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 part 60, subparts 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 apply 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. A process unit is defined as the equipment assembled for 

extraction of natural gas liquids from field gas, fractionation of liquids into natural gas products, or 

other processing of natural gas products.

The New Source Performance Standards (NSPS) for Onshore Natural Gas Processing: SO2

Emissions, published at 40 CFR part 60, subpart LLL, were proposed on January 20, 1984 and 

promulgated on October 1, 1985. These standards apply to the following affected facilities located 

at onshore natural gas processing plants: each sweetening unit, and each sweetening unit followed 

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

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

separates the hydrogen sulfide and carbon dioxide (CO2) contents from the sour natural gas stream. 

The provisions of subpart LLL do not apply to sweetening facilities that produce acid gas that is 

completely re-injected into oil or gas bearing geologic strata or that is otherwise not released to the 

atmosphere. The control and monitoring requirements of subpart LLL do not apply to affected 

facilities with design capacities of less than two long tons per day of hydrogen sulfide in the acid 

gas, expressed as sulfur.

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

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 system 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. In 
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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 563 sources per year will be subject to subpart KKK, and it is estimated 

that one additional source per year will become subject to the standard in the next three years. 

There are approximately 79 of these sources of these that are currently subject to subpart LLL, and 

it is estimated that three additional sources will become subject to the standard in the next three 

years.

There are approximately 563 onshore natural gas processing plants in the United States, 

which are all publicly owned and operated by the onshore natural gas processing industry. None 

of the 563 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 “Affected Public” listed below in Table 1: Annual Industry Burden 

and Cost - NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts 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 Part 60, Subparts

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 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

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

subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) 

install, use, and maintain such monitoring equipment, and use such 

audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall 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 onshore natural 

gas processing plants cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, the NSPS was promulgated for this source category 

at 40 CFR part 60, subparts 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 initial capability 

to comply with the emission standard. Continuous emission monitors are used to ensure 

compliance with the standard at all times. During the performance tests, a record of the operating 

parameters under which compliance was achieved 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 ensure that the pollution control devices are properly 

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

The performance 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. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subparts 
4

KKK and LLL.

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 their own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

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 (72 FR 10736) on March 9, 2007. No comments were received on the burden 

published in the Federal Register.

3(c) Consultations

Over the next three years, an average of 563 facilities per year will be subject to the 

standard. In estimating the affected number of sources and the growth rate of onshore natural gas 

processing plants subject to this standard, EPA contacted Ms. Lynn Reed at (918) 588-7380, 

ONEOK, Incorporated, Mr. Lance 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 

System (OTIS) which is the primary source of information regarding the number of existing 

sources. OTIS 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 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.

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 -
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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

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 (SIC) codes which correspond to 

the North American Industry Classification System (NAICS) code could be found in the following 

table:

40 CFR part 60, subparts 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 recordkeeping 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 Processing Plants (40 CFR Part 60, Subparts 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 system 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), 60.636(a), 

60.487(e)
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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 following 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, performance evaluations, calibration 

checks, adjustments and maintenance related to continuous monitoring 

systems.

60.7(f)

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

difficult to inspect (subpart KKK).

60.632(a), 

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

Keep records of inspections of closed vent systems 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 

systems 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 indicate 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)
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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 is less 

that 150 long tons per day of hydrogen sulfide expressed as sulfur 

(subpart LLL)

60.647(d)

Electronic Reporting

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.

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems 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 

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.

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).

Monitor 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 system leaks (subpart KKK).

Perform weekly visual inspections of pumps in light liquid service (subpart KKK).
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Respondent Activities

Monitor pressure relief devices in gas/vapor service for no detectable emissions, following 

pressure release (subpart KKK).

Monitor or repair leaks in pumps or valves in heavy liquid service, pressure relief devices in 

light or heavy liquid service, and connectors (subpart KKK).

Conduct annual inspections of vapor collection systems (subpart KKK).

Install, calibrate, maintain and operate CMS for (a) total sulfur emission rate and (b) exhaust gas 

temperature for oxidation control systems or reduction control systems that are followed by an 

incinerator (subpart LLL).

