Burden Calculations Table

1663t11.xlsx

Compliance Assurance Monitoring Program (40 CFR part 64) (Renewal)

Burden Calculations Table

OMB: 2060-0376

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Overview

Summary
Table 6.1a
Table 6.1b
Table 6.1c
Table 6.2a
Table 6.2b
Table 6.2c
Table 6.3
Table 6.4
Table 6.5
Table 6.6
PSEU Counts


Sheet 1: Summary

ICR Summary Information
Hours per Respondent One per PSEU; 36 per PA
Number of Respondents 22,200
Total Estimated Burden Hours 23,500
Total Estimated Costs $2,420,000
Annualized Capital O&M $0
Form Number Not Applicable
Total Number of Responses 9,388

Sheet 2: Table 6.1a

Table 6.1a: Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2023-24
























Burden Item c Hours a and Costs b Per Respondents





(A)
Clerical hours per occurrence
(B)
Technical hours per occurrence
(C)
Management hours per occurrence ([A+B]x0.05)
(D)
Annual occurrences
(E)
Annual person hours ([A+B+C]xD)
(F)
Labor cost/year
(G)
Total number of respondents
(H)
Total hours/year (ExG)
(I)
Total labor cost (FxG)



1. Review Requirements d 5 15 1 1 21 $2,445.92 100 2100 $244,592.00
Labor Rates
2. Determine Monitoring Approach e









Management $163.17
A. Units without existing monitoring 0.75 2.25 0.15 1 3.15 $366.89 74 233.1 $27,149.71
Technical $130.28
B. Units with existing monitoring 0.25 0.75 0.05 1 1.05 $122.30 134 140.7 $16,387.66
Clerical $65.71
3. Specify Monitoring Plan Elements e











A. Units without existing monitoring 4 12 0.8 1 16.8 $1,956.74 74 1243.2 $144,798.46


B. Units with exisiting monitoring 2 6 0.4 1 8.4 $978.37 134 1125.6 $131,101.31


4. Design Documentation e











A. Units without existing monitoring 0 4 0.2 1 4.2 $553.75 74 310.8 $40,977.80


B. Units with exisiting monitoring 0 2 0.1 1 2.1 $276.88 134 281.4 $37,101.52


5. CAM Renewal 1 2 0.15 1 3.15 $350.75 4324 13620.6 $1,516,623.54


6. Prepare QIP 5 20 1.25 1 26.25 $3,138.11 9 229.2 $27,399.49


7. Records of Corrective Actions











A. PSEUs with instrumental systems 0 0.15 0.0075 1 0.1575 $20.77 1 0.2 $23.43


B. PSEUs using work practices 0 0.5 0.025 1 0.525 $69.22 8 4.0 $526.26


8. Reporting of Corrective Actions 0 0.5 0.025 2 1.05 $138.44 9 9.45 $1,245.95


9. Facility Certification f 0.7 0 0.035 1 0.735 $51.71 0 0 $0.00


Total Labor Burden and Costs (rounded) g
19,300 $2,190,000


Total Capital and O&M Cost (rounded) g
$0


GRAND TOTAL (rounded) g
$2,190,000















Assumptions:


a All hours are per PSEU unless otherwise noted.


b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.


c See section 4(b)(ii) for a description of these activities.


d Hours are per facility, not per PSEU; number of respondents are facilities, not PSEUs.


e One-time activity.


f 3 hours per facility converted to impact per PSEU by dividing by the average number of PSEUs per facility with at least one PSEU (4.27).


g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 3: Table 6.1b

Table 6.1b: Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2024-25
























Burden Item c Hours a and Costs b Per Respondents





(A)
Clerical hours per occurrence
(B)
Technical hours per occurrence
(C)
Management hours per occurrence ([A+B]x0.05)
(D)
Annual occurrences
(E)
Annual person hours ([A+B+C]xD)
(F)
Labor cost/year
(G)
Total number of respondents
(H)
Total hours/year (ExG)
(I)
Total labor cost (FxG)



