2523ss06 (2060-AT54 final rule supporting statement)

SUPPORTING STATEMENT
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction,
Modification or Reconstruction Commenced After September 18, 2015
(40 CFR part 60, subpart OOOOa)
PART A
1.0

Identification of the Information Collection

(a)

Title and Number of the Information Collection.
The title of the Information Collection Request (ICR) is Standards of Performance for

Crude Oil and Natural Gas Facilities for Construction, Modification, or Reconstruction
Commenced After September 18, 2015 (40 CFR part 60, subpart OOOOa), U.S. Environmental
Protection Agency (EPA) tracking number is 2523.04, Office of Management and Budget (OMB)
Control Number 2060-0721.
(b)

Short Characterization.
On June 3, 2016, the EPA published the final rule for NSPS for the oil and natural gas

sector (“2016 NSPS OOOOa”).1 The oil and natural gas sector includes operations involved in the
extraction and production of oil and natural gas, as well as the processing, transmission, and
distribution of natural gas. The 2016 NSPS OOOOa established standards for volatile organic
compounds (VOC) and greenhouse gas (GHG) emissions from the oil and natural gas sector. This
included requirements for various segments of the industry including oil and natural gas
production, gas processing, and natural gas transmission and storage.
On March 28, 2017, President Donald Trump issued Executive Order 13783, entitled
“Promoting Energy Independence and Economic Growth,” which directs agencies to review
existing regulations that potentially burden the development of domestic energy resources, and
appropriately suspend, revise, or rescind regulations that unduly burden the development of U.S.
energy resources beyond what is necessary to protect the public interest or otherwise comply with
the law. The EPA is finalizing amendments to 2016 NSPS OOOOa as a result of this Executive
Order 13783 review (hereafter referred to as “Policy Review”). These amendments remove
sources in the transmission and storage segment from the source category, rescind the NSPS
(including both the volatile organic compounds (VOC) and methane requirements) applicable to

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those sources, and rescind the methane-specific requirements of the NSPS applicable to sources in
the production and processing segments.
In addition, following promulgation of the 2016 NSPS OOOOa, the Administrator
received petitions for reconsideration of several provisions of the 2016 NSPS OOOOa. The EPA
granted reconsideration of the fugitive emissions requirements at well sites and compressor
stations, well site pneumatic pump standards, the requirements for certification of closed vent
systems, and the provisions to apply for the use of an alternative means of emission limitation.
The EPA published proposed amendments to the NSPS OOOOa rule on October 15, 2018, in
response to these petitions.2
In addition to the changes associated with the Policy Review, the EPA is finalizing
changes and clarifications as a result of their reconsideration (hereafter referred to as
“Reconsideration Amendments”). The final Reconsideration Amendments also address other
issues raised, as well as revisions that provide clarity and certainty for the public and the regulated
community and more broadly provides streamlining and alignment of requirements.
Therefore, this ICR reflects the EPA’s final amendments to 2016 NSPS OOOOa as a result
of their Policy Review combined with the Reconsideration Amendments. The information
collected will be used by the EPA and delegated state and local agencies to determine the
compliance status of affected facilities subject to the rule.
The respondents are owners or operators of onshore oil and natural gas affected facilities
(40 CFR 60.5365a). For the purposes of this ICR, it is assumed that oil and natural gas affected
facilities located in the United States are owned and operated by the oil and natural gas industry
(the “Affected Public”), and that none of the affected facilities in the United States are owned or
operated by state, local, tribal or the Federal government. All affected facilities are assumed to be
privately owned for-profit businesses.
The original burden estimated for the 2016 NSPS OOOOa has been updated to 689,154
hours and $110,336,343 ($2016) on a 3-year annual average in order to reflect a more reasonable
estimate of the recordkeeping and reporting burden. The updated 2016 NSPS OOOOa baseline is
discussed in section 6(f)(i) of this supporting statement. The EPA estimates an average of 519
respondents will be affected by NSPS OOOOa over the three-year period (2021-2023). The
average annual burden for the recordkeeping and reporting requirements for these owners and
2

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operators is 374,988 person-hours, with an average annual cost of $71,958,301 over the three-year
period (2021-2023). The information collection activities associated with the amendments will
result in an estimated average annual burden reduction of 35 percent on a cost basis compared to
the updated 2016 NSPS OOOOa baseline. See section 6.f.i below for a description of the updated
2016 NSPS OOOOa burden estimate.
2.

Need For and Use of the Collection

(a)

Need/Authority for the Collection.
The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to

establish standards of performance for new stationary sources that reflect:
. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health
and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated.
Section 111(a)(l).
The Agency refers to this charge as selecting the best system of emissions reduction
(BSER). Section 111 of the CAA also requires that the Administrator review and, if appropriate,
revise such standards every 8 years.
In addition, section 114(a) of the CAA states that the Administrator may require any owner
or operator subject to any requirement of this Act to:
•

establish and maintain such records;

•

make such reports;

•

install, use, and maintain such monitoring equipment;

•

use such audit procedures, or methods;

•

sample such emissions (in accordance with such procedures or methods,
at such locations, at such intervals, during such periods, and in such
manner as the Administrator shall prescribe);

•

keep records on control equipment parameters, production variables or
other indirect data when direct monitoring of emissions is impractical;

•

submit compliance certifications in accordance with section 114(a)(3) of
the CAA; and

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•

provide such other information as the Administrator may reasonably
require.

The information collection activities being finalized under the amended NSPS OOOOa are
necessary for the Administrator to confirm the compliance status of new and modified oil and
natural gas affected facilities. These recordkeeping and reporting requirements are authorized by
CAA section 114.
(b)

Practical Utility/Users of the Data.
The information will be used by the delegated authority (state agency, or Regional

Administrator if there is no delegated state agency) to ensure that the standards and other
requirements of NSPS OOOOa are being achieved. Based on review of the recorded information
at the site and the reported information, the delegated permitting authority can identify affected
facilities that may not be in compliance and decide which affected facilities, records, or processes
may need inspection.
3.

Nonduplication, Consultations, and Other Collection Criteria

(a)

Nonduplication.
The information-gathered under the amended NSPS OOOOa will replace the information

gathered under the rule prior to being amended. Where it was deemed applicable, the
recordkeeping and reporting requirements for the 2016 NSPS OOOOa were developed following
similar reporting requirements as outlined in “Mandatory Reporting of Greenhouse Gases: Subpart
W Oil and Natural Gas” in 40 CFR 98.2 and 40 CFR 98.4. By remaining consistent with subpart
W, the EPA reduced the burden required to monitor and show compliance. In addition, if a State
or local agency has adopted their own similar standards to implement the Federal standards, a
copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of
the report required by the Federal standards.3 Therefore, no duplication exists.
(b)

Public Notice Required Prior to ICR Submission to OMB.
The final preamble for the amendments as a result of the Policy Review and

Reconsideration Amendments provided public notice of this ICR during the proposal rule phase.
The EPA considered the comments received when preparing this final ICR and the preamble to the
3

For example, paragraph 60.5420a(a)(2)(ii) states that “If you are subject to state regulations that require
advance notification of well completions and you have met those notification requirements, then you are
considered to have met the advance notification requirements of paragraph (a)(2)(i) of this section.”

4

final rule provides public notice on this ICR. Specifically, comments were received indicating that
the recordkeeping and reporting burden for the 2016 NSPS OOOOa was significantly
underestimated. After consideration of these comments, the EPA updated the assessment of the
recordkeeping and reporting burden for the 2016 NSPS OOOOa, as discussed in section 6(f)(i) of
this supporting statement. The EPA also included revisions to the ICR activities that will reduce
the burden associated with reporting and recordkeeping requirements on the regulated industry.
(c)

Consultations.
In developing the final NSPS OOOOa, the EPA performed a comprehensive review of

existing state rules and industry standards, consulted with individual companies and trade
organizations, state agencies, and environmental groups, and consider public comments from a
variety of interests. The main organizations that provided expert advice during the development of
this rule include the Agency’s industry experts. Stakeholder meetings and contacts are
documented in the docket for the 2016 NSPS OOOOa (Docket No. EPA-HQ-OAR-2010-0505),
the docket for the Reconsideration Amendments (Docket No. EPA-HQ-OAR-2017-0483), and the
docket for the Policy Review (Docket No. EPA-HQ-OAR-2017-0757).
(d)

Effects of Less Frequent Collection.
Respondents must monitor all specified criteria at each affected facility and maintain these

records for 2 years, as specified under 40 CFR 60.7. The reporting frequency to the EPA has been
established/amended to minimize the burden on owners and operators of affected facilities. If the
information required by NSPS OOOOa were collected less frequently, the likelihood of detecting
violations would be reduced.
(e)

General Guidelines.
This collection of information is consistent with all OMB guidelines established by OMB

at 5 CFR part 1320, section 1320.5.
(f)

Confidentiality.
All information submitted to the Agency for which a claim of confidentiality is made will

be safeguarded according to the EPA regulations set forth in 40 CFR 2.201 et seq., Chapter 1, Part
2, Subpart B-Confidentiality of Business Information.

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(g)

Sensitive Questions.
This section is not applicable because this ICR does not involve matters of a sensitive

nature.
4.

The Respondents and the Information Requested

(a)

Respondents/NAICS Codes.
Potential respondents under NSPS OOOOa after both the Policy Review final amendments

and the final reconsideration amendments are owners or operators of new, modified or
reconstructed oil and natural gas affected facilities as defined under the rule. The North American
Industry Classification System (NAICS) codes for the oil and gas industry include: 211120 (Crude
Petroleum Extraction); 211130 (Natural Gas Extraction); and 486210 (Pipeline Transportation of
Natural Gas).

