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Supporting Statement

Implementation of Ambient Air Protocol Gas Verification Program 

EPA ICR # 2375.01

PART A

1.  Identification of the Information Collection

     	   	 (a) Title of the Information Collection

Implementation of Ambient Air Protocol Gas Verification Program, EPA ICR
number 2375.01, OMB Control Number 2060-NEW

 	 (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, appendix A, Quality Assurance Requirements for
SLAMS, SPMs and PSD Air Monitoring.  These data and information are
collected by State, local, and Tribal air quality management agencies
and reported to the U.S. Environmental Protection Agency (EPA).    

The EPA Ambient Air Quality Monitoring Program’s QA requirements 40
CFR part 58, appendix A require:

2.6 Gaseous and Flow Rate Audit Standards. Gaseous pollutant
concentration standards (permeation devices or cylinders of compressed
gas) used to obtain test concentrations for CO, SO2, NO, and NO2 must be
traceable to either a National Institute of Standards and Technology
(NIST) Traceable Reference Material (NTRM), NIST Standard Reference
Materials (SRM) and Netherlands Measurement Institute (NMi) Primary
Reference Materials (valid as covered by Joint Declaration of
Equivalence) or a NIST-certified Gas Manufacturer's Internal Standard
(GMIS), certified in accordance with one of the procedures given in
reference 4 of this appendix. Vendors advertising certification with the
procedures provided in reference 4 of this appendix and distributing
gases as “EPA Protocol Gas” must participate in the EPA Protocol Gas
Verification Program or not use “EPA” in any form of advertising. 

These requirements give assurance to end users that all specialty gas
producers selling EPA Protocol Gases are participants in a program that
provides an independent assessment of the accuracy of their gases'
certified concentrations. In 2010 EPA will develop an Ambient Air
Protocol Gas Verification Program (AA-PGVP) that will provide end users
with information about participating producers and verification results.

This program is considered a verification program because its current
implementation level does not allow for a large enough sample of EPA
Protocol Gases from any one specialty gas producer to be measured to
yield a statistically rigorous assessment of the accuracy.  It will not
provide end users with a scientifically defensible estimate of whether
gases of acceptable quality can be purchased from a specific producer. 
Rather, the results provide information to end users that may inform
their purchasing decisions.  The final verification results will be
reported with an explanation on how the results should be interpreted.

Each year, EPA will attempt to compare gas cylinders from every
specialty gas producer being used by ambient air monitoring
organizations.  EPA Regions 7 and 2 have agreed to provide analytical
services to provide verifications of 40 cylinders/lab or 80 cylinders
total/year. Cylinders will be verified at a pre-determined time each
quarter.

 The selection goal in the following order would be:

Minimum one gas standard from every specialty gas vendor being used by
the monitoring community

Selection of a minimum of 3 standards per specialty gas vendor

Weight additional standards by vendor market share in ambient air
monitoring community.   

In order to make the appropriate selection, EPA needs to know what
specialty gas producers are being used by the monitoring organizations. 
Therefore EPA needs to collect information from each primary quality
assurance organization every year on specialty gas producers being used
and whether the monitoring organization would like to participate in the
verification for the upcoming calendar year.

	The burden estimates are for the 3-year period of 2011 through 2013. 
This ICR burden estimates are associated with the current monitoring
portion of ICR #0940.22 (2060-0084). 

	This 3-year information collection is estimated to involve
approximately 211 respondents for a total cost of approximately $13,750
(labor) which equates to 211 hours. The estimate is only labor hours
since EPA is asking the State, local, and Tribal air quality management
agencies to complete an annual form that should take approximately 20
minutes to complete. In addition to the costs at the State, local, and
Tribal air quality management agencies, there is a burden to EPA a total
of 120 hours which equates to approximately $17,309.  

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 in order to
meet the code of federal regulation requirements to implement an Ambient
Air Protocol Gas Verification Program. This program is integral to
ensure the quality of the data that is used 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 quality ambient air data and the use
of protocol gas calibration standards helps ensure this quality. 

The principal legal authority for this information collection is the
Clean Air Act 42 U.S.C.A. §§ 7403, 7410, and 7511a, from which the 40
CFR part 58, appendix A QA 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.  The Ambient Air Protocol
Gas Verification Program reduce the uncertainty of data collected under
§ 7403 (c),

2(b)  Practical Utility/Users of the Data

The EPA Office of Air Quality Planning and Standards (OAQPS) uses the
data included within this collection to determine what specialty gas
producers are selling calibration standards to monitoring organizations
implementing ambient air monitoring under 40 CFR part 58 that are
subject to use of protocol gasses.  In addition, the information is used
to determine the monitoring organizations willing to participate in the
program by submitting the purchased gasses to EPA for verification
testing.  

Results for the verification data can provide monitoring organizations
with information on specialty gas producers that are participating in
the Protocol Gas Verification Program and the results might also help
monitoring organizations with their protocol gas purchasing decisions.

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.  There is currently no
nationwide database that would allow EPA to gather information of this
detail.  

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  EPA
published a Federal Register notice soliciting public comment on March
2, 2010 (75 FR 9407).  No comments were received.

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, local, and Tribal air quality management agencies
through various methods including the regulatory process, regular
meetings, and training courses.  The EPA has developed an advisory group
for this program made up of OAQPS, EPA Regions and representatives from
the State, local, and Tribal air quality management agencies to assist
in the development of this information collection. This Advisory Group
meets quarterly to discuss pertinent issues associated with the AA-PGVP.
The EPA Regional Offices conduct annual ambient air monitoring meetings
with their affected State, local, and Tribal 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.  

