1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP:
OIL
AND
NATURAL
GAS
PRODUCTION
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP:
Oil
and
Natural
Gas
Production
(
40
CFR
Part
63,
Subpart
HH)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
for
the
regulations
published
at
40
CFR
Part
63,
Subpart
HH,
were
proposed
on
February
6,
1998
and
promulgated
on
June
17,
1999.
These
regulations
apply
to
the
following
facilities
in
40
CFR
Part
63,
Subpart
HH:
facilities
that
are
major
sources
of
hazardous
air
pollutants
(
HAP)
that
process,
upgrade,
or
store
hydrocarbon
liquids
prior
to
the
point
of
custody
transfer;
or
that
process,
upgrade,
or
store
natural
gas
prior
to
the
point
at
which
natural
gas
enters
the
natural
gas
transmission
and
storage
source
category,
or
is
delivered
to
a
final
end
user,
and
that
commence
construction,
modification
or
reconstruction
after
the
date
of
proposal.
The
emissions
controlled
by
this
regulation
are
total
organic
compounds
(
TOC)
or
hazardous
air
pollutants
(
HAP).
Specifically
exempted
from
this
regulation
are
oil
and
natural
gas
production
wells.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63,
Subpart
HH.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
start­
up,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NESHAP.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
5
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

Approximately
484
sources
are
currently
subject
to
the
regulation
and
it
is
estimated
that
an
additional
14
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
The
average
annual
respondent
cost
for
this
ICR
will
be
$
1,608,035.
This
ICR
is
submitted
with
no
terms
of
clearance.
2
2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

(
A)
Establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
TOC
or
HAP
emissions
from
oil
and
natural
gas
production
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
HH.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
TOC
or
HAP
from
oil
and
natural
gas
production
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
TOC
or
HAP
from
oil
and
natural
gas
production
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
TOC
or
HAP
emissions
using
the
following
control
devices:
(
1)
controlled
combustion
devices
(
e.
g.
thermal
vapor
incinerators,
catalytic
vapor
incinerators,
process
heaters);
(
2)
vapor
recovery
devices
(
e.
g.
carbon
absorption
system
or
condenser);
(
3)
flares
and,
(
4)
leak
detection
and
recovery
(
LDAR)
procedures.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
3
The
operating
conditions
are
as
follows:
controlled
combustion
devices
must
be
designed
and
operated
so
as
to
(
1)
reduce
TOC
or
total
HAP
by
95%
or
greater
by
weight;
(
2)
reduce
concentrations
of
TOC
or
total
HAP
by
20
ppm
or
less
(
volume,
dry
basis);
or
(
3)
operate
at
a
minimum
residence
time
of
0.5
seconds
at
a
minimum
temperature
of
760
degrees
Celsius.
A
vapor
recovery
device
or
other
control
device
that
is
designed
to
operate
so
as
to
(
1)
reduce
TOC
or
total
HAP
by
95%
or
greater
by
weight;
(
2)
reduce
concentrations
of
TOC
or
total
HAP
by
20
ppm
or
less
(
volume,
dry
basis);
or
(
3)
operate
at
a
minimum
residence
time
of
0.5
seconds
at
a
minimum
temperature
of
760
degrees
Celsius.
Flares
shall
be
designed
and
operated
to
conform
with
the
requirements
of
the
general
provisions
at
40
CFR
63.11.

The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63,
Subpart
HH.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
local
agency.
If
a
State
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
January
30,
2002,
(
67FR4421).
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
4
3(
c)
Consultations
Industry
trade
associations
and
EPA
personnel
were
consulted
for
this
ICR.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
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
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
TOC
or
HAP­
emitting
processes
and
operations
that
are
used
in
the
various
segments
of
the
oil
and
natural
gas
production
source
category.

