Page 1 January 2016 

SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION 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 Determinations 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 Appropriations 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 (hereafter referred to as “Part 98”) and implementation of Part 98 

is referred to as the Greenhouse Gas Reporting Program (GHGRP). This supporting statement 

addresses information collection activities that would 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 threshold levels of carbon dioxide (CO2) equivalent (CO2e) 

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, 2015 
 Page 2 January 2016 

(80 FR 64262) 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. 

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 OOOOa (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 methods to calculate and report greenhouse gas 

(GHG) emissions resulting from equipment leaks. These amendments are expected to impact 

industry segments that conduct leak detection surveys. These revisions are expected to increase 

respondent burden for subpart W reporters 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 facility would update their facility-specific calculation 

mechanism (i.e., calculation spreadsheet, recordkeeping database, etc.) when and if the facility 

becomes subject to the NSPS subpart OOOOa. 

All respondents subject to subpart W are required 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 respondent burden identified in the information 

collection for the GHGRP currently approved by the Office of Management and Budget (OMB), 

this information collection would result in an overall 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 Act, signed into law on December 26, 2007, 

directed the EPA to “develop and publish a draft rule not later than 9 months after the date of 

enactment of this Act, and a final rule not later than 18 months after the date of enactment of this 

Act, to require mandatory reporting of greenhouse gas emissions above appropriate thresholds in 

all sectors of the economy of the United States.” 

As stated in the October 30, 2009 preamble to Part 98 (74 FR 56260), CAA section 

114(a)(1) authorizes the Administrator to require emissions sources, persons subject to the CAA, 

or persons whom the Administrator believes may have necessary information to report emissions 

and provide such other information the Administrator requests for the purposes of carrying out 

any provision of the CAA. 

Therefore, the EPA is proposing this information 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 country are accessible to 

the public at: http://ghgdata.epa.gov/ghgp/main.do. Reporting entities generally use uniform 

methods for estimating emissions, which enables data to be compared and analyzed. 

Data collection in the GHGRP complements the Inventory of U.S. Greenhouse Gas 

Emissions and Sinks (Inventory) and provides a critical tool for communities to identify nearby 

sources of GHGs and provide information to state and local governments. 

The standardization of GHG data provides businesses with the necessary information to 

benchmark themselves against similar facilities, better understand their relative standing within 

their industry, and achieve and disseminate their environmental achievements. Businesses and 

other innovators can use the data to determine their GHG footprints, find cost- and fuel-saving 
 Page 4 January 2016 

efficiencies that reduce greenhouse gas emissions (e.g., through energy audits or other forms of 

assistance), and foster technologies to protect public health and the environment. 

Generally, the facility-specific GHG emissions data improve the understanding of the 

factors that influence GHG emission rates as well as the actions that facilities take to reduce 

emissions. The facility-based data can be aggregated to the 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 inventories. Various activity data are collected 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 equipment leak emission 

estimates provided under the GHGRP for facilities 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 emissions for the GHGRP rather than requiring the use of different 

monitoring or calculation methods. 

 
 Page 5 January 2016 

3. NONDUPLICATION, CONSULTATIONS 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) the number of complete 

equipment leak surveys performed during the calendar 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 CO2 emissions by component type; and (9) annual CH4

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 information 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 California, New Mexico, Connecticut, and New 

Jersey; 

 Reporting protocols developed by nongovernmental organizations, such as the World 

Resources Institute/World Business Council for Sustainable Development; 

 Programs from industrial trade organizations, such 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 CO2 Accounting and Reporting Standard for the 

Cement Industry; and 
 Page 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 significant 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 California’s Global Warming Solutions Act, AB32 

with the EPA’s GHGRP. The product of the collaboration is referred to as California Electronic 

Greenhouse Gas Reporting Tool, 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 further 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 of Existing Programs” (Docket Item No. EPAHQ-OAR-2008-0508-0052), and the January 27, 2009 memorandum entitled “Review of 

Existing State Greenhouse Gas Reporting Rules” (Docket Item No. EPA-HQ-OAR-2008-0508-

0054). Some GHG programs are described below: 

 A number of the EPA’s voluntary partnership programs include a GHG emissions 

and/or reductions reporting component (e.g., Natural Gas STAR program). However, 

the GHGRP has much broader coverage than 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 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. 

