SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

( Revised )

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Natural G as Transmission and Storage (40 CFR part 63, subpart HHH) ( Revised )

,

EPA ICR Number 1789.07 , OMB Control Number 2060

- 0418

. 1(b) Short Characterization/Abstract

T he amendments to the ICR are a result of the review of the existing The National

Emission Stan dards for Hazardous Air Pollutants (NESHAP) for Natural Gas Transmission and

Storage (40 CFR part 63, subpart HHH) as required by the Clean Air Act. The NESHAP for

Natural Gas Transmission and Storage, published at 40 CFR part 63, subpart HHH, were

propose d on February 6, 1998 and promulgated on June 17, 1999. These regulations apply to

existing facilities and new facilities that are major sources of hazardous air pollutants (HAP) and

that transport or store natural gas prior to entering the pipeline to a l ocal distribution company or

to a final end user (if there is n o local distribution company). New facilities include those that

commenced construction or reconstructi on after the date of proposal. This information is being

collected to assure compliance with 40 CFR part 63, subpart HHH.

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

periodic reports by the owners/operato rs of the affected facilities. These notifications, reports,

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

subject to NESHAP.

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

measurements, and retain the file for at least 5 years following the date of such measu rements,

mai ntenance 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) re gional office.

The proposed rulemaking would amend title 40, chapter I, part 63 subpart HH H to

include, emission sources for which standards were not previously developed. We are proposingstandards for these emission sources pursuant to CAA section 112(d) (2) and (3). Therefore, the

number of affected facilities under this su bpart is expected to increase. The estimates of the size

of the regulated universe are based on information obtained from the National Emissions

Inventory (NEI) database. Overall, EPA estimates that approximately 53 respondents would be

subject to th e regulation

. Labor costs were also updated in this ICR to reflect current burden on

industry and the Agency. EPA assumes that there is an average of one affected facility per plant

(i.e., r espondent). EPA estimates that the annual cost of this information collection will be $0 for

non

- labor and $ 86,823 for labor, based on a labor burden of 2,591 hour s

.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA i s charged under Section 112 of the Clean Air Act, as amended, to establish

standards of performance for each category or subcategory of major sources and area sources of

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous

air pollutants and shall require the maximum degree of emission reduction. In addition, section

114(a) states that the Administrator may require any owner/operator subject to any requirement

of this Act to:

 e stablish and maintain such records;

 m ake such reports;

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

use such audit procedures, or methods;

 sample such emissions (in accordance with such procedures

or methods, at such locations, at such intervals, during such

periods, and in suc h manner as the Administrator shall

prescribe);

 keep records on control equipment parameters, production

variables or other indirect data when direct monitoring of

emissions is impractical;

 submit compliance certifications in accordance with

Section 114( a)(3); and provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from natural gas transmission and

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

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

category at 40 CFR part 63, subpart HHH.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compli ance with the

applicable regulations which where promulgated in acco rdance 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 a n affected facility ’ s initial

capability to comp ly with the emission standard. Continuous emission monitors are used to

ensure compliance w ith the standard at all times. During the performance test, a record of the

operating parameters under which complian ce 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 re quirements of the regulations. The reviewing

authority may then inspect the source to check if the pollution control devices are properly

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

performance test may also be obse rved.

The required semiannual reports are used to determine periods of excess emissions,

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

determinations.

The information generated by the monitoring, recordkeepin g and reporting requirements

described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP

continues to operate the control equipment in compliance with the regulation.

3. Non

- duplication, Consultations, and Other Collectio n Criteria

3(a) Non

- duplication

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

ap propriate EPA regional office. Otherwise, the information is sent directly to the de legated stateor local agency. If a state or l ocal 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 requ ired by the Federal standards. Therefore, no duplic ation

exists.

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

This action is not applicable because it is a rule related ICR.

