SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY

Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems ; Final Rule (40 CFR Part 98, subpart W) November 2014

P art A of the Supporting Statement

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection Recordkeeping and Reporting Requirements for 2014 Revisions to Petroleum and Natural Gas Systems (40 CFR part 98, Subpart W ) . The OMB control number is 2060

- 0629 and the EPA
ICR tracking number is 2300.15

.

1(b) Short Characterization In response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public Law
110

- 161) and under authority of the Clean Air Act (CAA) , EPA finalized the Greenhouse Gas Reporting Rule (74 FR 56260; October 30, 2009). T he Greenhouse Gas Reporting Rule is
referred t o as 40 CFR Part 98 (Part 98) and i mplementation of Part 98 is referred to as the
Gr eenhouse Gas Reporting Program (GHGRP). This supporting statement addresses information
collection activities that will be imposed by “ Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Final Rule ”. Part 98, which became effective on December 29, 2009, requires that certain facilities and suppliers emitting above certain threshold levels of carbon dioxide ( CO 2 ) equivalent ( CO 2 e) monitor and report emissions of greenhouse gases (GHGs)

. A subsequent rule was published on
November 3 0, 2010 finalizing the requirements for the petroleum and natural gas systems source
category (hereafter referred to as “subpart W”) at 40 CFR part 98, subpart W (75 FR 74458)

. In this final amendatory package for subpart W, EPA is clarify ing terms and definitions,
and correct ing technical and editorial errors that have been identified during the course of implementation ; t hese revisions are not expected to substantively affect respondent burden

. EPA
is also rev is ing calculation methods, and amend ing monitoring and data reporting requirements ; some of these revisions may affect respondent burden. See Section 4(b) and Appendix A for a complete list of revisions to the reporting requirements. Potential respondents are owners or operators of petroleum and natural gas systems that meet the requirements of §98.2(a)(2) and the reporting thresholds of §98.231 . Respondents are required to report data elements according to §98.2 36, and maintain records according to §98.2 37 and other source categories, as applicable

.

Page 1 November 2014Approximately 2, 9 00 respondents will be subject to the regulation and this rulemaking is expected to increase labor costs for subpart W facilities. Compared with the estimated respondent burden identified in the information collection for the GHGRP currently approved by
the Office of Management and Budget ( OMB ) , this information collection will result in an
increase in annual burden of approximately 7, 7 00 hours and $ 60 3 ,000 ( labor costs), as shown in
Section 6.

Page 2 November 20142. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

T he FY2008 Consolidated Appropriations Act

, signed into law on December 26, 2007

, directed EPA to “develop and publish a draft rule not later than 9 months after the date of enactment of this Act, and a final rule not later than 18 months after the date of enactment of this Act, to require mandatory reporting of greenhouse gas emissions above appropriate thresholds in all sectors of the economy of the United States.”
As state d in the October 30, 2009 preamble to Part 98 (74 FR 56260), CAA section 114(a)(1) authorizes the Administrator to require emissions sources, persons subject to the CAA, or persons whom the Administrator believes may have necessary information to report em issions and provide such other information the Administrator requests for the purposes of carrying out any provision of the CAA

. Therefore, t he EPA is finalizing this information collection under the Clean Air Act ( CAA ) authority provided in CAA section 11 4.

2(b) Use /Users of the Data
The GHGRP collects information from facilities that directly emit GHGs and from suppliers of products that release GHGs if combusted, oxidized, or used. The comprehensive GHG data reported directly from large facilities and suppliers across the country are accessibl e to the public at: http://ghgdata.epa.gov/ghgp/main.do . Reporting entities generally use uniform methods for estimating emissions, which enables data to be compared and analyzed.
Data collection in the GHGRP complements the Inventory of U.S. Greenhouse Gas Emissions and Sinks (Inventory) and provides a critical tool for communities to identify nearby sources of GHGs and provide information to state and local governments. The standardization of GHG data p rovides businesses with the necessary information to benchmark themselves against similar facilities, better understand their relative standing within their industry, and achieve and disseminate their environmental achievements. Businesses and
other innova tors can use the data to determine their GHG footprints, find cost

- and fuel

- saving efficiencies that reduce greenhouse gas emissions (e.g., through energy audits or other forms of assistance), and foster technologies to protect public health and the envir onment. Generally, t he facility

- specific GHG emission data improve the understanding of the
factors that influence GHG emission rates as well as the actions that facilities take to reduce emissions. The facility

- based data can be aggregated to the corpora te level in order to track emission trends from industries, within industries, and across industries over time, particularly in response to policies and potential regulations. Specifically, Subpart W data can be used to complement atmospheric GHG studies and inform updates to emission inventories. Various activity data are collected that can be used to improve understanding of the occurrence of emissions from a variety of sources.

