ICR_Supporting_Statement_-_FINAL_1-22-10_CLEAN

ICR_Supporting_Statement_-_FINAL_1-22-10_CLEAN.doc

Nitrogen Oxides Ambient Air Monitoring (Final Rule)

OMB: 2060-0638

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______________________________________________________________________________

Supporting Statement

Ambient Oxides of Nitrogen Monitoring Regulations:

Revisions to Network Design Requirements

EPA ICR # 2358.02


PART A


1. Identification of the Information Collection


(a) Title of the Information Collection


Ambient Oxides of Nitrogen Monitoring Regulations: Revisions to Network Design Requirements, EPA ICR Number 2358.02, 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 Ambient Air Quality Surveillance regulations. 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 is revising the network design requirements for the oxides of nitrogen (NOX), specifically nitrogen dioxide (NO2), to support the proposed changes to the primary National Ambient Air Quality Standards (NAAQS) for NO2. Presently, States (including the District of Columbia, Puerto Rico, and the Virgin Islands) and local agencies when delegated by the State are required to operate minimum numbers of EPA-approved NO2 monitors based on the population of each of their Core Based Statistical Areas (CBSA) and the traffic related metrics including Annual Average Daily Traffic (AADT) of all the road segments in their CBSAs.


EPA is proposing a two-tiered monitoring network design. The two tiers are designed to: 1) monitor in areas of expected maximum 1-hour concentrations; and 2) monitor to characterize areas with the highest expected NO2 concentrations at the neighborhood and larger spatial scales, or “area-wide” scales. The proposed network design corresponds to the revised NAAQS based on peak 1-hour daily maximum concentrations, or 1-hour NAAQS, with a level of 100 parts per billion (ppb), and the retention of the current annual averaged NAAQS which has a level of 53 ppb. The introduction of the 1-hour NAAQS is intended to protect against peak, shorter term exposure risks. These exposure risks have been found to be of particular interest in the on-road and near-road environments due to on-road mobile source emissions, which led to the proposed minimum monitoring requirements to include near-road monitors to be included in the first tier of the network design.


In the first tier of the NO2 network design, EPA is finalizing minimum NO2 monitoring requirements which call for monitors near major roads, “near-road NO2 monitors,” in certain CBSAs to address on-road mobile source emission derived exposures. Specifically, the minimum monitoring requirements are for one near-road NO2 monitor to be placed in CBSAs of populations greater than or equal to 500,000 persons. A second near-road NO2 monitor is required in CBSAs of populations greater than or equal to 2,500,000 persons, or any CBSA with one or more roadway segments that have 250,000 or greater AADT volumes


The first tier of the proposed NO2 network design is anticipated to require 126 near road monitoring sites, which largely do not exist in the current monitoring network. Therefore, we recognize that there will likely be a need for capital funding to allow most, if not all, of the required near-road monitoring sites to be established. 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.


In the second tier of the monitoring network design, we are requiring a minimum number of monitors to characterize an area or areas within CBSAs with highest expected NO2 concentrations at the neighborhood and larger (area-wide) spatial scales. Specifically, we are proposing to require one area-wide monitoring site in each CBSA with a population greater than or equal to 1,000,000, which shall be sited to represent an area of maximum concentration at the neighborhood or larger spatial scales. This minimum monitoring requirement is expected to trigger 52 monitoring sites in as many CBSAs. Many of these monitors are likely already in place as part of the approximately 400 NO2 monitoring sites that are currently operating across the country that serve multiple monitoring objective aside from NAAQS comparisons, including ambient photochemical pollutant assessment, aiding in ozone forecasting, aiding in PM precursor analysis and PM forecasting, and to characterize point and area sources that may be impacting certain communities. Further, the EPA is allowing any current photochemical assessment monitoring station (PAMS) sites that are situated to address the highest NO2 concentrations in an urban area at neighborhood or urban scales to satisfy this proposed area-wide monitoring requirement. Therefore, this tier of the proposed network design is not anticipated to increase the number of monitoring sites above what is already operating in the current network.