Install, calibrate, maintain, and operate CMS for reduced sulfur compound emission rate for 

reduction control systems that are not followed by an incinerator (subpart LLL)

Perform initial performance test, reference the methods discussed in the rule language, and 

repeat performance tests if necessary (subpart LLL).

Perform daily monitoring of (a) accumulation of sulfur product and (b) H2S Concentration in the 

acid gas from the sweetening unit (subpart LLL).

Perform hourly monitoring of acid gas flow rate from the sweetening unit and calculate the daily 

average (subpart LLL).

Calculate (a) daily sulfur feed rate and (b) daily required SO2 emission reduction efficiency

(subpart LLL).

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way e.g., continuous parameter monitoring system. Although personnel at the source 

still need to evaluate the data, this type 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, 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, excess emissions reports, 

required to be submitted by industry.

Audit facility records.

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

test reports are used by 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 compliance determinations.

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

by the EPA Office of Compliance. OTIS is an EPA database for the collection, maintenance, and 

retrieval of compliance data for approximately 125,000 industrial and government-owned 

facilities. EPA uses 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 or operator for two 

years.

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 types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

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

entities. 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 Table 1: Annual Industry Burden, NSPS for Onshore Natural Gas Processing Plants (40 CFR 

part 60, subparts 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 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. 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 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 149,180 (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 $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 

2003, 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 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 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 costs are the ongoing costs to maintain the monitor and other costs such as 

photocopying and postage.
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(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)

SO2 CEM, 

control outlet 

only for subpart 

LLL

$73,000 3 $219,000 $17,100 7 $119,700

 1

 Costs reflect installation and maintenance of an in-situ SO2 CEM after the control device and assume installation 

occurred during the construction of the facility.

 

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 ICR are $219,000. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $119,700. 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 $338,700.

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 

$501,916.

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

Managerial $54.66 (GS-13, Step 5, $34.16 x 1.6) 

Technical $40.56 (GS-12, Step 1, $25.35 x 1.6)

Clerical $21.95 (GS-6, Step 3, $13.72 x 1.6)

These rates are from the Office of Personnel Management (OPM) 2004 General Schedule which 

excludes locality rates of pay. Details upon which this estimate is based appear in Table 2: 

Average Annual EPA Burden, NSPS for Onshore Natural Gas Processing Plants (40 CFR part 60, 

subparts 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 ICR, on average over the next three years, approximately

563 existing respondents will be subject to the standard. It is estimated that one additional

respondent will become subject to subpart KKK and three for subpart LLL over the next three 

years.

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

years covered by this ICR. 

Number of Respondents

Year

(A)

Number of 1

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)

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 this 

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 (H2S) 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-year 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 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

Subpart KKK

Notification of construction/reconstruction 57 1 n/a 57

Notification of modification 56 1 n/a 56

Notification of anticipated startup 113 1 n/a 113

Notification of actual startup 113 1 n/a 113

Notification of demonstration of continuous 

monitoring 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 563.

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 $9,518,358. Details regarding these estimates may be 

found in Table 1: Annual Industry Burden, NSPS for Onshore Natural Gas Processing Plants (40 

CFR part 60, subparts 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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor costs are $9,518,358. Details regarding these estimates may be 
14

found in Table 1. Annual Respondent Burden and Cost: NSPS for Onshore Natural Gas Processing 

Plants (40 CFR part 60, subparts KKK and LLL), below. Furthermore, the annual public reporting 

and recordkeeping burden for this collection of information is estimated to average 91 hours 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 burden and cost over next three years 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 part 60, subparts KKK and LLL), below.

6(f) Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the previous ICR. This is due 

to two considerations. First, 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 not 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 ICR shows a total of 149,180 annual hours. The small 

labor hour increase of six hours was caused by a mathematical error in the previous ICR.

