3175 supporting statement 10 28 2016

3175 supporting statement 10 28 2016.doc

Measurement of Gas (43 CFR Subpart 3175)

OMB: 1004-0210

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Supporting Statement A

Measurement of Gas (43 CFR Subpart 3175)

OMB Control Number 1004-0210

Terms of Clearance: None. This is a new collection of information.

General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The Bureau of Land Management (BLM) is finalizing a rule to replace Onshore Oil and Gas Order Number 5, Measurement of Gas (Order 5) with new and revised regulations that will be codified in the Code of Federal Regulations (CFR). The goal of the new regulations is to ensure the accurate measurement and proper reporting of all natural gas removed or sold from Federal and Indian leases, units, unit participating areas, and areas subject to communitization agreements. The new regulations apply to operators primarily, and also to lessees, purchasers, and transporters.

The Secretary of the Interior has the authority under the following Federal and Indian mineral leasing laws to manage oil and gas operations on Federal and Indian (except Osage Tribe) lands:

Allotted Mineral Leasing Act, 25 U.S.C. 396;
Indian Mineral Leasing Act, 25 U.S.C. 396a et seq.;
Indian Mineral Development Act, 25 U.S.C. 2101 et seq;
Mineral Leasing Act, 30 U.S.C. 181 et seq.;
Mineral Leasing Act for Acquired Lands, 30 U.S.C. 351 et seq.;
Federal Oil and Gas Royalty Management Act, 30 U.S.C. 1701 et seq.; and
Federal Land Policy and Management Act, 43 U.S.C. 1701 et seq.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

Many of the information collection activities in this rule are incurred by persons in the normal course of their activities and are ”usual and customary” within the meaning of 5 CFR 1320.3(b)(2), since they are commonly found in gas sales contracts and/or industry standards. Therefore they are not among the “burdens” that must be disclosed under the Paperwork Reduction Act. Some other activities are usual and customary only in part. The burdens of those activities are analyzed to the extent they are not usual and customary.

Some of the activities in this rule will result in one-time burdens because they apply only to equipment in operation before the effective date of the final rule and therefore pertain only to the initial implementation of the rule. These one-time burdens are spread over the next three years for the purposes of our request to OMB, giving an average annualized burden of 1,610 hours for industry, and 2,659 hours for the government.

For some other activities, there will be both an annual burden for some respondents, and a one-time burden for virtually all respondents in the initial implementation. Finally, some of the information collection activities apply only annually.

Table 2, below, lists all information collection activities that are in the final rule; however, only those that are not considered usual and customary business practices are included in the burden estimates of questions 12, 13, and 14.

Table 2

Summary of Information Collection Activities

Activity	Usual and Customary	Industry Hour Burden (Table 12-2)	Industry Non-Hour Burden (Table 13)	Government Hour Burden (Table 14-2)
Transducers  Test Data Collection and Submission for Existing Makes and Models 43 CFR 3174.43 and 3175.130 One-Time		X		X
Transducers  Test Data Collection and Submission for Future Makes and Models 43 CFR 3174.43 and 3175.130 Annual		X	X	X
Flow-Computer Software  Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.44 and 3175.140 One-Time		X		X
Flow-Computer Software  Test Data Collection and Submission for Future Makes and Models 43 CFR 3175.44 and 3175.140 Annual		X	X	X
Differential Primary Devices Other than Flange-Tapped Orifice Plates – Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.47 One-Time		X	X	X
Linear Measurement Devices– Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.48 One-Time		X		X
Linear Measurement Devices – Test Data Collection and Submission for Future Makes and Models 43 CFR 3175.48 Annual		X	X	X
Accounting Systems  Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.49 One-Time		X
Accounting Systems  Test Data Collection and Submission for Future Makes and Models 43 CFR 3175.49 One-Time		X
Orifice Plate Inspection 43 CFR 3175.80(d) and (e) Annual	X
Basic Inspection of Meter Tubes  Data Collection and Submission 43 CFR 3175.80(h)(5) Annual		X	X
Schedule of Basic Meter Tube Inspection 43 CFR 3175.80(h)(3) Annual		X
Detailed Inspection of Meter Tubes – Data Collection and Submission 43 CFR 3175.80(i) and (j) Annual		X	X
Request for Extension of Time for a Detailed Meter Tube Inspection 43 CFR 3175.80(i) Annual		X
Maintenance of Data at an FMP 43 CFR 3175.91(d) and 3175.101(c) Annual			X
Verification and Calibration of Mechanical Recorders 43 CFR 3175.92(d) and 3175.102(f) Annual	X
Redundancy Verification Check for Electronic Gas Measurement Systems 43 CFR 3175.102(e)(2) Annual		X
Notification of Verification 43 CFR 3175.92(e) and 3175.102(f) Annual		X
Test Equipment Certification 43 CFR 3175.92(g) and 3175.102(h) Annual	X
Sample Cylinder Cleaning  Documentation 43 CFR 3175.113(c)(3) Annual		X	X
Sample Separator Cleaning  Documentation 43 CFR 3175.113(d)(1) Annual		X	X
Evacuation and Pre-charge for the Helium Pop Method  Documentation 43 CFR 3175.114(a)(2) Annual		X
O-ring and Lubricant Composition for the Floating Piston Method  Documentation 43 CFR 3175.114(a)(3) Annual		X
Schedule for Spot Sampling 43 CFR 3175.113(b) Annul		X
Submission of On-line Gas Chromatograph Specifications 43 CFR 3175.117(c) Annual		X
Gas Chromatograph Verification  Documentation 43 CFR 3175.118(c) and (d) Annual		X	X
Integration Statements 43 CFR 3175.93 Annual	X
Quantity Transaction Record – Data Collection and Submission 43 CFR 3175.104(a) Annual	P*	X
Quantity Transaction Record Edits 43 CFR 3175.126(c) Annual	X
Configuration Log 43 CFR 3175.104(b) Annual	P*	X
Event Log 43 CFR 3175.104(c)	X
Alarm Log 43 CFR 3175.104(d)	X
Amended Reports Due to Calibration 43 CFR 3175.92(f) and 3175.102(g)	X
Gas Analysis Reports – Entry of Data into the Gas Analysis Reporting and Verification System 43 CFR 3175.120(f) Annual	P*	X	X
Gas Analysis – Spot Sampling 43 CFR 3175.115(a) and (b)	P*		X
Gas Analysis – Composite Sampling 43 CFR 3175.115(b)(5) One-Time	P*		X
Gas Analysis – Extended Gas Analysis 43 CFR 3175.119			X

*P means that there are aspects to the requirement that exceed what is considered usual and customary. The burdens associated with this activity only include those aspects that exceed what is usual and customary

Some of the information collection burdens listed in Tables 12-2, 13, or 14-2 do not include the costs of maintaining data and submitting it to the BLM. Data retention, and submission of data at the request of the BLM, are required at 43 CFR 3170.7, which will be part of the final rule for site security (RIN 1004-AE15; control number 1004-0207). In general, section 3170.7 requires maintenance and retention of records for 7 years for federal leases and for 6 years for Indian leases. Additional details are at 43 CFR 3170.7(c) through (e). The estimated PRA burdens for these activities are disclosed in the site-security rule under the heading, “Required Recordkeeping and Records Submission (43 CFR 3170.7).”

