1 SUPPORTING STATEMENT Emission Reporting Requirements for Ozone SIP Revisions ( or Associated Federal Implementation Plans) Relating to Statewide Budgets for NOx Emissions to Reduce the Regional Transport of Ozone EPA ICR # 1857.02 1. IDENTIFICATION OF THE INFORMATION COLLECTION 1( a) Title of the Information Collection " Emission Reporting Requirements for Ozone State Implementation Plan ( SIP) Revisions ( or Associated Federal Implementation Plans) Relating to Statewide Budgets for NOx Emissions to Reduce Regional Transport of Ozone."

1( b) Short Characterization/ Abstract This Information Collection Request ( ICR) addresses the labor hour burden and costs of State reporting requirements under § 51.122 contained in the U. S. Environmental Protection Agency's ( EPA) rule to control regional transport of ozone season NOx emissions contributing to exceedances of the ozone National Ambient Air Quality Standard ( NAAQS) in the eastern United States. The reporting requirements of this rule under § 51.122 are imposed directly on the States, not on industry. However, in order to meet the requirements of this rule, States will of necessity have to impose requirements on industry for installation of continuous emission monitors and for recordkeeping and reporting. Therefore, there will be an indirect record keeping and reporting burden on industry as a result of this rule. This ICR estimates the burden hours and costs incurred by industry as a result of reporting requirements of the rule. The rule does not require an emissions trading program, but it strongly encourages such a trading program, and it is anticipated that every State will adopt a trading program for fossil fuel fired NOx sources serving electrical generators with a nameplate capacity greater than 25 MW or boilers, combustion turbines or combined cycle units with maximum design heat input greater than 250 mm BTU/ hr. For this ICR, it is assumed that each State will adopt the Federal model trading program, and the burden associated with such a program is evaluated. This trading program burden would include the paper work burden related to ( 1) transferring and tracking allowances; ( 2) the allocation of allowances to affected units; ( 3) permitting; ( 4) annual year end compliance certification; and ( 5) meeting the monitoring and reporting requirements of the program. The 1For the remainder of this supporting statement, reference to " State( s)" includes the District of Columbia for a total of 22 " States".

2 monitoring and reporting requirements of a trading program will require capital and labor expenditures by industry, and these are evaluated. Reporting requirements under the trading program can often be used to satisfy the § 51.122 reporting requirements, but other requirements of the trading program are specific to the trading program and will often be discussed here under separate headings.

The options reported here are consistent with the set of assumptions used to develop the budgets for the NOx SIP call. However, there is no certainty that these options are what a particular State will adopt since States have flexibility to adopt different measures to meet their budget.

The reporting requirements were first proposed in the EPA's supplemental notice of proposed rulemaking ( SNPR), May 11, 1998 ( 63 FR 25901). The final NOx SIP call rule was issued by EPA on October 27, 1998 ( 63 FR 57356). Eight states challenged the rule and asked the U. S. Court of Appeals for the D. C. Circuit to stay the due date for the State plans. As an interim measure, the Court issued an indefinite stay on May 25, 1999. On March 3, 2000 the Court issued an opinion largely upholding the NOx SIP call, however the Court did not lift the stay until June 22, 2000.

The original rule established statewide ozone season NOx emissions budgets for 22 States and the District of Columbia. The March 3, 2000 U. S. Court of Appeals ruling vacated the rule for Wisconsin, therefore this analysis is done for 21 States plus the District of Columbia. 1 The NOx budgets for the 22 States were developed based in part on the recommendations of the Ozone Transport Assessment Group ( OTAG). The 22 States were required to achieve their NOx emissions budgets by 2007. The EPA is anticipating that each State will adopt control measures and implement controls on large stationary NOx emission sources by 2003. Many of these sources may need to install and operate continuous emissions monitoring systems ( CEMS) in order to monitor NOx mass emissions if they are not already equipped with these systems. Starting in 2003 ( for the year 2002), States will be required to electronically report data to EPA to demonstrate progress towards meeting their NOx budgets by 2007, and subsequently maintain compliance with their budgets after 2007. The EPA will use the data reported by each State to verify the State's progress toward meeting its NOx budget. The NOx emission reporting requirements are provided in § 51.122 of the final rule.

States are required to report data annually for those point, area, nonroad mobile, and highway mobile sources for which they adopt control measures to meet their NOx emissions budgets. These annual reports must include ozone season NOx emission inventories. States must report a statewide inventory of all NOx sources every 3 years starting in the year 2003 for the 2002 inventory, and must also report in 2008 for the 2007 compliance demonstration inventory. While the States are expected to use their existing emission inventory data collection and electronic reporting mechanisms for submitting the data to EPA, some modifications will be necessary to account for the reporting of ozone season 3 emissions data. The data reports may be provided using one of several procedures, including submittal in Emission Inventory Improvement Program/ Electronic Data Interchange ( EIIP/ EDI) format, or in proprietary format based on the EIIP data model. The EPA will allow for the direct reporting of point source data from sources to EPA if the sources are subject to the monitoring and reporting provisions of Subpart H of 40 CFR Part 75.

EPA has proposed Federal implementation plans ( FIPs) that may be needed if any State fails to revise its State implementation plan ( SIP) to comply with the nitrogen oxides ( NOx) SIP call. The FIPs would be applicable to sources of emissions of nitrogen oxides located within any State that is listed in 40 CFR 51.121 and for which EPA has found that the State has:

( 1) Failed to submit the State implementation plan revision required by 40 CFR 51.121; ( 2) Failed to submit such a plan revision meeting the minimum criteria in 40 CFR 51.103 and Appendix V of part 51; or ( 3) Submitted a plan revision that EPA has disapproved as not meeting the requirements of 40 CFR 51.121.

In these cases, the FIP will impose essentially the same reporting burden on affected sources as would be required by the NOx SIP call. The industry burden reported in this ICR will be essentially the same whether the burden is a result of the NOx SIP call or of FIPs. The industry sources will be required to comply with reporting requirements imposed either by the State as a result of the NOx SIP call or imposed by the EPA through a FIP. Before EPA proposed the FIP rule ( see " Federal Implementation Plans to Reduce the Regional Transport of Ozone; Proposed Rule," October 21, 1998 [ 63 FR 56394]), EPA prepared an Information Collection Request ( ICR) document ( ICR No. 1883.01) titled " Draft Information Collection Request for a Federal Implementation Plan to Reduce the Regional Transport of Ozone" which was submitted to the Office of Management and Budget and was made available on the internet at http:// www. epa. gov/ icr. The burden calculated in that FIP ICR has been incorporated into this current ICR, and this ICR will serve as the ICR for both the NOx SIP call and the FIP. This is appropriate because to do otherwise could result in double counting of the burden, since sources will be subject to either the NOx SIP call or a FIP and will incur approximately the same record keeping and reporting burden in either case. If all States comply with the NOx SIP call requirements, there will be no FIPs, and all the burden reported in this ICR will result from the NOx SIP call.

Emissions Trading Program The ability to buy and sell ( or transfer) allowances is expected to provide substantial economic benefits, by encouraging the greatest emissions reductions where costs of reductions are lowest. This concept of allowance transfers cannot be implemented, however, unless regulations governing emissions monitoring and permitting of sources are in place as well. To ensure compliance with the emissions reduction requirements and to provide the regionwide consistency needed to foster the allowance 4 market, the designated representative of the owners and operators of each source with affected units will be required to obtain an operating permit for the affected source and to certify that an approved emissions monitoring system has been installed and is properly operated at each affected unit's source of emissions.

While compliance is not mandatory until 2002, the Agency estimates that one third of the coalfired units subject to the program will choose to come into compliance before 2002. These early election units will record baseline emissions in 2000 and begin the allowance trading and banking program in 2001.

( i) Allowance Allocations For existing units, information for the allocation process will be recorded and collected as part of the emissions monitoring and reporting process. The allocation system is an input based system that uses information that is already needed for purposes of calculating NOx mass. New units will have to submit projected information to determine allowance allocations.

( ii) Permits Permit applicants are required to submit a permit application for each affected source. Because most sources regulated under the NOx Trading Program will have existing permits under Title V, a permit revision is all that will be necessary. Some sources will also need to obtain permits to construct necessary facilities.

( iii) Capital/ Start up Costs While many sources have already installed necessary emissions monitoring equipment due to requirements under other regulations, some sources will need to either install new monitors or upgrade existing monitors. Capital costs also usually include the cost of initial certification of new or upgraded monitors is included as part of start up costs.

( iv) Emissions Monitoring Emissions monitoring and reporting is the foundation upon which the allowance trading system is based. EPA will use the data contained in the reports to verify actual emissions. Without accurate monitoring and reporting of emissions, the integrity of the allowance system would be undermined, and there would be no assurance that emissions had been reduced. To meet the emissions monitoring, recordkeeping and reporting requirements, affected units are required to ( 1) submit a monitoring plan and certification reports for each monitoring system, ( 2) record hourly emissions data, and ( 3) submit reports of their emissions data to EPA. 5 ( v) Year end Compliance Certifications Each source is required to submit an annual statement providing information on which allowances are to be deducted and certifying that the unit is in compliance with emission limitations and monitoring and reporting requirements.

( vi) Allowance Transfers and Tracking All participants in the allowance transfer system will be required to complete and submit an allowance transfer form for each allowance transfer. Participants in the transfer system that are not affected sources, such as allowance brokers, fuel suppliers and environmental groups will also be required to file a one time account information application to establish an account in the Allowance Tracking System ( ATS).

2. NEED FOR AND USE OF THE COLLECTION 2( a) Need/ Authority for the Collection The State reporting requirements included in the final rule are necessary for EPA to carry out properly its evaluation of each State's compliance with its ozone season NOx emissions budget. The legal authority for the reporting requirements resides in Sections 110( a) and 301( a) of the Clean Air Act. Specifically, the requirement in Section 110( a)( 2)( D) that SIPs include " adequate provisions" to mitigate certain transport effects on other States implicitly authorizes emissions inventory reporting to EPA, as needed and appropriate to verify that a State is in fact meeting its NOx budget. Section 110( a)( 2)( F) provides additional authority for requiring that SIP call submissions include provisions for emissions reporting by sources to a State, correlation of source information by the State, and steps by the State to make the correlated information available to the public. Section 110( a)( 2)( K), in turn, requires a State to submit to EPA as requested data related to modeling the effect of NOx and other emissions on ambient air quality. The reported emissions inventory data described in this section will be used by EPA in air quality modeling to assess the effectiveness of the transport rulemaking's regional strategy. Finally, Section 301( a) grants EPA broad authority to prescribe such regulations as are necessary to carry out its functions under the Clean Air Act.

2( b) Practical Utility/ Users of the Data The EPA believes it is essential that compliance with the regional control strategy be verified. Tracking emissions is the principal mechanism to ensure compliance with the budget and to assure the downwind affected States and EPA that the ozone transport problem is being mitigated. 6 If tracking and periodic reports indicate that a State is not implementing all of its NOx control measures beginning in 2003 or is off track to meet its statewide budget by 2007, EPA will work with the State to determine the reasons for noncompliance and what course of remedial action is needed. The EPA will expect the State to submit a plan showing what steps it will take to correct the problems. Noncompliance with the NOx transport SIP may lead EPA to make a finding of failure to implement the SIP and potentially to implement sanctions, if the State does not take corrective action within a specified time period.

The EPA will use data from the 2007 inventory and beyond to assess how each State's SIP actually performed in meeting the statewide ozone season NOx emissions budget. If emissions exceed the required budget in any year after 2006, the control strategies in the SIP will need to be strengthened. The EPA will evaluate the circumstances for the budget failure and may issue a call for States to revise their SIPs, as appropriate.

Emissions Trading Program ( i) Permits Permit applications, including proposed compliance plans, will be used by EPA to issue operating permits and to allocate allowances. A permit application will be legally binding on the owners, operators, and designated representative of a source until the actual permit is issued. This aspect of the permit application reduces significantly the uncertainty imposed on a source due to possible delays at EPA. Affected sources may rely on the permit for information on the requirements with which they must comply. Because permit applications and permits will be public documents, they may be used by the public to examine activities undertaken by affected sources.

( ii) Emissions Monitoring Data from emissions monitoring is indispensable to successful implementation of the NOx Trading Program for two reasons:

° The primary purpose of the NOx Trading Program is to assist States in the attainment of the ozone national ambient air quality standards ( NAAQS) by reducing the adverse effects of the transport of ozone and ozone precursors from upwind States by reducing annual emissions of nitrogen oxides; and ° EPA can only enforce the program by comparing, for each affected unit, emissions data and the number of allowances held. 7 ( iii) Year end Compliance Certification This information will be used by EPA to determine annual compliance and to verify that the monitoring plan for the unit continues to be accurate.

( iv) Allowance Transfers and Tracking Information collected on allowance transfers will be used by EPA or its designated agent to track allowances for the purpose of determining compliance with the NOx Trading Program. Information on allowance transfers will also be used by participants in the allowance market and the public to evaluate the activities of affected sources, and by EPA for program evaluation.

Together, the allowance trading system, operating permits, and emissions data will help to provide the accountability to allow the NOx Trading Program to function without more stringent command and control approaches.

3. NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA 3( a) Nonduplication To minimize the reporting burden on State agencies, the reporting requirements for the final rule are based on existing annual and periodic emission inventory reporting requirements as much as possible. However, since these requirements are being established to support an ozone season reduction program and since existing provisions do not require the collection of ozone season inventories, some additional reporting will be required. The EPA requires that States report annually data for all point sources that are part of a control measure that was adopted for purposes of meeting the NOx budget. If States act in accordance with OTAG recommendations for setting the emissions budgets, the sources controlled will all be point sources emitting $ 100 tons per year ( tpy) of NOx. The 100 tpy threshold is consistent with the NOx reporting threshold for the existing annual emission inventory. However, the rule does allow States the option of defining the NOx point source threshold to be less than 100 tpy.

The EPA will allow the direct reporting of point source data from sources to EPA to satisfy this requirement if the sources are subject to the monitoring and reporting requirements of Subpart H of 40 CFR Part 75. The direct reporting of data from sources to EPA will minimize the reporting burden on States. Also, direct reporting will avoid duplication of effort for sources subject to the Part 75 requirements. 8 Currently, there are no existing annual reporting requirements for area, nonroad mobile, and highway mobile source emissions. For the purposes of the final rule, an area source is any anthropogenic source that is not included in the point, nonroad mobile, or highway mobile source inventories. The EPA requires that the State report annually area source NOx emissions for only those stationary area source categories for which the State adopts control measures for the purpose of meeting its NOx budget. For nonroad mobile and highway mobile sources, the EPA requires that the State report annually NOx emissions for only those source categories for which the State adopts control measures that are more stringent than Federal measures for the purpose of meeting its NOx budget. Based on the recommendations of OTAG, it is not expected that States will adopt area, nonroad mobile, or highway mobile source control measures to meet their NOx budgets. However, if one or more States do adopt such measures, annual reporting of emissions will be necessary to track the States' progress toward meeting their NOx budgets.

The rule contains a requirement for States to report statewide point, area, nonroad mobile, and highway mobile source NOx emissions data every 3 years starting with the inventory year 2002. The data reported would be ozone season emissions data for each third year and would include data from all source categories in the State regardless of whether sources are being controlled to meet a NOx budget. This 3 year cycle reporting requirement coincides with the schedule for the existing periodic emission inventory reporting requirement for the States.

The EPA requires that in 2007, States submit to EPA statewide ozone season NOx emissions data from all NOx sources ( point, area, nonroad mobile, and highway mobile) within the State. The data reporting requirements are identical to the reporting requirements for the 3 year cycle inventory, but would occur 1 year prior to the next 3 year cycle inventory. This one time reporting requirement for a 2007 statewide inventory will allow evaluation of whether the NOx budgets are met for 2007. However, EPA will work with the States to minimize the incremental burden associated with preparing a 2007 and a 2008 statewide inventory. The incremental burden is associated with the area and mobile source inventories since States must report point source data annually. For area, nonroad mobile, and highway mobile source data, States may project incremental changes in emissions from 2007 to 2008 to allow the 2008 inventory requirement to be more easily met and to reduce the burden on the States.

Emissions Trading Program Almost all information requested from respondents under this proposed ICR is not available from other sources. Where EPA needs information that has already been submitted, EPA is simply requiring a photocopy of the prior submittal or the retransmission of stored electronic data. In addition, EPA intends to integrate the reporting requirements for the NOx Trading Program into existing electronic data reporting ( EDR) formats. The EDR formats are used by Acid Rain Program units under Title IV of the Act and units subject to the NOx Budget Program implemented in the Ozone Transport Commission ( OTC) region under Title I of the Act. Thus, for units subject to the Acid Rain or OTC quarterly reporting requirements, only one submission will need to be made on a quarterly basis. 9 3( b) Public Notice Required Prior to ICR Submission to OMB The NOx SIP call ICR is for a rule related collection. The related FIP ICR proposal, which has been incorporated into the NOx SIP call, is also for a rule related collection. Therefore, the requirement to solicit public comments for a 60 day period prior to submitting the ICR to OMB does not apply.

For the NOx SIP call, the SNPR was signed by the EPA Administrator on April 28, 1998. The Federal Register notice, announcing the SNPR and ICR, was published on May 11, 1998. All comments received on the reporting rule § 51.122 during the public comment period were considered by EPA, and some revisions were made to reporting requirements in the final rule in response to comments. The only comments received on the proposal NOx SIP call ICR were those from OMB.

The proposal notice for the FIP, Federal Implementation Plans To Reduce the Regional Transport of Ozone, was published on October 21, 1998 ( 63 FR 56394). This notice announced the availability of an ICR document ( ICR No. 1883.01). The availability of the document was announced along with an internet site ( http:// www. epa. gov/ icr) where it could be downloaded. No comments were received on the proposed FIP ICR.

The NOx SIP call proposal ICR contained only consideration of the burden by the State to report to EPA under § 51.122. The proposal did not include burden to industry to collect data or the burden of participating in an emissions trading program. In response to comments by OMB, these burdens have been added to the ICR by incorporating the burden to operate an emission trading program in the affected states which was reported in the FIP ICR proposal as discussed in section 1( b). In addition, burden for data collection and reporting for cement kilns and I. C. engines were added.

3( c) Consultations On January 13, 1998, EPA held a one day pre proposal workshop with the States to discuss tracking issues. The objective of the workshop was to determine what type and frequency of inventory reporting is feasible for the different source sectors ( power generating sources, other point sources, area sources, nonroad mobile, and highway mobile sources), to identify key reporting issues related to each sector, and to develop recommendations on reporting requirements to ensure compliance with the NOx budgets. The goal was to share information and ideas rather than to reach consensus. A summary of the meeting is contained in the docket ( docket no. A 96 56, item V B 18) for this rulemaking.

The workshop participants generally thought that existing reporting requirements for attainment SIPs should be used whenever possible to minimize any new reporting burden. The States further recommended that the degree of reporting rigor should be directly related to the sectors that the State chooses to control in its NOx transport strategy. Reporting every 3 years was considered feasible for 10 all source sectors. Reporting on an annual basis was considered both achievable and necessary for all source sectors that a State chooses to regulate specifically for the purpose of meeting the SIP call NOx budgets. This would include all NOx sources within the State which are subject to measures included by the State in its transport SIP revision in response to the SIP call. In addition, it was noted that sources or source categories that would be participating in a trading program would need to meet the reporting protocols specific to that program. Consideration was also given to establishing uniform monitoring and reporting requirements and a centralized data base for reporting for other sources. Several States indicated support for this concept if there were easy access to the data by all parties. The reporting requirements included in the proposed and final rule are based, in part, on the suggestions of participants in the workshop.

Emissions Trading Program The requirements for the NOx Trading Program have been developed using both the methodology found in existing trading programs as well as consultations with interested parties.

EPA considered the strategy taken in the OTC's NOx Budget Program, a trading program developed for use in eleven States and the District of Columbia. EPA also considered the results of the findings of the Ozone Transport Assessment Group ( OTAG), especially OTAG's Trading and Incentives Workgroup. Members of OTAG include 37 States, the District of Columbia, EPA, and industry and environmental group participants. OTAG conducted meetings in 1995 and issued final recommendations in 1997 concerning ozone transport. EPA also considered the work of the RECLAIM program, another cap and trade market based system.

Prior to proposing the ICR for the FIP rule, EPA also held two public workshops in 1997, lasting two days each. Over 150 people participated in each of these workshops, including States and industry representatives. EPA received comments following the workshops and considered and incorporated those comments into the proposed ICR along with comments received during the meetings.

Finally, as part of updating the ICR for the Acid Rain Program ( Part 75) monitoring requirements, EPA contacted various affected parties to gather information on CEM capital costs, CEM operation and maintenance costs, fuel meter capital costs, and CEM/ fuelmeter testing costs. That information has been used in this ICR where appropriate.

3( d) Effects of Less Frequent Collection If this information collection were not carried out annually for sources being controlled to meet the NOx budgets, EPA would not be able to verify that NOx emission reductions necessary to meet each State's NOx emission budget were being achieved. In addition, a triennial report of all NOx sources 11 statewide is vital in enabling EPA to track States' progress towards meeting the NOx budgets. Because the NOx budgets prescribed have been deemed essential in order for downwind States to attain the NAAQS in a timely manner, data collected less frequently would be of little or no use.

Emissions Trading Program Submittal of allowance trading information and compliance information on an annual basis provides necessary feedback on the allocation of allowances. If this information collection were not carried out annually for sources being controlled to meet the NOx budgets, EPA would not be able to verify that NOx emission reductions necessary to meet each State's NOx emission budget were being achieved. Because the NOx budgets prescribed have been deemed essential in order for downwind States to attain the NAAQS in a timely manner, data collected less frequently would be of little or no use.

Quarterly collections of emissions data allows the opportunity to check data for errors and provide rapid feedback on needed adjustments to data collection systems, and thereby promotes accurate and reliable emissions data. For this same reason, existing federal and state emission monitoring programs often require quarterly reporting, or in some cases, monthly. Less frequent collection, such as semi annually or annually, would increase the amount of preparation and review time at the end of the reporting period both for regulated sources and for EPA. This would slow down the process for the verification of compliance.

As an option for this program, EPA will allow for ozone season reporting instead of quarterly reports for the entire calendar year. Under this option, units would only be required to submit two reports per year ( covering the second and third calendar quarters). However, because the Agency believes that full year quarterly reporting will be beneficial for both the source and the Agency, this ICR assumes all units will elect to comply with the standard quarterly reporting requirement.

3( e) General Guidelines This ICR does not violate any of OMB's guidelines for information collections.

3( f) Confidentiality As required by Section 114 of the Clean Air Act, estimates or measurements of emissions must be treated as nonconfidential. Under Agency procedures, data items relating to the computation of emissions may be identified as sensitive by a State and are then treated as " State sensitive" by EPA. The potentially State sensitive items include the following: Process rate, boiler design capacity, emission estimation codes, percent space heat, operating rate, and maximum operation rate/ hour. Where Federal and State requirements are inconsistent, EPA Regional Office should be consulted for final reconciliation. 2 The U. S. Court of Appeals decision of March 3, 2000 vacated the rule for Wisconsin.

12 3( g) Sensitive Questions Not applicable. This information collection does not ask any questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4( a) Respondents/ SIC Codes The reports submitted under this ICR will be submitted by the State air pollution control agencies for which NOx budgets will be established, which include the following 21 States and the District of Columbia: Alabama, Connecticut, Delaware, Georgia, Illinois, Indiana, Kentucky, Massachusetts, Maryland, Michigan, Missouri, North Carolina, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, South Carolina, Tennessee, Virginia, and West Virginia. 2 The affected SIC would be 9511  Air and Water Resource and Solid Waste Management, which includes government environmental protection and control agencies, as well as pollution control agencies.

This ICR also estimates a burden for affected industry sources to monitor NOx mass emissions and demonstrate compliance with NOx control measures. Sources may report data directly to EPA if a source is required to meet the monitoring and reporting requirements of Subpart H of Part 75. If the OTAG recommendations are followed, States will control larger electric utility and industrial combustion point sources to comply with their NOx emissions budgets for 2007. Electric utility combustion sources are generally classified as either SIC 4911  Electric Services, or 4931  Electric and Other Services Combined. States must decide which sources to control for the purpose of meeting their NOx budgets. Thus, at this time, it is not possible to determine the SIC codes for the industrial combustion sources that will potentially be controlled by the States. Large industrial combustion sources ( e. g., boilers, turbines, and internal combustion engines) are expected to fall under SIC codes for the manufacturing sector, i. e., SIC Major Groups 29 40. In addition, States have the option of controlling area, nonroad mobile, and highway mobile NOx sources for meeting their NOx budgets. However, based on OTAG's recommendations, it is unlikely that States will adopt area, nonroad mobile, or highway mobile source control measures to meet their NOx budgets. The Agency's action eventually will also impose additional, non trading program requirements on internal combustion engines ( potentially applicable in a variety of industries, with significant number in SIC 492  Gas Production and Distribution) and cement kilns ( primarily SIC 327  Concrete, Gypsum, and Plaster Products). 13 4( b) Information Requested This section describes State reporting and recordkeeping requirements and the activities ( i. e., burden items) associated with the requirements in § 51.122. States must report NOx emissions data as specified in § 51.122 of the final rule. States are required to submit the appropriate emissions data within 12 months of the end of the inventory year ( e. g., a statewide NOx emissions inventory for the year 2005 would be required by December of 2006). The activities that an affected source would have to conduct are also listed.

( i) Data items, including recordkeeping requirements Reporting requirements Many of the required emissions data elements are already being provided to the EPA under existing annual point source reporting requirements, as well as periodic SIP inventory reporting provisions for point, area and nonroad mobile, and highway mobile sources. The following lists the data items required for point, area, nonroad mobile, and highway mobile sources, and identifies new data items not required to be included in emission inventories currently reported to EPA.

Point sources For NOx point sources controlled for purposes of meeting the NOx budgets, States must annually report the following data items, unless the point sources are reporting directly to EPA under Subpart H of 40 CFR Part 75. The new data items are identified with an asterisk (*).

