EO12866_Oil and Gas CTG 2060 ZA22 Emission Reduction and Cost of Control_20150810

Oil and Natural Gas Industry Estimated Reasonably Available Control Technology Emission Reductions and Cost of Control

1.0	INTRODUCTION

      The Clean Air Act (CAA) provides that state implementation plans (SIPs) for ozone nonattainment (NA) areas must include reasonably available control technology (RACT) for sources of emissions, and stipulates that for moderate (and higher) ozone nonattainment (NA) areas, states must revise their SIPs to include RACT for volatile organic compound (VOC) emission sources covered by control techniques guidelines (CTG). Furthermore, the CAA requires that SIPs for states in ozone transport regions (OTRs) must comply with and implement RACT with respect to all sources of VOC in the state covered by a CTG. The proposed Control Techniques Guidelines for the Oil and Natural Gas Industry, henceforth the CTG, proposes recommendations for RACT for select emission sources in the oil and natural gas industry.
      
      The proposed CTG provides state, local and tribal air agencies (air agencies) with information to assist them in determining RACT for VOC from select oil and natural gas industry emission sources. During the development of the guidelines, the U.S. Environmental Protection Agency (EPA) evaluated the sources of VOC emissions from the oil and natural gas industry and the available control approaches to reduce these emissions, including the costs of the evaluated approaches. The EPA is recommending RACT for compressors, natural gas-driven pneumatic controllers, natural gas-driven pneumatic pumps, storage vessels, equipment leaks at natural gas processing plants and fugitive emissions at well sites and compressor stations in the oil and natural gas industry. Table 1-1 presents a summary of the recommended RACT level of control for each of these sources. 
      
      Air agencies can use the recommendations in the CTG to inform their own determination as to what constitutes RACT for VOC emissions for the oil and natural gas industry sources included in the CTG. The information contained in the CTG is provided only as guidance. The CTG does not change, or substitute for, requirements specified in applicable sections of the CAA or the EPA's regulations; nor is it a regulation itself. The CTG does not impose any requirements on facilities in the oil and natural gas industry. It provides only recommendations for air agencies to consider when they determine RACT. Air agencies are free to implement other technically-sound approaches that are consistent with the CAA and the EPA's implementing regulations.
      
      To understand the potential impact of the CTG, the EPA conducted a scoping analysis based on a snapshot of the existing oil and natural gas industry. While the CTG itself does not require facilities in the oil and natural gas industry to adopt specific control technologies, assessing the emission reductions and costs of the case where recommended RACTs were adopted by oil and natural gas emission sources in moderate and higher ozone NA areas and the OTR provides a reasonable basis for the impact of the RACT requirements ultimately determined by air agencies. Therefore, this document presents an assessment of the emission reductions and net expenditures required by the industry in the case where all affected oil and natural gas emission sources that existed in 2012 adopt the recommended RACT. It is estimated that in this case VOC emissions would be reduced by approximately 82 thousand tpy at an annualized net cost to the industry of approximately $76 million dollars based on the CTG recommended RACT. Additionally, the recommended RACT is estimated to reduce methane emissions by approximately 220 thousand tpy and hazardous air pollutant (HAP) emissions by three thousand tpy. 
      
      The assessment provides a reasonable estimate of the magnitude of expected emission reductions and net costs to the source category associated with the proposed CTG; however there are limitations, including some that suggest the cost estimates may be conservative in some dimensions. For example, while the analysis attempts to include existing state regulations, the 2012 snapshot may not fully account for state permit limits for individual sources that meet or exceed the recommended RACT level of control. Thus, the percentage of existing sources that are already achieving the recommended RACT level of control may be underestimated which would lead to fewer emission reductions and lower expected costs for owners and operators as a result of the CTG. Also, air agencies have the flexibility of determining RACT that may differ from what the EPA recommends. This flexibility allows them to potentially take advantage of their local conditions and implement a tailored RACT which may lower the costs for sources in their jurisdiction. This analysis is based on industry averages and does not account for heterogeneity in sources that affect the costs or emission reductions. The resulting state and local regulations may also require a lower level of control or may affect a lower number of sources than were included in the analysis presented here. The focus on a 2012 snapshot of existing sources may include some sources that are no longer in use. However, any small changes to the existing universe of sources it is not expected to notably change the magnitude of the estimates in this analysis.
      
      The document is organized as follows: 
      
          Section 2 presents a short discussion about the moderate or higher ozone NA and OTR areas impacted by RACT. 
          Sections 3 presents a summary of the information used to determine the number of sources, baseline emissions, emission reductions and costs. 
          Section 4 presents the methodology used to estimate baseline emissions, emission reductions and costs. 
          Section 5 presents a summary of the VOC RACT emission reductions and costs. 
      
      Table 1-1. Summary of the Oil and Natural Gas Industry Emission Sources and 
                              Proposed Recommended RACT
                                          
                                Emission Source
                                 Applicability
                             RACT Recommendations
1. Storage Vessels
Individual storage vessel 
95 percent reduction of VOC emissions from storage vessels with a potential to emit (PTE) greater than or equal to 6 tpy
2. Natural Gas-Driven Pneumatic Controllers
Individual continuous bleed, natural gas-driven pneumatic controller located at a natural gas processing plant
Natural gas bleed rate of zero scfh (unless there are functional needs, including but not limited to response time, safety and positive actuation, requiring a bleed rate greater than zero scfh).