Page 3 November 20143. NONDU PLICATION, CONSULTATIONS, A ND OTHER CO LLECTION
CRITERIA

3(a) Nonduplication
The information to be collected under the revisions includes 2 4 7 new data elements and

1 3 substantially revised data elements (refer to section 4(b) and Appendix A for a list of these data elements). These new and substantially revised data elements consist primarily of quantities that provide information on the activity level at the facility and other process information that
will provide key information for verific ation, including confirming that emissions are appropriate for a given activity

- level and estimating expected emissions based on data provided. These new and substantially revised reporting elements for subpart W are similar to the types of industry
data a lready being collected under the GHGRP. EPA has evaluated the types of industry data collected under Part 98, and concluded that the y do not duplicate other information collections

, as described below

. In developing the GHGRP, EPA reviewed monitoring methods

, incl uding:

• Federal programs within the United States , such as the Inventory , the U.S. Department of Energy’s (DOE’s) Energy Information Administration’s (EIA’s) 1605b program, the Acid Rain Program, EPA Natural Gas STAR Program, and voluntary GHG partnership programs;

• State and r egional GHG reporting programs , such as The Climate Registry, the Regional Greenhouse Gas Initiative, the Western Regional Air Partnership, and programs in several states including California, New Mexico, Connecticut, and New Jersey;

• Reporting protocols developed by nongovernmental organizations, such as the World Resources Institute/World Business Council for Sustainable Development;

• Programs from industrial trade organizations, such a s the Interstate Natural Gas Assoc iation of America’s GHG Emission Estimation Guidelines, the American Petroleum Institute’s Compendium of G HG Estimation Methodologies for the Oil and Gas Industry, and the World Business Council for Sustainable Development’s Cement Sustainability Initiativ e’s CO 2 Accounting and Reporting Standard for the Cement Industry ; and

• IPCC Guidelines for National Greenhouse Gas Inventories

.

Many of these programs collect different or additional data as compared to the GHGRP
and this rulemaking

. For example, state programs may include different data elements to support other programs (e.g., offsets)

. While some programs collect similar information on GHG emissions, the Agency has determined that the GHGRP supplement s and complement s , rather than duplicate s , existing programs’ data. Further, EPA has made significant efforts over the past

Page 4 November 2014four years to facilitate the reporting in the event a single entity has to report both the federal and
state level. For example, EPA has supported efforts by the California Air Resources Board to harmonize the reporting of information under California’s Global Warming Solutions Act, AB32
with EPA’s GHGRP . The product of the collaboration is referred to as California Electronic Greenhouse Gas Reporting Tool, or Cal e

- GGRT.

Doc umentation of EPA’s review of GHG monitoring protocols used by federal and state voluntary and mandatory GHG programs as well as GHG reporting rules can be found in the
docket at EPA

- HQ

- OAR

- 2008

- 0508

- 0 0 56

. For further discussion on the relationship of the GHGRP to other programs, please refer to the preambles of the proposed and final GHG reporting rules ( which can be found in the docket at EPA

- HQ

- OAR

- 2008

- 0508 )

, the June 6, 2008 memorandum entitled Review of Existing Programs (which can be found in the do cket at

EPA

- HQ

- OAR

- 2008

- 0508

- 0052)

, and the January 27, 2009 memorandum entitled Review of Existing State Greenhouse Gas Reporting Rules (which can be found in the docket at EPA

- HQ

OAR

- 2008

- 0508

- 0054)

. As noted in the current ICR for the GHGRP , a number of programs at the state, t rib al,

t erritorial, and local level require emission sources in their respective jurisdictions to monitor and
report GHG emissions. To reduce burden on reporters and program agencies, the Agency plans

to shar e reported da ta

, with the exception of any information determined to be Confidential Business Information ( CBI )

, with relevant agencies or approved entities using, where practical,
shared tools

, and infrastructure. Based on this evaluation, this information collection request does not duplicate other
information collections.

3(b) Public Notice Required Prior to Information Collection Request ( ICR ) Submissions to
OMB A public notice of this collection is provided in the Federal Register notice of

“ Greenhouse Gas Reporti ng Rule: 2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems ; Final Rule

. ”

3(c) Consultations Early in the development process of the GHGRP , EPA conducted a proactive communications outreach program to inform the public about the rule development effort. EPA solicited input and maintained an open

- door policy for those interested in discussing the rulemaking. Since January 2008, EPA staff has held more than 100 meetings with stakeholders, including the following :

• Trade a ssociations and firms in potentially affected industries/sectors;

• State, local, and tribal environmental control agencies and regional air quality planning organizations;

Page 5 November 2014• State and regional organizations already involved in GHG emissions reporting,
such as The Climate Registry, California Air Resources Board, and the Western Climate Initiative; and

• Environmental groups and other nongovernmental organizations.

