### 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 I CR Number 2440.02 , OMB Control Number 2060

- 0417

. **1(b) Short Characterization/Abstract** 
The amendments to this ICR are a result of the review of the existing NESHAP for Oil and Natural Gas Production (40 CFR p art 63, Subpart HH) as required b y 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 hazardous 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 ye ar; 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 are 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 I CR reflect the provision changes, an update in the cost of labor, and corrections to the number of affected facilities found in EPA I CR number 1788.09. The period considered in this I CR 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 regulated universe are based on data from the National Emissions Inventory (NE I) database

. O ver the three year period, we expect 363 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 ye ar period. The average annual burden from the recordkeeping and reporting requirements is 59 , 670 person hours, with an annual average cost of $ 1 , 997 , 402 and an annual capital cost of $2 23 , 954

. **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards 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 degree of emission reduction. In addition, section 114(a) states that the Administrator may require any o wner or operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall 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 reasonabl y 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 regulations which were promulgated in accordance with the Clean Air Act. Inaddition, 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 properl y installed and operated, that leaks are being detected and repaired, and that the standards are being met. The perform ance test may also be observed. 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 I CR is used by the Agency

to ensure that facilities affected by the NESHAP continues to operate the control equipment in compliance with the regulation.

### 4

**3. Non**
**- duplication, Consultations, and Other Collect** **ion Criteria 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 b y State or local agencies may duplicate information required b y this NESHAP. In these cases , a cop y of the report submitted to the S tate or local agency

can be sent to the Administrator in lieu of the report required b y the Federal standards. Th erefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submissi on 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 the 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 collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) General Guideline s** 
These 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.

### 5

These standards require the respondents to maintain all records , including reports and notifications for at least five years. This is consistent with the General Provision s as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the f ive

- ye ar 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 action. EPA has found that the most flagrant violators have violations extending beyond the five years. Without the five

- ye ar 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 i s made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (s ee 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 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. The North American Industry Clas sification System (NAICS) codes are 211112 for “Natural 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

### 6

reduce HAP emissions. In order to demo nstrate continuous compliance with the standards, certain facilities must use the continuous parameter monitoring s ys tems (CPMS). Although personnel at the affected facility

must still evaluate the data, internal automation has significantly reduced the burden 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/recon struct 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) majo r 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) are a 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)


### Noti fication of process change 63.775(f) 

### Semiannual excess emissions and continuous monitoring s ys tem 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 retention 63.10(b)(1), 63.774(b)(1)

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

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

- (ix) 

### Record related 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 gl yc ol dehydration units 63.764(e)(1), 63.774(d)(1) 

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

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

### Records of conditions for which gl yc ol 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 gl ycol dehydration unit operates under conditions for HAP reduction (alternative standards) 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 emissions, heat content, flow

- rate, exit velocity, pilot flame outages (flares onl y) 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 detection, 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 difficult

- 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 s ys tem performance 63.10(c)



### (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 inform ation. Adjust the existing way s 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 Collecte d: 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.

### 9

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

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

. Audit facility

records. M aintain data in the CDX
**5(b) Collection Methodology and Management**

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. The Central Data Exchange (CDX) enables f ast, 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 In fo 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 requirements. **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. Du e to technical considerations involving the process operations and the ty pes 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 requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. **5(d) Collection Schedule**
The specific frequency

f or each information collection activity w ithin 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)

### 10

**6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. 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 assumptions 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 59 , 670 ( 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 I CR 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 b een 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 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 ty pe of industry

costs associated with the inf ormation collection activities in the subject standard are labor costs which are addressed elsewhere in this IC R and the costs associated

### 11

with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regul ation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**
**Capital/Startup vs. Operation and Maintenan ce (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&Mb (G)

Total O&M, (E X F) Monitoring equipment (CMS) $1,015 1 38 $1 40 , 070 $134 626 $83,884 Total $1 40 , 070 $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 s ources have annual O&M costs.


### The total capital/startup costs for this I CR are $ 1 40 , 070 . This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 83,884

. This is the total of column G.
The avera ge annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the I CR is estimated to be $ 2 23 , 954

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is 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 collecte d information. The average annual Agency cost during the three years of the ICR is estimated to be $ 239,113

.

### 12

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

Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) 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 ben efit 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) (Revis ed). **6(d) Estimating the Responden t Universe and Total Burden and Costs** 
The number of area source respondents is derived from information in EPA I CR number and EPA I CR 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 analy sis to determine the MACT

. The number of respondents is calculated using the following table which addresses the 3 ye ars covered b y this ICR. Over the three ye ar period of this I CR, we expect 426 existing major source facilities to become new respondents. In addition, w e expect 43 new respondents to become subject over the three year period.

