Burden Calculation Tables

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Overview

Table 1
Table 2
#Sources
# Responses
Capital and O&M Costs

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Renewal)
	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
Burden item	Technical Person hours per occurrence	No. of occurrences per respondent per year	Technical Person hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost Per Year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Manager	$141.06
3. Reporting requirements										Technical	$120.27
a. Familiarize with rule requirement c										Clerical	$58.67
New sources	4	1	4	169	676	33.8	67.6	$90,036.44
Existing sources (major source only)	1	1	1	596	596	29.8	59.6	$79,381.24
b. Required activities	N/A
Major sources
i. Notification of construction/reconstruction c	2	1	2	28	56	2.8	5.6	$7,458.64
ii. Notification of actual startup c	2	1	2	28	56	2.8	5.6	$7,458.64
iii. Notification of date of CMS performance evaluation c	2	1	2	28	56	2.8	5.6	$7,458.64
iv. Notification of date of performance test c	2	1	2	28	56	2.8	5.6	$7,458.64
v. Notification of compliance status report c	4	1	4	28	112	5.6	11.2	$14,917.28
vi. Affirmative Defense and malfunction reports e	2	2	4	596	2,384	119	238	$317,524.96
vii. Semiannual periodic report e	2	2	4	596	2,384	119	238	$317,524.96
Area sources
i. Notification of intent to construct c	2	1	2	3	6	0.3	0.6	$799.14
ii. Notification of actual startup date c	1	1	1	3	3	0.15	0.3	$399.57
iii. Notification of intent to conduct performance test c, f	2	1	2	16	32	1.6	3.2	$4,262.08
iv. Notification of date of CMS performance evaluation c, f	2	1	2	16	32	1.6	3.2	$4,262.08
v. Notification of compliance status f	10	1	10	16	160	8	16	$21,310.40
vi. First periodic report g	4	1	4	3	12	0.6	1.2	$1,598.28
vii. Subsequent periodic reports g	2	1	2	78	157	8	16	$20,852.23		2% of existing area sources
viii. Affirmative Defense and malfunction reports h	2	10	20	16	320	16	32	$42,620.80		0.4% of existing area sources
c. Create information	N/A
d. Gather existing information c	8	1	8	169	1352	67.6	135	$180,072.88
e. Affirmative defense d	N/A
Subtotal for Reporting Requirements					9,717			$1,125,397
4. Recordkeeping requirements
a. Familiarize with rule requirement
Major source i	4	1	4	28	112	5.6	11.2	$14,917.28
Area source i	4	1	4	141	564	28.2	56.4	$75,119.16
b. Plan activities
Major source	16	1	16	28	448	22.4	44.8	$59,669.12
Area source
i. Sources required to operate add-on controls j	16	1	16	81	1300	65	130	$173,210.93		2% of existing area sources and 3 new area sources
ii. Sources required to implement MP k	4	1	4	138	552	27.6	55.2	$73,520.88
c. Implement activities
Major source	N/A
Area source
i. Performance test l	35	1	35	16	560	28	56	$74,586.40
ii. Design analysis l	12	1	12	65	783	39	78	$104,335.72
iii. Control equipment leak monitoring j	3	2	6	81	488	24	49	$64,954.10
iv. Operate and maintain CMS j, m	2	12	24	81	1951	98	195	$259,816.40
d. Develop record system
Major source
i. Control equipment c	8	1	8	28	224	11.2	22.4	$29,834.56
ii. Equipment inspection and monitoring n	13	1	13	596	7748	387	775	$1,031,956.12
Area source
Control equipment o	8	1	8	16	128	6.4	12.8	$17,048.32
e. Time to enter information
Major source
i. Control equipment monitoring n, p	1	2	2	596	1192	59.6	119	$158,762.48
ii. Control device CMS n, p, q	1	12	12	596	7152	358	715	$952,574.88
iii. Equipment inspection and monitoring n, p, q	1	12	12	596	7152	358	715	$952,574.88
Area source
i. Control equipment leak monitoring j, r	1	2	2	81	163	8	16	$21,651.37
ii. CMS measurements j	1	12	12	81	975	49	98	$129,908.20
f. Time to train personnel
Major source c, s	8	1	8	28	224	11.2	22.4	$29,834.56
Area source c, s	8	1	8	3	24	1.2	2.4	$3,196.56
g. Maintain records (area source) j, t	20	1	20	81	1626	81	163	$216,513.66
h. Retain records of emission u	1	1	1	3,836	3836	192	384	$510,879.55
i. Retrieve records/reports j, v	20	1	20	81	1626	81	163	$216,513.66
Subtotal for Recordkeeping Requirements					44,651			$5,171,378.79		# response
Total Labor Burden and Costs (rounded) w					54,400			$6,300,000		2,819
Total Capital and O&M Cost (rounded) w								$1,040,000
GRAND TOTAL (rounded) w								$7,340,000		hr/response
										19.3
Assumptions:
a We assume that on average there are 4,669 existing sources (596 existing major sources and 3,914 existing area sources) during the three-year period of this ICR. We assume that an additional 169 new respondents (28 new major source respondents and 141 new area source respondents) per year will become subject to new requirements under the rule over the three years of this ICR due to new construction. We assume that all 141 of the new area source respondents are newly constructed area sources, while 18 of the 28 new major source respondents are newly constructed (greenfield) major sources. The remaining 10 new major source respondents are existing major sources that perform construction or reconstruction and are required to file reports as though they were new major source respondents.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c New respondents are comprised of: 28 new major source respondents that are required to file reports, 3 new area source respondents that are required to file reports, and 138 new area source respondents that only maintain records, for a total of 169 new respondents per year on average. For existing respondents, we assume only major source respondents will need to re-familiarize with the regulatory requirement. Most area source respondents only have recordkeeping requirements.
