1
Part
A
of
the
Supporting
Statement
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Application
Requirements
for
the
Approval
and
Delegation
of
Federal
Air
Toxics
Programs
to
State,
Territorial,
Local,
and
Tribal
Agencies"
and
numbered
as
EPA
ICR
Number
1643.05
and
OMB
Control
Number
2060­
0264.
This
is
a
revision
of
the
OMB­
approved
EPA
ICR
Number
1643.04.

1(
b)
Short
Characterization
This
information
collection
is
an
application
from
State,
territorial,
local,
or
tribal
agencies
(
S/
L/
Ts)
for
delegation
of
regulations
developed
under
section
112
of
the
Clean
Air
Act
(
Act).
In
the
time
frame
for
this
submittal,
we,
the
Environmental
Protection
Agency
(
EPA)
estimate
that
the
majority
of
the
delegated
regulations
will
be
those
developed
under
section
112(
d)
of
the
Act.
The
procedures
and
requirements
that
the
S/
L/
Ts
will
use
to
request
the
delegations
are
codified
as
40
CFR
63,
subpart
E,
in
accordance
with
section
112(
l)
of
the
Act.

The
subpart
E
regulations
contain
the
following
five
options
for
delegation:

$
Straight
delegation
$
Rule
adjustment
$
Rule
substitution
$
Equivalency
by
permit
$
State
program
approval.

Straight
delegation
is
the
option
where
the
respondents,
S/
L/
Ts,
choose
to
accept
delegation
of
a
section
112
provision
and
to
implement
and
enforce
the
provision
as
written.
The
S/
L/
Ts
may
use
the
rule
adjustment
option
when
they
want
to
substitute
a
rule
and/
or
requirement
that
is
unequivocally
no
less
stringent
than
the
otherwise
applicable
section
112
standard,
such
as
a
Part
63
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP).
They
may
use
rule
substitution
when
they
wish
to
substitute
individual
rules
and/
or
requirements
in
place
of
the
otherwise
applicable
section
112
standard.
They
may
use
the
equivalency
by
permit
option
when
they
wish
to
substitute
operating
permit
terms
and
conditions
for
a
section
112
standard;
this
option
is
only
applicable
to
a
limited
number
of
sources
using
title
V
permit
terms
and
conditions.
Finally,
S/
L/
Ts
may
use
the
State
program
approval
option
if
they
want
to
substitute
their
overall
air
toxics
program
for
the
Federal
air
toxics
program;
i.
e.,
the
section
112(
d)
standards.

The
delegation
options
vary
in
the
types
of
changes
allowed,
the
level
of
demonstration
required,
and
the
amount
of
time
and
process
needed
to
implement
them.
Respondents
must
submit
any
packages
requesting
delegation
to
their
EPA
Regional
office.
We
must
then
review
2
and
approve,
partially
approve,
or
disapprove
the
request
based
on
the
subpart
E
approval
criteria.
The
request
may
only
take
effect
after
our
approval
(
or
partial
approval
of
a
subset
of
the
request),
public
notice,
and,
in
some
cases,
public
comment.

Subpart
E
also
contains
provisions
for
delegating
accidental
release
prevention
program
authorities
(
40
CFR
Part
68)
under
the
authority
of
section
112(
r)
of
the
Act.
In
addition,
we
also
reserve
the
right
to
review
and
withdraw
an
approved
S/
L/
T
rule,
program,
or
requirement
if
we
decide
it
is
not
as
stringent
as
the
otherwise
applicable
Federal
standard
or
if
the
S/
L/
T
is
failing
to
adequately
implement
or
enforce
it.
Subpart
E
includes
the
procedures
for
this
the
review
and
withdrawal
process.

The
Office
of
Management
and
Budget
(
OMB)
raised
the
following
issues
related
to
the
Terms
of
Clearance
applicable
to
the
currently
approved
collection
(
EPA
ICR
Number
1643.04).
We
have
addressed
these
issues
in
this
proposed
collection
(
ICR
Number
1643.05).

$
EPA
should
take
steps
to
ensure
electronic
reporting,
if
practicable,
in
accordance
with
the
Government
Paperwork
Elimination
Act.
See
section
5(
b)
for
a
discussion
of
this
issue.

$
EPA
should
review
the
estimated
cost
burden
to
ensure
it
accounts
for
non­
labor
costs
(
including
copying
and
mailing
costs).
See
Section
6(
b)
for
a
discussion
of
this
issue.

$
EPA
should
revise
the
wage
rates
used
in
the
ICR
to
use
appropriate
overhead
ratios.
See
Sections
6(
b)
and
6(
c)
for
discussions
of
this
issue.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
/
Authority
for
the
Collection
The
information
is
needed
and
used
to
determine
if
the
entity
submitting
an
application
has
met
the
criteria
established
in
the
subpart
E
rule.
This
information
is
necessary
for
the
Administrator
to
determine
the
acceptability
of
approving
the
S/
L/
T's
rules,
requirements,
or
programs
in
lieu
of
the
Federal
section
112
rules
or
programs.
The
collection
of
information
is
authorized
under
42
U.
S.
C.
7401­
7671q.

2(
b)
Practical
Utility
/
Users
of
the
Data
This
information
is
necessary
for
the
proper
performance
of
our
functions.
The
information
will
have
practical
utility
because
we
will
use
the
information
generated
from
the
collection
to
ensure
that
the
subpart
E
approval
criteria
have
been
met.
3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
This
information
collection
is
not
unnecessarily
duplicative
of
information
otherwise
reasonably
accessible
to
us.
Rather,
for
instances
where
other
reports
required
by
us
would
duplicate
information
required
by
this
rule
(
for
example,
the
part
70
operating
permits
rule),
it
is
possible
to
use
information
previously
submitted
to
the
EPA
to
meet
the
requirements
of
this
information
collection.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
We
solicited
public
comments
on
this
ICR
prior
to
submitting
it
to
the
Office
of
Management
and
Budget.
We
issued
a
Federal
Register
notice
requesting
comments
on
the
amended
burden
estimate
reflected
in
this
ICR
on
April
30,
2004
(
69
FR
23739).
No
significant
comments
were
received.

3(
c)
Consultations
The
final
rule
amendments
for
subpart
E
were
promulgated
on
September
14,
2000
(
65
FR
55810).
Since
then,
we
have
gained
extensive
experience
in
working
with
the
S/
L/
Ts
in
delegating
section
112(
d)
NESHAP.
We
have
consulted
with
knowledgeable
EPA
staff
in
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS),
Office
of
General
Council
(
OGC),
and
Office
of
Enforcement
and
Compliance
(
OECA)
as
well
as
each
of
the
EPA
Regional
Office
Air
Toxics
Coordinators
to
assess
their
experience
in
the
type
of
delegations
used
by
the
S/
L/
Ts,
the
overall
number
of
delegations
granted,
and
the
level
of
effort
expended.
We
used
this
information
to
prepare
this
ICR
renewal
package.

3(
d)
Effects
of
Less
Frequent
Collection
Applicants
are
only
required
to
submit
information
when
they
wish
to
receive
delegation
of
a
promulgated
section
112
standard.
Subpart
E
specifies
the
minimum
information
we
require
to
determine
whether
their
request
is
approvable.
The
rule
clarifies
that
the
respondent
only
needs
to
submit
material
demonstrating
it
meets
the
up­
front
approval
requirements
one­
time,
unless
circumstances
change
at
the
S/
L/
T,
which
would
require
an
updated
submittal.

The
intent
of
this
voluntary
program
is
to
encourage
S/
L/
Ts
to
accept
delegation
of
the
Federal
section
112
standards,
and
to
allow
them
to
adjust
or
substitute
S/
L/
T
requirements
when
they
can
be
shown
to
be
at
least
as
stringent
as
the
Federal
requirements.
These
provisions
for
alternatives
will
help
preserve
existing
S/
L/
T
programs
and
prevent
dual
regulation
of
sources.
4
We
also
reserve
the
right
to
review
and
withdraw
an
approved
S/
L/
T
rule,
program,
or
requirement
if
we
decide
it
is
not
as
stringent
as
the
otherwise
applicable
Federal
standard
or
if
the
S/
L/
T
is
failing
to
adequately
implement
or
enforce
it.
In
this
case,
the
S/
L/
T
would
be
asked
to
submit
information
regarding
permits,
monitoring,
resources,
etc.
We
will
use
this
information
to
decide
if
the
rule,
program,
or
requirement
should
be
withdrawn.
Our
ability
to
review
and
withdraw
approval
is
needed
to
ensure
we
can
satisfy
our
obligations
under
the
Act
to
implement
and
enforce
the
section
112
standards.

