1
SF­
83
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)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants,
published
at
40
CFR
part
60.630,
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
volatile
organic
compound
(
VOC)
service
or
in
wet
gas
service,
and
the
group
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.

The
New
Source
Performance
Standards
(
NSPS)
for
Onshore
Natural
Gas
Processing:
SO
2
Emissions,
published
at
40
CFR
part
60.640,
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
(
CO
2)
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
of
hydrogen
sulfide
in
the
acid
gas,
expressed
as
sulfur.

For
the
purposes
of
this
document,
new
facilities
are
those
affected
facilities
that
have
had
construction,
modification
or
reconstruction
within
the
last
three
years.
This
information
is
being
collected
to
determine
compliance
with
40
CFR
part
60,
subparts
KKK
and
LLL.

In
general,
all
NSPS
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
2
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
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
these
subparts
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.
Once
received
by
the
authority,
reports
are
reviewed
and
the
data
is
entered,
analyzed,
and
maintained
in
the
Air
Facility
System
(
AFS).
Information
from
these
reports
can
be
used
by
any
regions,
states,
agencies
and
offices
with
access
to
AFS
and
may
be
used
in
determining
where
inspections
and
enforcement
actions
may
be
necessary.

Approximately
561
sources
are
currently
subject
to
subpart
KKK,
and
it
is
estimated
that
one
additional
source
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
4
affected
facilities
per
plant.
Approximately
79
sources
are
currently
subject
to
subpart
LLL,
and
it
is
estimated
that
3
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
1
affected
facility
per
plant.

The
following
table
presents
the
annual
costs
of
the
ICR
for
subparts
KKK
and
LLL.

Category
Burden
Cost
Labor
(
hours)

subpart
KKK
Labor
$
6,887,057
107,940
Nonlabor
$
0
­­

subpart
KKK
Subtotal
$
6,887,057
107,940
subpart
LLL
Labor
$
2,631,301
41,240
Nonlabor
$
338,700
­­

subpart
LLL
Subtotal
$
2,970,001
41,240
Total
$
9,857,058
149,174
These
estimates
are
based
on
the
Oil
and
Gas
Journal's
PennWell
Surveys,
industry
contacts,
consultation
with
the
Department
of
Energy,
EPA's
Online
Tracking
Information
1
Oil
and
Gas
Journal.
"
Rest
of
world
continues
to
gain
ground
on
Canada,
US."
June
30,
2003.

2
Telephone
conversation
with
Jim
Tobin,
Office
of
Oil
and
Gas,
Energy
Information
Administration,
Department
of
Energy.

3
Oil
and
Gas
Journal.
"
2003:
Processing
outside
North
America
nearly
grabs
the
lead."
June
28,
2004.

4
Oil
and
Gas
Journal.
"
Shift
in
global
industry
continues;
2001
tests
US
processors."
June
24,
2002.

5
Correspondence
with
Lynn
Reed,
Compliance
Engineer,
ONEOK,
Inc.

6
Correspondence
with
Lance
Lodes,
Environmental
Coordinator,
OGE
­
Enogex,
Inc.

3
System
(
OTIS),
and
internal
EPA
cost
and
burden
information.
The
number
of
onshore
natural
gas
processing
plants
has
increased
by
three
since
the
previous
approval.
This
trend
of
one
new
respondent
per
year
for
subpart
KKK
is
expected
to
continue
over
the
next
three
years.
The
number
of
onshore
natural
gas
processing
plants
subject
to
subpart
LLL
has
increased
by
17
since
the
previous
approval.
This
trend
is
not
expected
to
continue
at
the
same
rate,
as
sulfur
production
in
the
United
States
has
declined
in
recent
years.
EPA
expects
three
new
respondents
per
year
for
subpart
LLL
over
the
next
three
years.
The
previous
approval
anticipated
that
no
new
respondents
would
become
subject
to
these
rules
in
the
following
three
years;
this
prediction
appears
to
have
been
incorrect,
based
on
the
number
of
sources
indicated
by
the
Oil
and
Gas
Journal's
PennWell
Surveys.

The
active
(
previous)
ICR
had
the
following
Terms
of
Clearance:

"
The
requested
extension
of
this
information
collection
is
approved
for
three
years
in
accordance
with
the
Paperwork
Reduction
Act.
Before
resubmission
of
this
ICR
for
further
extension,
the
Agency
should
verify
the
estimate
of
the
number
of
respondents
subject
to
these
requirements
and
also
provide
further
detail
in
the
Supporting
Statement
to
explain
the
adjustments
to
the
estimated
number
of
respondents."

