
INFORMATION
COLLECTION
REQUEST
FOR
40
CFR
PART
51
AND
52
PREVENTION
OF
SIGNIFICANT
DETERIORATION
AND
NONATTAINMENT
NEW
SOURCE
REVIEW
by
Arturo
Rios,
Economist
Innovative
Strategies
and
Economics
Group
Air
Quality
Strategies
and
Standards
Division
and
Juan
Santiago
Integrated
Implementation
Group
(
C339­
03)
Information
Transfer
and
Program
Integration
Division
Office
of
Air
Quality
Planning
and
Standards
Office
of
Air
and
Radiation
United
States
Environmental
Protection
Agency
RTP,
North
Carolina
27711
August
20,
2004
i
INFORMATION
COLLECTION
REQUEST
FOR
40
CFR
PART
51
AND
52
PREVENTION
OF
SIGNIFICANT
DETERIORATION
AND
NONATTAINMENT
NEW
SOURCE
REVIEW
TABLE
OF
CONTENTS
Page
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
TITLE
OF
THE
INFORMATION
COLLECTION
REQUEST
(
ICR)
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1
1(
b)
ABSTRACT/
EXECUTIVE
SUMMARY
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1
1(
c)
PAPERWORK
REDUCTION
ACT
REQUIREMENTS
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2
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)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
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3
3.
NONDUPLICATION,
CONSULTATIONS
AND
OTHER
COLLECTION
CRITERIA
4
3(
a)
NONDUPLICATION
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4
3(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
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4
3
(
c)
CONSULTATIONS
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4
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
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5
3(
e)
GENERAL
GUIDELINES
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5
3(
f)
CONFIDENTIALITY
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6
3(
g)
SENSITIVE
QUESTIONS
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6
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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6
4(
a)
RESPONDENTS/
STANDARD
INDUSTRIAL
CLASSIFICATION
(
SIC)
CODES
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6
4(
b)
INFORMATION
REQUESTED
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7
4(
b)(
1)
DATA
ITEMS,
INCLUDING
RECORD
KEEPING
REQUIREMENTS
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7
4(
b)(
2)
RESPONDENT
ACTIVITIES
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7
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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8
5(
a)
STATE
AND
LOCAL
AGENCY
ACTIVITIES
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8
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
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8
5(
c)
SMALL
ENTITY
FLEXIBILITY
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9
5(
c)(
1)
METHODOLOGY
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9
5(
c)(
2)
MEASURES
TO
AVERT
IMPACTS
ON
SMALL
ENTITIES
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9
5(
d)
COLLECTION
SCHEDULE
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10
ii
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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10
6(
a)
ESTIMATING
RESPONDENT
BURDEN
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10
6(
b)
ESTIMATING
RESPONDENT
COSTS
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11
6(
b)(
i)
ESTIMATING
LABOR
COSTS
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11
6(
b)(
ii)
ESTIMATING
CAPITAL
AND
OPERATIONS
AND
MAINTENANCE
COSTS
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12
6(
b)(
iii)
CAPITAL/
START­
UP
OPERATING
AND
MAINTENANCE
(
O&
M)
COST
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12
6(
b)(
iv)
ANNUALIZING
CAPITAL
COSTS
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12
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
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13
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
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13
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
TABLES
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14
6(
e)(
i)
RESPONDENT
TALLY
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14
6(
e)(
ii)
THE
AGENCY
TALLY
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14
6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
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15
6(
g)
BURDEN
STATEMENT
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15
Appendix
A:
INFORMATION
REQUIREMENTS
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21
iii
LIST
OF
TABLES
Page
4­
1
Primary
NSR
Respondents
by
SIC
Code
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7
6­
1
Industry
Respondent
Burden
and
Costs
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17
6­
2
State
and
Local
Agency
Burden
and
Costs
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18
6­
3
Agency
Burden
and
Costs
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19
6­
4
NSR
Program
Information
Collection
Burden
Summary
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.
20
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
OF
THE
INFORMATION
COLLECTION
REQUEST
(
ICR)

This
report
is
entitled
Information
Collection
Request
for
40
CFR
part
51
and
52
Prevention
of
Significant
Deterioration
and
Nonattainment
New
Source
Review.

1(
b)
ABSTRACT/
EXECUTIVE
SUMMARY
The
analyses
in
this
document
have
been
performed
in
support
of
a
renewal
of
the
New
Source
Review
(
NSR)
Program
Information
Collection
Request
(
ICR)
(
Office
of
Management
and
Budget
(
OMB)
Control
Number
2060­
0003;
EPA
Form
Number
1230.10).
Unless
it
is
renewed,
Program
ICR
will
expire
on
October
31,
2004.
The
regulations
covered
under
this
ICR
are
contained
in
Parts
51
and
52
of
Title
40
of
the
Code
of
Federal
Regulations
(
CFR).
These
requirements
govern
the
State
and
Federal
programs
for
preconstruction
review
and
permitting
of
major
new
and
modified
sources
pursuant
to
Part
C
"
Prevention
of
Significant
Deterioration"
(
PSD)
and
Part
D
"
Program
Requirements
for
Nonattainment
Areas"
of
the
Clean
Air
Act
(
CAA).
The
types
of
information
collection
activities
addressed
in
this
ICR
are
those
necessary
for
the
preparation
and
submittal
of
construction
permit
applications
and
the
issuance
of
final
permits.
Specific
burden­
producing
activities
are
listed
in
Appendix
A.
The
administrative,
reporting,
and
record
keeping
burden
for
industry
respondents
(
permit
applicants),
State
and
local
implementing
agencies
and
the
Environmental
Protection
Agency
are
summarized
in
Table
6­
4.

The
NSR
Program
ICR
was
renewed
in
October,
2001.
In
December
2002,
we
finalized
the
NSR
Reform
Rule
providing
for
several
changes
in
the
NSR
program.
Especifically,
the
changes
to
the
major
NSR
program
included
in
the
NSR
Reform
rule
are:
a
new
method
for
determining
baseline
emissions,
a
new
actual­
to­
projected­
actual
methodology
for
determining
whether
a
major
modification
will
occur
(
which
also
allows
to
continue
to
sue
the
historical
approach
of
using
potential
emissions
to
estimate
post­
change
emissions),
a
new
applicability
provision
for
emission
units
designated
as
Clean
Units
and
for
emissions
units
that
are
part
of
pollution
control
projects
(
PCPs),
and
changes
to
let
major
stationary
sources
manage
facility
wide
air
emissions
through
a
Plant­
wide
Applicability
Limitation
(
PAL)
without
requiring
a
preconstruction
major
NSR
permit.
An
ICR
was
prepared
for
the
reform
rules
and
it
also
expires
on
October
31,
2004.

The
2004
renewal
ICR
for
the
NSR
programs
estimated
the
burden
at
approximately
$
341
million
per
year
for
150,723
respondents.
The
change
(
net
increase)
in
burden
estimate
is
partially
due
to
use
of
current
labor
rates
for
the
respondents
and
EPA
("
Agency")
as
well
as
an
increase
in
Minor
NSR
actions
from
the
previous
ICR.
Consequently
the
estimated
burden
for
the
program
is
about
3.5
million
hours
to
industry
with
a
direct
cost
of
$
237
million
and
about
2.4
million
hours
to
permitting
agencies
for
a
total
respondent
cost
of
$
340
million
per
year.
The
costs
are
based
on
an
annual
average
of
265
Part
C
major
NSR
permit
applications
(
industrial
respondents),
488
Part
D
major
NSR
permit
applications,
and
74,609
minor
NSR
actions.
The
Agency
estimates
the
annualized
cost
of
NSR
to
States
and
local
agencies
to
be
approximately
$
103
million
per
year­­$
9,800
for
each
Part
C
permit,
$
3,900
for
each
Part
D
permit,
and
$
1,300
for
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
2
each
minor
NSR
permit.
The
Agency
expects
its
costs
will
be
$
568,000
per
year.
The
hourly
labor
costs
for
respondents
were
re­
estimated
as
described
in
section
(
6)(
b)
to
account
for
increases
in
the
labor
rates
from
2000
to
2004.

