SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

LLL) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

(Renewal), EPA ICR Number 1086.10, OMB Control Number 2060-0120

1(b) Short Characterization/Abstract

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

Plants (40 CFR part 60, subpart KKK) were proposed on January 20, 1984, promulgated on June 

24, 1985, and amended on both October 17, 200 and August 16, 2012. These regulations apply 

to the following types of existing 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. This 

information is being collected to assure compliance with 40 CFR part 60, subpart KKK.

The NSPS for Onshore Natural Gas Processing Plants at Subpart LLL were proposed on 

January 20, 1984, promulgated on October 1, 1985, and amended on both October 17, 200 and 

August 16, 2012. These regulations apply to the following types of existing facilities located at 

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

by a sulfur recovery unit. 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, or 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.

This ICR accounts for the burden of existing facilities that have not been modified and 

are required to report under subparts KKK and LLL. On August 16, 2012, EPA issued a new 

NSPS rule, subpart OOOO, addressing new and revised requirements for natural gas processing 

facilities, that are either new or modified sources after August 23, 2011 subject to subparts KKK 

and LLL, which will now report under this new rule. Although subpart OOOO addresses other 

portions of the oil and gas sector, some of which has not been regulated before, the burden 

associated with these other rule requirements are not specifically addressed in this ICR.

In general, all NSPS standards require initial notification reports, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NSPS. 
2

Any owner/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 U. S.

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. Each plant site has only one respondent (i.e., the owner/operator of 

the plant site).

Over the next three years, an average of 577 existing respondents per year will be subject 

to these rules. Of the total sources, approximately 70 of the 577 are currently subject to subpart 

LLL. Modified facilities after August 23, 2011, subject to subparts KKK and LLL, and new

onshore natural gas processing facilities, will be subject to and report under subpart OOOO.

This ICR combines the burden currently approved under OMB control number 2060-

0120 (EPA ICR Number 1986.09) for the onshore natural gas processing rule, and the change in 

burden resulting from the development of subpart OOOO, addressed under OMB control number 

2060-0672 (EPA ICR Number 2438.02). The Office of Management and Budget (OMB) 

approved the currently active ICR without any “Terms of Clearance.”

There are approximately 577 existing onshore natural gas processing plants in the United 

States, which are all publicly-owned and operated by for-profit businesses. None of the plants in 

the United States are owned by either state, or local, or tribal, or the Federal government. The 

“burden” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden 

and Cost, and Summary of Annual Respondents Burden – NSPS for Onshore Natural Gas 

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

Government “burden” is attributed entirely to work performed by either Federal employees or 

government contractors and may be found below in Table 2: Average Annual EPA Burden and 

Cost, and Summary of Agency Burden – NSPS for Onshore Natural Gas Processing Plants (40 

CFR Part 60, Subparts KKK and LLL) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 
3

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/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 and/or welfare. Therefore, the NSPS were promulgated for 

this source category at 40 CFR part 60, subparts KKK and LLL, and subsequently updated under 

NSPS subpart OOOO.

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 standards. Continuous emission monitors are used to 

ensure compliance with the standards 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 standards 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 standards 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 
4

determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

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

KKK and LLL.

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, duplication does not exist.

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (78 FR 33409) on June 4, 2013. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. 

The primary source of information as reported by industry, in compliance with the recordkeeping 

and reporting provisions in the standards, is the Online Tracking Information System (OTIS) 

which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for 

the collection, maintenance, and retrieval of all compliance data. The growth rate for the 

industry is based on our consultations with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity 

to comment on the burden associated with the standards as it was being developed and the 

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) ONEOK, Incorporated, at (405) 

557-6846; and 2) the Gas Processors Association, at (918) 493-3872.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection
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Less frequent information collection would decrease the margin of assurance that 

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

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

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

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - 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 United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is SIC 1311 and 1321, which corresponds to the North 