EPA
has
addressed
each
item
of
concern
in
the
Terms
of
Clearance
in
a
number
of
ways.
To
determine
the
number
of
respondents
subject
to
subpart
KKK,
EPA
consulted
the
Oil
and
Gas
Journal's
PennWell
Surveys.
1
These
surveys
indicate
that
there
are
590
natural
gas
processing
plants
in
the
U.
S.,
including
both
onshore
and
offshore
processing
plants.
EPA
believes
that
the
vast
majority
of
natural
gas
processing
operations
take
place
onshore;
this
belief
was
supported
by
a
contact
in
the
Department
of
Energy.
2
EPA
therefore
assumes
that
95
percent
of
natural
gas
processing
plants
are
located
onshore.
This
results
in
an
estimate
of
561
respondents
subject
to
subpart
KKK.
To
determine
the
rate
of
industry
growth,
EPA
again
consulted
the
PennWell
Surveys1,3,4
and
consulted
with
industry
contacts.
5,6
Based
on
this
research,
EPA
believes
that
there
is
very
little
growth
in
this
industry.
EPA
therefore
assumes
that
there
will
be
one
additional
7
Oil
and
Gas
Journal.
"
New
data,
old
story:
US,
Canada
continue
to
dominate
world's
gas
processing."
June
25,
2001.

8
Oil
and
Gas
Journal.
"
Shift
in
global
industry
continues;
2001
tests
US
processors."
June
24,
2002.

9
Oil
and
Gas
Journal.
"
Rest
of
world
continues
to
gain
ground
on
Canada,
US."
June
30,
2003.

4
respondent
per
year
over
the
next
three
years.

To
determine
the
number
of
respondents
subject
to
subpart
LLL,
EPA
consulted
the
Oil
and
Gas
Journal's
PennWell
Surveys1
and
industry
contacts.
5,6
Based
on
this
consultation,
EPA
believes
that
between
10
and
20
percent
of
sources
subject
to
subpart
KKK
may
operate
sweetening
units
and
may
therefore
be
subject
to
subpart
LLL.
The
PennWell
surveys
indicate
that
83
natural
gas
processing
plants
produced
sulfur
in
2003.
This
figure
includes
both
onshore
and
offshore
plants.
As
with
subpart
KKK,
EPA
assumes
that
95
percent
of
such
processing
operations
take
place
onshore.
EPA
therefore
assumes
that
there
are
79
onshore
natural
gas
processing
plants
that
produce
sulfur
and
are
subject
to
the
requirements
of
subpart
LLL.
This
is
about
14
percent
of
the
KKK
respondents
and
so
corroborates
the
10
to
20
percent
assumption
derived
from
consultation.
To
determine
the
rate
of
industry
growth,
EPA
again
consulted
the
PennWell
Surveys.
7,8,9
Based
on
this
research,
EPA
believes
that
an
average
of
six
respondents
per
year
became
subject
to
subpart
LLL
since
the
previous
approval.
These
data
sources
also
indicate
that
sulfur
production
in
the
U.
S.
is
in
decline.
EPA
therefore
believes
that
the
number
of
respondents
will
continue
to
grow,
but
at
a
lesser
rate.
EPA
anticipates
that
three
respondents
per
year
will
become
subject
to
subpart
LLL
over
the
next
three
years.

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.
5
In
the
Administrator's
judgment,
VOC
and
sulfur
dioxide
(
SO
2)
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,
the
NSPS
were
promulgated
for
this
source
category
at
40
CFR
part
60,
subparts
KKK
and
LLL.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
VOC
and
SO
2
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
SO
2
from
onshore
natural
gas
processing
plants
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
VOC
and
SO
2
emissions
using
leak
detection
and
repair
procedures
and
the
control
of
SO
2
emissions
using
oxidation
or
reduction
control
systems,
with
the
optional
use
of
incinerators.
The
notifications
required
in
the
applicable
regulations
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
regulations
are
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
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
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
sources
affected
by
the
NSPS
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
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
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
60,
subparts
KKK
and
LLL.

3(
a)
Nonduplication
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.
6
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
(
69
FR
29718)
on
May
25,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
In
addition
to
holding
a
public
comment
period
following
the
First
Federal
Register
Notice,
the
EPA
consulted
with
industry
representatives
to
determine
whether
it
would
be
possible
for
the
Agency
to
reduce
the
recordkeeping
and
reporting
burden
or
improve
the
language
in
the
standards
to
facilitate
industry
compliance.
The
Oil
and
Gas
Journal's
PennWell
Surveys
were
the
primary
sources
of
information
regarding
the
number
of
existing
affected
sources.
Consultations
with
industry
representatives
were
used
to
verify
such
information
and
provide
other
key
data
(
e.
g.,
industry
growth
rate,
level
of
electronic
reporting).
The
EPA
database
OTIS
was
also
consulted.
Finally,
EPA
personnel
in
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS)
were
consulted
regarding
industry
burden
table
assumptions.
The
burden
tables
were
revised
based
on
OAQPS
input.

