
Step
3,
fully
loaded
to
account
for
overhead,
benefits,
and
all
other
appropriate
costs.
To
fully
incorporate
the
cost
of
that
FTE's
support
staff
and
managerial
costs,
the
Agency
also
assumed
one­
eleventh
of
a
manager's
time
(
at
a
GS­
13,
Step
3
level),
and
one­
eighth
of
a
secretary's
time
(
at
a
GS­
6,
Step
6
level).
An
analysis
of
the
components
of
this
cost
can
be
found
in
the
part
71
ICR
in
Appendix
A
as
Table
A­
5,
which
defines
a
cost
of
$
34
per
hour
for
permitting
authority
and
Federal
burden.
8
Applying
the
same
process
to
current
ware
rates
for
the
Federal
government,
the
Agency
determined
the
appropriate
cost
of
Federal
and
permitting
authority
burden
is
$
37
per
hour.
Table
5
displays
the
calculation
of
this
rate.
6.3.2
Estimating
PA
and
Agency
Costs
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
19
11
January
2000
Table
7
lists
the
burden
categories
for
respondent
sources,
the
number
of
estimated
occurrences
for
each
item,
and
the
expected
cost
for
each,
based
on
the
burden
estimations
from
Table
2.

Table
8
lists
the
burden
categories
for
respondent
permitting
authorities,

the
expected
number
of
permits
or
programs
involved,
and
the
expected
cost
for
each,
based
on
the
burden
estimations
from
Table
3.

Table
9
lists
the
burden
categories
for
Federal
oversight,
the
number
of
estimated
permits
or
programs
involved,
and
the
expected
cost
for
each,

based
on
the
burden
estimations
from
Table
4.

TABLE
6
DETERMINATION
OF
FEDERAL
AND
PERMITTING
AUTHORITY
BURDEN
COSTS
Annual
Salary
of
Permit
Staff,
GS
11
Step
3
(
FY
99
Schedule)*
$
40,260.00
Annual
Cost
of
Supervisory
Staff,
GS
13
Step
3
(
FY
99
Schedule)*
$
57,379.00
Factor
(
1/
11)
0.09
$
5,164.11
Annual
Cost
of
Support
Staff,
GS
6
Step
6
(
FY
99
Schedule)*

Factor
(
1/
8)
$
26,773.00
0.13
$
3,346.63
Annual
Applicable
Salary
of
Permit
Staff
$
48,770.74
Benefits
(
at
16%)
$
7,803.32
Sick
Leave
/
Vacation
(
at
10%)
$
4,877.07
General
Overhead
$
15,767.58
Total
Cost
Per
FTE
$
77,218.70
Total
Hourly
Cost
(
Total
Per
FTE
divided
by
2,080
hours
per
year)
$
37.12
*
http://
www.
opm.
gov/
oca/
99tables/
GSannual/
gsannpdf/
99GS.
PDF,
December
7,
1999
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
20
11
January
2000
TABLE
7
THE
BURDEN
AND
COST
OF
SOURCE
ACTIVITIES
ACTIVITY
AFFECTED
PERMITS
TOTAL
BURDEN
(
HOURS)
TOTAL
COST
($
1999)

Program
Application
**
264
79,200
$
8,791,200
Draft
Permit
264
10,560
$
337,920
Gap
Filling
Monitoring
Development
5,007
200,280
$
6,408,960
Public
Hearing
Participation
200
2,000
$
64,000
Operate
Gap
Filling
Monitoring
year
1
3,390
year
2
6,607
year
3
8,264
year
1
678,000
year
2
1,321,400
year
3
1,652,800
3,652,200
$
21,696,000
$
42,284,800
$
52,889,600
$
116,870,400
Prepare
Monitoring
Reports
year
1
9,907
year
2
17,345
year
3
20,660
year
1
792,560
year
2
1,387,600
year
3
1,652,800
3,832,960
$
25,361,920,444,032,030
,000,000,000,000,000
Permit
Revisions
Significant
Permit
Modifications
Minor
Permit
Modifications
Administrative
Amendments
year
1
678
year
2
1,321
year
3
1,653
year
1
3,390
year
2
6,607
year
3
8,264
year
1
3,390
year
2
6,607
year
3
8,264
year
1
54,240
year
2
105,680
year
3
132,240
292,160
year
1
135,600
year
2
264,280
year
3
330,560
730,440
year
1
27,120
year
2
52,856
year
3
66,112
146,088
1,168,688
$
1,735,680
$
3,381,760
$
4,231,680
$
9,349,120
$
4,339,200
$
8,456,960
$
10,577,920
$
23,374,080
$
867,840
$
1,691,392
$
2,115,584
$
4,674,816
$
37,398,016
General
Permit
Renewal
551
1,102
$
35,264
Permit
Renewal
2,894
578,800
$
18,521,600
Other
Activities
2,894
57,880
$
1,852,160
TOTALS
9,583,670
$
306,677,440
*
9,909
total
permits
per
year
**
1/
3
contractor
support,
2/
3
in­
house
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
21
11
January
2000
TABLE
8
THE
COST
OF
PERMITTING
AUTHORITY
ACTIVITIES
*

ACTIVITY
AFFECTED
PERMITS
OR
PROGRAMS
**
TOTAL
BURDEN
(
HOURS)
TOTAL
COST
($
1999)

Program
Administration
112
PAs
/
yr
1,176,000
$
43,512,000
Permit
Application
Review
88
/
yr
26,400
$
976,800
Draft
Permit
Preparation
10,023
permits
1,503,450
$
55,627,650
Comment
Period
Notification
10,023
draft
permits
100,230
$
2,706,210
Public
Hearings
200
hearings
20,000
$
740,000
Interaction
with
EPA
10,023
permits
200,460
$
7,417,020
Analyzing
Public
Comments
1,002
permits
40,080
$
1,480,000
Permit
Issuance
10,023
permits
80,184
$
2,966,808
General
Permits
Administration
112
agencies
26,880
$
994,560
Permit
Revisions
***

Significant
Minor
Administrative
year
1
678
year
2
1,321
year
3
1,653
year
1
3,390
year
2
6,607
year
3
8,264
year
1
3,390
year
2
6,607
year
3
8,264
40,680
79,260
99,180
219,120
67,800
132,140
165,280
365,220
16,950
33,035
41,320
91,305
675,645
$
1,505,160
$
2,932,620
$
3,669,660
$
8,107,440
$
2,508,600
$
4,889,180
$
6,115,360
$
13,513,140
$
627,150
$
1,222,295
$
1,528,840
$
3,378,285
$
24,998,865
Permit
Renewals
2,894
renewals
173,640
$
6,424,680
Review
General
Permits
10
100
$
3,700
Review
Monitoring
and
Compliance
Certification
Reports
year
1
9,907
year
2
17,345
year
3
20,660
148,605
260,175
309,900
718,680
$
5,498,385
$
9,626,475
$
11,466,300
$
26,591,160
Annual
Enforcement
Reporting
112
agencies
13,440
$
497,280
TOTALS
4,755,189
$
175,941,993
*
112
Permitting
Authorities
**
Consult
the
Assumptions
page
for
explanation
of
other
numbers
in
the
column.
***
Number
of
issued
single
source
permits:
year
1
=
6,779;
year
2
=
14,217;
year
3
=
17,532
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
22
11
January
2000
TABLE
9
EPA
ACTIVITIES
ACTIVITY
AFFECTED
PERMITS
OR
PROGRAMS
TOTAL
BURDEN
(
HOURS)
TOTAL
COST
($
1999)

Review
permits
and
revisions
New
Permits
Significant
permit
revisions
Minor
Permit
Revisions
2,506
permits
year
1
678
year
2
1,321
year
3
1,653
year
1
3,390
year
2
6,607
year
3
8,264
50,120
5,424
10,568
13,224
29,216
3,390
6,607
8,264
18,261
$
1,854,440
$
200,688
$
391,016
$
489,288
$
1,080,992
$
125,430
$
244,459
$
305,768
$
675,657
Consult
with
PA
New
Permits
Significant
Permit
Revisions
Minor
Permit
Revisions
2,506
permits
year
1
170
year
2
331
year
3
414
year
1
848
year
2
1,652
year
3
2,066
20,048
1,360
2,648
3,312
7,320
848
1,652
2,066
4,566
$
741,776
$
50,320
$
97,976
$
122,544
$
270,840
$
31,376
$
61,124
$
76,442
$
168,942
Review
the
annual
report
112
/
yr
3,360
$
124,320
TOTALS
132,891
$
4,916,967
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
23
11
January
2000
Tables
2,
3,
and
4
display
the
activities
of
the
part
70
program
for
permitting
authorities,
sources,
and
the
Federal
government,
respectively.

Tables
7,
8,
and
9
display
the
costs
associated
with
each
of
these
categories.
Table
10
below
summarizes
the
costs
for
all
three
types
of
affected
entities
in
real
1999
dollars.

TABLE
10
BOTTOM
LINE
BURDEN
AND
COST
2000
­
2003
Number
of
Affected
Entities
Total
ICR
(
3
Year)

Burden
Hours
Average
Annual
Burden
Per
Respondent
Average
Annual
Burden
Per
Source
Total
ICR
(
3
Year)

Cost
($
1999)
Average
Annual
Cost
Per
Respondent
($
1999)
Average
Annual
Cost
Per
Source
($
1999)

Sources
20,924
9,583,670
153
153
$
306,677,440
$
4,896
$
4,896
PAs
112
4,755,189
14,152
76
$
175,941,993
$
523,173
$
2,812
Federal
1
132,891
44,297
2
$
4,916,967
$
3,462,300
$
78
TOTAL
14,471,750
NA
NA
$
487,536,400
NA
NA
Table
10
displays
the
expected
burden
and
cost
for
sources,
permitting
authorities,
and
the
Federal
government
for
implementation
of
the
title
V
Operating
Permits
Program
between
March
2000
and
March
2003.
Of
the
14.3
million
hours
the
Agency
anticipates
it
will
take
to
perform
all
the
functions
required
by
title
V,
two­
thirds
of
the
burden
applies
to
sources.

