SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Natural
Gas
Transmission
and
Storage,
published
at
40
CFR
part
63,
subpart
HHH,
were
proposed
on
February
6,
1998,
and
promulgated
on
June
17,
1999.
These
regulations
apply
to
existing
facilities
and
new
facilities
that
are
major
sources
of
hazardous
air
pollutants
(
HAP)
and
that
transport
or
store
natural
gas
prior
to
entering
the
pipeline
to
a
local
distribution
company
or
to
a
final
end
user
(
if
there
is
no
local
distribution
company).
New
facilities
include
those
that
commenced
construction
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
HHH.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
by
the
owners/
operators
of
the
affected
facilities.
They
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
affected
facilities
subject
to
NESHAP.

Any
owner/
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
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.

Approximately
19
respondents
are
currently
subject
to
the
reporting
requirements
of
this
regulation,
and
EPA
estimates
that
an
additional
two
reporting
respondents
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
In
addition,
approximately
807
existing
respondents
are
subject
only
to
the
recordkeeping
requirements
of
this
regulation.
Overall,
EPA
estimates
that
approximately
826
respondents
are
subject
to
the
regulation,
and
an
additional
2
respondents
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
These
estimates
of
the
size
of
the
regulated
universe
are
based
on
information
from
the
original
ICR
written
when
the
NESHAP
was
promulgated
and
a
search
of
EPA's
Online
Tracking
Information
System
(
OTIS)
database.
EPA
assumes
that
there
is
an
average
of
one
affected
facility
per
plant
2
(
i.
e.,
respondent).
EPA
estimates
that
the
annual
cost
of
this
information
collection
will
be
$
0
for
nonlabor
and
$
61,087
for
labor,
based
on
a
labor
burden
of
757
hours,
for
a
total
annual
cost
of
$
61,087.
OMB
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
section
114(
a)
states
that
the
Administrator
may
require
any
owner/
operator
subject
to
any
requirement
of
this
Act
to:

(
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,
HAP
emissions
from
natural
gas
transmission
and
storage
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
HHH.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standard
ensure
compliance
with
the
applicable
regulations
which
where
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.

Performance
tests
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standard.
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standard
at
all
times.
During
the
performance
test,
a
record
of
the
operating
parameters
under
which
compliance
was
achieved
may
be
recorded
and
used
to
determine
3
compliance
in
place
of
a
continuous
emission
monitor.

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

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

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
HHH.

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.

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
69909)
on
December
1,
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
(
FFRN),
the
EPA
contacted
the
American
Petroleum
Institute
(
API),
the
American
Gas
Association
(
AGA),
and
the
Interstate
Natural
Gas
Association
of
America
(
INGAA)
to
determine
whether
it
would
be
possible
for
the
Agency
to
reduce
the
recordkeeping
and
reporting
burden
or
improve
the
language
in
the
standards
to
facilitate
industry
compliance.
EPA
also
solicited
information
about
the
size,
growth,
and
other
characteristics
of
the
regulated
industry.
API
declined
to
provide
comments
on
the
NESHAP.
EPA
did
not
receive
a
response
from
AGA
or
INGAA.
EPA
also
searched
its
OTIS
database
for
information
on
the
number
of
existing
respondents.
4
To
determine
the
size
of
the
regulated
universe
EPA
used
information
from
the
Federal
Energy
Regulatory
Commission
on
the
U.
S.
annual
natural
gas
throughput
for
2003
to
estimate
the
size
of
the
source
category.

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

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

These
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications,
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five
year
records
retention
requirement
is
consistent
with
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
5
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
owners/
operators
of
natural
gas
transmission
and
storage
facilities.
The
SIC
codes
for
the
respondents
affected
by
the
standards
are
SIC
(
United
States
Standard
Industrial
Classification)
4922
and
4923,
which
correspond
to
NAICS
(
The
North
American
Industry
Classification
System)
48621
and
22121,
for
Pipeline
Transportation
of
Natural
Gas
and
Natural
Gas
Distribution,
respectively.

Standard
SIC
Codes
NAICS
Codes
40
CFR
part
63,
subpart
HHH
4922
48621
40
CFR
part
63,
subpart
HHH
4923
22121,
48621
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
the
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH).

