### SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) ( Revised )

1. Identificatio n of the Information Collection

1(a) Title of the Information Collection

N ational Emission Standards fo r Hazardous Air Pollutants (NESHAP) for Oil and Natural Gas

Production (40 CFR Part 63, Subpart HH) ( Revised) , EPA ICR Number 1788.10, OMB Control

Number 2060

- 0417.

1(b) Short Characterization/Abstract

The amendments to this ICR are a result of the revie w of the existing NESHAP for Oil and

Natural Gas Production (40 CFR Part 63, Subpart HH) as required by the Clean Air Act. The

NESHAP published at 40 CFR part 63, subpart HH were proposed on February 06, 1998, and

promulgated on June 17, 1999 only for majo r sources. On July 8, 2005, a supplemental proposal

was published for area sources with the final rule effec tive date on January 03, 2007. Th e current

proposed rulemaking applies to existing and new faci lities that are major sources. A major source

of haza rdous air pollutants (HAP) is one that has the potential to emit, 10 tons or more of any one

hazardous air pollutant or 25 tons or more of total HAP per year; an area source is one with the

pot ential to emit less than this. This information is being collec ted to assure compliance with 40

CFR part 63 subpart HH

.

In general, all NESHAP standards require initial notifications, performance tests, and

periodic reports by the owners/operato rs of the affected facilities. These notifications, reports, and

records a re essential in determining compliance, and are required of all affected facilities subject to

NESHAP. Semiannual summary reports are also required.

The proposed rulemaking would amend title 40, chapter I, part 63 subpart HH to include,

emission sources f

or which standards were not previously developed. We are proposing these

standards for these emission sources pursuant to CAA section 112(d)(2) and (3). Therefore, the

### 2

number of affected facilities under this subpart is expected to increase for major sourc es

. The

overall change in burden found in this ICR reflect the provision changes, an update in the cost of

labor, and correct ions to the number of affected facilities found in EPA ICR number 1788.09.

The period considered in this ICR and throughout this s upporting statement is the first

three years following the promulgation of the amended Oil and Natural Gas Production NESHAP.

The estimates of the size of the r egulated universe are based on data from the National Emissions

Inventory (NEI) database

. O ver the three year period, we expect 426 existing major source

facilities to become new respondents. In addition, w e expect a total of 43 new respondents to

become subject over the three year period. The average annual burden from the recordkeeping and

repor ting requirements is 63,304 person hours, with an annual average cost of $2 ,119,048 and an

annual capital cost of $245,086

.

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 Ai r Act, as amended, to establish

standards of performance for each category or subcategory of major sources and area sources of

hazardous air pollutants (HAP). These standards are applicable to new or existing sources of HAP

and shall require the maximum d egree 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 maint ain 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 pre scribe); (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

### 3

reasonably require.

In the Administrator's judgment, HAP emissions from oil and natural gas production

facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public

health or wel fare . Therefore, the NESHAP standards were promulgated for this source category at

40 CFR part 63, subpart HH.

2(b) Prac tical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the

applicable reg ulations which were promulgated in accordance with the Clean Air Act. In addition,

the collected information is used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’ s initial capability

to comply with the emission standard. Continuous emission monitors are used to ensure

compliance with the standard at all times. During the performance tests, a record of the operating

parameters under which compliance was achieved m ay be recorded and used to determine

compliance in place of a continuous emission monitor.

The notifications required in the standard 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 ensure that the pollution control devices are properly

installed and operated, that leaks are being detected and repaired, and that the standards are being

met. The perform ance test may also be obse rved.

The required semiannual reports are used to determine periods of excess emissions,

identify problems at the facility, verify operation/maintenance procedures, and for compliance

determinations.

The information generated by the monitoring, recordkeep ing and reporting requirements

described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP

continues to operate the control equipment in compliance with the regulation.

3. Non

- duplication, Consultations, and Other Collecti on Criteria

### 4

3(a) Non

- duplication

A search of EPA’ s existing standards and ongoing ICR’s revealed no duplication of

information gathering efforts. However, certain reports required by State or local agencies may

duplicate information required by this NESHA P. In these cases , a copy of the report submitted to

the S tate or local agency can be sent to the Administrator in lieu of the report required by the

Federal standards. Th erefore, no duplication exists.

