STANDARD
FORM
83­
I
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
No.
1788.07
INFORMATION
COLLECTION
REQUEST
FOR
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS:
OIL
AND
NATURAL
GAS
PRODUCTION
FACILITIES
(
Proposed
Rule)

U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
May
30,
2005
2
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
a.
Title
and
Number
of
the
Information
Collection
"
Recordkeeping
and
Reporting
Requirements
for
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP):
Oil
and
Natural
Gas
Production
Facilities
(
Propsed
Rule),"

EPA
ICR
No.
1788.07.

b.
Short
Characterization
This
ICR
is
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
rulemaking
developed
under
authority
of
section
112
of
the
Clean
Air
Act
(
CAA).
The
proposed
rulemaking
would
amend
title
40,
chapter
I,
part
63,
subpart
HH
 
National
Emission
Standards
for
Hazardous
Air
Pollutants
from
Oil
and
Natural
Gas
Production
Facilities
 
of
the
Code
of
Federal
Regulations
(
CFR)
.
Hereafter,
this
subpart
is
referred
to
as
the
"
Oil
and
Natural
Gas
Production
NESHAP".
The
current
Oil
and
Natural
Gas
Production
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAP),
while
the
proposed
amendments
would
add
standards
for
area
sources.
A
major
source
of
HAP
is
one
that
has
the
potential
to
emit,
considering
controls
(
in
place
under
a
federally
enforceable
agreement),
10
tons
or
more
of
any
one
HAP
or
25
tons
or
more
of
total
HAPs
per
year;
an
area
source
is
one
with
a
potential
to
emit
less
than
this.
Respondents
are
owners
or
operators
of
processes
and
operations
in
the
oil
and
natural
gas
production
source
category.
All
existing
area
sources
would
have
to
be
in
compliance
with
the
requirements
of
the
revised
rule
by
three
years
after
the
effective
date
of
the
amended
final
rule.

No
new
area
sources
are
anticipated
within
the
first
three
years
after
the
effective
date
of
the
amended
final
rule.

This
ICR
is
for
area
sources
of
HAP
emission
in
the
oil
and
natural
gas
production
source
category.
Of
the
total
estimated
population
of
120,000
facilities
(
not
including
oil
and
natural
gas
production
wells)
in
the
source
category,
it
is
estimated
that
approximately
2,222
existing
area
sources
will
be
subject
to
the
provisions
of
the
Oil
and
Natural
Gas
Production
NESHAP.
No
new
area
sources
will
be
subject
to
the
provisions
of
this
NESHAP
within
the
first
three
years
following
the
effective
date
of
the
amended
final
rule.

The
period
considered
in
this
ICR
and
throughout
this
supporting
statement
is
the
first
three
years
following
promulgation
of
the
amended
Oil
and
Natural
Gas
Production
NESHAP.
3
The
total
monitoring,
inspecting,
reporting,
and
recordkeeping
(
MIRR)
costs
for
existing
sources
during
the
first
three
years
after
promulgation
are
estimated
to
be
$
53
million.
Of
the
estimated
total
MIRR
costs,
$
49.7
million
is
labor
dollars
for
the
first
three
years
and
$
3.5
million
is
capital
and
operation
and
maintenance
(
O&
M)
for
the
first
three
years.
The
annual
costs
for
each
of
the
first
three
years
after
promulgation
are
not
expected
to
be
equal
and
are
expected
to
differ
from
costs
in
subsequent
years,
because
existing
area
sources
will
likely
phase
in
their
compliance
activities
prior
to
the
compliance
date,
which
is
three
years
after
the
promulgation
date.
See
section
6
for
more
details
on
cost
estimates.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
a.
Need/
Authority
for
the
Collection
Section
112
of
the
CAA
requires
the
EPA
to
establish
standards
to
limit
emissions
of
HAP
from
stationary
sources.
The
HAP
emission
points
in
the
oil
and
natural
gas
production
source
category
that
may
be
subject
to
the
rule
can
potentially
emit
10
or
more
of
the
188
HAP
listed
in
section
112
of
the
CAA.

