ATTACHMENT
A
Federal
Register
Notice,
August
__,
2004
Notice
of
Intent
to
Submit
this
Continuing
Information
Collection
Request
to
OMB
for
Review
and
Approval
Solicitation
of
Comments
Insert
copy
of
First
Federal
Register
Notice
after
publication.
ATTACHMENT
B
1
List
of
Respondents
to
EPA's
December
13,
1996
Proposed
Part
53
Regulations,
Revised
Requirements
for
Designation
of
Reference
and
Equivalent
Methods
for
PM
2.5,
Docket
A­
96­
51.

2
Standing
Air
Monitoring
Work
Group
(
SAMWG)
(
Non­
EPA
Personnel)

3
Recent
consultations
with
potential
submitters
B­
1
Attachment
B
Commenters
responding
to
EPA's
December
13,
1996
Proposed
Part
53
Regulations,
Revised
Requirements
for
Designation
of
Reference
and
Equivalent
Methods
for
PM
2.5,
Docket
A­
96­
51.
Final
rules
were
promulgated
July
18,
1997.

Docket
ID
Name
Organization
IV­
D­
177
Unknown
Ventura
County
Air
Pollution
Control
District
IV­
D­
218
O'Connor,
M.
Indiana
Department
of
Environmental
Management
IV­
D­
220
Unknown
State
of
Alaska
IV­
D­
222
Unknown
Cal/
EPA
IV­
D­
228
Meyer,
M.
B.
Rupprecht
and
Patashnick
Company
NA*
Lundgren,
D.
A.
Academia
but
commenting
on
behalf
of
National
Mining
Association
NA*
DiBattista,
C.
State
of
Connecticut,
Department
of
Environmental
Protection
*
No
Number
Assigned
B­
2
Attachment
B
Standing
Air
Monitoring
Work
Group
(
SAMWG)
(
Non­
EPA
Personnel)

Mr.
Gustave
Von
Bodungen
LA
Dept.
of
Environmental
Quality
7290
Bluebonnet
Baton
Rouge,
LA
70810
504­
765­
0102
Mr.
Miquel
Flores,
Chief
Monitoring
&
Data
Analysis
Branch
National
Park
Service
­
Air
12795
West
Alameda
Parkway
Lakewood,
CO
80228
303­
969­
2072
Mr.
Douglas
L.
Tubbs
Ventura
Co.
APCD
669
County
Square
Drive
Ventura,
CA
93003
805­
662­
6950
Mr.
Jeff
Cook
California
Air
Resources
Board
2020
L
Street
Sacramento,
CA
95814
916­
322­
3726
Mr.
Robert
Ostrowski
Air
Management
Services
500
South
Broad
Street
Philadelphia,
PA
19146
215­
823­
7584
Mr.
Charles
Pietarinen,
Chief
Bureau
of
Air
Monitoring
NJ
Dept.
of
Environmental
Protection
401
East
State
Street,
CN027
Trenton,
NJ
08625
609­
633­
7648
Mr.
Ray
Bishop
Tulsa
City­
County
Health
Dept.
4616
East
15th
Street
Tulsa,
OK
74112­
6199
405­
290­
8247­
I26
Mr.
Robert
Hannah
Dept.
of
Environmental
Quality
Office
of
Air
Quality
&
Rad.
Protection
7290
Bluebonnet
Baton
Rouge,
LA
70810
504­
765­
0108
Mr.
Larry
Byrum
Div.
of
Environmental
Quality
4545
N.
Lincoln
Blvd.,
Suite
250
Oklahoma
City,
OK
73105­
3483
405­
290­
8247
Ms.
Susan
S.
G.
Wierman
Executive
Director,
MARAMA
711
West
40th
Street,
Suite
318
Baltimore,
MD
21211
410­
467­
0170
Mr.
Doyle
Pendleton
Texas
Natural
Resources
Commission
Monitoring
Operations/
MC165
PO
Box
13087
Austin,
TX
78711­
3087
512­
239­
1600
Mr.
Harry
St.
Clair
Air
Quality
Programs
Hamilton
Co.
Dept.
of
Env.
Services
1632
Central
Parkway,
Room
201
Cincinnati,
OH
45210­
1604
513­
333­
4733
Lee
Alter
NESCAUM
129
Portland
Street,
Suite
105
Boston,
MA
02114
617­
367­
8540
Mr.
Mike
Gilroy
Puget
Sound
Air
Pollution
Control
Agency
110
Union
Street,
Suite
500
Seattle,
WA
98101­
2038
206­
689­
4001
Mr.
Brian
Jennison
Director,
Air
Quality
Division
Washoe
Co.
Dist.
Health
Dept.
PO
Box
11130
Reno,
NV
89520­
0027
702­
784­
7200
B­
3
Attachment
B
Recent
consultations
with
potential
application
submitters.