EPA also has met with federal agencies, including the U.S. Department of Energy and the U.S. Department of Agriculture, which have programs relevant to GHG emissions. On April 10, 2009 (74 FR 16448), EPA proposed the GHGRP . EPA held two public hearings, and received m ore than 16,000 written public comments. The public comment period ended on June 9, 2009. Comments related to Subpart W were received from more than 80 entities with over 1,200 pages of comments, recommendations, and alternatives for
consideration. Details about these meetings and the responses to comments are available in the docket (EPA

- HQ

- OAR

- 2009

- 0923). Following promulgation of the final 2010 subpart W rule

, EPA finalized actions revising subpart W (76 FR 22825, April 25, 2011; 76 FR 59533, September 2 7, 2011; 76 FR 80554, December 23, 2011; 77 FR 51477, August 24, 2012; 78 FR 25392, May 1, 2013; 78 FR 71904, Nov. 29, 2013). In the current action, the EPA is revisin g some of the GHG reporting requirements for the petroleum and natural gas systems sourc e category. The changes include revis ing calculation methods, amend ing monitoring and data reporting requirements, clarify ing terms and definitions,
and correct ing technical and editorial errors identified during the course of implementation. The revisions were identified from the verification of annual reports, review of Best Available Monitoring Method (BAMM) request submittals, and questions raised by reporting e ntities. In conjunction with this action, we are finalizing confidentiality determinations for the new and substantially revised data elements contained in these amendments ; we are also revising the confidentiality determination for one existing data eleme nt

.

3 (d) Effects of Less Frequent Collection
The frequency for reporting emissions information to EPA under the GHGRP was originally established to minimize the burden on owners and operators of affected facilities

, while ensuring that the GHGRP collects facility

- specific data of sufficient quality to achieve the

A gency’s objectives

. T he GHGRP r equire s annual reporting , except for a limited nu mber of facilities that are already subject to more frequent reporting requirements. This reporting frequency remains the same in these revisions to Part 98.

A nnual reporting will ensure that data are verified and made available to the public, as authorized by the CAA. If the information collection were not carried out on this schedule, t he Agency will not be able to develop an informed tracking system of trends in GHG emissions across the country.

3(e) General Guidelines This collection is consistent with all OMB guidelines under 5 CFR 1320. 5

.

Page 6 November 20143(f) Confidentiality
Data collected under the GHGRP must be made available to the public unless the data qualify for CBI treatment under the CAA and EPA regulations. The CAA precludes “emission data” from being treated as confidential. For data reported under the CAA that are not emission data, E PA typically makes CBI determinations under 40 CFR 2.301 on a case

- by

- case basis. Due to the large number of entities reporting under the GHGRP and the large number of data reporting elements, EPA previously concluded that case

- by

- case determinations will not result in timely release of emission and other non

- CBI data (see proposed CBI rule, July 7, 2010, 75 FR
39094 and final CBI rule, May 26, 2011, 76 FR 30782 ). For this reason, the EPA has made CBI determinations for most data reporting elements through a series of rulemakings that specify which data reporting elements in Part 98: (1) are CBI, (2) are non

- CBI, and (3) are emission data (i.e., ineligible for CBI protection). All data determined by EPA to be CBI are safeguarded in accordance with regulation s in 40 CFR Chapter 1, Part 2, Subpart B. The CBI determinations for subpart W data reporting elements (excluding data reporting elements used as inputs to emission calculations) were made in 77 FR 48072, August 13, 2012. The reporting of data elements use d as inputs to emission calculations were addressed in 79 FR 63750, October 24, 2014. In the current action, the EPA is finalizing confidentiality determinations for the new and substantially revised data elements contained in these amendments; we are also revising a confidentiality determination for one existing data element.

3(g) Sensitive Questions
The revisions to reporting or recordkeeping requirements in the revisions to Part 98 do not include sensitive questions.

Page 7 November 20144. THE RESPONDENTS AND THE INFORMATION REQUESTED The respondents in this information collection include owners and operators of petroleum and natural gas systems facilities that must report their GHG emissions to EPA to comply with Part 98, subpart W

. T his section provides a list of industry sectors that must comply with the rule, the data elements required of program participants

, and the activities in which participants

must engage to collect, assess, calculate, and in some cases submit the required data elements

.

