Burden Tables

2437t04.xlsx

NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution (40 CFR part 60, subpart OOOO) (Renewal)

Burden Tables

OMB: 2060-0673

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Overview

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


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 0 532 0 0 532 Revised to remove new respondents; all new facilities are subject to OOOOa.
2 0 532 0 0 532
3 0 532 0 0 532
Average 0 532 0 0 532
1 New respondents include sources with constructed, reconstructed, and modified affected facilities. Facilities that commence construction, modification, or reconstruction after September 18, 2015 are subject to 40 CFR 60, Subpart OOOOa.

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 a





Gas well completion 0 33 0 0

Gas well recompletion 0 4 0 0

New gas processing plant 0 1 0 0

New sweetening unit 0 1 0 0

Annual reports





Gas well completion/recompletion 0 1 0 0

Sweetening unit 12 1 0 12

Centrifugal compressor 52 1 0 52

Reciprocating compressor 1,676 1 0 1,676

Production pneumatic controller 300 1 0 300

Gas processing pneumatic controller 45 1 0 45

Storage vessel 304 1 0 304

Semiannual reports





Gas processing plant 87 2 0 174




Total 2,563







-prev renewal: 3,230 responses, 21 hrs/response.
Footnotes:





a These notifications are initial notifications for sources constructed, modified or re-contructed after August 2011 and prior to September 2015.




hrs/response: 27


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)
















Burden item A B C D E F G H



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




1. Applications N/A







Labor Rates:
2. Survey and Studies N/A







Management $147.40 These rates were updated 11/15/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
3. Acquisition, installation, and utilization of technology and systems N/A







Technical $117.92
4. Report requirements N/A







Clerical $57.02
a. Familiarization with the rule requirements c 1 1 1 532 532 26.6 53.2 $69,687.74



b. Required activities











i. Notification of gas well completion d 0.5 33 17 0 0 0 0 $0 Revised to 0 respondents


ii. Notification of gas well recompletion d 0.5 4 2 0 0 0 0 $0 Revised to 0 respondents Source Type No.
iii. Notification of new gas processing plant e 1 1 1 0 0 0 0 $0 Revised to 0 respondents Existing 532
iv. Notification of new sweetening unit f 1 1 1 0 0 0 0 $0 Revised to 0 respondents Exploration/production 300
c. Create information See 4B







Transmission/storage 136
d. Gather existing information See 4E







Processing plants 116
e. Annual reports








Sweetening units 12
i. Gas well completion/recompletion d 16 1 16 0 0 0 0 $0 Revised to 0 respondents New 0
ii. Sweetening unit f 1 1 1 9 9 0.45 0.9 $1,178.93 Revised # of respondents (removes new respondents) Processing plants 0
iii. Centrifugal compressor g 8 1 8 39 312 16 31 $40,869.50 Revised # of respondents (removes new respondents) Sweetening units 0
iv. Reciprocating compressor h 8 1 8 1,676 13,408 670 1,341 $1,756,340.74 Revised # of respondents (removes new respondents)


v. Production pneumatic controller i 8 1 8 300 2,400 120 240 $314,380.80
ERG Notes: We expect the number of sources subject to decrease over time as facilities are modified.

vi. Gas processing pneumatic controller j 8 1 8 45 360 18 36 $47,157.12 Revised # of respondents (removes new respondents)


vii. Storage vessel k 8 1 8 304 2,432 122 243 $318,572.54 Revised # of respondents (removes new respondents)


f. Semiannual reports











i. Gas processing plant l 40 2 80 87 6,960 348 696 $911,704.32 Revised # of respondents (removes new respondents)


Reporting Subtotal



30,375 $3,459,892



5. Recordkeeping requirements











a. Read instructions See 4A










b. Plan activities See 4B










c. Implement activities











i. Filing and maintaining records m 5 12 60 436 26,160 1,308 2,616 $3,426,750.72



ii. Filing and maintaining records n 5 12 60 128 7,680 384 768 $1,006,018.56 Revised # of respondents (removes new respondents)


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



38,916 $4,432,769



TOTAL LABOR BURDEN AND COST (rounded) o



69,300 $7,890,000



TOTAL CAPITAL AND O&M COST (rounded) o






$1,220,000



GRAND TOTAL (rounded) o






$9,110,000



N/A - Not Applicable
























Assumptions:











a EPA estimates an average of 532 existing sources and no 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. This number is expected to decrease over time as sources are modified or retired from service.