Individual continuous bleed natural gas-driven pneumatic controller located from the wellhead to the natural gas processing plant or point of custody transfer to an oil pipeline
Natural gas bleed rate less than or equal to 6 scfh (unless there are functional needs, including but not limited to response time, safety and positive actuation, requiring a bleed rate greater than 6 scfh). 
3. Natural Gas-Driven Pneumatic Pumps
Individual natural gas-driven chemical/methanol and diaphragm pump located at a natural gas processing plant
Zero natural gas emissions

Individual natural gas-driven chemical/methanol and diaphragm pump at locations other than natural gas processing plants from the well site to the point of custody transfer to the natural gas transmission and storage segment.
-If there is an existing control device at the location of the pneumatic pump, reduce VOC emissions from each gas-driven chemical/methanol and diaphragm pump at the location by 95 percent or greater. 
- If there is no existing control device at the location of the pneumatic pump, submit a certification that there is no device.
4. Compressors (Centrifugal and Reciprocating)
Individual reciprocating compressor located between the wellhead and point of custody transfer to the natural gas transmission and storage segment. 
Reduce VOC emissions by replacing reciprocating compressor rod packing after 26,000 hours of operation or 36 months since the most recent rod packing replacement. Alternatively, route rod packing emissions to a process through a closed vent system under negative pressure. 

Individual reciprocating compressor located at a well site, or an adjacent well site and servicing more than one well site 
RACT would not apply.

Individual centrifugal compressor using wet seals that is located between the wellhead and point of custody transfer to the natural gas transmission and storage segment. 
Reduce VOC emissions from each centrifugal compressor wet seal fluid gassing system by 95 percent or greater. 

Individual centrifugal compressor using wet seals located at a well site, or an adjacent well site and servicing more than one well site 
RACT would not apply.

Individual centrifugal compressor using dry seals
RACT would not apply.
5. Equipment Leaks
Equipment components in VOC service located at a natural gas processing plant
Implement the 40 CFR part 60, subpart VVa LDAR program for natural gas processing plants constructed or modified on or before August 23, 2011.
6. Fugitive Emissions
Individual well site with wells that produce, on average, greater than 15 barrel equivalents per day per well
Implement a semiannual optical gas imaging (OGI) monitoring and repair program.

Individual compressor station located from the wellhead to the point of custody transfer to the natural gas transmission and storage segment or point of custody transfer or to an oil pipeline
Implement a semiannual OGI monitoring and repair program.


2	MODERATE OR HIGHER OZONE NA AND OTR AREAS

	In order to estimate the potential moderate or higher ozone NA area and OTR area (referred to collectively as "RACT-impacted areas") emission reduction impacts for the proposed RACT recommendations, we obtained information on U.S. ozone NA areas from the EPA's Greenbook as of January 30, 2015 (http://www.epa.gov/oaqps001/greenbk/ancl.html). The list of the moderate or higher ozone NA areas included in this analysis is presented in Attachment 1 to this memorandum. The OTR areas included in this analysis are the States of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont and the CMSA that includes the District of Columbia). 

3	INFORMATION USED TO DETERMINE THE NUMBER OF SOURCES IMPACTED BY RACT, RACT-IMPACTED AREA BASELINE EMISSIONS AND EMISSION REDUCTIONS AND COSTS BASED ON RACT

      Activity data, baseline emissions and emission reductions per source were estimated based on information obtained from the following sources:
          2012 DI Desktop U.S. oil and natural gas wells information (2012 DI Desktop). Includes location and production information for oil and gas wells in the U.S. Discussed further below.
          Oil and Gas Journal (OGJ). Worldwide Gas Processing (Capacities as of January 1, 2013, and average production). June 3, 2013. (2012 Gas Processing Survey). Includes information on the number, location and capacities of gas processing plants worldwide. Discussed further below.
          Emissions information and counts for various emission sources were obtained from facility-level data submitted to the Greenhouse Gas Reporting Program (GHGRP) and data used to calculate national emissions in the Inventory of U.S. Greenhouse Gas Emissions and Sinks. The published data from 2013 was used in this analysis. For the purposes of this document these data sources are referred to as "GHGRP" and "GHG Inventory".[,]
          The proposed Control Techniques Guidelines for the Oil and Natural Gas Source Industry (CTG). Includes information on the baseline VOC emissions per unit, VOC emission reductions per unit, and VOC cost of control per unit used in this analysis.
          The TSD for the 2015 proposed NSPS standards is referred to in this document as the "2015 NSPS TSD".
          The gas composition memorandum that was developed during the NSPS process which characterizes an analysis of data to determine the gas composition and develop ratios for natural gas composition for the various segments of the oil and natural gas industry. This document is referred to in this document as the "2011 Gas Composition Memorandum".
          All of the calculations supporting the analyses in this document are included in the CTG docket (Docket ID. EPA-HQ-OAR-2015-0216) in the form of spreadsheets.
      
2012 DI Desktop Data

The EPA obtained well production data from the DI Desktop database dated February, 2014. The DI Desktop data collected by DrillingInfo, Inc. consists of oil and natural gas well information that provides parameters describing the location, operator, and production characteristics. The DI Desktop data extract from the DrillingInfo, Inc. database included the population of all wells with gas or hydrocarbon liquid production during 2010 to 2012 and with a recorded completion year of 2010 to the date of the extract (February, 2014). 

      The 2012 DI Desktop data was queried to identify oil and natural gas wells in production in 2012 in RACT-impacted areas using Federal Information Processing Standards (FIPS) codes for the respective areas. Gas wells were defined as those wells with an average gas to liquids ratio greater than or equal to 100,000 standard cubic feet per barrel over the lifetime of the well, and oil wells were defined as those wells with an average gas to liquids ratio less than 100,000 standard cubic feet per barrel over the lifetime of the well. If a well had liquids production but no gas production, it was classified as an oil well, and if a well had gas production but no liquids production, it was classified as a gas well.
       