Where data retention and/or submission are required by 43 CFR 3170.7, the titles of the information collection activities do not include the word “maintenance” and/or “submission.” Where these types of requirements are included in this final rule on gas measurement, the titles of the information collection activities include the word “maintenance” and/or “submission.”

The information collection activities in this rule can be organized into the following categories:

Testing of Makes and Models of Gas-Measurement Equipment;
Inspections and Verifications; and
Determining and Reporting Volumes, Heating Value, and Relative Density.

Testing of Makes and Models of Gas-Measurement Equipment

The following provisions of the final rule provide for the listing of approved makes and models of gas-measurement equipment or software at www.blm.gov. These provisions also provide for procedures to seek approval of other makes and models. The operator or manufacturer arranges for testing of the equipment or software by a qualified testing facility. The testing is accomplished by comparing the requested equipment or software with reference standards specified in the regulations.

The operator or manufacturer submits a report to the BLM’s Production Measurement Team (PMT). The PMT, which consists of BLM employees who are experts in oil and gas measurement, acts as a central advisory body for reviewing devices and software not specifically addressed and approved in these regulations. The report must show the results of the testing, as well as descriptions of the test set-up and procedures, qualifications of the test facility, and uncertainty analyses.

The PMT reviews the report, and then recommends to the BLM Director that use of the device or software be approved, disapproved, or approved with conditions. If the BLM Director decides to approve the device with or without conditions, the device is posted on the BLM website as being available for use by any operator without any further review or approval. These information collection activities assist the BLM in ensuring that the equipment and software used in gas measurement are in compliance with the performance standards in § 3175.31 of the rule.

None of the activities listed in this section are considered usual and customary; therefore, the full burden of each of these are included in questions 12, 13, and 14. We anticipate one-time, start-up requests during the first three years after the effective date of the rule as well as a limited number of recurring requests each year after that. We calculated cumulative burden estimates for these activities for the first three years after the effective date of the rule. We annualized these burden estimates for inclusion in the total estimated hour burdens of this rule. The start-up requests are indicated in the burden tables with the caption “ONE-TIME.” The recurring requests, after the first three years are indicated in the burden tables with the caption “ANNUAL.”

Transducers  Test Data Collection and Submission for Existing Makes and Models (43 CFR 3175.43 and 3175.130); and
Transducers  Test Data Collection and Submission for Future Makes and Models (43 CFR 3175.43 and 3175.130)

This information collection activity pertains to electronic gas measurement (EGM) systems. As defined at 43 CFR 3175.10, an EGM system includes all hardware and software necessary to convert the static pressure, differential pressure, and flowing temperature developed as part of a primary device, to a quantity, rate, or quality measurement that is used to determine Federal or Indian royalty.

For transducers that were developed and used at FMPs prior to the effective date of the rule, 43 CFR 3175.43(b) allows the manufacturer or operator to submit existing test data for that make and model of transducer in lieu of testing the transducers under 43 CFR 3175.130. Presumably, manufacturers already have this data because it was used to develop the transducer’s published performance specifications. The BLM believes that virtually all manufacturers of existing makes and models of transducers will choose this option to avoid the cost and time of testing their transducers under 43 CFR 3175.130. Because this option does not require new testing, there are no non-hour cost burdens (Table 13) related to this activity. The hourly burden costs (Table 12-2) account for the time required to find and compile the existing test data.

The PMT will review the data and develop performance specifications for that transducer make and model to the best of its ability. If the testing is insufficient to support the manufacturer’s published performance specifications, the PMT may recommend to the BLM Director that the approval of the transducer be limited to specific operating conditions.

For makes and models of transducers that are developed and used at FMPs after the effective date of the rule, the BLM Director will approve use of that make and model of transducer only on the basis that the transducer has been tested under the requirements listed at 43 CFR 3175.131 through 3175.133. See 43 CFR 3175.130. The information collection activity in this set of regulations is at 43 CFR 3175.134, which requires submission of a report showing the results of each test required by sections 3175.131 through 3175.133. All tests must be fully documented by the test facility performing the tests. It also provides that the report must indicate the results for each required test and include all data points recorded. The testing of the transducer is a non-hour cost burden (Table 13). The cost of preparing and submitting the test report, which is disclosed in Table 12-2, is a one-time burden for equipment existing before the effective date of the final rule, and is an annual burden for equipment that goes into operation after the effective date of the final rule.

The test report must be submitted to the PMT. If the PMT determines that all testing was completed as required by sections 3175.131 through 3175.133, it will make a recommendation that the BLM Director approve the transducer and post the transducer make, model, and range, along with the reference uncertainty (see 43 CFR 3175.135), influence effects, and any operating restrictions to the BLM’s website (www.blm.gov) as an approved device.

Transducers used at low- and very-low-volume FMPs are exempt from these requirements.

Flow-Computer Software  Test Data Collection and Submission for Existing Makes and Models (43 CFR 3175.44 and 3175.140); and
Flow-Computer Software  Test Data Collection and Submission for Future Makes and Models (43 CFR 3175.44 and 3175.140)

The BLM Director will approve a particular version of flow-computer software for use in a specific make and model of flow computer only if the testing performed on the software meets all of the standards and requirements in 43 CFR 3175.141 through 3175.144. Type-testing is required for each software version that affects the calculation of flow rate, volume, heating value, live input variable averaging, flow time, or the integral value. Software updates or changes that do not affect these items do not require BLM approval 43 CFR 3175.140. However, the manufacturer must still provide some documentation to the BLM (see paragraph (ii)).

The information collection activity in this set of regulations is at 43 CFR 3175.144, which requires submission of a report showing the results of each test required by sections 3175.141 through 3175.143, including all data points recorded. The testing must be performed by a qualified testing facility not affiliated with the manufacturer.

This report will be reviewed by the PMT who will recommend approval, approval with conditions, or denial to the BLM Director. The BLM Director’s approval, with or without conditions will be a pre-requisite for BLM posting of approved software for use in an EGM system at the BLM’s website (www.blm.gov). This requirement assists the BLM in ensuring that software used in gas measurement is in compliance with performance standards. The cost of the testing is considered a non-hour burden and is included in Table 13. The cost of preparing and submitting the test report is considered an hour burden and is included in Table 12-2.

