Page 1 January 2016 SUPPORTING STATEMENT ENVIRONMENTAL PRO TECTION AGENCY

Greenhouse Gas Reporting Rule: Leak Detection Methodology Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule (40 CFR Part 98, subpart W) January 2016

Part 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 Leak Detection Methodology Revisions and Confidentiality Determinati ons for 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
2300.19.

1(b) Short Characterization
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), the 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 (her eafter referred to as “Part 98”) and implementation of Part 98 is referred to as the Greenhouse Gas Reporti ng Program (GHGRP). This supporting statement
addresses information collection activities that woul d be imposed by “Greenhouse Gas Reporting Rule: Leak Detection Methodology Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule.” 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 gases (GHGs). Subsequent rules were published on November 30, 2010 (75 FR 74458), November 25, 2014 (79 FR 70352), and October 22, 2015Page 2 January 2016 (80 FR 64262) finalizing the requirements for the petroleum and natural gas systems source category (hereafter referred to as “su bpart W”) at 40 CFR part 98, subpart W. For this rulemaking, which affects subpart W reporters, the EPA is proposing to add new monitoring methods for detecting leaks from oil and gas equipment in the petroleum and natural gas systems source category consistent with the leak detection methods in the recently proposed new source performance standards (NSPS) for the oil and gas industry (80 FR 56593; September 18, 2015), also known as 40 CFR part 60, subpart OOO Oa (also referred to as the “NSPS subpart OOOOa”). In addition, the EPA is proposing to add emission factors for leaking equipment to be used in conjunction with these monitoring me thods to calculate and report greenhouse gas (GHG) emissions resulting from equipment leak s. These amendments are expected to impact industry segments that conduct leak detection surveys. These revisi ons are expected to increase respondent burden for subpart W re porters that become subject to the NSPS subpart OOOOa. To accommodate the new methods and emission factors added by these proposed amendments, the EPA expects that each affected subpart W facilit y would update their facility-specific calculation mechanism ( i.e. , calculation spreadsheet, recordkeeping da tabase, etc.) when and if the facility becomes subject to the NSPS subpart OOOOa. All respondents subject to subpart W are requi red to report data elements according to 40 CFR 98.236, and maintain records according to 40 CFR 98.237. All respondents must report and maintain records as specified in Part 98. Approximately 2,200 respondents are subject to subpart W and this rulemaking is expected to increase labor costs for some subpart W industry segments over the 3-year period of this ICR. Compared with the estimated re spondent burden identified in the information collection for the GHGRP currently approved by th e Office of Management and Budget (OMB),
this information collection woul d result in an overal l increase in annual burden of 502 hours and $50,000, as shown in Section 6.Page 3 January 2016 2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection
The FY2008 Consolidated Appropriations Ac t, signed into law on December 26, 2007, directed the EPA to “develop and publish a draft rule not later th an 9 months after the date of enactment of this Act, and a final rule not later than 18 months afte r the date of enactment of this Act, to require mandatory reporting of greenhouse gas emissions above appr opriate thresholds in all sectors of the economy of the United States.” As stated in the October 30, 2009 preamble to Part 98 (74 FR 56260), CAA section 114(a)(1) authorizes the Administrator to requ ire emissions sources, persons subject to the CAA, or persons whom the Administrator believes may have necessary information to report emissions and provide such other informa tion the Administrator requests fo r the purposes of carrying out any provision of the CAA. Therefore, the EPA is proposing this inform ation collection under the authority provided
in CAA section 114.

