1 **SUPPORTING STATEMENT Standards of Performance for New Stationary Sources: Oil and Natural Gas Production**  **and Natural Gas Transmission and Distribution**  **( 40 CFR part 60, subpart OOOO).** 
**PART A**
**1.0 Identification of the Information C**  **ollection** (a) Title and Number of the Information Collection. Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution ( 40 CFR part 60, subpart OOOO). This is a new information collection request (ICR) , and the EP A tracking number i s 2437.02

. (b) Short Characterization. This I CR covers information collection requirements in the proposed new source rule for Oil and Natural Gas Production Facilities ( 40 CFR part 60 , subpart OOOO). The information collected will be used by

EPA and delegated state and local agencies to determine the compliance status of sources subject to the rule. On June 24, 1985 (50 FR 26122), EPA promulgated an NSPS for the Crude Oil and Natural Gas Production category which addressed VOC emission s from leaking equipment at onshore natural gas processing plants (40 CFR part 60, subpart KKK). These standards apply to the following affected facilities constructed, reconstructed/or modified after January 20, 1984, located at onshore natural gas proces sing plants: a compressor in Volatile Organic Compound (VOC) service or in wet gas service, and the groups of all equipment (except compressors) within a process unit. A process unit is defined as the equipment assembled for extraction of natural gas liqui ds from field gas, fractionation of liquids into natural gas products, or other processing of natural gas products

. The New Source Performance Standards (NSPS) for Onshore Natural Gas Processing

- SO 2 Emissions

- ( 4 0 CFR part 60, subpart LLL) were proposed on January 20, 1984, and p romulgated on October 1, 1985. These standards apply to the following affected facilities located at onshore natural gas processing plants: each sweetening unit, and each sweetening unit followe d by

a sulfur recovery

unit. Affect ed facilities commenced construction, modification, or2

reconstructi on after the date of proposal. A sweetening unit is defined as a process device that separates the hydrogen sulfide and carbon dioxide (CO **2** ) contents fro m the sour natural gas stream. The p rovisions of subpart LLL do not apply to sweetening facilities that produce acid gas that is completely

re - injected into oil or gas bearing geologic strata or that is otherwise n ot released to the atmosphere. The control and monitoring requirements of subp art LLL do not apply to affected facilities with design capacities of less than two long tons per day (LT/D) of hydrogen sulfide in the acid gas, expressed as sulfur. As part of the mandatory

review of NSPS as required under the Clean Air Act, the require ments of subpart KKK and subpart LLL would be contained in a new subpart, 40 CFR 60, sub part OOOO. T he existing provisions of subpart s KKK /LLL will be included in the new subpart OOOO along w ith the new proposed provisions for the following affected facili ties: gas wellheads, pneumatic controllers , centrifugal and reciprocating compressors, and storage vessels. The oil and natural gas sector includes operations involved in the extraction and production of oil and natural gas, as well as the processing, tra nsmission, an d distribution of natural gas. The potential respondents are owners or operators of oil and gas affected facilities found throughout these industry segments. All of the oil and natural gas facilities located in the United States are owned and operated by the oil and natural gas industry (the “Affected Public”). None of the facilities in the United States are owned or operated by state, local, tribal or the Federal government. All facilities are privately , owned for

- profit business es
. Ingene ral, all NSPS standards require initial notifications, performance tests, and periodic reports. Owners or operators are also required to maintain records of calculations and compliance determinations. These notifications, reports, and records are essential in determining compliance, and are required of all sources subject to NSPS. We estimate approximately 1,459 operators will be affected by subpart OOOO . T he average annual burden for the recordkeeping and reporting requirements in subpart OOOO for these o wner and operators that are subject to the Oil and Natural Gas Production, and Natural Gas Transmission and Distribution NSPS is 213 , 282 person - hours, with an annual average cost of $ 7 , 139 , 491 . We expect three sweetening will each have additional capital c osts for sulfur dioxide monitors of $73,000 and additional annual monitoring costs of 17,100 per year
.3