4(a) Respondents/ North American Industrial Classification System (NAICS) Codes
The revisions to P art 98 affect facilities subject to subpart W

. R eporting facilities for Subpart W include , but are not limited to

, those operating one or more units that exceed the CO 2 e threshold for the industry sectors listed below (and listed in Table A

- 3 of 40 CFR 98.2(a)(1) )

. Industry sectors are listed by the corresponding subpart of P art 98 and NAICS code for
reference. The NAICS cod es are not exhaustive, but rather provide a list of facilities likely to be
affected.

Part and Subpart NAICS code(s) 40 CFR Part 98
W. Petroleum and Natural Gas Systems 486210 Pipeline transportation of natural gas. 221210 Natural gas distribution. 211111 Crude petroleum and natural gas extraction. 211112 Natural gas liquid extraction.

Page 8 November 20144(b) Information Requested (i) Data Items

. EPA is finalizing th e addition of 2 4 7 data elements , the deletion of 3 4
data elements

, and the substantial revis ion of 1 3 data elements that are currently required to be reported under the rule. T able A

- 1 of Appendix A specifies each new data element that will be reported by industry segment . Table A

- 2 of Appendix A specifies each substantially revised data
element that will be reported by industry segment

. Table A

- 3 of Appendix A specifies each deleted data element by industry segment. (ii) Respondent Activities

. The owner or operator of a facility that is subject to the subpart W reporting requirements must repo rt total annual GHG emissions. The primary tasks that reporting program respondents perform include:
1. Implement ing and updat ing , as necessary, appropriate monitoring plans for each affected source and each affected unit at a source, as applicable;
2. Co nducting o peration and maintenance activities associated with the monitoring, including quality assurance activities;
3. Ensuring data quality, preparing annual reports of emission data, and submitting these reports to EPA;
4. Potentially responding to q uestions or error messages from EPA; and
5. Maintaining records for a minimum of three years. Respondents that use CEMS also conduct tests to certify the operations of monitors, submit the results of these tests, and record emission data (this activity ge nerally is performed electronically). Reports must present the annual mass GHG emissions from each subpart W industry
segment separately. EPA is revis ing the units of emissions reported in 40 CFR 98.236 to require reporting in metric tons of methane (CH 4 ), CO 2 , and nitrous oxide (N 2 O), as applicable, instead of reporting each gas in metric tons of CO 2 e . EPA is also revis ing certain calculation methods that require the calculation of emissions in CO 2 e

. The calculations used to determine GHG emissions, the fr equency at which those calculations are required, and the methods used to estimate missing data depend on the specific subpart W industry segment

. (ii i ) Electronic Reporting

. Respondents report all data electronically through the
Electronic Greenhouse Gas Reporting Tool (e

- GGRT )

. All new and revised data elements will be reported in the same way. As the e

- GGRT accounts are already established, the only burden related to electronic reporting will be entering the data elements

.

Page 9 November 20145. THE INFORMATION COLLECTED

– AGENCY ACTIVITIES, COLLECTION
METHOD S , AND INFORMATION MANAGEMENT

5(a) Agency Activities EPA Headquarters activities include the monitoring and verification of emission reports, database and software maintenance, communication and outreach, an d program evaluation. This ICR reflects an incremental agency burden for program operation activities, which include monitoring and v erification of emission reports. Specifically, the additional burden for
the review of new and revised data elements was es timated.

5 (b) Collection Methodology and Management
To collect data currently reported under the GHGRP, EPA previously establish ed a central repository of inventory data for all respondents called the Electronic Greenhouse Gas Reporting Tool ( e

- GGRT )

. Respondents report da ta electronically, and EPA store s the data in the
database. The e

- GGRT system provides a user interface for entering the GHG data and also has an XML reporting schema that allow s facilities to upload GHG data directly

. Under the revisi ons

to P art 98, facilities subject to subpart W listed in section 4(a) w ill report the new data elements
and revised data elements via e

- GGRT.
The e

- GGRT system follows Agency standards for design, security, data element and reporting format conformance, and accessibility. EPA designed the system in an attempt to minimize respondents’ burden by integrating the new reporting requirements with existing data collection and data management systems, when feasible

.

5(c) Small Entity Flexibility
This information collection will not have a significant economic impact on a substantial number of small entities. Nonetheless, EPA has tried to reduce the impact of this information
collection on small entities

. As part of the process of finalization of the final 2010 subpart W rule (75 FR 74458, November 30, 2010) , the EPA determined appropriate thresholds that reduced the number of small businesses reporting and conducted several meetings with industry associations to discuss regulato ry options and the corresponding burden on industry, such as recordkeeping and reporting. T he EPA continues to conduct significant outreach on the GHG reporting rule and maintains an “open door” policy for stakeholders to help inform the EPA’s understandin g of key
issues for the industries.