### 13

The total number of annual responses per ye ar is calcul ated using the following table:**Y E** **A R**  **(A) (B)**  **(C )**  **(E) (F)**  **(G)**

**Number of New Responde nts** 

**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 Subm** **it Records**  **Major Area**  **Area**

**Only Keep**  **Records Major**  **Area**



### 1 135 3 138 470 2,927 12 1 3,6 73 3,006 667 2 135 3 138 605 3,068 12 1 3,9 49 3,145 8 04 3 135 3 138 740 3,209 12 1 4,2 25 3,283 942 Avg 135 3 138 605 3 , 068 12 1 3 , 9 49 3,145 8 04

1 New respondents include sources with constructed or reconstructed affected facilities. 2 We assume that there are 141 new area sources and 1 35 new major sources for a total o f 27 6 new sources each year

. We estimate 12 1 of the new major sources are existing facilities , while 14 new major sources are at new fac ilities. 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 sources will maintain and submit reports

.

### 14

**Total Annual Responses (A)**  **Inform ation Collection Activity**  **(B) Number of**  **Respondents (C)** 

**Number of Responses**  **(D)**

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

**Total Annual**  **Responses E=(BxC)** 

**Major sources** Notific ation of construction/reconstruction 135 1 0 1 35 Notification of actual startup 135 1 0 135 Notification of date of CMS performance evaluation 135 1 0 135 Notification of date of performance test 135 1 0 135 Notification of compliance status report 135 1 0 135 Semiannual periodic report 782 2 0 1, 564 **Area sources** Notification of intent to construct 3 1 0 3 Notification of actual startup date 3 1 0 3 Notification of intent to conduct performance test 16 1 0 16 Notification of date of CMS performance 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, 308


### The number of Total Annual Responses is 2, 308

. The total annual labor costs are $ 1 , 997 , 402 for 59 , 670 labor hours

. Details regarding these estimates may

b e 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 Burd en Hou**  **rs Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respe ctivel y, and summarized below.

### 15 **(i) Respondent Tally**
The total annual labor hours are 59 ,670 . 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). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 2 6 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 burden and cost over next three ye ars is estimated to be 4,931 l abor hours at a cost of $ 2 25 , 444 . 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 I CR reflect the provision changes, an update in the cost of labor, and corrections to errors found in EPA I CR number 1788.09.

### 16

**6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 2 6 hour s per response. Burden means the total time, effort, or financial 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, acquire, install, and utilize technology and s ys tems 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 w ith any p rev iously

a pplicable 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 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 ’ 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 s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R 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 information, 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 identif ied in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and In formation 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 Information Center Docket is (202) 566

- 1752

. Also, yo u 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 D ocket ID Number EPA

- HQ

- OECA

- 2009

- 0388 and OMB

### 17

Control Number 2060

- 0417 in any correspondence.
**Part B of the Supporting Statement**
This part is not applicable because no statistical methods were used in collecting this information.

### Table 1: **Annual Respond ent 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)** 

**Responden ts**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 1 1 1 27 6 276 1 4 28 $ 1 0 , 625 b. Required activities N/A c. Create information N/A d. Gather existing information 2 1 1 27 6 5 52 28 5 5 $ 2 1 , 250 Major so urces i. Notification of construction/reconstruction 1 1 1 135 6 8 3 7 $2 , 598 ii. Notification of actual startup 1 1 1 135 68 3 7 $2,598 iii. Notification of date of CMS performance evaluation c 1 1 1 135 68 3 7 $2,598 iv. Noti fication of date of performance test 1 1 1 135 68 3 7 $2,598 v. Notification of compliance status report 4 1 4 1 35 540 27 54 $ 2 0 , 788 vii. Semiannual periodic report 4 2 8 7 40 5 , 920 296 592 $ 2 27 ,8 93 Area sources i. Notificati on of intent to construct 1 1 2 3 6 0 1 $ 231 ii. Notification of actual startup date 1 1 1 3 3 0 0 $ 115 iii. Notification of intent to conduct performance test c 1 1 2 1 5 3 0 2 3 $ 1 ,155 iv. Notification of date of CMS performance evaluation e 1 1 2 15 30 2 3 $1,155 v. Notification of compliance status 4 1 10 1 5 1 5 0 8 1 5 $5 , 774 vi. First periodic report c 4 1 4 3 12 1 1 $ 462 vii. Subsequent periodic reports c 2 1 2 12 24 1 2 $ 924 **Subtotal for Reporting Requirem ents**  **8 ,**  **985 $**  **3 00**  **, 765**  **4 Recordkeeping requirements** a. Read instructions

