SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution 

(40 CFR Part 60, Subpart OOOO) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution (40 

CFR Part 60, Subpart OOOO) (Renewal), EPA ICR Number 2437.03, OMB Control Number 

2060-0673.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations published at 40 CFR

Part 60, Subpart OOOO were proposed on August 23, 2011 (76 FR 52737), promulgated on

August 16, 2012 (77 FR 49489), and recently amended on September 23, 2013 (78 FR 58415) 

and December 31, 2014 (79 FR 79017). The amendments provided clarification on notification 

and compliance dates and key definitions and addressed technical errors inadvertently included 

in the final rule; they did not modify rule reporting and recordkeeping requirements.

The regulations published at 40 CFR Part 60, Subpart OOOO apply to oil and natural gas 

facilities that commence construction, modification or reconstruction after August 23, 2011, and 

that are involved in the extraction and production of oil and natural gas, as well as the 

processing, transmission, and distribution of natural gas. The rule also incorporates the 

requirements of 40 CFR Part 60, Subparts KKK and LLL, which were added to reflect the eight 

year review EPA conducted on its oil and natural gas production and natural gas transmission 

and storage standards under section 111(b)(1)(B). Subparts KKK and LLL apply to onshore 

natural gas processing plants constructed, reconstructed, or modified after January 20, 1984 and 

on or before August 23, 2011. This information is being collected to assure compliance with 40 

CFR Part 60, Subpart OOOO.

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

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of all calculations and compliance determinations. These notifications, reports, 

and records are essential in determining compliance, and are required of all affected facilities 

subject to NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the appropriate EPA regional office and 

to the delegated state or local authority, with the exception of the advance well completion 

notifications. For advance well completion notifications, if you are subject to state regulations 

that require advance notification of well completions and you have met those notification 

requirements, then you do not have to submit the advance well completion notification to the 
2

EPA regional office. In the event that there is no such delegated authority, the reports are sent 

only to the United States Environmental Protection Agency (EPA) regional office.

The term “Affected Public” applies to oil and natural gas production, natural gas 

transmission, and natural gas distribution facilities, and may be found in Table 1: Annual 

Respondent Burden and Cost – NSPS for Oil and Natural Gas Production and Natural Gas 

Transmission and Distribution (40 CFR Part 60, Subpart OOOO) (Renewal). None of the 

facilities are owned by state, local, tribal, or the Federal government. All are owned and 

operated by privately-owned, for-profit businesses. The burden to the “Federal Government” 

burden is attributed entirely to work performed by federal employees or government contractors, 

and may be found in Table 2: Average Annual EPA Burden and Cost – NSPS for Oil and Natural 

Gas Production and Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart 

OOOO) (Renewal).

Over the next three years, approximately 564 respondents per year will be subject to the 

standard, and 32 additional respondents per year will become subject to the standard. The 564 

existing sources comprise 300 exploration and production businesses, 136 transmission and 

storage operations, 116 processing plants, and 12 sweetening units. The 32 new sources 

comprise 29 processing plants and 3 sweetening units. These estimates are derived from Agency

information gathered during rule development. During the renewal of this ICR, EPA also 

reviewed the Green House Gas Reporting Program (GHGRP) inventory, for which there is 

significant overlap with sources subject to this ICR. In comparing GHGRP data for the industry

sectors relevant to this ICR, EPA found good overall agreement with the number of subject 

sources estimated for this ICR.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

2. Need for and Use of the Collection

2(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
3

four years. In addition, Section 114(a) states that the Administrator may require any 

owner/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 prescribe); (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

reasonably require.

In the Administrator's judgment, VOC and sulfur dioxide emissions from oil and natural 

gas production, natural gas transmission, and natural gas distribution facilities cause or 

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

welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, 

Subpart OOOO.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures compliance with 

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also 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.

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 check if pollution control devices are properly installed 

and operated and that the standard is being met. The performance test may also be observed.

The required annual and semiannual reports are used to determine periods of excess 

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

compliance determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 60, Subpart 

OOOO.
4

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its 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.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is the Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data.

Industry trade associations and other interested parties were provided with an opportunity

to comment on the burden associated with the standard when it was being developed and further 

amended, and the standard has been previously reviewed to determine the minimum information 

needed for compliance purposes. For the current renewal, EPA contacted both the Independent 

Petroleum Association of America (IPAA) at (202) 857-4722 and America’s Natural Gas 

Alliance (ANGA)/American Exploration and Production Council at (202) 789-2642.