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(b)

Information Requested.

(i)

Data Items, Including Recordkeeping Requirements
Recordkeeping

For well affected facilities, record location and well identification information. Maintain completion log records
for each completion operation. For wells exempt from one or more requirements, maintain records to support
exemption.
For well affected facilities with ≤300 scf of gas per stock tank barrel of oil produced, keep records to
demonstrate exemption.
For centrifugal compressor affected facilities, maintain records related to equipment, purchase, location, and
control. Develop site-specific monitoring plan. Maintain compliance records for control device including
continuous parameter monitoring results, visible emission observation results, inspection results, corrective
actions, and maintenance. Maintain certification of closed vent system (CVS) capacity; record results of CVS
and by-pass inspections, maintenance, and corrective actions. Maintain records for no detectable emissions
requirement.

60.5375a(b); 60.5410a(a); 60.5415a(a);
60.5420a(c)(1)
60.5375a(g)(2); 60.5420a(c)(1)(vi).
60.5380a(d); 60.5410a(b)(8);
60.5411a(a)(3)(i)(A); 60.5411a(d); 60.5412a(c)
and (d); 60.5413a(d) and (e); 60.5415a(b);
60.5416a(a) and (b); 60.5417a(c), (e), and (f);
60.5420a(c)(2), (6)-(9), and (17).

For reciprocating compressor affected facilities, maintenance records of rod packing replacement and operating
data.

60.5385a(d); 60.5410a(c)(4); 60.5415a(c);
60.5420a(c)(3)

For reciprocating compressor affected facilities that collect emissions through a CVS to a process, maintain
certification of CVS capacity; record results of CVS and by-pass inspections, maintenance, and corrective
actions. Maintain records for no detectable emissions requirement.

60.5385a(d); 60.5410a(c)(4);
60.5411a(a)(3)(i)(A); 60.5411a(d); 60.5416a(a)
and (b)(13); 60.5420a(c)(3), (6)-(9), and (17).

For pneumatic controller affected facilities, maintain information related to equipment, purchase, and location.
Requirements to tag devices. Documentation of bleed rate and justification for use of device >6 scfh.

60.4390a(a), (b)(2), (c)(2), (f); 60.5410a(d)(4)
and (6); 60.5413a(d)(3); 60.5420a(c)(4)

For pneumatic pump affected facilities that are not controlled, maintain information related to equipment,
purchase, location, and manufacturer specifications. Prepare and submit applicable certification and maintain
records. Maintain information related to equipment, purchase, location, and manufacturer specifications.

60.5393a(b)(3)-(5); 60.5393a(e); 60.5410a(e)(8);
60.5420a(c)(16)

For pneumatic pump affected facilities that are controlled, maintain information related to equipment, purchase,
location, manufacturer specifications, and control. Maintain certification of CVS capacity; record results of
CVS and by-pass inspections, maintenance, and corrective actions.
For storage vessel affected facilities, maintain compliance records for control device including visible emission
observation results, inspection results, corrective actions, and maintenance. Maintain certification of CVS
capacity; record results of CVS and by-pass inspections, maintenance, and corrective actions.
For each collection of fugitive emissions components at a well site and each collection of fugitive emissions
components at a compressor station, maintain records of the date of startup of production/modification, daily
well site production and calculations of rolling average calculation for well sites, records of removal of major
production and processing equipment at a well site, fugitive emissions monitoring plan, monitoring survey, and
records of alternative fugitive emissions standards (if applicable).
For affected facilities at onshore gas processing plants, records of subject equipment, records of leak detection
and repair program.
For sweetening unit affected facilities at onshore natural gas processing plants, records of sulfur levels, acid
gas, calculations, measurements, and compliance records.

60.5393a(c), (e); 60.5410a(e)(8);
60.5420a(c)(16); 60.5411a(c)(3)(i)(A);
60.5411a(d); 60.5416a(c); 60.5420a(c)(6)-(8),
(16) and (17).
60.5395a(d)(3); 60.5411a(c)(3)(i)(A);
60.5411a(d); 60.5412a(c) and (d); 60.5413a(d)
and (e); 60.5416a(c); 60.5417a(h)60.5420a(c)(5)(8), (12)-(14), and (17).

60.5420a(c)(15)(i)-(vii).

60.5400a(a), 60.482-1a(b) and (d); 60.482-7a;
60.482-10a
60.5407a(a); 60.5423a

Notifications and Reporting
Notify the Administrator at least two days prior to a well completion operation.

60.5420a(a)(2)

Submit an annual report, per operating entity, for all wellhead, pneumatic controller, pneumatic pump, storage
vessel, centrifugal and reciprocating compressor affected facilities.
Submit an annual report for the collection of fugitive emissions components at each well site and the collection
of fugitive emissions components at each compressor station.

60.5420a(b)
60.5420a(b)(1); (7)

Notification of construction or reconstruction.

60.7(a)(1)

Notification of performance test.

60.8(d)

Annual reports including those of excess emissions.

60.5417a(c); 60.487a(c)(2)(i)-(vi)

Performance test results.
Semiannual report on excess emissions from and performance of continuous monitoring system, and/or
summary report forms at processing plants. Annual report on excess emissions from and performance of
continuous monitoring system for sweetening units.

60.487a(e)

Instructions for submitting reports to the EPA via CEDRI.

60.5420a(c)(11)

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60.5422a(b), 60.5410a(g)(3); 60.5423a(b)

(ii)

Respondent Activities.
Respondent Activities

Read instructions/rule.
Gather relevant information.
Perform initial performance test and repeat performance tests if necessary.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose
of collecting, validating, and verifying information.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining
information.
Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing
information.
Adjust the existing ways to comply with any previously applicable instructions and requirements.
Train personnel to be able to respond to a collection of information.
Transmit, or otherwise disclose the information.

5.

The Information Collected–Agency Activities, Collection Methodology, and
Information Management

(a)

Agency Activities.
The federal government (EPA) activities associated with the amended NSPS OOOOa are

provided in Tables 2a-2d (located at the end of this supporting statement) and are introduced in
section 6(c).
(b)

Collection Methodology and Management.
Data and records maintained by the respondents are tabulated and published for use in

compliance and enforcement programs of the delegated permitting authority. Information
contained in the reports will be required to be submitted electronically to EPA’s Central DATA
Exchange (CDX) using the Compliance and Emissions Data Reporting Interface (CEDRI). CDX
enables fast, efficient and more accurate environmental data submissions from state and local
governments, industry and tribes to EPA and participating program offices. EPA’s CDX is the
point of entry on the Environmental Information Exchange Network (Exchange Network) for
environmental data submissions to the Agency. CDX works with both EPA program offices
looking for a way to better manage incoming data, and stakeholders looking for a way to reduce
burden from reporting requirements. Appendix C includes the CEDRI electronic portal for
submitting reports under 40 CFR part 60, subpart OOOOa. The electronic portal to submit reports
online is accessed through the EPA’s CDX at https://cdx.epa.gov. The spreadsheet templates
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created by the EPA to facilitate annual reporting for Oil and Gas Facilities under 40 CFR part 60,
subpart OOOOa can be obtained at https://www.epa.gov/electronic-reporting-airemissions/cedri#list as well as https://www.epa.gov/controlling-air-pollution-oil-and-natural-gasindustry/implementation-oil-and-natural-gas-air#report.
(c)

Small Entity Flexibility.
The EPA performed a screening analysis for impacts on a sample of expected affected

small entities by comparing compliance costs to entity revenues during the development of the
2016 NSPS OOOOa. The impact on small entities (i.e., small businesses) was taken into
consideration during the development of the 2016 NSPS OOOOa and during the development of
the Reconsideration Amendments. The EPA has tried to reduce the impact of this rule on small
entities by specifying monitoring, recordkeeping and reporting requirements that are the minimum
necessary to ensure compliance.
(d)

Collection Schedule.
The specific frequency for each information collection activity within this request is shown

in Tables 1a-1d.
6.

Estimating the Burden and Cost of the Collection

(a)

Estimating Respondent Burden.
The annual burden estimates for the NSPS OOOOa are shown in Tables 1a-1d. These

numbers are based on the estimated number of affected facilities that would be subject to the
requirements of the NSPS from years 2021 to 2023.
(b)

Estimating Respondent Costs.
(i)

Estimating Labor Costs.

This ICR uses the following labor rates: $60.56 per hour for technical labor, $123.27 per
hour for management labor, and $40.72 for clerical labor. These rates include an increase of 110
percent to account for the benefit packages available to those employed by private industry. These
rates are from the May 2016 National Occupational Employment and Wage Estimates United
States published by the Bureau of Labor and Statistics
(https://www.bls.gov/oes/current/oes_nat.htm). Costs have been estimated in 2016 dollars for this

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ICR, which is consistent with the costs (i.e. cost of control) estimated in the supporting documents
developed for the reconsideration amendments to the 2016 NSPS OOOOa.
The information collection activities for NSPS OOOOa are presented in Tables 1a-1d.
Because the data are already collected by respondents as part of normal operations, no respondent
costs are associated with information collection activities.
(ii)

Estimating Capital and Operations and Maintenance (O&M) Costs.

