SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY
NSPS for Onshore Natural Gas Processing Plants
1. Identification of the Information Collection 1(a) Title of the Information Collection NSPS for Onshore Natural Gas Processing Plants (40 CFR p art 60, s ubpart s KKK and LLL) ( Renewal) 1(b) Short Characterization/Abstract The New Source Performance Standards (NSPS) for Equipment Leaks of volatile organic compound (VOC ) from Onshore Natural Gas Processing Plants, published at 40 CFR part 60, subpart KKK , were proposed on January 20, 1984 and promulgated on June 24, 1985. These standards appl y to the following affected facilities located at onshore natural gas processing plants: compressors in VOC service or in wet gas service, and the group of all equipment (except compressors) within a process unit. Affected facilities commenced construction, modification or reconstruction after the date of proposal. Ap rocess unit is defined as the equipment assembled for extraction of natural gas liquids from fie ld gas, fractionation of liquids into natural gas products, or other processing of natural gas products. The New Source Performance Standards (NSPS) for Onshore Natural Gas Processing: SO 2 Emissions, published at 40 CFR part 60 , subpart LLL , were proposed on January 20, 1984 and promulgated on October 1, 1985. These standards apply t o the following affected facilities located at onshore natural gas processing plants: each sweetening unit, and each sweetening unit followed by a sulfur recovery

unit. Affec ted facilities commenced construction, modification or reconstruction after the date of proposal. A sweetening unit is defined as a process device that separates the hydrogen sulfide and carbon dioxide (CO 2 ) contents from the sour natural gas stream. The provisions of subpart LLL do not appl y to sweetening facilities that produce acid gas that is completely

r e - injected into oil or gas bearing geologic strata or that is otherwise not released to the atmosphere. The control and monitoring requirements of s ubpart LLL do not apply to affected facilities with design capacities of less than two long tons per day of h ydrogen sulfide in the acid gas, expressed as sulfur. In general, all NSPS standards require initial notifications, performance tests, and periodi c reports. Owners or operators 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 s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all sources subject to NSPS. Any owner or operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority . In2

the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of four affected facilities at each plant site for subpart KKK, along with one affected facility at each plant site for subpart LLL, and that each plant site has only one respondent (i.e., the owner/operator of the plant site).
All of these sources subject to subpart LLL are also subject to subpart KKK. Over the next three years, an average of 56 3 sources per ye ar will be subject to subpart KKK, and it is estimated that one additional source per ye ar will becom e subject to the standard in the next three years. There are approximately

79 of these sources of these that are currentl y s ubject to subpart LLL, and it is estimated that three additional sources will become subject to the standard in the next three ye ars. There are approximately 56 3 onshore natural gas processing plants in the United States, which are all publicly

owned and operated b y the onshore natural gas processing industry . None of the 56 3 plants 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 “A ffected Public” listed below in Table 1: Annual Industry Burden and Cost

- NSPS for Onshore Natural Gas Processing Plants (40 CFR P art 60, S ubpart s KKK and LLL ) . The Federal government burden does not include work performed by Federal employees only work performed by

contractors, which could be found listed below in Table 2: Average Annual EPA Burden

- NSPS for Onshore Natural Gas Processing Plants (40 CFR P art 60, S ubpart s KKK and LLL )

. 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 s ection 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 sy stem 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 adequatel y 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 four years.3

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) in stall, 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 reasonabl y require. In the Administrator's judgment, VOC and sulfur dioxide e m issions from onshore natural gas processing plants cause or contribute to air pollution that may reasonably

be anticip ated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart s KKK and LLL. 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 i nitial 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 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 r equirements 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 standard is being met. The perf ormance test may

also be observed. The required semiannual and quarterly reports are used to determine periods of excess emissions, identify

problems at the facility , verify operation/maintenance procedures, and for compliance determinations. 3. Nondupl ication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 60, subpart s4

KKK and LLL. 3(a) Nonduplication If the subject standards have not been delegated, the information is sent direc tly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report su bmitted to the state or local agency can be sent to the Administrator in lieu of the report required b y 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 IC R was published in the Federal Register ( 7 2 FR 10736) on March 9, 2007. N o comments were received on the burden published in the Federal Register

. 3(c) Consultations Over the next three ye ars, an average of 563 facili ties per ye ar will be subject to the standard

. Inestimating the affected number of sources and the growth rate of onshore natural gas processing plants subject to this standard, EPA contacted Ms. Ly nn Reed at (918) 588