3(c) Consultations

During earlier ICR renewal s
, EPA contacted the American Petroleum Institute (API), the

American G as Association (AGA), and the Interstate Natural Gas Association of America

(INGAA) to determine whether it would be possible for the Agency to reduce the recordkeeping

and reporting burden or improve the language in the standards to f acilitate industry co mpliance.

EPA also solicited information about the size, growth, and other characteristics of the regulated

industry. API declined to provide comments on the NESHAP. EPA did not receive a response

from AGA or INGAA.

3(d) Effects of Less Frequent Collecti on

Less frequent information collection would decrease the margin of assurance that

facilities are co ntinuing to meet the standards. Requirements for information gathering and

recordkeeping are useful techniques to ensure that good operation and maintenanc e practices are

applied and emission limitations are met. If the information required by these standards was

collected less frequently, the likelihood of detecting poor operation and maintenance of control

equipment and noncompliance would decrease.

3(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations

established by OMB at 5 CFR part 1320, section 1320.5.

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

notificati ons, for at least 5 years. This is consistent with the General Provision s as applied to the

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

Part 70 permit program and the five year statute of limitations on wh ich the p ermit program is

based. T he retention of records for five years would allow EPA to establish the compliance

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

level of enforcement action. Historically, EP A has found that the most flagrant violatorsfrequently have violations e xtending beyond the five years. EPA would be prevented from

pursuing the worst violators due to the destruction or nonexistence of records if records were

retained for less than five years.

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 Informa tion (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 sensit ive questions.

4. The Respondents and the Information Requested

4(a) Respondents

, SIC and NAICS Codes

The respondents to the recordkeeping and reporting requirements are owners/operators of

natural gas transm ission and storage facilities. NAICS (The Nor th American Industry

Classification System) 48621 and 22121, for Pipeline Transportation of Natural Gas and Natural

Gas Distribution, respectively.

4(b) Information Requested

(i) Data Items

All data in this ICR that are recorded and/or reported are requi red by the NESHAP for

Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH). Respondents have the

opportunity to use to use monitoring equipment that automatically records parameter data to

alleviate burden. Under this provision, it would be r equired to transmit reports and data

electronically.

A source must make the following reports:

Notification Reports

Initial notification that a source is subject to the provisions in subpart

HHH. 63.9(b)(2), 63.1274(a), 63.1285(b)(1) andNotification Reports

(b)(2)

Notific ation of the date of a performance test. 63.7(b) and (c), 63.8(e)(2), 63.9(e), 63.9(g)(1), 63.1274(a), 63.1285(b)(3)
Notification of Compliance Status Report, including the results of any continuous monitoring system performance evaluations and inspection

results. 63.9(h), 63.1270(d), 63.1274(a), 63.1283(c)(2)(ii)(A), 63.1285(b)(4), 63.1285(d)(1) through (d)(10)
Notification of change in compliance demonstration methods for control device performance (submit with Periodic Report). 63.1282(e)

Performance test results for closed

- vent systems using flares as the control device (submit with Notification of Compliance Status Report). 63.7(g), 63.10(d)(2), 63.1274, 63.1282(d)(3), 63.1285(d)(2)
Design analysis documentation, including operating parameters and

c alculations, for closed

- vent systems using control devices other than flares (submit with Notification of Compliance Status Report). 63.1274, 63.1282(d)(4), 63.1285(d)(4)(i) through (d)(4)(iii)
One complete test report for each test method used for a part icular source (submit with Notification of Compliance Status Report). 63.1285(d)(3)

Analysis demonstrating whether an affected source is a major source (submit with Notification of Compliance Status Report). 63.1285(d)(8)

Statement of compliance with sub part HHH (submit with Notification of Compliance Status Report). 63.1285(d)(9)

Notification of any process change. 63.1285(f)

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

Notification of intent to construct or recon struct. 63.9(b)(5)(i), 63.9(d)(4)(i), 63.1274(a)