As part of reevaluating and updating the baseline 2016 NSPS OOOOa ICR, the EPA
specifically looked at the recordkeeping costs associated with the fugitive emissions requirements.
Because extensive records are required for each fugitive emissions survey that is conducted it is
critical that an appropriate data management system is used in order to manage the compliance
data collected. Specific estimates for recordkeeping costs for the existing rule were not identified,
therefore, the EPA relied on information received from commenters on the 2018 proposed
reconsideration and previous information collected by the Agency for similar programs. The
capital cost associated with the initial set-up of the database recordkeeping system was estimated
at $18,607 for 22 well sites or 7 gathering and boosting stations. These one-time costs were
accounted for in the first-year capital costs for each new well site and gathering and boosting
station. In addition to this initial set-up fee, annual licensing fees that include technical support
and updates to software were incorporated into the annual recordkeeping costs. The 2020 final
reconsideration TSD provides more information on how the capital and annual database
recordkeeping costs were estimated.4
(c)

Estimating Agency Burden and Cost.
Because reporting and recordkeeping requirements on the part of the respondents are

required under the operating permits rules in 40 CFR part 70 or part 71 and the part 60 NSPS
General Provisions, no operational costs will be incurred by the Federal Government. Publication
and distribution of the information are part of the Compliance Data System, with the result that no
Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the
respondents will occur incidentally as part of the periodic inspection of facilities that is part of
EPA’s overall compliance and enforcement program, and, therefore, is not attributable to the ICR.

4

See Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources. Background
Technical Support Document for the Final Reconsideration of the New Source Performance Standards 40 CFR Part
60, subpart OOOOa, April 2020. (2020 Final Reconsideration TSD).

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The only costs that the Federal government will incur are user costs associated with the analysis of
the reported information, as presented in Tables 2a-2d.
This cost is based on the average hourly labor rate as follows:
Managerial

$64.16 (GS-13, Step 5, $38.92 + 60%)

Technical

$47.62 (GS-12, Step 1, $28.88 + 60%)

Clerical

$25.76 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2016 General Schedule
rates of pay, which excludes locality. The rates have been increased by 60 percent to account for
the benefit packages available to government employees. Costs have been estimated in 2016
dollars for this ICR to be consistent with other costs (i.e., cost of control) estimated in the
development of the 2016 NSPS OOOOa.
(d)

Estimating the Respondent Universe and Total Burden and Costs.
It was estimated that an average of 519 respondents per year will be subject to NSPS

OOOOa during the 3-year period of this ICR as shown in the following table below. This estimate
encompasses the number of companies that the EPA expects will submit reports on behalf of all its
well sites (note: each company is assumed to own 22 well sites). The average annual number of
respondents per year is calculated using the following table.

Year

Annual Number of Respondents

1 (2021)

499

2 (2022)

522

3 (2023)

537

Average

519

For the NSPS OOOOa, the components of the total annual responses attributable to this
ICR are notifications of well completions/recompletions from an estimated average of 5,178
companies over the three-year period, notification of construction, reconstruction and modification
from an average of 8 companies over the three-year period, annual reports from an average of 463
companies over the three-year period, and semiannual reports from an average of 56 companies
over the three-year period. (Processing facilities report semiannually, all others annually).

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The average number of annual responses per year is calculated using the following table.
Total Annual Responses
Number of
Information Collection Activity
Respondentsa
Notification of well completions/recompletions
5,178b
Notification of construction/ reconstruction/modification
8
Annual Compliance Reports
463
Semiannual Compliance Reports
56

Number of
Total Annual
Responses
Responses
1
5,178
1
8
1
463
2
112
Total
5,761
a
The EPA assumes each facility will make the appropriate notifications and that each respondent will submit the
annual or semiannual report for all affected facilities in each year.
b
Per §60.5420a(a)(2), notifications are required for each well completion/recompletion. Therefore, the estimated
number of respondents is based on the estimated number of well completions/recompletions.

(e)

Bottom Line Burden Hours and Cost Tables.
(i)

Respondent tally. The bottom-line respondent burden hours and costs for the three

years (2021-2023) covered by this ICR are presented in Table 1d (located at the end of this
supporting statement). The average annual burden for the recordkeeping and reporting
requirements in NSPS OOOOa for the estimated 519 respondents that are subject to the rule is
374,988 labor hours, with an annual average labor cost of $71,958,301.
(ii)

The Agency Tally. The average annual Federal Government cost is $92,382 for

1,990 labor hours for NSPS OOOOa. The bottom-line Agency burden hours and costs, presented
in Table 2d, are calculated from Tables 2a-2c by adding person-hours per year down each column
for technical, managerial, and clerical staff, and by adding down the cost column.
(iii)

Variations in the annual bottom line. This section does not apply since no

significant variation is anticipated.
(f)

Reasons for Change in Burden.
(i)

Updated 2016 NSPS OOOOa ICR Burden. The original burden estimated for the

2016 NSPS OOOOa (ICR EPA tracking number 2523.03) was modified to reflect several changes
that were determined to be necessary to accurately reflect the true burden of the recordkeeping and
reporting burden. Comments received on 2018 NSPS OOOOa Reconsideration Proposal5
indicated that the recordkeeping and reporting burden for the 2016 NSPS OOOOa was
significantly underestimated. In particular, the commenters pointed to the estimated burden
associated with the fugitive emissions requirements. As a result of these comments, the EPA
reexamined the analysis for the 2016 NSPS OOOOa recordkeeping and reporting burden and
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made adjustments where warranted. The updated 2016 NSPS OOOOa baseline also reflects the
use of the most current available information on the projection of affected sources. These changes
resulted in an updated and more accurate assessment of the recordkeeping and reporting burden
for 2016 NSPS OOOOa.
The 3-year annual average estimated for the updated 2016 NSPS OOOOa baseline is
689,154 hours and $110,336,343 ($2016). The annual burden estimated for the updated 2016
NSPS OOOOa baseline is shown in Appendix A.
(ii)

Final NSPS OOOOa ICR Burden

This final NSPS OOOOa ICR burden reflects the Policy Review final amendments to
remove sources in the transmission and storage segment6 and the final amendments to NSPS
OOOOa as a result of the EPA’s reconsideration of several issues (including fugitive emissions
requirements), as well as amendments to streamline the implementation of the rule.
The final NSPS OOOOa combined burden of the Policy Review and Reconsideration
Amendments is 374,988 person-hours and $71,958,301 on an annual average basis over the threeyear period (2021-2023). The information collection activities associated with the final NSPS
OOOOa will result in an estimated average annual burden reduction of 35 percent on a cost basis
compared to the updated 2016 NSPS OOOOa burden discussed above (2016$), or an overall
reduction of 314,166 average annual labor hours and an associated decrease in average total
annual respondent burden cost for reporting and recordkeeping of $38,378,042 ($2016) in the 3year average.
(g)

Burden Statement
The annual public reporting and recordkeeping burden for this collection of information is

estimated to average 65 hours per response. Burden means the total time, effort, or financial
resources expended by persons to generate, maintain, retain, or disclose or provide information to
or for a Federal agency. This includes the time needed to review instructions; develop, acquire,
install, and utilize technology and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and providing information;
adjust the existing ways to comply with any previously applicable instructions and requirements;

6

For the burden associated with the removal of sources in the transmission and storage segment due to the Policy
Review, see the Policy Review Supporting Statement available under Docket ID Number EPA-HQ-OAR-2017-0757.

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train personnel to be able to respond to a collection of information; search data sources; complete
and review the collection of information; and transmit or otherwise disclose the information.
An agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a valid OMB Control Number. The OMB Control
Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.
To view comments received on the Agency’s need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing respondent burden,
including the use of automated collection techniques, the EPA has established a public docket for
this ICR under Docket ID Number [EPA-HQ-OAR-2017-0483]. An electronic version of the
public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of
the collection of information, view public comments submitted, access the index listing of the
contents of the docket, and to access those documents in the public docket that are available
electronically. When in the system, select “search,” then key in the docket ID number identified in
this document. The documents are typically available for public viewing at EPA Docket Center
Room 3334, EPA WJC West Building, 1301 Constitution Ave., NW, Washington, DC. EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday,
excluding legal holidays. The telephone number for the Public Reading Room is (202) 566-1744,
and the telephone number for the EPA Docket Center is (202) 566-1742.
PART B
This section is not applicable because statistical methods are not used in data collection
associated with the final rule.

14

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 1a. Year 1 Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Year

1. APPLICATIONS (Not Applicable)
2. SURVEY AND STUDIES (Not Applicable)
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
4. REPORT REQUIREMENTS
A. Read Instructions
New Affected Facilities
B. Required Activities
Notification of Well Completion/Recompletion
Notification of Construction/Reconstruction/Modification
C. Create Information
Fugitives - Non-Low Production Well Sites
Company-Wide Monitoring Plan - 60.5397a(c)
Recordkeeping Database System Set-up Fee
Fugitives - Gathering & Boosting Compressor Stations
Company-Wide Monitoring Plan
Recordkeeping Database System Set-up Fee
D. Gather Existing Information (Included in 5C)
E. Annual Reports
Well Completion/Recompletion
Centrifugal Compressor (Wet seal) (at Production & Processing Facilities)
Reciprocating Compressor (at Production & Processing Facilities)
Pneumatic Controllers (at Production & Processing Facilities)
Pneumatic Pumps
Storage Vessels
Fugitives - Well Sites
Non-Low Production
Low Production
Fugitives - Gathering & Boosting Compressor Stations
Sweetening Unit
F. Semiannual Reports
Gas Processing Plant

(A)

(B)

(C)

(D)

Person-Hours per
Occurrence

Number of
Occurrences per
Respondent per Year

Person-Hours per
Respondent per
Year (A*B)

Respondents per
Year

(F)

(G)