Inventory year State Federal Information Processing System ( FIPS) code County FIPS code Federal ID code ( plant) Federal ID code ( point) Federal ID code ( process) Federal ID code ( stack) Site name Physical address Source Classification Code ( SCC) Pollutant code Work weekday emissions Fuel heat content ( annual) Activity throughput ( annual) Emission factor 14 Spring/ Summer/ Fall throughput (%) Hour/ day in operation Operations start time ( hour) Day/ week in operation Week/ year in operation Area designation* Ozone season emissions* Fuel heat content ( seasonal)* Source of fuel heat content data* Activity throughput ( seasonal)* Source of activity throughput* Source of emission factor*

Additional reporting requirements apply every 3 years ( triennially), starting for the inventory year 2002, and for the year 2007. For these years, States must submit a statewide NOx point source inventory for all controlled and uncontrolled sources. In addition to the data items required for annual reporting, the following elements must be reported to EPA triennially and for 2007:

Latitude/ longitude Stack height Stack diameter Exit gas temperature Exit gas velocity Exit gas flow rate Standard Industrial Classification ( SIC) Boiler/ process throughput design capacity Maximum design rate Maximum capacity Primary control efficiency Secondary control efficiency Control device type Area sources The following lists the data elements States must report annually for area sources controlled for the purpose of meeting the NOx budgets. States must report these same data elements for all area sources in their statewide triennial inventory, starting in 2002, and for 2007. The new data items are identified with an asterisk (*).

Inventory year State FIPS code 3For highway mobile sources, the activity is expressed as VMT by roadway class.

15 County FIPS code SCC Pollutant code Emission factor Activity throughput level ( annual) Control efficiency (%) Spring/ Summer/ Fall throughput (%) Hour/ day in operation Day/ week in operation Week/ year in operation Ozone season emissions* Source of emission factor* Activity throughput level ( seasonal)* Source of activity throughput data* Source of emissions data*

Highway and nonroad mobile sources The following lists the data elements States must report annually for highway mobile and nonroad mobile sources controlled for purposes of meeting the NOx budgets. States are required to report annually for those highway and nonroad mobile sources covered by State adopted regulations that are more stringent than Federal standards. States must report these same data elements for all highway and nonroad mobile sources in their statewide triennial inventory starting in 2002, and for 2007. The new data items are identified with an asterisk (*).

Inventory Year State FIPS Code County FIPS Code SCC Pollutant code Summer work weekday emissions Emission factor Activity3 Ozone season emissions* Source of emission factor* Source of activity data* Source of emissions data* 16 Justification for additional data items Ozone season emissions are emissions for the period May 1 through September 30 of a year. Emission estimates representing this period are required in order to demonstrate that the reductions required by the final rule are made during this same period. The EPA is also requiring States to provide an example ozone season calculation, along with sufficient information for EPA to verify the calculated value of ozone season emissions. This calculation, as well as two additional seasonal data elements ( i. e., fuel heat content for point sources, activity/ throughput level), will facilitate quality assurance review of the seasonal emissions data. Other data fields for providing the source of fuel heat content data, source of emissions data, source of emission factor, and source of activity throughput data will also assist EPA in their NOx budget verification procedures.

The EPA is also requiring the " Area Designation" element so that States that establish an offset pool composed of actual emission reductions achieved through compliance with the SIP call NOx budgets can track whether they are obtaining creditable offsets as specified in Section 173( c) of the Act ( which requires that major sources obtain offsets from areas with equal or higher nonattainment classification).

Recordkeeping requirements The final rule specifies that States are to comply with existing SIP recordkeeping and data availability requirements as outlined in 40 CFR Part 51.116. As such, there are no recordkeeping burden items that are incremental to existing recordkeeping requirements.

( ii) Respondent activities The one time State burden items associated with this ICR include:

° Prepare SIP revision for submission to EPA in response to the NOx SIP call.

° Read the reporting requirements of the rule;

° Submit example ozone season emissions calculations to EPA [ § 51.122( g)];

° Create 7 additional data fields in electronic point source data base file, 5 additional data fields in the area source data base file, and 4 additional data fields in each of the nonroad mobile and highway mobile source electronic data base files for new data items [ § 51.122( c), ( d), ( e)];

° Develop procedures by which to estimate stationary area source NOx emissions for triennial statewide reporting requirements [ to comply with § 51.122( b)( 2), ( 3)]; 4Typically, the initial CEMS certification testing, as well as annual relative accuracy testing, are performed as part of a fixed price contract. However, for the purposes of this analysis, the costs to perform these activities are presented in terms of labor rates applied to burden hours.

17 ° Develop allocation for estimating county level vehicle miles traveled ( VMT) from Statelevel VMT data [ to comply with § 51.122( b)( 2), ( 3)];

° Project 2007 area, nonroad mobile, and highway mobile inventories to 2008 to satisfy 3 year cycle requirement [ § 51.122( b)( 2), ( 3)]; and ° Review Title V permit revisions from controlled sources [ § 51.121( h)( 1)].

The one time industry burden items associated with this ICR include:

° Read the reporting requirements of the rule;

° Revise Title V permit to incorporate NOx monitoring [ § 51.121( h)( 1)]; and ° Install and perform testing to certify NOx CEMS or other approved monitoring system [ § 51.121( h)( 1)]. 4 Annual State burden items associated with this ICR include:

° Determine ozone season emissions for controlled sources [ § 51.122( c)( 1), ( 2)];

° Notify the appropriate EPA Regional Office when submitting an annual, triennial, and 2007 NOx inventory [ § 51.122( h)]; and ° Submit electronic NOx budget emissions report [ § 51.122( b)( 1)].

The annual burden items for industry associated with this ICR include:

° For units subject to Title IV monitoring requirements, reporting compliance information to a State or EPA [ § 51.121( h)( 1)].

° For units not already subject to Title IV monitoring requirements:

° Perform general operations and maintenance activities ( e. g., quality assurance testing, calibrations, cylinder gas audits)[ § 51.121( h)( 1)]; and 18 ° Prepare and submit reports to demonstrate compliance, including update of monitoring plan [ § 51.121( h)( 1)].

Triennial State burden items associated with this ICR include:

° Prepare statewide inventory for area, nonroad mobile, and highway mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)]; and ° Compile summary report of statewide NOx emissions for submittal to EPA [ § 51.122( b)( 2), ( h)].

There are no triennial industry burden items associated with this collection in addition to the burdens listed above..

Emissions Trading Program This section describes the data items requested from affected sources for the collections described in this ICR. This section also defines the activities in which respondents must engage to assemble, submit, or store these data items. Except where explicitly noted below, these requirements apply only apply to the trading program units, not the non trading units ( internal combustion engines and cement kilns).

( i) Data Items, Including Recordkeeping Requirements ( a) Allowance Tracking There are several data items required for allowance tracking activities. First, the utility must submit account certificates of representation for the NOx authorized account representative and ( if desired) alternate NOx authorized account representative. This documentation, found in 40 CFR § 96.13, must include:

C Identification of the source and unit, C Name and contact information for the NOx authorized account representative and alternate, C A list of the owners and operators of each source and unit, and C A certification statement and signature of the NOx authorized account representative and alternate.

Certification applications are to be kept for a period of 5 years pursuant to the general requirements imposed for Title V permitted facilities. 19 ( b) Permitting The basic requirement for permitting will be an application for a permit revision to a source's operating permit issued under Title V of the Act. This requirement will apply to both trading and nontrading sources. Although there is some possibility that a non Title V source could be affected under the NOx Trading Program, all affected sources are assumed to be Title V sources for purposes of this ICR. Except for the permit revision application, all of the other monitoring, reporting or recordkeeping requirements associated with Title V permitting are either part of the baseline Title V requirements or are covered separately under sections 4( c) and 4( d), below. Title V permit applications must be kept for 5 years pursuant to Title V recordkeeping requirements. In addition, coal fired units that are not part of the Acid Rain Program and are located outside the OTC region are expected to have to apply for a permit to construct under Title I of the Act.

( c) Year end Compliance Certifications On or before November 30 of each year, the NOx authorized account representative for each source must submit a compliance certification report covering all units at the source. Under 40 CFR § 96.30, the report must include the following:

C Identification of each unit, C Serial numbers of each NOx allowance to be deducted from the unit's compliance account, C For units sharing a common stack, the percentage of allowances to be deducted from the unit's compliance account, and C Compliance certification, including certification that the unit was operated in accordance with the emission limitation, verification that the monitoring plan is complete and accurate, a statement that all NOx emissions have been monitored and reported appropriately, and whether the basis for certification has changed ( and, if so, details of the change).

( d) Monitoring and Reporting Affected trading program sources would be required to monitor NOx mass emissions, and record and report emissions data using the requirements of 40 CFR Part 75. The emissions monitoring requirements specify that affected sources must ( 1) submit a monitoring plan for each affected unit at a source, ( 2) submit data for certification of each monitor, and ( 3) record hourly operational, pollutant monitor, and flow monitor data for each affected unit and submit quarterly reports of their emissions data to EPA. Appendices A and B to this ICR contain a list of the data items required by the recordkeeping and reporting provisions of Part 75.

Respondents are required by 40 CFR 75.64 to submit the quarterly NOx mass emissions data electronically, by direct electronic submission to EPA, and must also include a certification statement by the designated representative of the unit. All monitoring records are to be kept for three years, with 20 one possible exception under a voluntary option for fuel flowmeter calibration testing. For purposes of the NOx Trading Program, EPA currently is not requiring electronic submission of reports, but intends to do so after finalizing proposed revisions to Part 75. For purposes of this ICR, the labor burdens and other costs are calculated on the assumption that such a requirement will be in effect at the time reporting is required under this program.

( ii) Respondent Activities The primary tasks that will be performed by trading program respondents to meet the emissions monitoring requirements are ( 1) completing and submitting appropriate monitoring plan forms for each affected source and each affected unit at a source; ( 2) conducting tests to certify the operation of monitors, and submitting test results to EPA; ( 3) recording hourly emissions data ( this activity generally is performed electronically); ( 4) operation and maintenance activities associated with the monitoring, including quality assurance activities; ( 5) assuring data quality, preparing quarterly reports of emissions data and submitting these reports to EPA; and ( 6) responding to error messages generated by EPA. In addition, respondents will have to purchase the necessary monitoring hardware and purchase the electronic data reporting software ( or software upgrades).

5. THE INFORMATION COLLECTED   AGENCY ACTIVITIES, COLLECTION METHODS, AND INFORMATION MANAGEMENT 5( a) Agency Activities The EPA activities associated with § 51.122 of the final rule are as follows:

° Review/ verify ozone season emissions calculation submitted by each State; ° Receive and store emission inventory data submitted by each State and by point sources; ° Review emissions data submitted annually by each State to track each State's progress toward meeting its NOx budget; ° Review summary report of statewide NOx emissions submitted by each State every 3 years; and ° Respond to questions from States and point sources concerning electronic submittal of emissions data.

Emissions Trading Program The major EPA activities related to the NOx Trading Program include ( 1) maintenance and administration of the allowance tracking system ( NATS), ( 2) reviewing permit applications, ( 3) 21 reviewing monitoring plans and certification applications, ( 4) processing, reviewing and evaluating reports of quarterly emissions data from affected units, ( 5) calculating/ reviewing ozone season emissions, and ( 6) reviewing emissions data submitted annually to track each State's progress toward meeting its NOx budget and creating a summary report of statewide NOx emissions every three years. EPA will use a computer system called the Emissions Tracking System ( ETS) to track and maintain monitoring and emissions information. EPA will also answer respondent questions and conduct audits of data submissions.

5( b) Collection Methodology and Management Several options are currently available for data reporting. One option is for an agency to convert its emissions data into the EIIP/ EDI format. Through the EIIP, EPA is participating in a joint effort with State and local air pollution control agencies to establish a common format for exchanging data from one agency to another ( example: State to State, State to EPA). The need for such a format has increased with the increase in regional air quality modeling efforts that require data sharing by multiple States. This file can then be made available to any requestor, either using E mail, floppy disk, or value added network ( VAN), or can be placed on a file transfer protocol ( FTP) site. As a second option, an agency may submit its emissions data in a proprietary format based on the EIIP data model. For the last two options, the terms submitting and reporting data are defined as either providing the data in the EIIP/ EDI format or the EIIP based data model proprietary format to EPA, Office of Air Quality Planning and Standards, Emission Factors and Inventory Group directly or notifying this group that the data are available in the specified format and at a specific electronic location ( e. g., FTP site).

Another option for annual reporting ( not for third year reports) is to have sources submit the data directly to EPA. This option will be available to any source in a State that is both participating in a trading program meeting the requirements of Part 96 and that has agreed to submit data in this format. The EPA will make both the raw data submitted in this format and summary data available to any State that chooses this option.

Emissions Trading Program To ensure consistency nationwide and to expedite data entry, EPA will require that standard electronic data reporting ( EDR) formats used for Part 75 reporting be used to submit the information collected for the NOx Trading Program. The revised draft EDR formats ( version 2.1) that correspond to the proposed revisions to Part 75 are included as Appendix A to this document. As discussed in Section 4( b), above, upon promulgation of currently proposed Part 75 revisions, EPA intends to require that data be sent via direct electronic submission to EPA using the revised EDR format. Nontrading program sources will have to report results of performance tests or excess emissions, as applicable consistent with the reporting required under 40 CFR Part 60. 22 Several computer systems and associated databases have been developed to ( 1) track allowances, ( 2) record quarterly emissions monitoring data, and ( 3) calculate the number of allowances to be deducted each year. The systems and databases are designed to coordinate the information for easy access and use by the Agency, states, regulated community, and the public.