For flow computer software that does not affect the calculation of flow rate, volume, heating value, live input variable averaging, flow time, or the integral value, the operator or manufacturer must provide the PMT with a list of these software versions along with a brief description of what changes were made from the previous version. The PMT will also post these software versions as approved software on the BLM website (www.blm.gov). No testing or approval is required. The cost of the testing is considered a non-hour burden and is included in Table 13. The cost of preparing and submitting the test report, which is disclosed in Table 12-2, is a one-time burden for software in use before the effective date of the final rule, and is an annual burden for software that will be in use only after the effective date of the final rule.

Isolating Flow Conditioners  Test Data Collection and Submission for Existing Makes and Models (43 CFR 3175.46)

Section 3175.46 provides for the listing of an approved make and model of isolating flow conditioner at www.blm.gov, and provides procedures for operators or manufacturers to seek that approval. The procedure involves testing by a qualified testing facility not affiliated with the manufacturer. The reference standards for the testing are included in the American Petroleum Institute’s (API’s) Manual of Petroleum Measurement Standards. The API standards for flow conditioners are among those that are incorporated by reference in these regulations. The operator or manufacturer reports the test data to the PMT, which reviews the test data to ensure that the requested flow conditioner meets the relevant requirements, and recommends that the BLM approve use of the device, disapprove use of the device, or approve its use with conditions. If the BLM Director approves the device, the BLM will add the approved make and model, and any applicable conditions of use, to the list maintained at www.blm.gov. The cost of the testing is a non-hour burden and is included in Table 13. The cost of preparing the test report, which is disclosed in Table 12-2, is a one-time hourly burden because it applies only to equipment in existence before the effective date of the final rule.

Differential Primary Devices Other than Flange-Tapped Orifice Plates  Test Data Collection and Submission for Existing Makes and Models (43 CFR 3175.47)

Section 3175.47 provides for the listing of an approved make and model of differential primary device at www.blm.gov, and provides a procedure for operators or manufacturers to seek approval of other makes and models. The procedures involve testing by a qualified testing facility not affiliated with the manufacturer. The reference standards for the testing are included in the American Petroleum Institute’s (API’s) Manual of Petroleum Measurement Standards, although the PMT may require additional testing. The API standards for differential primary devices are among those that are incorporated by reference in these regulations.

Next, the operator or manufacturer reports the test data to the PMT, which reviews the test data to ensure that the device meets the relevant requirements, and recommends that the BLM Director approve use of the device, disapprove use of the device, or approve its use with conditions. If the BLM Director approves the device, the BLM will add the approved make and model, and any applicable conditions of use, to the list maintained at www.blm.gov. The cost of the testing is a non-hour burden and is included in Table 13. The cost of preparing the test report, which is disclosed in Table 12-2, is a one-time hourly burden because it applies only to equipment in existence before the effective date of the final rule.

Linear Measurement Devices  Test Data Collection and Submission for Existing Makes and Models (43 CFR 3175.48); and
Linear Measurement Devices  Test Data Collection and Submission for Future Makes and Models (43 CFR 3175.48)

Section 3175.48 provides for the listing of an approved make and model of linear measurement device at www.blm.gov, and provides a procedure for seeking approval of other makes and models. The first step is to arrange for testing by a qualified test facility not affiliated with the linear measurement device manufacturer.

Next, the operator or manufacturer reports the test data to the PMT, which reviews the test data to ensure that the device meets the relevant requirements, and recommends that the BLM Director approve use of the device, disapprove use of the device, or approve its use with conditions. If the BLM Director approves the device, the BLM will add the approved make and model, and any applicable conditions of use, to the list maintained at www.blm.gov. The cost of the testing is a non-hour burden and is included in Table 13. The cost of preparing and submitting the test report, which is disclosed in Table 12-2, is a one-time burden for equipment existing before the effective date of the final rule, and is an annual burden for equipment that goes into operation after the effective date of the final rule.

Accounting Systems  Test Data Collection and Submission for Existing Makes and Models (43 CFR 3175.49); and
Accounting Systems  Test Data Collection and Submission for Future Makes and Models (43 CFR 3175.49)

The BLM Director will approve the use of a particular name and version of accounting system for use in conjunction with FMPs if the accounting system meets the standards of 3175.49. The information collection activity for quantity transaction records is at 43 CFR 3175.49(a) and (b); for configuration logs it is at 43 CFR 3175.49(c), for event logs it is at 43 CFR 3175.49(d), and for alarm logs, it is at 43 CFR 3175.49(e). The BLM may also request additional records under 43 CFR 3175.49(f). The PMT will compare the records generated by the flow computer with the records generated by the accounting system. If the comparison is successful, the PMT will recommend that the BLM Director approve the use of the accounting system. If the accounting system is approved, it will be listed at www.blm.gov. The costs associated with this information collection activity only involve the compilation of data from flow computers and the accounting system, all of which the BLM considers to be hourly burden costs (Table 12-2). There are no non-hour burden costs. The cost of preparing and submitting the test report, which is disclosed in Table 12-2, is a one-time burden for systems in use before the effective date of the final rule, and is an annual burden for systems that will be in use only after the effective date of the final rule.

Inspections and Verifications

The following information collection activities are necessary in order to ensure that the equipment used to measure gas is in good working condition. Some of these information collection activities are usual and customary because they are required by gas sales contracts and/or industry standards. To the extent they are usual and customary, they are not “burdens” under the Paperwork Reduction Act (see 5 CFR 1320.3(b)(2)). A description of what is considered usual and customary is given for each applicable activity.

The regulations pertaining to inspections and verifications refer to primary, secondary, and tertiary devices which measure the volume of natural gas on which royalty is due. While not all types of gas meters include tertiary devices, all differential types of gas meters consist of at least a primary device and a secondary device. The primary device is the equipment that creates a measureable and predictable pressure drop in response to the flow rate of fluid through the pipeline. A flange-tapped orifice plate is the most common primary device. The secondary device measures the differential pressure along with static pressure and temperature. In the case of an EGM system, there is also a tertiary device, which calculates volume and flow rate based on data received from the transducers and other data programmed into the flow computer.