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 c ountry are accessible to the public at: http://ghgdata.ep a.gov/ghgp/main.do . Reporting entities generally use uniform methods for estimating emissions, which enab les 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 provides a critical tool fo r 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-savingPage 4 January 2016 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. Generally, the facility-specific GHG emissi ons 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 aggreg ated to the corporate 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 inventor ies. Various activity data are co llected that can be used to improve understanding of the occurrence of emissions from a variety of sources. The proposed amendments in this rulemaking would refine the equi pment leak emission estimates provided under the GHGRP for facilitie s conducting fugitive emission monitoring. The proposed amendments would also allow facilities to use a consistent method to demonstrate compliance with multiple EPA programs. This proposal would limit burden for subpart W
facilities with affected sources that would also be required to comply with the proposed NSPS subpart OOOOa by allowing them to use data derived from the implementation of the NSPS subpart OOOOa to calculate emissi ons for the GHGRP rather than requiring the use of different monitoring or calculation methods.Page 5 January 2016 3. NONDUPLICATION, CONSULTATI ONS AND OTHER COLLECTION
CRITERIA

3(a) Nonduplication
The information proposed to be collected under the revisions includes nine new and substantially revised data elements. The data elements are: (1) th e number of complete equipment leak surveys performed during the cal endar year; (2) whether any equipment leak component types are subject to the NSPS subpart OOOOa; (3) whether you elected to report to subpart W using the equipment leak survey methodology; (4) the method(s) in 40 CFR 98.234(a) used to conduct the leak survey; (5) component type; (6) the number of each type of component identified as leaking; (7) the average time each type of surveyed components are assumed to be leaking and operational; (8) annual CO 2 emissions by component type; and (9) annual CH 4 emissions by component type. These data elements are similar to the types of industry data already being collected under the GHGRP. The EPA has evaluated the types of industry data collected under Part 98, and concluded that they do not duplicate other in formation collections,
as described below. In developing the GHGRP, the EPA reviewed 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 6 January 2016  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 supplements and complements, rather than duplicates, existing programs’ data. Further, the EPA has made signi ficant efforts over the past 4 years to facilitate reporting in the event a single entity has to report at both the federal and state level. For example, the EPA has supported efforts by the California Air Resources Board to harmonize the reporting of information under Calif ornia’s Global Warming Solutions Act, AB32 with the EPA’s GHGRP. The product of the collabor ation is referred to as California Electronic Greenhouse Gas Reporting T ool, or Cal e-GGRT.
Documentation of the 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 Docket ID No. EPA-HQ-OAR-2008-0508. For furt her discussion on the relationship of the GHGRP to other programs, please refer to the preambles of each of the GHGRP rulemakings, the June 6, 2008 memorandum entitled “Review ofExisting Programs” (Docket Item No. EPAHQ-OAR-2008-0508-0052), and the January 27 , 2009 memorandum entitled “Review of Existing State Greenhouse Gas Reporting Ru les” (Docket Item No. EPA-HQ-OAR-2008-0508- 0054). Some GHG programs are described below:

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

 The EPA reviewed the Inventory, which is an annual comprehensive top-down assessment of national greenhouses gas emi ssions. 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 fr om individual facilities that exceed appropriate thresholds.
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 toPage 7 January 2016 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 would 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: Leak Detectio n Methodology Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Proposed Rule.”

3(c) Consultations
Early in the development process of the GHGRP, the EPA conducted a proactive communications outreach program to inform the public about the rule development effort. The EPA solicited input and maintained an open-door policy for those interested in discussing the rulemaking. Since January 2008, the EPA staff has held more than 100 meetings with stakeholders, including the following:

 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 organizat ions 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.
The EPA also has met with federal agencies , including the U.S. Department of Energy and the U.S. Department of Agriculture, wh ich have programs rele vant to GHG emissions. On April 10, 2009 (74 FR 16448), the EPA proposed the GHGRP. The EPA held two public hearings, and received more than 16,000 written comments during the public comment period, which ended on June 9, 2009. Comments rela ted to Subpart W were received from morePage 8 January 2016 than 80 entities with over 1,200 pages of co mments, recommendations, and alternatives for
consideration. Details about thes e meetings and the responses to comments are available in Docket ID No. EPA-HQ-OAR-2009-0923. Following promulgation of the final subpa rt W rule (75 FR 74458, November 30, 2010), the EPA finalized the following actions revi sing 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 (November 29, 2013); 79 FR 63750 (October 24, 2014); 79 FR 70352 (November 25, 2014) ; and 80 FR 64262 (October 22, 2015). In the current action, the EPA is proposing to add new monitoring methods for detecting leaks from oil and gas equipment and to add emissi on factors for leaking equipment to be used in conjunction with the monitoring methods to calculate and report greenhouse gas (GHG) emissions resulting from equipment leaks. In conjunction with this action, we are propos ing confidentiality de terminations for the nine new and substantially revised data elem ents contained in these proposed amendments.