The EPA also has established an Acid Rain Home Page on the Internet, which includes detailed information collected from emissions reports. Those without access to the Internet may use the Acid Rain Hotline to request information, including the Acid Rain Program Updates or other summary reports. The Agency expects to rely on these electronic means to disseminate information about the NOx Trading Program as the program is developed.

5( c) Small Entity Flexibility The State control agencies affected by this rulemaking are not considered to be small entities. To support States with fewer sophisticated processing capabilities, the EPA has developed mainframe and PC software to facilitate State efforts in storing, maintaining, and reporting source data. A number of Territories and smaller States have adopted these and use them to make their submissions. By providing a number of means whereby the respondents can make their submissions, respondents are able to select those which minimize their efforts and costs and still use some type of electronic technology.

The rulemaking, which EPA published by notice in 63 FR 57356 ( October 8, 1998), would simply require States to develop, adopt, and submit SIP revisions. Pursuant to 5 U. S. C. 605( b), in the rulemaking, the Administrator certified that the rule will not have a significant economic impact on a substantial number of small entities.

Emissions Trading Program The NOx Trading Program only includes fossil fuel fired units ( stationary boilers, combustion turbines, and combined cycle systems) that serve an electrical generator of capacity greater than 25 MWe, and any other fossil fuel fired units that have a heat input capacity greater than 250 mmBtu/ hr. Units with a lower capacity are not included because of the high cost of monitoring emissions from these sources and the de minimis nature of their emissions.

There are two small unit exceptions that are applicable to the NOx Trading Program. The first provides for reduced monitoring and the second provides for an exemption from participation in the program. The low mass emitter exception ( 40 CFR 75.19), allows optional reduced monitoring, quality assurance, and reporting requirements for units that combust natural gas and/ or fuel oil and that emit no more than 50 tons of NOx annually ( or, at the source's election, 25 tons per ozone season) and that calculate no more than the same amount based on specified procedures for calculating and reporting emissions. Qualifying utilities are not required to keep monitoring equipment installed on ( or conduct 23 fuel sampling for) low mass emissions units, nor are they required to perform quality assurance or quality control tests. Moreover, emissions reporting requirements are significantly simplified for these units.

The second exception provides an exemption for units that restrict NOx mass emissions to less than 25 tons during the ozone season. To be eligible, the unit must accept a federally enforceable operating hour permit limit. The unit would calculate the operating hour restriction by dividing 25 tons by the unit's maximum potential hourly NOx mass emissions.

Even if a gas or oil fired unit does not qualify for the " low mass emissions unit" exception, the monitoring provisions of Part 75 do allow for the use of alternative methods to determine emissions. As discussed in the Regulatory Impact Analysis ( RIA) of the final Acid Rain Implementation Regulations ( October 19, 1992), smaller utilities are more likely to be dependent on these oil and gas fired units, especially very small utilities ( see p. 5 14 of that RIA document).

5( d) Collection Schedule Beginning for the inventory year 2003, the EPA is requiring States to annually submit ozone season inventories for all NOx sources for which States adopt control measures to meet their NOx budget. Every 3 years, starting for the inventory year 2002, statewide NOx inventories of all controlled and uncontrolled sources are required. This statewide inventory requirement also applies to the year 2007.

For all of the above reporting activities, the final rule specifies that States submit the appropriate emissions data within 12 months of the end of the inventory year ( e. g., a statewide NOx emissions inventory for the year 2005 would be required by December of 2006).

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6( a) Estimating Respondent Burden The State burden for complying with the reporting requirements under § 51.122 is estimated incremental to the burden associated with existing annual inventory and periodic inventory reporting requirements.

In general, States already have mechanisms in place for reporting emissions data to EPA. Under the existing annual point source inventory requirements, States are required to submit the emissions data specified in Section 4( b)( i) of this supporting statement ( excluding the incremental data elements identified). Since most of the data which the States are required to update for point sources ( area codes, addresses, or other physical parameters) do not change often, the updating of more than 24 90 percent of all source records is minimal and typically involves only changes in emissions and closely related information ( fuel usage, process rates, seasonal throughput, etc.).

Other ongoing State activities that support existing inventory reporting requirements include:

° Collecting emissions data and other associated information; ° Quality assuring emissions data; ° Training staff in coding and submissions techniques; ° Creating information ( e. g., assigning EPA codes to State point source records); ° Resolution of errors and anomalies identified by EPA; ° Maintaining records associated with data submitted by sources; and ° Preparing and submitting required inventory data items in approvable format.

Under the existing periodic inventory, States with ozone nonattainment areas ( or in the ozone transport region) must report triennially to EPA area, nonroad mobile, and highway mobile source emissions for the nonattainment areas. For the final rule, EPA is requiring that States report statewide area, nonroad mobile, and highway mobile source ozone season emissions every year if the State adopts control measures for these sources specifically for the purpose of meeting the NOx budget. This could be an incremental burden to States each year. However, no burden was estimated for States to annually report area, nonroad mobile, or highway mobile source emissions to EPA for years that do not coincide with the existing 3 year cycle inventory. This is because OTAG modeling results indicate that States will most likely control large stationary NOx emission sources rather than area, nonroad mobile, or highway mobile emission sources to meet their NOx budgets.

One time activities The time for States to read and interpret the reporting requirements of the § 51.122 rule was estimated to be 1 hour for technical staff and 1 hour for managerial staff. The time required for preparing and submitting example ozone season emissions calculations to EPA would vary, depending on the complexity of the calculations. States that estimate seasonal emissions by applying a factor of 5/ 12' s to their annual emissions inventory can complete this task in minimal time. States that account for factors such as changes in activity levels or fuels would require more time. On average, it was estimated to take 10 hours for technical staff and 0.5 hour for managerial staff. Another one time activity involves a State modifying its emissions data bases to incorporate 7 additional data items for point sources, 5 additional data items for area sources, and 4 additional data items for highway and nonroad mobile sources. Technical staff time to perform this activity was estimated to be 60 hours, and managerial staff time was estimated to be 3 hours.

A one time effort is expected for the States to establish procedures to estimate statewide ozone season NOx emissions from stationary area sources. Area source NOx emissions in the OTAG 25 inventory are due to stationary fuel combustion, incineration and open burning, and wildfires and prescribed burning. It is assumed that States would develop a spreadsheet or data base containing county level activity indicators ( e. g., population, employment, forest acreage) to allocate activity data typically available at the State level to the county level. It will also be necessary to account for any controls or seasonal restrictions that would impact NOx emissions. The average respondent time to develop the procedures to predict county level area source NOx emissions for an entire State was estimated to be 80 hours of technical staff time and 4 hours of managerial staff time.

For highway mobile sources, it will be necessary for States to prepare a procedure for estimating county level VMT as input to EPA's MOBILE model. It was assumed that States will distribute statewide VMT available from the Federal Highway Administration's ( FHWA) Highway Performance Monitoring System ( HPMS) to the county level using a surrogate activity indicator such as population. In addition, any highway mobile source controls applicable to a county must be identified and accounted for in the emission estimates for a county. The one time burden for performing these activities was estimated to take 40 technical hours and 2 managerial hours.

States must prepare and submit a statewide ozone season NOx emissions inventory of all controlled and uncontrolled sources for the year 2007. A 2007 statewide ozone season NOx emissions inventory for all point, area, nonroad mobile, and highway mobile sources is required to allow evaluation of whether the NOx budgets are met for the year 2007. This one time special inventory is necessary because the scheduled 3 year reporting cycle does not fall in the year 2007. States which must submit the 2007 inventory may project incremental changes in emissions from 2007 to 2008 to allow the 2008 inventory requirement to be more easily met and to reduce the burden on States which must submit full NOx inventories in consecutive years ( i. e., 2007 and 2008). The burden associated with projecting the area, nonroad mobile, and highway mobile source 2007 inventories to 2008 is accounted for in this ICR and is estimated to be 8 hours of technical staff time, and 0.4 hour of managerial staff time per State. No burden is estimated for point source inventory preparation since it is already collected annually.

Lastly, the burden for a State to review a Title V permit revision submitted by controlled sources was estimated to be 0.8 hours of technical staff ( i. e., 4 hours annualized over the 5 year permit cycle).

Annual Activities Annual State burden items associated with this ICR are as follows. States must notify the appropriate EPA Regional Office when submitting an annual, triennial, and 2007 NOx inventory. This activity was estimated to take 0.5 hour per year for managerial staff. An additional 0.5 hour per year was estimated for technical staff to prepare and submit an electronic NOx emissions budget report. Most of the data collection activities associated with the annual inventory are already being done to meet existing inventory requirements. However, there is additional burden associated with compiling 5EPA's NONROAD model is currently under development by EPA's Office of Mobile Sources ( OMS). A final version of the model is expected to be in use by States by 2003.

6These estimates are based on a State using MOBILE6, which will be the next version of EPA's MOBILE model.

26 and quality assuring the ozone season inventory. The additional annual burden for this activity was estimated to be 16 hours per year for technical staff and 0.8 hours per year for managerial staff.

Triennial Activities Every 3 years, States are required to submit ozone season emissions data for all point, area, nonroad mobile, and highway mobile sources of NOx within the State. States are already submitting a statewide emissions inventory of all point sources under the existing annual inventory requirements. However, a burden is expected for States to develop statewide NOx stationary area source, nonroad mobile source, and highway mobile source inventories every 3 years. Under the existing periodic SIP inventory requirements, emissions from these sectors were only determined for ozone nonattainment area counties. The incremental burden for developing statewide ozone season inventories for all controlled and uncontrolled sources consists of the following activities:

C For stationary area sources, collecting activity data needed to allocate State level activity data to the county level and estimating area source emissions; ( 160 technical hours; 8 managerial hours);

C For nonroad mobile sources, estimating emissions according to EPA's NONROAD emission inventory model5 ( 240 technical hours; 12 managerial hours); and C For highway mobile sources, estimating emissions using EPA's MOBILE model6 ( 120 technical hours; 10 managerial hours).

The above hour estimates also account for generating and quality assuring ozone season emissions. For the highway mobile source inventory, beginning in the year 2003, the recurrent burden hours every 3 years will include 40 hours of technical staff time to perform the VMT calculations. Thus, the burden for performing all the necessary steps to generate the 2002 highway mobile source inventory in 2003 is assumed to be 120 hours ( i. e., 40 + 80 hours).

States must compile a summary report of statewide NOx emissions for submittal to EPA. A small burden was estimated for States to account for sources that have been reporting directly to EPA annually using a different reporting format ( e. g., EDR format for Part 75). An additional 3 hours ( 1 for managerial, 2 for technical staff) was estimated to be the time needed for a State to request source 27 submitted data from EPA and merge these emissions data into a consistent format for the required triennial report.

Burden calculations Burden hours and associated costs were estimated for the first period that the affected States may start reporting emissions data to EPA. In this case, that period corresponds to the year 2002 ( States would have to begin reporting data for the year 2002 within 12 months of the end of 2002, however it is possible, if not likely, that a State could report by the end of year 2002..) Tables 6 1, 6 2, and 6 3 presents the annual State burden hours and costs by activity for the 2000 2002 time period. Tables 6 4, 6 5 and 6 6 present the annual industry burden hours and costs by activity for the 2000 2002 time period.

Emissions Trading Program This section estimates the paperwork burden and cost of submitting permit applications, allowance tracking and transfer materials ( including applications for early reduction credits), year end compliance certifications, submittal of monitoring plans, obtaining certification of each monitoring system, conducting monitor quality assurance activities, and recording and reporting data from CEM systems ( or approved alternatives).

To estimate the burden and/ or cost of each incidence of the various proposed rule revisions, EPA had available prior estimates of the costs of various activities, estimates provided by affected utilities in comments to the Agency, and estimates based on the Agency's experience in implementing the existing trading programs. In addition, the hourly labor rates for managerial, technical and clerical staff reflect the labor rates used in the existing Acid Rain program ICR but updated to 1998 dollars using the Employment Cost Index, consistent with Agency ICR guidance.

For the purposes of this analysis, the trading sources are grouped into the following categories:

C Trading units subject to Title IV Acid Rain monitoring requirements ( 40 CFR Part 75) that are located in the Ozone Transport Commission ( OTC) region (" AR OTC"); C Trading units subject to Title IV monitoring requirements that are not located in the OTC region (" AR NOTC"); C Trading units not subject to Title IV monitoring requirements that are located in the OTC region (" NAR OTC"); and C Trading units not subject to Title IV monitoring requirements that are not located in the OTC region (" NAR NOTC")

The NOx Trading Program requires all affected sources to install a NOx emission rate ( or concentration) CEM and a flow CEM ( or approved alternative). Affected gas and oil fired units may 28 elect to use a NOx emissions rate CEM and a fuel flowmeter. In addition, peaking units that burn natural gas and/ or fuel oil may use an alternative method for calculating NOx emission rates. EPA will also allow certain low mass emissions units to use assumed emissions factors together with operational data to calculate emissions.