Notification of actual date of startup. 63.9(b)(4)(v), 63.9(b)(5)(ii), 63.1274(a)Notification Reports

Results of performance evaluation. 63.8(e)(5), 63.10(e), 63.1274(a)

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

Semiannual Periodic Reports. 63.10(e), 63.1274(a), 63.1285(e)

Report to demonstrate compliance with benzene emission limit (alternative standards) (submit with Notification of Compliance Status Report). 63.1285(d)(7)

Analysis that demonst rates conditions under which the facility reduces 95.0 percent of its HAP emissions (submit with Notification of Compliance Status Report). 63.1281(e)(2), 63.1285(d)(10)

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

Semiannual excess emissio ns and continuous monitoring system performance report. 63.9(c)(8), 63.10(e)(3), 63.1274(a)

A source must keep the following records:

Recordkeeping
Records for each monitoring system including documentation of incidents such as breakdowns, repairs, calibration checks, and other

down time. 63.10(b)(2), 63.10(c), 63.1272(d), 63.1274(a), 63.1283(d), 63.1284(b)(3)
Continuous records of equipment operating parameters and daily average values of the parameters. 63.1284(b)(4)(i) and (ii)

Records of the times and duration of all periods during which pilot

flames are absent. 63.1284(b)(4)(ii), 63.1284(e)(3)

Records of flow indicator operation, detection, and vent stream

diversions. 63.1284(b)(4)(iii)

Records of inspections of seals or closure mechanisms and records of broken or changed seals, valves, or locks. 63.1284(b)(4)(iv)

Continuous monitoring system quality control program. 63.8(d), 63.1274(a)
Records pertaining to the inspection of closed

- vent systems including maintenance, leaks, repairs, dela ys, and shutdowns. This also applies to parts that are difficult or unsafe to inspect and those where a leak or

defect is detected. 63.1283(c)(3) through (c)(7), 63.1284(b)(5) through (8)

Records of glycol dehydration unit baseline operations, throughput quantity, and emissions information. 63.1281(e)(1) and (e)(2), 63.1284(b)(9)Recordkeeping

and (10), 63.1284(d)

Records of compliance with benzene emission limit (alternative standards). 63.1281(e)(2), 63.1284(c)

T hroughput and emissions records of exempt glycol dehy dration units. 63.1274(c) and (d), 63.1284(d)

Records of flare design and emissions. 63.1284(e)
Records of leak or defect detection, severity (maximum instrument reading), and date of repair. 63.1284(b)(7) and (b)(8)

Site

- specific performance evaluation test plan. 63.7(c)(2), 63.8(d)(2), 63.8(e)(3)(i), 63.1274(a)

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

(ii) Respondent Activities Respondent Activities

Read instructions.
Install, calibrate, maintain, and operate closed vent sy stems and CMS to: 1) achieve a 95% reduction in HAP, TOC, or total HAP, for control devices and vapor recovery devices; 2) achieve a reduction to 20 ppm of TOC or total HAP, and operates at a minimum residence time of 0.5 seconds at a minimum temperature o f 760 degrees Celsius for combustion devices.
Perform initial performance test, using the procedures listed in 40 CFR 63.1282(d), and repeat performance tests if necessary.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.
Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.

Trai n personnel to be able to respon d to a collection of information.

Transmit , or otherwise disclose the information.

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

mechanical, or other technical collection tech niques. Electronic submissions of reports are

required.5. The Information Col lected: 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 Activit ies

Observe initial performance tests and repeat performance tests if necessary.
Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.
Audit facility records.

A nalyze, and maintain data in CDX

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 pr operly installed and operated. Performance

t est reports are used by the Agency to discern a source = s initial capability to comply with the

emission standard, and serve as a record of the operating conditions under which compliance was

achieved. Data and records maintained by the respondents are tabu lated and published for use in

compli ance and enforcement programs. The semiannual reports are used for problem

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

determinations. The records required by this regulation must be retained by the owner or

operator for 5 years.

