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Supporting Statement

Ambient Oxides of Sulfur Monitoring Regulations: 

Revisions to Network Design Requirements

EPA ICR # 2370.01

PART A

1.  Identification of the Information Collection

     	   	 (a) Title of the Information Collection

     “Ambient Oxides of Sulfur Monitoring Regulations:  Revisions to
Network Design Requirements – Proposal”

 	 (b)  Short Characterization/Abstract

	This Information Collection Request (ICR) includes ambient air
monitoring data reporting and recordkeeping activities associated with
the 40 CFR part 58 Ambient Air Quality Surveillance regulations.  These
data and information are collected by State and local air quality
management agencies and reported to the U.S. Environmental Protection
Agency (EPA).  

	The EPA is proposing to revise the network design requirements for the
oxides of sulfur (SOX), specifically sulfur dioxide (SO2), to support
the proposed changes to the primary National Ambient Air Quality
Standards (NAAQS) for SO2.  Presently, state agencies, and local
agencies when delegated by the state, are required to operate minimum
numbers of EPA-approved SO2 monitors based on (1) the population of each
of their Core Based Statistical Areas (CBSA) and the amount of SO2
emissions within those CBSAs and (2) the amount of SO2 emissions emitted
within each state.  

EPA is proposing a two-pronged monitoring network design. The two prongs
are designed to: 1) monitor in CBSAs where there is an increased
coincidence of population and SO2 emissions and 2) to proportionally
require monitors in states corresponding to the amount of SO2 emissions
that state contributes to the national emissions inventory.  The
proposed network design corresponds to the proposal of the new NAAQS
based on peak 1-hour daily maximum concentrations, or 1-hour NAAQS, and
the associated proposed range of levels from 50 to 100 parts per billion
(ppb). The introduction of the 1-hour NAAQS and the range of levels are
intended to protect against peak, shorter term exposure risks.  

In the first prong of the SO2 network design, EPA is proposing minimum
SO2 monitoring requirements which call for monitors in CBSA by
developing a Population Weighted Emissions Index (PWEI) that uses
population and emissions inventory data at the CBSA level to assign
required monitoring for a given CBSA (population and emissions being
obvious relevant factors in prioritizing numbers of required monitors). 
The PWEI for a particular CBSA is calculated by multiplying the
population (using the latest Census Bureau estimates) of a CBSA by the
total amount of SO2 emissions in that CBSA. The CBSA emission value is
in tons per year, and is calculated by aggregating the county level
emissions for each county in a CBSA.  We then normalize by dividing the
resulting product of CBSA population and CBSA SO2 emissions by 1,000,000
to provide a PWEI value, the units of which are millions of people-tons
per year.  Those CBSAs with a PWEI value of 1,000,000 or more would be
required to operate three monitors within that CBSA.  Those CBSAs with a
PWEI value between 1,000,000 and 10,000 would be required to operate two
monitors within that CBSA. Those CBSAs with a PWEI value between 10,000
and 5,000 would be required to operate one monitor within that CBSA.  In
summary, EPA estimates that this first prong of the proposed SO2 network
design will require 231 monitoring sites in 132 CBSAs.

In the second prong of the proposed monitoring network design, EPA is
proposing to require a monitor or monitors in each state, allocated by
state-level SO2 emissions.  In this prong, EPA proposes to distribute
approximately 114 sites, based on the corresponding percent contribution
of each individual state to the national anthropogenic SO2 emission
inventory.  This prong of the network design is intended to allow a
portion of the overall required monitors to be placed where needed,
independent of the PWEI, inside or outside of CBSAs.  EPA proposes to
require monitors, using states as the geographic unit for allocation
purposes, in proportion to a state’s SO2 emissions, i.e., a state with
higher emissions will be required to have a proportionally higher number
of monitors.  The proposed percent contribution of individual states is
based on the most recent National Emissions Inventory, with SO2
emissions being aggregated by state.  Each one percent (after rounding)
would correspond to one required monitor.  Further, EPA proposes that
each state have at least one monitor required as part of this second
prong, even if a particular state contributes less than 0.5% of the
total anthropogenic, non-fire national emissions inventory.

