Page 1 February 2014 SUPPORTING STATEMENT ENVIRONMENTAL PRO TECTION AGENCY

Information Collection Request for the Greenhouse Gas Reporting Program (Greenhouse Gas Reporting Rule: Revisions a nd Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection Greenhouse Gas Reporting Program (Greenhous e Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule); OMB control number 2060-0629; ICR number 2300.15.

1(b) Short Charact erization/Abstract In response to the FY2008 Consolidated A ppropriations 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) . The Greenhouse Gas Reporting Rule is referred to as 40 CFR Part 98 (Part 98) and impl ementation of Part 98 is referred to as the Greenhouse Gas Reporting Program (GHGRP). This supporting statem ent addresses information

collection activities that would be imposed by “Greenhouse Ga s Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule” (hereafter referred to as the “proposed revisions”). Part 98, which became effective on December 29, 2009, requires that certain facilities and suppliers emitting above certain thre shold levels of carbon dioxide (CO 2 ) equivalent (CO 2 e) monitor and report emissions of greenhouse gase s (GHGs). A subsequent rule was published on November 30, 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). EPA is proposing to clarify certain terms a nd definitions, and correct certain technical

and editorial errors that have been identifie d during the course of implementation; these proposed revisions are not expected to substant ively affect respondent burden. EPA is also proposing to revise certain calcu lation methods, and amend certai n monitoring and data reportingPage 2 February 2014 requirements; some of these proposed revisions may affect respondent burden. See Section 4(b) and Appendix A for a complete list of propos ed revisions to the reporting requirements. Compared with the estimated respondent burde n identified in the information collection for the Greenhouse Gas Reporting Program (GHGRP) currently approved by Office of Management and Budget (OMB), this proposed in formation collection will result in an overall increase in annual burden of 6,920 hours and $5 43,000 (labor costs), as shown in Section 6.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection The EPA is proposing this information colle ction under its existing Clean Air Act (CAA) authority provided in CAA section 114. As stated in the October 30, 2009 preamble to Part 98 (74 FR 56260), CAA section 114(a)(1) provides EPA broad authority to re quire the information proposed to be gathered by Part 98 because such data would inform and are relevant to EPA’s carrying out a wide variety of CAA provisions. Additionally, signed into law on December 26, 2007, the FY2008 Consolidated Appropriations Act di rected 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 enact ment of this Act, to requir e mandatory reporting of greenhouse gas emissions above appropriate th resholds in all sectors of the economy of the United States.” Sections 114 and 208 of the CAA provide EP A authority to requi re the information mandated by the GHGRP because such data will in form and are relevant to future policy decisions. CAA section 114(a)(1) authorizes the Admi nistrator to require emissions sources, persons subject to the CAA, or persons whom the Administrator believes may have necessary information to report emissions and provide such other information the Administrator requests for the purposes of carrying out any provision of the CAA. For these reasons, the Administrator may request that a person, on a one-time, periodic or continuous basis, establish and maintain records, make reports, and, among other things, pr ovide such information the Administrator may reasonably require. Because EPA does not yet know the specific policies that will be adopted, the data reported under the GHGRP is of suffi cient quality to inform policy and program development.Page 3 February 2014 2(b) Practical Utilit y/Users of the Data

The GHGRP information collection collects info rmation from facilities that directly emit GHGs and from suppliers of products that rel ease GHGs if combusted, oxidized, or used. The comprehensive GHG data reported directly from la rge facilities and supplie rs across the country are now easily accessible to the public at: http://ghgdata.e pa.gov/ghgp/main.do . Reporting entities use uniform methods for estimating emissi ons, which enables data to be compared and analyzed. Data collection in the GHGRP complement s the Inventory of U.S. Greenhouse Gas Emissions and Sinks (Inventory) and can help EPA transition to use of the 2006 Intergovernmental Panel on Climate Change (IPCC) Guidelines for National Greenhouse Gas Inventories. This data resource also provides a critical tool for communities to identify nearby sources of GHGs and provide informati on to state and local governments. The standardization of GHG data provides busin esses with the necessary information to benchmark themselves against similar facilities , better understand their relative standing within their industry, and achieve and disseminate thei r environmental achievements. Businesses and

