SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
SUBPARTS
KKK
AND
LLL
STANDARDS
OF
PERFORMANCE
FOR
ONSHORE
NATURAL
GAS
PROCESSING
PLANTS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
KKK
Standards
of
Performance
for
Equipment
Leaks
of
VOC
from
Onshore
Natural
Gas
Processing
Plants,
and
NSPS
Subpart
LLL
Standards
of
Performance
for
Onshore
Natural
Gas
Processing:
SO2
Emissions.

1(
b)
Short
Characterization/
Abstract
Subpart
KKK
The
New
Source
Performance
Standards
(
NSPS)
for
Equipment
Leaks
of
VOC
from
Onshore
Natural
Gas
Processing
Plants
were
proposed
on
January
20,
1984
and
promulgated
on
June
24,
1985.
These
standards
apply
to
the
following
facilities
in
natural
gas
processing
plants:

a
compressor
in
VOC
service
or
in
wet
gas
service;
the
group
of
all
equipment
except
compressors
within
a
process
unit,
which
commenced
construction,
modification
or
reconstruction
after
the
date
of
proposal.
A
compressor
station,
dehydration
unit,
underground
storage
tank,
field
gas
gathering
system,
or
liquefied
natural
gas
unit
is
regulated
by
this
subpart
if
it
is
located
at
an
onshore
natural
gas
processing
unit.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
KKK.
This
type
of
collection
will
be
recordkeeping
and
periodic
reports.
EPA
Regional
offices
or
delegated
states
will
be
doing
the
collecting.
Recordkeeping
requirements
follows
a
general
leak
detection
program
regimen.
Applicable
pumps,
pressure
relief
valves,
sampling
connections,

and
compressors
will
be
inspected
and
information
regarding
any
repairs
made
will
be
recorded.

In
general,
gas
leaks
are
monitored
for
monthly
and
a
visual
inspection
for
liquid
leaks
is
performed
weekly.
EPA
and
states
will
use
the
data
to
determine
compliance
with
the
New
Source
Performance
Standards.
These
data
will
be
sent
to
delegated
states
or
EPA
regional
offices
and
entered
into
the
AIRS
computer
database.
The
information
collection
for
NSPS
Subpart
KKK
will
involve
558
respondents
at
$
6,169,322.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
Owners
or
operators
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.
Monitoring
requirements
specific
to
NSPS
Subpart
KKK
provide
information
on
the
efficacy
of
the
leak
detection
and
repair
program
implemented
by
the
facility.
Semiannual
reports
of
excess
emissions
are
required.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
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.

Based
on
information
received
from
the
DOE,
the
Oil
and
Gas
Journal's
Penwell
Surveys
and
trade
associations
approximately
558
sources
are
currently
subject
to
NSPS
KKK,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
one
affected
facility
per
plant
(
respondent).
The
cost
of
the
ICR
for
NSPS
KKK
will
be
6,169,322
dollars.
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
EPA
Regional
Office.

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

SO2
Emissions
were
proposed
on
January
20,
1984
and
promulgated
on
October
1,
1985.
These
standards
apply
to
the
following
facilities
in
natural
gas
processing
plants:
each
sweetening
unit,

and
each
sweetening
unit
followed
by
a
sulfur
recovery
unit,
which
commenced
construction,

modification
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
LLL.

This
type
of
collection
will
be
recordkeeping
and
periodic
reports.
EPA
Regional
offices
or
delegated
states
will
be
doing
the
collecting.
Records
must
be
kept
on
measurements
and
calculations
used
to
determine
initial
and
continuous
SO2
emission
reduction
efficiency,
and
periods
of
excess
emissions.
EPA
and
states
will
use
the
data
to
determine
compliance
with
the
New
Source
Performance
Standards.
These
data
will
be
sent
to
delegated
states
or
EPA
regional
offices
and
entered
into
the
AIRS
computer
database.
The
information
collection
for
NSPS
Subpart
LLL
will
involve
62
respondents
at
$
95,815.
The
information
collection
for
both
subparts
will
involve
558
respondents
at
a
total
of
$
6,265,137.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
Owners
or
operators
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.
Facilities
that
are
subject
to
Subpart
LLL
are
divided
into
three
categories.
Facilities
that
have
less
than
two
long
tons
per
day
(
LT/
D)
of
H2S
in
acid
gas
expressed
as
sulfur
shall
keep
an
analysis
at
the
plant
showing
the
facility
design
capacity
is
less
than
two
LT/
D
of
H2S
and
this
shall
be
kept
for
the
life
of
the
facility.

