Burden Calculation 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	0	532	0	0	532
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.

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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 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: 2,563 responses, 27 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

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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)
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	$149.84
3. Acquisition, installation, and utilization of technology and systems	N/A									Technical	$122.66
4. Report requirements	N/A									Clerical	$60.88
a. Familiarization with the rule requirements c	1	1	1	532	532	26.6	53.2	$72,479.68
b. Required activities
i. Notification of gas well completion d	0.5	33	17	0	0	0	0	$0
ii. Notification of gas well recompletion d	0.5	4	2	0	0	0	0	$0		Source Type	No.
iii. Notification of new gas processing plant e	1	1	1	0	0	0	0	$0		Existing	532
iv. Notification of new sweetening unit f	1	1	1	0	0	0	0	$0		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		New	0
ii. Sweetening unit f	1	1	1	9	9	0.45	0.9	$1,226.16		Processing plants	0
iii. Centrifugal compressor g	8	1	8	39	312	16	31	$42,506.88		Sweetening units	0
iv. Reciprocating compressor h	8	1	8	1,676	13,408	670	1,341	$1,826,705.92
v. Production pneumatic controller i	8	1	8	300	2,400	120	240	$326,976.00
vi. Gas processing pneumatic controller j	8	1	8	45	360	18	36	$49,046.40
vii. Storage vessel k	8	1	8	304	2,432	122	243	$331,335.68
f. Semiannual reports
i. Gas processing plant l	40	2	80	87	6,960	348	696	$948,230.40
Reporting Subtotal					30,375			$3,598,507
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	$3,564,038.40
ii. Filing and maintaining records n	5	12	60	128	7,680	384	768	$1,046,323.20
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			$4,610,362
TOTAL LABOR BURDEN AND COST (rounded) o					69,300			$8,210,000
TOTAL CAPITAL AND O&M COST (rounded) o								$1,220,000
GRAND TOTAL (rounded) o								$9,430,000
N/A - Not Applicable
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: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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.

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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)
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		Management	$69.04
ii. Notification of gas well recompletion	0.5	4	2	0	0	0	0	$0		Technical	$51.23
iii. Notification of new gas processing plant	0.5	1	1	0	0	0	0	$0		Clerical	$27.73
iv. Notification of new sweetening unit	0.5	1	1	0	0	0	0	$0
Review annual reports
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	$517.10
iii. Centrifugal compressor	1	1	1	39	39	1.95	3.9	$2,240.75
iv. Reciprocating compressor	1	1	1	1,676	1,676	83.80	167.6	$96,294.58
v. Production pneumatic controller	1	1	1	300	300	15	30	$17,236.50
vi. Gas processing pneumatic controller	1	1	1	45	45	2.25	4.5	$2,585.48
vii. Storage vessel	1	1	1	304	304	15	30	$17,466.32
Review semiannual reports
i. Gas processing plant	1	2	2	87	174	8.7	17	$9,997.17
TOTAL (rounded) c					2,900			$146,000
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 $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 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.

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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	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.