Page 1 November 2014 SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY

Greenhouse Gas Reporting Rule: 2015 Revisions and C onfidentiality Determinations for

Petroleum and Natural Gas Systems; Proposed Rule

(40 CFR Part 98, subpart W) November 2014

Part A of the Supporting Statement

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection
Recordkeeping and Reporting Requirements for Petrol eum and Natural Gas Systems (40 CFR part 98, Subpart W). The OMB Control number is 2060-0629 and the EPA ICR tracking
number is 2300.16.

1(b) Short Characterization
In response to the FY2008 Consolidated Appropriatio ns Act (H.R. 2764; Public Law 110-161) and under authority of the Clean Air Act ( CAA), the EPA finalized the Greenhouse Gas Reporting Rule (74 FR 56260; October 30, 2009). The Greenhouse Gas Reporting Rule is referred to as 40 CFR Part 98 (hereafter referred to as “Par t 98”) and implementation of Part 98 is referred to as the Greenhouse Gas Reporting Program (GHGRP). This supporting statement addresses information collection activities that would be imp osed by “Greenhouse Gas Reporting Rule: 2015 Revisions and Confidentiality Determinations for Pe troleum and Natural Gas Systems” (hereafter referred to as the “proposed revisions”). Part 98, which became effective on December 29, 200 9, requires that certain facilities and suppliers emitting above certain threshold levels o f carbon dioxide (CO 2 ) equivalent (CO 2 e) monitor and report emissions of greenhouse gases (G HGs). A subsequent rule was published on November 30, 2010 finalizing the requirements for t he petroleum and natural gas systems source category (hereafter referred to as “subpart W”) at 40 CFR part 98, subpart W (75 FR 74458).Page 2 November 2014

The EPA is proposing to add reporting requirements for two new industry segments, add reporting requirements for completions and workover s of oil wells with hydraulic fracturing, and add requirements to report well identification numb ers for certain sources. These proposed revisions are expected to increase respondent burde n. See Appendix A for a complete list of proposed additions to the reporting requirements. Potential new respondents are owners or operators o f petroleum and natural gas systems that meet the requirements of §98.2(a)(2) and the r eporting thresholds of §98.231. New respondents are required to report data elements ac cording to §98.236, and maintain records according to §98.237. Existing respondents must rep ort and maintain records as specified in Part
98. Approximately 3,300 respondents will be subject to the regulation and this rulemaking is expected to increase labor costs for subpart W faci lities. Compared with the estimated respondent
burden identified in the information collection for the GHGRP currently approved by the Office of Management and Budget (OMB), this proposed informat ion collection will result in an overall increase in annual burden of 73,000 hours and $7.2 million, as shown in Section 6.Page 3 November 2014

2. NEED FOR AND USE OF THE COLLECTION

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

2(b) Use /Users of the Data

The GHGRP collects information from facilities that directly emit GHGs and from suppliers of products that release GHGs if combuste d, oxidized, or used. The comprehensive GHG data reported directly from large facilities and su ppliers across the country are accessible to the public at: http://ghgdata.epa.gov/ghgp/main.do . Reporting entities generally use uniform methods for estimating emissions, which enables data to be compared and analyzed. Data collection in the GHGRP complements the Invent ory of U.S. Greenhouse Gas Emissions and Sinks (Inventory) and provides a crit ical tool for communities to identify nearby sources of GHGs and provide information to state an d local governments. The standardization of GHG data provides businesses with the necessary information to benchmark themselves against similar facilities, be tter understand their relative standing within their industry, and achieve and disseminate their e nvironmental achievements. Businesses and
other innovators can use the data to determine thei r GHG footprints, find cost- and fuel-savingPage 4 November 2014

efficiencies that reduce greenhouse gas emissions ( e.g., through energy audits or other forms of assistance), and foster technologies to protect pub lic health and the environment. Generally, the facility-specific GHG emissions data improve the understanding of the
factors that influence GHG emission rates as well a s the actions that facilities take to reduce emissions. The facility-based data can be aggregate d to the corporate level in order to track emission trends from industries, within industries, and across industries over time, particularly in response to policies and potential regulations. Specifically, subpart W data can be used to complem ent atmospheric GHG studies and inform updates to emission inventories. Various act ivity data are collected that can be used to improve understanding of the occurrence of emission s from a variety of sources.Page 5 November 2014

3. NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTI ON
CRITERIA

3(a) Nonduplication
The information to be collected under the proposed revisions includes 232 new data elements (refer to Appendix A for a list of these d ata elements). These proposed new data elements consist primarily of quantities related to the acti vity level at the facility, emission factors used, characteristics of carbon-containing streams, and o ther process information that would provide key information for verification, including confirm ing that emissions are appropriate for a given activity level and estimating expected emissions ba sed on data provided. These proposed new elements for subpart W are similar to the types of industry data already being collected under the GHGRP. The EPA has evaluated the types of industry data collected under Part 98, and concluded that they do not duplicate other information collec tions, as described below. In developing the GHGRP, the EPA reviewed monitorin g methods, including:

• Federal programs within the United States, such as the Inventory, the U.S. Department of Energy’s (DOE’s) Energy Information Administrati on’s (EIA’s) 1605b program, the Acid Rain Program, EPA Natural Gas STAR Program , and voluntary GHG partnership programs;

• State and regional GHG reporting programs, such as The Climate Registry, the Regional Greenhouse Gas Initiative, the Western Reg ional Air Partnership, and programs in several states including California, Ne w Mexico, Connecticut, and New Jersey;

• Reporting protocols developed by nongovernmental or ganizations, such as the World Resources Institute/World Business Council for Sust ainable Development;

• Programs from industrial trade organizations, such as the Interstate Natural Gas Association of America’s GHG Emission Estimation Gu idelines, the American Petroleum Institute’s Compendium of GHG Estimation Methodologies for the Oil and Gas Industry, and the World Business Council for Su stainable Development’s Cement Sustainability Initiative’s CO 2 Accounting and Reporting Standard for the Cement Industry; and

• IPCC Guidelines for National Greenhouse Gas Invento ries.
Many of these programs collect different or additio nal data as compared to the GHGRP and this proposal. For example, state programs may include different data elements to supportPage 6 November 2014

other programs (e.g., offsets). While some programs collect similar information on GHG emissions, the Agency has determined that the GHGRP supplements and complements, rather than duplicates, existing programs’ data. Further, the E PA has made significant efforts over the past four years to facilitate reporting in the event a s ingle entity has to report both the federal and sta te level. For example, the EPA has supported efforts b y the California Air Resources Board to harmonize the reporting of information under Califo rnia’s Global Warming Solutions Act, AB32 with the EPA’s GHGRP. The product of the collaborat ion is referred to as California Electronic Greenhouse Gas Reporting Tool, or Cal e-GGRT. Documentation of the EPA’s review of GHG monitoring protocols used by federal and state voluntary and mandatory GHG programs as well as GHG reporting rules can be found in Docket ID No. EPA-HQ-OAR-2008-0508. For further dis cussion on the relationship of the GHGRP to other programs, please refer to the preamb les of each of the GHGRP rulemakings the June 6, 2008 memorandum entitled “Review of Existin g Programs” (Docket Item No. EPA-HQ-OAR-2008-0508-0052), and the January 27, 200 9 memorandum entitled “Review of Existing State Greenhouse Gas Reporting Rules” (Doc ket Item No. EPA-HQ-OAR-2008-0508-0054). Some GHG programs are d escribed below:

• A number of the EPA’s voluntary partnership program s include a GHG emissions and/or reductions reporting component (e.g., Natura l Gas STAR program, etc.). However, the GHGRP has much broader coverage than t he voluntary programs and therefore helps the EPA learn more about emissions from facilities not included in current programs.

• The EPA reviewed the Inventory, which is an annual comprehensive top-down assessment of national greenhouses gas emissions. W hile the Inventory is generally compiled from national surveys (i.e., not broken do wn at the geographic or facility level), the GHGRP focuses on bottom-up data from in dividual facilities that exceed appropriate thresholds.
As noted in the current ICR for the GHGRP, a number of programs at the state, tribal, territorial, and local level require emission sourc es in their respective jurisdictions to monitor and report GHG emissions. To reduce burden on reporters and program agencies, the Agency plans to share reported data, with the exception of any info rmation determined to be Confidential Business Information (CBI), with relevant agencies or approv ed entities using, where practical, shared tools, and infrastructure.Page 7 November 2014

Based on this evaluation, this information collecti on request does not duplicate other
information collections.

3(b) Public Notice Required Prior to Information Co llection Request (ICR) Submissions to OMB
A public notice of this collection is provided in t he Federal Register notice of “Greenhouse Gas Reporting Rule: 2015 Revisions and Confidential ity Determinations for Petroleum and Natural Gas Systems; Proposed Rule.”

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

• Trade associations and firms in potentially affecte d industries/sectors;

• State, local, and tribal environmental control agen cies and regional air quality planning organizations;

• State and regional organizations already involved i n GHG emissions reporting, such as The Climate Registry, California Air Resources Boar d, and the Western Climate Initiative; and

• Environmental groups and other nongovernmental orga nizations.
The EPA also has met with federal agencies, includi ng the U.S. Department of Energy and the U.S. Department of Agriculture, which have prog rams relevant to GHG emissions. On April 10, 2009 (74 FR 16448), the EPA proposed t he GHGRP. The EPA held two public hearings, and received more than 16,000 writ ten public comments. The public comment period ended on June 9, 2009. Comments related to S ubpart W were received from more than 80 entities with over 1,200 pages of comments, recomme ndations, and alternatives for consideration. Details about these meetings and the responses to c omments are available in Docket ID No. EPA-HQ-OAR-2009-0923. Following promulgation of the final subpart W rule (75 FR 74458,Page 8 November 2014