3(d) Effects of Less Frequent Collection
The frequency for reporting emissions info rmation to the 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 these revisions to Part 98. Annual reporting would ensure th at data are verified and made available to the public, as authorized by the CAA. If the information colle ction were not carried out on this schedule, the agency would not be able to develop an inform ed tracking system of trends in GHG emissions across the country.
Note that the burden related to this rule making has been annualized over the 3-year period of the ICR. The EPA anticipates that each individual reporter will update the existing facility-specific calculation m echanism to accommodate the new methods and emission factors only once during the 3-year peri od of the ICR. Due to the size and complexity of Onshore
Petroleum and Natural Gas Production faciliti es and Onshore Petroleum and Natural GasPage 9 January 2016 Gathering and Boosting facilities, all subpart W facilities in th ese two industry segments are expected to become subject to the NSPS subpart OOOOa in the next 3 years through
modification or reconstruction. Th erefore, updating the facility-sp ecific calculation mechanism is expected to apply to all subpart W facilities in these two indu stry segments over the 3-year period of this ICR.

3(e) General Guidelines

This collection is consistent with all OMB guidelines under 5 CFR 1320.5.

3(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 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, the EPA typically makes CBI determina tions 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, the EPA previously conclude d that case-by-case determinations would not result in timely release of em ission and other non-CBI data (see proposed CBI rule, 75 FR 39094, July 7, 2010 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). A ll data determined by the EPA to be CBI are safeguarded in accordance with regu lations in 40 CFR Chapter 1, Part 2, Subpart B. The CBI determinations for subpart W data re porting elements (exc luding data reporting elements used as inputs to emission calcu lations) were made in 77 FR 48072 (August 13, 2012), 79 FR 70352 (November 25, 2014), a nd 80 FR 64262 (October 22, 2015). In the current action, the EPA is proposing c onfidentiality determin ations for the nine new and substantially revised data elements contained in these proposed amendments.Page 10 January 2016 3(g) Sensitive Questions
The proposed revisions to reporting or r ecordkeeping requirements do not include sensitive questions.Page 11 January 2016 4. THE RESPONDENTS AND THE INFORMATION REQUESTED

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 the EPA to comply with subpart W of Part 98. This se ction provides a list of industry sectors that must comply with the rule, the data elements required of progr am participants, and the activities in which participants must engage to coll ect, assess, calculate, and in so me cases submit the required data
elements.

4(a) Respondents/North Ameri can Industrial Classificati on System (NAICS) Codes

The revisions to Part 98 affect facilities s ubject to subpart W. Re porting facilities for subpart W include, but are not lim ited to, those operating one or mo re 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 NAI CS code in Table 1. The NAICS codes are not exhaustive, but rather provide a list of facili ties likely to be affected.