The OTC NOx Budget Program is a regionwide cap and trade program that targets utility and large industrial combustion sources to facilitate NOx emissions reductions in the OTC region. The OTC States include Maine, New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island, New York, New Jersey, Pennsylvania, Maryland, Delaware, and DC. For purposes of this ICR, it is important that the burdens and costs be calculated only in terms of incremental impacts for units located in these states. Similarly, non OTC states have existing requirements for CEMS in some cases that a unit will already be subject to. Thus, it should be noted that the labor hour and cost estimates per unit identified in this document, represent the weighted average burden and cost for all units and do not represent the actual burden and cost for a particular unit.

The following discussion highlights some of the basic differences for the four basic categories of units:

For AR OTC units, EPA believes that the only labor burdens will be associated with permit applications, certain allowance transactions, and applications for early election credits. These units will not incur additional burdens ( or capital and operating and maintenance costs) as a result of the NOx SIP call rule since they have already installed and are operating a CEMS ( or approved alternative) meeting Part 75 Subpart H specifications. However, AR NOTC units will likely require minor upgrades to their data acquisition and handling system ( DAHS). In addition, a few AR NOTC units with complex stack situations may need to reconfigure their Title IV approved monitoring systems under Part 75. Therefore, this ICR reflects some incremental monitoring costs for these sources.

For NAR OTC units, EPA believes that each unit will incur labor burdens associated with permit applications, certain allowance transactions, and applications for early election credits. In addition, some NAR OTC units are expected to have to install new flow CEMS to meet Part 75 Subpart H requirements. As a result, these units will incur additional capital and other operating costs. The additional labor burdens associated with flow CEMS quality assurance activities are offset by the fact that the unit will not be required to conduct the quality assurance activities for the flow monitoring alternative used under the OTC program. Finally, a large number of NAR OTC units are expected to incur some costs associated with upgrading the DAHS.

For NAR NOTC units, the respondents will incur the labor burdens and other costs for all of the activities associated with the NOx Trading Program. The costs will vary depending on what monitoring alternative is appropriate for the unit and what monitoring requirements apply to the unit under other regulatory programs. 29 Also, as discussed in section ( 1), the Agency anticipates a split in compliance dates, with 435 sources opting to be in the early election program ( beginning in 2000), and the remaining sources becoming subject to the trading rule in 2002. Note that some early election units are in the Acid Rain Program or OTC region, and will therefore incur additional costs under the trading rule only for permit applications, certain allowance transactions, and applications for early election credits. This ICR reflects the varying number of respondents through the 2000 2002 period.

The primary tasks performed by owners and operators of affected units are ( 1) permitting, ( 2) monitoring, recording, and reporting emissions data, ( 3) allowance trading activities and ( 4) submittal of the year end compliance certification.

( i) Permitting.

Each affected entity will have to submit a permit revision application to include in the source's Title V permit the necessary conditions related to compliance with the NOx Trading Program. The Agency believes that this application should be relatively routine, and that a standard method of incorporating the requirements by reference or a standard set of permit conditions will be available. The Agency estimates that, on a per unit basis, about 4 managerial hours will be required to revise the Title V permit, and that half of the revisions will occur in 2001, and half in 2002.

Some sources will also be required to construct additional facilities, and therefore will need to complete a permit to construct application. The Agency estimates that this requirement will be necessary for all coal fired units that are not in the Acid Rain Program or in the OTC and that the task will take 20 hours of managerial and 20 hours of technician time, per permit. These burden estimates are consistent with the average burden for a minor New Source Review permit application used in the ICR for the New Source Review program under Title 1 of the Act ( EPA ICR No. 1230.09).

( ii) Monitoring.

For monitoring, the burdens differ greatly based on the amount and type of monitoring the unit is already subject to and the particular subtask of monitoring being conducted. Note that in most cases, burdens will not be incurred until 2002. The exception is early election units, which will generally begin incurring burdens in 2000. The specific elements of burden are:

Start up Activities. A large part of start up activities involves capital and test contractor costs. However, the owner or operator will incur some labor burden for these activities, as applicable. For AR OTC units, the program imposes no start up burdens beyond existing programs. For ARNOTC units, the owner or operator will incur some small amount of burden associated with DAHS or ( in a small percent of circumstances) CEMS upgrade activities. For NAR OTC units, EPA estimates that a number of units will have to install a flow CEMS and that all of the units will have to arrange for a 30 DAHS upgrade. For the NAR NOTC units, the burdens reflect burdens for arranging for CEMS purchase ( as required) and oversight of the certification process.

Regulatory Review. The ICR includes an allocation of time for the managerial and technical staff to review the regulatory requirements and the EDR formats and instructions. The NAR NOTC units will have a burden similar to that estimated for Acid Rain Program units in the Acid Rain Program ICR  24 hours of managerial time and 24 hours of technician time in year one of the program and 4 hours each for managerial and technician time, per year, after year one. The burden estimates for NAR OTC units is reduced because of the similar OTC requirements. The estimates for these units are 5 hours of managerial time and 5 hours of technician time in year one and 1 hour each per year after year one.

Response to Error Messages. The Agency provides feedback to affected sources for errors that are found in monitoring plans or other reports. The Agency estimates that for each NARNOTC unit, an owner or operator will spend approximately 4 hours of managerial time and 8 hours of technician time responding to these error messages each year.

DAHS Debugging. Based on experience with the Acid Rain Program, some effort will be involved to fix problems with the DAHS software used to report in the EDR formats. This burden is assumed to fall primarily on units that are not affected under either the Acid Rain or OTC programs. Consistent with the existing Part 75 ICR, the Agency estimates that about 16 managerial and 88 technician hours will be spent on this task in the first year of implementation, and then 4 managerial and 12 technician hours will be required in the second and subsequent years of implementation.

Monitoring Plans. The regulations require submittal of monitoring plans. Because most of the monitoring plan elements are now part of the EDR format, the effort involved in developing and maintaining the plans are incorporated into the overall reporting burden estimate.

Monitor Certification/ Recertification. Initial certification burdens and costs for new monitoring equipment are addressed above under start up activities since these costs are often part of the overall purchase expense for the equipment. For some NAR NOTC units, however, there will be burdens associated with certifying existing monitors used under other programs for this program, as well as burdens for recertification to the extent a change in a monitoring system requires recertification. EPA estimates that approximately 10% of all units will have to recertify each year following the year in which the initial certification occurs. For this initial ICR, the only units that will incur recertification costs are a portion of the early election units. The ICR incorporates a labor burden estimate generally consistent with existing Agency models for the labor burdens associated with certification. However, note that the ICR reduces the labor hours for this activity to avoid double counting hours that are already accounted for in the quality assurance activity area ( see the following subsection below). The double counting would occur because a portion of the labor incurred for the certification or recertification event replaces 31 the labor burden that is generally allocated to the annual relative accuracy test audit ( RATA) in the year in which the certification event occurs.

Quality Assurance. Quality assurance ( QA) activities and other routine maintenance for monitoring systems is the largest burden item under the NOx Trading Program. These requirements generally include daily, quarterly and annual QA requirements, depending on the monitoring approach being used. For reporting units that use a CEMS, the Agency has assumed a per unit labor burden based on a variety of sources, including the existing Acid Rain Program ICR, information provided by Acid Rain Program sources, a CEM cost model developed by EPA, and comments submitted in response to the section 110 SIP Call for ozone transport. For units that rely on alternative methodologies, reduced labor burden estimates apply because the quality assurance activities for the excepted methods are less than for a CEMS. The labor burdens for these excepted methods were derived primarily from cost estimates provided by a group of affected utilities ( see Docket A 97 35, Item II D 48). Consistent with the existing Acid Rain Program ICR, the labor burden is expected to be almost entirely technician labor.

Quarterly Reports. Tasks performed by utilities in preparing quarterly reports include: ( 1) assuring the quality of the data, ( 2) preparing the quarterly report, ( 3) revising the monitoring plan, if necessary, ( 4) preparation of hard copy documentation accompanying the quarterly reports, and managerial review. The existing Acid Rain program ICR was used as the basis for these estimates, with some reduction in burden because the NOx Trading Program involves only NOx emissions.

Fuel Sampling. To calculate heat input where the source is using the fuel flowmeter option for an oil or gas fired unit, the source must obtain gross calorific value data from sampling in accordance with Appendix D of Part 75. For purposes of this ICR, it is assumed that the GCV data would be collected as part of standard business operating procedures to assure compliance with contractual specifications. Thus no additional fuel sampling burdens or costs should be incurred.

( iii) Year end compliance certification.

Each owner or operator will have to submit an annual compliance certification report. The compliance certification is anticipated to take about two managerial hours per unit.

( iv) Allowance transaction activities.

The Agency anticipates the total number of allowance transactions will be 2,602, 2,651, and 2,910 for the years 2000 2002, respectively. Those numbers are based first on the assumption that there will be an allowance allocation transaction for each unit in each year. Second, each early election unit will have an additional allocation transaction in 2001 and 2002. Finally, some percentage of all NAR NOTC units will likely conduct transactions in each year solely as a result of this program. The 32 Agency has estimated that 12.5% of these units will do so in 2000 and 2001, and 25% of these units will do so in 2002.

The Agency believes that each transaction will involve about 1 hour each of managerial and technician time.

( v) Application for Early Reduction Credits Sources that opted into the early election program will be eligible to receive early election credits beginning in 2001. The Agency estimates that completion of the annual application to receive the credits will take 8 labor hours per year, split between managerial and technician time. This burden will be incurred by all 435 early election units, and only in 2001 and 2002.

6( b) Estimating Respondent Costs Tables 6 4, 6 5, and 6 6 summarize the annual respondent costs. The following discussion describes how those costs were derived.

( i) Estimating Labor Costs For this ICR, the labor rate for technical staff at State agencies was assumed to be $ 25.73 per hour. This is consistent with the technical labor rate used for the ICR for the annual inventory ( OMB # 2060 0088). Hours assumed for managerial staff were multiplied by $ 40.00 per hour. This labor rate was derived from the federal government's 1998 General Schedule published by the U. S. Office of Personnel Management. The rate corresponds to a GS 13, Step 1 labor rate ($ 25.00 per hour) multiplied by a factor of 1.6 to account for benefits provided to workers.

In estimation of industry labor costs, EPA used the following amounts: $ 66.05 per hour for managers and $ 45.44 per hour for technicians. These rates were derived by updating the labor rates used in the existing Acid Rain Program ICR to 1998 dollars.

Federal Agency labor rates were assumed to be $ 40.00 per hour. This labor rate was derived from the federal government's 1998 General Schedule published by the U. S. Office of Personnel Management. The rate corresponds to a GS 13, Step 1 labor rate ($ 25.00 per hour) multiplied by a factor of 1.6 to account for benefits provided to workers.

( ii) Estimating Total Capital and Annual Operations and Maintenance Costs Capital/ start up costs include the cost of installing required CEMS or alternatives. Operation and maintenance costs ( exclusive of labor costs) reflect ongoing costs to a unit and include both contractor costs for the required recertification, diagnostic, and quality assurance ( QA) testing, and other direct 33 maintenance related expenses ( e. g., spare parts and calibration gases). These cost estimates have been derived from EPA CEM cost models, existing ICRs, Agency staff experience under the Acid Rain program, and supplemental estimates provided by affected utilities and others related to the various cost items ( see, e. g., EPA Air Dockets A 96 56 V H 93 and A 97 35, Item II D 48).

The AR OTC units are not expected to incur any non labor costs associated with this program. The total non labor cost for capital/ start up items is estimated at $ 2,500 to $ 5,000 per unit for most AR NOTC units ( to account for a DAHS upgrade), although approximately 1 percent of the units are also expected to need a CEMS upgrade of approximately $ 50,000. For NAR OTC units, most units will require only a DAHS upgrade, estimated at $ 5,000$ 10,000 per unit. However, EPA estimates that approximately one half of the coal fired NAR OTC units will also need to install a new flow CEMS at an estimated cost of $ 73,000 ( inclusive of DAHS upgrade). For NAR NOTC units, the Appendix E/ fuel flowmeter units are expected to incur only DAHS costs, while the other units will require some combination of a NOx, diluent and/ or flow CEMS. The costs for these units ranges from $ 25,000 to $ 270,000. The variance is due to the monitoring methodology used and what monitoring equipment may already be in place at the unit.

Note that testing contractor costs for certification, recertification and annual relative accuracy test audits ( RATAs) are presented as other direct costs and are not converted to equivalent source labor hours. This approach is consistent with the common business practice for obtaining outside contractors to conduct certification/ recertification tests and annual RATAs. For initial certification, the certification test costs are commonly bundled with equipment purchase contracts, according to information provided by a range of CEMS equipment vendors. For RATAs that are conducted either as part of the annual quality assurance requirements or as part of recertification, industry contacts have indicated that RATA testing is usually performed under a fixed price contract basis, except for travel costs that may be billed on an hourly basis beyond the basic contract cost. For annual RATAs, the sources indicated that an annual contract between a testing company and utility is often used. One municipal utility indicated that the applicable municipal regulations required that outside contracts be on a flat fee, not hourly, basis.

The Agency also notes that this ICR does not include a cost for the purchase of monitoring equipment for all affected units. Many sources covered by the NOx Trading Program are already required to have CEMS under other regulatory programs. Therefore, to the extent that no new equipment is needed by these sources, capital costs are not included because those costs were included in the ICRs of those other programs. Thus, the capital and other costs included in Table 6 1, above, represent weighted average costs for each respondent, not the total individual cost for any particular respondent.

