# MEMORANDUM

TO: Docket ID No. EPA-HQ-OAR-2015-0764

FROM: Alexis McKittrick and Ma rk de Figueiredo, EPA/CCD

DATE: January 21, 2016

SUBJECT: Data Category Assignments and Confidentiality Determinations for All Data

Elements in the Proposed “Leak Detection Methodology Revisions and

Confidentiality Determinations for Petroleum and Natural Gas Systems”

In the proposed rulemaking titled “Leak Detection Methodology Revisions and

Confidentiality Determinations for Petroleum and Natural Gas Systems” (referred to hereafter as

the Subpart W Leak Detection Proposed Amendmen ts), the EPA is proposing revisions to the

current subpart W reporting requirements. These revisions include the proposed addition of leak

detection methodologies and leaker emission factors. The propos ed additions to the reporting

requirements would involve revisions to existin g reporting requirements and the addition of new

data elements. In conjunction with the proposed revisions, the EPA is proposing confidentiality

determinations for proposed new and substantially revised data elements. In this memorandum,

we provide a list of all the pr oposed new and substantially revised data elements, the proposed

confidentiality determinations, and where appropriate, the data category assignments.

Table 1 shows the proposed category assignmen ts for all new and substantially revised

assigned to data categories for which a categorical confidentiality determination was previously

finalized in 2011. As explained in the preamble to the Subpart W Leak Detection Proposed

Amendments, for data elements listed in Table 1, the EPA is proposing to apply the categorical

determinations established in 2011. 1 

# For discussion of the proposed new and substantially

revised data elements where we are proposi ng to use previously finalized categorical

determinations, their proposed category assignments, and the proposed application of the

categorical confidentiality determinations, see Section III.B of the preamble to the Subpart W

Leak Detection Proposed Amendments.

Table 2 shows the proposed categorical assignments and confidentiality determinations

for all new and substantially re vised data elements assigned to the data category “Unit/Process

Operating Characteristics That Are Not Inputs to Emission Equations.” As explained in the

1 

# See “Proposed Confidentiality Determinations for Data Required Under the Mandatory Greenhouse Gas Reporting

Rule and Proposed Amendment to Special Rules Governing Certain Information Obtained Under the Clean Air Act”

published on July 7, 2010 (75 FR 39094); and “Confidentiality Determinations for Data Required under the

Mandatory Greenhouse Gas Reporting Rule and Amendment to Special Rules Governing Certain Information

Obtained under the Clean Air Act” published on May 26, 2011 (76 FR 30782).

# 2 preamble to Subpart W Leak Detection Propos ed Amendments, the EPA did not establish

categorical confidentiality determ inations for this data cate gory in 2011, and confidentiality

determinations for data elements assigned to th is data category are made on a case-by-case basis

for these data elements. See Section III.C of the preamble to the Subpart W Leak Detection

Proposed Amendments for more information on th e proposed new and substantially revised data

elements assigned to these two data categories, their proposed confidentiality determinations,

and the rationales for the proposed determinations.

As shown in Tables 1 and 2, the EPA is propos ing that none of the new or substantially

revised data elements in the Subpart W Leak Detection Proposed Amendments are eligible for

confidential treatment. A copy of the Subpart W Leak Detection Proposed Amendments can be

found on EPA’s website at http://www2.epa.gov/ghgreporting/r ulemaking-notices-ghg-reporting

. Copies of the proposed and final CBI rules id entified in this memo randum are available on

EPA’s website: http://www2.epa.gov/ghgreporting/confid ential-business-information-ghgreporting , and at the following links: http://www.gpo.gov/fdsys/pkg/FR-2010-07-07/pdf/2010-