Larry
Hackworth,
Zedek
Ckorporation,
Durham,
NC
919­
489­
7206
Bill
Roe,
Grimm
Technologies,
Inc.,
Douglasville,
GA
770­
577­
0853
Tom
Merrifield,
BGI
Incorporated,
Waltham,
MA
781­
891­
9380
David
Gobeli,
MetOne
Instruments,
Grants
Pass,
OR
909­
371­
7877
Kevin
J.
Goohs,
Thermo
Environmental
Corp.,
Franklin,
MA
508­
553­
6808
Edward
Hoopes,
Advanced
Pollution
Instrumentation,
San
Diego,
CA
858­
657­
9800
Gerald
McGowan,
Teledyne
Monitor
Labs,
Englewood,
CO
303­
792­
4367
Peter
Phaedonos,
Ecotech
Pty.
Ltd.,
Blackburn,
Victoria,
Australia
(
613)
9894
2399
ATTACHMENT
C
1
Sample
Survey
Questionnaire
2
List
of
Vendors
Surveyed
(
Please
Note:
Further
details
on
respondents
and
their
actual
survey
responses
are
considered
confidential
and
are
not
included
here.)
Page
3
of
3
Instructions
for
Section
II
General
Instructions:
Make
copies
of
the
annual
burden
estimate
worksheet
as
needed.
A
separate
sheet
should
be
filled
out
for
each
type
of
instrument
(
including
requests
for
modifications
to
existing
methods).
If
you
have
questions
you
may
call
Jeff
Harris
at
(
919)
419­
7567,
Walid
Ramadan
at
(
919)
419­
7534,
or
Stan
Sleva
at
(
919)
419­
7563.

Part
A:
Applicable
Method
Please
mark
the
appropriate
boxes
to
indicate
which
type
of
method
the
sheet
represents.
Also
mark
a
box
to
indicate
whether
the
sheet
represents
a
new
instrument
or
a
modification
of
an
existing
instrument.

Part
B:
Labor
Rates
Please
enter
the
fully
loaded
labor
rate
for
each
category
of
employee.
Note
that
"
fully
loaded"
includes
salary,
overhead,
fringe
benefits,
health
care
costs,
and
any
other
costs
directly
related
to
a
given
employee.
The
information
should
reflect
typical
rates;
exact
numbers
are
not
necessary.

Part
C:
Annual
Activity
Burden
Estimates
Fill
in
boxes
to
indicate
the
annual
burden
for
each
activity.
Labor
hours
should
be
broken
down
into
three
categories:
Management,
Professional/
Technical,
and
Clerical.
Space
is
also
provided
for
noting
costs
in
dollars
for
services
provided
by
outside
contractors
(
i.
e.,
laboratories
or
other
firms
performing
tests
for
which
you
are
not
equipped.)
The
columns
titled
"
O&
M"
and
"
Capital/
Startup"
should
be
used
to
record
any
in­
house
non­
labor
costs
associated
with
a
given
activity
(
i.
e.,
gas
standards,
equipment
purchases,
etc.)
O&
M
costs
are
ongoing
costs
(
i.
e.,
annual
calibration
or
certification
of
test
instruments
or
regular
purchases
of
supplies).
Capital/
Startup
costs
are
one­
time
costs
which
do
not
recur
regularly
(
i.
e.,
purchasing
test
instruments).
If
such
equipment
is
used
for
testing
multiple
instruments,
the
total
cost
should
be
distributed
across
the
instruments.
Startup
costs
for
ISO
9001
registration
should
be
distributed
similarly.
Please
make
notes
on
a
separate
sheet
of
paper
to
more
fully
describe
Contractor,
O&
M,
and
Capital/
Startup
costs.
Attachment
C
List
of
Vendors
Surveyed
Mr.
Rick
Panorese
Thermo
Environmental
Instruments,
Inc.
8
West
Forge
Parkway
Franklin,
MA
02038
508­
520­
0430
Dr.
Dominique
Thomas
Groupe
Environment
S.
A.
111,
bd
Robespierre
78300
Poissy­
France
33(
1)
39.22.38.00
Mr.
David
Gobeli
Horiba
Instruments,
Inc.
17671
Armstrong
Avenue
Irvine,
CA
92714
714­
250­
4811
Mr.
Paul
Stenberg
OPSIS,
Inc.
1165
Linda
Vista
Drive,
Suite
112
San
Marcos,
CA
92069
203­
698­
1810
Mr.
Bob
Gussman
BGI,
Inc.
58
Guinan
Street
Waltham,
MA
02154
617­
891­
9380
Mr.
Jon
Stone
University
Research
Glass
Corporation
116
South
Merritt
Mill
Road
Chapel
Hill,
NC
27516
919­
942­
2753
Mr.
Wes
Davis
Graseby
Anderson
500
Technology
Court
Smyrna,
GA
30082­
5211
770­
319­
9999
Ms.
Mary
Peterson
Rupprecht
&
Patashnick
Co.,
Inc.
25
Corporate
Circle
Albany,
NY
12203
518­
452­
0065
Mr.
James
Byrne
Advanced
Pollution
Instrumentation,
Inc.
6565
Nancy
Ridge
Drive
San
Diego,
CA
92121­
2251
619­
578­
2154
ATTACHMENT
D
Assumptions
and
Notes
Related
to
the
Determination
of
Burden
and
Cost
Estimates
D­
1
Assumptions
and
Notes:
Determination
of
Burden
Hours
and
Cost
Estimates
for
Applications
for
Reference
and
Equivalent
Methods
Representative
burden
hours
and
cost
estimates
were
prepared
for
five
categories
of
applications:
Gas
Analyzers,
Open
Path
Analyzers,
PM
10
Monitors,
PM
2.5
Reference
and
Class
I
Equivalent
Samplers,
and
PM
2.5
Class
II
Equivalent
Samplers.
These
average
category
estimates
are
included
in
the
tables
presented
in
Attachment
E
to
the
supporting
statement
and
were
derived
as
described
below.