EPA
consulted
with
four
individuals
with
knowledge
of
the
respondents
to
these
rules.
These
individuals
include:
Jim
Tobin,
Office
of
Oil
and
Gas,
Energy
Information
Administration,
Department
of
Energy
(
202
586­
4835);
Lynn
Reed,
Compliance
Engineer,
ONEOK,
Inc.
(
918
588­
7380);
Lance
Lodes,
Environmental
Coordinator,
OGE
­
Enogex,
Inc.
(
405
557­
6846);
and
Johnny
Dreyer,
Gas
Processors
Association
(
918
493­
3872).
They
provided
information
regarding
the
number
of
affected
onshore
natural
gas
processing
plants,
industry
growth
rate,
level
of
electronic
reporting,
number
of
facilities
using
CEM,
number
of
affected
facilities
per
respondent,
and
representation
of
small
businesses,
as
well
as
anecdotal
information
regarding
industry's
opinion
of
the
rules.

EPA
received
the
following
comments
regarding
the
burden
associated
with
the
recordkeeping
and
reporting
requirements
of
subparts
KKK
and
LLL:

"
Subpart
A
notification
letters
are
burdensome
because
there
is
no
easy
trigger
for
remembering
to
send
them.
It
requires
a
great
deal
of
communication
between
our
corporate
office
who
writes
the
letters
and
the
project
engineer
or
plant
manager
or
area
ESH
coordinator.
There
are
3
and
can
be
as
many
as
4
letters
that
need
to
be
written
for
each
new
affected
facility,
i.
e.,
40
CFR
§
60.7
(
a)(
1),
(
3),
(
4)
potentially,
and
§
60.8(
d)."

"
Documentation
of
each
process
unit
within
the
gas
plant
and
why
7
it
is
or
is
not
subject
to
NSPS
subpart
KKK
is
burdensome.
Typically
this
determination
is
made
by
a
small
group
of
2
or
3
people
who
are
familiar
with
the
project
and
the
regulations.
Committing
the
thought
process
to
paper
with
all
the
dates,
costs
and
emissions
estimates
is
time
consuming
and
sometimes
requires
additional
meetings
to
settle
gray
areas
and
assure
regulatory
interpretation
consistency
within
the
plant
and
within
the
company."

"
Auditing
of
contractor's
LDAR
findings
is
burdensome.
This
requires
a
great
deal
of
communication
between
the
ESH
coordinator,
the
plant
mechanics
and
the
LDAR
contractor.
If
you
don't
have
a
person
delegated
to
responding
to
the
contractor
on
the
first
and
second
repair
attempts,
then
it
is
easy
to
forget
to
do
the
second
attempt."

Complying
with
these
regulations
"
is
burdensome
and
expensive.
Changes
reducing
the
recordkeeping
and
reporting
requirements
should
be
considered.
Reporting
requirements
can
be
very
confusing
for
field
operations
personnel."

EPA
received
the
following
comments
regarding
the
clarity
of
the
language
of
subparts
KKK
and
LLL:

There
is
some
confusion
about
what
triggers
the
need
for
notification
letters
or
performance
tests.
Is
it
a
new,
modified
or
reconstructed
process
unit?
Does
a
few
valves
added
to
an
existing
process
unit
constitute
a
modification?

There
is
some
confusion
about
the
exemption
for
reciprocating
compressors
under
40
CFR
60.633(
f).
Is
the
entire
skid
unit
exempt,
or
is
it
only
the
packing
unit?

In
40
CFR
60.630(
a)(
2),
a
compressor
in
VOC
service
or
in
wet
gas
service
is
an
affected
facility.
Is
the
compressor
defined
as
the
packing
unit?
Or
is
it
defined
as
the
entire
skid/
unit
that
also
includes
valves?

Positive
displacement
(
PD)
"
pump
seals
are
designed
to
leak.
That
is
how
they
work.
The
rule
should
give
an
exemption
for
PD
pumps
the
same
as
it
did
on
reciprocating
compressors
in
wet
gas
8
service.
There
is
no
way
to
"
repair"
these
PD
pump
seals
within
15
days
because
industry
does
not
have
a
packing
or
seal
that
will
work.
This
is
very
frustrating
to
our
operators
to
change
the
seals
and
packing
as
required
by
the
regulation
and
still
have
a
leak
 
by
design
of
the
pump.
It
is
costly
to
continue
to
try
repairs
when
there
is
no
solution.
This
has
been
a
big
problem
throughout
our
industry."

"
Refineries
are
exempt
from
monitoring
reciprocating
pumps
due
to
`
burden
of
cost.'
It
is
my
opinion
that
the
natural
gas
industry
should
have
the
same
exemption
as
refineries.
Natural
gas
industry
should
not
be
required
to
monitor
reciprocating
pumps."

"
Clarify
frequency
of
monitoring
when
coming
out
of
skip­
leak
period.
Rule
is
not
clear
whether
or
not
the
facility
should
revert
back
to
quarterly
monitoring
or
monthly
monitoring."

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
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
(
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
9
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
the
owners
or
operators
of
onshore
natural
gas
processing
plants
with
affected
facilities
constructed,
reconstructed
or
modified
after
January
20,
1984.
The
SIC
codes
for
the
respondents
affected
by
the
standards
are
SIC
(
United
States
Standard
Industrial
Classification)
1311
and
1321,
which
correspond
to
NAICS
(
The
North
American
Industry
Classification
System)
211111
and
211112
for
crude
petroleum/
natural
gas
extraction
and
natural
gas
liquid
extraction.

