SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts
KKK and LLL) (Revised), EPA ICR Number 2438.02, OMB Control Number
2060-0120

1(b)  Short Characterization/Abstract

	

The New Source Performance Standards (NSPS) for Onshore Natural Gas
Processing Plants, published at 40 CFR part 60, subpart KKK, were
proposed on January 20, 1984, and promulgated on June 24, 1985. These
standards apply to the following affected facilities located at onshore
natural gas processing plants: compressors in equipment leaks of
Volatile Organic Compound (VOC) service or in wet gas service, and the
groups of all equipment (except compressors) within a process unit.
Affected facilities commenced construction, modification, or
reconstruction after the date of proposal. A process unit is defined as
the equipment assembled for extraction of natural gas liquids from field
gas, fractionation of liquids into natural gas products, or other
processing of natural gas products. This information is being collected
to assure compliance with 40 CFR part 60, subpart KKK.

The New Source Performance Standards (NSPS) for Onshore Natural Gas
Processing - SO2 Emissions- (0 CFR part 60, subpart LLL) were proposed
on January 20, 1984, and promulgated on October 1, 1985. These standards
apply to the following affected facilities located at onshore natural
gas processing plants: each sweetening unit, and each sweetening unit
followed by a sulfur recovery unit. Affected facilities commenced
construction, modification, or reconstruction after the date of
proposal. A sweetening unit is defined as a process device that
separates the hydrogen sulfide and carbon dioxide (CO2) contents from
the sour natural gas stream. The provisions of subpart LLL do not apply
to sweetening facilities that produce acid gas that is completely
re-injected into oil or gas bearing geologic strata or that is otherwise
not released to the atmosphere. The control and monitoring requirements
of subpart LLL do not apply to affected facilities with design
capacities of less than two long tons per day (LT/D) of hydrogen sulfide
in the acid gas, expressed as sulfur. This information is being
collected to assure compliance with 40 CFR part 60, subpart LLL.

As part of the mandatory review of NSPS as required under the Clean Air
Act, the requirements of both subpart KKK and LLL would be contained in
a new subpart, 40 CFR 60, subpart OOOO. Subpart OOOO will supersede
subpart KKK, and the existing provisions of subpart KKK and LLL would be
included in the new subpart OOOO along with the new proposed provisions.
The revisions to this ICR account for the reduction in new sources
estimated that will report under KKK and LLL (new sources will now
report under the ICR for subpart OOOO). This ICR accounts for the
existing burden for sources still reporting under KKK and LLL. We have
also updated labor cost estimates and removed all instances of recording
and reporting due to start-up, shutdown and malfunction.

In general, all NSPS standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities. These notifications, reports, and records are
essential in determining compliance, and are required of all sources
subject to NSPS.

Any owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two years following the date of such measurements, maintenance reports,
and records. All reports are sent to the delegated state or local
authority. In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an
average of four affected facilities at each plant site for subpart KKK,
along with one affected facility at each plant site for subpart LLL, and
that each plant site has only one respondent (i.e., the owner/operator
of the plant site).

All of these sources subject to subpart LLL are also subject to subpart
KKK. Over the next three years, an average of 507 sources per year will
be subject to subpart KKK. Approximately 70 of the 507, are also
currently subject to subpart LLL. 

None of the plants in the United States are owned by neither state,
local, tribal, or the Federal government. They are all owned and
operated solely by privately owned for-profit businesses.  The burden to
the “Affected Public” may be found in Table 1: Annual Respondent
Burden and Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR
Part 60, Subparts KKK and LLL) (Revised). The burden to the “Federal
government” is attributed entirely to work performed by Federal
employees or government contractors; this burden may be found in Table
2: Annual Agency Burden and Cost, NSPS for Onshore Natural Gas
Processing Plants (40 CFR Part 60, Subparts KKK and LLL) (Revised).

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years. 