Table 1. NAICS codes for affected reporters

Part and Subpart NAICS codes 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. The information proposed to be collected under the re visions includes nine new and substantially revised data elements. The data elements are: (1) the number of complete equipment leak surveys performed during the cal endar year; (2) whether any equipment leak component types are subject to the NSPS subpart OOOOa; (3) whether you elected to report to subpart W using the equipment leak survey methodology; (4) the method(s) in 40 CFR 98.234(a) used to conduct the leak survey; (5) component type; (6) the number of each type of componentPage 12 January 2016 identified as leaking; (7) the average time each type of surveyed components are assumed to be leaking and operational; (8) annual CO 2 emissions by component type; and (9) annual CH 4 emissions by component type. The final confidentiality determinations the EPA has previously made for the remainder of the subpart W data elements are unaffected by the proposed amendments and continue to apply. For information on confidentiality dete rminations for the GHGRP and subpart W data elements, see: 75 FR 39094, July 7, 2010; 76 FR 30782, May 26, 2011; 77 FR 48072, August 13, 2012; 79 FR 63750, October 24, 2014; 79 FR 70385, November 25, 2014; and 80 FR 64262, October 22, 2015. (ii) Respondent Activities. Th ese proposed amendments are expected to result in new respondent activities for facilitie s covered by subpart W. Howeve r, these respondent activities will only increase costs for facil ities in two industry segments, Onshore Petroleum and Natural
Gas Production and Onshore Petroleum and Natural Gas Gathering and Boosting. To accommodate the new methods and emission factors added by these proposed amendments, the EPA expects that each facility in these two industry segments would update the facility-specific
calculation mechanism when and if the facility becomes subj ect to the NSPS subpart OOOOa. These proposed amendments would not ch ange the respondent activities already established under subpart W. The owner or operator of a facility that is s ubject to the subpart W reporting requirements must continue to report total annual GHG emissions. The primary tasks that reporting program respondents perform continue to include:
1. Implementing and updating, as necessary, appropriate monitoring plans for each affected source and each affected unit at a source, as applicable; 2. Conducting operation and mainte nance activities associat ed with the monitoring, including quality assurance activities; 3. Ensuring data quality, preparing annual reports of emissions data, and submitting these reports to the EPA; 4. Potentially responding to questions or error messages from the EPA; and 5. Maintaining records for a minimum of 3 years.
Respondents that use CEMS also conduct test s to certify the operations of monitors, submit the results of these tests, and record em ission data (this activity generally is performed electronically). Reports must present the annual mass GHG em issions from each subpart W industry segment separately. Reporters are required to provi de emissions in metric tons of methane (CH 4 ),Page 13 January 2016 CO 2 , and nitrous oxide (N 2 O) for some sources and in metric tons of CO 2 e for other sources. The calculations used to determine GHG emissions, the frequency at which those calculations are required, and the methods used to estimate missing data depend on the specific subpart W industry segment. (iii) Electronic Reporting. Respondents repo rt all data electro nically through the Electronic Greenhouse Gas Reporting Tool (e-GGRT) . All new data elements would be reported in the same way. As the e-GGRT accounts are alr eady established, the only burden related to electronic reporting would be entering the data elements.Page 14 January 2016 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 does not reflect an incremental ag ency burden for program operation activities related to the review of the pr oposed nine new and substantially revised data elements because this burden is expected to be insignificant when compared to the agency burden already established for subpart W activities.

5(b) Collection Methodology and Management
To collect data currently re ported under the GHGRP, the EPA previously established a central repository of inventory data for all respondents called e-GGRT. Respondents report data electronically, and the EPA stores 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 allows facilities to upload GHG data directly. Under the revisions to Part 98, facilities subj ect to subpart W listed in Section 4(a) would report the new and subs tantially revised data elements via e-GGRT. The e-GGRT system follows agency standard s for design, security, data element and reporting format conformance, and accessibility . The EPA designed the system 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
The EPA has determined that some small businesses would be affected by these proposed amendments because their production processe s emit GHGs exceeding the reporting threshold. However, the EPA has determined that updating the facility-specific calculation mechanism when and if the facility become s subject to the NSPS subpart OOO Oa (an estimated cost of less than $200 per reporter) is not a significant increase. Therefore, these proposed amendments would not have a significant economic impact on a substantial numbe r of small entities.Page 15 January 2016 Although these proposed amendments would not have a significant economic impact on a substantial number of small entities, the EPA non etheless has tried to reduce the impact of this rule on small entities. As part of the process of finalizing the subpart W 2010 final rule (75 FR 74458, November 30, 2010), the EPA took several step s to evaluate the effect of the rule on small entities. For example, the EPA determined appropriate thresholds that reduced the number of small businesses reporting. In addition, the EPA supports a “help desk” for the GHGRP, which would be available to answer questions on the provisions in this rulemaking. Finally, the
rule includes a mechanism in 40 CFR 98.2 to allow facilities and suppliers that report less than 25,000 metric tons of CO 2 e/year for 5 years or less than 15,000 metric tons CO 2 e/year for 3 years to cease annual reporting to the EPA.

