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SUPPORTING STATEMENT PART A: 

INFORMATION COLLECTION REQUEST 

REGULATION TO ESTABLISH MANDATORY REPORTING OF GREENHOUSE 

GASES (FINAL RULE FOR PETROLEUM AND NATURAL GAS SYSTEMS, 

SUBPART W) 

EPA ICR No. 2376.02 

OMB CONTROL NUMBER 2060-NEW 

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

 

1(a) Title of the Information Collection 

TITLE: “Regulation to Establish Mandatory Reporting of Greenhouse Gases (Final Rule 

for Petroleum and Natural Gas Systems, Subpart W)”

1(b) Short Characterization/Abstract 

The United States (U.S.) Environmental Protection Agency (EPA) is adding Subpart W 

to the recently promulgated Mandatory Reporting of Greenhouse Gases Program established 

under 40 CFR 98. Subpart W applies to the calculation and reporting of vented, fugitive, flare 

combustion emissions, and stationary and portable equipment combustion emissions from 

selected equipment at the following facilities that emit equal to or greater than 25,000 metric tons 

(mt) of CO2-equivalent (CO2e) per year from source categories covered by the mandatory GHG 

reporting rule: offshore petroleum and natural gas production facilities, onshore petroleum and 

natural gas production facilities (including enhanced oil recovery (EOR)), onshore natural gas 

processing facilities, onshore natural gas transmission compression facilities, onshore natural gas 

storage facilities, liquefied natural gas (LNG) storage facilities, LNG import and export facilities 

and natural gas distribution facilities owned or operated by local distribution companies 

(LDC’s). 

This ICR supplements the ICR for the Mandatory Reporting of Greenhouse Gases Rule 

(OMB Control Number 2060-0629). EPA will merge these ICRs when they are renewed in the 

future. 
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2. NEED FOR AND USE OF THE COLLECTION 

 2(a) Need/Authority for the Collection 

Signed into law on December 26, 2007, the FY2008 Consolidated Appropriations Act 

(henceforth referred to as the “Appropriations Act”) directed EPA to “develop and publish a 

draft rule not later than 9 months after the date of enactment of this Act, and a final rule not later 

than 18 months after the date of enactment of this Act, to require mandatory reporting of 

greenhouse gas emissions above appropriate thresholds in all sectors of the economy of the 

United States.” 

 

The accompanying explanatory statement further directed EPA to “use its existing 

authority under the Clean Air Act” (CAA) to develop a mandatory GHG reporting rule. “The 

Agency is further directed to include in its rule reporting of emissions resulting from upstream 

production and downstream sources, to the extent that the Administrator deems it appropriate. 

The Administrator shall determine appropriate thresholds of emissions above which reporting is 

required, and how frequently reports shall be submitted to EPA. The Administrator shall have 

discretion to use existing reporting requirements for electric generating units” under §821 of the 

1990 CAA amendments. 

In accordance with this directive, EPA is extending the mandatory reporting program 

using its authority under §114 and §208 of the CAA. 

• CAA §114(a) provides EPA broad authority to collect data for the purpose of, among 

other things, “carrying out any provision” of the Act. Under §114(a)(1), EPA may 

require any person who owns or operates any emission source or may have 

information necessary to carry out the provisions of the Act to measure emissions 

(including installing monitoring equipment), maintain records, submit reports, and 

provide other information the Administrator may reasonably require. 

• CAA §208, in Title II of the Act, provides EPA with similar authority regarding the 

manufacturers of new motor vehicles or new motor vehicle engines. 

Further information on the authority provided under §114 and §208 of the CAA is 

contained in section I.C. of the preamble to the final GHG reporting rule (74 FR 56259). 

The scope of the persons potentially subject to a section 114(a)(1) information request 

(e.g., a person ‘‘who the Administrator believes may have information necessary for the 

purposes set forth in’’ section 114(a)) and the reach of the phrase ‘‘carrying out any provision’’ 

of the Act are quite broad. EPA’s authority to request information reaches to a source not subject 

to the CAA, and may be used for purposes relevant to any provision of the Act. 

EPA retains the proposal to include offshore platforms in the final rulemaking. Although 

offshore platforms are under the jurisdiction of the Department of the Interior, EPA believes that 

its jurisdiction under the CAA extends to these offshore platforms because EPA has broad 
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authority under section 114 to collect information that the Administrator believes necessary for 

carrying out the CAA. Because EPA is comprehensively considering how to address climate 

change under the CAA, including both regulatory and non-regulatory options, a rule that requests 

detailed information from a broad spectrum of sources, including offshore platforms, is 

reasonable. 

The Agency believes that information collected by this final rule would also prove useful 

to legislative efforts to address GHG emissions. Because EPA does not yet know the specific 

policies that will be adopted, the data reported through the mandatory reporting system should be 

of sufficient quality to inform policy and program development. Also, consistent with the 

Appropriations Act, the reporting rule covers a broad range of sectors of the economy. 

EPA has identified the following goals of the mandatory reporting system, including: 

• Obtain data that is of sufficient quality that it can be used to analyze and inform the 

development of a range of future climate change policies and potential regulations. 

• Balance the rule’s coverage to maximize the amount of emissions reported while 

excluding small emitters. 

• Create reporting requirements that are, to the extent possible and appropriate, 

consistent with existing GHG reporting programs in order to reduce reporting burden 

for all parties involved. 

2(b) Practical Utility/Users of the Data 

 

A mandatory reporting system for petroleum and natural gas systems will benefit EPA, 

other government agencies, and the public. Transparent, public data on emissions allows for 

accountability of polluters to the public stakeholders who bear the cost of the pollution. Citizens, 

community groups, and labor unions have made use of data from Pollutant Release and Transfer 

Registers to negotiate directly with polluters to lower emissions, circumventing greater 

government regulation. Publicly available emissions data also will allow individuals to alter 

their consumption habits based on the GHG emissions of producers. 

Benefits to industry of GHG emissions monitoring include the value of having 

independent, verifiable data to present to the public to demonstrate appropriate environmental 

stewardship, and a better understanding of their emission levels and sources to identify 

opportunities to reduce emissions. Such monitoring allows for inclusion of standardized GHG 

data into environmental management systems, providing the necessary information to achieve 

and disseminate their environmental achievements. 