(H)
Cost per Year

4

1

4

499

1,996

100

200

$141,316

0.25
0.5

1
1

0.3
0.5

10,134
8

2,534
4

127
0

253
0

$179,370
$283

40

1

40

380
380

15,200

760

1,520

$1,076,151
$321,480

25

1

25

30
30

750

38

75

$53,100
$558,210

1
3
1.5
1
2
2

1
1
1
1
1
1

1
3
2
1
2
2

10,134
0
728
1,234
4,641
6,372

10,134
0
1,092
1,234
9,282
12,744

507
0
55
62
464
637

1,013
0
109
123
928
1,274

$717,481
$0
$77,313
$87,366
$657,160
$902,268

3
1

1
1

3
1

49,580
10,566

148,740
10,566

7,437
528

14,874
1,057

$10,530,703
$748,066

3

1

3

212

636

32

64

$45,028

4

1

4

7

28

1

3

$1,982

24

2

48

49

2,352
217,292

118
10,865
249,885

235
21,729

$166,520

3,858
2,418
0
658
140
4,936
1,162
27,832
12,744

193
121
0
33
7
247
58
1,392
637

Reporting Requirement Subtotal
5. RECORDKEEPING REQUIREMENTS
A. Read Instructions (Included in 4A)
B. Plan Activities (Included in 4B)
C. Implement Activities
Maintain completion log records
Maintain 300 GOR exemption records
Centrifugal Compressor (Wet seal) (at Production & Processing Facilities)
Reciprocating Compressor (Rod Packing Change) (at Production & Processing Facilities)
Reciprocating Compressor (Route to Control Device) (at Production & Processing Facilities)
Pneumatic Controllers (at Production & Processing Facilities)
Pneumatic pumps (uncontrolled)
Pneumatic pumps (controlled)
Storage Vessels
Fugitives - Recordkeeping Database Maintenance/License Fee
Non-Low Production Well Sites (Semiannual Monitoring)
Gathering & Boosting Compressor Stations (Semiannual Monitoring)
Fugitives - Additional recordkeeping/data management costs
Non-Low Production Well Sites
Low Production Well Sites
Gathering & Boosting Compressor Stations
Processing Plants
Sweetening Units
D. Record Data (Included in 5C)
E. Time to Transmit or Disclose Information
Records required by standards (Included in 4E)
F. Train Personnel (Included in 5C)
G. Time for Audits (Not Applicable)

(E)

Technical Person- Managerial Person- Clerical PersonHours per Year
Hours per Year Hours per Year
(C*D)
(0.05*E)
(0.10*E)

0.5
1
4
1
2
4
1
8
2

1
1
1
1
1
1
1
1
1

1
1
4
1
2
4
1
8
2

7,716
2,418
0
658
70
1,234
1,162
3,479
6,372

386
242
0
66
14
494
116
2,783
1,274

49,580
1,484

1

1

1

8
4

4
1

32
4

49,580
10,566
1,484
49
7

10,566

528

1,057

1,568
28

78
1

157
3

283,202

TOTAL REPORTING AND RECORDKEEPING LABOR AND COST
Assumptions:
• 10,134 new wellsites in 2021 (2020 Annual Energy Outlook).
• Each company assumed to own 22 well sites.
• 250 new compressor stations per year (212 G&B (7 G&B stations per company) and 38 T&S)
• 7 new processing plants per year.
• 1 new sweetening facility per year.
• 0 new centrifugal compressors equipped with wet seals per year (2017 Compliance Reports).
• 72 reciprocating compressors in production & processing per year. (2018, GHGI, 2018 TSD and 2017 Compliance Reports). 10% route to a control device, 90% rod packing changeout.
• 1,234 new pneumatic controllers in production & processing per year (2018 GHGI).
• 663 new pneumatic pumps per year (2017 Compliance Reports). 50% are diaphragm pumps and affected facilities and 75% will be controlled (2018 TSD, page 92-93).
• 1,074 new storage vessels in 2021 (based on numbers from 2017 Compliance Reports and scaled using the number of well completions per year).

15

$273,144
$171,193
$0
$46,586
$9,912
$349,466
$82,269
$1,970,489
$902,268
$23,253,020
$681,156

65,910

Recordkeeping Requirement Subtotal

$16,122,482

3,296
75,797
14,160
325,682

6,591
28,320

$15,989,550
$748,066
$957,180
$111,013
$1,982

$45,547,294
$61,669,777

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 1b. Year 2 Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)
Year

(A)

(B)

(C)

(D)

Person-Hours per
Occurrence

Number of
Occurrences per
Respondent per Year

Person-Hours per
Respondent per
Year (A*B)

Respondents per
Year

4

1

4

522

2,088

104

209

$147,829

0.25
0.5

1
1

0.3
0.5

10,635
8

2,659
4

133
0

266
0

$188,238
$283

40

1

40

399
399

15,960

798

1,596

$1,129,958
$337,554

25

1

25

30
30

750

38

75

$53,100
$558,210

1
3
1.5
1
2
2

1
1
1
1
1
1

1
3
2
1
2
2

10,635
0
832
1,234
5,304
7,499

10,635
0
1,248
1,234
10,608
14,998

532
0
62
62
530
750

1,064
0
125
123
1,061
1,500

$752,952
$0
$88,358
$87,366
$751,040
$1,061,849

3
1

1
1

3
1

58,347
12,434

175,041
12,434

8,752
622

17,504
1,243

$12,392,798
$880,320

3

1

3

242

727

36

73

$51,461

4

1

4

8

32

2

3

$2,266

24

2

48

56

2,688
251,106

134
12,555
288,771

269
25,111

$190,309

4,049
2,538
0
752
160
4,936
1,328
31,808
14,998

202
127
0
38
8
247
66
1,590
750

405
254
0
75
16
494
133
3,181
1,500

1. APPLICATIONS (Not Applicable)
2. SURVEY AND STUDIES (Not Applicable)
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
4. REPORT REQUIREMENTS
A. Read Instructions
New Affected Facilities
B. Required Activities
Notification of Well Completion/Recompletion
Notification of Construction/Reconstruction/Modification
C. Create Information
Fugitives - Non-Low Production Well Sites
Company-Wide Monitoring Plan - 60.5397a(c)
Recordkeeping Database System Set-up Fee
Fugitives - Gathering & Boosting Compressor Stations
Company-Wide Monitoring Plan
Recordkeeping Database System Set-up Fee
D. Gather Existing Information (Included in 5C)
E. Annual Reports
Well Completion/Recompletion
Centrifugal Compressor (Wet seal) (at Production & Processing Facilities)
Reciprocating Compressor (at Production & Processing Facilities)
Pneumatic Controllers (at Production & Processing Facilities)
Pneumatic Pumps
Storage Vessels
Fugitives - Well Sites
Non-Low Production
Low Production
Fugitives - Gathering & Boosting Compressor Stations
Sweetening Unit
F. Semiannual Reports
Gas Processing Plant
Reporting Requirement Subtotal
5. RECORDKEEPING REQUIREMENTS
A. Read Instructions (Included in 4A)
B. Plan Activities (Included in 4B)
C. Implement Activities
Maintain completion log records
Maintain 300 GOR exemption records
Centrifugal Compressor (Wet seal) (at Production & Processing Facilities)
Reciprocating Compressor (Rod Packing Change) (at Production & Processing Facilities)
Reciprocating Compressor (Route to Control Device) (at Production & Processing Facilities)
Pneumatic Controllers (at Production & Processing Facilities)
Pneumatic pumps (uncontrolled)
Pneumatic pumps (controlled)
Storage Vessels
Fugitives - Recordkeeping Database Maintenance/License Fee
Non-Low Production Well Sites (Semiannual Monitoring)
Gathering & Boosting Compressor Stations (Semiannual Monitoring)
Fugitives - Additional recordkeeping/data management costs
Non-Low Production Well Sites
Low Production Well Sites
Gathering & Boosting Compressor Stations
Processing Plants
Sweetening Units
D. Record Data (Included in 5C)
E. Time to Transmit or Disclose Information
Records required by standards (Included in 4E)
F. Train Personnel (Included in 5C)
G. Time for Audits (Not Applicable)

0.5
1
4
1
2
4
1
8
2

1
1
1
1
1
1
1
1
1

1
1
4
1
2
4
1
8
2

8,097
2,538
0
752
80
1,234
1,328
3,976
7,499

(E)

(F)

(G)

Technical Person- Managerial Person- Clerical PersonHours per Year
Hours per Year Hours per Year
(C*D)
(0.05*E)
(0.10*E)

58,347
1,696

1

1

1

8
4

4
1

32
4

58,347
12,434
1,696
56
8

12,434

622

1,243

1,792
32

90
2

179
3

325,932

TOTAL REPORTING AND RECORDKEEPING LABOR AND COST
Assumptions:
• 10,635 new wellsites in 2022 (2020 Annual Energy Outlook).
• Each company assumed to own 22 well sites.
• 250 new compressor stations per year (212 G&B (7 G&B stations per company) and 38 T&S)
• 7 new processing plants per year.
• 1 new sweetening facility per year.
• 0 new centrifugal compressors equipped with wet seals per year (2017 Compliance Reports).
• 72 reciprocating compressors in production & processing per year. (2018, GHGI, 2018 TSD and 2017 Compliance Reports). 10% route to a control device, 90% rod packing changeout.
• 1,234 new pneumatic controllers in production & processing per year (2018 GHGI).
• 663 new pneumatic pumps per year (2017 Compliance Reports). 50% are diaphragm pumps and affected facilities and 75% will be controlled (2018 TSD, page 92-93).
• 1,127 new storage vessels in 2022 (based on numbers from 2017 Compliance Reports and scaled using the number of well completions per year).