Informa tion contained in the reports will be required to submit records electronically to

EPA ’s Central DATA Exchange (CDX) using the Electronic Reporting Tool. The Central Data

Exchange (CDX) enables fast, efficient and more accurate environmental data submissions from

state and local governments, industry and tribes to the Environmental Protection Agency (EPA)

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

Informati on 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 reportingrequiremen ts.

5(c) Small Entity Flexibility

The majority of the respondents are large enti ties (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 te chnical 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 need ed to ensure compliance and, therefore, cannot reduce them further for small

entities.

5(d) Collection Schedule

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

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

Transmission and Storage (40 CFR part 63, subpart HHH), attached.

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and

reporting requirements applicab le 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 unde r the Paperwork Reduction Act. Specific tasks and major assumptions

have been identified w here appropriate. Responses to this information collection are mandatory.

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

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

6 (a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 2,591 hours ( To tal Labor Hours from Table 1).

These hours are based on Agency studies a nd background documents from the development of

the regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments previously received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This I CR uses the following labor rates: $33.51 per hour for technical labor,$52.85 per hour for management labor, and $23.43 for clerical labor. The rates have already been

increased by 110 percent to account for the benefit packages available to those employe d by

private industry. These rates are from the Employer Costs for Employee Compensation

Historical Listing March 2004

– December 2010 published by the Bureau of Labor and Statistics

and represents the state of the industry in 2008, consistent with the con trol costs associated with

the proposed revisions (Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf).

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

The only costs to the regulated industry resulting from informat ion collection activities

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

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

installe d flares to control emissio ns. The only continuous monitoring required for a flare is the

monitoring of the presence of the pilot flame, which is a requirement for proper operation of a

flare under 40 CFR 63.11(b)(5).

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

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

regulation is the cost of labor

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

6(c) Estimating Agency Burden and Cost

The only costs to the Agenc y 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

$ 17,545

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

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

Managerial $59.63 (GS

- 13, Step 5, $37.27 + 60%)

Technical $47.20 (GS

- 12, Step 1, $29.50 + 60%)

Clerical $23.94 (GS

- 6, Step 3, $14.96 + 60%)

These rates are from the Office of Personnel Management (OPM), 2008 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. Costs have been estimated in 2008dollars for this ICR to be consistent with other costs (i .e. control devices) estimated in the

development of the proposed revisions. Details upon which this estimate is based appear in Table

2: Annual Agency Burden and Cost, NESHAP for Natural Gas Transmission and Storage (40

CFR part 63, subpart HHH), attache d.

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

A pproximately 36 existing respondents a nd an additional 17 new responde nts will be

subject to the reporting requirements for this NESHAP. The new respondents consist of 2 new

facilities and 15 existing facilities. The overall average number of respondents, as shown in the

table below, is 53 per year over the 3 year period. This estimate was determined based on

methodology outlined in the previous ICR, in addition to research necessary to conduct the

revision of the current rule.

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

three years covered by this ICR.

Respondents That Submit Reports (C)

Number of New Respondents That Are Existing

Sourc es (E)

Number of Respondents (E=A+B) Year (A)

Number of New Respondents (B)

Number of Existing Respondents

1 17 19 15 36

2 17 36 15 53

3 17 53 15 70

Avg 17 36 15 53The total number of annual responses per year is calcula ted using the following table:

Total Annual Responses

(A)

Information Collection Activity (B)

Number of Respondent

s (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But
Do Not Submit Reports (E)

Total Annual Respo nses E=(BxC)+D

Notification of intent to

construct or reconstruct 17 1 N/A 17

Notification of actual date of
startup 17 1 N/A 17

Notification of date of continuous monitoring system performance evaluation 17 1 N/A 17

Notification of planne d date of performance test 17 1 N/A 17

Notification of Compliance Status Report 17 1 N/A 17

Semiannual Reports

36 2 N/A 72

Total 157

The number of Total Annual Responses is 157

.