3(b) Public Notice Required Prior to ICR Submissio n to OMB

This action is not applicable because it is a rule related ICR.

3(c) Consultations

During the previous ICR renewal, Industry trade associations and other interested parties

were provided an opportunity to comment on the burden associated with th e standard as it was

being developed. We contacted the Independent Petroleum Association of America (IPAA) at

(202) 857

- 4722, and the American Gas Association (AGA) at (202) 824

- 7000.

3(d) Effects of Less Frequent Collection

Less frequent information c ollection 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

e mission limitations are met. If the information required by these standards was collected less

frequently, the proper operation and maintenance of control equipment and the possibility of

detecting violations would be less likely.

3(e) General Guidelines

T hese reporting or recordkeeping requirements are consistent with the regulations

established by OMB at 5 CFR part 1320, section 1320.5, expect for the maximum length of

maintaining records.

These standards require the respondents to maintain all records, including reports and

### 5

notifica tions for at least five years. This is consistent with the General Provision s as applied to the

standards. EPA believes that the five

- year records retention requirement is consistent with the Part

70 permit program and the fi ve

- year statute of limitations on which the permit program is based.

The retention of records for five years allows EPA to establish the compliance history of a source,

any pattern of non

- compliance, and to determine the appropriat e level of enforcement a ction. EPA

has found that the most flagrant violators have violations ex tending beyond the five years. Without

the five

- year record retention, EPA would be prevented from pursuing the violators due to the

destruction or nonexistence of essential records.

3 (f ) Confidentiality

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 (se e 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 Respondent s and the Information Requested

4(a) Respondents

The respondents to the recordkeeping and reporting requirements are oi l and natural gas

production. T he North American Industry Clas sification System (NAICS) codes are 211112 for

“Natura l Gas Liquid Extraction ” and 211111 for “ Crude Petroleum and Natural Gas Extraction .”

4(b) Information Requested

(i) Data Items

The standards are based on add

- on control devices and pollution prevention measures to

reduce HAP emissions. In order to demon strate continuous compliance with the standards, certain

### 6

facilities must use the continuous parameter monitoring systems (CPMS). Although personnel at

the affected facility must still evaluate the data, internal automation has significantly reduced the

bur den associated with monitoring and recordkeeping at a plant site.

A source must make the following reports:

Notifications

Initial notification 63.775(b)(1), 63.9(b)(2) major

source,
63.775(c)(1) area source



### Notification of intent to construct/recons truct 63.5(d), 63.9(b)(4) major

source 63.9(b)(5) area source


### Notification of actual startup date 63.9(b)(4), 63.9(b)(5)(ii) major

source 63.9(b)(5) area source


### Notification of date of CMS performance evaluation 63.775(b)(2), 63.8(e)(2), 63.9(g)(1) major source
63.775 (c)(2) area source


### Notification of intent to conduct a performance test 63.775(b)(3), 63.7(b), 63.9(e) major source

73.775(c)(3) area source


### Notification of compliance status 63.775(b)(4), 63.9(h), 63.775(d), major source

63.775(c)(4) area source 

### Periodic reports 63.775(b)(5), 63.769(c), 63.772(f) major source

63.775(c)(5) area source


### Results of performance test 63.7(g), 63.10(d)(2)



### Notification of change in compliance demonstration method for control device performance 63.772(f)



### Notif ication of process change 63.775(f)



### Semiannual excess emissions and continuous monitoring system performance report 63.8(c)(8), 63.10(e)(3)



### Semiannual HAP summary report 63.10(e)(3)



### A source must keep the following records:

Recordkeeping

Record ret ention 63.10(b)(1), 63.774(b)(1)



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

### 7

Recordkeeping

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

- (ix)



### Record r elated to control equipment inspections (area sources) 63.774(b)(5

- 8) 63.773(c)(7)



### Records related to CMS (area sources) 63.10(b)(2)(vi), (x), (xi), 63.10(c), 63.774(b)(3

- 4)


### Records required if complying via process modification (area sources) 63.774(b)( 10

- 11),

63.771(e)



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



### Records related to equipment that is exempt or subject to other

standards 63.764(e), 63.774(d) 63.774(b)(9)