Table
6­
1
identifies
the
changes
in
hourly
rates
and
total
hours
to
estimate
industry's
cost
per
source
for
each
type
of
permit.
The
estimated
total
cost
to
industry
is
over
$
237
million.
On
a
per
source
(
response)
basis,
these
costs
are
approximately
$
87,500
for
each
Part
C
permit,
$
37,800
for
each
Part
D
permit,
and
$
2,600
for
each
minor
NSR
permit.
The
Part
C
per
permit
cost
includes
a
direct
cost
of
$
8.6
million
for
34
permit
applicants
who
must
conduct
preconstruction
air
quality
monitoring.

1(
c)
PAPERWORK
REDUCTION
ACT
REQUIREMENTS
For
any
existing
rule,
§
3507(
g)
of
the
Paperwork
Reduction
Act
(
PRA)
limits
the
amount
of
time
that
a
Director
may
approve
a
collection
of
information
to
three
years.
Consequently,
the
annual
burden
estimates
are
calculated
for
the
three­
year
period
beginning
October
2004
and
ending
October
2007.

Except
for
information
collections
in
notices
of
proposed
rules
or
those
exempted
under
the
emergency
processing
provisions
of
44
U.
S.
C.
§
3507(
j),
the
PRA
requires
EPA
to
solicit
comments
on
each
proposed
information
collection,
including
the
renewal
or
modification
of
any
existing
ICR.
This
ICR
renewal
and
its
supporting
statement
were
publicly
noticed
in
the
Federal
Register
to
solicit
comments
on
the
data,
analyses,
and
conclusions.
After
the
public
notice
and
comment
period,
the
supporting
statement
will
be
revised
accordingly
and
will
be
submitted
to
OMB
for
approval.

The
information
that
this
ICR
covers
is
required
for
the
submittal
of
a
complete
permit
application
for
the
construction
or
modification
of
all
major
new
stationary
sources
of
pollutants
in
attainment
and
nonattainment
areas,
as
well
as
for
applicable
minor
stationary
sources
of
pollutants.
EPA
certifies
that
the
information
collection
is
necessary
for
the
proper
performance
of
EPA's
functions,
and
that
it
has
practical
utility;
is
not
unnecessarily
duplicative
of
information
EPA
otherwise
can
reasonably
access;
and
reduces,
to
the
extent
practicable
and
appropriate,
the
burden
on
persons
providing
the
information
to
or
for
EPA.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
Section
110
of
the
Clean
Air
Act
(
CAA)
requires
all
States
to
submit
an
implementation
plan
which
contains
a
preconstruction
review
program
for
all
major
new
or
modified
stationary
sources,
including
any
provisions
necessary
for
this
program
to
meet
the
specific
requirements
of
Parts
C
and
D
of
Title
I
of
the
CAA
related
to
major
construction.
Section
110(
a)(
2)(
C)
of
the
CAA
requires
that
no
new
or
modified
stationary
source,
in
conjunction
with
existing
source
emissions
in
the
same
area,
can
interfere
with
the
attainment
or
maintenance
of
the
National
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
3
Ambient
Air
Quality
Standards
(
NAAQS).
It
further
requires
that
no
source
can
construct
without
securing
a
permit
to
ensure
that
the
objectives
of
Parts
C
and
D
of
the
CAA
are
met.

Part
C
of
Title
I
of
the
CAA
outlines
specific
construction
requirements
for
new
and
modified
sources
constructing
in
areas
that
do
not
violate
the
NAAQS.
These
requirements
are
more
commonly
referred
to
as
the
prevention
of
significant
deterioration
(
PSD)
rules,
which
require
a
prospective
major
new
or
modified
source
to:
(
1)
demonstrate
that
the
NAAQS
and
increments
will
not
be
exceeded,
(
2)
ensure
the
application
of
best
available
control
technology
(
BACT),
and
(
3)
protect
Federal
Class
I
areas
from
adverse
impacts,
including
adverse
impacts
on
air
quality
related
values
(
AQRVs).

Similarly,
Part
D
of
Title
I
of
the
CAA
specifies
requirements
for
major
new
and
modified
sources
constructing
in
areas
designated
as
nonattainment
for
an
NAAQS
pursuant
to
Section
107
of
the
CAA.
The
Part
D
provisions
also
apply
to
major
source
permitting
in
the
Northeast
Ozone
Transport
Region
as
established
under
Section
184
of
the
CAA.
The
Part
D
rules
generally
require
a
prospective
major
construction
project
to:
(
1)
ensure
the
application
of
controls
which
will
achieve
the
lowest
achievable
emission
rate
(
LAER),
(
2)
certify
that
all
major
sources
in
a
State
which
are
owned
or
controlled
by
the
same
person
(
or
persons)
are
in
compliance
with
all
air
emissions
regulations,
and
(
3)
secure
reductions
in
existing
source
emissions
to
comply
with
specific
statutory
offset
ratios
and
are
otherwise,
equal
to,
or
greater
than
those
reductions
necessary
to
show
attainment
and
maintenance
of
the
applicable
NAAQS
(
offsets).

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
Before
the
owner
or
operator
of
a
facility
can
commence
construction
or
modification
of
its
source,
it
must
comply
with
all
applicable
construction
permit
requirements.
The
owner
or
operator
of
a
stationary
source
must
develop
or
collect
all
relevant
information
not
otherwise
available
to
the
Federal,
State,
or
local
permitting
authority
(
PA).
The
PA
reviews
the
application
materials
submitted
by
the
owner
or
operator
and
either
declares
the
permit
application
complete
for
processing
or
provides
the
owner
or
operator
guidance
on
how
to
correct
the
deficiencies
in
the
application.
If
the
application
has
deficiencies,
the
applicant
collects
any
additional
data
identified
by
the
PA
so
that
the
permit
application
can
be
deemed
"
complete."
Although
sufficient
information
must
be
submitted
by
the
applicant
before
its
permit
can
be
classified
as
complete,
some
additional
clarifying
information
can
be
submitted
at
a
later
date
by
the
applicant
to
assist
the
PA
in
processing
the
permit
application.

For
major
sources
to
be
constructed
or
modified
in
attainment
areas,
the
PA
uses
the
permit
application
information
to
determine:
(
1)
whether
the
source
will
cause
or
contribute
to
a
violation
of
the
NAAQS
and
air
quality
increments,
(
2)
if
the
technology
the
source
is
proposing
is
BACT,
and
(
3)
whether
the
source's
emissions
will
adversely
affect
any
Federal
Class
I
areas,
including
AQRVs
in
these
areas.
For
major
sources
to
be
constructed
or
modified
in
nonattainment
areas,
the
permit
application
information
is
used
by
the
PA
to
determine
whether:
(
1)
the
source
will
apply
LAER,
(
2)
the
source
will
have
secured
the
required
emissions
offsets,
and
(
3)
the
source
has
demonstrated
that
all
other
of
its
major
sources
in
the
same
State
are
in
compliance
with
all
applicable
air
emissions
regulations.
1
The
RBLC
is
available
on
the
OAQPS
Technology
Transfer
Network.
Access
to
the
RBLC
on
the
TTN
is
via
a
computer
and
communications
software
by
dialing
(
919)
541­
5742,
or
through
Internet
access
B
http://
www.
epa.
gov/
ttncatc1/
rblc/
htm/
welcome.
html.
or
TELNET:<
ttnbbs.
rtpnc.
epa.
gov>;
FTP:<
ttnftp.
rtpnc.
epa.
gov>
For
assistance
in
accessing
the
TTN,
contact
the
TTN
Help
Desk
at
(
919)
541­
5384
in
Research
Triangle
Park,
North
Carolina,
1:
00
p.
m.
to
5:
00
p.
m.
Eastern
Time.

40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
4
Once
the
application
is
complete,
the
PA
makes
a
preliminary
determination
regarding
the
approvability
of
the
permit
application.
This
determination,
along
with
the
application
and
supporting
information,
is
made
available
to
the
public
for
at
least
30
days.
The
PA
must
then
respond
to
public
comments
and
take
action
on
the
final
permit.
Typically
a
final
action
must
be
taken
on
a
permit
by
the
PA
within
one
year
of
receipt
of
a
complete
application.