1)
Gas
Analyzers:
These
numbers
represent
mean
values
received
from
survey
respondents
for
gas
analyzer
designation
application
burden
and
costs.

2)
Open
Path
Analyzers:
No
useful
cost
figures
for
open
path
analyzers
were
received
from
survey
respondents.
It
was
assumed
that
the
cost
for
preparing
an
open
path
analyzer
designation
application
is
roughly
three
times
that
for
a
standard
gas
analyzer.
However,
a
typical
open
path
analyzer
would
likely
be
submitted
for
designation
for
three
or
more
pollutants
at
little
additional
cost
per
pollutant.
Consequently,
the
cost
per
designation
application
for
open
path
analyzers
was
assumed
to
be
the
same
as
that
for
a
typical
gas
analyzer.

3)
PM
10
Monitors:
These
numbers
represent
mean
values
received
from
survey
respondents
for
PM
10
monitor
designation
application
costs
and
include
both
PM
10
samplers
and
analyzers.

4)
PM
2.5
Reference
and
Class
I
Equivalent
Samplers:
These
numbers
represent
mean
values
received
from
survey
respondents
for
PM
2.5
Reference
and
Class
I
Equivalent
Method
Sampler
designation
application
costs.

5)
PM
2.5
Class
II
Equivalent
Samplers:
No
useful
cost
figures
for
PM
2.5
Class
II
Equivalent
Samplers
were
received
from
survey
respondents.
It
was
estimated
that
the
costs
for
PM
2.5
Class
II
Equivalent
samplers
are
approximately
1.35
times
higher
than
for
Reference/
Class
I
samplers.

Weighted
average,
composite
burden
and
cost
estimates
for
a
typical
designation
application
were
developed
by
summing
up
the
estimates
for
all
the
different
analyzer
categories,
after
multiplying
each
by
a
factor
based
on
the
expected
fraction
of
total
applications
expected
over
the
next
3
years
for
each
analyzer
category.
The
fractions
used
for
this
purpose
are
as
follows:

20%
Gas
Analyzers
5%
Open
Path
Analyzers
30%
PM
10
Monitors
40%
PM
2.5
Reference/
Class
I
Equivalent
Samplers
5%
PM
2.5
Class
II
Equivalent
Samplers
6)
ISO
9001:
No
useful
cost
figures
were
received
from
respondents.
Instead,
data
provided
to
EPA
by
four
ISO­
9001
consultants
were
reviewed
and
used
to
develop
ISO
9001
cost
estimates
as
detailed
below:
D­
2
Contractor

s
Startup
Cost
for
Establishing
ISO
9001
includes
(
1)
a
pre­
assessment
meeting;
(
2)
preliminary
evaluations;
(
3)
registration
assessment;
(
4)
PM
2.5
checklist
including
evaluation
and
registration;
and
(
5)
training
costs.
These
costs
are
one­
time
fees
and
can
range
from
a
combined
total
of
$
15,250
to
$
34,500
depending
on
the
size
of
the
facility.
The
average
cost
is
therefore
about
$
24,900.
Annualizing
this
cost
over
a
three­
year
period
results
in
approximately
$
8,300
per
year.
Assuming
that
40
percent
of
the
companies
already
have
ISO
9001
programs
in
place,
the
annual
cost
is
$
4,980.
Assuming
further
that
these
costs
will
be
incurred
only
by
companies
applying
for
PM
2.5
methods
results
in
an
annual
cost
of
approximately
$
2,241.