      As a result of this analysis, for all producing wells, 101,464 oil and gas wells (63,936 oil wells and 37,528 gas wells) were identified in moderate or higher ozone NA areas and 90,232 oil and gas wells (24,169 oil wells and 66,063 gas wells) were identified in OTR areas. An estimated 22,426 oil and gas wells (1,249 oil wells and 21,177 gas wells) were located in OTR areas that were also located in moderate or higher ozone NA areas. For producing wells that produce, on average, greater than 15 barrel equivalents per day, 25,212 oil and gas wells (13,336 oil wells and 11,876 gas wells) were identified in moderate or higher ozone NA areas and 4,642 oil and gas wells (277 oil wells and 4,365 gas wells) were identified in OTR areas. An estimated 932 oil and gas wells (232 oil wells and 700 gas wells) were located in OTR areas that were also located in moderate or higher ozone nonattainment areas. States that had wells with RACT-impacted areas include California, Maryland, New York, Pennsylvania, Texas and Virginia.
      
This information was used to:
          estimate the number and location of all producing wells and individual well sites with wells that produce, on average, greater than 15 barrel equivalents per day in OTR and moderate or higher ozone NA areas (as noted), 
          estimate the number and location of storage vessels in OTR and moderate or higher ozone NA areas (assuming one storage vessel per well),
          estimate the number of production segment pneumatic controllers and pumps located in OTR and moderate or higher ozone NA areas (using the percentage of the number of wells located in each of the respective areas), and 
          estimate the number of gathering and boosting stations located in OTR and moderate or higher ozone NA areas (using the average of the percentage of wells and the percentage of total natural gas processing plants located in each respective areas).

OGJ Worldwide Gas Processing Survey (Capacities as of January 1, 2013, and Average Production)

      The OGJ Gas Processing Survey reflecting capacities as of January 1, 2013 (which would reflect capacities for 2012) was used to obtain location information of natural gas processing plants in OTR and moderate or higher ozone NA areas. Of the estimated 606 natural gas processing plants in the U.S., an estimated 10 natural gas processing plants were located in OTR areas and 40 were located in moderate or higher ozone NA areas. None of the 40 natural gas processing plants in moderate or higher ozone NA areas were located in OTR areas. States that had processing plants with RACT-impacted areas include California, Pennsylvania and Texas.
      
      This information was used to:
          estimate the number and location of natural gas processing plants in OTR and moderate or higher ozone NA areas,
          estimate the number of processing segment compressors and pneumatic controllers located in OTR and moderate or higher ozone NA areas (using the percentage of the number of gas processing plants located in OTR and moderate or higher ozone NA areas), and
          estimate the number of gathering and boosting stations located in OTR and moderate or higher ozone NA areas (using the average of the percentage of wells and the percentage of gas processing plants located in OTR and moderate or higher ozone NA areas).
4	METHODOLOGY USED TO ESTIMATE RACT-IMPACTED AREA BASELINE EMISSIONS, EMISSION REDUCTIONS AND COSTS  

	The following paragraphs present the methodologies used to estimate RACT-impacted area baseline emissions, emission reductions and costs for storage vessels, pneumatic controllers, pneumatic pumps, compressors, equipment leaks at natural gas processing plants and fugitive emissions at well sites and compressor stations.

4.1	Storage Vessels

4.1.1 	Approach	

RACT-impacted baseline emissions and emission reductions from storage vessels were calculated by multiplying the number of estimated uncontrolled storage vessels by emission factors based on oil and condensate production and production information from the 2012 DI Desktop database. Emission reductions were estimated by multiplying the emissions calculated for each storage vessel by 95 percent. The RACT-impacted area costs were estimated by multiplying the number of RACT-impacted storage vessels by costs per storage vessel. 

4.1.2 	RACT-Impacted Population of Storage Vessels

      In order to estimate the number of storage vessels that would potentially be impacted by RACT, we conducted an analysis using the following procedures:

          Estimated the number of wells in existence and located in RACT-impacted areas in 2012 (assuming one controlled storage vessel per well) based on 2012 DI Desktop location information.
          Subtracted the wells completed in 2012 from this number (assuming that these storage vessels would be subject to the NSPS).
          Subtracted the number of storage vessels subject to and presumed to be controlled at baseline under state air regulations from the number of storage vessels that would potentially be impacted by RACT,
          Used the emission factor from a typical storage vessel within each throughput bracket established under the NSPS to estimate emissions based on 2012 DI Desktop production information.
          Determined the number of storage vessels that would likely have VOC emissions greater than or equal to the RACT recommended applicability threshold of 6 tons per year (tpy).
          Estimated the number of storage vessels that would likely have VOC emissions greater than or equal to 6 tpy that would also be subject to and controlled under state air regulations.
          Using information on state environmental regulations developed for the CTG, we subtracted the number of storage vessels subject to and controlled under state air regulations from the number of storage vessels with VOC emissions greater than or equal to 6 tpy to determine the number of storage vessels that would potentially be impacted by RACT.

Attachments 2 and 3 to this memorandum include the RACT-impacted storage vessel population and baseline emissions analysis. Table 4-1 presents the estimated number of RACT-impacted storage vessels. 

            Table 4-1.  RACT-Impacted Population of Storage Vessels
                                       
                                Emission Source
                    Number of RACT-Impacted Storage Vessels
                                       
                                       
                                       
            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas
                                Storage Vessels
                                     2,451
                                      11
                                     2,462

      4.1.3	RACT-Impacted Storage Vessel Baseline Emissions, Emission Reductions and Costs

Using average storage vessel VOC emission factors based on well production rate brackets developed under the NSPS and 2012 DI Desktop production information, we calculated the RACT-impacted number of storage vessels and baseline VOC, methane and HAP emissions. RACT-impacted storage vessel emission reductions were estimated by multiplying the calculated baseline emissions per storage vessel by the 95 percent reduction efficiency attributable to combustion or capture and recovery. Using VOC to methane and VOC to HAP ratios developed for the oil and natural gas industry as presented in the 2011 Gas Composition memorandum, we estimated methane and HAP baseline emissions and emission reductions for storage vessels. Table 4-2 presents the estimated RACT-impacted storage vessel baseline emissions. RACT-impacted storage vessel emission reductions are provided in Table 4-3. 

