SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NSPS for Onshore Natural Gas Processing Plants

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
volatile organic compound (VOC) from Onshore Natural Gas Processing
Plants, published at 40 CFR part 60, subpart KKK, were proposed on
January 20, 1984 and promulgated on June 24, 1985.  These standards
apply to the following affected facilities located at onshore natural
gas processing plants: compressors in 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: SO2 Emissions, published at 40 CFR part 60, subpart LLL,
were proposed on January 20, 1984 and promulgated on October 1, 1985. 
These standards apply to the following affected facilities located at
onshore natural gas processing plants: each sweetening unit, and each
sweetening unit followed by a sulfur recovery unit.  Affected facilities
commenced construction, modification or reconstruction after the date of
proposal.  A sweetening unit is defined as a process device that
separates the hydrogen sulfide and carbon dioxide (CO2) contents from
the sour natural gas stream.  The provisions of subpart LLL do not apply
to sweetening facilities that produce acid gas that is completely
re-injected into oil or gas bearing geologic strata or that is otherwise
not released to the atmosphere.  The control and monitoring requirements
of subpart LLL do not apply to affected facilities with design
capacities of less than two long tons per day of hydrogen sulfide in the
acid gas, expressed as sulfur.

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

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

All of these sources subject to subpart LLL are also subject to subpart
KKK.  Over the next three years, an average of 563 sources per year will
be subject to subpart KKK, and it is estimated that one additional
source per year will become subject to the standard in the next three
years.  There are approximately 79 of these sources of these that are
currently subject to subpart LLL, and it is estimated that three
additional sources will become subject to the standard in the next three
years.

There are approximately 563 onshore natural gas processing plants in the
United States, which are all publicly owned and operated by the onshore
natural gas processing industry.  None of the 563 plants in the United
States are owned by either state, local, tribal or the Federal
Government.  They are all owned and operated solely by privately owned
for-profit businesses.  You can find the burden to the “Affected
Public” listed below in Table 1: Annual Industry Burden and Cost -
NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts
KKK and LLL).  The Federal government burden does not include work
performed by Federal employees only work performed by contractors, which
could be found listed below in Table 2: Average Annual EPA Burden - NSPS
for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subparts KKK
and LLL).

The Office of Management and Budget (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 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

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

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

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

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

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

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the 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 tests, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

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

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

3.  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 their 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 (72 FR 10736) on March 9, 2007. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

Over the next three years, an average of 563 facilities per year will be
subject to the standard.  In estimating the affected number of sources
and the growth rate of onshore natural gas processing plants subject to
this standard, EPA contacted Ms. Lynn Reed at (918) 588-7380, ONEOK,
Incorporated, Mr. Lance Lodes at (405) 557-6846, OGE-Enogex,
Incorporated, and Mr. Johnny Dreyer, (918) 493-3872, Gas Processors
Association (GPA).  We referenced the most recent data available.  We
reviewed information available from the Online Tracking Information
System (OTIS) which is the primary source of information regarding the
number of existing sources.  OTIS data was used in conjunction with
industry consultation to verify the number of sources and the industry
growth rate.

3(d)  Effects of Less Frequent Collection

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

3(e)  General Guidelines

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

 	

3(f)  Confidentiality

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

3(g)  Sensitive Questions

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
stationary gas turbines.  The United States Standard Industrial
Classification (SIC) codes which correspond to the North American
Industry Classification System (NAICS) code could be found in the
following table:

40 CFR part 60, subparts KKK and LLL	SIC Codes	NAICS Codes

Crude Petroleum and Natural Gas Extraction	1311	211111

Natural Gas Liquid Extraction	1321	211112



4(b)  Information Requested

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

(i)  Data Items

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

A source must make the following reports:

Notifications

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 of initial performance test	60.8(d)

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

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

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

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



A source must keep the following records:

Recordkeeping 

Maintain records of startups, shutdowns, malfunctions of affected
facilities; malfunctions of control devices; and periods where the
continuous monitoring system is inoperative.	60.7(b)

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

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

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

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

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

60.486(c)

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

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

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

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

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

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

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

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



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a plant site.

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

Respondent Activities

Read instructions.

Write the notification and reports listed above.

Enter information required to be recorded above.

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

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

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

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

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

Transmit, or otherwise disclose the information.

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

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

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

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

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

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

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

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

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

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

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

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

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

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



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way e.g., continuous parameter monitoring
system.  Although personnel at the source still need to evaluate the
data, this type of monitoring equipment has significantly reduced the
burden associated with monitoring and recordkeeping.