However,
the
magnitude
of
the
total
expected
burden
can
be
misleading,

due
to
the
number
of
permitted
sources.
For
the
20,924
sources
included
in
this
analysis,
the
average
expected
burden
is
relatively
small
­
about
one
month
of
a
full
time
employee's
time.
Likewise,
the
cost
associated
with
that
burden
is
also
small
­
about
$
5,000
­
or
7%
of
the
fully
loaded
FTE
cost
estimated
in
Table
5,
above.
6.3.3
Bottom
Line
Burden
Hours
and
Cost
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
24
11
January
2000
Permitting
authorities
incur
about
a
third
of
the
burden
in
Table
10,
with
the
total
burden
spread
between
a
significantly
smaller
number
of
entities
than
that
for
sources.
On
average,
the
Agency
estimates
the
PA
burden
associated
with
the
title
V
Operating
Permits
Program
will
be
about
14,000
hours
per
year.
However,
for
some
permitting
authorities
with
relatively
fewer
sources
(
Connecticut,
Wyoming,
etc.)
the
average
burden
will
be
higher;
and,
in
others
with
more
than
the
average
number
of
sources
(
Louisiana,
Texas,
etc.)
it
will
be
too
low.
A
better
measure
of
the
effect
of
title
V
regulations
on
permitting
authorities
would
be
to
divide
the
total
estimated
hours
by
the
number
of
operating
permits.
On
average,
each
PA
can
expect
to
spend
70
to
80
hours
managing
and
overseeing
each
permit
application
it
receives,
at
a
cost
of
approximately
$
2,800
per
permit.

However,
this
cost
cannot
be
considered
an
Unfunded
Mandate
from
the
Federal
government,
because
the
net
cost
to
permitting
authorities
for
their
management
of
an
operating
permits
program
must,
by
law,
be
passed
on
to
sources
in
the
form
of
permit
fees
of
sufficient
magnitude
to
fully
offset
all
permit
management
costs.
Therefore,
the
true
annual
cost
to
permitting
authorities
under
title
V
is
zero,
and
the
true
annual
cost
to
sources
is
$
161
million,
or
approximately
$
7,700
per
permit.

The
part
70
program
has
been
evolving
since
its
inception,
beginning
with
promulgation
of
the
part
70
regulations
in
1992.
Consequently,
the
activities
associated
with
implementing
the
part
70
program
have
changed
since
the
previous
ICR.
State
and
local
permitting
authorities
first
developed
their
programs
and
submitted
them
to
EPA
for
approval.
This
activity
occurred
over
several
years
during
which
approved
programs
were
beginning
to
be
implemented
by
first
having
sources
submit
permit
applications.
As
the
later
program
submissions
were
being
approved,
some
agencies
were
in
the
early
stages
of
issuing
permits.
As
of
the
beginning
of
this
ICR,
all
programs
are
approved
and
essentially
all
permit
applications
have
been
submitted
to
the
permitting
authorities.

With
the
experience
gained
through
program
implementation,
EPA
and
permitting
authorities
have
a
sense
of
the
activities
associated
with
the
program
and
the
burden
of
those
activities.
The
activities
in
this
ICR
have
been
developed
based
on
this
knowledge.
While
the
activities
correspond
On
average,
each
PA
can
expect
to
spend
between
70
and
80
hours
each
year
managing
and
overseeing
each
permit
application
it
receives,
at
a
cost
of
approximately
$
2,800
per
permit
per
year.

6.4
Reasons
for
Changes
in
the
Burden
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
25
11
January
2000
to
those
specified
in
the
previous
ICR,
they
are
broken
out
into
more
discrete
categories
for
which
burden
analyses
can
be
made
more
easily.

Therefore,
comparison
of
the
burden
in
this
ICR
to
the
approved
burden
levels
in
the
previous
ICR
cannot
be
accurately
made
on
an
activity
by
activity
basis.
Even
if
they
could
be
compared,
such
a
comparison
would
be
of
little
value
because
of
the
changing
nature
of
the
program.
Such
a
comparison
of
activity
categories
will
not
have
a
great
deal
of
meaning
until
all
permits
are
issued
and
the
program
stabilizes
in
terms
of
activity.

The
approved
burden
level
in
the
previous
ICR
was
3.5
million
hours
per
year
for
sources
and
1.7
million
burden
hours
per
year
for
permitting
authorities,
and
64
thousand
hours
for
Federal
oversight;
for
a
total
of
5.2
million
hours.
Table
11
compares
the
burden
in
the
previous
ICR
with
the
burden
in
this
ICR.
The
change
in
burden
is
a
reduction
from
the
previous
ICR
due
to
changes
in
program
activities
that
have
occurred
as
a
result
of
evolution
of
the
program.
These
changes
would
be
considered
"
adjustments"
and
are
shown
as
such
on
OMB
form
83­
1.

TABLE
11
BURDEN
CHANGE
FROM
2­
28­
97
ICR
TO
CURRENT
ICR
Average
Annual
Burden
in
2­
28­
1997
ICR
Average
Annual
Burden
in
ICR
Renewal
Difference
Sources
3,478,333
3,194,557
(
283,776)

PAs
1,682,000
1,585,063
(
96,937)

Federal
63,667
44,297
(
19,370)

TOTAL
5,224,000
4,823,917
(
400,083)

For
permitting
authorities,
burden
has
decreased
largely
because
program
development
and
review
of
permit
applications
have
been
completed.
The
activities
that
will
increase
and
require
the
largest
burden
during
the
3­
year
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
26
11
January
2000
period
of
this
ICR
(
and
which
will
offset
the
reduction
in
burden)
are
general
program
administration,
preparation
of
draft
permits,
processing
of
permit
revisions,
and
review
of
semi­
annual
monitoring
and
annual
compliance
reports.

The
main
reason
hourly
burden
has
decreased
for
sources
is
because
the
largest
burden
category,
(
preparation
of
initial
permit
applications),
has
been
completed.
These
activities
will
be
replaced
during
the
3­
year
period
of
this
ICR
by
an
increase
in
monitoring
activities,
preparing
and
submitting
semi­
annual
monitoring
reports
and
the
annual
compliance
certification
report,
preparing
permit
revision
applications,
and
preparing
applications
for
permit
renewals
for
some
of
the
sources.

As
previously
noted,
it
is
impractical
to
attempt
to
delineate
burden
by
respondent
and
activity
due
to
the
large
number
of
respondents,
the
variation
in
the
circumstances
for
each
respondent,
and
the
varied
nature
of
the
activities
of
the
program.
Following
is
the
apportioned
burden
for
each
respondent.
This
is
derived
from
the
total
permitting
authority
hourly
burden
divided
by
the
number
of
permitting
authorities,
and
similarly
for
sources.

TABLE
12
BURDEN
STATEMENT
Number
of
Respondents
Total
Annual
Burden
Average
Annual
Burden
per
Respondent
Average
Annual
Burden
Per
Source
Sources
20,924
3,194,557
153
153
PAs
112
1,585,063
14,152
76
Federal
1
44,297
44,297
2
6.5
Burden
Statement
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
27
11
January
2000
Send
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
through
the
use
of
automated
collection
techniques
to:

Oscar
Morales,
Director
Collection
Strategies
Division
Office
Of
Environmental
Information
2822
Environmental
Protection
Agency
401
M
Street,
SW
Washington,
DC
20460
and
to:

The
Office
of
Information
and
Regulatory
Affairs
Office
of
Management
and
Budget
725
17th
Street,
NW
Washington,
DC
20503
Attention:
Desk
Officer
for
EPA.

Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
ATTACHMENT
1
THE
STATUTORY
REQUIREMENTS
FOR
RESPONDENT
INFORMATION
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
29
11
January
2000
SECTIONS
502
THROUGH
504
OF
TITLE
V
OF
THE
CLEAN
AIR
ACT
SEC.
502.
PERMIT
PROGRAMS
(
a)
Violations.­
After
the
effective
date
of
any
permit
program
approved
or
promulgated
under
this
title,
it
shall
be
unlawful
for
any
person
to
violate
any
requirement
of
a
permit
issued
under
this
title,
or
to
operate
an
affected
source
(
as
provided
in
title
IV),
a
major
source,
any
other
source
(
including
an
area
source)
subject
to
standards
or
regulations
under
section
111
or
112,
any
other
source
required
to
have
a
permit
under
parts
C
or
D
of
title
I,
or
any
other
stationary
source
in
a
category
designated
(
in
whole
or
in
part)
by
regulations
promulgated
by
the
Administrator
(
after
notice
and
public
comment)
which
shall
include
a
finding
setting
forth
the
basis
for
such
designation,

except
in
compliance
with
a
permit
issued
by
a
permitting
authority
under
this
title.
(
Nothing
in
this
subsection
shall
be
construed
to
alter
the
applicable
requirements
of
this
Act
that
a
permit
be
obtained
before
construction
or
modification.)
The
Administrator
may,
in
the
Administrator's
discretion
and
consistent
with
the
applicable
provisions
of
this
Act,
promulgate
regulations
to
exempt
one
or
more
source
categories
(
in
whole
or
in
part)
from
the
requirements
of
this
subsection
if
the
Administrator
finds
that
compliance
with
such
requirements
is
impracticable,
infeasible,
or
unnecessarily
burdensome
on
such
categories,
except
that
the
Administrator
may
not
exempt
any
major
source
from
such
requirements.

