Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital and O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	16
Number of Respondents	5,146
Total Estimated Burden Hours	60,600
Total Estimated Costs	$8,390,000
Annualized Capital O&M	$1,110,000
Total Annual Responses	3,781
Form Number	Not Applicable

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Sheet 2: 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	$157.61
3. Reporting requirements										Technical	$123.94
a. Familiarize with regulatory requirements c										Clerical	$62.52
New sources	4	1	4	169	676	33.8	67.6	$93,337.99
Existing sources (major source only)	1	1	1	650	650	32.5	65	$89,748.07
b. Required activities	N/A
Major sources
i. Notification of construction/reconstruction c	2	1	2	28	56	2.8	5.6	$7,732.14
ii. Notification of actual startup c	2	1	2	28	56	2.8	5.6	$7,732.14
iii. Notification of date of CMS performance evaluation c	2	1	2	28	56	2.8	5.6	$7,732.14
iv. Notification of date of performance test c	2	1	2	28	56	2.8	5.6	$7,732.14
v. Notification of compliance status report c	4	1	4	28	112	5.6	11.2	$15,464.28
vi. Affirmative Defense and malfunction reports e	2	2	4	650	2,600	130	260	$358,992.27
vii. Semiannual periodic report e	2	2	4	650	2,600	130	260	$358,992.27
Area sources
i. Notification of intent to construct c	2	1	2	3	6	0.3	0.6	$828.44
ii. Notification of actual startup date c	1	1	1	3	3	0.15	0.3	$414.22
iii. Notification of intent to conduct performance test c, f	2	1	2	16	31.0	1.6	3.1	$4,283.05
iv. Notification of date of CMS performance evaluation c, f	2	1	2	16	31.0	1.6	3.1	$4,283.05
v. Notification of compliance status f	10	1	10	16	155.1	7.8	15.5	$21,415.27
vi. First periodic report g	4	1	4	3	12	0.6	1.2	$1,656.89
vii. Subsequent periodic reports g	2	1	2	87	173	9	17	$23,953.07		2% of existing area sources
viii. Affirmative Defense and malfunction reports h	2	10	20	90	1794.8	89.7	179.5	$247,815.13
c. Create information	N/A
d. Gather existing information c	8	1	8	169	1352	67.6	135	$186,675.98
e. Affirmative defense d	N/A
Subtotal for Reporting Requirements					11,983			$1,438,789
4. Recordkeeping requirements
a. Familiarize with rule requirement
Major source i	4	1	4	28	112	5.6	11.2	$15,464.28
Area source i	4	1	4	141	564	28.2	56.4	$77,873.71
b. Plan activities
Major source	16	1	16	28	448	22.4	44.8	$61,857.13
Area source
i. Sources required to operate add-on controls j	16	1	16	90	1436	72	144	$198,252.10		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	$76,216.82
c. Implement activities
Major source	N/A
Area source
i. Performance test l	35	1	35	16	542.85	27.1425	54.285	$74,953.44
ii. Design analysis l	12	1	12	74	891	45	89	$122,990.75
iii. Control equipment leak monitoring j	3	2	6	90	538	27	54	$74,344.54
iv. Operate and maintain CMS j, m	2	12	24	90	2154	108	215	$297,378.15
d. Develop record system
Major source
i. Control equipment c	8	1	8	28	224	11.2	22.4	$30,928.56
ii. Equipment inspection and monitoring n	13	1	13	650	8450	423	845	$1,166,724.88
Area source
Control equipment o	8	1	8	16	124.08	6.204	12.408	$17,132.22
e. Time to enter information
Major source
i. Control equipment monitoring n, p	1	2	2	650	1300	65	130	$179,496.14
ii. Control device CMS n, p, q	1	12	12	650	7800	390	780	$1,076,976.81
iii. Equipment inspection and monitoring n, p, q	1	12	12	650	7800	390	780	$1,076,976.81
Area source
i. Control equipment leak monitoring j, r	1	2	2	90	179	9	18	$24,781.51
ii. CMS measurements j	1	12	12	90	1077	54	108	$148,689.08
f. Time to train personnel
Major source c, s	8	1	8	28	224	11.2	22.4	$30,928.56
Area source c, s	8	1	8	3	24	1.2	2.4	$3,313.77
g. Maintain records (area source) j, t	20	1	20	90	1795	90	179	$247,815.13
h. Retain records of emission u	1	1	1	4,250	4250	213	425	$586,850.19
i. Retrieve records/reports j, v	20	1	20	90	1795	90	179	$247,815.13
