FINAL
Supporting
Statement
For
EPA
Information
Collection
Request
Number
1601.05
Outer
Continental
Shelf
Air
Regulations
May
10,
2002
ii
Table
of
Contents
Section
Page
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
....................................
1
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
.................
1
1(
b)
CHARACTERIZATION
OF
THE
INFORMATION
COLLECTION
................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
..........................................................
4
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
..............................................
4
2(
b)
USE/
USERS
OF
THE
DATA
...........................................................................
5
3.
NONDUPLICATION,
CONSULTATION,
AND
OTHER
COLLECTION
CRITERIA
..........................................................................................................................
7
3(
a)
NONDUPLICATION
......................................................................................
7
3(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
.................................................................................................................
7
3(
c)
CONSULTATIONS
..........................................................................................
7
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
............................................
8
3(
e)
GENERAL
GUIDELINES
................................................................................
8
3(
f)
CONFIDENTIALITY
.......................................................................................
9
3(
g)
SENSITIVE
QUESTIONS
...............................................................................
9
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
.............................
9
4a)
RESPONDENTS/
STANDARD
INDUSTRIAL
CLASSIFICATION
(
SIC)
CODES
.............................................................................................................
9
4(
b)
INFORMATION
REQUESTED
......................................................................
10
(
i)
DATA
ITEMS
................................................................................................
11
(
ii)
Respondent
Activities
.................................................................................
17
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION,
METHODOLOGY
AND
INFORMATION
MANAGEMENT
...................................
21
5(
a)
Agency
Activities
............................................................................................
21
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
............................
22
5(
c)
SMALL
ENTITY
FLEXIBILITY
....................................................................
23
5(
d)
COLLECTION
SCHEDULE
...........................................................................
24
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
.......................
25
6(
a)
ESTIMATING
RESPONDENT
BURDEN
AND
COSTS
................................
25
6(
b)
ESTIMATING
STATE
AND
LOCAL
AIR
POLLUTION
CONTROL
iii
AGENCY
BURDEN
AND
COSTS
.................................................................
30
6(
c)
ESTIMATING
THE
EPA
BURDEN
AND
COSTS
.........................................
32
6(
d)
REASONS
FOR
CHANGE
IN
BURDEN
........................................................
33
Appendix
..................................................................................................................
A­
1
Labor
Rates
...............................................................................................................
A­
2
Indexes
for
Updating
Labor
Rates
..............................................................................
A­
3
Universe
of
Respondents
............................................................................................
A­
4
iv
List
of
Tables
Table
Page
1.
References
for
Burden
Activities
Associated
with
OCS
Air
Regulations
........................................................................................
35
2.
Respondent
Data
And
Information
Requirements
For
Preparing
PSD
Construction
Permits
.............................................................................................................
36
3.
Respondent
Data
and
Information
Requirements
for
Preparing
Part
D
Construction
Permits
........................................................................................
38
4.
Respondent
Data
for
ATC
Permits
Required
by
Rule
201
of
the
SBCAPCD's
Air
Pollution
Regulations
............................................
39
v
List
of
Exhibits
Exhibit
Page
1.
New
Exploration
Sources
Under
EPA
Authority:
Respondent's
Annual
Burdens
............................................................................................
Ex­
1
2.
New
Development/
Production
Sources
Under
EPA
Authority:
Respondent's
Annual
Burdens
..........................................................
Ex­
2
3.
New
Exploration
Sources
Under
State/
Local
Authority:
Respondent's
Annual
Burdens
................................................................................
Ex­
3
4.
Existing
Sources
Under
State/
Local
Authority:
Respondent's
Annual
Burdens
............................................................................................
Ex­
4
5.
New
Exploration
Sources
Under
State/
Local
Authority:
State
And
Local
Agencies
Annual
Burdens
............................................................................................
Ex­
5
6.
Existing
Sources
Under
State/
Local
Authority:
State
And
Local
Agencies
Annual
Burdens
................................................................................
Ex­
6
7.
New
Exploration
Sources
Under
EPA
Authority:
EPA
Annual
Burden
.........................................................................
Ex­
7
8.
New
Development/
Production
Sources
Under
EPA
Authority:
EPA
Annual
Burden
.................................................................................
Ex­
8
9.
Consistency
Updates
and
Overseeing
State/
Local
Activities:
EPA
Annual
Burden
........................................................
Ex­
9
10.
OCS
Air
Regulations
Information
Collection
Burden:
Summary
of
Annual
Burdens
and
Costs
..............................................................................................
Ex­
10
vi
List
of
Acronyms
and
Abbreviations
ATC
Authority
to
Construct
BACT
Best
Available
Control
Technology
CAA
Clean
Air
Act
as
Amended
in
1990
CFR
Code
of
Federal
Regulations
COA
Corresponding
Onshore
Area
ECI
Employment
Cost
Index
EIS
Environmental
Impact
Statement
EPA
U.
S.
Environmental
Protection
Agency
FR
Federal
Register
ICR
Information
Collection
Request
LAER
Lowest
Achievable
Emission
Rate
MMS
Minerals
Management
Service,
Department
of
the
Interior
NOA
Nearest
Onshore
Area
NOI
Notice
of
Intent
OMB
Office
of
Management
and
Budget
O&
M
Operating
and
Maintenance
PSD
Prevention
of
Significant
Deterioration
PTO
Permit
to
Operate
SBCAPCD
Santa
Barbara
County
Air
Pollution
Control
District
SCAQMD
South
Coast
Air
Quality
Management
District
vii
SLOAPCD
San
Luis
Obispo
County
Air
Pollution
Control
Division
VCAPCD
Ventura
County
Air
Pollution
Control
District
1
Part
C
of
title
I
of
the
CAA
specifies
requirements
for
the
prevention
of
significant
deterioration
of
air
quality
in
areas
where
the
air
quality
is
better
than
the
national
ambient
air
quality
standards
for
criteria
pollutants.
Sources
which
will
be
located
within
25
miles
of
the
State
seaward
boundary,
and
for
which
the
corresponding
onshore
area
is
designated
as
nonattainment
for
one
or
more
criteria
pollutants,
will
have
to
comply
with
part
D
(
Plan
Requirements
For
Nonattainment
Areas)
of
title
I
of
the
CAA.
2
Section
328
of
the
1990
CAA
defines
"
corresponding
onshore
area,"
with
respect
to
any
OCS
source,
as
the
onshore
attainment
or
nonattainment
area
that
is
closest
to
the
source,
unless
the
EPA
Administrator
determines
that
another
area,
with
more
stringent
requirements
with
respect
to
the
control
and
abatement
of
air
pollution,
may
reasonably
be
expected
to
be
affected
by
such
emissions.

1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
This
information
collection
request
(
ICR)
is
entitled
"
Air
Pollution
Regulations
for
Outer
Continental
Shelf
(
OCS)
Activities:
Reporting,
Record
keeping,
and
Testing
Requirements."
Environmental
Protection
Agency
(
EPA)
number
1601.04,
The
Office
of
Management
and
Budget
(
OMB)
number
2060­
0249
1(
b)
CHARACTERIZATION
OF
THE
INFORMATION
COLLECTION
Section
328
(
Air
Pollution
From
Outer
Continental
Shelf
Activities)
of
the
Clean
Air
Act
(
CAA)
as
amended
in
1990,
gives
EPA
responsibility
for
regulating
air
pollution
from
OCS
sources
located
offshore
of
the
States
along
the
Pacific,
Arctic,
and
Atlantic
Coasts,
and
along
the
eastern
Gulf
of
Mexico
coast
(
off
the
coast
of
Florida).
The
U.
S.
Department
of
Interior's
Minerals
Management
Service
(
MMS)
retained
the
responsibility
for
regulating
air
pollution
from
sources
located
in
the
western
Gulf
of
Mexico.
To
comply
with
the
requirements
of
section
328
of
the
CAA,
EPA,
on
September
4,
1992
at
57
FR
40792,
promulgated
regulations
to
control
air
pollution
from
OCS
sources
in
order
to
attain
and
maintain
Federal
and
State
ambient
air
quality
standards
and
to
comply
with
the
provisions
of
part
C
of
title
I
of
the
CAA.
1
Sources
located
within
25
miles
of
a
State's
seaward
boundary
must
comply
with
the
same
State/
local
air
pollution
control
requirements
as
would
be
applicable
if
the
source
were
located
in
the
corresponding
onshore
area
(
COA).
2
Sources
located
more
than
25
miles
from
a
State's
seaward
boundary
(
25
mile
limit)
must
comply
with
EPA
air
pollution
control
regulations.
The
regulations
are
codified
as
part
55
of
chapter
I
of
title
40
of
the
Code
of
Federal
Regulations
(
CFR).
On
September
2,
1997,
EPA
made
two
court­
ordered
revisions
to
the
regulations.
The
references
for
the
sections
of
the
OCS
regulations
that
pertain
to
the
burden
activities
addressed
in
this
ICR
are
shown
in
Table
1.

This
ICR
addresses
the
information
collection
burden
(
i.
e.,
hours
and
costs)
to
industry
respondents
who
are
subject
to
the
reporting,
record
keeping,
and
testing
requirements
of
the
OCS
air
regulations.
Industry
respondents
include
owners
or
operators
of
existing
and
new
or
3
Memorandum
from
Herkhof,
D.,
Minerals
Management
Service,
Department
of
Interior,
to
Sanders,
D.,
U.
S.
Environmental
Protection
Agency.
December
12,
2001.
Projected
OCS
Activities
for
Period
2002­
2004.
The
memorandum
provided
a
projected
range
of
1
exploratory
well
and
2
production
platforms
off
the
coast
of
Alaska;
3
development
wells,
2
construction
projects,
and
4
exploration
wells
in
the
Pacific
Region;
3
exploratory
wells,
3
production
platforms
(
in
addition
to
the
11
structures
pending
in
the
Destin
Dome
Track)
off
Florida
in
the
Gulf
of
Mexico;
and
1
exploratory
well
off
the
coast
of
North
Carolina.

2
modified
stationary
sources.
This
ICR
also
addresses
the
burden
to
the
agencies
who
are
responsible
for
implementing
and
enforcing
the
OCS
regulations.
The
EPA
has
delegated
the
authority
to
implement
and
enforce
the
OCS
regulations
for
sources
located
off
the
coast
of
California
to
four
local
air
pollution
control
agencies:
Santa
Barbara
County
Air
Pollution
Control
District
(
SBCAPCD);
South
Coast
Air
Quality
Management
District
(
SCAQMD);
Ventura
County
Air
Pollution
Control
District
(
VCAPCD);
and
San
Luis
Obispo
County
Air
Pollution
Control
District
(
SLOAPCD).
The
EPA
implements
and
enforces
the
regulations
for
all
other
sources
under
its
authority.
All
burden
estimates
are
calculated
for
the
3­
year
period
beginning
May
1,
2002
and
ending
April
30,
2005.

