Burden Tables

---

Overview

Summary
Table 1a
Table 1b
Table 2a
Table 2b
Capital O&M
Responses
Respondents

---

Sheet 1: Summary

ICR Summary Information
Hours per Response	93
Number of Respondents	305
Total Estimated Burden Hours	56,900
Total Estimated Costs	$7,260,000
Annualized Capital O&M	$97,001
Total Annual Responses	610
Form Number	Not Applicable

---

Sheet 2: Table 1a

Table 1a: Annual Respondent Burden and Cost - NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subpart KKK) (Renewal)
Burden Item	(A) Person- hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person- hours per respondent per year (AxB)	(D) Respondents per yeara	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Managerial	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarization with Regulatory Requirements	1	1	1	291	291	15	29	$42,197.76		Clerical	$65.71
B. Required activities
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of modification	8	1	8	0	0	0	0	$0
Notification of anticipated startup c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of electing to comply with alternative standards for valves c	8	1	8	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Affirmative defense	30	1	30	0	0	0	0	$0
Semiannual reports d	8	2	16	291	4,656	232.8	465.6	$675,164.23
C. Create Information
Initial performance test c	N/A
D. Gather existing information	N/A
E. Write report	See 3B
Reporting Subtotal					5,689			$717,362
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	See 4C
B. Plan activities	See 4C
C. Implement activities	See 3E
Filing and maintaining records e	80	1	80	291	23,280	1164	2,328	$3,375,821.16
Startup, shutdown, or malfunction	80	1	80	0	0	0	0	$0
Recalibrate monitors	4	12	48	291	13,968	698	1,397	$2,025,492.70
Method 21 performance evaluation	2	2	4	291	1,164	58.2	116.4	$168,791.06
D. Develop record system	See 4C
E. Time to enter information	See 4C
F. Train personnel	See 4C
G. Audits	N/A
Recordkeeping Subtotal					44,174			$5,570,105
Total Labor Burden and Costs (Rounded) f					49,900			$6,290,000
Total Capital and O&M Costs (Rounded) f								$0
Grand Total (Rounded) f					49,900			$6,290,000
										93	hrs/response
Assumptions:
a We have assumed that the average number of existing respondents that will be subject to Subpart KKK will be 291. This estimated average accounts for modified facilities after August 2, 2016 subject to Subpart KKK that will become subject to 40 CFR Part 60, Subpart OOOOa and therefore, would no longer report under these rules.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c New respondents will be subject to 40 CFR Part 60, Subpart OOOOa.
d We have assumed that each existing respondent will take 8 hours, two times per year to write semiannual reports.
e We have assumed that each existing respondent will take 80 hours to file and maintain records.
f Totals are rounded to three significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: Table 1b

Table 1b: Annual Respondent Burden and Cost - NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subpart LLL) (Renewal)
Burden Item	(A) Person- hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person- hours per respondent per year (AxB)	(D) Respondents per yeara	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Managerial	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarization with Regulatory Requirements	1	1	1	14	14	0.7	1.4	$2,030.13		Clerical	$65.71
B. Required activities
Initial performance test c	60	1	60	0	0	0	0	$0
Repeat performance test	60	0.2	12	0	0	0	0	$0
Demonstration of CEMS	80	0.2	16	0	0	0	0	$0
Repeat Demonstration of CEMS	80	0.2	16	0	0	0	0	$0
C. Create Information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of modification c	2	1	2	0	0	0	0	$0
Notification of anticipated startup c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Notification of CMS demonstration c	2	1	2	0	0	0	0	$0
CMS demonstration	See 3B
Semiannual report d	40	2	80	14	1,120	56	112	$162,410.64
Reporting Subtotal					1,304			$164,441
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system e	40	1	40	0	0	0	0	$0
E. Time to enter information
Records of startup, shutdown, or malfunction	1.5	12	18	0	0	0	0	$0
Records of continuous recording	0.5	700	350	14	4,900	245	490	$710,546.55
Records of capacity data	2	1	2	3	6	0.3	0.6	$870.06
F. Train personnel	N/A
G. Audits	N/A
Recordkeeping Subtotal					5,642			$711,417
Total Labor Burden and Costs (Rounded) f					6,950			$876,000
Total Capital and O&M Costs (Rounded) f								$97,001
Grand Total (Rounded) f					6,950			$973,000
Assumptions:
a We have assumed that the average number of existing respondents that will be subject to subpart LLL will be 14. This estimated average accounts for modified facilities after August 2, 2016 subject to Subpart LLL that will become subject to 40 CFR Part 60, Subpart OOOOa and therefore, would no longer report under these rules.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c New respondents will be subject to 40 CFR Part 60, Subpart OOOOa.
d We have assumed that each existing respondent will take 40 hours, two times per year to write semiannual reports.
e We have assumed that each existing respondent will take 40 hours to develop record system. New respondents will be subject to 40 CFR Part 60, Subpart OOOOa recordkeeping requirements. However, Subpart LLL sources that have modified would need to track capacity data during the year it modified.
f Totals are rounded to three significant figures. Figures may not add exactly due to rounding.