3(
e)
General
Guidelines
None
of
the
general
information
collection
guidelines
in
5
CFR
1230.5(
d)(
2)
of
the
OMB
regulations
implementing
the
Paperwork
Reduction
Act
is
being
exceeded
in
the
subpart
E
regulations.

3(
f)
Confidentiality
All
information
submitted
to
us
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B,
Confidentiality
of
Business
Information.
See
40
CFR;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
3999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.
Even
where
we
have
determined
that
data
received
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
Part
2,
Subpart
B,
we
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"
under
the
statute
[
42
U.
S.
C.
7414(
c);
40
CFR
2.301(
g)].
The
information
collection
complies
with
the
Privacy
Act
of
1974
and
Office
of
Management
and
Budget
Circular
108.

3(
g)
Sensitive
Questions
This
section
is
not
applicable.
This
ICR
does
not
contain
any
sensitive
questions
relating
to
sexuality,
religious
beliefs,
or
other
matters
usually
considered
private.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
/
SIC
Codes
Respondents
are
S/
L/
Ts
participating
in
this
voluntary
program.
These
government
establishments
are
classified
as
Air
and
Water
Resource
and
Solid
Waste
Management
Programs
under
Standard
Industrial
Classification
(
SIC)
code
9511
and
North
American
Industry
Classification
System
(
NAICS)
code
92411.
No
industries
under
any
SIC
or
NAICS
codes
will
be
included
among
respondents.
5
4(
b)
Information
Requested
(
i)
Data
Items,
Including
Recordkeeping
Requirements
The
information
requirements
will
vary
depending
upon
the
type
of
option
an
S/
L/
T
chooses
for
accepting
delegation
of
the
Federal
standards.
The
information
requirements
are
as
follows:

For
overall
approval
to
receive
delegation
(
§
63.91)

$
Confirmation
letter
from
the
State
Attorney
General.

$
Demonstration
of
respondent's
resources.

$
Copy
of
the
respondent's
statutes,
regulations
and
other
requirements
that
contain
appropriate
provisions
granting
authority
to
implement
and
enforce
the
respondent's
rule
or
program
upon
approval
us.

$
Respondent's
implementation
schedule.

$
Respondent's
compliance
plan.

$
Respondent's
enforcement
plan.

Once
respondents
have
demonstrated
they
meet
the
overall
approval
criteria,
they
may
request
straight
delegation
(
§
63.91)
of
the
unchanged
section
112
standards.
This
request
may
be
automatic,
i.
e.,
the
overall
delegation
established
that
the
respondent
agreed
to
accept
delegation
of
all
future
NESHAP.
Alternatively,
the
overall
delegation
may
establish
a
procedure
where
the
respondent
requests
delegation
of
individual
standards
when
they
are
promulgated.
Respondents
choosing
to
utilize
any
of
the
other
options
to
demonstrate
the
equivalency
of
their
requirements
to
the
Federal
requirements
must
supply
the
following
information:

For
the
rule
adjustment
option
(
§
63.92):

$
Stringency
and
compliance
demonstration.

For
the
rule
substitution
option
(
§
63.93):

$
Demonstration
of
S/
L/
T
rule
equivalency
with
the
otherwise
applicable
Federal
standard.

For
the
equivalency
by
permit
option
(
§
63.94):

$
A
list
of
affected
sources
and
standards
within
the
respondent's
jurisdiction.

$
Draft
permit
terms
and
conditions.

$
Demonstration
of
the
equivalency
of
S/
L/
T
permit
terms
and
conditions
to
the
otherwise
applicable
Federal
standard.

For
the
State
program
approval
option
(
§
63.97):
6
$
Source
categories
for
submission
within
the
respondent's
jurisdiction.

$
Description
of
enforcement
measures
for
area
sources
(
if
the
otherwise
applicable
Federal
standard
applies
to
area
sources).

$
Collection
of
the
respondent's
rules,
regulations,
permits,
implementation
plans,
or
other
enforceable
mechanisms.

$
Equivalency
demonstration
of
respondents
alternative
rules
to
the
otherwise
applicable
Federal
standard.

For
the
accidental
release
prevention
program
(
§
63.95):

$
Demonstration
of
adequate
resources.

$
Demonstration
of
adequate
enforcement
authority.

$
Description
of
coordination
mechanisms.

We
also
have
the
option
of
withdrawing
a
program
if
we
decide
that
the
S/
L/
T
is
not
properly
implementing
its
rule
or
program
in
lieu
of
the
otherwise
applicable
Federal
standard.
Under
the
EPA
review
and
withdrawal
option
(
§
63.96),
the
respondents
must
submit
the
following:

$
Information
regarding
permits,
monitoring,
resources,
etc.

(
ii)
Respondent
Activities
The
respondent
activities
required
by
the
rule
are
listed
in
the
Table
1a
through
1g.
These
activities
vary
by
option
because
of
the
different
types
of
information
required
under
each
option.
To
the
maximum
extent
practicable,
these
activities
were
developed
to
allow
the
S/
L/
Ts
to
respond
in
ways
that
are
consistent
and
compatible
with
their
existing
reporting
and
recordkeeping
practices.
Note
that
we
only
anticipate
activities
related
to
delegation
options
described
in
Tables
1a
through
1d
during
the
3­
year
approval
period.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
This
section
addresses
the
our
activities
to
review
the
applications
submitted
by
the
S/
L/
Ts
under
subpart
E.
The
activities
vary
according
to
the
option
used
by
the
S/
L/
T
and
are
as
follows:

For
the
overall
approval
to
receive
delegation
(
§
63.91):

$
Create
a
Federal
Register
notice
seeking
public
comment.

$
Review
public
comments.

$
Evaluate
the
S/
L/
T
submittal.
7
$
Create
a
Federal
Register
notice
announcing
approval
or
disapproval
of
the
S/
L/
T
submittal.

For
the
straight
delegation
of
individual
standards,
the
Agency
will
either
automatically
delegate
them
to
the
S/
L/
T
or
delegate
them
in
response
to
a
written
request,
depending
on
the
mechanism
established
via
the
overall
approval.
If
the
S/
L/
T
decides
to
use
any
of
the
other
options
listed
within
subpart
E
to
demonstrate
the
equivalency
of
their
rules
to
the
Federal
rule,
then
we
will
complete
both
the
following
activities
listed
in
the
applicable
option
below.

For
the
rule
adjustment
option
(
§
63.92):

$
Create
a
Federal
Register
notice
seeking
public
comment.

$
Review
public
comments
and
S/
L/
T
responses.

$
Evaluate
the
S/
L/
T
submittal.

$
Create
a
Federal
Register
notice
announcing
the
approval
or
disapproval
of
the
S/
L/
T
submittal.

For
the
rule
substitution
option
(
§
63.93):

$
Create
a
Federal
Register
notice
seeking
public
comment.

$
Review
public
comments
and
S/
L/
T
responses.

$
Evaluate
the
S/
L/
T
submittal.

$
Create
a
Federal
Register
notice
announcing
approval
or
disapproval
of
the
S/
L/
T
submittal.

For
the
equivalency
by
permit
option
(
§
63.94):

$
Create
a
Federal
Register
notice
seeking
public
comment
on
the
up­
front
approval
of
the
S/
L/
T
submittal.

$
Review
public
comments
and
S/
L/
T
responses.

$
Create
a
Federal
Register
notice
announcing
approval
or
disapproval
of
the
S/
L/
T
upfront
submittal.

$
Evaluate
the
draft
permit
terms
and
conditions
submitted
by
the
S/
L/
T.

$
Create
a
final
Federal
Register
notice
announcing
approval
or
disapproval
of
the
draft
permit
terms
and
conditions.

For
the
State
program
approval
option
(
§
63.97):

$
Create
a
Federal
Register
notice
seeking
public
comment
on
the
up­
front
approval
of
the
S/
L/
T
submittal.

$
Review
public
comments
and
S/
L/
T
responses.

$
Create
a
Federal
Register
notice
announcing
approval
or
disapproval
of
the
S/
L/
T
submittal.
8
$
Create
a
Federal
Register
notice
seeking
public
comment
on
the
specific
alternative
rule
submitted
by
the
S/
L/
T.

$
Review
public
comments
and
S/
L/
T
responses.

$
Evaluate
the
equivalency
demonstration
submitted
by
the
S/
L/
T.

$
Create
a
final
Federal
Register
notice
announcing
approval
or
disapproval
of
the
alternative
rules
submitted
by
the
S/
L/
T.

For
the
accidental
release
prevention
program
(
§
63.95):

$
Evaluate
and
approve
or
disapprove
the
S/
L/
T
submittal.

Furthermore,
we
reserve
the
right
to
review
and
withdraw
a
S/
L/
T
rule
or
program
if
we
decide
that
the
program
is
not
as
stringent
as
the
otherwise
applicable
Federal
standard.
During
the
EPA
review
and
withdrawal
option
(
§
63.96),
we
conduct
the
following
activities:

$
Request
information
from
the
affected
S/
L/
T.