5(d) Collection Schedule
All data elements, including existing, new, a nd substantially revised elements, under this information collection would be submitted on an annual basis as part of the respondent’s annual report required under Part 98.Page 16 January 2016 6. ESTIMATING THE BURDEN A ND COST OF THE COLLECTION

This section presents the EPA’s estimates of the burden and costs to respondents
associated with the activities de scribed in Section 4 as well as the agency burden hours and costs
associated with the activities described in Secti on 5(a). Section 6(a) prov ides estimates of burden (hours) for all respondent types. Section 6(b) co ntains estimates of respondent costs for the information collection. Section 6(c) summarizes federal burden and costs. Section 6(d) describes the respondent universe and the to tal burden and cost of this co llection to respondents. Section 6(e) presents the bottom line burd en and cost. Section 6(f) provi des reasons for any change in
burden. The burden statement for this info rmation collection is in Section 6(g).

6(a) Estimating Respondent Burden
The EPA estimates that the total respondent burden to all affected subpart W entities would be approximately 183,000 hours over the 3 y ears covered by this information collection. Exhibit 6.1 presents aggregate burden hours by subpart W industry segment.
The information collection related to thes e proposed amendments would result in an
overall increase in annual burden of 502 hours. For details of the EPA’ s burden calculations, please see Appendix A. This increase is split between two subpart W industry segments as shown in Exhibit 6.2, which presents the cha nge in burden by subpart W industry segment.

6(b) Estimating Respondent Costs

The EPA estimates that the total annual cost to all affected non-fede ral entities would be approximately $28.1 million over the 3 years covered by this information collection. Exhibit 6.1 presents aggregate costs and costs by subpart W industry segment.
The information collection related to the proposed amendments would result in an increase in annual costs of approximately $50,00 0. For details of the EP A’s cost calculations, please see Appendix A. This increase is split be tween the two subpart W industry segments as
shown in Exhibit 6.2. (i) Estimating Labor Costs. Costs to res pondents associated with this information
collection include the cost of labor by facility staff to meet the rule’s information collectionPage 17 January 2016 requirements. To calculate labor costs, the EPA used labor rates classified according to the 2010 Standard Occupational Classificati on (SOC) system from the Bureau of Labor Statistics (BLS). For all subpart W industry segments, the labor rate derivations are based on second quarter 2014 dollars, as shown in Table 2. The labor rates for this ICR are: $129.83 for senior managers, $118.86 for middle managers, $99.18 for engi neers, and $52.84 for technicians.

Table 2. Labor Rate Derivations

Labor Category Wage and Salaries (2014$ Q2) a SOC Code Benefits Loading Factor b Overhead Loading Factor c Loaded Labor Rate (2014$ Q2) d Engineer $61.26 17-2112 0.4489 0.17 $99.18 Technician $32.64 17-3024 0.4489 0.17 $52.84 Middle manager $73.19 11-3051 0.4539 0.17 $118.86 Senior manager $78.55 11-1021 0.4829 0.17 $129.83

a The base hourly wages & salaries (not including benefits & overhead) are from BLS's May 2014 National Industry-Specific Occupational Employment and Wage Estimates (http://www. bls.gov/oes/current/oessrci.htm).

b From BLS's ECEC (http://www.bls.gov/ect/home.htm) for June of 2014, Table 2, using the ratio of wages and benefits to calculate the loading factor. For Technical, Engineers, and Technicians, used “Professional and related.” For Managerial, Middle Manager, and Senior Manager, used “Management, business, and financial.”

c The overhead loading factor is from Rice, Cody 2002. "Wage Rates for Economic An alyses of the Toxics Release Inventory

Program,” Analytical Support Branch, Envir onmental Analysis Division, Office of Environmental Information, U.S. EPA, June 10, 2002.

d The loaded hourly rate = Wages & Salaries + (Wages & Salaries * Benefits Loading Factor) + (Wages & Salaries *

Overhead Loading Factor).