In
addition,
the
public
and
other
permit
applicants
may
use
some
of
the
data
collected.
EPA
operates
a
RACT/
BACT/
LAER
Clearinghouse
(
RBLC)
1
which
contains
many
BACT
and
LAER
determinations
to
aid
applicants
and
reviewers
in
identifying
reasonable
and
available
control
technologies.
The
Clean
Air
Act
Amendments
require
that
the
BACT
or
LAER
information
in
each
permit
must
be
gathered
by
the
PA
and
submitted
for
entry
into
the
RBLC
database
as
a
reference
for
making
future
control
technology
determinations.
Annual
reports
containing
RBLC
update
information
are
also
available
to
the
public
through
the
National
Technical
Information
Service.

3.
NONDUPLICATION,
CONSULTATIONS
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
The
information
collection
activities
required
under
the
NSR
regulations
are
not
routinely
performed
elsewhere
by
EPA.
However,
similar
information
may
be
collected
during
the
development
of
certain
environmental
impact
statements
(
EIS).
In
such
cases,
regulations
and
policies
require
that
information
collected
for
EIS's
and
NSR
programs
be
coordinated
to
the
maximum
extent
possible
so
as
to
minimize
duplicating
the
collection
of
data.
Some
of
the
required
information
also
may
already
be
available
from
States
or
other
federal
agencies.
However,
even
when
these
data
are
available,
they
are
not
generally
adequate
to
address
completely
the
relevant
NSR
requirements.

3(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
The
first
public
notice
of
this
ICR
renewal
was
published
in
the
August
3,
2004
(
69
FR
46532);
and
the
comment
period
ends
October
4,
2004.

3(
c)
CONSULTATIONS
This
ICR
is
a
renewal
of
the
existing
ICR
for
the
NSR
program.
It
incorporates
the
base
elements
of
the
program
which
have
not
been
changed
for
this
renewal
plus
the
regulatory
changes
finalized
in
the
NSR
Reform
rules
of
December
2002.
As
such,
extensive
consultation
through
public
hearings
and
stakeholder
meetings
with
environmental
groups;
industry;
and
state,
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
5
local,
and
federal
agency
representatives
has
been
conducted
for
the
rules
included
in
this
ICR
renewal.

3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
The
Act
defines
the
rate
of
reporting
by
sources,
states,
and
local
entities.
Consequently,
less
frequent
collection
is
not
possible.

3(
e)
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
1320.5,
the
Agency
believes:

1.
The
NSR
regulations
do
not
require
periodic
reporting
more
frequently
than
semiannually
2.
The
NSR
regulations
do
not
require
respondents
to
participate
in
any
statistical
survey.
3.
Written
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
the
NSR
program
to
ensure
that
the
requirements
are,
to
the
greatest
extent
possible,
the
same
for
Federal
requirements
and
those
reviewing
authorities
who
already
have
preconstruction
permitting
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
NSR
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
parts
51
or
52.
8.
To
the
greatest
extent
possible,
the
Agency
has
taken
advantage
of
automated
methods
of
reporting.
9.
The
Agency
believes
the
impact
of
NSR
regulations
on
small
entities
to
be
insignificant
and
not
disproportionate.

The
recordkeeping
and
reporting
requirements
contained
in
the
current
NSR
program
and
the
changes
made
in
this
rulemaking
do
not
exceed
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.5,
except
for
the
guideline
which
limits
retention
of
records
by
respondents
to
three
years.
The
Act
requires
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.

3(
f)
CONFIDENTIALITY
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
6
Confidentiality
is
not
an
issue
for
the
NSR
program.
In
accordance
with
Title
V,
Section
503
(
e),
the
information
that
is
to
be
submitted
by
sources
as
a
part
of
their
permit
application
and
update,
applications
for
revisions,
and
renewals
is
a
matter
of
public
record.
To
the
extent
that
the
information
required
for
the
completeness
of
a
Federal
permit
is
proprietary,
confidential,
or
of
a
nature
that
it
could
impair
the
ability
of
the
source
to
maintain
its
market
position,
that
information
is
collected
and
handled
according
to
EPA's
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B­­
Confidentiality
of
Business
Information
(
see
40
CFR
2).
States
typically
have
similar
provisions.

3(
g)
SENSITIVE
QUESTIONS
The
consideration
of
sensitive
questions,
(
i.
e.,
sexual,
religious,
personal
or
other
private
matters),
is
not
applicable
to
the
NSR
program.
The
information
gathered
for
purposes
of
establishing
an
operating
permit
for
a
source
do
not
include
personal
data
on
any
owner
or
operator.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
RESPONDENTS/
STANDARD
INDUSTRIAL
CLASSIFICATION
(
SIC)
CODES
Table
4­
1
lists
the
industrial
groups
the
EPA
expects
will
contain
the
majority
of
the
industrial
respondents
affected
by
the
NSR
program.
These
categories
were
chosen
because
of
their
historic
relative
incidence
in
seeking
NSR
permits
as
established
in
prior
ICRs
and
confirmed
by
a
nationwide
air
pollutant
emission
inventory
developed
by
the
EPA
in
1986­
87.
These
industries
have
been
used
as
the
basis
for
impact
analysis
since
that
inventory.
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
7
Table
4­
1.
Most
Numerous
Industrial
Respondents
by
Industrial
Group
Industry
Group
SIC
NAICS*

Steam
Electric
Plants
491
221111,
22112,
22113,
221119,
221121,
221122
Petroleum
Refining
291
32411
Chemical
Processes
281
325181,
32512,
325131,
325182,
211112,
325998,
331311,
325188
Natural
Gas
Transport
492
48621,
22121,
48621
Pulp
Mills
261
32211,
322121,
322122,
32213
Paper
Mills
262
322121,
322122
Automobile
Manufacturing
371
336111,
336112,
33612,
336211,
336992,
336322,
33633,
33634,
33635,
336399,
336212,
336213
Pharmaceuticals
283
325411,
325412,
325413,
325414
*
1997
North
American
Industry
Classification
System
The
respondents
also
include
State
and
local
air
regulatory
agencies.
Because
of
the
national
scope
of
the
NSR
program,
these
governmental
respondents
are
in
all
50
States.

4(
b)
INFORMATION
REQUESTED
4(
b)(
1)
DATA
ITEMS,
INCLUDING
RECORD
KEEPING
REQUIREMENTS
Tables
A­
1
and
A­
2
of
Appendix
A
summarize
the
respondent
data
and
information
requirements
which
owners
or
operators
of
major
sources
must
include
in
PSD
and
nonattainment
NSR
construction
permit
applications.
The
tables
also
include
the
appropriate
references
in
40
CFR
part
51
for
the
data
and
information
requirements
that
govern
the
way
States
implement
NSR
programs.
For
each
reference
in
Part
51,
corresponding
language
will
be
found
in
part
52.
In
this
ICR
analysis,
the
minor
source
burden
is
for
owners
or
operators
of
minor
sources
to
submit
information
to
demonstrate
that
they
are
exempt
from
the
major
source
construction
permit
requirements.
Once
exempt
from
major
source
requirements
of
either
PSD
or
Nonattainment
NSR,
owners
or
operators
will
not
have
to
comply
with
all
of
the
respective
requirements
shown
in
Appendix
A,
Tables
A­
1
and
A­
2.

4(
b)(
2)
RESPONDENT
ACTIVITIES
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
8
Table
6­
1
lists
the
activities,
burden,
and
estimated
costs
of
the
NSR
activities
required
under
40
CFR
parts
51
and
52.
These
activities
include
three
broad
categories:
Preparation
and
Planning;
Data
Collection
and
Analysis;
and
Permit
Application.
Within
each
of
these
categories,
further
subdivision
of
a
source's
activities
can
be
found.
The
Agency
anticipates
it
will
take
265
Part
C
major
sources
an
average
of
approximately
839
hours
to
complete
each
NSR
application,
for
a
total
of
over
222,000
hours.
Each
of
the
488
Part
D
NSR
sources
will
require
an
average
of
557
hours,
or
a
total
of
over
271,500
hours
each
year
to
complete
Part
D
NSR
applications.
Each
minor
source
will
require
40
hours
to
complete
its
NSR
application
requirements,
for
a
total
of
2,980,000
hours.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
STATE
AND
LOCAL
AGENCY
ACTIVITIES
Table
A­
3
of
Appendix
A
summarizes
the
data
and
information
requirements
which
State
and
local
agencies
must
meet.
Table
A­
3
also
shows
the
Part
51
references
for
the
data
and
information
requirements
specified.
The
appropriate
language
from
the
CAA,
40
CFR
51
and
40
CFR
52
for
State
and
local
agencies
is
also
included.