In addition, section 114(a) states that the Administrator may require
any owner or operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, VOC and sulfur dioxide emissions from
onshore   natural gas processing plants either cause or contribute to
air pollution that may reasonably be anticipated to endanger public
health or welfare. Therefore, the NSPS was promulgated for this source
category at 40 CFR part 60, subparts KKK and LLL.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act. The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard.
Continuous emission monitors are used to ensure compliance with the
standard at all times. During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the standard are used to inform the Agency
or delegated authority when a source becomes subject to the requirements
of the regulations. The reviewing authority may then inspect the source
to check if the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standard is being met. The performance test may also be observed.

The required semiannual and quarterly reports are used to determine
periods of excess emissions, identify problems at the facility, verify
operation/maintenance procedures, and for compliance determinations.

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

3(a)  Non-duplication

If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office. Otherwise, the
information is sent directly to the delegated state or local agency. If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards. Therefore, no duplication
exists.

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

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

3(c)  Consultations

During the previous ICR renewal, several consultations were conducted
during a previous renewal of this ICR.  In estimating the affected
number of sources and the growth rate of onshore natural gas processing
plants subject to this standard, EPA contacted Ms. Lynn Reed at (918)
588-7380, ONEOK, Incorporated, Mr. Lance Lodes at (405) 557-6846,
OGE-Enogex, Incorporated, and Mr. Johnny Dreyer, (918) 493-3872, Gas
Processors Association (GPA).  These contacts, in turn, consulted a
limited number of its members.  Additionally, we reviewed information
available from the Online Tracking Information System (OTIS) which is
the primary source of information regarding the number of existing
sources.  OTIS data was used in conjunction with industry consultation
to verify the number of sources and the industry growth rate.  It was
determined that an average of 507 facilities per year will be subject to
the standard over the next three years.  Since this revision is removing
new sources subject to KKK in order to account for them under subpart
OOOO, no further contacts were made. 

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards.
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met. If the information required by
these standards was collected less frequently, the proper operation and
maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in title 40, chapter 1, part 2, subpart B -
Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

The reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
onshore natural gas processing plants.  The North American Industry
Classification System (NAICS) codes 211111 and 211112 for onshore
natural gas processing plants.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

In this ICR, all the data that is recorded or reported is required by
the New Source Performance Standards for Onshore Natural Gas Processing
Plants (40 CFR Part 60, Subparts KKK and LLL). 

A source must make the following reports:

Notifications

Semiannual reports of excess emissions (subparts KKK and LLL)	60.7(c)

Performance test results (subparts KKK and LLL)	60.8(a), 60.636(a),
60.487(e)

Semiannual reports (subpart KKK)	60.636(a)-(c), 60.487(a)

Semiannual report on excess emissions from and performance of continuous
monitoring system, and/or summary report forms (subpart LLL)	60.647(b)



A source must keep the following records:

Recordkeeping

Keep records of measurements, performance evaluations, calibration
checks, adjustments and maintenance related to continuous monitoring
systems.	60.7(f)

Keep records of parts of closed vent systems designated as unsafe or
difficult to inspect (subpart KKK).	60.632(a), 60.482-10(l)(1), (2)

Keep records of inspections of closed vent systems during which no leaks
are detected (subpart KKK).	60.632(a), 60.482-10(l)(4), (5)

Perform attachment of identification numbers to leaking equipment
(subpart KKK).	60.635(a), (b)

Keep records of leak detection and repair (subpart KKK).	60.632(a),
60.635(a), (b), 60.482-10(l)(3)

60.486(c)

Keep records of design requirements for and operation of closed vent
systems and control devices (subpart KKK).	60.635(a), 60.486(d)

Keep records listing all equipment subject to subpart KKK.	60.635(a),
(b), 60.486(e)

Keep records of compliance tests (subpart KKK).	60635(a), 60.486(e)(4)

Keep records of valves designated as unsafe or difficult to monitor
(subpart KKK).	60.635(a), 60486(f)

Keep records of design criterion that indicate failure (subpart KKK).
60.635(a), 60.486(h)

Keep records of parts not in VOC service or otherwise exempt (subpart
KKK).	60.635(a), (c), 60.486(j)

Keep records of calculations and measurements (subpart LLL).	60.647(a)

Facilities that choose to comply with 60.646(e) shall keep, for the life
of the facility, records demonstrating that the facility design capacity
is less that 150 long tons per day (LT/D) of hydrogen sulfide expressed
as sulfur (subpart LLL).	60.647(d)



(ii)  Respondent Activities

Respondent Activities

Read instructions.