In addition to the two prongs of the proposed SO2 network design, we
propose that the Regional Administrator will have discretion to require
monitoring above these minimum requirements under prongs 1 and 2, as
necessary to address situations where the minimum monitoring
requirements are not sufficient to meet monitoring objectives noted
above.  EPA recognizes that the minimum required monitors in the
proposed network design under the two prongs described above are based
on indicators that may not provide for all the monitoring that may be
necessary in an area.

EPA anticipates that there will likely be a need for capital funding to
allow for up to two-thirds of the minimally required monitors to be
established as new monitoring sites or cause some existing sites to be
relocated under the proposed network design. The establishment costs of
monitoring sites can include property access or leasing fees, power and
telecom services, site security, a climate controlled monitoring
shelter, pollutant analyzers, supporting quality assurance hardware and
consumables, and data collection and dissemination hardware and
software.

EPA has also proposed the requirement that State and local air quality
management agencies shall report the 1-hour average and the maximum
5-minute average concentration of the twelve 5-minute block averages in
each hour.  The requirement to report the maximum 5-minute average that
exist in an hour impose an increased burden by increasing the data
quality assurance and validation workload and by through increased data
processing in the field, which may not be a large burden for those State
and local agencies utilizing digital data acquisition methods. 

EPA and others (e.g., State and local air quality management agencies,
environmental groups, academic institutions, and industrial groups) use
the collected monitoring data for many purposes.  Some of the more
prominent uses include informing the public and other interested parties
of an area’s air quality, judging an area(s (e.g., county, city,
neighborhood) air quality in comparison with the established health or
welfare standards (including both national and local standards),
evaluating an air quality management agency’s progress in achieving or
maintaining air pollutant levels below the national and local standards,
developing and revising State Implementation Plans (SIPs) in accordance
with 40 CFR part 51, evaluating air pollutant control strategies,
developing or revising national control policies, providing data for air
quality model development and validation, supporting enforcement
actions, documenting episodes and initiating episode controls, air
quality trends assessment, and air pollution research.

The State and local air quality management agencies with responsibility
for reporting ambient air quality data and information as requested in
this ICR submit these data electronically to the EPA’s Air Quality
System (AQS) and AIRNow databases.  Quality assurance/quality control
records and monitoring network documentation are also maintained by each
State and local agency, in AQS electronic format where possible.

	Although the State and local air quality management agencies are
responsible for the operation of the air monitoring networks, the EPA
funds a portion of the total costs through federal grants.  Some of
these grants require an appropriate level of contribution, or match,
from the State/local air quality management agencies.  The costs shown
in this ICR are the total costs incurred for the monitoring program
regardless of the source of the funding.  

	For the purpose of this ICR, we have estimated the maximum potential
burden for the options being considered.  The ICR estimates for the
final rule will present the burden estimate based on the requirements
contained in the final rule.  The burden estimates are for the 3-year
period of 2011 through 2013.

	This Information Collection is estimated to involve 93 respondents for
a total approximate cost of $13,863,950 (total capital, and labor and
non-labor operation and maintenance) and a total burden of 172,449
hours. The labor costs associated with these hours is $9,247,885.
Included in the $13,863,950 total are other costs of non-labor
operations and maintenance of $903,787 and equipment and contract costs
of $3,712,278. In addition to the costs at the State and local air
quality management agencies, there is a burden to EPA of total of 5,431
hours and $ 382,786.

2.  Need for and Use of the Collection

	(a) Need/Authority for the Collection

The information requirements included within this ICR are necessary to
provide the EPA with ambient air quality surveillance data to determine
the United States air quality status, to make attainment decisions with
respect to the NAAQS, to assist in developing necessary control
strategies to ensure attainment of the NAAQS, to assess national trends
in air pollution, to inform the public of air quality, and to determine
the population’s exposure to various ambient air pollutants.  The
EPA’s goal of attaining the NAAQS in all areas of the United States is
directly dependent upon the availability of ambient air quality data
requested in this information collection.  Additionally, the EPA, State,
and local air quality management agencies, environmental groups,
industrial groups, and academic organizations use these data to study
atmospheric chemistry, e.g., the formation and fate of SO2, to determine
the most appropriate and effective control strategies necessary to
reduce air pollution.