          Table 4-2. RACT-Impacted Storage Vessel Baseline Emissions
                                Emission Source
             RACT-Impacted Storage Vessel Baseline Emissions (tpy)

            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                 Moderate or Higher Ozone NA Areas /OTR Areas

                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Storage Vessels
                                    24,515
                                     5,704
                                      769
                                      101
                                      21
                                       3
                                    24,617
                                     5,095
                                      773


        Table 4-3. RACT-Impacted Storage Vessel Emission Reductions[a]
                                Emission Source
                                Type of Control
                                       
            RACT-Impacted Storage Vessel Emission Reductions (tpy)

                                       
            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                       
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Storage Vessel
                                  95% Control
                                    23,290
                                     4,820
                                      731
                                      96
                                      20
                                       3
                                    23,386
                                     4,840
                                      734
[a] Assumes 94 percent of sources will use a combustion control device and 6 percent will use a VRU to comply with the recommended RACT.

Using the retrofit costs for a combustor or VRU developed for the CTG, we multiplied these costs by the number of RACT-impacted storage vessels, assuming 94 percent of the storage vessels would use combustion and 6 percent would use a vapor recovery unit (VRU). The capital costs and annual costs used for a combustion device was $100,986 and $22,228, respectively. The capital costs and annual costs used for a VRU used was $171,538 and $28,230, respectively. Gas savings is individual to production and emission rate class. Gas savings was estimated for storage vessels using a VRU only, assuming gas recovered would be valued at $4 per Mcf of recovered natural gas. No gas savings was attributed to storage vessels using combustion control. Attachment 2 presents the VRU and combustion cost analysis. Table 4-4 presents the estimated RACT-impacted storage vessel costs. 
                                       
                                       
                                       
                                       
                                       
                                       
                                       










                                       
                                       
                                       
                                       

                                       
                                       
                                       
                                       
                                       
                                       
                                       

                                       
               Table 4-4. RACT-Impacted Storage Vessel Costs[a]
                                Emission Point
            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
Storage Vessel
                                 $257,902,585 
                                 $55,365,741 
                                 $55,176,698 
                                  $1,157,410 
                                   $248,469 
                                   $247,688 
                                 $259,059,995 
                                 $55,614,210 
                                 $55,424,387 
[a] Assumes 94 percent of sources will use a combustion control device and 6 percent will use a VRU to comply with the recommended RACT.


4.2	Natural Gas-Driven Pneumatic Controllers

4.2.1 	Approach  
RACT-impacted natural gas-driven pneumatic controller baseline emissions and emission reductions were calculated by multiplying the number of uncontrolled natural gas-driven pneumatic controllers reported in the 2012 GHG Inventory (assuming that they were natural gas-driven) by emissions and emission reductions per controller. The RACT-impacted area costs were estimated by multiplying the calculated RACT VOC emission reductions by costs per controller.
   
4.2.2 	RACT-Impacted Population of Natural Gas-Driven Pneumatic Controllers  

Based on information in the 2012 GHG Inventory, there were an estimated 135 natural gas-driven pneumatic controllers in the processing segment nationally. The percentage of natural gas processing plants located in RACT-impacted areas based on the 2012 Gas Processing Survey was used to estimate the number of RACT-impacted natural gas-driven pneumatic controllers.

Similarly, based on information in the 2012 GHG Inventory, there were an estimated 165,372 high bleed natural gas-driven pneumatic controllers installed in the production segment nationally. The percentage of wells located in RACT-impacted areas based on 2012 DI Desktop location information was used to estimate the number of high bleed natural gas-driven pneumatic controllers located in RACT-impacted areas. 

Table 4-5 presents the estimated population of RACT-impacted natural gas-driven pneumatic controllers. 

Table 4-5.  RACT-Impacted Population of Natural Gas-Driven Pneumatic Controllers

                                    Segment
                        Number of RACT-Impacted Sources



Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas
Oil and Natural Gas Production 
                                    10,219
                                    11,666
                                    21,885
Processing Plants
                                       9
                                       2
                                      11

      4.2.3	RACT-Impacted Natural Gas-Driven Pneumatic Controller Baseline Emissions, Emission Reductions and Costs

      RACT-impacted natural gas-driven pneumatic controller baseline emissions were estimated by multiplying the population of natural gas-driven pneumatic controllers and the VOC, methane and HAP baseline emissions per natural gas-driven pneumatic controller. Using the cost and emission reductions developed for the CTG, we estimated emission reductions and costs by multiplying the number of natural gas-driven pneumatic controllers by the emission reductions and costs per natural gas-driven controller. For processing segment natural gas-driven pneumatic controllers, we used the emission reductions and costs associated with the use of an existing instrument air system. For production segment natural gas-driven pneumatic controllers, we used the emission reductions and costs associated with the replacement of an existing high bleed controller with a low bleed controller. Using methane to HAP ratios developed for the oil and natural gas industry as presented in the 2011 Gas Composition memorandum, we estimated RACT-impacted natural gas-driven pneumatic controller HAP baseline emissions and emission reductions.
      
      Tables 4-6 and 4-7 present the RACT-impacted natural gas-driven pneumatic controller baseline emissions and emission reductions. Tables 4-8 and 4-9 present the RACT-impacted natural gas-driven pneumatic controller costs. 
                                       
Table 4-6. RACT-Impacted Natural Gas-Driven Pneumatic Controller Baseline Emissions
                                    Segment
     Baseline Emissions Per Natural Gas-Driven Pneumatic Controller (tpy)
          RACT-Impacted Pneumatic Controller Baseline Emissions (tpy)


            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                 Moderate or Higher Ozone NA Areas /OTR Areas

                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Oil and Natural Gas Production 
                                      1.5
                                      5.3
                                     0.055
                                    15,057
                                    54,162
                                      567
                                    17,189
                                    61,831
                                      647
                                    32,246
                                    115,993
                                     1,214
Processing Plants
                                     0.28
                                      1.0
                                     0.01
                                      2.5
                                      8.9
                                      0.9
                                     0.62
                                      2.2
                                     0.02
                                      3.1
                                      11
                                     0.12