1. Review Requirements d 5 15 1 1 21 $2,445.92 100 2100 $244,592.00
Labor Rates
2. Determine Monitoring Approach e









Management $163.17
A. Units without existing monitoring 0.75 2.25 0.15 1 3.15 $366.89 74 233.1 $27,149.71
Technical $130.28
B. Units with existing monitoring 0.25 0.75 0.05 1 1.05 $122.30 134 140.7 $16,387.66
Clerical $65.71
3. Specify Monitoring Plan Elements e











A. Units without existing monitoring 4 12 0.8 1 16.8 $1,956.74 74 1243.2 $144,798.46


B. Units with exisiting monitoring 2 6 0.4 1 8.4 $978.37 134 1125.6 $131,101.31


4. Design Documentation e











A. Units without existing monitoring 0 4 0.2 1 4.2 $553.75 74 310.8 $40,977.80


B. Units with exisiting monitoring 0 2 0.1 1 2.1 $276.88 134 281.4 $37,101.52


5. CAM Renewal 1 2 0.15 1 3.15 $350.75 4324 13620.6 $1,516,623.54


6. Prepare QIP 5 20 1.25 1 26.25 $3,138.11 9 231.378 $27,660.58


7. Records of Corrective Actions











A. PSEUs with instrumental systems 0 0.15 0.0075 1 0.1575 $20.77 1 0.179865 $23.71


B. PSEUs using work practices 0 0.5 0.025 1 0.525 $69.22 8 4.02801 $531.08


8. Reporting of Corrective Actions 0 0.5 0.025 2 1.05 $138.44 9 9.45 $1,245.95


9. Facility Certification f 0.7 0 0.035 1 0.735 $51.71 0 0 $0.00


Total Labor Burden and Costs (rounded) g
19,300 $2,190,000


Total Capital and O&M Cost (rounded) g
$0


GRAND TOTAL (rounded) g
$2,190,000















Assumptions:











a All hours are per PSEU unless otherwise noted.



b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.


c See section 4(b)(ii) for a description of these activities.



d Hours are per facility, not per PSEU; number of respondents are facilities, not PSEUs



e One-time activity.



f 3 hours per facility converted to impact per PSEU by dividing by the average number of PSEUs per facility with at least one PSEU (4.27).



g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.




Sheet 4: Table 6.1c

Table 6.1c: Total Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2025-26
























Burden Item c Hours a and Costs b Per Respondents





(A)
Clerical hours per occurrence
(B)
Technical hours per occurrence
(C)
Management hours per occurrence ([A+B]x0.05)
(D)
Annual occurrences
(E)
Annual person hours ([A+B+C]xD)
(F)
Labor cost/year
(G)
Total number of respondents
(H)
Total hours/year (ExG)
(I)
Total labor cost (FxG)



1. Review Requirements d 5 15 1 1 21 $2,445.92 100 2100 $244,592.00
Labor Rates
2. Determine Monitoring Approach e









Management $163.17
A. Units without existing monitoring 0.75 2.25 0.15 1 3.15 $366.89 74 233.1 $27,149.71
Technical $130.28
B. Units with existing monitoring 0.25 0.75 0.05 1 1.05 $122.30 134 140.7 $16,387.66
Clerical $65.71
3. Specify Monitoring Plan Elements e











