SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

LLL) (Revised)

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) 

(Revised), EPA ICR Number 2438.02, OMB Control Number 2060-0120

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for 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 equipment leaks of Volatile Organic 

Compound (VOC) service or in wet gas service, and the groups 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. This information is being collected to 

assure compliance with 40 CFR part 60, subpart KKK.

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

SO2 Emissions- (0 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 (LT/D) of 

hydrogen sulfide in the acid gas, expressed as sulfur. This information is being collected to 

assure compliance with 40 CFR part 60, subpart LLL.

As part of the mandatory review of NSPS as required under the Clean Air Act, the

requirements of both subpart KKK and LLL would be contained in a new subpart, 40 CFR 60, 

subpart OOOO. Subpart OOOO will supersede subpart KKK, and the existing provisions of 

subpart KKK and LLL would be included in the new subpart OOOO along with the new

proposed provisions. The revisions to this ICR account for the reduction in new sources 
2

estimated that will report under KKK and LLL (new sources will now report under the ICR for 

subpart OOOO). This ICR accounts for the existing burden for sources still reporting under KKK 

and LLL. We have also updated labor cost estimates and removed all instances of recording and 

reporting due to start-up, shutdown and malfunction.

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

periodic reports by the owners/operators of the affected facilities. 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

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 507 sources per year will be subject to subpart KKK. 

Approximately 70 of the 507, are also currently subject to subpart LLL.

None of the plants in the United States are owned by neither state, local, tribal, or the 

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

businesses. The burden to the “Affected Public” may be found in Table 1: Annual Respondent 

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

KKK and LLL) (Revised). The burden to the “Federal government” is attributed entirely to work 

performed by Federal employees or government contractors; this burden may be found in Table 

2: Annual Agency Burden and Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR 

Part 60, Subparts KKK and LLL) (Revised).

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 
3

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. 

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 either 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 standards 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, that leaks are being detected and repaired, and that the standard is being 

met. The performance test may also be observed.
4

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. Non-duplication, Consultations, and Other Collection Criteria

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

This is not applicable since this is a rule related ICR.

3(c) Consultations

During the previous ICR renewal, several consultations were conducted during a previous 

renewal of this ICR. 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). 

These contacts, in turn, consulted a limited number of its members. Additionally, 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. It was determined that an average of 507 facilities per year will be subject to the standard 

over the next three years. Since this revision is removing new sources subject to KKK in order to 

account for them under subpart OOOO, no further contacts were made. 

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
5

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 - 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 in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are onshore natural gas 

processing plants. The North American Industry Classification System (NAICS) codes 211111 

and 211112 for onshore natural gas processing plants.

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 that is 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

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)

Semiannual reports (subpart KKK) 60.636(a)-(c), 

60.487(a)
6

Notifications

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

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)

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 (LT/D) of hydrogen sulfide expressed as 

sulfur (subpart LLL).

60.647(d)

(ii) Respondent Activities

Respondent Activities

Read instructions.

Write the notification and reports listed above.

Enter information required to be recorded above.
7

Respondent Activities

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).

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).

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, 
8

storage, and distribution of the required information.

Agency Activities

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 CDX

5(b) Collection Methodology and Management

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

compliance and enforcement programs of the delegated permitting authority. Information 

contained in the reports will be required to submit records electronically to EPA’s Central DATA 

Exchange (CDX) using the Electronic Reporting Tool. CDX enables fast, efficient and more 

accurate environmental data submissions from state and local governments, industry and tribes to 

the EPA and participating program offices. EPA's CDX is the point of entry on the 

Environmental Information Exchange Network (Exchange Network) for environmental data 

submissions to the Agency. CDX works with both EPA program offices looking for a way to 

better manage incoming data, and stakeholders looking for a way to reduce burden from 

reporting requirements. 

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

years. The semiannual reports are used for problem identification, as a check on source operation 

and maintenance, and for compliance determinations.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). After reviewing 

relevant available background documents related to the standard, an estimate of the number of 

small entities affected could not be determined. 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 below Table 1: Annual Respondent Burden and Cost, NSPS for Onshore Natural Gas 

Processing Plants (40 CFR Part 60, Subparts KKK and LLL) (Renewal).
9

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 each of the subparts included in this ICR. 

