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 New Stationary Sources Oil and Natural Gas Production

and Natural Gas Transmission and Distribution ( 40 CFR part 60, subpart OOOO). This is a new

information colle ction request (ICR)

, and the EPA tracking number i s 1716.07.

(b) Short Characterization.

This ICR 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 catego ry which addressed VOC emissions 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,

locate d at onshore natural gas processing plants: a compressor in Volatile Organic Compound

(VOC) service or in wet gas service, and the groups of all equipment (except compr essors)

within a process unit. A process unit is defined as the equipment assembled for extraction of

natural gas liquids 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

- (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. Affected 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 provisions 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 m onitoring requirements of subpart 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 t he Clean Air Act, the

requirements 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 facilities: 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, transmission, 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 th e

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, tri bal or the

Federal government. All facilities are privately, owned fo r

- profit business es

. In general, 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, repo rts, 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 requ iremen ts in subpart OOOO for

these owner and operators that are subject to the Oil and Natural Gas Production, and Natural

Gas Transmission and Distribution NSPS is 561,785 person

- hours, with an annual average cost

of $ 18,805,398 . We expect three sweetening will have additional capital costs 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 C lean Air Act (CAA), as amended, 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 suc h 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 demonstr ated t echnology (BDT).

Section 111 also requires that the Administrator review and, if appropriate, revise such standards

every 8 years.

In addition, section 114(a) states that the Administrator may require any owner or operator subject to any requirement of this Act to:

 e stablish and 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 locat ions, at such intervals, during 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 c ompliance certifications in 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

A dministrator if there is no 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 identif y 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.

W h ere it has been deemed applicable

, the recordkeeping a nd reporting requirements for

this NSPS have been developed following the similar reporting requirements as outlined in

“Mandatory Reporting of Green house Gases : Subpart W Oil and Natural Gas ” in 40 CFR 98.2

and 40 CFR 98.4

. By remaining consistent with s u bpart W, we have attempted to reduce the

burden required t o monitor and show compliance. In addition, 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 loca l agency can be sent to the 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

- relate d ICR.

(c) Consultations.

In developing 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 environme ntal 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 an d maintain

these records for 2 years. 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 gu idelines established by OMB

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

-- Confidentiality 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 secti on is not applicable because this ICR 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 facilities as defined under the rule. The North American Industry

Classification System (NAICS) codes for the oil and gas industry include: 211111 ( Crude

Petroleum and Natural Gas Extraction ); 211112 ( Natural Gas Liquid Extraction ); 22 1210

( 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 well, 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)

Maint ain records of manufacturer 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 t ype of seal installed. 60.5420 (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 re ciprocating 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 eva luations, 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(l)(1), (2)

Keep records related to pressure relief valves ; number 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(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)

K eep 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)

A nnual reports including those of excess emissi ons. 60.5417(c); 60.487(c)(2)(i)

- (vi):

Performance test results. 60.487(e)

Annual report on excess emissions from and performance of continuous monitoring system, and/or summary report forms at processing plants 60.5423 (b)

(ii) Respondent Activiti es.

Respondent Activities

Read 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 p rocessing 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.7 Respondent Activities

Transmit, or otherwise disclose the information.

5. The Information Collected

– Agency Activities, Collection Methodology, and Information

Management

(a) Agency Activities.

The Agenc y activities associated with the 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

. Information

contained in the reports will be required to submit records electronically to EPA’s Central DATA

Exchange (CDX) using the Electro nic Reporting Tool. CDX enables 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 Info rmation 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 requ irements.

(c) Small Entity Flexibility.

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 int o consideration during the development 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 insur e

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 t he following labor rates: $33.51 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 priv ate 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 cost s 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 woul d be required to meet the

standards 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 normal 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

monitorin g cost estimated for subpart OOOO 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 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×C) (E)

Annual O&M

Costs for One Respondent a (F)

Number of

Res pondents

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 construction of the facility.9

The total capital/startup costs for this ICR are $219,000. This is the total of column D in

the above table.

The total operation and maintenance (O&M) costs for this ICR are $ 51,300 . 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 $ 270,300

.

(c) Estimating Agency Burden and Cost

. Because reporting and recordkeeping r equirements 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 the Compliance Data System, with the result that

no Federal costs can be d irectly attributed to the ICR. Examination of records to be maintained

by the respondents will occur incidentally as part of the periodic inspection of s ources that is part

of EPA’s overall compliance and enforcement program, and, therefore, i s not attributable to the

ICR. The only costs that the Federal government will incur are user costs associated with the

analysis of the reported information, as prese nted in Table 2.10

This cost is based 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 dollar s for this ICR 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

. It was estimated that an average of 1,459 operators per year will be subject to the

proposed subpart OOOO during the 3

- year period of this ICR

. 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, a nd Distribution NSPS, the

components of the total annual responses attributable to this ICR are notification of construction,

reconstruction and modification from 21,889 and annual reporting from 1,459 entities.