5(d) Collection Schedule
All data elements under this information collection will be submitted on an annual basis as part of the respondent’s annual report required under Part 98.

Page 10 November 20146. ESTIMATING THE BURDEN AND COST OF THE COLLECTION This section presents EPA’s estimates of the burden and costs to respondents associated
with the activities described in section 4 as well as the federal burden hours and costs associated
with the activities described in s ection 5(a)

. Section 6(a) provides estimates of burden ( hours ) for all respondent types. Section 6(b) contains estimates of respondent costs for the information
collection. Section 6(c) summarizes federal burden and costs. Section 6(d) descr ibes the respondent universe and the total burden and cost of this collection to respondents. Section 6(e) presents the bottom line burden and cost. Section 6(f) provides reasons for any change in burden.
The burden statement for this information collectio n is in s ection 6( g ).

6(a) Estimating Respondent Burden Respondent burden estimates are presented in Exhibit 6.1. EPA estimates that the total
annual burden to all affected entities is approximately 24 4, 000 hours per year over the three years covered by this information collection. Exhibit 6.1 presents aggregate burden and burden by subpart W industry segment . For details of the burden calculations, please see Appendix B

.

6(b) Estimating Respondent Costs ( i) Estimating Labor Costs

. Labor c osts to respondents associated with this information
collection include the amount of labor for facility staff to gather data, conduct analyses and calculations, and report the results

. To calculate labor costs, EP A estimat ed Bureau of Labor Statistics using an approach consistent with the ICRs associated with the GHGRP currently approved by OMB

. 1 For all subpart W industry segments the labor rates are : $121.72 for senior managers, $106.89 for middle managers, $ 78.29 for engineers, and $66.57 for technicians

. EPA estimates that the total annual cost to all affected non

- federal entities is $ 22. 0 million over the three year s covered by this information collection. Exhibit 6.1 presents
aggregate costs and costs by subpart W industry segment . For details of EPA’s cost calculations, please see Appendix C

. The information collection will result in an overall increase in annual
burden of approximately 7, 7 0 0 hours and $ 60 3 ,000

. This increase is split between the eight subpart W industry segments as shown in Exhibit 6.2.

(ii) Estimating Annualized Capital Costs and Operations and Maintenance (O&M) Costs

. Th e amendments to subpart W that are included in this information collection affect only the labor costs. Capital and O&M costs have not changed from ICR Number 2300.12

.

1 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.relea se/archives/ecec_09082011.pdf).

Page 11 November 2014Exhibit 6.1 Annual Average Respondent Burden and Cost f or Subpart W of the GHGRP

Subpart W Industry Segment No. Respondents Responses/ Respondent Total Responses (1) Burden

- Technical

(hrs) Burden

- Managerial (hrs) Total
Burden

(hrs) Total Labor
Cost ($) Capital
Cost ($) O&M Cost ($) Total Cost ($)

Onshore Petroleum and
Natural Gas Production 1,033 2 2,066 81, 1 1 5 20,809 10 1,9 24 $8, 60 0, 681 $59 ,206 $0 $8,6 59, 886

Offshore Petroleum and
Natural Gas Production 72 2 130 2,15 3 1,074 3,2 27 $28 5,779 $0 $0 $28 5,779

Onshore Natural Gas Processing 291 2 398 22, 7 92 3,287 2 6

, 0 78 $2,0 3 5

, 807 $23 2,860 $124 ,257 $2,3 9 2,924

Onshore Natural Gas
Transmission Compression 1,152 2 1,501 70, 843 7,128 7 7,971 $5,9 4 3,128 $39 7,539 $1,161 ,170 $7, 50 1,838

Underground Natural Gas Storage 139 2 224 10, 5 9 0 2,107 12, 697 $ 1,00 3, 059 $6 5,803 $115 ,189 $1,18 4, 051

Natural Gas Distribution 159 1 159 17, 8 62 1,247 1 9, 10 9 $1,3 90, 860 $23 ,267 $254 ,082 $1,6 6 8,209

LNG Import and Export Equipment 4 1 4 3 3 1 43 3 7 3 $29

, 496 $2 ,400 $ 7,823 $39

, 7 1 8

LNG Storage 35 2 70 2,3 79 6 49 3,0 29 $2 50, 085 $1 4,883 $27 ,434 $2 92, 401

TOTAL 2,885 Varies 4,55 2 20 8, 066 36,3 44 24 4
, 4 10 $19, 5 38,894 $79 5,957 $1,6 89,954 $2 2
, 0 2 4,805

(1 ) Total responses equal the number of responses due to reporting of process emissions plus the number of responses due to repor ting combustion emissions. The total responses do not equal the number of respondents multiplied by the number of responses per re spondent because process emissions and combustion emissions are not applicable to the same number of respondents. See Appendi x C for the number of respondents applicable to each by industry segment

.