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 by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.
5

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, 

Subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators 

of new or modified oil and natural gas facilities. The United States Standard Industrial 

Classification (SIC) codes and corresponding North American Industry Classification System 

(NAICS) codes for respondents affected by the standard are listed in the following table.

Standard (40 CFR Part 60, Subpart 

OOOO)

SIC Codes NAICS Codes

Crude Petroleum and Natural Gas 

Extraction

1311 211111

Natural Gas Liquid Extraction 1321 211112

Natural Gas Distribution 4923, 4924, 4925, 4931, 

4932, 4939

221210

Pipeline Distribution of Crude Oil 4612 486110

Pipeline Transportation of Natural Gas 4922, 4923 486210

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NSPS for Oil and 

Natural Gas Production and Natural Gas Transmission and Distribution (40 CFR Part 60, 

Subpart OOOO).
6

A source must make the following notifications and reports:

Notifications and Reporting

Notification of date of construction or reconstruction (for equipment 

groups within a process unit and sweetening units at onshore natural 

gas plants only)

60.7(a)(1)

Notification of date of actual startup (for equipment groups within a 

process unit and sweetening units at onshore natural gas plants only)

60.7(a)(3)

Notification of physical or operation change (for equipment groups 

within a process unit and sweetening units at onshore natural gas 

plants only)

60.7(a)(4)

General notification and reporting requirements (for equipment 

groups within a process unit and sweetening units at onshore natural 

gas plants only)

60.19

Initial notifications (for equipment groups within a process unit and 

sweetening units at onshore natural gas plants only)

60.5420(a)(1)

Notify the Administrator at least two days prior to a well completion 

operation.

60.5410(a); 

60.5420(a)(2)

Annual report 60.5420(b)

Semiannual report for onshore natural gas processing plants 60.5422(b-c)

Notification of initial performance test. 60.8(d)

Annual reports including those of excess emissions. 60.5417(c); 

60.487a(c)(2)(i)-(vi)

Performance test results. 60.8(a), 

60.5420(b)(7), 

60.5420(b)(8), 

60.487a(e)

Annual report on excess emissions from and performance of 

continuous monitoring system, and/or summary report forms at 

onshore natural gas processing plants

60.5423(b)

A source must keep the following records:

Recordkeeping

For each gas well, maintain records identifying each well completion 

operation.

60.5420(b)(2);

(c)(1)(i)

For each gas well, maintain records of deviations in cases where well 

completion operations with hydraulic fracturing were not performed 

in compliance with 60.5375. 

60.5420(b)(2); 

(c)(1)(ii)

For each gas well, maintain records from each completion operation,

including the location of the well; the American Petroleum Institute 

(API) well number; the date and time of the onset of flowback 

60.5420(b)(2); 

(c)(1)(iii)
7

Recordkeeping

following hydraulic fracturing or refracturing; the date and time of 

each attempt to direct flowback to a separator; the date and time of 

each occurrence of returning to the initial flowback stage; and the date 

and time that the well was shut in and the flowback equipment was 

permanently disconnected, or the startup of production; the duration 

of flowback; duration of recovery to the flow line; duration of 

combustion; duration of venting; and specific reasons for venting in 

lieu of capture or combustion.

For each gas well, maintain a record of an exception claim under 

60.5375(a)(3), including the location of the well; the API well 

number; the specific exception claimed; the starting and ending dates

for the period the well operated under the exception; and an 

explanation of why the well meets the claimed exception.

60.5420(b)(2); 

(c)(1)(iv)

For each gas well, maintain a record of the digital photograph, if 

applicable.

60.5420(b)(2); 

(c)(1)(v)

For each centrifugal compressor, maintain records of identification of 

each centrifugal compressor which became affected during the 

reporting period, deviations in cases where the centrifugal compressor 

was not operated in compliance.

60.5420(b)(3); (c)(2)

For each reciprocating compressor, maintain records of cumulative 

number of hours of operation or number of months since initial 

startup, record of the time and date of rod packing replacement, 

records of deviations in cases where the reciprocating compressor was 

not operated in compliance.

