### MEMORANDUM

To: Docket # EPA

- HQ

- OAR

- 2011

- 0512

From: Mark d e Figueiredo, EPA/CCD

Date: November 10 , 201 4

Subject: Assessment of Impacts of the 2014 Final Revisions to Subpart W



## 1. Introduction

T he EPA is finalizing technical revisions and other clarifications to subpart W of the

Greenhouse Gas Reporting Rule ( 40 CFR p art 98, subpart W ) ( here in after referred to as

“subpart W”)

. In this memorandum , we discuss the potential burden to reporters affected by

the se amendments.

T he EPA estimated the cost of the amendment s to subpart W as the incremental costs

above the previously estimated costs of the requirements under subpart W. 1 

### The EPA calculated

this incremental cost based on the num ber of reporters in each segment that are likely to be

affected by the amendments

. The detail s for estimating this incremental cost ( the potential

burden to reporters) are included in the sections below.

Costs to reporter s associated with this rulemaking are expressed as labor costs (i.e., the

cost of labor by facility staff to meet the rule’s amendments ). The EPA determined labor costs

using an approach consistent with previous impacts analyses associated with the Greenhouse Gas

Reporting Program ( GHGRP )

. For all industry segments the labor rates are $78.29 for engineers

and $66.57 for technicians. 2

, 3



## 2. Summary of Amendment s

In this memorandum, we summarize the potential burden to reporters affected by the

substantive revisions in the rule

. In addition to these substantive revisions, the EPA is also

finalizing minor technical revisions to subpart W to improve readability, to create consistency in

terminology, and/or to correct typographical or other errors. These minor technical revisions wil l

not impart additional burden on reporters and are n ot discussed in this memorandum. 4



### The following sections detail the more substantive changes to subpart W that may or may

not impact reporters.

1 The previously estimated costs of the requirements under subpart W are included in the Information Collection Request for the

Greenhouse Gas Reporting Program, OMB Control No. 2060

- 0629, EPA ICR No. 2300.10, May 2013 and EPA ICR No.

2300.12, August 2013

. 2 None of the amendment s require an adjustment to middle and senior management labor hours

. 3 The engineering and technician labor rates are from the May 2011 National Industry

- Specific Occupational Employment and

Wage Estimates (http://www.bls.gov/oes/current/oessrci.htm) and Employer Costs for Employee Compensation for June of 2011

(http://www.bls.gov/news.release/archives/ecec_09082011.pdf).

4 For explanation o f the minor technical revisions refer to the memorandum

, “Minor Technical Corrections to Subpart W,

Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems ;

Final Rule ” in D ocket ID No. EPA

- HQ

- OAR

- 2011

- 0512.



### 1

### 2.1 Gas Well Completions and Workovers

The EPA is revis ing reporting requirements for gas well completions and workovers to

differentiate between completions and workovers with different well type combinations in each

sub

- basin category. The EPA is clarify ing the number of measurements or calculations that must

b e taken to estimate the average ratio of flowback rate (FRM). Reporter s may have to conduct

more tests/measurements

, because a separate FRM value is required for each well type

combination . This revision represents a potential increase to burden and cost. Using 2012

subpart W data reported to EPA as of September 1, 2013, the EPA determined that 40% of

onshore production facilities reported completion and workover emissions and 23% of the se

facilities reported emissions from completions under more than one w ell type combination

. It

was estimate d that these facilities with completions will have to take two additional

measurements to determine additional FRM values and that an engineer will take approximat e l y

8 hours to conduct each additional measurement. Ther efore, engineering labor hours (at a cost of

$78.29/hour) were adjusted upwards by 1.472 hours per reporter [ 16 * 0.40 * 0.23 = 1.472 ]

.

The EPA is modify ing Equation W

- 10A (which is a calculation that determines annual

volumetric total gas emissions from gas well venting during completions or workovers following

hydraulic fracturing) in order to enable quantification of natural gas emitted during the initial

flowback stage of a well when insufficient gas is present to enable separation and metering. In

add ition, the EPA is modify ing Equation W

- 10A to ensure reporter s account for sales gas

volume only once in this calculation. The new method is similar in complexity as the previous

method and uses measurements that are of similar complexity; therefore, these changes to

Equation W

- 10A will not impose any additional (or reduced) burden and costs.

The EPA is revis ing Equation W

- 13 (which is a calculation that determines annual

volumetric total gas emissions from gas well venting during completions or workovers without

hydraulic fracturing) to separate the calculation of emissions from workovers and the calculation

of emissions from completions into two equations. Reporter s will have to perform two

calculations as opposed to one; however, it is the same calculation that reporter s are currently

doing broken into two steps. Therefore, these changes to Equation W

- 13 will n ot impose any

additional (or reduced) burden and costs.