Page 12 November 2014Exhibit 6. 2 Annual Average Change in Respondent Burden and Cost f or Subpart W of the GHGRP

Subpart W Industry Segment Change In Change In Change In Change In

Total Burden Burden Total Cost Cost (Technical Labor Hours) (Technical Labor Hours / Respondent) ($) ($ / Respondent)

Onshore Petroleum and Natural Gas Production 1 4, 1 71 4. 0 4 $3 2 5, 678 $3 1 5

Offshore Petroleum and Natural Gas Production 2 7 0.1 0 $ 564 $ 8
Onshore Natural Gas Processing 3 5 84 2.01 $ 4 6,766 $1 61
Onshore Natural Gas Transmission Compression 4 2, 465 2. 1 4 $1 9 4,183 $1 69
Underground Natural Gas Storage 5 2 48 1. 7 8 $ 19,597 $1 4 1

Natural Gas Distribution 6 1 22 0. 7 7 $ 9, 585 $ 60
LNG Import and Export Equipment 7 6 1. 57 $ 5 02 $ 1 2 5

LNG Storage 8 7 4 2. 1 2 $ 6, 603 $ 1 89

TOTAL 7, 677

--- $ 60 3,478

---
1 For Onshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 97,754 hours to 10 1 ,9 24 hours, which increased the total cost from $8,334,208 to $8,6 59, 886

. 2 For Offshore Petroleum and Natural Gas Production, the technica l labor hour burden increased from 3,220 hours to 3,227 hours, which increased the total cost from $285,215 to $285,779.

3 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

. 4 For Onshore Natural Gas Transmission Compression, 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

. 5 For Underground Natur al 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

. 6 For Natural Gas Distribution, the technical labor hour burden increased from 18,986 hours to 1 9, 10 9 hours, which increased the total cost from $1,658,624 to $1,6 6 8,209

. 7 For LNG Import 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

. 8 For LNG Storage, the technical labor hour burden increased from 2,954 hours to 3,0 29 hours, which increased the total cost from $285,799 to $2 92, 401

.

Page 13 November 20146(c) Estima ting Agency Burden and Cost
This section describes the burden and cost to the federal government associated with this
information collection . Federal activities under this information collection include EPA Headquarters oversight of the reporting program.

(i) EPA burden and cost

. EPA activities associated with the mandatory GHG reporting rule include Headquarters oversight and implementation of the reporting program, e.g., monitoring and verification of emission reports, database and software maintenance, communication and outreach, and program evaluation. EPA estimates that, in implementing subpart W, Headquarters will incur a burden of 4 full time equivalents (FTEs), or approximately $4 36 ,000 for these activities per year

. There are no incremental burden increases due to these revisions to subpart W

. To develop EPA labor costs, EPA estimates the average hourly labor rate for salary and overhead and benefits for Agency staff to be $52.37. To derive this figure, EPA multiplied the hourly compensation at GS

- 12, Step 5 on the 2011 GS pay scale ($32.73) by the standard government benefits multiplication factor of 1.6 to account for overhead and benefits.

(ii) Burden and cost for federal facilities covered by the rule

. Exhibit 6.3 presents the
annual burden and cost for federal facilities that must comply with the rule.

Exhibit 6.3 Annual Agency Burden and Cost

Information Collection Activity Annual Responses Total Annual Burden Hours Labor Cost Non

- Labor Cost Total Annual

Cost

W. Petroleum and Natural Gas Systems 1 8

, 320 $43 5,718 $ 0 $ 435,718

TOTAL 1 8

, 320 $43 5,718 $ 0 $ 435,718

6(d) Estimating the Respondent Universe and Total Burden and Costs The number of respondents in each subpart W industry sector that will perform the required activities under this information collection is presented in Exhibit 6.1.

6(e) Bottom Line Burden Hours and Costs
The bottom line burden hours and costs are shown in Exhibit 6. 4

.