(
b)
Regulations.­
The
Administrator
shall
promulgate
within
12
months
after
the
date
of
the
enactment
of
the
Clean
Air
Act
Amendments
of
1990
regulations
establishing
the
minimum
elements
of
a
permit
program
to
be
administered
by
any
air
pollution
control
agency.
These
elements
shall
include
each
of
the
following:

(
1)
Requirements
for
permit
applications,
including
a
standard
application
form
and
criteria
for
determining
in
a
timely
fashion
the
completeness
of
applications.

(
2)
Monitoring
and
reporting
requirements.

(
3)(
A)
A
requirement
under
State
or
local
law
or
interstate
compact
that
the
owner
or
operator
of
all
sources
subject
to
the
requirement
to
obtain
a
permit
under
this
title
pay
an
annual
fee,
or
the
equivalent
over
some
other
period,
sufficient
to
cover
all
reasonable
(
direct
and
indirect)

costs
required
to
develop
and
administer
the
permit
program
requirements
of
this
title,
including
section
507,
including
the
reasonable
costs
of
­

(
i)
reviewing
and
acting
upon
any
application
for
such
a
permit,

(
ii)
if
the
owner
or
operator
receives
a
permit
for
such
source,
whether
before
or
after
the
date
of
the
enactment
of
the
Clean
Air
Act
Amendments
of
1990,
implementing
and
enforcing
the
terms
and
conditions
of
any
such
permit
(
not
including
any
court
costs
or
other
costs
associated
with
any
enforcement
action),
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2000
(
iii)
emissions
and
ambient
monitoring,

(
iv)
preparing
generally
applicable
regulations,
or
guidance,

(
v)
modeling,
analyses,
and
demonstrations,
and
(
vi)
preparing
inventories
and
tracking
emissions.

(
B)
The
total
amount
of
fees
collected
by
the
permitting
authority
shall
conform
to
the
following
requirements:

(
i)
The
Administrator
shall
not
approve
a
program
as
meeting
the
requirements
of
this
paragraph
unless
the
State
demonstrates
that,
except
as
otherwise
provided
in
subparagraphs
(
ii)

through
(
v)
of
this
subparagraph,
the
program
will
result
in
the
collection,
in
the
aggregate,
from
all
sources
subject
to
subparagraph
(
A),
of
an
amount
not
less
than
$
25
per
ton
of
each
regulated
pollutant,
or
such
other
amount
as
the
Administrator
may
determine
adequately
reflects
the
reasonable
costs
of
the
permit
program.

(
ii)
As
used
in
this
subparagraph,
the
term
"
regulated
pollutant"
shall
mean
(
I)
a
volatile
organic
compound;
(
II)
each
pollutant
regulated
under
section
111
or
112;
and
(
III)
each
pollutant
for
which
a
national
primary
ambient
air
quality
standard
has
been
promulgated
(
except
that
carbon
monoxide
shall
be
excluded
from
this
reference).

(
iii)
In
determining
the
amount
under
clause
(
i),
the
permitting
authority
is
not
required
to
include
any
amount
of
regulated
pollutant
emitted
by
any
source
in
excess
of
4,000
tons
per
year
of
that
regulated
pollutant.

(
iv)
The
requirements
of
clause
(
i)
shall
not
apply
if
the
permitting
authority
demonstrates
that
collecting
an
amount
less
than
the
amount
specified
under
clause
(
i)
will
meet
the
requirements
of
subparagraph
(
A).

(
v)
The
fee
calculated
under
clause
(
i)
shall
be
increased
(
consistent
with
the
need
to
cover
the
reasonable
costs
authorized
by
subparagraph
(
A))
in
each
year
beginning
after
the
year
of
the
enactment
of
the
Clean
Air
Act
Amendments
of
1990
by
the
percentage,
if
any,
by
which
the
Consumer
Price
Index
for
the
most
recent
calendar
year
ending
before
the
beginning
of
such
year
exceeds
the
Consumer
Price
Index
for
the
calendar
year
1989.
For
purposes
of
this
clause
­

(
I)
the
Consumer
Price
Index
for
any
calendar
year
is
the
average
of
the
Consumer
Price
Index
for
all­
urban
consumers
published
by
the
Department
of
Labor,
as
of
the
close
of
the
12­
month
period
ending
on
August
31
of
each
calendar
year,
and
(
II)
the
revision
of
the
Consumer
Price
Index
which
is
most
consistent
with
the
Consumer
Price
Index
for
calendar
year
1989
shall
be
used.

(
C)(
i)
If
the
Administrator
determines,
under
subsection
(
d),
that
the
fee
provisions
of
the
operating
permit
program
do
not
meet
the
requirements
of
this
paragraph,
or
if
the
Administrator
makes
a
determination,
under
subsection
(
i),
that
the
permitting
authority
is
not
adequately
administering
or
enforcing
an
approved
fee
program,
the
Administrator
may,
in
addition
to
taking
any
other
action
authorized
under
this
title,
collect
reasonable
fees
from
the
sources
identified
under
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Page
31
11
January
2000
subparagraph
(
A).
Such
fees
shall
be
designed
solely
to
cover
the
Administrator's
costs
of
administering
the
provisions
of
the
permit
program
promulgated
by
the
Administrator.

(
ii)
Any
source
that
fails
to
pay
fees
lawfully
imposed
by
the
Administrator
under
this
subparagraph
shall
pay
a
penalty
of
50
percent
of
the
fee
amount,
plus
interest
on
the
fee
amount
computed
in
accordance
with
section
6621(
a)(
2)
of
the
Internal
Revenue
Code
of
1986
(
relating
to
computation
of
interest
on
underpayment
of
Federal
taxes).

(
iii)
Any
fees,
penalties,
and
interest
collected
under
this
subparagraph
shall
be
deposited
in
a
special
fund
in
the
United
States
Treasury
for
licensing
and
other
services,
which
thereafter
shall
be
available
for
appropriation,
to
remain
available
until
expended,
subject
to
appropriation,
to
carry
out
the
Agency's
activities
for
which
the
fees
were
collected.
Any
fee
required
to
be
collected
by
a
State,
local,
or
interstate
agency
under
this
subsection
shall
be
utilized
solely
to
cover
all
reasonable
(
direct
and
indirect)
costs
required
to
support
the
permit
program
as
set
forth
in
subparagraph
(
A).

(
4)
Requirements
for
adequate
personnel
and
funding
to
administer
the
program.

(
5)
A
requirement
that
the
permitting
authority
have
adequate
authority
to:

(
A)
issue
permits
and
assure
compliance
by
all
sources
required
to
have
a
permit
under
this
title
with
each
applicable
standard,
regulation
or
requirement
under
this
Act;

(
B)
issue
permits
for
a
fixed
term,
not
to
exceed
5
years;

(
C)
assure
that
upon
issuance
or
renewal
permits
incorporate
emission
limitations
and
other
requirements
in
an
applicable
implementation
plan;

(
D)
terminate,
modify,
or
revoke
and
reissue
permits
for
cause;

(
E)
enforce
permits,
permit
fee
requirements,
and
the
requirement
to
obtain
a
permit,

including
authority
to
recover
civil
penalties
in
a
maximum
amount
of
not
less
than
$
10,000
per
day
for
each
violation,
and
provide
appropriate
criminal
penalties;
and
(
F)
assure
that
no
permit
will
be
issued
if
the
Administrator
objects
to
its
issuance
in
a
timely
manner
under
this
title.

(
6)
Adequate,
streamlined,
and
reasonable
procedures
for
expeditiously
determining
when
applications
are
complete,
for
processing
such
applications,
for
public
notice,
including
offering
an
opportunity
for
public
comment
and
a
hearing,
and
for
expeditious
review
of
permit
actions,
including
applications,
renewals,
or
revisions,
and
including
an
opportunity
for
judicial
review
in
State
court
of
the
final
permit
action
by
the
applicant,
any
person
who
participated
in
the
public
comment
process,
and
any
other
person
who
could
obtain
judicial
review
of
that
action
under
applicable
law.

(
7)
To
ensure
against
unreasonable
delay
by
the
permitting
authority,
adequate
authority
and
procedures
to
provide
that
a
failure
of
such
permitting
authority
to
act
on
a
permit
application
or
permit
renewal
application
(
in
accordance
with
the
time
periods
specified
in
section
503
or,
as
appropriate,
title
IV)
shall
be
treated
as
a
final
permit
action
solely
for
purposes
of
obtaining
judicial
review
in
State
court
of
an
action
brought
by
any
person
referred
to
in
paragraph
(
6)
to
require
that
action
be
taken
by
the
permitting
authority
on
such
application
without
additional
delay.
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2000
(
8)
Authority,
and
reasonable
procedures
consistent
with
the
need
for
expeditious
action
by
the
permitting
authority
on
permit
applications
and
related
matters,
to
make
available
to
the
public
any
permit
application,
compliance
plan,
permit,
and
monitoring
or
compliance
report
under
section
503(
e),
subject
to
the
provisions
of
section
114(
c)
of
this
Act.

(
9)
A
requirement
that
the
permitting
authority,
in
the
case
of
permits
with
a
term
of
3
or
more
years
for
major
sources,
shall
require
revisions
to
the
permit
to
incorporate
applicable
standards
and
regulations
promulgated
under
this
Act
after
the
issuance
of
such
permit.
Such
revisions
shall
occur
as
expeditiously
as
practicable
and
consistent
with
the
procedures
established
under
paragraph
(
6)
but
not
later
than
18
months
after
the
promulgation
of
such
standards
and
regulations.
No
such
revision
shall
be
required
if
the
effective
date
of
the
standards
or
regulations
is
a
date
after
the
expiration
of
the
permit
term.
Such
permit
revision
shall
be
treated
as
a
permit
renewal
if
it
complies
with
the
requirements
of
this
title
regarding
renewals.