The regulations also pertain to the inspections and verifications that determine the heating value and relative density of the gas. The heating value of the gas is used directly in the determination of royalty due while the relative density is used in the determination of volume. The inspection items for heating value and relative density include documentation to ensure that sampling equipment is clean, calibrated, and properly used and that samples are taken at the required frequency

Inspection of Meter Tubes (43 CFR 3175.80(h) through (j))

Section 3175.80 requires basic inspections of meter tubes and, depending on the results of the basic inspection, it may require detailed inspections of meter tubes. It also requires operators to maintain records of both types of inspections, and to provide those records to the BLM upon request. Although meter tube inspections may be part of some gas sales contracts, for the purpose of this analysis the BLM assumed that this inspection is not usual and customary because this was not a requirement of Order 5. Therefore, the burdens in Table 12-2 and Table 13 represent the total burden of these inspections in the rule.

Schedule of Basic Meter Tube Inspection (43 CFR 3175.80(h)(3)

The operator must notify the BLM at least 72 hours in advance of performing a basic inspection of meter tubes or submit a monthly or quarterly schedule of basic inspections to the BLM in advance. The schedule of basic meter tube inspections may be submitted to the BLM in lieu of a 72-hour notice. There is no set format for this submittal. All costs associated with preparation of the schedule are considered to be hourly burdens and are listed in Table 12-2 as such. There are no non-hour burdens associated with this recordkeeping activity.

Basic Inspection of Meter Tubes – Data Collection and Submission (43 CFR 3175.80(h)(5 ))

Table 1 at 43 CFR 3175.80 establishes the required frequency of basic inspection of meter tubes, which is yearly for very-high-volume FMPs, once every other year for high-volume FMPs, or once every 5 years for low-volume FMPs. The BLM may require additional inspections if conditions warrant. Examples of such conditions include corrosive or erosive-flow conditions, or signs of physical damage to the meter tube. Very-low-volume FMPs are exempt from meter tube inspections.

The purpose of a basic inspection is to identify pitting, obstructions, or the buildup of foreign substances in the meter tube, all which can affect the accuracy of the meter. If the basic inspection reveals pitting, obstructions, or a buildup of foreign material on a high- or very-high-volume FMP, the operator must perform a detailed inspection of that meter tube within 30 days. For low-volume FMPs, the operator only needs to clean the meter tube. A detailed inspection requires disassembly of the meter tube in order to physically measure the roundness and surface roughness of the inside walls to ensure the meter tube complies with API’s Manual of Petroleum Measurement Standards that are listed in the regulation, or with the requirements listed at 43 CFR 3175.61, if the meter tube is grandfathered .

If the meter tube does not comply with the applicable standards, the operator must repair the meter tube and bring the meter tube into compliance with these standards or replace the meter tube with one that is in compliance. The BLM may grant an extension to the 30-day timeframe if the operator submits a request justifying the need for an extension.

The recordkeeping requirements for a basic inspection include:

The information required in 43 CFR 3170.7(g)
The time and date of inspection
The type of equipment used to make the inspection; and
A description of findings, including location and severity of pitting, obstructions, and buildup of foreign substances.

Detailed Inspection of Meter Tubes – Data Collection and Submission (43 CFR 3175.80(i) and (j))

If a basic meter tube inspection reveals pitting, obstructions, or a buildup of foreign material on a high- or very-high-volume FMP, the operator must perform a detailed inspection of that meter tube within 30 days. A detailed inspection is also required when a meter tube is first installed at a high- or very-high-volume FMP, although an operator can submit documentation showing that the meter tube complies with provisions of API’s Manual of Petroleum Measurement Standards that are listed at 43 CFR 3175.80, in lieu of performing a detailed inspection.

The operator must retain documentation of all detailed meter tube inspections, demonstrating that the meter tube complies with API 14.3.2, Subsections 5.1 through 5.4 (all incorporated by reference, see 43 CFR 3175.30), and showing all required measurements. The operator must provide such documentation to the BLM upon request for every meter-tube inspection. Documentation must also include the information required in 43 CFR 3170.7(g).

The recordkeeping requirements for a detailed inspection include the information required in 43 CFR 3170.7(g) along with all measurements and findings that demonstrate the meter tube complies with API standards. Section 3170.7(g) requires that all records, including source records that are used to determine quality, quantity, disposition and verification of production attributable to a Federal or Indian lease, unit PA, or CA, must include a unique meter identification number and the name of the company that created the record.

Request for Extension of Time for a Detailed Meter Tube Inspection (43 CFR 3175.80(i))

There is no set format or requirements for a request for an extension of time to perform a detailed inspection. The operator must submit a request to the BLM for an extension of the 30-day timeframe, justifying the need for the extension

2. Maintenance of Data at an FMP (43 CFR 3175.91(d) and 3175.101(c))

Sections 3175.91(d) and 3175.101(c) require that certain data be maintained at FMPs for mechanical recorders and EGM systems, respectively. The purpose of maintaining these data is to allow BLM inspectors to verify the monthly reported volumes of gas reported on the Oil and Gas Operator Reports and, for EGM systems, to verify the configuration of and calculations of flow computers.

For mechanical recorders, these data include:

Differential-bellows range;
Static-pressure-element range;
Temperature-element range;
Static-pressure units of measure (psia or psig);
Relative density (specific gravity);
Meter elevation;
Meter-tube inside diameter;
Primary device type;
Orifice-bore or other primary-device dimensions necessary for device verification, Beta- or area-ratio determination, and gas-volume calculation;
Make, model, and location of approved isolating flow conditioners, if used;
Location of the downstream end of 19-tube-bundle flow straighteners, if used;
Date of last primary-device inspection; and
Date of last verification.

For EGM systems:

The unique meter ID number;
Relative density (specific gravity);
Elevation of the FMP;
Primary device information such as orifice bore diameter (inches) or Beta or area ratio and discharge coefficient, as applicable;
Meter-tube mean inside diameter;
Make, model, and location of approved isolating flow conditioners, if used;
Location of the downstream end of 19-tube-bundle flow straighteners, if used;
For self-contained EGM systems, make and model number of the system;
For component-type EGM systems, make and model number of each transducer and the flow computer;
URL and upper calibrated limit for each transducer;
Location of the static pressure tap (upstream or downstream);
Last primary-device inspection date; and
Last secondary device verification date.

Although some of this information is required by the statewide NTLs for EGM systems, the BLM does not believe this requirement is usual and customary. Because the posting and maintenance of these data would typically be done as a field activity in conjunction with meter calibration and maintenance, rather than a reporting activity done by office personnel, the BLM included these as non-hourly burden costs in Table 13. There are no hourly burden costs associated with this activity. Therefore, this activity is not listed in Table 12-2.