Regulation
SIC
Codes
NAICS
Codes
5
40
CFR
Part
63,
Subpart
HH
1311
211111
40
CFR
Part
63,
Subpart
HH
1321
211112
4(
b)
Information
Requested
These
standards
require
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
of
40
CFR
Part
63
as
applied
to
the
standards,
and
with
the
five
year
records
retention
requirement
in
the
operating
permit
program
under
Title
V
of
the
CAA.
EPA
believes
that
the
five
year
records
retention
requirement
is
consistent
with
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
the
NESHAP
From
Oil
and
Natural
Gas
Production
Facilities
(
40
CFR
Part
63,
Subpart
HH).
A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
63,
Subpart
HH
Construction/
reconstruction
63.5
Initial
notifications
63.9(
b),
63.775(
b)

Performance
test
reports
63.10(
d)

Performance
evaluation
reports
for
CMS
63.10(
e)

Initial
performance
test
results
63.10(
d)(
2)

Initial
performance
test
63.7(
b),
63.9(
e)
and
(
g),
63.775(
d)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
63.9(
g)

Compliance
status
63.9(
h),
63.775(
b)
and
(
d)
Reports
for
40
CFR
Part
63,
Subpart
HH
6
Periodic
start­
up,
shutdown,
malfunction
reports
63.10(
d)(
5),
63.775(
b)

Summary
report
63.10(
e)(
3)

Periodic
report
63.10(
e),
63.775(
e)

Notification
of
process
change
63.775(
f)

A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
63,
Subpart
HH
Start­
ups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2),
63.774(
b)(
3)(
ii)

All
reports
and
notifications
63.10,
63.774
Records
of
all
maintenance
performed
on
air
pollution
control
equipment
63.10(
b)(
2)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
b)(
3),
63.774(
b)(
4)

Records
are
required
to
be
retained
for
5
years.
The
most
recent
12
months
of
records
must
be
retained
at
the
facility.
63.10(
b)(
1),
63.774
Benzene
emissions
records
63.774(
c)

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Gather
relevant
information.

Install,
calibrate,
maintain,
and
operate
closed
vent
systems
and
CMS
to:
1)
achieve
a
95%
reduction
in
HAP,
TOC,
or
total
HAP,
for
control
devices
and
vapor
recovery
devices;
2)
achieve
a
reduction
to
20
ppm
of
TOC
or
total
HAP,
and
operates
at
a
minimum
residence
time
of
0.5
seconds
at
a
minimum
temperature
of
760
degrees
Celsius
for
combustion
devices.
Respondent
Activities
7
Perform
initial
performance
tests,
and
repeat
performance
tests
if
necessary
(
using
Method(
s)
1,
1A;
2,
2A,
2C
or
2D;
or
either
Method
18
or
25A:
located
at
40
CFR
part
60,
appendix
A).

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

It
is
estimated
that
10%
of
the
responses
to
this
ICR
can
be
collected
electronically.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Conduct
on­
site
inspections
as
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.
8
5(
b)
Collection
Methodology
and
Management
Following
notification
of
start­
up,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
State
and
local
regulatory
agencies,
EPA
Regional
Offices
and
EPA
Headquarters.
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve
and
analyze
the
data.
The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
regulation.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Annual
Industry
Reporting
and
Recordkeeping
Requirements,
Existing
and
New
Sources.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.
The
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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
29,489
hours
(
total
annual
labor
hours
from
Table
2).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
9
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
78.54
($
37.40
+
110%
overhead)
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
55.34
($
26.35
+
110%
overhead)
per
hour
for
Technical
labor,
and
$
35.64
($
16.97
+
110%
overhead)
per
hour
for
Clerical
labor.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
hourly
wage
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
For
the
purposes
of
this
analysis,
it
is
assumed
that
each
labor
hour
is
composed
of
5
percent
management,
85
percent
technical,
and
10
percent
clerical,
resulting
in
an
average
hourly
rate
of
$
54.53
per
hour.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
and
CEMs.
The
capital/
startup
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Startup
Cost
($)
for
One
Affected
Facility
(
C)
No.
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
(
B
x
C)
(
E)
Annual
O&
M
Costs
($)
for
One
Affected
Facility
(
F)
No.
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
x
F)

Combustion
Device
991
11
10,901
1,090
453
493,770
Flares
1,423
3
4,269
427
102
43,554
Vapor
Recovery
232
4
928
93
147
13,671
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
10
Total
of
all
Continuous
Monitoring
Devices
$
16,098
$
550,995
The
total
capital/
startup
costs
for
this
ICR
are
$
16,098.
This
is
the
total
of
column
D.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
a
(
Total
annualized
capital/
startup
costs
(
O&
M)).
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
550,995.
This
is
the
total
of
column
G.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b
(
Total
annual
costs
(
O&
M)).