5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
The
owners
and
operators
of
new
or
modified
stationary
sources
affected
by
the
NSR
regulations
will
be
responsible
for
submitting
construction
permit
applications
to
the
PA.
The
PA
will
log
in
permit
applications,
store
applications
in
a
central
filing
location
at
the
PA,
notify
the
Federal
Land
Manager
(
FLM)
and
provide
a
copy
of
the
application
(
if
applicable),
and
transmit
copies
of
each
application
to
EPA.
Once
construction
permits
have
been
approved,
the
reviewing
authority
will
submit
control
technology
information
to
EPA's
RBLC
database.
Because
the
construction
permits
and
associated
control
technology
determinations
are
performed
on
a
caseby
case
basis,
the
regulations
will
not
contain
additional
forms
that
owners
or
operators
would
have
to
fill
out
and
submit
to
the
PA.
States
will
likely
use
their
current
permit
application
forms
for
NSR
purposes.

Qualified
personnel
who
work
for
the
PA
will
perform
permit
reviews
and
check
the
quality
of
data
submitted
by
the
applicant
on
a
case­
by­
case
basis.
The
applicant
will
be
required
to
submit
information
on
how
the
data
were
obtained
(
e.
g.,
indicate
whether
emissions
data
were
obtained
through
the
use
of
emissions
factors
or
test
data)
and
how
the
calculations
were
performed.
The
PA
personnel
will
check
data
quality
by
reviewing
test
data
and
checking
engineering
calculations,
and
by
reviewing
control
technology
determinations
for
similar
sources.
The
RBLC
and
other
sources
will
be
reviewed
for
information
on
control
technology
determinations
made
for
sources
similar
to
the
sources
included
in
the
permit
application.
Confidential
information
submitted
by
the
applicant
will
be
handled
by
the
permit
reviewing
authority's
confidential
information
handling
procedures.
The
public
will
be
provided
the
opportunity
to
review
a
permit
application
and
other
materials
relevant
to
the
PA's
decision
on
issuing
the
permit,
including
FLM
findings,
by
obtaining
a
copy
from
the
permit
reviewing
2
"
Economic
Assessment
of
the
Impacts
of
Part
C
and
D
Regulatory
Changes,"
June
2,
1994.

3
The
definition
for
"
small
business"
employed
for
all
SIC
categories
in
this
analysis
was
any
business
employing
fewer
than
500
employees.

40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
9
authority
or
by
attending
the
public
hearing.
The
NSR
regulations
will
not
require
information
through
any
type
of
survey.

Table
6­
2
lists
the
State
and
local
agency
burden
and
costs
associated
with
the
major
NSR
permitting
rule,
as
modified
by
the
final
NSR
Reform
rule
changes.
As
is
the
case
with
the
respondents,
State
and
local
agencies
who
approve
NSR
permits
will
only
have
start­
up
costs
for
any
given
permit.
Consequently,
while
the
State
or
local
agency
will
approve
many
permits
each
year,
the
annual
burden
for
that
function
is
simply
equal
to
the
burden
found
in
any
1
year.

5(
c)
SMALL
ENTITY
FLEXIBILITY
The
Regulatory
Flexibility
Act
(
RFA)
requires
regulatory
agencies,
upon
regulatory
action,
to
assess
that
actions
potential
impact
on
small
entities
(
businesses,
governments,
and
small
non­
governmental
organizations)
and
report
the
results
of
the
assessments
in
(
1)
an
Initial
Regulatory
Flexibility
Analysis
(
IRFA),
(
2)
a
Final
Regulatory
Flexibility
Analysis
(
FRFA),
and
(
3)
a
Certification.
For
ICR
approval,
the
Agency
must
demonstrate
that
it
"
has
taken
all
practicable
steps
to
develop
separate
and
simplified
requirements
for
small
businesses
and
other
small
entities"
(
5
CFR
1320.6(
h)).
In
addition,
the
agencies
must
assure
through
various
mechanisms
that
small
entities
are
given
an
opportunity
to
participate
in
the
rulemaking
process.

A
Regulatory
Flexibility
Act
Screening
Analysis
(
RFASA)
developed
as
part
of
a
1994
draft
Regulatory
Impact
Analysis
(
RIA)
and
incorporated
into
the
September
1995
ICR
renewal
analysis
reported
an
initial
regulatory
flexibility
screening
analysis
showed
that
the
changes
to
the
NSR
program
due
to
the
1990
Clean
Air
Act
amendments
would
not
have
an
adverse
impact
on
small
entities.
2
This
analysis
encompassed
the
entire
universe
of
applicable
major
sources
that
were
likely
to
also
be
small­
businesses.
The
Agency
estimates
there
are
approximately
50
"
small
business"
major
sources.
3
Because
the
administrative
burden
of
the
NSR
program
are
the
primary
source
of
the
NSR
program's
regulatory
costs,
the
analysis
estimated
a
negligible
"
cost
to
sales"
(
regulatory
cost
divided
by
the
business
category
mean
revenue)
ratio
for
this
source
group.
Currently,
there
is
no
economic
basis
for
a
different
conclusion
at
this
time.

5(
c)(
1)
MEASURES
TO
AVERT
IMPACTS
ON
SMALL
ENTITIES
The
Agency
may
not,
under
any
circumstances,
exempt
a
major
source
of
air
pollution.
Since
the
impacts
of
NSR
regulations
which
may
impact
small
entities
are
predominantly
to
major
sources,
little
room
exists
for
regulatory
flexibility
to
avert
the
impact
of
the
proposed
rulemaking
on
small
entities
through
exemption.

5(
c)(
2)
MEASURES
TO
MITIGATE
IMPACTS
ON
SMALL
ENTITIES
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
10
Even
though
the
NSR
program
is
not
anticipated
to
have
an
adverse
impact
on
a
significant
number
of
small
businesses,
measures
are
in
place
to
assist
in
those
incidental
exceptions.
Implementation
of
small
business
stationary
source
technical
and
environmental
compliance
assistance
programs,
as
called
for
in
section
507
of
the
Act
(
at
the
Federal
and
State
levels)
can
reduce
the
reporting
burden
of
small
entities
which
are
subject
to
major
NSR.
These
programs
may
significantly
alleviate
the
economic
burden
on
small
sources
by
establishing:
1)
programs
to
assist
small
businesses
with
determining
what
Act
requirements
apply
to
their
sources
and
when
they
apply,
and
2)
guidance
on
alternative
control
technology
and
pollution
prevention
for
small
businesses.

5(
d)
COLLECTION
SCHEDULE
Respondents
are
not
subjected
to
a
collection
schedule
per
se
under
NSR
permitting
regulations
of
parts
51
and
52.
In
general,
each
affected
source
is
required
to
submit
an
application
as
a
prerequisite
to
receiving
a
construction
permit.
Preparation
of
a
construction
permit
application
is
a
one­
time­
only
activity
for
each
project
involving
construction
of
a
new
source
or
modification
of
an
existing
source.
The
applicable
SIP
typically
states
the
time
period
that
is
necessary
to
process
a
permit
application
and
issue
a
permit;
consequently,
a
prospective
source
would
be
obliged
to
work
backward
from
the
hopeful
commencement
of
construction
to
determine
the
optimum
submittal
date
for
the
application.
The
NSR
permit
regulations
will
not
require
periodic
reporting
or
surveys.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
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.
The
burden
estimate
should
be
composed
of
(
1)
a
total
capital
and
start­
up
cost
component
annualized
over
its
useful
life;
(
2)
a
total
operation,
maintenance
and
purchases
of
services
component.
Each
component
should
be
divided
into
burden
borne
directly
by
the
respondent
and
any
services
that
are
contracted
out.