Standard
SIC
Codes
NAICS
Codes
40
CFR
part
60,
subpart
KKK
1311,
1321
211111,
211112
40
CFR
part
60,
subpart
LLL
1311,
1321
211111,
211112
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
40
CFR
part
60,
subpart
KKK
­
Standards
of
Performance
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
and
40
CFR
part
60,
subpart
LLL
­
Standards
of
Performance
for
Onshore
Natural
Gas
Processing:
SO
2
Emissions.

A
source
must
make
the
following
reports:

Notification
Reports
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)

Notification
of
demonstration
of
continuous
monitoring
system.
60.7(
a)(
5)
Notification
Reports
10
Notification
of
initial
performance
test.
60.8(
d)

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

Performance
test
results.
60.8(
a),
60.636(
a),
60.487(
e)

subpart
KKK
Only
Semiannual
reports.
60.636(
a)­(
c),
60.487(
a)

subpart
LLL
Only
Semiannual
reports
of
excess
emissions
from
and
performance
of
continuous
monitoring
systems,
and/
or
summary
report
forms.
60.647(
b)

A
source
must
keep
the
following
records:

Recordkeeping
subparts
KKK
and
LLL
Keep
records
of
startups,
shutdowns,
and
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)

subpart
KKK
Only
Recordkeeping
11
Keep
records
of
parts
of
closed
vent
systems
designated
as
unsafe
or
difficult
to
inspect.
60.632(
a),
60.482­
10(
l)(
1),(
2)

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

Perform
attachment
of
identification
numbers
to
leaking
equipment.
60.635(
a),(
b),
60.486(
b)

Keep
records
of
leak
detection
and
repair.
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.
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.
60.635(
a),
60.486(
e)(
4)

Keep
records
of
valves
designated
as
unsafe
or
difficult
to
monitor.
60.635(
a),
60.486(
f)

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

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

subpart
LLL
Only
Keep
records
of
calculations
and
measurements.
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
than
150
long
tons
per
day
of
hydrogen
sulfide
expressed
as
sulfur
60.647(
d)
10
Correspondence
with
Lynn
Reed,
Compliance
Engineer,
ONEOK,
Inc.

11
Correspondence
with
Lance
Lodes,
Environmental
Coordinator,
OGE
­
Enogex,
Inc.

12
Electronic
Reporting
Presently,
some
sources
are
using
monitoring
equipment
that
provide
automated
parameter
data.
Based
on
industry
consultation,
EPA
believes
that
the
majority
of
respondents
use
some
form
of
automated
recordkeeping.
10,11
Although
personnel
at
the
affected
facilities
must
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
entities
(
both
government
agencies
and
respondents)
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
The
extent
of
this
practice
among
respondents
is
unclear,
but
EPA
believes
that
at
least
10
percent
of
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
subparts
KKK
and
LLL
Read
instructions.

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
13
Transmit,
or
otherwise
disclose
the
information.

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

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

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

Repair
pump,
compressor,
valve,
and
vapor
collection
system
leaks.

Perform
weekly
visual
inspections
of
pumps
in
light
liquid
service.

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

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

Conduct
annual
inspections
of
vapor
collection
systems.

subpart
LLL
Only
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.

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

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

Perform
daily
monitoring
of
(
a)
accumulation
of
sulfur
product
and
(
b)
H
2
S
concentration
in
the
acid
gas
from
the
sweetening
unit.
Respondent
Activities
14
Perform
hourly
monitoring
of
acid
gas
flow
rate
from
the
sweetening
unit
and
calculate
the
daily
average.

Calculate
(
a)
daily
sulfur
feed
rate
and
(
b)
daily
required
SO
2
emission
reduction
efficiency.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
observe
repeat
performance
tests
if
necessary.

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

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
may
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
regulations
are
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
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
Note
that
subpart
KKK
does
not
require
VOC
control
devices.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS,
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
12
Correspondence
with
Lynn
Reed,
Compliance
Engineer,
ONEOK,
Inc.

15
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
these
regulations
must
be
retained
by
the
owner
or
operator
for
two
years.
However,
facilities
subject
to
subpart
LLL
that
produce
less
than
150
long
tons
per
day
(
LT/
D)
and
elect
to
do
reduced
monitoring,
records
must
be
kept
for
the
life
of
the
facility
showing
that
the
design
capacity
of
that
facility
is
less
than
150
LT/
D.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
Based
on
industry
consultation,
EPA
estimates
that
between
10
and
20
percent
of
respondents
could
be
described
as
small
entities.
12
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
requirements
the
minimum
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.

Subpart
LLL
contains
a
provision
to
reduce
the
burden
on
respondents
with
small
facilities.
The
control
and
monitoring
requirements
do
not
apply
to
affected
facilities
with
design
capacities
of
less
than
two
long
tons
per
day
of
hydrogen
sulfide
in
the
acid
gas,
expressed
as
sulfur.
These
respondents
need
only
maintain
analyses
showing
the
design
capacities
of
such
facilities.