To
be
consistent
with
terminology
used
by
the
MMS,
OCS
sources
associated
with
the
recovery
of
oil
and
gas
resources
are
characterized
according
to
one
of
the
following
operational
phases.
The
first
phase
consists
of
exploration
activities,
which
are
conducted
from
temporarily
placed
vessels
or
structures.
Drilling
of
an
exploration
or
delineation
well
generally
lasts
2
to
3
months,
but
can
last
up
to
6
months.
The
second
phase
consists
of
the
construction
and
installation
of
a
permanent
production
platform
on
the
seabed
and
the
associated
"
topside"
(
above
sea
level)
structures.
A
typical
construction
phase
lasts
from
6
to
12
months.
The
third
phase
consists
of
the
development
drilling
of
wells,
from
which
the
oil
and
gas
resources
are
extracted,
and
the
long­
term
operations
and
maintenance
of
the
production
facility
over
the
life
of
the
field
or
structure.
A
typical
development/
production
phase
can
last
for
over
30
years.
These
three
phases
are
referred
to
as
exploration,
construction,
and
development/
production,
respectively,
throughout
the
remainder
of
this
ICR.

The
MMS
receives
development
plans
from
the
companies
authorized
to
conduct
exploration
and
development
of
the
OCS
tracks.
From
those
plans,
MMS
estimates3
the
following
new
OCS
activities
will
occur
in
the
2002
to
2005
time
frame:

Alaska
Coast:
1
exploratory
well
and
1
production
platform.

Pacific
Coast:
3
development
projects­
2
new
development
wells
and
1
development
well
from
existing
facility,
2
construction
projects
from
existing
facilities,
and
2
to
4
exploratory
wells.

Eastern
Gulf
of
Mexico:
3
Destin
Dome
­­
Project
is
pending.
11
production
platforms
are
currently
in
permitting
process.
Other
areas
­­
1­
3
exploratory
wells
and
2­
3
production
platforms.

There
is
still
a
great
deal
of
uncertainty
regarding
the
timing
and
number
of
eastern
Gulf
of
Mexico
projects
because
of
coastal
zoning
issues
associated
with
Destin
Dome.
The
structures
in
the
Destin
Dome
track
are
currently
stalled
in
the
permitting
process.
For
this
ICR,
it
was
assumed
that
a
total
of
11
structures
are
in
the
process
of
being
reviewed
for
the
Destin
Dome
track
and
three
permits
for
the
other
production
platforms
off
the
Florida
coast.
In
addition
to
the
projected
new
OCS
facilities,
there
are
21
existing
OCS
facilities
under
State/
local
jurisdiction,
all
off
the
coast
of
California.
Regarding
the
exploratory
well
off
the
coast
of
North
Carolina,
this
project
was
halted
due
to
litigation.
Chevron,
the
company
retaining
the
permit,
won
the
lawsuit;
however
it
is
unclear
whether
the
company
intends
to
continue
drilling
in
the
near
future.
All
the
sources
except
for
the
exploratory
well
off
the
coast
of
North
Carolina
are
expected
to
be
within
the
25­
mile
limit.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
The
need
and
authority
for
this
information
collection
is
contained
in
section
328
of
the
CAA
and
in
EPA
OCS
Air
Regulations,
codified
as
title
40
CFR
part
55.
Section
328
requires
EPA
to
establish
requirements
to
control
air
pollution
from
OCS
sources
to
attain
and
maintain
Federal
and
State
ambient
air
quality
standards
and
to
comply
with
the
provisions
of
part
C
of
title
I
of
the
CAA.
The
Administrator
must
update
the
requirements
as
necessary
to
maintain
consistency
with
onshore
regulations.
Each
requirement
established
under
section
328
is
treated,
for
purposes
of
sections
113
(
Federal
Enforcement),
114
(
Inspections,
Monitoring,
and
Entry),
116
(
Retention
of
State
Authority),
120
(
Noncompliance
Authority),
and
304
(
Citizen
Suits)
of
the
CAA,
as
a
standard
under
section
111
and
a
violation
of
any
such
requirements
will
be
considered
a
violation
of
section
111(
e)
of
the
CAA.

In
addition,
40
CFR
55.11
establishes
the
procedures
for
States
and
local
agencies
to
request
and
receive
delegation
of
authority
to
implement
and
enforce
the
regulations.
The
requesting
agency
must
demonstrate
that
it
has:

2.
Adopted
the
appropriate
portions
of
part
55
into
State
law,
3.
Adequate
authority
under
State
law
to
implement
and
enforce
the
requirements
of
part
55,
4.
Adequate
resources
to
implement
and
enforce
the
requirements
of
part
55,
and
5.
Adequate
administrative
procedures
to
implement
and
enforce
the
requirements
of
part
55.
4
2(
b)
USE/
USERS
OF
THE
DATA
There
are
five
types
of
reporting
requirements
for
the
industrial
respondent:
Notice
of
intent
(
NOI)
to
construct,
Preconstruction
permit
application,
Compliance
testing,
Operating
permit
application,
and
Record
keeping
and
reporting
tasks.

NOI
to
Construct
The
owner
or
operator
of
proposed
new
or
modified
development/
production
sources
that
are
located
within
the
25­
mile
limit
will
be
required
to
prepare
an
NOI
to
construct.
The
owner
or
operator
must
submit
not
more
than
18
months
prior
to
submitting
a
permit
application,
an
NOI
to
construct
to
the
EPA
Administrator
through
the
EPA
Regional
Office
and
the
air
pollution
control
agency
of
the
nearest
onshore
area
(
NOA)
and
adjacent
onshore
areas.
The
purposes
of
the
NOI
are
to
(
1)
trigger
an
EPA
review
of
onshore
regulations
to
determine
if
they
are
consistent
with
the
OCS
regulations
and,
(
2)
to
allow
adequate
time
for
onshore
areas,
other
than
the
NOA,
to
determine
if
they
will
petition
the
EPA
for
designation
as
the
COA.
Preconstruction
Permit
Applications
All
major
sources
must
comply
with
all
applicable
preconstruction
permit
requirements
including
the
need
to
submit
an
application
for
a
preconstruction
review
permit.
The
owner
or
operator
of
an
OCS
source
is
responsible
for
developing
or
collecting
all
relevant
information
not
otherwise
available
to
the
permit
reviewing
authority.
The
permit
reviewing
authority
reviews
the
application
materials
and
determines
if
the
proposed
source
meets
all
the
applicable
requirements.
This
includes
the
pollution
control
technology.
For
sources
which
will
be
constructed
or
modified
in
attainment
areas,
the
emissions
control
must
represent
the
best
available
control
technology
(
BACT)
and
must
be
shown
not
to
violate
the
national
ambient
air
quality
standards,
the
prevention
of
significant
deterioration
increments,
or
adversely
affect
air
quality
related
values
in
any
Class
I
areas.
For
sources,
which
will
be
constructed
or
modified
in
nonattainment
areas,
the
emissions
must
represent
the
lowest
achievable
emission
rate
(
LAER)
and
also
demonstrate
emission
reduction
offsets.
In
addition,
EPA
operates
a
BACT/
LAER
Clearinghouse,
which
contains
many
BACT
and
LAER
determinations
to
aid
sources
and
application
reviewers
in
identifying
reasonable
control
technology
proposals.
The
BACT
or
LAER
information
in
each
permit
will
be
gathered
and
submitted
for
entry
into
the
BACT/
LAER
Clearinghouse
database
as
a
reference
for
making
future
control
technology
determinations.
Information
on
BACT
and
LAER
determinations
is
available
to
the
public
through
the
National
Technical
Information
Service
and
the
EPA's
Office
of
Air
Quality
Planning
and
Standards'
Technology
Transfer
Network.

Compliance
Testing
5
Within
6
months
of
the
start
of
operations,
each
new
or
modified
major
source
is
required
to
complete
initial
compliance
tests
to
demonstrate
compliance
with
control
equipment
design
and
performance
specifications
in
its
preconstruction
permit.
In
addition,
annual
compliance
tests
are
required
for
existing
sources
in
California.

Operating
Permit
Application
A
second
type
of
permit
which
an
owner
or
operator
of
major
sources
must
obtain
is
the
operating
permit.
The
operating
permits
contain
information
on
the
ownership
and
location
of
a
source,
equipment
and
fuel
parameters
which
cause
emissions,
the
amount
and
type
of
emissions
from
each
source,
control
techniques
used
to
control
emissions,
and
record
keeping
and
reporting
requirements
to
ensure
that
control
techniques
are
properly
implemented.
The
information
in
operating
permits
is
used
by
regulatory
authorities
to
assess
a
source's
compliance
with
the
OCS
regulations,
to
assess
emissions
fees,
and
to
assess
noncompliance
penalties.

Record
keeping
and
Reporting
Tasks
Sources,
in
addition
are
required
to
monitor
emissions
and
operating
parameters
to
ensure
compliance
with
operating
requirements.
The
regulatory
agencies
will
use
the
compliance
test
results
and
the
monitoring
information
to
ensure
compliance
with
the
appropriate
regulations.
The
emission
data
will
also
be
used
by
the
regulatory
agencies
to
model
the
air
quality
in
the
area
and
to
evaluate
control
strategies.

3.
NONDUPLICATION,
CONSULTATION,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
The
information
collection
activities
that
will
be
required
under
the
OCS
regulations
are
not
routinely
required
elsewhere
by
the
EPA.
However,
similar
information
may
be
collected
during
the
development
of
certain
environmental
impact
statements
(
EIS).
In
such
cases,
regulations
and
policies
require
that
information
collected
for
EIS's
and
OCS
programs
be
coordinated
to
the
maximum
extent
possible
to
minimize
duplicating
the
collection
of
data.
Some
of
the
required
information
may
also
be
available
from
State
or
other
Federal
agencies.
However,
even
when
these
data
are
available,
they
are
not
generally
adequate
to
address
completely
the
relevant
requirements
of
the
OCS
regulations.
Section
328
of
the
CAA
requires
the
OCS
sources
within
25
miles
of
the
States'
seaward
boundaries
to
meet
the
same
requirements
as
are
applicable
in
the
COA.
This
includes
the
permitting,
monitoring,
record
keeping
and
reporting
requirements.
The
OCS
Air
Regulations
require
sources
located
beyond
25
miles
from
the
States'
seaward
boundaries
to
meet
the
requirements
of
the
nationally
promulgated
programs
(
e.
g.,
PSD,
new
source
performance
6
standards
programs,
and
title
V
operating
permit
program)
including
the
monitoring,
record
keeping
and
reporting
requirements
of
those
programs.
The
only
additional
information
collection
requirement
for
sources
is
the
need
to
file
a
NOI.
This
information
is
not
available
elsewhere
in
the
Agency
and
is
necessary
to
identify
the
COA
and
to
ensure
that
the
regulatory
requirements
are
updated.

3(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
On
November
2,
2001
at
66
FR
27819,
EPA
published
a
notice
announcing
its
intention
to
submit
this
ICR
to
the
Office
of
Management
and
Budget
and
the
availability
of
the
draft
supporting
statement.
The
EPA
received
one
minor
comment
on
the
draft
statement.