Although
there
have
been
regulatory
changes
to
the
NSR
program
since
the
2001
renewal,
we
believe
that
those
will
generally
not
change
the
source's
permit
application
requirements
and
as
such,
the
hourly
burden
estimates
per
permit
application
have
been
retained.
They
are
listed
with
the
line­
item
activities
in
Table
6­
1.

Table
6­
1
identifies
the
average
burden
by
activity
for
the
industrial
respondents.
Note
that
only
34
of
the
265
Part
C
(
PSD)
permit
applications
require
preconstruction
air
quality
4
U.
S.,
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
DRAFT
INFORMATION
COLLECTION
REQUEST
FOR
40
CFR
PART
51
AND
52
PREVENTION
OF
SIGNIFICANT
DETERIORATION
AND
NONATTAINMENT
NEW
SOURCE
REVIEW,
February
14,
2001,
p.
18.

40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
11
monitoring.
The
average
burden
for
preparing
and
submitting
minor
NSR
permit
applications
reflects
a
range
of
estimated
burden
from
8
to
120
hours,
depending
on
the
nature
of
the
permit
action
required.
The
average
assumes
the
following
average
burdens
for
different
types
of
permit
actions
(
percent
of
total
actions
in
parentheses):
40
hours
for
new
minor
sources,
new
synthetic
minor
sources,
and
synthetic­
based
modifications
(
30%);
8
hours
for
true
minor
modifications
(
30%);
120
hours
for
netting­
based
minor
modifications
(
20%);
and
8
hours
for
minor/
administrative
permit
revisions
(
20%).
Table
6­
2
identifies
the
average
burden
by
activity
for
the
State
and
local
respondents.

6(
b)
ESTIMATING
RESPONDENT
COSTS
6(
b)(
i)
Estimating
Labor
Costs
In
this
ICR,
the
entire
burden
for
all
respondents
(
and
the
Agency)
is
treated
as
a
labor
cost.
The
explanation
for
the
absence
of
capital
and
operations
and
maintenance
costs
appears
below
in
sections
6(
b)(
ii)
and
6(
b)(
iii).
Consequently,
there
is
only
an
annual
value
of
the
costs
of
the
ICR
burden,
which
is
equal
to
the
cost
of
the
first
yearly
outlay.
The
same
annual
ICR
burden
and
cost
are
reported
for
each
year
because
the
EPA
projects
that
the
yearly
average
number
of
permit
applications
will
be
constant
over
the
term
of
the
ICR.

In
order
to
improve
the
accuracy
of
burden
estimates,
this
renewal
ICR
uses
2004
values
with
the
wage
rate
methods
established
in
the
July,
1997
renewal
ICR.
The
1997
renewal
was
the
source
for
the
extrapolated
values
used
in
the
2001
renewal
ICR.
The
single
exception
is
the
estimate
of
pre­
construction
ambient
air
quality
costs,
which
were
adjusted
from
the
2001
renewal
ICR
due
to
the
lack
of
computational
detail
provided
in
the
1997
renewal.

The
labor
rate
used
to
calculate
the
industrial
respondents'
labor
cost
is
$
65.50/
hr
and
reflects
a
division
of
labor
between
in­
house
technical
staff
and
managerial
staff,
and
the
involvement
of
outside
consultants.
Following
the
methodology
detailed
in
the
July
10,
1997
ICR,
the
labor
rate
is
calculated
by
taking
70%
of
the
2004
in­
house
rate,
which
is
derived
using
fully
loaded
but
weighted
technical,
clerical,
and
managerial
staff
wages,
and
adding
the
resulting
labor
rate
to
30%
of
the
2004
fully
loaded
weighted
consultant
rate
for
technical,
clerical,
and
managerial
staff.
The
resultant
rate
equals
$
65.50/
hr.

Following
the
same
assumptions
as
the
2001
ICR
renewal,
34
of
the
industrial
respondents
submitting
Part
C
(
PSD)
permit
applications
will
conduct
pre­
construction
ambient
air
quality
monitoring.
4
The
average
cost
for
this
activity
is
estimated
to
be
$
253,337,
which
is
calculated
using
the
same
three
year
adjustment
factor
(
1.16)
as
the
previous
ICR
and
adding
an
additional
growth
of
5.33%
(
1/
3
of
16%)
for
2004.
5
U.
S.,
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
DRAFT
INFORMATION
COLLECTION
REQUEST
FOR
CHANGES
TO
THE
40
CFR
PART
51
AND
52
PREVENTION
OF
SIGNIFICANT
DETERIORATION
AND
NEW
SOURCE
REVIEW
APPLICABILITY
REQUIREMENTS
FOR
MODIFICATIONS
TO
EXISTING
SOURCES,
November,
2002,
p.
29.

40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
12
The
labor
rate
used
to
calculate
the
State
and
local
respondents'
labor
cost
is
$
43.53/
hr.
This
rate
is
the
result
of
inserting
2004
federal
government
pay
schedule
wage
rates
for
clerical,
technical,
and
managerial
staff
into
the
weighting
system
developed
in
the
1997
renewal
ICR
and
described
in
the
November
2002
parts
51
&
52
ICR
update.
5
Table
6­
2
presents
the
State
and
local
agency
respondents'
burden
and
costs.
Their
annual
cost
is
equal
to
the
cost
of
the
first
year
outlay,
which
recurs
each
year.

6(
b)(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Even
if
an
applicant
is
a
brand
new
company
and
the
prospective
source
is
a
"
greenfield"
source
(
the
EPA
estimates
less
than
one
percent
of
the
combined
number
of
major
and
minor
industrial
respondents
fit
that
description)
most,
and
perhaps
all,
of
the
equipment
needed
to
prepare
permit
applications
(
for
example,
the
computers
and
basic
software)
will
be
part
of
the
source's
business
operation
inventory.
Furthermore,
much
of
the
data
and
regulatory
and
policy
information
for
making
technology
determinations
and
even
models
for
performing
ambient
air
impact
analyses
are
available
in
electronic
form
from
several
different
EPA
bulletin
boards
for
just
the
communication
charges,
which
are
typically
absorbed
in
routine
business
overhead
expenses.

Since
the
purchase
of
capital
equipment
is
believed
to
be
an
insignificant
factor
in
permit
application
preparation,
the
EPA
assumes
the
operation,
maintenance,
or
services
for
same
are
negligible.
Further,
once
a
permit
is
issued,
there
is
no
operations
and
maintenance
cost
associated
with
it.
It
remains
unaltered
unless
the
source
or
the
permitting
authority
discovers
specific
reasons
to
reexamine
it
and
change
any
conditions
or
specifications.
If
purely
administrative,
the
changes
are
handled
exclusively
by
the
permitting
authority.
If
changes
have
the
potential
for
environmental
consequences,
the
action
may
be
significant
enough
to
be
counted
as
a
separate
and
new
application,
to
which
a
new
burden
and
cost
may
be
ascribed.

6(
b)(
iii)
Capital/
Start­
up
Operating
and
Maintenance
(
O&
M)
Costs
Capital/
start­
up
and
O&
M
costs
are
non­
labor
related
costs.
One­
time
capital/
start­
up
costs
are
incurred
with
the
purchase
of
durable
goods
needed
to
provide
information.
According
to
the
Paperwork
Reduction
Act,
capital/
start­
up
cost
should
include
among
other
items,
preparations
for
collecting
information
such
as
purchasing
computers
and
software,
monitoring,
sampling,
drilling,
and
testing
equipment.
As
a
practical
matter,
these
costs
are
not
typical
of
the
costs
associated
with
preparing
a
major
source
permit
application.
For
the
same
reason,
the
O&
M
costs
associated
with
start­
up
capital
equipment
are
zero
for
this
ICR.

6(
b)(
iv)
Annualizing
Capital
Costs
6
U.
S.,
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
DRAFT
INFORMATION
COLLECTION
REQUEST
FOR
40
CFR
PART
51
AND
52
PREVENTION
OF
SIGNIFICANT
DETERIORATION
AND
NONATTAINMENT
NEW
SOURCE
REVIEW,
July
10,
1997,
p.
44.

7
The
annual
salary
for
Grade
11
Step
3
in
the
2000
General
Schedule
is
$
41,790
(
www.
opm.
gov/
oca/
2000tbls/
GSannual/
html/
GSBASE.
HTM).
Division
by
2080
hrs/
hr
yields
the
hourly
rate
used
in
this
supporting
statement.