Section
114
of
the
CAA
gives
the
EPA
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to:
(
1)
identify
existing
sources
subject
to
the
Oil
and
Natural
Gas
Production
NESHAP
and
(
2)
ensure
that
the
Oil
and
Natural
Gas
Production
NESHAP
are
being
achieved.

b.
Use/
Users
of
the
Data
The
information
will
be
used
by
the
EPA's
enforcement
personnel
to:
(
1)
identify
existing
area
source
HAP
emission
points
subject
to
the
Oil
and
Natural
Gas
Production
NESHAP,

(
2)
identify
the
emission
control
devices
and
control
methodologies
being
applied,
and
(
3)
ensure
that
the
emission
control
devices
and
control
methodologies
are
being
properly
operated
and
maintained
on
a
continuous
basis.

In
addition,
records
and
reports
are
necessary
to
enable
the
EPA
to
identify
the
facilities
that
may
not
be
in
compliance
with
the
Oil
and
Natural
Gas
Production
NESHAP.
Based
on
the
reported
information,
the
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
indicates
to
the
EPA
whether
facility
personnel
are
operating
and
maintaining
emission
control
devices
and
control
methodologies
properly.
4
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
a.
Nonduplication
A
search
of
the
EPA's
existing
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts.
However,
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
Oil
and
Natural
Gas
Production
NESHAP.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
Oil
and
Natural
Gas
Production
NESHAP.

b.
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Because
this
is
a
rule­
related
ICR,
it
is
not
necessary
to
solicit
public
comments
prior
to
submittal
of
this
ICR
to
OMB.
However,
a
60­
day
public
comment
period
will
be
provided
after
proposal
of
the
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP
in
the
Federal
Register,
during
which
all
affected
parties
will
be
given
the
opportunity
to
comment
on
the
proposed
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP.
All
comments
that
are
received
will
be
considered
and
some
changes
in
response
to
the
comments
may
be
reflected
in
the
final
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP.

c.
Consultations
Consultations
with
numerous
representatives
of
companies
involved
in
oil
and
natural
gas
production
and
industry
trade
associations
were
conducted
throughout
the
development
of
the
original
proposal
of
the
Oil
and
Natural
Gas
Production
NESHAP,
which
includes
proposed
standards
for
area
sources
that
were
removed
before
promulgation
of
the
rule.
EPA
ICR
#
1788.01
includes
a
list
of
people
consulted
during
the
original
rule
development.
During
preparation
of
the
proposed
amendments,
which
would
re­
insert
the
standards
for
area
sources,

EPA
consulted
with
Jean
Terry
at
the
Colorado
Department
of
Public
Health
and
the
Environment
(
phone:
303­
692­
3255).

d.
Effects
of
Less
Frequent
Collection
If
the
relevant
information
were
collected
less
frequently,
the
EPA
would
not
be
reasonably
assured
that
a
source
is
in
compliance
with
the
Oil
and
Natural
Gas
Production
NESHAP.
In
addition,
the
EPA's
authority
to
take
administrative
action
would
be
reduced
significantly.

Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
5
administrative
proceedings
are
less
costly
and
require
use
of
fewer
resources
than
judicial
proceedings,
both
the
EPA
and
the
regulated
community
benefit
from
preservation
of
the
EPA's
administrative
powers.

e.
General
Guidelines
The
Oil
and
Natural
Gas
Production
NESHAP
requires
that
facility
owners
or
operators
retain
records
for
a
period
of
five
years,
which
exceeds
the
three
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
five
year
retention
period
is
consistent
with
the
provisions
of
the
General
Provisions
of
40
CFR
part
63,
and
with
the
five
year
records
retention
requirement
in
the
operating
permit
program
under
title
V
of
the
CAA.
All
subsequent
guidelines
have
been
followed
and
do
not
violate
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.6.