Information collected from the oil and gas facilities will allow EPA to gain a better 

understanding of the entire CO2 capture and sequestration (CCS) system. The data reported 

under the final rulemaking and subsequent regulatory actions will together enable EPA to 

understand the amount of CO2 supplied, emitted, and sequestered in the U.S., to carry out a wide 
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variety of CAA provisions. These data can also be coupled with efforts at the local, state, 

federal, and international levels to assist corporations and facilities in determining their carbon 

footprints and identifying further opportunities to reduce emissions. These data can also inform 

future climate change policy decisions. 

The rule is not intended to be a survey and the respondents affected by the rule are not 

intended to be a statistical sample of a larger universe of entities. EPA does not intend to use the 

data collected under this rule to characterize non-reporting entities or to draw statistical 

inferences about a larger population. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA 

 3(a) Nonduplication 

In developing the initial proposal for mandatory reporting from petroleum and natural gas 

systems (April 2009), a second proposed rule (April 2010), as well as the final rulemaking, EPA 

reviewed monitoring methods included in international guidance (e.g., Intergovernmental Panel 

on Climate Change), as well as Federal voluntary programs (e.g., EPA Natural Gas STAR 

Program and the U.S. Department of Energy Voluntary Reporting of Greenhouse Gases Program 

(1605(b))), corporate protocols (e.g., World Resources Institute and World Business Council for 

Sustainable Development GHG Protocol) and industry guidance (e.g., methodological guidance 

from the American Petroleum Institute, the Interstate Natural Gas Association of America, and 

the American Gas Association). 

EPA also reviewed State reporting programs (e.g., California and New Mexico) and 

Regional partnerships (e.g., The Climate Registry, the Western Regional Air Partnership). These 

are important programs that not only led the way in reporting of GHG emissions before the 

Federal government acted but also assist in quantifying the GHG reductions achieved by various 

policies. Many of these programs collect different or additional data as compared to this final 

rule. For example, State programs may establish lower thresholds for reporting, request 

information on areas not addressed in EPA’s reporting rule, or include different data elements to 

support other programs. 

Documentation of EPA’s review of GHG monitoring protocols used by federal, state, and 

international voluntary and mandatory GHG programs, and the review of state mandatory GHG 

rules, can be found in the docket at EPA-HQ-OAR-2008-0508-056. A few of these programs are 

described below: 

• EPA reviewed the Inventory of U.S. Greenhouse Gas Emissions and Sinks (Inventory), 

which is an annual comprehensive top-down assessment of national greenhouses gas 

emissions. While the Inventory is compiled from national surveys, which are not broken 

down at the geographic or facility level, the rule focuses on bottom-up data from 

individual facilities that exceed appropriate thresholds. The bottom-up approach to data 
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collection in the final rule can help EPA transition to the Intergovernmental Panel on 

Climate Change (IPCC) 2006 guidelines for capture, transport, and geological storage at 

the appropriate time. In addition, the emissions factor being used in the 2008 U.S. GHG 

Inventory is believed to significantly underestimate emissions based on industry 

experience as included in the Natural Gas STAR Program publicly available information. 

The 2008 U.S. GHG Inventory emissions factor was developed prior to the boom in 

unconventional well drilling (1992) in the absence of any field data, and therefore does 

not capture the diversity of well completion and workover operations or the variance in 

emissions that can be expected from different hydrocarbon reservoirs in the country. 

• The Agency also examined the voluntary GHG registry that the U.S. Department of 

Energy’s (DOE’s) Energy Information Administration (EIA) implements under §1605b 

of the Energy Policy Act. Under EIA’s “1605b program,” reporters can choose to prepare 

an entity-wide greenhouse gas inventory and identify specific greenhouse gas reductions 

made by the entity. EPA’s mandatory GHG reporting rule covers a much broader set of 

reporters, primarily at the facility rather than entity-level, but this reporting rule is not 

designed with the specific intent of reporting of emission reductions, as is the 1605(b) 

program. 

• The DOE also administers the Climate Vision program (Voluntary Innovative Sector 

Initiatives: Opportunities Now), whose goal includes accelerating the transition to 

technologies, practices, and processes that are capable of reducing, capturing, or 

sequestering GHGs. All voluntary reporting under the Climate Vision Program is 

covered under 1605(b), and as such, it also does not meet EPA’s needs for mandatory 

reporting. 

A growing 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 will share emissions data with the 

exception of any confidential business information (CBI) data with relevant agencies or 

approved entities using, where practical, shared tools and infrastructure. 
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 3(b) Public Notice Required Prior to Information Collection Request (ICR) 

Submissions to OMB 

 As part of the Federal Register notice on the proposed regulation, EPA solicited 

comments on this information collection and the estimates in the April 2010 proposed ICR (75 

FR 18608). EPA also solicited comments on specific aspects of the information collection, as 

described below: 

1) Whether the collection of information is necessary for the proper performance of the 

functions of the Agency, including whether the information would have practical 

utility; 

2) Whether the Agency’s burden estimate is accurate, including the validity of the 

methodology and assumptions used; 

3) How to enhance the quality, utility, and clarity of the information to be collected; and 

4) How to minimize the burden on respondents, including use of appropriate automated 

electronic, mechanical, or other technological collection techniques or other forms of 

information technology. 

EPA received one comment about the ICR. The commenter stated that that use of Clean 

Air Act Section 114 (Section 114) as the basis for the rule runs counter to its longstanding use of 

the section in the past which as been limited to issuing Information Collection Requests (“ICRs”) 

and that ICRs are limited to collecting data from specific sources over a discrete period of time. 

EPA determined that this comment confuses Section 114 and ICR requirements under the 

Paperwork Reduction Act, 44 U.S.C. 3501, et seq. EPA has issued an ICR for this rulemaking, 

has been assigned an EPA ICR number by OMB and has fully complied with PRA requirements. 

