INFORMATION
COLLECTION
REQUEST
UPDATE
FOR
THE
40
CFR
PART
64
COMPLIANCE
ASSURANCE
MONITORING
PROGRAM
Agency
Form
No.
EPA
ICR
1663.03
(
For
OMB
Review)

Prepared
by:

Daniel
Charles
Mussatti,
Senior
Economist
United
States
Environmental
Protection
Agency
Office
of
Air
and
Radiation
Office
of
Air
Quality
Planning
and
Standards
Air
Quality
Strategies
and
Standards
Division
Innovative
Strategies
and
Economics
Group
MD­
15
Research
Triangle
Park,
NC
27701
March
2001
EXECUTIVE
SUMMARY
Part
64
of
the
Code
of
Federal
Regulations
(
CFR),
as
defined
in
the
Compliance
Assurance
Monitoring
(
CAM)
Rule,
requires
monitoring,
compliance
certification,
periodic
reporting,
and
record
keeping
information
collections
by
owners
and
operators
of
title
V
sources
with
controlled
pollutant
specific
emissions
units
that
have
a
pre­
control
potential
to
emit
major
amounts
of
regulated
air
pollutants.
CAM
identifies
two
categories
of
emission
units:

$
"
Large"
pollutant
specific
emission
units:
units
that
have
the
potential
to
emit,
with
controls,
the
applicable
regulated
air
pollutant
in
an
amount
equal
to
or
greater
than
the
amount
required
for
a
source
to
be
classified
as
a
major
source,
and
$
"
Other"
pollutant
specific
emission
units:
the
set
of
remaining
affected
pollutant
specific
emission
units
This
analysis
differentiates
between
these
two
types
of
units
because
they
are
subject
to
different
monitoring
requirements
(
e.
g.,
monitoring
frequency
requirements)
and
implementation
timetables
under
part
64.
There
is
no
difference
between
this
Information
Collection
Request
(
ICR)
Update
and
the
ICR
analysis
performed
for
the
original
1997
rule,
other
than
an
adjustment
for
the
general
level
of
prices
over
time
and
the
correction
of
several
computational
errors
that
affected
the
1997
ICR's
bottom
line
estimations
but
not
its
conclusions.
Consequently,
this
update
reports
an
average
annual
burden
to
sources
of
25
thousand
hours
for
"
Large"
units
and
111
thousand
hours
for
"
Other"
units,
with
an
estimated
annualized
cost
of
$
5.9
million
and
$
2.1
million,
respectively,
in
$
2001.
The
Agency
also
estimates
the
average
annual
burden
for
States
and
other
Permitting
Authorities
(
PAs)
at
10
thousand
hours
($
434
thousand)
for
"
Large"
units
and
27
thousand
($
1.2
milliion)
for
"
Other"
units,
for
a
total
annual
PA
burden
and
cost
of
37
thousand
hours
and
$
1.6
million
in
$
2001.
This
analysis
does
not
include
burden
and
cost
estimates
for
Federal
activities
because
the
small
number
of
sources
initiating
monitoring
within
the
three
year
period
covered
by
this
ICR
makes
the
impact
of
these
actions
negligible.
The
CAM
Rule
has
no
significant
impact
on
a
substantial
number
of
small
entities
(
SISNOSE)
and
requires
no
record
keeping
or
reporting
that
could
be
considered
an
unfunded
mandate.

Table
ES­
1
National
Results
Respondent
Type
Number
of
Respondents
Average
Annual
Burden
Hours
Total
Annualized
Cost1
Sources
(
Large
Units)
1,060
24,896
$
5,922
Sources
(
Other
Units)
10,730
110,633
$
2,142
PAs
(
Large
Units)
112
9,869
$
434
PAs
(
Other
Units)
2
112
27,300
$
1,201
Federal
Authority3
1
­­­­
­­­­

Total
172,698
$
9,699
1
In
thousands
of
$
2001
2
There
are
only
112
PAs,
each
of
which
handles
both
"
Large"
and
"
Other"
units
3
Burden
hours
and
costs
are
expected
to
be
negligible.
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
TITLE
OF
THE
INFORMATION
COLLECTION
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1
1(
b)
REGULATORY
BACKGROUND
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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2
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
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2
2(
b)
USE/
USERS
OF
THE
DATA
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4
3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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4
3(
a)
RESPONDENTS
/
SIC
CODES
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4
3(
b)
INFORMATION
REQUESTED
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5
3(
b)(
i)
DATA
ITEMS
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5
FIGURE
3­
1
DATA
REQUIRED
BY
THE
INFORMATION
COLLECTION
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5
3(
b)(
ii)
RESPONDENT
ACTIVITIES
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7
4.
THE
INFORMATION
COLLECTED
C
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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8
4(
a)
AGENCY
ACTIVITIES
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8
4(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
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8
4(
c)
SMALL
ENTITY
FLEXIBILITY
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8
4(
c)(
i)
MEASURES
TO
AVERT
IMPACTS
ON
SMALL
ENTITIES
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9
4(
c)(
ii)
MEASURES
TO
MITIGATE
IMPACTS
ON
SMALL
ENTITIES
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9
4(
d)
COLLECTION
SCHEDULE
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9
4(
e)
ENVIRONMENTAL
JUSTICE
CONSIDERATIONS
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10
5.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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10
5(
a)
NONDUPLICATION
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10
5(
b)
CONSULTATIONS
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10
5(
c)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
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11
5(
d)
GENERAL
GUIDELINES
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11
5(
e)
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
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12
5(
e)(
I)
CONFIDENTIALITY
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12
5(
e)(
ii)
SENSITIVE
QUESTIONS
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12
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
.
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.
12
6(
a)
ESTIMATING
RESPONDENT
BURDEN
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13
6(
b)
ESTIMATING
RESPONDENT
COSTS
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13
6
(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
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14
TABLE
6.1
Total
and
Average
Source
Burden
and
Labor
Costs
for
"
Large"
Sources
­
All
Pollutants
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15
TABLE
6.2
Total
and
Average
Source
Burden
and
Labor
Costs
for
"
Other";
Five
Sample
States
­
All
Pollutants
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16
TABLE
6.3
Permitting
Authority
Annual
Labor
Hours
and
Costs
for
"
Large"
Sources
­
All
Pollutants
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17
TABLE
6.4
Permitting
Authority
Annual
Labor
Hours
and
Costs
for
"
Other"
Sources
­
All
Pollutants
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17
6
(
d)
SUMMARY
BURDEN
HOUR
AND
COST
ESTIMATES
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18
TABLE
6­
5
NATIONAL
RESULTS
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18
6
(
e)
REASONS
FOR
CHANGE
IN
BURDEN
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18
6
(
f)
BURDEN
STATEMENT
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18
1
For
purposes
of
simplicity,
this
ICR
applies
the
terms
"
owners
and
operators",
"
firm",
and
"
sources"
interchangeably.
References
to
actions
or
responsibilities
of
sources
or
firms
should
be
interpreted
as
referring
to
the
owners
and
operators
of
that
source
or
firm.

Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
OF
THE
INFORMATION
COLLECTION
This
document
fulfills
the
Agency's
requirements
under
the
Paperwork
Reduction
Act
(
PRA)
with
regards
to
determining
the
regulatory
burden
associated
with
the
Compliance
Assurance
Monitoring
(
CAM)
Rule,
codified
at
40
CFR
part
64.
It
has
been
assigned
EPA
tracking
number
1663.03and
OMB
Control
Number
2060­
0376.
The
title
of
this
Information
Collection
Request
(
ICR)
is
"
Information
Collection
Request
for
the
40
CFR
Part
64
Compliance
Assurance
Monitoring
Program."

1(
b)
REGULATORY
BACKGROUND
Part
64
of
the
Code
of
Federal
Regulations
(
CFR),
as
defined
in
the
CAM
Rule,
requires
monitoring,
compliance
certification,
periodic
reporting,
and
record
keeping
information
collections
by
owners
and
operators
of
title
V
sources
[
57
Fed.
Reg.
32250­
32312]
(
1992)
(
codified
at
40
C.
F.
R.
part
70)
1
with
controlled
pollutant
specific
emissions
units
that
have
a
precontrol
potential
to
emit
major
amounts
of
regulated
air
pollutants.
CAM
identifies
two
categories
of
emission
units:

$
"
Large"
pollutant
specific
emission
units:
units
that
have
the
potential
to
emit,
with
controls,
the
applicable
regulated
air
pollutant
in
an
amount
equal
to
or
greater
than
the
amount
required
for
a
source
to
be
classified
as
a
major
source,
and
$
"
Other"
pollutant
specific
emission
units:
the
set
of
remaining
affected
pollutant
specific
emission
units
This
analysis
differentiates
between
these
two
types
of
units
because
they
are
subject
to
different
monitoring
requirements
(
e.
g.,
monitoring
frequency
requirements)
and
implementation
timetables
under
part
64.
Upon
approval
by
the
permitting
authority
(
PA)
of
the
monitoring
proposed
by
the
source,
the
source
use
the
approved
monitoring
method
to
collect
data.
These
data
provide
the
basis
on
which
owners
or
operators
can
certify,
in
accordance
with
the
requirements
of
the
operating
permit
program,
the
compliance
of
their
emissions
units
with
the
applicable
requirements.
In
addition,
these
data
provide
the
basis
on
which
owners
or
operators
submit
monitoring
reports
on
no
less
than
a
semi­
annual
basis.
Consistent
with
the
recordkeeping
period
established
in
the
operating
permit
program,
CAM
requires
sources
to
store
and
maintain
these
data
for
at
least
five
years.
Implementational
delays
in
the
CAM
Rule
over
the
first
three
years
prevented
more
thatn
a
handful
of
"
Large"
sources
from
seeking
permits.
Consequently,
the
projected
impact
described
in
this
update
is
substantially
the
same
as
that
reported
in
the
1997
ICR.
In
the
next
three
years,
the
information
collection
and
capital
investment
requirements
of
the
CAM
program
will
involve
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
2
only
some
of
the
affected
pollutant
points.
When
fully
implemented,
the
Agency
estimates
the
CAM
program
will
involve
approximately
9,000
facilities,
covering
27,000
emissions
units.
This
ICR
estimates
the
expected
average
annual
burden
over
the
next
three
years
to
be
about
49,000
hours,
at
an
expected
cost
of
$
2.7
million.
The
activities
at
sources
leading
to
these
impacts
include:

$
Determination
of
a
monitoring
approach;

$
Installation
and
operation
of
monitoring
equipment,
if
necessary;

$
Administrative
burden
for
record
keeping
and
reporting;

$
Upgraded
operating/
maintenance
activities;

$
Improved
quality
assurance;
and
$
Permit
fees
to
cover
regulatory
costs
of
the
program.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
EPA's
operating
permit
and
CAM
programs
require
this
information.
The
operating
permit
program
requires
owners
or
operators
of
units
that
emit
air
pollutants
to
submit
annual
compliance
certifications,
to
submit
monitoring
results
at
least
semiannually,
and
to
report
deviations
promptly,
but
no
implementation
guidance
is
provided
within
the
operating
permit
program.
CAM
provides
the
vehicle
to
implement
operating
permits
program
requirements
in
a
cost­
effective
manner.
The
Clean
Air
Act
(
Act)
Amendments
of
1990,
Public
Law
101­
549,
enacted
on
November
15,
1990,
establish
the
legal
authority
for
this
information
collection.
Section
502(
b)
directs
EPA
to
promulgate
regulations
that
will
require
the
owners
or
operators
of
certain
stationary
sources
of
air
pollution
to
conduct
monitoring
and
to
make
compliance
certifications.
These
provisions
are
set
forth
in
both
title
V
(
operating
permits
provisions)
and
title
VII
(
enforcement
provisions)
of
the
1990
Amendments.
Title
V
directs
the
Agency
to
implement
monitoring
and
compliance
certification
requirements
through
the
operating
permits
program.
Section
503(
b)(
2)
requires
at
least
annual
certifications
of
compliance
with
permit
requirements
and
prompt
reporting
of
deviations
from
permit
requirements.
Section
504(
a)
mandates
that
owners
or
operators
submit
to
the
PA
the
results
of
any
required
monitoring
at
least
every
six
months.
This
section
also
requires
permits
to
include
"
such
other
conditions
as
are
necessary
to
assure
compliance
with
applicable
requirements"
of
the
Act.
Section
504(
b)
of
the
Act
also
allows
the
Agency
to
prescribe,
by
rule,
methods
and
procedures
for
determining
compliance,
and
states
that
continuous
emission
monitoring
systems
need
not
be
required
if
other
methods
or
procedures
provide
sufficiently
reliable
and
timely
information
for
determining
compliance.
Under
section
504(
c),
each
operating
permit
must
"
set
forth
inspection,
entry,
monitoring,
compliance
certification,
and
reporting
requirements
to
assure
compliance
with
the
permit
terms
and
conditions."
Title
VII
of
the
1990
Amendments
added
a
new
section
114(
a)(
3)
that
requires
EPA
to
promulgate
rules
on
enhanced
monitoring
and
compliance
certifications.
This
paragraph
provided,
in
part:

"
The
Administrator
shall
in
the
case
of
any
person
which
is
the
owner
or
operator
of
a
major
stationary
source,
and
may,
in
the
case
of
any
other
person,
require
enhanced
monitoring
and
submission
of
compliance
certifications.
Compliance
certifications
shall
include
(
A)
identification
of
the
applicable
requirement
that
is
the
basis
of
the
certification,
(
B)
the
method
used
for
determining
the
compliance
status
of
the
source,
(
C)
the
compliance
status,
(
D)
whether
compliance
is
continuous
or
intermittent,
(
E)
such
other
facts
as
the
Administrator
may
require."