8
U.
S.
EPA,
ICR
Handbook
(
February
1999),
p.
A­
39.

40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
13
Typically
annualized
capital
cost
would
be
derived
from
a
discounted
net
present
value
of
the
stream
of
costs
that
would
occur
over
the
life
of
the
permit,
or
the
ICR,
whichever
is
shorter.
However,
in
the
case
of
NSR,
there
are
only
labor
costs
for
preparing
and
processing
permit
applications.
Labor
costs
are
expensed
when
incurred
and
not
amortized.
Therefore,
the
capital
costs
for
NSR
permitting
are
zero.

6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
Staff
in
EPA's
regional
offices
typically
review
major
NSR
permits.
The
EPA
expects
its
review
of
NSR
permits
to
comprise
the
tasks
listed
in
Table
6­
3.
The
cost
estimate
uses
a
"
loaded"
labor
rate
of
$
36.21/
hr.
The
rate
reflects
the
assumption,
made
in
the
July
10,
1997
renewal
ICR
and
the
February,
2001
renewal
ICR,
that
the
staff
reviewing
permits
are
classified
as
Grade
11
Step
3.6
The
corresponding
salary
is
loaded
with
benefits
at
the
rate
of
60%.
7
This
approach
to
determining
the
loaded
labor
rate
is
consistent
with
the
ICR
Handbook,
which
states
that
salary
is
to
be
multiplied
by
a
1.6
benefits
multiplication
factor.
8
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COST
For
the
purpose
of
estimating
burden
in
this
ICR,
the
respondent
universe
is
defined
by
the
annual
number
of
permit
applications
prepared
by
major
and
minor
sources,
and
the
annual
number
of
permit
applications
processed
by
State
and
local
agencies.
We
began
with
the
baseline
data
found
in
the
current
ICR
(
320
Part
C,
590
Part
D,
56,500
minor
NSR),
from
that
baseline,
we
then
made
several
adjustments
to
reflect
the
expected
effect
of
the
regulatory
changes
finalized
since
the
last
ICR
renewal.
Specifically,
the
number
of
major
NSR
permit
actions
was
for
each
program
element
finalized
under
the
December
2002
reform
rules
as
follows:

1.
For
baseline
determination
it
is
anticipated
that
no
more
than
5
percent
of
the
sources
will
avoid
major
NSR
under
this
requirement.
2.
For
actual­
to­
future­
actual,
it
is
anticipated
that
no
more
than
10
percent
of
the
sources
will
avoid
major
NSR
under
this
requirement.
3.
For
plantwide
applicability
limits
(
PALs),
it
is
anticipated
that
no
more
than
3
percent
of
the
sources
will
avoid
major
NSR
under
this
provision.
4.
For
the
clean
unit
test
(
CUT),
it
is
anticipated
that
no
more
than
5
percent
of
the
sources
will
avoid
major
NSR
under
this
provision.
5.
For
the
pollution
control
project
(
PCP),
it
is
anticiopated
that
no
more
than
3
percent
of
the
sources
will
avoid
major
NSR
under
this
provision.
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
14
In
addition,
this
analysis
uses
the
112
reviewing
authorities
count
used
by
other
permitting
ICRs
for
one­
time
tasks
(
e.
g.,
SIP
revision)
and
the
appropriate
source
count
for
individual
permit­
related
items
(
e.
g.,
attending
pre­
application
meetings
with
the
source).
The
resulting
number
of
respondents
for
this
ICR
renewal
is
then
estimated
to
be
as
follows:

1.
265
Part
C
(
PSD)
permit
applications
prepared
by
industry.
2.
488
Part
D
(
nonattainment)
permit
applications
prepared
by
industry.
3.
74,609
minor
NSR
permit
applications
prepared
by
industry.
4.
265
Part
C
(
PSD)
permit
applications
processed
by
State
and
local
agencies.
5.
488
Part
D
(
nonattainment)
permit
applications
processed
by
State
and
local
agencies.
6.
74,609
minor
NSR
permit
applications
processed
by
State
and
local
agencies.

Therefore,
for
each
category
of
permit
application,
the
total
number
of
respondents
is
twice
the
number
of
permit
applications.

The
total
annual
effort
for
industrial
respondents
submitting
Part
C
(
PSD)
permit
applications
is
221,943
hours,
and
the
corresponding
annual
cost
is
$
23,150,755.
The
total
annual
effort
for
industrial
respondents
submitting
Part
D
(
nonattainment)
permit
applications
is
281,422
hours,
and
the
corresponding
annual
cost
is
$
18,433,150.
The
total
annual
effort
for
industrial
respondents
submitting
minor
NSR
permits
is
2,984,368
hours,
and
the
corresponding
annual
cost
is
$
195,476,104.
For
industrial
respondents,
the
overall
total
annual
effort
is
3,487,734
hours
and
$
237,060,009.

The
total
annual
effort
for
State
and
local
respondents
processing
Part
C
(
PSD)
permit
applications
is
71,953
hours,
and
the
corresponding
annual
cost
is
$
3,123,117.
The
total
annual
effort
for
State
and
local
respondents
processing
Part
D
(
nonattainment)
permit
applications
is
53,163
hours,
and
the
corresponding
annual
cost
is
$
2,314,182.
The
total
annual
effort
for
State
and
local
respondents
processing
minor
NSR
permits
is
2,238,276
hours,
and
the
corresponding
annual
cost
is
$
97,432,154.
For
the
State
and
local
respondents,
the
overall
total
annual
effort
is
2,363,392
hours
and
$
102,878,454.

6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COST
TABLES
6(
e)(
i)
Respondent
Tally
Table
6­
4
summarizes
the
estimated
burden
and
cost
to
industry
respondents,
State
and
local
agency
respondents,
and
the
EPA
for
submittal
and
processing
of
NSR
permit
applications
and
the
issuance
of
the
permits.
It
also
includes
the
cost
to
the
respective
respondents
and
reviewing
agencies
for
nonapplicability
findings,
which
preclude
sources
from
further
major
source
requirements.
For
industrial
and
State
and
local
agency
respondents,
the
overall
total
annual
burden
is
5,851,126
hours
and
$
339,938,463.

6(
e)(
ii)
The
Agency
Tally
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
15
The
total
annual
effort
for
the
Agency
for
processing
Part
C
(
PSD)
permit
applications
is
3,703
hours,
and
the
corresponding
annual
cost
is
$
134,103.
The
total
annual
effort
for
the
Agency
for
processing
Part
D
(
nonattainment)
permit
applications
is
6,341
hours,
and
the
corresponding
annual
cost
is
$
229,591.
The
total
annual
effort
for
the
Agency
for
processing
minor
NSR
permits
is
5,650
hours,
and
the
corresponding
annual
cost
is
$
204,587.
For
the
Agency,
the
overall
total
annual
effort
is
15,694
hours
and
$
568,280.

6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
The
burden
has
changed
due
in
part
to
a
change
in
the
labor
rates.
As
explained
in
section
6(
b)(
i)
of
this
document,
the
labor
rates
for
industry
respondents
and
State
and
local
agency
respondents
were
not
adjusted
from
the
previous
ICR
as
they
were
in
the
2001
renewal
ICR.
Instead,
in
order
to
improve
the
accuracy
or
burden
estimates,
the
rates
were
recalculated
using
2004
values
and
following
the
same
methodology
established
in
the
July
10,
1997
renewal
ICR.

Also
contributing
to
the
increase
in
burden
has
been
an
increase
in
Minor
NSR
Applications.
The
increase
in
sources
preparing
and
submitting
Minor
NSR
Permit
Applications
rose
by
almost
18,000
from
the
previous
ICR
(
February,
2001
renewal)
as
a
result
of
a
revision
to
the
number
of
reviewing
authorities
and
the
number
of
minor
source
actions
processes
by
each
reviewing
authority.

