Appendix B

Detailed Unit Burden and Costs

Petroleum and Natural Gas Systems (Subpart W)
B-1a Onshore Petroleum and Natural Gas Production

LABOR, AVERAGE ONSHORE PRODUCTION FACILITY (PROCESS EMISSIONS ONLY)

Activity

Labor Hours

Labor Cost per Year per 

Reporting Unit/Facility 

Engineer Technician (2011$)

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 1.37 0.00 0.16 0.36 $165

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 9.00 0.00 0.19 0.50 $781

Sampling and Analysis 

(Calculations) (1) 33.17 0.00 0.00 2.00 $2,811

Reporting (2) 23.15 0.00 0.09 5.00 $2,358

Total 66.68 0.00 0.44 7.86 $6,115

(1) Labor hours adjusted upwards to reflect revisions to the calculation requirements for completions and workovers with hydraulic fracturing (to 

differentiate between completions and workovers with different well type combinations in each sub-basin category). Based on 2012 subpart 

W data reported to EPA as of September 1, 2013, 40% of onshore production facilities report completion/workover emissions; and 23% of 

facilities with completions/workovers would have additional measurements. Assume 2 additional measurements per facility; and 8 

engineering hrs / measurement. Hour increase = (40%) * (23%) * 2 * 8.

(2) There are 121 new data elements, 8 revised data elements, and 16 deleted data elements for this industry segment. However, not all facilities 

report data for each emission source. Therefore, based on 2012 subpart W data reported to EPA as of September 1, 2013, the average number 

of data elements per facility is 60 new, 3 revised, and 12 deleted data elements. Labor hours adjusted by 3 minutes per data element to 

account for the new, revised, and deleted data elements.

NON-LABOR, AVERAGE ONSHORE PRODUCTION FACILITY (PROCESS EMISSIONS ONLY)

Activity

Capital 

Cost

Equipment 

Lifetime 

(years)

Discount 

Rate (%)

Annualized 

Capital Cost

O&M 

Costs

Total Non 

Labor Cost 

(2011$)

Equipment (select, purchase, install) $0 5 7% $0 $0

Equipment (select, purchase, install) $0 1 $0 $0

Performance testing

Recordkeeping $235 5 7% $57 $57

Travel $0 $0

Total $235 $57 $0 $57

LABOR, AVERAGE ONSHORE PRODUCTION FACILITY (COMBUSTION) 

Activity

Labor Hours

Labor Cost per Year 

per Reporting 

Unit/Facility (2011$)

Technical (1) Management (2)

72.43 114.31

Develop QA & Monitoring Plan 0.00 0.00 $0

Annual Activities 11.84 11.84 $2,211

Total 11.84 11.84 $2,211

(1) Rate for technical is an average of engineer and senior operator.

(2) Rate for manager is an average of senior and middle manager.

B-2
B-1b Offshore Petroleum and Natural Gas Production

LABOR, AVERAGE OFFSHORE FACILITY (PROCESS EMISSIONS ONLY)

Activity

Labor Hours Labor Cost 

per Year per 

Reporting 

Unit/Facility 

(2011$)

Engineer Technician

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 10.26 0.00 1.03 2.07 $1,150

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 0.42 0.00 0.03 0.06 $43

Sampling and Analysis 

(Calculations) 0.15 0.00 0.00 0.00 $12

Reporting (1) 9.54 0.00 0.17 2.02 $984

Total 20.37 0.00 1.23 4.15 $2,188

(1) There are 2 new data elements, 0 revised data elements, and 0 deleted data elements for this industry segment.

LABOR, AVERAGE OFFSHORE FACILITY (COMBUSTION) 

Activity

Labor Hours Labor Cost per 

Year per 

Reporting 

Unit/Facility 

(2011$)

Technical (1) Management (2)

72.43 114.31

Develop QA & Monitoring Plan 0.00 0.00 $0

Travel 11.84 11.84 $2,211

Total 11.84 11.84 $2,211

(1) Rate for technical is an average of engineer and senior operator.

(2) Rate for manager is an average of senior and middle manager.