$
Evaluate
technical
information,
data,
and
results
of
any
site
visits
within
the
jurisdiction
of
the
S/
L/
T.

$
Create
a
Federal
Register
notice
announcing
our
intent
to
withdraw
the
S/
L/
T
program
or
rule.

$
Evaluate
public
comments
and
S/
L/
T
responses.

$
Create
a
Federal
Register
notice
announcing
the
final
decision.

The
EPA
activities
required
by
the
rule
and
the
technical
hours
associated
with
them
are
found
in
Tables
2a
through
2g.
Note
that
we
only
anticipate
activities
related
to
delegation
options
described
in
Tables
2a
through
2d
during
the
3­
year
approval
period.

5(
b)
Collection
Methodology
and
Management
All
S/
L/
Ts
using
subpart
E
to
accept
delegation
of
Federal
standards
must
submit
the
proper
application
to
us
for
review
and
evaluation.
They
should
prepare
their
applications
using
guidance
we
issued
in
April
2001
to
facilitate
subpart
E
implementation.
This
guidance
is
available
on
the
internet
at
www.
epa.
gov/
ttn/
atw/
112(
l)/
112­
lpg.
html.
The
regulations
contain
no
forms.

Qualified
staff
that
work
for
the
EPA
Regional
offices
as
well
as
EPA
Headquarters
will
review
the
subpart
E
applications.
The
S/
L/
Ts
must
supply
any
calculations
and
assumptions
supporting
the
technical
portion
of
the
application,
and
we
will
review
these
supporting
materials
to
verify
them.
In
regard
to
information
management,
we
have
planned
and
allocated
resources
for
the
efficient
and
effective
use
of
the
information,
including
the
processing
of
the
information
in
a
manner
which
enhances
the
utility
of
the
information
to
us
and
to
the
public.
For
example,
in
most
cases,
existing
S/
L/
T
part
70
operating
permit
program
approvals
may
be
used
to
meet
the
up­
front
approval
criteria
in
§
63.91.
9
The
subpart
E
regulations
do
not
require
the
request
of
information
through
any
type
of
survey.

Electronic
submission
of
S/
L/
T
subpart
E
applications
is
acceptable
in
general;
however,
whether
Regional
offices
accept
them
electronically
may
vary
from
Region
to
Region.
The
S/
L/
Ts
should
work
with
their
applicable
EPA
Regional
office
to
determine
the
exact
procedures
to
follow
in
using
an
electronic
format.
Approvals
still
have
to
be
sent
to
the
Federal
Register
for
publication,
but
courtesy
copies
can
be
sent
to
S/
L/
Ts
via
e­
mail.

5(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
principle
for
our
efforts.
The
subpart
E
regulations
only
include
the
application,
recordkeeping
and
reporting
requirements
we
need
to
determine
compliance
with
the
rule.
We
have
reduced
the
collection
burden
to
the
extent
practicable
and
appropriate,
including
consideration
of
the
resources
available
to
the
respondents
and
clarifying,
consolidating,
and
simplifying
the
requirements.
Furthermore,
we
do
not
anticipate
that
any
small
entities
will
be
participating
in
this
program.

5(
d)
Collection
Schedule
The
schedule
is
tied
to
the
promulgation
of
Federal
section
112
standards.
As
these
are
issued,
S/
L/
Ts
may
request
delegation.
Each
S/
L/
T
may
submit
an
application
under
one
of
the
five
options
discussed
in
section
1(
b).
Preparation
of
an
application
in
compliance
with
subpart
E
is
a
one­
time
per
standard
activity.
The
subpart
E
regulations
do
not
require
periodic
reporting
or
surveys.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
ICR
requires
the
calculation
of
the
amount
of
burden
hours
associated
with
each
activity
for
each
respondent
(
S/
L/
T)
when
complying
with
the
subpart
E
regulations.
In
calculating
the
burden
hours
for
subpart
E,
we
made
assumptions
about
the
number
of
S/
L/
Ts
that
would
use
each
option
as
well
as
the
total
number
of
Federal
standards
delegated
by
each
option.
Over
the
3­
year
period
of
this
ICR,
we
expect
to
promulgate
and
delegate
the
remaining
10­
year
NESHAP,
which
are
approximately
20
standards.
In
addition
to
these
20,
our
information
gathering
informed
us
that
EPA
Region
6
will
be
approving
more
than
60
existing
NESHAP
for
Texas
and
for
the
Albuquerque
Air
Quality
Control
Board
(
AQCB)
in
2004.
Although
we
are
currently
developing
section
112
residual
risk
standards
and
area
source
standards,
we
do
not
expect
these
standards
to
be
promulgated
in
time
for
S/
L/
Ts
to
request
their
delegation
within
the
applicable
3­
year
time
frame.
10
Based
on
our
consultations
as
described
in
section
3(
c),
we
assumed
that
124
of
the
127
S/
L/
Ts
would
continue
to
maintain
their
subpart
E
program
and
that
80
percent
of
S/
L/
Ts
will
delegate
the
NESHAP
via
the
Straight
Delegation
option;
3
percent
via
the
Rule
Adjustment
Option;
5
percent
through
the
Rule
Substitution
Option;
12
percent
through
the
Equivalency
by
Permit
Option;
and
none
through
the
State
Program
Approval
Option.
Moreover,
we
assumed
that
6
percent
of
the
S/
L/
Ts
would
be
applying
for
initial
approval
of
the
Equivalency
by
Permit
Option
and
that
no
S/
L/
Ts
would
apply
for
initial
approval
of
the
State
Program
Approval
Option.
We
also
assumed
that
no
more
S/
L/
Ts
would
be
accepting
delegation
of
the
section
112(
r)
program
and
that
we
would
withdraw
no
approvals
over
the
3­
year
period.

We
assumed
that
the
total
number
of
occurrences
during
the
3­
year
period
would
be
as
follows:
372
for
maintaining
the
subpart
E
program;
2,134
for
straight
delegation
(
this
includes
the
extra
delegations
for
Texas
and
the
Albuquerque
AQCB);
74
for
the
Rule
Adjustment
Option;
124
for
the
Rule
Substitution
Option;
21
initial
Equivalency
by
Permit
Option
approvals;
and
298
Equivalency
by
Permit
Option
per
NESHAP
approvals;
and
0
for
the
State
Program
Approval
Option.
Figure
1
provides
a
flowchart
on
how
we
allocated
the
number
of
S/
L/
Ts
using
each
option
and
the
amount
of
occurrences.
Table
3
shows
the
total
number
of
occurrences
for
each
option.
Based
on
this
information,
we
estimate
that
the
average
number
of
responses
per
year
is
1,008.

With
one
exception,
in
calculating
the
burden
hours
associated
with
each
delegation
option,
we
retained
the
same
activities
and
burden
hour
estimates
used
in
the
previous
ICR
(
ICR
Number
1643.04)
for
subpart
E.
However,
for
the
burden
associated
with
the
overall
approval
to
receive
delegation
(
see
table
1a),
we
assumed
that
all
S/
L/
Ts
have
completed
the
delegation
request
activities
and
are
now
merely
maintaining
their
programs.

The
total
hours
associated
with
each
option
in
tables
1a
through
1g
are
for
technical
hours
only.
Consistent
with
the
previous
ICR,
we
calculated
management
hours
as
5
percent
of
technical
hours
and
clerical
hours
as
10
percent
of
technical
hours.
Table
4a
contains
the
results
of
the
burden
hours
calculation
for
each
activity
during
each
year
of
this
ICR.
Overall,
the
promulgated
subpart
E
regulations
contain
an
average
burden
of
41,577
hours
per
year.

6(
b)
Estimating
Respondent
Cost
(
i)
Estimating
Labor
Costs
To
estimate
respondent
labor
costs,
we
used
State
and
local
government
wage
rates
and
benefit
costs
obtained
from
the
Bureau
of
Labor
Statistics
(
BLS).
We
chose
the
different
pay
grade
levels
for
management,
technical,
and
clerical
personnel
by
following
the
example
set
by
other
ICRs.
We
calculated
the
overhead
rate
as
50
percent
of
the
total
compensation
rate
(
i.
e.,
salary
plus
benefits).
The
addition
of
benefits
and
overhead
to
the
hourly
rate
produces
a
pay
rate
that
reflects
the
true
cost
to
employ
a
State
worker.
Following
is
a
summary
of
the
computed
wages
for
S/
L/
T
personnel.
11
Labor
Type
Base
Salary,
Hourly
Rate
Benefit
Hourly
Rate
Overhead
Hourly
Rate
Adjusted
Hourly
Rate
Management
28.83
13.07
20.95
62.85
Technical
19.43
9.33
14.38
43.14
Clerical
14.08
7.58
10.83
32.49
The
respondent
labor
costs
are
found
by
multiplying
the
burden
hours
associated
with
each
activity
by
the
hourly
rate
associated
with
each
labor
type.
In
total,
the
subpart
E
regulations
contain
an
average
labor
cost
of
$
1,790,760
per
year.
Table
4a
contains
the
results
of
the
calculation
of
labor
costs
for
the
respondents.

