1 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 Re porting of Greenhouse Gases (Final Rule for Petroleum and Natural Gas Systems, Subpart W)”

1(b) Short Charact erization/Abstract

The United States (U.S.) Environmental Pr otection Agency (EPA) is adding Subpart W to the recently promulgated Mandatory Reporti ng of Greenhouse Gases Program established under 40 CFR 98. Subpart W applies to the calcula tion and reporting of ve nted, fugitive, flare combustion emissions, and stationary and por table equipment combustion emissions from selected equipment at the followi ng facilities that emit equal to or greater than 25,000 metric tons (mt) of CO 2 -equivalent (CO 2 e) per year from source categories covered by the mandatory GHG reporting rule: offshore petroleum and natural ga s production facilities, onshore petroleum and natural gas production facilities (including enha nced oil recovery (EOR )), onshore natural gas processing facilities, onshore natu ral gas transmission compression facilities, onshore natural gas storage facilities, liquefied natural gas (LNG) st orage facilities, LNG import and export facilities and natural gas distribution f acilities owned or operated by local distribution companies (LDC’s).

This ICR supplements the ICR for the Ma ndatory Reporting of Greenhouse Gases Rule (OMB Control Number 2060-0629). EPA will merge th ese ICRs when they are renewed in the future.2 2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Signed into law on December 26, 2007, the FY 2008 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 thres holds in all sectors of the economy of the United States.”

The accompanying explanatory statement furt her 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 determin e appropriate thresholds of em issions above which reporting is required, and how frequently reports shall be submitted to EPA. The Administrator shall have discretion to use existing reporti ng requirements for electric gene rating 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 operate s any emission source or may have information necessary to ca rry out the provisions of th e Act to measure emissions (including installing monitoring equipment) , maintain records, submit reports, and provide other information the Admi nistrator may reasonably require.

• CAA §208, in Title II of the Act, provides EPA with similar authority regarding the manufacturers of new mo tor vehicles or new mo tor vehicle engines.

Further information on the authority pr ovided under §114 and §208 of the CAA is contained in section I.C. of the preamble to the final GHG reporting ru le (74 FR 56259).

The scope of the persons potentially subjec t 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 phras e ‘‘carrying out any provision’’ of the Act are quite broad. EPA’s authority to requ est information reaches to a source not subject to the CAA, and may be used for purposes re levant 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 broad3 authority under section 114 to co llect information that the Administrator believes necessary for carrying out the CAA. Because EPA is comprehe nsively considering how to address climate change under the CAA, including both regulatory a nd 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 pr ogram 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 th e mandatory reporting system, including:

• Obtain data that is of sufficient quality th at it can be used to analyze and inform the development of a range of future climate change policies and pot ential 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 progr ams in order to reduce reporting burden for all parties involved.

2(b) Practical Utilit y/Users of the Data

A mandatory reporting system for petroleum and natural gas systems will benefit EPA, other government agencies, and the public. Tr ansparent, 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 pollute rs to lower emissions, circumventing greater government regulation. Publicly available emissi ons 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 unde rstanding of their emission le vels and sources to identify opportunities to reduce emissions. Such monitori ng allows for inclusion of standardized GHG data into environmental management systems, providing the necessary in formation to achieve and disseminate their envir onmental achievements.

Information collected from the oil and gas f acilities will allow EP A to gain a better understanding of the entire CO 2 capture and sequestration (CCS ) system. The data reported under the final rulemaking and subsequent regula tory actions will together enable EPA to understand the amount of CO 2 supplied, emitted, and sequestered in the U.S., to carry out a wide4 variety of CAA provisions. Thes e data can also be coupled with efforts at the local, state, federal, and international levels to assist corporations and facil ities in determining their carbon footprints and identifying furthe r opportunities to reduce emissions. These data can also inform future climate change policy decisions.

The rule is not intended to be a survey a nd 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 enti ties or to draw statistical inferences about a larger population.

3. NONDUPLICATION, CONSULTATION S, AND OTHER COLLECTION CRITERIA

3(a) Nonduplication

In developing the initial proposal for mandato ry reporting from petroleum and natural gas systems (April 2009), a second pr oposed rule (April 2010), as we ll as the final rulemaking, EPA reviewed monitoring methods included in inte rnational guidance (e.g., Intergovernmental Panel on Climate Change), as well as Federal vo luntary programs (e.g., EPA Natural Gas STAR Program and the U.S. Department of Energy Vo luntary Reporting of Greenhouse Gases Program (1605(b))), corporate protocols (e.g., World Resources Institute and World Business Council for Sustainable Development GHG Pr otocol) and industry guidan ce (e.g., methodological guidance from the American Petroleum Ins titute, the Interstate Natural Gas Association of America, and the American Gas Association).

