2440ss01

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Proposed Rule)

1. Identification of the Information Collection

1(a) Title of the Information Collection

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised), EPA ICR Number 2440.01, OMB Control Number 2060-NEW.

1(b) Short Characterization/Abstract

The amendments to this ICR are a result of the review of the existing NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) as required by the Clean Air Act. The NESHAP published at 40 CFR part 63, subpart HH were proposed on February 06, 1998, and promulgated on June 17, 1999 only for major sources. On July 8, 2005, a supplemental proposal was published for area sources with the final rule effective date on January 03, 2007. The current proposed rulemaking applies to existing and new facilities that are major sources. A major source of hazardous air pollutants (HAP) is one that has the potential to emit, 10 tons or more of any one hazardous air pollutant or 25 tons or more of total HAP per year; an area source is one with the potential to emit less than this. This information is being collected to assure compliance with 40 CFR part 63 subpart HH.

In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Semiannual summary reports are also required.

The proposed rulemaking would amend title 40, chapter I, part 63 subpart HH to include, emission sources for which standards were not previously developed. We are proposing these standards for these emission sources pursuant to CAA section 112(d)(2) and (3). Therefore, the number of affected facilities under this subpart is expected to increase for major sources. The overall change in burden found in this ICR reflect the provision changes, an update in the cost of labor, and corrections to the number of affected facilities found in EPA ICR number 1788.09/2060-0417. After the ICR for the final rule is approved, the burden approved under this ICR will be transferred to 2060-0417.

The period considered in this ICR and throughout this supporting statement is the first three years following the promulgation of the amended Oil and Natural Gas Production NESHAP. The estimates of the size of the regulated universe are based on data from the National Emissions Inventory (NEI) database. Over the three year period, we expect 426 existing major source facilities to become new respondents. In addition, we expect a total of 43 new respondents to become subject over the three year period. The average annual burden from the recordkeeping and reporting requirements is 63,304 person hours, with an annual average cost of $2,119,048 and an annual capital cost of $245,086.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants (HAP). These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner or operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.

In the Administrator's judgment, HAP emissions from oil and natural gas production facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP standards were promulgated for this source category at 40 CFR part 63, subpart HH.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. In addition, the collected information is used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures, and for compliance determinations.

The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP continues to operate the control equipment in compliance with the regulation.

3. Non-duplication, Consultations, and Other Collection Criteria

3(a) Non-duplication

A search of EPA’s existing standards and ongoing ICR’s revealed no duplication of information gathering efforts. However, certain reports required by State or local agencies may duplicate information required by this NESHAP. In these cases, a copy of the report submitted to the State or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

The preamble to the proposed rule will give public notice of the ICR.

3(c) Consultations

During the previous ICR renewal, Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. We contacted the Independent Petroleum Association of America (IPAA) at (202) 857-4722, and the American Gas Association (AGA) at (202) 824-7000.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements are consistent with the regulations established by OMB at 5 CFR part 1320, section 1320.5, expect for the maximum length of maintaining records.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the five years. Without the five-year record retention, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents

The respondents to the recordkeeping and reporting requirements are oil and natural gas production. The North American Industry Classification System (NAICS) codes are 211112 for “Natural Gas Liquid Extraction” and 211111 for “Crude Petroleum and Natural Gas Extraction.”

4(b) Information Requested

(i) Data Items

The standards are based on add-on control devices and pollution prevention measures to reduce HAP emissions. In order to demonstrate continuous compliance with the standards, certain facilities must use the continuous parameter monitoring systems (CPMS). Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

A source must make the following reports:

Notifications
Initial notification	63.775(b)(1), 63.9(b)(2) major source, 63.775(c)(1) area source
Notification of intent to construct/reconstruct	63.5(d), 63.9(b)(4) major source 63.9(b)(5) area source
Notification of actual startup date	63.9(b)(4), 63.9(b)(5)(ii) major source 63.9(b)(5) area source
Notification of date of CMS performance evaluation	63.775(b)(2), 63.8(e)(2), 63.9(g)(1) major source 63.775 (c)(2) area source
Notification of intent to conduct a performance test	63.775(b)(3), 63.7(b), 63.9(e) major source 73.775(c)(3) area source
Notification of compliance status	63.775(b)(4), 63.9(h), 63.775(d), major source 63.775(c)(4) area source
Periodic reports	63.775(b)(5), 63.769(c), 63.772(f) major source 63.775(c)(5) area source
Results of performance test	63.7(g), 63.10(d)(2)
Notification of change in compliance demonstration method for control device performance	63.772(f)
Notification of process change	63.775(f)
Semiannual excess emissions and continuous monitoring system performance report	63.8(c)(8), 63.10(e)(3)
Semiannual HAP summary report	63.10(e)(3)

A source must keep the following records:

Recordkeeping
Record retention	63.10(b)(1), 63.774(b)(1)
Copies of notifications and reports and supporting documentation	63.10(b)(2)(xiv)
Records of performance tests, other compliance demonstrations, and performance evaluations (area sources)	63.10(b)(2)(vii)-(ix)
Record related to control equipment inspections (area sources)	63.774(b)(5-8) 63.773(c)(7)
Records related to CMS (area sources)	63.10(b)(2)(vi), (x), (xi), 63.10(c), 63.774(b)(3-4)
Records required if complying via process modification (area sources)	63.774(b)(10-11), 63.771(e)
Records required if complying via benzene emission limit (area sources)	63.774(c)
Records related to equipment that is exempt or subject to other standards	63.764(e), 63.774(d) 63.774(b)(9)
Records of exempt glycol dehydration units	63.764(e)(1), 63.774(d)(1)
Records of exempt ancillary equipment and compressors	63.764(e)(2), 63.774(d)(2)
Records of glycol dehydration unit baseline operations (alternative standards)	63.771(e)(1), 63.774(b)(10)
Records of conditions for which glycol dehydration unit baseline operations shall be modified to achieve 95% HAP emission reduction (alternative standards)	63.771(e)(2), 63.774(b)(11)
Records to demonstrate that glycol dehydration unit operates under conditions for HAP reduction (alternative standards)	63.771(e)(3), 63.774(b)(11)
Documentation of condenser design analysis	63.769(c), 63.772(e)(4)
Records of control device operating parameters – continuous and daily average (except flares)	63.774(b)(4)(i-ii)
Records of flare design, visible emissions, heat content, flow-rate, exit velocity, pilot flame outages (flares only)	63.774(b)(4)(i-ii), 63.774(e)
Records of 365 days rolling average condenser efficiency (condensers only)	63.774(b)(4)(ii)(B)
Records of flow indicator operation, flow detection, vent stream diversions	63.774(b)(4)(iii)
Records of inspections of seals or closure mechanisms, records of broken/changed/checked out seals/valves/locks	63.774(b)(4)(iv)
Records of unsafe-to-inspect parts	73.773(c)(7), 63.774(b)(5)
Records of difficult-to-inspect parts	63.773(c)(7), 63.774(b)(6)
Records of leak or defect detection and repair	63.769(c), 61.246, 63.773(c)(7), 63.774(b)(7)
Records of inspections during which no leaks or defects were detected	63.773(c)(7), 63.774(b)(8)
Records of compliance with benzene emission limit (alternative standards)	63.774(c)
Site-specific performance evaluation test plan	63.7(c)(2), 63.8(d)(2), 63.8(e)(3)(i)
Records of results of performance test	63.7(g)(3)
Continuous monitoring system quality control program	63.8(d)
Records of continuous monitoring system performance	63.10(c)

(ii) Respondent Activities

Respondent Activities

Read instructions.

Gather relevant information.

Perform initial performance test and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of 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.

Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry.

Audit facility records.

