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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH) (Renewal), 

EPA ICR Number 1789.07, OMB Control Number 2060-0418. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Natural 

Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) were proposed on February 6, 

1998, and promulgated on June 17, 1999. These regulations apply to existing facilities and new 

facilities that are major sources of hazardous air pollutants (HAP) and that either transport or 

store natural gas prior to entering the pipeline to a local distribution company or to a final end 

user (if there is no local distribution company). New facilities include those that commenced 

construction or reconstruction after the date of proposal. This information is being collected to 

assure compliance with 40 CFR part 63, subpart HHH.

In general, all NESHAP 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 the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

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 delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 27 respondents per year will be subject to the 

reporting requirements of this standard, and 2 additional respondents per year will become 

subject to these requirements. In addition, approximately 807 existing respondents are subject 

only to the recordkeeping requirements of this standard. Overall, EPA estimates a total of 836 

respondents for this standard. EPA assumes that there is an average of one affected facility per 

plant (i.e., respondent). 
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There are approximately 836 natural gas transmission and storage facilities in the United 

State which are owned and operated by the natural gas transmission and storage industry. 

None of the 836 facilities in the United States are owned by either, state, local, tribal, or the 

Federal government. They are all owned and operated solely by privately-owned, for-profit 

businesses. You can find the burden to the “Affected Public” listed below in Table 1: Annual 

Respondent Burden and Cost - NESHAP for Natural Gas Transmission and Storage (40 CFR 

Part 63, Subpart HHH) (Renewal). The Federal government burden associated with the review of 

reports submitted by the respondent is shown below in Table 2: Average Annual EPA Burden -

NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH).

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

Collection Request (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 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. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. 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, HAP emissions from natural gas transmission and 

storage facilities cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, the NESHAP were promulgated for this source 

category at 40 CFR part 63, subpart HHH.
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2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where 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. During the performance test, a record 

of the operating parameters under which compliance was achieved may 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 check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. The 

performance 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.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart 

HHH.

3(a) Non-duplication

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 (76 FR 26900) on May 9, 2011. No comments were received on the 

burden published in the Federal Register.
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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 OTIS, which is operated and maintained by EPA’s Office of 

Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all 

compliance data. We estimate that there are on average 27 existing respondents subject to the 

reporting requirements of this standard, and that 2 new sources each year will become subject to 

the standard over the three-year period covered by this ICR.

Consultations with industry representatives were conducted to determine if there is any

way for EPA to reduce the recordkeeping and reporting burden or improve the language in the 

standards to facilitate industry compliance. Industry representatives were also provided an 

opportunity to comment on the ICR burden, including the size, growth, and other characteristics 

of the regulated industry. For this renewal, the following representatives were contacted:

Name Organization Phone

Pam Lacey

American Gas Association 

(AGA) 202-824-7340

Kathryn Daley

Interstate Natural Gas 

Association of America

(INGAA) 202-216-5926

EPA did not receive any comments from the consultations. 

It is our policy to respond after a thorough review of comments received from the public 

since the last ICR renewal as well as those submitted in response to the first Federal Register

notice. In this case, no comments were received. 

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 likelihood of detecting poor operation and maintenance of control 

equipment and noncompliance would decrease.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 
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established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications, for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with 

the Part 70 permit program and the five-year statute of limitations on which the permit program 

is based. Also, the retention of records for five years would allow EPA to establish the 

compliance history of a source and any pattern of compliance for purposes of determining the 

appropriate level of enforcement action. EPA has found that the most flagrant violators 

frequently have violations extending beyond the five years. In addition, EPA would be 

prevented from pursuing the worst 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 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 (CBI) (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 do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents, SIC and NAICSCodes

The respondents to the recordkeeping and reporting requirements are natural gas 

transmission and storage facilities. The United States Standard Industrial Classification (SIC) 

codes for the respondents affected by the standards, which corresponds to The North American 

Industry Classification System (NAICS) codes, are listed below for source category description.

Standard (40 CFR Part 63, Subpart HHH) SIC Codes NAICS Codes

Pipeline Transportation of Natural Gas 4922 48621

Natural Gas Distribution 4923 22121, 48621
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4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported are required by the NESHAP for 

Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH).