Page 14 November 2014Exhibit 6. 4 Bottom Line Annual Burden and Cost

Number of Respondents 2,885 From Exhibit 6.1

Total Annual Responses 4,55 2 From Exhibit 6.1

Number of Responses per Respondent 1.6 Total annual responses from above ÷ Total respondents from above

Total Respondent Hours 24 4

, 4 10 From Exhibit 6.1

Hours per Response 53. 7 Total annual hours from above ÷ Total respondents from above

Annual O&M and Capital Cost ($) 2,48 5,912 From Exhibit 6.1

Total Respondent Cost ($) 2 2

, 0 2 4,805 From Exhibit 6.1

Total Hours (Respondents and Agency) 2 5 2

, 7 30 Total respondent hours from above + Total EPA hours

Total Cost (Respondents and Agency) ($) 2 2

, 4 6 0,524 Total respondent cost from above + Total
EPA cost

Note: Detail may not add exactly to total due to independent rounding.

6(f) Reasons for Change in Burden
This rule will result in an overall increase in annual burden of approximately 7, 7 0 0 hours and $ 60 3

, 00 0 (labor costs). Specific respondent activities that impose either a reduction or
increa se in burden and costs due to EPA’s revisions to subpart W are identified below and reviewed in more detail in Appendix B

.

Reporting New Data Elements . For each of the 2 4 7 new data elements required to be reported (see section 4(b)(i) and Appendix A ), respondents will be required to calculate the data element using readily available data, and submit the value via e

- GGRT as part of the annual report currently required under Part 98. This revision is an increase to burden and cost.

Reporting Revised Data Elements . For each of the 1 3 revised data elements required to be reported (see section 4(b)(i)), respondents will be required to calculate the data element using readily available data, and submit the value via e

- GGRT as part of the annual report cu rrently required under Part 98. This revision is an increase to burden and cost.

Deleted Data Elements

. EPA is delet ing 34 d ata elements that are currently required to be reported (see section 4(b)(i)), respondents will no longer be required to calculate the data
element and submit the value via e

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

. This revision is a reduction to burden and cost.

Page 15 November 2014Gas Well Completions And Workovers . EPA is revis ing reporting requirements for completions an d workovers to differentiate between completions and workovers with different well type combinations in each sub

- basin category. EPA is clarifying the number of measurements or calculations that must be taken to estimate the average ratio of flowback rate (FRM). Respondents may have to conduct more tests/measurements because a separate FRM value is required for each well type combination

. This revision is an increase to burden and cost.

Gas Well Venting During Completions Or Workovers From Hydraulic Fractu ring
Calculation . 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 natu ral gas emitted during the initial flowback stage of a well when insufficient gas is present to enable separation and metering. In addition, the EPA is modify ing Equation W

- 10A to ensure respondents only account for sales gas volume once in this calculatio n. The method is similar in complexity as the previous method and uses measurements that are of similar complexity. Therefore, t h is change will not impose any additional (or reduced) burden and costs.

Gas Well Venting During Completions Or Workovers Witho ut Hydraulic Fracturing
Calculation . 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 calculatio n of emissions from workovers from the calculation of completions into two equations. Respondents will have to perform two calculations as opposed to one; however, it is the same calculation that respondents are currently doing only being broken into two s teps. T h is change will not impose any additional (or reduced)
burden and costs.

Flare Stack Emissions Calculation . EPA is revis ing the calculation and reporting requirements for onshore natural gas transmission compression, underground natural gas storag e, LNG storage, and LNG import and export to include emissions from flare stacks. Facilities that
had flares formerly did not have to report flare stack emissions , but will now need to collect flare data, calculate, and report these emissions. This revision is an increase to burden and cost.

Monitoring Group Of Manifolded Compressor Sources . EPA is revis ing the monitoring requirements so that, in cases where multiple compressor sources are manifolded together downstream, respondents can measu re downstream of the manifold and will not have to measure the compressor sources individually . For manifolded compressors, reporters will also have to report activity data for the manifold ( e.g., number of compressor sources manifolded together
and mode o f each compressor). Respondents are no longer required to annually measure compressor sources th at are manifolded individually. I nstead

, respondents will measure the

Page 16 November 2014manifolded group of compressor sources once per year. Therefore, this change is a burden

r eduction for respondents that have two or more compressor sources manifolded together.

Calculation For Compressor Sources Vented To Flare . EPA is remov ing vented compressor emissions that go to a flare from the compressor emissions total (clarifying that these emissions should be reported in the flared emissions total) and retain the requirement to report uncontrolled vented emissions from compressors. Respondents are no longer required to perform individual compressor leak measurements or continuous meas urements, but rather perform a single calculation under the flare stack emissions methodology

. The latter is less burdensome
because it only requires respondents to either continuously monitor total flow and composition to
the flare , or use engineering est imates.