A
source
must
make
the
following
reports:

Notification
Reports
Initial
notification
that
a
source
is
subject
to
the
provisions
in
subpart
HHH.
63.9(
b)(
2),
63.1274(
a),
63.1285(
b)(
1)
and
(
b)(
2)

Notification
of
the
date
of
a
performance
test.
63.7(
b)
and
(
c),
63.8(
e)(
2),
63.9(
e),
63.9(
g)(
1),
63.1274(
a),
63.1285(
b)(
3)

Notification
of
Compliance
Status
Report,
including
the
results
of
any
continuous
monitoring
system
performance
evaluations
and
inspection
results.
63.9(
h),
63.1270(
d),
63.1274(
a),
63.1283(
c)(
2)(
ii)(
A),
63.1285(
b)(
4),
63.1285(
d)(
1)
through
(
d)(
10)
6
Notification
Reports
Notification
of
change
in
compliance
demonstration
methods
for
control
device
performance
(
submit
with
Periodic
Report).
63.1282(
e)

Performance
test
results
for
closed­
vent
systems
using
flares
as
the
control
device
(
submit
with
Notification
of
Compliance
Status
Report).
63.7(
g),
63.10(
d)(
2),
63.1274,
63.1282(
d)(
3),
63.1285(
d)(
2)

Design
analysis
documentation,
including
operating
parameters
and
calculations,
for
closed­
vent
systems
using
control
devices
other
than
flares
(
submit
with
Notification
of
Compliance
Status
Report).
63.1274,
63.1282(
d)(
4),
63.1285(
d)(
4)(
i)
through
(
d)(
4)(
iii)

One
complete
test
report
for
each
test
method
used
for
a
particular
source
(
submit
with
Notification
of
Compliance
Status
Report).
63.1285(
d)(
3)

Analysis
demonstrating
whether
an
affected
source
is
a
major
source
(
submit
with
Notification
of
Compliance
Status
Report).
63.1285(
d)(
8)

Statement
of
compliance
with
subpart
HHH
(
submit
with
Notification
of
Compliance
Status
Report).
63.1285(
d)(
9)

Notification
of
any
process
change.
63.1285(
f)

Application
for
approval
of
construction
or
reconstruction.
63.5(
d)(
1),
63.1274(
a)

Notification
of
intent
to
construct
or
reconstruct.
63.9(
b)(
5)(
i),
63.9(
d)(
4)(
i),
63.1274(
a)

Notification
of
actual
date
of
startup.
63.9(
b)(
4)(
v),
63.9(
b)(
5)(
ii),
63.1274(
a)

Results
of
performance
evaluation.
63.8(
e)(
5),
63.10(
e),
63.1274(
a)

Notification
of
special
compliance
requirements.
63.9(
d),
63.1274(
a)
7
Reports
Semiannual
startup,
shutdown,
or
malfunction
reports
(
may
be
submitted
with
Periodic
Report).
63.6(
e)(
3)(
iv),
63.10(
d)(
5),
63.1274(
a),
63.1285(
b)(
6)

Semiannual
Periodic
Reports.
63.10(
e),
63.1274(
a),
63.1285(
e)

Report
to
demonstrate
compliance
with
benzene
emission
limit
(
alternative
standards)
(
submit
with
Notification
of
Compliance
Status
Report).
63.1285(
d)(
7)

Analysis
that
demonstrates
conditions
under
which
the
facility
reduces
95.0
percent
of
its
HAP
emissions
(
submit
with
Notification
of
Compliance
Status
Report).
63.1281(
e)(
2),
63.1285(
d)(
10)

Semiannual
excess
emissions
and
continuous
monitoring
system
performance
report.
63.9(
c)(
8),
63.10(
e)(
3),
63.1274(
a)

Semiannual
HAP
summary
report.
63.10(
e)(
3)(
vi),
63.1274(
a)

A
source
must
keep
the
following
records:

Recordkeeping
Records
for
each
monitoring
system
including
documentation
of
incidents
such
as
breakdowns,
repairs,
calibration
checks,
startup,
shutdown,
malfunctions,
and
other
down
time.
63.10(
b)(
2),
63.10(
c),
63.1272(
d),
63.1274(
a),
63.1283(
d),
63.1284(
b)(
3)