f.
Confidentiality
All
information
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
EPA
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
3999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.
Even
where
the
EPA
has
determined
that
data
received
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
part
2,
subpart
B,
the
EPA
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"
under
the
statute
[
42
U.
S.
C.
§
7414
(
C);
40
CFR
2.301
(
g)].
The
information
collection
complies
with
the
Privacy
Act
of
1974
and
Office
of
Management
and
Budget
(
OMB)
Circular
108.

g.
Sensitive
Questions
Information
to
be
reported
consists
of
emission
data
and
other
information
that
are
not
of
a
sensitive
nature.
No
sensitive
personal
or
proprietary
data
are
being
collected.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
a.
Respondents/
SIC
and
NAICS
Codes
Respondents
are
owners
or
operators
of
HAP­
emitting
processes
and
operations
that
are
used
in
the
various
segments
of
the
oil
and
natural
gas
production
source
category.
The
processes
and
operations
that
are
likely
to
be
subject
to
the
Oil
and
Natural
Gas
Production
NESHAP
are
classified
in
the
four­
digit
Standard
Industrial
Classification
(
SIC)
Codes
1311
for
"
Crude
Petroleum
and
Natural
Gas"
and
1321
for
"
Natural
Gas
Liquids."
The
corresponding
6
North
American
Industrial
Classification
System
(
NAICS)
codes
are
211111
and
211112.

However,
not
all
processes
classified
in
these
SIC
and
NAICS
codes
are
regulated
by
the
Oil
and
Natural
Gas
Production
NESHAP.

b.
Information
Requested
The
standards
are
based
on
add­
on
control
devices
and
pollution
prevention
measures
to
reduce
HAP
emissions.
In
order
to
demonstrate
continuous
compliance
with
the
standards,

facilities
must
use
continuous
parameter
monitoring
systems
(
CPMS).

i.
Data
items,
including
recordkeeping
requirements
The
Oil
and
Natural
Gas
Production
NESHAP
requires
the
owner
or
operator
of
each
area
source
to
submit
certain
reports
and
maintain
certain
records
as
specified
in
the
NESHAP,

and
in
the
General
Provisions
(
40
CFR
63
subpart
A).
These
activities
are
listed
in
Attachment
1.

All
reports
must
be
submitted
to
the
respondent's
State
agency,
if
it
has
an
approved
title
V
permit
program
implementation
authority,
or
to
the
appropriate
EPA
Regional
Office.
Records
must
be
retained
for
5
years
and
must
be
maintained
on­
site,
or
readily
accessible
from
on­
site
through
a
computer
or
other
means,
for
at
least
12
months
after
the
date
of
each
occurrence,
measurement,

maintenance,
corrective
action,
report,
or
record.
Records
may
be
kept
offsite
for
the
remaining
four
years
but
must
be
made
readily
available
upon
request.

ii.
Respondent
Activities
The
activities
that
would
be
performed
by
respondents
to
meet
the
MIRR
requirements
of
the
Oil
and
Natural
Gas
Production
NESHAP
for
each
of
the
first
three
years
following
promulgation
of
the
proposed
amendments
are
presented
in
Tables
1a
through
1c
for
existing
area
sources.
The
respondent
activities
are
also
listed
in
Attachment
1.

This
ICR
assumes
that
existing
area
sources
each
have
one
condenser
controlling
emissions
from
glycol
dehydration
units.
For
existing
area
sources,
this
ICR
assumes
that
all
sources
will
read
the
rule
and
submit
the
initial
notification
in
the
first
year.
In
each
of
the
second
and
third
years,
this
ICR
assumes
that
half
of
the
existing
area
sources
will
install
monitoring
equipment,
conduct
performance
tests
or
design
analyses,
and
complete
other
reporting
and
recordkeeping
activities.
It
is
assumed
that
10
percent
of
all
sources
will
conduct
performance
tests,
while
the
remaining
sources
will
opt
to
conduct
design
analyses
instead.
It
is
estimated
that
10
percent
of
the
responses
to
this
ICR
can
be
collected
electronically.
7
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
a.
Agency
Activities
A
list
of
the
EPA's
activities
for
each
of
the
first
three
years
after
promulgation
is
provided
in
Tables
3a
through
3c,
which
are
introduced
in
section
6(
c).
Table
4
summarizes
the
EPA's
estimated
labor
hours
and
cost
over
the
first
three
years
after
promulgation.
The
Agency's
activities
conducted
in
connection
with
the
acquisition,
analysis,
storage,
and
distributed
of
the
required
information
include:
(
1)
observing
performance
tests,
(
2)
reviewing
notifications
and
reports
required
to
be
submitted
by
industry,
(
3)
conducting
on­
site
inspections
as
necessary,