Subpart
KKK
contains
provisions
to
reduce
the
burden
on
some
respondents.
For
example,
pumps,
compressors,
and
valves
with
no
detectable
emissions
can
be
exempted
from
certain
monitoring
and
inspection
requirements.
This
rule
contains
reduced
monitoring
requirements
for
valves
that
have
not
had
leaks
detected
for
at
least
two
months.
Also,
certain
pumps,
valves,
and
pressure
relief
devices
are
exempt
from
monthly
monitoring
requirements
if
they
are
either
(
a)
located
at
a
nonfractionating
plant
that
does
not
have
the
design
capacity
to
process
10
million
standard
cubic
feet
per
day
or
more
of
field
gas,
or
(
b)
located
within
a
process
unit
that
is
located
in
the
Alaskan
North
Slope.
16
5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1A:
Annual
Respondent
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
part
60,
subpart
KKK),
and
Table
1B:
Annual
Respondent
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO
2
Emissions
(
40
CFR
part
60,
subpart
LLL),
below.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
1A
and
1B
document
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
each
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
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
149,174
hours
(
107,940
hours
for
subpart
KKK
and
41,240
hours
for
subpart
LLL).
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
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
17
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
standard
for
NSPS
subpart
KKK
consists
of
a
leak
detection
and
repair
program;
this
rule
does
not
require
continuous
monitoring.
Therefore,
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
standard
for
NSPS
subpart
LLL
may
consist
of
continuous
monitoring
of
SO
2
emissions.
Therefore,
the
type
of
industry
costs
associated
with
the
information
collection
activities
required
by
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(
s)
and
other
costs
such
as
photocopying
and
postage.

This
ICR
results
in
an
increase
in
the
estimated
capital/
startup
and
operation
and
maintenance
costs
to
the
respondents.
This
is
due
to
several
revisions.
The
number
of
existing
respondents
to
subpart
LLL
has
increased
since
the
previous
approval;
therefore,
there
are
greater
anticipated
operation
and
maintenance
costs.
The
number
of
expected
new
respondents
to
subpart
LLL
has
also
increased
since
the
previous
approval,
which
predicted
no
new
respondents;
therefore,
there
are
greater
anticipated
capital/
startup
costs.
Also,
the
previous
approval
assumed
that
only
one
respondent
to
subpart
LLL
required
use
of
continuous
monitoring.
EPA
believes
that
the
number
of
respondents
needing
continuous
monitoring
is
7.
This
ICR
also
uses
updated
cost
information
for
monitoring
devices.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
following
table
presents
the
respondent
costs
associated
with
capital/
startup,
and
operation
and
maintenance
of
the
control
devices
and
monitoring
systems
that
are
required
by
40
CFR
part
60,
subpart
LLL:

Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Device
(
C)
Annual
Number
of
New
Devices
(
D)
Total
Annual
Capital/
Startu
p
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Device
(
F)
Annual
Number
of
Devices
(
G)
Total
O&
M,
(
E
X
F)

subpart
KKK
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
18
No
controls
required
­­
­­
­­
­­
­­
­­

subpart
LLL
SO2
CEM,
control
outlet
only
$
73,000
1
3
$
219,000
$
17,100
1
7
$
119,700
Total
$
219,000
$
119,700
1
These
capital/
startup
and
operation
and
maintenance
costs
are
based
on
EPA's
Air
Pollution
Control
Cost
Manual,
Sixth
Edition
(
January
2002).
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.
Costs
do
not
include
any
labor.

The
total
capital/
startup
costs
for
this
ICR
are
$
219,000.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
119,700.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs
and
the
annual
operation
and
maintenance
costs.
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
$
338,700.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

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
$
501,916.
19
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2A:
Annual
Agency
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
part
60,
subpart
KKK),
and
Table
2B:
Annual
Agency
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO
2
Emissions
(
40
CFR
part
60,
subpart
LLL),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
561
existing
sources
are
currently
subject
to
NSPS
subpart
KKK
and
approximately
79
existing
sources
are
currently
subject
to
NSPS
subpart
LLL.
It
is
estimated
that
one
additional
source
per
year
will
become
subject
to
subpart
KKK
over
the
next
three
years,
and
three
additional
sources
per
year
will
become
subject
to
subpart
LLL
over
the
next
three
years.

The
number
of
respondents
is
calculated
using
the
following
table,
which
addresses
the
three
years
covered
by
this
ICR:

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
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=
A+
B+
CD

subpart
KKK
1
113
2
561
0
112
2
562
2
113
2
562
0
112
2
563
3
114
2
563
0
113
2
564
Number
of
Respondents
20
Average
113
2
562
0
112
2
563
subpart
LLL
1
3
79
3
3
0
85
2
3
82
3
3
0
88
3
3
85
3
3
0
91
Average
3
82
3
3
0
88
1
New
respondents
include
sources
that
constructed,
reconstructed
and
modified
affected
facilities
in
the
past
three
years.
In
this
standard,
existing
respondents
submit
initial
notifications.