2.2 Flare Stack Emissions

The EPA is revis ing the calculation and reporting requirements for onshore natural gas

transmission compression, underground natural gas storage, liquefied natural gas ( LNG ) sto rage,

and LNG import and export to include emissions from flare stacks. This revision represents a

potential increase to burden and cost for reporter s in these four industry segments. Facilities in

these industry segments that ha ve flares d o not have to re port flare stack emissions currently , but

will need to collect flare data, calculate, and report these emissions under the revisions

. However, because underground natural gas storage and LNG storage facilities do not report

flared emissions for compressors

, which is required under the current rule if these facilities ha ve

flare d emission s associated with their compressors

, the EPA assumed that 0% of these facilities

operate flares . Therefore, t his revision will not impose any additional (or reduced) burden and

costs on these two industry segments.

In order to calculate the potential increase to reporter s in the onshore natural gas

transmission compression and LNG import and export industry segments, the EPA estimated that

2

### the percent of facilities that will report flare stack emissions was equal to the percent of facilities

that reported flared emissions for compressors for each of these two industry segment s

. Using

2012 subpart W data reported to EPA as of September 1, 2013 , 1% of the onshore natural gas

tr ansmission compression facilities and 14 % of LNG import and export facilities reported flared

emissions from compressors. The incremental increase in hours per reporter was then determined

by multiplying the percent of facilities that would report flare st ack emissions in each industry

segment (i.e., 1% and 14 %, respectively) by 20 minutes (i.e., the amount of time the EPA

estimated an engineer will need to collect data and estimate emissions). The result was an

estimated increase in the engineering labor h ours of 0.00 2 hours per reporter (at a rate of

$78.29/hour) in the onshore natural gas transmission compression industry segment; and an

increase of 0. 05 hours per reporter (at a rate of $78.29/hour) in the LNG import and export

industry segment.

2.3 Centrifugal and Reciprocating Compressor Venting

The EPA is revis ing the monitoring requirements so that, in cases where multiple

compressor sources are manifolded together downstream, reporter s can measure downstream of

the manifold and will not have to m easure the compressor sources individually. For manifolded

compressors, reporters will also have to report activity data for the manifold (i.e.

, number of

compressor sources manifolded together, mode of each compressor). Reporter s will no longer be

require d to annually measure compressor sources that are manifolded individually. Instead,

reporter s will measure the manifolded group of compressor sources once per year. Therefore,

this change is a burden reduction for reporter s that have two or more compressor sources

manifolded together. This revision is expected to affect only compressors at onshore natural gas

processing facilities, onshore natural gas transmission compression facilities, underground

natural gas storage facilities, LNG storage facilities, an d LNG import and export equipment

facilities. 5 

### The EPA assumed that facilities with manifolded compressor sources will use the new

option. Therefore, the EPA calculated the decrease in burden associated with this measurement

option by adjusting engineering and technician labor hours downwards per reporter for each

industry segment that could use the new option. This adjustment downward in labo r hours was

determined by first e stimating the average number of compressors that are located at a facility in

each affected industry segment

, 6 

### and then m ultiplying the average number of compressors

located at a facility by 10% ( because it was assumed that 10% of the facilities will have

manifolded compressor sources ). The EPA then took the number of manifolded compress or

sources and multiplied it by 10 minutes

— the estimated time for a technician to take the

measurement, and by 30 minutes

— the estimated time for an engineer to perform the calculation.

The calculation resulted in a decrease in 0. 3 5 engineering labor hours (at a rate of

$78.29/hour) and 0. 12 technician labor hours (at a rate of $66.75/hour) per reporter for the

onshore natural gas processing and underground natural gas storage industry segments , a

5 The manifold measurement option would not impact onshore petroleum and natural gas production facilities

because compressor emission calculation methods are different for this industry segment. It would not impact

natu ral gas distribution facilities or offshore petroleum and natural gas production facilities because compressor

emission calculation methods are not required for these industry segments.

6 The EPA determined the average number of compressors per facility us ing 2012 subpart W data reported to EPA

as of September 1, 2013: 8 compressors at onshore natural gas processing facilities; 6 compressors at onshore

natural gas transmission compression facilities; 8 compressors at underground natural gas storage faciliti es; and

5 compressors at LNG import and export equipment facilities.



### 3

### decrease in 0. 2 5 engineering labor hours and 0.0 8 technician labor hours per reporter for the

onshore natural gas transmission compression industry segment

, a decrease in 0. 0 5 engineering

labor hours and 0.0 2 technician labor hours per reporter for the LNG storage industry segment

, and a decrease in 0. 2 0 engineering labor hours and 0.0 7 technician labor hours per reporter for

the LNG import and export equipment industry segment.