The
1990
Amendments
also
revised
section
114(
a)(
1)
of
the
Act
to
provide
additional
authority
concerning
monitoring,
reporting,
and
record
keeping
requirements.
As
amended,
that
section
provides
the
Administrator
with
the
authority
to
require
any
owner
or
operator
of
a
source,
on
a
one­
time,
periodic
or
continuous
basis
to:
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
4
(
A)
establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables,
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

Obtaining
ongoing
compliance
is
a
two­
step
process.
First,
the
Agency
must
assure
properly
designed
control
measures
are
installed
or
otherwise
employed.
These
measures
include
control
devices,
process
modifications,
operating
limitations
and
other
control
measures
as
applicable.
Furthermore,
the
Agency
must
assure
the
control
measures
are
proven
to
be
capable
of
achieving
applicable
requirements.
In
the
past,
this
step
has
been
addressed
through
new
source
review
permitting,
initial
stack
testing,
compliance
inspections
and
similar
mechanisms.
The
title
V
permit
application
and
review
process,
including
the
applicant's
initial
compliance
certification
and
compliance
plan
obligations,
will
add
another
tool
for
assuring
that
source
owners
or
operators
have
adopted
proper
control
measures
for
achieving
compliance.
The
second
step
involves
monitoring
by
sources
to
determine
continued
assurance
that
the
source's
control
measures,
once
installed
or
otherwise
employed,
are
properly
operated
and
maintained
so
that
they
do
not
deteriorate
to
the
point
where
the
owner
or
operator
fails
to
remain
in
compliance
with
applicable
requirements.
The
Agency
believes
that
monitoring,
reporting,
record
keeping
and
ongoing
or
recurring
compliance
certification
requirements
under
titles
V
and
VII
should
be
designed
so
that
owners
or
operators
carry
out
this
second
step
in
assuring
ongoing
compliance.
The
Agency
has
adopted
the
CAM
approach
to
assure
the
proper
operation
and
maintenance
of
control
measures
employed
by
sources.
CAM
establishes
monitoring
to:

(
1)
documenting
continued
operation
of
the
control
measures
within
ranges
of
specified
indicators
of
performance
(
such
as
emissions,
control
device
parameters
and
process
parameters)
that
are
designed
to
provide
a
reasonable
assurance
of
compliance
with
applicable
requirements;
(
2)
indicating
any
excursions
from
these
ranges;
and
(
3)
responding
to
the
data
so
that
excursions
are
corrected.

This
type
of
monitoring
is
an
appropriate
approach
to
enhanced
monitoring
in
the
context
of
title
V
permitting
for
significant
emission
units
that
use
control
devices
to
achieve
compliance
with
emission
limits.
In
particular,
CAM
1)
provides
cost­
effective
achievement
of
air
pollution
emission
reductions;
2)
establishes
voluntary
compliance
and
self­
certification
by
owners
or
operators;
and
3)
holds
owners
or
operators
accountable
for
regulated
air
pollutants
emitted
by
units.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
5
2(
b)
USE/
USERS
OF
THE
DATA
Owners
or
operators
of
affected
emissions
units
will
use
the
information
as
the
basis
for
the
compliance
certification
required
by
the
operating
permit
program,
and
as
the
basis
for
compliance
assurance
monitoring
reports.
Sources
will
also
use
the
information
to
determine
and
maintain
the
efficiency
of
process
or
emissions
control
devices.
PAs
will
use
the
information
collected
and
submitted
in
permit
applications
in
determining
acceptability
of
proposed
compliance
assurance
monitoring.
The
PAs
will
use
source
monitoring
data
to
assess
compliance,
as
input
into
reports
to
other
agencies,
and,
when
necessary,
as
evidence
in
enforcement
proceedings.
PAs
will
use
the
information
on
excursions
and
exceedences
collected
from
owners
or
operators
to
require
the
development
and
implementation
by
source
operators
of
a
Quality
Improvement
Plan
(
QIP).
The
QIP
will
address
the
timetable,
methods,
and
procedures
for
dealing
with
these
excursions
and
exceedances.
PAs
will
also
collect
summaries
of
information
on
compliance
and
will
review
the
information
as
part
of
their
permitting
responsibilities
and
ongoing
compliance
activities.
The
information
may
be
entered
into
local,
regional,
or
national
databases
for
review
and
action
by
air
pollution
control
agencies.
Other
Federal
entities,
such
as
the
Department
of
Energy,
may
request
and
use
the
information
collected
to
fulfill
specific
mission
objectives.
Citizens
may
request
the
information
collected
in
order
to
determine
the
compliance
status
of
any
emissions
unit
or
particular
group
of
emissions
units.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
6
3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
RESPONDENTS
/
NAICS
CODES
CAM
applies
to
most
North
American
Industrial
Classification
System
(
NAICS)
code
groups
and
to
certain
service
industries
regulated
under
the
Act.

3(
b)
INFORMATION
REQUESTED
3(
b)(
i)
DATA
ITEMS
The
following
matrices
display
the
types
of
additional
data
required
by
the
part
64
CAM
Rule,
along
with
the
location
of
the
requirement
in
the
rule.

FIGURE
3­
1
DATA
REQUIRED
BY
THE
INFORMATION
COLLECTION
Additional
Requirements
for
Permit
Applications
Regulation
Reference
For
all
major
source
pollutant­
specific
emission
units
that
satisfy
the
applicability
criteria
outlined
in
64.2,
the
owner
or
operator
shall
submit
a
proposed
monitoring
approach
to
the
PA.
The
monitoring
approach
shall
be
submitted
as
part
of
the
initial,
revised,
or
renewed
part
70
or
71
permit
application.
64.5
Consistent
with
the
design
requirements
in
64.3,
the
submission
shall
include
the
following
information:

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

either
(
i)
the
ranges
or
designated
conditions
for
such
indicators
or
(
ii)
the
process
by
which
such
indicator
ranges
or
designated
conditions
shall
be
established.
64.4(
a)(
2)

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

if
applicable,
the
indicator
ranges
and
performance
criteria
for
a
CEMS,
COMS,
or
PEMS
pursuant
to
64.3(
d).
64.4(
a)(
4)

As
part
of
the
information
submitted,
the
owner
or
operator
shall
submit:
Additional
Requirements
for
Permit
Applications
Regulation
Reference
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
7
a
justification
for
the
proposed
elements
of
monitoring.
The
justification
shall
include
any
supporting
data
and
may
refer
to
any
generally
available
sources
of
information
such
as
air
pollution
engineering
manuals
or
EPA
or
PA
publications.
In
addition,
the
owner
or
operator
may
base
the
required
justification
exclusively
on
the
regulatory
precedents
cited
in
64.4(
b)(
1)­(
5).
If
the
performance
specifications
proposed
to
satisfy
64.3(
b)(
2)
or
(
3)
include
differences
from
manufacturer
recommendations,
the
owner
or
operator
shall
explain
the
reasons
for
the
differences.
64.4(
b)

control
device
(
and
process
and
capture
system,
if
applicable)
operating
parameter
data
obtained
during
the
conduct
of
applicable
compliance
or
performance
tests.
Such
data
may
be
supplemented,
if
desired,
by
engineering
assessments
and
manufacturer's
recommendations
to
justify
the
indicator
ranges.
64.4(
c)(
1)

documentation
to
certify
that
no
changes
to
the
pollutant­
specific
emissions
unit,
including
the
control
device
and
capture
system,
have
taken
place.
64.4(
c)(
2)