Continuous
records
of
equipment
operating
parameters
and
daily
average
values
of
the
parameters.
63.1284(
b)(
4)(
i)
and
(
ii)

Records
of
the
times
and
duration
of
all
periods
during
which
pilot
flames
are
absent.
63.1284(
b)(
4)(
ii),
63.1284(
e)(
3)

Records
of
flow
indicator
operation,
detection,
and
vent
stream
diversions.
63.1284(
b)(
4)(
iii)
8
Recordkeeping
Records
of
inspections
of
seals
or
closure
mechanisms
and
records
of
broken
or
changed
seals,
valves,
or
locks.
63.1284(
b)(
4)(
iv)

Continuous
monitoring
system
quality
control
program.
63.8(
d),
63.1274(
a)

Startup,
shutdown,
and
malfunction
plan.
63.6(
e)(
3),
63.8(
c)(
1)(
iii),
63.1272(
d),
63.1274(
a)

Records
of
control
device
activities,
malfunctions,
and
down
time.
63.1274,
63.1281(
c)(
3),
63.1283(
d),
63.1284(
b)(
3)
and
(
b)(
4)

Records
pertaining
to
the
inspection
of
closed­
vent
systems
including
maintenance,
leaks,
repairs,
delays,
and
shutdowns.
This
also
applies
to
parts
that
are
difficult
or
unsafe
to
inspect
and
those
where
a
leak
or
defect
is
detected.
63.1283(
c)(
3)
through
(
c)(
7),
63.1284(
b)(
5)
through
(
8)

Records
of
glycol
dehydration
unit
baseline
operations,
throughput
quantity,
and
emissions
information.
63.1281(
e)(
1)
and
(
e)(
2),
63.1284(
b)(
9)
and
(
10),
63.1284(
d)

Records
of
compliance
with
benzene
emission
limit
(
alternative
standards).
63.1281(
e)(
2),
63.1284(
c)

Throughput
and
emissions
records
of
exempt
glycol
dehydration
units.
63.1274(
c)
and
(
d),
63.1284(
d)

Records
of
flare
design
and
emissions.
63.1284(
e)

Records
of
leak
or
defect
detection,
severity
(
maximum
instrument
reading),
and
date
of
repair.
63.1284(
b)(
7)
and
(
b)(
8)

Site­
specific
performance
evaluation
test
plan.
63.7(
c)(
2),
63.8(
d)(
2),
63.8(
e)(
3)(
i),
63.1274(
a)

Record
of
results
of
performance
test.
63.7(
g)(
3),
63.1274(
a)
9
Electronic
Reporting
At
the
present,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data
(
e.
g.,
temperature).
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also,
regulatory
agencies,
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
these
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
closed
vent
systems
and
CMS
to:
1)
achieve
a
95%
reduction
in
HAP,
TOC,
or
total
HAP,
for
control
devices
and
vapor
recovery
devices;
2)
achieve
a
reduction
to
20
ppm
of
TOC
or
total
HAP,
and
operates
at
a
minimum
residence
time
of
0.5
seconds
at
a
minimum
temperature
of
760
degrees
Celsius
for
combustion
devices.

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

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

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

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

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

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

Transmit,
or
otherwise
disclose
the
information.

The
rule
does
not
require
use
of
information
collection
techniques
such
as
automated,
mechanical,
or
other
technical
collection
techniques.
Electronic
submissions
can
be
made
but
they
must
be
followed
up
with
a
hard
copy
that
is
signed
by
the
owner/
operator
of
the
facility.
10
5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

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

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

Audit
facility
records.