2
Based
on
industry
consultation,
EPA
believes
that
approximately
20
percent
of
existing
respondents
for
Subpart
KKK
will
construct
one
new
affected
facility
per
year.
Column
D
represents
this
estimate
of
the
number
of
existing
respondents
adding
new
affected
facilities.
Column
A
represents
the
same
number,
plus
the
estimated
number
of
wholly
new
sources
per
year
(
1
per
year).

3
Affected
facilities
with
design
capacities
of
less
than
two
long
tons
per
day
of
hydrogen
sulfide
(
H2S)
in
the
acid
gas,
expressed
as
sulfur,
have
no
reporting
requirements
pursuant
to
Subpart
LLL.
Based
on
information
from
the
Oil
and
Gas
Journal's
PennWell
Surveys,
three
respondents
have
source
capacities
below
this
threshold.

To
avoid
double­
counting
respondents,
Column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
563
(
all
sources
subject
to
subpart
LLL
are
also
subject
to
subpart
KKK).
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
subpart
KKK
Notification
of
construction
or
reconstruction.
57
1
1
­­
57
Notification
of
modification.
56
1
1
­­
56
Total
Annual
Responses
21
Notification
of
anticipated
startup
113
1
­­
113
Notification
of
actual
startup
date.
113
1
­­
113
Notification
of
demonstration
of
continuous
monitoring
system.
0
1
­­
0
Notification
of
initial
performance
test.
0
1
­­
0
Performance
test
results.
0
1
0
0
Semiannual
reports.
563
2
0
1,126
subpart
LLL
Notification
of
construction
or
reconstruction.
1.5
1
1
­­
1.5
Notification
of
anticipated
startup.
3
1
­­
3
Notification
of
actual
startup.
3
1
­­
3
Notification
of
demonstration
of
continuous
monitoring
system.
3
1
­­
3
Notification
of
initial
performance
test.
3
1
­­
3
Semiannual
reports.
82
2
2
164
CEMS
demonstration
report
3
0.2
0.6
Total
1,643
1
EPA
assumes
that
one­
half
of
the
new
affected
facilities
are
the
result
of
construction
or
reconstruction,
while
the
other
half
are
the
result
of
modifications
of
existing
facilities.

2
This
figure
represents
the
average
number
of
respondents
over
the
next
three
years
(
85
respondents),
one
affected
facility
per
respondent,
and
three
respondents
that
do
not
require
controls
(
85
*
1
­
3
=
82).

The
number
of
Total
Annual
Responses
is
1,643.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.
Note
that
113
respondents
for
subpart
KKK
have
been
double
counted
in
the
above
table
because
they
have
both
existing
affected
facilities
and
new
affected
facilities.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
for
respondents
are
$
9,518,358.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1A:
Annual
22
Respondent
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
part
60,
subpart
KKK),
and
Table
1B:
Annual
Respondent
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO
2
Emissions
(
40
CFR
part
60,
subpart
LLL),
below.
Table
1A:
Annual
Response
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
Part
60,
Subpart
KKK)
23
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
1.
Applications
2.
Survey
and
Studies
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
563
563
28.2
56.3
41,315
B.
Required
activities
Notification
of
construction/
reconstruction
2
1
2
57
114
5.7
11.4
8,365
Notification
of
modification4
8
1
8
56
448
22.4
44.8
32,872
Notification
of
anticipated
startup
2
1
2
113
226
11.3
22.6
16,583
Notification
of
actual
startup
2
1
2
113
226
11.3
22.6
16,583
Table
1A:
Annual
Response
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
Part
60,
Subpart
KKK)

Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
24
Notification
of
electing
to
comply
with
alternative
standards
for
valves2
8
1
8
0
0
0
0
0
Notification
of
initial
performance
test3
2
1
2
0
0
0
0
0
Semiannual
reports5
8
2
16
563
9,008
450.4
900.8
660,962
C.
Create
Information
Initial
Performance
Tests
NA
D.
Gathering
Existing
Information
NA
E.
Time
to
write
reports
See
3B
4.
Recordkeeping
Requirements
Table
1A:
Annual
Response
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
Part
60,
Subpart
KKK)

Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
25
A.
Read
Instructions
See
4C
B.
Plan
Activities
See
4C
C.
Implement
Activities
Filing
and
maintaining
records
80
1
80
563
45,040
2,252
4,504
3,304,810
Startup,
shutdown,
or
malfunction4
80
1
80
112
8,960
448
896
657,440
Recalibrate
monitors
4
12
48
563
27,024
1,351.2
2,702.4
1,982,886
Method
21
performance
evaluation
2
2
4
563
2,252
112.6
225.2
165,241
D.
Develop
Record
System
See
4C
Table
1A:
Annual
Response
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
Part
60,
Subpart
KKK)

Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
26
E.
Time
to
Enter
Information
See
4C
F.
Train
Personnel
See
4C
G.
Audits
NA
Total
Burden
6,887,057
Assumptions
for
Table
1A:

1.
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rate
[(
Technical
hrs
x
$
64.60)
+
(
Management
hrs
x
$
95.32)
+
(
Clerical
hrs
x
$
40.09)].