A source must make the following reports:
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Notifications

Initial notification that a source is subject to the provisions in 

subpart HHH.

63.9(b)(2), 63.1274(a), 

63.1285(b)(1-2)

Notification of the date of a performance test. 63.7(b-c), 63.8(e)(2), 

63.9(e), 63.9(g)(1), 

63.1274(a), 63.1285(b)(3)

Notification of Compliance Status Report, including the results 

of any continuous monitoring system performance evaluations 

and inspection results.

63.9(h), 63.1270(d), 

63.1283(c)(2)(ii)(A), 

63.1285(b)(4), 63.1274(a), 

63.1285(d)(1-10)

Notification of change in compliance demonstration methods for 

control device performance (submit with Periodic Report).

63.1282(e)

Performance test results for closed-vent systems using flares as 

the control device (submit with Notification of Compliance 

Status Report).

63.7(g), 63.10(d)(2), 

63.1274, 63.1282(d)(3), 

63.1285(d)(2)

Design analysis documentation, including operating parameters 

and calculations, for closed-vent systems using control devices 

other than flares (submit with Notification of Compliance Status 

Report).

63.1274, 63.1282(d)(4), 

63.1285(d)(4)(i) through 

(d)(4)(iii)

One complete test report for each test method used for a 

particular source (submit with Notification of Compliance Status 

Report).

63.1285(d)(3)

Analysis demonstrating whether an affected source is a major 

source (submit with Notification of Compliance Status Report).

63.1285(d)(8)

Statement of compliance with subpart HHH (submit with 

Notification of Compliance Status Report).

63.1285(d)(9)

Notification of any process change. 63.1285(f)

Application for approval of construction or reconstruction. 63.5(d)(1), 63.1274(a)

Notification of intent to construct or reconstruct. 63.9(b)(5)(i), 63.9(d)(4)(i), 

63.1274(a)

Notification of actual date of startup. 63.9(b)(4)(v), 

63.9(b)(5)(ii), 63.1274(a)
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Notifications

Results of performance evaluation. 63.8(e)(5), 63.10(e), 

63.1274(a)

Notification of special compliance requirements. 63.9(d), 63.1274(a)

Reports

Semiannual startup, shutdown, or malfunction reports (may be 

submitted with Periodic Report).

63.6(e)(3)(iv), 63.10(d)(5), 

63.1274(a), 63.1285(b)(6)

Semiannual Periodic Reports. 63.10(e), 63.1274(a), 

63.1285(e)

Report to demonstrate compliance with benzene emission limit 

(alternative standards) (submit with Notification of Compliance

Status Report).

63.1285(d)(7)

Analysis that demonstrates conditions under which the facility

reduces 95.0 percent of its HAP emissions (submit with 

Notification of Compliance Status Report).

63.1281(e)(2), 

63.1285(d)(10)

Semiannual excess emissions and continuous monitoring system 

performance report.

63.9(c)(8), 63.10(e)(3), 

63.1274(a)

Semiannual HAP summary report. 63.10(e)(3)(vi), 63.1274(a)

A source must keep the following records:

Recordkeeping

Records for each monitoring system including documentation of 

incidents such as breakdowns, repairs, calibration checks, 

startup, shutdown, malfunctions, and other down time.

63.10(b)(2), 63.10(c), 

63.1272(d), 63.1274(a), 

63.1283(d), 63.1284(b)(3) 

Continuous records of equipment operating parameters and daily

average values of the parameters.

63.1284(b)(4)(i) and (ii)

Records of the times and duration of all periods during which 

pilot flames are absent.

63.1284(b)(4)(ii), 

63.1284(e)(3)

Records of flow indicator operation, detection, and vent stream 

diversions.

63.1284(b)(4)(iii)
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Recordkeeping

Records of inspections of seals or closure mechanisms and 

records of broken or changed seals, valves, or locks.

63.1284(b)(4)(iv)

Continuous monitoring system quality control program. 63.8(d), 63.1274(a)

Startup, shutdown, and malfunction (SSM) plan. 63.6(e)(3), 63.8(c)(1)(iii), 

63.1272(d), 63.1274(a)

Records of control device activities, malfunctions, and down 

time.