16

Cost per Year

$18,526,061

$286,631
$179,689
$0
$53,241
$11,328
$349,466
$94,022
$2,251,987
$1,061,849
$27,364,743
$778,464

74,827

Recordkeeping Requirement Subtotal

(H)

3,741
86,050
16,297
374,822

7,483
32,593

$18,816,908
$880,320
$1,093,920
$126,873
$2,266

$53,351,706
$71,877,767

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 1c. Year 3 Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Year

(A)

(B)

(C)

(D)

Person-Hours per
Occurrence

Number of
Occurrences per
Respondent per Year

Person-Hours per
Respondent per
Year (A*B)

Respondents per
Year

1. APPLICATIONS (Not Applicable)
2. SURVEY AND STUDIES (Not Applicable)
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
4. REPORT REQUIREMENTS
A. Read Instructions
New Affected Facilities
B. Required Activities
Notification of Well Completion/Recompletion
Notification of Construction/Reconstruction/Modification
C. Create Information
Fugitives - Non-Low Production Well Sites
Company-Wide Monitoring Plan - 60.5397a(c)
Recordkeeping Database System Set-up Fee
Fugitives - Gathering & Boosting Compressor Stations
Company-Wide Monitoring Plan
Recordkeeping Database System Set-up Fee
D. Gather Existing Information (Included in 5C)
E. Annual Reports
Well Completion/Recompletion
Centrifugal Compressor (Wet seal) (at Production & Processing Facilities)
Reciprocating Compressor (at Production & Processing Facilities)
Pneumatic Controllers (at Production & Processing Facilities)
Pneumatic Pumps
Storage Vessels
Fugitives - Well Sites
Non-Low Production
Low Production
Fugitives - Gathering & Boosting Compressor Stations
Sweetening Unit
F. Semiannual Reports
Gas Processing Plant

(F)

(G)

(H)
Cost per Year

4

1

4

537

2,148

107

215

$152,077

0.25
0.5

1
1

0.3
0.5

10,964
8

2,741
4

137
0

274
0

$194,061
$283

40

1

40

411
411

16,440

822

1,644

$1,163,942
$347,706

25

1

25

30
30

750

38

75

$53,100
$558,210

1
3
1.5
1
2
2

1
1
1
1
1
1

1
3
2
1
2
2

10,964
0
936
1,234
5,967
8,661

10,964
0
1,404
1,234
11,934
17,322

548
0
70
62
597
866

1,096
0
140
123
1,193
1,732

$776,245
$0
$99,402
$87,366
$844,920
$1,226,387

3
1

1
1

3
1

67,385
14,360

202,155
14,360

10,108
718

20,216
1,436

$14,312,453
$1,016,679

3

1

3

273

818

41

82

$57,894

4

1

4

9

36

2

4

$2,549

24

2

48

63

3,024
285,334

151
14,267
328,134

4,174
2,616
0
846
180
4,936
1,494
35,784
17,322

209
131
0
42
9
247
75
1,789
866

Reporting Requirement Subtotal
5. RECORDKEEPING REQUIREMENTS
A. Read Instructions (Included in 4A)
B. Plan Activities (Included in 4B)
C. Implement Activities
Maintain completion log records
Maintain 300 GOR exemption records
Centrifugal Compressor (Wet seal) (at Production & Processing Facilities)
Reciprocating Compressor (Rod Packing Change) (at Production & Processing Facilities)
Reciprocating Compressor (Route to Control Device) (at Production & Processing Facilities)
Pneumatic Controllers (at Production & Processing Facilities)
Pneumatic pumps (uncontrolled)
Pneumatic pumps (controlled)
Storage Vessels
Fugitives - Recordkeeping Database Maintenance/License Fee
Non-Low Production Well Sites (Semiannual Monitoring)
Gathering & Boosting Compressor Stations (Semiannual Monitoring)
Fugitives - Additional recordkeeping/data management costs
Non-Low Production Well Sites
Low Production Well Sites
Gathering & Boosting Compressor Stations
Processing Plants
Sweetening Units
D. Record Data (Included in 5C)
E. Time to Transmit or Disclose Information
Records required by standards (Included in 4E)
F. Train Personnel (Included in 5C)
G. Time for Audits (Not Applicable)

(E)

Technical Person- Managerial Person- Clerical PersonHours per Year
Hours per Year Hours per Year
(C*D)
(0.05*E)
(0.10*E)

0.5
1
4
1
2
4
1
8
2

1
1
1
1
1
1
1
1
1

1
1
4
1
2
4
1
8
2

8,347
2,616
0
846
90
1,234
1,494
4,473
8,661

302
28,533

417
262
0
85
18
494
149
3,578
1,732

67,385
1,908

1

1

1

8
4

4
1

32
4

67,385
14,360
1,908
63
9

14,360

718

1,436

2,016
36

101
2

202
4

369,097

TOTAL REPORTING AND RECORDKEEPING LABOR AND COST
Assumptions:
• 10,964 new wellsites in 2023 (2020 Annual Energy Outlook).
• Each company assumed to own 22 well sites.
• 250 new compressor stations per year (212 G&B (7 G&B stations per company) and 38 T&S)
• 7 new processing plants per year.
• 1 new sweetening facility per year.
• 0 new centrifugal compressors equipped with wet seals per year (2017 Compliance Reports).
• 72 reciprocating compressors in production & processing per year. (2018, GHGI, 2018 TSD and 2017 Compliance Reports). 10% route to a control device, 90% rod packing changeout.
• 1,234 new pneumatic controllers in production & processing per year (2018 GHGI).
• 663 new pneumatic pumps per year (2017 Compliance Reports). 50% are diaphragm pumps and affected facilities and 75% will be controlled (2018 TSD, page 92-93).
• 1,162 new storage vessels in 2023 (based on numbers from 2017 Compliance Reports and scaled using the number of well completions per year).

17

$295,481
$185,211
$0
$59,896
$12,744
$349,466
$105,774
$2,533,486
$1,226,387
$31,603,565
$875,772

83,764

Recordkeeping Requirement Subtotal

$214,097
$20,955,295

4,188
96,328
18,455
424,462

8,376
36,910

$21,731,663
$1,016,679
$1,230,660
$142,732
$2,549

$61,372,065
$82,327,360

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 1d. Three-Year Average Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification,
or Reconstruction Commenced after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Year
1 (2021)
2 (2022)
3 (2023)
Total
Average

Total Respondents
499
522
537
1,558
519

Technical Hours
283,202
325,932
369,097
978,231
326,077

Clerical Hours
14,160
16,297
18,455
48,912
16,304

Management Hours
28,320
32,593
36,910
97,823
32,608

Total Labor Hours
325,682
374,822
424,462
1,124,965
374,988

Labor Cost
$61,669,777
$71,877,767
$82,327,360
$215,874,903
$71,958,301

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 2a. Year 1 Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Activity
Report Review
Notification of Construction/Reconstruction/Modification
Annual Report
Semiannual Report

(A)
EPA personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

(C)
EPA personhours per
plant per
year
(C=AxB)

(D)
Responses
per
year (a)

(E)
Technical
person-hours
per year
(E=CxD)

(F)
Management
person-hours
per year
(Ex0.05)

(G)
Clerical
personhours per
year
(Ex0.1)

(H)
Cost,$ (a)

0.5
3.0
3.0

1.0
1.0
2.0

0.5
3.0
6.0

8
450
49

4
1,350
294
1,648

0
68
15
82
1,895

0
135
29
165

$214
$72,090
$15,700

TOTAL ANNUAL BURDEN
a

$88,003

The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $64.16 (GS-13, Step 5,
$40.10 × 1.6), Technical rate of $47.62 (GS-12, Step 1, $29.76 × 1.6), and Clerical rate of $25.76 (GS-6, Step 3, $16.10 × 1.6). These rates are from the Office of Personnel Management (OPM),
2016 General Schedule, which excludes locality rates of pay.

18

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 2b. Year 2 Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Activity
Report Review
Notification of Construction/Reconstruction/Modification
Annual Report
Semiannual Report

(A)
EPA personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

(C)
EPA personhours per
plant per
year
(C=AxB)

(D)
Responses
per
year (a)

(E)
Technical
person-hours
per year
(E=CxD)

(F)
Management
person-hours
per year
(Ex0.05)

(G)
Clerical
personhours per
year
(Ex0.1)

(H)
Cost,$ (a)

0.5
3.0
3.0

1.0
1.0
2.0

0.5
3.0
6.0

8
466
56

4
1,398
336
1,738

0
70
17
87
1,999

0
140
34
174

$214
$74,653
$17,942

TOTAL ANNUAL BURDEN

$92,809

a

The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $64.16 (GS-13, Step 5,
$40.10 × 1.6), Technical rate of $47.62 (GS-12, Step 1, $29.76 × 1.6), and Clerical rate of $25.76 (GS-6, Step 3, $16.10 × 1.6). These rates are from the Office of Personnel Management
(OPM), 2016 General Schedule, which excludes locality rates of pay.

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 2c. Year 3 Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Activity
Report Review
Notification of Construction/Reconstruction/Modification
Annual Report
Semiannual Report

(A)
EPA personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

(C)
EPA personhours per
plant per
year
(C=AxB)

(D)
Responses
per
year (a)

(E)
Technical
person-hours
per year
(E=CxD)

(F)
Management
person-hours
per year
(Ex0.05)

(G)
Clerical
personhours per
year
(Ex0.1)

(H)
Cost,$ (a)

0.5
3.0
3.0

1.0
1.0
2.0

0.5
3.0
6.0

8
474
63

4
1,422
378
1,804

0
71
19
90
2,075

0
142
38
180

$214
$75,935
$20,185

TOTAL ANNUAL BURDEN
a

$96,334

The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $64.16 (GS-13, Step 5,
$40.10 × 1.6), Technical rate of $47.62 (GS-12, Step 1, $29.76 × 1.6), and Clerical rate of $25.76 (GS-6, Step 3, $16.10 × 1.6). These rates are from the Office of Personnel Management
(OPM), 2016 General Schedule, which excludes locality rates of pay.