Burden estimates related to these proposed amendments were calculated by assigning a level of effort of 2 hours to an Engineer to upd ate the facility-specific calculation mechanism to
accommodate the new methods and emission factors. Therefore, the estimated cost per reporter is $198.36.
For details of the burden calcu lations, please see Appendix A. No other changes are proposed to be made to the existing burden estimates established by ICR Number 2300.17 (80 FR 68534; November 5, 2015). (ii) Estimating Capital and Operations a nd Maintenance (O&M) Co sts. These proposed amendments to subpart W would not impact the capital and O&M costs required to comply with the monitoring, recordkeeping, and reporti ng of emissions within this rule. No changes are proposed to be made to th e existing capital and O&M costs established by ICR Number 2300.17 (80 FR 68534; November 5, 2015).Page 18January 2016Exhibit 6.1 Annual Average Respondent Burden and Cost for Subpart W of the GHGRPSubpart WIndustry SegmentNo. RespondentsTotalResponsesTotal Burden(hrs)Total Labor CostCapital CostO&M CostTotal CostOnshore Natural GasTransmission Pipelines183 366 5,490 $580,852 $107,117 $0 $687,968Onshore Petroleum andNatural Gas Gathering andBoosting200 3,400 11,560 $1,206,203$141,457 $1,709,600 $3,057,259Onshore Natural GasProcessing435 6,960 14,740 $1,605,142$266,938 $1,601,105 $3,473,185Onshore Natural GasTransmission Compression487 4,870 16,982 $1,834,787$359,397 $1,100,000 $3,294,185Underground Natural GasStorage50 350 1,611 $176,080 $26,926 $107,500 $310,506LNG Import and ExportEquipment8 56 263 $27,919 $5,268 $20,000 $53,187Onshore Petroleum andNatural Gas Production553 16,640 125,423 $12,581,268$216,916 $3,557,285 $16,355,470Natural Gas Distribution1755255,506 $574,417 $0 $275,000 $849,417LNG Storage530153$16,113$585$7,500$24,199Offshore Petroleum andNatural Gas Production107 214 1,794 $25,157 $0 $0 $25,157TOTAL 2,20333,411183,523$18,627,939 $1,124,604 $8,377,990 $28,130,534Page 19January 2016Exhibit 6.2 Annual Average Change in RespondentBurden and Cost for Subpart W of the GHGRPSubpart W Industry SegmentAnnual Change in TotalBurden(Technical Labor Hours)Annual Change in Burden(Technical LaborHours/Respondent)Annual Change inTotal Cost($)Annual Changein Cost($/Respondent)kOnshore Natural Gas TransmissionPipelinesa0 0.00 $0 $0Onshore Petroleum and Natural GasGathering and Boostingb134 2.00 $13,290 $198Onshore Natural Gas Processingc00.00$0$0Onshore Natural Gas TransmissionCompressiond00.00$0$0Underground Natural Gas Storagee00.00$0$0LNG Import and Export Equipmentf00.00$0$0Onshore Petroleum and Natural GasProductiong3682.00$36,498$198Natural Gas Distributionh00.00$0$0LNG Storagei00.00$0$0Offshore Petroleum and Natural GasProductionj0 0.00 $0 $0TOTAL 5022.00$49,788$198aFor Onshore Natural Gas Transmission Pipelines, the technical labor hourburden and costs are expected to remain the same.bFor Onshore Petroleum and Natural Gas Gathering and Boosting,the technical labor hour burden increased from 11,427 hours to 11,561 hours, which increased the total costfrom $3,044,035 to $3,057,326.cFor Onshore Natural Gas Processing, the technical labor hour burden and costs are expected to remain the same.dFor Onshore Natural Gas Transmission Compression, the technical labor hour burden andcosts are expected to remain the same.eFor Underground Natural Gas Storage,the technical labor hour burden and costs are expected to remain the same.fFor LNG Import and Export Equipment, the technical laborhour burden and costs are expected to remain the same.gFor Onshore Petroleum and Natural GasProduction, the technical labor hour burdenincreased from 125,054 hours to 125,422 hours, which increased the total cost from$16,318,905 to $16,355,404.hFor Natural Gas Distribution, the technical labor hourburden and costs are expected to remain the same.iFor LNG Storage, the technical labor hour burden and costs are expected to remain the same.jFor Offshore Petroleum and Natural Gas Production, the technical labor hour burden andcosts are expected to remain the same.kAssuming that one-third of the existing respondents comply in each year of the 3-year ICR period.Page 20 January 2016 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 information collection include EPA Headquarters oversight of the reporting program. The 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. These proposed am endments are not exp ected to increase the current overall agency burden. Therefore, the incremental agency cost for these proposed amendments is 0 hours and $0. To develop the EPA labor costs related to the implementation of subpart W under the GHGRP, the EPA updated the average hourly labor rate for salary and overhead and benefits for agency staff to be $53.42 per hour. To derive this figure, the EPA multiplied the hourly compensation at GS-12, Step 5 on the 2015 GS pa y scale ($33.39) by the standard government benefits multiplication factor of 1.6 to account for overhead and benefits. 1 The total annual burden and cost to the agency is 10,400 hours and $555,610.

