Calculation Tables

2478t03.xlsx

Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa, and Arikara Nation), North Dakota (Renewal)

Calculation Tables

OMB: 2008-0001

Document [xlsx]
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Overview

Year 1
Year 2
Year 3
Agency Year 1
Agency Year 2
Agency Year 3
Other Data for SupportStatement
Conversion into 2018 dollars
Respondents-Facilities Data


Sheet 1: Year 1

Exhibit 1a. Year 1 Respondent Burden of Reporting and Recordkeeping Requirements
Labor Rates Labor rates were obtained from http://www.bls.gov/news.release/ecec.toc.htm (September 2015)
Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa, and Arikara Nation), North Dakota
Technical 35.92















Managerial 59.86
Year (A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)
Clerical 26.5
Person-Hours per Occurrence Number of Occurences per Respondent per Year Person-Hours per Respondent per Year (A*B) Respondents per Year Technical Person-Hours per Year (C*D) Managerial Person-Hours per Year (0.05*E) Clerical Person-Hours per Year (0.10*E) Capital/Startup Costa O&M Costa,i Labor Costb Total Cost per Year
FIP Requirement

1. APPLICATIONS (Not Applicable)
Inflation to 2018 dollars 1.068 or 6.8%
2. SURVEY AND STUDIES (Not Applicable)



3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS





Continous pilot or auto-ignition system with continous monitoring/recordingc 24 1 24 2221 53,304 2,665 5,330 $3,470 $5,073 $2,215,474 $21,189,477.15
§ 49.4165(c)(6)(iv)

4. RECORDKEEPING REQUIREMENTS




A. Read Instructions







Existing sourcesd 1 0.059 0.059 2000 118 6 12 $0 $0 $4,904 $4,904





New affected sourcese 1 0.059 0 221 13 1 1 $0 $0 $542 $542




B. Required Activities







Measure barrels of oil producedf 0 1 0 2221 0 0 0 $0 $0 $0 $0
§ 49.4167(a)(1)



Volume of produced natural gas sent to control devicef 0 1 0 2221 0 0 0 $0 $0 $0 $0
§ 49.4167(a)(2)



Volume of natural gas emissions sent to control device 1 1 1 2221 2,221 111 222 $0 $0 $92,311 $92,311
§ 49.4167(a)(3)



Well completion and recompletion operations 2 1 2 2221 4,442 222 444 $0 $0 $184,623 $184,623
§ 49.4167(a)(4)



Control device monitoring and deviations 8 1 8 2221 17,768 888 1,777 $0 $0 $738,491 $738,491
§ 49.4167(a)(5)



Restricted use of pit flaresg 0.5 0.059 0 2221 66 3 7 $0 $0 $2,723 $2,723
§ 49.4167(a)(6)



Closed-vent system or control device not operatingg 0.5 0.059 0 2221 66 3 7 $0 $0 $2,723 $2,723
§ 49.4167(a)(7)



Produced oil and water storage tank inspections 4 1 4 2221 8,884 444 888 $0 $0 $369,246 $369,246
§ 49.4167(a)(8)



Records retention requirements 0.25 1 0 2221 555 28 56 $0 $0 $23,078 $23,078
§ 49.4167(b) and (c)


C. Train Personnel
Included in 3




Recordkeeping Requirement Subtotal 87,436 4,372 8,744 $3,470 $5,073 $1,418,642 $22,608,119




100,552 $8,543



5. REPORTING REQUIREMENTS




A. Read Instructions
Included in 4A




B. Required Activities







Annual reporth 20 0.059 1.18 937 1,106 55 111 $0 $0 $45,955 $45,955
§ 49.4168(b)