November 30, 2010), the EPA finalized actions revis ing subpart W (76 FR 22825, April 25, 2011; 76 FR 59533, September 27, 2011; 76 FR 80554, Decem ber 23, 2011; 77 FR 51477, August 24, 2012; 78 FR 25392, May 1, 2013; 78 FR 71904, Novemb er 29, 2013; 79 FR 63750, October 24, 2014; and 79 FR 70352, November 25, 2014). In the current action, the EPA is proposing to revi se certain petroleum and natural gas systems source category GHG reporting requirements. The proposed changes would add reporting requirements for two new industry segments (Onshore Natural Gas Transmission Pipelines and Onshore Petroleum and Natural Gas Gathering and Boo sting), add reporting requirements for completions and workovers of oil wells with hydraul ic fracturing, and add requirements to report
well identification numbers for certain sources. In conjunction with this action, we are proposing c onfidentiality determinations for the new data elements contained in these proposed amend ments.

3(d) Effects of Less Frequent Collection
The frequency for reporting emissions information t o the EPA under the GHGRP was originally established to minimize the burden on ow ners and operators of affected facilities, while ensuring that the GHGRP collects facility-specific data of sufficient quality to achieve the Agency’s objectives. The GHGRP requires annual repo rting, except for a limited number of facilities that are already subject to more frequen t reporting requirements. This reporting frequency remains the same in these proposed revisi ons to Part 98. Annual reporting will ensure that data are verified and made available to the public, as authorized by the CAA. If the information collectio n were not carried out on this schedule, the Agency would not be able to develop an informed tra cking system of trends in GHG emissions across the country.

3(e) General Guidelines This collection is consistent with all OMB guidelin es under 5 CFR 1320.5.Page 9 November 2014

3(f) Confidentiality

Data collected under the GHGRP must be made availab le to the public unless the data qualify for CBI treatment under the CAA and EPA reg ulations. The CAA precludes “emission data” from being treated as confidential. For data reported under the CAA that are not emission data, the EPA typically makes CBI determinations un der 40 CFR 2.301 on a case-by-case basis. Due to the large number of entities reporting under the GHGRP and the large number of data reporting elements, the EPA previously concluded th at case-by-case determinations would not result in timely release of emission and other non- CBI data (see proposed CBI rule, 75 FR 39094, July 7, 2010 39094 and final CBI rule, May 26, 2011 , 76 FR 30782). For this reason, the EPA has made CBI determinations for most data reporting ele ments through a series of rulemakings that specify which data reporting elements in Part 98: ( 1) are CBI, (2) are non-CBI, and (3) are emission data (i.e., ineligible for CBI protection) . All data determined by the EPA to be CBI are safeguarded in accordance with regulations in 40 CF R Chapter 1, Part 2, Subpart B. The CBI determinations for subpart W data reporting element s (excluding data reporting elements used as inputs to emission calculations) were made in 77 FR 48072 (August 13, 2012) and 79 FR 70352 (November 25, 2014). In the current action, the EPA is proposing confidentiality determinations for the new data elements contained in these propos ed amendments.

3(g) Sensitive Questions
The revisions to reporting or recordkeeping require ments in the proposed revisions to Part 98 do not include sensitive questions.Page 10 November 2014

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

The respondents in this information collection incl ude owners and operators of petroleum and natural gas systems facilities that must report their GHG emissions to the EPA to comply with Part 98, subpart W. This section provides a list of industry sectors that must comply with the rule, the data elements required of program participants, and the activities in which participants must engage to collect, assess, calculate, and in some c ases submit the required data elements.

4(a) Respondents/North American Industrial Classifi cation System (NAICS) Codes
The proposed revisions to Part 98 affect facilities subject to subpart W. Reporting facilities for subpart W include, but are not limited to, thos e operating one or more units that exceed the
CO 2 e threshold for the industry sectors listed below ( and listed in Table A-3 of 40 CFR 98.2(a)(1)). Industry sectors are listed by NAICS c ode in Table 1. The NAICS codes are not exhaustive, but rather provide a list of facilities likely to be affected.

Table 1. NAICS codes for affected reporters Part and Subpart NAICS codes 40 CFR Part 98 W. Petroleum and Natural Gas Systems 486210 Pipeline transportation of natural gas. 221210 Natural gas distribution. 211111 Crude petroleum and natural gas extraction. 211112 Natural gas liquid extraction.