A. Units without existing monitoring 4 12 0.8 1 16.8 $1,956.74 74 1243.2 $144,798.46


B. Units with exisiting monitoring 2 6 0.4 1 8.4 $978.37 134 1125.6 $131,101.31


4. Design Documentation e











A. Units without existing monitoring 0 4 0.2 1 4.2 $553.75 74 310.8 $40,977.80


B. Units with exisiting monitoring 0 2 0.1 1 2.1 $276.88 134 281.4 $37,101.52


5. CAM Renewal 1 2 0.15 1 3.15 $350.75 4324 13620.6 $1,516,623.54


6. Prepare QIP 5 20 1.25 1 26.25 $3,138.11 9 233.562 $27,921.67


7. Records of Corrective Actions











A. PSEUs with instrumental systems 0 0.15 0.0075 1 0.1575 $20.77 1 0.182007 $24.00


B. PSEUs using work practices 0 0.5 0.025 1 0.525 $69.22 8 4.06455 $535.90


8. Reporting of Corrective Actions 0 0.5 0.025 2 1.05 $138.44 9 9.45 $1,245.95


9. Facility Certification f 0.7 0 0.035 1 0.735 $51.71 0 0 $0.00


Total Labor Burden and Costs (rounded) g
19,300 $2,190,000


Total Capital and O&M Cost (rounded) g
$0


GRAND TOTAL (rounded) g
$2,190,000















Assumptions:











a All hours are per PSEU unless otherwise noted.



b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.


c See section 4(b)(ii) for a description of these activities.



d Hours are per facility, not per PSEU; number of respondents are facilities, not PSEUs



e One-time activity.



f 3 hours per facility converted to impact per PSEU by dividing by the average number of PSEUs per facility with at least one PSEU (4.27).



g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.




Sheet 5: Table 6.2a

Table 6.2a: Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2023-24
















Burden item a (A)
Technical hours per occurrence b
(B)
Occurrences per year
(C)
Technical hours per year (AxB)
(D)
Management hours per year (Cx0.05)
(E)
Total cost per year c



1. CAM Activities





Labor Rates
A. Rule familiarization d 12 117 1404 70.2 $81,688.93
Management $73.46
B. Determine applicability 0.67 208 139.36 6.968 $8,108.38
Technical $54.51
2. Initial CAM Review







A. Units without existing monitoring 2 74 148 7.4 $8,611.08


B. Units with existing monitoring 1 134 134 6.7 $7,796.52


3. Evaluate CAM Renewals 0.5 4324 2162 108.1 $125,791.65


4. Review QIPs 1 9 9 0.44 $508.01


5. Review Reports of Corrective Actions 0.5 18 9 0.45 $523.65


6. Review Annual Facility Certifications 0.33 0 0 0 $0.00


TOTAL (rounded) e
4,010 200 $233,000






Assumptions:


a See section 4(b)(ii) for a description of these activities.


b All hours are per PSEU unless otherwise noted.


c The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%) and Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.


d Burden for Rule Familiarization is per Permitting Authority (PA), of which there are 117. Because this is a mature program, PAs are generally familiar with the CAM Rule, but we include 12 hours/year per PA for new staff to become familiar with the rule.


e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 6: Table 6.2b

Table 6.2b: Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2024-25
















Burden item a (A)
Technical hours per occurrence b
(B)
Occurrences per year
(C)
Technical hours per year (AxB)
(D)
Management hours per year (Cx0.05)
(E)
Total cost per year c



1. CAM Activities





Labor Rates
A. Rule familiarization d 12 117 1404 70.2 $81,688.93
Management $73.46
B. Determine applicability 0.67 208 139.36 6.968 $8,108.38
Technical $54.51
2. Initial CAM Review







A. Units without existing monitoring 2 74 148 7.4 $8,611.08


B. Units with existing monitoring 1 134 134 6.7 $7,796.52


3. Evaluate CAM Renewals 0.5 4324 2162 108.1 $125,791.65


4. Review QIPs 1 9 9 0.44 $512.85


5. Review Reports of Corrective Actions 0.5 18 9 0.45 $523.65


6. Review Annual Facility Certifications 0.33 0 0 0 $0.00


TOTAL (rounded) h
4,010 200 $233,000






Assumptions:


a See section 4(b)(ii) for a description of these activities.


b All hours are per PSEU unless otherwise noted.


c The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%) and Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.


d Burden for Rule Familiarization is per Permitting Authority (PA), of which there are 117. Because this is a mature program, PAs are generally familiar with the CAM Rule, but we include 12 hours/year per PA for new staff to become familiar with the rule.


e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 7: Table 6.2c

Table 6.2c: Total Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants, 2025-26
