C. Create information
Included in 5B




D. Gather existing information
Included in 5B




E. Write report
Included in 5B




Reporting Requirement Subtotal 1,106 55 111 $0 $0 $45,955 $45,955




1,272 $0



TOTAL REPORTING AND RECORDKEEPING LABOR AND COST 88,542 4,427 8,854 $3,470 $5,073 $3,680,071 $22,654,074



101,823 $8,543





















a Capital and O&M Costs are per respondent (1 respondent = 1 oil and natural gas production facility)



b Costs are based on September 2018 Bureau of Labor Statistics, Employer Costs for Employee Compensation total compensation index which includes wages, salaries, and benefits. Costs are estimated using the following hourly rates: technical at $35.92, management at $59.82, and clerical at $26.50. (Source: http://www.bls.gov/news.release/ecec.toc.htm, Table 2)



c Annual total capital investment costs were determined using cost information and the appropriate CRF factor for the life expectancy of equipment provided by 2 of the FBIR operators. Additionaly, annual O&M cost specific to auto-ignition systems and continuous pilot flame systems were provided by the 2 operators. There is no "purchase of services component" cost for the monitoring requirements in this FIP.



d Existing sources in Year 1 are estimated to be 2,000 oil and natural gas facilities. This number was calculated using the total estimated number of existing sources subject to the FIP in April 2019. (Source: https://info.drillinginfo.com)



e New sources for Year 1 are estimated to be 221 oil and natural gas facilities. This is based on data available at https://info.drillinginfo.com/ for 2016-2018. This estimate is consistent with the number of new facilities reported in annual reports and therefore suffices as an appropriate and accurate data source rather than manually tallying data from hard copy reports.



f Burden for recordkeeping of measured barrels of oil and produced natural gas vented to flare is covered under another ICR for OMB Control Number 1012-0004.



g Recordkeeping only required under specific circumstances which are not expected to occur regularly at each facility. The number of occurences per respondent per year has been reduced to 0.059 to reflect this assumption.



h The rule allows each owner/operator to submit a combined annual report for all of their respective facilities in 1 submittal once per year. Currently there are 17 known owners/operators subject to the FIP requirements. Therefore, we have reduced the number of occurences per respondent per year to 0.059 to conservatively account for 1 submittal per each owner/operator for all of facilities subject to the FIP.



i O&M costs were adjusted from 2015 dollars to 2018 dollars for the ICR renewal




Sheet 2: Year 2

Exhibit 1b. Year 2 Respondent Burden of Reporting and Recordkeeping Requirements













Labor Rates Labor rates were obtained from http://www.bls.gov/news.release/ecec.toc.htm (September 2015)
Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa, and Arikara Nation), North Dakota
Technical 35.92















Managerial 59.86
Year (A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)
Clerical 26.5
Person-Hours per Occurrence Number of Occurences per Respondent per Year Person-Hours per Respondent per Year (A*B) Respondents per Year Technical Person-Hours per Year (C*D) Managerial Person-Hours per Year (0.05*E) Clerical Person-Hours per Year (0.10*E) Capital/Startup Costa O&M Costa,i Labor Costb Cost per Year
FIP Requirement

1. APPLICATIONS (Not Applicable)
Inflation to 2018 dollars 1.068 or 6.8%
2. SURVEY AND STUDIES (Not Applicable)



3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS





Continous pilot or auto-ignition system with continous monitoring/recordingc 24 1 24 2,442 58,608 2,930 5,861 $3,470 $5,073 $2,435,924 $23,297,930
§ 49.4165(c)(6)(iv)

4. RECORDKEEPING REQUIREMENTS




A. Read Instructions







Existing sourcesd 0 0 0 2221 0 0 0 $0 $0 $0 $0





New affected sourcese 1 0.059 0 221 13 1 1 $0 $0 $542 $542




B. Required Activities







Measure barrels of oil producedf 0 1 0 2,442 0 0 0 $0 $0 $0 $0
§ 49.4167(a)(1)



Volume of produced natural gas sent to control devicef 0 1 0 2,442 0 0 0 $0 $0 $0 $0
§ 49.4167(a)(2)



Volume of natural gas emissions sent to control device 1 1 1 2,442 2,442 122 244 $0 $0 $101,497 $101,497
§ 49.4167(a)(3)



