INFORMATION
NEEDED
TO
PREPARE
AN
UPDATED
INFORMATION
COLLECTION
REQUEST
(
ICR)
FOR
THE
PART
70
REGULATIONS
The
information
needed
to
update
the
burden
estimate
of
the
ICR
consists
of
the
burden
(
in
terms
of
hours
spent)
of
accomplishing
all
the
activities
associated
with
implementing
the
part
70
program.
(
This
does
not
include
activities
underway
before
title
V
such
as
ambient
monitoring,
NSR,
enforcement,
etc.)
Please
provide
estimates
of
the
hourly
burden
of
accomplishing
the
activities
listed
below.
Feel
free
to
point
out
part
70
program
activities
not
included
on
the
list.

Include
hours
for
all
participants.
For
instance,
if
three
2­
hour
meetings
are
typically
held
on
developing
a
permit
with
four
people
attending
each
meeting,
the
burden
is
3
meetings
times
2
hours
each
times
4
people
for
a
total
burden
of
24
hours.
For
any
activity,
add
in
hours
to
account
for
management
and
clerical
support.

The
figure
being
sought
is
an
average
burden
per
permit
for
the
various
part
70
program
activities.
These
values
will
be
multiplied
by
the
total
number
of
part
70
sources
to
generate
a
nationwide
burden
for
the
whole
program.
Some
activities
are
not
permit
specific,
but
are
program
specific,
such
as
training,
responding
to
public
inquiries,
attending
conferences.
In
these
cases,
skip
the
individual
permit
burden
and
provide
only
an
average
burden
(
the
last
column)
by
dividing
the
burden
by
your
number
of
part
70
sources.

Some
permits
take
longer
than
others
and
require
more
issue
resolution,
more
gap­
filling
monitoring
determinations,
more
analysis
of
emissions
units/
applicable
requirements,
etc.
The
first
step
is
to
estimate
these
burdens
for
the
individual
permits
that
are
affected.
However,
I
need
an
average
per
permit
value
to
multiply
times
all
permits
to
get
a
program
estimate.
Therefore,
if
some
activities
are
carried
out
for
only
a
portion
of
permits
(
e.
g.,
public
hearing,
flexible
permit
development,
gap­
filling
determination,
alternative
scenarios
development),
after
estimating
the
burden
for
an
activity
for
a
single
permit,
pro­
rate
the
burden
to
obtain
an
average
value
for
all
permits.
For
instance,
if
an
activity
is
performed
for
only
a
third
of
your
permits,
divide
the
burden
value
by
three
to
obtain
an
average
per
permit
value.

This
analysis
will
be
the
burden
of
the
part
70
program
for
the
3
years
from
October
2004
until
October
2007.
Do
not
include
burden
for
activities
that
will
be
completed
by
that
time,
or
that
will
not
occur
during
that
period,
such
as
developing
program
guidance,
training
staff,
determining
completeness
of
permit
applications,
etc.

Thank
you
for
your
help.
PERMITTING
AUTHORITY
ACTIVITIES
BURDEN
HOURS
ACTIVITY
BURDEN
PER
INDIVIDUAL
PERMIT
BURDEN
AVERAGED
OVER
ALL
PERMITS
Responding
to
source
inquires
about
part
70
program
applicability
and
to
public
inquiries
about
the
program.

Part
70
program­
specific:
developing
internal
and
external
program
guidance,
attending
program
training,
providing
source
training,
attending
EPA
meetings
and
conferences,
providing
public
education,
and
other
program
related
activities.

Reviewing
a
permit
application,
including
discussions
with
a
source
concerning
the
permit
application.

Preparing
a
draft
permit,
including
contact
with
the
source.

Providing
notice
to
the
public,
EPA,
and
affected
States
of
the
comment
period
on
a
draft
permit.

Holding
a
public
hearing
on
a
permit.

Interaction
with
EPA
on
a
proposed
permit,
including
negotiations,
re­
drafting,
and
formal
EPA
objections
(
including
those
attributable
to
public
petitions).

Issuing
the
permit,
including
web
activities
and
source
notification.

Revising
a
permit.

Renewing
a
permit.

Reviewing
semiannual
monitoring
reports,
including
annual
compliance
certification.
SOURCE
ACTIVITIES
BURDEN
HOURS
ACTIVITY
BURDEN
PER
SOURCE
BURDEN
AVERAGED
OVER
ALL
SOURCES
Preparing
a
permit
application,
including
internal
meetings,
management
and
legal
department
involvement,
responsible
official
certification,
contractor
services.

Interaction
with
the
permitting
authority
on
the
permit
application
and
draft
permit
development.

Development
of
periodic
monitoring
gap­
filling.

Involvement
with
public
comment
analysis.

Public
hearing
participation.

Operation
of
gap­
filling
periodic
monitoring
(
annual
burden
to
operate
monitors/
recordkeeping/
etc.
plus
one­
time
and
annual
capital
costs
for
any
equipment).

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.

Preparing
application
for
permit
revisions.
Put
in
terms
of
number
of
and
burden
for
each:
N/
A
N/
A
°
Significant
permit
modification
°
Minor
permit
modification
°
Administrative
amendment
Preparing
an
application
for
permit
renewal.

Other
activities
associated
with
permit
renewal,
including
involvement
with
public
comment
analysis
and
public
hearing
participation.
