Burden Tables

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden
Capital & O&M

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Sheet 1: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	32	532	0	0	564
2	32	564	0	0	596
3	32	596	0	0	628
Average	32	564	0	0	596
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.

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Sheet 2: # Responses

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)+D		ERG Notes:
Notifications
Gas well completion	300	33	0	9,900
Gas well recompletion	300	4	0	1,200
New gas processing plant	29	1	0	29
New sweetening unit	3	1	0	3
Annual reports
Gas well completion/recompletion	300	1	0	300
Centrifugal compressor	65	1	0	65
Reciprocating compressor	2,095	1	0	2,095
Sweetening unit	15	1	0	15
Production pneumatic controller	300	1	0	300
Gas processing pneumatic controller	75	1	0	75
Storage vessel	380	1	0	380
Semiannual reports
Gas processing plant	145	2	0	290
			Total	14,652		-prev renewal: 3,230 responses, 21 hrs/response.
			hrs/response:	6.4

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart OOOO) (Renewal)										Source Type	No.
				Labor Rates:	$103.97	$129.93	$51.79			Existing	564
Burden item	A	B	C	D	E	F	G	H		Exploration/production	300
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		Transmission/storage	136
1. Applications	N/A									Processing plants	116
2. Survey and Studies	N/A									Sweetening units	12
3. Acquisition, installation, and utilization of technology and systems	N/A									New	32
4. Report requirements	N/A									Processing plants	29
a. Familiarization with the rule requirements c	1	1	1	596	596	29.8	59.6	68,924.72		Sweetening units	3
b. Required activities
i. Notification of gas well completion d	0.5	33	17	300	4,950	247.5	495	572,445.23		ERG Notes:
ii. Notification of gas well recompletion d	0.5	4	2	300	600	30	60	69,387.3
iii. Notification of new gas processing plant e	1	1	1	29	29	1.45	2.9	3,353.72
iv. Notification of new sweetening unit f	1	1	1	3	3	0.15	0.3	346.94
c. Create information	See 4B
d. Gather existing information	See 4E
e. Annual reports
i. Gas well completion/recompletion d	16	1	16	300	4,800	240	480	555,098.4
ii. Sweetening unit f	1	1	1	15	15	0.75	1.5	1,734.68
iii. Centrifugal compressor g	8	1	8	65	520	26	52	60,135.66
iv. Reciprocating compressor h	8	1	8	2,095	16,760	838	1,676	1,938,218.58
v. Production pneumatic controller i	8	1	8	300	2,400	120	240	277,549.2
vi. Gas processing pneumatic controller j	8	1	8	75	600	30	60	69,387.3
vii. Storage vessel k	8	1	8	380	3,040	152	304	351,562.32
f. Semiannual reports
i. Gas processing plant l	40	2	80	145	11,600	580	1,160	1,341,487.8
Reporting Subtotal					52,799			5,309,632
5. Recordkeeping requirements
a. Read instructions	See 4A
b. Plan activities	See 4B
c. Implement activities
i. Filing and maintaining records l	5	12	60	436	26,160	1,308	2,616	3,025,286.28
ii. Filing and maintaining records m	5	12	60	160	9,600	480	960	1,110,196.8
d. Record data	N/A
e. Time to transmit or disclose information
i. Records required by standards	See 5C
f. Time to train personnel	See 5C
g. Time for audits	N/A
Recordkeeping Subtotal					41,124			4,135,483
TOTAL ANNUAL BURDEN AND COST (ROUNDED)					93,900			9,450,000
TOTAL ANNUAL CAPITAL AND O&M COST (SEE SECTION 6(b)(iii))								1,750,000
GRAND TOTAL (LABOR, CAPITAL, AND O&M)								11,200,000		Prev renewal: 68,906 hrs and $2,306,573 (3-yr avg). Net increase due to industry growth. Also note that labor rates have nearly doubled since prev ICR, hence the significant burden increase.
N/A - Not Applicable
Note: Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.
Assumptions:
a EPA estimates an average of 564 existing sources and 32 new sources will be subject to the standard over the next three years. Existing sources comprise 300 exploration and production businesses, 136 transmission and storage operations, 116 processing plants and 12 sweetening units. New sources comprise 29 processing plants and 3 sweetening units.
b This ICR uses the following labor rates: $103.97 (technical), $129.93 (managerial), and $51.79 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c This burden represents the time existing respondents spend re-familiarizing themselves with rule requirements, or that new respondents spend learning rule requirements.