**2. Need For and Use of the Collection**  (a) Need/Authority for the Collection

. The EPA is charged under s ection 111 of the Clean Air Act (CAA), as ame nded, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality

health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every 8 ye ars. Inaddition, section 114(a) states that the Administrator may require any

owner or operator subject to any

requirement of this Act to:

 e stablish an d maintain such records;
 make such reports; (C) install, use, and maintain such monitoring equipment,
 and use such audit procedures, or methods;
 sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, d uring such periods, and in such manner as the Administrator shall prescribe);
 keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical;
 submit compliance certifications i n accordance with Section 114(a)(3); and
 provide such other information as the Administrator may reasonably

require. (b) Use/Users of the Data. The information will be used by the delegated authority ( s tate agency , or Regional Administrator if there is n o delegated s tate agency ) to ensure that the standards and other requirements are being achieved. Based on review of the recorded information at the site and the4

reported information, the delegated permitting authority can identify facilities that may

not be in compliance and decide which facilitie s, records, or processes may need inspection

. **3. Nonduplication, Consultations, and Other Collection Criteria**  (a) Nonduplication. Wh ere it has been deemed applicable , the recordkeeping and reporting requirements for this NSPS have been developed following the similar reporting requirements as outlined in “Mandatory

Reporting of Greenhouse Gases : Subpart W Oil and Natural Gas ” in 40 CFR 98.2 and 40 CFR 98.4

. By

remaining consistent with s ubpart W, we have attempted to reduce the burden required t o monitor and show compliance. Inaddition, 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 th e Administrator in lieu of the report required by

the Federal standards. Therefore , no duplication exists. (b) Public Notice Required Prior to ICR Submission to OMB. This section is not applicable because this is a rule

- related I CR. (c) Consultations. Indeveloping the proposed rule, EPA performed a comprehensive review of existing state rules and industry

standards , visited oil and natural gas sites, as well as consulted with individual companies, state agencies, and environmental groups. The main organizations that provided expert advice during the development of this rule include the Agency ’s industry experts. (d) Effects of Less Frequent Collection. Respondents must monitor all specified criteria at each affected facility and maintain these records f

or 2 ye ars. The proposed reporting frequency to EPA has been established to minimize the burden on owners and ope rators of affected facilities. (e) General Guidelines

. This collection of information is consistent with all OMB guidelines established by OM B at 5 CFR part 1320, section 1320.5. (f) Confidentiality. All information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart5

B

-- Conf identiality

of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by

43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). (g) Sensitive Questions. This section is not applicable becau se this I CR does not involve matters of a sensitive nature. **4. The Respondents and the Information Requested**  (a) Respondents/NAIC S Codes

. Potential respondents under s ubpart OOOO are owners or operators of new or modified oil and natural gas affected facil ities as defined under the rule. The North American Industry Classification System (NAI CS) codes for the oil and gas industry include: 211111 ( Crude Petroleum and Natural Gas Extraction); 211112 (Natural Gas Liquid Extraction); 221210 (Natural Gas Distribution ); 486110 ( Pipeline Distribution of Crude Oil ); 486210 ( Pipeline Transportation of Natural Gas ). (b) Information Requested. (i) Data Items, Including Recordkeeping Requirements.

**Recordkeeping** Maintain records from each completion operation including the location of the we ll, duration of gas capture, duration of flaring, duration of gas venting, and reasons for venting to occur in lieu of capture or flaring. 60.5420(b)(2) ; (c)(1) ; 60.5415 (2) (b)(1)(i)

- (ii ) ; (c)(1) Maintain records of manufacture r specification for each pneumatic controller, date device is installed, device location, electricity availability at location, and device utility. 60.5420 (b)(5); (c)(4) For each centrifugal compressor, maintain records on the type of seal installed. 60.5 420 (b)(3); (c)(2) Maintain records of rod packing baseline emissions and reductions achieved to reach the emissions limit for reciprocating compressors. Maintain records of date of replacement for each rod packing system for reciprocating compressors. 60. 5420 (b)(4); (c)(3) Maintain records of storage vessel emissions and reductions. Records related to storage vessel inspections including results of inspection. 60.5420 (b)(6); (c)(5) Keep records of measurements, performance evaluations, calibration checks , adjustments and maintenance related to continuous monitoring systems. 60.7(f) Keep records of parts of closed vent systems designated as unsafe or difficult to inspect. 60.632(a) ; 60.482

- 10 a (l)(1), (2) Keep records related to pressure relief valves ; numb er of pressure relief valves 60.5421(b) ; 60.5422(a)