other innovators 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 tec hnologies to protect public he alth and the environment. The facility-specific GHG emissions data im prove 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 corp orate level in order to tr ack emission trends from industries, within industries, and across industrie s over time, particularly in response to policies and potential regulations. Subpart W data can be used to inform a nu mber of different types of analyses. For example, it can complement atmospheric GHG studies and inform updates to emission inventories. Numerous activity da ta are collected that can be used to improve understanding of the occurrence of emissions from a variety of sources. The GHGRP is not intended to be a survey and the respondents affected by the program are not intended to be a statistical sample of a larger universe of entities.Page 4 February 2014 3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION

CRITERIA

3(a) Nonduplication The new information proposed to be collected under the proposed revisions are 245 new data elements and 15 substantially revised data elements (refer to section 4(b) and Appendix A for a list of these data elements). These proposed new and substantially revised data elements consist primarily of quantities that provide in formation on the activity level at the facility, emission factors used, charac teristics of carbon-containing streams, and other process information that would provide key informati on for verification, includ ing confirming that emissions are appropriate for a given activity-lev el and estimating expected emissions based on data provided. These proposed new and substa ntially revised reporti ng elements, described above, are the same types of industry data curre ntly collected under the GHGRP. EPA previously evaluated these types of industry data currently collected under Part 98, a nd concluded that they do not duplicate other information collections, as described below. This conclusion, as described below, applies to the proposed new and subs tantially revised data elements as well. In developing the GHGRP, EPA review ed monitoring methods, including:

 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 regional GHG reporting programs, such as The Climate Registry, the Regional Greenhouse Gas Initiative, the Western Regional Air Partnership, and programs in several states including Calif ornia, New Mexico, Connecticut, and New Jersey;

 Reporting protocols developed by nongovernment al organizations, such as the World Resources Institute/World Business C ouncil for Sustainable Development;

 Programs from industrial trade organizations , such as the Interstate Natural Gas Association of America’s GHG Emission Estimation Guidelines, the American Petroleum Institute’s Compendium of GHG Estimation Methodologies for the Oil and Gas Industry, and the World Business Council for Sustainable Development’s Cement Sustainability Initiative’s CO 2 Accounting and Reporting Standard for the Cement Industry; andPage 5 February 2014  IPCC Guidelines for National Gr eenhouse Gas Inventories.

These programs led the way in reporting of GHG emissions before the federal government acted and assisted in quantifying the GHG reductions achieve d by various policies. Many of these programs collect different or add itional data as compared to the GHGRP and this proposal. 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 supplements and complements, rather than duplicates, existing programs’ data. Further, EPA has made significant efforts over the past four years to facilitate the reporting in the event a sing le entity has to report both the federal and state level. For example, EPA has supported effort s by the California Air Resources Board to harmonize the reporting of information under Calif ornia’s Global Warming Solutions Act, AB32 with EPA’s GHGRP. The product of the collaborati on is referred to as California Electronic Greenhouse Gas Reporting T ool, or Cal e-GGRT.

Documentation of EPA’s review of GHG mon itoring 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-2008-0508-056. For further discussion on the relationship of the GHGRP to other programs, please refer to the preambles of each of the GHGRP rulemakings (which can be found in the docket at EP A-HQ-OAR-2008-0508), the June 6, 2008 memorandum entitled Review of Existing Programs (which can be found in the docket at EPA-HQ-OAR-2008- 0508-0052), and the January 27, 2009 memorandu m entitled Review of Existing State Greenhouse Gas Reporting Rules (which can be found in the docke t at EPA-HQ-OAR-2008- 0508-0054). Some GHG programs are described below:

 A number of EPA’s voluntary partnership programs include a GHG emissions and/or reductions reporting component (e.g., Natura l Gas STAR program, etc.). However, the GHGRP has much broader coverage th an the voluntary programs and therefore helps EPA learn more about emissions fr om facilities not included in current programs.