B-3
B-1c. Onshore Natural Gas Processing

LABOR, AVERAGE PROCESSING FACILITY (PROCESS EMISSIONS ONLY)

Activity

Labor Hours

Labor Cost 

per Year 

per 

Reporting 

Unit/Facilit

y (2011$)

Engineer Technician

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 1.91 0.00 0.18 0.36 $210

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 6.28 0.00 0.42 0.72 $620

Sampling and Analysis (Calculations) (1,2) 9.21 30.75 0.00 2.00 $2,982

Reporting (3) 25.82 0.00 0.11 3.16 $2,372

Total 43.22 30.75 0.70 6.24 $6,183

(1) Labor hours adjusted to reflect savings due to revisions for manifolded compressors. Based on 2012 subpart W data reported to EPA as of 

September 1, 2013, the avg. # compressors per facility is 8. Using engineering estimates, the # facilities with manifolded vents are estimated to 

be 10% of total # facilities in industry segment. Assume 10 minutes for technician to take measurement & 30 minutes for engineer to perform 

calculation; 1 measurement per manifold. Hour reduction = (10%) * (8-1) * (10 min or 30 min / 60).

(2) Labor hours adjusted to reflect savings due to revisions for compressors controlled with flares. Based on 2012 subpart W data reported to EPA 

as of September 1, 2013, the # facilities with flares is 21% of total # facilities in industry segment; the avg. # compressors per facility 

estimated to be 8; and 69% of the compressors at these facilities are venting to flares. Assume 10 minutes for technician to take measurement 

& 20 minutes for engineer to perform calculation. Hour reduction = (21%) * (69%) * 8 * (10 min or 20 min / 60).

(3) There are 121 new data elements, 4 revised data elements, and 18 deleted data elements for this industry segment. However, not all facilities 

report data for each emission source. Therefore, based on 2012 subpart W data reported to EPA as of September 1, 2013, the average number 

of data elements per facility is 73 new, 2 revised, and 11 deleted data elements. Labor hours adjusted by 3 minutes per data element to account 

for the new, revised, and deleted data elements.

NON-LABOR, AVERAGE PROCESSING FACILITY (PROCESS EMISSIONS ONLY)

Activity

Capital 

Cost

Equipment 

Lifetime 

(years)

Discount 

Rate (%)

Annualized 

Capital 

Cost

O&M 

Costs

Total Non 

Labor Cost 

(2011$)

Equipment (select, purchase, install) $3,046 5 7% $743 $743

Equipment (select, purchase, install) $0

Performance testing

Recordkeeping $235 5 7% $57 $57

Travel $427 $427

Total $3,281 $800 $427 $1,227

LABOR, AVERAGE GAS PROCESSING FACILITY (COMBUSTION) 

Activity

Labor Hours

Labor Cost per Year per Reporting 

Unit/Facility (2011$)

Technical (1) Management (2)

72.43 114.31

Develop QA & Monitoring Plan 0.00 0.00 $0

Travel 11.84 11.84 $2,211

Total 11.84 11.84 $2,211

(1) Rate for technical is an average of engineer and senior operator.

(2) Rate for manager is an average of senior and middle manager.

B-4
B-1d. Onshore Natural Gas Transmission Compression

LABOR, AVERAGE COMPRESSOR STATION (PROCESS EMISSIONS ONLY)

Activity

Labor Hours Labor Cost per 

Year per 

Reporting 

Unit/Facility 

(2011$)

Engineer Technician

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 0.07 0.00 0.00 0.01 $6

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 2.49 0.00 0.08 0.09 $214

Sampling and Analysis (Calculations) (1,2,3) 7.40 27.62 0.00 2.00 $2,632

Reporting (4) 20.33 0.00 0.00 0.42 $1,636

Total 30.29 27.62 0.08 2.52 $4,489

(1) Labor hours adjusted to reflect savings due to revisions for manifolded compressors. Based on 2012 subpart W data reported to EPA as of 

September 1, 2013, the avg. # compressors per facility is 6. Using engineering estimates, the # facilities with manifolded vents are estimated to 

be 10% of total # facilities in industry segment. Assume 10 minutes for technician to take measurement & 30 minutes for engineer to perform 

calculation; 1 measurement per manifold. Hour reduction = (10%) * (6-1) * (10 min or 30 min / 60).