6(g) Burden Statement

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

estimated to average 91 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-2007-0047. 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 access those documents in the public docket that are available electronically. When in the 

system, 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 Compliance Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, N.W., Washington, DC. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 

Enforcement and Compliance Docket and Information Center Docket is (202) 566-1752. Also, 

you 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-2007-0047 and OMB 

Control Number 2060-0120 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 – NSPS for Onshore Natural Gas Processing Plants (40 CFR part 60, subparts

KKK and LLL)

(A) (B) (C) (D) (E) (F) (G) (H) 

Burden item 

Personhours per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Personhours per 

respondent 

per year 

(C=AxB)

Respondents 

per year (a)

Technical 

personhours per 

year 

(E=CxD)

Management 

person-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 c8 1 8 56 448 22.4 44.8 $32,872

 Notification of anticipated startup d2 1 2 113 226 11.3 22.6 $16,583

 Notification of actual startup d2 1 2 113 226 11.3 22.6 $16,583

 Notification of electing to comply with

 alternative standards for valves e 8 1 8 0 0

0 0

$0

 Notification of initial performance test f2 1 2 0 0 0 0 $0

 Semiannual reports g8 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 3B
17

 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

 

212 1.53 0.15 0.3 $220

 Notification of modification N/A

 Notification of anticipated startup

h

21236 0.3 0.6 $440

Notification of actual startup

h

21236 0.3 0.6$440

Notification of initial performance test

h

21236 0.3 0.6$440

Notification of CMS demonstration

h

 212360.30.6$440

CMS demonstration See 3B

Semiannual report

i

402 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 recordsj 801 80 563 45,040 2,252 4,504 $3,304,810

 Startup, shutdown, or malfunctionk 801 80 112 8,960 448 896 $657,440

 Recalibrate monitors4 12 48 563 27,024 1,351.2 2,702.4 $1,982,886

 Method 21 performance evaluation224 563 2,252 112.6 225.2 $165,241

 Subpart LLL N/A

 D. Develop record system 

 Subpart KKK See 4C

 Subpart LLL

l

401 403 120

6 12 $8,805

 E. Time to enter information

 Subpart KKK See 4C
18

 Subpart LLL

 Records of startup, shutdown, 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 $440

 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 $9,518,358

TOTAL ANNUAL BURDEN AND COST 

(rounded) 149,180 $9,518,358

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: $95.32 per hour for Executive, Administrative, and Managerial labor; $64.60 per hour for Technical labor, and $40.09

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2003, “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.

 We have assumed that one-half of new 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 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 respondent is 

expected to use this option. Therefore, 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 write semiannual reports.

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 write 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 implement 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 part 60, subparts KKK and 

LLL)

(A) (B) (C) (D) (E) (F) (G) (H) 

Activity

EPA 

personhours per 

occurrence

No. of 

occurrences 

per plant 

per year

EPA 

personhours per 

plant per 

year 

(C=AxB)

Plants per 

year (a)

Technical 

personhours 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/

 reconstruction c 2 1 2 56 112 5.6 11.2 $5,095

 Review notification of modification c2 1 2 56 112 5.6 11.2 $5,095

 Review notification of anticipated

 startup d 2 1 2 112 224 11.2 22.4 $10,189

 Review notification of actual startup d2 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 notification 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 construction/

 reconstruction f 2 1 2 1.5 3 0.15 0.3 $137

 Review notification of modification f2 1 2 1.5 3 0.15 0.3 $137

 Review notification of anticipated

 startup g 2 1 2 3 6 0.3 0.6 $273

 Review notification of actual startup g2 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 g2 1 2 3 6 0.3 0.6 $273

 Review notification of initial 

 performance test g 2 1 2 3 6 0.3 0.6 $273

 Review of semiannual reports e8 2 16 82 1,312 65.6 131.2 $59.680
20

Review results of performance test 2 1 2 3 6 0.3 0.6 $273

TOTAL ANNUAL BURDEN AND COST 

(rounded) 12,689 $501,916

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 average 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.

 The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial 

rates of $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). These 

rates are from the Office of Personnel Management (OPM) “2004 General Schedule” which excludes locality rates of pay.

c.

 We have assumed that one-half of new 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 new respondents will review notification of construction/reconstruction and the other half will review notification of 

modification.

g.

 We have assumed that each of the new respondents will take two hour to review notification.