- 7380, ONEOK, Incorporated, Mr. Lan c e Lodes at ( 405 ) 557

- 6846 , OGE

- Enogex, Incorporated, and Mr. Johnny Dreyer, (918) 493

- 3872, Gas Processors Association (GPA) . We referenced the most recent data available. We reviewed information available from the Online Tracking Information Sy stem (OTI S) which is the primary source of information regarding the number of existing sources. OT IS data was used in conjunction with industry consultation to verify

the number of sources and the industry

growth rate. 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 likel y. 3(e) General Guidelines These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. 3(f) Confidentiality Any i nformation 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

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Confidentiality

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, Septe mber 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 Respondents and the Information Requested 4(a) Respondents/ SIC Codes The respondents to the recordkeeping and reporting requirements are stationary gas turbines. The United States Standard Industrial Classification (SI C) codes which correspond to the North American Industry C lassification Sy stem (NAICS) code could be found in the following table: 40 CFR part 60, subpart s KKK and LLL SIC Codes NAICS Codes Crude Petroleum and Natural Gas Extraction 1311 211111 Natural Gas Liquid Extraction 1321 211112 4(b) Information Requested None of these reporting or rec ordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. (i) Data Items In this ICR, all the data recorded or reported is required by the New Source Performance Standards for Onshore Natural Gas Proce ssing Plants (40 CFR Part 60, Subpart s KKK and LLL ). A source must make the following reports:
Notifications Notification of construction or reconstruction 60.7(a)(1) Notification of actual startup date 60.7(a)(3) Notification of modification 60.7(a)( 4 Notification of demonstration of continuous monitoring s ys tem 60. 7 ( a) (5) Notification of initial performance test 60. 8( d) Semiannual reports of excess emissions (subparts KKK and LLL) 60.7(c) Performance test results (subparts KKK and LLL) 60.8(a), 6 0.636(a), 60.487(e)6 Notifications Semiannual reports (subpart KKK) 60.636(a)

- (c), 60.487(a) Semiannual report on excess emissions from and performance of continuous monitoring system, and/or summary report forms (subpart LLL) 60.647(b)

A source must keep the followi ng records: Recordkeeping Maintain records of startups, shutdowns, malfunctions of affected facilities; malfunctions of control devices; and periods where the continuous monitoring system is inoperative. 60.7(b) Keep records of measurements, performanc e evaluations, calibration checks, adjustments and maintenance related to continuous monitoring sy stems. 60.7(f) Keep records of parts of closed vent s ys tems designated as unsafe or difficult to inspect (subpart KKK). 60.632(a), 60.482

- 10(l)(1), (2) Keep records of inspections of closed vent s ys tems during which no leaks are detected (subpart KKK). 60.632(a), 60.482

- 10(l)(4), (5) Perform attachment of identification numbers to leaking equipment (subpart KKK) 60.635(a), (b)

Keep records of leak detection and repair (subpart KKK) 60.632(a), 60

. 635(a), (b), 60.482

- 10(l)(3) 60.486(c) Keep records of design requirements for and operation of closed vent sy stems and control devices (subpart KKK) 60.635(a), 60.486(d) Keep records listing all equipment subject to subpart KKK 60.635(a), (b), 60.486(e) Keep records of compliance tests (subpart KKK) 60635(a), 60.486(e)(4) Keep records of valves designated as unsafe or difficult to monitor (subpart KKK) 60.635(a), 60486(f) Keep records of design criterion that in dicate failure (subpart KKK) 60.635(a), 60.486(h) Keep records of parts not in VOC service or otherwise exempt (subpart KKK) 60.635(a), (c), 60.486(j) Keep records of calculations and measurements (subpart LLL) 60.647(a)7 Recordkeeping Facilities that choose to comply with 60.646(e) shall keep, for the life of the facility , records demonstrating that the facility design capacity i s less that 150 long tons per day of hydrogen sulfide expressed as sulfur (subpart LLL) 60. 64 7( d)

Electronic Reporting Some of the respond ents 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. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically. However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting. Respondent Activities Read instructions. Write the notification and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a colle ction of information. Transmit, or otherwise disclose the information. Perform initial performance test, reference the methods discussed in the rule language, and repeat performance tests if necessary . Applicable if controls are used (subpart KKK). Mon itor control devices to ensure that they are operated and maintained in conformance with design . Applicable if controls are used (subpart KKK)

