1789ss11

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), EPA ICR Number 1789.11, OMB Control Number 2060-0418.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) were proposed on February 6, 1998; promulgated on June 17, 1999; amended on August 16, 2012; and most-recently amended on November 19, 2020¹. These regulations apply to existing facilities and new facilities that are major sources of hazardous air pollutants (HAP) and that either 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 containing these documents and retain the file for at least five years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional offices.

There are approximately 67 facilities, which are owned and operated by the natural gas industry. None of the 67 facilities in the United States are owned by either state, local, tribal or the Federal government². They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries.

Based on our consultations with industry representatives, there are an average of one affected facility at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 67 respondents per year will be subject to these standards, and 6 additional respondents per year will become subject to these same standards. The overall average number of respondents is 73 per year.

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 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 either 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 either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/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 these standards ensure compliance with the applicable regulations which were 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 these emission standards. Continuous emission monitors are used to ensure compliance with these standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in the standards are used to inform the Agency or its 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 and leaks are being detected and repaired and that the standards are 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.

The EPA is requiring that owners or operators of affected sources would submit electronic copies of notifications required in 40 CFR 63.9(b) and 63.9(j) and performance test reports required in 40 CFR 63.1285(g) through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI). For the notifications required in 40 CFR 63.9(b) and 63.9(j), owners and operators would be required to upload a PDF of the required notifications.

CEDRI includes the Electronic Reporting Tool (ERT) software, which is used by facilities to generate electronic reports of performance tests. The EPA is also requiring that 40 CFR part 63, Subpart HHH performance test reports be submitted through the EPA’s ERT.

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

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart HHH.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist.

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 (86 FR 8634) on February 8, 2021. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts, including a review of EPA’s ECHO, GHGRP, and data from related rulemakings. Approximately 73 respondents will be subject to these standards over the three-year period covered by this ICR. This ICR reflects an increase in the number of respondents based on review of data in EPA’s ECHO and collected as part of recent rulemakings and is also due to growth within the industry.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and that these standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted the American Gas Association, at (202) 824-7000, and Dominion Energy, at (866) 366-4357. The EPA did not receive comments about the estimated range of the number of affected sources; therefore, the EPA maintained the same industry growth rate cited in the previous ICR renewal.

3(d) Effects of Less-Frequent Collection

Less-frequent information collection would decrease the margin of assurance that facilities are continuing to meet these 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.

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 these 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. The retention of records for five years allows the EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. The EPA has found that the most flagrant violators have violations extending beyond five years. In addition, the EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.

3(f) Confidentiality

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

3(g) Sensitive Questions

The reporting or recordkeeping requirements in these standards do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are natural gas transmission and storage facilities. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards and the corresponding North American Industry Classification System (NAICS) are listed below:

Standard (40 CFR Part 63, Subpart HHH)	SIC Codes	NAICS Codes
Pipeline Transportation of Natural Gas	4922	48621
Natural Gas Distribution	4923	221210, 48621

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH).

A source must make the following reports:

Notifications
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 (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), 63.1283(c)(2)(ii)(A), 63.1285(b)(4), 63.1274(a), 63.1285(d)(1) through (d)(12)
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), 63.1285(g)
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)(1) and (d)(4)(i) through (d)(4)(iv)
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)
Combustion control device parameters and fuel analysis results (submit with Notification of Compliance Status Report).	§§63.1282(g)(8), 63.1285(d)(11) and (12)
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(b)(4)(i), 63.1274(a)
Notification of actual date of startup.	§§63.9(b)(4)(v), 63.9(b)(5)(ii), 63.1274(a)
Notification of special compliance requirements.	§§63.9(d), 63.1274(a)
Notification of reclassification to area source status or to revert back to major source status (electronic submission)	§§63.9(b), 63.9(j)

Reports
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)
Results of performance evaluation.	§§63.8(e)(5), 63.10(e), 63.1274(a)
Semiannual HAP summary report.	§§63.10(e)(3)(vi), 63.1274(a)

A source must keep the following records:

Recordkeeping
Records of flare design, compliance determination, and the times and duration of all periods during which pilot flames are absent.	§§63.1284(b)(4)(ii), 63.1284(e)
Records of the times and durations of all periods when the vent stream is diverted from the control device or the device is not operating.	§63.1284(b)(4)(iii)
Records of inspections of seals or closure mechanisms, records of duration of all periods when the seal mechanism is broken, the bypass line valve position has changed, or the key for a lock-and-key type lock has been checked out, and records of any car-seal that has broken.	§63.1284(b)(4)(iv)
Continuous monitoring system quality control program.	§§63.8(d), 63.1274(a)
Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control equipment and monitoring equipment.	§§63.10(b)(2), 63.1284(b)(2) and (f)
Records of monitoring system and 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 (b)(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 (b)(10)
Records of compliance with benzene emission limit (alternative standards).	§§63.1281(e)(2), 63.1284(c)
Throughput and emissions records of glycol dehydration units that are exempt from control requirements.	§§63.1274(c)(3), 63.1284(d)
Records of leak or defect detection, severity (maximum instrument reading), and date of repair.	§§63.1284(b)(7) and (b)(8)
Records of visible emission readings and flowrate calculations made during compliance determination and records of periods when pilot fame is absent.	§§63.1284(g)
The date the semi-annual maintenance inspection is performed and a list of any modifications or repairs made to the control device during the inspection and other maintenance performed.	§§63.1283(b), 63.1284(h)
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)

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.

The rule was amended to include electronic reporting provisions for performance test results on August 16, 2012. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts.

This rule was recently amended to include additional electronic reporting provisions on November 19, 2020. Respondents are required to use the EPA’s CEDRI to submit notification in the event of reclassification to area source status and to sources that revert back to major source status. The notification is a one-time notification already required in 40 CFR 63.9(j) in the case where the facility is notifying of a change in major source status, and is an upload of the currently required notification in portable document format (PDF) file. For purposes of this ICR, it is assumed that there is no additional burden associated with the requirement for respondents to submit the notifications and reports electronically. Electronic copies of records may also be maintained to satisfy federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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 collecting, validating, and verifying information.

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

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

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

Transmit, or otherwise disclose the information.

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

5(a) Agency Activities

The 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 Enforcement and Compliance History Online (ECHO) and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could 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 standards 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 reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. The 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. The Agency estimates that 49 percent of the parent companies affected by proposed action are small entities as defined by the U.S. Small Business Administration. 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 at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Natural Gas Transmission and Storage (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for 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 neither conduct nor 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 3,780 hours (Total Labor Hours from Table 1 below). 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 $149.84 ($71.35 + 110%)

Technical $122.66 ($58.41 + 110%)

Clerical $60.88 ($28.99 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

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

The only costs to the regulated industry resulting from information collection activities required by the subject standard(s) are labor costs. There are no capital/startup or operation and maintenance costs incurred in these standards, because the industry has primarily installed flares to control emissions.

(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.

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 such activities 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 $20,900.

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

Managerial $69.04 (GS-13, Step 5, $43.15 + 60%)

Technical $51.23 (GS-12, Step 1, $32.02 + 60%)

Clerical $27.73 (GS-6, Step 3, $17.33 + 60%)

These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 67 existing respondents will be subject to these standards. It is estimated that an additional 6 respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 73 per year.

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

Number of Respondents
	Respondents That Submit Reports		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 2	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D) 3
1	6	61	N/A	0	67
2	6	67	N/A	0	73
3	6	73	N/A	0	79
Average	6	67	N/A	0	73

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

² Column C does not apply as there are no existing respondents that are required to keep records only on an annual basis since major source determination is a one-time activity to determine rule applicability.

³ The previous (currently approved) ICR expires on 10/31/2021. Therefore, Year 1 of this ICR renewal corresponds to November 2021 through October 2022.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 73.

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 construction/ reconstruction	6	1	N/A	6
Notification of actual startup	6	1	N/A	6
Notification of date of CMS performance evaluation	6	1	N/A	6
Notification of planned date of performance test	6	1	N/A	6
Notification of compliance status report1	6	1	N/A	6
Semiannual Periodic Report	73	2	N/A	146
			Total	176

¹ Performance test reports are submitted with the Notification of Compliance Status and must be developed using EPA’s Electronic Reporting Tool (ERT) and submitted through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI).

The number of Total Annual Responses is 176.

The total annual labor costs are $448,000 (rounded). Details regarding these estimates may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

(i) Respondent Tally

The total annual labor hours are 3,780 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks, because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks, because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 21 hours per response.