3(
c)
CONSULTATIONS
In
developing
the
initial
regulations,
EPA
held
round
table
discussions
with
industry
and
environmental
groups
and
with
Federal,
State,
and
local
agencies.
Four
public
hearings
were
held
in
January
1992
in
Anchorage,
San
Francisco,
Los
Angeles,
and
Washington,
D.
C.
Since
promulgation
of
the
regulations,
EPA
has
continued
to
work
with
the
MMS,
States
and
local
air
pollution
control
agencies
and
industry
representatives
to
update
information.
7
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
The
information
required
to
be
submitted
by
each
preconstruction
permit
applicant
will
be
submitted
on
a
one­
time­
only
basis.
When
an
existing
OCS
source
wishes
to
modify
or
expand
a
facility
already
in
operation,
most
of
the
information
submitted
will
pertain
to
the
new
construction.
New
development/
production
sources
and
platforms
are
expected
to
obtain
an
operating
permit
approximately
1
year
after
the
source
commences
operation.
In
the
previous
ICR,
the
development/
production
sources
and
platforms
were
not
expected
to
commence
operation
until
at
least
2000.
Thus
it
was
assumed
that
approximately
one­
half
of
the
23
projected
new
development/
production
sources
under
EPA's
regulatory
authority
would
apply
and/
or
obtain
an
operation
permit
during
the
3­
year
time
period
covered
by
that
ICR.
For
the
purposes
of
this
ICR,
a
similar
assumption
is
made
regarding
the
15
new
projected
development/
production
sources.
For
the
new
exploration
sources
and
existing
development/
production
sources
assumed
to
be
under
the
regulatory
authority
of
local
agencies,
it
was
projected
that
each
source
would
obtain
its
initial
permit
to
operate
(
PTO)
or
would
renew
its
PTO
during
the
3­
year
time
period
covered
by
this
ICR
to
comply
with
local
agency
regulations.
The
new
exploration
sources
and
existing
development/
production
sources
assumed
to
be
under
the
regulatory
authority
of
local
agencies
are
projected
to
be
subject
to
annual
compliance
testing,
record
keeping,
and
reporting
requirements
to
demonstrate
compliance
with
their
PTO's.
Less
frequent
collection
of
information
than
that
required
by
these
requirements
would
jeopardize
the
ability
of
regulatory
agencies
to
evaluate
a
source's
compliance
with
the
OCS
regulations.

3(
e)
GENERAL
GUIDELINES
This
ICR
adheres
to
the
guidelines
stated
in
the
1995
Paperwork
Reduction
Act,
the
Office
of
Management
and
Budget's
implementing
regulations,
EPA's
Information
Collection
Request
Handbook,
and
other
applicable
OMB
guidance.
3(
f)
CONFIDENTIALITY
Any
information
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
EPA's
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B­­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
SENSITIVE
QUESTIONS
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.
Therefore,
this
section
is
not
applicable.
8
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
RESPONDENTS/
STANDARD
INDUSTRIAL
CLASSIFICATION
(
SIC)
CODES
Section
328(
a)(
4)(
C)
of
the
CAA
defines
"
OCS
sources"
as
".
.
.
any
equipment,
activity,
or
facility
which:

·
Emits
or
has
the
potential
to
emit
any
air
pollutant,

·
Is
regulated
or
authorized
under
the
Outer
Continental
Shelf
Lands
Act,
and
·
Is
located
on
the
Outer
Continental
Shelf
or
in
or
on
waters
above
the
Outer
Continental
Shelf.

Such
activities
include,
but
are
not
limited
to,
platform
and
drill
ship
exploration,
construction,
development,
production,
processing,
and
transportation.
Emissions
from
any
vessel
servicing
or
associated
with
an
OCS
source,
including
emissions
while
at
the
OCS
source
or
en
route
to
or
from
the
OCS
source
within
25
miles
of
the
OCS
source,
will
be
considered
direct
emissions
from
the
OCS
source."

The
SIC
codes
for
sources
which
may
be
subject
to
the
OCS
regulations
include
the
following:

·
Major
Group
13
­
Oil
and
Gas
Extraction
·
SIC
code
1311
­
Crude
petroleum
and
natural
gas
·
SIC
code
1321
­
Natural
gas
liquids
·
SIC
code
1382
­
Oil
and
gas
field
exploration
services
·
Major
Group
44
­
Water
Transportation
·
SIC
code
4449
­
Water
transportation
of
freight,
not
elsewhere
classified
·
SIC
code
4492
­
Towing
and
tugboat
services
·
Major
Group
46
­
Pipelines,
Except
Natural
Gas
·
SIC
code
4612
­
Crude
petroleum
pipelines
·
Major
Group
49
­
Electric,
Gas,
and
Sanitary
Services
·
SIC
code
4922
­
Natural
gas
transmissions
4(
b)
INFORMATION
REQUESTED
4
The
SBCAPCD's
regulations
refer
to
preconstruction
permits
as
"
Authority
to
Construct"
permits
and
operating
permits
as
"
Permits
to
Operate."
For
this
ICR,
the
terms
"
Authority
to
Construct"
and
"
Permits
to
Operate"
are
used
when
discussing
the
SBCAPCD's
regulations.

9
Since
the
OCS
Air
Regulations
essentially
extend
the
coverage
of
other
regulations,
the
data
and
information
requirements
associated
with
the
regulations
will
vary
depending
on
the
underlying
regulations.
For
example,
sources
locating
within
25­
mile
limit
off
the
coast
of
a
nonattainment
area
will
generally
have
more
stringent
NSR
regulations
than
those
locating
off
the
coast
of
an
attainment
area.
The
data
and
information
requirements
will
also
vary
depending
on
the
size
and
type
of
source.
The
exploration
sources
are
generally
smaller
sources
and
not
subject
to
the
permit
requirements
of
larger
sources.

Based
on
the
MMS
projections,
the
following
OCS
facilities
were
assumed
for
the
purposes
of
this
ICR:

Sources
under
EPA
authority
Existing
development/
production
sources
0
Exploratory
wells
within
25­
mile
limit
4
Exploratory
wells
beyond
25­
mile
limit
0
New
development/
production
sources
15
Sources
under
the
authority
of
the
local
agencies
Existing
development/
production
sources
21
Exploratory
wells
within
25­
mile
limit
4
Exploratory
wells
beyond
25­
mile
limit
0
Construction
Projects
from
existing
sources
2
New
development/
production
sources
3
Please
note
that
in
many
instances
a
range
of
projected
permit
activities
was
given
by
MMS.
For
the
purposes
of
calculating
cost
and
burden
the
upper
number
of
the
range
was
selected.

The
sources
under
EPA
authority
will
most
likely
locate
off
the
coast
of
an
attainment
area
and
the
exploratory
wells
will
likely
be
minor
sources
and
not
required
to
obtain
either
a
PSD
or
an
operating
permit.
On
the
other
hand,
sources
under
the
authority
of
the
local
agencies
are
off
the
coast
of
non­
attainment
areas
and
subject
to
the
more
stringent
requirements.
For
the
purposes
of
this
ICR,
the
SBCAPCD
was
used
as
a
typical
local
agency
to
estimate
the
resource
burdens.

The
SBAPCD's
Rule
202
(
paragraph
(
C)(
h))
requires
a
source
with
drilling
rig
engines
exceeding
a
total
of
300
brake
horsepower
to
obtain
an
Authority
to
Construct
(
ATC)
permit
and
a
PTO
if
nitrogen
oxide
emissions
from
all
of
the
source's
drilling
rig
engines
exceed
25
tons
in
any
consecutive
4
calendar
quarters.
4
This
type
of
source
is
treated
as
a
stationary
source
under
10
the
SBCAPCD's
regulations.
For
the
purpose
of
this
analysis,
it
was
assumed
that
four
new
exploration
sources
anticipated
for
the
southern
California
planning
area
will
exceed
the
brake
horsepower
and
emissions
threshold
limits
and
will
be
subject
to
the
ATC
and
PTO
requirements.
The
sources
will
also
have
to
prepare
and
submit
an
NOI
to
construct
in
accordance
with
the
requirements
of
the
OCS
Air
Regulations.

(
i)
Data
Items
NOI
to
Construct
New
or
modified
sources
that
will
be
located
within
the
25­
mile
limit
will
have
to
prepare
and
submit
an
NOI
to
construct
not
more
than
18
months
before
submitting
a
permit
application.
The
data
and
information
requirements
which
a
source
must
include
in
an
NOI
to
construct
must
include
the
following
minimum
information:

·
General
company
information,
including
company
name
and
address,
owner's
name
and
agent,
and
facility
site
contact.

·
Facility
description
in
terms
of
the
process
and
products,
including
identification
by
SIC
code.

·
Estimate
of
the
proposed
project's
potential
emissions
of
any
air
pollutant,
expressed
in
total
tons
per
year
and
in
such
other
terms
as
may
be
necessary
to
determine
the
applicability
of
requirements
of
section
55.4
of
the
regulation.
Potential
emissions
for
the
project
must
include
all
vessel
emissions
associated
with
the
proposed
project
in
accordance
with
the
definition
of
potential
emissions
in
section
55.2
of
the
regulation.

·
Description
of
all
emission
points
including
associated
vessels.

·
Estimate
of
quantity
and
type
of
fuels
and
raw
materials
to
be
used.

·
Description
of
proposed
air
pollution
control
equipment.

·
Proposed
limitations
on
source
operations
or
any
work
practice
standards
affecting
emissions.

·
Other
information
affecting
emissions,
including
where
applicable,
information
related
to
stack
parameters
(
including
height,
diameter,
and
plume
temperature),
flow
rates,
and
equipment
and
facility
dimensions.
11
·
Such
other
information
as
may
be
necessary
to
determine
the
applicability
of
onshore
requirements.

·
Such
other
information
as
may
be
necessary
to
determine
the
source's
impact
in
onshore
areas.
Exploration
sources
are
exempt
from
this
requirement.

In
the
past,
owners
or
operators
of
new
sources
have
had
to
include
these
data
items
in
parts
C
and
D
preconstruction
permit
applications.
Therefore,
collection
of
these
data
items
for
an
NOI
to
construct
is
not
considered
an
additional
burden
over
the
data
items
presently
required
in
preconstruction
permit
applications.

Preconstruction
Permit
Applications
All
new
or
modified
major
sources
are
required
to
prepare
and
submit
a
preconstruction
permit
application.
The
table
2
summarizes
the
data
and
information
requirements
which
must
be
included
in
all
part
C
PSD
preconstruction
permit
applications.

The
table
also
shows
the
references
for
the
data
and
information
requirements
specified
in
the
CAA
and
the
current
regulations
specified
in
the
CFR.
The
first
CFR
reference
shown
for
each
requirement
in
table
2
pertains
to
the
requirements
under
part
51
which
govern
the
way
States
implement
part
C
programs.
The
second
CFR
reference
(
shown
in
brackets)
pertains
to
the
requirements
under
part
52
that
govern
the
way
the
EPA
implements
part
C
programs
when
States
fail
to
implement
part
C
programs.

Table
3
summarizes
the
data
and
information
requirements
that
must
be
included
in
all
part
D
construction
permit
applications.
Table
3
also
shows
the
references
for
the
data
and
information
requirements
specified
in
the
CAA
and
the
current
regulations
specified
in
the
CFR.