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

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

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,
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
this
regulation
must
be
retained
by
the
owner/
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
There
is
a
distribution
of
business
sizes
among
the
respondents.
At
the
time
of
rulemaking,
the
Agency
estimated
that
the
number
of
affected
small
entities
would
likely
be
11
1
Preamble
to
Final
Rule
(
see
64
FR
32626,
June
17,
1999).
minimal
due
to
several
considerations
in
these
rules
that
minimize
the
burden
on
all
firms,
both
small
and
large.
1
These
considerations
include
exempting
from
the
control,
monitoring,
and
reporting
requirements
of
the
NESHAP
those
glycol
dehydration
units
below
certain
thresholds
for
natural
gas
throughput
(
less
than
283
thousand
standard
cubic
meters
per
day)
or
benzene
emissions
(
less
than
0.90
megagram
per
year).
The
Agency
considers
the
remaining
recordkeeping
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.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH),
attached.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
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
757
hours
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
97.46
($
46.41
+
110%)
12
Technical
$
83.71
($
39.86
+
110%)
Clerical
$
42.55
($
20.26
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
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
the
subject
standards
are
labor
costs.
There
are
no
capital/
startup
or
operations
and
maintenance
costs
incurred
as
a
result
of
this
standard
because
the
industry
has
primarily
installed
flares
to
control
emissions.
The
only
continuous
monitoring
required
for
a
flare
is
the
monitoring
of
the
presence
of
the
pilot
flame,
which
is
a
requirement
for
proper
operation
of
a
flare
under
40
CFR
63.11(
b)(
5).

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
costs.
There
are
no
capital/
startup
or
operation
and
maintenance
costs.

The
total
capital/
startup
costs
for
this
ICR
are
$
0.
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
$
0.
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
$
0.
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
13
2
Background
Information
for
Final
Standards:
Summary
of
Public
Comments
and
Responses,
U.
S.
EPA,
May
1999,
EPA­
453/
R­
99­
004b.

3
Original
ICR
supporting
statement
(
http://
www.
epa.
gov/
icr/
icrs/
icrpages/
1789ss02.
htm).

4
Federal
Energy
Regulatory
Commission
(
FERC)
Form
2
­
Major
Natural
Gas
Pipeline
Annual
Report
Historical
Data
(
http://
www.
ferc.
gov/
docs­
filing/
eforms/
form­
2/
data/
historical.
asp).

5
FERC
Form
2A
­
Non­
major
Natural
Gas
Pipeline
Annual
Report
Historical
Data
(
http://
www.
ferc.
gov/
docs­
filing/
eforms/
form­
2a/
data/
historical.
asp).

6
FERC
Form
2/
2A
­
Major
and
Non­
major
Natural
Gas
Pipeline
Annual
Report
Data
(
http://
www.
ferc.
gov/
docs­
filing/
eforms/
form­
2/
data.
asp).
$
5,035.

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

Managerial
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Technical
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2005
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH),
attached.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
on
average
over
the
next
three
years,
approximately
21
existing
respondents
will
be
subject
to
the
standard.
It
is
estimated
that
an
additional
two
respondents
per
year
will
become
subject.
An
additional
807
existing
respondents
keep
records
but
do
not
submit
reports.
The
overall
average
number
of
respondents,
as
shown
in
the
table
below,
is
830
per
year.

At
the
time
of
rulemaking,
EPA
estimated
the
source
category
consisted
of
814
facilities,
assuming
one
glycol
dehydration
unit
per
facility,
and
expected
seven
of
these
facilities
would
be
subject
to
the
NESHAP.
2,3
EPA
based
these
estimates
on
surveys
from
114
glycol
dehydration
units
at
facilities
in
the
source
category,
and
on
a
US
annual
natural
gas
transmission
throughput
of
approximately
31.31
trillion
cubic
feet
(
Tcf).
4,5
The
US
annual
natural
gas
transmission
throughput
for
2003,
the
most
recent
year
for
which
data
are
available,
was
approximately
31.79
Tcf,
an
increase
of
1.5
percent
since
1996
(
31.79
/
31.31
=
1.015).
6
Therefore,
EPA
estimates
that
the
source
category
now
consists
of
approximately
826
facilities
(
814
x
1.015
=
826).
Based
on
a
search
of
EPA's
OTIS
database
14
7
MACT
Prioritization
Tool
(
http://
www.
epa.
gov/
idea/
mact/).
using
the
MACT
Prioritization
Tool,
EPA
estimates
there
are
currently
19
existing
major
sources
that
are
subject
to
the
NESHAP.
7
EPA
assumes
as
an
upper
bound
that
the
other
807
existing
facilities
in
the
source
category
are
exempt
facilities
under
40
CFR
63.1270(
f),
which
must
maintain
records
of
their
applicability
determination
as
required
in
40
CFR
63.10(
b)(
3).
Some
of
these
807
facilities
may
be
area
sources,
which
are
not
required
to
maintain
records
under
the
NESHAP.
EPA
does
not
have
the
data
to
quantify
how
many
of
these
facilities
are
area
sources,
and
therefore,
assumes
that
all
807
are
major
sources
exempt
under
40
CFR
63.1270(
f).