---

Sheet 4: Table 2a

Table 2a: Average Annual EPA Burden and Cost - NSPS for Onshore Natural Gas Production (40 CFR Part 60, Subpart KKK) (Renewal)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost b
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0		Labor Rates
Review notification of modification c	2	1	2	0	0	0	0	$0		Managerial	$73.46
Review notification of anticipated startup c	2	1	2	0	0	0	0	$0		Technical	$54.51
Review notification of actual startup c	2	1	2	0	0	0	0	$0		Clerical	$29.50
Notification of demonstration of CEMS c	2	1	2	0	0	0	0	$0
Review initial CEMS demonstration report c	2	1	2	0	0	0	0	$0
Review notification of performance test c	2	1	2	0	0	0	0	$0
Review results of performance test c	2	1	2	0	0	0	0	$0
Review semiannual reports d	8	2	16	291	4,656	232.8	465.6	$284,635.25
TOTAL (Rounded) e					5,350			$285,000
Assumptions:
a We have assumed that the average number of existing respondents that will be subject to Subpart KKK will be 291. This estimated average accounts for modified facilities after August 2, 2016 subject to Subpart KKK will become subject to 40 CFR Part 60, Subpart OOOOa and therefore, would no longer report under these rules.
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 $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c New respondents will become subject to 40 CFR Part 60, Subpart OOOOa.
d We have assumed that the agency will spend eight hours per plant, two times per year to review semiannual reports.
e Totals are rounded to three significant figures. Figures may not add exactly due to rounding.

---

Sheet 5: Table 2b

Table 2b: Average Annual EPA Burden and Cost - NSPS for Onshore Natural Gas Processing Plants (40 CFR Part 60, Subpart LLL) (Renewal)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost b
Review notification of construction/reconstruction c	2	1	2	0	0	0	0	$0		Labor Rates
Review notification of modification c	2	1	2	0	0	0	0	$0		Managerial	$73.46
Review notification of anticipated startup c	2	1	2	0	0	0	0	$0		Technical	$54.51
Review notification of actual startup c	2	1	2	0	0	0	0	$0		Clerical	$29.50
Review notification of demonstration of CEMS c	2	1	2	0	0	0	0	$0
Review of CEMS demonstration report c	2	1	2	0	0	0	0	$0
Review notification of initial performance test c	2	1	2	0	0	0	0	$0
Review of semiannual reports d	8	2	16	14	224	11	22	$13,693.79
Review results of performance test c	2	1	2	0	0	0	0	$0
TOTAL (Rounded) e					258			$13,700
Assumptions:
a We have assumed that the average number of existing respondents that will be subject to Subpart LLL will be 14. This estimated average accounts for modified facilities after August 2, 2016 subject to Subpart LLL will become subject to 40 CFR Part 60, Subpart OOOOa and therefore, would no longer report under these rules.
b The cost is based on the following labor rates which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c New respondents will become subject to 40 CFR Part 60, Subpart OOOOa.
d We have assumed that the agency will spend eight hours per plant, two times per year to review semiannual reports.
e Totals are rounded to three significant figures. Figures may not add exactly due to rounding.

---

Sheet 6: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent b	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent c	Number of Respondents with O&M d	Total O&M, (E X F)
SO2 CEM, control outlet (only for Subpart LLL) a	$103,525	0	$0	$24,250	4	$97,001		$97,001
Assumptions:
a 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.
b Assume that capital/startup costs for a new sulfur CEMS and control outlet is $103,525. Capital costs have been increased from 2008 to 2022 $ using the CEPCI Equipment Cost Index.
c Assume that the annual O&M costs of the sulfur CEMS and control outlet is $24,250. Costs have been increased from 2008 to 2022 $ using the CEPCI Equipment Cost Index.
d We expect 4 existing facilities to have annual O&M costs for monitoring under subpart LLL.

---

Sheet 7: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Subpart KKK
Semiannual reports	291	2	N/A	582
Subtotal for Subpart KKK				582
Subpart LLL
Semiannual report	14	2	N/A	28
Subtotal for Subpart LLL				28
TOTAL				610

---

Sheet 8: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of Existing Respondents that would now report under Subpart OOOOa a	(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= B+C-A-D)
Subpart KKK
1	27	345	0	0	318
2	27	318	0	0	291
3	27	291	0	0	264
Average	27	318	0	0	291
Subpart LLL b
1	3	17	3	0	17
2	3	14	3	0	14
3	3	11	3	0	11
Average	3	14	3	0	14
Total c					305
Assumptions:
a We expect 27 of the existing facilities subject to Subpart KKK to undergo modifications in each year, which would indicate these facilities would report under Subpart OOOOa and no longer report under Subpart KKK. For Subpart LLL, we expect three facilities to perform a modification and report under Subpart OOOOa.
b Affected facilities with design capacities of less than two long tons per day (LT/D) 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.
c This is the total average of existing respondents subject to both Subparts KKK and LLL.