3. Redundancy Verification Check for Electronic Gas Measurement Systems (43 CFR 3175.102(e)(2))

Section 3175.102(e)(2) allows redundancy verification in lieu of routine verification. If an operator opts to use redundancy verification, the final rule establishes standards for the information that must be retained and submitted to the BLM on request, usually during production audits. The use of redundancy verification is not currently a common practice in the United States, and the BLM anticipates that it will only be used on 10 percent of FMPs classified as very-high volume. Because redundancy verification primarily consists of comparing the readings from two sets of transducers and documenting that comparison, there are no non-hour cost burdens associated with this activity. Table 12-2 shows the projected hourly burden of collecting the information.

The following information is required:

The information required at 43 CFR 3170.7(g) (a regulation that is part of the rulemaking for site security, RIN 1004-AE15, control no. 1004-0207);
The month and year for which the redundancy check applies;
The makes, models, upper range limits, and upper calibrated limits of the primary set of transducers;
The makes, models, upper range limits, and upper calibrated limits of the check set of transducers;
The information required in provisions of API’s Manual of Petroleum Measurement Standards that are listed in the regulation, which includes comparisons of volume, energy, differential pressure, static pressure, and temperature both in tabular form (average values) and graphical form (instantaneous values).
The tolerance for differential pressure, static pressure, and temperature as calculated under 43 CFR 3175.102(d)(2); and
Whether or not each transducer required verification under paragraph (c) of this section.

4. Notification of Verification (43 CFR 3175.92(e) and 3175.102(f))

The final rule requires that for routine verifications, the operator must either provide the BLM with notice of verifications at least 72 hours prior to verification or provide the BLM with a monthly or quarterly schedule of verifications. The BLM uses this information to schedule the witnessing of verifications. The BLM does not believe that providing 72-hour notice of verifications, normally by phone or email, results in any significant cost burden. However, the preparation of a monthly or quarterly schedule will involve some hourly cost burdens, which are included in Table 12-2. There are no non-hour cost burdens associated with this activity.

5. Sample Cylinder Cleaning  Documentation (43 CFR 3175.113(c)(3))

Section 3175.113(c)(3) requires operators to clean sample cylinders used to collect gas samples in accordance with Gas Processor’s Association (GPA) standards. This section also requires the operator to maintain documentation of the cleaning and submit it to the BLM on request. The BLM uses this information during an audit or during the witnessing of a gas sample being taken in order to ensure that the sample cylinder is clean and free of contaminates that could alter the composition of the sampled gas and, in turn, affect royalty. The rule does not specify a format or minimal informational requirements for the documentation.

The BLM does not believe that cleaning sample cylinders and providing documentation of the cleaning is a usual and customary business practice. Therefore, the non-hour burden cost of cleaning a sample cylinder is included in Table 13 and the hourly cost burden of preparing the documentation is included in Table 12-2.

6. Sample Separator Cleaning  Documentation (43 CFR 3175.113(d)(1))

Section 3175.113(d)(1) requires that sampling separators, if used, must be cleaned in accordance with GPA standards. Sample separators are sometimes used with portable GCs to ensure that liquids do not get into and damage the GC. The cleaning process for sample separators is identical to the cleaning process for sample cylinders. This section also requires the operator to maintain documentation of the cleaning and submit it to the BLM on request. The BLM uses this information during an audit or during the witnessing of a gas sample being taken in order to ensure that the sample separator is clean and free of contaminates that could alter the composition of the sampled gas and, in turn, affect royalty. The rule does not specify a format or minimal informational requirements for the documentation.

The BLM does not believe that cleaning sample separators and providing documentation of the cleaning is a customary or usual business practice. Therefore, the non-hour burden cost of cleaning a sample separator is included in Table 13 and the hourly cost burden of preparing the documentation is included in Table 12-2.

7. Documentation Related to the “Helium Pop” Sampling Method (3174.114(a)(2))

The “helium pop” method employs a sample cylinder that is evacuated and then pre-charged with helium. This process is done at a central facility where the BLM would not normally have access. If the cylinder is not evacuated and pre-charged with helium, the resulting gas sample may not represent the gas flowing through the meter, which could affect royalty. By requiring operators to provide documentation of the evacuation and pre-charge process, the BLM will have some assurance that the sample will be properly taken.

The BLM believes that the evacuation and helium pre-charge is a usual and customary business practice for operators employing this sampling method. However, the BLM does not believe that documenting this process and having that documentation on-site during gas sampling is a usual and customary business. Therefore, Table 12-2 includes the hourly cost burden of the documentation of this process. Because the non-hour cost burden is a usual and customary process, there is no non-hour cost burden in Table 13.

8. O-ring and Lubricant Composition for the Floating Piston Method  Documentation

(43 CFR 3175.114(a)(3))

The “floating piston” method employs a piston inside the sampling cylinder that allows the operator to maintain a constant pressure when collecting a sample. To work properly, the piston must form an air-tight seal against the inside walls of the cylinder. This is accomplished using O-rings and lubricants. If the O-rings or lubricants are composed of certain materials, they could contaminate the sample which, in turn, could affect royalty. The only way the BLM can ensure that the O-rings or lubricants will not contaminate the gas sample is to have documentation of what the O-rings and lubricants consist of when the BLM is witnessing a sample using a floating piston.

The BLM believes that the using proper O-rings and lubricants is a usual and customary business practice for operators employing this sampling method. However, the BLM does not believe that documenting the composition of the O-rings and lubricants and having that documentation on-site during gas sampling is a usual and customary business. Therefore, Table 12-2 includes the hourly cost burden of the documentation of this process. Because the non-hour cost burden is a usual and customary process, there is no non-hour cost burden in Table 13.

9. Schedule for Spot Sampling (43 CFR 3175.113(b))

The final rule requires the operator to either provide the BLM with notice of sampling at least 72 hours prior to sampling or provide the BLM with a monthly or quarterly schedule of sampling. The BLM uses this information to schedule the witnessing of sampling. The BLM does not believe that providing 72-hour notice of sampling, normally by phone or email, results in any significant cost burden. However, the preparation of a monthly or quarterly schedule would involve some hourly cost burdens, which are included in Table 12-2. There are no non-hour cost burdens associated with this activity.

Sampling Separator Cleaning  Documentation (43 CFR 3175.113(d)(1)

Sampling separators, if used, must be operated and cleaned in accordance with standards in the regulations. The applicable standards are listed at 43 CFR 3175.113(d)(1). The operator must maintain documentation of cleaning, and have the documentation available on-site during sampling , and provide it to the BLM upon request. Gas Analysis  Spot Sampling (43 CFR 3175.115(a) and (b))

With some exceptions, spot samples for all FMPs must be taken and analyzed at the following frequency:

Once every 12 months for very-low volume FMPs;
Once every 6 months for low-volume FMPS;
Once every 3 months for high-volume FMPs;
Once a month for very-high volume FMPs.