See, preamble Section IV.B. See also, Vol 9 explaining that while it might be generally true that 

EPA has used its information gathering authority in a more targeted manner, nothing in Section 

114 precludes this broader, yet still targeted rulemaking. For complete response, see EPA’s 

Response to Comments document, Volume 9.1, the consolidated response to comments EPAHQ-OAR-2009-0923-1005-1, EPA-HQ-OAR-2009-0923-1011-26, EPA-HQ-OAR-2009-0923-

1011-55, EPA-HQ-OAR-2009-0923-1011-58, EPA-HQ-OAR-2009-0923-1196-1 

EPA also received numerous comments on the April 2010 proposed rule itself, many of 

which addressed the reporting activities required by the rule and the associated costs. For 

example, EPA assessed a number of alternative methodologies that were either recommended by 

commenters or are known to provide effective quantification of emissions at a significantly 

lower cost burden. EPA reviewed and updated the economic impact analysis to reflect changes 

made in the final rule. 

The preamble to the final rule summarizes the comments received on the proposed rule as 

well as EPA’s responses. In addition, responses to significant comments on the proposed rule 

can be found in the comment response documents. Both the preamble and the comment response 

documents are in the docket for the rule (EPA-HQ-OAR-2009-0923). 
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In addition, EPA did not receive any comments specifically addressing the ICR for the 

April 2009 proposed rule, i.e., the Mandatory GHG Reporting Rule (74 FR 16448), which 

included the original proposal for subpart W. Although EPA did not receive any comments 

specifically addressing the ICR for that proposed rule, EPA received a substantial number of 

comments on the recordkeeping and reporting requirements about that proposal. For example, 

public comments on the April 2009 proposed rule suggested that EPA require retention of 

records for three years rather than the five years specified in the proposed rule. (In response, 

EPA changed the record retention requirement in the final rule from five years to three years.) 

See ICR 2300.03 (OMB Control Number 2060-0629) for complete details about the ICR for the 

April 2009 proposed rule. 

In compliance with the Paperwork Reduction Act (44 USC 3501 et seq.), EPA is 

submitting this ICR for the final Subpart W: Petroleum and Natural Gas Systems rule to the 

Office of Management and Budget (OMB) for review and approval. 

3(c) Consultations 

Early in the development process of the GHG reporting rule, EPA conducted a proactive 

communications outreach program to inform the public about the rule development effort. EPA 

solicited input and maintained an open-door policy for those interested in discussing the 

rulemaking. Since January 2008, EPA staff has held more than 100 meetings with stakeholders, 

including: 

• 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. 

EPA also met with federal agencies, including DOE and the U.S. Department of 

Agriculture, which have programs relevant to GHG emissions. 

On April 10, 2009 (74 FR 16448), EPA proposed the GHG reporting rule. EPA held two 

public hearings, and received more than 16,000 written public comments. The public comment 

period ended on June 9, 2009. Subpart W received comments from more than 80 entities with 

over 1,200 pages of comments, recommendations, and alternatives for consideration. Details 

about these meetings and the responses to comments are available in the docket (EPA-HQ-OAR2009-0923). 
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 3(d) Effects of Less Frequent Collection 

The reporting frequency for emissions data to EPA has been established to minimize the 

burden on owners and operators of affected facilities, while ensuring that the reporting rule 

collects facility-specific data of sufficient quality to achieve the Agency’s objectives. EPA 

requires that emissions from the petroleum and natural gas industry be reported on an annual 

basis, except where existing programs must provide data on a more frequent basis. 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. The yearby-year GHG emissions information from a broad range of industry sectors may eventually be 

used to inform future climate change policy decisions. 

 3(e) General Guidelines 

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

1320.6. 

 3(f) Confidentiality 

EPA issued a proposal addressing the confidentiality of the Part 98 data elements on July 

7, 2010 (75 FR 39094). The proposed confidentiality determination specified which data 

reporting elements in part 98 would be treated as confidential business information (CBI) and 

which data elements must be available to the public under section 114 of the CAA. Final 

determinations will be made regarding the confidentiality of the data reporting elements before 

the reporting elements are made available to the public. 

 3(g) Sensitive Questions 

This information collection does not ask any questions concerning sexual behavior or 

attitudes, religious beliefs, or other matters usually considered private. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

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

gas facilities that must report their emissions to EPA to comply with the rulemaking. This section 

lists the industry sectors that must comply with the rule, the data items required of program 

participants, and the activities in which participants must engage to collect, assess, and in some 

cases submit the required data items. 

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

The industry sectors for Subpart W are listed below and its NAICS code is provided for 

reference. 

Part and Subpart NAICS code(s)

Part 98 

W. Petroleum and 

Natural Gas Systems 

486210 Pipeline transportation of natural gas. 

221210 Natural gas distribution facilities. 

211 Extractors of crude petroleum and natural gas. 

211112 Natural gas liquid extraction facilities. 

 

4(b) Information Requested 

(i) Data Items 

 Reporting Requirements 

The following is a summary of the information requested by facilities that would be 

subject to subpart W: 

General requirements that apply to all sources. All respondents that exceed the 

reporting threshold or that belong to a source category in which all respondents report, including 

subpart W, must submit the general information required in 40 CFR 98.3 and adhere to the 

reporting, certification, and notification requirements in 40 CFR 98.4 and 40 CFR 98.2, if 

applicable. EPA is not making any changes to these requirements. This information is described 

in the ICR for the Mandatory Reporting of Greenhouse Gases; Final Rule (EPA ICR No. 

2300.03). In addition, the owner or operator of a facility that exceeds the threshold specific to 

subpart W must report emissions annually from all source categories present at the facility for 

which methods are specified in 40 CFR part 98. 

Petroleum and natural gas systems under Subpart W. 

a) Report annual emissions separately for each of the industry segments listed below in metric 

tons CO2e per year at standard conditions. For each segment, report emissions from each 

source type 40 CFR 98.232 (a) in the aggregate, unless specified otherwise. 

1) Onshore petroleum and natural gas production. 

2) Offshore petroleum and natural gas production. 

3) Onshore natural gas processing. 

4) Onshore natural gas transmission compression. 

5) Underground natural gas storage. 

6) LNG storage. 