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

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

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 109, 266 labor hours. The recordkeeping hours 

shown below in Table 1 are 61,959. The reporting requirement hours shown below in Table 1 

are 47,308. 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 $116.05 ($55.26 + 110%) 

Technical $97.21 ($46.29 + 110%)

Clerical $48.87 ($23.27 + 110%)

These rates are from the U. S. Department of Labor, Bureau of Labor Statistics, March 2010, 

“Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, 

“Total Compensation.” The rates have been increased by 110 percent to account for the benefit 

packages available to those employed by private industry.

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

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

required by subpart KKK are labor costs. There are no capital/startup or operation and 

maintenance costs.

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

LLL 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 
10

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.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B×C)

(E)

Annual O&M 

Costs for One 

Respondent a

(F)

Number of 

Respondents 

with O&M b

(G)

Total 

O&M,

(E×F)

SO2 CEM, 

control outlet 

(only for subpart 

LLL)

$73,000 0 0 $17,100 4 $68,400

Assumptions:

a 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.

b

 We expect four existing facilities to have annual O & M costs for monitoring under subpart LLL. 

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $68,400. This is the 

total of column G.

6(c) Estimating Agency Burden and Cost

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

information. The EPA 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 

$420,400. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010 General 

Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to 

account for the benefit packages available to government employees. Details upon which this 

estimate is based appear below in Table 2: Annual Agency Burden and Cost, NSPS for Onshore 

Natural Gas Processing Plants (40 CFR Part 60, Subparts KKK and LLL) (Renewal).
11

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

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

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

three years. The overall average number of respondents, as shown in the table below is 507 per 

year.

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

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports

Year

(A) (B) (C) (D)

Number of 

Existing 

Respondents

Number of 

Existing 

Respondents that 

would now 

Report under 

Subpart OOOO a

Number of 

Existing 

Respondents that 

keep records but 

do not submit 

reports

Number of 

Respondents

(D=A-B-C)

Subpart KKK 

1 561 27 0 534

2 534 27 0 507

3 507 27 0 480

Average 534 27 0 507

Subpart LLL b

1 79 3 3 73

2 76 3 3 70

3 73 3 3 67

Average 76 3 3 70

Assumptions:

a. In this standard, existing respondents submit initial notifications. New sources for the same affected facilities 

report under subpart OOOO. We expect 27 of the existing facilities to undergo modifications in each year , which 

would indicate these facilities would report under subpart OOOO and no longer report under subpart KKK. For 

subpart LLL, we expect three facilities to perform a modification and report under subpart OOOO. 

b. Affected facilities with design capacities of less than two long tons per day (LT/D) 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.

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

average Number of Respondents over the three-year period of this ICR is 507. This includes the 

70 respondents that also report under subpart LLL because all sources subject to LLL are also 

subject to subpart KKK.
12

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents that 

include a report for 

LLL with their 

report for KKK

(E)

Total Annual 

Responses

E = (B×C)

Subpart KKK and LLL

Semiannual reports 507 2 70 1,014

TOTAL (rounded) 1,014

N/A – Not Applicable.

The number of Total Annual Responses is 1,014.

The total annual labor costs are $10,251,963. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost, NSPS for Onshore Natural Gas 

Processing Plants (40 CFR Part 60, Subparts KKK and LLL)(Revised).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 below, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 109,266. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost, NSPS for Onshore Natural Gas 

Processing Plants (40 CFR Part 60, Subparts KKK and LLL) (Revised). Furthermore, the annual 

public reporting and recordkeeping burden for this collection of information is estimated to 

average 107.7 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $68.400. The 

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

Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 9,329

labor hours at a cost of $420,400. See below Table 2: Annual Agency Burden and Cost, NSPS 

for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts KKK and LLL) (Revised).

6(f) Reasons for Change in Burden
13

The change in burden results from the development of subpart OOOO, which supersedes 

both subpart KKK and LLL. Any new or modified affected facility will begin reporting under 

subpart OOOO instead of subpart KKK and LLL.