Facilities
that
have
two
LT/
D
or
greater
or
less
than
150
LT/
D
of
H2S
expressed
as
sulfur
shall
reduce
SO2
emissions
by
recovering
sulfur
and
by
achieving
an
SO2
reduction
efficiency
based
on
the
sulfur
feed
rate
in
Tables
1
and
2
of
the
standards.
Facilities
that
have
150
LT/
D
or
greater
of
H2S
expressed
as
sulfur
shall
use
continuous
emissions
monitoring
(
CEM)
to
control
SO2
emissions.
Semiannual
reports
of
excess
emissions
are
required.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
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.

Based
on
information
received
from
the
DOE,
the
Oil
and
Gas
Journal's
Penwell
Surveys
and
trade
associations
approximately
62
sources
are
currently
subject
to
NSPS
LLL,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
one
affected
facilities
per
plant
(
respondent).
The
cost
of
the
ICR
for
NSPS
Subpart
LLL
will
be
95,815
dollars.
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
EPA
Regional
Office.

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,
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
nonair
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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)

provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
VOC
and
SO2
emissions
from
onshore
natural
gas
processing
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60
Subpart
KKK
and
40
CFR
Part
60
Subpart
LLL
.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
VOC
and
SO2
from
onshore
natural
gas
processing
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOC
and
SO2
from
onshore
natural
gas
processing
plants
are
the
result
of
plant
operation
(
especially
compressor
units
and
sweetening
units).
These
standards
rely
on
the
reduction
of
VOC
and
SO2
emissions
by
implementing
a
leak
detection
program
and
controlling
the
sulfur
feed
rate
of
the
gas
stream.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.

The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
leaks
are
being
detected
and
repaired,
the
proper
sulfur
feed
rate
is
maintained,
and
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
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.
For
VOC
emissions
control
the
plant
must
show
they
have
the
capability
and
proper
technique
to
implement
an
effective
leak
detection
program
and
for
SO2
emissions
control
the
plant
must
show
that
they
can
properly
test
for
sulfur
content
in
the
gas
stream
to
maintain
the
proper
sulfur
feed
rate.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
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
NSPS
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.

Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60
Subpart
KKK
and
Subpart
LLL.
If
the
standard
has
not
been
delegated
the
information
is
sent
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
their
own
similar
regulation
to
implement
the
Federal
Regulation,
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
Standard.
Therefore,

no
duplication
exists.

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
on
August
16,
1999.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
Subpart
KKK
or
Subpart
LLL,
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
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
(
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
contained
in
40
CFR
Part
60
Subpart
KKK
or
Subpart
LLL,
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
onshore
natural
gas
processing
plants
that
engage
in
the
extraction
of
natural
gas
liquids
from
field
gas
or
fractionation
of
mixed
natural
gas
liquids
to
natural
gas
products
and
in
the
case
of
Subpart
LLL
which
require
sulfur
removal,
that
commenced
construction,
modification,
or
reconstruction
after
January
20,
1984.
They
are
listed
under
SIC
Codes
1311
and
1321.
The
government
is
in
the
process
of
transitioning
to
the
new
North
American
Industrial
Classification
System
(
NAICS).

The
NAICS
codes
for
this
industry
are
211111
and
211112.

4(
b)
INFORMATION
REQUESTED
(
I)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60
Subpart
KKK
Standards
of
Performance
for
Equipment
Leaks
of
VOC
from
Onshore
Natural
Gas
Plants
and
40
CFR
Part
60
Subpart
LLL
Standards
of
performance
for
Onshore
Natural
Gas
Processing:
SO2
Emissions.

A
source
must
make
the
following
reports
Notification
Reports
Construction/
reconstruction
60.7(
a)(
1)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
60.8(
d)

Demonstration
of
continuous
monitoring
system
60.7(
a)(
5)

Physical
or
operational
change
60.7(
a)(
4)

Reports
Initial
performance
test
results
60.8
(
a)

Semiannual
report
of
pressure
relief
devices
for
which
leaks
are
detected
and
not
repaired.
60.636(
a),
60.487(
b)

Excess
emission
reports
60.7(
c),
60.647(
b)
A
source
must
keep
the
following
records.

Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
(
60.7(
b)

Continuous
monitoring
system
and
performance
test
(
60.7(
d),
60.13
Record
pressure
relief
device
leaks
60.635(
a)
and
(
b)

Records
are
required
to
be
retained
for
two
of
Years.

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
wet
scrubber.

Perform
initial
performance
test
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.

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.
Respondent
Activities
Transmit,
or
otherwise
disclose
the
information.

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
information
required
under
40
CFR
Subpart
KKK
and
LLL:

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.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup
for
facilities
subject
to
Subpart
LLL,
the
reviewing
authority
might
inspect
the
source
to
check
if
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
note
the
operating
conditions
under
which
compliance
was
achieved
(
initial
SO2
reduction
efficiency
is
determined
by
considering
sulfur
feed
rate
and
sulfur
content
of
the
natural
gas).
For
facilities
subject
to
either
subparts
KKK
or
LLL
data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
tabulated
and
published
for
internal
Agency
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
fro
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutants.
The
impact
on
small
businesses
was
accounted
for
in
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
Even
though,
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

For
Subpart
LLL
facilities
that
have
a
design
capacity
of
less
than
two
long
tons
per
day
of
hydrogen
sulfide
in
the
acid
gas
are
exempt
from
the
requirements
of
this
subpart
except
that
they
have
to
keep,
for
the
life
of
the
facility,
an
analysis
demonstrating
that
the
their
design
capacity
is
less
than
two
long
tons
per
day
of
hydrogen
sulfide
expressed
as
sulfur.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Tables
2A
and
2B.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
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
(
40
CFR
Parts
60.1,
60.630
and
60.640)
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
at
114,036
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
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
labor
rates
of
$
54.94.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.

The
wage
rates
have
been
loaded
by
adding
110%
overhead.
Only
the
technical
rate
is
used
for
this
older
NSPS
standard.
This
is
because
this
standard
is
less
sophisticated
than
the
newer
standards
and
most
of
its
requirements
are
initial
only.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
CEMs.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
There
are
no
capital
start
up
costs
for
this
regulation.
This
is
based
on
a
projection
of
no
new
sources
per
year.
The
annual
operations
and
maintenance
costs
are
74,100
dollars.
This
is
based
on
one
existing
source
multiplied
by
74,100
dollars
for
upkeep
of
the
monitoring
device.
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
burden
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
74,100
dollars.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
The
standard
for
NSPS
Subpart
KKK
does
not
use
continuous
monitoring
but
instead
has
a
leak
detection
and
repair
program.
The
standard
for
NSPS
Subpart
LLL
may
use
continuous
monitoring
of
SO2
emissions.
The
following
information
applies
to
Subpart
LLL.
Monitoring
device
Start
up
cost
($)
Annual
O&
M
costs
($)

Continuous
monitor
for
Zero
dollars
for
74,100
dollars
for
1
unit
control
device:
1
unit,
or
NA
SO2
emissions
because
no
new
sources
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.

Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
57,901.
This
cost
is
based
on
an
average
wage
of
a
GS
10
step
1
employee
rate
($
16.52
hr
+

110%
overhead
=
$
34.69)
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
40
CFR
60.630
Subpart
KKK
and
40
CFR
60.640
Subpart
LLL
is
558.
The
number
of
new
sources
subject
to
40
CFR
60.630
Subpart
KKK
and
40
CFR
60.640
Subpart
LLL
is
zero.
The
number
of
total
respondents
is
558.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.
The
total
annual
responses
is
1,116.
This
number
is
calculated
from
the
number
of
new
sources
multiplied
by
the
number
of
initial
reports,
plus
the
number
of
existing
sources
multiplied
by
the
semiannual
reports.
The
total
annual
labor
costs
are
114,036
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
74,100
dollars.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:

Industry
Burden.
6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
tables
1A,
1B,
2A,
and
2B.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
decrease
in
the
number
of
sources.

.
6(
g)
Burden
Statement
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
OP
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
401
M
St.,
S.
W.,
Washington,
D.
C.

20460;
and
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.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