EPA's
current
estimate
for
the
number
of
facilities
in
the
source
category
is
12
facilities
higher
than
the
estimate
at
the
time
of
rulemaking
(
826
­
814
=
12).
Dividing
by
seven
years
(
2003
­
1996
=
7),
EPA
estimates
there
are
approximately
two
new
facilities
per
year
in
the
source
category
(
12
/
7
=
2).
Similarly,
EPA's
estimate
of
the
number
of
subject
facilities
also
increased
by
12
facilities
(
19
­
7
=
12).
Dividing
by
seven
years
(
2005
­
1998
=
7),
EPA
estimates
there
are
approximately
two
new
subject
facilities
per
year
(
12
/
7
=
2).
Based
on
these
estimates,
both
of
the
two
new
facilities
per
year
in
the
source
category
are
also
subject
to
the
NESHAP.

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
(
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+
C­
D)

1
2
19
807
0
828
2
2
21
807
0
830
3
2
23
807
0
832
Average
2
21
807
0
830
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
830.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.
15
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
Notification
of
intent
to
construct
or
reconstruct
2
1
N/
A
2
Notification
of
actual
date
of
startup
2
1
N/
A
2
Notification
of
date
of
continuous
monitoring
system
performance
evaluation
2
1
N/
A
2
Notification
of
planned
date
of
performance
test
2
1
N/
A
2
Notification
of
Compliance
Status
Report
2
1
N/
A
2
Semiannual
Reports
21
2
N/
A
42
Total
52
The
number
of
Total
Annual
Responses
is
52.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
61,087.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH),
attached.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entities
are
$
0.
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.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
124
labor
hours
at
a
cost
of
$
5,035.
See
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH),
attached.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
16
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
61,087.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH),
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
15
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
0.
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
124
labor
hours
at
a
cost
of
$
5,035.
See
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Natural
Gas
Transmission
and
Storage
(
40
CFR
part
63,
subpart
HHH),
attached.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
four
adjustments.
Two
adjustments
contributed
increases
in
burden
and
two
adjustments
contributed
decreases
in
burden,
for
a
net
increase
in
burden.

The
first
and
second
adjustments
result
from
changes
in
the
calculations
for
labor
burden
and
cost.
The
first
adjustment
contributed
an
increase
in
burden
due
to
the
increase
in
labor
rates.
Industry
labor
rates
increased
by
an
average
of
31.6
percent
from
the
active
ICR,
while
the
Agency
labor
rates
increased
by
12.4
percent
from
the
active
ICR.
The
second
adjustment
contributed
an
increase
in
burden
by
calculating
both
the
industry
and
Agency
technical
labor
hours
at
a
higher
level
relative
to
total
labor
hours
than
in
the
active
ICR.

The
third
adjustment
contributed
a
decrease
in
the
industry
burden
due
to
the
removal
of
activities
that
are
required
to
comply
with
the
NESHAP,
not
to
show
compliance
with
the
NESHAP.
These
activities
included
leak
monitoring,
control
device
design,
and
CMS
operating
and
maintenance.

The
fourth
adjustment
contributed
a
decrease
in
the
Agency
burden
due
to
the
removal
of
activities
associated
with
compliance
inspections
and
enforcement
actions.
These
activities
are
17
included
in
EPA's
overall
compliance
and
enforcement
program.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
15
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
0037,
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
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
0037
and
OMB
Control
Number
2060­
0418
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
Table
1.
Annual
Respondent
Burden
and
Cost,

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

18
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent/

Yr.
(
C)
Hours/
Respondent/

Yr.

[
C=
AxB]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E=
CxD]
(
F)
Management
Hours/
Yr.

[
F=
0.05xE]
(
G)
Clerical
Hours/
Yr.

[
G=
0.1xE]
(
H)
1
Total
Labor
Costs/
Yr.