In addition, the EPA is remov ing vented compressor emissions routed to a flare from the

compressor emissions total (clarifying th at these emissions should be reported in the flared

emissions total) and retain the requirement to report uncontrolled vented emissions from

compressors. Reporter s will no longer be required to perform individual compressor leak

measurements or continuous measurements, but rather perform a single calculation under the

flare stack emissions methodology. The latter will be less burdensome

, because it only requires

reporter s to either continuously monitor total flow and composition to the flare or use

engineer ing estimates. This amendment is expected to affect only compressors routed to a flare

at onshore natural gas processing facilities, onshore natural gas transmission compression

facilities, and LNG import and export equipment facilities. 7 

### The EPA calculate d the decrease in

burden associated with this amendment by adjusting engineering and technician labor hours

downwards per reporter for each affected industry segment. The first steps in adjusting the labor

hours included the following: (1) e stimating the a verage number of compressors that are located

at a facility in each affected industry segment ; 8 

### (2) estimating the average percent of facilities

that report under the “other flare stacks” category in each affected industry segment ; 9 

### and

(3) estimating the a verage percent of the compressors at facilities that report flared emissions for

reciprocating or centrifugal compressors

. 10 

### Th e downward adjustment in labor hours was

determined by multiplying the three estimates by 10 minutes

— the estimated time for a

technician to take the measurement, and by 30 minutes

— the estimated time for an engineer to

perform the calculation.

Th is calculation resulted in a decrease of 0. 58 engineering labor hours (at a rate of

$78.29/hour) and 0.19 technician labor hours (at a r ate of $66.57/hour) per reporter for the

onshore natural gas processing industry segment , a decrease in 0.02 engineering labor hours and

0.01 technician labor hours per reporter for the onshore natural gas transmission compression

7 Th is amendment would not impact onshore petroleum and natural gas production facilities because compressor

flare emission calculation methods are different for this industry segment. It would not impact natural gas

distribution facilities or offshore petroleum and natural gas production facilities because compressor flare emission

calculation methods are not require d for these industry segments. It would not impact underground natural gas

storage and LNG storage facilities because underground natural gas storage and LNG storage facilities do not have

compressors controlled by flares according to 2012 subpart W data reported to EPA as of September 1, 2013.

8 The EPA determined the average number of compressors per facility using 2012 subpart W data reported to EPA

as of September 1, 2013: 8 compressors at onshore natural gas processing facilities; 6 compressors at onshore

natural gas transmission compression facilities; and 5 compressors at LNG import and export equipment facilities

. 9 The EPA determined the percent of facilities with flares using 2012 subpart W data reported to EPA as of

September 1, 2013: 21% of facilities in onshore natural gas processing; < 1% of facilities in onshore natural gas

transmission compression; and 14 % of facilities in LNG import and export equipment).

10 The EPA determined the percent of the compressors at facilities with flares that are actually venting to flares

using 2012 subp art W data reported to EPA as of September 1, 2013: 6 9 % of the compressors are venting to flares at

onshore natural gas processing facilities ; 92% of the compressors at these facilities are venting to flares at onshore

natural gas transmission compression facilities ; and 100% of the compressors are venting to flares at LNG import

and export facilities

.



### 4

### industry segment

, and a d ecrease in 0. 36 engineering labor hours and 0. 1 2 technician labor hours

per reporter for the LNG import and export equipment industry segment.

The EPA is also finalizing that compressors not measured in the “not

- operating

depressurized

- mode” for over three years, must be measured in the “not

- operating

depressurized

- mode” at the next scheduled shutdown. Regardless of when the “not

- operating

depressurized

- mode” will be measured, the reporter will still be required to conduct an annual

measurement in whatever mode the compressor is found. Therefore, the frequency of

measurements will be unchanged

, and this change will not impose any additional (or reduced)

burden and costs.

2.4 Pneumatic Devices

The EPA is simplifying the procedure for determining the counts of pneumatic devices

operating each year as well as modifying Equation W

- 1 to calculate the volume of emissions

instead of the mass. The mass still must be calculated using procedures in 98.233(u), but the

approach is consistent with other emission source typ es. For the onshore petroleum and natural

gas production industry segment, reporters continue to have the option in the first two reporting

years to estimate counts of pneumatic devices using engineering estimates. T h ese change s will

not impose any additio nal (or reduced) burden and costs.

2.5 Liquids Unloading

The EPA is modify ing the liquids unloading calculation to annualize venting data for

facilities that use Calculation Method 1

. The EPA is also revising Calculation Method 1 at

40 CFR 98.233(f)(1) to sepa rate the calculation and reporting of emissions from wells that have

plunger lifts and wells that do not have plunger lifts. The impacts assessment assume d that

Calculation Method 2 and Calculation Method 3 are lower

- burden options than Calculation

Method 1 and that reporters will choose the lower

- burden option. While the changes to

Calculation Method 1 will increase facility flexibility, no changes were made to Calculation

Method 2 or Calculation Method 3. Therefore, these change s will not impose any addit ional (or

reduced) burden and costs.