(
10)
Provisions
to
allow
changes
within
a
permitted
facility
(
or
one
operating
pursuant
to
section
503(
d))
without
requiring
a
permit
revision,
if
the
changes
are
not
modifications
under
any
provision
of
title
I
and
the
changes
do
not
exceed
the
emissions
allowable
under
the
permit
(
whether
expressed
therein
as
a
rate
of
emissions
or
in
terms
of
total
emissions:
Provided,
That
the
facility
provides
the
Administrator
and
the
permitting
authority
with
written
notification
in
advance
of
the
proposed
changes
which
shall
be
a
minimum
of
7
days,
unless
the
permitting
authority
provides
in
its
regulations
a
different
timeframe
for
emergencies.

(
c)
Single
Permit.­
A
single
permit
may
be
issued
for
a
facility
with
multiple
sources.

(
d)
Submission
and
Approval.­
(
1)
Not
later
than
3
years
after
the
date
of
the
enactment
of
the
Clean
Air
Act
Amendments
of
1990,
the
Governor
of
each
State
shall
develop
and
submit
to
the
Administrator
a
permit
program
under
State
or
local
law
or
under
an
interstate
compact
meeting
the
requirements
of
this
title.
In
addition,
the
Governor
shall
submit
a
legal
opinion
from
the
attorney
general
(
or
the
attorney
for
those
State
air
pollution
control
agencies
that
have
independent
legal
counsel),
or
from
the
chief
legal
officer
of
an
interstate
agency,
that
the
laws
of
the
State,
locality,

or
the
interstate
compact
provide
adequate
authority
to
carry
out
the
program.
Not
later
than
1
year
after
receiving
a
program,
and
after
notice
and
opportunity
for
public
comment,
the
Administrator
shall
approve
or
disapprove
such
program,
in
whole
or
in
part.
The
Administrator
may
approve
a
program
to
the
extent
that
the
program
meets
the
requirements
of
this
Act,
including
the
regulations
issued
under
subsection
(
b).
If
the
program
is
disapproved,
in
whole
or
in
part,
the
Administrator
shall
notify
the
Governor
of
any
revisions
or
modifications
necessary
to
obtain
approval.
The
Governor
shall
revise
and
resubmit
the
program
for
review
under
this
section
within
180
days
after
receiving
notification.

(
2)(
A)
If
the
Governor
does
not
submit
a
program
as
required
under
paragraph
(
1)
or
if
the
Administrator
disapproves
a
program
submitted
by
the
Governor
under
paragraph
(
1),
in
whole
or
in
part,
the
Administrator
may,
prior
to
the
expiration
of
the
18­
month
period
referred
to
in
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2000
subparagraph
(
B),
in
the
Administrator's
discretion,
apply
any
of
the
sanctions
specified
in
section
179(
b).

(
B)
If
the
Governor
does
not
submit
a
program
as
required
under
paragraph
(
1),
or
if
the
Administrator
disapproves
any
such
program
submitted
by
the
Governor
under
paragraph
(
1),
in
whole
or
in
part,
18
months
after
the
date
required
for
such
submittal
or
the
date
of
such
disapproval,

as
the
case
may
be,
the
Administrator
shall
apply
sanctions
under
section
179(
b)
in
the
same
manner
and
subject
to
the
same
deadlines
and
other
conditions
as
are
applicable
in
the
case
of
a
determination,
disapproval,
or
finding
under
section
179(
a).

(
C)
The
sanctions
under
section
179(
b)(
2)
shall
not
apply
pursuant
to
this
paragraph
in
any
area
unless
the
failure
to
submit
or
the
disapproval
referred
to
in
subparagraph
(
A)
or
(
B)
relates
to
an
air
pollutant
for
which
such
area
has
been
designated
a
nonattainment
area
(
as
defined
in
part
D
of
title
I).

(
3)
If
a
program
meeting
the
requirements
of
this
title
has
not
been
approved
in
whole
for
any
State,
the
Administrator
shall,
2
years
after
the
date
required
for
submission
of
such
a
program
under
paragraph
(
1),
promulgate,
administer,
and
enforce
a
program
under
this
title
for
that
State.

(
e)
Suspension.­
The
Administrator
shall
suspend
the
issuance
of
permits
promptly
upon
publication
of
notice
of
approval
of
a
permit
program
under
this
section,
but
may,
in
such
notice,

retain
jurisdiction
over
permits
that
have
been
federally
issued,
but
for
which
the
administrative
or
judicial
review
process
is
not
complete.
The
Administrator
shall
continue
to
administer
and
enforce
federally
issued
permits
under
this
title
until
they
are
replaced
by
a
permit
issued
by
a
permitting
program.
Nothing
in
this
subsection
should
be
construed
to
limit
the
Administrator's
ability
to
enforce
permits
issued
by
a
State.

(
f)
Prohibition.­
No
partial
permit
program
shall
be
approved
unless,
at
a
minimum,
it
applies,
and
ensures
compliance
with,
this
title
and
each
of
the
following:

(
1)
All
requirements
established
under
title
IV
applicable
to
"
affected
sources."

(
2)
All
requirements
established
under
section
112
applicable
to
"
major
sources",
"
area
sources,"
and
"
new
sources."

(
3)
All
requirements
of
title
I
(
other
than
section
112)
applicable
to
sources
required
to
have
a
permit
under
this
title.
Approval
of
a
partial
program
shall
not
relieve
the
State
of
its
obligation
to
submit
a
complete
program,
nor
from
the
application
of
any
sanctions
under
this
Act
for
failure
to
submit
an
approvable
permit
program.

(
g)
Interim
Approval.­
If
a
program
(
including
a
partial
permit
program)
submitted
under
this
title
substantially
meets
the
requirements
of
this
title,
but
is
not
fully
approvable,
the
Administrator
may
by
rule
grant
the
program
interim
approval.
In
the
notice
of
final
rulemaking,
the
Administrator
shall
specify
the
changes
that
must
be
made
before
the
program
can
receive
full
approval.
An
interim
approval
under
this
subsection
shall
expire
on
a
date
set
by
the
Administrator
not
later
than
2
years
after
such
approval,
and
may
not
be
renewed.
For
the
period
of
any
such
interim
approval,
the
provisions
of
subsection
(
d)(
2),
and
the
obligation
of
the
Administrator
to
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2000
promulgate
a
program
under
this
title
for
the
State
pursuant
to
subsection
(
d)(
3),
shall
be
suspended.

Such
provisions
and
such
obligation
of
the
Administrator
shall
apply
after
the
expiration
of
such
interim
approval.

(
h)
Effective
Date.­
The
effective
date
of
a
permit
program,
or
partial
or
interim
program,

approved
under
this
title,
shall
be
the
effective
date
of
approval
by
the
Administrator.
The
effective
date
of
a
permit
program,
or
partial
permit
program,
promulgated
by
the
Administrator
shall
be
the
date
of
promulgation.

(
i)
Administration
and
Enforcement.­
(
1)
Whenever
the
Administrator
makes
a
determination
that
a
permitting
authority
is
not
adequately
administering
and
enforcing
a
program,

or
portion
thereof,
in
accordance
with
the
requirements
of
this
title,
the
Administrator
shall
provide
notice
to
the
State
and
may,
prior
to
the
expiration
of
the
18­
month
period
referred
to
in
paragraph
(
2),
in
the
Administrator's
discretion,
apply
any
of
the
sanctions
specified
in
section
179(
b).

(
2)
Whenever
the
Administrator
makes
a
determination
that
a
permitting
authority
is
not
adequately
administering
and
enforcing
a
program,
or
portion
thereof,
in
accordance
with
the
requirements
of
this
title,
18
months
after
the
date
of
the
notice
under
paragraph
(
1),
the
Administrator
shall
apply
the
sanctions
under
section
179(
b)
in
the
same
manner
and
subject
to
the
same
deadlines
and
other
conditions
as
are
applicable
in
the
case
of
a
determination,
disapproval,
or
finding
under
section
179(
a).

(
3)
The
sanctions
under
section
179(
b)(
2)
shall
not
apply
pursuant
to
this
subsection
in
any
area
unless
the
failure
to
adequately
enforce
and
administer
the
program
relates
to
an
air
pollutant
for
which
such
area
has
been
designated
a
nonattainment
area.

(
4)
Whenever
the
Administrator
has
made
a
finding
under
paragraph
(
1)
with
respect
to
any
State,
unless
the
State
has
corrected
such
deficiency
within
18
months
after
the
date
of
such
finding,

the
Administrator
shall,
2
years
after
the
date
of
such
finding,
promulgate,
administer,
and
enforce
a
program
under
this
title
for
that
State.
Nothing
in
this
paragraph
shall
be
construed
to
affect
the
validity
of
a
program
which
has
been
approved
under
this
title
or
the
authority
of
any
permitting
authority
acting
under
such
program
until
such
time
as
such
program
is
promulgated
by
the
Administrator
under
this
paragraph.
[
42
U.
S.
C.
7661a]

SEC.
503.
PERMIT
APPLICATIONS.

(
a)
APPLICABLE
DATE.­
Any
source
specified
in
section
502(
a)
shall
become
subject
to
a
permit
program,
and
required
to
have
a
permit,
on
the
later
of
the
following
dates­

(
1)
the
effective
date
of
a
permit
program
or
partial
or
interim
permit
program
applicable
to
the
source;
or
(
2)
the
date
such
source
becomes
subject
to
section
502(
a).