As noted in the current ICR for the GHGRP, a number of programs at the state, tribal, 

territorial, and local level require emission sources in their respective jurisdictions to monitor and 

report GHG emissions. To reduce burden on reporters and program agencies, the agency plans to 
 Page 7 January 2016 

share reported data, with the exception of any information determined to be Confidential 

Business Information (CBI), with relevant agencies or approved entities using, where practical, 

shared tools, and infrastructure. 

Based on this evaluation, this information collection request would not duplicate other 

information collections. 

3(b) Public Notice Required Prior to Information Collection Request (ICR) Submissions to 

OMB 

A public notice of this collection is provided in the Federal Register notice of 

“Greenhouse Gas Reporting Rule: Leak Detection 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 potentially affected industries/sectors; 

 State, local, and tribal environmental control agencies and regional air quality 

planning organizations; 

 State and regional organizations already involved in GHG emissions reporting, such 

as The Climate Registry, California Air Resources Board, and the Western Climate 

Initiative; and 

 Environmental groups and other nongovernmental organizations. 

The EPA also has met with federal agencies, including the U.S. Department of Energy 

and the U.S. Department of Agriculture, which have programs relevant to GHG emissions. 

On April 10, 2009 (74 FR 16448), 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 related to Subpart W were received from more 
 Page 8 January 2016 

than 80 entities with over 1,200 pages of comments, recommendations, and alternatives for 

consideration. Details about these meetings and the responses to comments are available in 

Docket ID No. EPA-HQ-OAR-2009-0923. 

Following promulgation of the final subpart W rule (75 FR 74458, November 30, 2010), 

the EPA finalized the following 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 (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 emission 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 proposing confidentiality determinations for the 

nine new and substantially revised data elements contained in these proposed amendments. 

3(d) Effects of Less Frequent Collection 

The frequency for reporting emissions information 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 collects facility-specific data of sufficient quality to achieve the 

agency’s objectives. The GHGRP requires annual reporting, except for a limited number of 

facilities that are already subject to more frequent reporting requirements. This reporting 

frequency remains the same in these revisions to Part 98. 

Annual reporting would ensure that data are verified and made available to the public, as 

authorized by the CAA. If the information collection were not carried out on this schedule, the 

agency would not be able to develop an informed tracking system of trends in GHG emissions 

across the country. 

Note that the burden related to this rulemaking 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 mechanism to accommodate the new methods and emission factors 

only once during the 3-year period of the ICR. Due to the size and complexity of Onshore 

Petroleum and Natural Gas Production facilities and Onshore Petroleum and Natural Gas 
 Page 9 January 2016 

Gathering and Boosting facilities, all subpart W facilities in these two industry segments are 

expected to become subject to the NSPS subpart OOOOa in the next 3 years through 

modification or reconstruction. Therefore, updating the facility-specific calculation mechanism is 

expected to apply to all subpart W facilities in these two industry 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 EPA regulations. The CAA precludes “emission 

data” from being treated as confidential. For data reported under the CAA that are not emission 

data, the EPA typically makes CBI determinations under 40 CFR 2.301 on a case-by-case basis. 

Due to the large number of entities reporting under the GHGRP and the large number of data 

reporting elements, the EPA previously concluded that case-by-case determinations would not 

result in timely release of emission 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). All data determined by the 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 inputs to emission calculations) were made in 77 FR 48072 (August 13, 2012), 

79 FR 70352 (November 25, 2014), and 80 FR 64262 (October 22, 2015). 

In the current action, the EPA is proposing confidentiality determinations 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 recordkeeping requirements do not include 

sensitive questions. 
 Page 11 January 2016 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

The respondents in this information collection include owners and operators of petroleum 

and natural gas systems facilities that must report their GHG emissions to the EPA to comply 

with subpart W of Part 98. This section provides a list of industry sectors that must comply with 

the rule, the data elements required of program participants, and the activities in which 

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

elements. 