2.
No
respondents
are
expected
to
use
the
alternative
standards.

3.
While
Subpart
KKK
includes
the
option
of
using
closed
vent
systems
and
control
devices
to
demonstrate
compliance,
this
is
not
required
by
rule.
No
respondents
are
expected
to
use
this
option.

Therefore,
no
respondents
are
expected
to
submit
the
associated
notifications
and
reports.

4.
Activity
added
since
previous
ICR
based
on
research
of
original
ICR
and
consultation
with
OAQPS.

5.
Hours
per
occurrence
changed
based
on
research
of
original
ICR
and
consultation
with
OAQPS.
Table
1B:
Annual
Response
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO2
Emissions
(
40
CFR
Part
60,

Subpart
LLL)
27
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents1
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
2
1.
Applications
2.
Survey
and
Studies
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
82
82
4.1
8.2
6,017
B.
Required
activities
Initial
performance
test3
60
1
60
3
180
9
18
13,208
Repeat
performance
test3
60
0.2
12
3
36
1.8
3.6
2,642
Demonstration/

CEMS3
80
0.2
16
3
48
2.4
4.8
3,522
Repeat
demonstration
of
CEMS3
80
0.2
16
3
48
2.4
4.8
3,522
Table
1B:
Annual
Response
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO2
Emissions
(
40
CFR
Part
60,

Subpart
LLL)
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents1
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
2
28
C.
Create
Information
See
3B
D.
Gathering
Existing
Information
See
3B
E.
Write
Report
Notification
of
Construction/
Reconstruction
2
1
2
1.5
3
0.15
0.3
220
Notification
of
modification
NA
Notification
of
Anticipated
Startup
2
1
2
3
6
0.3
0.6
440
Notification
of
Actual
Startup
2
1
2
3
6
0.3
0.6
440
Notification
of
Initial
Performance
Test
2
1
2
3
6
0.3
0.6
440
Table
1B:
Annual
Response
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO2
Emissions
(
40
CFR
Part
60,

Subpart
LLL)
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents1
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
2
29
Notification
of
CMS
Demonstration
2
1
2
3
6
0.3
0.6
440
CMS
Demonstration
Report
See
3B
Semiannual
Reports3
40
2
80
82
6,560
328
656
481,340
4.
Recordkeeping
Requirements
A.
Read
Instructions
See
3A
B.
Plan
Activities
NA
C.
Implement
Activities
NA
D.
Develop
Record
System
40
1
40
3
120
6
12
8,805
E.
Time
to
Enter
Information
Table
1B:
Annual
Response
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO2
Emissions
(
40
CFR
Part
60,

Subpart
LLL)
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents1
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
2
30
Records
of
startup,

shutdown,
or
malfunction
1.5
12
18
3
54
2.7
5.4
3,962
Records
of
continuous
recording
0.5
700
350
82
28,700
1,435
2,870
2,105,863
Records
of
capacity
data
2
1
2
3
6
0.3
0.6
440
F.
Train
Personnel
NA
G.
Audits
NA
Total
Burden
2,631,301
Assumptions
for
Table
1B:

1.
See
"
Number
of
Respondents"
table
in
Section
6(
d),
82
facilities
submit
reports
and
3
facilities
only
keep
records.

2.
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rate
[(
Technical
hrs
x
$
64.60)
+
(
Management
hrs
x
$
95.32)
+
(
Clerical
hrs
x
$
40.09)].

3.
Hours
per
occurrence
changed
based
on
research
of
original
ICR
and
consultation
with
OAQPS.
Table
2A:
Annual
Agency
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
Part
60,
Subpart
KKK)
31
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
1.
Review
of
notification
of
construction/

reconstruction
2
1
2
56
112
5.6
11.2
5,095
2.
Review
of
notification
of
modification
2
1
2
56
112
5.6
11.2
5,095
3.
Review
of
notification
of
anticipated
startup
2
1
2
112
224
11.2
22.4
10,189
4.
Review
of
notification
of
actual
startup
2
1
2
112
224
11.2
22.4
10,189
5.
Notification
of
demonstration
of
CEMS2
2
1
2
0
0
0
0
0
6.
Review
of
initial
CEMS
demonstration
report2
2
1
2
0
0
0
0
0
7.
Review
of
notification
of
performance
test2
2
1
2
0
0
0
0
0
Table
2A:
Annual
Agency
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
Part
60,
Subpart
KKK)

Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
32
8.
Review
of
results
of
performance
test2
2
1
2
0
0
0
0
0
9.
Review
of
semiannual
reports
8
2
16
563
9,008
450.4
900.8
409,756
Total
Burden
440,324
Assumptions
for
Table
2A:

1.
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hrs
x
$
40.56)
+
(
Management
hrs
x
$
54.66)
+
(
Clerical
hrs
x
$
21.95)].