The
SBCAPCD's
Rule
201
(
Permits
Required)
requires
the
owner
or
operator
of
a
new
OCS
source
to
obtain
an
ATC
permit
before
the
owner
or
operator
can
begin
construction
of
the
source.
Paragraphs
C.
4,
C.
5,
and
C.
6
of
Rule
201
also
specify
the
data
which
an
owner
or
operator
must
include
in
a
part
D
and
part
C
ATC
permit
application.
These
data
and
information
requirements
are
summarized
in
Table
4.

The
SBCAPCD's
Rule
205
(
Standards
for
Granting
Applications)
specifies
the
requirements
that
the
owner
or
operator
of
a
new
source
must
meet
before
the
SBCAPCD
will
issue
an
ATC
permit.
The
requirements
for
part
D
and
part
C
permits
are
specified
in
section
3.
a
and
3.
b
of
Rule
205,
respectively.
The
requirements
contained
in
section
3.
b
of
Rule
205
are
similar
to
the
requirements
contained
in
EPA's
part
C
PSD
regulations.
In
addition,
section
3.
b
requires
the
owner
or
operator
of
a
proposed
new
source
to
obtain
emissions
offsets
from
existing
5
The
requirements
for
air
quality
modeling
may
be
waived
by
the
SBCAPCD
if
(
1)
the
applicant
submits
sufficient
information
to
demonstrate
that
emissions
from
the
new
source
will
result
in
a
net
air
quality
benefit,
(
2)
the
applicant
will
use
new
or
innovative
control
technology
which
will
result
in
a
significantly
lower
emission
rate
than
would
have
occurred
with
the
use
of
previously
known
BACT,
and
which
will
likely
serve
as
a
model
for
technology
to
be
applied
to
similar
sources
within
the
State.

12
sources
sufficient
to
offset
all
anticipated
quarterly
emissions
increases
associated
with
the
new
source.

Section
3.
a
of
Rule
205
requires
the
owner
or
operator
of
a
new
source
to
prepare
an
ATC
permit
application
to
show
that
emissions
that
are
precursors
to
ozone
and
PM­
10
formation
are
controlled
sufficiently
to
ensure
that
the
source
will
not
exceed
the
Federal
and
California
ozone
standards
and
the
California
PM­
10
standard.
Precursors
to
ozone
formation
include
volatile
organic
compounds
and
nitrogen
oxides.
Precursors
to
PM­
10
formation
include
volatile
organic
compounds,
nitrogen
oxides,
and
sulfur
oxides.
The
requirements
in
the
SBCAPCD's
section
3.
a
are
similar
to
the
EPA's
part
D
regulations.
However,
the
SBCAPCD's
rules
will
be
more
stringent
than
the
part
D
requirements
in
three
respects.
First,
Rule
205
requires
an
emissions
offset
ratio
of
1.2
to
1
where
the
part
D
emissions
offset
ratio
is
1.15
to
1
for
volatile
organic
compound
emissions.
Second,
Rule
205
requires
air
quality
modeling,
but
the
EPA's
part
D
regulations
do
not
explicitly
require
air
quality
modeling.
5
Third,
Rule
205
will
require
the
owner
or
operator
of
a
new
source
that
will
be
located
in
a
nonattainment
area
for
a
pollutant
to
obtain
an
ATC
permit
if
the
source
will
cause
any
increase
in
emissions
that
contribute
to
the
formation
of
the
nonattainment
pollutant,
where
the
EPA's
part
D
regulations
require
the
owner
or
operator
of
a
source
to
obtain
a
preconstruction
permit
if
the
source's
emissions
exceed
specified
emissions
thresholds.

Compliance
Testing
New
exploration
off
the
coast
of
California
and
development/
production
sources
are
required
to
perform
initial
compliance
tests
to
demonstrate
compliance
with
the
control
equipment
design
and
performance
specifications
in
their
preconstruction
permits
before
they
can
obtain
operating
permits.
For
the
purpose
of
this
analysis,
it
was
assumed
that
four
new
exploration
sources
which
will
be
under
the
regulatory
authority
of
the
delegated
programs
and
all
of
the
new
three
development/
production
platforms
will
perform
their
initial
compliance
tests
between
May
1,
2002
and
April
30,
2005.

Annual
compliance
tests
are
required
for
the
21
existing
development/
production
sources
located
within
the
25­
mile
limit
of
California.
The
purpose
of
the
annual
testing
requirements
is
to
demonstrate
that
each
source
is
in
compliance
with
its
operating
permit.
For
the
purpose
of
this
analysis,
it
was
assumed
that
these
sources
would
be
subject
to
3
years
of
annual
compliance
testing.
13
Operating
Permits
For
the
purpose
of
this
analysis,
it
was
assumed
that
some
of
the
new
development/
production
sources
which
will
be
under
the
EPA's
regulatory
authority
will
be
required
to
obtain
title
V
operating
permits
before
becoming
fully
operational.
Operating
permits
typically
contain
the
following
minimum
information
requirements:

·
Ownership
and
location
of
the
source;

·
An
inventory
of
the
type
and
amount
of
emissions
associated
with
each
piece
of
equipment
used
at
the
source;

·
Emissions
control
techniques
for
each
piece
of
equipment;
such
techniques
may
include
process
design
or
operational
changes
to
equipment,
add­
on
control
equipment,
and
inspection
and
maintenance
procedures;

·
Record
keeping
requirements
to
ensure
that
control
techniques
and
inspection
and
maintenance
procedures
are
being
properly
implemented;

·
Annual
compliance
testing
requirements;

·
Reporting
requirements
for
the
periodic
submittal
of
record
keeping
or
test
data
for
review
by
the
regulatory
authority.

The
21
existing
development/
production
sources
off
the
coast
of
Southern
California
are
required
to
obtain
PTO's.
The
information
which
these
sources
are
required
to
include
in
their
PTO's
is
similar
to
the
types
of
information
shown
above
for
title
V
operating
permits.

The
SBCAPCD's
Rule
202
(
paragraph
(
C)(
h))
requires
new
exploration
sources
to
obtain
PTO's.
According
to
the
SBCAPCD,
record
keeping
and
reporting
requirements
are
added
to
a
source's
ATC
permit
which
is
then
converted
to
the
source's
PTO
when
the
source
is
ready
to
become
operational.
Therefore,
the
only
additional
data
items
a
source
must
collect
are
associated
with
the
record
keeping
requirements
in
its
PTO.
Under
Rule
202
(
paragraph
(
C)(
h)(
3)),
owners
or
operators
of
drilling
rigs
are
required
to
maintain
a
log
book
of
fuel
use.
The
log
book
is
to
contain
the
following
entries:

·
Name,
identification
number,
and
location
of
each
well;

·
Start
and
end
dates
of
drilling;
14
·
Daily
fuel
use
as
determined
by
dipstick
measurement
and
fuel
deliveries
or
other
means
approved
by
the
SBCAPCD.

Record
keeping
and
Reporting
Tasks
The
record
keeping
and
reporting
tasks
will
vary
depending
on
the
type
of
source
and
the
operating
permits
requirements.
For
example,
exploration
sources
off
the
Santa
Barbara
coast
must
maintain
an
log
book
and
provide
a
copy
of
the
book
to
the
SBAPCD
when
the
exploration
is
complete.
Development
and
production
source
typically
are
required
to
monitor
certain
emissions
and
operational
parameters
and
submit
annual
reports
to
the
local
districts.

(
ii)
Respondent
Activities
NOI
to
Construct
The
following
items
are
a
comprehensive
list
of
the
activities
that
the
owner
or
operator
of
a
new
development/
production
OCS
source
will
have
to
perform
to
prepare
and
submit
an
NOI
to
construct:

·
Read
applicable
regulations
to
determine
compliance
requirements;

·
Inquire
or
meet
with
the
appropriate
permit
reviewing
authority
to
obtain
guidance
on
what
data
are
needed
to
meet
the
applicable
requirements;

·
Prepare
NOI
to
construct;

·
Submit
the
NOI
to
construct
to
the
EPA
Administrator
through
the
EPA
Regional
Office
and
to
the
air
pollution
control
agency
of
the
NOA
and
adjacent
onshore
areas.

Preconstruction
Permit
Applications
The
following
items
are
a
comprehensive
list
of
the
activities
that
the
owner
or
operator
of
a
new
development/
production
source
will
have
to
perform
to
prepare
a
preconstruction
permit
application
if
the
source
is
subject
to
part
C
PSD
regulations:

·
Read
applicable
regulations
to
determine
compliance
requirements;

·
Inquire
or
meet
with
the
appropriate
permit
reviewing
authority
to
obtain
guidance
on
what
data
are
needed
to
meet
the
applicable
requirements;

·
Prepare
BACT
engineering
analysis;
15
·
Perform
air
quality
modeling;

·
Perform
pre­
and
post­
construction
air
quality
monitoring
(
if
not
already
available);

·
Determine
impacts
on
air
quality
related
values
in
Federal
Class
I
areas;

·
Submit
application
to
the
U.
S.
Fish
and
Wildlife
Service
for
endangered
species
impact
analysis;

·
Prepare
and
submit
permit
application;

·
Attend
public
hearing;

·
Revise
permit
application
per
comments
received
from
the
permit
reviewing
authority
and/
or
public
comments.

For
the
purpose
of
this
analysis,
it
was
assumed
that
permit
applications
for
the
fourteen
development/
production
sources
off
the
Florida
coast
and
the
one
off
the
coast
of
Alaska
will
be
submitted.
However,
the
level
of
effort
associated
with
performing
the
activities
as
shown
above
will
vary
from
source
to
source
depending
on
the
types
and
amounts
of
pollutants
emitted
by
the
source,
location
of
the
source,
and
availability
of
existing
information
such
as
air
quality
and
modeling
data.
For
example,
an
owner
or
operator
will
not
have
to
perform
dispersion
modeling
analyses
to
determine
impacts
on
air
quality
related
values
in
a
Federal
Class
I
area
if
the
source's
emissions
will
not
impact
a
Federal
Class
I
area.
In
addition,
an
owner
or
operator
will
only
have
to
perform
monitoring
if
requested
by
the
permit
reviewing
authority.

The
four
new
exploration
sources
expected
to
locate
off
the
coast
of
Southern
California
were
assumed
to
be
subject
to
the
SBCAPCD's
regulations.
As
a
result,
the
sources
will
undergo
part
D
preconstruction
review
because
the
Santa
Barbara
onshore
area
is
classified
as
a
serious
nonattainment
area
for
ozone
and
moderate
nonattainment
for
PM­
10.
The
sources
will
also
have
to
undergo
part
C
PSD
preconstruction
review
for
the
attainment
pollutants
(
i.
e.,
nitrogen
dioxide,
sulfur
dioxide,
carbon
monoxide,
and
lead).
However,
the
source
is
not
expected
to
exceed
the
emissions
thresholds
for
carbon
monoxide
or
lead
and,
therefore,
would
not
have
to
obtain
an
ATC
permit
for
these
two
pollutants.
Section
3.
a
of
Rule
205
of
the
SBCAPCD's
regulations
requires
ambient
modeling
as
part
of
the
source's
application
for
a
part
D
permit.
The
source
would
be
required
to
prepare
a
LAER
and
a
BACT
engineering
analysis
for
nonattainment
and
attainment
pollutants,
respectively.
In
the
SBCAPCD's
Rule
201,
LAER
and
BACT
requirements
are
included
together
under
the
paragraph
C.
5
(
see
Table
4).
It
was
assumed
that
the
owner
or
operator
of
a
source
subject
to
the
SBCAPCD's
regulations
will
also
have
to
demonstrate
that
emissions
offsets
have
been
achieved
for
the
precursors
to
ozone
and
PM­
10,
16
and
that
the
offsets
would
be
sufficient
to
meet
the
offset
requirements
for
the
attainment
pollutants
(
i.
e.,
nitrogen
dioxide
and
sulfur
dioxide).