### Records of exempt glycol dehydration units 6 3.764(e)(1), 63.774(d)(1)



### Records of exempt ancillary equipment and compressors 63.764(e)(2), 63.774(d)(2)



### Records of glycol dehydration unit baseline operations (alternative standards) 63.771(e)(1), 63.774(b)(10)



### Records of conditions for which glycol dehydration unit baseline operations shall be modified to achieve 95% HAP emission reduction (alternative standards) 63.771(e)(2), 63.774(b)(11)



### Records to demonstrate that glycol dehydration unit operates under conditions for HAP reduction (alternative s tandards) 63.771(e)(3), 63.774(b)(11)



### Documentation of condenser design analysis 63.769(c), 63.772(e)(4)



### Records of control device operating parameters

– continuous and daily average (except flares) 63.774(b)(4)(i

- ii)



### Records of flare design, visible e missions, heat content, flow

- rate, exit velocity, pilot flame outages (flares only) 63.774(b)(4)(i

- ii), 63.774(e)



### Records of 365 days rolling average condenser efficiency (condensers only) 63.774(b)(4)(ii)(B)



### Records of flow indicator operation, flow det ection, vent stream

diversions 63.774(b)(4)(iii)



### Records of inspections of seals or closure mechanisms, records of broken/changed/checked out seals/valves/locks 63.774(b)(4)(iv)



### Records of unsafe

- to

- inspect parts 73.773(c)(7), 63.774(b)(5)



### Records of di fficult

- to

- inspect parts 63.773(c)(7), 63.774(b)(6)



### Records of leak or defect detection and repair 63.769(c), 61.246, 63.773(c)(7), 63.774(b)(7)


### Records of inspections during which no leaks or defects were

detected 63.773(c)(7), 63.774(b)(8)



### Records of compliance with benzene emission limit (alternative standards) 63.774(c)

### 8

Recordkeeping

Site

- specific performance evaluation test plan 63.7(c)(2), 63.8(d)(2), 63.8(e)(3)(i)


### Records of results of performance test 63.7(g)(3)



### Continuous monitoring system quality control program 63.8(d)



### Records of continuous monitoring system performance 63.10(c)



### (ii) Respondent Activities

Respondent Activities

Read instructions.

Gather relevant information.

Perform initial performance test and repeat performance tests if necessar y. 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 ver ifying 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 informa tion.

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

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

Transmit, or otherwise disclose the information.

5. The Information Collected : Agency Activities, Collection Methodol ogy, 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

O bserve initial performance tests and repeat performance tests if necessary.

### 9

Agency Activities

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

M aintain data in th e CDX

5(b) Collection Methodology and Management

Information contained in the reports will be required to submit records electronically to

EPA ’s Central DATA Exchange (CDX) using the Electronic Reporting Tool. The Central Data

Exchange (CDX) enables fas t, efficient and more accurate environmental data submissions from

state and local governments, industry and tribes to the Environmental Protection Agency (EPA)

and participating program offices. EPA's CDX is the point of entry on the Environmental

Inform ation Exchange Network (Exchange Network) for environmental data submissions to the

Agency. CDX works with both EPA program offices looking for a way to better manage incoming

data, and stakeholders looking for a way to reduce burden from reporting require ments.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the

impact on small entities (i.e., small businesses) was taken into consideration during the

development of the regulation. Due to technical considerations involving the process operations

and the types of control equipment employed, the recordkeeping and reporting requirements are

the same for both small and large entities. The Agency considers these to be the minimum

requirement s needed to ensure compliance and, therefore, cannot reduce the m further for small

entities.

5(d) Collection Schedule

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

below in Table 1: Annual Respondent Burden

- NESHAP for Oil and Natural Gas Production (40

CFR Part 63, Subpart HH) ( Revised)

6. Estimating the Burden and Cost of the Collection

### 10

Table 1 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. Wherever appropriate, specific tasks and

major ass umptions have been identified. Responses to this inform ation 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 C ontrol 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 63,308 ( Total Labor Hours from Table 1). These

hours are based on Agency studies and background documents from the development of 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: $33.51 per hour for technical labor, $52.85 per

hour for management labor, and $23.43 for clerical labor. The rates have already been increased by

110 percent to account for the benefit packages available to those employed by private industry.

These rates are from the Employer Costs for Employee Compensation Historical Listing March

2004

– December 2010 published by the Bureau of Labor and Statistics and represents th e state of

the industry in 2008. This is consistent with the control costs associated with the proposed

revisions to subpart HH (Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf).