Write the notification and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.

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

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

Adjust the existing ways to comply with any previously applicable
instructions and requirements.

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

Transmit, or otherwise disclose the information.

Perform initial performance test, reference the methods discussed in the
rule language, and repeat performance tests if necessary.  Applicable if
controls are used (subpart KKK).

Monitor control devices to ensure that they are operated and maintained
in conformance with design. Applicable if controls are used (subpart
KKK).

Perform monthly monitoring of pumps in light liquid service and valves
in gas/vapor service or in light liquid service (subpart KKK).

Repair pump, compressor, valve, and vapor collection system leaks
(subpart KKK).

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

Monitor pressure relief devices in gas/vapor service for no detectable
emissions, following pressure release (subpart KKK).

Monitor or repair leaks in pumps or valves in heavy liquid service,
pressure relief devices in light or heavy liquid service, and connectors
(subpart KKK).

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

Install, calibrate, maintain and operate CMS for: (a) total sulfur
emission rate; and (b) exhaust gas temperature for oxidation control
systems or reduction control systems that are followed by an incinerator
(subpart LLL).

Install, calibrate, maintain, and operate CMS for reduced sulfur
compound emission rate for reduction control systems that are not
followed by an incinerator (subpart LLL)

Perform initial performance test, reference the methods discussed in the
rule language, and repeat performance tests if necessary (subpart LLL).

Perform daily monitoring of: (a) accumulation of sulfur product; and (b)
H2S concentration in the acid gas from the sweetening unit (subpart
LLL).

Perform hourly monitoring of acid gas flow rate from the sweetening unit
and calculate the daily average (subpart LLL).

Calculate: (a) daily sulfur feed rate; and (b) daily required SO2
emission reduction efficiency (subpart LLL).



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

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Review notifications and reports, including performance test reports,
and excess emissions reports required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in CDX



5(b)  Collection Methodology and Management

Data and records maintained by the respondents are tabulated and
published for use in compliance and enforcement programs of the
delegated permitting authority.  Information contained in the reports
will be required to submit records electronically to EPA’s Central
DATA Exchange (CDX) using the Electronic Reporting Tool.  CDX enables
fast, efficient and more accurate environmental data submissions from
state and local governments, industry and tribes to the EPA and
participating program offices.  EPA's CDX is the point of entry on the
Environmental Information Exchange Network (Exchange Network) for
environmental data submissions to the Agency.  CDX works with both EPA
program offices looking for a way to better manage incoming data, and
stakeholders looking for a way to reduce burden from reporting
requirements. 

	The records required by this regulation must be retained by the
owner/operator for two years. The semiannual reports are used for
problem identification, as a check on source operation and maintenance,
and for compliance determinations.

5(c)  Small Entity Flexibility

	The majority of the respondents are large entities (i.e., large
businesses).  After reviewing relevant available background documents
related to the standard, an estimate of the number of small entities
affected could not be determined.  However, the impact on small entities
(i.e., small businesses) was taken into consideration during the
development of the regulation.  Due to technical considerations
involving the process operations and the types of control equipment
employed, the recordkeeping and reporting requirements are the same for
both small and large entities.  The Agency considers these to be the
minimum requirements needed to ensure compliance and, therefore, cannot
reduce them further for small entities.  To the extent that larger
businesses can use economies of scale to reduce their burden, the
overall burden will be reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in below Table 1: Annual Respondent Burden and
Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60,
Subparts KKK and LLL) (Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
each of the subparts included in this ICR.  The individual burdens are
expressed under standardized headings believed to be consistent with the
concept of burden under the Paperwork Reduction Act. Where appropriate,
specific tasks and major assumptions have been identified. Responses to
this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 109,
266 labor hours.  The recordkeeping hours shown below in Table 1 are
61,959.  The reporting requirement hours shown below in Table 1 are
47,308.  These hours are based on Agency studies and background
documents from the development of the regulation, Agency knowledge and
experience with the NSPS program, the previously approved ICR, and any
comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$116.05 ($55.26 + 110%)   