19

Policy + Technical Amendments to 2016 NSPS OOOOa
Table 2d. Three-Year Average Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification,
or Reconstruction Commenced after September 18, 2015 (40 CFR part 60, subpart OOOOa)
Year
1 (2021)
2 (2022)
3 (2023)
Total
Average

Technical Hours
1,648
1,738
1,804
5,190
1,730

Clerical Hours
165
174
180
519
173

Management Hours
82
87
90
260
87

20

Total Labor Hours
1,895
1,999
2,075
5,969
1,990

Labor Cost
$88,003
$92,809
$96,334
$277,146
$92,382

Appendix A
Updated 2016 NSPS OOOOa ICR Burden

A-1

2016 NSPS OOOOa Updated Baseline
Table 1a. Year 1 Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)
Year

(A)

(B)

(C)

(D)

Person-Hours per
Occurrence

Number of
Occurrences per
Respondent per Year

Person-Hours per
Respondent per
Year (A*B)

Respondents per
Year

1. APPLICATIONS (Not Applicable)
2. SURVEY AND STUDIES (Not Applicable)
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
4. REPORT REQUIREMENTS
A. Read Instructions
New Affected Facilities
4
B. Required Activities
Notification of Well Completion/Recompletion
0.25
Notification of Construction/Reconstruction/Modification
0.5
C. Create Information
Fugitives - Well Sites
Company-Wide Monitoring Plan - 60.5397a(c)
Site-Specific Monitoring Plan - 60.5397a(d)
Recordkeeping Database System Set-up Fee
Fugitives - Compressor Stations
Gathering & Boosting
Company-Wide Monitoring Plan
Station-Specific Monitoring Plan
Recordkeeping Database System Set-up Fee
Transmission and Storage
Monitoring Plan
Recordkeeping Database System Set-up Fee
D. Gather Existing Information (Included in 5C)
E. Annual Reports
Well Completion/Recompletion
Centrifugal Compressor (Wet seal)
Reciprocating Compressor
Pneumatic Controllers
Pneumatic Pumps
Storage Vessels
Well Site (Fugitives)
Compressor Station (Fugitives)
Sweetening Unit
F. Semiannual Reports
Gas Processing Plant

(F)

(G)

(H)
Cost per Year

1

4

537

2,148

107

215

$152,077

1
1

0.3
0.5

10,134
8

2,534
4

127
0

253
0

$179,370
$283

40
6.5

1
1

40
6.5

461
10,134
461

18,440
65,871

922
3,294

1,844
6,587

$1,305,541
$4,663,627
$390,006

25
6.5

1
1

25
6.5

30
212
30

750
1,378

38
69

75
138

$53,100
$97,562
$558,210

60

1

60

38
38

2,280

114

228

$161,423
$707,066

1
3
1.5
1
2
2
4
4
4

1
1
1
1
1
1
1
1
1

1
3
2
1
2
2
4
4
4

10,134
0
1,260
1,542
4,641
6,372
60,146
478
7

10,134
0
1,890
1,542
9,282
12,744
240,584
1,912
28

507
0
95
77
464
637
12,029
96
1

1,013
0
189
154
928
1,274
24,058
191
3

$717,481
$0
$133,811
$109,173
$657,160
$902,268
$17,033,203
$135,368
$1,982

24

2

48

49

2,352
373,873

118
18,694
429,953

235
37,387

3,858
2,418
0
1,134
252
6,168
1,162
27,832
12,744

193
121
0
57
13
308
58
1,392
637

386
242
0
113
25
617
116
2,783
1,274

Reporting Requirement Subtotal
5. RECORDKEEPING REQUIREMENTS
A. Read Instructions (Included in 4A)
B. Plan Activities (Included in 4B)
C. Implement Activities
Maintain completion log records
Maintain 300 GOR exemption records
Centrifugal Compressor (Wet seal)
Reciprocating Compressor (Rod Packing Change)
Reciprocating Compressor (Route to Control Device)
Pneumatic controllers
Pneumatic pumps (uncontrolled)
Pneumatic pumps (controlled)
Storage Vessels
Fugitives - Recordkeeping Database Maintenance/License Fee
Low Production Well Sites (Semiannual Monitoring)
Non-Low Production Well Sites (Semiannual Monitoring)
Compressor Stations (Quarterly Monitoring)
Fugitives - Additional recordkeeping/data management costs
Well Sites
Compressor Stations
Fugitives - Management of Change (Site Map/Observation Path)
Well Sites
Compressor Stations
Processing Plants
Sweetening Units
D. Record Data (Included in 5C)
E. Time to Transmit or Disclose Information
Records required by standards (Included in 4E)
F. Train Personnel (Included in 5C)
G. Time for Audits (Not Applicable)

(E)

Technical Person- Managerial Person- Clerical PersonHours per Year
Hours per Year Hours per Year
(C*D)
(0.05*E)
(0.10*E)

0.5
1
4
1
2
4
1
8
2

1.5
1.5
8
4

1
1
1
1
1
1
1
1
1

1
1
4
1

Recordkeeping Requirement Subtotal

1
1
4
1
2
4
1
8
2

1.5
1.5
32
4

7,716
2,418
0
1,134
126
1,542
1,162
3,479
6,372

$4,955,454
$23,253,020
$826,000

60,146
1,750

$25,862,780
$1,505,000

60,146
1,750
49
7

90,219
2,625
1,568
28

4,511
131
78
1

9,022
263
157
3

150,008

7,500
172,509
26,194
602,463

15,001

Assumptions:
• 10,134 new wellsites in 2021 (2020 Annual Energy Outlook).
• Each company assumed to own 22 well sites.
• 250 new compressor stations per year (212 G&B (7 G&B stations per company) and 38 T&S)
• 7 new processing plants per year.
• 1 new sweetening facility per year.
• 0 new centrifugal compressors equipped with wet seals per year (2017 Compliance Reports).
• 180 reciprocating compressors per year. (2018 TSD and 2017 Compliance Reports). 10% are assumed to comply by routing to a control device, 90% are assumed to comply by rod packing changeout.
• 1,542 new pneumatic controllers per year (2018 GHGI).
• 663 new pneumatic pumps per year (2017 Compliance Reports). 50% are diaphragm pumps and affected facilities and 75% will be controlled (2018 TSD, page 92-93).
• 1,074 new storage vessels in 2021 (based on numbers from 2017 Compliance Reports and scaled using the number of well completions per year).

A-2

$273,144
$171,193
$0
$80,287
$17,841
$436,691
$82,269
$1,970,489
$902,268

10,566
49,580
1,750

523,881

TOTAL REPORTING AND RECORDKEEPING LABOR AND COST

$166,520
$27,973,154

52,388

$6,387,451
$185,848
$111,013
$1,982

$67,022,730
$94,995,884

2016 NSPS OOOOa Updated Baseline
Table 1b. Year 2 Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)
Year

(A)

(B)

(C)

(D)

Person-Hours per
Occurrence

Number of
Occurrences per
Respondent per Year

Person-Hours per
Respondent per
Year (A*B)

Respondents per
Year

1. APPLICATIONS (Not Applicable)
2. SURVEY AND STUDIES (Not Applicable)
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
4. REPORT REQUIREMENTS
A. Read Instructions
New Affected Facilities
4
B. Required Activities
Notification of Well Completion/Recompletion
0.25
Notification of Construction/Reconstruction/Modification
0.5
C. Create Information
Fugitives - Well Sites
Company-Wide Monitoring Plan - 60.5397a(c)
Site-Specific Monitoring Plan - 60.5397a(d)
Recordkeeping Database System Set-up Fee
Fugitives - Compressor Stations
Gathering & Boosting
Company-Wide Monitoring Plan
Station-Specific Monitoring Plan
Recordkeeping Database System Set-up Fee
Transmission and Storage
Monitoring Plan
Recordkeeping Database System Set-up Fee
D. Gather Existing Information (Included in 5C)
E. Annual Reports
Well Completion/Recompletion
Centrifugal Compressor (Wet seal)
Reciprocating Compressor
Pneumatic Controllers
Pneumatic Pumps
Storage Vessels
Well Site (Fugitives)
Compressor Station (Fugitives)
Sweetening Unit
F. Semiannual Reports
Gas Processing Plant

(F)

(G)