(
ii)
Capital
/
Start­
up
Costs
This
ICR
does
not
require
any
capital
or
start­
up
costs
for
equipment,
machinery,
and
construction.

(
iii)
Operating
and
Maintenance
(
O&
M)
Costs
Respondents
who
choose
to
request
delegation
under
subpart
E
must
submit
a
complete
application,
which
results
in
photocopying
and
postage
costs.
We
determined
that
two
types
of
documents
would
be
both
copied
and
mailed:
2­
ounce
letters
and
1­
pound
packages.
The
2­
ounce
letter
would
contain
5
pages,
and
the
1­
pound
package
would
contain
200
pages.
Based
on
the
typical
price
to
copy
a
page,
we
used
$
0.05
a
page
as
our
price
per
unit
cost
of
copying.
The
cost
for
mailing
a
2­
ounce
letter
and
1­
pound
package
via
the
United
States
Postal
Service
is
$
0.60
and
$
3.85,
respectively.
We
also
assumed
that
a
total
of
three
copies
would
be
made
for
each
letter
or
package.
Tables
5a
through
5d
show
the
activities
that
would
require
copying
and
postage.
Table
6
summarizes
the
total
copying
and
mailing
costs
per
year.
For
respondents,
the
average
cost
for
copying
and
postage
is
$
25,720
per
year.
Therefore,
the
average
total
cost
to
respondents,
including
labor
cost
and
copying/
postage
cost
is
$
1,816,490
per
year.
Table
7
shows
this
breakdown
by
year.

6(
c)
Estimating
Agency
Burden
and
Cost
Under
the
subpart
E
regulations,
we
must
review
and
evaluate
the
subpart
E
applications
submitted
by
the
S/
L/
Ts.
In
reviewing
and
evaluating
these
applications,
we
will
carry
out
the
activities
listed
in
section
5(
a)
of
this
ICR.
Managerial
activities
are
considered
5
percent
of
the
technical
hours
while
clerical
activities
are
considered
10
percent
of
the
technical
hours.
12
We
calculated
hourly
rates
for
EPA
employees
using
information
on
annual
salaries
from
the
Internet
site
for
the
Office
of
Personnel
Management
for
the
appropriate
pay
grade
levels
for
management,
technical,
and
clerical
personnel.
We
divided
the
annual
pay
rate
by
2,080,
the
amount
of
working
hours
during
a
calendar
year,
to
get
the
hourly
wage
rate
and
then
multiplied
this
rate
by
a
1.6
benefit
multiplier
factor
to
produce
a
pay
rate
that
reflects
the
true
cost
to
the
Federal
government
to
employ
a
Federal
worker.
Following
is
a
summary
of
the
computed
wages
for
EPA
personnel.

Labor
Type
Pay
Grade
Annual
Salary
Hourly
Rate
Adjusted
Hourly
Rate
Management
GS­
15
$
99,099
$
47.64
$
76.23
Technical
GS­
12
$
59,951
$
28.82
$
46.12
Clerical
GS­
6
$
30,416
$
14.62
$
23.40
The
EPA
labor
costs
are
found
by
multiplying
the
burden
hours
associated
with
each
activity
by
the
hourly
rate
associated
with
each
labor
type.
Overall,
the
average
burden
hours
for
the
EPA
is
32,731
hours
per
year.
Table
4b
contains
a
breakdown
of
EPA
burden
hours
per
year.
The
average
labor
cost
for
the
EPA
is
$
1,487,770
dollars
per
year.
Table
4b
contains
a
breakdown
of
EPA
labor
costs
per
year.
Copying
and
postal
costs
for
the
EPA
were
calculated
in
the
same
manner
as
described
in
the
last
paragraph
of
section
6(
b).
Tables
5a
through
5d
contain
a
detailed
listing
of
EPA
copying
and
postal
costs.
Table
6
presents
the
total
EPA
copying
and
postal
costs.
The
EPA
would
spend
an
average
of
$
670
on
copying
and
postage.
The
total
cost
for
EPA,
including
labor
and
copying/
postal
costs
would
be
an
average
of
$
1,488,440
per
year.
Table
7
shows
a
breakdown
of
the
total
cost
for
the
EPA
by
year.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
In
order
to
estimate
the
number
of
S/
L/
Ts
participating
in
the
subpart
E
program,
we
obtained
information
from
the
Regional
Air
Toxic
Coordinator
contacts
regarding
subpart
E
delegation
activity
in
their
Regions.
We
determined
that
124
agencies
are
participating
in
the
subpart
E
program.
The
breakdown
of
these
agencies
is
as
follows:
49
State
agencies,
4
territorial
agencies,
66
local
agencies,
and
5
Tribal
agencies.

As
indicated
in
Table
4a,
the
total
respondent
burden
for
the
124
S/
L/
Ts
is
124,730
hours.
As
shown
in
Table
7,
the
total
respondent
cost
is
$
5,449,460.
13
6(
e)
Bottom
Line
Burden
Hours
and
Cost
(
i)
Respondent
Tally
Over
the
3­
year
period
of
this
ICR,
the
total
average
annual
burden
and
labor
cost
for
the
respondents
resulting
from
the
subpart
E
regulations
are
41,577
hours
and
$
1,790,760,
respectively.
Table
4a
contains
the
bottom
line
estimate
of
burden
hours
and
labor
cost
associated
with
the
subpart
E
regulations.
There
are
no
capital
start­
up
costs
associated
with
this
collection.
Operation
and
maintenance
costs
result
from
photocopying
and
postage
expenses,
which
are
a
total
of
$
25,720
per
year.
Table
6
shows
the
O&
M
costs.
The
total
average
annual
cost
to
respondents
is
$
1,816,490.
Table
7
contains
the
total
estimate
of
costs
associated
with
the
subpart
E
regulations.

(
ii)
Agency
Tally
Over
the
3­
year
period
of
this
ICR,
the
total
average
annual
burden
and
labor
cost
for
the
EPA
is
32,731
hours
and
$
1,487,770,
respectively.
Table
4b
contains
the
bottom
line
estimate
of
burden
hours
and
labor
cost
associated
with
the
subpart
E
regulations.
Operation
and
maintenance
costs
result
from
photocopying
and
postage
expenses,
which
are
a
total
of
$
670
per
year.
Table
6
shows
the
O&
M
costs.
The
total
average
annual
cost
to
EPA
is
$
1,488,440.
Table
7
contains
the
total
estimate
of
costs
associated
with
the
subpart
E
regulations.

6(
f)
Reasons
for
Change
in
Burden
The
currently
approved
reporting
and
recordkeeping
hour
burden,
based
on
ICR
Number
1643.04,
is
137,549
hours
per
year.
We
are
requesting
a
decrease
in
burden
to
41,577
hours
per
year.
The
difference,
95,972
hours,
is
due
to
a
program
adjustment.
The
following
discussion
explains
these
changes.

The
changes
in
burden
are
related
to
four
main
changes:
(
1)
a
reduced
number
of
occurrences
related
to
the
number
of
participating
S/
L/
Ts
and
the
number
of
NESHAP
delegated;
(
2)
a
change
in
the
distribution
of
S/
L/
Ts
using
each
option;
(
3)
the
assumption
that
some
portions
of
the
subpart
E
program
will
not
be
used
over
the
next
3
years;
and
(
4)
the
reduction
of
hours
per
occurrence
related
to
overall
program
approval.
These
changes
are
discussed
below.

First,
the
number
of
occurrences
has
decreased
because
fewer
S/
L/
Ts
are
participating
in
the
program,
and
fewer
NESHAP
are
being
promulgated.
Based
on
our
consultations
with
the
Regional
Air
Toxics
Coordinators,
we
determined
that
1
State
agency
and
2
local
agencies
will
not
be
participating
in
the
subpart
E
program
over
the
next
3
years.
This
reduces
the
number
of
S/
L/
Ts
participating
in
the
program
by
3
from
127
S/
L/
Ts
to
124
S/
L/
Ts.
Also,
we
will
have
promulgated
the
remaining
10­
year
NESHAP
in
2003
and
2004.
We
have
assumed
that
the
last
20
standards
will
be
delegated
over
the
next
3
years.
This
is
15
NESHAP
fewer
than
the
previous
3­
year
period.
14
Second,
based
on
the
experience
the
Regional
Air
Toxics
Coordinators
have
had
with
the
subpart
E
program,
S/
L/
Ts'
use
of
the
various
delegation
options
has
changed.
As
shown
in
the
table
below,
Straight
Delegation
is
still
the
primary
delegation
mechanism
and
we
have
assumed
that
all
of
the
S/
L/
Ts
will
continue
to
maintain
their
overall
program
approval
delegation.
However,
we
found
that
S/
L/
Ts
are
using
the
Equivalency
by
Permit
Option,
the
Rule
Adjustment
Option,
and
the
Rule
Substitution
Option
with
greater
frequency
than
previously
assumed.
Also,
no
sources
have
yet
to
use
the
State
Program
Approval
Option,
nor
are
any
expected
to
do
so
in
the
upcoming
3­
year
clearance
period.