If
existing
data
from
unit­
specific
compliance
or
performance
testing
specified
in
64.4(
c)
are
not
available,
the
owner
or
operator:

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

may
submit
indicator
ranges
(
or
procedures
for
establishing
indicator
ranges)
that
rely
on
engineering
assessments
and
other
data,
provided
that
the
owner
or
operator
demonstrates
that
factors
specific
to
the
type
of
monitoring,
control
device,
or
pollutant­
specific
emissions
unit
make
compliance
or
performance
testing
unnecessary
to
establish
indicator
ranges
at
levels
that
satisfy
the
criteria
in
64.3(
a).
64.4(
d)(
2)

If
the
monitoring
submitted
by
the
owner
or
operator
requires
installation,
testing,
or
other
necessary
activities
prior
to
use
for
the
purposes
of
part
64,
the
owner
or
operator
shall
include:

an
implementation
plan
and
64.4(
e)

schedule
for
installing,
testing,
and
performing
any
other
appropriate
activities
prior
to
the
use
of
the
monitoring.
64.4(
e)

Reporting
Requirements
Regulation
Reference
Submit
monitoring
reports
in
accordance
with
70.6(
a)(
3)(
iii).
In
addition
the
monitoring
report
shall
include:
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
8
summary
information
of
the
number,
duration
and
cause
(
including
unknown
cause,
if
applicable)
of
excursions
or
exceedances
and
the
corrective
actions
taken.
64.9(
a)(
2)(
i)

summary
information
of
the
number,
duration
and
cause
(
including
unknown
cause,
if
applicable)
for
monitor
downtime
incidents
(
other
than
downtime
associated
with
zero
and
span
or
other
daily
calibration
checks,
if
applicable).
64.9(
a)(
2)(
ii)

a
description
of
the
actions
taken
to
implement
a
quality
improvement
plan
(
QIP)
specified
in
64.8.
Upon
completion
of
a
QIP,
the
owner
or
operator
shall
include
in
the
next
summary
report
documentation
that
the
implementation
of
the
plan
has
been
completed
and
reduced
the
likelihood
of
similar
levels
of
excursions
or
exceedances
occurring.
64.9(
a)(
2)(
iii)

Record
Keeping
Requirements
Regulation
Reference
Records
shall
be
maintained
in
accordance
with
the
requirements
specified
in
70.6(
a)(
3)(
ii).
In
addition
the
records
shall
include:

records
of
monitoring
data
64.9(
b)

monitor
performance
data
64.9(
b)

any
written
QIP
required
pursuant
to
64.8
64.9(
b)

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

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

records
of
monitoring
maintenance.
64.9(
b)

Additional
Requirements
for
Compliance
Certification
Regulation
Reference
For
all
affected
pollutant­
specific
units,
an
annual
compliance
certification
is
required.
As
part
of
the
compliance
certification,
it
is
necessary
to
identify:

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

the
method(
s)
or
other
means
used
by
the
owner
or
operator
for
determining
the
compliance
status
with
each
term
and
condition
during
the
certification
period,
and
whether
such
methods
or
means
provide
continuous
or
intermittent
data.
70.6(
c)(
5)(
iii)(
B)

the
status
of
compliance
with
the
terms
and
conditions
of
the
permit
for
the
period
covered
by
the
certification
70.6(
c)(
5)(
iii)(
C)

such
other
facts
as
the
PA
may
require.
70.6(
c)(
5)(
iii)(
D)
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
9
3(
b)(
ii)
RESPONDENT
ACTIVITIES
The
following
list
displays
typical
activities
sources
will
have
to
perform
to
meet
the
additional
permit
application,
record
keeping,
and
reporting
requirements
of
CAM:

1.
Review
requirements;
2.
Determine
monitoring
approach;
3.
Specify
monitoring
plan
elements;
4.
Prepare
documentation;
5.
Revise
CAM,
as
applicable;
6.
Renew
CAM
at
permit
renewal;
7.
Maintain
records;
8.
Submit
reports;
9.
Certify
facility
compliance.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
10
4.
THE
INFORMATION
COLLECTED
C
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4(
a)
AGENCY
ACTIVITIES
State
and
local
agencies
will
perform
the
following
activities:

1.
Rule
familiarization;
2.
Determine
applicability;
3.
Review
and
approve/
disapprove
monitoring
chosen
by
owners/
operators;
4.
Respond
to
requests
for
reviews/
revisions
to
CAM;
5.
Review
reports;
6.
Evaluate
CAM
renewals;
7.
Review
annual
facility
certifications.

The
EPA
will
perform
the
following
activities:

1.
Provide
oversight
and
guidance
to
State
and
local
agencies;
2.
Assess
requests
for
alternative
monitoring.

4(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
CAM
does
not
mandate
the
use
of
standardized
forms
for
reporting
information.
§
64.9(
b)(
2)
allows
record
keeping
in
a
variety
of
media
as
long
as
all
records
are
available
for
inspection
and
there
are
no
conflicts
with
other
record
keeping
requirements.

4(
c)
SMALL
ENTITY
FLEXIBILITY
The
Agency
assessed
the
impacts
of
the
CAM
Rule
on
small
businesses,
governments,
and
organizations
in
Chapter
V
of
the
rule's
Regulatory
Impact
Analysis
in
1997.
This
assessment
still
holds
true,
indicating
the
CAM
Rule
will
probably
not
have
a
significant
impact
on
a
substantial
number
of
small
entities
(
SISNOSE).
For
additional
discussion
on
this
assertion,
the
Agency
invites
the
reader
to
review
the
CAM
Rule
RIA
and
ICR
from
1997.
The
Agency
determined
the
benefits
of
additional
monitoring
requirements
on
small
sources
of
pollution
would
not
justify
the
additional
cost
incurred
to
achieve
them.
Section
502(
a)
of
the
Act
allows
that:
"
The
Administrator,
may,
in
the
Administrator's
discretion
and
consistent
with
the
applicable
provisions
of
[
the
Clean
Air
Act],
promulgate
regulations
to
exempt
one
of
more
source
categories
(
in
whole
or
in
part)
from
the
requirements
of
[
exempt
one
or
several
source
categories
or
subcategories,
in
whole
or
in
part,
from
the
requirements
[
of
title
V]
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
2
A
small
source
is
not
necessarily
a
small
entity,
nor
is
there
a
direct
relationship
between
large
sources
and
large
entities.
Source
size
is
a
function
of
the
level
of
its
emissions,
and
entity
size
depends
on
the
productive
capacity
and
employment
of
the
firm,
according
to
United
States
Small
Business
Administration
guidelines.

Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
11
major
source
from
such
requirements."
Acting
under
this
authority,
the
Agency
exercised
its
discretionary
authority
and
determined
the
current
level
of
monitoring
performed
by
small
sources
of
pollution
2
is
sufficient
to
fulfill
the
requirements
of
part
64,
and
decided
to
not
subject
these
small
sources
of
pollution
to
part
64
monitoring.

4(
d)
COLLECTION
SCHEDULE
Submission
of
initial
source
information
required
under
part
64
depends
on
whether
the
unit
is
classified
as
"
Large"
or
"
Other."
If
the
source's
permit
application
has
not
been
filed,
is
being
revised,
or
is
not
complete,
"
Large"
units
must
submit
monitoring
information
on
or
before
the
180th
day
after
publication
of
the
final
rule
in
the
Federal
Register.
If
these
conditions
are
not
met,
sources
must
submit
monitoring
design
criteria
at
the
first
significant
permit
revision,
or
at
permit
renewal,
whichever
occurs
first.
For
all
other
pollutant­
specific
emission
units
subject
to
part
64
(
i.
e.,
"
Other"
units),
the
owner
or
operator
shall
submit
the
required
information
upon
renewal
of
a
part
70
or
71
permit.
Upon
approval
of
the
permit,
sources
must
collect
the
information
specified
in
their
permits
in
accordance
with
the
collection
frequency
specified,
maintaining
these
data
for
at
least
five
years.
Sources
must
also
submit
semi­
annual
monitoring
reports
and
annual
compliance
certifications.
These
requirements
have
not
changed
since
the
initial
ICR
was
approved,
and
because
of
the
delay
in
program
implementation,
the
scope
of
their
effect
has
not
changed
significantly,
either.

4(
e)
ENVIRONMENTAL
JUSTICE
CONSIDERATIONS
The
President's
priorities
in
promoting
environmental
justice
are
contained
in
Executive
Order
#
12898.
In
and
of
themselves,
monitoring
and
enforcement
requirements
do
not
provide
many
opportunities
for
identifying
potential
environmental
justice
concerns.
The
greatest
opportunity
for
insuring
and
promoting
environmental
justice
under
the
CAM
Rule
actually
occur
under
part
70
and
71,
which
provide
the
framework
for
public
participation
and
empowerment.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
12
5.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5(
a)
NONDUPLICATION
For
approval
of
a
proposed
ICR,
the
Agency
must
ensure
that
it
has
taken
every
reasonable
step
to
avoid
duplication
in
its
paperwork
requirements
in
accordance
with
5
CFR
1320.4.
The
part
64
rulemaking
is
mandated
by
the
Act,
and
supports
the
title
V
permit
program
under
40
CFR
part
70
as
well
as
title
VII
enforcement
provisions.
Recognizing
that
many
sources
have
already
implemented
monitoring
strategies
to
fulfill
their
part
70
requirements,
the
part
64
monitoring
guidelines
were
carefully
crafted
by
the
Agency
and
OMB
to
minimize
any
unnecessary
duplication.
The
part
64
CAM
Rule
has
also
been
carefully
designed
to
function,
as
much
as
possible,
in
a
manner
complementary
to
that
of
the
part
70
operating
permit
program
managed
by
PAs.

5(
b)
CONSULTATIONS
The
Agency
has
continued
discussions
with
stakeholders
through
a
series
of
workshops
and
public
meetings.
The
workgroups
at
these
meetings
discussed
and
review
CAM
requirements
and
reviewed
extensive
public
input
concerning
the
development
and
implementation
of
CAM.

5(
c)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
As
part
of
the
permit
application
required
under
the
operating
permit
program,
an
owner
or
operator
must
submit
to
the
PA
monitoring
that
satisfies
the
design
requirements
in
§
64.3.
In
addition,
it
must
be
demonstrated
that
the
proposed
monitoring
is
sufficient
to
provide
compliance
status
information.
Without
such
information,
PAs
will
be
unable
to
issue
complete
permits.
Furthermore,
owners
or
operators
will
be
unable
to
certify
compliance
with
emissions
limitations
or
standards
unless
costly
reference
test
methods
are
employed.
Part
64
requires
semi­
annual
reports
because
the
statue
requires
all
monitoring
reports
to
be
submitted
at
least
semiannually
(
section
504(
a)).
In
addition,
without
timely
evaluation
of
the
reports,
excess
emissions
of
regulated
air
pollutants
could
rise.
Consequently,
less
frequent
collection
of
monitoring
information
is
not
permissible
under
the
statute
and
could
result
in
a
net
loss
of
environmental
quality
and
was
not
considered
for
this
rulemaking.

5(
d)
GENERAL
GUIDELINES
OMB's
general
guidelines
for
information
collections
must
be
adhered
to
by
all
Federal
Agencies
for
approval
of
any
rulemaking's
collection
methodology.
In
accordance
with
the
requirements
of
5
CFR
1320.6,
the
Agency
believes:
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
13
1.
Part
64
regulations
do
not
require
periodic
reporting
more
frequently
that
semi­
annually.

2.
The
part
64
regulations
do
not
require
respondents
to
participate
in
any
statistical
survey.

3.
Responses
to
Agency
inquiries
are
not
required
to
be
submitted
in
less
than
thirty
days.

4.
Special
consideration
has
been
given
in
the
design
of
part
64
to
ensure
that
the
requirements
are,
to
the
greatest
extent
possible,
the
same
for
Federal
requirements
and
those
permitting
authorities
who
already
have
monitoring
programs
in
place.

5.
Confidential,
proprietary,
and
trade
secret
information
necessary
for
the
completeness
of
the
respondent's
permit
are
protected
from
disclosure
under
the
requirements
of
§
503(
e)
and
§
114(
c)
of
the
Act.

6.
The
part
64
regulations
do
not
require
more
that
one
original
and
two
copies
of
the
permit
application,
update,
or
revision
to
be
submitted
to
the
Agency.

7.
Respondents
do
not
receive
remuneration
for
the
preparation
of
reports
required
by
the
Act
or
part
64.

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

9.
The
Agency
believes
the
impact
of
part
64
on
small
entities
to
be
insignificant
and
not
disproportionate.

The
record
keeping
and
reporting
requirements
contained
in
the
CAM
program
regulations
do
not
exceed
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.6,
except
for
the
guideline
which
limits
retention
of
records
by
respondents
to
three
years.
The
CAM
program
and
the
operating
permit
program
require
both
respondents
and
State
or
local
agencies
to
retain
records
for
a
period
of
five
years.
The
justification
for
this
exception
is
found
in
28
U.
S.
C.
2462,
which
specifies
five
years
as
the
general
statute
of
limitations
for
Federal
claims
in
response
to
violations
by
regulated
entities.
The
decision
in
U.
S.
v.
Conoco,
Inc.,
No.
83­
1916­
E
(
W.
D.
Okla.,
January
23,
1984)
found
that
the
five
year
general
statute
of
limitations
applied
to
the
Clean
Air
Act.

