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 Collection

(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 collection request (ICR), and the EPA tracking number is 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 category 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, 

located 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 compressors) 

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 -

SO2 Emissions- (0 CFR part 60, subpart LLL) were proposed on January 20, 1984, and 

promulgated 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 

followed by a sulfur recovery unit. Affected facilities commenced construction, modification, or 
2

reconstruction after the date of proposal. A sweetening unit is defined as a process device that 

separates the hydrogen sulfide and carbon dioxide (CO2) contents from 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 not 

released to the atmosphere. The control and monitoring 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 the Clean Air Act, the 

requirements of subpart KKK and subpart LLL would be contained in a new subpart, 40 CFR 60, 

subpart OOOO. The existing provisions of subparts KKK/LLL will be included in the new 

subpart OOOO along with 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, and 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 businesses. 

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, 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. The 

average annual burden for the recordkeeping and reporting requirements 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 section 111 of the Clean 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 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 years. 

In addition, section 114(a) states that the Administrator may require any owner or 

operator subject to any requirement of this Act to:

 establish 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 locations, 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 compliance 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 (state agency, or Regional 

Administrator if there is no delegated state agency) to ensure that the standards and other 

requirements are being achieved. Based on review of the recorded information at the site and the 
4

reported information, the delegated permitting authority can identify facilities that may not be in 

compliance and decide which facilities, records, or processes may need inspection.

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

Where 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 subpart W, we have attempted to reduce the 

burden required to 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 local 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-related 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 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 for 2 years. The proposed reporting frequency to EPA has been established to 

minimize the burden on owners and operators of affected facilities. 

(e) General Guidelines.

This collection of information is consistent with all OMB guidelines 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, Subpart 
5

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 section is not applicable because this ICR does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under subpart 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); 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 

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)

Maintain 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 type 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 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(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)

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.

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 Activities. 

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 processing and 

maintaining information.

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

providing information.

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

requirements.

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

EPA performed a screening analysis for impacts on a sample of expected affected small 

entities by comparing compliance costs to entity revenues. The impact on small entities (i.e., 

small businesses) was taken into 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 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: $33.51 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 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).

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 

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 

monitoring 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 

Respondents 

with O&M b

(G)

Total 

O&M,

(E×F)

SO2 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 SO2 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 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 incurred 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 directly attributed to the ICR. Examination of records to be maintained 

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

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

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

analysis of the reported information, as presented in Table 2.
10

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

Managerial $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 Personnel 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 ICR to be consistent 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. This 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 

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 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 4,377
11

The total number of annual responses per year is calculated using the following table.

Total Annual Responses

(A)

Information Collection 

Activity

(B)

Number of 

Respondents1 

(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

21,883 1 N/A 21,883

Annual Compliance 

Reports 1,459 1 N/A 1,459

Total 23,342

1 We assume each facility will make the appropriate notifications and that each owner will submit 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 by 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 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 ICR.

(g) Burden Statement

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

is estimated to average 110 hours per response. Burden means the total time, effort, or financial 

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

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

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

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

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

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

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

collection of information unless it displays a 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 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 listing of the contents of the 

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

When in the system, select “search,” then 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 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 Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 
13

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 Affairs, 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 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

Personhours per 

respondent 

per year

Respondent

s per year

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

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 a1 1 1.0 1,459 1,459 73 146 56,165

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 d0.5 1 0.5 29 15 1 1 558

Centrifugal Compressors e0.5 1 1.0 30 30 2 3 1,155

Reciprocating Compressors f0.5 1 1.0 256 256 13 26 9,855

Sweetening Units g0.5 1 1.0 3 3 0 0 115

Storage Vessels h0.5 1 1.0 76 76 4 8 2,926

Annual Report a40 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 i80 1 80.0 1,459 116,720 5,836 11,672 4,493,195
15

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 number 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 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 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 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 in 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 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 located. 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 respondent 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 three 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 

Personhours per 

occurrence

No. of 

occurrence

per 

respondent 

per year

EPA 

Personhours per 

respondent 

per year

Responses 

per year

Technical 

personhours per 

year

Manageme

nt personhours per 

year

Clerical 

personhours per 

year

Cost

($)

Activity (C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

Report Review

Notification of Construction, 

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 operators. This 

is based on 741 exploration and production 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 exception 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.