2.6 Blowdown Vent Stacks

The EPA is revis ing the calculation for “unique physical volume” so reporter s can report

emissions from blowdown vent stacks by equipment type instead of by “ unique physical

volume. ” Although reporter s will no longer be required to report blowdown vent stack emissions

by each “ unique physical volume, ” reporter s still have to calculate blowdown vent stack

emissions from each “ unique physical volume. ” Therefore, this change will not impose any

ad ditional (or reduced) burden and costs.

The EPA is allowing the optional use of a compressibility factor in Equations W

- 14A,

W

- 14B, W

- 33 and W

- 34. A s a t proposal, the use of a default value i s assumed to be the option

with the lowest reporter burden and th is change will not impose any additional (or reduced)

burden and costs

.

The EPA is allow ing an option to directly measure blowdown emissions in lieu of

performing “ unique physical volume ” calculations. Although this option may decrease burden

for those rep orter s that currently measure blowdown emissions, because they could simply report

5

### these measured emissions (without the burden of performing calculations), the EPA

conservatively assumed that facilities would not directly measure all of their “ unique physical

volumes” and t herefore the EPA estimate d that this change would not impose any additional (or

reduced) burden and costs

. The EPA is also adding an optional calculation method (40 CFR

98.233(i)(3)) for blowdown emissions for situations where a flow meter is in place and including

associated reporting requirements in 40 CFR 98.236. As this is an optional calculation, this

change will not impose any additional (or reduced) burden and costs.

2.7 Associated Gas Venting and Flaring

The EPA is modify ing the c alculation method for associated gas venting and flaring to

account for situations where part of the gas is going to the sales line. The reporter will still have

to perform a similar calculation to what is currently being required. T he calculation method

m odifies the current equation to include a new term for the volume of sales gas, which is already

being calculated elsewhere and/or can be estimated. Therefore, this change will not impose any

additional (or reduced) burden and costs.

The EPA is not finaliz ing the addition of the proposed term “ERE

p,q 

### ” for emissions

reported under other sources. T his change will not impose any additional (or reduced) burden

and costs.

2.8 Above Grade Metering

- Regulating Stations

The EPA is finalizing technical revisions to the natural gas distribution segment to clarify

the calculation methodologies and reporting requirements for above grade metering

- regulating

stations. The rule clarif ies that reporter s calculate only two emission factors (one for CO 2 

### and

one for CH 4 

### ) for meter/regulator runs instead of separate emission factors for all component

types. These changes will not impose any additional (or reduced) burden and costs.

2.9 GHG Emissions from Natural Gas Volume Emissions

The EPA is allowing for the use of either site

- specific composition data or a default gas

composition in the calculation of natural gas emissions for natural gas transmission compression,

underground natural gas storage, LNG storage, LNG import and export, and natural gas

di stribution facilities. T his allowance will not impose any additional (or reduced) burden and

costs.

2.10 Best Available Monitoring Methods (BAMM)

As a change from proposal, t he EPA is re vising 40 CFR 98.234(f) to provide short

- term

transitional BAMM . BAMM was designed to be a temporary flexibility mechanism and not a

permanent option in the rule. Reporters have the option of using BAMM from January 1, 2015 to

March 31, 2015 without prior EPA approval for certain parameters that cannot reasonably be

measured ac cording to the monitoring and QA/QC requirements of 40 CFR 98.234. Reporters

also have the opportunity to request an extension for the use of BAMM from April 1, 2015

through December 31, 2015. Because BAMM is optional, the transitional BAMM provisions do

n ot change the burden associated with the methods of s ubpart W.

6

### 2.11 Reporting Provisions

Also part of this rule , t he EPA is adding 2 4 7 new data elements , while substantially

revising 1 3 data elements and delet ing 34 data elements that we re required to be report ed under

Part 98

. The list of these data reporting elements are listed in Appendix A, as Table A

- 1,

Table A

- 2, and Table A

- 3, respectively.

The new and revise d data elements will impose additi onal burden and costs because, f or

each of the new and revised data elements required to be reported, reporter s will be required to

calculate the data element using readily available data, and report the value to the EPA via the

EPA’s Electronic Greenhouse Gas Reporting Tool ( e

- GGRT ) as part of the annual report

curre ntly required under Part 98. The deletion of data elements reduce s burden for reporter s

.

The EPA calculated the increase in burden associated with new and revised data elements

by adjusting engineering labor hours upwards per reporter for all industry segm ents. This

increase in labor hours was determined by first adjusting the number of new and revised data

elements for each industry segment using the percentage of facilities that reported emissions for

each emission source

, according to 2012 subpart W data reported to the EPA as of September 1,

2013

.