EPA also reviewed State reporting progr ams (e.g., California and New Mexico) and Regional partnerships (e.g., The Climate Registry, the Wester n 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 estab lish 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 monito ring protocols used by federal, state, and international voluntary and mandatory GHG progra ms, 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. Greenhous e Gas Emissions and Sinks (Inventory), which is an annual comprehensive top-dow n assessment of national greenhouses gas emissions. While the Inventory is compiled fr om national surveys, which are not broken down at the geographic or f acility level, the rule focuses on bottom-up data from individual facilities that exceed appropriate thresholds. The bottom-up approach to data5 collection in the final rule can help EPA tr ansition to the Intergovernmental Panel on Climate Change (IPCC) 2006 guidelines for capture , transport, and geological storage at the appropriate time. In addition, the emissi ons factor being used in the 2008 U.S. GHG Inventory is believed to significantly underestimate em issions based on industry experience as included in the Natural Gas ST AR Program publicly av ailable information. The 2008 U.S. GHG Inventory emissions fact or was developed prior to the boom in unconventional well drilling (1992) in the abse nce 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 differe nt 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 Ad ministration (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 a nd identify specific gree nhouse gas reductions made by the entity. EPA’s mandatory GHG repor ting 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 repor ting of emission reductions, as is the 1605(b)

program.

• The DOE also administers the Climate Vi sion program (Voluntary Innovative Sector Initiatives: Opportunities Now), whose goal includes acce lerating the transition to technologies, practices, and processes th at are capable of reducing, capturing, or sequestering GHGs. All volunt ary 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 jurisdic tions 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 informati on (CBI) data with re levant agencies or approved entities using, wh ere practical, shared tools and infrastructure.6 3(b) Public Notice Required Prior to Information Collection Request (ICR) Submissions to OMB

As part of the Federal Register notic e 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 specifi c aspects of the info rmation collection, as described below:

1) Whether the collection of information is necessary for the proper performance of the functions of the Agency, including whethe r 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 technologica l 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 th e 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 confus es 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 a nd 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’sResponse to Comments document, Volume 9.1, the consolidated response to comments EPAHQ-OAR-2009-0923-1005-1, EP A-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 th e 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 alternativ e methodologies that were either recommended by commenters or are known to provide effective quantific ation of emissions at a significantly lower cost burden. EPA reviewed and updated th e economic impact analysis to reflect changes made in the final rule.

The preamble to the final rule summarizes th e comments received on the proposed rule as well as EPA’s responses. In addition, responses to significan t 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 th e rule (EPA-HQ- OAR-2009-0923).7 In addition, EPA did not receive any comment s specifically addressing the ICR for the April 2009 proposed rule, i.e., the Mandato ry 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 fo r that proposed rule, EPA received a substantial number of comments on the recordkeeping and reporting requi rements 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 y ears specified in the propos ed rule. (In response, EPA changed the record retention requirement in th e 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 Pape rwork 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 (O MB) 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 pol icy for those interested in discussing the rulemaking. Since January 2008, EPA staff has held more than 100 meetings with stakeholders, including:

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

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

• State and regional organizat ions already involved in GHG emissions reporting, such as The Climate Registry, California Air Resources Board, and the Western Climate Initiative; and

• Environmental groups and other nongovernmental organizations.

EPA also met with federal agencies, incl uding DOE and the U.S. Department of Agriculture, which have progr ams 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 co mments from more than 80 entities with over 1,200 pages of comments, recommendations, and alternatives for cons ideration. Details about these meetings and the responses to co mments are available in the docket (EPA-HQ-OAR2009-0923).8 3(d) Effects of Le ss Frequent Collection

The reporting frequency for emi ssions data to EPA has been established to minimize the burden on owners and operators of affected fac ilities, 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 provi de data on a more fre quent basis. If the information collection were not car ried 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 consis tent with all OMB guidelines under 5 CFR 1320.6.

3(f) Confidentiality

EPA issued a proposal addressing the confidentiality of the Pa rt 98 data elements on July 7, 2010 (75 FR 39094). The proposed confidential ity 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 confiden tiality of the data reporting elements before the reporting elements are ma de available to the public.

3(g) Sensitive Questions

This information collection does not ask a ny questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually cons idered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

The respondents in this information collecti on include operators of petroleum and natural gas facilities that must report their emissions to EPA to comp ly with the rulemaking. This section lists the industry sectors that must comply w ith the rule, the data items required of program participants, and the activities in which participan ts must engage to collect, assess, and in some cases submit the required data items.