(
b)
COMPLIANCE
PLAN.­(
1)
The
regulations
required
by
section
502(
b)
shall
include
a
requirement
that
the
applicant
submit
with
the
permit
application
a
compliance
plan
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
35
11
January
2000
describing
how
the
source
will
comply
with
all
applicable
requirements
under
this
Act.
The
compliance
plan
shall
include
a
schedule
of
compliance,
and
a
schedule
under
which
the
permittee
will
submit
progress
reports
to
the
permitting
authority
no
less
frequently
than
every
6
months.

(
2)
The
regulations
shall
further
require
the
permittee
to
periodically
(
but
no
less
frequently
than
annually)
certify
that
the
facility
is
in
compliance
with
any
applicable
requirements
of
the
permit,

and
to
promptly
report
any
deviations
from
permit
requirements
to
the
permitting
authority.

(
c)
DEADLINE.­
Any
person
required
to
have
a
permit
shall,
not
later
than
12
months
after
the
date
on
which
the
source
becomes
subject
to
a
permit
program
approved
or
promulgated
under
this
title,
or
such
earlier
date
as
the
permitting
authority
may
establish,
submit
to
the
permitting
authority
a
compliance
plan
and
an
application
for
a
permit
signed
by
a
responsible
official,
who
shall
certify
the
accuracy
of
the
information
submitted.
The
permitting
authority
shall
approve
or
disapprove
a
completed
application
(
consistent
with
the
procedures
established
under
this
title
for
consideration
of
such
applications),
and
shall
issue
or
deny
the
permit,
within
18
months
after
the
date
of
receipt
thereof,
except
that
the
permitting
authority
shall
establish
a
phased
schedule
for
acting
on
permit
applications
submitted
within
the
first
full
year
after
the
effective
date
of
a
permit
program
(
or
a
partial
or
interim
program).
Any
such
schedule
shall
assure
that
at
least
one­
third
of
such
permits
will
be
acted
on
by
such
authority
annually
over
a
period
of
not
to
exceed
3
years
after
such
effective
date.
Such
authority
shall
establish
reasonable
procedures
to
prioritize
such
approval
or
disapproval
actions
in
the
case
of
applications
for
construction
or
modification
under
the
applicable
requirements
of
this
Act.

(
d)
TIMELY
AND
COMPLETE
APPLICATIONS.­
Except
for
sources
required
to
have
a
permit
before
construction
or
modification
under
the
applicable
requirements
of
this
Act,
if
an
applicant
has
submitted
a
timely
and
complete
application
for
a
permit
required
by
this
title
(
including
renewals),
but
final
action
has
not
been
taken
on
such
application,
the
source's
failure
to
have
a
permit
shall
not
be
a
violation
of
this
Act,
unless
the
delay
in
final
action
was
due
to
the
failure
of
the
applicant
timely
to
submit
information
required
or
requested
to
process
the
application.
No
source
required
to
have
a
permit
under
this
title
shall
be
in
violation
of
section
502(
a)
before
the
date
on
which
the
source
is
required
to
submit
an
application
under
subsection
(
c).

(
e)
COPIES;
AVAILABILITY.­
A
copy
of
each
permit
application,
compliance
plan
(
including
the
schedule
of
compliance),
emissions
or
compliance
monitoring
report,
certification,
and
each
permit
issued
under
this
title,
shall
be
available
to
the
public.
If
an
applicant
or
permittee
is
required
to
submit
information
entitled
to
protection
from
disclosure
under
section
114(
c)
of
this
Act,

the
applicant
or
permittee
may
submit
such
information
separately.
The
requirements
of
section
114(
c)
shall
apply
to
such
information.
The
contents
of
a
permit
shall
not
be
entitled
to
protection
under
section
114(
c).

SEC.
504.
PERMIT
REQUIREMENTS
AND
CONDITIONS.
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
36
11
January
2000
(
a)
CONDITIONS.­
Each
permit
issued
under
this
title
shall
include
enforceable
emission
limitations
and
standards,
a
schedule
of
compliance,
a
requirement
that
the
permittee
submit
to
the
permitting
authority,
no
less
often
than
every
6
months,
the
results
of
any
required
monitoring,
and
such
other
conditions
as
are
necessary
to
assure
compliance
with
applicable
requirements
of
this
Act,

including
the
requirements
of
the
applicable
implementation
plan.

(
b)
MONITORING
AND
ANALYSIS.­
The
Administrator
may
by
rule
prescribe
procedures
and
methods
for
determining
compliance
and
for
monitoring
and
analysis
of
pollutants
regulated
under
this
Act,
but
continuous
emissions
monitoring
need
not
be
required
if
alternative
methods
are
available
that
provide
sufficiently
reliable
and
timely
information
for
determining
compliance.
Nothing
in
this
subsection
shall
be
construed
to
affect
any
continuous
emissions
monitoring
requirement
of
title
IV,
or
where
required
elsewhere
in
this
Act.

(
c)
INSPECTION,
ENTRY,
MONITORING,
CERTIFICATION,
AND
REPORTING.­
Each
permit
issued
under
this
title
shall
set
forth
inspection,
entry,
monitoring,
compliance
certification,

and
reporting
requirements
to
assure
compliance
with
the
permit
terms
and
conditions.
Such
monitoring
and
reporting
requirements
shall
conform
to
any
applicable
regulation
under
subsection
(
b).
Any
report
required
to
be
submitted
by
a
permit
issued
to
a
corporation
under
this
title
shall
be
signed
by
a
responsible
corporate
official,
who
shall
certify
its
accuracy.

§
70.5(
c)
Standard
applications
form
and
required
information.
The
State
program
under
this
part
shall
provide
for
a
standard
application
form
or
forms.
Information
as
described
below
for
each
emissions
unit
at
a
part
70
source
shall
be
included
in
the
application.
The
Administrator
may
approve
as
part
of
a
State
program
a
list
of
insignificant
activities
and
emissions
levels
which
need
not
be
included
in
permit
applications.
However,
for
insignificant
activities
which
are
exempted
because
of
size
or
production
rate,
a
list
of
such
insignificant
activities
must
be
included
in
the
application.
An
application
may
not
omit
information
needed
to
determine
the
applicability
of,
or
to
impose,
any
applicable
requirement,
or
to
evaluate
the
fee
amount
required
under
the
schedule
approved
pursuant
to
§
70.9
of
this
part.
The
permitting
authority
may
use
discretion
in
developing
application
forms
that
best
meet
program
needs
and
administrative
efficiency.
The
forms
and
attachments
chosen,
however,
shall
include
the
elements
specified
below:

(
1)
Identifying
information,
including
company
name
and
address
(
or
plant
name
and
address
if
different
from
the
company
name),
owner's
name
and
agent,
and
telephone
number
and
names
of
plant
site
manager/
contact.

(
2)
A
description
of
the
source's
processes
and
products
(
by
Standard
Industrial
Classification
Code)
including
any
associated
alternative
scenario
identified
by
the
source.

(
3)
The
following
emission
related
information:

(
i)
All
emissions
of
pollutants
for
which
the
source
is
major,
and
all
emissions
of
regulated
air
pollutants.
A
permit
application
shall
describe
all
emissions
of
regulated
air
pollutants
emitted
from
any
emissions
unit,
except
where
such
units
are
exempted
under
this
paragraph
(
c)
of
this
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
37
11
January
2000
section.
The
permitting
authority
shall
require
additional
information
related
to
the
emissions
of
air
pollutants
sufficient
to
verify
which
requirements
are
applicable
to
the
source,
and
other
information
necessary
to
collect
any
permit
fees
owed
under
the
fee
schedule
approved
pursuant
to
§
70.9(
b)
of
this
part.

(
ii)
Identification
and
description
of
all
points
of
emissions
described
in
paragraph
(
c)(
3)(
i)

of
this
section
in
sufficient
detail
to
establish
the
basis
for
fees
and
applicability
of
requirements
of
the
Act.

(
iii)
Emissions
rate
in
tpy
and
in
such
terms
as
are
necessary
to
establish
compliance
consistent
with
the
applicable
standard
reference
test
method.

(
iv)
The
following
information
to
the
extent
it
is
needed
to
determine
to
regulate
emissions:

Fuels,
fuel
use,
raw
materials,
production
rates,
and
operating
schedules.

(
v)
Identification
and
description
of
air
pollution
control
equipment
and
compliance
monitoring
devices
or
activities.

(
vi)
Limitations
on
source
operation
affecting
emissions
or
any
work
practice
standards,

where
applicable,
for
all
regulated
pollutants
at
the
part
70
source.

(
vii)
Other
information
required
by
any
applicable
requirement
(
including
information
related
to
stack
height
limitations
developed
pursuant
to
section
123
of
the
Act.)

(
viii)
Calculations
on
which
the
information
on
paragraphs
(
c)(
3)(
i)
through
(
c)(
3)(
vii)
of
this
section
is
based.

(
4)
The
following
air
pollution
control
requirements:

(
i)
Citation
and
description
of
all
applicable
requirements,
and
(
ii)
Description
of
or
reference
to
any
applicable
test
method
for
determining
compliance
with
each
applicable
requirement.

(
5)
Other
specific
information
that
may
be
necessary
to
implement
and
enforce
other
applicable
requirements
of
the
Act
or
of
this
part
or
to
determine
the
applicability
of
such
requirements.

(
6)
An
explanation
of
any
proposed
exemptions
from
otherwise
applicable
requirements.