d Not applicable.
e We assume that affirmative defense and malfunction reports may be included as part of the semiannual periodic reports. In addition, we estimate two hours are required to complete each report. All existing major sources are subject to malfunction and semiannual reports.
f We assume that 11% of new area sources are located within an urbanized area (UA)/urban cluster (UC) plus offset boundary and have facilities subject to control, monitoring, and recordkeeping requirements.
g We assume that 2% of existing area sources and 3 new area sources will complete this activity.
h We assume that affirmative defense and malfunction reports may be included as part of the semiannual periodic reports. We assume that 2% of existing area sources and 3 new area sources will complete this activity. In addition, we estimate two hours are required to complete each report.
i We assume that it will take each of the new sources (28 major and 141 area) four hours to read instructions.
j We assume that 2% of the 3,914 existing area sources (78 sources) and 3 new area sources will complete this activity.
k This applies to new area sources that only keep records.
l Performance of control devices can be evaluated with performance tests or design analysis. The estimated hours per activity and number of sources are based on estimates from EPA ICR Number 1788.09 and 2440.02.
m We assume that it will take each respondent two hours twelve times per year to implement this activity.
n This applies to the existing major sources.
o The 11% of new area sources doing a performance test on control equipment need to develop a record system. The estimated hours per activity and number of sources are based on estimates from EPA ICR Number 1788.09 and 2440.02.
p We assume that all of the major sources will each take one hour to enter information.
q We assume that each respondent will be required to enter information twelve times per year.
r We assume that each respondent will be required to enter information two times per year.
s We assume that new respondents subject to reporting requirements will take eight hours to train personnel in the recordkeeping system.
t We assume that it will take 20 hours for each respondent to maintain records.
u We assume that 98% of the 3,914 existing area source respondents are subject only to the recordkeeping requirements. These sources will take one hour each year to process records of emissions.
v We assume that each respondent will take twenty hours once per year to retrieve records/reports.
w Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year	Plants per year a	Technical person- hours per year	Management person-hours per year	Clerical person-hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			Labor Rates
Major source										Manager	$66.62
Initial notification c	2	1	2	28	56	2.8	5.6	$3,104.98		Technical	$49.44
Preconstruction review application c	4	1	4	28	112	5.6	11.2	$6,209.95		Clerical	$26.75
Performance test notification c	2	1	2	28	56	2.8	5.6	$3,104.98
Compliance status notification c	4	1	4	28	112	5.6	11.2	$6,209.95
Affirmative Defense and malfunction reports d	2	2	4	596	2,384	119.2	238.4	$132,183.26
Semiannual periodic reports e	2	2	4	596	2,384	119.2	238.4	$132,183.26
Area sources
Notification of intent to construct	2	1	2	3	6	0.3	0.6	$332.68
Notification of actual startup date	2	1	2	3	6	0.3	0.6	$332.68
Notification of intent to conduct performance test f	2	1	2	16	32	1.6	3.2	$1,774.27
Notification of date of CMS performance evaluation	2	1	2	16	32	1.6	3.2	$1,774.27
Notification of compliance status	4	1	4	16	64	3.2	6.4	$3,548.54
Periodic reports - first and subsequent g	2	1	2	81	163	8.1	16	$9,013.30
Affirmative Defense and malfunction reports h	2	1	2	16	32	1.6	3.2	$1,774.27
TOTAL (rounded) i					6,250			$302,000
Assumptions:
a We assume that on average there are 4,6698 existing sources (596 existing major sources and 3,914 existing area sources) during the three-year period of this ICR. We assume that an additional 169 new respondents (28 new major source respondents and 141 new area source respondents) per year will become subject to new requirements under the rule over the three years of this ICR due to new construction. We assume that all 141 of the new area source respondents are newly constructed area sources, while 18 of the 28 new major source respondents are newly constructed (greenfield) major sources. The remaining 10 new major source respondents are existing major sources that perform construction or reconstruction and are required to file reports as though they were new major source respondents.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that this is a one-time only activity for each facility.
d We have assumed that affirmative defense and malfunction reports may be included as part of the semiannual periodic reports.
e We have assumed that each respondent will take two hours two times per year to complete the semiannual periodic reports.
f We have assumed that each of the respondents will take two hours once per year to complete requirements.
g We assume that 2% of existing area sources and 3 new area sources will complete this activity.
h We have assumed that it will take two hours once per year to review reports.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: #Sources