### 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)** 

**Responden ts**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b ($)** 

- Major source d 1 1 4 135 540 27 54 $ 2 0 , 788

- Area source d 1 1 4 141 564 28 56 $ 21,711 b. Plan activities

- Major source 16 1 16 1 35 2, 160 1 08 2 16 $83 , 1 5 0

- Area source i. Sources required to operate add

- on controls 16 1 16 1 5 2 40 1 2 2 4 $ 9, 239 ii. Sources required to implement MP 4 1 4 138 552 28 55 $ 21,250 c . Implement 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 1 5 1 80 9 1 8 $6,929 iii. Control equipment leak monitoring e 3 2 6 62 372 19 37 $ 14,320 iv. Operate and maintain CMS e, f 2 12 24 62 1,488 74 149 $ 57,281 d. Develop record system

- Major source i. Control equipment 8 1 8 1 35 1, 0 8 0 5 4 1 08 $ 4 1 , 575 ii. Equipment Inspection and M onitoring 13 1 13 7 40 9,620 481 962 $ 3 70 , 327

- Area source i. Control equipment 8 1 8 1 5 12 0 6 1 2 $ 4, 619 e. Time to enter information

- Major source i. Control equipment monitoring g, h 1 2 2 7 40 1,480 7 4 1 48 $5 6, 973 ii. Control device CMS g , h, i 1 12 12 7 40 8 , 880 444 888 $ 3 4 1, 840 iii. Equipment Inspection and Maintenance , h, i 1 12 12 7 40 8 , 880 444 8 88 $ 3 4 1, 840

- Area source i Co ntrol equipment leak monitoring e, j 1 2 2 62 124 6.2 12 $ 4,773 ii. CMS measurements e 1 12 12 62 744 37 74 $ 28,641 f. Time to train personnel

- Major source 8 1 8 135 1, 080 54 1 08 $ 4 1 , 575

- Area source k 16 1 1 6 15 240 12 2 4 $ 9, 239 g. Maintain records (area source) e, l 20 1 20 62 1,240 62 124 $ 47,734

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**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)** 

**Responden ts**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 m 1 1 1 3,145 3,145 157 314 $ 121,054 i. Retrieve records/reports n 20 1 20 62 1,240 62 124 $ 47,734 **Subtotal for Recordkeepin g Requirements**  **5 0**  **, 685**  **$ 1**  **, 696**  **, 637**  **4 4**  **, 074**  **2, 204**  **4, 407**  **TOTAL LABOR BURDEN AND COST (rounded)**  **59 ,**  **670 $1**  **, 997**  **, 402** 

**Assu mptions:** 

a We have assumed that the average number of reporting respondents that will be su bject to this rule will b e 3,9 4 9 during the reporting period , which consists of 3,068 existing area sources, 6 05 existing major sources and an additional 27 6 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 th e proposed rule. Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf
c We have assumed that the requirements do not apply to sources located outside of an urbaniz ed area (UA)/urban cluster (UC) plus offset boundary. d We have assumed that it will take each of the respondents four hours to read instructions.
e We have assumed that 50 existing area sources, and 12 new area sources (8 percent of area sources ) will co mp lete this activity. f We have assumed that it will take each respondent two hours twelve times per year to implement this activity. g We have assumed that it will take each of the respondents one hour to enter information. h We assume that all of the ma jor sources will each take one hour to enter information. i We have assumed that each respondent will be required to enter information twelve times per year. j We have assumed that each respondent will be required to enter information two times per year. k 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. l We have assumed that it will take 20 hours for each resp ondent to maintain records.
m We have assumed that all of the respondents that are subject only to the recordkeeping requirements will take one hour each year to process records of emissions.
n 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)**

**E PA**  **person**   ** hours** **per plant per year**  **(C=AxB) (D)** 

**Plants per**  **year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

Major source Initial noti fication c 2 1 2 135 270 14 27 $ 1 4 , 195 Preconstruction review application c 4 1 4 135 540 27 5 4 $ 2 8 , 391 Performance test notification c 2 1 2 135 270 14 27 $ 1 4 , 195 Compliance status notification c 4 1 4 135 540 27 5 4 $ 2 8 , 391 Semiannual periodic reports d 2 2 4 628 2,512 126 251 $ 132,070 Area sources Notification of intent to construct 2 1 2 3 6 0 1 $ 315 Notification of actual startup date 2 1 2 3 6 0 1 $ 315 Notification of intent to conduct performance test e 2 1 2 15 3 0 2 3 $ 1, 577 Notification of date of CMS performance evaluation f 2 1 2 15 30 2 6 3 $ 1, 577 Notification of compliance status 4 1 4 15 60 3 6 $3,155 Periodic reports

– new

source g 2 1 2 12 24 1 2 $ 1,262 **Subtotals Labor Burden and co st**  **4, 28**  **8 2**  **14 4**  **29 $**  **2 25**  **, 444**  **TOTAL ANNUAL BURDEN AND COST (rounded)**  **4 ,**  **931**

**Assu mptions:** 

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 reporting period, which consists o f 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 reports

. 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. c We have assumed that this is a one

- time only activity for each facility.

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d We have assumed that each respondent 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 sources 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.