7) LNG import and export. 
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8) Natural gas distribution. Report each source in the aggregate for pipelines and for 

Metering and Regulating (M&R) stations. 

b) Offshore petroleum and natural gas production is not required to report activity data and 

emissions for each aggregated source under 40 CFR 98.236 (c). Reporting requirements for 

offshore petroleum and natural gas production is set forth by BOEMRE in compliance with 

30 CFR 250.302 through 304. 

c) For each aggregated source, unless otherwise specified, report activity data and emissions (in 

metric tons CO2e per year at standard conditions) for each aggregated source type as follows: 

1) For natural gas pneumatic devices (refer to Equation W-1 of 40 CFR 98.233), report 

the following: 

i) Actual count and estimated count separately of natural gas pneumatic high 

bleed devices as applicable. 

ii) Actual count and estimated count separately of natural gas pneumatic low 

bleed devices as applicable. 

iii) Actual count and estimated count separately of natural gas pneumatic 

intermittent bleed devices as applicable. 

iv) Report emissions collectively. 

2) For natural gas driven pneumatic pumps (refer to Equation W-2 of 40 CFR 98.233), 

report the following, 

i) Count of natural gas driven pneumatic pumps. 

ii) Report emissions collectively. 

3) For each acid gas removal unit (refer to Equation W-3 and Equation W-4 of 40 CFR 

98.233), report the following: 

i) Total throughput off the acid gas removal unit using a meter or engineering 

estimate based on process knowledge or best available data in million cubic 

feet per year. 

ii) For Calculation Methodology 1 and Calculation Methodology 2 of 40 CFR 

98.233(d), fraction of CO2 content in the vent from the acid gas removal unit 

(refer to 40 CFR 98.233(d)(1) or (d)(5)). 

iii) For Calculation Methodology 3 of 40 CFR 98.233(d), volume fraction of CO2

content of natural gas into and out of the acid gas removal unit (refer to 40 

CFR 98.233(d)(6) and (d)(7)). 

iv) Report emissions from the AGR unit recovered and transferred outside the 

facility. 

v) Report emissions individually. 

4) For dehydrators, report the following: 

i) For each Glycol dehydrator with a throughput greater than or equal to 0.4 

MMscfd (refer to 40 CFR 98.233(e)(1)), report the following: 

A) Glycol dehydrator feed natural gas flow rate in MMscfd, determined 

by engineering estimate based on best available data. 
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B) Glycol dehydrator absorbent circulation pump type. 

C) Whether stripper gas is used in glycol dehydrator. 

D) Whether a flash tank separator is used in glycol dehydrator. 

E) Type of absorbent. 

F) Total time the glycol dehydrator is operating in hours. 

G) Temperature, in degrees Fahrenheit and pressure, in psig, of the wet 

natural gas. 

H) Concentration of CH4 and CO2 in natural gas. 

I) What vent gas controls are used (refer to 40 CFR 98.233(e)(3) and 

(e)(4)). 

J) Report vent and flared emissions individually. 

ii) For all glycol dehydrators with a throughput less than 0.4 MMscfd (refer to 

40 CFR 98.233, Equation W-5 of 40 CFR 98.233), report the following: 

A) Count of glycol dehydrators. 

B) Whether any vent gas controls are used (refer to 40 CFR 

98.233(e)(3) and (e)(4)). 

C) Report vent emissions collectively. 

iii) For absorbent desiccant dehydrators (refer to Equation W-6 of 40 CFR 

98.233), report the following: 

A) Count of desiccant dehydrators. 

B) Report emissions collectively. 

5) For well venting for liquids unloading (refer to Equations W-7, W-8 and W-9 of 40 

CFR 98.233), report the following by field: 

i) Count of wells vented to the atmosphere for liquids unloading. 

ii) Count of plunger lifts. 

iii) Cumulative number of unloadings vented to the atmosphere. 

iv) Average flow rate of the measured well venting in cubic feet per hour (refer 

to 40 CFR 98.233(f)(1)(i)(A)). 

v) Average casing diameter in inches. 

vi) Report emissions collectively. 

6) For well completions and workovers, report the following for each field: 

i) For gas well completions and workovers with hydraulic fracturing (refer to 

Equation W-10 of 40 CFR 98.233): 

A) Total count of completions in calendar year. 

B) Average flow rate of the measured well completion venting in cubic 

feet per hour (refer to 40 CFR 98.233(g)(1)(i)(A) or (g)(1)(ii)(A)). 

C) Total count of workovers in calendar year. 

D) Average flow rate of the measured well workover venting in cubic 

feet per hour (refer to 40 CFR 98.233(g)(1)(i)(A) or (g)(1)(ii)(A)). 
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E) Total number of days of gas venting to the atmosphere during 

backflow for completion. 

F) Total number of days of gas venting to the atmosphere during 

backflow for workovers. 

G) Report number of completions and workovers employing reduced 

emissions completions and engineering estimate based on best 

available data of the amount of gas recovered to sales. 

H) Report vent emissions collectively. Report flared emissions 

collectively. 

ii) For gas well completions and workovers without hydraulic fracturing (refer 

to Equation W-13 of 40 CFR 98.233): 

A) Total count of completions in calendar year. 

B) Total count of workovers in calendar year. 

C) Total number of days of gas venting to the atmosphere during 

backflow for completion. 

D) Report vent emissions collectively. Report flared emissions 

collectively. 

7) For each blowdown vent stack (refer to Equation W-14 of 40 CFR 98.233), report 

the following: 

i) Total number of blowdowns per equipment type in calendar year. 

ii) Report emissions collectively per equipment type. 

8) For gas emitted from produced oil sent to atmospheric tanks: 

i) For wellhead gas-liquid separator with oil throughput greater than or equal to 

10 barrels per day, using Calculation Methodology 1 and 2 of 40 CFR 

98.233(j), report the following by field: 

A) Number of wellhead separators sending oil to atmospheric tanks. 

B) Estimated average separator temperature, in degrees Fahrenheit, and 

estimated average pressure, in psig. 

C) Estimated average sales oil stabilized API gravity, in degrees. 

D) Count of hydrocarbon tanks at well pads. 