4(b) Information Requested
(i) Data Items. The EPA is proposing that 232 new d ata elements be reported. Table 1 of Appendix A specifies each new data element that wou ld be reported by industry segment. (ii) Respondent Activities. The owner or operator o f a facility that is subject to the subpart W reporting requirements must report total annual G HG emissions. The primary tasks that reporting program respondents perform include:
1. Implementing and updating, as necessary, appropriat e monitoring plans for each affected source and each affected unit at a source, as applicable;Page 11 November 2014

2. Conducting operation and maintenance activities ass ociated with the monitoring, including quality assurance activities; 3. Ensuring data quality, preparing annual reports of emissions data, and submitting these reports to the EPA; 4. Potentially responding to questions or error messag es from the EPA; and 5. Maintaining records for a minimum of three years.
Respondents that use CEMS also conduct tests to cer tify the operations of monitors, submit the results of these tests, and record emission dat a (this activity generally is performed electronically). Reports must present the annual mass GHG emissions from each subpart W industry segment separately. Reporters are required to provi de emissions in metric tons of methane (CH 4 ),
CO 2 , and nitrous oxide (N 2 O) for some sources and in metric tons of CO 2 e for other sources. The calculations used to determine GHG emissions, the f requency at which those calculations are required, and the methods used to estimate missing data depend on the specific subpart W industry segment. (iii) Electronic Reporting. Respondents report all data electronically through the Electronic Greenhouse Gas Reporting Tool (e-GGRT). All new data elements will be reported in the same way. As the e-GGRT accounts are already es tablished, the only burden related to electronic reporting will be entering the data elem ents.Page 12 November 2014

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

5(a) Agency Activities
EPA Headquarters activities include the monitoring and verification of emission reports, database and software maintenance, communication an d outreach, and program evaluation. This ICR reflects an incremental agency burden for program operation activities, which include monitoring and verification of emission rep orts. Specifically, the additional burden for the
review of new data elements was estimated.

5(b) Collection Methodology and Management
To collect data currently reported under the GHGRP, the EPA previously established a central repository of inventory data for all respon dents called the e-GGRT. Respondents report data electronically, and the EPA stores the data in the database. The e-GGRT system provides a user interface for entering the GHG data and also h as an XML reporting schema that allows facilities to upload GHG data directly. Under the p roposed revisions to Part 98, facilities subject to subpart W listed in Section 4(a) would report the p roposed new data elements via e-GGRT. The e-GGRT system follows Agency standards for desi gn, security, data element and reporting format conformance, and accessibility. Th e EPA designed the system to minimize respondents’ burden by integrating the new reportin g requirements with existing data collection and data management systems, when feasible.

5(c) Small Entity Flexibility
This information collection will not have a signifi cant economic impact on a substantial number of small entities. As part of the proposal p rocess for this rule package, the EPA conducted a screening assessment comparing compliance costs t o onshore petroleum and natural gas production specific receipts data for establishment s owned by small businesses. This ratio constitutes a “sales” test that computes the annual ized compliance costs of this rule as a percentage
of sales and determines whether the ratio exceeds 1 percent. The cost-to-sales ratios were constructed at the establishment level (average rep orting program costs per establishment/averagePage 13 November 2014

establishment receipts) for several business size r anges. This allowed the EPA to account for receipt differences between establishments owned by large and small businesses and differences in
small business definitions across affected industri es. The cost-to-sales ratios are less than 1 percent fo r all establishments, except the ratio for the 1–20 employee range for facilities in the Onsho re Petroleum and Natural Gas Production segment with NAICS code 213111, which is 1 percent, and the ratios for the 1–20 employee range
for facilities in the Onshore Petroleum and Natural Gas Production and Onshore Petroleum and Natural Gas Gathering and Boosting segments with NA ICS code 213112, which are greater than 1 percent but less than 2 percent. The petroleum and natural gas industry has a large number of enterprises, the majority of them in the 1–20 emplo yee range. However, a large fraction of production comes from large corporations and not th ose with less than 20 employee enterprises. The smaller enterprises in most cases deal with ver y small operations (such as a single family owning a few production wells) that are unlikely to cross the 25,000 metric tons CO 2 e threshold considered for the rule. An exception to such a sce nario is a small (less than 20 employee) enterprise owning large operations but conducting n early all of its operations through contractors. This is not an uncommon practice in the Onshore Pet roleum and Natural Gas Production segment. Such enterprises, however, are a very small group a mong the almost 16,000 enterprises in the less than 20 employee category, and the EPA proposes to cover them in the rule. Therefore, this rule will not have a significant ec onomic impact on a substantial number of
small entities.

5(d) Collection Schedule

All data elements under this information collection would be submitted on an annual basis as part of the respondent’s annual report required under Part 98.Page 14 November 2014

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents the EPA’s estimates of the bu rden 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). Sect ion 6(a) provides estimates of burden (hours) for all respondent types. Section 6(b) contains estimat es 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 o f this collection to respondents. Section 6(e) presents the bottom line burden and cost. Section 6 (f) provides reasons for any change in burden.
The burden statement for this information collectio n is in Section 6(g).