(
7)
Additional
information
as
determined
to
be
necessary
by
the
permitting
authority
to
define
alternative
operating
scenarios
identified
by
the
source
pursuant
to
§
70.6(
a)(
9)
of
this
part
or
to
define
permit
terms
and
conditions
implementing
§
70.4(
b)(
12)
or
§
70.6(
a)(
10)
of
this
part.

(
8)
A
compliance
plan
for
all
part
70
sources
that
contains
all
the
following:

(
i)
A
description
of
the
compliance
status
of
the
source
with
respect
to
all
applicable
requirements.

(
ii)
A
description
as
follows:

(
A)
For
applicable
requirements
with
which
the
source
is
in
compliance,
a
statement
that
the
source
will
continue
to
comply
with
such
requirements.

(
B)
For
applicable
requirements
that
will
become
effective
during
the
permit
term,
a
statement
that
the
source
will
meet
such
requirements
on
a
timely
basis.
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
38
11
January
2000
(
C)
For
requirements
for
which
the
source
is
not
in
compliance
at
the
time
or
permit
issuance,

a
narrative
description
of
how
the
source
will
achieve
compliance
with
such
requirements.

(
iii)
A
compliance
schedule
as
follows:

(
A)
For
applicable
requirements
with
which
the
source
is
in
compliance,
a
statement
that
the
source
will
continue
to
comply
with
such
requirements.

(
B)
For
applicable
requirements
that
will
become
effective
during
the
permit
term,
a
statement
that
the
source
will
meet
such
requirements
on
a
timely
basis.
A
statement
that
the
source
will
meet
in
a
timely
manner
applicable
requirements
that
become
effective
during
the
permit
term
shall
satisfy
this
provision,
unless
a
more
detailed
schedule
is
expressly
required
by
the
applicable
requirement.

(
C)
A
schedule
of
compliance
for
sources
that
are
not
in
compliance
with
all
applicable
requirements
at
the
time
of
permit
issuance.
Such
a
schedule
shall
include
a
schedule
of
remedial
measures,
including
an
enforceable
sequence
of
actions
with
milestones,
leading
to
compliance
with
any
applicable
requirements
for
which
the
source
will
be
in
noncompliance
at
the
time
of
permit
issuance.
This
compliance
schedule
shall
resemble
and
be
at
least
as
stringent
as
that
contained
in
any
judicial
consent
decree
or
administrative
order
to
which
the
source
is
subject.
Any
such
schedule
of
compliance
shall
be
supplemental
to
and
shall
not
sanction
noncompliance
with,
the
applicable
requirements
on
which
it
is
based.

(
iv)
A
schedule
for
submission
of
certified
progress
reports
no
less
frequently
than
every
6
months
for
sources
required
to
have
a
schedule
of
compliance
to
remedy
a
violation.

(
v)
The
compliance
plan
content
requirements
specified
in
this
paragraph
shall
apply
and
be
included
in
the
acid
rain
portion
of
a
compliance
plan
for
an
affected
source,
except
as
specifically
superseded
by
regulations
promulgated
under
title
IV
of
the
Act
with
regard
to
the
schedule
and
method(
s)
the
source
will
use
to
achieve
compliance
with
the
acid
rain
emissions
limitations.

(
9)
Requirements
for
compliance
certification,
including
the
following:

(
i)
A
certification
of
compliance
with
all
applicable
requirements
by
a
responsible
official
consistent
with
paragraph
(
d)
of
this
section
and
section
114(
a)(
3)
of
the
Act;

(
ii)
A
statement
of
methods
used
for
determining
compliance,
including
a
description
of
monitoring,
recordkeeping,
and
reporting
requirements
and
test
methods;

(
iii)
A
schedule
for
submission
of
compliance
certifications
during
the
permit
term,
to
be
submitted
no
less
frequently
than
annually,
or
more
frequently
if
specified
by
the
underlying
applicable
requirement
or
by
the
permitting
authority;
and
(
iv)
A
statement
indicating
the
source's
compliance
status
with
any
applicable
enhanced
monitoring
and
compliance
certification
requirements
of
the
Act.

(
10)
The
use
of
nationally­
standardized
forms
for
acid
rain
portions
of
permit
applications
and
compliance
plans,
as
required
by
regulations
promulgated
under
title
IV
of
the
Act.

(
d)
Any
application
form,
report,
or
compliance
certification
submitted
pursuant
to
these
regulations
shall
contain
certification
by
a
responsible
official
of
truth,
accuracy,
and
completeness.
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
39
11
January
2000
This
certification
and
any
other
certification
required
under
this
part
shall
state
that,
based
on
information
and
belief
formed
after
reasonable
inquiry,
the
statements
and
information
in
the
document
are
true,
accurate,
and
complete.
ATTACHMENT
2
OCTOBER
18,
1999
FEDERAL
REGISTER
NOTICE
ATTACHMENT
3
ASSUMPTIONS
FOR
PART
70
ICR
RENEWAL
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
44
11
January
2000
ASSUMPTIONS
TIME
PERIOD
OF
ICR
The
time
period
covered
by
this
ICR
is
February
28,
2000
to
February
28,
2003
(
shown
as
March
2000
to
March
2003
for
these
analyses)

SOURCE
POPULATION
!
Total
population
of
title
V
sources
as
of
November
1999
=
20,660
o
New
Jersey
estimates
an
additional
114
sources
will
be
added
to
their
program
o
Applications
for
the
114
sources
will
be
received
during
first
year
of
ICR
o
Permits
for
those
114
sources
are
projected
to
be
issued
in
year
3
of
this
ICR
o
This
ICR
projects
that
50
additional
sources
will
become
subject
to
title
V
each
year
of
this
ICR
for
a
total
of
150
additional
sources
during
this
ICR
period.

RATE
OF
PERMIT
ISSUANCE
!
Assume
48%
of
the
permits
will
be
issued
by
March
2000
o
8,254
sources
(
40%
of
total
population)
were
issued
permits
as
of
November
1999
o
Assume
permit
issuance
rate
of
2%
per
month
between
November
1999
and
March
2000
(
i.
e.,
an
additional
8%)

o
Around
1,653
additional
sources
(
i.
e.,
the
8%
of
20,660)
will
therefore
be
issued
permits
between
November
1999
and
March
2000
o
Total
is
1,653
+
8,254
=
9,907
by
March
2000
(
leaving
10,753
sources
to
be
issued
permits
during
the
period
of
this
ICR)

!
Assume
a
3%
issuance
rate
per
month
after
March
2000
o
Therefore,
it
is
estimated
that
36%
additional
sources
will
be
issued
permits
between
March
2000
and
March
2001
(
i.
e.,
7,438
sources
issued
permits
in
the
first
year
of
this
ICR)

o
Total
of
17,345
sources
issued
permits
by
March
2001
(
9,907
+
7,438),
the
end
of
year
1
of
this
ICR
o
The
remaining
sources
will
be
issued
permits
by
March
2002
(
i.
e.,
3,315
additional
permits
during
year
2
of
this
ICR)
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
45
11
January
2000
GENERAL
PERMITS
!
As
of
November
1999,
38%
of
the
sources
already
issued
permits
(
i.
e.,
3,128
of
the
8,254
sources
already
issued
permits)
are
covered
by
23
general
permits
­
this
is
15%
of
the
total
source
population
of
20,660
!
Assume
ultimately
20%
of
all
sources
(
i.
e.,
an
additional
5%)
will
be
covered
by
general
permits,
because
general
permits
are
usually
the
first
to
be
issued
and,
therefore,
the
number
of
sources
covered
by
general
permits
will
fall
off
sharply
!
20%
of
the
total
source
population
=
4,132
sources
which
will
be
covered
by
general
permits
(
4,132
­
3,128
already
covered
=
1,004
general
permit
sources
to
be
covered
by
an
estimated
10
general
permits
during
the
term
of
this
ICR)

!
Assume
the
10
general
permits
covering
the
1,004
sources
will
be
issued
during
year
1
of
this
ICR
NEW
SOURCES:

EPA
estimates
there
will
be
approximately
50
new
major
sources
nationwide
applying
for
a
title
V
permit
each
year
during
the
term
of
this
ICR
(
150
total
for
the
3
years
of
this
ICR).
For
this
ICR,
given
the
workload
of
issuing
permits,
it
is
assumed
these
permits
will
be
issued
during
the
third
year
of
this
ICR.
In
New
Jersey,
114
sources
will
become
subject
to
the
program
and
will
submit
permit
applications
during
the
period
of
this
ICR.
Assume
these
sources
will
be
permitted
in
year
3.