Exhibit 6.3 Annual Agency Burden and Cost for Subpart W

Information Collection Activity Annual Responses Total Annual Burden Labor Cost Non-Labor Cost Total Annual Cost Petroleum and Natural Gas Systems 1 10,400 $555,610 $0 $555,610 TOTAL 1 10,400 $555,610 $0 $555,610

6(d) Estimating the Respondent Un iverse and Total Burden and Costs
The number of respondents in each subpart W i ndustry sector that w ould be expected to perform the activities under th is information collection is presented in Exhibit 6.1.

1 http://www.opm.gov/policy-data-ove rsight/pay-leave/salaries-wages/s alary-tables/pdf/2015/GS_h.pdfPage 21 January 2016 6(e) Bottom Line Burden Hours and Costs/Master Tables

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 2,203 From Exhibit 6.1 Total Annual Responses 33,411 From Exhibit 6.1 Number of Responses per Respondent 15.2 Total annual responses from above ÷ Total respondents from above Total Respondent Hours 183,523 From Exhibit 6.1 Hours per Respondent 83.3 Total annual hours from above ÷ Total respondents from above Annual Labor Cost $18,627,939 From Exhibit 6.1 Annual O&M and Capital Cost $9,502,594 From Exhibit 6.1 Total Respondent Cost (labor + non) $28,130,534 From Exhibit 6.1 Total Agency Hours 10,400 From Exhibit 6.3 Total Agency Costs $555,610 From Exhibit 6.3 Total Hours (Respondents and Agency) 193,923 Total respondent hours from above + Total EPA hours Total Cost (Respondents and Agency) $28,686,143 Total respondent cost from above + Total EPA costs Note: Detail may not add exactly to total due to independent rounding.

6(f) Reasons for Change in Burden

This rule would result in an overall increase in annual bur den of 502 hours and approximately $50,000. These proposed amendments would impose an increase in burden and
costs due to the EPA’s revisions to subpart W of Part 98 to add methods and emission factors
related to emission leaks.