5(
e)
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
5(
e)(
i)
CONFIDENTIALITY
Confidentiality
is
not
an
issue
for
this
rulemaking.
In
accordance
with
the
Clean
Air
Act
Amendments
of
1990,
monitoring
information
must
be
submitted
by
sources
as
a
part
of
their
permit
application
and
update;
and
revisions
­
all
of
which
are
a
matter
of
public
record.
To
the
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
14
extent
that
the
information
required
is
proprietary,
confidential,
or
of
a
nature
that
could
impair
the
ability
of
the
source
to
maintain
its
market
position,
that
information
is
collected
and
handled
subject
to
the
requirements
of
§
503(
e)
and
§
114(
c)
of
the
Act.
Information
received
and
identified
by
owners
or
operators
as
confidential
business
information
(
CBI)
and
approved
as
CBI
by
EPA,
in
accordance
with
Title
40,
Chapter
1,
Part
2,
Subpart
B,
shall
be
maintained
appropriately
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

5(
e)(
ii)
SENSITIVE
QUESTIONS
Sensitive
questions,
(
i.
e.,
sexual,
religious,
personal
or
other
private
matters),
are
not
applicable
to
this
rulemaking.
The
information
gathered
for
purposes
of
establishing
an
operating
permit
for
a
source
do
not
include
personal
data
on
any
owner
or
operator.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
15
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
This
section
discusses
the
development
of
burden
estimates
and
their
conversion
estimates
into
costs,
which
are
separated
into
burden
costs
and
capital
and
O&
M
costs.
The
methodology
employed
in
this
ICR
matches
that
used
in
the
original
1997
ICR.
According
to
the
latest
guidance
for
ICRs,
capital
and
O&
M
costs
display
the
cost
of
any
new
capital
equipment
the
source
or
PA
may
have
to
purchase
solely
for
information
collection,
assimilation,
and
storage
purposes.
For
example,
if
a
source
had
to
purchase
a
new
mini­
computer
to
store
and
manipulate
CEM
data,
that
computer
would
be
a
cost
of
administration
subject
to
reporting
in
the
ICR.
In
addition,
the
latest
guidance
instructs
the
Agency
to
differentiate
the
burden
associated
with
a
source's
labor
and
that
which
it
hires
through
outside
contractors.
However,
a
sensitivity
analysis
of
the
effect
of
contracted
labor
on
the
CAM
Rule
reveals
that,
if
all
of
the
affected
sources
were
to
employ
contractors
to
perform
as
much
as
half
of
the
work
necessary
for
full
compliance
with
the
rule,
overall
costs
would
increase
by
less
than
five
percent.
Consequently,
this
analysis
assumes
sources
will
not
employ
contracted
labor.

Note
that
the
Federal
Register
document
required
under
5
CFR
1320.8(
d),
soliciting
comments
on
this
collection
of
information
was
published
on
April
26,
2001,
66
FR
20986;
no
comments
were
received.

6(
a)
ESTIMATING
RESPONDENT
BURDEN
This
section
presents
estimates
of
the
burden
hours
expected
to
be
incurred
at
sources
with
emission
units
affected
by
Compliance
Assurance
Monitoring,
applying
the
same
methodology
used
for
this
rulemaking's
original
RIA
and
ICR.
Results
are
contained
in
Tables
6­
1
through
6­
4.
These
tables
summarize
burden
impacts
for
all
pollutants
by
activity.
The
burden
estimates
reflect
the
expert
judgement
of
EPA
staff,
contractors,
and
industry
experts.
All
burden
estimates
represent
the
increment
over
part
70
requirements.
Due
to
the
differences
in
monitoring
frequency
requirements
and
implementation
schedules
for
the
"
Large"
and
"
Other"
emission
units,
the
Agency
calculated
the
associated
burdens
separately.
Tables
6­
1
and
6­
2
report
labor
burdens
for
each
type
of
units.
The
estimation
methodology
employed
in
this
ICR
is
the
same
as
that
used
in
the
initial
ICR
of
1997.
Average
annual
labor
burden
is
computed
as
the
arithmetic
average
of
the
sum
of
the
annual
labor
burden
across
the
three
years
of
the
information
collection.
Total
annual
burden
for
the
five
State
sample
is
computed
as
the
product
of
the
annual
labor
hours
per
respondent
for
a
specific
activity
times
the
number
of
respondents.
National
totals
are
derived
by
multiplying
the
values
from
the
five
State
sample
by
ten.
This
analysis
estimates
the
national
average
annual
labor
burden
over
the
next
three
years
for
"
Large"
and
"
Other"
emissions
units
at
about
25
thousand
hours
and
111
thousand
hours,
respectively.
Differences
between
the
prior
ICR
and
the
results
in
Tables
6.1
and
6.2
are
due
to
changes
in
labor
cost
and
arithmetic
errors
revealed
during
this
update.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
16
6(
b)
ESTIMATING
RESPONDENT
COSTS
Tables
6­
1
and
6­
2
also
show
the
costs
associated
with
each
type
of
emission
unit.
Burden
costs
in
Tables
6­
1
and
6­
2
are
classified
into
one
of
three
categories:
costs
associated
with
CAM
design
activities,
record
keeping
activities,
or
reporting
activities.
Also,
for
capital
and
O&
M
costs,
the
tables
only
report
aggregate
totals.
The
nature
of
the
data
prohibits
any
further
disaggregation.
All
cost
estimates
represent
the
increment
over
part
70
requirements.
Consistent
with
the
1997
ICR,
this
study
identifies
two
labor
categories:
a
management
level
category
with
a
wage
rate
of
$
75/
hour
(
revised
from
the
1997
ICR
to
2001
dollars)
and
a
technical
staff
category
with
a
rate
of
$
38/
hour
(
also
revised
to
2001
dollars).
These
rate
assumptions
are
consistent
with
other
RIAs
and
ICRs
prepared
by
this
Agency.
The
cost
of
the
Federal
burden
included
in
this
ICR
was
derived
through
a
process
determined
by
the
EPA's
Office
of
General
Council
(
OGC).
The
OGC
determined
the
appropriated
base
salary
level
to
employ
was
a
GS
11,
Step
3
(
FY
95
Schedule),
with
the
addition
of
one­
eleventh
of
a
supervisory
staff
member's
salary
at
GS
13
Step
3
(
FY
95
Schedule)
and
oneeighth
of
a
support
staff
person's
salary
at
GS
6
Step
6
(
FY
95
Schedule).
To
this
base
salary,
OGC
instructed
the
EPA
to
add
16
percent
for
benefits,
10
percent
for
sick
leave
and
vacation,
and
a
factor
of
32.3
percent
for
general
overhead.
This
total
loaded
salary
was
then
divided
by
2,080
hours
to
establish
a
per­
hour
rate
for
Federal
employees.
This
rate
also
applies
to
state
and
other
PA's
analysts'
salaries.
From
Tables
6­
1
and
6­
2,
the
national
total
annualized
cost
($
2001)
is
$
1.2
million
for
"
Large"
units
and
$
5.2
million
for
the
"
Other"
units.
The
Agency
calculated
capital
and
O&
M
costs
separately
for
items
associated
with
the
collection
request.
All
capital
equipment
costs
for
durable
monitoring
equipment
are
annualized
over
the
expected
life
of
the
equipment
and
discounted
at
a
seven
percent
real
rate.
Tables
6­
1
shows
the
capital
and
O&
M
costs
associated
with
"
Large"
units,
reported
at
$
123
thousand
per
year.
"
Other"
emissions
units
have
no
incremental
capital
or
O&
M
costs
over
the
three
years
of
this
ICR.