4(a) Respondents/North American Industrial Classification System (NAICS) Codes 

The revisions to Part 98 affect facilities subject to subpart W. Reporting facilities for 

subpart W include, but are not limited to, those operating one or more units that exceed the CO2e 

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 NAICS code in Table 1. The NAICS codes are not exhaustive, but 

rather provide a list of facilities 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 transportation 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 revisions includes nine 

new and substantially revised data elements. The data elements are: (1) the number of complete 

equipment leak surveys performed during the calendar 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 
 Page 12 January 2016 

identified as leaking; (7) the average time each type of surveyed components are assumed to be 

leaking and operational; (8) annual CO2 emissions by component type; and (9) annual CH4

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 determinations 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. These proposed amendments are expected to result in new 

respondent activities for facilities covered by subpart W. However, these respondent activities 

will only increase costs for facilities 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 subject to the NSPS subpart OOOOa. 

These proposed amendments would not change the respondent activities already 

established under subpart W. The owner or operator of a facility that is subject 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 maintenance activities associated 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 tests to certify the operations of monitors, 

submit the results of these tests, and record emission data (this activity generally is performed 

electronically). 

Reports must present the annual mass GHG emissions from each subpart W industry 

segment separately. Reporters are required to provide emissions in metric tons of methane (CH4), 
 Page 13 January 2016 

CO2, and nitrous oxide (N2O) for some sources and in metric tons of CO2e 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 report all data electronically 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 already 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 monitoring and verification of emission reports, 

database and software maintenance, communication and outreach, and program evaluation. 

This ICR does not reflect an incremental agency burden for program operation activities 

related to the review of the proposed 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 reported 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 subject to subpart W listed 

in Section 4(a) would report the new and substantially revised data elements via e-GGRT. 

The e-GGRT system follows agency standards 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 processes emit GHGs exceeding the reporting threshold. 

However, the EPA has determined that updating the facility-specific calculation mechanism 

when and if the facility becomes subject to the NSPS subpart OOOOa (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 number 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 nonetheless 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 steps 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 CO2e/year for 5 years or less than 15,000 metric tons CO2e/year for 3 years 

to cease annual reporting to the EPA. 

5(d) Collection Schedule 

All data elements, including existing, new, and 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 AND COST OF THE COLLECTION 

This section presents the EPA’s estimates of the burden and costs to respondents 

associated with the activities described in Section 4 as well as the agency 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 respondent costs for the 

information collection. Section 6(c) summarizes federal burden and costs. Section 6(d) describes 

the respondent universe and the total burden and cost of this collection to respondents. Section 

6(e) presents the bottom line burden and cost. Section 6(f) provides reasons for any change in 

burden. The burden statement for this information 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 years covered by this information collection. 

Exhibit 6.1 presents aggregate burden hours by subpart W industry segment. 

The information collection related to these 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 change in burden by subpart W industry segment. 

6(b) Estimating Respondent Costs 

The EPA estimates that the total annual cost to all affected non-federal 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 $50,000. For details of the EPA’s cost calculations, 

please see Appendix A. This increase is split between the two subpart W industry segments as 

shown in Exhibit 6.2. 

(i) Estimating Labor Costs. Costs to respondents associated with this information 

collection include the cost of labor by facility staff to meet the rule’s information collection 
 Page 17 January 2016 

requirements. To calculate labor costs, the EPA used labor rates classified according to the 2010 

Standard Occupational Classification (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 engineers, and $52.84 for technicians. 

Table 2. Labor Rate Derivations 

Labor Category 

Wage and 

Salaries 

(2014$ Q2)a SOC Code 

Benefits 

Loading 

Factorb

Overhead 

Loading Factorc

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 Analyses of the Toxics Release Inventory 

Program,” Analytical Support Branch, Environmental 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 update 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 calculations, 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 and Maintenance (O&M) Costs. These proposed 

amendments to subpart W would not impact the capital and O&M costs required to comply with 

the monitoring, recordkeeping, and reporting of emissions within this rule. 