60.5420(b)(4); (c)(3)

For each pneumatic controller, maintain records for, identification 

(date, location and manufacturer) of each pneumatic controller which 

became affected during the reporting period, device location, 

manufacturer specifications, records of reasons why pneumatic 

controllers with a bleed rate of greater than 6 scf/hr are required.

60.5420(b)(5); (c)(4)

Maintain records of storage vessel emissions and reductions. Records 

related to storage vessel inspections including results of inspection.

60.5420(b)(6); (c)(5)

Records of each closed vent system inspection required for centrifugal 

compressors or storage vessels.

60.5420(c)(6)

Records of each cover inspection required for centrifugal or 

reciprocating compressors or storage vessels.

60.5420(c)(7)

Records of each inspection, key checkout, or alarm sounding required 

for centrifugal or reciprocating compressors.

60.5420(c)(8)

Records of closed vent system monitoring required for centrifugal or 

reciprocating compressors.

60.5420(c)(9)

Records of carbon replacement schedule required for centrifugal 

compressors.

60.5420(c)(10)

Records of minimum and maximum operating parameter values, 60.5420(c)(11)
8

Recordkeeping

continuous parameter monitoring system data, calculated averages of 

continuous parameter monitoring system data, results of all 

compliance calculations, and results of all inspections for each 

centrifugal compressor.

Records of carbon replacement required for storage vessels. 60.5420(c)(12)

Records of inspections, manufacturers' operating instructions, 

procedures and maintenance schedule, and EPA Method 22 test 

results for storage vessels.

60.5420(c)(13)

Records of calculations and measurements required for sweetening 

units, including records retention two years for onshore natural gas 

processing plants.

60.5423(a)

Record of analysis demonstrating the source’s design capacity is 

below applicable limits, including retention for the life of the facility

for onshore natural gas processing plants.

60.5423(c-d)

Keep records of measurements, performance evaluations, calibration 

checks, adjustments and maintenance related to continuous 

monitoring systems for onshore natural gas processing plants.

60.7(f)

Keep records of parts of closed vent systems designated as unsafe or 

difficult to inspect for onshore natural gas processing plants.

60.482-10a(l)(1), (2)

Keep records related to pressure relief valves; number of pressure 

relief valves for onshore natural gas processing plants.

60.5421(b); 

60.5422(a)-(c)

Keep records of inspections of closed vent systems during which no 

leaks are detected for onshore natural gas processing plants.

60.632(a); 60.482-

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

Perform attachment of identification numbers to leaking equipment

for onshore natural gas processing plants.

60.5416(b)(1)

Keep records of leak detection and repair for onshore natural gas 

processing plants.

60.5416(b)(2)

Keep records of design requirements for and operation of closed vent 

systems and control devices for onshore natural gas processing plants.

60.486(d)

Keep records listing equipment for onshore natural gas processing 

plants. 

60.486a(e)

Keep records of compliance tests for onshore natural gas processing 

plants..

60.486a(e)(4)

Keep records of valves designated as unsafe or difficult to monitor for 

onshore natural gas processing plants.

60.486a(f); 

60.5417(b)

Keep records of design criterion that indicate failure for onshore 

natural gas processing plants. .

60.486a(h)

Keep records of parts not in VOC service or otherwise exempt for 

onshore natural gas processing plants.

60.486(j)

Electronic Reporting
9

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs of the Administrator. 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.

Some of the respondents are using monitoring equipment that automatically records 

parameter data. 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. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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.

Transmit, or otherwise disclose the information.
10

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The annual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve, and analyze the data.

The records required by this regulation must be retained by the owner/operator for two 

years.
11

5(c) Small Entity Flexibility

During the development of this standard, 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. The Agency considers these to be the 

minimum requirements needed to ensure compliance and, therefore, cannot reduce them further 

for small entities. To the extent that larger businesses can use economies of scale to reduce their 

burden, the overall burden will be reduced.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Oil and Natural Gas 

Production and Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart OOOO) 

(Renewal).