(H)
Cost per Year

1

4

560

2,240

112

224

$158,591

1
1

0.3
0.5

10,635
8

2,659
4

133
0

266
0

$188,238
$283

40
6.5

1
1

40
6.5

483
10,635
483

19,320
69,128

966
3,456

1,932
6,913

$1,367,844
$4,894,186
$408,618

25
6.5

1
1

25
6.5

30
212
30

750
1,378

38
69

75
138

$53,100
$97,562
$558,210

60

1

60

38
38

2,280

114

228

$161,423
$707,066

1
3
1.5
1
2
2
4
4
4

1
1
1
1
1
1
1
1
1

1
3
2
1
2
2
4
4
4

10,635
0
1,440
1,542
5,304
7,499
70,781
546
8

10,635
0
2,160
1,542
10,608
14,998
283,124
2,184
32

532
0
108
77
530
750
14,156
109
2

1,064
0
216
154
1,061
1,500
28,312
218
3

$752,952
$0
$152,927
$109,173
$751,040
$1,061,849
$20,045,009
$154,626
$2,266

24

2

48

56

2,688
425,729

134
21,286
489,589

269
42,573

4,049
2,538
0
1,296
288
6,168
1,328
31,808
14,998

202
127
0
65
14
308
66
1,590
750

405
254
0
130
29
617
133
3,181
1,500

Reporting Requirement Subtotal
5. RECORDKEEPING REQUIREMENTS
A. Read Instructions (Included in 4A)
B. Plan Activities (Included in 4B)
C. Implement Activities
Maintain completion log records
Maintain 300 GOR exemption records
Centrifugal Compressor (Wet seal)
Reciprocating Compressor (Rod Packing Change)
Reciprocating Compressor (Route to Control Device)
Pneumatic controllers
Pneumatic pumps (uncontrolled)
Pneumatic pumps (controlled)
Storage Vessels
Fugitives - Recordkeeping Database Maintenance/License Fee
Low Production Well Sites (Semiannual Monitoring)
Non-Low Production Well Sites (Semiannual Monitoring)
Compressor Stations (Quarterly Monitoring)
Fugitives - Additional recordkeeping/data management costs
Well Sites
Compressor Stations
Fugitives - Management of Change (Site Map/Observation Path)
Well Sites
Compressor Stations
Processing Plants
Sweetening Units
D. Record Data (Included in 5C)
E. Time to Transmit or Disclose Information
Records required by standards (Included in 4E)
F. Train Personnel (Included in 5C)
G. Time for Audits (Not Applicable)

(E)

Technical Person- Managerial Person- Clerical PersonHours per Year
Hours per Year Hours per Year
(C*D)
(0.05*E)
(0.10*E)

0.5
1
4
1
2
4
1
8
2

1.5
1.5
8
4

1
1
1
1
1
1
1
1
1

1
1
4
1

Recordkeeping Requirement Subtotal

1
1
4
1
2
4
1
8
2

1.5
1.5
32
4

8,097
2,538
0
1,296
144
1,542
1,328
3,976
7,499

$5,831,546
$27,364,743
$944,000

70,781
2,000

$30,435,830
$1,720,000

70,781
2,000
56
8

106,172
3,000
1,792
32

5,309
150
90
2

10,617
300
179
3

173,468

8,673
199,488
29,960
689,077

17,347

Assumptions:
• 10,635 new wellsites in 2022 (2020 Annual Energy Outlook).
• Each company assumed to own 22 well sites.
• 250 new compressor stations per year (212 G&B (7 G&B stations per company) and 38 T&S)
• 7 new processing plants per year.
• 1 new sweetening facility per year.
• 0 new centrifugal compressors equipped with wet seals per year (2017 Compliance Reports).
• 180 reciprocating compressors per year. (2018 TSD and 2017 Compliance Reports). 10% are assumed to comply by routing to a control device, 90% are assumed to comply by rod packing changeout.
• 1,542 new pneumatic controllers per year (2018 GHGI).
• 663 new pneumatic pumps per year (2017 Compliance Reports). 50% are diaphragm pumps and affected facilities and 75% will be controlled (2018 TSD, page 92-93).
• 1,127 new storage vessels in 2022 (based on numbers from 2017 Compliance Reports and scaled using the number of well completions per year).

A-3

$286,631
$179,689
$0
$91,756
$20,390
$436,691
$94,022
$2,251,987
$1,061,849

12,434
58,347
2,000

599,197

TOTAL REPORTING AND RECORDKEEPING LABOR AND COST

$190,309
$31,656,679

59,920

$7,516,878
$212,398
$126,873
$2,266

$78,577,549
$110,234,228

2016 NSPS OOOOa Updated Baseline
Table 1c. Year 3 Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)
Year

(A)

(B)

(C)

(D)

Person-Hours per
Occurrence

Number of
Occurrences per
Respondent per Year

Person-Hours per
Respondent per
Year (A*B)

Respondents per
Year

1. APPLICATIONS (Not Applicable)
2. SURVEY AND STUDIES (Not Applicable)
3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS (Not Applicable)
4. REPORT REQUIREMENTS
A. Read Instructions
New Affected Facilities
4
B. Required Activities
Notification of Well Completion/Recompletion
0.25
Notification of Construction/Reconstruction/Modification
0.5
C. Create Information
Fugitives - Well Sites
Company-Wide Monitoring Plan - 60.5397a(c)
Site-Specific Monitoring Plan - 60.5397a(d)
Recordkeeping Database System Set-up Fee
Fugitives - Compressor Stations
Gathering & Boosting
Company-Wide Monitoring Plan
Station-Specific Monitoring Plan
Recordkeeping Database System Set-up Fee
Transmission and Storage
Monitoring Plan
Recordkeeping Database System Set-up Fee
D. Gather Existing Information (Included in 5C)
E. Annual Reports
Well Completion/Recompletion
Centrifugal Compressor (Wet seal)
Reciprocating Compressor
Pneumatic Controllers
Pneumatic Pumps
Storage Vessels
Well Site (Fugitives)
Compressor Station (Fugitives)
Sweetening Unit
F. Semiannual Reports
Gas Processing Plant

(F)

(G)

(H)
Cost per Year

1

4

575

2,300

115

230

$162,839

1
1

0.3
0.5

10,964
8

2,741
4

137
0

274
0

$194,061
$283

40
6.5

1
1

40
6.5

498
10,964
498

19,920
71,266

996
3,563

1,992
7,127

$1,410,324
$5,045,590
$421,308

25
6.5

1
1

25
6.5

30
212
30

750
1,378

38
69

75
138

$53,100
$97,562
$558,210

60

1

60

38
38

2,280

114

228

$161,423
$707,066

1
3
1.5
1
2
2
4
4
4

1
1
1
1
1
1
1
1
1

1
3
2
1
2
2
4
4
4

10,964
0
1,620
1,542
5,967
8,661
81,745
615
9

10,964
0
2,430
1,542
11,934
17,322
326,980
2,460
36

548
0
122
77
597
866
16,349
123
2

1,096
0
243
154
1,193
1,732
32,698
246
4

$776,245
$0
$172,043
$109,173
$844,920
$1,226,387
$23,149,988
$174,167
$2,549

24

2

48

63

3,024
477,331

151
23,867
548,931

302
47,733

4,174
2,616
0
1,458
324
6,168
1,494
35,784
17,322

209
131
0
73
16
308
75
1,789
866

417
262
0
146
32
617
149
3,578
1,732

Reporting Requirement Subtotal
5. RECORDKEEPING REQUIREMENTS
A. Read Instructions (Included in 4A)
B. Plan Activities (Included in 4B)
C. Implement Activities
Maintain completion log records
Maintain 300 GOR exemption records
Centrifugal Compressor (Wet seal)
Reciprocating Compressor (Rod Packing Change)
Reciprocating Compressor (Route to Control Device)
Pneumatic controllers
Pneumatic pumps (uncontrolled)
Pneumatic pumps (controlled)
Storage Vessels
Fugitives - Recordkeeping Database Maintenance/License Fee
Low Production Well Sites (Semiannual Monitoring)
Non-Low Production Well Sites (Semiannual Monitoring)
Compressor Stations (Quarterly Monitoring)
Fugitives - Additional recordkeeping/data management costs
Well Sites
Compressor Stations
Fugitives - Management of Change (Site Map/Observation Path)
Well Sites
Compressor Stations
Processing Plants
Sweetening Units
D. Record Data (Included in 5C)
E. Time to Transmit or Disclose Information
Records required by standards (Included in 4E)
F. Train Personnel (Included in 5C)
G. Time for Audits (Not Applicable)

(E)

Technical Person- Managerial Person- Clerical PersonHours per Year
Hours per Year Hours per Year
(C*D)
(0.05*E)
(0.10*E)

0.5
1
4
1
2
4
1
8
2

1.5
1.5
8
4

1
1
1
1
1
1
1
1
1

1
1
4
1

Recordkeeping Requirement Subtotal

1
1
4
1
2
4
1
8
2

1.5
1.5
32
4

8,347
2,616
0
1,458
162
1,542
1,494
4,473
8,661

$6,734,840
$31,603,565
$1,062,000

81,745
2,250

$35,150,350
$1,935,000

81,745
2,250
63
9

122,618
3,375
2,016
36

6,131
169
101
2

12,262
338
202
4

197,384

9,869
226,992
33,736
775,922

19,738

Assumptions:
• 10,964 new wellsites in 2023 (2020 Annual Energy Outlook).
• Each company assumed to own 22 well sites.
• 250 new compressor stations per year (212 G&B (7 G&B stations per company) and 38 T&S)
• 7 new processing plants per year.
• 1 new sweetening facility per year.
• 0 new centrifugal compressors equipped with wet seals per year (2017 Compliance Reports).
• 180 reciprocating compressors per year. (2018 TSD and 2017 Compliance Reports). 10% are assumed to comply by routing to a control device, 90% are assumed to comply by rod packing changeout.
• 1,542 new pneumatic controllers per year (2018 GHGI).
• 663 new pneumatic pumps per year (2017 Compliance Reports). 50% are diaphragm pumps and affected facilities and 75% will be controlled (2018 TSD, page 92-93).
• 1,162 new storage vessels in 2023 (based on numbers from 2017 Compliance Reports and scaled using the number of well completions per year).

