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Supporting Statement

Restructuring of the Stationary Source Audit Program

EPA ICR # 2355.01

PART A

1.  Identification of the Information Collection

     	   	 (a) Title of the Information Collection

     “Restructuring of the Stationary Source Audit Program”

 	 (b)  Short Characterization/Abstract

This final rule will allow accredited private audit sample providers to
supply regulated emission sources with audit samples to verify the
results of emissions testing that demonstrates compliance with emission
limits.  A regulated emission source conducting a compliance test, would
purchase an audit sample from an accredited audit sample provider(AASP).
 The AASP would report the true value of the audit sample to the
compliance authority (State, local or EPA Regional Office).  This is a
new  reporting requirement.   The AASP would in most cases make the
report by electronic mail.  A report would be made for each audit sample
that the AASP sold to a regulated emission source that was conducting an
emissions test to determine compliance with an emission limit.  Based on
historic data, EPA estimates that there will be about 832 audit samples
sold each year generating the need for about 832 reports.   	

2.  Need for and Use of the Collection

	(a) Need/Authority for the Collection

The information requirements included within this ICR are necessary to
assure the EPA that the restructured audit sample program is operating
in a way that protects the integrity of the audit samples.  The
integrity of an audit sample depends on its being distributed as a
“blind sample.”  This means that the true value of the audit sample
is known by the provider but not the user.  The flow of information
about the audit sample in the current program is slightly different than
that of the restructured program.  In the current system, EPA supplies
the audit sample to the appropriate compliance authority who then gives
it to the user.   After measuring the audit sample, the user reports the
result to the compliance authority who then reports it to EPA and
receives the true value in return.  In the restructured program, the
accredited audit sample provider (AASP) supplies the audit sample to the
user.  Just as in the current program, the user reports the measured
result to the appropriate compliance authority an to the AASP.  The
restructured program then requires the AASP to report the true value of
the sample to the compliance authority before or at the same time as the
true value is reported to the user.  This is a new reporting requirement
that does not exist under the current program.  This requirement is
necessary to help the compliance authority insure that the audit samples
are provided as blind samples to the user.  

The principal legal authority for this information collection is 23
U.S.C. § 101 and 42 U.S.C. ( 7410-7671q.

2(b)  Practical Utility/Users of the Data

Local, State and EPA regional offices who have been delegated authority
to enforce emission limits will use the data from the audit samples to
assure that regulated sources are correctly measuring their pollutant
emissions when they perform compliance tests.  The results from the
audit samples are an objective measure of testing performance during a
compliance test.  If the emissions tester produces results that are
within the allowable range for the audit sample, the compliance
authority has objective evidence to show that the tester‘s performance
was within the normal range for a well qualified tester.

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 compliance authorities.  There is
no other source for this information.

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 this collection and its associated
regulation, the EPA regularly consulted with affected AASPs, and State
and local compliance authorities through regular public meetings.  

3(d)  Effects of Less Frequent Collection

	The reporting under this information collection is event driven.  There
is no regular schedule for reporting.   Information is collected only
when an audit sample is supplied to a user during a compliance test.  A
report must be submitted for each event.  

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.

• 	There is no data reporting schedule.

•	There is no requirement to retain records for more than three years.


3(f)  Confidentiality

Information that is considered personal, private, proprietary, or
confidential is not required for this collection.  

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 laboratories that supply audit samples.   The SIC is
8734.

4(b)  Information Requested

	AASPs must report to the appropriate compliance authority the true
value of any audit sample supplied for quality assurance purposes to a
regulated emission source or the source’s authorized representative
for use during a compliance test.  The AASP must also maintain for three
years a record of the recipient of the sample, the date the sample was
provided, and the true value of the sample.

(i)  Data items, including record keeping requirements

	Audit sample number;

	Name of the recipient of the sample; and

	True value of the sample. 

(ii)  Respondent Activities

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

▪     Produce an audit sample and verify it’s true value.

▪     Ship the audit sample to the source that is conducting a
compliance test.

•	Generate an electronic message showing the audit sample number, the
sample recipient’s name, and the true value of the sample.

•	Transmit the message electronically to the appropriate compliance
authority.

•	Record electronically the audit sample number, the sample
recipient’s name, the date the sample was shipped, and the true value
of the sample.