Burden item a (A)
Technical hours per occurrence b
(B)
Occurrences per year
(C)
Technical hours per year (AxB)
(D)
Management hours per year (Cx0.05)
(E)
Total cost per year c



1. CAM Activities





Labor Rates
A. Rule familiarization d 12 117 1404 70.2 $81,688.93
Management $73.46
B. Determine applicability 0.67 208 139.36 6.968 $8,108.38
Technical $54.51
2. Initial CAM Review







A. Units without existing monitoring 2 74 148 7.4 $8,611.08


B. Units with existing monitoring 1 134 134 6.7 $7,796.52


3. Evaluate CAM Renewals 0.5 4324 2162 108.1 $125,791.65


4. Review QIPs 1 9 9 0.44 $517.69


5. Review Reports of Corrective Actions 0.5 18 9 0.45 $523.65


6. Review Annual Facility Certifications 0.33 0 0 0 $0.00


TOTAL (rounded) h
4,010 200 $233,000






Assumptions:


a See section 4(b)(ii) for a description of these activities.


b All hours are per PSEU unless otherwise noted.


c The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%) and Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.


d Burden for Rule Familiarization is per Permitting Authority (PA), of which there are 117. Because this is a mature program, PAs are generally familiar with the CAM Rule, but we include 12 hours/year per PA for new staff to become familiar with the rule.


e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 8: Table 6.3

Table 6.2c: Federal Labor Hours and Costs for All "Large" and "Other" Sources - All Pollutants, 2024-26










CAM Activities Annual Burden Three Year Total
Labor Rates

Technical Hours Management Hours Total Hours Annual Cost b Technical Hours Management Hours Total Hours Annual Cost
Management $73.46
Rule Familiarzation a 114 6 120 $6,633 342 17 359 $19,899
Technical $54.51
Review CAM Plans a 1786 94 1880 $104,260 5358 282 5640 $312,780


Total Cost and Burden (rounded) c 1900 100 2000 $111,000 5700 299 6000 $333,000














a We assumed 0.1 FTEs, or 200 hours per region per year; 200 hours/region * 10 regions = 2,000 hours/yr. We assumed the majority of the time is spent reviewing CAM plans; some time was allocated to Rule familiarization for new staff.


b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%) and Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.


c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 9: Table 6.4

Table 6.4: Average Source Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants








Year Annual Total Hours Annual Labor Cost Annual Capital & O&M Cost Total Annual Cost
2023 - 24 19,300 $2,190,000 $0 $2,190,000
2024 - 25 19,300 $2,190,000 $0 $2,190,000
2025 - 26 19,300 $2,190,000 $0 $2,190,000





Total 57,900 $6,570,000 $0 $6,570,000
Average 19,300 $2,190,000 $0 $2,190,000










Year # PSEUs Subject to CAM Annual Total Hours Hours per PSEU Hours per Facility a
2023 - 24 21,828 19,300 1 4
2024 - 25 22,036 19,300 1 4
2025 - 26 22,244 19,300 1 4





Total 66,108 57,900 3 11
Average 22,036 19,300 1 4





a Assumes 4.27 PSEUs per facility




Sheet 10: Table 6.5

Table 6.5: Average Permitting Authority Burden and Labor Costs for All "Large" and "Other" Sources - All Pollutants




Year Annual Total Hours Total Annual Cost
2023 - 24 4,210 $233,000
2024 - 25 4,210 $233,000
2025 - 26 4,210 $233,000



Total 12,631 $699,000
Average 4,210 $233,000




Sheet 11: Table 6.6

Table 6.6: Total Estimated Respondent Burden and Cost Summary














Type of respondent Average annual number of respondents Average annual labor hours Average annual labor cost Average annual capital and O&M cost Average total annual cost Average annual labor hours per respondent Average annual cost per respondent
Sources a 22,036 19,300 $2,190,000 $0 $2,190,000 1 $99
PAs 117 4,210 $233,000 $0 $233,000 36 $1,991
Total (rounded) b 22,200 23,500 $2,420,000 $0 $2,420,000









a For sources, the number of respondents is the number of PSEUs subject to the CAM Rule. There are an average of 4.27 affected PSEUs per facility with at least one PSEU.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.