There are no capital/startup or operation and maintenance costs to the regulated entity. See 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 419 labor hours at a cost of $20,900; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks, because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks, because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in the total estimated burden from the most-recently approved ICR as currently identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes. This increase is due to an increase in the number of affected sources subject to the rule based on the latest available data and taking into account growth in this industry. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts, including a review of EPA’s ECHO, GHGRP, and data from related rulemakings. There are no capital/startup or operation and maintenance costs incurred as a result of these standards, because the industry has primarily installed flares to control emissions. There is also an increase in costs, which is due to the increase in the number of affected sources and the use of updated labor rates. This ICR uses labor rates from the most recent U.S. Bureau of Labor Statistics report (September 2020) to calculate respondent burden costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 21 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2020-0623. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2020-0623 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) (Renewal)

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirementsc	2	1	2	73	146	7.3	14.6	$19,891.04
B. Required activities	N/A
C. Create information	N/A
D. Gather existing information	4	1	4	73	292	14.6	29.2	$39,782.08
E. Write Report
i. Notification of construction/ reconstructiond	2	1	2	6	12	0.6	1.2	$1,634.88
ii. Notification of actual startupd	2	1	2	6	12	0.6	1.2	$1,634.88
iii. Notification of date of CMS performance evaluationd	2	1	2	6	12	0.6	1.2	$1,634.88
iv. Notification of planned date of performance testd	2	1	2	6	12	0.6	1.2	$1,634.88
v. Notification of compliance status reportd	4	1	4	6	24	1.2	2.4	$3,269.76
vi. Semiannual Periodic Report	4	2	8	73	584	29.2	58.4	$79,564.16
Subtotal for Reporting Requirements					1258			$149,046.56
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activitiesd	16	1	16	6	96	4.8	9.6	$13,079.04
C. Implement activities	N/A
D. Develop record system
i. Control equipmentd	4	1	4	6	24	1.2	2.4	$3,269.76
E. Time to enter information
i. Control device designd	4	1	4	6	24	1.2	2.4	$3,269.76
ii. Control equipment testingd	1	1	1	6	6	0.3	0.6	$817.44
iii. Control equipment inspection	8	2	16	73	1168	58.4	116.8	$159,128.32
iv. Control equipment monitoring	1	2	2	73	146	7.3	14.6	$19,891.04
v. Control device CMS	1	6	6	73	438	21.9	43.8	$59,673.12
F. Time to train personnel	4	1	4	73	292	14.6	29.2	$39,782.08
G. Perform Audits	N/A
H. Retain records of actual throughput (facilities exempt under 63.1270(f)e	N/A
Subtotal for Recordkeeping Requirements					2,523			$298,910.56
TOTAL LABOR BURDEN AND COST (rounded)f					3,780			$448,000
TOTAL CAPITAL AND O&M COST (rounded)f								$0
GRAND TOTAL (rounded)f								$448,000
Assumptions:
a We have assumed that there are approximately 67 respondents subject to the rule, on average over the three-year period. It is estimated that 6 additional new or reconstructed sources becoming subject to the rule annually over the next three years, for a total of 73 respondents.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, 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 It is estimated that each source will familiarize themselves with the rule requirements each year.
d One-time requirement for the 6 new or reconstructed sources. Performance test reports are submitted with the Notification of Compliance Status and must be developed using EPA’s Electronic Reporting Tool (ERT) and submitted through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI).
e Respondents are expected to maintain records of actual annual throughput as a standard business practice; therefore, there is no additional burden associated with these records under this rule.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal)

Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Review reports
a. Initial notification	2	1	2	6	12	0.6	1.2	$689.46
b. Preconstruction review application	4	1	4	6	24	1.2	2.4	$1,378.92
c. Performance test notification	2	1	2	6	12	0.6	1.2	$689.46
d. Compliance status notification	4	1	4	6	24	1.2	2.4	$1,378.92
e. Semiannual periodic reports	2	2	4	73	292	14.6	29.2	$16,776.86
TOTAL ANNUAL BURDEN AND COSTc					419			$20,900
Assumptions:
a We have assumed that there are approximately 67 respondents subject to the rule, on average over the three year period. It is estimated that 6 additional new or reconstructed sources becoming subject to the rule annually over the next three years, for a total of 73 respondents.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 for Managerial, $51.23 for Technical, and $27.73 for Clerical. These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

1 The most recent amendments (85 FR 73854) include notification and recordkeeping requirements that apply to sources choosing to reclassify to area source status and to sources that revert back to major source status, including a requirement for electronic notification.

2 Although there may be potential facilities owned by tribal governments, we did not identify these facilities in our review of available data. Further, per the 2012 final rule (77 FR 49490), the EPA concluded that the NESHAP does not impose a significant cost to the tribal government.