These required frequencies are at Table 1 to 43 CFR 3175.110. The BLM may change the required sampling frequency for high-volume and very-high-volume FMPs if the BLM determines that the sampling frequency required in Table 1 in section 3175.110 is not sufficient to achieve the heating value uncertainty levels required in the final rule.

For high-volume FMPs, the BLM may change the sampling frequency no sooner than 2 years after the FMP begins measuring gas or 4 years after the effective date of the regulation, whichever is later. For very-high-volume FMPs, the BLM may change the sampling frequency or require compliance with paragraph (b)(5) of this section no sooner than 1 year after the FMP begins measuring gas or 3 years after the effective date of the regulation, whichever is later.

Gas Analysis  Composite Sampling (43 CFR 3175.115(b)(5)

For very-high-volume FMPs, the BLM may require the installation of a composite sampling system or on-line GC if the heating value uncertainty levels in section 3175.31(b) cannot be achieved through spot sampling.

13. On-line Gas Chromatograph Specifications (43 CFR 3175.117(c))

If the operator uses an on-line gas chromatograph, the final rule requires the operator to submit the manufacturer’s specifications and installation and operational recommendations to the BLM on request. The BLM would request this data to ensure that the on-line gas chromatograph is properly installed and operated in the field. Unlike other measurement-related devices, the design and operation of on-line gas chromatographs could vary significantly from manufacturer to manufacturer or even from model to model. The cost of retrieving operational manuals for these devices would incur a minimal hourly cost burden, which is included in Table 12-2. There are no non-hour cost burdens associated with this requirement.

14. Gas Chromatograph Verification (43 CFR 3175.118(c) and (d))

Gas chromatographs are used for analyzing samples of natural gas to determine the heating value and relative density of the gas, as discussed below. In order to ensure that a gas chromatograph is accurately determining the composition of gases sampled at FMPs, the chromatograph must periodically be verified. The verification process involves running a gas of a known composition through the chromatograph and comparing the composition determined by the chromatograph with the known composition. If the difference in these compositions is outside the allowable tolerance of these devices, the chromatograph is calibrated and then re-verified to make sure it is accurate.

The BLM requires documentation on the gas chromatograph verification to ensure, either while witnessing a gas analysis or during a production audit, that the chromatograph is accurately analyzing the composition of the gas at FMPs, which is used directly in the determination of royalty.

Gas chromatographs are subject to standards listed at 43 CFR 3175.113(d) (portable gas chromatographs), 3175.117 (on-line gas chromatographs), and 3175.118 (all gas chromatographs). These sections all require that gas chromatographs be installed, operated, and calibrated in accordance with standards of the Gas Processors Association that are specified in the respective regulations. Those standards are incorporated by reference in the final rule. The regulations also require compliance with the verification and calibration requirements of 43 CFR 3175.118. Upon request, the operator must submit to the BLM the results of all verifications.

Section 3175.118(d) requires retention of verification records for the periods specified at 43 CFR 3170.7(c) through (e).

Section 3175.118(d) lists the records that must be retained:

The components analyzed;
The response factor for each component;
The peak area for each component;
The mole percent of each component as determined by the gas chromatograph;
The mole percent of each component in the gas used for verification;
The difference between the mole percents described above, expressed in relative percent;
Evidence that the gas used for verification and calibration meets the requirements under paragraph 3175.118(c)(2), was authenticated under 3175.118(c)(3), and was maintained under 3175.118(c)(4);
The chromatograms generated during the verification process;
The time and date the verification was performed; and
The name and affiliation of the person performing the verification.

Although the BLM believes that the verification of gas chromatographs is common industry practice, the BLM does not know what the usual and customary verification frequency is, or if it is usual and customary to document and retain verification records. For that reason, and because gas chromatograph verification was not required in Onshore Order 5, the BLM has included the cost of the verifications required under 3175.118(c) as a non-hour burden in Table 13. The cost of documenting the verification required under 3175.118(d) is included as an hourly cost burden in Table 12-2.

Determining and Reporting Volumes, Heating Value, and Relative Density

Information collection activities under this section include those activities that are used to report the volume and heating value of the gas on the Oil and Gas Operations Report and that are used to verify those volumes, typically during a production audit.

1. Quantity Transaction Record (43 CFR 3175.104(a))

As defined at 43 CFR 3175.10(a), a “Quantity Transaction Record (QTR)” is “a report generated by EGM equipment that summarizes the daily and hourly volume calculated by the flow computer and the average or totals of the dynamic data that is used in the calculation of volume.”

Section 3175.104(a) requires operators to retain the original, unaltered, unprocessed, and unedited daily and hourly QTRs. The generation and retention of this information is required by virtually all gas sales contracts involving orifice plates and EGMs. It is also required by industry standards and by the statewide NTLs for Electronic Flow Computers. The final rule requires the QTR to contain the information identified in provisions of API’s Manual of Petroleum Measurement Standards that are listed in the regulation, with the following additions and clarifications:

The information required at 43 CFR 3170.7(g) (a regulation that is part of the rulemaking for site security, RIN 1004-AE15, control no. 1004-0207);
The volume, flow time, integral value or average extension must be reported to at least 5 decimal places and the average differential pressure, static pressure, and temperature as calculated in section 3175.103(c), must be reported to at least 3 decimal places; and
A statement of whether the operator has submitted the integral value or average extension.

The burdens in Table 12-2 include the burden to operators to provide the additional information listed above. There are no non-hour cost burdens associated with this information collection activity.

2. Configuration Log (43 CFR 3175.104(b))

Section 3175.104(b) requires operators to retain, and submit to the BLM upon request, usually during production audits, the original, unaltered, unprocessed, and unedited configuration log. These requirements are specific to EGMs.

As defined at 43 CFR 3175.10(a), a configuration log is “a list of all fixed or user-programmable parameters used by the flow computer that could affect the calculation or verification of flow rate, volume, or heating value.” The BLM uses these logs to verify that the flow computer is properly calculating the volume of gas on which royalty is due.

The generation and retention of configuration logs is required by virtually all gas sales contracts involving orifice meters and EGMs, and is required by industry standards. The statewide NTLs for electronic flow computers also require configuration logs. The final rule requires the configuration log to contain the information required by provisions of API’s Manual of Petroleum Measurement Standards that are listed in the regulation, with the following additions and clarifications:

The information required at 43 CFR 3170.7(g) (a regulation that is part of the rulemaking for site security, RIN 1004-AE15, control no. 1004-0207);
Software/firmware identifiers that comply with applicable API standards;
For very-low-volume FMPs, the fixed temperature, if not live (˚F), and;
The static-pressure tap location (upstream or downstream).