Maintain data in the CDX

5(b) Collection Methodology and Management

Information contained in the reports will be required to submit records electronically to EPA’s Central DATA Exchange (CDX) using the Electronic Reporting Tool. The Central Data Exchange (CDX) enables fast, efficient and more accurate environmental data submissions from state and local governments, industry and tribes to the Environmental Protection Agency (EPA) and participating program offices. EPA's CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data submissions to the Agency. CDX works with both EPA program offices looking for a way to better manage incoming data, and stakeholders looking for a way to reduce burden from reporting requirements.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden - NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised)

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The 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.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 63,308 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: $33.51 per hour for technical labor, $52.85 per hour for management labor, and $23.43 for clerical labor. The rates have already been increased by 110 percent to account for the benefit packages available to those employed by private industry. These rates are from the Employer Costs for Employee Compensation Historical Listing March 2004 – December 2010 published by the Bureau of Labor and Statistics and represents the state of the industry in 2008. This is consistent with the control costs associated with the proposed revisions to subpart HH (Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf).

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standard are labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/ Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/ Startup Cost (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&Mb	(G) Total O&M, (E X F)
Monitoring equipment (CMS)	$1,015	159	$161,202	$134	626	$83,884
Total			$161,202			$83,884

^{a. We assume all new major sources and 2 percent of new area sources purchase the equipment.}

^{b. We assume the average number of existing major sources have annual O&M costs.}

The total capital/startup costs for this ICR are $161,202. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $83,884. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $245,086.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. The EPA compliance and enforcement program includes activities such as: the examination of records maintained by the respondents; periodic inspection of sources of emissions; and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $239,113.

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden - NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised).

6(d) Estimating the Respondent Universe and Total Burden and Costs

The number of area source respondents is derived from information in EPA ICR number and EPA ICR number 1788.08/2060-0417, section 4 (b) (ii).

The number of major source respondents was updated based on the NEI database, which was used during the analysis to determine the MACT. The number of respondents is calculated using the following table which addresses the 3 years covered by this ICR. Over the three year period of this ICR, we expect 426 existing major source facilities to become new respondents. In addition, we expect 43 new respondents to become subject over the three year period.

The total number of annual responses per year is calculated using the following table:

YEAR	(A)			(B)		(C)	(E)	(F)	(G)
	Number of New Respondents 1 & 2			Number of Existing Respondents3		Number of Existing Respondents That Are Also New Respondents	Total Number of Respondents (E=A+B)	Number of Respondents that Only Maintain Records4	Number of Respondents That Submit Records
	Major	Area	Area Only Keep Records	Major	Area
1	156	3	138	470	2,927	142	3,694	3,006	688
2	156	3	138	626	3,068	142	3,991	3,145	846
3	156	3	138	782	3,209	142	4,288	3,283	1,005
Avg	156	3	138	626	3,068	142	3,991	3,145	846

1. New respondents include sources with constructed or reconstructed affected facilities.

2. We assume that there are 141 new area sources and 156 new major sources for a total of 297 new sources each year. We estimate 142 of the new major sources are existing facilities, while 14 new major sources are at new facilities.

3. We assume there are 3,068 existing area sources and 626 existing major sources.

4. We assume that 98 percent of area sources will only be required to maintain records. All major sources and 2 percent of area sources will maintain and submit reports.

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)
Major sources
Notification of construction/reconstruction	156	1	0	156
Notification of actual startup	156	1	0	156
Notification of date of CMS performance evaluation	156	1	0	156
Notification of date of performance test	156	1	0	156
Notification of compliance status report	156	1	0	156
Semiannual periodic report	782	2	0	1,564
Area sources
Notification of intent to construct	3	1	0	3
Notification of actual startup date	16	1	0	16
Notification of intent to conduct performance test	16	1	0	16
Notification of date of CMS performance evaluation	16	1	0	16
Notification of compliance status	16	1	0	16
First periodic report	3	1	0	3
Subsequent periodic reports	12	1	0	12
Total Number of Annual Responses			Total	2,426

The number of Total Annual Responses is 2,426.

The total annual labor costs are $2,119,048 for 63,304 labor hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised).

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 63,304. Details regarding these estimates may be found below in Table 1. Annual Respondent Burden and Cost - NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 26 hours (rounded) per response.

The total annual capital/startup and Operation and Maintenance (O&M) costs to the regulated entity are $245,086.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 5,230 labor hours at a cost of $239,113. See below Table 2: Annual Agency Burden and Cost – NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised).