No changes are proposed to be made to the existing capital and O&M costs established 

by ICR Number 2300.17 (80 FR 68534; November 5, 2015).
Page 18 

Exhibit 6.1 Annual Average Respondent Burden and Cost for Subpart W of the GHGRP 

Subpart W 

Industry Segment No. Respondents Total Responses Total Burden (hrs) Total Labor Cost Capital Cost O&M Co

Onshore Natural Gas Transmission Pipelines 183 366 5,490 $580,852 $107,117 $0 Onshore Petroleum and Natural Gas Gathering and Boosting 

200 3,400 11,560 $1,206,203 $141,457 $1,709,60

Onshore Natural Gas Processing 435 6,960 14,740 $1,605,142 $266,938 $1,601,10Onshore Natural Gas Transmission Compression 487 4,870 16,982 $1,834,787 $359,397 $1,100,00Underground Natural Gas Storage 50 350 1,611 $176,080 $26,926 $107,500 LNG Import and Export Equipment 8 56 263 $27,919 $5,268 $20,000 Onshore Petroleum and Natural Gas Production 553 16,640 125,423 $12,581,268 $216,916 $3,557,28Natural Gas Distribution 175 525 5,506 $574,417 $0 $275,000 LNG Storage 5 30 153 $16,113 $585 $7,500 Offshore Petroleum and Natural Gas Production 107 214 1,794 $25,157 $0 $0 TOTAL 2,203 33,411 183,523 $18,627,939 $1,124,604 $8,377,99
Page 19 

Exhibit 6.2 Annual Average Change in Respondent Burden and Cost for Subpart W of the GHGRP 

Subpart W Industry Segment 

Annual Change in Total 

Burden 

(Technical Labor Hours) 

 Annual Change in Burden 

(Technical Labor 

Hours/Respondent) 

Annual Chang

Total Cos

($) 

Onshore Natural Gas Transmission Pipelinesa 0 0.00 $0 Onshore Petroleum and Natural Gas Gathering and Boostingb 134 2.00 $13,290 Onshore Natural Gas Processingc 0 0.00 $0 Onshore Natural Gas Transmission Compressiond 0 0.00 $0 Underground Natural Gas Storagee 0 0.00 $0 LNG Import and Export Equipmentf 0 0.00 $0 Onshore Petroleum and Natural Gas Productiong 368 2.00 $36,498 Natural Gas Distributionh 0 0.00 $0 LNG Storagei 0 0.00 $0 Offshore Petroleum and Natural Gas Productionj 0 0.00 $0 TOTAL 502 2.00 $49,788 

a For Onshore Natural Gas Transmission Pipelines, the technical labor hour burden and costs are expected to remain the same. b For Onshore Petroleum and Natural Gas Gathering and Boosting, the technical labor hour burden increased from 11,427 hours to 11,561 hours, whic

from $3,044,035 to $3,057,326. 

c For Onshore Natural Gas Processing, the technical labor hour burden and costs are expected to remain the same. d For Onshore Natural Gas Transmission Compression, the technical labor hour burden and costs are expected to remain the same. e For Underground Natural Gas Storage, the technical labor hour burden and costs are expected to remain the same. f For LNG Import and Export Equipment, the technical labor hour burden and costs are expected to remain the same. g For Onshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 125,054 hours to 125,422 hours, which increase

$16,318,905 to $16,355,404. 

h For Natural Gas Distribution, the technical labor hour burden and costs are expected to remain the same. i For LNG Storage, the technical labor hour burden and costs are expected to remain the same. j For Offshore Petroleum and Natural Gas Production, the technical labor hour burden and costs are expected to remain the same. k Assuming 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 amendments are not expected 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 pay 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 Universe and Total Burden and Costs 

The number of respondents in each subpart W industry sector that would be expected to 

perform the activities under this information collection is presented in Exhibit 6.1. 