Sheet 12: PSEU Counts

Assumptions





























(1) Initial CAM implementation is complete - all existing PSEUs at existing facilities came into the program during a title V permit renewal prior to this ICR. All these PSEUs previously submitted CAM plans and have implemented monitoring. Thus, the only PSEUs now entering the CAM program are new PSEUs at new facilities and new PSEUs constructed at existing facilities.






















(2) Ongoing recordkeeping and reporting for CAM are required under title V and impose no burden attributable to the CAM program.






















(3) Quality Improvement plans (QIPs) are required for 0.04% of all PSEUs each year, along with associated recordkeeping and reporting.




















































































Industry Labor Rates (2022$) (i)

Permitting Authority Labor Rates (2023$) (ii)


























Clerical $65.71
Technical $54.51

























Technical $130.28
Management $73.46

























Management $163.17



























































(i) This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.





















































(ii) The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%) and Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.





















































100 new facilities get title V permits each year nationwide - 50 per 6-month period




























































230 existing facilities add new PSEUs each year nationwide - 115 per 6-month period




























































Existing PSEUs in the CAM program nationwide, calculated based on the number of applicable title V permits in Year 2 of the ICR for part 70 (2019):





























Applicable permits = 14301




























Large PSEUs = 2787 See footnote b for the factors used to derive the number of existing affected Large and Other PSEUs from the number of title V permits.



























Other PSEUs = 18833




























Total = 21620
1.51178239283966 affected PSEUs per title V permit (including GHG-only title V permits)

4.27 affected PSEUs per facility with at least one PSEU (derived from 2008 RIA data)





















Numbers of Facilities & PSEUs






























Date Nationwide New Permits Issued OR Permits Revised to Add PSEUs Monitoring Approach Submission -
new PSEUs
Review Requirements -
new facilities
Determine Approach -
new PSEUsd

Justification - new PSEUse


Specify Monitoring Elements - new PSEUse


Perform Monitoring - cumulative existing and new PSEUsf










Renewals - existing PSEUs QIPs



# Title V Permitsa # PSEUsb # Facilitiesc # PSEUs w/o ex mon # PSEUs w/ex mon # PSEUs w/o ex mon
# PSEUs w/ex mon
# PSEUs w/o ex mon
# PSEUs w/ex mon
# PSEUsg Acceptable Systemsh Upgrade Instr. Systemsh Install Parameter Monitorh



Install CEM/COMh Acceptable Systemsi Upgrade WPi Initiate WPi # PSEUsj # PSEUs for which QIP Preparedk Records - Instr. Systemsl Records - WPsl







Non-CEM/COM response CEM/COM response Non-CEM/COM response CEM/COM response Non-CEM/COM response CEM/COM response Non-CEM/COM response CEM/COM response


CO NOx PM SO2 VOC







Large PSEUs Jan-24 50 10 50 6 4 6 0 4 0 6 0 4 0











279


at new facilities Jul-24 50 10 50 6 4 6 0 4 0 6 0 4 0 2807 253 974 684.908 0 432.278 126.315 336.84 0


279 1.1228 1.1228

Jan-25 50 10 50 6 4 6 0 4 0 6 0 4 0











279



Jul-25 50 10 50 6 4 6 0 4 0 6 0 4 0 2827 254 981 689.788 0 435.358 127.215 339.24 0


279 1.1308 1.1308

Jan-26 50 10 50 6 4 6 0 4 0 6 0 4 0











279



Jul-26 50 10 50 6 4 6 0 4 0 6 0 4 0 2847 256 988 694.668 0 438.438 128.115 341.64 0


279 1.1388 1.1388































Large PSEUs added Jan-24 115 7 0 4 3 4 0 3 0 4 0 3 0















at exitisting facilities Jul-24 115 7 0 4 3 4 0 3 0 4 0 3 0 14 1 5 3.416 0 2.156 0.63 1.68 0