b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% 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 Initial notification and annual reporting for completions and recompletions is required for gas wells that commenced construction, modification or reconstruction after August 23, 2011, and on or before September 18, 2015. New gas wells or gas wells modified after September 18, 2015 are subject to requirements under 40 CFR 60, Subpart OOOOa.



e Processing plants that commenced construction, modification or reconstruction after September 18, 2015 are subject to requirements under 40 CFR 60, Subpart OOOOa.



f EPA estimates an average of 12 existing sweetening units and no new sweetening units. EPA estimates that 75% of those sweetening units will experience one reportable deviation per year. Sweetening units that commenced construction, modification or reconstruction after September 18, 2015 are subject to requirements under 40 CFR 60 Subpart OOOOa.



g EPA estimates an average of 52 existing and no new centrifugal compressors equipped with wet seals at processing plants. EPA estimates that 75% of those centrifugal compressors will experience one reportable deviation per year. Centrifugal compressors equipped with wet seals at processing plants that commenced construction, modification or reconstruction after September 18, 2015 are subject to requirements under 40 CFR 60 Subpart OOOOa.



h EPA estimates an average of 1,676 existing and no new reciprocating compressors. New reciprocating compressors that commenced construction, modification or reconstruction after September 18, 2015 are subject to requirements under 40 CFR 60 Subpart OOOOa.



i EPA estimates 13,632 pneumatic controllers across the 300 exploration & production sites. EPA estimates that all 300 sites will experience one reportable deviation per year.



j EPA estimates an average of 60 existing and no new pneumatic controllers at affected processing plants. EPA estimates that 75% of those pneumatic controllers will experience one reportable deviation per year.



k EPA estimates an average of 304 existing and no 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 EPA estimates an average of 116 existing and no new gas processing plants. EPA estimates that 75% of those plants will experience one reportable deviation per year.



m Activity applies to exploration & production businesses and transmission & storage operations, for which EPA estimates an average of 300 and 136 sources, respectively.



n Activity applies to gas processing plants and sweetening units. EPA estimates an average of 116 existing processing plants and 12 existing sweetening units.



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




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)
























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




Review initial notifications c








Labor Rates:
i. Notification of gas well completion 0.5 33 17 0 0 0.0 0 $0
Management $65.71 These rates were updated 11/15/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
ii. Notification of gas well recompletion 0.5 4 2 0 0 0 0 $0
Technical $48.75
iii. Notification of new gas processing plant 0.5 1 1 0 0.0 0.00 0.00 $0
Clerical $26.38
iv. Notification of new sweetening unit 0.5 1 1 0 0.0 0.00 0.00 $0



Review annual reports








ERG Notes: We expect the number of sources subject to decrease over time as facilities are modified.

i. Gas well completion/recompletion 1 1 1 0 0 0 0 $0



ii. Sweetening unit 1 1 1 9 9 0.45 0.9 $492.06



iii. Centrifugal compressor 1 1 1 39 39 1.95 3.9 $2,132.27



iv. Reciprocating compressor 1 1 1 1,676 1,676 83.80 167.6 $91,632.79



v. Production pneumatic controller 1 1 1 300 300 15 30 $16,402.05



vi. Gas processing pneumatic controller 1 1 1 45 45 2.25 4.5 $2,460.31



vii. Storage vessel 1 1 1 304 304 15 30 $16,620.74



Review semiannual reports











i. Gas processing plant 1 2 2 87 174 8.7 17 $9,513.19



TOTAL (rounded) c



2,900 $139,000
















Assumptions:











a EPA estimates an average of 532 existing sources and no 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.



b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.



c Initial notification is required for these source categories that commenced construction, modification or reconstruction after August 23, 2011, and on or before September 18, 2015. New gas wells or gas wells constructed, modified, or reconstructed after September 18, 2015 are subject to 40 CFR 60, Subpart OOOOa.



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




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 Revised to remove new respondents.
SO2 CEMS (control outlet) $73,000 0 $0 $17,100 12 $205,200

Continuous control device monitoring for centrifugal compressors 2 N/A 0 $0 $804 52 $41,808

Continuous control device monitoring for storage vessels 2 N/A 0 $0 $804 1,216 $977,664

Total

$0

$1,220,000

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.







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