The total annual labor costs are $ 86,823

. Details regar ding these estimates may be found

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

Storage (40 CFR part 63, subpart HHH), attached.

The total annual capital/startup and O&M costs to the regulated entities are $0. The cost

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

(O&M) Costs.

The average annual Agency burden and cost over next three years is estimated to be 400

labor hours at a cost of $ 17, 545 . See Table 2: Annual Agency Burden and Cost, NESHAP for

Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH), attached.

6(e) Bottom Line Burden Hours Burden Hours and Cost TablesThe 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 $ 86,823 . Details regarding these estimates may be found

in Table 1: Annual Respondent Burden and Cost, NESHAP for Natural G as Transmission and

Storage (40 CFR part 63, subpart HHH), attached.

The total annual capital/startup and O&M costs to the regulated entity are $0. The cost

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

(O &M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next 3 years is estimated to be 400

labor hours at a cost of $ 17, 545 . See Table 2 : Annual Agency Burden and Cost, NESHAP for

Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH), attached.

6(f) Reasons for Change in Burden

T he number of affected facilities under this subpart is expected to increas e based on the

inclusion of previously unregulated sources pursuant to CAA section 112(d)(2) and (3). In

addition, labor costs have been updated.

6(g) Burden Statement

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

is estimated to average 16.5 hours per response. Burden means the total time, effort, or financial

resources exp ended 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 collecti ng, 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 resp ond 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 o f 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 estimat es, 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

- 2008

- 0425

. 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 docke t that are available

electronically. When in the system , select “search,” then key in the docket ID number identified

in this document. The documents are also available for public viewing at the Enforcement and

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West,

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal

holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone

number for the Enforcement and Compliance Docket and Information Center Docket is (202)

566

- 1514. Also, you can send comments to the Office of Information and Regulatory Affairs,

Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention:

Desk Office for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2008

- 0425

and OMB Control Number 2060

- 0418 in any correspondence.

Part B of the Supporting Statement

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

information.Table 1. Annual Respondent Burden and Cost,

NES HAP for Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH) 16

Activity (A)

Technical

Hrs/

Occurrence (B)

Occurrences/ Respondent/

Yr. (C)

Hours/ Respondent/

Yr. [C=AxB] (D)

Number of Respondents (E)

Technical

Hrs/Yr. [E=CxD] (F )

Management
Hours/Yr. [F=0.05xE] (G)

Clerical

Hours/Yr. [G=0.1xE] (H) 1

Total Labor
Costs/Yr. ($)

1. Applications Not applicable
2. Survey and Studies Not applicable
3. Reporting Requirements

a. Read instructions 1 1 1 36 36 1.8 3.6 1,386

b. Re quired activities Not applicable

c. Create information Not applicable

d. Gather existing information 2 1 2 36 72 3.6 7.2 2,772

e. Write reports

i. Notification of construction/

reconstruction 1 1 1 17 17 0.85 1.7 654

ii. Notification of actual startup 1 1 1 17 17 0.85 1.7 654

iii. Notification of date of CMS performance evaluation 1 1 1 17 17 0.85 1.7 654

iv. Notification of planned date of performance test 1 1 1 17 17 0.85 1.7 654

v. Notification of Compliance Status Rep ort 4 1 4 17 68 3.4 6.8 2,618

vii. Semiannual Periodic Report 4 2 8 36 288 14.4 28.8 11,087

Reporting Subtotals 611.8 $20,480Table 1. Annual Respondent Burden and Cost,

NES HAP for Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH) 17

Activity (A)

Technical

Hrs/

Occurrence (B)

Occurrences/ Respondent/

Yr. (C)

Hours/ Respondent/

Yr. [C=AxB] (D)

Number of Respondents (E)

Technical

Hrs/Yr. [E=CxD] (F )