( iii) Capital/ Start up vs. Operating and Maintenance ( O & M) Costs Capital costs reflect one time costs for purchase of equipment which will be used over a period of years. Conversely, operating and maintenance costs are those costs which are incurred on an annual or 34 other scheduled basis. For instance, costs associated with quality assurance activities, such as spare parts or contractor costs for work, will be incurred on an annual basis.

( iv) Annualizing Capital Costs The relevant capital costs for this ICR were annualized at a rate of 7%. The annualized cost of the necessary capital purchases varies from $ 400 to $ 29,600, per year, per source, depending on the type of monitoring methodology. Tables 6 5, 6 6, and 6 7 contains a breakdown of annual costs by monitoring methodology.

6( c) Estimating Agency Burden and Cost The Agency activities associated with the final rule § 51.122 will only slightly increase the burden of the activities that EPA is already performing to manage emissions data to evaluate compliance of States with their ozone SIPs, and to evaluate compliance of emission sources already reporting to EPA under the acid rain provisions of 40 CFR Part 75. The EPA will use its existing emission inventory reporting mechanisms and staff to handle the emissions data submitted to comply with the reporting requirements of the final rule. For example, EPA assisted OTAG in compiling emissions inventory data for all 37 OTAG States and the District of Columbia in preparing the base year and projection year emission inventories that were used to establish the NOx emission budgets for the 22 States that will be subject to the rule. In so doing, EPA already has experience in interacting with the 22 States to transfer emission inventory data bases and has resolved difficulties associated with electronic submittals of emission inventory data. Finally, EPA is already providing States with data reported directly by point sources to EPA. Thus, EPA does not anticipate any additional burden associated with providing States with directly reported point source emissions data which States will need to prepare their summary report of statewide NOx emissions every 3 years.

Emissions Trading Program The primary burdens for EPA associated with the implementation of the trading program are related to reviewing permits, certifying monitors, tracking allowances and emissions and certifying end of year compliance. Table 6 8 summarizes the Agency burden and costs associated with administering the emission trading program for the NOx SIP call States, as well as for processing emissions reported under § 51.122.

6( d) Estimating the Respondent Universe and Total Burden and Costs The number of State respondents is estimated to be 22 jurisdictions, including 21 States and the District of Columbia.. The number of industry respondents varies depending on the activity in question. Activities such as title V permit application or precessing allowance transfers can involve over two thousand sources. The number of sources which will be required to install a particular type of 35 monitoring equipment will be less since many sources already have monitoring equipment especially if they are in the Ozone Transport Commission region. Tables 6 2, 6 3, and 6 4 give estimates of State burden. These burdens include preparation of the SIP revision in response to the NOx SIP call, activities associated with participating in an emissions trading program, and reporting information to EPA under § 51.122 . Tables 6 5, 6 6, and 6 7 give estimates of industry burden. This burden includes monitoring, reporting and other activities involved in participating in an emissions trading program. The total average number of respondents is estimated to be 2,831.

6( e) Bottom Line Burden Hours and Cost Tables ( i) Respondent Tally Table 6 1 summarizes the aggregate burden and cost estimates to respondents from 2000 through 2002 for collections associated with implementation of the NOx SIP call. This burden includes burden on States and industry to comply with requirements imposed by the SIP call. The total burden for 2000, 2001, and 2002 is 106,141 hours, 84,252 hours, and 663,846 hours respectively. This gives an average burden for the three years of 284,746 hours. Since the burden varies by year during the startup period, the burden reported on the form OMB 83 I ( item 13) is the average of the burden estimates for each of the years 2000, 2001, and 2002.

The total annualized capital/ start up cost for 2000, 2001 and 2002 is $ 3,657,090, $ 4,158, 712 and $ 19,234,700 respectively. This gives an average capital/ start up cost for the three years of $ 9,016,834. The total annual O& M cost for 2000, 2001 and 2002 is $ 2,486,400, $ 2,360,400, and $ 15,164,200 respectively. This gives an average O& M cost for the three years of $ 6,670,333.

( ii) The Agency Tally Table 6 8 summarizes the aggregate burden and cost estimates to EPA for monitoring certifications, audits, allowance tracking and collection, analysis, and storage of the emissions data under an emissions trading program. This table also estimates Agency burden for processing data reported by States under § 51.122. A burden estimate is made for the Agency review of the NOx SIP revision submissions from States in response to the NOx SIP call.

( iii) Variations in the Annual Bottom Line There is a substantial amount of variation in the years 2000 2002 because of the delayed compliance date and the early election program. Because only a small perentage of total units will be incurring burdens and costs in 2000 and 2001 for most required activities, the total cost/ burden rises steeply in 2002. After the program is fully implemented, annual burdens and costs are expected to have reduced variation. For the core units in the NOx Trading Program, the costs and burdens in 2002 are expected to see the highest burdens and costs because of several one time activities required near 36 the start of the program. After 2002, the burdens associated with permit applications and start up for new monitoring or DAHS equipment will cease, and the burdens associated with reviewing regulatory requirements and debugging computer software should drop sharply. The expected reduction in burden in 2003 from these activities will be approximately 140,000 hours, or over 20% of the total burden in 2002.

6( f) Reasons for Change in Burden Not applicable since this is a new ICR.

6( g) Burden Statement 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 time required to comply with this information collection is estimated to average 284,746 hours per year over the next three years. Table 6 1. Total Estimated Respondent Burden and Cost Summary, 2000  2002 Number of Respondents Number of Activities Total Hours per Year Total Labor Costs per Year Total Annual Capital Costs Total Annual O& M Costs Total Annual Costs 2000 State Respondents 22 110 4,158 $ 115,148 $ 11,990 $ 0 $ 127,138 Industry Respondents 2,415 3,558 101,983 $ 5,213,475 $ 3,645,100 $ 2,486,400 $ 11,344,975 Total 2,437 3,668 106,141 $ 5,328,623 $ 3,657,090 $ 2,486,400 $ 11,472,113 2001 State Respondents 22 44 2,090 $ 55,659 $ 513,612 $ 0 $ 569,271 Industry Respondents 2,850 5,539 82,162 $ 4,171,507 $ 3,645,100 $ 2,360,400 $ 10,177,007 Total 2,872 5,583 84,252 $ 4,227,166 $ 4,158,712 $ 2,360,400 $ 10,746,278 2002 State Respondents 22 418 38,830 $ 1,026,292 $ 0 $ 0 $ 1,028,292 Industry Respondents 3,163 14,553 625,016 $ 31,109,025 $ 19,234,700 $ 15,164,200 $ 65,509,925 Total 3,185 14,971 663,846 $ 32,137,317 $ 19,234,700 $ 15,164,200 $ 66,538,217 The burden calculated in this table is for NOx SIP call as published in the final rule October 27, 1998 minus the State of Wisconsin . Table 6 2 Annual State Respondent Burden and Cost by Activity for Trading Program, 2000 Annualized Mgr. Tech. Capital/ Total Total Total $ 40.00 $ 25.73 Respondent Labor Startup Number Labor Labor Capital Total / Hour / Hour Hours/ Year Cost/ Year Costs of hrs/ yr cost/ yr cost/ year Cost/ Year Information Collection Activity 2000 2000 2000 2000 2000 Respondents 2000 2000 2000 2000 State Trading Program Activities Read regulations 16 16 32 $ 1,052 $ 0 22 704 $ 23,137 $ 0 $ 23,137 Monitoring certifications AR OTC 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 AR NOTC 1 10 11 $ 297 $ 0 22 242 $ 6,541 $ 0 $ 6,541 NAR OTC 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 NAR NOTC 3 48 51 $ 1,355 $ 0 22 1,122 $ 29,811 $ 0 $ 29,811 Annual auditing costs 5 88 93 $ 2,464 $ 545 22 2,046 $ 54,213 $ 11,990 $ 66,203 Subtotal 4,114 $ 113,702 $ 11,990 $ 125,692 Information Collection Activities for § 51.122 One time Read the reporting requirements of the rule 1 1 2 $ 66 $ 0 22 44 $ 1,446 $ 0 $ 1,446 Submit example ozone season emissions calculations to EPA [ § 51.122( g)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Modify point, area, nonroad mobile, and highway mobile source data bases to add data fields for additional data items [ § 51/ 122( c). ( d), ( e)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Develop procedures by which to estimate area source NOx emissions for triennial statewide reporting requirements [ § 51.122( b)( 2),( 3)] 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Develop procedure for generating county level vehicle miles traveled ( VMT) [ § 51.

122( b)( 2),( 3)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Project 2007area nonroad mobile, and highway mobile source inventories to 2008 to satisfy 3 year cycle requirement [ § 51.122( b)( 2),( 3)] 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Review Title V permit revisions from controlled sources [ § 51/ 121( h)( 1)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Annual Determine ozone season emissions for controlled sources [ § 51.122( c)( 1).( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Notify the apppropriate EPA Regional Office when submitting annual, triennial,

and 2007 NOx inventory [ § 51/ 122( h)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Submit electronic NOx budget emissions report [ § 51.122( b)( 1)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Triennial Prepare statewide ozone season inventory for area nonroad mobile, and highway mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Prepare statewide ozone season inventory for nonroad mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Prepare statewide ozone season inventory for highway mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Compile summary report of statewide ozone season NOx emissions and account for sources that have been reporting directly to EPA [ § 51.122( b)( 2),( h)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Subtotal 44 $ 1,446 $ 0 $ 1,446 TOTAL 4,158 $ 115,148 $ 11,990 $ 127,138 Table 6 3. Annual State Respondent Burden and Cost by Activity , 2001 Annualized Mgr. Tech. Capital/ Total Total Total $ 40.00 $ 25.73 Respondent Labor Startup Number Labor Labor Capital Total / Hour / Hour Hours/ Year Cost/ Year Costs of hrs/ yr cost/ yr cost/ year Cost/ Year Information Collection Activity 2001 2001 2001 2001 2001 Respondents 2001 2001 2001 2001 State Trading Program Activities Read regulations 1 1 2 $ 66 $ 0 22 44 $ 1,446 $ 0 $ 1,446 Monitoring certifications AR OTC 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 AR NOTC 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 NAR OTC 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 NAR NOTC 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Annual auditing costs 5 88 93 $ 2,464 $ 23,346 22 2,046 $ 54,213 $ 513,612 $ 567,825 Subtotal 2,090 $ 55,659 $ 513,612 $ 569,271 Information Collection Activities for § 51.122 One time Read the reporting requirements of the rule 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Submit example ozone season emissions calculations to EPA [ § 51.122( g)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Modify point, area, nonroad mobile, and highway mobile source data bases to add data fields for additional data items [ § 51/ 122( c). ( d), ( e)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Develop procedures by which to estimate area source NOx emissions for triennial statewide reporting requirements [ § 51.122( b)( 2),( 3)] 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Develop procedure for generating county level vehicle miles traveled ( VMT) [ § 51.

122( b)( 2),( 3)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Project 2007area nonroad mobile, and highway mobile source inventories to 2008 to satisfy 3 year cycle requirement [ § 51.122( b)( 2),( 3)] 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Review Title V permit revisions from controlled sources [ § 51/ 121( h)( 1)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Annual Determine ozone season emissions for controlled sources [ § 51.122( c)( 1).( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Notify the apppropriate EPA Regional Office when submitting annual, triennial, and 2007 NOx inventory [ § 51/ 122( h)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Submit electronic NOx budget emissions report [ § 51.122( b)( 1)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Triennial Prepare statewide ozone season inventory for area nonroad mobile, and highway mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Prepare statewide ozone season inventory for nonroad mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Prepare statewide ozone season inventory for highway mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Compile summary report of statewide ozone season NOx emissions and account for sources that have been reporting directly to EPA [ § 51.122( b)( 2),( h)] 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Subtotal 0 $ 0 $ 0 $ 0 TOTAL 2,090 $ 55,659 $ 513,612 $ 569,271 Table 6 4. Annual State Respondent Burden and Cost by Activity , 2002 Annualized Mgr. Tech. Capital/ Total Total Total $ 40.00 $ 25.73 Respondent Labor Startup Number Labor Labor Capital Total / Hour / Hour Hours/ Year Cost/ Year Costs of hrs/ yr cost/ yr cost/ year Cost/ Year Information Collection Activity 2002 2002 2002 2002 2002 Respondents 2002 2002 2002 2002 State Trading Program Activities Read regulations 1 1 2 $ 66 $ 0 22 44 $ 1,446 $ 0 $ 1,446 Monitoring certifications AR OTC 1 13 14 $ 374 $ 0 22 308 $ 8,239 $ 0 $ 8,239 AR NOTC 2 25 27 $ 723 $ 0 22 594 $ 15,912 $ 0 $ 15,912 NAR OTC 1 18 19 $ 503 $ 0 22 418 $ 11,069 $ 0 $ 11,069 NAR NOTC 14 269 283 $ 7,481 $ 0 22 6,226 $ 164,590 $ 0 $ 164,590 Annual auditing costs 32 599 631 $ 16,692 $ 0 22 13,882 $ 367,230 $ 0 $ 367,230 Subtotal 21,472 $ 568,486 $ 0 $ 568,486 Information Collection Activities for § 51.122 One time Read the reporting requirements of the rule 0 0 0 $ 0 $ 0 22 0 $ 0 $ 0 $ 0 Submit example ozone season emissions calculations to EPA [ § 51.122( g)] 1 10 11 $ 297 $ 0 22 242 $ 6,541 $ 0 $ 6,541 Modify point, area, nonroad mobile, and highway mobile source data bases to add data fields for additional data items [ § 51/ 122( c). ( d), ( e)] 3 60 63 $ 1,664 $ 0 22 1,386 $ 36,604 $ 0 $ 36,604 Develop procedures by which to estimate area source NOx emissions for triennial statewide reporting requirements [ § 51.122( b)( 2),( 3)] 4 89 93 $ 2,450 $ 0 22 2,046 $ 53,899 $ 0 $ 53,899 Develop procedure for generating county level vehicle miles traveled ( VMT) [ § 51.