 EPA reviewed the Inventory, which is an annual comprehensive top-down assessment of national greenhouses gas emissions. While the Inventory is generally compiled from national surveys (i.e., not broken down at the geographic or facility level), the GHGRP focuses on bottom-up data from individual facilities that exceed appropriate thresholds. The bottom-up approach to data collection in the GHGRP can help reduce uncertainty in emissions estimates for sp ecific industries, and more broadly, helpsPage 6 February 2014 EPA transition to use of the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, which will be required to meet international reporting obligations under the United Nations Framework Convention on Climate Change in the near future.

As noted in the current ICR for the GHGRP, a number of programs at the state, tribal, territorial, and local level requir e emission sources in their respective jurisdictions to monitor and report GHG emissions. To reduce burden on reporters and program agencies, the Agency plans to share reported data, with the exception of any information determined to be Confidential Business Information (CBI), with relevant agenci es 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 Informat ion Collection Request (ICR) Submissions to

OMB A public notice of this collection is provi ded in the Federal Register notice of ”Greenhouse Gas Reporting Rule: Revisions and C onfidentiality Determinations for Petroleum and Natural Gas Systems; Proposed 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 pol icy for those interested in discussing the rulemaking. Since January 2008, EPA staff has held more than 100 meetings with stakeholders, including:

 Trade associations and firms in poten tially affected industries/sectors;

 State, local, and tribal environmental c ontrol agencies and regional air quality planning organizations;

 State and regional organizations alre ady involved in GHG emissions reporting, such as The Climate Registry, Californi a Air Resources Board, and the Western Climate Initiative; and

 Environmental groups and other nongovernmental organizations.Page 7 February 2014 EPA also has met with federal agencies, incl uding 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 more than 16,000 written public comment s. The public comment period ended on June 9, 2009. Subpart W received comments from more than 80 entities with over 1,200 pages of comments, recommen dations, 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 subpa rt W rule, EPA finalized actions revising subpart W (76 FR 22825, April 25, 2011; 76 FR 59533, September 27, 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 proposing to make certain revisions to the petroleum and natural gas systems source category GHG reporting requirements. The proposed changes revise certain calculation methods, amend certain monito ring and data reporting requirements, clarify certain terms and definitions, and correct certain technical and edito rial errors identified during the course of implementation. The proposed revisi ons were identified from the verification of annual reports, review of Best Available Moni toring Method (BAMM) request submittals, and questions raised by reporting en tities. In conjunction with this action, we are proposing confidentiality determinations for the new and s ubstantially revised data elements contained in these proposed amendments; we are also proposin g a revised confidentiality determination for one existing data element.

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 coll ects facility-specific data of su fficient quality to achieve the Agency’s objectives. The GHGRP requires annu al reporting, except for a limited number of facilities that are already subj ect to more frequent reporting requirements. This reporting frequency remains the same in thes e proposed revisions to Part 98. Annual reporting will ensure that data are verified and made available to the public, as authorized by the CAA, and use the data for the purposes described in section 2(b). If thePage 8 February 2014 information collection were not car ried out on this schedule, the Agency would not be able to develop an informed tracking system of tr ends in GHG emissions across the country.

3(e) General Guidelines

This collection of information is consis tent with all OMB guidelines under 5 CFR

1320.6.

3(f) Confidentiality

Data collected under the GHGRP must be ma de available to the public unless the data qualify for CBI treatment under the CAA and EP A regulations. The CAA precludes “emission data” from being treated as confidential. For da ta reported under the C AA that are not emission data, EPA typically makes CBI determinations under 40 CFR 2.301 on a case-by-case basis. Due to the large number of entit ies reporting under the GHGRP and the large number of data reporting elements, EPA previously concluded that case-by-case de terminations would not result in timely release of emission and other non-CBI data (see proposed CBI rule, July 7, 2010, 75 FR 39094). For this reason, the EPA has made CB I determinations for most data reporting elements through a series of rulemakings that spec ify 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 regulations in 40 CFR Chapter 1, Part 2, Subpart B. The CBI determinations for subpart W data reporting elements (excluding data reporting elements used as inpu ts to emission calculations) were made in 77 FR 48072, August 13, 2012. In the current action, the EPA is proposing confidentiality determinations for the new and substantially revi sed data elements contained in these proposed amendments; we are also proposing a revised conf identiality determination for one existing data

element.