Well completion and recompletion operations 2 1 2 2,442 4,884 244 488 $0 $0 $202,994 $202,994
§ 49.4167(a)(4)



Control device monitoring and deviations 8 1 8 2,442 19,536 977 1,954 $0 $0 $811,975 $811,975
§ 49.4167(a)(5)



Restricted use of pit flaresg 0.5 0.059 0 2,442 72 4 7 $0 $0 $2,994 $2,994
§ 49.4167(a)(6)



Closed-vent system or control device not operatingg 0.5 0.059 0 2,442 72 4 7 $0 $0 $2,994 $2,994
§ 49.4167(a)(7)



Produced oil and water storage tank inspections 4 1 4 2,442 9,768 488 977 $0 $0 $405,987 $405,987
§ 49.4167(a)(8)



Records retention requirements 0.25 1 0 2,442 611 31 61 $0 $0 $25,374 $25,374
§ 49.4167(b) and (c)


C. Train Personnel
Included in 3




Recordkeeping Requirement Subtotal 96,006 4,800 9,601 $3,470 $5,073 $1,554,357 $24,852,287




110,406 $8,543



68




A. Read Instructions
Included in 4A




B. Required Activities







Annual reporth 20 0.059 1.18 1,094 1,291 65 129 $0 $0 $53,655 $53,655
§ 49.4168(b)


C. Create information
Included in 5B




D. Gather existing information
Included in 5B




E. Write report
Included in 5B




Reporting Requirement Subtotal 1,291 65 129 $0 $0 $53,655 $53,655




1,485 $0



TOTAL REPORTING AND RECORDKEEPING LABOR AND COST 97,297 4,865 9,730 $3,470 $5,073 $4,043,936 $24,905,942



111,891 $8,543





















a Capital and O&M Costs are per respondent (1 respondent = 1 oil and natural gas production facility)



b Costs are based on September 2018 Bureau of Labor Statistics, Employer Costs for Employee Compensation total compensation index which includes wages, salaries, and benefits. Costs are estimated using the following hourly rates: technical at $35.92, management at $59.82, and clerical at $26.50. (Source: http://www.bls.gov/news.release/ecec.toc.htm, Table 2)



c Annual total capital investment costs were determined using cost information and the appropriate CRF factor for the life expectancy of equipment provided by 2 of the FBIR operators. Additionaly, annual O&M cost specific to auto-ignition systems and continuous pilot flame systems were provided by the 2 operators. There is no "purchase of services component" cost for the monitoring requirements in this FIP.



d Existing sources in Year 2 are estimated to be 2,221 oil and natural gas facilities based on Year 1 numbers. There is no cost for existing sources to read instructons because it is covered under prior year.



e New sources for Year 2 are estimated to be 221 oil and natural gas facilities. This is based on data available at https://info.drillinginfo.com/ for 2016-2018. This estimate is consistent with the number of new facilities reported in annual reports and therefore suffices as an appropriate and accurate data source rather than manually tallying data from hard copy reports.



f Burden for recordkeeping of measured barrels of oil and produced natural gas vented to flare is covered under another ICR for OMB Control Number 1012-0004.



g Recordkeeping only required under specific circumstances which are not expected to occur regularly at each facility. The number of occurences per respondent per year has been reduced to 0.059 to reflect this assumption.



h The rule allows each owner/operator to submit a combined annual report for all of their respective facilities in 1 submittal once per year. Currently there are 17 known owners/operators subject to the FIP requirements. Therefore, we have reduced the number of occurences per respondent per year to 0.059 to conservatively account for 1 submittal per each owner/operator for all of facilities subject to the FIP.



i O&M costs were adjusted from 2015 dollars to 2018 dollars for the ICR renewal




Sheet 3: Year 3

Exhibit 1c. Year 3 Respondent Burden of Reporting and Recordkeeping Requirements













Labor Rates Labor rates were obtained from http://www.bls.gov/news.release/ecec.toc.htm (September 2015)
Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa, and Arikara Nation), North Dakota
Technical 35.92