Table 4-7. RACT-Impacted Natural Gas-Driven Pneumatic Controller Emission Reductions
                                    Segment
                                Type of Control
                                       
              Emission Reductions Per Pneumatic Controller (tpy)
         RACT-Impacted Pneumatic Controller Emission Reductions (tpy)

                                       

            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                       
                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Oil and Natural Gas Production 
                             Replace w/ Low Bleed
                                      1.4
                                     5.10
                                     0.05
                                    14,444
                                    52,118
                                      546
                                    16,489
                                    59,498
                                      623
                                    30,933
                                    111,616
                                     1,169
Processing Plants
                        Existing Instrument Air System
                                     0.28
                                      1.0
                                     0.01
                                      2.5
                                      8.9
                                     0.09
                                     0.62
                                      2.2
                                     0.02
                                      3.1
                                      11
                                     0.12

Table 4-8. Total Annual Costs and VOC Cost of Control Per Natural Gas-Driven Pneumatic Controller
                                    Segment
                     Natural Gas Savings Per Source (Mcf)
             Total Value of Natural Gas Savings Per Source ($/yr)
                      Total Capital Costs Per Source ($)
                     Total Annual Costs Per Source ($/yr)
                  VOC Cost of Control ($/ton of VOC reduced)










                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings
Oil and Gas Production 
                                      296
                                    $1,184 
                                    $2,698 
                                     $296
                                    ($886)
                                     $210 
                                    ($627)
Processing Plants
                                      58
                                     $232 
                                    $2,000 
                                     $285 
                                     $53 
                                    $1,018 
                                     $190 
                                       
    Table 4-9. RACT-Impacted Natural Gas-Driven Pneumatic Controller Costs
                                    Segment
            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                  Capital ($)
                           Annual w/o savings ($yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
Oil and Gas Production 
                                 $27,571,450 
                                  $3,027,197 
                                 ($9,054,192)
                                 $31,475,544 
                                  $3,455,846 
                                 ($10,336,259)
                                 $59,046,994 
                                  $6,483,043 
                                 ($19,390,451)
Processing Plants
                                   $17,822 
                                    $2,540 
                                     $474 
                                    $4,455 
                                     $635 
                                     $118 
                                   $22,277 
                                    $3,175 
                                     $592 


4.3	Natural Gas-Driven Pneumatic Pumps
4.3.1 	Approach  
RACT-impacted natural gas-driven pneumatic pump baseline emissions and emission reductions were calculated by multiplying the number of uncontrolled natural gas-driven pneumatic pumps reported in the 2012 GHG Inventory (assuming they were all natural gas-driven pumps) by emissions and emission reductions per pump. The RACT-impacted natural gas-driven pneumatic pump costs were estimated by multiplying the calculated RACT VOC emission reductions by costs per pump. 

4.3.2 	RACT-Impacted Population of Natural Gas-Driven Pneumatic Pumps 
Based on information in the 2012 GHG Inventory for oil production, there were an estimated 14,408 diaphragm pumps and 14,293 piston pumps. The number of pneumatic pumps reported in the 2012 GHG Inventory for gas production was an estimated 37,477 pneumatic pumps (for both diaphragm and piston pumps). Similar to the assumption used in the 2015 NSPS TSD, we assumed that 50 percent of the gas production inventory pumps to be diaphragm pumps and 50 percent of the pumps to be piston pumps. Based on these assumptions, and assuming that all of the reported pumps were natural gas-driven, we estimated that there were 33,147 diaphragm and 33,032 piston natural gas-driven pneumatic pumps in the production segment nationally. The percentage of RACT-impacted wells based on 2012 DI Desktop location information was used to estimate the number of RACT-impacted high bleed natural gas-driven pneumatic pumps. 

The 2012 GHG Inventory did not estimate emissions from pneumatic pumps for the natural gas processing segment.

Table 4-10 presents the estimated RACT-impacted population of natural gas-driven pneumatic pumps. 

  Table 4-10.  RACT-Impacted Population of Natural Gas-Driven Pneumatic Pumps

                             Pneumatic Pump Type 
                        Number of RACT-Impacted Sources



            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas
Diaphragm  
                                     2,048
                                     2,338
                                     4,387
Piston 
                                     2,041
                                     2,330
                                     4,371
   
4.3.3	RACT-Impacted Natural Gas-Driven Pneumatic Pump Baseline Emissions, Emission Reductions and Costs 

RACT-impacted natural gas-driven pneumatic pump baseline emissions were estimated by multiplying the population of natural gas-driven pneumatic pumps and the VOC, methane and HAP baseline emissions per diaphragm and piston natural gas-driven pneumatic pump. Using the emission reductions and costs developed for the CTG, we estimated the emission reductions and costs by multiplying the number of natural gas-driven pneumatic pumps by the emission reductions and costs associated with routing emissions to an existing combustion device. Using methane to HAP ratios developed for the oil and natural gas industry as presented in the 2011 Gas Composition memorandum, we estimated RACT-impacted natural gas-driven pneumatic pump HAP baseline emissions and emission reductions. 