Option
Percent
Distribution
of
Responses
2001
2004
Difference
Straight
Delegation
(
§
63.91)
91.45%
82.90%
­
8.55%

Rule
Adjustment
Option
(
§
63.92)
0.02%
2.45%
2.43%

Rule
Substitution
Option
(
§
63.93)
3.33%
4.10%
0.77%

Equivalency
by
Permit
Option
(
§
63.94)
4.97%
10.55%
5.58%

State
Program
Approval
Option
(
§
63.97)
0.22%
0.00%
­
0.22%

Third,
we
determined
through
our
consultations
that
the
delegation
of
the
section
112(
r)
standards
as
well
as
the
EPA
Withdrawal
Option
will
not
have
any
occurrences.
All
of
the
S/
L/
Ts
accepting
delegation
of
the
Accidental
Release
Prevention
Program
(
§
63.95)
have
completed
the
delegation
process.
Therefore,
we
assume
that
the
predicted
number
of
occurrences
of
this
portion
of
the
subpart
E
program
will
drop
from
127
occurrences
to
0
occurrences.
Likewise,
our
consultations
with
knowledgeable
OAQPS
staff
showed
that
the
EPA
does
anticipate
the
need
to
withdraw
any
of
the
already
delegated
S/
L/
T
programs
over
the
next
3
years.
Thus,
the
occurrences
of
the
EPA
Withdrawal
Option
(
§
63.96)
are
expected
to
drop
from
2
occurrences
to
0
occurrences.

Fourth,
we
have
assumed
that
all
S/
L/
Ts
who
wish
to
seek
subpart
E
program
approval
have
completed
that
process
before
the
applicable
date
of
this
ICR.
S/
L/
Ts
will
now
be
maintaining
their
programs,
which
would
result
in
a
reduction
of
the
amount
of
hours
needed
per
occurrence.
In
the
previous
ICR,
the
amount
of
hours
per
occurrence
for
this
part
of
the
program
was
75.5
hours
per
occurrence.
Over
the
next
3
years,
we
anticipate
that
only
20
hours
per
occurrence
will
be
necessary
for
the
S/
L/
Ts
to
maintain
their
subpart
E
programs.
15
Overall,
the
respondent
hour
burden
has
decreased.
The
table
below
breaks
this
decrease
down
by
option.
As
shown
below,
the
amount
of
hours
increases
for
the
Rule
Adjustment
Option
while
all
of
the
other
aspects
of
the
subpart
E
program
decrease.
However,
due
to
the
overall
decrease
in
the
amount
of
occurrences,
the
overall
burden
decreases
by
almost
70
percent.

Option
Average
Annual
Burden
(
hr/
yr)

2001
2004
Difference
Percent
Difference
Straight
Delegation
Option
(
§
63.91)
50773.5
11032.3
­
39741.2
­
78.3%

Rule
Adjustment
Option
(
§
63.92)
91.8
1863.0
1771.2
1929.4%

Rule
Substitution
Option
(
§
63.93)
38924.0
10528.6
­
28395.4
­
73.0%

Equivalency
by
Permit
Option
(
§
63.94)
42424.7
18152.8
­
24271.9
­
57.2%

Accidental
Release
Prevention
Program
(
§
63.95)
3005.7
0.0
­
3005.7
­
100.0%

EPA
Withdrawal
(
§
63.96)
76.7
0.0
­
76.7
­
100.0%

State
Program
Approval
Option
(
§
63.97)
2252.4
0.0
­
2252.4
­
100.0%

Total
137548.8
41576.7
­
95972.1
­
69.8%

Similarly,
the
respondent
average
total
labor
cost
per
year
decreased
by
66
percent.
The
breakdown
by
option
within
the
subpart
E
program
is
shown
in
the
table
below.
The
increase
in
the
total
average
annual
cost
for
the
Rule
Adjustment
Option
reflects
the
increase
in
the
amount
of
burden
for
that
particular
option.
However,
the
overall
total
cost
burden
decreases
for
the
same
reasons
discussed
above.
The
amount
of
decrease
is
less
than
the
amount
of
decrease
in
hours
largely
due
to
increases
in
the
average
labor
wage
rates,
which
were
updated
to
reflect
current
estimates.

We
are
requesting
an
increase
in
the
reporting
and
recordkeeping
cost
burden
due
to
the
addition
of
photocopying
and
postage
costs
for
the
delegation
applications
as
part
of
annual
O&
M
costs.
The
current
collection
does
not
reflect
these
costs,
so
this
is
a
program
adjustment.
Our
assumptions
for
copying
and
postage
costs
are
discussed
in
section
6(
b).
The
total
copying
and
postage
costs
for
S/
L/
Ts
is
$
25,720
per
year,
of
which
78
percent
is
associated
with
obtaining
straight
delegation
of
the
NESHAP.
16
Option
Average
Annual
Total
Cost
($
1,000/
yr)
H
2001
2004
Difference
Percent
Difference
Straight
Delegation
Option
(
§
63.91)
1991.70
475.17
­
1516.53
­
76.1%

Rule
Adjustment
Option
(
§
63.92)
3.50
80.26
76.76
2193.1%

Rule
Substitution
Option
(
§
63.93)
1509.30
453.48
­
1055.82
­
70.0%

Equivalency
by
Permit
Option
(
§
63.94)
1624.87
781.86
­
843.01
­
51.9%

Accidental
Release
Prevention
Program
(
§
63.95)
102.23
0.00
­
102.23
­
100.0%

EPA
Withdrawal
(
§
63.96)
3.03
0.00
­
3.03
­
100.0%

State
Program
Approval
Option
(
§
63.97)
87.17
0.00
­
87.17
­
100.0%

Total
5321.80
1790.76
­
3531.03
­
66.4%

6(
g)
Burden
Statement
This
estimate
includes
all
activities
associated
with
this
ICR.
Overall,
the
subpart
E
program
will
have
the
following
total
average
annual
burden:
41,577
hours
and
$
1,816,490
(
total
costs)
for
the
respondents
and
32,731
hours
and
$
1,488,440
(
total
costs)
for
the
EPA.
Tables
4a,
4b,
and
7
provide
a
breakdown
of
the
amount
of
hours
and
dollars
spent
each
year.
The
respondents'
average
hour
burden
is
335
hours
per
S/
L/
T
and
41
hours
per
application.
The
average
cost
burden
is
$
14,649
per
S/
L/
T
and
$
1,802
per
application.
The
average
burden
per
application
for
EPA
is
32
hours
and
$
1,476.

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
need
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
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
regulation
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.
17
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2004­
0065,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2004­
0065)
and
OMB
control
number
(
2060­
0264)
in
any
correspondence.
18
Part
B
of
the
Supporting
Statement
Part
B
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
19
FIGURE
20
Total
S/
L/
Ts
with
approved
subpart
E
program:
124
Total
MACT
to
be
delegated
over
3­
year
period:
20
aAssumes
all
124
have
previously
accepted
delegation
and
are
only
maintaining
their
program.

bThis
number
also
includes
150
existing
MACT
to
be
delegated
to
Texas
and
Albequerque
AQCB.
This
estimates
75
MACT
promulgated
to
each
agency.

cThis
number
is
related
only
to
the
number
of
S/
L/
Ts
seeking
initial
approval
of
the
Equivalency
by
Permit
Option.