E) Best estimate of count of stock tanks not at well pads receiving your 

oil. 

F) Total volume of oil from all wellhead separators sent to tank(s) in 

barrels per year. 

G) Count of tanks with emissions control measures, either vapor 

recovery system or flaring, for tanks at well pads. 

H) Best estimate of count of stock tanks assumed to have emissions 

control measures not at well pads, receiving your oil. 

I) Range of concentrations of flash gas, CH4 and CO2. 
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J) Report emissions individually for Calculation Methodology 1 and 2 

of 40 CFR 98.233(j). 

ii) For wells with oil production greater than or equal to 10 barrels per day, 

using Calculation Methodology 3 and 4 of 40 CFR 98.233(j), report the 

following by field: 

A) Total volume of sales oil from all wells in barrels per year. 

B) Total number of wells sending oil directly to tanks. 

C) Total number of wells sending oil to separators off the well pads. 

D) Sales oil API gravity range for (B) and (C) of this section, in 

degrees. 

E) Count of hydrocarbon tanks on wellpads 

F) Count of hydrocarbon tanks, both on and off well pads assumed to 

have emissions control measures: either vapor recovery system or 

flaring of tank vapors. 

G) Report emissions collectively for Calculation Methodology 3 and 4 

of 40 CFR 98.233(j). 

iii) For wellhead gas-liquid separators and wells with throughput less than 10 

barrels per day, using Calculation Methodology 5 of 40 CFR 98.233(j) 

Equation W-15 of 40 CFR 98.233), report the following: 

A) Number of wellhead separators. 

B) Number of wells without wellhead separators. 

C) Total volume of oil production in barrels per year. 

D) Best estimate of fraction of production sent to tanks with assumed 

control measures: either vapor recovery system or flaring of tank 

vapors. 

E) Count of hydrocarbon tanks on well pads. 

F) Report CO2 and CH4 emissions collectively. 

iv) If wellhead separator dump valve is functioning improperly during the 

calendar year (refer to Equation W-16 of 40 CFR 98.233), report the 

following: 

A) Count of wellhead separators that dump valve factor is applied. 

9) For transmission tank emissions identified using optical gas imaging instrument per 

40 CFR 98.234(a) (refer to 40 CFR 98.233(k)), or acoustic leak detection of scrubber 

dump valves report the following for each tank: 

i) Report emissions individually. 

10) For well testing (refer to Equation W-17 of 40 CFR 98.233), report the following for 

each basin: 

i) Number of wells tested per basin in calendar year. 

ii) Average gas to oil ratio for each basin. 

iii) Average number of days the well is tested in a basin. 
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iv) Report emissions of the venting gas collectively. 

11) For associated natural gas venting (refer to Equation W-18 of 40 CFR 98.233), report 

the following for each basin: 

i) Number of wells venting or flaring associated natural gas in a calendar year. 

ii) Average gas to oil ratio for each basin. 

iii) Report emissions of the flaring gas collectively. 

12) For flare stacks (refer to Equation W-19, W-20, and W-21 of 40 CFR 98.233), report 

the following for each flare: 

i) Whether flare has a continuous flow monitor. 

ii) Volume of gas sent to flare in cubic feet per year. 

iii) Percent of gas sent to un-lit flare determined by engineering estimate and 

process knowledge based on best available data and operating records. 

iv) Whether flare has a continuous gas analyzer. 

v) Flare combustion efficiency. 

vi) Report uncombusted and combusted CO2 and CH4 emissions separately. 

13) For each centrifugal compressor: 

i) For compressors with wet seals in operational mode (refer to Equations W-22 

through W-24 of 40 CFR 98.233), report the following for each degassing 

vent: 

A) Number of wet seals connected to the degassing vent. 

B) Fraction of vent gas recovered for fuel or sales or flared. 

C) Annual throughput in million scf, use an engineering calculation 

based on best available data. 

D) Type of meters used for making measurements. 

E) Reporter emission factor for wet seal oil degassing vents in cubic 

feet per hour (refer to Equation W-24 of 40 CFR 98.233). 

F) Total time the compressor is operating in hours. 

G) Report seal oil degassing vent emissions for compressors measured 

(refer to Equation W-22 of 40 CFR 98.233) and for compressors not 

measured (refer to Equation W-24 of 40 CFR 98.233). 

ii) For wet and dry seal centrifugal compressors in operating mode, (refer to 

Equations W-22 through W-24 of 40 CFR 98.233), report the following: 

A) Total time in hours the compressor is in operating mode. 

B) Reporter emission factor for blowdown vents in cubic feet per hour 

(refer to Equation W-23 of 40 CFR 98.233). 

C) Report blowdown vent emissions when in operating mode (refer to 

Equation W-24 of 40 CFR 98.233). 

iii) For wet and dry seal centrifugal compressors in not operating, depressurized 

mode (refer to Equations W-22 through W-24 of 40 CFR 98.233), report the 

following: 
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A) Total time in hours the compressor is in shutdown, depressurized 

mode. 

B) Reporter emission factor for isolation valve emissions in shutdown, 

depressurized mode in cubic feet per hour (refer to Equation W-24 

of 40 CFR 98.233). 

C) Report the isolation valve leakage emissions in not operating, 

depressurized mode in cubic feet per hour (refer to Equation W-22 

of 40 CFR 98.233). 

iv) Report total annual compressor emissions from all modes of operation (refer 

to Equation W-24 of 40 CFR 98.233). 

v) For centrifugal compressors in onshore petroleum and natural gas production 

(refer to Equation W-25 of 40 CFR 98.233), report the following: 

A) Count of compressors. 

B) Report emissions (refer to Equation W-25 of 40 CFR 98.233) 

collectively. 

14) For reciprocating compressors: 

i) For reciprocating compressors rod packing emissions with or without a vent 

in operating mode, report the following: 

A) Annual throughput in million scf, use an engineering calculation 

based on best available data. 

B) Total time in hours the reciprocating compressor is in operating 

mode. 