6(
g)
BURDEN
STATEMENT
The
average
annual
burden
on
an
industrial
respondent
submitting
a
Part
C
(
PSD)
permit
application
is
839
hours
and
$
87,515;
these
estimates
reflect
the
direct
cost
for
pre­
application
monitoring
averaged
for
all
PSD
permit
applications.]
The
average
annual
burden
on
an
industrial
respondent
submitting
a
Part
D
(
nonattainment)
permit
application
is
577
hours
and
$
37,794.
The
average
annual
burden
on
an
industrial
respondent
submitting
a
minor
NSR
permit
application
is
40
hours
and
$
2,620.

The
average
annual
burden
on
a
State
or
local
agency
respondent
processing
a
Part
C
(
PSD)
permit
application
is
272
hours
and
$
11,840.
The
average
annual
burden
on
a
State
or
local
agency
respondent
processing
a
Part
D
(
nonattainment)
permit
application
is
109
hours
and
$
4,745.
The
average
annual
burden
on
a
State
or
local
agency
respondent
processing
a
minor
NSR
permit
application
is
30
hours
and
$
1,306.

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,
verifying,
processing,
maintaining,
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
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
16
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2004­
0081,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
Docket
is
(
202)
566­
1742).
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0081)
in
any
correspondence.
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
17
3,375$
1,688$
844$
844$
405$
675$
14,160$
7,099$
21,259$
4,668$
3,764$
1,245
Table
6­
1
Industrial
Respondent
Burden
and
Cost
(
Annual)

Activity
Units
Hours
per
Unit
Annual
Hours
Annual
Cost
($
1000)

I.
Part
C
(
PSD)

A.
Preparation
and
Planning
Determination
of
Compliance
Requirements
265
170
44,971
$
2,946
Obtain
guidance
on
Data
Needs
265
120
31,744
$
2,079
Preparation
of
BACT
Engineering
Analysis
265
85
22,485
$
1,435
B.
Data
Collection
and
Analysis
Air
Quality
Modeling
265
200
52,907
$
3,465
Determination
of
Impact
on
Air
Quality
Related
Values
265
100
26,453
$
1,733
Post­
construction
Air
Quality
Monitoring
265
50
13,227
$
866
C.
Permit
Application
Preparation
and
Submittal
of
Permit
Application
265
50
13,227
$
866
Public
Hearings
265
24
6,349
$
416
Revisions
to
Permit
265
40
10,581
$
693
D.
Subtotal
burden
839
221,943
$
14,537
E.
Direct
cost
for
Pre­
construction
Air
Quality
Monitoring
34
$
8,613
F.
Total
cost
$
23,151
II.
PART
D
(
Nonattainment)

A.
Preparation
and
Planning
Determination
of
Compliance
Requirements
488
150
73,160
$
4,792
Obtain
guidance
on
Data
Needs
488
100
48,773
$
3,195
B.
Data
Collection
and
Analysis
Preparation
of
LAER
Engineering
Analysis
488
40
19,509
$
1,278
Demonstrate
Offsets
488
40
19,509
$
1,278
Prepare
Analysis
of
Alternative
Sites,
Processes,
etc.
488
60
29,264
$
1,917
Air
Quality
Modeling
488
100
48,773
$
3,195
C.
Permit
Application
Preparation
and
Submittal
of
Permit
Application
488
38
18,534
$
1,214
Public
Hearings
488
25
12,193
$
799
Revisions
to
Permit
488
24
11,706
$
767
D.
Total
577
281,422
$
18,433
III.
MINOR
NSR
A.
Preparation
and
Submittal
of
Minor
NSR
Permit
Application
74,609
40
2,984,368
$
195,476
III.
GRAND
TOTAL
75,361
3,487,734
$
237,060
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
18
Table
6­
2
State
And
Local
Respondent
Burden
and
Cost
(
Annual)

Activity
Units
Hours
Per
Unit
Annual
Hours
Annual
Cost
($
1000)

I.
PART
C
(
PSD)

A.
Attend
Preapplication
Meetings
265
36
9,523
$
415
B.
Answer
Respondent
Questions
265
20
5,291
$
230
C.
Log
In
and
Review
Data
Submissions
265
16
4,233
$
184
D.
Request
Additional
Information
265
8
2,116
$
92
E.
Analyze
for
and
Provide
Confidentiality
Protection
265
24
6,349
$
276
F.
Prepare
Completed
Applications
for
Processing
265
32
8,465
$
368
G.
File
and
Transmit
Copies
265
8
2,116
$
92
H.
Prepare
Preliminary
Determination
265
24
6,349
$
276
I.
Prepare
Notices
for
and
Attend
Public
Hearings
265
40
10,581
$
461
J.
Application
Approval
265
40
10,581
$
461
K.
Notification
of
Applicant
of
PA
Determination
265
8
2,116
$
92
L.
Submittal
of
Information
on
BACT
/
LAER
to
RBLC
265
16
4,233
$
184
M.
Total
272
71,953
$
3,132
II.
PART
D
(
Nonattainment)

A.
Attend
Preapplication
Meetings
488
7
3,414
$
149
B.
Answer
Respondent
Questions
488
10
4,877
$
212
C.
Log
In
and
Review
Data
Submissions
488
8
3,902
$
170
D.
Request
Additional
Information
488
4
1,951
$
85
E.
Analyze
for
and
Provide
Confidentiality
Protection
488
4
1,951
$
85
F.
Prepare
Completed
Applications
for
Processing
488
12
5,853
$
255
G.
File
and
Transmit
Copies
488
4
1,951
$
85
H.
Prepare
Preliminary
Determination
488
8
3,902
$
170
I.
Prepare
Notices
for
and
Attend
Public
Hearings
488
18
8,779
$
382
J.
Application
Approval
488
16
7,804
$
340
K.
Notification
of
Applicant
of
PA
Determination
488
2
975
$
42
L.
Submittal
of
Information
on
BACT
/
LAER
to
RBLC
488
16
7,804
$
340
M.
Total
109
53,163
$
2,314
III.
MINOR
NSR
Total
for
Preparation
and
Submittal
of
Minor
NSR
Permit
Application
74,609
30
2,238,276
$
97,432
III.
GRAND
TOTAL
75,361
2,363,392
$
102,878
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
19
Table
6­
3
Agency
Burden
and
Cost
(
Annual)

Activity
Units
Hours
Per
Unit
Annual
Hours
Annual
Cost
($
1000)

I.
PART
C
(
PSD)

A.
Review
and
Verify
Applicability
Determination
265
2
529
$
19
B.
Review
Control
Technology
Determination
265
3
794
$
29
C.
Evaluate
Air
Quality
Monitoring
265
4
1,058
$
38
D.
Evaluate
Alternative
and
Secondary
Impact
Analysis
265
2
529
$
19
E.
Evaluate
Class
I
Area
Analysis
265
2
529
$
19
F.
Administrative
Tasks
265
1
265
$
10
G.
Total
14
3,703
$
134
II.
PART
D
(
Nonattainment)