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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information 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 Control 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 93,900 (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 NSPS program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 
12

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the information collection activities in the 

subject standard is both labor costs, which are addressed elsewhere in this ICR, and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance (O&M) costs 

are the ongoing costs to maintain the monitor(s) and other costs such as photocopying and 

postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs

(A)

Continuous 

Monitoring Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent1

(F)

Number of 

Respondents 

with O&M

(G)

Total 

O&M,

(E X F)

SO2 CEMS 

(control outlet)

$73,000 3 $219,000 $17,100 15 $256,500

Continuous control 

device monitoring 

for centrifugal 

compressors 2

N/A 13 $0 $804 65 $52,260

Continuous control 

device monitoring 

for storage vessels 2

N/A 304 $0 $804 1,520 $1,222,080

Total (rounded) 3$219,000 $1,530,000

1 Annual O&M costs for centrifugal compressors and storage vessels were calculated assuming 2 hours per month 

at $33.51 per hour.

2 Capital/Startup costs for continuous control device monitoring were included in storage vessel and centrifugal 

compressor control device costs.

3 Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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

the above table. 
13

The total operation and maintenance (O&M) costs for this ICR are $1,530,000. 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 $1,750,000. These are 

recordkeeping costs.

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall 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 distribution of collected information. 

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

$476,000.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 General Schedule,

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

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

based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Oil and 

Natural Gas Production and Natural Gas Transmission and Distribution (40 CFR Part 60, 

Subpart OOOO) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

564 existing respondents will be subject to the standard. The 564 existing sources comprise 300 

exploration and production businesses, 136 transmission and storage operations, 116 processing 

plants, and 12 sweetening units. It is estimated that an additional 32 respondents per year will 

become subject and will comprise 29 processing plants and 3 sweetening units. The overall 

average number of respondents, as shown in the table below, is 596 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
14

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 32 532 0 0 564

2 32 564 0 0 596

3 32 596 0 0 628

Average 32 564 0 0 596

1

New respondents include sources with constructed, reconstructed, and modified affected facilities. In this 

ICR, existing respondents also submit initial notifications for new affected facilities at existing respondent sites.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 596. 

It is important to note that some annual responses and associated burdens in this ICR are 

specific to the number of affected units at respondents’ sites. Where appropriate, EPA has 

determined burdens based on the number of units associated with existing and new respondents. 

The following table summarizes the values used by EPA to estimate the burden presented in this 

ICR. These values are derived from Agency information gathered during rule development. 

EPA also reviewed the Green House Gas Reporting Program (GHGRP), for which there is 

significant overlap with sources subject to this ICR. In comparing GHGRP data for the industry

sectors relevant to this ICR, EPA found good overall agreement with the number of subject 

sources estimated for this ICR.

Affected Units at Respondent Sites

(A)

Affected Unit

(B)

Affected Sources

(C)

Number of Existing 

Units at Affected 

Sources

(D)

Number of New 

Units at Affected 

Sources

Centrifugal compressors Processing plants 52 13

Reciprocating 

compressors

Gathering & boosting stations 840 210

Processing plants 836 209
15

Affected Units at Respondent Sites

(A)

Affected Unit

(B)

Affected Sources

(C)

Number of Existing 

Units at Affected 

Sources

(D)

Number of New 

Units at Affected 

Sources

Pneumatic controllers

Exploration & production sites 13,632 0

Processing plants 60 15

Storage vessels Production, processing, 

transmission, or storage

1,216 304

Total 16,636 751

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

Notifications

Gas well completion 300 33 0 9,900

Gas well recompletion 300 4 0 1,200

New gas processing plant 29 1 0 29

New sweetening unit 3 1 0 3

Annual reports

Gas well 

completion/recompletion

300 1 0 300

Centrifugal compressor 65 1 0 65

Reciprocating compressor 2,095 1 0 2,095

Sweetening unit 15 1 0 15

Production pneumatic 

controller

300 1 0 300

Gas processing pneumatic 

controller

75 1 0 75

Storage vessel 380 1 0 380

Semiannual reports

Gas processing plant 145 2 0 290

Total 14,652
16

1 Column B is based on either the number of respondents or the number of affected units, as appropriate for the 

given information collection activity. The number of respondents and affected units are provided above.

The number of Total Annual Responses is 14,652.

The total annual labor costs are $9,450,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NSPS for Oil and Natural Gas 

Production and Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart OOOO) 

(Renewal).

6(e) Bottom Line 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 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 93,900. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost – NSPS for Oil and Natural Gas Production and 

Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart OOOO) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies, and maintain records.