6(f) Reasons for Change in Burden

The proposed rulemaking would amend title 40, chapter I, part 63 subpart HH to include, emission sources for which standards were not previously developed. We are proposing these standards for these emission sources pursuant to CAA section 112(d)(2) and (3). Therefore, the number of affected facilities under this subpart is expected to increase for major sources. At this time, none of the proposed amendments will affect area sources.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 26 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; to 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; to adjust the existing ways to comply with any previously applicable instructions and requirements; to train personnel to be able to respond to a collection of information; to search data sources; to complete and review the collection of information; and to 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 valid OMB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2010-0505. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the content of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Air and Radiation Docket and Information Center Docket is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2010-0505 and OMB Control Number 2060-0417 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

Table 1: Annual Respondent Burden and Cost – NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised)

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b ($)
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
a. Read rule and instructions c	4	1	1	297	472	24	47	18,170
b. Required activities	N/A
c. Create information	N/A
d. Gather existing information c	2	1	1	297	594	30	59	22,866
Major sources
i. Notification of construction/reconstruction c	1	1	1	156	78	4	8	3,003
ii. Notification of actual startup c	1	1	1	156	78	4	8	3,003
iii. Notification of date of CMS performance evaluation c	1	1	1	156	78	4	8	3,003
iv. Notification of date of performance test c	1	1	1	156	78	4	8	3,003
v. Notification of compliance status report c	4	1	4	156	624	31	62	24,021
vii. Semiannual periodic report	4	2	8	782	6,256	313	626	240,828
Area sources
i. Notification of intent to construct c	1	1	2	3	6	0	1	231
ii. Notification of actual startup date c	1	1	1	3	3	0	0	115
iii. Notification of intent to conduct performance test c, e	1	1	2	16	32	2	3	1,232
iv. Notification of date of CMS performance evaluation c, e	1	1	2	16	32	2	3	1,232
v. Notification of compliance status	4	1	10	16	160	8	16	6,159
vi. First periodic report c, e	4	1	4	3	12	1	1	462
vii. Subsequent periodic reports e	2	1	2	12	24	1	2	924
Subtotal for Reporting Requirements			40		9,806			328,251
4 Recordkeeping requirements
a. Read instructions
- Major source g	1	1	4	156	624	31	62	24,021
- Area source g	1	1	4	141	564	28	56	21,711
b. Plan activities
- Major source	16	1	16	156	2,496	125	250	96,085
- Area source
i. Sources required to operate add-on controls	16	1	16	16	256	13	26	9,855
ii. Sources required to implement MP	4	1	4	138	552	28	55	21,250
c. Implement activities
- Major source	N/A
- Area source
i. Performance test	35	1	35	3	105	5	11	4,042
ii. Design analysis	12	1	12	16	192	10	19	7,391
iii. Control equipment leak monitoring h	3	2	6	62	372	19	37	14,320
iv. Operate and maintain CMS h, i	2	12	24	62	1,488	74	149	57,281
d. Develop record system
- Major source
i. Control equipment	8	1	8	156	1,248	62.4	125	4,8042
ii. Equipment Inspection and Monitoring	13	1	13	782	10,166	508	1,017	391,345
- Area source
i. Control equipment	8	1	8	16	128	6	13	4,927
e. Time to enter information
- Major source
i. Control equipment monitoring j, k	1	2	2	782	1564	78	156	60,207
ii. Control device CMS j, k, l	1	12	12	782	9,384	469	938	361,242
iii. Equipment Inspection and Maintenance, k, l	1	12	12	782	9,384	469	938	361,242
- Area source
i Control equipment leak monitoring h, m	1	2	2	62	124	6.2	12	4,773
ii. CMS measurements h	1	12	12	62	744	37	74	28,641
f. Time to train personnel
- Major source	8	1	8	156	1,248	62	125	48,042
- Area source n	16	1	16	16	256	12.8	26	9,855
g. Maintain records (area source) h, o	20	1	20	62	1,240	62	124	47,734
h. Retain records of emission p	1	1	1	3,145	3,145	157	314	121,054
i. Retrieve records/reports q	20	1	20	62	1,240	62	124	47,734
Subtotal for Recordkeeping Requirements						53,498		1,790,797
					46,520	2,326	4,652
TOTAL LABOR BURDEN AND COST (rounded)						63,304		2,119,048