The
total
respondent
non­
labor
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup,
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
567,093.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c
(
Total
annualized
cost
requested).

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Agency
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
180,243
(
see
Table
1).
The
Agency
labor
rate
is
calculated
using
$
49.82
(
GS­
13,
Step
5,
$
31.14
x
1.6)
per
hour
for
Managerial
labor,
$
36.98
(
GS­
12,
Step
1,
$
23.11
x
1.6)
per
hour
for
Technical
labor,
and
$
20.00
(
GS­
6,
Step
3,
$
12.50
x
1.6)
per
hour
for
Clerical
labor.
These
rates
are
from
OPM's
"
2001
General
Schedule"
which
excludes
locality
rates
of
pay.
For
this
analysis,
it
is
assumed
that
each
labor
hour
is
composed
of
5
percent
management,
85
percent
technical,
and
10
percent
clerical,
including
60
percent
to
account
for
government
overhead
expenses,
resulting
in
an
average
hourly
rate
of
$
35.92.
Details
upon
which
this
estimate
is
based
appear
in
Table
1,
attached
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
11
Respondent
Universe
Regulation
Citation
(
A)
No.
of
New
Sources/
Yea
r
(
B)
No.
of
Initial
Reports
for
New
Sources
(
C)
No.
of
Existing
Sources
(
D)
No.
of
Reports
for
Existing
Sources
(
E)
Total
Annual
Responses
(
AxB)+(
CxD)

40
CFR
Part
63,
Subpart
HH
14
2
484
2
996
The
number
of
total
respondents
is
498.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table
above.
This
represents
the
number
of
existing
sources
plus
the
number
of
anticipated
new
sources
averaged
over
the
three­
year
period
of
this
ICR.
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
996.
This
is
the
number
in
column
E
of
the
Respondent
Universe
table
above.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
labor
costs
(
including
training
labor
and
costs
for
new
sources)
are
$
1,994,961.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
Industry
Reporting
and
Recordkeeping
Requirements;
Existing
and
New
Sources.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
567,093.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
section
6(
b)(
iii),
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
hours
from
the
most
recently
approved
ICR
is
due
an
increase
in
the
burden
hours
placed
upon
the
affected
industry
since
the
last
approved
ICR.
This
is
attributed
to
full
affected
industry
compliance
with
the
regulations,
rather
than
the
prior
ICRs
accounting
for
gradual
compliance
over
the
allowed
three
year
period.

6(
g)
Burden
Statement
12
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
standards
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1788.03
and
2060­
0417
OMB
Control
Number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
Table
1.
Estimated
Federal
Burden.

Activity
A.
Person
hours
per
response
or
task
B.
Annual
#
of
responses
or
tasks
C.
Total
annual
person
hours
(
A
x
B)
D.
Annual
labor
cost
(
C
x
$
35.92)
E.
Annual
direct
costs
F.
Total
annual
cost
(
D
+
E)

1.
Review
reports
a.
Initial
notification
2
14
28
1,006
0
1,006
b.
Preconstruction
review
application
4
14
56
2,012
0
2,012
c.
Performance
test
notification
2
17
34
1,221
0
1,221
d.
Compliance
status
notification
4
501
2,004
71,984
0
71,984
e.
Performance
test
reports
4
17
68
2,443
0
2,443
d.
Startup
/
shutdown
/
malfunction
reports
2
501
1,002
35,992
0
35,992
g.
Semi­
annual
summary
reports
2
515
1,030
36,998
0
36,998
2.
Compliance
inspections
a.
Select
site
and
review
permit
file
4
17
68
2,443
0
2,443
b.
Travel
to/
from
site
8
17
136
4,885
1,000
5,885
c.
On­
site
inspection
4
17
68
2,443
0
2,443
d.
Prepare
inspection
report
16
17
112
4,023
0
4,023
3.
Enforcement
action
a.
Notice
of
noncompliance
160
2
320
11,494
0
11,494
b.
Followup
compliance
inspection
32
2
64
2,299
0
2,299
Table
1.
Estimated
Federal
Burden.

c.
Litigation
N.
A.