Managerial 59.82
Year (A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)
Clerical 26.5
Person-Hours per Occurrence Number of Occurences per Respondent per Year Person-Hours per Respondent per Year (A*B) Respondents per Year Technical Person-Hours per Year (C*D) Managerial Person-Hours per Year (0.05*E) Clerical Person-Hours per Year (0.10*E) Capital/Startup Costa O&M Costa,i Labor Costb Cost per Year
FIP Requirement

1. APPLICATIONS (Not Applicable)
Inflation to 2018 dollars 1.068 or 6.8%
2. SURVEY AND STUDIES (Not Applicable)



3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS





Continous pilot or auto-ignition system with continous monitoring/recordingc 24 1 24 2,663 63,912 3,196 6,391 $3,470 $5,073 $2,656,247 $25,406,255.63
§ 49.4165(c)(6)(iv)

4. RECORDKEEPING REQUIREMENTS




A. Read Instructions







Existing sourcesd 0 0 0 2442 0 0 0 $0 $0 $0 $0





New affected sourcese 1 0.059 0 221 13 1 1 $0 $0 $542 $542




B. Required Activities







Measure barrels of oil producedf 0 1 0 2,663 0 0 0 $0 $0 $0 $0
§ 49.4167(a)(1)



Volume of produced natural gas sent to control devicef 0 1 0 2,663 0 0 0 $0 $0 $0 $0
§ 49.4167(a)(2)



Volume of natural gas emissions sent to control device 1 1 1 2,663 2,663 133 266 $0 $0 $110,677 $110,677
§ 49.4167(a)(3)



Well completion and recompletion operations 2 1 2 2,663 5,326 266 533 $0 $0 $221,354 $221,354
§ 49.4167(a)(4)



Control device monitoring and deviations 8 1 8 2,663 21,304 1,065 2,130 $0 $0 $885,416 $885,416
§ 49.4167(a)(5)



Restricted use of pit flaresg 0.5 0.059 0 2,663 79 4 8 $0 $0 $3,265 $3,265
§ 49.4167(a)(6)



Closed-vent system or control device not operatingg 0.5 0.059 0 2,663 79 4 8 $0 $0 $3,265 $3,265
§ 49.4167(a)(7)



Produced oil and water storage tank inspections 4 1 4 2,663 10,652 533 1,065 $0 $0 $442,708 $442,708
§ 49.4167(a)(8)



Records retention requirements 0.25 1 0 2,663 666 33 67 $0 $0 $27,669 $27,669
§ 49.4167(b) and (c)


C. Train Personnel
Included in 3




Recordkeeping Requirement Subtotal 104,693 5,235 10,469 $3,470 $5,073 $1,694,895 $27,101,151




120,397 $8,543



5. REPORTING REQUIREMENTS




A. Read Instructions
Included in 4A




B. Required Activities







Annual reporth 20 0.059 1.18 1,251 1,476 74 148 $0 $0 $61,352 $61,352
§ 49.4168(b)


C. Create information
Included in 5B




D. Gather existing information
Included in 5B




E. Write report
Included in 5B




Reporting Requirement Subtotal 1,476 74 148 $0 $0 $61,352 $61,352




1,698 $0



TOTAL REPORTING AND RECORDKEEPING LABOR AND COST 106,169 5,308 10,617 $3,470 $5,073 $4,412,493 $27,162,502



122,094 $8,543





















a Capital and O&M Costs are per respondent (1 respondent = 1 oil and natural gas production facility)



b Costs are based on September 2018 Bureau of Labor Statistics, Employer Costs for Employee Compensation total compensation index which includes wages, salaries, and benefits. Costs are estimated using the following hourly rates: technical at $35.92, management at $59.82, and clerical at $26.50. (Source: http://www.bls.gov/news.release/ecec.toc.htm, Table 2)



c Annual total capital investment costs were determined using cost information and the appropriate CRF factor for the life expectancy of equipment provided by 2 of the FBIR operators. Additionaly, annual O&M cost specific to auto-ignition systems and continuous pilot flame systems were provided by the 2 operators. There is no "purchase of services component" cost for the monitoring requirements in this FIP.