In addition, EPA has also recognized that susceptible and vulnerable populations, which include asthmatics and disproportionately exposed groups (as discussed in sections II.B.4 and II.F.4.d of the preamble to the final rule) are at particular risk of NO2-related health effects. The Administrator is therefore requiring the Regional Administrators, working in collaboration with states, to site 40 monitors in appropriate locations, focusing primarily on protecting susceptible and vulnerable communities. Further, Regional Administrators may also use their discretionary authority to require monitoring above the minimum requirements as necessary to address situations inside or outside of CBSAs in which (1) the required near-road monitors do not represent all locations of expected maximum hourly NO2 concentrations in an area and NO2 concentrations may be approaching or exceeding the NAAQS in that area; (2) areas that are not required to have a monitor in accordance with the monitoring requirements and NO2 concentrations may be approaching or exceeding the NAAQS; or (3) the minimum monitoring requirements for area-wide monitors are not sufficient to meet monitoring objectives.


The total number of monitors being minimally required in this rulemaking is estimated to be 218. EPA and others (e.g., State, local, and Tribal air quality management agencies, environmental groups, academic institutions, and industrial groups) use the data from the monitoring network 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, local, and Tribal 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, local, and Tribal agency, in AQS electronic format where possible.


Although the State, local, and Tribal 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 142 respondents for a total approximate cost of $3,261,007 (total capital, and labor and operation and maintenance) and a total burden of 49,474 hours. The labor costs associated with these hours is $2,737,485. The operations and maintenance costs are $661,960 and equipment and contract costs are $289,002. In addition to the costs at the State, local, and Tribal air quality management agencies, there is a burden to EPA of total of 5,431 hours and $ 390,054.


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, local, and Tribal 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 NO2, 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.A. Sections 7403, 7410, and 7511a, from which the 40 CFR part 58 regulations were promulgated.


Under Section 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.


Section 7511a (c)(1) states that the Administrator will promulgate rules requiring that State, local, and Tribal air quality management agencies conduct enhanced monitoring of ozone and its precursors (oxides of nitrogen and volatile organic compounds) in serious, severe, or extreme ozone nonattainment areas.



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, local, and Tribal 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, local, and Tribal 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. 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, local, and Tribal 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, 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. 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, local, and Tribal 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


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, local, and Tribal 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


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 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 ambient air pollutant concentrations of NO, NO2, and total NOX collected at SLAMS/PAMS and tribal 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, local, and Tribal 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, local, and Tribal 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, 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 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, local, and Tribal 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, local, and Tribal 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, local, and Tribal 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 350,000). 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, local, and Tribal 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 July 1 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 July 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, 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 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

(142 respondents)

1. Network design

4

2. Site installation

3

3. Sampling & analysis

94

4. Maintenance & repairs

67

5. Data management

38

6. Quality assurance

108

7. Supervision

33

TOTAL

347




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

(142 respondents)

1. Network design

$278

2. Site installation

$2180

3. Sampling & analysis

$4874

4. Maintenance & repairs

$4662

5. Data management

$2223

6. Quality assurance

$6776

7. Supervision

$1961

TOTAL

$22,954




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 5,431 hours and $390,054 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 142 respondents. The total labor burden for the respondents was estimated to be 49,474 hours at a total cost of $2,737,485.


Worksheet 3: Annual Total Respondent Labor Burden/Cost Estimates


Collection

Activities

Total Labor Hours

Per Year

Total Labor Cost

Per Year

1. Network design

642

$40,932

2. Site installation

477

$20,540

3. Sampling & analysis

13,340

$587,876

4. Maintenance & repairs

9,560

$531,671

5. Data management

5,447

$315,730

6. Quality assurance

15,339

$962,205

7. Supervision

4,669

$278,532

TOTAL

49,474

$2,737,485



6(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally


Respondent Total Annual Burden = 49,474 hours


Respondent Total Annual Labor Cost = $2,737,485

Respondent Total Annual Cost for O & M = $234,520


Respondent Total Equipment/Contract Dollars = $289,002


Total Respondent Tally = $3,261,007


(ii) The Agency Tally


Agency Total Annual Burden = 5,431 hours


Agency Total Annual Cost = $390,054


(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 revise the network design requirements for NO2 to support changes to the primary national ambient air quality standards (NAAQS) for NO2 that are being proposed. For the purpose of this, ICR we have estimated the maximum potential burden for the options being considered in the proposed rule. The ICR burden estimates are associated with the current NO2 monitoring portion of the approved ICR 2060-0084 – “Ambient Air Quality Surveillance.”


6(g) Burden Statement


The annual public reporting and recordkeeping burden for this collection of information is estimated to average 22 hours 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, 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 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. 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.

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