Management
Hours/Yr. [F=0.05xE] (G)

Clerical

Hours/Yr. [G=0.1xE] (H) 1

Total Labor
Costs/Yr. ($)

4. Recordkeeping Requirements

a. Read instructions See 3a

b. Plan activities 16 1 16 17 272 13.6 27.2 10,471

c . Implement activities Not applicable

d. Develop record system

i. Control equipment 4 1 4 17 68 3.4 6.8 2,618

e. Enter information

i. Control device design 4 1 4 17 68 3.4 6.8 2,618

ii. Control equipment testing 1 1 1 17 17 0.85 1.7 654

iii. Control equipment inspection 8 1 8 36 288 14.4 28.8 11,087

iv. Control equipment monitoring 1 12 12 36 432 21.6 43.2 16,630

v. Control device CMS 1 12 12 36 432 21.6 43.2 16,630

f. Train personnel 4 1 4 36 144 7.2 14.4 5,543

h. Perform audits Not applicableTable 1. Annual Respondent Burden and Cost,

NES HAP for Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH) 18

Activity (A)

Technical

Hrs/

Occurrence (B)

Occurrences/ Respondent/

Yr. (C)

Hours/ Respondent/

Yr. [C=AxB] (D)

Number of Respondents (E)

Technical

Hrs/Yr. [E=CxD] (F )

Management
Hours/Yr. [F=0.05xE] (G)

Clerical

Hours/Yr. [G=0.1xE] (H) 1

Total Labor
Costs/Yr. ($)

i. Retain records of actual throughput (facilities exempt under 63.1270(f)) 3 Not applicable

Recordkeeping Subtotal 1,979 $66,251

TOTAL LABOR BURDEN AND COST (rounded) 2,591 $86,823

1 This ICR uses the following l abor rates: $33.51 per hour for technical labor, $52.85 per hour for management labor, and $23.43 for clerical labor. The rat es have been increased by 110 percent to account for the benefit packages available to those employed by private industry. These ra tes are from the Employer Costs for Employee Compensation Historical Listing March 2004

– December 2010 published by the Bureau of Labor and Statistics and represents the state of the industry in 2008, consistent with the control costs associated with the proposed rule. Source: ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececqrtn.pdf

2 . Respondents are expected to maintain records of actual throughput as a standard business pr actice; therefore, there is no additional burden associated with

these records under this rule.Table 2: Annual Agency Burden and Cost,

NESHAP for Natural Gas Transmission and Storage (40 CFR part 63, subpart HHH) 19

Activity (A)

Technical

Hrs/

Occurrence (B)

Occurrences/ Respondent/

Yr. (C)

Hours/ Respondent/

Yr. [C=AxB] (D)

Number of Respondents (E)

Technical

Hrs/Y r. [E=CxD] (F)

Management
Hours/Yr. [F=0.05xE] (G)

Clerical

Hours/Yr. [G=0.1xE] (H) 1

Total Labor
Costs/Yr. ($)

1. Review reports

a. Initial notification 2 1 2 17 34 1.7 3.4 1,788

b. Preconstruction review application 4 1 4 17 68 3.4 6.8 3,412

c. Performance test notification 2 1 2 17 34 1.7 3.4 1,706

d. Compliance status notification 4 1 4 17 68 3.4 6.8 3,412

e. Semiannual periodic reports 2 2 2 4 36 144 7.2 14.4 7,226

TOTAL LABOR BURDEN AND COST (rounded) 400 $ 17, 545

1. The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhe ad expenses. Managerial rates of $59.63 (GS

- 13, Step 5, $37.27 × 1.6), Technical rate of $47.20 (GS

- 12, Step 1, $29.50 × 1.6), and Clerical rate of $23.94 (GS

- 6, Step 3, $14.96 × 1.6). These rates are from the Office of Personnel Management (OPM), 2008 General Schedule, which excludes locality rates of pay.