The principal legal authority for this information collection is the
Clean Air Act 42 U.S.C. 7403, 7410, and 7511a, from which the 40 CFR
part 58 regulations were promulgated.

Under 7403 (c), the Administrator is required to conduct a program of
research, testing, and development of methods for sampling, measurement,
monitoring, analysis, and modeling of air pollutants, specifically
including a requirement to establish a national network to monitor,
collect, and compile data with quantification of certainty in the status
and trends of air emissions and air quality.  This program will also
include the development of improved methods and technologies to increase
understanding of the sources of nitrogen oxides, its formation,
transport, regional influences and trends, and interactions with other
pollutants.  

Section 7410 (a) contains the SIP requirements, which include a
requirement that each State submit a SIP that provides for the
establishment and operation of appropriate devices, methods, systems,
and procedures necessary to monitor, compile, analyze, and make
available to the Administrator data on ambient air quality.  

2(b) Practical Utility/Users of the Data

The EPA Office of Air Quality Planning and Standards (OAQPS) uses the
ambient air quality data included within this collection to make
attainment decisions with respect to each air pollutant subject to
NAAQS.  For those areas that do not attain the NAAQS for one or more
pollutants, the OAQPS, the affected EPA Regional Office, and the
affected State or local air quality management agency will work to
develop an appropriate SIP to address how the area(s air quality can be
improved to meet the applicable NAAQS.

To identify how the nation is progressing in improving air quality, the
OAQPS prepares annually the National Air Quality and Emissions Trends
report (http://www.epa.gov/airtrends) using the ambient air quality data
collected through this ICR.  The State and local air quality management
agencies use these data for multiple purposes including tracking their
progress toward achieving and maintaining air quality within the
established NAAQS and any statewide standards they have established. 
For example, the State of California has established a separate
statewide ozone air quality standard that is more stringent than the
NAAQS for ozone; therefore, they use ambient air data to determine
compliance with both standards.  

3.  NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-duplication

This collection is not unnecessarily duplicative of information
otherwise reasonably accessible to the agency.  The AQS and AIRNow
systems, which contain information based solely on this collection, are
the only national air quality data repositories available to the EPA. 
The ambient air quality surveillance data and related information
collected through this information collection are not otherwise
reasonably accessible to the EPA.

A few State and local air quality management agencies have their own
data storage systems (e.g., the California Air Resources Board);
however, most State and local air quality management agencies use the
AQS and AIRNow as their primary repositories for all air quality data.

3(b) Public Notice Required Prior to ICR Submission to OMB

The 1995 Paperwork Reduction Act requires that any agency developing a
non-rule related ICR must solicit public comments for a 60-day period
prior to submitting the ICR to OMB.    SEQ CHAPTER \h \r 1 This section
is not applicable to this ICR because this is a rule-related ICR.

3(c) Consultations

	Through the course of planning, monitoring, and improving upon this
collection and its associated regulation, the EPA regularly consults
with affected State and local air quality management agencies through
various methods including the regulatory process, regular meetings, and
training courses.  The EPA conducts annual work shops and training on
the AQS reporting system, e.g., the annual AQS Conference.  The EPA
Regional Offices conduct annual ambient air monitoring meetings with
their affected State and local air quality management agencies to assist
these affected agencies with this collection and its associated
regulation.  The EPA’s OAQPS also meets regularly with leading State
and local air monitoring managers to discuss the Nation’s ambient air
monitoring program and this collection, via large monthly phone calls
and smaller in person meeting two or three times per year.  Starting in
1999, the Clean Air Scientific Advisory Committee (CASAC) established
the subcommittee on fine particle monitoring to provide advice to EPA on
various implementation aspects of the PM monitoring networks.  In
addition, CASAC also has established a monitoring strategy subcommittee
to extend consultation to the entire network.