As shown in Appendix A, the new, revised, and deleted data reporting elements fall into

28 separate categories and are not universally reported by all eight industry segments. Table 1,

Table 2, and Table 3 sho w the estimated counts of data reporting elements by data element

category and industry segment for new elements, revised elements, and deleted elements,

respectively. The totals are shown at the bottom of each table and match the counts above:

2 4 7 new rep orting elements, 1 3 revised reporting elements and 34 deleted reporting elements.

7

### Table 1. Count of Data Element Categories by Industry Segment f or New Data Elements

Data Element CategoryAll Industry SegmentsOnshore Petroleum andNatural Gas ProductionOffshore Petroleum andNatural Gas ProductionOnshore Natural GasProcessingOnshore Natural GasTransmissionCompressionUnderground NaturalGas StorageNatural Gas DistributionLNG Importand ExportEquipmentLNG Storage

Natural Gas Pneumatic Device Venting 3 3 0 0 3 3 0 0 0

Natural Gas Pneumatic Pump Venting 2 2 0 0 0 0 0 0 0

Acid Gas Removal 16 16 0 16 0 0 0 0 0

Dehydrators 18 18 0 18 0 0 0 0 0

Well Venting for Liquids Unloading 12 12 0 0 0 0 0 0 0

Completions and Workovers with Hydraulic

Fracturing 7 7 0 0 0 0 0 0 0

Completions and Workovers without

Hydraulic Fracturing 9 9 0 0 0 0 0 0 0

Blowdown Vent Stacks 8 0 0 8 8 0 0 8 0

Onshore Production Storage Tanks 10 10 0 0 0 0 0 0 0

Transmission Storage Tanks 10 0 0 0 10 0 0 0 0

Well Testing Venting and Flaring 5 5 0 0 0 0 0 0 0

Associated Natural Gas Venting and Flaring 6 6 0 0 0 0 0 0 0

Flare Stack Emissions 3 3 0 3 3 3 0 3 3

Centrifugal Compressors 33 0 0 33 33 33 0 33 33

Reciprocating Compressors 33 0 0 33 33 33 0 33 33

Equipment Leaks by Leak Detection 9 0 0 3 3 3 9 3 3

Equipment Leaks by Population Counts 9 5 0 0 0 3 7 3 3

EOR Injection Pump Blowdown 5 5 0 0 0 0 0 0 0

EOR H ydrocarbon L iquid D issolved CO2 2 2 0 0 0 0 0 0 0

Combustion 5 5 0 0 0 0 5 0 0

Natural Gas Distribution 7 0 0 0 0 0 7 0 0

Onshore Petroleum and Natural Gas

Production 1 3 1 3 0 0 0 0 0 0 0

Offshore Petroleum and Natural Gas

Production 2 0 2 0 0 0 0 0 0

Onshore Natural Gas Processing 7 0 0 7 0 0 0 0 0

Onshore Natural Gas Transmission

Compression 5 0 0 0 5 0 0 0 0

Underground Natural Gas Storage 3 0 0 0 0 3 0 0 0

LNG Import and Export Equipment 2 0 0 0 0 0 0 2 0

LNG Storage 3 0 0 0 0 0 0 0 3

TOTAL 24 7 12 1 2 121 98 81 28 85 78



### 8

### Table 2

. Count of Data Element Categories by Industry Segment

for Revised Data Elements

Data Element CategoryAll Industry SegmentsOnshore Petroleum andNatural Gas ProductionOffshore Petroleum andNatural Gas ProductionOnshore Natural GasProcessingOnshore Natural GasTransmissionCompressionUnderground NaturalGas StorageNatural Gas DistributionLNG Import and ExportEquipmentLNG Storage