(2) Labor hours adjusted to reflect savings due to revisions for compressors controlled with flares. Based on 2012 subpart W data reported to EPA 

as of September 1, 2013, the # facilities with flares is 1% of total # facilities in industry segment; the avg. # compressors per facility estimated 

to be 6; and 92% of the compressors at these facilities are venting to flares. Assume 10 minutes for technician to take measurement & 20 

minutes for engineer to perform calculation. Hour reduction = (1%) * (92%) * 6 * (10 min or 20 min / 60).

(3) Labor hours adjusted to reflect inclusion of estimating emissions from other flare stacks. Assume 1% of facilities would have other flare stacks 

(same as % reporting flares for compressors), with 20 minutes to collect data and estimate emissions.

(4) There are 98 new data elements, 2 revised data elements, and 16 deleted data elements for this industry segment. However, not all facilities 

report data for each emission source. Therefore, based on 2012 subpart W data reported to EPA as of September 1, 2013, the average number 

of data elements per facility is 61 new, 1 revised, and 12 deleted data elements. Labor hours adjusted by 3 minutes per data element to account 

for the new, revised, and deleted data elements.

NON-LABOR, AVERAGE COMPRESSOR STATION (PROCESS EMISSIONS ONLY)

Activity

Capital 

Cost

Equipment 

Lifetime 

(years)

Discount 

Rate (%)

Annualized 

Capital Cost

O&M 

Costs

Total Non 

Labor Cost 

(2011$)

Equipment (select, purchase, install) $1,385 5 7% $338 $0 $338

Equipment (select, purchase, install)

Performance testing

Recordkeeping $30 5 7% $7 $7

Travel $1,008 $1,008

Total $1,415 $345 $1,008 $1,353

LABOR, AVERAGE GAS COMPRESSOR STATION (COMBUSTION) 

Activity

Labor Hours

Labor Cost per Year per 

Reporting Unit/Facility (2011$)

Technical (1) Management (2)

72.43 114.31

Develop QA & Monitoring Plan 0.00 0.00 $0

Travel 11.84 11.84 $2,211

Total 11.84 11.84 $2,211

(1) Rate for technical is an average of engineer and senior operator.

(2) Rate for manager is an average of senior and middle manager.

B-5
B-1e Underground Natural Gas Storage

LABOR, AVERAGE STORAGE FACILITY (PROCESS EMISSIONS ONLY)

Activity

Labor Hours Labor Cost per 

Year per 

Reporting 

Unit/Facility 

(2011$)

Engineer Technician

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 2.44 0.00 0.08 0.49 $252

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 5.44 0.00 0.43 0.65 $548

Sampling and Analysis (Calculations) (1,2) 6.61 33.22 0.00 3.00 $3,050

Reporting (3) 21.23 0.00 0.11 3.17 $2,014

Total 35.73 33.22 0.62 7.30 $5,864

(1) Labor hours adjusted to reflect savings due to revisions for manifolded compressors. Based on 2012 subpart W data reported to EPA as of 

September 1, 2013, the avg. # compressors per facility is 8. Using engineering estimates, the # facilities with manifolded vents are estimated 

to be 10% of total # facilities in industry segment. Assume 10 minutes for technician to take measurement & 30 minutes for engineer to 

perform calculation; 1 measurement per manifold. Hour reduction = (10%) * (8-1) * (10 min or 30 min / 60).

(2) Labor hours not adjusted to reflect inclusion of estimating emissions from other flare stacks. Assume 0% of facilities would have other flare 

stacks (same as % reporting flares for compressors).

(3) There are 81 new data elements, 2 revised data elements, and 9 deleted data elements for this industry segment. However, not all facilities 

report data for each emission source. Therefore, based on 2012 subpart W data reported to EPA as of September 1, 2013, the average number 

of data elements per facility is 48 new, 1 revised, and 4 deleted data elements. Labor hours adjusted by 3 minutes per data element to account 

for the new, revised, and deleted data elements.

NON-LABOR, AVERAGE STORAGE FACILITY (PROCESS EMISSIONS ONLY)

Activity

Capital 

Cost

Equipment 

Lifetime 

(years)

Discount 

Rate (%)

Annualized 

Capital Cost

O&M 

Costs

Total Non 

Labor Cost 

(2011$)

Equipment (select, purchase, install) $1,810 5 7% $441 $0 $441

Equipment (select, purchase, install) $0

Performance testing

Recordkeeping $131 5 7% $32 $32

Travel $829 $829

Total $1,941 $10 $0 $473 $829 $1,302

LABOR, AVERAGE STORAGE FACILITY (COMBUSTION) 

Activity

Labor Hours

Labor Cost per Year per Reporting 

Unit/Facility (2011$)

Technical (1) Management (2)

72.43 114.31

Develop QA & Monitoring Plan 0.00 0.00 $0

Travel 11.84 11.84 $2,211

Total 11.84 11.84 $2,211

(1) Rate for technical is an average of engineer and senior operator.