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

5(a)  Agency Activities

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

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

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

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (OTIS).



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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  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 OTIS which is
operated and maintained by the EPA Office of Compliance.  OTIS is an EPA
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses OTIS 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 or
operator for two years.

5(c)  Small Entity Flexibility

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

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden, NSPS for
Onshore Natural Gas Processing Plants (40 CFR part 60, subparts KKK and
LLL).

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.  Wherever appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

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

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be
149,180 (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 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 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 standard are labor costs. 
The type of industry costs associated with the information collection
activities in the subject standard are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent 1 	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost,  (B X C)	(E)

Annual O&M Costs for One Respondent 1 	(F)

Number of Respondents with O&M 2	(G)

Total O&M,

(E X F)

SO2 CEM, control outlet only for subpart LLL	$73,000 	3	$219,000	$17,100
7	$119,700

    1   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.

    2   After consultation with the industry we believe that the number
of respondents needing continuous monitoring is seven.  

The total capital/startup costs for this ICR are $219,000.  This is the
total of column D in the above table. 

The total operation and maintenance (O&M) costs for this ICR are
$119,700.  This is the total of column G. 

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.

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.

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 2: Average Annual EPA
Burden, NSPS for Onshore Natural Gas Processing Plants (40 CFR part 60,
subparts KKK and LLL), below.

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 563 existing respondents will be subject to the
standard.  It is estimated that one additional respondent will become
subject to subpart KKK and three for subpart LLL over the next three
years.

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

Number of Respondents

Year	(A)

Number of 1 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)

Subpart KKK 2





	1	113	561	0	112	562

2	113	562	0	112	563

3	113	563	0	112	564

Average	113	562	0	112	563

Subpart LLL 3





	1	3	79	3 	0	85

2	3	82	3	0	88

3	3	85	3	0	91

Average	3	82	3	0	88

1 New respondent include sources with constructed, reconstructed and
modified affected facilities.  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.

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.  Three
respondents have sources 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 and also subject to
subpart KKK).

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses

E=(BxC)+D

Subpart KKK





Notification of construction/reconstruction 	57	1	n/a	57

Notification of modification 	56	1	n/a	56

Notification of anticipated startup	113	1	n/a	113

Notification of actual startup	113	1	n/a	113

Notification of demonstration of continuous monitoring system	0	1	n/a	0

Notification of initial performance tests	0	1	n/a	0

Semiannual reports	563	2	n/a	1,126

Subpart LLL





Notification of construction/reconstruction	1.5	1	n/a	1.5

Notification of anticipated startup	3	1	n/a	3

Notification of actual startup	3	1	n/a	3

Notification of initial performance test	3	1	n/a	3

Notification of CMS demonstration	3	1	n/a	3

CMS demonstration report	3	0.2	n/a	0.6

Semiannual report	82	2	n/a	164



	Total (rounded)	1,643



The number of total respondents is 563.

The number of Total Annual Responses is 1,643.  This is the number in
column E of the Respondent Universe and Number of Responses per year in
table above.

The total annual labor costs are $9,518,358.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden, NSPS for
Onshore Natural Gas Processing Plants (40 CFR part 60, subparts KKK and
LLL), below.

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 1 and 2, respectively,
and summarized below. 

(i) Respondent Tally

The total annual labor costs are $9,518,358.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NSPS for Onshore Natural Gas Processing Plants (40 CFR part 60, subparts
KKK and LLL), below.  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 cost to the regulated entity
are $338,700.

(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 2.
Annual Agency Burden and Cost: NSPS for Onshore Natural Gas Processing
Plants (40 CFR part 60, subparts KKK and LLL), below.

6(f)  Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the
previous ICR.  This is due to two considerations.  First, the
regulations have not changed over the past three years and are not
anticipated to change over the next three years.  Secondly, the growth
rate for the industry is very low, negative or non-existent, so there is
not significant change to the overall labor hours.

There is however, an adjustment in the labor hour estimate.  The
previous ICR shows a total of 149,174 annual hours.  This renewal ICR
shows a total of 149,180 annual hours.  The small labor hour increase of
six hours was caused by a mathematical error in the previous ICR.