Technical	$97.21 ($46.29 + 110%)

Clerical	$48.87 ($23.27 + 110%)

These rates are from the U. S. Department of Labor, Bureau of Labor
Statistics, March 2010, “Table 2. Civilian Workers, by Occupational
and Industry group.”  The rates are from column 1, “Total
Compensation.”  The rates have been increased by 110 percent to
account for the benefit packages available to those employed by private
industry.

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

The only costs to the regulated industry resulting from information
collection activities required by subpart KKK are labor costs.  There
are no capital/startup or operation and maintenance costs.

The type of industry costs associated with the information collection
activities in subpart LLL are both labor costs, which are addressed
elsewhere in this ICR, and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/‌Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost, (B×C)	(E)

Annual O&M Costs for One Respondent a	(F)

Number of Respondents with O&M b	(G)

Total O&M,

(E×F)

SO2 CEM, control outlet (only for subpart LLL)	$73,000	0	0	$17,100	4
$68,400

Assumptions:

a Costs reflect installation and maintenance of an in-situ SO2 CEM after
the control device and assume installation occurred during the
construction of the facility.

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

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

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

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information. 

The average annual Agency cost during the three years of the ICR is
estimated to be $420,400.  

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

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

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

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

These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Annual Agency Burden and Cost, NSPS for
Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts KKK and
LLL) (Renewal).

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

Based on our research for this ICR, on average over the next three
years, approximately 507 existing respondents will be subject to the
standard.  It is estimated that an additional one respondent per year
will become subject to subpart KKK and three for subpart LLL over the
next three years.  The overall average number of respondents, as shown
in the table below is 507 per year.

The number of respondents is calculated using the following table that
addresses the three years covered by this ICR.  

Number of Respondents

 	Respondents That Submit Reports	 	 

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

	Number of Existing Respondents	Number of Existing Respondents that
would now Report under Subpart OOOO a	Number of Existing Respondents
that keep records but do not submit reports	Number of Respondents

	 	 	 	(D=A-B-C)

Subpart KKK 

1	561	27	0	534

2	534	27	0	507

3	507	27	0	480

Average	534	27	0	507

Subpart LLL b

1	79	3	3	73

2	76	3	3	70

3	73	3	3	67

Average	76	3	3	70



Assumptions:

a. In this standard, existing respondents submit initial notifications.
New sources for the same affected facilities report under subpart OOOO.
We expect 27 of the existing facilities to undergo modifications in each
year , which would indicate these facilities would report under subpart
OOOO and no longer report under subpart KKK. For subpart LLL, we expect
three facilities to perform a modification and report under subpart
OOOO. 

b. Affected facilities with design capacities of less than two long tons
per day (LT/D) of hydrogen sulfide (H2S) in the acid gas, expressed as
sulfur, have no reporting requirements pursuant to subpart LLL.  Three
respondents have sources capacities below this threshold. 

Column D is subtracted to avoid double-counting respondents.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 507.  This includes the 70 respondents that also report
under subpart LLL because all sources subject to LLL are also subject to
subpart KKK.

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents that include a report for LLL  with their
report for KKK	(E)

Total Annual Responses

E = (B×C)

Subpart KKK and LLL

Semiannual reports	507	2	70	1,014

TOTAL (rounded)



1,014

N/A – Not Applicable.

The number of Total Annual Responses is 1,014.

The total annual labor costs are $10,251,963.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60,
Subparts KKK and LLL)(Revised). 

6(e)  Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2 below,
respectively, and summarized below.  