Contractor

s
ISO
9001
Maintenance
Cost
includes
(
1)
continuous
assessment;
(
2)
ISO
file
maintenance
fee;
and
(
3)
continuous
checks
for
PM
2.5
checklist.
These
costs
are
annual
fees
and
can
range
from
a
combined
total
of
$
2,375
to
$
6,875
depending
on
the
size
of
the
facility.
The
average
cost
is
therefore
$
4,625
per
year.
Assuming
that
these
costs
will
be
incurred
only
by
companies
applying
for
PM
2.5
methods
results
in
an
annual
cost
of
approximately
$
2,081.

In­
House
Startup
Cost
for
Establishing
ISO
9001
includes
labor
cost
for
management,
technical/
professional,
and
clerical
staff.

a)
Management
Startup
Cost
for
Establishing
ISO
9001:
Management
labor
hours
range
from
32
hours
per
year
to
120
hours
per
year
depending
on
the
size
of
the
facility.
These
hours
are
used
for
management
reviews.
The
average
management
labor
hours
is
therefore
76
hours
per
year.
Assuming
that
40
percent
of
the
companies
already
have
ISO
9001
programs
in
place,
the
annual
burden
is
45.6
hours,
and
assuming
further
that
these
hours
will
be
incurred
only
by
companies
applying
for
PM
2.5
methods
results
in
an
annual
burden
of
20.5
hours.

b)
Technical/
Professional
Startup
Cost
for
Establishing
ISO
9001:
Technical/
professional
labor
hours
include
training
internal
ISO
coordinators
and
auditors.
It
is
assumed
that
2
to
5
technical/
professional
staff
are
involved
at
24
to
40
hours
per
staff,
resulting
in
48
to
200
hours
depending
on
the
size
of
the
facility.
The
average
technical/
professional
labor
hours
are
therefore
124
hours
per
year.
Annualizing
this
cost
over
a
three­
year
period
results
in
approximately
42
hours
per
year.
Assuming
that
40
percent
of
the
companies
already
have
ISO
9001
programs
in
place,
gives
a
burden
of
25.2
hours
per
year,
and
assuming
further
that
these
hours
will
be
incurred
only
by
companies
applying
for
PM
2.5
methods
results
in
an
annual
burden
of
11.3
hours.

c)
Clerical
Startup
Cost
for
Establishing
ISO
9001:
None
identified
In­
House
Maintenance
Cost
for
Establishing
ISO
9001
includes
labor
cost
for
management,
technical,
and
clerical
staff.

a)
Management
ISO
9001
Maintenance
Cost:
Management
labor
hours
range
from
32
hours
per
year
to
120
hours
per
year
depending
on
the
size
of
the
facility.
These
hours
are
used
for
management
reviews.
The
average
management
labor
hours
is
therefore
76
hours
per
year.
Assuming
that
these
hours
will
be
incurred
only
by
companies
applying
for
PM
2.5
methods
results
in
an
annual
burden
of
34.2
hours.

b)
Technical/
Professional
ISO
Maintenance
Cost:
Technical/
professional
labor
hours
include
reviewing,
recommending
revisions,
and
approving
internal
audits.
It
is
assumed
that
2
to
20
technical/
professional
staff
are
involved
at
16
to
24
hours
per
staff,
resulting
in
32
to
480
hours
per
year
depending
on
the
size
of
the
facility.
The
average
technical/
professional
labor
hours
is
therefore
256
hours
per
year.
Assuming
that
these
hours
will
be
incurred
only
by
companies
applying
for
PM
2.5
methods
results
in
an
annual
burden
of
115.2
hours.
D­
3
c)
Clerical
ISO
Maintenance
Cost:
Clerical
labor
hours
include
drafting
new
or
revising
existing
SOPs,
and
training
SOP
writers.
It
is
assumed
that
48
to
675
clerical
hours
are
needed
for
these
tasks
depending
on
the
size
of
the
facility.
The
average
clerical
labor
hours
is
therefore
362
hours
per
year.
Assuming
that
these
hours
will
be
incurred
only
by
companies
applying
for
PM
2.5
methods
results
in
an
annual
burden
of
162.9
hours.
ATTACHMENT
E
1
Supplementary
Tables
of
Burden
and
Cost
Estimates
for
the
Application
Categories
2
Burden
Calculations
for
OMB
Form
83­
I
E­
1
to
E­
6
Insert
Tables
E­
1
through
E­
6
from
file
ICR0559­
2004.
xls
ATTACHMENT
F
Copy
of
40
CFR
Part
53
ATTACHMENT
G
Draft
Second
Federal
Register
Notice
Notice
announcing
the
submission
of
the
ICR
to
OMB
and
soliciting
further
comments,
as
required
by
the
PRA