American Industry Classification System (NAICS) code 211111 and 211112 for Crude 

Petroleum and Natural Gas Extraction and Natural Gas Liquid Extraction, respectively.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Onshore 

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

A source must make the following reports:
6

Notifications

Notification of construction or reconstruction 60.7(a)(1)

Notification of actual startup date 60.7(a)(3)

Notification of modification 60.7(a)(4)

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)

Semiannual report on excess emissions from and performance of 

continuous monitoring system, and/or summary report forms (subpart 

LLL)

60.647(b)

A source must keep the following records:

Recordkeeping

Maintain records of startups, shutdowns, malfunctions of affected 

facilities; malfunctions of control devices; and periods where the 

continuous monitoring system is inoperative.

60.7(b)

Keep records of measurements, performance evaluations, calibration 

checks, adjustments and maintenance related to continuous 

monitoring systems.

60.7(f)

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

difficult to inspect (subpart KKK).

60.632(a), 60.482-

10(l)(1), (2)

Keep records of inspections of closed vent systems during which no 

leaks are detected (subpart KKK).

60.632(a), 60.482-

10(l)(4), (5)

Perform attachment of identification numbers to leaking equipment 

(subpart KKK).

60.635(a), (b)

Keep records of leak detection and repair (subpart KKK). 60.632(a), 60.486(c), 

60.635(a), (b), 

60.482-10(l)(3)

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). 60.635(a), 

60.486(e)(4)
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Recordkeeping

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)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

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

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device. 

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.
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Respondent Activities

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.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping. 

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

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. 
9

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

A majority of the respondents are large entities (i.e., large businesses). However, 

the impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

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

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

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

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request 

is shown below in Table 1: Annual Respondent Burden and Cost, and Summary of Annual 

Respondents Burden – NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, 

Subparts KKK and LLL) (Renewal).

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. Wherever 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 121,646 hours (Total Labor Hours from Table 1

below). 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.
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6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2013, “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 type of industry costs associated with the information collection activities in the 

subject standards are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitors 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 X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X 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 4 existing facilities to have annual O&M costs for monitoring under subpart LLL.

The total capital/startup costs for this ICR are zero. 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. 
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The average annual cost for capital/startup and operation and maintenance costs 

to industry over the next three years of the ICR is estimated to be $68,400. These are 

recordkeeping 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 

$478,444. 

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), 2013 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: Average Annual EPA Burden and Cost, and Summary of Agency

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

LLL) (Renewal).

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

Based on our research for this ICR, there is an average of approximately 507 existing 

respondents subject to subpart KKK, plus 70 existing respondents subject to subpart LLL, over 

the next three years. New and modified respondents after August 23, 2011 will become subject 

to the standards at subpart OOOO. 

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

years covered by this ICR. 
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Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of 

Existing 

Respondents that 

would now 

report under 

Subpart OOOO 

a

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E= B-C-A-D)

Subpart KKK 

1 27 561 0 0 534

2 27 534 0 0 507

3 27 507 0 0 480

Average 27 534 0 0 507

Subpart LLL b

1 3 79 3 0 73

2

3 76 3 0 70

3 3 73 3 0 67

Average 3 76 3 0 70

Total c

577

Assumptions:

a

 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.

c This is the total average of existing respondents subject to both subparts KKK and LLL.

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 for subpart KKK 

and 70 for subpart LLL, respectively. Note all the sources subject to subpart LLL are also 

subject to subpart KKK. 

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

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Subpart KKK

Semiannual reports 507 2 N/A 1,014

Affirmative defense 2 1 N/A 2

Subtotal for Subpart KKK 1,016

Subpart LLL

Semiannual report 70 2 N/A 140

Subtotal for Subpart LLL 140

TOTAL 1,156

The number of Total Annual Responses is 1,156. 

The combined, total labor costs are $11,899,080 annually. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost, and Summary

of Annual Respondents Burden – NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 

60, Subparts KKK and LLL) (Renewal).