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

4. THE RESPONDENTS AND THE INFORMATION REQUESTEDPage 9 February 2014 The respondents in this information collecti on include owners and ope rators of petroleum and natural gas systems facilities that must re port their GHG emissions to EPA to comply with Part 98, subpart W. This section provides a list of industry sectors that must comply with the rule, the data elements required of program partic ipants, and the activities in which participants must engage to collect, assess, calculate, and in some cases su bmit the required data elements.

4(a) Respondents/North Ameri can Industrial Classificati on System (NAICS) Codes The proposed revisions to Part 98 affect f acilities subject to th e subpart W. Reporting facilities for Subpart W include, but are not limited to, those opera ting one or more units that

exceed the CO 2 e threshold for the industry sectors list ed below (and listed in Table A-3 of 40 CFR 98.2(a)(1)). Industry sectors are listed by th e corresponding subpart of Part 98 and NAICS

code for reference. The NAICS codes are not exhaus tive, 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 transporta tion of natural gas. 221210 Natural gas distribution. 211111 Crude petroleum and natural gas extraction. 211112 Natural gas liquid extraction.

4(b) Information Requested (i) Data Items. EPA is proposing that 245 new data elements be reported. EPA is also proposing to delete 63 data elements and substant ial revise15 data elements that are currently required to be reported under the rule. Table 1 of Appendix A specifies each new data element that would be reported by industry segment. Ta ble 2 of Appendix A specifies each substantially revised data element that would be reporte d by industry segment. Table 3 of Appendix A specifies each deleted data element by industry segment. (ii) Respondent Activities . The owner or operator of a facil ity that is subject to the Part 98, subpart W’s reporting requirements must re port total annual GHG emissions. The primary tasks that reporting program respondents perform include: 1. Implement and update, as necessary, appropriate monitoring plans for each

affected source and each affected unit at a source, as applicable;Page 10 February 2014 2. Operation and maintenan ce activities associated w ith the monitoring, including quality assurance activities; 3. Ensuring data quality, preparing annual reports of emissions data, and submitting these reports to EPA; 4. Potentially responding to questions or error messages from EPA; and 5. Maintaining records for a minimum of three years. Respondents that use CEMS also conduct test s to certify the operations of monitors, submit the results of these tests, and record emi ssions data (this activity generally is performed electronically). Reports must present the annual mass GHG em issions from each subpart W industry segment separately. EPA is proposing to revise the units of emissions reported in 40 CFR 98.236 to require reporting in metr ic 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 proposing to revise certain calculation methods that requi re the calculation of emissions in CO 2 e. The calculations used to determine GHG emissions, the frequenc y at which those calculations are required, the methods used to estimate missing data, and the QA/QC requirements depend on the specific subpart W industry segment.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION METHODS, AND INFORMATION MANAGEMENT

5(a) Agency Activities EPA Headquarters activities include the mon itoring and verification of emission reports, database and software maintenance, communi cation and outreach, and program evaluation. This ICR reflects an incremental agency bur den for program operation activities, which include monitoring and verification of emission re ports. Specifically, the additional burden for

the review of new and revised data elements was estimated.

5(b) Collection Methodology and Management To collect data currently reported under the GHGRP, EPA previously established a central repository of inventory data for all respondents called the El ectronic Greenhouse GasPage 11 February 2014 Reporting Tool (e-GGRT). Respondents report data electronically, and EPA st ores the data in the database. The e-GGRT system has an XML reporti ng schema that allows facilities to upload GHG data directly in lieu of using the web forms provided through e-GGRT. Under the proposed revisions to Part 98, facilities subject to subpa rt W listed in section 4(a) would report the proposed new data elements and revi sed data elements via e-GGRT. The e-GGRT system follows Agency standard s 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 finaliza tion of the final subpart W rule, the EPA took several steps to evaluate the effect of the rule on sma ll entities. For example, the EPA determined appropriate thresholds that redu ced the number of small businesses reporting. In addition, the EPA conducted severa l meetings with industry associ ations to discuss regulatory options and the corresponding burden on industry, such as recordkeeping and reporting. Finally,

the EPA continues to conduct significant outreach on the GHG re porting rule and maintains an “open door” policy for stakeholders to help inform the EPA’s understanding of key issues for the

industries.