PERMIT
ISSUANCE
RATE
ACCOUNTING
FOR
GENERAL
PERMITS
AND
NEW
SOURCES
!
Single
source
permits
(
other
than
general
permits)
which
will
be
subject
to
the
full
permit
issuance
process
o
10,753
sources
will
be
issued
permits
during
the
period
of
the
ICR
(
7,438
in
year
1
and
3,315
in
year
2)

o
1,004
of
these
sources
will
be
covered
by
general
permits
issued
in
year
1
o
7,438
­
1,004
=
6,434
single
source
permits
issued
during
year
1
of
the
ICR
o
6,434
year
1
plus
3,315
year
2
permits
=
9,749
single
source
permits
issued
during
this
ICR
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
46
11
January
2000
o
Add
in
the
10
general
permits,
150
new
sources,
and
the
114
sources
in
New
Jersey:

9,749
+
10
+
150
+
114
=
a
total
of
10,023
permits
issued
during
the
3­
year
period
of
this
ICR
(
10,013
will
be
single
source
permits)

!
Summary
of
new
permit
issuance
by
year:

o
Year
1
­
6,434
+
10
general
permits
=
6,444
permits
issued
o
Year
2
­
3,315
permits
issued
o
Year
3
­
264
permits
issued
for
new
sources
PERMIT
REVISION
RATES
!
Sources
covered
by
general
permits
will
not
apply
for
permit
revisions,
so
these
sources
are
removed
for
purposes
of
this
analysis
!
8,254
sources
were
covered
by
permits
as
of
November
1999
of
which
3,128
were
sources
covered
by
general
permits
(
8,254
­
3,128
=
5,126
single
source
permits)

!
At
a
2%
per
month
issuance
rate,
an
additional
1,653
sources
will
be
issued
permits
between
November
1999
and
March
2000
(
assume
all
are
single
source
permits)

!
Number
of
single
source
permits
issued
by
the
beginning
of
this
ICR
(
i.
e.,
March
2000)
for
which
permit
revisions
will
be
made
during
year
1
of
this
ICR:

o
5,126
single
source
permits
issued
by
November
1999
o
1,653
sources
covered
by
permits
between
November
1999
and
March
2000
o
5,126
+
1,653
=
6,779
single
source
permits
issued
by
March
2000
!
Single
source
permits
issued
as
of
beginning
of
year
2
(
i.
e.,
March
2001)
of
this
ICR
(
for
which
permit
revisions
will
be
made
during
year
2)
is
6,434
issued
during
year
1
plus
the
6,779
already
issued
=
13,213
single
source
permits
!
Single
source
permits
issued
as
of
beginning
of
year
3
(
i.
e.,
March
2002)
of
this
ICR
(
for
which
permit
revisions
will
be
made
during
year
3)
is
3,315
issued
during
year
2
plus
the
13,213
already
issued
=
16,528
single
source
permits
!
Summary:

o
Permits
for
which
revisions
will
be
made
during
year
1
­
6,779
o
Permits
for
which
revisions
will
be
made
during
year
2
­
13,213
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
47
11
January
2000
o
Permits
for
which
revisions
will
be
made
during
year
3
­
16,528
PERMIT
RENEWAL:

!
By
March
1997,
1493
sources
had
been
issued
permits
(
all
within
the
previous
year,
renewal
therefore
will
be
during
the
year
from
March
2001
to
March
2002)
­
assume
16%,
or
239,
are
sources
covered
by
general
permits
(
this
is
from
past
data)
leaving
1,254
renewals
during
year
2
of
this
ICR
!
By
March
1998,
an
additional
1,952
sources
had
been
issued
permits
­
these
will
be
up
for
renewal
between
March
2002
and
March
2003
­
assume
16%,
or
312,
are
sources
covered
by
general
permits
leaving
1,640
renewals
during
year
3
of
this
ICR
!
Summary:

o
1493
+
1952
=
3445
total
sources
covered
by
permits
of
which
239
+
312
=
551
are
general
permits
o
3445
­
551
=
2894
single
source
permits
which
will
have
to
be
renewed
during
this
ICR
period
(
1,254
in
year
2
and
1,640
in
year
3)

SOURCES
REPORTING
MONITORING
AND
COMPLIANCE
STATUS
All
sources
with
issued
permits
(
including
those
covered
by
general
permits)
will
report
monitoring
data
semi­
annually
and
compliance
certifications
annually.
Sources
with
issued
permits
are
as
follows:

o
9,907
sources
will
be
covered
by
issued
permits
at
the
beginning
of
this
ICR
and
will
be
submitting
reports
during
year
1
of
this
ICR.

o
7,438
sources
will
be
covered
by
permits
issued
in
year
1
(
6,434
covered
by
single
source
permits
and
1,004
covered
by
general
permits).
7,438
+
9,907
sources
already
covered
by
permits
=
17,345
sources
that
will
be
covered
by
permits
by
the
beginning
of
year
2
and
will
be
submitting
reports
during
year
2.

o
3,315
sources
will
be
covered
by
permits
issued
in
year
2.
3,315
+
17,345
sources
already
covered
by
permits
=
20,660
sources
that
will
be
covered
by
permits
by
the
beginning
of
year
3
and
will
be
submitting
reports
during
year
3.

SYNTHETIC
MINOR
PERMITS:
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
48
11
January
2000
All
synthetic
minor
permits
had
been
issued
prior
to
March
2000
so
no
burden
is
included
during
the
term
of
this
ICR
PERMIT
APPLICATIONS
During
the
period
of
this
ICR,
it
is
assumed
150
new
sources
will
submit
permit
applications
plus
114
sources
in
New
Jersey
will
submit
applications.
The
total
will
be
150
+
114
=
264
permit
applications.

SUMMARY
TABLE
OF
ASSUMPTIONS
ITEM
NUMBER
COMMENTS
Number
of
sources
subject
to
part
70
20,660
Number
of
sources
already
issued
permits
at
the
beginning
of
this
ICR
9,907
(
6,779
single
source)
3,128
sources
covered
by
general
permits
Number
of
sources
which
will
become
subject
to
part
70
during
this
ICR
264
50
each
year
plus
114
from
New
Jersey
Sources
issued
permits
in
year
1
of
this
ICR
7,438
(
6,434
single
source)
1,004
sources
covered
by
10
general
permits
Sources
issued
permits
in
year
2
of
this
ICR
3,315
All
single
source
permits
Sources
issued
permits
in
year
3
of
this
ICR
264
150
new
sources
which
become
subject
to
part
70
plus
114
New
Jersey
sources
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
49
11
January
2000
Total
issued
permits
during
this
ICR
10,023
(
10,013
single
source)
6,434
single
source
permits
and
10
general
permits
in
year
1,
3,315
single
source
permits
in
year
2,
264
single
source
permits
in
year
3
Issued
permits
for
which
revisions
will
be
made:
N/
A
All
are
single
source
permits
o
Year
1
6,779
Single
source
permits
issued
at
beginning
of
ICR
o
Year
2
13,213
6,779
already
issued
plus
6,434
single
source
permits
issued
in
year
1
o
Year
3
16,528
13,213
already
issued
plus
3,315
single
source
permits
issued
in
year
2
Permits
subject
to
renewal:
N/
A
2,894
total
o
Year
2
1,254
o
Year
3
1,640
Permit
applications
submitted
during
this
ICR
264
150
new
sources
plus
114
New
Jersey
sources
Sources
submitting
semiannual
monitoring
and
annual
compliance
certification
reports
N/
A
From
all
sources,
including
those
under
general
permits
o
Year
1
9,907
o
Year
2
17,345
o
Year
3
20,660
ATTACHMENT
4
WORKSHEETS
FOR
BURDEN
ESTIMATES
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
51
11
January
2000
WORKSHEETS
The
EPA
contacted
respondents
from
the
regulated
community
and
EPA
Regional
Offices
to
obtain
information
to
be
used
as
the
basis
for
calculating
burden
hour
estimates
for
implementing
the
part
70
regulations.
The
respondents
are
listed
in
section
3.3.
Tables
1,
2,
and
3
below
are
the
worksheets
used
for
calculating
burden
estimates.

TABLE
1
PERMITTING
AUTHORITY
ACTIVITIES
ACTIVITY
BURDEN
PER
INDIVIDUAL
PERMIT
OR
PROGRAM
COMMENTS*
TOTAL
PROGRAM
BURDEN
FOR
3
YEARS
Program
administration:

Responding
to
inquiries
about
the
program,
developing
internal
and
external
program
guidance,

planning,
attending
program
training,
permit
fee
collection,

providing
source
training,

attending
EPA
meetings
and
conferences,
providing
public
education,
and
other
program
related
activities.
3,500
hrs.
per
agency
112
agencies
392,000
hrs.

per
year
1,176,000
for
3
years
of
ICR
Reviewing
a
permit
application,

including
discussions
with
a
source
concerning
the
permit
application.
100
hrs./
permit
Assume
264
new
sources
will
submit
permit
applications
nationwide
26,400
for
3
years
of
ICR
Preparing
a
draft
permit,
including
contact
with
the
source.
150
hrs./
permit
10,023
permits
issued
during
3­

year
ICR
time
period
1,503,450
for
3
years
of
ICR
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
52
11
January
2000
Providing
notice
to
the
public,

EPA,
and
affected
States
of
the
comment
period
on
a
draft
permit.
10
hrs./
permit
10,023
draft
permits
during
ICR
time
period
100,230
for
3
years
of
ICR
Holding
a
public
hearing
on
a
permit.
100
hrs./
hearing
Assume
a
hearing
for
1
in
50
of
the
10,023
new
single
source
permits
(
i.
e.,

200
hearings)
20,000
for
3
years
of
ICR
Interaction
with
EPA
on
a
proposed
permit,
including
negotiations,
re­
drafting,
and
formal
EPA
objections
(
including
those
attributable
to
public
petitions).
20
hrs./
permit
10,023
proposed
permits
during
ICR
time
period
200,460
for
3
years
of
ICR
Analyzing
public
comments
and
revising
the
permit
accordingly
40
hrs./
permit
Assume
comments
on
1
in
10
permits
(
i.
e.,
1,002
permits)
40,080
for
3
years
of
ICR
Issuing
the
permit,
including
web
activities
and
source
notification.
8
hrs./
permit
10,023
new
permits
issued
during
ICR
time
period
80,184
for
3
years
of
ICR
Administering
general
permits
(
Burden
for
issuing
general
permits
included
with
other
permit
issuance
burden)
80
hrs.
per
agency
per
year
112
agencies
8,960
hrs.
per
year
26,880
for
3
years
of
ICR
Revising
a
permit.
N/
A
Number
of
issued
single
source
permits:

year
1
­
6,779
year
2
­
13,213
year
3
­
16,528
N/
A
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
53
11
January
2000
°
Significant
(
1
out
of
every
10
issued
permits
per
year)
60
hrs.
each
Significant
permit
modifications:

678
­
yr
1
1,321
­
yr
2
1,653
­
yr
3
Hours:

40,680
­
yr
1
79,260
­
yr
2
99,180
­
yr
3
219,120
for
3
years
of
ICR
°
Minor
(
1
out
of
every
2
issued
permits
per
year)
20
hrs.
each
Minor
permit
modifications:

3,390
­
yr
1
6,607
­
yr
2
8,264
­
yr
3
Hours:

67,800
­
yr
1
132,140
­
yr
2
165,280
­
yr
3
365,220
for
3
years
of
ICR
°
Administrative
(
1
out
of
every
2
issued
permits
per
year)
5
hrs.
each
Administrative
amendments:

3,390
­
yr
1
6,607
­
yr
2
8,264
­
yr
3
Hours:

16,950
­
yr
1
33,035
­
yr
2
41,320
­
yr
3
91,305
for
3
years
of
ICR
Renewing
a
permit
(
reviewing
application,
drafting
any
changes,

public
notice,
issuance).
60
hrs./
permit
renewal
2894
renewals
during
ICR
term
173,640
for
3
years
of
ICR
Renewing
a
general
permit
10
hrs./
general
permit
renewal
10
general
permit
renewals
100
for
3
years
of
ICR
Reviewing
two
semiannual
monitoring
reports,
and
the
annual
compliance
certification.
15
hrs./
permit
(
5
hrs.
each)
Number
of
issued
single
source
permits
for
which
reports
will
be
submitted:

year
1
­
9,907
year
2
­
17,345
year
3
­
20,660
Hours:

148,605­
yr.
1
260,175
­
yr.
2
309,900
­
yr.
3
718,680
for
3
years
of
ICR
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
54
11
January
2000
Preparing
and
submitting
to
EPA
annually
a
report
of
the
State's
enforcement
activities.
40
hrs./
agency
112
agencies
4,480
hrs.
per
year
13,440
for
3
years
of
ICR
*
See
the
Assumptions
in
Attachment
3
for
the
derivation
of
some
of
these
numbers.

TOTAL
BURDEN
HOURS
FOR
PERMITTING
AUTHORITIES:

4,755,189
hours
for
3
years
÷
3
=
1,585,063
hours
per
year
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
55
11
January
2000
TABLE
2
SOURCE
ACTIVITIES
ACTIVITY
BURDEN
PER
SOURCE
COMMENTS*
TOTAL
PROGRAM
BURDEN
FOR
3
YEARS
Preparing
a
permit
application,

including
internal
meetings,

permitting
authority
discussions,

management
and
legal
department
involvement,
responsible
official
certification,
contractor
services.
300
hrs.
Assume
264
permit
applications
during
3
years
of
ICR
79,200
for
3
years
of
ICR
Interaction
with
the
permitting
authority
on
draft
permit
development.
40
hrs.
Assume
264
new
single
source
permits
issued
during
3
years
of
ICR
10,560
for
3
years
of
ICR
Development
of
periodic
monitoring
gap­
filling.
40
hrs.
per
source
Assume
gap­
filling
for
50%
of
10,013
single
source
permits
issued
during
3
years
of
ICR
(
i.
e.,
5,007)
200,280
for
3
years
of
ICR
Public
hearing
participation.
10
hrs.
(
1
in
50
new
single
source
permits
get
hearing)
10,013
new
permits
during
ICR
period
1
in
50
=
200
sources
2,000for
3
years
of
ICR
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
56
11
January
2000
Operation
of
gap­
filling
periodic
monitoring
(
annual
burden
to
operate
monitors,
keep
records,

etc.).
200
hrs.
per
year
Assume
gap­
filling
for
50%
of
single
source
permits:

3,390
­
yr.
1
6,607
yr.
2
8,264
­
yr.
3
Hours:

678,000
­
yr.
1
1,321,400
­
yr.
2
1,652,800
yr
3
3,652,200
for
3
years
of
ICR
Preparing
semi­
annual
monitoring
data
reports,
including
data
analysis,
responsible
official
certification,
and
report
submission
(
annual
burden
for
both
reports).

Include
preparing
and
submitting
annual
compliance
certification.
80
hrs.
per
year
Issued
single
source
permits:

9,907
­
yr.
1
17,345
­
yr.
2
20,660
­
yr.
3
Hours:

792,560
­
yr.
1
1,387,600yr.
2
1,652,800yr.
3
3,832,960for
3
years
of
ICR
Preparing
application
for
permit
revisions.

°
Significant
permit
modifications
(
1
out
of
every
10
permits
per
year)
80
hrs.
each
Significant
permit
revisions:

678
­
yr
1
1,321
­
yr
2
1,653
­
yr
3
Hours:

54,240
­
yr.
1
105,680
­
yr.
2
132,240
­
yr.
3
292,160
for
3
years
of
ICR
°
Minor
permit
modifications
(
1
out
of
every
2
permits
per
year)
40
hrs.
each
Minor
permit
modifications:

3,390
­
yr.
1
6,607­
yr.
2
8,264
­
yr.
3
Hours:

135,600yr.
1
264,280­
yr.
2
330,560
­
yr.
3
730,440
for
3
years
of
ICR
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
57
11
January
2000
°
Administrative
amendments
(
1
out
of
every
2
permits
per
year)
8
hrs.
each
Administrative
amendments:

3,390
­
yr.
1
6,607
­
yr.
2
8,264
­
yr.
3
Hours:

27,120
­
yr.
1
52,856
­
yr.
2
66,112
­
yr.
3
146,088
for
3
years
of
ICR
Preparing
an
application
for
permit
renewal.
200
hrs.
2,894
renewals
during
ICR
term
578,800
for
3
years
of
ICR
Re­
applying
for
coverage
under
a
general
permit
2
hrs.
551
sources
1,102
for
3
years
of
ICR
Other
activities
associated
with
permit
renewal,
including
discussions
with
permitting
authority
and
public
hearing
participation.
20
hrs.
2,894
renewals
during
ICR
term
57,880
for
3
years
of
ICR
*
See
the
Assumptions
in
Attachment
3
for
the
derivation
of
some
of
these
numbers.

TOTAL
BURDEN
HOURS
FOR
SOURCES:

9,583,670
hours
for
3
years
÷
3
=
3,194,557
hours
per
year
PROGRAM
TOTAL
4,755,189
hours
(
permitting
authorities)
+
9,583,670
hours
(
sources)
=

14,338,859
total
hours
for
3
years
14,338,859
total
hours
÷
3
=
4,779,620
hours
per
year
for
permitting
authorities
and
sources
to
implement
the
part
70
program
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
58
11
January
2000
TABLE
3
EPA
ACTIVITIES
ACTIVITY
BURDEN
PER
INDIVIDUAL
PERMIT
OR
PROGRAM
COMMENTS
TOTAL
PROGRAM
BURDEN
FOR
3
YEARS
Review
proposed
permits
and
permit
revisions
to
determine
if
they
provide
for
compliance
with
all
applicable
requirements.
N/
A
N/
A
N/
A
o
New
permits
20
hrs.
per
new
permit
Review
25%
of
10,023
permits
issued
during
ICR
term
(
2506
permits)
50,120
for
3
years
of
ICR
o
Significant
permit
revision
8
hrs.
per
revision
Review
all.

Revisions:

678
­
yr.
1
1,321
­
yr.
2
1,653
­
yr.
3
Hours:

5,424
­
yr.
1
10,568
­
yr.
2
13,224
­
yr.
3
29,216
for
3
years
of
ICR
o
Minor
permit
revision
1
hr.
per
revision
Review
all.

Revisions:

3,390
­
yr.
1
6,607
­
yr.
2
8,264
­
yr.
3
Hours
3,390
­
yr.
1
6,607
­
yr.
2
8,264
­
yr.
3
18,261
for
3
years
of
ICR
Information
Collection
Request
For
Part
70
Operating
Permit
Regulations
Page
59
11
January
2000
Review
periodic
monitoring
provisions
of
proposed
permits
or
permit
revisions
to
see
if
they
are
adequate
to
demonstrate
compliance
with
applicable
requirements.
N/
A
Burden
included
above
in
review
of
permits
and
revisions.
N/
A
Consult
with
the
permitting
authority
on
any
problems
detected
in
the
proposed
permit
or
permit
revision.
N/
A
N/
A
N/
A
o
New
permits
8
hrs.
per
new
permit
Consult
on
25%.

10,023
permits
issued
during
ICR
term
(
2,506)
20,048
years
of
ICR
o
Significant
permit
modifications
8
hrs.
per
revision
Consult
on
25%.

Sig.
mods:

678
­
yr.
1
(
170)

1,321
­
yr.
2
(
331)

1,653
­
yr.
3
(
414)
Hours:

1,360
­
yr.
1
2,648
­
yr.
2
3,312
­
yr.
3
7,320
for
3
years
of
ICR
o
Minor
permit
modifications
1
hr.
per
revision
Consult
on
25%.

Minor
mods:

3,390
­
yr.
1
(
848)

6,607
­
yr.
2
(
1652)

8,264
­
yr.
3
(
2066)
Hours:

848
­
yr.
1
1,652
­
yr.
2
2,066
­
yr.
3
4,566
for
3
years
of
ICR
Review
the
annual
report
of
enforcement
activities.
10
hrs.
per
report
112
agencies
3,360
for
3
years
of
ICR
TOTAL
FOR
EPA:
132,891
hours
for
3
years
÷
3
=
44,297
hours
per
year