4(a) Respondents/North Am erican Industrial Classificati on Systems (NAICS) Codes9 Reporting facilities for Subpart W include, but are not limited to, those operating one or more units that exceed the CO 2 e 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 informati on requested by facili ties 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 a ll respondents report, including subpart W, must submit the general informati on required in 40 CFR 98.3 and adhere to the reporting, certification, and no tification requirements in 40 CFR 98.4 and 40 CFR 98.2, if applicable. EPA is not making any changes to thes e 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 f acility that exceeds the threshold specific to subpart W must report emissions annually from a ll 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 lis ted below in metric

tons CO 2 e per year at standard conditions. For ea ch segment, report emissions from each source type 40 CFR 98.232 (a) in the aggr egate, 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.10 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 repor t 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 spec ified, report activity data and emissions (in

metric tons CO 2 e 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 sepa rately of natural gas pneumatic high bleed devices as applicable. ii) Actual count and estimated count sepa rately of natural gas pneumatic low bleed devices as applicable. iii) Actual count and estimated count se parately 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 remova l 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 Ca lculation Methodology 2 of 40 CFR 98.233(d), fraction of CO 2 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), volum e fraction of CO 2 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 r ecovered and transf erred 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 ga s flow rate in MMscfd, determined by engineering estimate base d on best available data.11 B) Glycol dehydrator absorb ent 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 dehydrat or is operating in hours. G) Temperature, in degrees Fahrenheit and pressure, in psig, of the wet natural gas. H) Concentration of CH 4 and CO 2 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 th roughput less than 0.4 MMscfd (refer to 40 CFR 98.233, Equation W-5 of 40 CF R 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 (re fer 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 fe et 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, re port 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 measur ed well workover venting in cubic feet per hour (refer to 40 CFR 98.233 (g)(1)(i)(A) or (g)(1)(ii)(A)).12 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 engi neering estimate based on best

available data of the amount of gas recovered to sales. H) Report vent emissions collectiv ely. 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 collectiv ely. 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 equi pment type in calendar year. ii) Report emissions collectively per equipment type. 8) For gas emitted from produced o il sent to atmospheric tanks: i) For wellhead gas-liquid separator with o il throughput greater than or equal to 10 barrels per day, using Calcula tion Methodology 1 and 2 of 40 CFR 98.233(j), report the foll owing by field: A) Number of wellhead separators se nding oil to atmospheric tanks. B) Estimated average separator temperature, in degrees Fahrenheit, and estimated average pressure, in psig. C) Estimated average sales oil stabi lized API gravity, in degrees. D) Count of hydrocarbon ta nks at well pads. E) Best estimate of count of stock ta nks 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 flari ng, for tanks at well pads. H) Best estimate of count of stock tanks assumed to have emissions

control measures not at we ll pads, receiving your oil. I) Range of concentrations of flash gas, CH 4 and CO 2

.13 J) Report emissions individually fo r Calculation Methodology 1 and 2 of 40 CFR 98.233(j). ii) For wells with oil production greater th an or equal to 10 barrels per day, using Calculation Methodology 3 an d 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: ei ther vapor recovery system or flaring of tank vapors. G) Report emissions collectively fo r Calculation Methodology 3 and 4 of 40 CFR 98.233(j). iii) For wellhead gas-liquid separators a nd wells with throughput less than 10 barrels per day, using Calculati on 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 producti on in barrels per year. D) Best estimate of fraction of produc tion sent to tanks with assumed control measures: either vapor reco very system or flaring of tank

vapors. E) Count of hydrocarbon tanks on well pads. F) Report CO 2 and CH 4 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 de tection 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 pe r basin in calendar year. ii) Average gas to oil ratio for each basin. iii) Average number of days the we ll is tested in a basin.14 iv) Report emissions of the ve nting gas co llectively. 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 asso ciated natural gas in a calendar year. ii) Average gas to oil ratio for each basin. iii) Report emissions of the fl aring 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 flar e in cubic feet per year. iii) Percent of gas sent to un-lit flare determined by engineering estimate and process knowledge based on best ava ilable data and ope rating records. iv) Whether flare has a continuous gas analyzer. v) Flare combustion efficiency. vi) Report uncombusted and combusted CO 2 and CH 4 emissions separately. 13) For each centrifugal compressor: i) For compressors with wet seals in oper ational 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 connect ed 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 s eal 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 em issions 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 compre ssors 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 blowdow n vents in cubic feet per hour (refer to Equation W-23 of 40 CFR 98.233). C) Report blowdown vent emissions wh en in operating mode (refer to Equation W-24 of 40 CFR 98.233). iii) For wet and dry seal centrifugal compre ssors in not operating, depressurized mode (refer to Equations W-22 thr ough W-24 of 40 CFR 98.233), report the following:15 A) Total time in hours the compressor is in shutdown, depressurized