. Perform monthly monitoring of pumps in light liquid service and valves in gas/vapor service or in light liquid service (subpart KKK). Repair pump, compressor, valve, and vapor collection syst em leaks (subpart KKK). Perform weekl y visual inspections of pumps in light liquid service (subpart KKK).8 Respondent Activities Monitor pressure relief devices in gas/vapor service for no detect able emissions, following pressure release (subpart KKK). Monitor or repair leaks in pumps or valves in heavy liquid service, pressure relief devices in light or heav y liquid service, and connectors (subpart KKK). Conduct annual inspections of vapor coll ection sy stems (subpart KKK). Install, calibrate, maintain and operate CMS for (a) total sulfur emission rate and (b) exhaust gas temperature for oxidation control sy stems or reduction control sy stems that are followed by an incinerator (subpart LLL). In stall, calibrate, maintain, and operate CMS for reduced sulfur compound emission rate for reduction control s ys tems that are not followed b y an incinerator (subpart LLL) Perform initial performance test, reference the methods discussed in the rule languag e, and repeat performance tests if necessary (subpart LLL). Perform dail y monitoring of (a) accumulation of sulfur product and (b) H 2 S Concentration in the acid gas from the sweetening unit (subpart LLL). Perform hourl y m onitoring of acid gas flow rate f rom the sweetening unit and calculate the dail y average (subpart LLL). Calculate (a) dail y sulfur feed rate and (b) dail y required SO 2 emission reduction efficiency (subpart LLL). Currently , sources are using monitoring equipment that provides parameter data in an automated way

e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. 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, analy sis, 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, excess emissions reports, required to be submitted by industry

. Audit facil ity

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S).9

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 properl y i nstalled and operational. P erformance test reports are used b y the Agency to discern a source’s initial capability to comply

with the emission standard, and note 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 compli ance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by the EPA Office of Compliance. OTI S is an EPA database for the collection, maintenance, and retrieval of compliance data for approximately 1 25,000 industrial and government

- owned facilities. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be retained by the owner or operator for two ye ars. 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. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and repor ting 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. T o 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

f or each information collection activity w ithin this request is shown in Table 1: Annual Industry Burden, NSPS for Onsho re Natural Gas Processing Plants (40 CFR p art 60, s ubpart s KKK and LLL)

. 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 indus try 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 information collection are mandatory

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The Agency

may not conduct or sponsor, and a person i s 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 149,180 (Total Labor Hours from Table 1). These hours are based on Agency studies and back ground documents from the development of the regulation, Agency

knowledge and experience with the NSP S program, the previously approved ICR, and any comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs
This I CR uses the foll owing labor rates: Managerial $ 95.32 ($ 45.39 + 110%) Technical $ 64.60 ($ 30.76 + 110%) Clerical $ 40.09 ($ 19.09 + 110%)
These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 200 3 , Table 2.Civilian Worker s, by o ccupational 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 Opera tion and Maintenance Costs The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. The type of industry costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this I CR 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 costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.11
(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 1 (C)

Number of New Respondents (D)

Total Capital/Sta rtup Cost, (B X C) (E)

Annual O&M Costs for One Respondent 1 (F)

Number of Respondents with O&M 2 (G)

Total O&M, (E X F)

SO 2 CEM, control outlet only for subpart LLL $ 7 3,0 00 3 $ 2 1 9 , 00 0 $ 17,100 7 $ 119,700

1 Costs reflect installation and maintenance of an in

- situ SO 2 CEM after the control device and assume installation occurred during the construction of the facility. 2 After consultation with the industry we believe that the number of respondents needing continuous monitoring is seven. The total capital/startup costs for this I CR are $ 219,000 . This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 11 9 ,7 00 . 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 ye ars of the I CR is estimated to be $ 338,700

. 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. 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 $ 501,916

. This cost is based on the average h ourl y labor rate as follows: Managerial $ 54.66 (GS

- 13, Step 5, $3 4.1 6 x 1.6 ) Technical $4 0.56 (GS

- 12, Step 1, $2 5.35 x 1.6 ) Clerical $2 1.95 (GS

- 6, Step 3, $1 3.72 x 1.6 ) These rates are from the Office of Personnel Management (OPM) 200 4 General Schedule which e xcludes locality

rates of pay . De tails upon which this estimate is based appear in Table 2: Average Annual EPA Burden, NSPS for Onshore Natural Gas Processing Plants (40 CFR p art 60, s ubpart s KKK and LLL ), below