5(d) Collection Schedule

All data elements under this information collection would be submitted on an annual basis as part of the respondent’s annual report required under Part 98.

6. ESTIMATING THE BURDEN A ND COST OF THE COLLECTION This section presents EPA’s estimates of th e burden and costs to respondents associated

with the activities described in section 4 as well as the federa l burden hours and costs associated

with the activities described in section 5(a). Section 6(a) provides estimates of burden (hours) for all respondent types. Section 6(b) contains estimates of respo ndent costs for the informationPage 12 February 2014 collection. Section 6(c) summar izes federal burden and costs. Section 6(d) describes the respondent universe and the total bu rden and cost of this collecti on to respondents. Section 6(e) presents the bottom line burden and cost. Section 6(f) provides reasons fo r any change in burden.

The burden statement for this informa tion collection is in section 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 243,652 h ours 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 burd en calculations, please see Appendix B.

6(b) Estimating Respondent Costs Costs to respondents associated with this information collect ion include labor costs (i.e., the cost of labor by facility staff to meet th e rule’s information collection requirements). To calculate labor costs, EPA estimated Bureau of Labor Statistics using an approach consistent with the ICRs associated with the GHGRP currently approved by OMB. 1 For all industry segments the labor rates are: $121.72 for se nior managers, $106.89 for middle managers, $78.29 for engineers, $66.57 for technicians.

EPA estimates that the total annual cost to all affected non-federal entities is $22.1 million over the three years covered by this information collection. Exhibit 6.1 presents aggregate costs and costs by subpart W industry segment. For detail s of EPA’s cost calculations, please see Appendix C. The proposed information co llection will result in an overall increase in annual burden of 6,920 hours and $543,000. This increase is split between the eight subpart W industry segments as shown in Exhibit 6.2.

1 May 2011 National Industry-Specific Occupatio nal Employment a nd 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.rel ease/archives/ecec_09082011.pdf).Page 13 February 2014Exhibit 6.1 Annual Average Respondent Burden and CostFor Subpart W of the GHGRPSubpartWIndustrySegmentNo.Respond‐entsResponses/RespondentTotalResponses(1)Burden‐Technical(hrs)Burden‐Managerial(hrs)Burden‐Clerical(hrs)Burden‐Legal(hrs)TotalBurden(hrs)TotalLaborCost($K)CapitalCost($K)O&MCost($K)TotalCost($K)OnshoreNaturalGasProcessing291239822,6253,2870025,912$2,023$233$124$2,380OnshoreNaturalGasTransmissionCompression1,15221,50170,5997,1280077,727$5,924$398$1,161$7,482UndergroundNaturalGasStorage139222410,5392,1070012,646$999$66$115$1,180LNGImportandExportEquipment4243264300368$29$2$8$39OnshorePetroleumandNaturalGasProduction1,03322,06681,00620,80900101,816$8,592$59$0$8,651NaturalGasDistribution159215917,7321,2470018,979$1,381$23$254$1,658LNGStorage352682,347626002,973$245$15$27$287OffshorePetroleumandNaturalGasProduction7221302,1571,074003,231$286$0$0$286TOTAL2,885Varies4,550207,33236,32000243,652$19,478$796$1,690$21,964(1)Total responses equal the number of responses due to reporting ofprocess emissions plus the number of responses due to reporting combustion emissions. The totalresponses do not equal the numberof respondents multiplied by the number of responses per respondent because process emissions and combustion emissions are notapplicable to the same number of respondents. See Appendix C for thenumber of respondents applicableto each by industry segment.Page 14 February 2014Exhibit 6.2 Annual Average Change in Respondent Burden and CostFor Subpart W of the GHGRPSubpart W Industry SegmentChange InChange InChange InChange InTotal BurdenBurdenTotal CostCost(Technical LaborHours)(Technical LaborHours / Respondent)($)($ / Respondent)Onshore Natural Gas Processing1417 1.43 $33,612 $116Onshore Natural Gas Transmission Compression22,221 1.93 $174,662 $152Underground Natural Gas Storage3197 1.42 $15,552 $112LNG Import and Export Equipment41 0.33 $125 $31Onshore Petroleum and Natural Gas Production54,062 3.93 $317,186 $307Natural Gas Distribution6-8 -0.05 -$622 -$4LNG Storage718 0.52 $1,507 $43Offshore Petroleum and Natural Gas Production811 0.15 $846 $12TOTAL 6,920 --- $542,868 ---1For onshore natural gas processing, the technical labor hourburden increased from 25,495 hours to 25,912 hours, which increased the total cost from $2,346,000 to $2,380,000.2For onshore natural gas transmission compression, the technical labor hour burden increased from 75,506 hours to 77,727 hours,which increased the total cost from $7,554,000to $7,482,000.3For underground natural gas storage, thetechnical labor hour burdenincreased from 12,450 hours to 12,646 hours, which increased the total cost from $1,164,000 to $1,180,000.4For LNG import and export equipment, thetechnical labor hour burden increased from 367 hours to 368 hours, which increased thetotal cost from $39,200 to $39,300.5For onshore petroleum and natural gas production, the technical labor hour burden increased from 97,754 hours to 101,816 hours,which increased the total cost from $8,334,000to $8,651,000.6For natural gas distribution, the technical labor hour burdenincreased from 18,986 hours to 18,979 hours, which increased thetotal cost from $1,659,000 to $1,658,000.7For liquefied natural gas (LNG) storage, the technical laborhour burden increased from 2,954 hours to 2,973 hours, which increased the total cost from $286,000 to $287,000.8For offshore petroleum and natural gas production, the technical labor hour burden increased from 3,220 hours to 3,231 hours, which increased the total cost from $285,000 to$286,000Page 15 January 2014 6(c) Estimating Agency Burden and Cost