63.1274, 63.1281(c)(3), 

63.1283(d), 63.1284(b)(3) 

and (b)(4)

Records pertaining to the inspection of closed-vent systems 

including maintenance, leaks, repairs, delays, and shutdowns. 

This also applies to parts that are difficult or unsafe to inspect 

and those where a leak or defect is detected.

63.1283(c)(3-7), 

63.1284(b)(5-8)

Records of glycol dehydration unit baseline operations, 

throughput quantity, and emissions information.

63.1281(e)(1-2), 

63.1284(b)(9-10),

63.1284(d)

Records of compliance with benzene emission limit (alternative 

standards).

63.1281(e)(2), 63.1284(c)

Throughput and emissions records of exempt glycol dehydration 

units.

63.1274(c-d), 63.1284(d)

Records of flare design and emissions. 63.1284(e)

Records of leak or defect detection, severity (maximum 

instrument reading), and date of repair.

63.1284(b)(7-8)

Site-specific performance evaluation test plan. 63.7(c)(2), 63.8(d)(2), 

63.8(e)(3)(i), 63.1274(a)

Record of results of performance test. 63.7(g)(3), 63.1274(a)

Electronic Reporting

At the present, respondents are using monitoring equipment that automatically records 

parameter data (e.g., temperature). Although personnel at the affected facility must evaluate the 

data, this internal automation has significantly reduced the burden associated with monitoring 

and recordkeeping at the plant site.
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Also, regulatory agencies, in cooperation with the respondents, continue to create 

reporting systems to transmit data electronically. However, these electronic reporting systems 

are still not widely used. At this time, it is estimated that approximately 10 percent of the 

respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate closed vent systems and CMS to: 1) achieve a 95% 

reduction in HAP, TOC, or total HAP, for control devices and vapor recovery devices; 2) 

achieve a reduction to 20 ppm of TOC or total HAP, and operates at a minimum residence 

time of 0.5 seconds at a minimum temperature of 760 degrees Celsius for combustion devices.

Perform initial performance test, using the procedures listed in 40 CFR 63.1282(d), 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.

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

Transmit, or otherwise disclose the information.

The rule does not require use of information collection techniques such as automated, 

mechanical, or other technical collection techniques. Electronic submissions can be made but 

they must be followed up with a hard copy that is signed by the owner/operator of the facility.

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

Information Management

5(a) Agency Activities
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EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might 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, and serve as a record of the operating conditions under which 

compliance was achieved. Data and records maintained by the respondents are tabulated and 

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

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

determinations.

Information contained in the reports is entered into the OTIS, which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS 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 five 

years.

5(c) Small Entity Flexibility

There is a distribution of business sizes among the respondents. At the time of 

rulemaking, the Agency estimated that the number of affected small entities would likely be 

minimal due to several considerations in these rules that minimize the burden on all firms, both 

small and large. These considerations include exempting from the control, monitoring, and 

reporting requirements of the NESHAP those glycol dehydration units below certain thresholds 

for natural gas throughput (less than 283 thousand standard cubic meters per day) or benzene 

emissions (less than 0.90 mega-gram per year). The Agency considers the remaining 
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recordkeeping requirements the minimum 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. The Agency estimates that 49 

percent of the parent companies affected by proposed action are small entities as defined by the 

Small Business Administration. Therefore, approximately 410 facilities of the average 836

facilities are small entities. 

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost - NESHAP for Natural Gas 

Transmission and Storage (40 CFR Part 63, Subpart HHH) (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. Specific tasks and major assumptions 

have been identified where appropriate. 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 950 hours (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 ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%) 

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 
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September 2011, “Table 2: Civilian workers, by occupational and industry group.” The rates are 

from column 1, “Total Compensation.” The rates have been increased by 110% to account for 

the benefit packages available to those employed by private industry.

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

The only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. There are no capital/startup or operations and 

maintenance (O&M) costs incurred as a result of this standard because the industry has primarily

installed flares to control emissions.

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

The only type of industry costs associated with the information collection activity in the 

regulations is labor costs. There are no capital/startup or operation and maintenance 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 

$6,841.