($)

1.
Applications
Not
applicable
2.
Survey
and
Studies
Not
applicable
3.
Reporting
Requirements
a.
Read
instructions
2
1
2
21
42
2
4
3,899
b.
Required
activities
Not
applicable
c.
Create
information
Not
applicable
d.
Gather
existing
information
4
1
4
21
84
4
8
7,798
e.
Write
reports
i.
Notification
of
construction/

reconstruction
2
1
2
2
4
0.2
0.4
371
ii.
Notification
of
actual
startup
2
1
2
2
4
0.2
0.4
371
iii.
Notification
of
date
of
CMS
performance
evaluation
2
1
2
2
4
0.2
0.4
371
iv.
Notification
of
planned
date
of
performance
test
2
1
2
2
4
0.2
0.4
371
v.
Notification
of
Compliance
Status
Report
2
1
2
2
4
0.2
0.4
371
vi.
Startup/
shutdown/

malfunction
reports2
2
2
4
21
84
4
8
7,798
vii.
Semiannual
Periodic
Report
2
2
4
21
84
4
8
7,798
4.
Recordkeeping
Requirements
a.
Read
instructions
See
3a
b.
Plan
activities
4
1
4
2
8
0.4
0.8
743
c.
Implement
activities
Not
applicable
d.
Develop
record
system
i.
Control
equipment
4
1
4
2
8
0.4
0.8
743
Table
1.
Annual
Respondent
Burden
and
Cost,

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

19
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent/

Yr.
(
C)
Hours/
Respondent/

Yr.

[
C=
AxB]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E=
CxD]
(
F)
Management
Hours/
Yr.

[
F=
0.05xE]
(
G)
Clerical
Hours/
Yr.

[
G=
0.1xE]
(
H)
1
Total
Labor
Costs/
Yr.

($)

ii.
Startup/
shutdown/
malfunction
plan
12
1
12
2
24
1
2
2,228
e.
Enter
information
i.
Control
device
design
4
1
4
2
8
0.4
0.8
743
ii.
Control
equipment
testing
1
1
1
2
2
0.1
0.2
186
iii.
Control
equipment
inspection
1
2
2
21
42
2
4
3,899
iv.
Control
equipment
monitoring
1
2
2
21
42
2
4
3,899
v.
Control
device
CMS
1
6
6
21
126
6
13
11,698
f.
Train
personnel
4
1
4
21
84
4
8
7,798
g.
Perform
audits
Not
applicable
h.
Retain
records
of
actual
throughput
(
facilities
exempt
under
63.1270(
f))
3
Not
applicable
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
757
$
61,087
1.
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
83.71)
+
(
Management
hours
x
$
97.46)
+

(
Clerical
hours
x
$
42.55)].

2.
Startup/
shutdown/
malfunction
reports
may
be
included
in
the
semiannual
periodic
reports.

3.
Respondents
are
expected
to
maintain
records
of
actual
throughput
as
a
standard
business
practice;
therefore,
there
is
no
additional
burden
associated
with
these
records
under
this
rule.
Table
2:
Annual
Agency
Burden
and
Cost,

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

20
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent/

Yr.
(
C)
Hours/
Respondent/

Yr.

[
C=
AxB]
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E=
CxD]
(
F)
Management
Hours/
Yr.

[
F=
0.05xE]
(
G)
Clerical
Hours/
Yr.

[
G=
0.1xE]
(
H)
1
Total
Labor
Costs/
Yr.

($)

1.
Review
reports
a.
Initial
notification
2
1
2
2
4
0.2
0.4
186
b.
Preconstruction
review
application
4
1
4
2
8
0.4
0.8
373
c.
Performance
test
notification
2
1
2
2
4
0.2
0.4
186
d.
Compliance
status
notification
4
1
4
2
8
0.4
0.8
373
e.
Semiannual
periodic
reports2
2
2
4
21
84
4
8
3,916
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
124
$
5,035
1.
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
41.57)
+
(
Management
hours
x
$
56.02)
+

(
Clerical
hours
x
$
22.50)].

2.
Startup/
shutdown/
malfunction
reports
may
be
included
in
the
semiannual
periodic
reports.