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the inform ation collection activities in the

subject standard are labor costs which are addressed elsewhere in this ICR and the costs associated

with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes

subject to the regulati on. The annual operation and maintenance costs are the ongoing costs to

### 11

maintain the monitor and other costs su ch 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) Capital/

Startup Cost

for One Respondent (C)

Number of

New Respondents (D)

Total Capital/ Startup Cost (B X C) (E)

Annual O&M

Costs for One Respondent (F)

Number of Respondents

with O&M b (G)

Total

O&M

, (E X F)

Monitoring equipment (CMS) $1,015 159 $161,202 $134 626 $83,884

Total $161,202 $83,884

a. We assume all new major sources and 2 percent of new area sources purchase the equipment.

b

. We assume the average number of existing major sour ces have annual O&M costs.



### The total capital/startup costs for this ICR are $ 161,202 . This is the total of column D in

the above table.

The total operation and maintenance (O&M) costs for this ICR are $ 83,884

. This is the

total of column G.

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 $ 245,086

.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported

information. The EPA compliance and enforcement program includes activities such as: the

examination of records maintained by the respondents; periodic inspection of sources of

emissions; and the publication and distrib ution of collected i nformation.

The average annual Agency cost during the three years of the ICR is estimated to be

$ 239,113

.

This cost is based on the averag e hourly labor rate as follows:

Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%)

### 12

Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%)

Clerical $25. 01 (GS

- 6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for

the benefit packages available to government employees. Details upon which this estimate is based

appear below in Table 2: Average Annual EPA Burden

- NESHAP for Oil and Natural Gas

Production (40 CFR Part 63, Subpart HH) (Re vis ed ).

6(d) Estimating the Respondent Un iverse and Total Burden and Costs

The number of area source respondents is derived from information in EPA ICR number

and EPA ICR number 1788.08, section 4 (b) (ii)

.

The number of major source respondents was updated based on the NEI database, which

was used during the analysis to determine the MACT

. The number of respondents is calculated

using the following table which addresses the 3 years covered by this ICR. Over the three year

period of this ICR, we expect 426 existing major source facilities to bec ome new respondents. In

addition, w e expect 43 new respondents to become subject over the three year period.

The total number of annual responses per year is calcul ated using the following table:

YEAR (A) (B) (C ) (E) (F) (G)

Number of New Respondents

1 & 2 Number of Existing Respondents 3 Number of

Existing Respondents

That Are

Also New Respondents Total

Number of Respondents (E=A+B) Number of

Respondents that Only

Maintain

Records 4 Number of

Respondents

That Submit

Records Major Area Area

Only Keep

Records Major Area



### 1 156 3 138 470 2,927 142 3,694 3,006 688

2 156 3 138 626 3,068 142 3,991 3,145 846

3 156 3 138 782 3,209 142 4,288 3,283 1,005
Avg 156 3 138 626 3

, 068 142 3

, 991 3,145 846

1 New respondents include sources with constructed or rec onstructed affected facilities.

### 13

2 We assume that there are 141 new area sources and 1 5 6 new major sources for a total o f 297 new sources each year

. We estimate 142 of the new major sources are existing facilities , while 14 new major sources are at new facili ties.
3 We assume there are 3,068 existing area sources and 626 existing major sources.

4 We assume that 98 percent of area sources will only be required to maintain records. All major sources and 2 percent of area sou rces will maintain and submit reports

.



### Total Annual Responses

(A) Information Collection Activity (B)

Number of Respondent

s (C)

Number

of Response

s (D)

Number of Existing Respondents That Keep Records But

Do Not Submit Reports (E)

Total

Annual Responses E=(BxC)

Major sources

Notificatio n of construction/reconstruction 156 1 0 156

Notification of actual startup 156 1 0 156

Notification of date of CMS performance

evaluation 156 1 0 156

Notification of date of performance test 156 1 0 156

Notification of compliance status report 156 1 0 156

Semiannual periodic report 782 2 0 1, 564

Area sources

Notification of intent to construct 3 1 0 3

Notification of actual startup date 16 1 0 16

Notification of intent to conduct

performance test 16 1 0 16

Notification of date of CMS performa nce

evaluation 16 1 0 16

Notification of compliance status 16 1 0 16

First periodic report 3 1 0 3

Subsequent periodic reports 12 1 0 12

Total Number of Annual Responses Total 2, 426



### The number of Total Annual Responses is 2,426

.