While the configuration log is a usual and customary business practice, the BLM included the incremental burdens due to the additional information required in the final rule as an hourly cost burden in Table 12-2. There are no non-hour cost burdens related to this information collection activity.

3. Gas Analysis Report – Entry into Gas Analysis Reporting and Verification System (43 CFR 3175.120(f))

The final rule requires that information about gas samples, in the form of a gas analysis report, be entered into the BLM’s Gas Analysis Reporting and Verification System (GARVS). The rule also authorizes operators to request a variance from this requirement. The BLM will grant such a request only in cases where the operator demonstrates that it is a small business, as defined by the U.S. Small Business Administration, and does not have access to the Internet.

The operator must submit all gas analysis reports to the BLM within 15 days of the due date for the sample as specified in 43 CFR 3175.115. For high- and very-high-volume FMPs, the BLM may adjust the sampling frequency to attain a set level of average annual heating value uncertainty as required by 43 CFR 3175.31(b). For very-high-volume FMPs, the BLM may require the installation of a composite sampling system or an on-line gas chromatograph if the required levels of certainty cannot be met through spot sampling.

The gas analysis report contains a list of the concentration of each component found in the gas sample along with header information including the location, date, time, temperature, pressure, and type of sample taken. The gas analysis report also contains values calculated from the composition such as heating value and relative density.

The BLM uses the gas analysis report to determine if the correct heating value and relative density were calculated from the composition listed, if the analysis was within tolerance limits established by the final rule, and if the analysis included tests for the components required in the final rule. The gas analysis reports are used to ensure the sampling frequency is in accordance with the final rule and whether the sample frequency needs to be adjusted to obtain the levels of uncertainty required in the rule. The BLM also uses these reports to verify the royalty which is due.

The generation and retention of gas analysis reports is usual and customary. However, the final rule includes some requirements that may not be considered usual and customary:

The usual and customary sampling frequency, based on the requirements of Onshore Order 5, is once per year. The rule requires additional sampling for all but very-low-volume FMPs. Samples that are required to be taken more than once per year are not considered as usual and customary;
It is not usual and customary to install a composite gas sampler at FMPs;
It is usual and customary for gas analysis reports to contain a breakdown of components through heptane (C5) and lump all components greater than heptane into one category called hexanes plus (C6+). The rule requires additional analysis for high- and very-high-volume FMPs that contain more than 0.5 mole percent of C6+, which is not considered usual and customary;
It is usual and customary for operators to submit gas analysis reports to the BLM on request using email or regular mail. The rule requires operators to enter all gas analyses into a new computer system (i.e., GARVS), which is not usual and customary which is not covered under the submittal burdens of 43 CFR 3170.7.

The cost of obtaining gas analyses that are not usual and customary are included as non-hour cost burdens in Table 13. These costs include the items in the first three bullet points above. The costs of generating the gas analysis report and entering that data into GARVS is an hourly cost burden that is included in Table 12-2.

The requirement to for operators to submit all gas analysis reports and required related information to the BLM through the Gas Analysis Reporting and Verification System (GARVS) in 43 CFR 3175.120(f) will begin 2 years after the effective date of the final rule. Section 3175.120(a) requires gas analysis reports to contain the following information:

The information required at 43 CFR 3170.7(g) (a regulation that is part of the rulemaking for site security, RIN 1004-AE15, control no. 1004-0207);
The date and time that the sample for spot samples was taken or, for composite samples, the date the cylinder was installed, and the date the cylinder was removed;
The date and time of the analysis;
For spot samples, the effective date, if other than the date of sampling;
For composite samples, the effective start and end date;
The name of the laboratory where the analysis was performed;
The device used for analysis (i.e., gas chromatograph, calorimeter, or mass spectrometer);
The make and model of analyzer;
The date of last calibration or verification of the analyzer;
The flowing temperature at the time of sampling;
The flowing pressure at the time of sampling, including units of measure (psia or psig);
The flow rate at the time of the sampling;
The ambient air temperature at the time the sample was taken;
Whether or not heat trace or any other method of heating was used;
The type of sample (i.e., spot-cylinder, spot-portable GC, composite);
The sampling method if spot-cylinder (e.g., fill and empty, helium pop);
A list of the components of the gas tested;
The un-normalized mole percentages of the components tested, including a summation of those mole percents;
The normalized mole percent of each component tested, including a summation of those mole percents;
The ideal heating value (Btu/scf);
The real heating value (Btu/scf), dry basis;
The hexane+ split, if applicable;
The pressure base and temperature base;
The relative density;
The name of the company obtaining the gas sample, and;
The chromatogram generated during the analysis, if requested by the BLM.

Components that are listed on the analysis report, but not tested, must be annotated as such.

4. Gas Analysis – Spot Sampling (43 CFR 3175.115(a) and (b))

The costs associated with submitting gas analysis reports to GARVS are associated with the natural gas sampling requirements in 43 CFR 3175.115. The cost of these provisions is associated with the act of sampling itself, and is thus not an hourly recordkeeping requirement listed in Table 12-2. Thus, that cost is included in Table 13.

Spot samples are required for all FMPs. Appendix F of the Regulatory Impact Analysis describes how the costs for spot sampling were derived.

The costs in that analysis match the costs shown in Table 13, which are derived assuming a $100 cost per sample. The estimated numbers of spot samples per year are in addition to those that are usual and customary, and differ according to the amount of volume handled at the relevant FMP:

Very-low-volume FMPs: No increase;
Low-volume FMPs: 25,186 additional spot samples per year;
High-volume FMPs: 49,463 additional spot samples per year, and;
Very-high-volume FMPs: 8,128 additional spot samples per year.

5. Gas Analysis  Composite Sampling (43 CFR 3175.115(b)(5))

As discussed above, the costs associated with submitting gas analysis reports to GARVS are associated with the natural gas sampling requirements in 43 CFR 3175.115. The cost of these provisions is associated with the act of sampling itself, and is thus not an hourly recordkeeping requirement listed in Table 12-2. Composite sampling is required only for very-high-volume FMPs. Appendix F of the Regulatory Impact Analysis describes how the costs for composite sampling were derived. We estimate 2,518 composite samples per year in addition to those that are usual and customary, and a $100 non-hour burden per sample.

In addition to the annual composite sampling costs described above, operators of about one-quarter of the very-high-volume FMPs that will have to take composite samples will incur the one-time costs of installing the necessary equipment to do so. These costs are not hourly recordkeeping costs on their own and are thus not included in Table 12-2. However, they do reflect a one-time installation expense for very-high-volume FMP operators that will be needed to generate the gas analysis reports that must be submitted to GARVS under 43 CFR 3175.120(f). This installation cost is thus presented as a non-hourly cost in Table 13. It reflects an estimated $20,000 installation cost for installing the necessary sampling equipment on the estimated 210 very-high-volume FMPs that are required to carry out composite samples under the final rule.