Year
1:

124a
Initial
Program
Approval
(
§
63.91)

Year
2:

124a
Year
3:

124a
Total:

372
%
Taking
Delegation:

100
Straight
Delegation
(
per
MACT)

(
§
63.91)

Year
1:

1,142b
Year
2:

694
Year
3:

298
Total:

2,134
%
Taking
Delegation:

80
Rule
Adjustment
Option
(
§
63.92)

%
Taking
Delegation:

3
Year
1:

37
Year
2:

26
Year
3:

11
Total:

74
Rule
Substitution
Option
(
§
63.93)

%
Taking
Delegation:

5
Year
1:

62
Year
2:

43
Year
3:

19
Total:

124
Equivalency
by
Permit
Option
(
Initial
Approval)

(
§
63.94)

%
Taking
Delegation:

6
Year
1:

7c
Year
2:

7c
Year
3:
7c
Total:

21
Equivalency
by
Permit
Option
(
per
MACT)

(
§
63.94)

%
Taking
Delegation:

12
Year
1:

149
Year
2:

104
Year
3:

45
Total:

298
Total
Occurrences:

3,023
The
amount
of
occurrences
was
determined
by
multiplying
the
total
number
of
S/
L/
Ts
by
the
following
MACT
delegation
distribution:

Year
1
 
10,
Year
2
 
7,
Year
3
 
3.
This
number
was
then
multiplied
by
the
percentage
distribution
for
each
option
as
listed
below.

Figure
1.
Allocation
of
Subpart
E
Delegation
Options
21
TABLES
22
Table
1a.
Activity
and
Burden
for
the
Overall
Approval
to
Receive
Delegation/
Straight
Delegation
(
§
63.91)
H
Activity
Technical
Hours
per
Occurrence
A.
Read
Rule
0
B.
Receive
Training
on
Rule
0
C.
Plan
Process
0
D.
Create
Confirmation
Letter
from
Attorney
General
0
E.
Create
Adequate
Resources
Demonstration/
Legal
Authority
0
F.
Supply
a
Copy
of
State
Statutes,
Regulations,
and
Requirements
0
G.
Create
Expeditious
Implementation
Schedule
and
Compliance
Plan
0
H.
Compile,
Process,
and
Review
Information
0
I.
Create
Overall
Cover
Letter
0
J.
Fill
Out
Completeness
Checklist
0
K.
Send
Submittal
to
EPA
0
L.
Store,
File,
and
Maintain
Information
20
Total
(
hr/
yr)
20
M.
Request
Straight
Delegation
of
NESHAP
10
HFor
this
renewal
period,
we
assumed
that
all
agencies
have
already
completed
activities
A­
K
and
have
received
upfront
delegation.
23
Table
1b.
Activity
and
Burden
for
the
Rule
Adjustment
Option
Activity
Technical
Hours
per
Occurrence
A.
Conduct
State
Rulemaking
35
B.
Collect
Alternative
Rule
and
NESHAP
for
Analysis
and
Demonstrate
Stringency
15
C.
Fill
out
Completeness
Checklist
1
D.
Send
Submittal
to
EPA
1.5
E.
Store,
File,
and
Maintain
Information
20
Total
(
hr/
yr)
72.5
24
Table
1c.
Respondent
Activity
and
Burden
for
the
Rule
Substitution
Option
(
§
63.93)

Activity
Technical
Hours
per
Occurrence
A.
Conduct
Rulemaking
and
Respond
to
Public
Comments
45
B.
Prepare
Equivalency
Demonstration
Table
60
C.
Prepare
Narrative
Text
for
Equivalency
Demonstration
Table
60
D.
Prepare
Cover
Letter
and
Completeness
Checklist
for
Submittal
Package
10
E.
Send
Submittal
to
EPA
1.5
F.
Respond
to
Public
Comments
25
G.
Store,
File,
and
Maintain
Information
20
Total
(
hr/
yr)
221.5
25
Table
1d.
Respondent
Activities
and
Burden
for
the
Equivalency
by
Permit
Option
(
§
63.94)

Activity
Technical
Hours
per
Occurrence
One­
Time
Activities
A.
Preparation
of
List
of
Affected
Sources
and
Affected
112
Standards
20
Activities
per
Standard
A.
Collection
of
Draft
Terms
and
Conditions
to
Submit
to
EPA
20
B.
Alteration
of
Draft
Terms
and
Conditions
26
C.
Preparation
of
Side­
by­
Side
Comparison
of
Alternative
Requirements
30
D.
Preparation
of
Narrative
to
Side­
by­
Side
Comparison
30
E.
Completion
of
Cover
Letter
and
Completeness
Checklist
for
Submittal
to
EPA
10
F.
Send
Submittal
to
EPA
1.5
G.
Incorporation
of
Alternative
Requirements
into
Permits
20
H.
Store,
File,
and
Maintain
Information
20
Total
(
hr/
yr)
158
26
Table
1e.
Respondent
Activities
and
Burden
for
the
State
Program
Approval
Option
(
§
63.97)
H
Activity
Technical
Hours
per
Occurrence
One­
time
activities
A.
Collection
of
Source
Categories
for
Submission
0
B.
Description
of
Enforcement
Measures
for
Area
Sources
15
C.
Preparation
of
Up­
front
Submittal
to
EPA
40
Activities
per
Standard
A.
Participation
in
the
Review
of
Public
Comments
and
Consultations
20
B.
Collection
of
State
Rules,
Regulations,
Permits,
Implementation
Plans,
or
Other
Enforceable
Mechanisms
and
State
Rulemaking
60
C.
Preparation
of
Equivalency
Demonstration
Table
40
D.
Preparation
of
Narrative
to
Accompany
Equivalency
Demonstration
Table
40
E.
Preparation
of
Submission
to
EPA
and
Completeness
Checklist
5
F.
Submittal
to
EPA
1.5
G.
Store,
File,
and
Maintain
Information
20
Total
(
hr/
yr)
251.5
HNot
expected
to
use
this
option
during
3­
year
period.
27
Table
1f.
Respondent
Activities
and
Burden
for
the
Accidental
Release
Prevention
Program
(
§
63.95)
H
Activity
Technical
Hours
per
Occurrence
A.
Resource
Demonstration
5
B.
Demonstration
of
Adequate
Enforcement
Authority
20
C.
Description
of
Coordination
Mechanism
15
D.
Preparation
of
Package
for
Submission
to
the
EPA
25
Total
(
hr/
yr)
65
HNot
expected
to
use
this
option
during
3­
year
period.
28
Table
1g.
Respondent
Activities
and
Burden
for
the
EPA
Review
and
Withdrawal
Option
(
§
63.96)
H
Activity
Technical
Hours
per
Occurrence
A.
Respond
to
Information
Requests
(
permits,
monitoring,
meetings,
etc.)
30
B.
S/
L/
T
attempts
to
correct
deficiencies
30
C.
Notification
to
Sources
of
Withdrawal
40
Total
(
hr/
yr)
100
HNot
expected
to
use
this
option
during
3­
year
period.
29
Table
2a.
EPA
Activities
and
Burden
for
the
Overall
Approval
to
Receive
Delegation/
Straight
Delegation
(
§
63.91)
H
Activity
Technical
Hours
per
Occurrence
A.
Review
Submission
for
Completeness
0
B.
Notification
to
State
of
Complete/
Incomplete
Application
0
C.
Creation
of
Federal
Register
Notice
to
Seek
Public
Comment
0
D.
EPA
Review
of
Public
Comments
and
S/
L/
T
Responses
0
E.
EPA
Evaluation
of
General
Criteria
0
F.
Creation
of
Final
Federal
Register
Notice
0
G.
Answer
Respondent
Questions
10
H.
Store,
File,
and
Compile
Information
10
Total
(
hr/
yr)
20
I.
Send
Letter
Granting
Straight
Delegation
5
HFor
this
renewal
period,
we
assumed
that
all
agencies
have
already
completed
activities
A­
F
and
have
received
upfront
delegation.
30
Table
2b.
EPA
Activities
and
Burden
for
the
Rule
Adjustment
Option
(
§
63.92)

Activity
Technical
Hours
per
Occurrence
A.
Creation
of
Federal
Register
Notice
to
Seek
Public
Comment
5
B.
EPA
Review
of
Public
Comments
and
S/
L/
T
Responses
20
C.
EPA
Evaluation
of
General
Criteria
5
D.
Creation
of
Final
Federal
Register
Notice
5
E.
Answer
Respondent
Questions
15
F.
Store,
File,
and
Compile
Information
10
Total
(
hr/
yr)
60
31
Table
2c.
EPA
Activities
and
Burden
for
the
Rule
Substitution
Option
(
§
63.93)

Activity
Technical
Hours
per
Occurrence
A.
Review
Submission
for
Completeness
10
B.
Creation
of
Federal
Register
Notice
to
Seek
Public
Comment
5
C.
EPA
Review
of
Public
Comments
20
D.
EPA
Evaluation
of
Equivalency
Demonstrations
80
E.
Creation
of
Final
Federal
Register
Notice
10
F.
Answer
Respondent
Questions
35
G.
Store,
File,
and
Compile
Information
10
Total
(
hr/
yr)
170
32
Table
2d.
EPA
Activities
and
Burden
for
the
Equivalency
by
Permit
Option
(
§
63.94)