122( b)( 2),( 3)] 2 40 42 $ 1,109 $ 0 22 924 $ 24,402 $ 0 $ 24,402 Project 2007area nonroad mobile, and highway mobile source inventories to 2008 to satisfy 3 year cycle requirement [ § 51.122( b)( 2),( 3)] 1 8 9 $ 246 $ 0 22 198 $ 5,408 $ 0 $ 5,408 Review Title V permit revisions from controlled sources [ § 51/ 121( h)( 1)] 0 1 1 $ 26 $ 0 22 22 $ 566 $ 0 $ 566 Annual Determine ozone season emissions for controlled sources [ § 51.122( c)( 1).( 2)] 1 16 17 $ 452 $ 0 22 374 $ 9,937 $ 0 $ 9,937 Notify the apppropriate EPA Regional Office when submitting annual, triennial, and 2007 NOx inventory [ § 51/ 122( h)] 1 0 1 $ 40 $ 0 22 22 $ 880 $ 0 $ 880 Submit electronic NOx budget emissions report [ § 51.122( b)( 1)] 0 1 1 $ 26 $ 0 22 22 $ 566 $ 0 $ 566 Triennial Prepare statewide ozone season inventory for area nonroad mobile, and highway mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 8 160 168 $ 4,437 $ 0 22 3,696 $ 97,610 $ 0 $ 97,610 Prepare statewide ozone season inventory for nonroad mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 12 240 252 $ 6,655 $ 0 22 5,544 $ 146,414 $ 0 $ 146,414 Prepare statewide ozone season inventory for highway mobile sources, including a determination of ozone season emissions for all sources [ § 51.122( b)( 2)] 8 120 128 $ 3,408 $ 0 22 2,816 $ 74,967 $ 0 $ 74,967 Compile summary report of statewide ozone season NOx emissions and account for sources that have been reporting directly to EPA [ § 51.122( b)( 2),( h)] 1 2 3 $ 91 $ 0 22 66 $ 2,012 $ 0 $ 2,012 Subtotal 17,358 $ 459,807 $ 0 $ 459,807 TOTAL 38,830 $ 1,028,292 $ 0 $ 1,028,292 Table 6 5. Annual Industry Respondent Burden and Cost by Activity, 2000 Annualized Mgr. Tech. Capital/ Total $ 66.05 $ 45.44 Respondent Labor Startup O & M Number of Hours/ Total / Hour / Hour Hours/ Year Cost/ Year Costs Cost Respondents Year Cost/ Year Information Collection Activity 2000 2000 2000 2000 2000 2000 2000 2000 2000 Trading units Title V pemit application 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 Permit to Construct Application 20 20 40 $ 2,230 $ 0 $ 0 112 4,480 $ 249,738 Startup/ Capital Items ( Inc. initial cert. for new equip.)

1. AR NOTC a. NOx and Flow CEMS 3 6 9 $ 471 $ 800 $ 0 228 2,052 $ 289,740 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 700 $ 0 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 400 $ 0 0 0 $ 0 2. NAR OTC a. NOx and Flow CEMS 38 8 46 $ 2,873 $ 5,900 $ 0 25 1,150 $ 219,336 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 1,400 $ 0 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 700 $ 0 0 0 $ 0 3. NAR NOTC a. NOx and Flow CEMS 72 10 82 $ 5,210 $ 29,600 $ 0 112 9,184 $ 3,898,720 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 23,400 $ 0 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 3,600 $ 0 0 0 $ 0 EMISSIONS MONITORING Review Instructions and Requirements 1. NAR OTC 5 5 10 $ 557 $ 0 $ 0 25 250 $ 13,936 2. NAR NOTC 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 3. NAR NOTC ( Early Elec. Units) 24 24 48 $ 2,676 $ 0 $ 0 112 5,376 $ 299,685 Respond to EPA Generated Error Messages 1. NAR NOTC 0 9 9 $ 409 $ 0 $ 0 0 0 $ 0 2. NAR NOTC ( Early Elec. Units) 4 8 12 $ 628 $ 0 $ 0 112 1,344 $ 70,305 Debug Computer Software 1. NAR OTC 1 4 5 $ 248 $ 0 $ 0 25 125 $ 6,195 2. NAR NOTC 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 3. NAR NOTC ( Early Elec. Units) 16 88 104 $ 5,056 $ 0 $ 0 112 11,648 $ 566,218 Certify Existing monitors and App. E Methods/ Recertify Early Elec. Monitors 1. NAR NOTC a. NOx and Flow CEMS 0 0 0 $ 0 $ 0 $ 2,800 0 0 $ 0 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 0 $ 2,800 0 0 $ 0 c. App. E 0 0 0 $ 0 $ 0 $ 10,000 0 0 $ 0 2. NAR NOTC ( Early Elec. Units) 35 40 75 $ 4,129 $ 0 $ 2,800 56 4,200 $ 388,044 Peform QA Testing and Maintenance 1. NAR NOTC a. NOx and Flow CEMS 0 0 0 $ 0 $ 0 $ 20,800 0 0 $ 0 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 0 $ 17,400 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 0 $ 1,800 0 0 $ 0 2. NAR NOTC ( Early Elec. Units) 40 400 440 $ 20,818 $ 0 $ 20,800 112 49,280 $ 4,661,216 Assure Data Quality, Prepare Reports ( Inc. monitor plan update), Submit Reports 1. NAR NOTC 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 2. NAR NOTC ( Early Election Units) 20 52 72 $ 3,684 $ 0 $ 0 112 8,064 $ 412,595 Year End Compliance Certification 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 Table 6 5. Annual Industry Respondent Burden and Cost by Activity, 2000 Annualized Mgr. Tech. Capital/ Total $ 66.05 $ 45.44 Respondent Labor Startup O & M Number of Hours/ Total / Hour / Hour Hours/ Year Cost/ Year Costs Cost Respondents Year Cost/ Year Information Collection Activity 2000 2000 2000 2000 2000 2000 2000 2000 2000 Allowance Transfers 1 1 2 $ 111 $ 0 $ 0 2,415 4,830 $ 269,248 Application for Early Reduction Credits 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 Subtotal 101,983 $ 11,344,975 Non Trading rule units 1. Read the reporting requirements 0 0 0 $ 0 $ 0 $ 0 352 0 $ 0 2. Revise Title V operating permit 0 0 0 $ 0 $ 0 $ 0 352 0 $ 0 3. Perform NOx monitoring activities Cement Plants a. Annual testing 0 0 0 $ 0 $ 0 $ 0 57 0 $ 0 b. Prepare and submit reports, monitoring plan update 0 0 0 $ 0 $ 0 $ 0 57 0 $ 0 IC Engines a. Annual testing 0 0 0 $ 0 $ 0 $ 0 295 0 $ 0 b. Prepare and submit reports, monitoring plan update 0 0 0 $ 0 $ 0 $ 0 295 0 $ 0 Subtotal 0 $ 0 TOTAL 101,983 $ 11,344,975 Table 6 6. Annual Industry Respondent Burden and Cost by Activity, 2001 Annualized Mgr. Tech. Capital/ Total $ 66.05 $ 45.44 Respondent Labor Startup O & M Number of Hours/ Total / Hour / Hour Hours/ Year Cost/ Year Costs Cost Respondents Year Cost/ Year Information Collection Activity 2001 2001 2001 2001 2001 2001 2001 2001 2001 Trading units Title V pemit application 4 0 4 $ 264 $ 0 $ 0 1156 4,624 $ 305,415 Permit to Construct Application 20 20 40 $ 2,230 $ 0 $ 0 112 4,480 $ 249,738 Startup/ Capital Items ( Inc. initial cert. for new equip.)

1. AR NOTC a. NOx and Flow CEMS 0 0 0 $ 0 $ 800 $ 0 228 0 $ 182,400 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 700 $ 0 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 400 $ 0 0 0 $ 0 2. NAR OTC a. NOx and Flow CEMS 38 8 46 $ 2,873 $ 5,900 $ 0 25 1,150 $ 219,336 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 1,400 $ 0 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 700 $ 0 0 0 $ 0 3. NAR NOTC a. NOx and Flow CEMS 0 0 0 $ 0 $ 29,600 $ 0 112 0 $ 3,315,200 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 23,400 $ 0 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 3,600 $ 0 0 0 $ 0 EMISSIONS MONITORING Review Instructions and Requirements 1. NAR OTC 1 1 2 $ 111 $ 0 $ 0 25 50 $ 2,787 2. NAR NOTC 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 3. NAR NOTC ( Early Elec. Units) 4 4 8 $ 446 $ 0 $ 0 112 896 $ 49,948 Respond to EPA Generated Error Messages 1. NAR NOTC 0 0 0 $ 0 $ 0 0 0 $ 0 2. NAR NOTC ( Early Elec. Units) 4 8 12 $ 628 $ 0 $ 0 112 1,344 $ 70,305 Debug Computer Software 1. NAR OTC 1 4 5 $ 248 $ 0 $ 0 25 125 $ 6,195 2. NAR NOTC 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 3. NAR NOTC ( Early Elec. Units) 4 12 16 $ 809 $ 0 $ 0 112 1,792 $ 90,662 Certify Existing monitors and App. E Methods/ Recertify Early Elec. Monitors 1. NAR NOTC a. NOx and Flow CEMS 0 0 0 $ 0 $ 0 $ 2,800 0 0 $ 0 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 0 $ 2,800 0 0 $ 0 c. App. E 0 0 0 $ 0 $ 0 $ 10,000 0 0 $ 0 2. NAR NOTC ( Early Elec. Units) 35 40 75 $ 4,129 $ 0 $ 2,800 11 825 $ 76,223 Peform QA Testing and Maintenance 1. NAR NOTC a. NOx and Flow CEMS 0 0 0 $ 0 $ 0 $ 20,800 0 0 $ 0 b. NOx CEMS & Fuelmeter 0 0 0 $ 0 $ 0 $ 17,400 0 0 $ 0 c. App. E & Fuelmeter 0 0 0 $ 0 $ 0 $ 1,800 0 0 $ 0 2. NAR NOTC ( Early Elec. Units) 40 400 440 $ 20,818 $ 0 $ 20,800 112 49,280 $ 4,661,216 Table 6 6. Annual Industry Respondent Burden and Cost by Activity, 2001 Annualized Mgr. Tech. Capital/ Total $ 66.05 $ 45.44 Respondent Labor Startup O & M Number of Hours/ Total / Hour / Hour Hours/ Year Cost/ Year Costs Cost Respondents Year Cost/ Year Information Collection Activity 2001 2001 2001 2001 2001 2001 2001 2001 2001 Assure Data Quality, Prepare Reports ( Inc. monitor plan update), Submit Reports 1. NAR NOTC 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 2. NAR NOTC ( Early Election Units) 20 52 72 $ 3,684 $ 0 $ 0 112 8,064 $ 412,595 Year End Compliance Certification 0 0 0 $ 0 $ 0 $ 0 0 0 $ 0 Allowance Transfers 1 1 2 $ 111 $ 0 $ 0 2850 5,700 $ 317,747 Application for Early Reduction Credits 4 4 8 $ 446 $ 0 $ 0 435 3,480 $ 193,993 Subtotal 81,810 $ 10,153,757 Non Trading rule units 1. Read the reporting requirements 1 0 1 $ 66 $ 0 $ 0 352 352 $ 23,250 2. Revise Title V operating permit 0 0 0 $ 0 $ 0 $ 0 352 0 $ 0 3. Perform NOx monitoring activities Cement Plants a. Annual testing 0 0 0 $ 0 $ 0 $ 0 57 0 $ 0 b. Prepare and submit reports, monitoring plan update 0 0 0 $ 0 $ 0 $ 0 57 0 $ 0 IC Engines a. Annual testing 0 0 0 $ 0 $ 0 $ 0 295 0 $ 0 b. Prepare and submit reports, monitoring plan update 0 0 0 $ 0 $ 0 $ 0 295 0 $ 0 Subtotal 352 $ 23,250 TOTAL 82,162 $ 10,177,007 Table 6 7. Annual Industry Respondent Burden and Cost by Activity, 2002 Annualized Mgr. Tech. Capital/ Total $ 66.05 $ 45.44 Respondent Labor Startup O & M Number of Hours/ Total / Hour / Hour Hours/ Year Cost/ Year Costs Cost Respondents Year Cost/ Year Information Collection Activity 2002 2002 2002 2002 2002 2002 2002 2002 2002 Trading units Title V pemit application 4 0 4 $ 264 $ 0 $ 0 1157 4,628 $ 305,679 Permit to Construct Application 20 20 40 $ 2,230 $ 0 $ 0 111 4,440 $ 247,508 Startup/ Capital Items ( Inc. initial cert. for new equip.)