Compliance
Testing
For
the
purposes
of
this
analysis,
it
was
assumed
that
development/
production
sources
would
use
Reference
Method
20
to
test
for
nitrogen
oxide
emissions
from
gas
turbines.
For
development/
production
and
exploration
sources
that
have
internal
combustion
engines,
it
was
assumed
that
the
instrumental
methods
of
Reference
Methods
3A,
6C,
and
7E
using
the
electrochemical
cell
methodology
would
be
used
to
test
for
nitrogen
oxide,
carbon
monoxide,
hydrocarbon,
and
sulfur
dioxide
emissions.
The
activities
associated
with
completing
compliance
tests
are
as
follows:

·
Prepare
a
pretest
plan
and
submit
the
plan
to
the
appropriate
permit
reviewing
authority
for
review
and
approval
at
least
30
days
before
conducting
the
tests;

·
Clean
and
calibrate
test
equipment
for
tests;

·
Perform
tests;

·
Analyze
samples,
summarize
data,
and
write
report.

Operating
Permits
In
general,
the
activities
that
new
or
modified
and
existing
sources
will
have
to
perform
to
prepare
an
operating
permit
application
include
the
following:

·
Read
applicable
regulations
to
determine
compliance
requirements;

·
Inquire
or
meet
with
the
appropriate
permit
reviewing
authority
to
obtain
guidance
on
which
data,
compliance
testing,
and
record
keeping
and
reporting
activities
are
needed
to
meet
the
applicable
requirements;

·
Prepare
and
submit
the
permit
application;

·
Attend
public
hearing;

·
Revise
permit
application
per
comments
received
from
the
permit
reviewing
authority
and/
or
public
comments.

The
SBCAPCD's
Rule
202
(
paragraph
(
C)(
h))
requires
new
exploration
sources
to
obtain
a
PTO.
According
to
the
SBCAPCD,
record
keeping
and
reporting
requirements
are
added
to
a
17
source's
ATC
permit
which
are
then
converted
to
the
sources'
PTO
when
the
sources
are
ready
to
become
operational.
Therefore,
the
owner
or
operator
of
an
exploration
source
will
have
to
prepare
a
PTO
application
containing
all
relevant
information
from
its
ATC
permit
and
record
keeping
and
reporting
requirements
determined
by
the
SBCAPCD.

Record
keeping
and
Reporting
Tasks
Once
an
owner
or
operator
has
obtained
approval
of
its
PTO
application,
the
owner
or
operator
will
have
to
submit
its
log
book
for
each
well
drilled
to
the
SBCAPCD
within
60
days
after
drilling
has
been
terminated.
The
SBCAPCD's
regulation
requires
the
drilling
contractor
to
certify
and
submit
a
copy
of
the
fuel
log
book
records,
or
summary
thereof,
showing
the
total
amount
of
fuel
used
during
the
drilling
of
each
well.

Authority
to
implement
and
enforce
the
regulations
for
the
existing
development/
production
sources
has
been
delegated
to
the
local
air
pollution
control
districts.
Therefore,
the
existing
development/
production
sources
are
subject
to
annual
reporting
requirements
through
their
PTO's
required
by
local
agencies.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION,
METHODOLOGY
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
State
and
Local
Agency
Activities
Agencies
delegated
authority
for
the
OCS
program
are
responsible
for
processing
NOI's
to
construct,
reviewing
and
acting
on
preconstruction
and
operating
permit
applications,
conducting
enforcement
activities
such
as
inspections,
reviewing
pretest
plans
and
test
reports,
attending
tests
(
if
desired
by
the
agency),
and
reviewing
reports
that
sources
must
submit
to
comply
with
their
operating
permits.

Agencies
responsible
for
processing
NOI's
to
construct
and
preconstruction
and
operating
permit
applications
will
typically
perform
the
following
activities:

·
Answer
respondent
questions;

·
Log­
in
and
review
data
submissions;

·
Request
additional
information
for
incomplete
applications;

·
Analyze
requests
for
confidentiality
and
provide
appropriate
protection;
18
·
Prepare
completed
applications
for
processing
and
approval;

·
Prepare
notices
of
public
hearings
on
permit
applications
for
publication
in
newspapers,
arrange
and
attend
public
hearings,
and
summarize
and
respond
to
public
comments;

·
Submit
information
on
BACT/
LAER
determinations
to
the
EPA's
BACT/
LAER
Clearinghouse
for
entry
into
database.

EPA
Activities
The
EPA
will
perform
reviews
of
new
regulations
adopted
by
State
and
local
COA's
to
determine
if
the
regulations
are
applicable
to
OCS
sources.
If
it
is
determined
that
a
new
onshore
regulation
is
applicable
to
OCS
sources
and
EPA
determines
that
the
new
regulation
does
not
conflict
with
Federal
law,
then
the
EPA
will
update
the
OCS
regulations
by
the
incorporation
of
such
regulation.
Such
an
update
will
require
formal
notice
in
the
FR
and
opportunities
for
public
comment.
The
EPA
expects
to
allocate
staff
equivalent
to
one­
half
of
an
person
each
year
for
the
purpose
of
consistency
updates
from
May
1,
2002
through
April
30,
2005.

The
EPA
will
consult
with
the
MMS
to
prepare
air
quality
impact
analyses
for
environmental
impact
statements
for
OCS
leasing
activities,
and
to
comply
with
the
consultation
process
requirement
of
the
Endangered
Species
Act.
However,
this
consultation
process
is
not
expected
to
increase
the
EPA's
burden
associated
with
the
OCS
program.
Therefore,
a
burden
estimate
was
not
calculated
for
this
activity.

5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
It
is
the
responsibility
of
each
owner
and
operator
of
an
OCS
source
affected
by
the
OCS
regulations
to
prepare
and
submit
an
NOI
to
construct,
a
preconstruction
permit,
and/
or
an
operating
permit
application
to
the
permit
reviewing
authority.
The
permit
reviewing
authority
will
log
in
permit
applications
and
store
them
in
a
central
file
at
the
location
of
the
permit
reviewing
authority.
Once
preconstruction
permits
have
been
approved,
the
permits
will
be
submitted
to
the
EPA's
BACT/
LAER
Clearinghouse
where
control
technology
information
will
be
entered
into
a
database.
Because
the
preconstruction
permits
and
associated
control
technology
determinations
are
performed
on
a
case­
by­
case
basis,
the
OCS
regulations
will
not
contain
forms
which
owners
or
operators
will
have
to
fill
out
and
submit
to
the
permit
reviewing
authority.

Qualified
personnel
that
work
for
the
permit
reviewing
authority
will
perform
permit
reviews
and
check
the
quality
of
data
submitted
by
the
applicant
on
a
case­
by­
case
basis.
The
applicant
will
be
required
to
submit
information
on
how
the
data
were
obtained
(
e.
g.,
indicate
whether
emissions
data
were
obtained
through
the
use
of
emissions
factors
or
test
data)
and
how
calculations
were
performed.
The
permit
reviewing
authority
personnel
will
check
data
quality
by
reviewing
test
data
and
checking
engineering
calculations,
and
by
reviewing
control
technology
19
determinations
for
similar
sources.
The
BACT/
LAER
Clearinghouse
database
will
be
reviewed
for
information
on
control
technology
determinations
made
for
sources
similar
to
the
sources
included
in
a
permit
application.
Confidential
information
submitted
by
the
applicant
will
be
handled
by
the
permit
reviewing
authority's
confidential
information
handling
procedures.
The
public
will
be
provided
the
opportunity
to
review
a
permit
application
by
obtaining
a
copy
of
the
application
from
the
permit
reviewing
authority
and
by
attending
the
public
hearing.

The
OCS
regulations
do
not
require
the
request
of
information
through
any
type
of
survey.

5(
c)
SMALL
ENTITY
FLEXIBILITY
This
section
is
not
applicable
because
the
NOI
to
construct,
preconstruction
and
operating
permit,
annual
compliance
testing,
recordkeeping,
and
reporting
requirements
associated
with
the
OCS
regulations
do
not
directly
affect
small
entities.

5(
d)
COLLECTION
SCHEDULE
Existing
development/
production
sources
are
currently
subject
to
the
OCS
regulations,
and
authority
to
implement
and
enforce
the
regulations
for
those
sources
has
been
delegated
to
the
local
air
pollution
control
districts.
Therefore,
the
existing
development/
production
sources
are
subject
to
annual
reporting
requirements
through
their
PTO's
required
by
local
agencies.
It
is
not
known
when
the
new
exploration
sources
will
begin
construction.
For
the
purpose
of
this
analysis,
it
was
assumed
that
the
exploration
sources
under
the
local
regulatory
authority
would
conduct
activities
throughout
the
time
period
covered
by
this
ICR.
For
the
new
exploration
sources
under
the
EPA's
regulatory
authority,
it
was
assumed
that
they
would
complete
operations
before
April
2005.
For
the
new
development/
production
sources
under
EPA's
regulatory
authority,
it
was
assumed
that
they
would
become
operational
by
April
2005.
However,
because
of
the
time
needed
to
obtain
a
permit
and
construct
the
source,
it
was
assumed
that
most
would
not
be
operational
until
sometime
in
2005.
20
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
AND
COSTS
This
section
presents
estimates
of
the
burden
to
exploration
and
development/
production
sources
associated
with
the
OCS
regulations.
The
respondent
burden
estimates
are
based
on
the
data
items
and
respondent
activities
described
in
section
4(
b).

All
costs
are
presented
in
2002
dollars.
The
cost
estimates
are
based
on
a
respondent
inhouse
wage
rate
of
$
52.00
per
hour
and
a
contractor
wage
rate
of
$
69.00
per
hour.
Both
rates
were
adjusted
from
the
previous
ICR
using
the
Bureau
of
Labor
Statistics'
Employment
Cost
Index
for
Civilian
Workers
Excluding
Sales.
(
See
appendix
A).
The
wage
rates
represent
average
rates
for
the
various
types
of
individuals
(
e.
g.,
managers,
engineers,
technicians,
legal
staff,
and
clerical)
required
to
complete
the
tasks
and
include
direct
personnel
and
overhead
costs.
The
operating
and
maintenance
(
O&
M)
costs
include
various
items
necessary
to
record
and
keep
data
and
to
submit
the
data
and
reports
to
EPA
and/
or
the
delegated
local
agency.
This
includes
the
costs
for
filing
cabinets,
photocopying
and
shipping.
The
capital
costs
include
the
cost
for
any
additional
monitoring
equipment
necessary
to
comply
with
the
OCS
Air
Regulations.
The
respondent's
annual
labor
hours
and
costs
for
the
3­
year
time
period
covered
by
this
ICR
are
presented
in
exhibits
1
through
4.