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6(d) Estimating the Respondent Universe and Total Burden and Costs
Based on our research for this I CR, on average over the next three ye ars, approximately 56 3 existing respondents will be subject to the sta ndard. It is estimated that one additional respondent will become subject to subpart KKK and three for subpart LLL over the next three ye ars
. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. Number of Respondents

Year (A)

Number of 1 New Respondents (B)

Numbe r 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) Subpart KKK 2 1 113 561 0 112 562 2 113 562 0 112 563 3 113 563 0 112 564 Average 113 562 0 112 563 Subpart LLL 3 1 3 79 3 0 85 2 3 82 3 0 88 3 3 85 3 0 91 Average 3 82 3 0 88 1 New respondent include sources with constructed, reconstructed and modified affected facilities . In thi s standard existing respondents submit initial notifications.

2 Based on industry consultation, EPA believes that approximately 20 percent of existing respondents for subpart KKK will construct one new affected facility per year.

3 Affected facilities with design capacities of less than two long tons per day of hydrogen sulfide (H 2 S) in the acid gas, expressed as sulfur, have no reporting requirements pursuant to subpart LLL. Three respondents have sources capacities below this threshold. To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 563 (all sources subject to subpart LLL and also subject to subpart KKK). The total number of annual responses per ye ar is calculated using the following table:13
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 Annua l Responses E=(BxC)+ D Subpart KKK Notification of construction /reconstruction 57 1 n/a 57 Notification of mo dification 56 1 n/a 56 Notif ication of anticipated startup 113 1 n/a 113 Notification of actual startup 113 1 n/a 113 Notification of de mo nstration of continuous mo nitoring system 0 1 n/a 0 Notification of initial performance tests 0 1 n/a 0 Semiannual reports 563 2 n/a 1,126 Subpart LLL Notification of construction/reconstruction 1.5 1 n/a 1.5 Notification of anticipated startup 3 1 n/a 3 Notification of actual startup 3 1 n/a 3 Notification of initial performance test 3 1 n/a 3 Notification of CMS demonstration 3 1 n/a 3 CMS demonstration report 3 0.2 n/a 0.6 Semiannual report 82 2 n/a 164 Total (rounded) 1,643
The number of total respondents is 56 3. The number of Total Annual Responses is 1,643

. This is the number in column E of the Respondent Universe and Number of Responses per year in table above. The total annual labor costs are $ 9,518,3 5 8. Details regarding th ese estimates may be found in Table 1: Annual Industry Burden, NSPS for Onshore Natural Gas Processing Plants (40 CFR p art 60, s ubpart s KKK and LLL ) , below. 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, respectivel y, and summarized below. (i) Respondent Tally The total annual labor costs are $ 9,518,3 5 8 . Details regarding these estimates may be14

found in Table 1. Annu al Respondent Burden and Cost: NSPS for Onshore Natural Gas Processing Plants (40 CFR p art 60, s ubpart s KKK and LLL ) , below. F urthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 91 ho urs per response. The total annual capital/startup and O&M cost to the regulated entity are $ 338,700

. (ii) The Agency Tally The average annual Agency b urden and cost over next three ye ars is estimated to be 12,689 labor hours at a cost of $ 501,916 . See Table 2. Annual Agency Burden and Cost: NSPS for Onshore Natural Gas Processing Plants (40 CFR p art 60, s ubpart s KKK and LLL ) , below

. 6(f) Reasons for Change in Burden There is no change in the labor hours in this IC R compared to the previous ICR. Thi s is due to two considerations. F irst, the regulations have not changed over the past three years and are not anticipated to change over the next three years. Secondly, the growth rate for the industry is very low, negative or non

- existent, so there is n ot significant change to the overall labor hours. There is however, an adjustment in the labor hour estimate. The previous ICR shows a total of 149,174 annual hours. This renewal IC R shows a total of 1 4 9, 180 annual hours

. The small labor hour increase of six hours was caused b y a mathematical error in the previous I CR. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of inf ormation is estimated to average 91 hours per response. Burden means the total tim e, effort, or financial resources expended by

persons to generate, maintain, retain, or disclose or provide informati on to or for a Federal agency

. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirement s; 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 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

- 2007

- 004 7

. 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,15

and to acc ess those documents in the public docket that are available electronically . When in the sy stem, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compl iance 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 leg al holiday s. 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

- 1 752

. 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 Docket ID Number EPA

- HQ

- OECA

- 2007

- 004 7 and OMB Control Number 2060

- 0 1 20 in any correspondence.
Part B o f the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.Table 1: A nnual Respondent Burden and Cost