A-4

$295,481
$185,211
$0
$103,226
$22,939
$436,691
$105,774
$2,533,486
$1,226,387

14,360
67,385
2,250

674,715

TOTAL REPORTING AND RECORDKEEPING LABOR AND COST

$214,097
$35,318,494

67,472

$8,681,245
$238,948
$142,732
$2,549

$90,460,424
$125,778,918

2016 NSPS OOOOa Updated Baseline
Table 1d. Three-Year Average Respondent Burden of Reporting and Recordkeeping Requirements
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification,
or Reconstruction Commenced after September 18, 2015 (40 CFR part 60, subpart OOOOa)
Year
1 (2021)
2 (2022)
3 (2023)
Total
Average

Total
537
560
575
1,672
557

Technical Hours
523,881
599,197
674,715
1,797,793
599,264

Clerical Hours
26,194
29,960
33,736
89,890
29,963

A-5

Management Hours Total Labor Hours
52,388
602,463
59,920
689,077
67,472
775,922
179,779
2,067,462
59,926
689,154

Labor Cost
$94,995,884
$110,234,228
$125,778,918
$331,009,030
$110,336,343

2016 NSPS OOOOa Updated Baseline
Table 2a. Year 1 Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Activity
Report Review
Notification of Construction/Reconstruction/Modification
Annual Report
Semiannual Report

(A)
EPA personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

(C)
EPA personhours per
plant per
year
(C=AxB)

(D)
Responses
per
year (a)

(E)
Technical
person-hours
per year
(E=CxD)

(F)
Management
person-hours
per year
(Ex0.05)

(G)
Clerical
personhours per
year
(Ex0.1)

(H)
Cost,$ (a)

0.5
4.0
4.0

1.0
1.0
2.0

0.5
4.0
8.0

8
488
49

4
1,952
392
2,348

0
98
20
117
2,700

0
195
39
235

$214
$104,237
$20,933

TOTAL ANNUAL BURDEN

$125,383

a

The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $64.16 (GS-13, Step 5,
$40.10 × 1.6), Technical rate of $47.62 (GS-12, Step 1, $29.76 × 1.6), and Clerical rate of $25.76 (GS-6, Step 3, $16.10 × 1.6). These rates are from the Office of Personnel Management (OPM),
2016 General Schedule, which excludes locality rates of pay.

2016 NSPS OOOOa Updated Baseline
Table 2b. Year 2 Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Activity
Report Review
Notification of Construction/Reconstruction/Modification
Annual Report
Semiannual Report

(A)
EPA personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

(C)
EPA personhours per
plant per
year
(C=AxB)

(D)
Responses
per
year (a)

(E)
Technical
person-hours
per year
(E=CxD)

(F)
Management
person-hours
per year
(Ex0.05)

(G)
Clerical
personhours per
year
(Ex0.1)

(H)
Cost,$ (a)

0.5
4.0
4.0

1.0
1.0
2.0

0.5
4.0
8.0

8
504
56

4
2,016
448
2,468

0
101
22
123
2,838

0
202
45
247

$214
$107,654
$23,923

TOTAL ANNUAL BURDEN

$131,791

a

The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $64.16 (GS-13, Step 5,
$40.10 × 1.6), Technical rate of $47.62 (GS-12, Step 1, $29.76 × 1.6), and Clerical rate of $25.76 (GS-6, Step 3, $16.10 × 1.6). These rates are from the Office of Personnel Management (OPM),
2016 General Schedule, which excludes locality rates of pay.

2016 NSPS OOOOa Updated Baseline
Table 2c. Year 3 Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (40 CFR part 60, subpart OOOOa)

Activity
Report Review
Notification of Construction/Reconstruction/Modification
Annual Report
Semiannual Report

(A)
EPA personhours per
occurrence

(B)
No. of
occurrences
per plant
per year

(C)
EPA personhours per
plant per
year
(C=AxB)

(D)
Responses
per
year (a)

(E)
Technical
person-hours
per year
(E=CxD)

(F)
Management
person-hours
per year
(Ex0.05)

(G)
Clerical
personhours per
year
(Ex0.1)

(H)
Cost,$ (a)

0.5
4.0
4.0

1.0
1.0
2.0

0.5
4.0
8.0

8
512
63

4
2,048
504
2,556

0
102
25
128
2,939

0
205
50
256

$214
$109,363
$26,914

TOTAL ANNUAL BURDEN

$136,490

a

The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $64.16 (GS-13, Step 5, $40.10
× 1.6), Technical rate of $47.62 (GS-12, Step 1, $29.76 × 1.6), and Clerical rate of $25.76 (GS-6, Step 3, $16.10 × 1.6). These rates are from the Office of Personnel Management (OPM), 2016
General Schedule, which excludes locality rates of pay.

Table 2d. Three-Year Average Annual Burden and Cost to the Federal Government
Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification,
or Reconstruction Commenced after September 18, 2015 (40 CFR part 60, subpart OOOOa)
Year
1 (2021)
2 (2022)
3 (2023)
Total
Average

Technical Hours
2,348
2,468
2,556
7,372
2,457

Clerical Hours
235
247
256
737
246

Management Hours
117
123
128
369
123

A-6

Total Labor Hours
2,700
2,838
2,939
8,478
2,826

Labor Cost
$125,383
$131,791
$136,490
$393,665
$131,222

Appendix B
Estimate of New Sources Affected for purposes of the Information Collection Request under
the Final Amendments to 40 CFR Part 60, Subpart OOOOa.

B-1

Source/Facility Type

2015

2016

2017

2018

2019

2020

2021

2022

2023

10,791

5,108

6,579

8,766

9,084

9,684

10,134

10,635

10,964

Non-Low Production Sites
Gas Well Sites
Oil Well Sites (GOR > 300)
Oil Well Sites (GOR < 300)

8,895
1,338
6,066
1,492

4,211
633
2,871
706

5,423
816
3,698
909

7,226
1,087
4,928
1,212

7,488
1,126
5,106
1,255

7,983
1,201
5,443
1,339

8,354
1,257
5,697
1,401

8,767
1,319
5,978
1,470

9,038
1,359
6,163
1,515

Low Production Sites
Gas Well Sites
Oil Well Sites (GOR > 300)
Oil Well Sites (GOR < 300)

1,896
206
606
1,083
2,575
8,216
1,542
1,234
663
497
166
180

897
98
287
513
1,219
3,889
1,542
1,234
663
497
166
180

1,156
126
370
660
1,569
5,010
1,542
1,234
663
497
166
180

1,540
167
492
880
2,092
6,674
1,542
1,234
663
497
166
180

1,596
173
510
912
2,167
6,915
1,542
1,234
663
497
166
180

1,701
185
544
972
2,311
7,373
1,542
1,234
663
497
166
180

1,780
193
569
1,017
2,418
7,716
1,542
1,234
663
497
166
180

1,868
203
597
1,068
2,538
8,097
1,542
1,234
663
497
166
180

1,926
209
616
1,101
2,616
8,347
1,542
1,234
663
497
166
180

148
72

148
72

148
72

148
72

148
72

148
72

148
72

148
72

148
72

Rod Packing Changeout

65

65

65

65

65

65

65

65

65

Routed to Control

7

7

7

7

7

7

7

7

7

32

32

32

32

32

32

32

32

32

29

29

29

29

29

29

29

29

29

3
0
1,143

3
0
541

3
0
697

3
0
929

3
0
962

3
0
1,026

3
0
1,074

3
0
1,127

3
0
1,162

212
7

212
7

212
7

212
7

212
7

212
7

212
7

212
7

212
7

1

1

1

1

1

1

1

1

1

Well Completions
Fugitives – Well Sites

GOR < 300
Gas and GOR > 300
Pneumatic Devices
Producing & Processing
Pneumatic Pumps
Controlled
Not Controlled
Reciprocating Compressors
Compressor Stations
Production & Processing

Gas Processing Plants
Rod Packing Changeout
Routed to Control
Centrifugal Compressors
Storage Vessels
Fugitives – Compressor Stations
Gathering and Boosting
Natural Gas Processing Plants
Sweetening Units

B-2

Appendix C
EPA’s Compliance and Emissions Data Reporting (CEDRI) Interface

C-1

Appendix D
Instructions for submitting reports to the EPA via CEDRI per 60.5420a(c)(11):
(11) You must submit reports to the EPA via CEDRI, except as outlined below. (CEDRI
can be accessed through the EPA's CDX (https://cdx.epa.gov/).) The EPA will make all the
information submitted through CEDRI available to the public without further notice to you. Do
not use CEDRI to submit information you claim as CBI. Anything submitted using CEDRI cannot
later be claimed CBI. You must use the appropriate electronic report in CEDRI for this subpart or
an alternate electronic file format consistent with the extensible markup language (XML) schema
listed on the CEDRI website (https://www.epa.gov/electronic-reporting-air-emissions/cedri/). If
the reporting form specific to this subpart is not available in CEDRI at the time that the report is
due, you must submit the report to the Administrator at the appropriate address listed in §60.4.
Once the form has been available in CEDRI for at least 90 calendar days, you must begin
submitting all subsequent reports via CEDRI. The reports must be submitted by the deadlines
specified in this subpart, regardless of the method in which the reports are submitted. Although we
do not expect persons to assert a claim of CBI, if you wish to assert a CBI claim, submit a
complete report generated using the appropriate form in CEDRI or an alternate electronic file
consistent with the XML schema listed on the EPA’s CEDRI website, including information
claimed to be CBI, on a compact disc, flash drive, or other commonly used electronic storage
medium to the EPA. The electronic medium shall be clearly marked as CBI and mailed to U.S.
EPA/OAQPS/CORE CBI Office, Attention: Group Leader, Fuels and Incineration Group, MD
C404-02, 4930 Old Page Rd., Durham, NC 27703. The same file with the CBI omitted shall be
submitted to the EPA via CEDRI. All CBI claims must be asserted at the time of submission.
Furthermore, under CAA section 114(c), emissions data is not entitled to confidential treatment,
and the EPA is required to make emissions data available to the public. Thus, emissions data will
not be protected as CBI and will be made publicly available.

D-1