6(g) Burden Statement
The incremental respondent reporting burden for these proposed amendments is estimated to average 502 hours and $49,788 per year for a 3-year period, where identical annual costs are anticipated for all 3 ye ars. The incremental average annual burden to the EPA for this period is estimated to be 0 hours and $0 for overs ight activities. The annual respondent reporting and recordkeeping burden for this proposed collec tion of information is estimated to average 2.0 hours per respondent. The respondent reporting burden fo r this collection of informa tion is estimated to average 183,500 hours and $28.1 million per year for a 3-year period, where identi cal annual costs are anticipated for all 3 years. The average annual burden to the EPA for this period is estimated to be 10,400 hours and $555,610 for oversight activ ities, where identical annual costs arePage 22 January 2016 anticipated for all 3 years. The annual responde nt reporting and recordkeeping burden for this
collection of information is estimate d to average 83.3 hours per respondent. 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 u tilize 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 the EPA’s regula tions are listed in 40 CFR part 9. To comment on the agency’s need for this information, the accur acy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, the EP A has established a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2015-0764, whic h is available for online viewing at http://www.regulations.gov/, or in person viewi ng at the Air and 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 to the Office of Information and Regulatory Affa irs, Office of Management and Budget, 725 17 th Street, NW, Washington, D.C. 20503 , Attention: Desk Officer fo r EPA. Please include the EPA
Docket ID Number EPA- HQ-OAR-2015-0764 and OMB Contro l Number 2060-0629 on any correspondence.Page 23 January 2016 Part B of the Supporting Statement
This section is not applicable because statistical methods ar e not used in data collection associated with the proposed amendments.

### Appendix A: Recordkeeping and Reporting Requirem ents for Leak Detection Methodology Revisions and Confidentiality Determinat ions for Petroleum and Natural Gas Systems (40 CFR part 98, Subpart W)
Dated January 2016

Respondent Burden for Years 1 through 3Page A-1Year 1 through Year 3Incremental Costs Due to Proposed Amendments(A)Hours perOccurrence(B)Occurrences/Respondent/Year(C)Hours/Respondent/Year (A x B)(D)Respondents/Year(E)EngineerHours/Year(C x D)TechnicianHours/YearMiddleManagerHours/YearSeniorManagerHours/YearCost/Yeara1. APPLICATIONS (Not Applicable)2. SURVEY AND STUDIES (Not Applicable)3. ACQUISITION, INSTALLATION, ANDUTILIZATION OF TECHNOLOGY AND SYSTEMS4. REPORT REQUIREMENTSA. Read Rule, Instructions, Guidance DocumentsOnshore Petroleum and Natural Gas Gathering andBoosting reportersb,c0.00 0 0.00 200 0 $0Onshore Petroleum andNatural Gas Productionreportersb,d0.00 0 0.00 553 0 $0B. Required ActivitiesC. Create Information (Included in 4B)D. Gather Existing Information (Included in 4E)E. Write ReportAnnual Compliance Reporting through e-GGRTb0.00 0 0.00 0 0 $05. RECORDKEEPING REQUIREMENTSA. Read Instructions (Included in 4A)B. Plan Activities (Included in 4B)C. Implement Activities (Included in 4B)D. Recordkeeping and Associated Calculationsb0.00 0 0.00 0 0 $0Time to update facility-specific calculationmechanism (i.e., calculation spreadsheet,recordkeeping database, etc.) to allow for use ofnew leaker factorse2.00 1.0 2.00 251 502.0 $49,788E. Time to Transmit or Disclose Information(included in 4E)F. Time to Train Personnel (Not Applicable)G. Time for Audits (Not Applicable)TOTAL ANNUAL LABOR BURDEN AND COST502.0 $49,788aCosts are calculated by multiplying the number of hours by the appropriate hourly labor rate.For these proposed amendments, only Engineer hours were estimated.bThese activities are already included inthe Subpart W burden according to ICR Number 2300.17 (80 FR 68534; November 5, 2015).These proposed amendments would notimpact the burden or cost associated with these activities.cThere are 200 existing facilities in the Onshore Petroleum and Natural Gas Gathering and Boosting industry segment.dThere are 553 existing facilities in the Onshore Petroleum and Natural Gas Production industry segment.eAssuming that one-third would comply in each year of the 3-years ICR period, there would be 251 respondents per year. [(200 + 553) / 3 = 251]