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

information is estimated to average 6 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $1,750,000. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is estimated to be

10,400 labor hours at a cost of $476,000. See Table 2: Average Annual EPA Burden and Cost –

NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution (40 

CFR Part 60, Subpart OOOO) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies, and maintain records.
17

6(f) Reasons for Change in Burden

There is an increase in the total estimated respondent burden and total annual O&M as 

currently identified in the OMB Inventory of Approved Burdens. This burden increase is due to 

adjustments EPA has made to account for industry growth that has occurred since the ICR was 

last approved. EPA has also updated corresponding labor costs to reflect current rates referenced 

from the Bureau of Labor Statistics. EPA has similarly adjusted the Agency labor burden to 

reflect industry growth over the past three years and has updated labor costs to reflect rates 

referenced from the Office of Personnel Management.

EPA has also revised the respondent burden associated with compressor notifications and 

storage vessel annual reports. The previous ICR assumed respondents would submit initial 

notifications for affected centrifugal and reciprocating compressors. These sources, however, are 

not subject to initial notification requirements, thus we have removed them from the burden 

calculations. For storage vessels, the previous ICR assumed respondents would complete an 

individual report for each affected storage vessel. The rule, however, allows respondents to 

submit a single report for all affected storage vessels at their site. EPA’s experience has been 

that respondents typically consolidate reporting activities in order to reduce the overall reporting 

burden. For this reason, we have revised the burden calculations to assume each respondent will 

submit a single report.

6(g) Burden Statement

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

is estimated to average 6 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-OECA-2014-0102. 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 
18

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 

number for the docket center is (202) 566-1927. 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-OECA-2014-0102 and OMB Control Number 2060-0673 in any

correspondence. 

Part B of the Supporting Statement

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

information.
19

Table 1: Annual Respondent Burden and Cost – NSPS for Oil and Natural Gas Production and Natural Gas Transmission and 

Distribution (40 CFR Part 60, Subpart OOOO) (Renewal)

Burden item

A B C D E F G H

Personhours per 

occurrence

Annual 

occurrences

per 

respondent

Person-hours

per respondent

per year (AxB)

Respondents

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours

per year

(Ex0.10)

Annual cost

($) b

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, installation, and utilization 

of technology and systems

N/A

4. Report requirements N/A

a. Familiarization with the rule 

requirements c

1 1 1 596 596 29.8 59.6 68,924.72

b. Required activities

i. Notification of gas well 

completion d

0.5 33 17 300 4,950 247.5 495 572,445.23

ii. Notification of gas well 

recompletion d

0.5 4 2 300 600 30 60 69,387.3

iii. Notification of new gas 

processing plant e

1 1 1 29 29 1.45 2.9 3,353.72

iv. Notification of new sweetening 

unit f

1 1 1 3 3 0.15 0.3 346.94

c. Create information See 4B

d. Gather existing information See 4E

e. Annual reports

i. Gas well completion/

recompletion d

16 1 16 300 4,800 240 480 555,098.4

ii. Sweetening unit f1 1 1 15 15 0.75 1.5 1,734.68

iii. Centrifugal compressor g8 1 8 65 520 26 52 60,135.66

iv. Reciprocating compressor h8 1 8 2,095 16,760 838 1,676 1,938,218.58

v. Production pneumatic controller i8 1 8 300 2,400 120 240 277,549.2
20

Burden item

A B C D E F G H

Personhours per 

occurrence

Annual 

occurrences

per 

respondent

Person-hours

per respondent

per year (AxB)

Respondents

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours

per year

(Ex0.10)

Annual cost

($) b

vi. Gas processing pneumatic 

controller j

8 1 8 75 600 30 60 69,387.3

vii. Storage vessel k8 1 8 380 3,040 152 304 351,562.32

f. Semiannual reports

i. Gas processing plant l40 2 80 145 11,600 580 1,160 1,341,487.8

Reporting Subtotal 52,799 5,309,632

5. Recordkeeping requirements

a. Read instructions See 4A

b. Plan activities See 4B

c. Implement activities

i. Filing and maintaining records l5 12 60 436 26,160 1,308 2,616 3,025,286.28

ii. Filing and maintaining records m5 12 60 160 9,600 480 960 1,110,196.8

d. Record data N/A

e. Time to transmit or disclose 

information

i. Records required by standards See 5C

f. Time to train personnel See 5C

g. Time for audits N/A

Recordkeeping Subtotal 41,124 4,135,483

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 93,900 9,450,000

TOTAL ANNUAL CAPITAL AND O&M COST (SEE SECTION 6(b)(iii)) 1,750,000

GRAND TOTAL (LABOR, CAPITAL, AND O&M) 11,200,000

N/A - Not Applicable

Note: Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

Assumptions:

a

 EPA estimates an average of 564 existing sources and 32 new sources will be subject to the standard over the next three years. Existing sources comprise 300 

exploration and production businesses, 136 transmission and storage operations, 116 processing plants and 12 sweetening units. New sources comprise 29 
21

processing plants and 3 sweetening units.