C) Report rod packing emissions for compressors measured (refer to 

Equation W-26 of 40 CFR 98.233) and for compressors not 

measured (refer to Equation W-27 of 40 CFR 98.233). 

ii) For reciprocating compressors blowdown vents not manifold to rod packing 

vents, in operating and standby pressurized mode (refer to Equations W-26 

through W-28 of 40 CFR 98.233), report the following: 

A) Total time in hours the compressor is in standby, pressurized mode. 

B) Reporter emission factor for blowdown vents in cubic feet per hour 

(refer to 40 CFR 98.233, Equation W-27). 

C) Report blowdown vent emissions when in operating and standby 

pressurized modes (refer to Equation W-27 of 40 CFR 98.233). 

iii) For reciprocating compressors in not operating , depressurized mode (refer to 

Equations W-26 through W-28 of 40 CFR 98.233), report the following: 

A) Total time the compressor is in not operating, depressurized mode. 

B) Reporter emission factor for isolation valve emissions in not 

operating, depressurized mode in cubic feet per hour (refer to 

Equation W-28 of 40 CFR 98.233). 
16

C) Report the isolation valve leakage emissions in not operating, 

depressurized mode. 

iv) Report total annual compressor emissions from all modes of operation (refer 

to Equation W-27 of 40 CFR 98.233). 

v) For reciprocating compressors in onshore petroleum and natural gas 

production (refer to Equation W-29 of 40 CFR 98.233), report the following: 

A) Count of compressors. 

B) Report emissions collectively. 

15) For each equipment leak sources that uses emission factors for estimating emissions 

(refer to 40 CFR 98.233(q) and (r). 

i) For equipment leaks found in each leak survey (refer to 40 CFR 98.233(q)), 

report the following: 

A) Total count of leaks found in each complete survey listed by date of 

survey and each type of leak source for which there is a leaker 

emission factor in Tables W-2, W-3, W-4, W-5, W-6, and W-7 of 

this subpart. 

B) Concentration of CH4 and CO2 as described in Equation W-30 of 40 

CFR 98.233. 

C) Report CH4 and CO2 emissions (refer to Equation W-30 of 40 CFR 

98.233) collectively by equipment type. 

ii) For equipment leaks calculated using population counts and factors (refer to 

40 CFR 98.233(r)), report the following: 

A) For source categories 40 CFR 98.230(a)(3), (a)(4), (a)(5), (a)(6), and 

(a)(7), total count for each type of leak source in Tables W-2, W-3, 

W-4, W-5, and W-6 of this subpart for which there is a population 

emission factor, listed by major heading and component type. 

B) [Reserved] 

C) Report CH4 and CO2 emissions (refer to Equation W-30 of 40 CFR 

98.233) collectively by equipment type. 

16) For local distribution companies, report the following: 

i) Number of custody transfer gate stations. 

ii) Number of non-custody transfer gate stations. 

iii) Custody transfer gate station meter run leak factor (refer to Equation W-32 of 

40 CFR 98.233). 

iv) Number of below grade M&R stations with inlet pressure greater than 300 

psig. 

v) Number of below grade M&R stations with inlet pressure between 100 and 

300 psig. 

vi) Number of below grate M&R stations with inlet pressure less than 100 psig. 

vii) Number of miles of unprotected steel distribution mains. 
17

viii)Number of miles of protected steel distribution mains. 

ix) Number of miles of plastic distribution mains. 

x) Number of miles of cast iron distribution mains. 

xi) Number of unprotected steel distribution services. 

xii) Number of protected steel distribution services. 

xiii)Number of plastic distribution services. 

xiv) Number of copper distribution services. 

xv) Total emissions from each natural gas distribution facility. 

17) For each EOR injection pump blowdown (refer to Equation W-37 of 40 CFR 

98.233), report the following: 

i) Pump capacity, in barrels per day. 

ii) Volume of critical phase gas between isolation valves. 

iii) Number of blowdowns per year. 

iv) Critical phase EOR injection gas density. 

v) Report emissions collectively. 

18) For EOR hydrocarbon liquids dissolved CO2 for each field (refer to Equation W-38 

of 40 CFR 98.233), report the following: 

i) Volume of crude oil produced in barrels per year. 

ii) Amount of CO2 retained in hydrocarbon liquids in metric tons per barrel, 

under standard conditions. 

iii) Report emissions individually. 

19) For onshore petroleum and natural gas production and natural gas distribution 

combustion emissions, report the following: 

i) Cumulative number of external fuel combustion units with a rated heat 

capacity equal to or less than 5 mmBtu/hr, by type of unit. 

ii) Cumulative number of external fuel combustion units with a rated heat 

capacity larger than 5 mmBtu/hr, by type of unit. 

iii) Cumulative emissions from external fuel combustion units with a rated heat 

capacity larger than 5 mmBtu/hr, by type of unit. 

iv) Cumulative volume of fuel combusted in external fuel combustion units with 

a rated heat capacity larger than 5 mmBtu/hr, by fuel type. 

v) Cumulative number of all internal combustion units, by type of unit. 

vi) Cumulative emissions from internal combustion units, by type of unit. 

vii) Cumulative volume of fuel combusted in internal combustion units, by fuel 

type. 

d) Report annual throughput as determined by engineering estimate based on best available data 

for each industry segment listed in paragraphs (a)(1) through (a)(8) of this section. 

e) For offshore petroleum and natural gas production facilities, report the number of connected 

wells, and whether the wells are producing oil, gas, or both. 
18

f) Report emissions separately for portable equipment for the following source types: drilling 

rigs, dehydrators, compressors, electrical generators, steam boilers, and heaters. 

1) Aggregate emissions by source type. 

2) Report count of each source type. 

Recordkeeping Requirements 

General requirements that apply to all sources. EPA has not changed the general 

recordkeeping requirements that apply to all sources, including Subpart W. This information is 

described in the ICR for the Mandatory Reporting of Greenhouse Gases; Final Rule (EPA ICR 

No. 2300.03). In addition, the owner or operator of a facility that exceeds the threshold specific 

to subpart W must comply with recordkeeping requirements associated with the specific 

subparts. 

Petroleum and natural gas facilities under Subpart W. Petroleum and natural gas 

facilities must also retain records for the following information specific to the given source 

category. 