- (c) Keep records of inspections of closed vent systems during which no leaks are detected. 60.632(a) ; 60.482

- 10 a (l)(4), (5)6

Perform attachment of identification numbers to leaking equipment. 60.5416(b )(1) Keep records of leak detection and repair. 60.5416(b)(2) Keep records of design requirements for and operation of closed vent systems and control devices. 60.635(a) ; 60.486(d) Keep records listing equipment. 60.635(a), (b) ; 60.486(e) Keep records of compliance tests. 60

. 635(a), 60.486(e)(4) Keep records of valves designated as unsafe or difficult to monitor. 60.635 (a); 60.486(f); 60.5417(b) Keep records of design criterion that indicate failure. 60.635(a); 60.486(h) Keep records of parts not in VOC service or otherwise exempt. 60.635(a),(c); 60.486(j) **Notifications and Reporting**  Notify the Administrator at least thirty days prior to a well completion operation. 60.5410(a) Submit an annual report for all wellhead, pneumatic, storage vessels and compressor affected facilities per operating entity. 60.5420(b) Notification of construction or reconstruction. 60.7(a)(1) Notification of initial performance test. 60.8(d) Annual reports including those of excess emissions. 6 0.5417(c); 60.487(c)(2) (i)

- (vi) Performance test results. 60.487(e) Annual report on excess emissions from and performance of continuous mo nitoring system, and/or summary report forms at processing plants 60.5423(b)

**(ii) Respondent Activities. Respondent Activities**  R ead instructions. Gather relevant information. Perform initial performance test and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining infor

mation. 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.7 **Respondent Activities** Transmit, or otherwise disclose the information.

**5.** The Information Collected

–Agency Activities, Collection Methodology , and Information Management (a) Agency Activities. The Agency

activities associated with th e proposed subpart OOOO are provided in Table 2 (located at the end of this supporting statement) and are introduced in section 6(c). (b) Collection Methodology and Management

. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs of the delegated permitting authority

. In formation contained in the reports will be required to submit records electronically to EPA’s Central DATA Exchange (CDX) using the Electronic Reporting Tool. CDX enable s fast, efficient and more accurate environmental data submissions from state and local governments, industry and tribes to the EPA and participating program offices. EPA's CDX is the point of entry on the Environmental Information Exchange Network (Exchange Network) for environmental data submissions to the Agency

. CDX works with both EPA program offices looking for a way to better manage incoming data, and stakeholders looking for a way to reduce burden from reporting requirements. (c) Small Entity F

lexibility. EPA performed a screening analysis for impacts on a sample of expected affected small entities by

comparing compliance costs to entity revenues. T he impact on small entities (i.e., small businesses) was taken into consideration during the deve lopment of the regulation. EPA nonetheless has tried to reduce the impact of this rule on small entities by the selection of highly cost

- effective controls and specifying monitoring requirements that are the minimum to insure compliance. (d) Collection Schedule

. The specific frequency

for each information collection activity within this request is shown in Table 1.8

**6. Estimating the Burden and Cost of the Collection**  (a) Estimating Respondent Burden. This ICR uses the following labor rates: $33.5 1 per hour for techn ical 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 f rom 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 ass ociated with the proposed rule ( Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf ). The annual burden estimates for the proposed subpart OOOO are shown in Table 2. These numbers were derived from estimates of new sources that would be required to meet the stand ards based on EPA’s experience with other standards. (b) Estimating Respondent Costs. The information collection activities for the proposed subpart OOOO are presented in Table 1. Because the data are already collected by

respondents as part of norma l operations , no respondent development costs are associated with the information collection activities. (i) Estimating Labor Costs

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

. The only monitoring cost estimated for subpart OO OO is the monitoring cost currently estimated in the existing provisions for subpart LLL, which are now incorporated into subpart OOOO. We do not estimate additional monitoring costs for the newly affected sources.