(
4)
inputing,
analyzing,
and
maintaining
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
database,
(
5)
auditing
facility
records,
and
(
6)
conducting
enforcement
actions.

b.
Collection
Methodology
and
Management
Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Data
obtained
during
periodic
visits
by
EPA
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.

c.
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
the
EPA's
part.
The
EPA
has
included
provisions
for
size
and
emissions
cutoffs
that
reduce
the
number
of
smaller
sources
from
being
subject
to
the
NESHAP.
The
EPA
has
reduced
the
recordkeeping
and
reporting
requirements
to
include
only
the
information
needed
by
the
EPA
to
determine
compliance
with
the
Oil
and
Natural
Gas
Production
NESHAP.

The
burden
to
respondents
has
been
minimized
by
requiring
the
collection
and
reporting
of
information
which
is
clearly
essential
to
ensure
that
sources
comply
with
the
Oil
and
Natural
Gas
Production
NESHAP.

By
definition,
a
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field
as
defined
by
the
Small
Business
Administration
(
SBA)
regulations
under
Section
3
of
the
Small
Business
Act.
For
the
purpose
of
assessing
the
impacts
of
the
proposed
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP
on
small
entities,
a
small
8
entity
is
defined
based
on
definitions
provided
by
the
SBA.
The
results
of
a
screening
analysis
showed
that
none
of
the
small
businesses
that
would
be
subject
to
the
Oil
and
Natural
Gas
Production
NESHAP
are
expected
to
have
compliance
costs
of
1
percent
or
more.
Therefore,
the
final
rule
will
not
have
a
significant
impact
on
a
substantial
number
of
small
entities,
and
small
business
considerations
do
not
apply.

d.
Collection
Schedule
The
Oil
and
Natural
Gas
Production
NESHAP
amendments
will
be
proposed
in
the
Federal
Register
and
then
promulgated
after
consideration
of
all
comments
received
after
proposal.
Collection
of
data
will
begin
after
promulgation
of
the
standards.
The
schedule
for
reports
that
would
be
required
by
the
amended
Oil
and
Natural
Gas
Production
NESHAP
and
the
General
Provisions
is
detailed
below.

The
initial
notification
would
be
due
one
year
after
the
promulgation
date
of
the
amendments
for
existing
area
sources.
The
notification
of
intent
to
conduct
a
performance
test
must
be
submitted
at
least
60
days
before
a
performance
test
is
scheduled
to
begin.
The
notification
of
compliance
status
is
to
be
submitted
180
days
following
the
compliance
date
of
the
regulation.

Area
sources
are
required
to
submit
periodic
reports
on
an
annual
basis,
no
later
than
30
days
after
the
end
of
each
one­
year
reporting
period.
The
first
periodic
report
for
existing
area
sources
would
be
due
on
January
1
after
the
compliance
date.
Area
sources
must
report
actions
taken
during
startup,
shutdown,
and
malfunction
(
SSM)
events
not
consistent
with
the
SSM
plan
within
two
working
days
and
submit
a
letter
within
seven
working
days
after
the
end
of
the
event.