mode. B) Reporter emission factor for isola tion 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 leak age 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 CF R 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 packi ng 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 recipro cating 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 pressu rized 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 blowdow n 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 E quation W-27 of 40 CFR 98.233). iii) For reciprocating compressors in not ope rating , 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 isol ation 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 leak age 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 co mplete survey listed by date of survey and each type of leak s ource 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 CH 4 and CO 2 as described in Equation W-30 of 40

CFR 98.233. C) Report CH 4 and CO 2 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 s ource 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 majo r heading and component type. B) [Reserved] C) Report CH 4 and CO 2 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 tr ansfer 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 w ith 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 unprotect ed steel distri bution mains.17 viii) Number of miles of protected steel distribution mains. ix) Number of miles of plas tic distribution mains. x) Number of miles of cast iron distribution mains. xi) Number of unprotected st eel distribution services. xii) Number of protected stee l distribution services. xiii) Number of plastic distribution services. xiv) Number of copper distribution services. xv) Total emissions from each natura l 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 ga s 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 CO 2 for each field (refer to Equation W-38 of 40 CFR 98.233), report the following: i) Volume of crude oil produ ced in barrels per year. ii) Amount of CO 2 retained in hydrocarbon liquids in metric tons per barrel,

under standard conditions. iii) Report emissions individually. 19) For onshore petroleum and natural gas pr oduction 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 th an 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 dete rmined by engineering estimate based on best available data for each industry segment listed in paragr aphs (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 equipm ent 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 sour ces, including Subpart W. This information is described in the ICR for the Mandatory Reporti ng 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 recordkeepi ng requirements associated with the specific subparts.

Petroleum and natural gas fa cilities under Subpart W. Petroleum and natural gas

facilities must also retain records for the fo llowing 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 a nd measurement instruments used.

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

estimation of emissions.

(ii) Respondent Activities

The owner or operator of a fac ility that is subject to the rule’s reporting requirements must report total annual GHG emi ssions in metric tons of CO 2 e from all the source categories at the facility. The primary task s that reporting program res pondents 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 th ree years. In addition, respondents must purchase the necessary monitoring hardwa re and purchase the electronic data19 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 determin e 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 sp ecific source category.

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

5(a) Agency Activities

EPA Headquarters activities a ssociated with the rule include program start-up activities

are reflected in the ICR for the Final Mandato ry Reporting Rule (EPA ICR No. 2300.03). This ICR reflects an incremental agency burden fo r program operation activ ities, which include monitoring and verification of emission repor ts, database and software maintenance, communication and outreach, and program evaluation.

5(b) Collection Methodology and Management

EPA will establish a central repository of i nventory data for all respondents. Respondents will report data electronically, and EPA will store th e 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 info rms 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 exis ting programs, such as the Acid Rain Program and the Title VI Stratospheric Ozone Protecti on 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 elec tronic signatures accepte d under another Agency20 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 y ear 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 sy stem to provide each facility with a unique identification code to be sp ecified 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, a nd other organizations and stakeholders for air modeling, analyzing emissions by in dustry 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 co llection and data management systems, when

feasible.

5(c) Small Entity Flexibility

The Agency met several times with industry tr ade 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 mini mize the impacts on sma ll entities, and these provisions would apply to facil ities 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 mtCO 2 e for 5 years to cease annual re porting to EPA. If reported emissions are less than 15,000 mtCO 2 e per year for three consecutive years, then the owner or operator may discontinue reporting. In developi ng 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, whil e still ensuring that the progra m yields high quality data and essential information. For example, the fina l rule includes altern ative 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 pr oducts with emission less than 25,000 mtCO 2 e for five years in a row may cease reporting.21 6. ESTIMATING THE BURDEN A ND COST OF THE COLLECTION

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

with the activities described in Section 4 as we ll 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 responde nt burden associated with th is 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 provi des estimates of burden (hours) for all respondent types. Section 6(b) contains estimates of respondent co sts for the information collection. Section 6(c)

summarizes federal burden and co sts. Section 6(d) describes the respondent universe and the

total burden and cost of this collection to respondents. Sectio n 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 h ours 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 pe r year. Exhibit 6.1 presents aggregate burden by sector only; for the deta ils of burden calculations, please see Appendix A.