0.0056 0.0056

Jan-25 115 7 0 4 3 4 0 3 0 4 0 3 0
















Jul-25 115 7 0 4 3 4 0 3 0 4 0 3 0 28 3 10 6.832 0 4.312 1.26 3.36 0



0.0112 0.0112

Jan-26 115 7 0 4 3 4 0 3 0 4 0 3 0
















Jul-26 115 7 0 4 3 4 0 3 0 4 0 3 0 42 4 15 10.248 0 6.468 1.89 5.04 0



0.0168 0.0168































Other PSEUs Jan-24 50 66 0 20 46 20 0 46 0 20 0 46 0











1883


at new facilities Jul-24 50 66 0 20 46 20 0 46 0 20 0 46 0 18965







4134 8951 5879 1883 7.586
7.586

Jan-25 50 66 0 20 46 20 0 46 0 20 0 46 0











1883



Jul-25 50 66 0 20 46 20 0 46 0 20 0 46 0 19097







4163 9014 5920 1883 7.6388
7.6388

Jan-26 50 66 0 20 46 20 0 46 0 20 0 46 0











1883



Jul-26 50 66 0 20 46 20 0 46 0 20 0 46 0 19229







4192 9076 5961 1883 7.6916
7.6916































Other PSEUs added Jan-24 115 21 0 7 14 7 0 14 0 7 0 14 0















at exitisting facilities Jul-24 115 21 0 7 14 7 0 14 0 7 0 14 0 42







9 20 13
0.0168
0.0168

Jan-25 115 21 0 7 14 7 0 14 0 7 0 14 0
















Jul-25 115 21 0 7 14 7 0 14 0 7 0 14 0 84







18 40 26
0.0336
0.0336

Jan-26 115 21 0 7 14 7 0 14 0 7 0 14 0
















Jul-26 115 21 0 7 14 7 0 14 0 7 0 14 0 126







27 59 39
0.0504
0.0504































All Jan-24 165 104 50 37 67 37 0 67 0 37 0 67 0 0 0 0 0 0 0 0 0 0 0 0 0 2162 0 0 0

Jul-24 165 104 50 37 67 37 0 67 0 37 0 67 0 21828 4397 979 688.324 0 434.434 126.945 338.52 0 4143 8971 5892 2162 8.7312 1.1284 7.6028

Jan-25 165 104 50 37 67 37 0 67 0 37 0 67 0 0 0 0 0 0 0 0 0 0 0 0 0 2162 0 0 0

Jul-25 165 104 50 37 67 37 0 67 0 37 0 67 0 22036 4438 991 696.62 0 439.67 128.475 342.6 0 4181 9054 5946 2162 8.8144 1.142 7.6724

Jan-26 165 104 50 37 67 37 0 67 0 37 0 67 0 0 0 0 0 0 0 0 0 0 0 0 0 2162 0 0 0

Jul-26 165 104 50 37 67 37 0 67 0 37 0 67 0 22244 4479 1003 704.916 0 444.906 130.005 346.68 0 4219 9135 6000 2162 8.8976 1.1556 7.742































All 2023-24 330 208 100 74 134 74 0 134 0 74 0 134 0 21828 4397 979 688.324 0 434.434 126.945 338.52 0 4143 8971 5892 4324 8.7312 1.1284 7.6028

2024-25 330 208 100 74 134 74 0 134 0 74 0 134 0 22036 4438 991 696.62 0 439.67 128.475 342.6 0 4181 9054 5946 4324 8.8144 1.142 7.6724

2025-26 330 208 100 74 134 74 0 134 0 74 0 134 0 22244 4479 1003 704.916 0 444.906 130.005 346.68 0 4219 9135 6000 4324 8.8976 1.1556 7.742





























































































a Assume 100 new facilities obtaining title V permits each year nationwide; thus, 50 each 6-month period. Assume 230 existing facilitities nationwide revise their title V permits to add new PSEUs each year; thus, 115 each 6-month period.





























b Derived based on Equations IV-1 and IV-2 in the 2008 RIA. Differs by not converting number of permits nationwide to the number in the 9 sample states as was done in the 2008 RIA (i.e., excluded factor SS = 0.214).





