b

 This ICR uses the following labor rates: $103.97 (technical), $129.93 (managerial), and $51.79 (clerical). These rates are from the United States Department of 

Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total 

compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c

 This burden represents the time existing respondents spend re-familiarizing themselves with rule requirements, or that new respondents spend learning rule 

requirements.

d Assumes 9,759 completions and 1,206 recompletions each year performed by 300 operators.

e EPA estimates an average of 116 existing and 29 new processing plants.

f EPA estimates an average of 12 existing and 3 new sweetening units.

g EPA estimates an average of 52 existing and 13 new centrifugal compressors equipped with wet seals at processing plants.

h EPA estimates an average of 1,676 existing and 419 new reciprocating compressors. For existing sources, EPA estimates there are 840 compressors at gathering 

& boosting stations and 836 compressors are at processing plants. For new sources, EPA estimates there will be 210 compressors at gathering & boosting 

stations and 209 compressors at processing plants.

i EPA estimates 13,632 pneumatic controllers across the 300 exploration & production sites.

j EPA estimates an average of 60 existing and 15 new pneumatic controllers at affected processing plants.

k EPA estimates an average of 304 existing and 76 new respondents in the production, processing, transmission, or storage segment will submit annual reports. 

EPA anticipates each report will cover approximately four storage vessels, based on research the Agency conducted during initial rule development.

l Activity applies to exploration & production businesses and transmission & storage operations, for which EPA estimates an average of 300 and 136 sources, 

respectively.

m Activity applies to gas processing plants and sweetening units. EPA estimates an average of 116 existing and 29 new processing plants and 12 existing and 3 

new units.
22

Table 2: Average Annual EPA Burden and Cost – NSPS for Oil and Natural Gas Production and Natural Gas Transmission 

and Distribution (40 CFR Part 60, Subpart OOOO) (Renewal)

Burden item

A B C D E F G H

EPA

personhours per 

occurrence

Annual 

occurrences

per 

respondent

EPA

person-hours

per respondent

per year (AxB)

Respondents

per year a

Technical 

hours

per year

(CxD)

Management

hours per 

year

(Ex0.05)

Clerical 

hours

per year

(Ex0.10)

Annual 

cost

($) b

Review initial notifications

i. Notification of gas well completion 0.5 33 17 300 4,950 247.5 495 259,083

ii. Notification of gas well recompletion 0.5 4 2 300 600 30 60 31,404

iii. Notification of new gas processing 

plant

0.5 1 1 29 14.5 0.73 1.45 759.24

iv. Notification of new sweetening unit 0.5 1 1 3 1.5 0.08 0.15 78.82

Review annual reports

i. Gas well completion/recompletion 1 1 1 300 300 15 30 15,702

ii. Sweetening unit 1 1 1 15 15 0.75 1.5 785.1

iii. Centrifugal compressor 1 1 1 65 65 3.25 6.5 3,402.1

iv. Reciprocating compressor 1 1 1 2,095 2,095 104.75 209.5 109,652.3

v. Production pneumatic controller 1 1 1 300 300 15 30 15,702

vi. Gas processing pneumatic controller 1 1 1 75 75 3.75 7.5 3,925.5

vii. Storage vessel 1 1 1 380 380 19 38 19,889.2

Review semiannual reports

i. Gas processing plant 1 2 2 145 290 14.5 29 15,178.6

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 10,400 476,000

Note: Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

Assumptions:

a

 EPA estimates an average of 564 existing sources and 32 new sources will be subject to the standard over the next three years. Existing sources comprise 300 

exploration and production businesses, 136 transmission and storage operations, 116 processing plants and 12 sweetening units. New sources comprise 29 

processing plants and 3 sweetening units.

b This ICR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are from the Office of Personnel 

Management (OPM), 2014 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.