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 Gas 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

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

Emission Standards 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 

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

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

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

to a final end user (if there is no local distribution company). New facilities include those that 

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

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

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

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

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

subject to NESHAP.

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

measurements, and retain the file for at least 5 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.

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

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

number of affected facilities under this subpart 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 the 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., respondent). 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 hours.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

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

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

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

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

of this Act to:

 establish and maintain such records;

 make 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 such 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 anticipated to 

endanger 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 compliance with the 

applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

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

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

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

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

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

performance test may also be observed.

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

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

determinations.

The information generated by the monitoring, recordkeeping 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 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 action is not applicable because it is a rule related ICR. 

3(c) Consultations

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

American Gas 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 facilitate industry compliance. 

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 Collection

Less frequent information collection would decrease the margin of assurance that 

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

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

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

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

equipment and noncompliance would decrease.

3(e) General Guidelines

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 

notifications, for at least 5years. This is consistent with the General Provisions as applied to the 

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

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

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

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

level of enforcement action. Historically, EPA has found that the most flagrant violators 
frequently have violations extending 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 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 and NAICS Codes

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

natural gas transmission and storage facilities. NAICS (The North 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 required 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 required 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) and 
Notification Reports

(b)(2)

Notification 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 

calculations, for closed-vent systems using control devices other than 

flares (submit with Notification of Compliance Status Report).

63.1274, 

63.1282(d)(4), 

63.1285(d)(4)(i) 

through (d)(4)(iii)

One complete test report for each test method used for a particular 

source (submit with Notification of Compliance Status Report).

63.1285(d)(3)

Analysis demonstrating whether an affected source is a major source 

(submit with Notification of Compliance Status Report).

63.1285(d)(8)

Statement of compliance with subpart HHH (submit with Notification 

of Compliance Status Report).

63.1285(d)(9)

Notification of any process change. 63.1285(f)

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

63.1274(a)

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

63.9(d)(4)(i), 

63.1274(a)

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

63.9(b)(5)(ii), 

63.1274(a)
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 demonstrates conditions under which the facility reduces 

95.0 percent of its HAP emissions (submit with Notification of 

Compliance Status Report).

63.1281(e)(2), 

63.1285(d)(10)

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

63.1274(a)

Semiannual excess emissions 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, delays, and shutdowns. This also applies 

to parts that are difficult or unsafe to inspect and those where a leak or 

defect is detected.

63.1283(c)(3) 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)

Throughput and emissions records of exempt glycol dehydration 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 systems and CMS to: 1) achieve a 95% 

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

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

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

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

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

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

Transmit, or otherwise disclose the information.

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

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

required.
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, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Analyze, 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 properly installed and operated. Performance 

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

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

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

compliance and enforcement programs. The semiannual reports are used for problem 

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

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

operator for 5 years.

Information 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 

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. 

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. 

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 applicable to the industry for the subpart included in this ICR. The 

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

concept of burden under the Paperwork Reduction Act. Specific tasks and major assumptions 

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

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

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

6(a) Estimating Respondent Burden

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

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

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

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

approved ICR, and any comments previously received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR 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 employed 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 control 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 information collection activities 

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

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

installed flares to control emissions. 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 collection 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 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 

$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 2008 
dollars 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), attached.

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

Approximately 36 existing respondents and an additional 17 new respondents 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 

Sources

(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 53
The total number of annual responses per year is calculated 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 

Responses 

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 planned 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 regarding these estimates may be found 

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

Storage (40 CFR part 63, subpart HHH), 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 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 $86,823. Details regarding these estimates may be found 

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

Storage (40 CFR part 63, subpart HHH), 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

The number of affected facilities under this subpart is expected to increase 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 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-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 docket that are available 

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

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

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

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

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

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

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

566-1514. 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 applicable because no statistical methods were used in collecting this 

information.
Table 1. Annual Respondent Burden and Cost, 

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

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. Required 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 Report 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 $20,480
Table 1. Annual Respondent Burden and Cost, 

NESHAP 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 applicable
Table 1. Annual Respondent Burden and Cost, 

NESHAP 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

1This ICR 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 been increased by 110 percent to account for the benefit packages available to those employed 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 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 practice; 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/Yr.

[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 reports2 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 overhead 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.