Tables 4-11 and 4-12 present the RACT-impacted natural gas-driven pneumatic pump baseline emissions and emission reductions. Tables 4-13 and 4-14 present the RACT-impacted natural gas-driven pneumatic pump costs. 
Table 4-11. RACT-Impacted Natural Gas-Driven Pneumatic Pump Baseline Emissions
                                Emission Source
        Baseline Emissions Per Natural Gas-Driven Pneumatic Pump (tpy)
   RACT-Impacted Natural Gas-Driven Pneumatic Pump Baseline Emissions (tpy)


               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Diaphragm
                                     0.96
                                      3.5
                                     0.04
                                     1,966
                                     7,087
                                      74
2,245
                                     8,091
                                      85
                                     4,211
                                    15,178
                                      159
Piston
                                     0.11
                                     0.38
                                     0.004
                                      225
                                      776
                                      8.1
                                      256
                                      885
                                      9.3
                                      481
                                     1,661
                                      17

Table 4-12. RACT-Impacted Natural Gas-Driven Pneumatic Pump Emission Reductions
                                Emission Source
                                Type of Control
                                       
        Emission Reductions Per Natural Gas-Drven Pneumatic Pump (tpy)
   RACT-Impacted Natural Gas-Driven Pneumatic Pump Emission Reductions (tpy)

                                       

               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                       
                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Diaphragm
                          Existing Combustion Device
                                     0.91
                                      3.3
                                     0.034
                                     1,872
                                     6,733
                                      70
                                     2,137
                                     7,686
                                      80
                                     4,008
                                    14,419
                                      151
Piston
                          Existing Combustion Device
                                     0.10
                                     0.36
                                    0.0038
                                      205
                                      737
                                      7.7
                                      234
                                      841
                                      8.8
                                      439
                                     1,578
                                      17

Table 4-13. Total Annual Costs and VOC Cost of Control Per Natural Gas-Driven Pneumatic Pump
                                Emission Source
                     Natural Gas Savings Per Source (Mcf)
             Total Value of Natural Gas Savings Per Source ($/yr)
                      Total Capital Costs Per Source ($)
                     Total Annual Costs Per Source ($/yr)
                  VOC Cost of Control ($/ton of VOC reduced)










                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings
Diaphragm
                                       0
                                      $0
                                    $2,000
                                     $285
                                     $285
                                     $312 
                                     $312 
Piston
                                       0
                                      $0
                                    $2,000 
                                     $285 
                                     $285 
                                    $2,840 
                                    $2,840 
                                       
       Table 4-14. RACT-Impacted Natural Gas-Driven Pneumatic Pump Costs
                                Emission Point
               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
Diaphragm
                                  $4,096,598 
                                   $583,765 
                                   $583,765 
                                  $4,676,673 
                                   $666,426 
                                   $666,426 
                                  $8,773,271 
                                  $1,250,191 
                                  $1,250,191 
Piston
                                  $4,082,385 
                                   $581,740 
                                   $581,740 
                                  $4,660,447 
                                   $664,114 
                                   $664,114 
                                  $8,742,833 
                                  $1,245,854 
                                  $1,245,854 

4.4	Compressors
4.4.1 	Approach  
RACT-impacted reciprocating compressor and wet seal centrifugal compressor baseline emissions and emission reductions were calculated by multiplying the number of uncontrolled compressors based on information reported in the 2012 GHG Inventory by emissions and emission reductions by compressor. The RACT-impacted reciprocating compressor and wet seal centrifugal compressor costs were estimated by multiplying the calculated RACT VOC emission reductions by costs per compressor.  

4.4.2 	RACT-Impacted Population of Reciprocating Compressors and Wet Seal Centrifugal Compressors  
Based on information in the 2012 GHG Inventory, there were an estimated 36,066 reciprocating compressors located at gathering and boosting stations. The average of the percentage of the total number of RACT-impacted natural gas processing plants based on the 2012 Gas Processing Survey and the percentage of the total number of RACT-impacted oil and natural gas wells based on 2012 DI Desktop location information was used to estimate the number of RACT-impacted reciprocating compressors located at gathering and boosting stations.

Based on information in the 2012 GHG Inventory, there were an estimated 5,624 reciprocating compressors in the processing segment. The percentage of the total number of RACT-impacted natural gas processing plants based on the 2012 Gas Processing Survey was used to estimate the number of RACT-impacted reciprocating compressors in the processing segment. 

Based on information in the 2012 GHG Inventory, there were an estimated 658 wet seal compressors in the processing segment. The percentage of the total number of RACT-impacted natural gas processing plants based on the 2012 Gas Processing Survey was used to estimate the number of RACT-impacted reciprocating compressors in the processing segment.

Table 4-15 presents the estimated population of RACT-impacted reciprocating compressors and wet seal compressors. 



                                       
Table 4-15.  RACT-Impacted Population of Reciprocating Compressors and Wet Seal Compressors

                                Emission Source
                        Number of RACT-Impacted Sources



            Moderate or Higher Ozone NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas
Reciprocating Compressors - Gathering/Boosting Stations
                                     2,305
                                     1,570
                                     3,874
Reciprocating Compressors - Processing Plants
                                      371
                                      93
                                      464
Centrifugal Compressors - Wet Seals Processing Plants
                                      43
                                      11
                                      54

4.4.3	RACT-Impacted Reciprocating Compressor and Wet Seal Centrifugal Compressor Baseline Emissions, Emission Reductions and Costs 

	RACT-impacted compressor baseline emissions were estimated by multiplying the population of compressors and the VOC, methane and HAP emissions per compressor. Using the emission reductions and costs developed for the CTG, we estimated emission reductions and costs by multiplying the number of compressors by the emission reductions and costs per compressor. For reciprocating compressors, we used the emission reductions and costs associated with replacing reciprocating compressor rod packing after 26,000 hours of operation or 36 months since the most recent rod packing replacement. For wet seal compressors, we used the emission reductions and costs associated with routing emissions to an existing combustion device. Using methane to HAP ratios developed for the oil and natural gas industry as presented in the 2011 Gas Composition memorandum, we estimated natural gas-driven pneumatic pump HAP baseline emissions and emission reductions.