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
EPA-HQ-OECA-2007-0047.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the content of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search” than key in the
docket ID number identified in this document.  The documents are also
available for public viewing at the Enforcement and Compliance Docket
and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Avenue, N.W., 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 Docket is (202)
566-1752.  Also, you can send comments to the Office of Information and
Regulatory Affairs, Office of Management and Budget, 725 17th Street,
N.W., Washington, DC 20503, Attention: Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2007-0047 and OMB Control
Number 2060-0120 in any correspondence.

Part B of the Supporting Statement

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

Table 1:  Annual Respondent Burden and Cost – NSPS for Onshore
Natural Gas Processing Plants (40 CFR part 60, subparts KKK and LLL)

 	(A)	(B)	(C)	(D)	(E)	(F)	(G)	 (H) 

 Burden item 	Person- hours per occurrence	No. of occurrences per
respondent per year	Person- hours per respondent per year (C=AxB)
Respondents per year (a)	Technical person- hours per year (E=CxD)
Management person-hours per year (Ex0.05)

	Clerical person-hours per year 

(Ex0.1)

	Cost ($) (b) 

1. Applications	N/A	 	 	 	 

	  

2. Survey and Studies	N/A	 	 	 	 

	  

3. Reporting requirements	 	 	 	 	 

	  

    A.  Read instructions









         Subpart KKK	1	1	1	563	563	28.2	56.3	$41,315

         Subpart LLL	1	1	1	82	82	4.1	8.2	$6,017

    B.  Required activities









    Subpart KKK









     Notification of construction/

     reconstruction c                             	2	1	2	57	114	5.7	11.4
$8,365

         Notification of modification c	8	1	8	56	448	22.4	44.8	$32,872

         Notification of anticipated startup d	2	1	2	113	226	11.3	22.6
$16,583

         Notification of actual startup d	2	1	2	113	226	11.3	22.6
$16,583

         Notification of electing to comply with

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

         Notification of initial performance test f	2	1	2	0	0	0	0	$0

         Semiannual reports g	8	2	16	563	9,008	450.4	900.8	$660,962

    Subpart LLL









         Initial performance test	60	1	60	3	180	9	18	$13,208

        Repeat performance test	60	0.2	12	3	36	1.8	3.6	$2,642

        Demonstration of CEMS	80	0.2	16	3	48	2.4	4.8	$3,522

        Repeat Demonstration of CEMS	80	0.2	16	3	48	2.4	4.8	$3,522

    C.  Create Information









    Subpart KKK









         Initial performance test	N/A







	    Subpart LLL	See 3B







	     D.  Gather existing information 









         Subpart KKK	N/A







	         Subpart LLL	See 3B







	     D.  Gather existing information	See 3B







	     E.   Write report  









         Subpart KKK 	See 3B







	         Subpart LLL









         Notification of construction/

         reconstruction c          	2	1	2	1.5	3	0.15	0.3	$220

         Notification of modification	N/A







	         Notification of anticipated startup h	2	1	2	3	6	0.3	0.6	$440

 Notification of actual startup h	2	1	2	3	6	0.3	0.6	$440

 Notification of initial performance test h	2	1	2	3	6	0.3	0.6	$440

 Notification of CMS demonstration h                               	2	1
2	3	6	0.3	0.6	$440

 CMS demonstration                                                      
                    	See 3B







	 Semiannual report i	40	2	80	82	6,560	328	656	$481,340

4.  Recordkeeping requirements









  A.  Read instructions









       Subpart KKK	See 4C







	       Subpart LLL	See 3A







	      B.  Plan activities	See 3E





	  

           Subpart KKK	See 4C







	           Subpart LLL	N/A







	      C.  Implement activities	See 3E





	  

           Subpart KKK









           Filing and maintaining records j	80	1	80	563	45,040	2,252
4,504	$3,304,810

           Startup, shutdown, or malfunction k	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

           Subpart LLL	N/A







	  D.  Develop record system 







  

       Subpart KKK	See 4C







	       Subpart LLL l	40	1	40	3	120	6	12	$8,805

      E.  Time to enter information









           Subpart KKK	See 4C







	          Subpart LLL









          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









          Subpart KKK	See 4C







	          Subpart LLL	N/A







	     G.  Audits









      Subpart KKK	N/A







	      Subpart LLL	N/A







	Subtotal



	129,722	6,486.15	12,972.2	$9,518,358

TOTAL ANNUAL BURDEN AND COST (rounded)





149,180

  $9,518,358



Assumptions:

a.  We have assumed that the average number of respondents that will be
subject to subpart KKK will be 563 with one new source becoming subject
to the rule over the three-year period of this ICR.  It is also assumed
that the overage number of respondents that will be subject to subpart
LLL will be 82 with one additional source becoming subject to the rule
over the three-year period of this ICR.