**Capital/Startup vs. Operation and Maint enance (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×C) (E)

Annual O&M Costs for One Respondent a (F)

Number of Respondents with O&M b (G)

Total O &M, (E×F) SO 2 CEM, control outlet (only for subpart LLL) $73,000 3 $219,000 $17,100 3 $ 51,300 **Assumptions:**
a Costs reflect installation and maintenance of an in

- situ SO 2 CEM after the control device and assume installation occurred during the constructi on of the facility.9

The total capital/startup costs for this I CR are $219,000. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 51,300 . This is the total of column G. The average annu al cost for capital/startup and operation and maintenance costs to industry over the next three years of the I CR is estimated to be $ 270,300

. (c) Estimating Agency Burden and Cost

. Because reporting and recordkeeping requirements on the part of the respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the part 60 NSPS General Provisions, no operational costs will be incur red by the Federal Government. Publication and distribution of the information are part of th e Compliance Data System, with the result that no Federal costs can be d irectly attributed to the I CR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sources that is part of EPA’s ov erall compliance and enforcement program, and, therefore, i s not attributable to the IC R. The only

costs that the Federal government will incur are user costs associated with the analysis of the reported information, as presented in Table 2.10

This cost is b ased on the average hourly labor rate as follows: Manag erial $59.63 (GS

- 13, Step 5, $37.27 + 60%) Technical $47.20 (GS

- 12, Step 1, $29.50 + 60%) Clerical $23.94 (GS

- 6, Step 3, $14.96 + 60%) These rates are from the Office of P ersonnel Management (OPM), 2008 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. Costs have been estimated in 2008 dollars for this I CR to be cons istent with other costs (i.e. control devices) estimated in the development of subpart OOOO. (d) Estimating the Respondent Universe and Total Burden and Costs

. Itwas estimated that an average of 1,459 operators per year will be subject to the proposed subpart OOOO during the 3

- ye ar period of this I CR

. T his value encompasses the number of processing plants that we expect will submit reports separately as its own entity

. For the Crude Oil and Natural Gas Production, Transmission, and Distribution NSPS, the compo nents of the total annual responses attributable to this I CR are notification of construction, reconstruction and modification from 741 and annual reporting from 1,459 entities. The number of total annual responses for subpart OOOO is estimated as: 4,337 total respondents over the three year period.

**Year Annual Number of Respondents**  1 1,459 2 1,459 3 1,459 Total 4,37711

The total number of annual responses per year is calcu lated using the following table.
**Total Annual Responses**
(A)
In formation Collection Activity (B)

Number of Respondents 1 (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+D

Notification of construction, reconstruction, or modification 773 1 N/A 773 Annual Compliance Reports 1,459 1 N/A 1,459 Total 2, 2 32 1 We assume each facility will make the appropriate notifications and th at each owner will sub mit the annual report for all affected sources in each year.
(e) Bottom Line Burden Hours and Cost Tables. (i) Respondent tally. The bottom line respondent burden hours and costs, presented in Table 1 are calculated by

adding person

- hours per year down each column for technical, managerial, and clerical staff, and b y adding down the cos t column. The average annual burden for the recordkeeping and reporting requirements in subpart OOOO for the 1,459 owners and operators that are subject to the Crude Oil and Natural Gas Production, Transmission, and Distribution NSPS is 213 , 282 person - hour s, with an annual average cost of $ 7 , 139 , 491

. (ii) The Agency tally. The average annual Federal Government cost is $ 633,982 for 13 , 867 hours for subpart OOOO . The bottom line Agency burden hours and costs presented in Table 2 are calculated by

adding person - hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column. (iii) Variations in the annual bottom line. This section does not apply since no significant variation is anticipated.12

(f) Reasons for Change in Burden. This section does not apply because this is a new I CR. (g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 96 hours per response

. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, or disclose or provide informati on to or for a Federal agency

. This includes the time needed to review instructions; develop, acquire, install, and utilize techno logy 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 valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 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 I CR under Docket ID Number EPA

- HQ

- OAR

- 2010

. An el ectronic 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 information, submit or view public comments, access the index listing of the contents of the docket, and to acce ss those documents in the public docket that are available elect ronically

. When in the system, select “search,” then key in the docket ID numbe r 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 Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Fri day , excluding legal hol idays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone13

number for the Enforcement and Compliance Docket and Information Center is (202) 566

- 1752. Also, you can send comments to the Office of Information and Regulatory Affair s, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OAR

- 2010 in any correspondence.