Tables 4-16 and 4-17 present the RACT-impacted reciprocating compressor and wet seal compressor baseline emissions and emission reductions. Tables 4-18 and 4-19 present the RACT-impacted reciprocating compressor and wet seal compressor costs
Table 4-16. RACT-Impacted Reciprocating Compressor and Wet Seal Compressor Baseline Emissions
                                Emission Source
                    Baseline Emissions Per Compressor (tpy)
               RACT-Impacted Compressor Baseline Emissions (tpy)


               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Reciprocating Compressor  -  Gathering and Boosting Station
                                      3.4
                                      12
                                     0.13
                                     7,892
                                    28,390
                                      297
5,375
                                    19,377
                                      203
                                    13,267
                                    47,726
                                      500
Reciprocating Compressor  -  Processing
                                      6.1
                                      22
                                     0.23
                                     2,270
                                     8,176
                                      86
                                      568
                                     2,042
                                      21
                                     2,838
                                    10,209
                                      107
Wet Seal Compressor  -  Processing
                                      19
                                      211
                                      2.2
                                      830
                                     9,144
                                      96
                                      207
                                     2,286
                                      24
                                     1,037
                                    11,430
                                      120

Table 4-17. RACT-Impacted Reciprocating Compressor and Wet Seal Compressor Emission Reductions
                                Emission Source
                                Type of Control
                                       
                   Emission Reductions Per Compressor (tpy)
              RACT-Impacted Compressor Emission Reductions (tpy)

                                       

               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                       
                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Reciprocating Compressor  -  Gathering and Boosting Station
                       Replace Packing After Three Years
                                      1.9
                                      6.8
                                     0.07
                                     4,385
                                    15,774
                                      165
                                     2,986
                                    10,744
                                      113
                                     7,371
                                    26,518
                                      278
Reciprocating Compressor  -  Processing
                       Replace Packing After Three Years
                                      4.9
                                      18
                                     0.18
                                     1,814
                                     6,525
                                      68
                                      453
                                     1,631
                                      17
                                     2,267
                                     8,156
                                      85
Wet Seal Compressor  -  Processing
                95 Percent Control; Existing Combustion Device
                                      18
                                      200
                                      2.1
                                      788
                                     8,706
                                      91
                                      197
                                     2,177
                                      23
                                      985
                                    10,883
                                      114

     Table 4-18. Total Annual Costs and VOC Cost of Control Per Compressor
                                Emission Source
                     Natural Gas Savings Per Source (Mcf)
             Total Value of Natural Gas Savings Per Source ($/yr)
                      Total Capital Costs Per Source ($)
                     Total Annual Costs Per Source ($/yr)
                  VOC Cost of Control ($/ton of VOC reduced)










                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings
Reciprocating Compressor  -  Gathering and Boosting Station
                                      397
                                    $1,587 
                                    $5,650 
                                    $2,153
                                     $566 
                                    $1,132 
                                     $298 
Reciprocating Compressor  -  Processing
                                     1,019
                                    $4,074 
                                    $4,280 
                                    $1,631 
                                   ($2,443)
                                     $334 
                                    ($500)
Wet Seal Compressor  -  Processing
                                       0
                                      $0 
                                   $23,252 
                                    $3,311 
                                    $3,311 
                                     $182
                                     $182 

Table 4-19. RACT-Impacted Reciprocating Compressor and Centrifugal Compressor Costs
                                Emission Source
               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
Reciprocating Compressor  -  Gathering and Boosting Station
                                 $13,020,363 
                                  $4,961,431 
                                  $1,305,079 
                                  $8,868,297 
                                  $3,379,279 
                                   $888,902 
                                 $21,888,661 
                                  $8,340,711 
                                  $2,193,981 
Reciprocating Compressor  -  Processing
                                  $1,588,826 
                                   $605,462 
                                  ($906,997)
                                   $397,207 
                                   $151,365 
                                  ($226,749)
                                  $1,986,033 
                                   $756,827 
                                 ($1,133,746)
Wet Seal Compressor  -  Processing
                                  $1,009,889 
                                   $143,804 
                                   $143,804 
                                   $252,472 
                                   $35,951 
                                   $35,951 
                                  $1,262,361 
                                   $179,756 
                                   $179,756 

4.5.	Equipment Leaks at Natural Gas Processing Plants
4.5.1 	Approach  
RACT-impacted equipment leaks at natural gas processing plants baseline emissions and emission reductions were calculated by multiplying the number of natural gas processing plants and the baseline emissions and emission reductions per plant. The RACT-impacted equipment leaks at natural gas processing plants costs were estimated by multiplying the emission reductions by costs per natural gas processing plant. 

4.5.2 	RACT-Impacted Population of Natural Gas Processing Plants  
The number of RACT-impacted natural gas processing plants was obtained from information in the 2012 Gas Processing Survey. There were 40 natural gas processing plants located in moderate or higher ozone NA areas and 10 natural gas processing plants in OTR areas in 2012. Table 4-20 presents the estimated RACT-impacted population of natural gas processing plants. 

    Table 4-20.  RACT-Impacted Population of Natural Gas Processing Plants
                                Emission Source
                        Number of RACT-Impacted Sources



               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas
Natural Gas Processing Plants
                                      40
                                      10
                                      50

4.5.3	RACT-Impacted Equipment Leaks at Natural Gas Processing Plants Baseline Emissions, Emission Reductions and Costs 

	RACT-impacted equipment leaks at natural gas processing plants baseline VOC, methane and HAP emissions were estimated by multiplying the population of natural gas processing plants and the methane and VOC emissions per plant. The baseline assumes that existing natural gas processing plants currently implement an LDAR program equivalent to 40 CFR part 60 subpart VV. Using the emission reductions and costs developed for the CTG, we estimated emission reductions and costs by multiplying the number of natural gas processing plants by the emission reductions and costs associated with the implementation of an LDAR program equivalent to 40 CFR part 60 subpart VVa (subpart VVa). Using methane to HAP ratios developed for the oil and natural gas industry as presented in the 2011 Gas Composition memorandum, we estimated HAP baseline emissions per natural gas processing plant. 

Tables 4-21 and 4-22 present the RACT-impacted equipment leaks at natural gas processing plants baseline emissions and emission reductions. Tables 4-23 and 4-24 present the RACT-impacted equipment leaks at natural gas processing plants costs.