This section describes the burden and cost to the federal government associated with this

information collection. Federal activities under this inform ation collection include EPA Headquarters oversight of the reporting program.

EPA burden and cost

EPA activities associated with the mandato ry GHG reporting rule include Headquarters oversight and implementation of the reporting program, e.g., monitoring and verification of emission reports, database and software mainte nance, communication and outreach, and program evaluation. EPA estimates that, in implemen ting subpart W, Headquarters will incur an incremental burden of 4 full time equivalents (FTEs), or just $436,000 for these activities. To develop EPA labor costs, EPA estimates th e 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. In addition to the labor cost, EPA will incur an incremental cost of just under $800 thousand in each of the first three years for third-party verification.

Burden and cost for federal faci lities 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 ($K)

Information Collection Activity Annual Responses Total Annual Burden Hours Labor Cost ($K) Non-Labor Cost ($K) Total Annual

Cost ($K)

W. Petroleum and Natural Gas Systems 1 8320 $436 $783 $1,200

TOTAL 1 8320 $436 $783 $1,200Page 16 January 2014 6(d) Estimating the Respondent Un iverse and Total Burden and Costs The number of respondents in each subpart W industry sector that will perform the required activities under this informati on 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.

Exhibit 6.4 Bottom Line Annual Burden and Cost

Number of Respondents 2,885 From Exhibit 6.1

Total Annual Responses 4,550 From Exhibit 6.1

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

Total respondents from above

Total Respondent Hours 243,652 From Exhibit 6.1

Hours per Response 53.5 Total annual hours from above ÷

Total respondents from above

Annual O&M and Capital Cost ($K) 2,486 From Exhibit 6.1

Total Respondent Cost (labor + non) ($K) 21,964 From Exhibit 6.1

Total Hours (Respondents and Agency) 29.3 Total respondent hours from above ÷

Total EPA hours

Total Cost (Respondents and Agency) ($K) 18.3 Total respondent cost from above ÷

Total EPA hours

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

6(f) Reasons for Change in Burden This proposed rule will result in an overall increase in annual burden of 6,920 hours and $543,000 (labor costs). Specific resp ondent activities that impose either a reduction or increasePage 17 January 2014 in burden and costs due to EPA’s proposed revisi ons to Part 98, subpart W are identified below and reviewed in more detail in Appendix B. Reporting Proposed New Data Elements . For each of the 245 new data elements required to be reported (see section 4(b) (i)), respondents would be required to calculate the data element using readily available data, and submit the va lue via e-GGRT as part of the annual report currently required under Part 98. This proposed re vision is an increase to burden and cost. Reporting Proposed Revised Data Elements . For each of the 15 revised data elements required to be reported (see section 4(b)(i)), resp ondents would be required to calculate the data element using readily available data, and subm it the value via e-GGRT as part of the annual report currently required under Part 98. This proposed revision is an increas e to burden and cost.