(2) Rate for manager is an average of senior and middle manager.

B-6
B-1f. Natural Gas Distribution

LABOR, AVERAGE LDC FACILITY (PROCESS EMISSIONS ONLY)

Activity

Labor Hours

Labor Cost per Year per Reporting 

Engineer Technician Unit/Facility (2011$)

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 2.41 0.00 0.08 0.48 $250

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 5.13 0.00 0.42 0.64 $521

Sampling and Analysis 

(Calculations) 9.75 76.34 0.00 3.00 $6,166

Reporting (1) 18.71 0.00 0.11 3.12 $1,811

Total 36.00 76.34 0.61 7.24 $8,748

(1) There are 28 new data elements, 3 revised data elements, and 1 deleted data elements for this industry segment. However, not all facilities 

report data for each emission source. Therefore, based on 2012 subpart W data reported to EPA as of September 1, 2013, the average number 

of data elements per facility is 14 new, 1 revised, and 0 deleted data elements. Labor hours adjusted by 3 minutes per data element to account 

for the new, revised, and deleted data elements.

NON-LABOR, AVERAGE LDC FACILITY (PROCESS EMISSIONS ONLY)

Activity

Capital 

Cost

Equipment 

Lifetime 

(years)

Discount 

Rate (%)

Annualized 

Capital Cost

O&M 

Costs

Total Non 

Labor 

Cost 

(2011$)

Equipment (select, purchase, install) $365 5 7% $89 $89

Equipment (select, purchase, install)

Performance testing 5

Recordkeeping $235 7% $57 $57

Travel $1,598 $1,598

Total $600 $146 $1,598 $1,744

B-7
B-1g. LNG Import and Export Equipment

LABOR, AVERAGE LNG IMPORT/EXPORT FACILITY (PROCESS EMISSIONS ONLY)

Activity

Labor Hours Labor Cost per 

Year per 

Reporting 

Unit/Facility 

(2011$)

Engineer Technician

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 2.43 0.00 0.08 0.51 $254

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 6.00 0.00 0.40 0.60 $583

Sampling and Analysis (Calculations) (1,2,3) 23.26 21.31 0.00 5.00 $3,774

Reporting (4) 29.68 0.00 0.10 4.00 $2,763

Total 61.36 21.31 0.58 10.11 $7,374

(1) Labor hours adjusted to reflect savings due to revisions for manifolded compressors. Based on 2012 subpart W data reported to EPA as of 

September 1, 2013, the avg. # compressors per facility is 5. Using engineering estimates, the # facilities with manifolded vents are estimated

to be 10% of total # facilities in industry segment. Assume 10 minutes for technician to take measurement & 30 minutes for engineer to 

perform calculation; 1 measurement per manifold. Hour reduction = (10%) * (5-1) * (10 min or 30 min / 60).

(2) Labor hours adjusted to reflect savings due to revisions for compressors controlled with flares. Based on 2012 subpart W data reported to EPA 

as of September 1, 2013, the # facilities with flares is 14% of total # facilities in industry segment; the avg. # compressors per facility 

estimated to be 5; and 100% of the compressors at these facilities are venting to flares. Assume 10 minutes for technician to take 

measurement & 20 minutes for engineer to perform calculation. Hour reduction = (14%) * (100%) * 6 * (10 min or 20 min / 60).

(3) Labor hours adjusted to reflect inclusion of estimating emissions from other flare stacks. Assume 50% of facilities would have other flare 

stacks (same as % reporting flares for compressors), with 20 minutes to collect data and estimate emissions.

(4) There are 85 new data elements, 2 revised data elements, and 16 deleted data elements for this industry segment. However, not all facilities 

report data for each emission source. Therefore, based on 2012 subpart W data reported to EPA as of September 1, 2013, the average number 

of data elements per facility is 55 new, 1 revised, and 11 deleted data elements. Labor hours adjusted by 3 minutes per data element to 

account for the new, revised, and deleted data elements.