ActivityH
Technical
Hours
per
Occurrence
A.
Notification
of
Whether
Alternative
Rule
Submittal
is
Complete
(
Letter
and
Consultations)
10
B.
Creation
of
Federal
Register
notice
for
Public
Comment
for
Up­
front
Approval
5
C.
Review
of
Public
Comments
and
S/
L
Responses
for
Up­
front
Approval
30
D.
Creation
of
Federal
Register
Notice
to
Approve/
Disapprove
Program
25
E.
Notification
to
Respondent
of
Complete
Package
of
Alternative
Terms
and
Conditions
for
Approval
10
F.
Evaluation
of
Draft
Permit
Terms
and
Conditions
50
G.
Creation
of
Notification
of
Approved/
Disapproved
Draft
Permit
Terms
and
Conditions
(
Letters
and
Meetings)
20
H.
Creation
of
Final
Federal
Register
Notice
for
Notification
15
I.
Answer
Respondent
Questions
35
J.
Store,
File,
and
Maintain
Information
10
Total
(
hr/
yr)
140
H
Assumes
that
any
up­
dates
by
the
respondent
to
the
list
of
affected
sources
and
standards
will
be
incorporated
as
part
of
any
individual
requests.
33
Table
2e.
EPA
Activities
and
Burden
for
the
State
Program
Approval
Option
(
§
63.97)
H
Activity
Technical
Hours
per
Occurrence
A.
Notification
by
Letter
and
Meetings
of
Whether
Alternative
Rule
Submittal
is
Complete
10
B.
Creation
of
Federal
Register
Notice
for
Public
Comment
for
Upfront
Approval
5
C.
Review
of
Public
Comments
and
S/
L/
T
Responses
for
Up­
front
Approval
30
D.
Creation
of
Federal
Register
Notice
to
Approve/
Disapprove
Submittal
25
E.
Notification
of
Complete
Alternative
Requirements
10
F.
Creation
of
Federal
Register
Notice
for
Public
Comment
on
Alternative
Rules
5
G.
Review
of
Public
Comments
and
State
Responses
on
Alternative
Rules
40
H.
Evaluation
of
Equivalency
Demonstration
40
I.
Creation
of
Final
Federal
Register
Notice
for
Notification
25
J.
Answer
Respondent
Questions
35
K.
File,
Store,
and
Maintain
Information
10
Total
165
HNot
expected
to
use
this
option
during
3­
year
period.
34
Table
2f.
EPA
Burden
and
Activities
for
the
Accidental
Release
Prevention
Program
(
§
63.95)*

Activity
Technical
Hours
per
Occurrence
Evaluation
of
Submission
for
Approval
25
HNot
expected
to
use
this
option
during
3­
year
period.
35
Table
2g.
EPA
Activities
and
Burden
for
the
EPA
Review
and
Withdrawal
Option
(
§
63.96)*

Activity
Technical
Hours
per
Occurrence
A.
Creation
of
Request
for
Information
15
B.
Evaluation
of
Information
Submitted
by
S/
L/
Ts
(
Permits,
Site
Visits,
Monitoring
Data)
180
C.
Letter
Informing
S/
L/
T
of
Inadequate
Program
10
D.
Creation
of
Notice
for
Proposed
Withdrawal
15
E.
Evaluation
of
Public
Comments
and
S/
L/
T
Responses
50
F.
Notification
of
Changes
for
S/
L/
Ts
to
Make
to
Correct
Deficiencies
15
G.
Notification
of
Withdrawal
10
H.
Publication
of
Schedule
for
Compliance
5
Total
(
hr)
300
HNot
expected
to
use
this
option
during
3­
year
period.
36
Table
3.
Summary
of
Delegations
by
S/
L/
Ts
Total
Number
of
Occurrences
per
Year
Year
1
Year
2
Year
3
Total
Option/
Year
(
occ/
yr)
(
occ/
yr)
(
occ/
yr)
(
occ)

Overall
Delegation(
§
63.91)
124
124
124
372
Straight
Delegation
per
Standard
(
§
63.91)
1142
694
298
2134
Rule
Adjustment
(
§
63.92)
37
26
11
74
Rule
Substitution
(
§
63.93)
62
43
19
124
Equivalency
by
Permit
 
Initial
Approval
(
§
63.94)
7
7
7
21
Equivalency
by
Permit
 
Per
Standard
(
§
63.94)
149
104
45
298
State
Program
Approval
 
Initial
Approval
(
§
63.97)
0
0
0
0
State
Program
Approval
(
§
63.97)
0
0
0
0
Accidental
Release
Prevention
Program
(
§
63.95)
0
0
0
0
Withdrawal
(
§
63.96)
0
0
0
0
Total
1,521
998
504
3,023
Average
occurrences/
yr
1,008
37
Table
4a.
Total
Annual
Burden
for
Respondents
Person­
Hours
Labor
Costs
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

Straight
Delegation
(
§
63.91)
­­
Administrative
Criteria
2,852.0
2,852.0
2,852.0
8,556.0
122.84
122.84
122.84
368.52
Straight
Delegation
(
§
63.91)
­­
Delegation
of
Standard
13,133.0
7,981.0
3,427.0
24,541.0
565.65
343.75
147.60
1,057.00
Rule
Adjustment
Option
(
§
63.92)
2,790.4
1,952.4
846.2
5,589.0
120.20
84.12
36.45
240.77
Rule
Substitution
Option
(
§
63.93)
15,793.0
10,953.0
4,839.9
31,585.9
680.23
471.76
208.44
1,360.43
Equivalency
by
Permit
Option
(
§
63.94)
­­
One­

Time
Application
161.0
161.0
161.0
483.0
6.93
6.93
6.93
20.79
Equivalency
by
Permit
Option
(
§
63.94)
­­
per
Standard
26,987.7
18,837.0
8,150.7
53,975.4
1,162.37
811.36
351.05
2,324.78
Table
4a.
Total
Annual
Burden
for
Respondents
Person­
Hours
Labor
Costs
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

38
State
Program
Approval
Option
(
§
63.97)
­­
One­

Time
Application
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
State
Program
Approval
Option
(
§
63.97)
­­
Per
Standard
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
Accidental
Release
Prevention
Program
(
§
63.95)
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
EPA
Review
and
Withdrawal
(
§
63.96)
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
Total
61717.1
42736.4
20276.8
124730.3
2658.22
1840.76
873.31
5,372.29
Average
41,576.8
1,790.76
39
Table
4b.
Total
Annual
Burden
for
EPA
Person­
Hours
Labor
Costs
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

Straight
Delegation
('
63.91)
­­
Administrative
Criteria
2,852.0
2,852.0
2,852.0
8,556.0
129.64
129.64
129.64
388.92
Straight
Delegation
(
§
63.91)
­­
Delegation
of
Standard
6,566.6
3,990.5
1,713.5
12,270.6
298.47
181.39
77.89
557.75
Rule
Adjustment
Option
(
§
63.92)
2,553.2
1,794.0
799.4
5,146.6
116.05
81.56
36.35
233.96
Rule
Substitution
Option
(
§
63.93)
12,121.0
8,406.6
3,714.6
24,242.2
550.94
382.11
168.82
1,101.87
Equivalency
by
Permit
Option
(
§
63.94)
­­
One­

Time
Application)
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
Equivalency
by
Permit
Option
(
§
63.94)
­­
per
Standard
23,989.1
16,744.0
7,245.1
47,978.2
1,090.40
761.06
329.34
2,180.80
Table
4b.
Total
Annual
Burden
for
EPA
Person­
Hours
Labor
Costs
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
(
hr/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

40
State
Program
Approval
Option
(
§
63.97)
­­
One­

Time
Application
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
State
Program
Approval
Option
(
§
63.97)
­­
Per
Standard
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
Accidental
Release
Prevention
Program
(
§
63.95)
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
EPA
Review
and
Withdrawal
(
§
63.96)
0.0
0.0
0.0
0.0
0.00
0.00
0.00
0.00
Total
48,081.9
33,787.1
16,324.6
98,193.6
2,185.50
1,535.76
742.04
4,463.30
Average
32,731.2
1,487.77
41
Table
5a.
Copying/
Postal
Costs
for
the
Straight
Delegation
Option
(
§
63.91)

Activity
(
Respondent/
EPA)
Answer
respondent
questions
(
EPA)*,
a
Send
submittal
to
EPA
(
Respondent)*,
b
Year
Occurrences
Year
1
124
1142
Year
2
124
694
Year
3
124
298
Postage
Year
1
($/
yr)
74.40
4,396.70
Year
2
($/
yr)
74.40
2,671.90
Year
3
($/
yr)
74.40
1,147.30
Copying
Year
1
($/
yr)
93.00
34,260.00
Year
2
($/
yr)
93.00
20,820.00
Year
3
($/
yr)
93.00
8,940.00
Total
Year
1
($
1,000/
yr)
0.17
38.66
Year
2
($
1,000/
yr)
0.17
11.61
Year
3
($
1,000/
yr)
0.17
10.09
Total
($
1,000/
yr)
0.50
60.35
Average
($
1,000/
yr)
0.17
20.12
*
Falls
under
maintenance
of
subpart
E
program
approval.
*
Falls
under
the
Straight
Delegation
Option.