Natural Gas Pneumatic Device Venting 0 0 0 0 0 0 0 0 0

Natural Gas Pneumatic Pump Venting 0 0 0 0 0 0 0 0 0

Acid Gas Removal 2 2 0 2 0 0 0 0 0

Dehydrators 0 0 0 0 0 0 0 0 0

Well Venting for Liquids Unloading 1 1 0 0 0 0 0 0 0

Completions and Workovers with Hydraulic

Fracturing 1 1 0 0 0 0 0 0 0

Completions and Workovers without

Hydraulic Fracturing 2 2 0 0 0 0 0 0 0

Blowdown Vent Stacks 0 0 0 0 0 0 0 0 0

Onshore Production Storage Tanks 1 1 0 0 0 0 0 0 0

Transmission Storage Tanks 0 0 0 0 0 0 0 0 0

Well Testing Venting and Flaring 0 0 0 0 0 0 0 0 0

Associated Natural Gas Venting and Flaring 0 0 0 0 0 0 0 0 0

Flare Stack Emissions 0 0 0 0 0 0 0 0 0

Centrifugal Compressors 1 0 0 1 1 1 0 1 1

Reciprocating Compressors 1 0 0 1 1 1 0 1 1

Equipment Leaks by Leak Detection 1 0 0 0 0 0 1 0 0

Equipment Leaks by Population Counts 0 0 0 0 0 0 0 0 0

EOR Injection Pump Blowdown 1 1 0 0 0 0 0 0 0

EOR Hydrocarbon Liquid Dissolved CO2 0 0 0 0 0 0 0 0 0

Combustion 2 0 0 0 0 0 2 0 0

Natural Gas Distribution 0 0 0 0 0 0 0 0 0

Onshore Petroleum and Natural Gas

Production 0 0 0 0 0 0 0 0 0

Offshore Petroleum and Natural Gas

Production 0 0 0 0 0 0 0 0 0

Onshore Natural Gas Processing 0 0 0 0 0 0 0 0 0

Onshore Natural Gas Transmission

Compression 0 0 0 0 0 0 0 0 0

Underground Natural Gas Storage 0 0 0 0 0 0 0 0 0

LNG Import and Export Equipment 0 0 0 0 0 0 0 0 0

LNG Storage 0 0 0 0 0 0 0 0 0

TOTAL 13 8 0 4 2 2 3 2 2



### 9

### Table 3

. Count of Data Element Categories by Industry Segment

for Deleted Data Elements

Data Element CategoryAll Industry SegmentsOnshore Petroleum andNatural Gas ProductionOffshore Petroleum andNatural Gas ProductionOnshoreNatural GasProcessingOnshore Natural GasTransmissionCompressionUnderground NaturalGas StorageNatural Gas DistributionLNG Import and ExportEquipmentLNG Storage

Natural Gas Pneumatic Device Venting 0 0 0 0 0 0 0 0 0

Natural Gas Pneumatic Pump Venting 0 0 0 0 0 0 0 0 0

Acid Gas Removal 0 0 0 0 0 0 0 0 0

Dehydrators 0 0 0 0 0 0 0 0 0

Well Venting for Liquids Unloading 0 0 0 0 0 0 0 0 0

Completions and Workovers with Hydraulic

Fracturing 4 4 0 0 0 0 0 0 0

Completions and Workovers without

Hydraulic Fracturing 0 0 0 0 0 0 0 0 0

Blowdown Vent Stacks 7 0 0 7 7 0 0 7 0

Onshore Production Storage Tanks 11 11 0 0 0 0 0 0 0

Transmission Storage Tanks 0 0 0 0 0 0 0 0 0

Well Testing Venting and Flaring 0 0 0 0 0 0 0 0 0

Associated Natural Gas Venting and Flaring 0 0 0 0 0 0 0 0 0

Flare Stack Emissions 0 0 0 0 0 0 0 0 0

Centrifugal Compressors 6 0 0 6 6 6 0 6 6

Reciprocating Compressors 3 0 0 3 3 3 0 3 3

Equipment Leaks by Leak Detection 2 0 0 2 0 0 0 0 0

Equipment Leaks by Population Counts 0 0 0 0 0 0 0 0 0

EOR Injection Pump Blowdown 0 0 0 0 0 0 0 0 0

EOR Hydrocarbon Liquid Dissolved CO2 0 0 0 0 0 0 0 0 0

Combustion 1 1 0 0 0 0 1 0 0

Natural Gas Distribution 0 0 0 0 0 0 0 0 0

Onshore Petroleum and Natural Gas

Production 0 0 0 0 0 0 0 0 0

Offshore Petroleum and Natural Gas

Production 0 0 0 0 0 0 0 0 0

Onshore Natural Gas Processing 0 0 0 0 0 0 0 0 0

Onshore Natural Gas Transmission

Compression 0 0 0 0 0 0 0 0 0

Underground Natural Gas Storage 0 0 0 0 0 0 0 0 0

LNG Import and Export Equipment 0 0 0 0 0 0 0 0 0

LNG Storage 0 0 0 0 0 0 0 0 0

TOTAL 34 16 0 18 16 9 1 16 9



### 10

### Using 2012 subpart W data reported to EPA as of September 1, 2013 , the number of

reporters that reported each data element category was determined. Using the total number of

reporters in each industry segment, the percentage of reporters by industry segment was

calculated for each data element category. The percentage s are shown in Table 4.