1. Dates on which measurements were conducted. 

2. Results of all emissions detected and measurements. 

3. Calibration reports for detection and measurement instruments used. 

4. Inputs and outputs of calculations or emissions computer model runs used for engineering 

estimation of emissions. 

(ii) Respondent Activities 

The owner or operator of a facility that is subject to the rule’s reporting requirements 

must report total annual GHG emissions in metric tons of CO2e from all the source categories at 

the facility. The primary tasks that reporting program respondents will perform include: 

1. Developing appropriate monitoring plans for each affected source and each affected 

unit at a source, as applicable; 

2. 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 EPA; 

4. Potentially responding to questions or error messages from EPA; and 

5. Maintaining records for a minimum of three years. In addition, respondents must 

purchase the necessary monitoring hardware and purchase the electronic data 
19

reporting software (or software upgrades) if they had not done so for another 

reporting program. 

Reports must present the annual mass GHG emissions from each source category 

separately. The calculations used to determine GHG emissions, the frequency at which those 

calculations are required, the methods used to estimate missing data, and the QA/QC 

requirements depend on the specific source category. 

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT 

 5(a) Agency Activities 

EPA Headquarters activities associated with the rule include program start-up activities 

are reflected in the ICR for the Final Mandatory Reporting Rule (EPA ICR No. 2300.03). This 

ICR reflects an incremental agency burden for program operation activities, which include 

monitoring and verification of emission reports, database and software maintenance, 

communication and outreach, and program evaluation. 

 5(b) Collection Methodology and Management 

EPA will establish a central repository of inventory data for all respondents. Respondents 

will report data electronically, and EPA will store the data in the database. The electronic format, 

which will reflect the underlying electronic data reporting system, will be developed prior to the 

first reporting date. By specifying in the rule text the exact information that must be reported but 

not specifying the exact reporting format, EPA informs reporters about exactly what information 

they must report and has flexibility to modify the electronic reporting format and electronic data 

reporting system in a timely manner based on implementation experience and new technology. 

EPA has used this approach successfully in existing programs, such as the Acid Rain Program 

and the Title VI Stratospheric Ozone Protection Program, facilitating the deployment of new 

reporting formats and reporting systems that take advantage of technologies such as eXtensible 

Markup Language (XML), and reduce the burden on reporters and the Agency. The electronic 

reports submitted under this rule are subject to the provisions of 40 CFR part 3, specifying EPA 

systems to which electronic submissions must be made and the requirements for valid electronic 

signatures. 

The Designated Representative must use an electronic signature device (e.g., a PIN or 

password) to submit a report. If the Designated Representative holds an electronic signature 

device that is currently used for valid electronic signatures accepted under another Agency 
20

program, EPA intends to design the new reporting system to also accept valid electronic 

signatures executed with that device where feasible. 

EPA’s reporting format for a given reporting year could make use of several ID codes – 

unique codes for a unit or facility. To ensure proper matching between databases, e.g., EPAassigned facility ID codes and the ORIS (DOE) ID code, and consistency from one reporting 

year to the next, we plan for the reporting system to provide each facility with a unique 

identification code to be specified by the Administrator. 

The Agency plans to publish data submitted or collected under this rulemaking through 

EPA's Web site, reports, and other formats (e.g., XML), with the exception of any CBI data. The 

data could be used by EPA and other agencies, and other organizations and stakeholders for air 

modeling, analyzing emissions by industry sector and region, informing future climate change 

policy decisions, and answering questions from the public. The new system will follow Agency 

standards for design, security, data element and reporting format conformance, and accessibility. 

In designing the data base, EPA will attempt to minimize respondents’ burden by integrating the 

new reporting requirements with existing data collection and data management systems, when 

feasible. 

 5(c) Small Entity Flexibility 

The Agency met several times with industry trade associations to discuss the reporting 

options considered and their possible impacts on small entities. In the final Mandatory GHG 

Reporting Rule, EPA took several steps to minimize the impacts on small entities, and these 

provisions would apply to facilities under subpart W. EPA further minimized impacts on small 

entities by not requiring facilities below a certain emissions threshold to report their emissions. 

In addition, the rule includes a mechanism in 40 CFR 98.2 to allow facilities and suppliers that 

report less than 25,000 mtCO2e for 5 years to cease annual reporting to EPA. If reported 

emissions are less than 15,000 mtCO2e per year for three consecutive years, then the owner or 

operator may discontinue reporting. In developing the Subpart W final rule, EPA continued to 

take steps to minimize the impacts on small entities. EPA has made every effort to reduce the 

burden and costs of the rule, while still ensuring that the program yields high quality data and 

essential information. For example, the final rule includes alternative data collection 

methodologies to target major emitting equipment sources. 

 5(d) Collection Schedule 

Under 40 CFR part 98, subpart W, facilities must submit GHG emission reports annually. 

Respondents that have emissions or products with emission less than 25,000 mtCO2e for five 

years in a row may cease reporting. 
21

 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

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

with the activities described in Section 4 as well as the federal burden hours and costs associated 

with the activities described in Section 5(a). EPA estimates that, over the three years covered by 

this request, the total respondent burden associated with this reporting will average 396,474 

hours per year and the cost to respondents of the information collection will average $27.7 

million per year. 

Section 6(a) of this ICR 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. The burden statement for this information collection is in Section 6(f). 

6(a) Estimating Respondent Burden 

 Respondent burden estimates are presented in Exhibit 6.1. EPA estimates that the total 

annual burden to all affected entities is 396,474 hours per year over the three years covered by 

this information collection. EPA also estimated the number of responses, or actions taken as a 

result of the rule, per respondent (facility) per year; for facilities collecting samples on a daily 

basis, this means a minimum of 365 responses per year. Exhibit 6.1 presents aggregate burden by 

sector only; for the details of burden calculations, please see Appendix A. 

6(b) Estimating Respondent Costs 

Costs to respondents associated with this information collection include labor costs (i.e., 

the cost of labor by facility staff to meet the rule’s information collection requirements) and nonlabor costs (e.g., the cost of purchasing and installing monitoring equipment or contractor costs 

associated with providing the required information). 