b.  This ICR uses the following labor rates: $95.32 per hour for
Executive, Administrative, and Managerial labor; $64.60 per hour for
Technical labor, and $40.09 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December 2003, “Table 2.  Civilian Workers, by
occupational and industry group.” The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

c.  We have assumed that one-half of new facilities are the result of
construction or reconstruction, while the other half are the result of
modifications of existing facilities.

d.  We have assumed that 20 percent of existing respondents will
construct one new facility per year.

e.  We have assumed that no respondent is expected to use the
alternative standards.

f.   We have assumed that while this subpart includes the option of
using closed vent systems and control devices to demonstrate compliance,
no respondent is expected to use this option.  Therefore, no respondent
is expected to submit the associated notifications and reports.

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

h.  We have assumed that each respondent will take two hours to complete
reports.

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

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

k.  We have assumed that 20 percent of respondents will take 80 hours to
implement this activity.

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







Table 2:  Average Annual EPA Burden – NSPS for Onshore Natural Gas
Processing Plants (40 CFR part 60, subparts KKK and LLL)

 	(A)	(B)	(C)	(D)	(E)	(F)	(G)	 (H) 

Activity 	EPA person- hours per occurrence	No. of occurrences per plant 

per year	EPA person- hours per plant per year (C=AxB)	Plants per year
(a)	Technical person- hours per year (E=CxD)	Management person-hours per
year (Ex0.05)

	Clerical person-hours per year 

(Ex0.1)

	Cost ($) (b) 

Subpart KKK

 	 	 	 

	  

     Notification of construction/

     reconstruction c	2	1	2	56	112	5.6	11.2	$5,095

     Review notification of modification c	2	1	2	56	112	5.6	11.2	$5,095

     Review notification of anticipated

     startup d	2	1	2	112	224	11.2	22.4	$10,189

     Review notification of actual startup d	2	1	2	112	224	11.2	22.4
$10,189

     Notification of demonstration of CEMS	2	1	2	0	0	0	0	$0

     Review initial CEMS demonstration

     report	2	1	2	0	0	0	0	$0

     Review notification of performance

     test	2	1	2	0	0	0	0	$0

     Review results of performance test	2	1	2	0	0	0	0	$0

 Review semiannual reports e                           	8	2	16	563	9,008
450.4	900.8	$409,756

Subpart LLL









    Review notification of construction/

    reconstruction f	2	1	2	1.5	3	0.15	0.3	$137

    Review notification of modification f	2	1	2	1.5	3	0.15	0.3	$137

    Review notification of anticipated

    startup g	2	1	2	3	6	0.3	0.6	$273

    Review notification of actual startup g	2	1	2	3	6	0.3	0.6	$273

    Review notification of demonstration of

    CEMS g	2	1	2	3	6	0.3	0.6	$273

    Review of CEMS demonstration report g	2	1	2	3	6	0.3	0.6	$273

    Review notification of initial 

    performance test g	2	1	2	3	6	0.3	0.6	$273

    Review of semiannual reports e	8	2	16	82	1,312	65.6	131.2	$59.680

Review results of performance test	2	1	2	3	6	0.3	0.6	$273

TOTAL ANNUAL BURDEN AND COST (rounded)





12,689

$501,916



Assumptions:

a.  We have assumed that the average number of respondents that will be
subject to subpart KKK will be 563 with one new source becoming subject
to the rule over the three-year period of this ICR.  It is also assumed
that the average number of respondents that will be subject to subpart
LLL will be 82 with one additional source becoming subject to the rule
over the three-year period of this ICR.

b.  The cost is based on the following labor rate which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses.  Managerial rates of $54.66 (GS-13, Step 5, $34.16x1.6),
Technical rate of $40.56 (GS-12, Step 1, $25.35 x 1.6), and Clerical
rate of $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.

c.  We have assumed that one-half of new facilities are the result of
construction or reconstruction, while the other half are the result of
modifications of existing facilities.

d. We have assumed that 20 percent of respondents will each take two
hours to review notifications.

e.  We have assumed that it will take each respondent eight hours two
time per year to review semiannual reports.

f.  We have assumed that one-half of new respondents will review
notification of construction/reconstruction and the other half will
review notification of modification.

g.  We have assumed that each of the new respondents will take two hour
to review notification.





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