New
Exploration
Sources
Under
EPA
Authority
(
Exhibit
1)

Of
the
expected
four
new
exploration
sources
under
EPA
authority,
three
are
projected
to
locate
off
the
coast
of
Florida
in
the
eastern
Gulf
of
Mexico
and
one
is
projected
to
locate
off
the
coast
of
Alaska
in
the
Beaufort
Sea.
However,
for
the
purposes
of
this
ICR,
it
was
assumed
that
all
exploratory
sources
under
EPA
authority
would
have
the
same
burden.
The
affected
exploration
sources
will
have
to
read
the
regulations,
prepare
a
NOI
to
construct,
and
conduct
some
record
keeping
and
reporting
tasks.
But,
because
they
are
expected
to
be
minor
sources,
they
will
not
have
to
prepare
preconstruction
permit
applications
to
comply
with
PSD
requirements
under
part
C
of
title
I
of
the
CAA.
It
is
anticipated
that
the
exploration
sources
will
not
have
to
install
any
additional
monitoring
equipment
to
comply
with
the
regulatory
requirements.
Therefore,
there
will
be
no
capital
cost
for
these
sources.

Exhibit
1
provides
a
breakdown
of
the
burden
and
costs
for
these
activities.
For
the
estimated
three
responses,
the
average
annual
burden
for
the
respondents
is
estimated
to
be
96
hours
and
$
4,992
plus
an
additional
$
323
in
O&
M
costs.
Since
the
exploration
vessels
are
expected
to
have
all
necessary
monitoring
equipment
to
meet
the
OCS
Air
Regulations,
no
capital
cost
is
projected
to
be
necessary.
21
New
Development/
Production
Sources
Under
EPA
Authority
(
Exhibit
2)

Of
the
fifteen
new
development/
production
sources,
eleven
are
projected
to
locate
off
the
coast
of
Florida
in
the
Destin
Dome
track,
three
additional
sources
in
other
areas
in
the
eastern
Gulf
of
Mexico,
and
one
is
projected
to
locate
off
the
coast
of
Alaska.
All
are
expected
to
be
located
within
25
miles
of
the
States
seaward
boundaries.
These
fifteen
new
sources
are
expected
to
read
the
regulations,
consult
with
EPA
or
the
State/
local
agencies,
prepare
an
NOI
to
construct,
prepare
a
PSD
application,
perform
a
compliance
test,
submit
an
operating
permit
application
and
conduct
recordkeeping
and
reporting
tasks.
Because
of
the
expertise
required
to
prepare
a
preconstruction
permit
application
and
to
conduct
a
compliance
emission
test,
the
sources
will
most
likely
use
a
contractor
for
these
operations.
Typical
tasks
which
the
contractor
will
perform
in
the
preparation
of
the
preconstruction
permit
application
include:

·
Inquire
or
meet
with
the
appropriate
permit
reviewing
authority
to
obtain
guidance
on
what
data
are
needed
to
meet
the
applicable
requirements;

·
Prepare
BACT
engineering
analysis;

·
Perform
air
quality
modeling;

·
Perform
preconstruction
air
quality
monitoring
(
if
not
already
available);

·
Determine
impacts
on
air
quality
related
values
in
Federal
Class
I
areas;

·
Prepare
a
DRAFT
permit
application;

·
Attend
public
hearing;

·
Revise
permit
application
per
comments
received
from
the
permit
reviewing
authority
and/
or
public
comments.

Typical
tasks
which
the
contractor
will
perform
in
the
conducting
compliance
tests
include:

·
Prepare
a
pretest
plan
and
submit
the
plan
to
the
appropriate
permit
reviewing
authority
for
review
and
approval
at
least
30
days
before
conducting
the
tests;

·
Clean
and
calibrate
test
equipment
for
tests;

·
Perform
tests;

·
Analyze
samples,
summarize
data,
and
write
report.
6
Based
on
an
telephone
conversation
with
Craig
Strommen,
Chief
Inspector
for
the
Santa
Barbara
Air
Pollution
Control
District.
7
Based
on
a
telephone
conversation
with
Marianne
Strange,
M.
Strange
and
Associates.

22
The
contractors
are
expected
to
bill
the
services
on
an
hourly
basis.

Generally,
development/
production
sources
are
required
to
monitor
process
parameters,
fuel
consumption,
exhaust
gas
flow
rates
and
sulfur
concentrations
in
the
gases.
6
When
the
OCS
rules
were
adopted,
the
existing
platforms
had
to
install
some
additional
gas
flow
and
sulfur
monitoring
equipment.
One
platform
reportedly
had
to
install
a
complex
monitoring
system,
which
cost
almost
$
100,000.
In
addition,
the
vessels
servicing
the
platforms
also
had
to
install
fuel­
monitoring
meters,
which
cost
between
$
30,000
and
$
50,000
each.
7
However,
in
most
cases
new
sources
under
EPA
authority
are
not
expected
to
have
to
install
additional
monitoring
equipment
beyond
that
which
is
required
by
the
MMS.
Even
if
the
new
sources
have
to
install
additional
monitoring
equipment,
the
cost
of
installing
that
equipment
on
new
facilities
would
be
less
than
the
cost
of
retrofitting
older
units
and
it
is
anticipated
that
the
service
vessels
would
be
servicing
more
that
one
platform.

The
capital
cost
for
the
monitoring
equipment
was
estimated
in
1998
to
be
$
25,000
per
development/
production
source.
The
Chemical
Engineering
Plant
Index
for
process
instruments
may
be
used
to
update
the
cost
to
2002
dollars.
However,
the
index
value
is
actually
smaller
in
2002
than
in
1998
indicating
a
lower
capital
cost
in
2002,
and
the
change
in
cost
is
smaller
than
the
uncertainty
in
the
estimate.
Therefore,
the
estimate
of
$
25,000
was
used
for
the
2002
capital
cost.

Exhibit
2
provides
a
breakdown
of
the
burden
and
cost
to
the
respondents
for
these
activities.
For
the
25
responses,
the
average
annual
burden
for
the
respondents
is
estimated
to
be
8,475
hours
and
$
542,105
plus
an
additional
$
6,341
in
O&
M
costs
and
$
125,000
in
capital
costs.

New
Exploration
Sources
Under
State/
Local
Authority
(
Exhibit
3)

The
four
new
exploration
sources
projected
for
the
southern
California
area
are
expected
to
be
located
within
25
miles
of
California's
boundary
and
under
the
regulatory
authority
of
the
local
districts.
These
sources
will
have
to
read
the
regulations,
prepare
NOIs
to
construct
and
ATC
permit
applications
to
comply
with
the
district
regulations.
In
addition,
the
sources
will
have
to
conduct
a
compliance
test
and
recordkeeping
and
reporting
tasks.
The
sources
will
be
subject
to
preconstruction
permit
requirements
for
nonattainment
and
attainment
pollutants
such
as
sections
3.
a
and
3.
b
of
SBCAPCD's
Rule
205,
respectively.
As
discussed
under
section
4(
b)
of
this
ICR,
section
3.
a
of
Rule
205
contains
the
requirements
for
complying
with
part
D
of
title
I,
and
section
3.
b
of
Rule
205
contains
the
requirements
for
complying
with
part
C
of
title
I
of
the
CAA.
Because
of
the
expertise
required
to
conduct
a
compliance
emission
test,
the
sources
will
most
likely
use
a
contractor
to
conduct
the
tests.
23
Typical
tasks
which
the
contractor
will
perform
in
conducting
compliance
tests
include:

·
Prepare
a
pretest
plan
and
submit
the
plan
to
the
appropriate
permit
reviewing
authority
for
review
and
approval
at
least
30
days
before
conducting
the
tests;

·
Clean
and
calibrate
test
equipment
for
tests;

·
Perform
tests;

·
Analyze
samples,
summarize
data,
and
write
report.

It
is
anticipated
that
the
exploration
sources
will
not
have
to
install
any
additional
monitoring
equipment
to
comply
with
the
regulatory
requirements.
Therefore,
there
will
be
no
capital
cost
for
these
sources.
Exhibit
3
provides
a
breakdown
of
the
burden
and
costs
for
these
activities.
The
average
annual
burden
for
the
respondents
is
estimated
to
be
1,344
hours
and
$
87,205
plus
$
840
in
O&
M
costs.
Since
the
exploration
vessels
are
expected
to
have
all
necessary
monitoring
equipment
to
meet
the
OCS
Air
Regulations,
no
capital
cost
is
projected
to
be
necessary.

Existing
Sources
Under
State/
Local
Authority
(
Exhibit
4)

The
existing
twenty­
one
development/
production
sources
off
the
southern
California
coast
are
located
within
25
miles
of
the
State's
seaward
boundary
and
EPA
has
delegated
to
the
local
districts
the
authority
to
implement
and
enforce
OCS
Air
Regulations
for
those
sources.
These
twenty­
one
existing
sources
are
expected
prepare
a
Title
V
operating
permit
renewal
application
once
during
the
3
year
period
covered
by
this
ICR,
perform
annual
compliance
tests,
and
conduct
recordkeeping
and
reporting
tasks.
Because
of
the
expertise
required
to
conduct
a
compliance
emission
test,
the
sources
will
most
likely
use
contractor
to
conduct
the
tests.

Typical
tasks
which
the
contractor
will
perform
in
the
conducting
compliance
tests
include:

·
Prepare
a
pretest
plan
and
submit
the
plan
to
the
appropriate
permit
reviewing
authority
for
review
and
approval
at
least
30
days
before
conducting
the
tests;

·
Clean
and
calibrate
test
equipment
for
tests;

·
Perform
tests;

·
Analyze
samples,
summarize
data,
and
write
report.
24
The
existing
development/
production
sources
have
already
installed
their
monitoring
equipment,
therefore
they
are
not
expected
to
incur
any
additional
capital
cost
for
new
monitoring
equipment.
Exhibit
4
provides
a
breakdown
of
the
burden
and
cost
to
the
respondents
for
these
activities.
The
average
annual
burden
for
the
respondents
is
estimated
to
be
20,259
hours
and
$
1,277,137
plus
$
15,289
in
O&
M
costs.

Total
Industry
Respondent
Burden
and
Costs
Exhibit
10
summarizes
the
industry
burden
for
the
OCS
Air
Regulations.
The
average
annual
industry
respondent
burden
for
the
period
March
1,
1999
through
February
28,
2002
is
estimated
to
be
30,174
hours
and
$
1,911,439
plus
$
22,793
for
O&
M
costs
and
$
125,000
for
capital
costs.
As
discussed
below,
the
total
respondent
burden
also
includes
the
burden
on
the
State
and
local
air
pollution
control
agencies
that
have
been
delegated
the
implementation
and
enforcement
authority
for
the
regulation.

6(
b)
ESTIMATING
STATE
AND
LOCAL
AIR
POLLUTION
CONTROL
AGENCY
BURDEN
AND
COSTS
This
section
presents
estimates
of
the
burden
to
State
and
local
agencies
associated
with
the
OCS
Air
Regulations.
The
burden
estimates
are
based
on
the
data
items
and
respondent
activities
described
in
section
4(
a)
of
this
ICR.