To calculate labor costs, EPA estimated technical, managerial, clerical, and legal loaded 

labor rates for each industry sector using labor rates from the Bureau of Labor Statistics[1] and 

applying a 60% loading factor[2]; these rates vary somewhat by sector. For Subpart W, the labor 

 

[1] These rates reflect adjustments of the manufacturing sector's average productivity increase of 3.7% per year for 6 

quarters between 2006 Q2 and 2007 Q4, based on the estimate released by the Bureau of Labor Statistics in March 

2008.

[2] The ICR Handbook (November 2005) recommends using a multiplier of 1.6 to account for benefits and overhead 

related to government wages; this is considered a conservative estimate (potentially high) for the private sector. 
22

rates are: $88.79 for electricity managers; $101.31 for refinery managers, $71.03 for industrial 

managers; $60.84 for electricity engineers/technicians, $63.89 for Refinery Engineers/ 

Technicians, and $55.20 for Industrial Engineers/Technicians; $29.65 for clerical staff, and 

$101.00 for legal staff. Non-labor costs (capital and O&M) for individual sectors are presented in 

Appendix C. 

 
EPA estimates that the total annual cost to all affected non-federal entities is $27.7 million over the three 

information collection. Exhibit 6.1 presents aggregate costs by sector only; for the details of EPA’s cost calculatiAppendix B. Exhibit 6.1 Annual Average Respondent Burden and Cost For Subpart W of the GHG Reporting Rule ($K) 

Source Category

No.

Respond‐

ents

Responses/

Respondent

Total

Responses

Burden ‐ 

Technical

(hrs)

Burden ‐ 

Managerial

(hrs)

Burden ‐ 

Clerical

(hrs)

Burden ‐ 

Legal

(hrs)

Total Burden

(hrs)

Total Labor

Cost

($K)

Capital Cost

($K)

O&M Cost

($K)

Total 

($K

Gas Processing 289 2 394 50,381 5,061 0 0 55,441 $3,798 $220 $123 

Transmission Compressor

Stations 1,145 2 1,487 113,877 7,528 0 0 121,405 $8,054 $395 $1,154 Storage 133 2 215 16,229 2,988 0 0 19,218 $1,309 $26 $147 Lng Terminals 4 2 4 399 65 0 0 463 $33 $12 $8 

Onshore Production 981 2 1,962 111,354 31,343 0 0 142,698 $10,152 $56 $0 $

Local Distribution Companies 143 2 143 18,235 1,840 0 0 20,075 $1,268 $21 $228 Lng Storage 33 2 64 4,165 1,002 0 0 19,004 $362 $14 $26 

Offshore Production 58 2 102 2,633 1,327 0 0 18,170 $286 $0 $0 

TOTAL 2,786 Varies 4,371 317,273 51,155 0 0 396,474 $25,261 $745 $1,687 $
24
25

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 and required reporting by federally owned GHG 

generating facilities. 

EPA burden and cost 

EPA activities associated with the mandatory GHG reporting rule include Headquarters 

oversight and implementation of the reporting program, e.g., monitoring and verification of 

emission reports, database and software maintenance, communication and outreach, and program 

evaluation. EPA estimates that, in implementing subpart W, Headquarters will incur an 

incremental burden of 4 full time equivalents (FTEs), or just $460,000 for these activities. 

To develop EPA labor costs, EPA estimates the average hourly labor rate for salary and 

overhead and benefits for Agency staff to be $50.14. To derive this figure, EPA multiplied the 

hourly compensation at GS-12, Step 5 on the 2008 GS pay scale ($31.34) by the standard 

government benefits multiplication factor of 1.6 to account for overhead and benefits. 

In addition to the labor cost, EPA will incur an incremental cost of just under $700 

thousand in each of the first three years for third-party verification. 

Burden and cost for federal facilities covered by the rule 

Exhibit 6.2 presents the annual burden and cost for federal facilities that must comply 

with the rule. 

Exhibit 6.2 Annual Agency Burden and Cost ($K) 

Information Collection 

Activity 

Annual 

Responses 

Total 

Annual 

Burden 

Labor 

Cost 

Non-Labor 

Cost 

Total 

Annual 

Cost 

W. Petroleum and Natural 

Gas Systems 1 9174 $460 $660 $1,100 

TOTAL 1 9174 $460 $660 $1,100 

6(d) Estimating the Respondent Universe and Total Burden and Costs 
26

The number of respondents in each sector that will perform the required activities under 

this information collection is presented in Exhibit 6.1. 

6(e) Bottom Line Burden Hours and Costs 

The bottom line burden hours and costs are shown in Exhibit 6.3. 

Exhibit 6.3 Bottom Line Annual Burden and Cost 

Number of Respondents 2,786 From Exhibit 6.1

Total Annual Responses 4,371 From Exhibit 6.1

1.6 = 4,371 Total annual responses from above ÷

2,786 Total respondents from above

Total Respondent Hours 396,474 From Exhibit 6.1

Hours per Response 90.71 = 396,474 Total annual hours from above ÷

4,371 Total responses from above

Annual O&M and Capital Cost   $2,431,360 From Exhibit 6.1

Total Respondent Cost (labor + non) $27,692,483 From Exhibit 6.1

405,648 = 396,474 Total respondent hours from above +

9,174 Total EPA hours

$28,792,483 = $27,692,483 Total respondent cost from above +

$1,100,000 Total EPA cost

Number of Responses per Respondent

Total Hours (Respondents and agency)

Total Cost (Respondents plus Agency)

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

6(f) Burden Statement 

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

396,474 hours per year for a three year period, including a first year where initial labor and 

capital costs are anticipated, and two subsequent years in which identical annual costs are 

anticipated. The average annual burden to EPA for this period is estimated to be 9,174 hours for 

oversight activities for other federal facilities that must comply with the rule. The annual public 
27

reporting and recordkeeping burden for this collection of information is estimated to average 91 

hours per response. 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 EPA’s regulations are listed in 40 CFR part 9. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OAR-2009-0923, 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), EPA West Building, 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-2009-0923 and 

OMB Control Number 2060-NEW on any correspondence.