3(d) Effects of Less Frequent Collection

	State and local air quality management agencies would collect and
report ambient air quality data without the 40 CFR 58 regulations
associated with this collection.  Sanctions do not automatically accrue
to State or local air quality management agencies that fail to meet
these requirements.  The 40 CFR part 58 regulations and this associated
collection do provide for a consistent system for reporting and record
keeping that would not exist without these requirements.  The effects of
less frequent collection include:

• 	A national database that is not consistently updated and available
for public consumption;

• 	Less timely attainment designations with respect to the NAAQS;

• 	More difficultly in identifying and repairing problems with an
ambient air monitor--i.e., data are used as to check a monitor’s
operating condition, and reporting data less frequently would delay a
State or local agency’s ability to recognize a problem with a monitor
or a laboratory procedure; and

• 	The EPA would not be able to consistently answer questions from the
public in a timely fashion regarding air quality in various areas of the
country.

3(e) General Guidelines

  SEQ CHAPTER \h \r 1 All of the OMB’s general guidelines for
information collections in 5 CFR 1320.6 are met by this ICR.  None of
the guidelines are exceeded.

• 	Data reporting on a quarterly basis is the requirement.  Nearly all
respondents voluntarily report on a monthly basis.

•	Record retention is for no more than 3 years (most records are kept
by the EPA data repository, not the affected State and local air quality
management agencies)

•	Information is maintained and reported in the standardized
electronic AQS format.

3(f) Confidentiality

Information that is considered personal, private, proprietary, or
confidential is not required for this collection.  One purpose of
collecting ambient air data through AQS and AIRNow is to inform the
public of general air quality in ambient air (air considered generally
accessible to the public), and as such, does not present a need for
maintaining a confidential nature.  Security measures are taken to
prevent tampering with the AQS electronic database by limiting the
access to the AQS mainframe only to authorized users

3(g) Sensitive Questions

	  SEQ CHAPTER \h \r 1 This section is not applicable to this ICR
because no information involving matters of a sensitive nature is
collected.

4.  THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes

This ICR affects State and local governments (SIC code 951,
Administration of Environmental Quality Program) that are currently
operating and maintaining established ambient air quality networks.  The
40 CFR part 58 regulations associated with this request require that
State and local air quality management agencies conduct the ambient air
quality surveillance and report the data to the EPA’s AQS.  Although
industrial, environmental, and research organizations may use the data
available through the AQS, they are not required to report any
information for this information collection.  Data submittal to AIRNow
is voluntary for all organizations, but most State and local agencies
reporting to AQS also report to AIRNow.

4(b) Information Requested

(i)  Data items, including record keeping requirements

	These data items are submitted electronically to EPA’s AQS as
required by 40 CFR part 58.   These data are stored electronically
within the EPA’s AQS, and separate records kept by the State or local
air quality management agency are not required.

•	Hourly and sub-hourly (5-minute) ambient air pollutant
concentrations of SO2 collected at SLAMS/PAMS sites.

•	Precision and accuracy data for all SLAMS sites, PAMS, and Special
Purpose Monitors (SPM).

•	SLAMS monitoring network description information, including the site
AQS identification number, site location, sampling and analysis method,
operating schedule, monitoring objective, site’s scale of
representation, identity of the urban area represented, and quality
assurance plan.

•	Results of the annual ambient air monitoring network and quality
assurance plan review.

•	Annual SLAMS summary report which includes the location, date,
pollution source, and duration of each incident of air pollution during
which ambient levels of a pollutant reached or exceeded the significant
harm levels as defined in 40 CFR 51.151, the certification of the
report’s accuracy by a designated State air pollution control officer,
and various other summary statistics as provided by the AQS system.

(ii)  Respondent Activities

A model respondent would engage in the following activities to comply
with this information request:

•	Read the 40 CFR part 58 regulatory provisions and other EPA guidance
(for example, please reference our Internet site at
www.epa.gov/ttn/amtic.)

•	Plan ambient air monitoring activities, such as developing a quality
assurance plan for the network operation and maintenance, developing and
reviewing the ambient air quality surveillance network design, planning
where to locate sites, plan how to maintain and operate each site,
develop a data reporting and validation plan.

•	Write the quality assurance plan for network operation and
maintenance, the ambient air quality surveillance network plan, and the
data reporting and validation plan.  Submit these plans to the EPA
Regional or Headquarters office for review, and approval if appropriate.