6(a) Estimating Respondent Burden
Respondent burden estimates are presented in Exhibi t 6.1. The EPA estimates that the total
annual burden to all affected entities is 63.4 hour s per year over the three years covered by this information collection. There are expected to be ap proximately 400 new reporters will become subject to subpart W as a result of these amendment s. Exhibit 6.1 presents aggregate burden and burden by subpart W industry segment.

6(b) Estimating Respondent Costs

The EPA estimates that the total annual cost to all affected non-federal entities is approximately $29.2 million over the 3 years covere d by this information collection. Exhibit 6.1 presents aggregate costs and costs by subpart W ind ustry segment. For details of the EPA’s cost calculations, please see Appendix C and Appendix D. The proposed information collection will
result in an overall increase in annual burden of 7 3,000 hours and $7.2 million. This increase is split between the three subpart W industry segments as shown in Exhibit 6.2. (i) Estimating Labor Costs. Costs to respondents as sociated with this information collection include the cost of labor by facility st aff to meet the rule’s information collection requirements. To calculate labor costs, the EPA use d labor rates from the Bureau of LaborPage 15 November 2014

Statistics consistent with the ICRs associated with the GHGRP currently approved by OMB. 1 For all subpart W industry segments, the labor rate der ivations are shown in Table 2. The labor rates for this ICR are: $121.72 for senior managers, $106 .89 for middle managers, $78.29 for engineers, and $66.57 for technicians.

Table 2. Labor Rate Derivations

Labor Category Wage and

Salaries a BLS

Occupational Code Benefits

Loading Factor b Overhead

Loading Factor c Loaded Labor

Rate (2011$) d Engineer $50.84 17-2112 0.3699 0.17 $78.29 Technician $43.23 17-3024 0.3699 0.17 $66.57 Middle manager $64.12 11-3051 0.4970 0.17 $106.89 Senior manager $73.02 11-1021 0.4970 0.17 $121.72

a The base hourly wages & salaries (not including be nefits & overhead) are from BLS's May 2011 National Industry Specific Occupational Employment and Wage Estimates (http://www.bls.gov/oes/2011/may/oessrci.htm#22).

b From BLS's ECEC (http://www.bls.gov/ect/home.htm) for June of 2006 (see archive at http://www.bls.gov/news.release/archives/ecec_09222 006.pdf).

c The overhead loading factor is from Rice, Cody 200 2. "Wage Rates for Economic Analyses of the Toxics Release Inventory Program,” Analytical Support Branch, Envi ronmental Analysis Division, Office of Environmenta l Information, U.S. EPA, June 10, 2002.

d The loaded hourly rate = Wages & Salaries + (Wages & Salaries x Benefits Loading Factor) + (Wages & S alaries * Overhead Loading Factor). The benefits loading fact or and overhead loading factor reflect the factors used in the 2009 and 2010 ICRs.

Burden estimates were calculated by assigning a lev el of effort for each new requirement in the rule, assigning each requirement to one or more of the labor categories above, estimating the number of units affected by each new requirement, d etermining how many reporters will be impacted under each segment, and multiplying by the appropriate labor rates.
In order to be consistent with the levels of effort used for the existing industry segments, all levels of effort were estimated using the Economic Impact Analysis from November 2010. 2 For details of the burden calculations, please see Appendix B. (ii) Estimating Capital and Operations and Maintena nce (O&M) Costs Related to Process Emissions. The amendments to subpart W assume that various capital and O&M costs will be

1 May 2011 National Industry-Specific Occupational E mployment and Wage Estimates (http://www.bls.gov/oes/2011/may/oessrci.htm) and E mployer Costs for Employee Compensation for June of 2011 (http://www.bls.gov/news.release/archives/ecec_0908 2011.pdf). 2 Economic Impact Analysis for the Mandatory Reportin g of Greenhouse Gas Emissions Under Subpart W Final Rule (GHG Reporting); Final Report, U.S. Environmen tal Protection Agency Office of Atmospheric Program s. Climate Change Division. November 2010. Docket Item No. EPA-HQ-OAR-2009-0923-3601. Pages 4-23 through 4-28.Page 16 November 2014