aAssumes
2­
oz.
letter.
bAssumes
1­
lb.
package.
42
Table
5b.
Copying/
Postal
Costs
for
the
Rule
Adjustment
Option
(
§
63.92)

Activity
(
Respondent/
EPA)
Send
submittal
to
EPA
(
Respondent)
a
Answer
Respondent
Questions
(
EPA)
b
Year
Occurrences
Year
1
37
37
Year
2
26
26
Year
3
11
11
Postage
Year
1
($/
yr)
142.45
22.20
Year
2
($/
yr)
100.10
15.60
Year
3
($/
yr)
42.35
6.60
Copying
Year
1
($/
yr)
1,110.00
27.75
Year
2
($/
yr)
780.00
19.50
Year
3
($/
yr)
330.00
8.25
Total
Year
1
($
1,000/
yr)
1.25
0.05
Year
2
($
1,000/
yr)
0.88
0.04
Year
3
($
1,000/
yr)
0.37
0.01
Total
($
1,000/
yr)
2.50
0.10
Average
($
1,000/
yr)
0.84
0.03
aAssumes
1­
lb.
package.
bAssumes
2­
oz.
letter.
43
Table
5c.
Copying/
Postal
Costs
for
the
Rule
Substitution
Option
(
§
63.93)

Activity
(
Respondent/
EPA)
Send
submittal
to
EPA
(
Respondent)
a
Answer
Respondent
Questions
(
EPA)
b
Year
Occurrences
Year
1
62
62
Year
2
43
43
Year
3
19
19
Postage
Year
1
($/
yr)
238.70
37.20
Year
2
($/
yr)
165.55
25.80
Year
3
($/
yr)
73.15
11.40
Copying
Year
1
($/
yr)
1,860.00
46.50
Year
2
($/
yr)
1,290.00
32.25
Year
3
($/
yr)
570.00
14.25
Total
Year
1
($
1,000/
yr)
2.10
0.08
Year
2
($
1,000/
yr)
1.46
0.06
Year
3
($
1,000/
yr)
0.64
0.03
Total
($
1,000/
yr)
4.20
0.17
Average
($
1,000/
yr)
1.40
0.06
aAssumes
1­
lb.
package.
bAssumes
2­
oz.
letter.
44
Table
5d.
Copying/
Postal
Costs
for
the
Equivalency
by
Permit
Option
(
§
63.94)

Activity
(
Respondent/
EPA)
Preparation
of
a
list
of
affected
sources
and
affected
112
standardsH,
a
(
Respondent)
Send
submittal
to
EPA*,
b
(
Respondent)
Notification
of
whether
alternative
rule
submittal
is
complete*,
a
(
EPA)
Notification
to
respondent
of
complete
package
of
alternative
terms
&
conditions*,
a
(
EPA)
Creation
of
notification
of
approved/
disa
pproved
draft
permit
terms
and
conditions*,
a
(
EPA)
Answer
respondent
questions*,
a
(
EPA)

Year
Occurrences
Year
1
7
149
4
149
149
149
Year
2
2
104
2
104
104
104
Year
3
2
45
2
45
45
45
Postage
Year
1
($/
yr)
4.20
573.65
4.20
89.40
89.40
89.40
Year
2
($/
yr)
1.20
400.40
1.20
62.40
62.40
62.40
Year
3
($/
yr)
1.20
400.40
1.20
27.00
27.00
27.00
Copying
Year
1
($/
yr)
5.25
4,470.00
5.25
111.75
111.75
111.75
Year
2
($/
yr)
1.50
3,120.00
1.50
78.00
78.00
78.00
Year
3
($/
yr)
1.50
1,350.00
1.50
33.75
33.75
33.75
Table
5d.
Copying/
Postal
Costs
for
the
Equivalency
by
Permit
Option
(
§
63.94)

Activity
(
Respondent/
EPA)
Preparation
of
a
list
of
affected
sources
and
affected
112
standardsH,
a
(
Respondent)
Send
submittal
to
EPA*,
b
(
Respondent)
Notification
of
whether
alternative
rule
submittal
is
complete*,
a
(
EPA)
Notification
to
respondent
of
complete
package
of
alternative
terms
&
conditions*,
a
(
EPA)
Creation
of
notification
of
approved/
disa
pproved
draft
permit
terms
and
conditions*,
a
(
EPA)
Answer
respondent
questions*,
a
(
EPA)

Year
45
Total
Year
1
($
1,000/
yr)
0.01
5.04
0.01
0.20
0.20
0.20
Year
2
($
1,000/
yr)
0.00
3.52
0.00
0.14
0.14
0.14
Year
3
($
1,000/
yr)
0.00
1.52
0.00
0.06
0.06
0.06
Total
($
1,000/
yr)
10.10
Respondents
1.22
EPA
Average
($
1,000/
yr)
3.37
Respondents
0.41
EPA
*
Initial
Equivalency
by
Permit
Option
approval.

*
Per
Standard
Equivalency
by
Permit
Option
approval.

aAssumes
1­
lb.
package.

bAssumes
2­
oz.
letter.
46
Table
6.
Total
Copying/
Postal
Costs
for
Respondents
and
EPA
Respondents
EPA
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

Straight
Delegation
(
§
63.91)
­­
Administrative
Criteria
0
0
0
0.00
0.17
0.17
0.17
0.51
Straight
Delegation
(
§
63.91)
­­
Delegation
of
Standard
38.66
11.61
10.09
60.36
0.00
0.00
0.00
0.00
Rule
Adjustment
Option
(
§
63.92)
1.25
0.88
0.37
2.50
0.05
0.04
0.01
0.10
Rule
Substitution
Option
(
§
63.93)
2.10
1.46
0.64
4.20
0.08
0.06
0.03
0.17
Equivalency
by
Permit
Option
(
§
63.94)
­­
One­

Time
Application)
0.01
0.01
0.01
0.03
0.01
0.01
0.01
0.03
Equivalency
by
Permit
Option
(
§
63.94)
­­
per
Standard
5.04
3.52
1.52
10.08
0.6
0.42
0.18
1.20
State
Program
Approval
Option
(
§
63.97)
­­
One­

Time
Application
0
0
0
0
0
0
0
0
Table
6.
Total
Copying/
Postal
Costs
for
Respondents
and
EPA
Respondents
EPA
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

47
State
Program
Approval
Option
(
§
63.97)
­­
Per
Standard
0
0
0.00
0
0
0
0
0
Accidental
Release
Prevention
Program
(
§
63.95)
0
0.00
0.00
0
0
0
0.00
0
EPA
Review
and
Withdrawal
(
§
63.96)
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Total
47.06
17.48
12.63
77.17
0.91
0.7
0.4
2.01
Average
25.72
0.67
48
Table
7.
Total
Costs
for
Respondents
and
EPA
(
Labor
and
Copying/
Postal)

Respondents
EPA
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

Straight
Delegation
(
§
63.91)
­­
Administrative
Criteria
122.84
122.84
122.84
368.52
129.81
129.81
129.81
389.43
Straight
Delegation
(
§
63.91)
­­
Delegation
of
Standard
604.31
355.36
157.69
1,117.36
298.47
181.39
77.89
557.75
Rule
Adjustment
Option
(
§
63.92)
121.45
85.00
36.82
243.27
116.10
81.60
36.36
234.06
Rule
Substitution
Option
(
§
63.93)
682.33
473.22
209.08
1,364.63
551.02
382.17
168.85
1,102.04
Equivalency
by
Permit
Option
(
§
63.94)
­­
One­

Time
Application)
6.94
6.94
6.94
20.82
0.01
0.01
0.01
0.03
Equivalency
by
Permit
Option
(
§
63.94)
­­
per
Standard
1,167.41
814.88
352.57
2,334.86
1,091.00
761.48
329.52
2,182.00
State
Program
Approval
Option
(
§
63.97)
­­
One­

Time
Application
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Table
7.
Total
Costs
for
Respondents
and
EPA
(
Labor
and
Copying/
Postal)

Respondents
EPA
Year
Year
1
Year
2
Year
3
Total
Year
1
Year
2
Year
3
Total
Option
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)
($
1,000/
yr)

49
State
Program
Approval
Option
(
§
63.97)
­­
Per
Standard
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Accidental
Release
Prevention
Program
(
§
63.95)
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
EPA
Review
and
Withdrawal
(
§
63.96)
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Total
2,705.28
1,858.24
885.94
5,449.46
2,186.41
1,536.46
742.44
4,465.31
Average
1,816.49
1,488.44