16317.pdf and http://www.gpo.gov/fdsys/pkg/FR -2011-05-26/pdf/2011-12930.pdf

.3Table 1.Proposed Data Category Assignments and Confidentiality Determinations for New Data Elements Assigned to Categories with CategoricalDeterminations2Rule CitationNew/Substantially Revised byIndustry Segment3Proposed Data ElementProposed CategoryAssignmentCategoricalDetermination(as Establishedin 2011)§98.236(q)(1)(i)New: OPNGP, OPNGGBThe number of complete equipment leaksurveys performed during the calendar year.Test and CalibrationMethodsNot CBI§98.236(q)(1)(iii)New: OPNGP, OPNGGB, ONGP,ONGTC, UNGS, LNGS, LNGIEE, NGDWhether any equipment leak componenttypes were subject to 40 CFR part 60, subpartOOOOa.Facility and UnitIdentifierInformationEmission Data§98.236(q)(1)(iv)New: OPNGP, OPNGGB, ONGP,ONGTC, UNGS, LNGS, LNGIEE, NGDWhether you elected to comply with§98.233(q)(1)(iii).Facility and UnitIdentifierInformationEmission Data§98.236(q)(1)(v)New: OPNGP, OPNGGB, ONGP,ONGTC, UNGS, LNGS, LNGIEE, NGDEach type of method described in §98.234(a)that was used to conduct leak surveys.Test and CalibrationMethodsNot CBI§98.236(q)(2)(i)New: OPNGP, OPNGGBSubstantially Revised: ONGP, ONGTC,UNGS, LNGS, LNGIEEFor each component type that is located atyour facility, component type.Facility and UnitIdentifierInformationEmission Data§98.236(q)(2)(iv)New: OPNGP, OPNGGBSubstantially Revised: ONGP, ONGTC,UNGS, LNGS, LNGIEEFor each component type that is located atyour facility, annual CO2emissions, in metrictons CO2.EmissionsEmission Data§98.236(q)(2)(v)New: OPNGP, OPNGGBSubstantially Revised: ONGP, ONGTC,UNGS, LNGS, LNGIEEFor each component type that is located atyour facility, annual CH4emissions, in metrictons CH4.EmissionsEmission Data2The categorical confidentiality determinations for the data categories listed in this table were finalized on May 26, 2011 (see 76 FR 30782).3OPNGP = Onshore Petroleum and Natural Gas Production; OPNGGB =Onshore Petroleum and Natural Gas Gathering and Boosting; ONGP= Onshore Natural Gas Processing;ONGTC = Onshore Natural Gas Transmission Compression; UNGS = Underground Natural Gas Storage; LNGS = Liquefied Natural Gas (LNG) Storage; LNGIEE = LNG Importand Export Equipment; NGD = Natural Gas Distribution.4Table 2.Proposed Data Category Assignments and Confidentiality Determinations for New Data Elements Assigned to the Unit/Process OperatingCharacteristics Data CategoryRule CitationNew/SubstantiallyRevised by IndustrySegment4Proposed Data ElementProposed CategoryAssignmentProposedDetermination§98.236(q)(2)(ii) New: OPNGP, OPNGGBSubstantially Revised:ONGP, ONGTC, UNGS,LNGS, LNGIEEFor each component type that is located at yourfacility, total number of the surveyed componenttype that were identified as leaking in the calendaryear (“xp” in Equation W-30).Unit/Process OperatingCharacteristics that areNot Inputs to EmissionEquationsNot CBI§98.236(q)(2)(iii) New: OPNGP, OPNGGBSubstantially Revised:ONGP, ONGTC, UNGS,LNGS, LNGIEEFor each component type that is located at yourfacility, average time the surveyed components areassumed to be leaking and operational, in hours(average of “Tp,z” from Equation W-30).Unit/Process OperatingCharacteristics that areNot Inputs to EmissionEquationsNot CBI4OPNGP = Onshore Petroleum and Natural Gas Production; OPNGGB =Onshore Petroleum and Natural Gas Gathering and Boosting; ONGP= Onshore Natural Gas Processing;ONGTC = Onshore Natural Gas Transmission Compression; UNGS = Underground Natural Gas Storage; LNGS = Liquefied Natural Gas (LNG) Storage; LNGIEE = LNG Importand Export Equipment; NGD = Natural Gas Distribution.