•	Obtain on-site leases or agreements to locate ambient air quality
surveillance equipment.

•	Investigate vendors, and procure equipment necessary to meet the
ambient air quality network plan.

•	Receive training for site operation and maintenance, quality
assurance procedures, and data processing and reporting.

•	Make arrangements for appropriate utility hookups for each ambient
air quality surveillance site, i.e., electricity, telephones, data lines
for electronic submission of concentrations from automated analyzers.

•	Install ambient air quality surveillance equipment and equipment
shelter.  Ensure security of the site.

•	Conduct ambient air quality monitoring, incorporating all
appropriate quality assurance procedures such as calibrations, precision
and accuracy checks, and, if necessary, concurrent monitoring.

•	Validate the ambient air data for quality assurance considerations.

•	Electronically submit the complete and validated ambient air data to
the AQS and/or AIRNow data repositories.

•	Prepare and submit to EPA annually the SLAMS sites summary report.  

Each of these activities are conducted using existing reporting and
recordkeeping practices, including electronic submittal to the AQS and
to AIRNow .  If the 40 CFR part 58 regulations did not exist, and
presumably the related AQS and AIRNow, the quality assurance procedures,
and the siting guidance did not exist, the State and local air quality
management agencies would in a majority of cases conduct monitoring;
however, methods used by each agency would vary and data would not be
readily available to EPA and the public.  The influence of the 40 CFR
part 58 regulations has been to provide a nationally consistent
mechanism for collecting ambient air quality data including uniform
quality assurance procedures, data collection and storage mediums (AQS),
and uniform methodology.  Without this regulations and associated ICR,
managing and maintaining a national air quality program would be
extremely difficult, if possible.

 

 

5.  THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

The EPA conducts the following activities to implement this ICR and
associated regulation:

•	Periodically review the 40 CFR part 58 regulations to update the
information collection and monitoring requirements in light of new
technological developments or new air pollutant standards.  Develop
revisions to the regulations in response to legislative action and
program changes.

•	Establish, maintain, and support the AQS and AIRNow as the national
repositories for all State and local air quality management agency
ambient air quality data and monitoring information.  Periodically
evaluate and improve upon this system as new technologies, and new
regulatory requirements would dictate.

•	Answer respondent (generally State and local air quality management
agencies, but also industrial organizations, environmental groups, and
others) questions about ambient air monitoring, the 40 CFR part 58
regulatory requirements, and the AQS and AIRNow.  This includes the
establishment of the Ambient Monitoring Technology Information Center
bulletin board, the AQS toll-free hotline, and other written or verbal
communication.

•	Support the quality assurance program by working within the EPA and
with the respondents to evaluate precision and accuracy data, oversee
the National Performance Audit Program, participate in systems audits,
and conduct data validation checks on the AQS data submittal.

•	Provide within the AQS mechanisms for statistical calculations, such
as the number of times a particular ambient air quality monitoring site
exceeds the NAAQS.  Distribute the AQS data in various ways including
upon written request, by Freedom of Information Act request, by press
release, and in the annual National Air Quality and Emissions Trends
Report. 

•	Provide adequate electronic storage space within the AQS for all
ambient air quality surveillance data and information.

•	Provide various reports and graphics for users of AIRNow.

5(b) Collection Methodology and Management

All State and local ambient air monitoring networks have access to and
use well-established quality assurance procedures as defined in the
Quality Assurance Handbook for Air Pollution Measurement Systems,
Volumes I and II, EPA/600/R-94/038a & b.  These documents ensure that
all ambient air quality data are accurate and reliable.  

The EPA has provided and will continue to provide resources for the
maintenance and operation of the AQS and AIRNow national data
repositories.  All data required by this collection are submitted
electronically to reduce the burden of the collection and to improve
data quality, agency efficiency, and responsiveness to the public. 
Various statistical and graphical summaries are also provided by the AQS
and AIRNow systems which enhance the utility of the information for
consumption by the public and all affected State and local air quality
management agencies.  In submitting ambient air data into the AQS and
AIRNow national repositories, we ensure that the data are publicly
available, electronically stored, and electronically retrievable.  State
and local air quality management agencies and the EPA have been
submitting data to the AQS since its inception in 1987.