6.
ESTIMATING
BURDEN
AND
COST
OF
THE
COLLECTION
a.
Estimating
Respondent
Burden
The
annual
burden
for
respondent
activities
includes
labor
cost,
capital/
startup
cost,
and
O&
M
cost.
EPA's
estimates
of
total
burden
for
respondents
for
each
of
the
first
three
years
after
promulgation
of
the
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP
are
presented
in
Tables
1a
through
1c.

b.
Estimating
Respondent
Costs
i.
Estimating
labor
costs
The
estimates
of
total
technical
labor
hours
per
year
per
source
and
the
number
of
activities
per
respondent
per
year
listed
in
each
of
Tables
1a
through
1c
are
based
upon
1
Memorandum.
Akin,
T.
and
Viconovic,
G.,
EC/
R
Incorporated,
to
Docket
No.
A­
94­
04.
Tabular
Cost
Estimates
of
Control
Options
for
the
Oil
and
Natural
Gas
Production
Industry.
January
31,
1995.

2http://
www.
che.
com/
ei
9
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts
and
the
number
of
emission
points
in
each
source.
Activities
that
are
one­
time­
only
activities
are
identified
as
such
in
the
tables.

The
estimated
costs
of
the
activities
listed
in
Tables
1a
through
1c
were
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics'
(
BLS)
Internet
web
site
(
http://
www.
bls.
gov/
ncs/
ect/
home.
htm),
Table
9
of
Employer
Costs
for
Employee
Compensation
(
September
2004),
accessed
February
17,
2005.
Labor
costs
were
divided
into
the
following
three
categories:
(
1)
technical,
(
2)
managerial,
and
(
3)
clerical.
Managerial
and
clerical
labor
hours
were
calculated
as
5
and
10
percent,
respectively,
of
each
technical
labor
hour
requirement.

In
addition,
the
labor
rates
were
increased
by
110
percent
to
account
for
overhead
costs.

Therefore,
the
labor
costs
were
estimated
to
be
$
97.55
per
hour
($
97.55/
hr)
for
managerial
($
37.99
+
110
percent),
$
79.78/
hr
for
technical
($
46.45
+
110
percent),
and
$
41.18/
hr
for
clerical
($
19.61
+
110
percent).
These
estimates
include
fringe
benefits.

ii.
Estimating
capital
and
operation
and
maintenance
costs
Area
source
oil
and
natural
gas
production
facilities
subject
to
standards
under
the
Oil
and
Natural
Gas
Production
NESHAP
would
incur
capital
costs
associated
with
monitoring
equipment
that
these
sources
must
use
to
demonstrate
continuous
compliance
and
meet
reporting
and
recordkeeping
requirements.
For
the
purpose
of
assessing
the
impacts
of
the
proposed
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP,
one
CMS
is
assumed
to
be
used
on
each
condenser.
The
total
installed
capital
cost
of
the
CMS
is
estimated
at
$
1,139
for
area
sources.
These
costs
were
escalated
from
July
1993
dollar
estimates
included
in
rulemaking
background
materials1
to
April
2004
dollars
using
the
most
recent
Chemical
Engineering
Plant
Cost
Index2
available.
The
cost
of
add­
on
control
equipment
is
not
included
in
this
ICR
because
it
is
not
purchased
for
the
purpose
of
satisfying
the
reporting
and
recordkeeping
requirements.
See
Table
2
for
capital
cost
information.

The
total
annual
estimated
O&
M
costs
in
Box
14
of
OMB
83­
I
were
calculated
based
on
(
1)
operation
and
maintenance
costs
for
monitoring
equipment,
(
2)
the
estimated
postage
costs
for
responses
(
see
Box
13
on
OMB
83­
I)
associated
with
the
provisions
of
the
Oil
and
Natural
10
Gas
Production
NESHAP,
and
(
3)
contracting
costs
for
the
performance
test
that
some
sources
would
use
to
demonstrate
compliance
with
this
standard.
The
annual
O&
M
cost
for
operating
the
monitoring
equipment
is
estimated
at
10
percent
of
the
total
capital
cost,
or
$
114
for
CMS
for
area
sources.
Postage
costs
are
for
submittal
to
regulatory
agencies
of
notifications
and
reports
required
by
the
rule.
The
postage
rates
($
3.85
per
one­
pound
package
by
Priority
Mail
and
$
0.37
per
one­
ounce
First
Class
letter)
were
based
on
data
from
the
U.
S.
Postal
Service
Internet
website
(
http://
www.
usps.
com),
accessed
February
21,
2005.
The
per­
facility
cost
of
performance
test
contracting
is
estimated,
based
on
information
provided
by
test
contractors,
to
be
$
12,000
for
area
sources.
See
Table
2
for
O&
M
cost
information.