The number of total annual responses for su bpart 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)

Information 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

constructio n, reconstruction, or

modification 21,883 1 N/A 21,883

A nnual Compliance Reports 1,459 1 N/A 1,459

Total 23,342

1 We assume each facility will make t he appropriate notifications and t h 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 c lerical staff, and b y adding down the cost 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 561,785 person

- hours, with an annual average cost of $ 18,805,398.

(ii) The Agency tally. The average annual Federal Government cost is $ 1,188,916 for

26,006 hours for subpart OOOO . The bottom line Agency burden hours and costs pr esented 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

signi ficant variation is anticipated.12

(f) Reasons for Change in Burden.

This section does not apply because this is a new ICR.

(g) Burden Statement

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

is estimated to aver age 11 0 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 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 a ny 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 ag ency may not conduct or sponsor, and a person is not required to respond to, a

collection of information unless it displa ys 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 comme nt 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

- OAR

- 2010

. 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

information, submit or view public comments, access the index listi ng of the contents of the

docket, and to access 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

holidays. 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 th e Office of Information and Regulatory Affairs, Office of

Management and Budget, 725 17th Street, NW, Washington, DC 20503, At tention: Desk Officer

for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OAR

- 2010 in any

correspondence.

PART B

This secti on is not applicable because statistical methods 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

occurrence

per respondent

per year Person

hours per respondent

per year Respondent

s per year Technical

person
hours per

year Management

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 56,1 65 B. Required activities b

Notification of Construction/Reconstruction/Modification Completions/Recompletions/Workovers

c 0.5 29 14.5 21,489 311,591 15,580 31,159 11,994,832

Equipment Leaks at Processing Plants d 0.5 1 0.5 29 15 1 1 558

Centr ifugal Compressors e 0.5 1 1.0 30 30 2 3 1,155 Reciprocating Compressors f 0.5 1 1.0 256 256 13 26 9,855 Sweetening Units g 0.5 1 1.0 3 3 0 0 115 Storage Vessels h 0.5 1 1.0 76 76 4 8 2,926 Annual Report a 40 1 40.0 1,459 58,360 2,918 5,836 2,246,597

Required Activities Subtotal 371,789 18,589 37,179 14,312,203 427,557

C. Create information See 4B D. Gather existing information See 4B E. Write report See 4B 5. Recordkeeping Requirements

A. Read instructions See 5C

B. Plan activities See 5C C. Implement activities See 4B Filing and Maintaining Records i 80 1 80.0 1,459 116,720 5,836 11,672 4,493,19515

D. Develop record system See 5C

E. Time to enter information

Records of all information required by

standards See 5C

F. Train Personnel See 5C

I. Time for audits N/A

TOTAL ANNUAL BURDEN 488,509 24,425 48,851 18,805,398

561,785 N/A = Not Applicable. a We have assumed that the average n umber of respondents that will be subject to subpart OOOO will be 1,459 owners and operators. This is based on 741 exploration and production businesses, 139 transportation businesses and 579 processing plants. (Owners are assu med to submit one annual repo rt 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 management labor, and $2 3.43 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 publis hed 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 plant s will be constructed or modified each year within the 3 year period covered by this ICR that would be subject to the Equipment leak provisions (new sources previously regulated under Subpart KKK).

e

. This is based on 14 new centrifugal compressor in the transmission sector and 16 in the production would have to notify each year within the 3 year period covered by this ICR

f

. Each compressor represents and unit and multiple units will be located at a same facility based on the industry segment it is loca ted. We assume 5 units per respondent for gathering and boosting (210 units, 42 respondents), 2.5 units per respondent for processing (375 units, 150 respondents), 3.3 units per respondent in transmission (199 units, 61 respondents) and 3 units per respon dent in underground storage (9 units, 3 respondents).

g. We expect 3 new sweetening units per year (new sources previously regulated under Subpart LLL). h. We expect 4 storage vessels per respondent (304 new storage vessels, 76 respondents) over the thr ee year period covered by this ICR.

i. 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 STANDARDS

(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 Manageme

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 21,883 10,942 547 1,094 575,255

Annual Report 8 1 8.0 1,459 11,672 584 1,167 613,661

TOTAL ANNUAL BURDEN 22,614 1,131 2,261 1,188,916 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 production businesses, 139 tran sportation 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 su bmits its own report.

b The cost is based on the following labor rat e 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.