Assumptions:

a. We have assumed that the average number of reporting respondents that will be subject to this rule will be 3,991 during the reporting period, which consists of 3,068 existing area sources, 626 existing major sources and an additional 297 new sources. The majority of these respondents, 3,145, are not required to submit reports.

b. This ICR uses the following labor rates: $33.51 per hour for technical labor, $52.85 per hour for management labor, and $23.43 for clerical labor. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. These rates are from the Employer Costs for Employee Compensation Historical Listing March 2004 – December 2010 published by the Bureau of Labor and Statistics and represents the state of the industry in 2008, consistent with the control costs associated with the proposed rule. Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf

e. We have assumed that the requirements do not apply to sources located outside of an urbanized area (UA)/urban cluster (UC) plus offset boundary.

g. We have assumed that it will take each of the respondents four hours to read instructions.

h. We have assumed that 50 existing area sources, and 12 new area sources (8 percent of area sources ) will complete this activity.

i. We have assumed that it will take each respondent two hours twelve times per year to implement this activity.

j. We have assumed that it will take each of the respondents one hour to enter information.

k. We assume that all of the major sources will each take one hour to enter information.

l. We have assumed that each respondent will be required to enter information twelve times per year.

m. We have assumed that each respondent will be required to enter information two times per year.

n. We have assumed that a sixteen (3 new and 13 existing) respondents will each take sixteen hour to train personnel. This follows the assumption that 2 percent of area sources will submit records.

o. We have assumed that it will take 20 hours for each respondent to maintain records.

p. We have assumed that all of the respondents that are subject only to the recordkeeping requirements will take one hour each year to process records of emissions.

q. We have assumed that each respondent will take twenty hours once per year to retrieve records/reports.

Table 2: Average Annual EPA Burden - NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Revised)

Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person- hours per year (Ex0.1)	(H) Cost, $ b
Major source
Initial notification c	2	1	2	156	312	15.6	31.2	16,404
Preconstruction review application c	4	1	4	156	624	31.2	62.4	32,807
Performance test notification c	2	1	2	156	312	15.6	31.2	16,404
Compliance status notification c	4	1	4	156	624	31.2	62.4	32,807
Semiannual periodic reports d	2	2	4	628	2,512	125.6	251.2	132,070
Area sources					0	0	0
Notification of intent to construct	2	1	2	3	6	0.3	0.6	315
Notification of actual startup date	2	1	2	3	6	0.3	0.6	315
Notification of intent to conduct performance test e	2	1	2	16	32	1.6	3.2	1,682
Notification of date of CMS performance evaluation f	2	1	2	16	32	1.6	3.2	1,682
Notification of compliance status	4	1	4	16	64	3.2	6.4	3,365
Periodic reports – new sourceg	2	1	2	12	24	1.2	2.4	1,262
Subtotals Labor Burden and cost					4,548	227	455	239,113
TOTAL ANNUAL BURDEN AND COST (rounded)					5,230

Assumptions:

a. We have assumed that the average number of reporting respondents that will be subject to this rule will be 3,991 during the reporting period, which consists of 2,926 existing area sources, 626 existing major sources and an additional 297 new sources. The majority of these respondents, 3,145, are not required to submit reports.

b. The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $59.63 (GS-13, Step 5, $37.27 × 1.6), Technical rate of $47.20 (GS-12, Step 1, $29.50 × 1.6), and Clerical rate of $23.94 (GS-6, Step 3, $14.96 × 1.6). These rates are from the Office of Personnel Management (OPM), 2008 General Schedule, which excludes locality rates of pay.

c. We have assumed that this is a one-time only activity for each facility.

d. We have assumed that each respondent will take two hours two times per year to complete the semiannual periodic reports.

e. We have assumed that each of the respondents will take two hours once per year to complete requirements.

f. We have assumed that the requirements do not apply to sources located outside of an urbanized area (UA)/urban cluster (UC) plus offset boundary.

g .We have assumed that each respondent will take two hours once per year to review reports.