Number of Respondents
	(A)			(B)		(C)	(D)	(E)
Year	Number of New Respondents 1, 2			Number of Existing Respondents 3		Number of Existing Respondents that keep records but do not submit reports 3, 4	Number of Existing Respondents That Are Also New Respondents 5	Number of Respondents (E=A+B-D)		Correction to the 'Number of Existing Respondents That Are Also New Respondents': 1. ICR 1788.10 combined burden associated with the original rule, ICR 1788.09, and burden for the amendment, ICR 2440.02. However, 1788.10, and subsequently 1788.11, did not subtract out the values in Column D, leading to a double counting of the number of new major sources in Column E. That is corrected here. 2. The number of major sources subject to Subpart HH for 2018 in ECHO is 559, therefore, the total number of major sources from prior 1788.11 in year 3 is overestimated. To determine the growth rate for new major sources, we assumed 559 sources in 2018 - 470 sources in 2014 = (559-470)/5 years= ~18 new sources per year. Therefore, we have retained the total number of new major sources(Column A), however, the estimated value of the 'Number of Existing Respondents That Are Also New Respondents' due to new contruction/modification (Column D) has been revised from 25 to 10. This revision appears to more accurately reflect the growth rate of the industry for new (greenfield) major sources. This is QAed below (yellow highlight).
	Major	Area	Area - Only Keep Records	Major	Area	Area	Major	Area + Major
ICR 1788.10
1	28	3	138	470	2,927	2,868	10	3,556
2	28	3	138	488	3,068	3,007	10	3,715
3	28	3	138	506	3,209	3,145	10	3,874
Average	28	3	138	488	3,068	3,007	10	3,715
ICR 1788.11
1	28	3	138	524	3,350	3,283	10	4,033		If there are 28 new major source respondents and 141 new area source respondents each year, and if 10 of the new respondents come from existing sources (major), then the increase in the total 'Number of Respondents' each year should be (28+3+138) - 10 = 159.
2	28	3	138	542	3,491	3,421	10	4,192
3	28	3	138	560	3,632	3,559	10	4,351
Average	28	3	138	542	3,491	3,421	10	4,192		Note to EPA: Data downloaded from ECHO in May 2019 (2018 data) indicates that there are 559 major sources subject to Subpart HH. Assuming that year 2 of ICR 1788.11 (issued in July 2016 with a renewal due in 2019) also represents 2018 data, then the number of major sources shown for year 2 of the current ICR (1788.11) should be close to 559. Total is 542+28-10=560.
ICR 1788.12
1	28	3	138	578	3,773	3,698	10	4,510
2	28	3	138	596	3,914	3,836	10	4,669
3	28	3	138	614	4,055	3,974	10	4,828
Average	28	3	138	596	3,914	3,836	10	4,669
1   New respondents include sources with constructed or reconstructed affected facilities.
2   We assume that there are 141 new area source respondents and 28 new major source respondents.
3   All major sources and 2 percent of area sources will maintain records and submit reports.									Existing	New
4   We assume that 98 percent of area sources will only be required to maintain records.									4510	169
5   We estimate 10 of the 28 new major source respondents are existing respondents that become new respondents due to construction or reconstruction, while 18 of the 28 new major source respondents are new facilities. Of the 10 existing respondents that become new major source respondents due to construction/reconstruction, we assume that all 10 of these existing respondents are already existing major sources.

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Sheet 4: # Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Major sources
Notification of construction/reconstruction	28	1	0	28
Notification of actual startup	28	1	0	28
Notification of date of CMS performance evaluation	28	1	0	28
Notification of date of performance test	28	1	0	28
Notification of compliance status report	28	1	0	28
Affirmative defense and malfunction reports	596	2	0	1,192
Semiannual periodic report	596	2	0	1,192
Area sources
Notification of intent to construct	3	1	0	3
Notification of actual startup date	3	1	0	3
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	78	1	0	78
Affirmative defense and malfunction reports	16	10	0	160
			Total	2,819

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Sheet 5: Capital and O&M Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
THC analyzer (major source) a	$10,200	28	$285,600	$1,020	596	$607,920
Monitoring equipment (CMS) b, c	$1,015	31	$31,465	$134	677	$90,718
Postage cost d	NA	0	$0	$7.63	2,819	$21,511		Total Capital and O&M
Total e			$317,000			$720,000		$1,040,000
a.  Cost information for THC analyzer is from the EPA Air Pollution Control Cost Manual, January 2002, “Table 4.12: Default Analyzer and Monitor Equipment Costs for CEMS ($).” EPA assumes all major sources utilize an organic monitoring device to measure the concentration level of organic compounds in the exhaust vent system. EPA estimates the cost for a TOC/HAP monitor based on the cost of a total hydrocarbon (THC) analyzer.
b. We assume that all new major sources (28) and 2 percent of new area sources (3) are required to purchase CMS per year.
c.  We assume the average number of existing major sources (596), 2% of existing area sources (78), and 3 new area sources have O&M costs associated with CMS.
d. We estimate an average of 2,819 responses (reports).
e.  Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.