Deleted Data Elements . EPA is proposing to delete 63 da ta elements that are currently required to be reported (see section 4(b)(i)), resp ondents would 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 proposed revision is a reduction to burden and cost. Completions And Workovers . EPA is proposing to revise reporting requirements for completions and workovers to differentiate betw een completions and workovers with different well type combinations in each sub-basin category. EPA is clarif ying the number of

measurements or calculations that must be take n 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. This propos ed revision is an increa se to burden and cost.

Flare Stack Emissions Calculation . EPA is proposing to revise the calculation and reporting requirements for onshore natural gas transmission compression, underground natural gas storage, LNG storage, and LNG import and e xport to include emissions from flare stacks.

Facilities that had flares former ly did not have to report flare stack emissions, but will now need to collect flare data, calculate, and report these emissions. This pr oposed revision is an increase

to burden and cost. Monitoring Group Of Manifolded Compressor Sources . EPA is proposing to revise the monitoring requirements so that, in cases wher e multiple compressor sources are manifolded together downstream, respondents can measure dow nstream of the manifold and would not have to measure the compressor sources individually. For manifolded compressors, reporters will also have to report activity data for the manifold (i.e. number of compressor sources manifoldedPage 18 January 2014 together, mode of each compre ssor). Respondents are no longer required to annually measure compressor sources that are manifolded indi vidually. Instead, respondents would measure the manifolded group of compressor sour ces three times per year. Theref ore, this proposed change is a burden reduction for respondents that have mo re than three compressor sources manifolded together. Calculation For Compressor Sources Vented To Flare . EPA is proposing to remove vented compressor emissions that go to a flar e from the compressor emissions total (clarifying that these emissions should be repo rted in the flared emissions to tal) and retain the requirement to report uncontrolled vented emissions from compressors. Respondents are no longer required to perform individual compressor leak measurem ents or continuous measurements, but rather perform a single calculation unde r the flare stack emissions methodology. The latter is less burdensome since it only requires respondents to either continuously monitor total flow and composition to the flare, or use engineering estimates. Other respondent activities that are associat ed with EPA’s proposed revisions to Part 98, subpart W and do not impose any additional (or reduced) burden and costs are discussed below. Site-Specific Composition Data Fo r Pneumatic Devices Calculation . EPA is proposing to allow either the use of site-specific compositi on data for natural gas transmission compression and underground natural gas storag e facilities or the use of a default gas composition. The

calculation still must be conducted in much the sa me way that is curren tly required; however, respondents are now allowed to use site-specific data if it is available. Liquids Unloading Calculation . EPA is proposing to modify the liquids unloading calculation to allow flexibility for metered da ta that does not exactly correspond to a given reporting year (i.e. January 1st to December 31st) . While this modification increases facility flexibility, the calculation still must be conduc ted in much the same way that is currently required. Gas Well Venting During Completions Or Workovers Following Hydraulic Fracturing

Calculation . EPA is proposing to modify Equation W-10A (which is a calculation that determines annual volumetric total gas emissions from gas well venting during completions or workovers following hydraulic fr acturing) in order to enable quantification, as opposed to measurement, of natural gas emitted during the initi al flowback stage of a well when insufficient gas is present to enable sepa ration and metering. In addition, the EPA is proposing to modifyPage 19 January 2014 Equation W-10A to ensure respondents only account for sales gas volume once in this calculation. The proposed method is similar in co mplexity as the previous method and uses measurements that are of similar complexity. Gas Well Venting During Completions Or Workovers Without Hydraulic Fracturing

Calculation . EPA is proposing to revise 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 calculat ion of emissions from workovers from the calculation of completions into two equatio ns. Respondents will have to perform two calculations as opposed to one; however, it is th e same calculation that respondents are currently doing only being broken into two steps. Blowdown Vent Stacks Calculation By Equipment . EPA is proposing to revise the calculation for “unique physical volume” so re spondents can report emissions from blowdown 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 from each "unique physical

volume."