3(d)  Effects of Less Frequent Collection

	State, local, and Tribal air quality management agencies would collect
and report ambient air quality data without the 40 CFR 58 regulation
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;

• 	EPA would not be able to ensure new specialty gas vendors were
participating in the program and were selling gasses of acceptable
quality.

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 annual basis is the requirement.  

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

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

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 State, local, and Tribal 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, local, and Tribal air quality management agencies conducting the
ambient air quality surveillance under this regulation to use protocol
gases from specialty gas producers participating in the AA-PGVP.   

4(b)  Information Requested

(i)  Data items, including record keeping requirements

	These data items are submitted electronically to EPA and are stored
electronically within the EPA's AA-PGVP data base. 

•	Primary quality assurance organization (PQAO) name and code and
Reporting Agency name and code.  Both the name and codes can be found in
the EPA Air Quality System (AQS) Database.

•	Monitoring organization protocol gas point of contact and email
address

•	Specialty gas producer(s) used, their address and the gas
concentrations normally purchased

•	Information on when monitoring organizations might purchase protocol
gas in the upcoming calendar year, whether they would like to
participate in the verification activity and whether they have had DOT
hazardous materials shipping training.

(ii)  Respondent Activities

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

•	Read the one page instructions on how to fill out the form.  

•	Complete the one page Microsoft Excel form each year within the
specified time period and submit it to OAQPS AA-PGVP Lead.

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 such as the use of
protocol gasses.  

  

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 AA-PGVP data base as the
national repositories for all State, local, and Tribal air quality
management agency ambient air protocol gas information.  Periodically
evaluate and improve upon this system as new technologies, and new
regulatory requirements would dictate.

•	Answer respondent (generally State, local, and Tribal air quality
management agencies, but also industrial organizations, environmental
groups, and others) questions about ambient air monitoring, the 40 CFR
part 58 protocol gas regulatory requirements.  

•	Support the AA-PGVP by ensuring that the EPA Region 2 and 7
laboratories are able to conduct verifications of specialty gas
standards each year. 

•	Provide annual assessment reports of the protocol gas verifications
for posting on the AMTIC website or public dissemination.

5(b)  Collection Methodology and Management

The EPA has provided and will continue to provide resources for the
maintenance and operation of the protocol gas database.  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.  In submitting the information to EPA,
we ensure that the data are publicly available, electronically stored,
and electronically retrievable.  

5(c)  Small Entity Flexibility  -- 

	This collection contains a minimum amount of information in order to
implement the AA-PGVP.  The AA-PGVP form is not anticipated to take more
than 10 minutes for any entity, regardless of size, to complete.  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 100,000).  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))

5(d)  Collection Schedule- 

The information will be reported annually from September through
November and the results will reflect the following calendar year. 

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. 

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

•	through report specifically generated for this program.

	Due to the nature of the program, information related to what specialty
gas cylinders were use from individual monitoring organizations will not
be published until the cylinder has been analyzed and data validated. 
In this manner specialty gas vendors will not be aware ahead of time
that a specific cylinder is being used for the verification. 

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, based on the average of
the first two quarters.  

	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 Minutes

Per Respondent Per Year

(211 respondents)

1.  Read instructions	5

2.  Complete Form	15

TOTAL	20 minutes



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 

(211 respondents)

1.  Read instructions	$5.43

2.  Complete Form	$16.28

TOTAL	$21.71



Costs in Worksheet 2 were averaged over the 3-year period (2011-2013) 

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, and the ten Regional Offices. 
The in-house activities for this collection are completed by a variety
of individuals with a variety of salaries; therefore, we used EPA
payroll averages (one estimate for EPA Regions and one estimate for
OAQPS) as an average for computing the program costs.  We estimated a
total of 40 hours ($5,770) total agency annual 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 211 respondents. 
The total labor burden for the respondents was estimated to be 70.3
hours ($4,582).

Worksheet 3:  Annual Total Respondent Labor Burden/Cost Estimates

Collection

 Activities	Total Labor Hours

Per Year	Total Labor Cost

Per Year

1.  Read Instructions	17.6	$1145

2.  Complete Form	52.7	$3437

TOTAL	70.3	$4582



6(e)  Bottom Line Burden Hours and Cost Tables

 (i)  Respondent Tally 

Respondent Total Annual Burden = 70 hours

Respondent Total Annual Labor Cost = $4582

(ii) The Agency Tally		

Agency Total Annual Burden = 40 hours

Agency Total Annual Cost = $5770

(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

EPA is proposing to require monitoring organization to submit
information to EPA on a annual basis on the specialty gas vendors they
use in order to ensure specialty gas producer participation in the
Ambient Air Protocol Gas Verification Program.  

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 20 minutes per response.  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 and verifying information, processing and
maintaining information, and disclosing and providing information;
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. EPA-HQ-OAR-2010-0050 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 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 and Radiation Docket and Information Center
Docket is (202) 566-1742.  An electronic version of the public docket is
available at 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 can send
comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, D.C. 20503,
Attention: Desk Officer for EPA.  Please include the EPA Docket ID
Number EPA-HQ-OAR-2010-0050 and OMB Control Number 2060-NEW 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.

	

		

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