Table 4. Percentage of Facilities in Each Industry Segment Reporting Ea ch Data Element

Type for the 2012 C alendar Y ear (as of September 1, 2013) a

Data Element Category b ,cOnshore Petroleum andNatural Gas ProductionOffshore Petroleum andNatural Gas ProductionOnshore Natural GasProcessingOnshore Natural GasTransmissionCompressionUnderground NaturalGas StorageNatural Gas DistributionLNG Importand ExportEquipmentLNG Storage

Natural Gas Pneumatic Device

Venting 83.50% 0.00% 0.00% 70.84% 77.55% 0.00% 0.00% 0.00%

Natural Gas Pneumatic Pump

Venting 69.38% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Acid Gas Removal 5.57% 0.00% 55.56% 0.00% 0.00% 0.00% 0.00% 0.00%

Dehydrators 51.49% 0.00% 72.22% 0.00% 0.00% 0.00% 0.00% 0.00%

Well Venting for Liquids Unloading 50.30% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Completions and Workovers with

Hydraulic Fracturing 39.36% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Completions and Workovers

without Hydraulic Fracturing 38.17% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Blowdown Vent Stacks 0.00% 0.00% 66.92% 93.52% 0.00% 0.00% 87.50% 0.00%

Onshore Production Storage Tanks 83.70% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Transmission Storage Tanks 0.00% 0.00% 0.00% 23.11% 0.00% 0.00% 0.00% 0.00%

Well Testing Venting and Flaring 2.19% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Associated Natural Gas Venting and

Flaring 29.82% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Flare Stack Emissions 42.74% 0.00% 73.99% 0.00% 0.00% 0.00% 0.00% 0.00%

Centrifugal Compressors 0 .00 % 0.00% 29.04% 64.15% 18.37% 0.00% 37.50% 0.00%

Reciprocating Compressors 0 .00 % 0.00% 74.24% 60.69% 95.92% 0.00% 87.50% 40.00%

Equipment Leaks by Leak Detection 0.00% 0.00% 93.69% 93.52% 83.67% 56.04% 100.00% 60.00%

Equipment Leaks by Population

Counts 94.63% 0.00% 0 .0 0 % 0. 00 % 79.59% 0.00% 62.50% 0.00%

EOR Injection Pump Blowdown 1.39% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

EOR H ydrocarbon L iquid D issolved

CO2 2.58% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Combustion 91.25% 0.00% 0.00% 0.00% 0.00% 46.70% 0.00% 0.00%

(continued)



### 11

### Table 4. Percentage of Facilities in Each Industry Segment Reporting Each Data Element

Type for the 2012 Calendar Year (as of September 1, 2013) a 

### (continued)

Data Element Category b,cOnshore Petroleum andNatural Gas ProductionOffshore Petroleum andNatural Gas ProductionOnshore Natural GasProcessingOnshore Natural GasTransmissionCompressionUnderground NaturalGas StorageNatural Gas DistributionLNG Import and ExportEquipmentLNG Storage

Natural Gas Distribution 0.00% 0.00% 0.00% 0.00% 0.00% 100.00% 0.00% 0.00%

Onshore Petroleum and Natural Gas

Production 100.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Offshore Petroleum and Natural Gas

Production 0.00% 100.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Onshore Natural Gas Processing 0.00% 0.00% 100.00% 0.00% 0.00% 0.00% 0.00% 0.00%

Onshore Natural Gas Transmission

Compression 0.00% 0.00% 0.00% 100.00% 0.00% 0.00% 0.00% 0.00%

Underground Natural Gas Storage 0.00% 0.00% 0.00% 0.00% 100.00% 0.00% 0.00% 0.00%

LNG Import and Export Equipment 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 100.00% 0.00%

LNG Storage 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 100.00%

a A value of 0.00% means either there are no new, revised, or deleted data elements in the particular data element category in

Tables 1 through 3 or that none of the facilities in the particular industry segment have the type of equipment to which the

particu lar data element category applies.

b Counts were based on facilities that indicated with a check box on their annual report that the equipment was present.

c For equipment without an associated checkbox, counts were based on emissions that were zero or h igher, assuming that blank

meant no equipment and zero meant no emissions at this time.



### 12

### Using the information from Table 1 through Table 4

, t he EPA developed “adjusted”

counts of new and revised data elements per industry segment. The adjusted counts rep resent the

average number of new and revised data elements that facilities in each industry will report.

Some facilities will not report all of the data elements because they do not have the applicable

equipment. The EPA then multipl ied the adjusted number of new and revised data elements for

each industry segment by 3 minutes per data element

— the amount of time that the EPA

estimated an engineer will need to access the data element from readily available data and submit

the value via e

- GGRT as part of the annual report currently required under Part 98. Table 5

shows the potential labor increase by industry segment associated with the new and revised data

elements

. Appendix B shows how th e adjusted new and revised counts were developed.