5(c) Small Entity Flexibility 

This collection contains a minimum amount of information in order to
manage the air quality program for the United States.  The smallest
entities affected by this collection are local air quality management
agencies, typically consisting of the governing agencies for a county or
group of counties, or a smaller metropolitan area (e.g., cities with a
population of 50,000).  This collection reduces to the extent
practicable and appropriate the burden on entities that provide ambient
air quality data and information to or for the EPA, including with
respect to small entities, as defined in the Regulatory Flexibility Act
(5 U.S.C. 601(6)), the use of such techniques as:

•	Establishing differing compliance or reporting requirements or
timetables that account for the resources available to those who are to
respond (e.g., the monitoring and reporting requirements decrease as the
population of an area decreases, and various timetables for deploying
ambient air monitoring stations are negotiated between the affected
State or local air quality management agency and the EPA with
consideration of the respondent’s resources);  

•	Clarification, consolidation, or simplification of compliance and
reporting requirements (e.g., by establishing, maintaining, and
improving as needed the AQS and AIRNow national repositories for ambient
air quality data and information);

•	Exemption from coverage of the collection of information, or any
part thereof (e.g., the EPA negotiates with State and local air quality
management agencies to determine the most effective and most efficient
ambient air quality networks with respect to the monitoring needs,
technical abilities, and resources available to each affected agency).

5(d) Collection Schedule

Ambient air quality surveillance data and precision and accuracy data
for criteria air pollutants are submitted according to the schedule
defined in 40 CFR 58.16.  These current regulations require that State
and local air quality management agencies report their data within 90
days after the end of the quarter during which the data were collected. 


The annual SLAMS report is submitted by May 1 (effective 2010) of each
year for data collected from January 1 through December 31 of the
previous year in accordance with 40 CFR 58.15.  This certification
applies to all SLAMS and all SPM monitoring data that have been
submitted by May 1.  

The annual air quality surveillance network reviews are conducted and
reports are submitted to the EPA on a schedule that is determined by the
affected State or local air quality management agency and the EPA
Regional Office.  

Ambient air quality data and information are made available to the
public at any time in various ways, including:

•	Upon request to the appropriate EPA Regional office, or to the
OAQPS;

•	By Freedom of Information Act Request to the appropriate EPA
Regional Office or the OAQPS;

•	From the State or local air quality management agency responsible
for collecting the ambient air quality data and information; 

•	By obtaining access, through appropriate EPA channels, to the AQS
and AIRNow to obtain the data electronically; 

•	Through EPA public reports, such as the annual (National Air Quality
and Emissions Trends Report(; or

•	Through the AIRNow data base and the AQI reporting mechanisms which
include newspaper, television, Internet and other publicly available
notices (see www.epa.gov/airnow).

6.  ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

All activities listed with section 4 (b) (ii) of this ICR Supporting
Statement are presented in Worksheet 1.  The detailed burden and cost
estimates for the different types of monitors are based on information
provided in the updated version of Guidance for Estimating Ambient Air
Monitoring Costs for Criteria Pollutants and Selected Air Toxic
Pollutants (prepared by Desert Research Institute for the EPA Office of
Air Quality Planning and Standards, Air Quality Assessment Division,
Ambient Air Monitoring Group, January 2005).  The cost estimates
presented in this guidance document are based on existing literature and
direct monitoring experience.  The costs for equipment and supplies were
verified with vendors.  The monitoring costs are based on vendor quotes
for the monitor type that EPA expects respondents to use to comply with
the requirements.  Costs for level of effort estimates are verified with
selected State and local agencies.  All cost values presented in the
guidance document are adjusted to 2004 dollars.  

	For use in preparing the burden estimates for this ICR, costs for the
monitoring requirements were inflated to 2011, 2012, and 2013.  The cost
escalation factors were estimated based on the appropriate Gross
Domestic Product (GDP) price indices as reported in the report available
at   HYPERLINK "http://www.jsc."  http://www.jsc.
nasa.gov/bu2/inflateGDP.html.  Tables showing the detailed burden
estimate calculations are presented below.  A summary of the average
annual respondent burden costs follows.