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, respectively, and summarized below. 

(i) Respondent Tally

The combined, total labor hours are 121,646 hours annually, at a cost of $11,899,080. 

Details regarding these estimates may be found in Table 1 below: Annual Respondent Burden 

and Cost, and Summary of Annual Respondents Burden – NSPS for Onshore Natural Gas 

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

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to be a combined average of 105 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $68,400. The 

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

(O&M) Costs.
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(ii) The Agency Tally

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

10,617 labor hours at a cost of $478,444. See below Table 2: Average Annual EPA Burden and 

Cost, and Summary of Agency Burden – NSPS for Onshore Natural Gas Processing Plants (40 

CFR Part 60, Subparts KKK and LLL) (Renewal).

6(f) Reasons for Change in Burden

There is a decrease in burden from the OMB Inventory of Approved Burden. This 

change is attributed to a decrease in the number of affected onshore gas processing facilities 

subject to subparts KKK and LLL, which was due to the impact of a new NSPS rule, subpart 

OOOO. This ICR merges EPA ICR Numbers 1086.09 and 2438.02 in order to resolve 

inconsistencies with the required monitoring, recordkeeping and reporting requirements under 

these rules, as well as to update the number of existing respondents, resulting from the issuing of 

the new subpart OOOO. New and modified sources after August 23, 2011 that are subject to 

subparts KKK and LLL will report under subpart OOOO; thus this ICR only includes the burden 

for existing respondents that are subject to the subparts KKK and LLL, respectively. 

It should be noted that the wage rates in this ICR have been updated, resulting in an 

increase in the labor cost.

6(g) Burden Statement

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

is estimated to average a combined total of 105 hours per response. “Burden” means the total 

time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information either 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-2013-0316. 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 
15

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

electronically. When in the system, select “search,” and 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), WJC 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 docket 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-2013-0316 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.
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Table 1: Annual Respondent Burden and Cost – NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts

 KKK and LLL) (Renewal)

Burden Item

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

person-hours 

per year 

(Ex0.1)

(H) 

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 25.35 50.7 $57,032.43 

Subpart LLL 1 1 1 70 70 3.5 7 $7,874.30 

B. Required activities

Subpart KKK

Notification of construction/reconstruction c

2 1 2 0 0 0 0 $0 

Notification of modification c

8 1 8 0 0 0 0 $0 

Notification of anticipated startup c

2 1 2 0 0 0 0 $0 

Notification of actual startup c

2 1 2 0 0 0 0 $0 

Notification of electing to comply with 

alternative standards for valves c 8 1 8 0 0 0 0 $0 

Notification of initial performance test c

2 1 2 0 0 0 0 $0 

Affirmative defense 30 1 30 2 60 3 6 $6,749.40 

Semiannual reports d

8 2 16 507 8,112 405.6 811.2 $912,518.88 

Subpart LLL

Initial performance test 60 1 60 0 0 0 0 $0 

Repeat performance test 60 0.2 12 0 0 0 0 $0 
17

Burden Item

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

person-hours 

per year 

(Ex0.1)

(H) 

Cost b($)

Demonstration of CEMS 80 0.2 16 0 0 0 0 $0 

Repeat Demonstration of CEMS 80 0.2 16 0 0 0 0 $0 

Notification of construction/reconstruction c

2 1 2 0 0 0 0 $0

Notification of modification 2 1 2 0 0 0 0 $0

Notification of anticipated startup c

2 1 2 0 0 0 0 $0

Notification of actual startup c

2 1 2 0 0 0 0 $0

Notification of initial performance test c

2 1 2 0 0 0 0 $0

Notification of CMS demonstration c

2 1 2 0 0 0 0 $0

CMS demonstration See 3B

Semiannual report e

40 2 80 70 5,600 280 560 $629,944.00 

Reporting Subtotal 16,501 $1,614,119

4. Recordkeeping requirements

A. Implement activities

Subpart KKK

Filing and maintaining records f

80 1 80 507 40,560 2,028 4,056 $4,562,594.40 

Recalibrate monitors 4 12 48 507 24,336 1,216.8 2,433.6 $2,737,556.64 

Method 21 performance evaluation 2 2 4 507 2,028 101.4 202.8 $228,129.72 

Subpart LLL N/A

B. Develop record system 

Subpart KKK See 4A

Subpart LLL g

40 1 40 0 0 0 0 $0

C. Time to enter information

Subpart KKK See 4A
18

Burden Item

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

person-hours 

per year 

(Ex0.1)