6(
c)
ESTIMATING
STATE
BURDEN
AND
COST
Tables
6­
3
and
6­
4
show
the
burden
and
costs
for
State
and
Local
Agencies
for
"
Large"
and
"
Other"
units,
respectively.
The
Agency
believes
the
activities
shown
in
the
tables
fully
define
the
State
and
Local
Agencies'
burden
under
part
64.
The
labor
hour
estimates
for
each
activity
are
based
on
the
expert
knowledge
of
EPA
staff.
The
labor
estimates
for
these
activities
reflect
the
PA
hours
required
to
complete
the
activities
for
one
pollutant
specific
emissions
unit.
Depending
on
the
activity,
the
labor
hours
required
may
be
broken
out
by
the
type
of
existing
monitoring
and
the
type
of
response.
Costs
are
reported
in
2001
dollars
and
reflect
a
time
horizon
of
three
years.
Total
annualized
costs
for
all
PAs
are
$
434
thousand
for
"
Large"
units
and
$
1.2
million
for
"
Other"
units.
The
operating
permits
program
requires
the
cost
of
administering
a
State
permit
program
to
be
fully
repaid
out
of
the
permitting
fees
collected
by
that
State.
Therefore,
the
true
cost
of
the
CAM
Rule
to
States
and
other
PAs
is
zero,
and
the
recorded
cost
of
administration
should
be
allocated
to
sources.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
17
This
analysis
does
not
include
burden
and
cost
estimates
for
Federal
activities.
Based
on
historical
data
for
related
actions
under
other
regulations,
the
Agency's
permitting
experts
determined
each
request
can
be
processed
with
no
more
than
two
hours
of
labor.
Because
of
the
small
number
of
sources
initiating
monitoring
within
the
three
year
period
covered
by
this
ICR,
the
impact
of
these
actions
is
expected
to
be
negligible.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
18
TABLE
6.1
Total
and
Average
Source
Burden
and
Labor
Costs
for
"
Large"
Sources
­
All
Pollutants
5­
State
Sample
National
Annual
­
Per
Respondent
Number
of
Respondents
Labor
Hours
Per
Unit
Year
3­
Year
Total
3­
Year
Average
Task
CAM
Activities
Admin.
Tech.
Cost1
2001­
02
2002­
03
2003­
04
Hours
Cost2
Hours
Cost2
1
Review
Requirements
5
15
$
945
106
0
0
21,200
$
1,002
7,067
$
334
2
Determine
Monitoring
Approach
Units
without
existing
monitoring
0.75
2.25
$
142
43
7
29
2,370
$
112
790
$
37
Units
with
existing
monitoring
0.25
0.75
$
47
49
7
34
900
$
42
300
$
14
3
Specify
Monitoring
Elements
Units
w/
out
monitoring:
non
CEM/
COM
4
12
$
756
38
6
26
11,200
$
8,467
3,733
$
2,822
Units
w/
out
monitoring:
CEM/
COM
2
8
$
454
5
1
3
900
$
409
300
$
136
Units
with
monitoring:
non
CEM/
COM
2
8
$
454
28
4
20
5,200
$
2,361
1,733
$
787
Units
with
monitoring:
CEM/
COM
1
3
$
189
20
3
14
1,480
$
280
493
$
93
4
Design
Documentaiton
Units
w/
out
monitoring:
non
CEM/
COM
0
4
$
152
38
6
28
2,880
$
438
960
$
146
Units
w/
out
monitoring:
CEM/
COM
0
2
$
76
5
1
3
180
$
14
60
$
5
Units
with
monitoring:
non
CEM/
COM
0
2
$
76
28
4
20
1,040
$
79
347
$
26
Units
with
monitoring:
CEM/
COM
0
1
$
38
20
3
14
370
$
14
123
$
5
5
CAM
Revisions
Units
without
existing
monitoring
0
4
$
152
0
1
3
160
$
24
53
$
8
Units
with
existing
monitoring
0
2
$
76
0
1
3
80
$
12
27
$
4
6
CAM
Renewal
2
8
$
454
0
0
62
6,200
$
2,815
2,067
$
938
7
Recordkeeping
Activities
Incremental
recordkeeping
burden
0
26
$
988
0
1
1
520
$
514
173
$
171
Daily
recordkeeping
for
new
work
0
390
$
14,820
0
2
2
15,600
$
593
5,200
$
198
Incremental
recordkeeping
burden
(
VE)
0
26
$
988
0
2
2
1,040
$
40
347
$
13
8
Incremental
reporting
0
1
$
38
0
91
106
1,970
$
75
657
$
25
9
Facility
Certificaiton
0.71
0
$
53
0
91
106
1,399
$
105
466
$
35
TOTALS
17.71
515
$
20,898
74,689
$
17,396
24,896
$
5,799
CAPITAL
AND
O&
M
COSTS
$
123
TOTAL
ANNUALIZED
COSTS
$
5,922
1
In
$
2001
2
In
Thousands
of
$
2001
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
19
TABLE
6.2
Total
and
Average
Source
Burden
and
Labor
Costs
for
"
Other"
Sources
­
All
Pollutants
Per
Respondent
National
Annual
­
Per
Respondent
Number
of
Respondents
Labor
Hours
Per
Unit
Year
3­
Year
Total
3­
Year
Average
Task
CAM
Activities
Admin.
Tech.
Cost1
2001­
02
2002­
03
2003­
04
Hours
Cost2
Hours
Cost2
1
Review
Requirements
5
15
$
945
10,730
0
0
214,600
$
1,014
71,533
$
338
2
Determine
Monitoring
Approach
Units
without
existing
monitoring
0.75
2.25
$
142
0
0
2,540
7,620
$
361
2,540
$
120
Units
with
existing
monitoring
0.25
0.75
$
47
0
0
2,140
2,140
$
101
713
$
3
3
Specify
Monitoring
Elements
Units
w/
out
monitoring:
non
CEM/
COM
4
12
$
756
0
0
2,470
39,520
$
1,867
13,173
$
622
Units
w/
out
monitoring:
CEM/
COM
2
6
$
378
0
0
70
560
$
26
187
$
9
Units
with
monitoring:
non
CEM/
COM
2
6
$
378
0
0
1,870
14,960
$
707
4,987
$
236
Units
with
monitoring:
CEM/
COM
1
3
$
189
0
0
260
1,040
$
49
347
$
16
4
Design
Documentaiton
Units
w/
out
monitoring:
non
CEM/
COM
0
4
$
152
0
0
2,470
9,880
$
375
3,293
$
125
Units
w/
out
monitoring:
CEM/
COM
0
2
$
76
0
0
70
140
$
5
47
$
2
Units
with
monitoring:
non
CEM/
COM
0
2
$
76
0
0
1,870
3,740
$
142
1,247
$
47
Units
with
monitoring:
CEM/
COM
0
1
$
38
0
0
260
260
$
10
87
$
3
5
CAM
Revisions
Units
without
existing
monitoring
0
4
$
152
0
0
0
0
$
0
0
$
0
Units
with
existing
monitoring
0
2
$
76
0
0
0
0
$
0
0
$
0
6
CAM
Renewal
2
6
$
378
0
0
4,680
37,440
$
1,769
12,480
$
590
7
Recordkeeping
Activities
Incremental
recordkeeping
burden
0
26
$
988
0
0
0
0
$
0
0
$
0
Daily
recordkeeping
for
new
work
0
130
$
4,940
0
0
0
0
$
0
0
$
0
Incremental
recordkeeping
burden
(
VE)
0
26
$
988
0
0
0
0
$
0
0
$
0
8
Incremental
reporting
0
1
$
38
0
0
0
0
$
0
0
$
0
9
Facility
Certificaiton
0.71
0
$
53
0
0
0
0
$
0
0
$
0
TOTALS
17.71
249
10772.54
10,730
0
18,700
331,900
$
6,426
110,633
$
2,142
CAPITAL
AND
O&
M
COSTS
$
0
TOTAL
ANNUALIZED
COSTS
$
2,142
1
In
$
2001
2
In
Thousands
of
$
2001
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
20
Table
6.3
Permitting
Authority
Annual
Labor
Hours
and
Costs
for
"
Large"
Sources
­
All
Pollutants
5
State
Sample
National
Per
Respondent
Respondents
Total
Annual
CAM
Activities
Hours
Cost1
Year
1
Year
2
Year
3
Hours
Costs
1
Hours
Costs
1
Rule
Familiarization
54
$
2,376
5
0
0
270
$
11,880
2,700
$
118,800
Applicability
Determination
0.67
$
29
0
91
15
71
$
3,125
710
$
31,249
Initial
CAM
Review
W/
o
existing
monitoring:
non
CEM/
COM
2
$
88
0
38
6
88
$
3,872
880
$
38,720
W/
o
existing
monitoring:
CEM/
COM
1
$
44
0
5
1
6
$
264
60
$
2,640
With
existing
monitoring:
non
CEM/
COM
1
$
44
0
28
5
33
$
1,452
330
$
14,520
With
existing
monitoring:
CEM/
COM
0.5
$
22
0
20
3
12
$
506
115
$
5,060
CAM
Revisions
Units
w/
o
existing
monitoring
1
$
44
0
1
3
4
$
176
40
$
1,760
Units
with
existing
monitoring
0.5
$
22
0
1
3
2
$
88
20
$
880
Review
Reports
2
$
88
0
91
107
396
$
17,424
3,960
$
174,240
CAM
Renewals
1
$
44
0
0
0
40
$
1,760
400
$
17,600
Certifications
0.33
$
15
0
91
107
65
$
2,875
653
$
28,750
Total
Cost
and
Burden:
987
$
43,422
9,869
$
434,218
1
In
real
$
2001.