Blowdown Vent Stacks Calcul ation Compressibility Term . EPA is proposing to add a compressibility term to the blowdown vent stack calculations. It is anti cipated that respondents handle gas within the proposed comp ressibility factor default ranges; therefore, it is unlikely that adding this compressibility factor term into th e blowdown vent stack calculations will increase burden to respondents.

Blowdown Vent Stacks Direct Measurement . EPA is proposing to allow an option to directly measure blowdown emissions in li eu of performing "unique physical volume" calculations. Although this option may decrease bu rden for those responden ts that currently do this because they could simply report thes e measured emissions (without the burden of performing calculations), it is un likely that facilities directly measure a ll of their "unique physical volumes.” Associated Gas Venting And Flaring Calculation . EPA is proposing to modify the calculation method for associated gas venting and fl aring to account for situ ations where part of the gas is going to the sales li ne and part of the gas emissions are reported under other emission sources included in this subpart (i.e., tank venting). The resp ondents still have to perform aPage 20 January 2014 similar calculation to what is currently being required. Alth ough the proposed calculation method modifies the current equation to include two new terms, these new terms are already being calculated elsewhere and/or can be estimated. Triennial Testing Of Compressors . EPA is proposing that compressors not measured in the “not-operating-depressurized-mode” for over th ree years, must be measured in the “notoperating-depressurized-mode” at the next schedu led depressurized shutdown (for centrifugal compressors) or at the next scheduled shutdow n when the compressor rod packing is replaced (for reciprocating compressors). Even though th e “not-operating-depres surized-mode” is only measured at scheduled shutdowns (which might be every three years or gr eater), the reporter is still required to conduct an annual measuremen t in whatever mode the compressor is found. Therefore, the frequency in measurements is unchanged. Above Grade Metering-Regula ting Stations Calculation . EPA is proposing technical revisions to the natural gas di stribution segment to clarify the calculation methodologies and reporting requirements for above grade metering- regulating stations. EPA is clarifying that respondents only calculate two emission factors (one for CO 2 and one for CH 4 ) for meter/regulator runs instead of separate em ission factors for all component types. Missing Data Methods . Except for missing data that are continuously monitored or measured (for example flow meters), or for mi ssing temperature or pressure data, a complete record of all estimated and/or measured parame ters used in the GHG emissions calculations is required by the current rule. EPA is proposing cer tain ways that respondents can substitute a value for certain specific missing estimated a nd/or measured parameters. In addition, for respondents who are newly subject to subpart W in a given reporting year and for respondents who acquire wells during a reportin g year that were not subject to subpart W prior to the acquisition, EPA is proposing to a llow the use of best engineering estimates for any parameter that cannot be reasonably measur ed or obtained according to the requirements in subpart W for up to six months from the first date of subpart W applicability.

BAMM . EPA is proposing to remove all provisions in 40 CFR 98.234(f) for BAMM. BAMM is designed to be a temporary flexibility mechanism and not a permanent option in the rule. Therefore, removing BAMM does not change the burden associated with the methods of Subpart W.Page 21 January 2014 6(g) Burden Statement The respondent reporting burden for this collection of information is estimated to average 243,652 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 activit ies. The annual public reporti ng and recordkeeping burden for

this collection of informa tion is estimated to aver age 53.5 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or di sclose or provide information to or for a federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instruct ions and requirements; train personnel to respond to a collection of information; search data s ources; complete and re view the collection of information; and transmit or othe rwise disclose the information. An agency may not conduct or sponsor, a nd 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 this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA–HQ– OAR–2011-0512, which is available for online viewing at http://www.regulations.gov, or in person viewing at the Air a nd Radiation docket in the EPA Docket Center (EPA/DC), William Jefferson C linton Federal Building - West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EP A Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday thro ugh 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 s ite can be used to submit or view public comments, access the index listing of the conten ts of the public docke t, and to access those documents in the public docket that are availabl e electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments toPage 22 January 2014 the Office of Information and Regulatory Affair s, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503 , Attention: Desk Officer fo r EPA. Please include the EPA

Docket ID Number EPA– HQ–OAR–2011-0512 and OMB Control Number 2060-0629 on any correspondence.