All
costs
are
presented
in
2002
dollars.
A
wage
rate
of
$
49
per
hour
was
used
to
calculate
cost
estimates
from
labor­
hour
estimates.
This
wage
rate
was
adjusted
from
the
previous
ICR
using
the
Employment
Cost
Index
for
civilian
workers
State
and
Local
Government(
See
appendix
A).
The
wage
rate
includes
direct
personnel
and
overhead
costs.

Prepare
Delegation
Requests
The
EPA
has
delegated
the
authority
to
implement
and
enforce
the
OCS
regulations
to
four
local
air
pollution
control
districts
in
California
(
SBCAPCD,
SCAQMD,
VCAPCD,
SLOCAPCD).
No
additional
delegation
requests
are
expected
during
the
period
May
1,
2002
to
April
30,
2005.

New
Exploration
Sources
Under
State/
Local
Authority
(
Exhibit
5)

The
MMS
projected
that
four
new
exploration
sources
would
locate
off
the
coast
of
Southern
California
during
the
3­
year
period
covered
by
this
ICR.
The
exact
location
of
the
exploration
sources
was
not
identified,
therefore
for
the
purposes
of
estimating
the
burden
it
was
assumed
that
they
would
locate
off
the
coast
of
Santa
Barbara
County.
The
districts
will
have
to
25
consult
with
the
sources
as
they
develop
their
applications,
review
the
NOI
to
construct,
review
the
operating
permit
applications,
oversee
the
initial
compliance
tests,
and
review
the
data
reports
submitted
by
the
sources.
Exhibit
5
provides
a
breakdown
of
the
burden
and
cost
to
the
local
air
pollution
control
district
for
implementing
and
enforcing
the
OCS
Air
Regulations
for
these
sources.
The
average
annual
burden
for
the
local
districts
is
estimated
to
be
276
hours
and
$
13,524.

Existing
Sources
Under
State/
Local
Authority
(
Exhibit
6)

The
twenty­
one
existing
development/
production
sources
located
within
25
miles
of
the
States
seaward
boundary
off
of
southern
California
and
are
under
the
authority
of
the
local
districts.
The
sources
are
generally
required
to
conduct
annual
compliance
tests
and
submit
data
reports
to
the
local
districts
In
addition,
the
local
district
conduct
quarterly
compliance
inspections
of
the
facilities.
It
is
assumed
that
these
sources
will
renew
their
PTO's
during
the
time
period
covered
by
this
ICR
to
comply
with
local
agency
regulations.
Exhibit
6
provides
a
breakdown
of
the
burden
and
cost
to
the
local
air
pollution
control
district
for
implementing
and
enforcing
the
OCS
Air
Regulations
for
these
sources.
The
average
annual
burden
for
the
local
districts
is
estimated
to
be
3,199
hours
and
$
156,751.

Total
State
and
Local
Agency
Burden
and
Costs
The
average
annual
State/
local
burden
to
implement
and
enforce
the
OCS
Air
Regulations
for
the
period
from
May
1,
2002
to
April
30,
2005
is
estimated
to
be
3,475
hours
and
$
170,275.

Total
Respondents
Burden
The
total
respondent
burden
includes
30,174
hours
and
$
1,911,439
plus
$
22,793
for
O&
M
costs
and
$
125,000
for
capital
costs
for
industry
and
3,475
hours
and
$
170,275
for
State
and
local
agencies
for
a
total
of
33,649
hours
and
$
2,081,714
plus
$
22,793
for
O&
M
costs
and
$
125,000
for
capital
costs.

6(
c)
ESTIMATING
THE
EPA
BURDEN
AND
COSTS
This
section
presents
estimates
of
the
burden
to
the
EPA
associated
with
the
OCS
regulations.
The
burden
estimates
are
based
on
the
data
items
and
respondent
activities
described
in
section
4(
a)
of
this
ICR.

All
costs
are
presented
in
2002
dollars.
A
wage
rate
of
$
43
per
hour
was
used
to
calculate
cost
estimates
from
labor­
hour
estimates.
This
wage
rate
was
adjusted
from
the
previous
ICR
using
the
percentage
increase
in
the
Federal
civilian
pay
schedule
from
1997
through
2001.
The
wage
rate
includes
direct
personnel
and
overhead
costs.
26
Review
Requests
for
Delegation
of
Authority
The
EPA
has
delegated
the
authority
to
implement
and
enforce
the
OCS
regulations
to
four
local
air
pollution
control
districts
in
California
(
SBCAPCD,
SCAQMD,
VCAPCD,
SLOCAPCD).
No
additional
delegation
requests
are
expected
during
the
period
May
1,
2002
to
April
30,
2005.
Therefore,
there
is
no
burden
associated
with
the
processing
of
delegation
requests
for
the
3­
year
time
period
covered
by
this
ICR.

New
Exploration
Sources
Under
EPA
Authority
(
Exhibit
7)

The
four
new
exploration
sources
which
will
be
under
the
regulatory
authority
of
the
EPA
will
be
required
to
prepare
and
submit
NOI
to
construct
before
they
begin
operation
and
submit
data
reports
to
EPA.
Exhibit
7
provides
a
breakdown
of
the
burden
and
cost
to
EPA
for
implementing
and
enforcing
the
OCS
Air
Regulations
for
these
sources
in
areas
where
EPA
has
not
delegated
its
authority
to
a
State
or
local
air
pollution
control
district.
The
average
annual
burden
for
the
local
districts
is
estimated
to
be
64
hours
and
$
2,752.

New
Development/
Production
Sources
Under
EPA
Authority
(
Exhibit
8)

The
fifteen
new
development/
production
sources
under
EPA's
authority
will
consult
with
EPA,
submit
NOIs
to
construct,
submit
a
PSD
application,
perform
a
compliance
test,
and
conduct
recordkeeping
and
reporting
tasks.
In
addition,
it
is
expected
that
half
of
those
sources
will
file
an
application
for
an
operating
permit
during
the
period
of
this
ICR.
Exhibit
8
provides
a
breakdown
of
the
burden
and
cost
to
EPA
for
implementing
and
enforcing
the
OCS
Air
Regulations
for
these
sources
in
areas
where
EPA
has
not
delegated
its
authority
to
a
State
or
local
air
pollution
control
district.
The
average
annual
burden
for
EPA
is
estimated
to
be
2,362
hours
and
$
127,853.

Consistency
Updates
of
OCS
Regulations
and
Overseeing
State/
Local
Activities
(
Exhibit
9)

The
EPA
routinely
reviews
the
onshore
regulations
for
the
areas,
which
have
potential
for
offshore
development,
and
updates
the
OCS
Air
Regulations
for
consistency.
Based
on
past
experience,
EPA
expects
that
consistency
updates
require
half
a
staff
member
each
year.
This
covers
the
three
States
where
EPA
has
not
delegated
its
authority
to
implement
and
enforce
its
regulations
and
four
local
districts
where
it
has.
Exhibit
9
provides
a
breakdown
of
the
cost
and
burden
to
EPA
to
implement
and
conduct
the
consistency
updates
and
to
oversee
the
regulatory
implementation
in
the
districts
where
the
authority
has
been
delegated.
The
average
annual
burden
for
EPA
is
estimated
to
be
1,210
hours
and
$
52,030.
27
Total
EPA
Burden
and
Costs
The
average
annual
EPA
burden
to
implement
and
enforce
the
OCS
Air
Regulations
for
the
period
from
May
1,
2002
through
April
30,
2005
is
estimated
to
be
3,636
hours
and
$
182,635.

6(
d)
REASONS
FOR
CHANGE
IN
BURDEN
The
burden
estimates
for
the
OCS
Air
Regulations
have
been
revised
due
to
three
main
factors:

·
Mineral
Management
Service
has
projected
a
significant
increase
in
the
number
of
Outer
Continental
Shelf
facilities
being
constructed
during
the
next
3
years
than
were
estimated
at
the
time
of
the
original
ICR.

·
The
estimated
time
for
the
consistency
updates
conducted
by
EPA
has
been
reduced
based
on
experience
of
conducting
the
updates.

·
The
estimates
have
been
calculated
and
arrayed
to
meet
the
guidelines
for
preparing
ICRs.
28
Table
1.
References
for
Burden
Activities
Associated
with
OCS
Air
Regulations
Applicable
Sections
of
OCS
Air
Regulations
Burden
Activities
55.4
Requirements
to
Submit
a
Notice
of
Intent
55.5
Corresponding
Onshore
Area
Designation
55.6
Permit
Requirements
55.8
Monitoring,
Reporting,
Inspections,
and
Compliance
55.9
Enforcement
55.11
Delegation
55.12
Consistency
Updates
55.13
Federal
Requirements
that
Apply
to
OCS
Sources
55.14
Federal,
State,
and
Local
Requirements
that
Apply
to
OCS
Sources
Located
Within
25
Miles
of
States'
Seaward
Boundaries,
by
State
29
Table
2
Respondent
Data
And
Information
Requirements
For
Preparing
PSD
Construction
Permits
Requirements
Current
Regulation
Reference
40
CFR
CAA
Reference
Description
of
the
nature,
location,
design
capacity,
and
typical
operating
schedule
51.166(
n)(
2)(
i)
[
52.21(
n)(
1)(
i)]
110(
a)(
2)(
A)

Detailed
schedule
for
construction
51.166(
n)(
2)(
ii)
[
52.21(
n)(
1)(
ii)]
110(
a)(
2)(
A)

Description
of
continuous
emission
reduction
system,
emission
estimates,
and
other
information
needed
to
determine
that
BACT
is
used
51.166(
n)(
2)(
iii)
[
52.21(
n)(
1)(
iii)]
165(
a)(
4)

Air
quality
impact,
meteorological,
and
topographical
data
51.166(
n)(
3)(
i)
[
52.21(
n)(
2)(
i)]
165(
a)(
3)

Nature
and
extent
of
general
commercial,
residential,
industrial,
and
other
growth
in
area
of
source
51.166(
n)(
3)(
ii)
[
52.21(
n)(
2)(
ii)]
165(
a)(
6)

Use
of
air
quality
models
to
demonstrate
compliance
with
NAAQS
51.166(
k)&(
l)
[
52.21(
k)&(
l)]
165(
a)(
3)&(
e)(
3)(
D)

Information
necessary
to
determine
adverse
impacts
on
any
air
quality
related
values
(
including
visibility)
for
Federal
Class
I
areas
51.166(
o)
[
52.21(
o)]
51.166(
p)(
4)
[
52.21(
p)(
5)]
165(
a)(
5)
165(
d)(
2)(
C)(
iii)&
(
iv)

Air
quality
monitoring
data
51.166(
m)(
1)(
b)
[
52.21(
m)(
1)(
b)]
165(
a)(
7)
110(
a)(
2)(
B)&(
F)

Impairment
of
visibility,
soils,
and
vegetation
51.166(
o)(
1)
[
52.21(
o)(
1)]
165(
e)(
3)