– NSPS for Onshore Natural Gas Processing Plants (40 CFR p art 6 0 , s ubpart s

KKK an d LLL ) (A) (B) (C) (D) (E) (F) (G) (H)

Burden item Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent per year (C=AxB) Respondents

per year (a) Technical

person hours per year (E=CxD) Management

pe rson - hours per year (Ex0.05) Clerical

person - hours per year (Ex0.1) Cost ( $ ) (b)

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions Subpart KKK 1 1 1 563 563 28.2 56.3 $41,315 Subpart LLL 1 1 1 82 82 4.1 8.2 $6,017 B. Required activities Subpart KKK Notification of construction/ reconstruction c 2 1 2 57 114 5 .7 11.4 $8 ,365 Notification of modification c 8 1 8 56 448 22.4 44.8 $32,872 Notification of anticipated startup d 2 1 2 113 226 11.3 22.6 $16,583 Notification of actual startup d 2 1 2 113 226 11.3 22.6 $16,583 Notification o f electing to comply with a lternative standards for valves e 8 1 8 0 0 0 0 $0 Notification of initial performance test f 2 1 2 0 0 0 0 $0 Semiannual reports g 8 2 16 563 9,008 450.4 900.8 $660,962 Subpart LLL Initial performance test 60 1 60 3 180 9 18 $13,208 Repeat performance test 60 0.2 12 3 36 1.8 3.6 $2,642 Demonstration of CEMS 80 0.2 16 3 48 2.4 4.8 $3,522 Repeat Demonstration of CEMS 80 0.2 16 3 48 2.4 4.8 $3,522 C. Create Information Subpart KKK Initial performance test N/A Subpart LLL See 3B17

D. Gather existing information Subpart KKK N/A Subpart LLL See 3B D. Gather existing information See 3B E. Write report Subpart KKK See 3B Subpart LLL Notification of construction/ reconstruction c 2 1 2 1.5 3 0.15 0.3 $220 Notification of modification N/A Notification of anticipated startup h 2 1 2 3 6 0.3 0.6 $440 Notification of actual startup h 2 1 2 3 6 0.3 0. 6 $ 440 Notification of initial performance test h 2 1 2 3 6 0.3 0.6 $ 440 Notification of C MS demonstration h 2 1 2 3 6 0 .3 0 .6 $ 440 CMS demonstration See 3B Semiannual report i 40 2 80 82 6,560 328 656 $ 481,340 4. Recordkeeping requirements A. Read instructions Subpart KKK See 4C Subpart LLL See 3A B. Plan activities See 3E Subpart KKK See 4C Subpart LLL N/A C. Implement activities See 3E Subpart KKK Filing and maintaining records j 80 1 80 563 45,040 2,252 4,504 $3,304,810 Startup, shutdown, or malfunction k 80 1 80 112 8,960 448 896 $657,440 Recalibrate mo nitors 4 12 48 563 27,024 1,351.2 2,702.4 $1,982,886 Method 21 performance evaluation 2 2 4 563 2,252 112.6 225.2 $165,241 Subpart LLL N/A D. Develop record system Subpart KKK See 4C S ubpart LLL l 40 1 40 3 120 6 12 $8,805 E. Time to enter information Subpart KKK See 4C18

Subpart LLL Records of startup, shutdow n, or malfunction 1.5 12 18 3 54 2.7 5.4 $ 3,962 Records of continuous recording 0.5 700 350 82 28,700 1,435 2,870 $2,105,863 Records of capacity data 2 1 2 3 6 0.3 0.6 $4 4 0 F. Train personnel Subpart KKK See 4C Subpart LLL N/A G. Audits Subpart KKK N/A Subpart LLL N/A Subtotal 129,722 6,486.15 12,972.2 $ 9,518,3 5 8 TO TAL ANNUAL BURDEN AND COST (rounded) 149,180 $ 9,518,3 5 8
Assumptions:
a. We have assumed that the average number of respondents that will be subject to subpart KKK will be 563 with one new source becoming subject to the rule over the three

- year period of this ICR. It is also assumed that the overage number of respondents that will be subject to subpart LLL will be 82 with one additional source becoming subject to the rule over the three

- year period of this ICR

. b

. This ICR uses the following labor rates: $ 9 5. 32 per hour for Executive, Administrative, and Managerial labor; $ 64 .6 0 per hour for Technical labor, and $4 0.0 9 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 200 3 , “T able 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. We have assumed that one