NON-LABOR, AVERAGE LNG IMPORT/EXPORT FACILITY (PROCESS EMISSIONS ONLY)

Activity

Capital 

Cost

Equipment 

Lifetime 

(years)

Discount 

Rate (%)

Annualized 

Capital 

Cost

O&M 

Costs

Total Non 

Labor Cost 

(2011$)

Equipment (select, purchase, install) $2,381 5 7% $581 $581

Equipment (select, purchase, install)

Performance testing

Recordkeeping $78 5 7% $19 $19

Travel $1,956 $1,956

Total $2,460 $600 $1,956 $2,556

LABOR, AVERAGE LNG IMPORT/EXPORT FACILITY (COMBUSTION) 

Activity

Labor Hours Labor Cost per Year 

per Reporting 

Unit/Facility (2011$)

Technical (1) Management (2)

72.43 114.31

Develop QA & Monitoring Plan 0.00 0.00 $0

Travel 11.84 11.84 $2,211

Total 11.84 11.84 $2,211

(1) Rate for technical is an average of engineer and senior operator.

(2) Rate for manager is an average of senior and middle manager.

B-8
B-1h LNG Storage

LABOR, AVERAGE LNG STORAGE FACILITY (PROCESS EMISSIONS ONLY)

Activity

Labor Hours Labor Cost per 

Year per 

Reporting 

Unit/Facility 

(2011$)

Engineer Technician

Senior 

Manager

Middle 

Manager

78.29 66.57 121.72 106.89

Planning 2.42 0.00 0.08 0.47 $249

QA/QC 0.00 0.00 0.00 0.00 $0

Recordkeeping 4.49 0.00 0.42 0.64 $471

Sampling and Analysis (Calculations) (1) 14.30 15.98 0.00 1.88 $2,384

Reporting (2,3) 18.95 0.00 0.11 3.12 $1,830

Total 40.16 15.98 0.61 6.11 $4,934

(1) Labor hours not adjusted to reflect inclusion of estimating emissions from other flare stacks. Assume 0% of facilities would have other flare 

stacks (same as % reporting flares for compressors), with 20 minutes to collect data and estimate emissions.

(2) Labor hours adjusted to reflect savings due to revisions for manifolded compressors. Based on 2012 subpart W data, the avg. # compressors 

per facility is 4. Using engineering estimates, the # facilities with manifolded vents are estimated to be 10% of total # facilities in industry 

segment. Assume 10 minutes for technician to take measurement & 30 minutes for engineer to perform calculation; 1 measurement per 

manifold. Hour reduction = (10%) * (4-1) * (10 min or 30 min / 60).

(3) There are 78 new data elements, 2 revised data elements, and 9 deleted data elements for this industry segment. However, not all facilities 

report data for each emission source. Therefore, based on 2012 subpart W data reported to EPA as of September 1, 2013, the average number 

of data elements per facility is 18 new, 0 revised, and 1 deleted data elements. Labor hours adjusted by 3 minutes per data element to account 

for the new and deleted data elements.

NON-LABOR, AVERAGE LNG STORAGE FACILITY (PROCESS EMISSIONS ONLY)

Activity

Capital 

Cost

Equipment 

Lifetime 

(years)

Discount 

Rate (%)

Annualized 

Capital Cost

O&M 

Costs

Total Non 

Labor Cost 

(2011$)

Equipment (select, purchase, install) $1,509 5 7% $368 $368

Equipment (select, purchase, install) $0 1 7% $0 $0

Performance testing

Recordkeeping $235 5 7% $57 $57

Travel $784 $784

Total $1,744 $425 $784 $1,209

LABOR, AVERAGE LNG STORAGE FACILITY (COMBUSTION) 

Activity

Labor Hours

Labor Cost per 

Year per Reporting 

Unit/Facility (2011$)

Technical (1) Management (2)

72.43 114.31

Develop QA & Monitoring Plan 0.00 0.00 $0

Travel 11.84 11.84 $2,211

Total 11.84 11.84 $2,211

(1) Rate for technical is an average of engineer and senior operator.

(2) Rate for manager is an average of senior and middle manager.

B-9