d Existing sources in Year 3 are estimated to be 2,442 oil and natural gas facilities based on Year 3 numbers. There is no cost for existing sources to read instructions because it is covered under the prior year.



e New sources for Year 3 are estimated to be 221 oil and natural gas facilities. This is based on data available at https://info.drillinginfo.com/ for 2016-2018. This estimate is consistent with the number of new facilities reported in annual reports and therefore suffices as an appropriate and accurate data source rather than manually tallying data from hard copy reports.



f Burden for recordkeeping of measured barrels of oil and produced natural gas vented to flare is covered under another ICR for OMB Control Number 1012-0004.



g Recordkeeping only required under specific circumstances which are not expected to occur regularly at each facility. The number of occurences per respondent per year has been reduced to 0.059 to reflect this assumption.



h The rule allows each owner/operator to submit a combined annual report for all of their respective facilities in 1 submittal once per year. Currently there are 17 known owners/operators subject to the FIP requirements. Therefore, we have reduced the number of occurences per respondent per year to 0.059 to conservatively account for 1 submittal per each owner/operator for all of facilities subject to the FIP.



i O&M costs were adjusted from 2015 dollars to 2018 dollars for the ICR renewal




Sheet 4: Agency Year 1

Exhibit 2a. Year 1 Agency Burden and Cost









Labor Rates Labor rates based on 2018 federal salary table including locality pay for Denver, Colorado at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/DEN_h.pdf
Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa, and Arikara Nation), North Dakota
Technical $72.75 (Includes multiplier of 1.6)











Managerial $97.42 (Includes multiplier of 1.6)
Activity - Year 1 (A) (B) (C) (D) (E) (F) (G) (H)
Clerical $36.78 (Includes multiplier of 1.6)
EPA Hours per Occurrence Number of Occurences per Respondent per Year EPA Hours per Respondent per Year (A*B) Respondents per Year EPA Technical Hours per Year (C*D) EPA Managerial Hours per Year (0.05*E) EPA Clerical Hours per Year (0.10*E) EPA Cost per Yeara
FIP Requirement

REPORTING REQIUREMENTS













Review annual reportsb 1 1 1 2,221 2,221 111 222 $180,565
§ 49.4168(b)

Total Annual Hours 2,221 111 222 $180,565



2,554



a Costs are based on January 2018 Office of Personnel Management salary table for General Schedule (GS) federal employees including locality payment of 25.47% for the Denver, Colorado area and have been increased by 60% to account for benefit packages. Costs are estimated using the following rates: technical at $72.75, management at $97.42, and clerical at $36.78.



b Assumes 1,338 oil and natural gas production facilities will submit annual reports in Year 1.




Sheet 5: Agency Year 2

Exhibit 2b. Year 2 Agency Burden and Cost









Labor Rates Labor rates based on 2018 federal salary table including locality pay for Denver, Colorado at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/DEN_h.pdf
Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa, and Arikara Nation), North Dakota
Technical $72.75 (Includes multiplier of 1.6)











Managerial $97.42 (Includes multiplier of 1.6)
Activity - Year 2 (A) (B) (C) (D) (E) (F) (G) (H)
Clerical $36.78 (Includes multiplier of 1.6)
EPA Hours per Occurrence Number of Occurences per Respondent per Year EPA Hours per Respondent per Year (A*B) Respondents per Year EPA Technical Hours per Year (C*D) EPA Managerial Hours per Year (0.05*E) EPA Clerical Hours per Year (0.10*E) EPA Cost per Yeara
FIP Requirement

REPORTING REQIUREMENTS













Review annual reportsb 1 1 1 2,442 2,442 122 244 $198,532
§ 49.4168(b)

Total Annual Hours 2,442 122 244 $198,532



2,808



a Costs are based on January 2018 Office of Personnel Management salary table for General Schedule (GS) federal employees including locality payment of 25.47% for the Denver, Colorado area and have been increased by 60% to account for benefit packages. Costs are estimated using the following rates: technical at $72.75, management at $97.42, and clerical at $36.78.



b Assumes 1,475 oil and natural gas production facilities will submit annual reports in Year 2.