iii.
Annualizing
capital
costs
The
total
installed
capital
costs
of
the
monitoring
equipment
were
multiplied
by
a
capital
recovery
factor
(
CRF)
of
0.1098,
using
an
interest
rate
of
seven
percent
and
an
estimated
equipment
life
of
15
years,
to
calculate
the
annualized
capital
cost.
The
annualized
capital
costs
is
$
125
for
CMS
for
area
sources.

c.
Estimating
the
EPA's
Burden
and
Cost
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
Oil
and
Natural
Gas
Production
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
recordkeeping
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
operated
and
maintained
by
the
EPA's
OAQPS,
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
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.

The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
analyzing
the
reported
information,
observing
performance
tests
(
it
is
assumed
that
EPA
will
observe
10
percent
of
the
performance
tests
conducted),
conducting
inspections,
and
conducting
enforcement
actions,
as
presented
in
Tables
3a
through
3c
for
existing
area
sources.
Labor
rates
and
associated
costs
are
based
on
the
2005
General
Schedule
(
GS)
base
salary
data
from
the
U.
S.

Office
of
Personnel
Management
Internet
website
(
http://
www.
opm.
gov/
oca/
05tables/
pdf/
gs_
h.
pdf),
accessed
February
21,
2005.
We
estimated
11
hourly
labor
costs
of
$
56.02/
hr
(
GS­
13,
Step
5;
$
35.01
x
1.6)
for
management,
$
41.57/
hr
(
GS­

12,
Step
3;
$
25.98
x
1.6)
for
technical,
and
$
22.50/
hr
(
GS­
6,
Step
3;
$
14.06
x
1.6)
for
administrative.
Labor
rates
include
an
additional
60
percent
for
overhead
expenses,
the
standard
government
benefits
multiplication
factor.
The
federal
burden
and
cost
are
summarized
in
Table
4.

d.
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
To
calculate
the
total
burden
for
respondents,
the
number
of
respondents
(
the
respondent
universe)
to
complete
each
activity
was
estimated.
The
burden
for
each
activity
was
calculated
by
multiplying
the
per­
respondent
burden
per
activity
by
the
number
of
respondents.

The
respondent
universe
varies
among
the
activities
listed
in
Tables
1a
through
1c,

because
not
all
respondents
must
complete
each
activity
each
year.
The
total
burden
and
costs
are
summarized
in
Table
2.

e.
Bottom
Line
Burden
Hours
and
Costs
i.
Respondent
tally
The
bottom
line
respondent
burden
hours
and
costs
are
summarized
in
Table
2.
The
estimated
total
nationwide
burden
in
the
first
three
years
after
promulgation
of
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP
are
an
estimated
653,518
total
labor
hours
and
$
49.7
million
for
existing
area
sources.
The
total
estimated
annual
labor
hour
reporting
and
recordkeeping
burden
for
the
first
three
years
is
217,839
labor
hours.

The
total
estimated
annualized
capital
costs
and
annual
O&
M
costs
to
comply
with
the
standards
were
estimated
to
be
$
1.2
million
for
existing
area
sources.
Table
2
includes
summarized
annualized
capital
costs
and
annual
O&
M
costs.
The
total
annualized
capital
costs
reflect
the
estimated
capital
costs
of
equipment
to
comply
with
the
MIRR
activities
associated
with
the
standards.
The
total
annual
O&
M
costs
reflect
costs
that
are
associated
with
the
MIRR
equipment
but
that
are
not
included
in
the
labor
hour
burden
estimate.