Subtotal for Recordkeeping Requirements					48,622			$5,837,759.70		# response
Total Labor Burden and Costs (rounded) w					60,600			$7,280,000		3,781		60,600
Total Capital and O&M Cost (rounded) w								$1,110,000
GRAND TOTAL (rounded) w								$8,390,000		hr/response
										16.0
Assumptions:
a We assume that on average there are 5,146 existing sources (650 existing major sources and 4,337 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: Managerial $157.61 ($75.05+ 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
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 4,337 existing area sources (87 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 4,337 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 3: 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										Managerial	$70.56
Initial notification c	2	1	2	28	56	2.8	5.6	$3,288.99		Technical	$52.37
Preconstruction review application c	4	1	4	28	112	5.6	11.2	$6,577.98		Clerical	$28.34
Performance test notification c	2	1	2	28	56	2.8	5.6	$3,288.99
Compliance status notification c	4	1	4	28	112	5.6	11.2	$6,577.98
Affirmative Defense and malfunction reports d	2	2	4	650	2,600	130	260	$152,703.20
Semiannual periodic reports e	2	2	4	650	2,600	130	260	$152,703.20
Area sources
Notification of intent to construct	2	1	2	3	6	0.3	0.6	$352.39
Notification of actual startup date	2	1	2	3	6	0.3	0.6	$352.39
Notification of intent to conduct performance test f	2	1	2	16	31.02	1.551	3.102	$1,821.87
Notification of date of CMS performance evaluation	2	1	2	16	31.02	1.551	3.102	$1,821.87
Notification of compliance status	4	1	4	16	62.04	3.102	6.204	$3,643.73
Periodic reports - first and subsequent g	2	1	2	90	179	9.0	18	$10,541.22
Affirmative Defense and malfunction reports h	2	1	2	90	179.48	8.974	17.948	$10,541.22
TOTAL (rounded) i					6,940			$354,000
Assumptions:
a We assume that on average there are 5,146 existing sources (650 existing major sources and 4,337 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 cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for for the benefit packages available to government employees: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
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 4: Capital and O&M

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	650	$663,000
Monitoring equipment (CMS) b, c	$1,015	31	$31,465	$134	740	$99,125
Postage cost d	NA	0	$0	$7.63	3,781	$28,846		Total Capital and O&M
Total e			$317,000			$791,000		$1,110,000
a.  Cost information for THC analyzer is from the EPA Air Pollution Control Cost Manual, January 2002, “Table 4.12: Default Analyzer and Monitor Equipment Costs for CEMS ($).” 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 (650), 2% of existing area sources (87), and 3 new area sources have O&M costs associated with CMS.
d. We estimate an average of 3,781 responses (reports).
e.  Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	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	650	2	0	1,300
Semiannual periodic report	650	2	0	1,300
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	87	1	0	87
Affirmative defense and malfunction reports	90	10	0	897
			Total	3,781

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Sheet 6: Respondents

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)
	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
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
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
ICR 1788.13
1	28	3	138	632	4,196	4,112	10	4,987
2	28	3	138	650	4,337	4,250	10	5,146
3	28	3	138	668	4,478	4,388	10	5,305
Average	28	3	138	650	4,337	4,250	10	5,146
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.
4   We assume that 98 percent of area sources will only be required to maintain records.
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.