Air
quality
impact
resulting
from
general
commercial,
residential,
industrial,
and
other
growth
associated
with
source
51.166(
o)(
2)
[
52.21(
o)(
2)]
165(
e)(
3)

Written
notice
of
proposed
relocation
of
portable
source
51.166(
i)(
4)(
iii)(
d)
[
52.21(
i)(
4)(
viii)]
301
Description
of
the
location,
design
construction,
and
operation
of
building,
structure,
facility,
or
installation
51.160(
c)(
2)
110(
a)(
2)(
A)

Description
of
the
nature
and
amounts
of
emissions
to
be
emitted
51.160(
c)(
1)
110(
a)(
2)(
F)(
ii)

Description
of
the
air
quality
data
and
51.160(
f)
110(
a)(
2)(
B)&(
K)
Requirements
Current
Regulation
Reference
40
CFR
CAA
Reference
30
dispersion
or
other
air
quality
modeling
used
Sufficient
information
to
ensure
attainment
and
maintenance
of
NAAQS
51.160(
c)­(
e)
51.161
51.162
51.163
110(
a)(
2)(
A)
31
Table
3
Respondent
Data
and
Information
Requirements
for
Preparing
Part
D
Construction
Permits
Requirements
Regulation
Reference
40
CFR
CAA
Reference
Documentation
that
LAER
is
being
applied
51.165(
a)(
2)
173(
2)

Documentation
that
all
sources
owned
or
operated
by
same
person
are
in
compliance
51.165(
a)(
2)
173(
3)

Documentation
that
sufficient
emissions
reductions
are
occurring
to
ensure
reasonable
further
progress
(
RFP)
51.165(
a)(
2)
173(
1)

Documentation
that
benefits
of
proposed
source
significantly
outweigh
the
environmental
and
social
costs
imposed
as
a
result
of
its
location,
construction,
or
modification
­
­
­
173(
a)(
5)

Description
of
the
location,
design
construction,
and
operation
of
building,
structure,
facility,
or
installation
51.160(
c)(
2)
110(
a)(
2)(
A)

Description
of
the
nature
and
amounts
of
emissions
to
be
emitted
51.160(
c)(
1)
110(
a)(
2)(
F)(
ii)

Description
of
the
air
quality
data
and
dispersion
or
other
air
quality
modeling
used
51.160(
f)
110(
a)(
2)(
B)&(
K)

Sufficient
information
to
ensure
attainment
and
maintenance
of
NAAQS
51.160(
c)­(
e)
51.161
51.162
51.163
110(
a)(
2)(
A)
172(
c)(
6)
32
Table
4
Respondent
Data
for
ATC
Permits
Required
by
Rule
201
of
the
SBCAPCD's
Air
Pollution
Regulations
Paragraph
C.
4.
Information
Required
­
General
a.
A
schematic
of
the
basic
equipment
and
control
equipment
showing:
1)
Electric
motors
and
horsepower.
2)
Capacity
or
dimensions
of
any
storage
vessels.
3)
Manufacturer,
model,
and
Btu
rating
of
any
burners.
b.
Normal
operating
hours.
c.
Raw
material
usage.

C.
5.
Information
Required
­
Best
Available
Control
Technology
a.
Scaled
and
dimensioned
plot
plan
of
facility
that
shows
and
identifies
the
locations
of:
1)
Public
and
private
streets.
2)
Property
lines.
3)
Existing
and
proposed
buildings
(
indicate
their
heights).
4)
Adjacent
property
owners
and
uses.
5)
Storage
areas
for
fuel,
materials
and
products.
6)
Basic,
control
and
air
monitoring
equipment.
7)
Piping
and
ducts
for
carrying
fuels,
products
and
possible
sources
of
air
pollutants.
8)
Points
of
emissions.
b.
Detailed
schematic
of
basic
equipment
and
control
equipment
and
listing
of:
1)
Electric
motor­
driven
equipment
and
horsepower.
Also
list
equipment
driven
by
other
prime
movers
such
as
steam
or
heat
engines.
2)
Vessels
with
capacity
and
dimensions.
3)
Pumps
and
compressors.
Give
manufacturer,
model,
type
and
type
of
gland
seal
used.
4)
Burners,
manufacturer,
model,
Btu
rating,
mode
of
atomization,
mode
of
control
(
manual,
high­
low,
etc.),
firing
type
(
tangential,
opposed,
front,
etc.),
fuel
type
and
temperature
and
excess
air
used.
5)
Air
pollution
control
equipment
showing
manufacturer,
model
and
type.
Include
horsepower
or
any
prime
movers.
6)
Automatic
control
equipment
and
principal
instrumentation.
c.
Description
of
Operation
1)
Time
­
hours/
day,
days/
week,
days/
year.
State
season
or
time
when
plant
will
not
be
in
operation.
2)
Loads
­
Provide
tabulation
showing:
a)
Hourly
raw
material
usage,
fuel
usage,
electrical
usage,
rate
of
production,
rate
of
emission
of
pollutants
and
stack
gases
at
maximum
design
capacity
and
at
'
normal'
working
level.
b)
Estimated
annual
totals
in
tons/
year.
33
c)
Provide
particle
size
distribution
and
other
pertinent
physical
and
chemical
properties
of
emissions.
3)
Include
pressures,
temperatures
(
including
stack
temperatures)
and
sequences.
4)
For
burners,
provide
manufacturer
and
model
and
mention
excess
air,
fuel
preheating
and
atomization
mode,
type
of
fuel,
and
type
of
controls
used
to
ensure
efficient
combustion.
When
oil
tanks
are
used,
schematic
with
relief
valve
settings
and
vapor
pressure
at
storage
temperature.
5)
Describe
and
estimate
fugitive
emissions
incidental
to
the
plant
and
its
operation.

C.
6.
Information
Required
­
Air
Quality
Impact
Analysis
a.
Any
monitoring
stations
that
may
be
installed
by
applicant.
b.
Sufficient
data
to
perform
an
impact
analysis
from
all
emission
points
and
fugitive
emissions.
1)
Meteorological
data.
2)
Topographical
data.
3)
Air
quality
data.
4)
Computer
modeling
data,
including
assumptions
that
should
be
made.
c.
Identify
all
facilities
within
the
air
basin
that
are
owned
or
operated
by
the
applicant
and
the
compliance
status
of
each.
d.
Power
Consumption
of
Facility
1)
Total
amount
of
electrical
power
to
be
consumed
by
the
new
facility
or
the
increase
in
the
amount
of
electrical
power
to
be
consumed
due
to
the
modification.
2)
Percentage
of
electrical
power
provided
by
off­
site
generating
facilities;
identify
the
source
of
power.
e.
Cargo
Carriers
List
the
frequency
of
visits,
describe
types
and
sizes
of
all
cargo
carriers
(
other
than
motor
vehicles),
identify
nature
of
cargo,
and
conditions
under
which
the
cargo
is
transferred.
f.
If
applicant
is
applying
for
trade­
offs
from
other
existing
sources,
provide
sufficient
information
to
determine
whether
adequate
emission
reductions
will
be
achieved
to
offset
the
air
quality
impacts
of
the
applicant's
source
(
e.
g.,
name
and
location
of
trade­
off
sources
and
of
how
the
emission
trade­
offs
will
be
effected).
g.
List
proposed
mitigating
measures:
1)
Air
pollution
control
equipment
proposed.
2)
Process
changes
or
operations
utilized
to
reduce
emissions.
3)
Other.
h.
Identify
any
air
quality
impacts
from
the
following
precursor­
secondary
pollutant
relationships.
34
Precursors
Secondary
Pollutants
Hydrocarbons
and
substituted
hydrocarbons
(
reactive
organics)
a)
Photochemical
oxidant
(
ozone)
b)
The
organic
fraction
of
suspended
particulate
matter
gases)

Nitrogen
oxides
(
NO
x)
a)
Nitrogen
dioxide
(
NO
2)
b)
The
nitrate
fraction
of
suspended
particulate
matter
c)
Photochemical
accident
(
ozone)

Sulfur
oxides
(
SO
x)
a)
Sulfur
dioxide
(
SO
2)
b)
Sulfates
(
SO
4)
c)
The
sulfate
fraction
of
suspended
particulate
matter
"
Precursors"
means
a
directly­
emitted
pollutant
that,
when
released
to
the
atmosphere,
forms
or
causes
to
be
formed
or
contributes
to
the
formation
of
a
secondary
pollutant
for
which
an
ambient
air
quality
standard
has
been
adopted,
or
whose
presence
in
the
atmosphere
will
contribute
to
the
violation
of
one
or
more
ambient
air
quality
standards.
35
Appendix
i
Appendix
A
LABOR
RATES
*

Contractor
Rates
2002
Hourly
1998
1997­
2001
ECI
2002
$
69.00
$
60.00
1.16
$
69.48
Respondent
Rates
2002
Hourly
1998
1997­
2001
ECI
2002
$
52.00
$
45.00
1.16
$
52.11
State/
Local
Agency
Rates
2002
Hourly
1998
1997­
2001
ECI
2002
$
49.00
$
43.00
1.14
$
49.18
EPA
Rates
2002
Hourly
1998
1997­
2001
ECI
2002
$
43.00
$
37.00
1.17
$
43.42
*
The
contractor,
respondent,
and
state/
local
agency
labor
rates
used
in
the
1998
ICR
were
updated
based
upon
the
Bureau
of
Labor
Statistics'
Employment
Cost
Index
(
ECI).
The
ECI
is
an
economic
indicator
which
measures
changes
in
compensation
costs.

The
EPA
labor
rates
were
updated
based
upon
the
US
Office
of
Personnel
Management's
Federal
Pay
Scale.

Page
A­
3
shows
the
value
of
the
indexes
that
were
used
in
this
analysis.
ii
A
ppendix
A
(
Continued)

Indexes
for
Updating
Labor
R
ates
SOURCE:
Bureau
of
Labor
S
tatistics
1
Employment
C
ost
Index
­­
C
ivilian
W
orkers
E
xcluding
S
ales
June
1989
=
100
Dec.
1997
135.4
Dec.
2001
156.8
21.4
15.81%
Incr
1997­
2001
1.16
Employment
C
ost
Index
­­
C
ivilian
W
orkers
S
tate
and
Local
Government
June
1989
Dec.
1997
135.7
Dec.
2001
155.2
19.5
14.37%
Incr
1997­
2001
1.14
SOURCE:
U
S
Office
o
f
Personnel
M
anagement
2
Federal
P
ay
Scale
­
GS
11
S
tep
5
1998
$
43,738.00
2002
$
51,322.00
7584
17.34%
Incr
1997­
2001
1.17
1.
http
://
www.
bls.
gov/
ncs/
ect/

3.
http
://
www.
opm.
gov/
oca/
02tables/
RUS.
htm
iii
Appendix
A
Universe
of
Respondents
Universe
Estimates
Sources
under
EPA
authority
#
New
exploration
sources
4
#
New
development/
production
sources
15
#
Existing
sources
0
Sources
under
State/
local
authority
#
New
exploration
sources
4
#
New
development/
production
sources
3
#
Existing
sources
21
#
Construction
mod
to
existing
sources
2
Total
Number
of
Sources
49