- half of ne w facilities are the result of construction or reconstruction, while the other half are th e result of modifications of existing facilities. d

. We have assumed that 20 percent of existing respondents will construct one new facility per year.
e
. We have assumed that no respondent is expected to use the alternative standards. f

. We have assumed that while this subpart includes the option of using closed vent systems and control devices to demonstrate compliance, no respond ent is expected to use this option. T herefore, no respondent is expected to submit the associated notifications and reports. g
. We have assumed that each respondent will take 8 hours two times per year to w rite semiannual report s
. h

. We have assumed that each respondent will take two hours to complete reports. i. We have assumed that each respondent will take 40 hours two times per year to w rite semiannual reports. j

. We have assumed that each respondent will take 80 hours to file and maintain records. k. We have assumed that 20 percent of respondents will take 80 hours to im plement this activity. l

. We have assumed that each respondent will take 40 hours to develop record system.19

Table 2 : Average Annual EPA Burden

– NSPS for Onshore Natural Gas Processing Plants (40 CFR p art 6 0 , s ubpart s KKK and LLL ) (A) (B) (C) (D) (E) (F) (G) (H)

Activity EPA p erson hours per occurrence No. of

occurrences per plant per year EPA

p erson hours per plant per year (C=AxB) Plants per

year (a) Technical

person hours per year (E=CxD) Management

person - hours per year (Ex0.05) Clerical

person - hours per year (Ex0.1) Cost ($) (b)

Subpart KKK Notification of construction/ r econstruction c 2 1 2 56 112 5.6 11.2 $5,095 Review notification of modification c 2 1 2 56 112 5.6 11.2 $5,095 Review notification of anticipated s tartup d 2 1 2 11 2 224 11.2 22.4 $10,189 Review notification of actual startup d 2 1 2 112 224 11.2 22.4 $10,189 Notification of demonstration of CEMS 2 1 2 0 0 0 0 $0 Review initial CEMS demonstration report 2 1 2 0 0 0 0 $ 0 Review notificatio n of performance test 2 1 2 0 0 0 0 $0 Review results of performance test 2 1 2 0 0 0 0 $0 Review semiannual reports e 8 2 16 563 9,008 450.4 900.8 $ 409,756 Subpart LLL Review notification of constructi on/ r econstruction f 2 1 2 1.5 3 0.15 0.3 $137 Review notification of modification f 2 1 2 1.5 3 0.15 0.3 $137 Review notification of anticipated s tartup g 2 1 2 3 6 0.3 0.6 $ 273 Review notification of actual startup g 2 1 2 3 6 0.3 0.6 $273 Review notification of demonstration of CEMS g 2 1 2 3 6 0. 3 0. 6 $ 273 Review of CEMS demonstration report g 2 1 2 3 6 0.3 0.6 $273 Review notification of initial p erformance test g 2 1 2 3 6 0.3 0.6 $273 Review of semi annual reports e 8 2 16 82 1,312 65.6 131. 2 $59.68020

Revie w results of performance test 2 1 2 3 6 0.3 0.6 $273 TO TAL ANNUAL BURDEN AND COST (rounded) 12,689 $ 501,916 Assumptions:
a
. We have assumed that the average number of respondents that wil l be subject to subpart KKK will be 563 with one new source becoming subject to the rule over the three

- year period of this ICR. I t is also assumed that the average number of respondents that will be subject to subpart LLL will be 82 with one additional s ource becoming subject to the rule over the three

- year period of this ICR

. b. The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for governme nt overhead expenses. Managerial rates of $54.66 ( GS

- 13, Step 5, $34.16x1.6), Technical rate of $40.56 (GS

- 12, Step 1, $25.35 x 1.6), and Clerical rate of $21.95 (GS

- 6, Step 3, $13.72 x 1.6). T hese rates are from the Office of Personnel Management (OPM) “2004 General Schedule” which excludes locality rat es of pay.
c. We have assumed that one - half of ne w facilities are the result of construction or reconstruction, while the other half are the result of modifications of existing facilities. d

. We have assumed that 20 percent of respondents will each take two hours to review notifications.
e. We have assumed that it will take each respondent eight hours two time per year to review semiannual reports. f. We have assumed that one - half of ne w respondents will review notification of construction/reconstructi on and the other half will review notification of mo dification. g. We have assumed that each of the ne w respondents will take two hour to review notification.