(i) Respondent Tally

The total annual labor hours are 109,266.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60,
Subparts KKK and LLL) (Revised).  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 107.7 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $68.400.  The cost calculations are detailed above in Section
6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 9,329 labor hours at a cost of $420,400.  See below
Table 2: Annual Agency Burden and Cost, NSPS for Onshore Natural Gas
Processing Plants (40 CFR Part 60, Subparts KKK and LLL) (Revised).

6(f)  Reasons for Change in Burden

	The change in burden results from the development of subpart OOOO,
which supersedes both subpart KKK and LLL.  Any new or modified affected
facility will begin reporting under subpart OOOO instead of subpart KKK
and LLL. 

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 107.7 per response.  Burden means
the total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for
a Federal agency.  This includes the time needed to review instructions;
develop, acquire, install, and utilize technology and systems for the
purposes of collecting, validating, and verifying information,
processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously
applicable instructions and requirements; train personnel to be able to
respond to a collection of information; search data sources; complete
and review the collection of information; and transmit or otherwise
disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA regulations are listed
at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2010-0363.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Enforcement and Compliance Docket and Information Center is (202)
566-1752.  Also, you can send comments to the Office of Information and
Regulatory Affairs, Office of Management and Budget, 725 17th Street,
NW, Washington, DC 20503, Attention: Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2010-0363 and OMB Control
Number 2060-0120 in any correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

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

 	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(I)

Reporting/Recordkeeping Requirements	Person- hours 

per occurrence	No. of occurrences per respondent per year	Person- hours
per respondent per year 

(C = A×B)	Respondents 

per year a	Technical person- hours per year 

(E = C×D)	Management person-hours 

per year 

(E×0.05)	Clerical person-hours per year 

(E×0.1)	Cost ($) b

1.  Applications	N/A







	2.  Survey and Studies	N/A







	3.  Reporting requirements









A.  Read instructions









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

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

B.  Required activities









Subpart KKK and LLL	 	 	 	 	 	 	 	 

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

Reporting Subtotal



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

4.  Recordkeeping requirements









A.  Read instructions









Subpart KKK	See 4C







	Subpart LLL	See 3A







	B.  Plan activities	See 3E







	Subpart KKK	See 4C







	Subpart LLL	N/A







	C.  Implement activities	See 3E







	Subpart KKK









Filing and maintaining records e	80	1	80	507	40,560	2,028	4,056
$4,376,404

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

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

Subpart LLL	N/A







	D.  Develop record system









Subpart KKK	See 4C







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

E.  Time to enter information f









Subpart KKK and LLL	See 4C







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

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

F.  Train personnel









Subpart KKK	See 4C







	Subpart LLL	N/A







	G.  Audits









Subpart KKK	N/A







	Subpart LLL	N/A







	Recordkeeping Subtotal



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

TOTAL ANNUAL BURDEN AND COST



	109,266	$10,251,963

N/A - Not Applicable.







Assumptions:







a. We have assumed that the average number of respondents that will be
subject to subpart KKK will be 507. New affected facilities will no
longer report under KKK or LLL, and instead will report under subpart
OOOO. It is also assumed that the average number of respondents that
will be subject to subpart LLL will be 70.

b. This ICR uses the following labor rates: $116.05 per hour for
Executive, Administrative, and Managerial labor; $97.21 per hour for
Technical labor, and $48.87 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 2010, “Table 2. Civilian Workers, by Occupational
and Industry group.” The rates are from column 1, “Total
Compensation.”  The rates have been increased by 110 percent to
account for the benefit packages available to those employed by private
industry.

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



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



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



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



	 g. We have assumed continuous monitoring occurs for 0.5 hours on the
approximate number of business days. Table 2:  Annual Agency Burden and
Cost, NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60,
Subparts KKK and LLL) (Revised)

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 Managerial rates of $62.27 (GS-13, Step 5, $38.92 × 1.6), Technical
rate of $46.21 (GS-12, Step 1, $28.88 × 1.6), and Clerical rate of
$25.01 (GS-6, Step 3, $15.63 × 1.6).  These rates are from the Office
of Personnel Management (OPM), 2010 General Schedule, which excludes
locality rates of pay.



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