required to comply with the monitoring, recordkeepi ng, and reporting of process emissions within this proposed rule. Each new reporter was assumed to require a 4-drawer vertical file cabinet and an external hard drive for storing various records and electron ic data. The annualized capital cost for each reporter is $57 per year for a total of $22,800 per year. 3 During oil well completions and workovers with hydr aulic fracturing, there is a flowback period where the gas flow rate is monitored using a volumetric flow meter. These requirements affect approximately 50 new and 246 existing report ers in the Onshore Petroleum and Natural Gas Production industry segment. These reporters are as sumed to purchase a volumetric flow meter at a cost of $585 per year ($2,400 annualized over 5 y ears at 7% interest). 4 The total cost is approximately $173,000 per year. The final capital and O&M cost impacts are related to travel costs. For Onshore Petroleum and Natural Gas Gathering and Boosting facilities, the size of a facility was assumed to encompass a much larger geographic area than a relatively com pact producing field or a gas processing plant.
In order to account for emissions measurement acros s a larger area, travel costs were included and assumed to consist of 14 overnight trips per report er per year. Assuming $150 per night and $100 per diem, 5 a cost of $3,500 per reporter per year was assumed . The total annual cost for travel is $700,000 per year. Due to the fact that compressor stations are unmann ed, pipeline throughput is continuously monitored and controlled and the engineering data w ould be readily available to the reporters in the Onshore Natural Gas Transmission Pipeline segme nt. Therefore, reporters are assumed to perform engineering calculations based on pressure, temperature, and volume of the pipeline segment rather than traveling to the compressor sta tions to take measurements. The addition of oil well completions and workovers with hydraulic fracturing is not expected to impact any amount of travel that may be required of reporters in the Onshore Petroleum and Natural Gas Production segment.

3 Ibid. Page 4-29. 4 Based on an average cost of five volumetric gas fl ow meters from Omega Engineering, FLO-CORP, Sierra Instruments, and Instrumart. 5 Economic Impact Analysis for the Mandatory Reportin g of Greenhouse Gas Emissions Under Subpart W Final Rule (GHG Reporting); Final Report, U.S. Environmen tal Protection Agency Office of Atmospheric Program s. Climate Change Division. November 2010. Docket Item No. EPA-HQ-OAR-2009-0923-3601

. Page 4-29.Page 17 November 2014

(iii) Estimating Capital and O&M Costs Related to C ombustion Emissions. The amendments to subpart W that are included in this i nformation collection affect the combustion-related capital and O&M costs for the On shore Petroleum and Natural Gas Gathering and Boosting industry segment. For all other segmen ts, the capital and O&M costs have not changed from ICR Number 2300.15. For the Onshore Petroleum and Natural Gas Gathering and Boosting and Onshore Petroleum and Natural Gas Production segments, the capital and O&M costs associated with combustion emissions were based on the assumptions in ICR Number 2376.02, which included capital equipment costs of $3,500 (annualized over 10 years at 7% interest to $500 per year) and O&M costs of $1,700 per year. 6
There are no combustion sources at Onshore Natural Gas Transmission Pipeline facilities, so there are no increases to capital and O&M costs as a result of the subpart W amendments.

6 Ibid. Page 4-11Page 18 November 2014Exhibit 6.1 Annual Average Respondent Burden and Cost for Subpart W of the GHGRPSubpart WIndustry SegmentNo.RespondentsTotalResponsesBurden–Engineer(hrs)Burden -Technician(hrs)Burden –MiddleManager(hrs)Burden –SeniorManager(hrs)TotalBurden(hrs)Total LaborCost($)Capital Cost($)O&M Cost($)Total Cost($)Onshore NaturalGas TransmissionPipelines150 150 5,190 0 375 188 5,753 $469,231 $8,597 $0 $477,828Onshore Petroleumand Natural GasGathering andBoosting200 200 8,187 360 500 250 9,297 $748,774 $111,064 $1,040,000 $1,899,839Onshore NaturalGas Processing291 398 13,844 8,948 3,082 204 26,078 $2,035,807 $232,860 $124,257 $2,392,924Onshore NaturalGas TransmissionCompression1,152 1,501 70,734 0 7,128 0 77,862 $5,943,128 $397,539 $1,161,170 $7,501,838UndergroundNatural Gas Storage139 224 10,583 0 2,107 0 12,690 $1,003,059 $65,803$115,189 $1,184,051LNG Import andExport Equipment4 4 330 0 43 0 373 $29,496 $2,400 $7,823 $39,718Onshore Petroleumand Natural GasProduction1,083 2,166 138,701 236 20,934 63 159,934 $13,142,142 $260,116 $85,000 $13,487,258Natural GasDistribution159 159 17,862 0 1,247 0 19,109 $1,390,860 $23,267$254,082 $1,668,209LNG Storage 35 70 2,379 0 649 0 3,029 $250,085 $14,883 $27,434 $292,401Offshore Petroleumand Natural GasProduction72 130 2,153 0 1,074 0 3,227 $285,779 $0 $0 $285,779TOTAL 3,285 5,002 269,964 9,544 37,140 704 317,352$25,298,361 $1,116,529 $2,814,954 $29,229,844Page 19 November 2014Exhibit 6.2 Annual Average Change in Respondent Burden and Cost For Subpart W of the GHGRPSubpart W Industry SegmentChange In Total Burden(Technical Labor Hours)Change in Burden(Technical LaborHours/Respondent)Change In TotalCost($)Change in Cost($/Respondent)Onshore Natural Gas Transmission Pipelinesa5,753 38.35 $477,828 $3,186Onshore Petroleum and Natural GasGathering and Boostingb9,297 46.48 $1,899,839 $9,499Onshore Natural Gas Processingc0 0.00 $0 $0Onshore Natural Gas TransmissionCompressiond0 0.00 $0 $0Underground Natural Gas Storagee0 0.00 $0 $0LNG Import and Export Equipmentf0 0.00 $0 $0Onshore Petroleum and Natural GasProductiong57,963 53.52 $4,827,372 $4,457Natural Gas Distributionh0 0.00 $0 $0LNG Storagei0 0.00 $0 $0Offshore Petroleum and Natural GasProductionj0 0.00 $0 $0TOTAL73,012 --- $7,205,039 ---aFor Onshore Natural Gas Transmission Pipelines, thetechnical labor hour burden increased from 0 hoursto 5,753 hours, which increased the total cost from $0 to $477,828.bFor Onshore Petroleum and Natural Gas Gathering andBoosting, the technical labor hour burden increased from 0 hours to 9,297 hours, which increased thetotal cost from $0 to$1,899,839.cFor Onshore Natural Gas Processing, the technicallabor hour burden and costs remained the same.dFor Onshore Natural Gas Transmission Compression,the technical labor hour burden and costs remainedthe same.eFor Underground Natural Gas Storage, the technicallabor hour burden and costs remained the same.fFor LNG Import and Export Equipment, the technicallabor hour burden and costs remained the same.gFor Onshore Petroleum and Natural Gas Production, the technical labor hour burden increased from 101,924 hours to 159,888 hours, which increased the total cost from $8,659,886to $13,487,258.hFor Natural Gas Distribution, the technical laborhour burden and costs remained the same.Page 20 November 2014