The
total
capital
and
O&
M
costs
for
the
first
three
years
after
promulgation
of
the
amendments
are
estimated
to
be
$
3.5
million
for
existing
area
sources.

ii.
The
EPA
tally
The
bottom
line
Federal
government
burden
hours
and
costs
that
would
result
from
this
ICR
in
the
first
three
years
after
promulgation
of
the
amendments
to
the
Oil
and
Natural
Gas
Production
NESHAP
are
presented
in
Tables
3a
through
3c.
Estimated
hours
and
costs
in
the
12
first
three
years
after
promulgation
are
26,059
total
labor
hours
and
$
1.1
million
for
existing
area
sources.
Table
4
summarizes
the
Federal
government
burden
hours
and
costs
for
the
Oil
and
Natural
Gas
Production
NESHAP
over
the
first
three
years
after
promulgation
of
the
amendments.

iii.
Variations
in
the
annual
bottom
line
Variation
in
the
annual
bottom
line
for
this
regulation
may
occur
over
the
first
three
years
following
promulgation
of
the
amendments
to
this
rule
because:
(
1)
certain
one­
time
activities
would
typically
occur
prior
to
the
source's
compliance
date
and
(
2)
it
is
not
until
the
end
of
the
third
year
following
promulgation
that
all
sources
must
be
in
compliance
and
will
be
subject
to
recurring
recordkeeping
and
reporting
requirements.

f.
Reasons
for
Change
in
Burden
This
proposed
rule
would
add
standards
for
area
sources.

g.
Burden
Statement
The
respondent
universe
consists
of
2,222
facilities.
The
total
burden
hours
and
costs
for
this
collection
are
presented
in
Table
2.

The
total
three­
year
monitoring,
reporting,
and
recordkeeping
burden
for
this
collection
is
estimated
at
653,518
labor
hours,
and
the
annual
average
burden
is
217,839
labor
hours.
The
annualized
capital
cost
for
monitoring
equipment
is
estimated
to
be
$
188
per
facility.
Annual
O&
M
costs
are
estimated
to
be
$
3.1
million
existing
area
sources
over
three
years,
averaging
$
1.0
million
per
year.
The
hour
burden
estimate
includes
time
to
read
the
rule,
write
and
submit
required
notifications
and
reports,
perform
recordkeeping
activities,
perform
performance
tests
and
design
analyses,
develop
plans
for
implementing
recordkeeping
requirements,
develop
record
systems,
train
personnel,
and
store,
file
and
retrieve
records.
The
cost
burden
estimate
includes
the
cost
of
labor
hours,
purchase
of
capital
equipment
necessary
to
generate
and
record
data
needed
to
meet
the
MIRR
requirements
of
the
rule,
postage
to
submit
notifications
and
reports,

and
performance
test
contractor
costs.

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
purpose
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
13
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
respond
to
a
collection
of
information;
search
existing
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
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,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2004­
0238,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,

1301
Constitution
Avenue,
NW,
Washington
DC.
The
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
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
and
Information
Center
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.

Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.

Please
include
the
EPA
Docket
ID
No.
(
OAR­
2004­
0238
and
OMB
control
number
(
2060­
0417)

in
any
correspondence.
14
PART
B
OF
THE
SUPPORTING
STATEMENT
Not
applicable.
No
sampling
or
other
methods
are
used
to
select
respondents
because
all
owners
and
operators
of
facilities
subject
to
the
Oil
and
Natural
Gas
Production
NESHAP
are
required
to
collect
information.
1­
1
Attachment
1
Source
Data
and
Information
Requirements
Table
1­
1.
Reporting
Requirements.