Each of these activities is part of the customary and usual business
practice (CBP) of the AASP because the same information must be provided
to the recipient of the audit sample.   Development of the database and
system to handle the recordkeeping and reporting are attributed to the
CBP of the AASP.  The activities related to the ICR are only the
incremental activity needed to produce and distribute the audit sample
and to transmit a copy of the results of the audit sample to the
appropriate compliance authority.

 

 

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

5(a)  Agency Activities

	There are no EPA activities associated with this ICR.

5(b)  Collection Methodology and Management

The information will be collected and used by the appropriate compliance
authority for each regulated source.  The AASP will submit the report
using the procedures described in a publicly available technical
criteria document (TCD).  The TCD must be developed by a public process
through a consensus making body.  The consensus making body will select
a third party accreditor who will be responsible for insuring that all
AASPs operate in accordance with the procedures in the technical
criteria document.

5(c)  Small Entity Flexibility  -- 

This collection requires submittal of the minimum amount of information
in order to insure that the restructured stationary source audit program
continues to operate in a credible manner.  This collection reduces to a
practicable and appropriate level the burden on any small entities that
are AASPs. 

5(d)  Collection Schedule

	There is no regular schedule for collecting information.  The
information is event driven and information is collected only when an
AASP supplies an audit sample to a user.

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.  

	

Tables showing the detailed burden estimate calculations are presented
below.  A summary of the average annual respondent burden costs follows.
 The burden for this ICR is limited to the incremental activity required
to provide a copy of the information generated for the audit sample user
to the appropriate compliance authority.  All the labor expended on
behalf of this ICR will be expended by the AASPs.  However, they will
not bear the burden of the ICR costs.  Their labor costs will be passed
to the stationary sources who are required to demonstrate compliance
with pollutant emission limits and must purchase audit sample as part of
the demonstration.  There are estimated to be a very limited number (a
maximum of nine) AASPs who will supply the audit samples, but there will
be many stationary sources who will buy them.  The following estimates
are believed to be an accurate estimate for each respondent, but the
actual costs of the respondents will be paid by an estimated 504
stationary sources so that the actual cost per stationary source will be
on average about $398.66.

Worksheet 1:  Annual Average Respondent Burden Estimates

Collection

Activities	Total Labor Hours

Per Respondent Per Year

(9 respondents)

1.  Prepare audit samples	136

2.  Verify audit sample concentration	95

3.  Distribute audit samples	53

4.  Generate and transmit audit sample report	7

5.  Record audit sample results	4

TOTAL	294



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 

(9 respondents)

1.  Prepare audit samples	$10,170

2.  Verify audit concentration	$8,058

3.  Distribute audit samples	$3,432

4.  Generate and transmit audit sample report	$416

5.  Record audit sample results	$249

TOTAL	$22,325



6(c)  Estimating Agency Burden and Cost

We estimated the Agency burden and cost to be zero.

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 9 respondents.  The
total labor burden for the respondents was estimated to be 2646 hours at
a total cost of $201,091.

Worksheet 3:  Annual Total Respondent Labor Burden/Cost Estimates

Collection

 Activities	Total Labor Hours

Per Year	Total Labor Cost

Per Year

1.  Prepare audit sample	1220	$91530

2.  Verify audit sample concentration	853	$72522

3. Distribute audit samples	475	$30888

4.  Generate and transmit audit sample report	62	$3906

5.  Record audit sample results	36	$2245

TOTAL	2646	$201091



6(e)  Bottom Line Burden Hours and Cost Tables

 (i)  Respondent Tally 

Respondent Total Annual Burden =294 hours

Respondent Total Annual Labor Cost = $22,325.

(ii) The Agency Tally		

Agency Total Annual Burden = 0 hours

Agency Total Annual Cost = $0.0

(iii) Variations In The Annual Bottom Line.

We do not expect any significant variations in the annual bottom line
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 245 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 the rulemaking that
includes this ICR under Docket ID Number EPA-HQ-OAR-2008-0531 which is
available for online viewing at http://www.regulations.gov, or in person
viewing at the Air Docket Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 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 Center is (202) 566-1742.  An electronic version of the
public docket is available at http://www.regulations.gov.  This site can
be used 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.  When in the system,
select “search,” then key in the Docket ID Number identified above. 
Also, you may 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 Number EPA-HQ-OAR-2008-0531 and OMB Control Number
_____-_____ in any correspondence.

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.

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