6(c) Estimating Agency Burden and Cost

This section describes the burden and cost to the f ederal government associated with this
information collection. Federal activities under th is information collection include EPA Headquarters oversight of the reporting program.

EPA burden and cost

The EPA activities associated with the mandatory GH G reporting rule include Headquarters oversight and implementation of the re porting program, e.g., monitoring and verification of emission reports, database and soft ware maintenance, communication and outreach, and program evaluation. The EPA estimates that, in implementing the two new industry segments under subpart W, Headquarters will incur a n incremental burden of 1 full time equivalent (FTE). The total Agency cost is $544,648, which is $109,000 higher than the previous ICR estimate of $436,000. To develop the EPA labor costs, the EPA estimates t he average hourly labor rate for salary and overhead and benefits for Agency staff to be $5 2.37. To derive this figure, the EPA multiplied the hourly compensation at GS-12, Step 5 on the 201 1 GS pay scale ($32.73) by the standard government benefits multiplication factor of 1.6 to account for overhead and benefits.

Burden and cost for federal facilities covered by t he rule

Exhibit 6.3 presents the annual burden and cost for federal facilities that must comply with
the rule.
Exhibit 6.3 Annual Agency Burden and Cost ($)

Information Collection Activity Annual

Responses Total Annual

Burden Labor Cost Non-Labor Cost Total Annual Cost

W. Petroleum and Natural Gas Systems 1 10,400 $544,648 $0 $544,648 TOTAL 1 10,400 $544,648 $0 $544,648Page 21 November 2014

6(d) Estimating the Respondent Universe and Total B urden and Costs
The number of respondents in each subpart W industr y sector that will perform the required activities under this information collecti on is presented in Exhibit 6.1.

6(e) Bottom Line Burden Hours and Costs/Master Tabl es
The bottom line burden hours and costs are shown in Exhibit 6.4.

Exhibit 6.4 Bottom Line Annual Burden and Cost

Number of Respondents 3,285 From Exhibit 6.1 Total Annual Responses 5,002 From Exhibit 6.1 Number of Responses per Respondent 1.5 Total annual responses from above ÷ Total respo ndents from above Total Respondent Hours 317,352 From Exhibit 6.1 Hours per Response 63.4 Total annual hours from above ÷ Total responde nts from above Annual O&M and Capital Cost 3,931,483 From Exhibit 6.1 Total Respondent Cost (labor + non) 29,229,844 From Exhibit 6.1 Total Hours (Respondents and Agency) 327,752 Total respondent hours from above + Total E PA hours Total Cost (Respondents and Agency) 29,774,492 Total respondent cost from above + Total EPA costs Note: Detail may not add exactly to total due to in dependent rounding.