Sheet 6: Agency Year 3

Exhibit 2c. Year 3 Agency Burden and Cost









Labor Rates Labor rates based on 2018 federal salary table including locality pay for Denver, Colorado at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/DEN_h.pdf
Federal Implementation Plan for Oil and Natural Gas Well Production Facilities; Fort Berthold Indian Reservation (Mandan, Hidatsa, and Arikara Nation), North Dakota
Technical $72.75 (Includes multiplier of 1.6)











Managerial $97.42 (Includes multiplier of 1.6)
Activity - Year 3 (A) (B) (C) (D) (E) (F) (G) (H)
Clerical $36.78 (Includes multiplier of 1.6)
EPA Hours per Occurrence Number of Occurences per Respondent per Year EPA Hours per Respondent per Year (A*B) Respondents per Year EPA Technical Hours per Year (C*D) EPA Managerial Hours per Year (0.05*E) EPA Clerical Hours per Year (0.10*E) EPA Cost per Yeara
FIP Requirement

REPORTING REQIUREMENTS













Review annual reportsb 1 1 1 2,663 2,663 133 266 $216,499
§ 49.4168(b)

Total Annual Hours 2,663 133 266 $216,499



3,062



a Costs are based on January 2018 Office of Personnel Management salary table for General Schedule (GS) federal employees including locality payment of 25.47% for the Denver, Colorado area and have been increased by 60% to account for benefit packages. Costs are estimated using the following rates: technical at $72.75, management at $97.42, and clerical at $36.78.



b Assumes 1,695 oil and natural gas production facilities will submit annual reports in Year 3.




Sheet 7: Other Data for SupportStatement

Calculated Information from tables included in text of Supporting Statement (used 3 significant figures)

Use for background info. only, not meant for inclusion as table in supporting statement




Section of Suporting Statement Calculation Result
1b average annual hours burden - respondent 111,936
1b average annual total costs - respondent 24,907,506
1b Annual average capital/startup costs $8,473,740
1b annual average O&M costs $12,388,266
6a year 1 labor costs $3,680,071
6a year 2 labor costs $4,043,936
6a year 3 labor costs $4,412,493
6a total labor costs $12,136,500
6a average annual labor costs $4,045,500
6d average # of respondents 2,442
6e average annual agency hours 2,808
6e average annual agency costs $198,532
6g average hours per response 45.8

Sheet 8: Conversion into 2018 dollars

Conversion to 2018 Dollars.






used website: https://research.stlouisfed.org/fred2/series/GDPDEF


website gives the gross domestic product: implicit price deflator, Alex Macpherson from HQ recommended using this index to inflate 2012 dollars to 2015 dollars for the U&O FIP, was used in the CTGs to inflate dollars.


this was also used in 2016 ICR renewal






Q1: 2015 104.148




111.190/104.148 = 1.068 or 6.8%
Q4: 2018 111.19





(Dates used 01/01/2015 - 10/01/2018 October was the last available data for 2018)


(numbers pulled from website 04/16/2019)



Sheet 9: Respondents-Facilities Data

Summary of first production dates obtained from website: https://info.drillinginfo.com/






Total of approximately 2,000 wells and 17 operators are located within the exterior boundary of the Fort Berthold Indian Reservation























Year Estimated Respondents/Facilities Column1




2019 (Thru Feb only) 15 + 50 (see Confidential below) = 65




2018 255 + 50 (see Confidential below) = 305 Average of 2016 thru 2018 =

221

2017
220




2016
137













Confidential wells = 100; split evenly between 2018 and 2019




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