6(b) Estimating Respondent Costs

Costs to respondents associated with this information collect ion include labor costs (i.e., the cost of labor by facility staff to meet the rule’s information collection requirements) and nonlabor costs (e.g., the cost of purchasing and inst alling monitoring equipment or contractor costs associated with providing the required information).

To calculate labor costs, EPA estimated tech nical, managerial, clerical, and legal loaded labor rates for each industry sector using labo r rates from the Bureau of Labor Statistics [1] and applying a 60% loading factor [2] ; these rates vary somewhat by s ector. For Subpart W, the labor

[1] These rates reflect adjustments of th e manufacturing sector's average productiv ity 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 (N ovember 2005) recommends using a multiplier of 1.6 to account for benefits and overhead related to government wages; this is considered a conser vative estimate (potentially high) for the private sector.22 rates are: $88.79 for electricity managers; $101.3 1 for refinery managers, $71.03 for industrial managers; $60.84 for electricity engineers/tech nicians, $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 co sts (capital and O&M) for indi vidual sectors are presented in Appendix C.23EPA estimates that the total annual cost to all affectednon-federal entities is $27.7 millionover the three years covered bythisinformation collection. Exhibit 6.1 presents aggregate costs by sector only; for the details ofEPA’s cost calculations, pleaseseeAppendix B.Exhibit 6.1 Annual Average Respondent Burden and CostFor Subpart W of the GHG Reporting Rule ($K)SourceCategoryNo.Respond‐entsResponses/RespondentTotalResponsesBurden‐Technical(hrs)Burden‐Managerial(hrs)Burden‐Clerical(hrs)Burden‐Legal(hrs)TotalBurden(hrs)TotalLaborCost($K)CapitalCost($K)O&MCost($K)TotalCost($K)GasProcessing289 2 394 50,381 5,061 0 0 55,441 $3,798 $220 $123 $4,142TransmissionCompressorStations1,145 2 1,487 113,877 7,528 0 0 121,405 $8,054 $395 $1,154 $9,603Storage133 2 215 16,229 2,988 0 0 19,218 $1,309 $26 $147 $1,482LngTerminals4 2 4 399 65 0 0 463 $33 $12 $8 $52OnshoreProduction981 2 1,962 111,354 31,343 0 0 142,698 $10,152 $56 $0 $10,208LocalDistributionCompanies143 2 143 18,235 1,840 0 0 20,075 $1,268 $21 $228 $1,517LngStorage33 2 64 4,165 1,002 0 0 19,004 $362 $14 $26 $402OffshoreProduction58 2 102 2,633 1,327 0 0 18,170 $286 $0 $0 $286TOTAL2,786 Varies 4,371 317,273 51,155 0 0 396,474 $25,261 $745 $1,687 $27,6922425 6(c) Estimating Agency Burden and Cost

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

information collection. Federal activities under this inform ation collection include EPA Headquarters oversight of the reporting program and required reporting by federally owned GHG generating facilities.

EPA burden and cost

EPA activities associated with the mandato ry GHG reporting rule include Headquarters oversight and implementation of the reporting program, e.g., monitoring and verification of emission reports, database and software mainte nance, communication and outreach, and program evaluation. EPA estimates that, in implemen ting subpart W, Headquarters will incur an incremental burden of 4 full time equivalents (FTEs), or just $460,000 for these activities.

To develop EPA labor costs, EPA estimates th e average hourly labor rate for salary and overhead and benefits for Agency staff to be $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 faci lities 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 Un iverse and Total Burden and Costs26 The number of respondents in each sector th at will perform the re quired 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 co sts 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 fo r this collection of informa tion is estimated to average 396,474 hours per year for a three year period, incl uding a first year where initial labor and capital costs are anticipated, and two subseque nt 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 fede ral facilities that must comply with the rule. The annual public27 reporting and recordkeeping burden for this collec tion 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 disclo se or provide informati on to or for a federal agency. This includes the time needed to review in structions; develop, acquire , install, and utilize technology and systems for the purposes of colle cting, validating, and verifying information, processing and maintaining information, and disc losing and providing information; adjust the existing ways to comply with any previously ap plicable instructions and requirements; train personnel to respond to a collection of information; search data s ources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, a nd a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CFR part 9.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ- OAR-2009-0923, which is available for online viewing at http://www.regulations.gov, or in person viewing at the Air a nd Radiation docket in the EPA Docket Center (EPA/DC), EPA West Build ing, 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 hol idays. 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 availabl e 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 documen ts in the public docket that are available electronically. When in the system, select “search,” then key in th e 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.