Reporting
Requirement
40
CFR
Part
63
Due
Date
Major
Sources
Area
Sources
Initial
notificationa
§
63.775(
b)(
1)
§
63.775(
c)(
1)
1
year
after
effective
date
Notification
of
intent
to
construct/
reconstructb
63.5(
d);
63.9(
b)(
4)
63.9(
b)(
5)
As
soon
as
practicable
before
construction
begins
Notification
of
actual
startup
dateb
63.9(
b)(
4)
63.9(
b)(
5)
15
days
after
startup
Notification
of
date
of
CMS
performance
evaluation
63.775(
b)(
2)
63.775(
c)(
2)
60
days
before
evaluation
(
or
with
initial
notif.)

Notification
of
intent
to
conduct
a
performance
test
63.775(
b)(
3)
63.775(
c)(
3)
60
days
before
test
(
or
with
initial
notification)

Notification
of
compliance
status
63.775(
b)(
4)
63.775(
c)(
4)
180
days
after
compliance
date
Periodic
reports
63.775(
b)(
5)
63.775(
c)(
5)
Major
sources:
1st
report:
240
days
after
NOCS
is
due
Subsequent
reports:
60
days
after
end
of
6­
month
reporting
period
Area
sources:
1st
report:
January
1
after
the
compliance
date
Subsequent
reports:
60
days
after
end
of
6­
month
reporting
period
Startup,
shutdown
and
malfunction
reports
63.775(
b)(
6)
63.775(
c)(
6)
Within
2
working
days
after
commencing
actions
not
consistent
with
the
SSM
plan,
followed
by
a
letter
within
7
days.

a
Applies
to
existing
sources
only.
b
Applies
to
new
and
reconstructed
sources
only.
c
Only
applies
if
actions
taken
during
startup,
shutdown,
or
malfunction
are
not
consistent
with
the
startup,
shutdown
or
malfunction
plan.
1­
2
Table
1­
2.
Recordkeeping
Requirements.

Recordkeeping
Requirement
40
CFR
Part
63
5­
year
retention
of
records
§
63.774(
b)(
1)

Copies
of
notifications
and
reports
and
supporting
documentation
63.10(
b)(
2)(
xiv)

Records
of
performance
tests,
other
compliance
demonstrations,
and
performance
evaluations
63.10(
b)(
2)(
vii)­
(
ix)

Records
relating
to
control
equipment
inspections
63.773(
c)(
7);
63.774(
b)(
5)­(
8)

Records
related
to
CMS
63.774(
b)(
3)­(
4);
63.10(
b)(
2)(
vi),
(
x),
and
(
xi);
63.10(
c)

Records
required
if
complying
via
process
modification
63.771(
e);
63.774(
b)(
10)­(
11)

Records
required
if
complying
via
benzene
emission
limit
63.774(
c)

Records
related
to
equipment
that
is
exempt
or
subject
to
other
standards
63.764(
e),
63.774(
b)(
9),
63.774(
d)
1­
3
Table
1­
3.
Respondent
Activities.

Respondent
Activities
40
CFR
Part
63
Read
instructions
Gather
relevant
information
Write
the
notifications
and
reports
listed
in
Table
1­
1
above
Develop
a
startup,
shutdown,
and
malfunction
plan
§
63.762(
d)

Conduct
a
performance
test
or
design
analysis
for
each
control
devicea
§
63.772(
e)

Conduct
control
equipment
inspections
(
annually)
63.773(
c);
63.772(
c)

Conduct
control
equipment
leak
monitoring
(
whenever
a
component
is
repaired,
replaced,
unsealed)
and
repair
63.773(
c)

Develop,
acquire,
install,
and
utilize
CMS
for
the
purpose
of
collecting,
validating,
and
verifying
information
for
control
devices
63.773(
d)

Develop,
acquire,
install,
and
utilize
technology
for
the
purpose
of
processing,
maintaining,
disclosing,
and
providing
information
(
record
systems)

Record
the
information
listed
in
Table
1­
2
above
Train
personnel
to
be
able
to
respond
to
a
collection
of
information
Transmit
or
otherwise
disclose
information
a
One­
time
activities.