Pc,t = RS * Sc * Pc * Ac





























Pc,t is the number of PSEUs in Category c expected to become subject to CAM at a given time. The Categories are Large PSEUs and Other PSEUs.





























RS is the number of relevant title V permits nationwide





























Sc is the percent of sources expected to construct at least one new PSEU in Category c. For Large PSEUs = 11.5%; for Other PSEUs = 34.8%





























Pc is the number of Category c PSEUs expected to be constructed at a facility that has at least one Category c PSEU. For new facilities, Pc is 3.15 for Large PSEUs and 7.06 for Other PSEUs. For existing facilities adding new PSEUs Pc is 1 for both Large and Other PSEUs





























Ac is the percent of PSEUs in Category c that are projected to be subject to CAM. For Large PSEUs = 53.8%; for Other PSEUs = 53.6%





























c Assume that this is a one-time task, which only newly permitted facilities must carry out; existing facilities that are adding PSEUs are already familiar with the CAM requirements. The new permits in each period considered for Large (rows 32-37) and Other (rows 46-51) PSEUs are the same permits, so the review task only needs to be incuded once (here in rows 32-37).





























d Fraction of Large PSEUs without existing monitoring = 0.563; with existing monitoring = 0.437. Fraction of Other PSEUs without existing monitoring = 0.31; with existing monitoring = 0.69





























e Assume no PSEUs have CEMs or COMs, so PSEUs in "Justification" and "Specify Monitoring Elements" Non-CEM/COM columns are the same as for "Determine Approach" with and without existing monitoring





























f All the columns under "Perform Monitoring" include the cumulative number of PSEUs in each category, that is, all the existing PSEUs that were in the CAM Program at the beginning of this ICR period plus all the new ones coming in during the period. THESE NUMBERS ARE NO LONGER USED TO CALCULATE CAM BURDEN UNDER THE ASSUMPTION THAT THIS BURDEN IS INCLUDED IN THE PART 70 ICR.





























g The existing Large and Other PSEUs are included in the counts with the new facilities. We assume 2,927 existing Large PSEUs and 19,780 existing Other PSEUs based on the number of existing title V permits in Year 2 of the ICR for part 70 (2014) and the factors developed for the 2008 RIA (see footnote b). See the comments in some cells in this column for additional information.





























h These columns apportion the number of Large PSEUs in Column P according to the following fractions. THESE COLUMNS ARE VESTIGES OF THE 2008 RIA AND PREVIOUS ICRs AND ARE NO LONGER USED IN ICR CALCULATIONS.





























Acceptable existing system - 0.090





























Upgrade existing instrumental system - 0.347





























Install a CO parametric monitor - 0.244





























Install a NOx parametric monitor - 0





























Install a PM parametric monitor - 0.154





























Install an SO2 parametric monitor - 0.045





























Install a VOC parametric monitor - 0.120





























Install a CEM or COM - 0





























i These columns apportion the number of Other PSEUs in Column P according to the following fractions. THESE COLUMNS ARE VESTIGES OF THE 2008 RIA AND PREVIOUS ICRs AND ARE NO LONGER USED IN ICR CALCULATIONS.





























Acceptable existing work practices - 0.218





























Upgrade existing work practices - 0.472





























Initiate work practices - 0.31





























j This column includes PSEUs at facilities renewing existing title V permits, which have a 5-year term. Thus, about 20% of permits are renewed each year, or 10% each 6-month period. These renewals are for permits issued in 2009, 2010, and 2011, so the new PSEUs added during the period of this ICR do not figure in.





























k This column includes the PSEUs for which QIPs must be prepared. We assume that this is a one-time activity and that in each year QIPs are prepared for 0.04% of the total population of PSEUs, both existing and new.





























l This column includes PSEUs for which records of corrective actions under a QIP must be kept. We assume a rate in each year of 0.04% of all PSEUs subject to CAM, both existing and new.





























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