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

Managerial $62.27 (GS-13, Step 5, $39.92 x 1.6)

Technical $46.21 (GS-12, Step 1, $28.88 x 1.6)

Clerical $25.01 (GS-6, Step 3, $15.63 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2011 General Schedule”,

which excludes locality rates of pay. Details upon which this estimate is based appear below in 

Table 2: Average Annual EPA Burden and Cost - NESHAP for Natural Gas Transmission and 

Storage (40 CFR Part 63, Subpart HHH) (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

27 existing respondents will be subject to the standard. It is estimated that an additional two 

respondents per year will become subject. An additional 807 existing respondents keep records,

but do not submit reports. The overall average number of respondents, as shown in the table 
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below, is 836 per year.

The number of respondents is calculated using the following table, which addresses the 

three years covered by this ICR.

.

Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any 

Reports

Year

(A)

Number of New 

Respondents

(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 2

25 807 0 834

2 2

27 807 0 836

3 2

29 807 0 838

Average 2

27 807 0 836

To avoid double-counting respondents column D is subtracted. As shown above, the 

average Number of Respondents over the three year period of this ICR is 836.

The total number of annual responses per year is calculated using the following table:
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Total Annual Responses

(A)

Information 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)+D

Notification of intent to construct/reconstruct 2 1 N/A 2

Notification of actual date of startup 2 1 N/A 2

Notification of date of continuous 

monitoring system performance evaluation

2 1 N/A 2

Notification of planned date of performance 

test

2 1 N/A 2

Notification of compliance status report 2 1 N/A 2

Semiannual reports 27 2 N/A 54

Total 64

The number of Total Annual Responses is 64.

The total annual labor costs are $91,018. Details regarding these estimates may 

be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Natural 

Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal).

There are no capital/startup or operation and maintenance costs.

The average annual Agency burden and cost over next three years is estimated to be 152 

labor hours at a cost of $6,841. See below Table 2: Average Annual EPA Burden and Cost -

NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal).

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

(i) Respondent Tally

The total annual labor costs are $91,018. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost - NESHAP for Natural Gas Transmission and 

Storage (40 CFR Part 63, Subpart HHH) (Renewal). 
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Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 15 hours per response.

There are no capital/startup or operation and maintenance costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 152 

labor hours at a cost of $6,841. See below Table 2: Average Annual EPA Burden and Cost -

NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in labor hours and costs for both the respondents and the Agency

from the most recently approved ICR. This is due to two considerations: 1) the estimated 

number of respondents subject to the standard has increased due to industry growth in the past 

three years; and 2) this ICR uses updated labor rates to reflect the most recent data from the 

Bureau of Labor Statistics. 

6(g) Burden Statement

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

is estimated to average 15 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’s 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-2011-0238. 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 
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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 

number for the Enforcement and Compliance Docket and Information Center Docket 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 Office for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0238

and OMB Control Number 2060-0418 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 Respondent Burden and Cost - NESHAP for Natural Gas Transmission and Storage (40 CFR part 63, 

subpart HHH) (Renewal)

[Type text]

18

Activity (A)

Person 

hours per

Occurrence

(B)

No. of 

Occurrences

per

Respondent

per year

(C)

Person hours

per

respondent

per year

[C=AxB]

(D)

Respondents

per year a

(E)

Technical 

personhours per 

year

[E=CxD]

(F)

Management 

person-hours 

per year

[F=0.05xE]

(G)

Clerical 

person-hours 

per year

[G=0.1xE]

(H)

Total Labor 

Costs per 

year b

1. Applications Not applicable

2. Survey and Studies Not applicable

3. Reporting Requirements

a. Read instructions 2 1 2 27 54 2.7 5.4 $5,950.36

b. Required activities Not applicable

c. Create information Not applicable

d. Gather existing information 4 1 4 27 108 5.4 10.8 $11,900.74

e. Write reports

i. Notification of construction/ 

reconstruction 2 1 2

2 4 0.2 0.4 $440.76

ii. Notification of actual startup 2 1 2 2 4 0.2 0.4 $440.76

iii. Notification of date of CMS 

performance evaluation 2 1 2

2 4 0.2 0.4 $440.76

iv. Notification of planned date of 

performance test 2 1 2

2 4 0.2 0.4 $440.76

v. Notification of compliance 

status report 2 1 2

2 4 0.2 0.4 $440.76

vi. SSM reports c2 2 4 27 108 5.4 10.8 $11,900.74

vii. Semiannual Periodic Report 2 2 4 27 108 5.4 10.8 $11,900.74

Reporting Subtotal 457.7

4. Recordkeeping Requirements
Table 1. Annual Respondent Burden and Cost - NESHAP for Natural Gas Transmission and Storage (40 CFR part 63, 

subpart HHH) (Renewal)