6. Gas Analysis – Extended Gas Analysis (43 CFR 3175.119)

In addition to the annual composite sampling costs described above, operators of high- and very-high-volume FMPs must submit an extended gas analysis report under 43 CFR 3175.119(b) if the concentration of their C6+ analysis exceeds 0.5 mole percent. Operators will also have the option under 43 CFR 3175.119(c) of periodically testing for these components at a minimum of once per year for high-volume FMPs and once every 6 months for very-high-volume FMPs, and adjusting the assumed C6+ composition to remove any heating value bias. Although performing these extended analyses is not an hourly recordkeeping cost, operators are required to submit gas analysis reports via GARVS to the BLM each time these analyses occur. Thus, the cost of this provision is not included as an hourly recordkeeping cost in Table 12-2, but it is included as a non-hourly recordkeeping cost in Table 13.

The BLM estimates that an average of one extended gas analysis will be performed for every 4 high-volume FMPs (1,731 analyses per year), and one extended gas analysis will be performed for every 2 very-high-volume FMPs (429 analyses per year). The BLM estimates that each analysis will cost $200 to perform.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden and specifically how this collection meets GPEA requirements.

The BLM authorizes various collection and submission techniques. For example, the BLM will accept testing data on makes and models that are submitted via mail or email.

Table 3

Collection and Submission Techniques

A. Type of Response	B. Collection and Submission Techniques
Transducers – Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.43 and 3175.130 One-Time	Data submitted by the manufacturer to the BLM via mail or email.
Transducers – Test Data Collection and Submission for Future Makes and Models 43 CFR 3175.4 and 3175.130 Annual	Data collected by the testing facility and submitted to the BLM via mail or email.
Flow-Computer Software – Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.44 and 3175.140 One-Time	Data collected by the testing facility and submitted to the BLM via mail or email.
Flow-Computer Software – Test Data Collection and Submission for Future Makes and Models 43 CFR 3175.44 and 3175.140 Annual	Data collected by the testing facility and submitted to the BLM via mail or email.
Isolating Flow Conditioners  Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.46 One-Time	Data collected by the testing facility and submitted to the BLM via mail or email.
Differential Primary Devices Other than Flange-Tapped Orifice Plates – Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.47 One-Time	Data collected by the testing facility and submitted to the BLM via mail or email.
Linear Measurement Devices– Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.48 One-Time	Data collected by the testing facility and submitted to the BLM via mail or email.
Linear Measurement Devices – Test Data Collection and Submission for Future Makes and Models 43 CFR 3175.48 Annual	Data collected by the testing facility and submitted to the BLM via mail or email.
Accounting Systems  Test Data Collection and Submission for Existing Makes and Models 43 CFR 3175.49 One-Time	Data collected by the operators from their accounting systems and, as provided at 43 CFR 3175.49, from their flow computers. Submitted by the operators to the BLM via mail or email.
Accounting Systems – Test Data Collection and Submission for Future Makes and Models 43 CFR 3175.49 Annual	Data collected by the operators from their accounting systems and, as provided at 43 CFR 3175.49, from their flow computers. Submitted by the operators to the BLM via mail or email.
Schedule of Basic Meter Tube Inspection 43 CFR 3175.80(h)(3) Annual	Schedule determined by the operators and submitted by the operators to the BLM via mail or email.
Basic Inspection of Meter Tubes – Data Collection and Submission 43 CFR 3175.80(h)(5) Annual	Data collected manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
Detailed Inspection of Meter Tubes – Data Collection and Submission 43 CFR 3175.80(i) and (j) Annual	Data collected manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
Request for Extension of Time for a Detailed Meter Tube Inspection 43 CFR 3175.80(i) Annual	Request written by hand or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
Maintenance of Data at an FMP 43 CFR 3175.91(d) and 3175.101(c) Annual	Data collected manually and posted at the FMP by the operators.
Redundancy Verification Check for Electronic Gas Measurement Systems 43 CFR 3175.102(e)(2) Annual	Data collected automatically by the EGM software and submitted by the operators to the BLM via mail or email.
Notification of Verification 3175.92(e) and 3175.102(f)) Annual	Notification written manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
Sample Cylinder Cleaning – Documentation 43 CFR 3175.113(c)(3) Annual	Documentation written manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
Sample Separator Cleaning – Documentation 43 CFR 3175.113(d)(1) Annual	Documentation written manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
Evacuation and Pre-charge for the Helium Pop Method – Documentation 43 CFR 3175.114(a)(2) Annual	Documentation written manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
O-ring and Lubricant Composition for the Floating Piston Method - Documentation 43 CFR 3175.114(a)(3) Annual	Documentation written manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email.
Schedule for Spot Sampling 43 CFR 3175.113(b) Annual	Schedule written manually or key-entered into a computer by the operators and submitted by the operators to the BLM via mail or email
Submission of On-line Gas Chromatograph Specifications 43 CFR 3175.117(c) Annual	Manually retrieved by the operators and submitted by the operators to the BLM via mail or email.
Quantity Transaction Record – Data Collection and Submission 43 CFR 3175.104(a) Annual	Data collected automatically by the electronic gas measurement software and submitted to the BLM by the operators via mail or email.
Configuration Log – Data Collection and Submission 43 CFR 3175.104(b) Annual	Data collected automatically by the electronic gas measurement software and submitted to the BLM by the operators via mail or email.
Gas Chromatograph Verification – Documentation 43 CFR 3175.118(c) and(d) Annual	Data collected by the operators manually or via an automated system. Submitted to the BLM by the operators via mail or email.
Gas Analysis Report – Entry into Gas Analysis Reporting and Verification System 43 CFR 3175.120(f) Annual	Reports submitted to the BLM electronically using the BLM’s Gas Analysis Reporting and Verifications System (GARVS) that the BLM is developing. The GARVS will be implemented 2 years after the effective date of the final rule. Operators will be required to submit all gas analyses electronically unless a variance is granted to allow paper submission. The variance will only be granted in extreme cases where the operator demonstrates that it is a small business, as defined by the U.S. Small Business Administration, and does not have access to the Internet.

Type of Response

Collection and Submission Techniques

Transducers – Test Data Collection and Submission for Existing Makes and Models

43 CFR 3175.43 and 3175.130

One-Time

Data submitted by the manufacturer to the BLM via mail or email.

Transducers – Test Data Collection and Submission for Future Makes and Models

43 CFR 3175.4 and 3175.130

Annual