6(f) Reasons for Change in Burden
This proposed rule will result in an overall increa se in annual burden of 73,000 hours and $7.2 million. Specific respondent activities that i mpose an increase in burden and costs due to the EPA’s proposed revisions to Part 98, subpart W are identified below and reviewed in more detail in Appendix B. Reporting Proposed New Data Elements. For each of t he 232 new data elements required to be reported (see Section 4(b)(i)), respondents w ould be required to calculate the data element using readily available data, and submit the value via e-GGRT as part of the annual report currently required under Part 98. This proposed rev ision is an increase to burden and cost. Oil Wells with Hydraulic Fracturing. The EPA is pro posing to add reporting requirements for completions and workovers of oil wells with hyd raulic fracturing. The proposed provisionsPage 22 November 2014

include the reporting of activity data on the numbe r of wells fractured and on the use of flaring and reduced emissions completions. This proposed revisi on is an increase in burden and cost to the estimated 50 new reporters and 246 existing reporte rs containing oil wells with hydraulic fracturing, who would be reporting data elements th at were not previously required. Onshore Petroleum and Natural Gas Gathering and Boo sting. The EPA is proposing to add a new Onshore Petroleum and Natural Gas Gathering a nd Boosting segment to subpart W. The proposed requirements would require the reporting o f GHG emissions from an entire gathering and boosting facility instead of the partial approa ch that currently exists under the GHGRP. Specifically, some gathering and boosting emission sources, such as natural gas compression stations, are only required to report GHG emissions if the facility exceeds the 25,000 metric tons
CO 2 e annual emission reporting threshold in subpart A, 40 CFR 98.2(a)(2), based on combustion emissions that are reported under subpart C. Subpar t W does currently require reporting from facilities that perform “natural gas processing” in 40 CFR 98.230(a)(3), but this requirement is only for those facilities that perform separation o f natural gas liquids or non-methane gases from produced natural gas or the separation of natural g as liquids into one or more component mixtures and exceed 25 million standard cubic feet per day a nnual average daily gas throughput Due to these proposed changes, the sources in this segment would include venting from natural gas pneumatic devices, natural gas driven p neumatic pumps, storage tanks, reciprocating compressors, dehydrators, acid gas removal units, a nd centrifugal compressors; flare stacks; and leaks from gathering pipelines and components such as valves and connectors. Approximately 200 new reporters in this industry segment would need t o collect data, calculate, and report these emissions under the proposed revisions. This propos ed revision is an increase to burden and cost. Natural Gas Transmission Lines Between Compressor S tations. The EPA is proposing to add reporting requirements for emissions from blowd owns of natural gas transmission pipelines in a new Onshore Natural Gas Transmission Pipeline seg ment in subpart W. The EPA is proposing that reporters would use one of two methods to calc ulate or measure emissions from pipeline blowdown events. One method allows a reporter to ca lculate emissions based on the volume of the pipeline segment between isolation valves that is b lown down and the pressure and temperature of the gas within the pipeline. The second method allo ws the reporter to measure the emissions from the blowdown using a flow meter on the blowdown ven t stack. In both methods, approximatelyPage 23 November 2014

150 new reporters would calculate both CH 4 and CO 2 emissions from the volume of natural gas vented using either default gas composition or engi neering estimates of composition. This proposed revision is an increase to burden and cost

. Well Identification Numbers. The EPA is proposing t o add reporting requirements for well identification numbers for wells in the onshore pet roleum and natural gas production. The well
identification number is either the US Well Number (formerly called the API Well Number), or if a US Well Number has not been assigned, a unique nu mber assigned by the permitting authority. These numbers are readily available and do not requ ire any additional data gathering or
calculation. The small additional burden needed to report the numbers in e-GGRT is included in the overall reporting burden estimate of 10 hours p er reporter per year.

6(g) Burden Statement
The respondent reporting burden for this collection of information is estimated to average 317,400 hours and $29.2 million per year for a thre e-year period, where identical annual costs are anticipated for all three years. The average annual burden to the EPA for this period is estimated to be 10,400 hours for oversight activities. The annua l public reporting and recordkeeping burden for
this collection of information is estimated to aver age 63.4 hours per response. Burden means the total time, effort, or financial r esources 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; de velop, acquire, install and utilize technology and systems for the purposes of collecting, validat ing and verifying information, processing and maintaining information and disclosing and providin g 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 curr ently valid OMB control number. The OMB control numbers for the EPA’s regulations are liste d in 40 CFR part 9. To comment on the Agency’s need for this informatio n, the accuracy of the provided burden estimates and any suggested methods for mini mizing respondent burden, including thePage 24 November 2014

use of automated collection techniques, the EPA has established a public docket for this ICR under Docket ID No. EPA–HQ–OAR–2014-0831, which is available for online viewing at http://www.regulations.gov/, or in person viewing a t the Air and Radiation docket in the EPA Docket Center (EPA/DC), William Jefferson Clinton F ederal Building - West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA D ocket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Fr iday, 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 electron ic version of the public docket is available at http://www.regulations.gov. This site can be used t o 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 t he system, select “search,” then key in the Docket ID Number identified above. Also, you can se nd comments to the Office of Information and Regulatory Affairs, Office of Management and Bu dget, 725 17 th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA– HQ–OAR-2014-0831 and OMB Control Number 2060-0629 o n any correspondence.

Part B of the Supporting Statement
This section is not applicable because statistical methods are not used in data collection associated with the proposed amendments.