1. AR NOTC a. NOx and Flow CEMS 2 4 6 $ 314 $ 800 $ 0 573 3,438 $ 638,242 b. NOx CEMS & Fuelmeter 3 4 7 $ 380 $ 700 $ 0 16 112 $ 17,279 c. App. E & Fuelmeter 3 4 7 $ 380 $ 400 $ 0 98 686 $ 76,431 2. NAR OTC a. NOx and Flow CEMS 13 3 16 $ 995 $ 5,900 $ 0 75 1,200 $ 517,123 b. NOx CEMS & Fuelmeter 3 6 9 $ 471 $ 1,400 $ 0 251 2,259 $ 469,568 c. App. E & Fuelmeter 3 6 9 $ 471 $ 700 $ 0 86 774 $ 100,688 3. NAR NOTC a. NOx and Flow CEMS 24 3 27 $ 1,722 $ 29,600 $ 0 299 8,073 $ 9,365,134 b. NOx CEMS & Fuelmeter 64 10 74 $ 4,682 $ 23,400 $ 0 369 27,306 $ 10,362,110 c. App. E & Fuelmeter 20 10 30 $ 1,775 $ 3,600 $ 0 108 3,240 $ 580,543 EMISSIONS MONITORING Review Instructions and Requirements 1. NAR OTC 5 5 10 $ 557 $ 0 $ 0 412 4,120 $ 229,669 2. NAR NOTC 24 24 48 $ 2,676 $ 0 $ 0 664 31,872 $ 1,776,705 3. NAR NOTC ( Early Elec. Units) 4 4 8 $ 446 $ 0 $ 0 112 896 $ 49,948 Respond to EPA Generated Error Messages 1. NAR NOTC 4 8 12 $ 628 $ 0 $ 0 664 7,968 $ 416,806 2. NAR NOTC ( Early Elec. Units) 4 8 12 $ 628 $ 0 $ 0 112 1,344 $ 70,305 Debug Computer Software 1. NAR OTC 1 4 5 $ 248 $ 0 $ 0 412 2,060 $ 102,098 2. NAR NOTC 16 88 104 $ 5,056 $ 0 $ 0 664 69,056 $ 3,356,865 3. NAR NOTC ( Early Elec. Units) 4 12 16 $ 809 $ 0 $ 0 112 1,792 $ 90,662 Certify Existing monitors and App. E Methods/ Recertify Early Elec. Monitors 1. NAR NOTC a. NOx and Flow CEMS 32 10 42 $ 2,568 $ 0 $ 2,800 76 3,192 $ 407,968 b. NOx CEMS & Fuelmeter 32 10 42 $ 2,568 $ 0 $ 2,800 92 3,864 $ 493,856 c. App. E 8 24 32 $ 1,619 $ 0 $ 10,000 108 3,456 $ 1,254,848 2. NAR NOTC ( Early Elec. Units) 35 40 75 $ 4,129 $ 0 $ 2,800 11 825 $ 76,223 Peform QA Testing and Maintenance 1. NAR NOTC a. NOx and Flow CEMS 40 400 440 $ 20,818 $ 0 $ 20,800 223 98,120 $ 9,280,814 b. NOx CEMS & Fuelmeter 20 375 395 $ 18,361 $ 0 $ 17,400 369 145,755 $ 13,195,809 c. App. E & Fuelmeter 5 30 35 $ 1,693 $ 0 $ 1,800 108 3,780 $ 377,293 2. NAR NOTC ( Early Elec. Units) 40 400 440 $ 20,818 $ 0 $ 20,800 112 49,280 $ 4,661,216 Assure Data Quality, Prepare Reports ( Inc. monitor plan update), Submit Reports 1. NAR NOTC 20 52 72 $ 3,684 $ 0 $ 0 664 47,808 $ 2,446,096 2. NAR NOTC ( Early Election Units) 20 52 72 $ 3,684 $ 0 $ 0 112 8,064 $ 412,595 Year End Compliance Certification 2 0 2 $ 132 $ 0 $ 0 1610 3,220 $ 212,681 Allowance Transfers 1 1 2 $ 111 $ 0 $ 0 2804 5,608 $ 312,618 Application for Early Reduction Credits 4 4 8 $ 446 $ 0 $ 0 435 3,480 $ 193,993 Table 6 7. Annual Industry Respondent Burden and Cost by Activity, 2002 Annualized Mgr. Tech. Capital/ Total $ 66.05 $ 45.44 Respondent Labor Startup O & M Number of Hours/ Total / Hour / Hour Hours/ Year Cost/ Year Costs Cost Respondents Year Cost/ Year Information Collection Activity 2002 2002 2002 2002 2002 2002 2002 2002 2002 Subtotal 551,716 $ 62,099,371 Non Trading rule units 1. Read the reporting requirements 1 1 2 $ 111 $ 0 $ 0 352 704 $ 39,244 2. Revise Title V operating permit 0 1 1 $ 45 $ 0 $ 0 352 352 $ 15,995 3. Perform NOx monitoring activities 0 Cement Plants a. Annual testing 0 160 160 $ 7,270 $ 0 $ 0 57 9,120 $ 414,413 b. Prepare and submit reports, monitoring plan update 10 52 62 $ 3,023 $ 0 $ 0 57 3,534 $ 172,333 IC Engines a. Annual testing 0 140 140 $ 6,362 $ 0 $ 0 295 41,300 $ 1,876,672 b. Prepare and submit reports, monitoring plan update 10 52 62 $ 3,023 $ 0 $ 0 295 18,290 $ 891,897 Subtotal 73,300 $ 3,410,554 TOTAL 625,016 $ 65,509,925 Table 6 8. Annual Agency Respondent Burden and Cost by Activity, 2000 2002 Hours Hours Hours Other Other Other $ 40.00 $ 40.00 $ 40.00 Labor Labor Labor Direct Direct Direct Total Total Total / Hour / Hour / Hour Cost/ Year Cost/ Year Cost/ Year Costs Costs Costs Costs Costs Costs Information Collection Activity 2000 2001 2002 2000 2001 2002 2000 2001 2002 2000 2001 2002 Emission trading program activities Processing Emissions Data 224 224 1,624 $ 8,960 $ 8,960 $ 64,960 $ 0 $ 0 $ 0 $ 8,960 $ 8,960 $ 64,960 ' Monitoring recertifications 0 110 110 $ 0 $ 4,400 $ 4,400 $ 2,000 $ 85,620 $ 0 $ 2,000 $ 90,020 $ 4,400 ' Allowance tracking system 3,630 3,630 3,630 $ 145,200 $ 145,200 $ 145,200 $ 170,000 $ 170,000 $ 170,000 $ 315,200 $ 315,200 $ 315,200 ' Emissions tracking system 17,070 17,070 17,070 $ 682,800 $ 682,800 $ 682,800 $ 136,000 $ 136,000 $ 136,000 $ 818,800 $ 818,800 $ 818,800 ' EPA Permitting 0 1,156 1,157 $ 0 $ 46,240 $ 46,280 $ 1,040 $ 44,522 $ 0 $ 1,040 $ 90,762 $ 46,280 § 51.122 activities ' QA and input data 0 0 1,373 $ 0 $ 0 $ 54,920 $ 0 $ 0 $ 55,000 $ 0 $ 0 $ 109,920 TOTAL 20,924 22,190 24,964 $ 836,960 $ 887,600 $ 998,560 $ 309,040 $ 436,142 $ 361,000 $ 1,146,000 $ 1,323,742 $ 1,359,560 A 1 Appendix A to the ICR Supporting Statement: Data Items Required to be Reported Electronically for the NOx Trading Program Under the Recordkeeping and Reporting Sections of Part 75 This Appendix lists the sections of 40 CFR 75 which contain NOx mass related data elements that must be recorded and reported electronically under the rule. These sections are:

C Monitoring Plan Requirements ( § 75.53) C General Recordkeeping Requirements ( § 75.57) C Recordkeeping For Special Situations ( § 75.58) C Quality Assurance Recordkeeping ( § 75.59) C Certification Application ( § 75.63) C Quarterly Reports ( § 75.64) B 1 Appendix B to the ICR Supporting Statement: Other Data Items Required for the NOx Trading Program Under the Recordkeeping and Reporting Sections of Part 75 In addition to the data collected electronically in the EDR, the following additional NOx mass related recordkeeping and/ or reporting is required under Part 75. Items which must be recorded and kept onsite rather than reported/ submitted to the Agency, are marked with an asterisk.

Monitoring Plan Requirements ( § 75.53):

C Information, including identification of the test strategy; protocol for the relative accuracy test audit; other relevant test information; calibration gas levels for the calibration error test and linearity check; calculations for determining maximum potential concentration, maximum expected concentration, maximum potential flow rate, maximum potential NOx emission rate, and span; and apportionment strategies C Description of site locations for each monitoring component in the continuous emission monitoring systems C A data flow diagram denoting the complete information handling path from output signals of continuous emission monitoring system components to final reports C A schematic diagram identifying entire gas handling system from boiler to stack for all affected units C Stack and duct engineering diagrams showing the dimensions and location of fans, turning vanes, air preheaters, monitor components, probes, reference method sampling ports, and other equipment that affects the monitoring system location, performance, or quality control checks General Recordkeeping Requirements ( § 75.57):

C Causes of any missing data periods and the actions taken to cure such causes*

Recordkeeping For Special Situations ( § 75.58):

For units with add on NOx emission controls following the provisions of § 75.34( a)( 1) or ( a)( 2):

C Parametric data which demonstrate the proper operation of the add on emission controls* C A flag indicating that the add on emission controls are operating properly* B 2 Quality Assurance Recordkeeping ( § 75.59):

For calibration error tests of continuous emission or flow monitoring systems:

C Certification from the cylinder gas vendor or CEMS vendor that calibration gas, as defined in the applicable sections of Part 75, was used to conduct calibration error testing* C Description of any adjustments, corrective actions, or maintenance following test*

For daily interference checks of flow monitoring systems:

C Description of any adjustments, corrective actions, or maintenance following test*

For relative accuracy test audits:

C Description of any adjustments, corrective actions, or maintenance following test* C The flow polynomial equation used to linearize the flow monitor and the numerical values of the polynomial coefficients of that equation*

Other required quality assurance test data items:

C Hardcopy quality assurance relative accuracy test reports, certification reports, or recertification reports for pollutant concentration or stack flow CEMS including test results, printouts, reference method data, equations, calibration gas certificates, laboratory calibrations, test protocols, diagrams, and names of personnel involved in the testing. For each relative accuracy test audit, supporting information sufficient to substantiate compliance with all applicable sections and appendices in this Part.* ( not reported unless requested) C An indication of which data have been excluded from the quarterly span and range evaluations of the NOX monitor( s) and the reasons for excluding the data*

Excepted monitoring systems for gas fired and oil fired units:

C Test results for each transmitter or transducer accuracy test for an orifice, nozzle, or venturi type flowmeter* ( note: test summary is reported electronically) C For units with add on NOx emission controls following the provisions of § 75.34( a)( 1) or ( a)( 2): a list of operating parameters for the add on emission controls, and the range of each operating parameter in the list that indicates the add on emission controls are properly operating B 3 Notifications ( § 75.61):

The designated representative ( DR) shall submit notification for the following events on an as applicable basis:

C Initial certification tests, recertification tests, new unit/ stack, unit shutdown/ recommencement, use of backup fuels for Appendix E procedures, combustion of emergency fuels under Appendix D or E.

Certification Application ( § 75.63):

Each application for initial certification or recertification shall contain the following information, as applicable:

C Certification or recertification application form ( EPA form 7610 14) C The results of the test( s) required by § 75.20, including the type of test conducted, testing date, information required by § 75.56 or § 75.59, as applicable, and the results of any failed tests that affect data validation C Any changed portions of the hardcopy monitoring plan information required under § § 75.53( c) and ( d), or § § 75.53( e) and ( f), as applicable C Designated representative signature C If the owner or operator is applying to use the optional low mass emissions excepted methodology in § 75.19( c) in lieu of a certified monitoring system, a statement that the unit burns only natural gas or fuel oil and a list of the fuels that are burned or a statement that the unit is projected to burn only natural gas or fuel oil and a list of the fuels that are projected to be burned; a statement that the unit meets the applicability requirements in § § 75.19( a) and ( b); and any unit historical actual and projected emissions data and calculated emissions data demonstrating that the affected unit qualifies as a low mass emissions unit under § § 75.19( a) and ( b)

Quarterly Reports ( § 75.64):

C Compliance certification ( in hardcopy or optionally in electronic format)

Quality Assurance/ Quality Control Program ( Section 1 of Appendix B to Part 75) B 4 C Written QA/ QC plan that describes in detail ( or that refers to separate documents containing) complete, step by step procedures and operations For preventative maintenance, quality assurance testing, fuel sampling and sample retention* C Maintenance records of all testing, maintenance, and repair activities, including: date, time, and description of any testing, adjustment, repair, replacement, or preventive maintenance action*