TABLE
6.4
Permitting
Authority
Labor
Hours
and
Costs
for
"
Other"
Sources
­
All
Pollutants
5
State
Sample
National
Per
Respondent
Respondents
Total
Annual
CAM
Activities
Hours
Cost
Year
1
Year
2
Year
3
Hours
Costs
1
Hours
Costs
1
Rule
Familiarization
546
$
24,024
5
0
0
2,730
$
120,120
27,300
$
1,201,200
Applicability
Determination
0.67
$
29
0
0
0
0
$
0
0
$
0
Initial
CAM
Review
W/
o
existing
monitoring:
non
CEM/
COM
2
$
88
0
0
0
0
$
0
0
$
0
W/
o
existing
monitoring:
CEM/
COM
1
$
44
0
0
0
0
$
0
0
$
0
With
existing
monitoring:
non
CEM/
COM
1
$
44
0
0
0
0
$
0
0
$
0
With
existing
monitoring:
CEM/
COM
0.5
$
22
0
0
0
0
$
0
0
$
0
CAM
Revisions
Units
w/
o
existing
monitoring
1
$
44
0
0
0
0
$
0
0
$
0
Units
with
existing
monitoring
0.5
$
22
0
0
0
0
$
0
0
$
0
Review
Reports
2
$
88
0
0
0
0
$
0
0
$
0
CAM
Renewals
1
$
44
0
0
0
0
$
0
0
$
0
Certifications
0.33
$
15
0
0
0
0
$
0
0
$
0
Total
Cost
and
Burden:
2,730
$
120,120
27,300
$
1,201,200
1
In
real
$
2001
6(
d)
SUMMARY
BURDEN
HOUR
AND
COST
ESTIMATES
Table
6­
5
summarizes
the
national
annual
average
expected
burden
hours
and
annualized
costs
displayed
in
Tables
6­
1
through
6­
4.
Table
6­
5
reports
the
results
for
PAs
differentiated
by
"
Large"
and
"
Other"
unit
source
types.
These
data
include
the
annualized
costs
for
reporting
and
record
keeping
activities
as
well
as
the
annualized
costs
for
capital
equipment
and
O&
M.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
21
Table
6­
5
National
Results
Respondent
Type
Number
of
Respondents
Average
Annual
Burden
Hours
Total
Annualized
Cost1
Sources
(
Large
Units)
1,060
24,896
$
5,922
Sources
(
Other
Units)
10,730
110,633
$
2,142
PAs
(
Large
Units)
112
9,869
$
434
PAs
(
Other
Units)
2
112
27,300
$
1,201
Federal
Authority3
1
Total
172,698
$
9,699
1
In
thousands
of
$
2001
2
There
are
only
112
PAs,
each
of
which
handles
both
"
Large"
and
"
Other"
units
3
Burden
hours
and
costs
are
expected
to
be
negligible.

6(
e)
REASONS
FOR
CHANGE
IN
BURDEN
The
changes
in
the
burden
associated
with
the
CAM
Rule
since
the
approval
of
the
initial
ICR
in
1997
are
associated
with
better
estimation
of
costs,
gained
through
experience,
as
well
as
adjustment
for
the
rate
of
inflation
and
correction
of
several
arithmetic
and
typographical
errors
that
did
not
change
the
conclusions
of
this
analysis.

6(
f)
BURDEN
STATEMENT
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information,
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
Send
comments
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
the
Director,
U.
S.
Environmental
Protection
Agency,
Collection
Strategies
Division,
(
Mail
Code
2822),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1663.03
and
OMB
control
number
2060­
0376
in
any
correspondence.
Part
64
Compliance
Assurance
Monitoring
Rule
Information
Collection
Request
Page
22