Worksheet 1:  Annual Average Respondent Burden Estimates

Collection

Activities	Total Labor Hours

Per Respondent Per Year

(93 respondents)

1.  Network design	6

2.  Site installation	14

3.  Sampling & analysis	504

4.  Maintenance & repairs	285

5.  Data management	491

6.  Quality assurance	334

7.  Supervision	220

8.  Meteorological Instrumentation	0

TOTAL	1854



6(b) Estimating Respondent Costs

All activities listed with section 4 (b) (ii) of this ICR Supporting
Statement are included in the Worksheet 2. A summary of the average
annual respondent burden costs follows.

Worksheet 2:  Annual Average Respondent Cost Estimates

Collection

Activities	Total Labor Cost 

Per Respondent Per Year 

(93 respondents)

1.  Network design	$363

2.  Site installation	$617

3.  Sampling & analysis	$25,388

4.  Maintenance & repairs	$15,310

5.  Data management	$26,134

6.  Quality assurance	$18,590

7.  Supervision	$13035

8.  Meteorological Instrumentation	$0

TOTAL	$99,437



6(c) Estimating Agency Burden and Cost

We estimated the Agency burden and cost by using current burden and cost
of the ambient air monitoring program related to this collection.  We
included burden and cost for the OAQPS, the ten Regional Offices, and
associated contract activities.  The in-house activities for this
collection are completed by a variety of individuals with a variety of
salaries; therefore, we used the actual salary as an average for
computing the program costs.  Actual contractor expenses were used for
those activities completed using extramural resources.  We estimated a
total of 14,147 hours and $858,280 total agency burden.

6(d)	Estimating the Respondent Universe and Total Burden and Costs 

Worksheet 3 shows the total respondent hourly burdens and costs which
was taken from section 6(b) above for the estimated 93 respondents.  The
total labor burden for the respondents was estimated to be 172,449 hours
at a total cost of $9,247,885.

Worksheet 3:  Annual Total Respondent Labor Burden/Cost Estimates

Collection

 Activities	Total Labor Hours

Per Year	Total Labor Cost

Per Year

1.  Network design	532	$33,796

2.  Site installation	1,337	$57,396

3.  Sampling & analysis	46,904	$2,361,123

4.  Maintenance & repairs	26,520	$1,423,837

5.  Data management	45,637	$2,430,494

6.  Quality assurance	31,044	$1,728,939

7.  Supervision	20,475	$1,212,300

8.  Meteorological Instrumentation	0	0

TOTAL	172,449	$9,247,885



6(e) Bottom Line Burden Hours and Cost Tables

 (i)  Respondent Tally 

Respondent Total Annual Burden =172,449 hours

Respondent Total Annual Labor Cost for O & M = $9,247,885

Respondent Total Annual Cost for Non-labor O & M = $903,787

Respondent Total Equipment/Contract Dollars = $3,712,278

Total Respondent Tally = $13,863,950	

(ii) The Agency Tally		

Agency Total Annual Burden = 14,147 hours

Agency Total Annual Cost = $858,280

(iii) Variations In The Annual Bottom Line.

We do not expect any significant variations in the annual bottom line
for the ambient air monitoring networks for the clearance period
requested.

	

6(f) Reasons for Change in Burden

N/A

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 193 hours per respondent.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.  An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. 
The OMB control numbers for EPA's regulations are listed in 40 CFR part
9 and 48 CFR chapter 15.  

To allow 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 established a public docket for this ICR under Docket ID
No. OAR-2008-0338 which has been available for public viewing at the Air
and Radiation Docket and Information Center Docket 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 and Information Center
Docket is (202) 566-1742.  An electronic version of the public docket
was made available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket.  The public was able to 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 have been available electronically.  The public was also advised to
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.

PART B OF SUPPORTING STATEMENT

	

This section is not applicable to this ICR because statistical methods
are not used in the data collection associated with the rule amendments.
	

 CBSAs are defined by the U.S. Census Bureau, and are comprised of both
Metropolitan Statistical Areas and Micropolitan Statistical Areas ( 
HYPERLINK "http://www.census.gov"  http://www.census.gov ). 

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