The total an nual la bor costs are $ 2

, 119,048 for 6 3,304 labor hours

. Details regarding these

estimates may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Oil

and Natural Gas Production (40 CFR Part 63, Subpart HH) ( Revised ).

6(e) Bottom Line Burden Hou rs Burden Hours and Cost Tables

### 14

The detailed bottom line burden hours and cost calculations for the respondents and the

Agency are shown in Tables 1 and 2, respe ctively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 6 3,3 04 . Details regarding these estimates may be found

below in Table 1. Annual Respondent Burden and Cost

- NESHAP for Oil and Natural Gas

Production (40 CFR Part 63, Subpart HH) (R evised ).

Furthermore, the annual public reporting and recordkeeping burden fo r this collection of

information is estimated to average 26 hours (rounded) per response.

The total annual capital/startup and Operation and Maintenance (O&M) costs to the

regulated entity are $ 245,086

.

(ii) The Agency Tally

The average annual Agency burd en and cost over next three years is estimated to be 5, 230

l abor hou rs at a cost of $ 239

, 113 . See below Table 2: Annual Agency Burden and Cost

–

NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH) ( Revised).

6(f) Reasons for Change in Burden

The proposed rulemaking would amend title 40, chapter I, part 63 subpart HH to include,

emission sources for which standards were not previously developed. We are proposing these

standards for these emission sources pursuant to CAA section 112(d) (2) and (3). Therefore, the

number of affected facilities under this subpart is expected to increase for major sources. At this

time, none of the proposed amendments will affect area sources. The overall change in burden

found in this ICR reflect the pr ovision changes, an update in the cost of labor, and corrections to

errors found in EPA ICR number 1788.09.

6(g) Burden Statement

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

estimated to average 26 hours p er response. Burden means the total time, effort, or financial

### 15

resources expended by persons to generate, maintain, retain, disclose or provide information to or

for a Federal agency. This includes the time needed to review instructions; to develop, acqu ire,

install, and utilize technology and systems for the purposes of collecting, validating, and verifying

information, processing and maintaining information, and disclosing and providing information;

to adjust the existing ways to comply with any previou sly applicable instructions and requirements;

to train personnel to be able to respond to a collection of information; to search data sources; to

complete and review the collection of information; and to transmit or othe rwise disclose the

information.

An agency may not conduct or sponsor, and a person is not required to respond to, a

collection of information unless it displays a valid OMB Control Number. The OMB Control

Numbers for EPA

= s regulations are listed at 40 CF R 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 Number EPA

- HQ

- OECA

- 2009

- 0388. An electronic version of the public docket is available at

http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of

informatio n, submit or view public comments, access the index listing of the content of the docket,

and to access those documents in the public docket that are available electronically. When in the

system, select “search” than key in the docket ID number identified in this document. The

documents are also available for public viewing at the Enforcement and Compliance Docket and

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301

Constitution Avenue, N.W., 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

Enforcement and Compliance Docket and Informatio n Center Docket is (202) 566

- 1752

. Also,

you can send comments to the Office of Information and Regulatory Affairs, Office of

Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer

for EPA. Please include the EPA Dock et ID Number EPA

- HQ

- OECA

- 2009

- 0388 and OMB

Control Number 2060

- 0417 in any correspondence.

Part B of the Supporting Statement

### 16

This part is not applicable because no statistical methods were used in collecting this

information.

### Table 1: Annual Respondent Burden and Cost

– NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH )

( Revised )

Burden item (A)

Person hours per

occurrence (B)

No. of

occurrences

per respondent

per year (C)

Person hours per respondent

per year (C=AxB) (D)

Respondents

per year a (E)

Technical

person

hours per

year (E=CxD) (F)

Management person hours

per year (Ex0.05) (G)

Clerical

person hours

per year (Ex0.1) (H)

Total Cost

Per year b

($)