[Type text]

19

Activity (A)

Person 

hours per

Occurrence

(B)

No. of 

Occurrences

per

Respondent

per year

(C)

Person hours

per

respondent

per year

[C=AxB]

(D)

Respondents

per year a

(E)

Technical 

personhours per 

year

[E=CxD]

(F)

Management 

person-hours 

per year

[F=0.05xE]

(G)

Clerical 

person-hours 

per year

[G=0.1xE]

(H)

Total Labor 

Costs per 

year b

a. Read instructions See 3A

b. Plan activities 4 1 4 2 8 0.4 0.8 $881.54

c. Implement activities Not applicable

d. Develop record system

i. Control equipment 4 1 4 2 8 0.4 0.8 $881.54

ii. SSM plan 12 1 12 2 24 1.2 2.4 $2,644.60

e. Enter information

i. Control device design 4 1 4 2 8 0.4 0.8 $881.54

ii. Control equipment testing 1 1 1 2 2 0.1 0.2 $220.38

iii. Control equipment inspection 1 2 2 27 54 2.7 5.4 $5,950.36

iv. Control equipment monitoring 1 2 2 27 54 2.7 5.4 $5,950.36

v. Control device CMS 1 6 6 27 162 8.1 16.2 $17,851.10

f. Train personnel 4 1 4 27 108 5.4 10.8 $11,900.74

g. Perform audits Not applicable

h. Retain records of actual 

throughput (facilities exempt under 

63.1270(f) d

Not applicable

Recordkeeping Subtotal 492.2

TOTAL LABOR BURDEN AND COST (rounded) 950 $91,018
Table 1. Annual Respondent Burden and Cost - NESHAP for Natural Gas Transmission and Storage (40 CFR part 63, 

subpart HHH) (Renewal)

[Type text]

20

Assumptions:

a

 We have assumed that there are approximately 836 respondents on average, with 2 additional new or reconstructed sources becoming subject to the rule annually

over the next three years. Within those 836 existing sources, we estimate only 27 are subject to the standard. The remaining 807 respondents are not required to 

submit reports.

b

 This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “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.

c

 Startup/ shutdown/ malfunction reports may be included in the semiannual periodic reports.

d

 Respondents are expected to maintain records of actual throughput as a standard business practice; therefore, there is no additional burden associated with these 

records under this rule.
[Type text]

21

Table 2: Annual Agency Burden and Cost - NESHAP for Natural Gas Transmission and Storage (40 CFR part 63, subpart 

HHH) (Renewal)

Activity (A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant per 

year

(C)

EPA personhours per plant 

per year

(C=AxB)

(D)

Plants per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours per 

year

(Ex0.1)

(H)

Cost, $ b

1. Review reports

a. Initial notification 2 1 2 2 4 0.2 0.4 $207.29

b. Preconstruction review application 4 1 4 2 8 0.4 0.8 $414.60

c. Performance test notification 2 1 2 2 4 0.2 0.4 $207.29

d. Compliance status notification 4 1 4 2 8 0.4 0.8 $414.60

e. Semiannual periodic reports22 2 4 27 108 5.4 10.8 $5,597.05

TOTAL LABOR BURDEN AND COST (rounded) 152 $6,841

a

 We have assumed that there are approximately 836 respondents, with 2 additional new or reconstructed sources becoming subject to the rule annually over the 

next three years. Within those 836 existing sources, we estimate only 27 are subject to the standard. The remaining 807 respondents are not required to submit 

reports.

b

 This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for 

Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are 

from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.

c

 Startup/ shutdown/ malfunction reports may be included in the semiannual periodic reports.