Table 5 . Labor Change Associated with New and Revised Data Elements

Industry Segment New Data

Elements Revised

Data

Elements New Data

Elements

Adjusted Revised

Data

Elements

Adjusted Adjusted

Total Total Ch ange

in Labor

Hours per

Reporter a

Onshore Petroleum and

Natural Gas Production 12 1 8 6 0 3 6 3 3. 1 4 b

Offshore Petroleum and

Natural Gas Production 2 0 2 0 2 0.1

Onshore Natural Gas

Processing 121 4 73 2 7 5 3. 7 8

Onshore Natural Gas

Transmission Compression 98 2 61 1 6 2 3.1

Underground Natural Gas

Storage 81 2 48 1 49 2. 4 5

Natural Gas Distribution 28 3 1 4 1 1 5 0. 80

LNG Import and Export

Equipment 85 2 55 1 5 6 2. 8 2

LNG Storage 78 2 18 1 1 8 0.9 2

a Engineering labor hours at $78.29/hour

b Example calculation for onshore petroleum and natural gas production: (63 adjusted elemen ts) x (3 minutes/element) x

(1 hour/60 minutes) = 3.15 hours



### The EPA calculated the decrease in burden associated with deletion of data elements by

adjusting engineeri ng labor hours downwards per reporter for all affected industry segments.

This decrease in labor hours was determined by first adjusting the number of deleted data

elements for each industry segment using the same procedure described above for developing

a djusted counts of new and revised data elements. Table 6 shows the labor adjustment by

industry segment associated with the deleted data elements. Appendix B shows how the adjusted

deleted data element counts were developed.

13

### Table 6 . Labor Change Associated with Deleted Data Elements

Industry Segment Deleted Data

Elements Deleted Data

Elements

Adjusted Total Change in Labor

Hours per Reporter a

Onshore Petroleum and Natural Gas Production 16 12

− 0. 59 b

Offshore Petroleum and Natural Gas Production 0 0 0.00

Onshore Natural Gas Processing 18 1 1

− 0. 5 3

Onshore Natural Gas Transmission Compression 16 1 2

− 0. 6 1

Underground Natural Gas Storage 9 4

− 0. 2 0

Natural Gas Distribution 1 0 0. 0 0

LNG Import and Export Equipment 16 1 1

− 0. 55

LNG Storage 9 1

− 0. 0 6

a Engineering labor hours at $78.29/hour

b Example calculation for onshore petroleum and natural gas production: ( 12 adjusted elements) x (

- 3 minutes/element) x (1

hour/60 minutes) =

- 0. 59 hours



### 14

## 4. Results of Analysis

The estimated change in burden (labor hours) and cost for the amendments to subpart W

are summarized by industry segment in Table 7

.

Table 7 . Annual Average Cha nge in Reporter Burden and Cost

for Subpart W of the GHGRP

Subpart W Industry Segment Change In

Total Burden

(Technical

Labor Hours) Change In

Burden

(Technical

Labor Hours /

Reporter ) Change In

Total Cost

($) Change In Cost

($ / Reporter )

Onshore Petroleum and Natural Gas

Production a 4, 1 71 4.0 4 $32 5, 678 $31 5

Offshore Petroleum and Natural Gas

Production b 7 0.10 $564 $8

Onshore Natural Gas Processing c 5 84 2.01 $4 6,766 $1 61

Onshore Natural Gas Transmission

Compression d 2, 4 65 2. 1 4 $1 9 4 ,1 83 $1 69

Underground Natural Gas Storage e 2 48 1. 7 8 $ 19,597 $1 4 1

Natural Gas Distribution f 1 22 0. 7 7 $ 9, 585 $ 60

LNG Import and Export Equipment g 6 1. 5 7 $ 5 02 $12 5

LNG Storage h 7 4 2.1 2 $6, 603 $1 89

TOTAL 7, 6 77

--- $ 60 3,478

---

a For Onshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 97,754 hours to 101,9 24

hours, which increased the total cost from $8,334,208 to $8,6 59, 886

.

b For Offshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 3,220 hours to 3,227

hours, which increased the total cost from $285,215 to $285,779.

c For Onshore Natural Gas Processing, the technical labor hour burden increased from 25,495 hours to 26,0 78 hours, which

increased the total cost from $2,346,157 to $2,39 2,924

.

d For Onshore Natural Gas Transmission Co mpression, the technical labor hour burden increased from 75,506 hours to 7 7,971

hours, which increased the total cost from $7,307,654 to $7, 50 1,838

.

e For Underground Natural Gas Storage, the technical labor hour burden increased from 12,450 hours to 12, 697 hours, which

increased the total cost from $1,164,454 to $1,18 4, 051

.

f For Natural Gas Distribution, the technical labor hour burden increased from 18,986 hours to 19, 10 9 hours, which increased

the total cost from $1,658,624 to $1,66 8,209

.

g For LNG Im port and Export Equipment, the technical labor hour burden increased from 367 hours to 37 3 hours, which

increased the total cost from $39,217 to $39, 7 1 8

.

h For LNG Storage, the technical labor hour burden increased from 2,954 hours to 3,0 29 hours, which in creased the total cost

from $285,799 to $292, 401

.



### 15