6(g) Burden Statement

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

is estimated to average 107.7 per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information to 

or for a Federal agency. This includes the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2010-0363. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

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 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 Officer 

for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2010-0363 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.
14

Table 1: Annual Respondent Burden and Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts KKK 

and LLL) (Revised)

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

Reporting/Recordkeeping 

Requirements

Person- hours 

per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Personhours per 

respondent 

per year 

(C = A×B)

Respondents 

per year a

Technical 

personhours per 

year 

(E = C×D)

Management 

person-hours 

per year 

(E×0.05)

Clerical 

personhours 

per year 

(E×0.1)

Cost ($) b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions

Subpart KKK 1 1 1 507 507 25 51 $54,705

Subpart LLL 1 1 1 70 70 4 7 $7,553

B. Required activities

Subpart KKK and LLL

Semiannual reports d 40 2 80 507 40,560 2,028 4,056 $4,376,404

Reporting Subtotal 41,137 2,057 4,114 $4,438,662

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 e 80 1 80 507 40,560 2,028 4,056 $4,376,404

Recalibrate monitors 4 12 4 507 2,028 101 203 $218,820

Method 21 performance evaluation 2 2 4 507 2,028 101 203 $218,820

Subpart LLL N/A
15

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

Reporting/Recordkeeping 

Requirements

Person- hours 

per 

occurrence

No. of 

occurrences 

per 

respondent 

per year

Personhours per 

respondent 

per year 

(C = A×B)

Respondents 

per year a

Technical 

personhours per 

year 

(E = C×D)

Management 

person-hours 

per year 

(E×0.05)

Clerical 

personhours 

per year 

(E×0.1)

Cost ($) b

D. Develop record system

Subpart KKK See 4C

Subpart LLL l 40 1 40 3 120 6 12 $12,948

E. Time to enter information f

Subpart KKK and LLL See 4C

Records of continuous recording 0.5 261 131 70 9,135 457 914 $985,662

Records of capacity data 2 1 2 3 6 0.3 0.6 $647

F. Train personnel

Subpart KKK See 4C

Subpart LLL N/A

G. Audits

Subpart KKK N/A

Subpart LLL N/A

Recordkeeping Subtotal 53,877 2,694 5,388 5,813,301

TOTAL ANNUAL BURDEN AND 

COST 109,266 $10,251,963

N/A - Not Applicable.

Assumptions:

a. We have assumed that the average number of respondents that will be subject to subpart KKK will be 507. New affected facilities will no longer report under KKK 

or LLL, and instead will report under subpart OOOO. It is also assumed that the average number of respondents that will be subject to subpart LLL will be 70.

b. This ICR uses the following labor rates: $116.05 per hour for Executive, Administrative, and Managerial labor; $97.21 per hour for Technical labor, and $48.87 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2010, “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 each respondent will take 8 hours, two times per year to write semiannual reports.

d. We have assumed that each respondent will take 40 hours, two times per year to write semiannual reports.

e. We have assumed that each respondent will take 80 hours to file and maintain records.

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

g. We have assumed continuous monitoring occurs for 0.5 hours on the approximate number of business days. 
16

Table 2: Annual Agency Burden and Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts KKK and 

LLL) (Revised)

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

Activity EPA personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA 

personhours per 

plant per 

year

Plants per 

year a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours per 

year

Cost ($) b

(C = A×B) (E = C×D) (E×0.05) (E×0.1)

Subpart KKK and LLL

Review semiannual reports e 8 2 16 507 8,112 406 811 $420,400 

TOTAL ANNUAL BURDEN 9,329 $420,400 

Assumptions:

a. We have assumed that the average number of respondents that will be subject to subpart KKK will be 507. New affected facilities will no longer report under KKK or 

LLL, and instead will report under subpart OOOO. It is also assumed that the average number of respondents that will be subject to subpart LLL will be 70. 

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 

$62.27 (GS-13, Step 5, $38.92 × 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 × 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $15.63 × 1.6). These rates are 

from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality rates of pay.