A.
Review
and
Verify
Applicability
Determination
488
2
975
$
35
B.
Review
Control
Technology
Determination
488
3
1,463
$
53
C.
Evaluate
Offsets
488
1
488
$
18
D.
Evaluate
Air
Quality
Monitoring
488
4
1,951
$
71
E.
Evaluate
Alternative
and
Secondary
Impact
Analysis
488
2
975
$
35
F.
Administrative
Tasks
488
1
488
$
18
G.
Total
13
6,341
$
230
III.
MINOR
NSR
Review
Synthetic/
Netting­
Based
Minor
NSR
Permits
2,825
2
5,650
$
205
III.
GRAND
TOTAL
3,577
29
15,694
$
568
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
20
Table
6­
4
NSR
Program
Information
Collection
Burden
Summary
Total
Per
Unit
Part
C
(
PSD)
Part
D
(
Nonattainment
Minor
NSR
Cumulative
Total
Part
C
(
PSD)
Part
D
(
Nonattainment
Minor
NSR
Number
of
Respondentsa
529
975
149,218
150,723
[
13.
a.&.
b]
b
Respondent
Burden
Hours
Industry
221,943
281,422
2,984,368
3,487,734
839
577
40
State/
Local
71,953
53,163
2,238,276
2,363,392
272
109
30
Industry
and
State/
Local
Agency
Totals
293,897
334,585
5,222,644
5,851,126
[
13.
c]
1,111
686
70
Federal
(
Agency)
Burden
3,703
6,341
5,650
15,694
14
13
2
Program
Grand
Total
Burden
297,600
340,926
5,228,294
5,866,820
Respondent
Annual
Cost
($
1000)
c
Industry
Labord
$
14,537
$
18,433
$
195,476
$
228,447
$
54.95
$
37.79
$
2.62
Other
direct
Coste
$
8,613
$
0
$
0
$
8,613
$
253.34
$
0.00
$
0.00
Total
Industry
Costf
$
23,151
$
18,433
$
195,476
$
237,060
$
87.52
$
37.79
$
2.62
State
/
Local
Cost
$
3,132
$
2,314
$
97,432
$
102,878
$
11.84
$
4.74
$
1.31
Industry
and
State/
Local
Totals
$
26,283
$
20,747
$
292,908
$
339,938
Federal
(
Agency)
Annual
Cost
($
1000)
$
134
$
230
$
205
$
568
$
0.51
$
0.47
$
0.00
Program
Grand
Total
Cost
($
1000)
$
26,417
$
20,977
$
293,113
$
340,507
$
99.86
$
43.01
$
3.93
(
a)
Number
of
respondents
is
twice
the
number
of
permitting
actions
for
a
given
category
due
to
(
1)
the
applicant
preparing
the
application
and
(
2)
the
permitting
agency
reviewing
and
issuing
the
permit.
(
b)
References
to
specific
entries
on
OMB
Form
83­
I
are
enclosed
in
brackets.
(
c)
All
costs
are
in
thousands
of
current
(
2004)
dollars.
All
costs
represent
one­
time
permit
application
costs
[
16.
c.
8.].
Operating
and
maintenance
costs
are
$
0.00
[
14.
b.].
The
cost
for
compliance
monitoring
is
not
covered
by
the
NSR
program.
Other
ICRs
such
as
that
for
the
CAM
rule
and
the
Title
V
ICRs
cover
these
burdens
and
costs.
(
d)
The
EPA
estimates
that
30%
of
the
in­
house
hourly
burden
may
be
contracted,
but
because
it
is
at
the
discretion
of
the
applicant,
the
cost
has
not
been
converted
to
direct
cost.
Furthermore
EPA
assumes
the
labor
rate
would
remain
the
same,
in
which
case
there
is
no
impact
on
total
annual
costs.
(
e)
These
direct
costs
are
for
34
(
approximately
13%)
PSD
sources
at
$
253,337
per
source,
for
preapplication
monitoring
of
air
quality
via
contract
services.
This
cost
is
not
incurred
by
Part
D
permit
applicants.
(
f)
Per
unit
cost
for
PSD
permits
reflects
the
direct
cost
for
pre­
application
monitoring
averaged
over
all
PSD
permits.
The
estimated
34
sources
that
require
preconstruction
monitoring
are
estimated
to
incur
a
total
cost
of
$
308,292
per
application.
The
others
will
incur
$
54,955.
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
21
APPENDIX
A
INFORMATION
REQUIREMENTS
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
22
TABLE
A­
1.
INDUSTRY
RESPONDENT
DATA
AND
INFORMATION
REQUIREMENTS
FOR
PREPARING
PART
C
(
PSD)
CONSTRUCTION
PERMITS
Current
Requirements
Regulation
Reference
Description
of
the
nature,
location,
design
capacity,
and
typical
operating
schedule
40
CFR
51.166(
n)(
2)(
I)

Detailed
schedule
for
construction
40
CFR
51.166(
n)(
2)(
ii)

Description
of
continuous
emission
reduction
system,
emission
estimates,
and
other
information
needed
to
determine
that
BACT
is
used
40
CFR
51.166(
n)(
2)(
iii)

Air
quality
impact,
meteorological,
and
topographical
data
40
CFR
51.166(
n)(
3)(
I)

Nature
and
extent
of,
and
air
quality
impacts
of
general
commercial,

residential,
industrial,
and
other
growth
in
area
of
source
40
CFR
51.166(
n)(
3)(
ii)

Use
of
air
quality
models
to
demonstrate
compliance
with
NAAQS
and
increment
40
CFR
51.166(
k)&(
l)

A
demonstration
that
the
benefits
of
the
proposed
source
significantly
outweigh
the
environmental
and
social
costs
imposed
as
a
result
of
its
location,
construction,
or
modification
Not
a
current
requirement;,
but
is
a
1990
Act
Requirement

173(
a)(
5)

Information
necessary
to
determine
impact
on
AQRVs
in
Class
I
areas
40
CFR
51.166(
n)(
4)

Air
quality
monitoring
data
40
CFR
51.166(
m)
Impairment
of
visibility,
soils,
and
vegetation
40
CFR
51.166(
o)(
1)

Air
quality
impact
resulting
from
general
commercial,
residential,
industrial,

and
other
growth
associated
with
source
40
CFR
51.166(
o)(
2)

Written
notice
of
proposed
relocation
from
portable
source
40
CFR
51.166(
I)(
4)(
iii)(
d)

Description
of
the
location,
design
construction,
and
operation
of
building,

structure,
facility,
or
installation
40
CFR
51.160(
c)(
2)

Description
of
the
nature
and
amounts
of
emissions
to
be
emitted
40
CFR
51.160(
c)(
1)

Description
of
the
air
quality
data
and
dispersion
or
other
air
quality
modeling
used
40
CFR
51.160(
f)

Sufficient
information
to
ensure
attainment
and
maintenance
of
NAAQS
40
CFR
51.160(
c)­(
e),
40
CFR
51.161­
163
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
23
Table
A­
2:
INDUSTRY
RESPONDENT
DATA
AND
INFORMATION
REQUIREMENTS
FOR
PREPARING
PART
D
(
NONATTAINMENT
NSR)
CONSTRUCTION
PERMITS
Requirements
Regulation
Reference
Documentation
that
LAER
is
being
applied
40
CFR
51.165(
d)(
2)
Documentation
that
all
sources
owned
or
operated
by
same
person
are
in
compliance
40
CFR
51.165(
h)(
1)

Documentation
that
sufficient
emissions
reductions
are
occurring
to
comply
with
specific
offset
requirements
and
to
ensure
RFP
40
CFR
51.165(
e)

Documentation
that
benefits
of
proposed
source
significantly
outweigh
the
environmental
and
social
costs
imposed
as
a
result
of
its
location,
construction,
or
modification
CAA

173(
a)(
5)

Description
of
the
location,
design
construction,
and
operation
of
building,
structure,
facility,
or
installation
40
CFR
51.160(
c)(
2)

Description
of
the
nature
and
amounts
of
emissions
to
be
emitted
40
CFR
51.160(
c)(
1)
Description
of
the
air
quality
data
and
dispersion
or
other
air
quality
modeling
used
40
CFR
51.160(
f)

Sufficient
information
to
ensure
attainment
and
maintenance
of
NAAQS
40
CFR
51.160(
c)­(
e)

40
CFR
51.161
40
CFR
51.162
40
CFR
51.163
40
CFR
parts
51
and
52
PSD
and
Nonattainment
NSR
Information
Collection
Request
August
20,
2004
24
TABLE
A­
3.
PERMITTING
AGENCY
DATA
AND
INFORMATION
REQUIREMENTS
Requirement
Regulation
Reference
Early
FLM
notification
and
opportunity
to
participate
in
meetings
40
CFR
51.166(
p)(
1)(
ii)
Submission
of
all
permit
applications
to
EPA
40
CFR
51.166(
q)(
1)
Submission
of
notice
of
application,
preliminary
determination,

degree
of
increment
consumption,
and
opportunity
for
public
comment
40
CFR
51.166(
q)(
2)(
iv)

Submission
to
FLM
of
permit
applications
40
CFR
51.166(
p)(
1)

Submission
of
written
request
to
exempt
sources
from
review
40
CFR
52.21(
I)(
4)(
vi)
Written
request
for
use
of
innovative
control
technology
40
CFR
51.166(
s)

Establishing
and
operating
a
permitting
program
for
all
new
sources
40
CFR
51.160
Provide
notice
to
EPA
of
all
permits
40
CFR
51.161(
d)
Provide
for
public
comment
for
all
NSR
permits
40
CFR
51.161