Triennial Testing Of Compressors . EPA is 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 depressurized shutd own (for centrifugal compressors) or at the next scheduled shutdown when the compressor rod packing is replaced (for reciprocating compressors). Even though the “not

- operating

- depressurized

- mode” is only measured at scheduled shutdowns (which might be ever y three years or greater), the reporter is still required to conduct an annual measurement in whatever mode the compressor is found. Therefore, the frequency in measurements is unchanged

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

Pneumatic Devices Calculation

. EPA is simplifying the procedure for determining the counts of pneumatic devices operating each year

. 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 i s change will not impose any additional (o r reduced) burden and costs.

Liquids Unloading Calculation . EPA is modify ing the liquids unloading calculation to The EPA is modify ing the liquids unloading calculation to annualize venting data for facilities
that use Calculation Method 1. The EPA is al so revising Calculation Method 1 at 40 CFR 98.233(f)(1) to separate the calculation and reporting of emissions from wells that have plunger lifts and wells that do not have plunger lifts

. The impacts assessment assumed that Calculation
Method 2 and Calcula tion Method 3 are lower

- burden options than Calculation Method 1 and that reporters will choose the lower

- burden option. While th e changes to Calculation Method 1
will increase facility flexibility, no changes were made to Calculation Method 2 or Calculati on Method 3. Therefore, these change s will not impose any additional (or reduced) burden and

costs.

Page 17 November 2014Blowdown Vent Stacks Calculation By Equipment . EPA is revis ing the calculation for “unique physical volume” so respondents can report emissions from blow down vent stacks by equipment instead of by "unique physical volume

. " Although respondents are no longer required to report blowdown vent stack emissions by each "unique physical volume

, " respondents still
have to calculate blowdown vent stack emissions fr om each "unique physical volume

. ”

T herefore, this change will not impose any additional (or reduced) burden and costs.

Blowdown Vent Stacks Calculation Compressibility Term . EPA is allowing the optional

use of a compressibility factor in Equations W

- 14A, W

- 14B, W

- 33 and W

- 34 . As at proposal,
the use of a default value is assumed to be the option with the lowest reporter burden and this change will not impose any additional (or reduced) burden and costs

.

Blowdown Vent Stacks Direct Meas urement . 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 re porters that currently measure blowdown emissions, because they cou ld simply report 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 therefore the EPA estimated that this change

wou ld 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

.

Associated Gas Venting And Flaring Calculation . EPA is modify ing the calculation method for associated gas venting and flaring to account for situations where part of the gas is going to the sales line. T he calculation method modifies the current equation to include a new

term for the volume of sales gas, which is alre ady 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 finalizing the addition of the proposed term “EREp,q” for emissions reported under other sources

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

Above Grade Metering

- Regulating Stations Calculation . EPA is finalizing technical revisions to the natural gas distribution segment to clarify the calculation methodologies and

rep orting requirements for above grade metering

- regulating stations. The rule clarifies that respondents only calculate 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

. T hese changes
will not impose any additional (or reduced) burden and costs.

Page 18 November 2014BAMM

. As a change from proposal, t he EPA is revising 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, changes to transitional
BAMM do not c hange the burden associated with the methods of s ubpart W.

6( g ) Burden Statement The respondent reporting burden for this collection of information is estimated to

average 24 4

, 410 hours per year for a three year period, where identical annual costs are anticipated for all three years . The average annual burden to EPA for this period is estimated to
be 8,320 hours for oversight activities. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 53. 7 hours per response

. Burden means the total time, effort, or financial r esources expended by persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. This includes the time needed to review instructions; develop , acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any prev iously applicable instructions and requirements; train personnel to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduc t or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB
control numbers for EPA’s regulations are listed in 40 CFR Part 9

. To comment on the Agency's need for th is 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

- 2011

- 0512 , which is available for online viewing at http:// www.regulations.gov, or in person viewing at the Air and Radiation docket in the EPA Docket Center (EPA/DC), William Jefferson Clinton Federal Building

- West, Room 3334 , 1301 Constitution Avenue, NW, Washington, D.C. 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 Air and Radiation docket is (202) 566

- 1742. An electronic version of the public docket is
available at http:// www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the publi c docket, and to access those documents in the public docket that are available electronically. When in the system, select

Page 19 November 2014“search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA
Docket ID Number EPA

- HQ

- OAR

- 2011

- 0512 and OMB Control Number 2060

- 0629 on any correspondence

.

PART B of the Sup porting Statement

This section is not applicable because statistical methods are not used in data collection
associated with the final amendments.

Page 20 November 2014