**PART B** This section is not applicable because statistical meth ods are not used in data collection associated with the final rule.14

**TABLE 1. ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE PROPOSED STANDARD**  **(A) (B)**  **(C) (D)**  **(E) (F)**  **(G) (H)**  Person

- hours per occurrence No. of

occ urrence per respondent per year **Person**
 

** hours per** **respondent per year**  **Respondent**

**s per year**  **Technical**

**person**   ** hours per** **year Managem**  **ent**

**person -**  **hours per year**  **Clerical**

**person**   ** hours** **per year Cost** 

**($)**

**(C=AxB) (E=C**  **x D)**  **(E x**  **0.05) (E**  **x 0.1)**  1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, & Utilization of Tech. & Systems N/A 4. Reporting Requirements A. Read instructions a 1 1 1.0 1,459 1,459 73 146 $ 56,165 B. Required activities b Notifi cation of Construction/Reconstruction/Modification

Completions/Recompletions c 1.0 12 1 2.0 741 8 , 892 445 889 $342,302 Equipment Leaks at Processing Plants d 1.0 1 1.0 29 29 1 3 $1,116

Sweetening Units e 1.0 1 1.0 3 3 0 0 $ 115 Annual Report a 40 .0 1 40. 0 1,459 58,360 2,918 5,836 $ 2,246,597 **Required Activities Subtotal 68**  **,7 43**  **3 ,**  **437 6**  **, 874**  **$2 ,**  **646 ,**  **296 79**  **, 054**  C. Create information See 4B D. Gather existing information See 4B E. Write report See 4B 5. Recordkeeping Require ments A. Read instructions See 5C B. Plan activities See 5C C. Implement activities See 4B Filing and Maintaining Records f 80 1 80.0 1,459 116,720 5,836 11,672 $ 4,493,195 D. Develop record system See 5C E. Time to enter information Records of all information required by standards See 5C15

F. Train Personnel See 5C I. Time for audits N/A **TOTAL ANNUAL BURDEN 185**  **, 463**  **9 ,**  **273 18**  **, 546**  **$7 ,**  **139 ,**  **491 561,785**  N/A = Not Applicable.
a We have assumed that the average number of respondents that will be subject to subpart OOOO will be 1,459 owners and operator s. This is based on 741 exploration and production businesses, 139 transportation businesses and 579 processing plants. (Owners are assumed to submit one annual report for all affected facilities within the year. We expect processing plant submit separate reports per facility

. b This ICR uses the following labor rates: $33.51 per hour for technical labor, $52.85 per hour for manageme nt 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 privat e 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 represent s the state of the industry in 2008, consistent with the control costs associated with the proposed rule. Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf
c This assumes that 741 operators perform 29 completion and/or workovers i n the three year period covered by this ICR. We have assumed 9,313 completions with hydraulic fracturing and 12,050 recompletions with hydraulic fracturing occur each year. d We expect 29 processing plants will be constructed or modified each year within the 3 year period covered by this ICR that wo uld be subject to the Equipment leak provisions (new sources previously regulated under Subpart KKK).
e We expect 3 new sweete ning units per year (new sources previously regulated under Subpart LLL). f We have assumed that each respondent (operators) will take 80 hours to file and maintain records.16

**TABLE 2. ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT OF THE PROPOSED ST**  **ANDARDS** (A) (B) (C) (D) (E) (F) (G) (H) EPA Person

hours per occurrence No. of

occurrence per respondent per year **EPA**

**Person**
  ** hours per** **respondent per year**  **Responses**

**per year Technical** 

**person**   ** hours per** **year Managem**  **e**

**nt person**   ** hours per** **year Clerical** 

**person**   ** hours per** **year Cost** 

**($)** Activity (C=AxB) (E=CxD) (Ex0.05) (Ex0.1) Report Review Notification of Constr

uction, Reconstruction or Modification c 0.5 1 0.5 773 387 19 39 $20,320 Annual Report 8 1 8.0 1,459 11,672 584 1,167 $ 613 ,661 **TOTAL ANNUAL BURDEN 22,614**  **1,131 2,261**  **$633,982 26,006** 

a We have assumed that the average number of respondents that will be subject to subpart OOOO will be 1,459 owners and operator s. This is based on 741 exploration and prod uction businesses, 139 transportation companies and 579 processing plants. (Owners are assumed to submit one annual report for all affected facilities within the year with the excep tion that a processing plant submits its own report. 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

.