Total
180,243
Table
2.
Annual
Industry
Reporting
and
Recordkeeping
Requirements;
Existing
and
New
Sources.

Reporting
and
Recordkeeping
Requirements
A.
Person
hours
per
occurrence
B.
Annual
occurrences
per
respondent
C.
Annual
person
hours
per
respondent
(
A
x
B)
D.
Total
number
of
respondents
E.
Total
annual
person
hours
(
C
x
D
)
F.
Total
annual
cost
(
E
x
$
54.53)

1.
Reporting
requirements
a.
Read
instructions
4
1
4
14
56
3,054
b.
Gather
existing
information
8
1
8
14
112
6,107
c.
Write
reports
i.
Initial
notification
2
1
2
14
28
1,527
ii.
Performance
review
application
2
1
2
14
28
1,527
iii.
Performance
test
notification
2
1
2
5
10
545
iv.
Compliance
status
notification
4
1
4
484
1,936
105,570
v.
Performance
test
reports
4
1
4
5
20
1,091
vi.
Startup
/
shutdown
/
malfunction
reports
2
2
4
484
1,936
105,570
vii.
Semiannual
summary
report
2
2
4
484
1,936
105,570
2.
Recordkeeping
requirements
a.
Read
instructions
4
1
4
484
1,936
105,570
b.
Plan
activities
16
1
16
484
7,744
422,280
c.
Implement
activities
Table
2.
Annual
Industry
Reporting
and
Recordkeeping
Requirements;
Existing
and
New
Sources.

i.
Material
determinations
4
1
4
13
52
2,836
Table
2.
Annual
Industry
Reporting
and
Recordkeeping
Requirements;
Existing
and
New
Sources.

Reporting
and
Recordkeeping
Requirements
A.
Person
hours
per
occurrence
B.
Annual
occurrences
per
respondent
C.
Annual
person
hours
per
respondent
(
A
x
B)
D.
Total
number
of
respondents
E.
Total
annual
person
hours
(
C
x
D
)
F.
Total
annual
cost
(
E
x
$
54.53)

ii.
Control
equipment
inspections
N.
A.

iii.
Control
equipment
leak
monitoring
4
2
8
13
104
5,671
iv.
Control
devices
Design
analysis
16
1
16
39
624
34,027
Performance
test
40
1
40
5
200
10,906
Operate
and
maintain
CMS
2
12
24
14
336
18,322
v.
LDAR
program
Identify
all
affected
streams
7
1
7
2
14
763
Perform
monitoring
/
repair
5
12
60
2
120
6,544
d.
Develop
record
system
i.
Develop
startup/
shutdown/
malfunction
plan
20
1
20
14
280
15,268
ii.
Control
equipment
8
1
8
14
112
6,107
iii.
LDAR
program
13
1
13
2
26
1,418
e.
Time
to
enter
information
i.
Cover
designs
8
1
8
5
40
2,181
ii.
Control
device
design
8
1
8
14
112
6,107
iii.
Control
equipment
testing
1
1
1
5
5
273
Table
2.
Annual
Industry
Reporting
and
Recordkeeping
Requirements;
Existing
and
New
Sources.

Reporting
and
Recordkeeping
Requirements
A.
Person
hours
per
occurrence
B.
Annual
occurrences
per
respondent
C.
Annual
person
hours
per
respondent
(
A
x
B)
D.
Total
number
of
respondents
E.
Total
annual
person
hours
(
C
x
D
)
F.
Total
annual
cost
(
E
x
$
54.53)

iv.
Control
equipment
inspection
1
2
2
484
968
52,785
v.
Control
equipment
monitoring
1
2
2
484
968
52,785
vi.
Control
device
CMS
1
12
12
484
5,808
316,710
vii.
LDAR
program
1
12
12
2
24
1,309
viii.
Material
determination
1
1
1
7
7
382
f.
Time
to
train
personnel
i.
Material
determination
methods
8
1
8
5
40
2,181
ii.
Control
equipment
inspection
&
monitoring
8
1
8
484
3,872
211,140
iii.
LDAR
program
5
1
5
7
35
1,909
Total
29,489
1,608,035