d Assumes 9,759 completions and 1,206 recompletions each year performed by 300 operators.
e EPA estimates an average of 116 existing and 29 new processing plants.
f EPA estimates an average of 12 existing and 3 new sweetening units.
g EPA estimates an average of 52 existing and 13 new centrifugal compressors equipped with wet seals at processing plants.
h EPA estimates an average of 1,676 existing and 419 new reciprocating compressors. For existing sources, EPA estimates there are 840 compressors at gathering & boosting stations and 836 compressors are at processing plants. For new sources, EPA estimates there will be 210 compressors at gathering & boosting stations and 209 compressors at processing plants.
i EPA estimates 13,632 pneumatic controllers across the 300 exploration & production sites.
j EPA estimates an average of 60 existing and 15 new pneumatic controllers at affected processing plants.
k EPA estimates an average of 304 existing and 76 new respondents in the production, processing, transmission, or storage segment will submit annual reports. EPA anticipates each report will cover approximately four storage vessels, based on research the Agency conducted during initial rule development.
l Activity applies to exploration & production businesses and transmission & storage operations, for which EPA estimates an average of 300 and 136 sources, respectively.
m Activity applies to gas processing plants and sweetening units. EPA estimates an average of 116 existing and 29 new processing plants and 12 existing and 3 new units.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart OOOO) (Renewal)
				Labor Rates:	$46.67	$62.90	$25.25
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		ERG Notes:
Review initial notifications
i. Notification of gas well completion	0.5	33	17	300	4,950	247.5	495	259,083
ii. Notification of gas well recompletion	0.5	4	2	300	600	30	60	31,404
iii. Notification of new gas processing plant	0.5	1	1	29	14.5	0.73	1.45	759.24
iv. Notification of new sweetening unit	0.5	1	1	3	1.5	0.08	0.15	78.82
Review annual reports
i. Gas well completion/recompletion	1	1	1	300	300	15	30	15,702
ii. Sweetening unit	1	1	1	15	15	0.75	1.5	785.1
iii. Centrifugal compressor	1	1	1	65	65	3.25	6.5	3,402.1
iv. Reciprocating compressor	1	1	1	2,095	2,095	104.75	209.5	109,652.3
v. Production pneumatic controller	1	1	1	300	300	15	30	15,702
vi. Gas processing pneumatic controller	1	1	1	75	75	3.75	7.5	3,925.5
vii. Storage vessel	1	1	1	380	380	19	38	19,889.2
Review semiannual reports
i. Gas processing plant	1	2	2	145	290	14.5	29	15,178.6
TOTAL ANNUAL BURDEN AND COST (ROUNDED)					10,400			476,000		Prev renewal: 9,207 hrs and $420,919 (3-yr avg). Net increase due to industry growth.
Note: Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.
Assumptions:
a EPA estimates an average of 564 existing sources and 32 new sources will be subject to the standard over the next three years. Existing sources comprise 300 exploration and production businesses, 136 transmission and storage operations, 116 processing plants and 12 sweetening units. New sources comprise 29 processing plants and 3 sweetening units.
b This ICR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are from the Office of Personnel Management (OPM), 2014 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.

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Sheet 5: Capital & O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Requirement	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent 1	Number of Respondents with O&M	Total O&M, (E X F)	ERG Notes
SO2 CEMS (control outlet)	$73,000	3	$219,000	$17,100	15	$256,500
Continuous control device monitoring for centrifugal compressors 2	N/A	13	$0	$804	65	$52,260
Continuous control device monitoring for storage vessels 2	N/A	304	$0	$804	1,520	$1,222,080
Total			$219,000			$1,530,840	Prev renewal: Cap/Startup = $219,000; O&M = $612,336; O&M increase due to industry growth.
CEM - Continuous Emission Monitoring System
N/A - Not Applicable
Assumptions:
1 Annual O&M costs for centrifugal compressors and storage vessels were calculated assuming 2 hours per month at $33.51 per hour.
2 Capital/Startup costs for continuous control device monitoring were included in storage vessel and centrifugal compressor control device costs.