1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements

a. Read rule and instructions c 4 1 1 297 472 24 47 18,170 b. Required activities N/A

c. Create information N/A d. Gather existing information c 2 1 1 297 594 30 59 22,866 Major sourc es
i. Notification of construction/reconstruction c 1 1 1 156 78 4 8 3,003 ii. Notification of actual startup c 1 1 1 156 78 4 8 3,003 iii. Notification of date of CMS performance

evaluation c 1 1 1 156 78 4 8 3,003

iv. Notifica tion of date of performance test c 1 1 1 156 78 4 8 3,003 v. Notification of compliance status report c 4 1 4 156 624 31 62 24,021 vii. Semiannual periodic report 4 2 8 782 6,256 313 626 240,828

Area sources

i. Notification of intent to construct c 1 1 2 3 6 0 1 231 ii. Notification of actual startup date c 1 1 1 3 3 0 0 115

iii. Notification of intent to conduct performance test c, e 1 1 2 16 32 2 3 1,232

iv. Notification of date of CMS performance

evaluation c, e 1 1 2 16 32 2 3 1,232

v. Notification of compliance status 4 1 10 16 160 8 16 6,159 vi. First periodic report c, e 4 1 4 3 12 1 1 462 vii. Subsequent periodic reports e 2 1 2 12 24 1 2 924

Subtotal for Reporting Requireme nts 40 9,806 328,251

4 Recordkeeping requirements

a. Read instructions

### 18

Burden item (A)

Person hours per

occurrence (B)

No. of

occurrences

per respondent

per year (C)

Person hours per respondent

per year (C=AxB) (D)

Respondents

per year a (E)

Technical

person

hours per

year (E=CxD) (F)

Management person hours

per year (Ex0.05) (G)

Clerical

person hours

per year (Ex0.1) (H)

Total Cost

Per year b

($)

- Major source g 1 1 4 156 624 31 62 24,021

- Area source g 1 1 4 141 564 28 56 21,711

b. Plan activities

- Major source 16 1 16 156 2,496 125 250 96,085

- Area source i. Sources required to operate add

- on controls 16 1 16 16 256 13 26 9,855 ii. Sources required to implement MP 4 1 4 138 552 28 55 21,250

c. Im plement activities

- Major source N/A

- Area source

i. Performance test 35 1 35 3 105 5 11 4,042 ii. Design analysis 12 1 12 16 192 10 19 7,391 iii. Control equipment leak monitoring h 3 2 6 62 372 19 37 14,320 iv. Operate and maintain CMS h, i 2 12 24 62 1,488 74 149 57,281 d. Develop record system

- Major source i. Control equipment 8 1 8 156 1,248 62.4 125 4,8042 ii. Equipment Inspection and Monitori ng 13 1 13 782 10,166 508 1,017 391,345

- Area source i. Control equipment 8 1 8 16 128 6 13 4,927

e. Time to enter information

- Major source i. Control equipment monit oring j, k 1 2 2 782 1564 78 156 60,207

ii. Control device CMS j, k, l 1 12 12 782 9,384 469 938 361,242 iii. Equipment Inspection and Maintenance , k, l 1 12 12 782 9,384 469 938 361,242

- Area source i Control equi pment leak monitoring h, m 1 2 2 62 124 6.2 12 4,773

ii. CMS measurements h 1 12 12 62 744 37 74 28,641 f. Time to train personnel

- Major source 8 1 8 156 1,248 62 125 48,042

- Area source n 16 1 16 16 256 12.8 26 9,855 g. Maintain records (area source) h, o 20 1 20 62 1,240 62 124 47,734

### 19

Burden item (A)

Person hours per

occurrence (B)

No. of

occurrences

per respondent

per year (C)

Person hours per respondent

per year (C=AxB) (D)

Respondents

per year a (E)

Technical

person

hours per

year (E=CxD) (F)

Management person hours

per year (Ex0.05) (G)

Clerical

person hours

per year (Ex0.1) (H)

Total Cost

Per year b

($)

h. Retain records of emission p 1 1 1 3,145 3,145 157 314 121,054 i. Retrieve records/reports q 20 1 20 62 1,240 62 124 47,734

Subtotal for Recordkeeping Requirements 53,498 1

, 790

, 797 46,520 2,326 4,652

TOTAL LABOR BURDEN AND COST (rounded) 63,304 2,119,048

Assumptions:



### a

. We have assumed that the average number of reporting respondents that will be su bject to this rule w ill be 3,991 during the reporting period , which consists of 3,068 existing area sources, 626 existing major sources and an additional 297 new sources. The majority of these respondents, 3,145, are not required to submit reports

. 