 

1

 http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/GS_h.pdf 
Page 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 burden 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 years. The incremental average annual burden to the EPA for this 

period is estimated to be 0 hours and $0 for oversight activities. The annual respondent reporting 

and recordkeeping burden for this proposed collection of information is estimated to average 2.0 

hours per respondent. 

The respondent reporting burden for this collection of information is estimated to average 

183,500 hours and $28.1 million per year for a 3-year period, where identical 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 activities, where identical annual costs are 
 Page 22 January 2016 

anticipated for all 3 years. The annual respondent reporting and recordkeeping burden for this 

collection of information is estimated to average 83.3 hours per respondent. 

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a federal agency. This 

includes the time needed to review instructions; develop, acquire, install and utilize technology 

and systems for the purposes of collecting, validating and verifying information, processing and 

maintaining information and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to respond 

to a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for the 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, the EPA has established a public docket for this ICR 

under Docket ID No. EPA-HQ-OAR-2015-0764, which is available for online viewing at 

http://www.regulations.gov/, or in person viewing at the Air and Radiation docket in the EPA 

Docket Center (EPA/DC), William Jefferson Clinton Federal Building - West, Room 3334, 1301 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 

Air and Radiation docket is (202) 566-1742. An electronic version of the public docket is 

available at http://www.regulations.gov. This site can be used to submit or view public 

comments, access the index listing of the contents of the public docket, and to access those 

documents in the public docket that are available 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 Affairs, Office of Management and Budget, 725 17th

Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID Number EPA-HQ-OAR-2015-0764 and OMB Control Number 2060-0629 on any 

correspondence. 
 Page 23 January 2016 

Part B of the Supporting Statement 

This section is not applicable because statistical methods are not used in data collection 

associated with the proposed amendments. 
 

Appendix A: 

Recordkeeping and Reporting Requirements for Leak Detection Methodology 

Revisions and Confidentiality Determinations for Petroleum and Natural Gas 

Systems (40 CFR part 98, Subpart W) 

Dated January 2016 

Respondent Burden for Years 1 through 3
Page A-1 

Year 1 through Year 3 

Incremental Costs Due to Proposed Amendments 

(A) 

Hours per 

Occurrence

(B) 

Occurrences/ 

Respondent/

Year 

(C) 

Hours/ 

Respondent/

Year (A x B) 

(D) 

Respondents/

Year 

(E) 

Engineer 

Hours/Year 

(C x D) 

Technician 

Hours/ 

Year 

M

M

H

1. APPLICATIONS (Not Applicable) 2. SURVEY AND STUDIES (Not Applicable) 3. ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS 4. REPORT REQUIREMENTS  A. Read Rule, Instructions, Guidance Documents 

Onshore Petroleum and Natural Gas Gathering and Boosting reporters b,c 0.00 0 0.00 200 0 Onshore Petroleum and Natural Gas Production reporters b,d 0.00 0 0.00 553 0 

 B. Required Activities  C. Create Information (Included in 4B)  D. Gather Existing Information (Included in 4E)  E. Write Report  Annual Compliance Reporting through e-GGRT b 0.00 0 0.00 0 0 5. RECORDKEEPING REQUIREMENTS  A. Read Instructions (Included in 4A)  B. Plan Activities (Included in 4B)  C. Implement Activities (Included in 4B)  D. Recordkeeping and Associated Calculations b 0.00 0 0.00 0 0 

Time to update facility-specific calculation mechanism (i.e., calculation spreadsheet, recordkeeping database, etc.) to allow for use of new leaker factors e 2.00 1.0 2.00 251 502.0 

E. 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 COST 502.0 

a Costs are calculated by multiplying the number of hours by the appropriate hourly labor rate. For these proposed amendments, only Engineer hours wb These activities are already included in the Subpart W burden according to ICR Number 2300.17 (80 FR 68534; November 5, 2015). These proposed 

impact the burden or cost associated with these activities. 

c There are 200 existing facilities in the Onshore Petroleum and Natural Gas Gathering and Boosting industry segment. d There are 553 existing facilities in the Onshore Petroleum and Natural Gas Production industry segment. e Assuming 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]