(H) 

Cost b($)

Subpart LLL

Records of startup, shutdown, or malfunction 1.5 12 18 0 0 0 0 $0 

Records of continuous recording 0.5 700 350 70 24,500 1,225 2,450 $2,756,005.00 

Records of capacity data 2 1 2 3 6 0.3 0.6 $674.94

F. Train personnel

Subpart KKK See 4C

Subpart LLL N/A

G. Audits

Subpart KKK N/A

Subpart LLL N/A

Recordkeeping Subtotal 105,145 $10,284,960.70 

TOTAL ANNUAL BURDEN AND COST (rounded) 121,646 $11,899,080 

N/A - Not Applicable.

Assumptions:

a

 We have assumed that the average number of existing respondents that will be subject to subpart KKK will be 507. It is also assumed that the average number 

of existing respondents that will be subject to subpart LLL will be 70. These estimated average accounts for modified facilities after August 23, 2011 subject to 

subparts KKK and LLL that will become subject to subpart OOOO and therefore, would no longer report under these rules.

b

 This ICR uses the following labor rates: $123.04 per hour for Executive, Administrative, and Managerial labor; $101.22 per hour for Technical labor, and 

$51.18 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013, “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

 New respondents will be subject to subpart OOOO. 

d

 We have assumed that each existing respondent will take 8 hours, two times per year to write semiannual reports.

e

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

f

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

g

 We have assumed that each existing respondent will take 40 hours to develop record system. New respondents will be subject to subpart OOOO recordkeeping 
19

requirements. However, subpart LLL sources that have modified would need to track capacity data during the year it modified.

Summary of Respondent Burden

Standard Reporting 

Burden (hr)

Recordkeeping 

Burden (hr)

Total Respondent 

Burden (hr) Cost ($)

Subpart KKK (rounded) 9,981 76,963 86,944 $8,504,582

Subpart LLL (rounded) 6,520 28,182 34,702 $3,394,498 

Total (rounded) 16,501 105,145 121,646 $11,899,080
20

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

KKK and LLL) (Renewal)

Activity

(A) 

EPA personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant per 

year

(C) 

EPA personhours per 

plant per 

year 

(AxB)

(D) 

Plants per 

year a

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

person-hours 

per year 

(Ex0.1)

(H) 

Cost b($)

Subpart KKK

Review semiannual reports c

8 2 16 507 8,112 405.6 811.2 $420,400.34 

Subpart LLL

Review of semiannual reports c

8 2 16 70 1,120 56 112 $58,043.44 

TOTAL ANNUAL BURDEN AND COST (rounded) 10,617 $478,444 

Assumptions:

a

 We have assumed that the average number of existing respondents that will be subject to subpart KKK will be 507. It is also assumed that the average number 

of existing respondents that will be subject to subpart LLL will be 70. These estimated average accounts for modified facilities after August 23, 2011 subject to 

subparts KKK and LLL will become subject to subpart OOOO and therefore, would no longer report under these rules.

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), 2013 General Schedule, which excludes locality, rates of pay.

c

 We have assumed that it will take each existing respondent eight hours, two times per year to review semiannual reports.

Summary of Agency Burden

Standard Agency Burden 

(hr) Cost ($)

Subpart KKK 9,329 $420,400.34 

Subpart LLL 1,288 $58,043.44 

Total 10,617 $478,444