### b

. This ICR uses the following labor rates: $33.51 per hour for technical labor, $52.85 per hour for management labor, and $23.43 for clerical labor. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. These rates are from the Employer Costs for Employee Compensation Historical Listing March 2004

– December 2010 published by the Bureau of Labor and Statistics and represents the state of the industry in 2008, consistent with the control costs associated with the proposed rul e. Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf



### e

. We have assumed that the requirements do not apply to sources located outside of an urbanized area (UA)/ urban cluster (UC) plus offset boundary.



### g

. We have assumed that it will take each of the respondents four hours to read instructions.


### h

. We have assumed that 50 existing area sources, and 12 new area sources (8 percent of area sources ) will complete this activity.

i

. We have assumed that it will take each respondent two hours twelve times per year to implement this activity. j

. We have assumed that it will take each of the respondents one hour to enter information.

k

. We assume that all of the major sour ces will each take one hour to enter information.

l. We have assumed that each respondent will be required to enter information twelve times per year.

m

. We have assumed that each respondent will be required to enter information two times per year.

n

. We have assumed that a sixteen (3 new and 13 existing) respondents will each take si xteen hour to train personnel. This follows the assumption that 2 percent of area

sources will submit records.

o

. We have assumed that it will take 20 hours for each responde nt to maintain records.

p

. We have assumed that all of the respondents that are subject only to the recordkeeping requirements will take one hour each y ear to process records of emissions.

q

. We have assumed that each respondent will take twenty hours once per year to retrieve records/reports.

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Table 2: Average Annual EPA Burden

- NESHAP for Oil and Natural Gas Production (40 CFR Part 63, Subpart HH )

(Re vised )

Activity (A)

EPA

person

hours per

occurrence (B)

No. of

occurrences per plant

per year (C)

EPA

person

hours per plant

per year (C=AxB) (D)

Plants

per

year a (E)

Technical

person

hours per

year (E=CxD) (F)

Management

person

- hours

per year (Ex0.05) (G)

Clerical

person

hours

per year (Ex0.1) (H)

Cost, $ b

Major source

Initial notifi cation c 2 1 2 156 312 15.6 31.2 16,404 Preconstruction review application c 4 1 4 156 624 31.2 62.4 32,807

Performance test notification c 2 1 2 156 312 15.6 31.2 16,404 Compliance status notification c 4 1 4 156 624 31.2 62.4 32,807

S emiannual periodic reports d 2 2 4 628 2,512 125.6 251.2 132,070

Area sources 0 0 0

Notification of intent to construct 2 1 2 3 6 0.3 0.6 315 Notification of actual startup date 2 1 2 3 6 0.3 0.6 315

Notification of intent to conduct performance test e 2 1 2 16 32 1.6 3.2 1,682

Notification of date of CMS performance

evaluation f 2 1 2 16 32 1.6 3.2 1,682

Notification of compliance status 4 1 4 16 64 3.2 6.4 3,365 Periodic reports

– new source g 2 1 2 12 24 1.2 2.4 1,2 62

Subtotals Labor Burden and cost 4,548 227 455

23 9,113 TOTAL ANNUAL BURDEN AND COST (rounded) 5,230

Assumptions:



### a

. We have assumed that the average number of reporting respondents that will be su bject to this rule will be 3,991 during the r eporting period, which consists of 2,926 existing area sources, 626 existing major sources and an additional 297 new sources. The majority of these respondents, 3,145 , are not required to submit re ports

. 

### b

. The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $59.63 (GS

- 13, Step 5, $37.27 × 1.6), Technical rate of $47.20 (GS

- 12, Step 1, $29.50 × 1.6), and Clerical rate of $23.94 (GS

- 6, Step 3, $14.96 × 1.6). These rates are from the Office of Personnel Management (OPM), 2008 General Schedule, which excludes locality rates of pay.

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c

. We have assumed that this is a one

- time only activity for each facility.

d

. We have assumed that each respond ent will take two hours two times per year to complete the semiannual periodic reports.

e

. We have assumed that each of the respondents will take two hours once per year to complete requirements.

f

. We have assumed that the requirements do not apply to sou rces located outside of an urbanized area (UA)/urban cluster (UC) plus offset boundary.

g

. We have assumed that each respondent will take two hours o nce per year to review reports.