2.
While
Subpart
KKK
includes
the
option
of
using
closed
vent
systems
and
control
devices
to
demonstrate
compliance,
this
is
not
required
by
rule.
No
respondents
are
expected
to
use
this
option.

Therefore,
no
respondents
are
expected
to
submit
the
associated
notifications
and
reports.
Table
2B:
Annual
Agency
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO2
Emissions
(
40
CFR
Part
60,

Subpart
LLL)
33
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
1.
Review
of
notification
of
construction/
reconstruction
2
1
2
1.5
3
0.15
0.3
137
2.
Review
of
notification
of
modification
2
1
2
1.5
3
0.15
0.3
137
Review
notification
of
anticipated
startup
2
1
2
3
6
0.3
0.6
273
3.
Review
of
notification
of
actual
startup
2
1
2
3
6
0.3
0.6
273
Review
notification
of
demonstration
of
CEMS
2
1
2
3
6
0.3
0.6
273
4.
Review
of
CEMS
demonstration
report
2
1
2
3
6
0.3
0.6
273
Table
2B:
Annual
Agency
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO2
Emissions
(
40
CFR
Part
60,

Subpart
LLL)
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences
/
Respondent/

Year
(
C)
Hours/
Respondent/

Year
[
C
=
A
x
B]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr
[
E
=
C
x
D]
(
F)
Management
Hrs/
Yr
[
F
=
0.05
x
E]
(
G)
Clerical
Hrs/
Yr
[
G
=
0.1
x
E]
(
H)

Total
Labor
Costs/
Yr
[$]
1
34
5.
Review
of
notification
of
initial
performance
test
2
1
2
3
6
0.3
0.6
273
6.
Review
of
semiannual
reports
8
2
16
82
1,312
65.6
131.2
59,680
7.
Review
of
results
of
performance
test
2
1
2
3
6
0.3
0.6
273
Total
Burden
61,592
Assumptions
for
Table
2B:

1.
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hrs
x
$
40.56)
+
(
Management
hrs
x
$
54.66)
+
(
Clerical
hrs
x
$
21.95)].
35
6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1A,
1B,
2A
and
2B,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
9,518,358.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1A:
Annual
Respondent
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
part
60,
subpart
KKK),
and
Table
1B:
Annual
Respondent
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO
2
Emissions
(
40
CFR
part
60,
subpart
LLL),
above.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
91
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
338,700.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
12,689
labor
hours
at
a
cost
of
$
501,916.
See
Table
2A:
Annual
Agency
Burden
and
Cost,
NSPS
for
Equipment
Leaks
of
VOC
From
Onshore
Natural
Gas
Processing
Plants
(
40
CFR
part
60,
subpart
KKK),
and
Table
2B:
Annual
Agency
Burden
and
Cost,
NSPS
for
Onshore
Natural
Gas
Processing:
SO
2
Emissions
(
40
CFR
part
60,
subpart
LLL),
above.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
adjustments.
The
adjustment
increase
in
burden
from
the
most
recently
approved
ICR
is
primarily
due
to
an
increase
in
the
number
of
respondents
and
an
adjustment
of
the
recordkeeping
and
reporting
burden.

This
ICR
results
in
an
increase
in
the
estimated
capital/
startup
and
operation
and
maintenance
costs
to
the
respondents.
This
is
due
to
the
following
factors.
The
number
of
expected
new
respondents
to
subpart
LLL
has
increased
to
3
since
the
previous
approval,
which
predicted
no
new
respondents;
therefore,
there
are
greater
anticipated
capital/
startup
costs.
The
number
of
existing
respondents
to
subpart
LLL
that
have
CEMs
has
increased
from
1
to
7
since
the
previous
approval.
This
results
in
an
increase
in
both
the
estimated
capital/
startup
and
36
operation
and
maintenance
costs.
Also
note
that
the
previous
ICR
erroneously
used
$
74,000
as
the
cost
of
O&
M
for
one
facility,
instead
of
$
17,100.
Capital/
startup
and
O&
M
cost
for
this
ICR
is
taken
from
EPA's
Air
Pollution
Control
Cost
Manual,
Sixth
Edition
(
January
2002).
This
ICR
also
uses
updated
cost
information
for
monitoring
devices.

Summarizing
the
changes
in
capital
and
O&
M
cost
since
the
previous
ICR:

*
Anticipated
new
facilities
went
from
0
to
3,
increasing
cost
from
$
0
to
$
219,000
(
3
x
$
73,000).
*
Existing
facilities
incurring
O&
M
cost
went
from
1
to
7,
increasing
cost
from
$
74,000
to
$
119,700
(
7
x
$
17,100).

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
91
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

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

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0005,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
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.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
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
above.
Also,
you
can
send
comments
to
37
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
OECA­
2004­
0005
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.