Table 4-21. RACT-Impacted Natural Gas Processing Plant Equipment Leaks Baseline Emissions 
                                Emission Source
          Baseline Emissions Per Natural Gas Processing Plant  (tpy)
      RACT-Impacted Natural Gas Processing Plant Baseline Emissions (tpy)


               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Natural Gas Processing Plants - Equipment Leaks
                                      35
                                      126
                                      1.3
                                     1,397
                                     5,027
                                      53
                                      349
                                     1,257
                                      13
                                     1,747
                                     6,284
                                      66

Table 4-22. RACT-Impacted Natural Gas Processing Plant Equipment Leaks Emission Reductions
                                Emission Source
                                Type of Control
                                       
          Emission Reductions Per Natural Gas Processing Plant (tpy)
     RACT-Impacted Natural Gas Processing Plant Emission Reductions (tpy)

                                       

               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                       
                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Natural Gas Processing Plants - Equipment Leaks
                                  Subpart VVa
                                      4.6
                                      16
                                     0.17
                                      182
                                      656
                                       7
                                      46
                                      164
                                       2
                                      228
                                      820
                                       9

Table 4-23. Total Annual Costs and VOC Cost of Control Per Natural Gas Processing Plant
                                Emission Source
                     Natural Gas Savings Per Source (Mcf)
             Total Value of Natural Gas Savings Per Source ($/yr)
                      Total Capital Costs Per Source ($)
                     Total Annual Costs Per Source ($/yr)
                  VOC Cost of Control ($/ton of VOC reduced)










                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings
Natural Gas Processing Plants - Equipment Leaks
                                      950
                                    $3,800 
                                    $8,499 
                                   $12,959 
                                    $9,159 
                                    $2,844 
                                    $2,010 

 Table 4-24. RACT-Impacted Natural Gas Processing Plant Equipment Leaks Costs
                                Emission Point
               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas
                                       
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
Natural Gas Processing Plants - Equipment Leaks
                                   $339,960 
                                   $518,366 
                                   $366,379 
                                   $84,990 
                                   $129,591 
                                   $91,595 
                                   $424,950 
                                   $647,957 
                                   $457,974 


4.6	Fugitive Emissions at Well Sites and Compressor Stations

4.6.1	Approach 

RACT-impacted fugitive emissions at well sites that produce, on average, greater than 15 barrel equivalents per day per well, and gathering and boosting stations baseline emissions and emission reductions were calculated by multiplying the number of well sites and gathering and boosting stations by the baseline emissions and emission reductions per site/station. The RACT-impacted well site and gathering and boosting station costs were estimated by multiplying the calculated RACT VOC emission reductions by costs per well site/gathering and boosting station. 

4.6.2 	RACT-Impacted Population of Wells Sites and Gathering and Boosting Stations  
      The DI Desktop database was used to obtain information on the number of oil and natural gas wells in 2012 in the U.S that produce, on average, greater than 15 barrel equivalents per day. The number of natural gas wells in RACT impacted areas was estimated to be 15,541. The number of oil wells in RACT-impacted areas was estimated to be 13,381. Using information developed for the 2015 NSPS TSD and CTG, we estimated the number of well sites that would be subject to RACT by dividing the number of wells by two (assuming a national average of two wells per well site). 
      
      Based on information in the 2015 NSPS TSD, we estimated that there would be 8,015 gathering and boosting stations nationally. The average of the percentage of the total RACT-impacted number of natural gas processing plants based on the 2012 Gas Processing Survey and the percentage of the total RACT-impacted number of oil and natural gas wells based on 2012 DI Desktop location information was used to estimate the number of RACT-impacted gathering and boosting stations.

      Table 4-25 presents the estimated population of RACT-impacted well sites and gathering and boosting stations.

Table 4-25.  RACT-Impacted Population of Oil and Natural Gas Well Sites and Gathering and Boosting Stations
                                       
                                Emission Source
                        Number of RACT-Impacted Sources



               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas
Natural Gas Well Sites
                                     5,588
                                     2,183
                                     7,771
Oil Well Sites
                                     6,552
                                      139
                                     6,691
Gathering and Boosting Stations
                                      512
                                      349
                                      861

4.6.3	RACT-Impacted Oil and Natural Gas Well Site and Gathering and Boosting Station 
      Fugitive Emissions, Fugitive Emission Reductions and Costs 

	RACT-impacted oil and natural gas well site and gathering and boosting station baseline fugitive emissions were estimated by multiplying the population of oil and gas well sites and gathering and boosting stations and VOC baseline emissions per site/station. Using the emission reductions and costs developed for the 2015 NSPS TSD and CTG, we estimated emission reductions and costs by multiplying the number of oil and gas well sites and gathering and boosting stations by the emission reductions and costs per well site/station. Using VOC to methane and VOC to HAP ratios developed for the oil and natural gas industry as presented in the 2011 Gas Composition Memorandum, we estimated methane and HAP baseline emissions and emission reductions. 

Tables 4-26 and 4-27 present the RACT-impacted oil and natural gas well site and gathering and boosting station baseline fugitive emissions and fugitive emission reductions. Tables 4-28 and 4-29 present the RACT-impacted oil and gas well site and gathering and boosting station costs.

Table 4-26. RACT-Impacted Oil and Natural Gas Well Site and Gathering and Boosting Station Baseline Fugitive Emissions 
                                Emission Source
          Baseline Emissions Per Natural Gas Processing Plant  (tpy)
RACT-Impacted Oil and Gas Well Site and Gathering and Boosting Station Baseline Fugitive Emissions (tpy)


               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Natural Gas Well Sites
                                      1.3
                                      4.5
                                     0.05
                                     7,051
                                    25,365
                                      266
                                     2,754
                                     9,907
                                      104
                                     9,805
                                    35,272
                                      369
Oil Well Sites
                                     0.30
                                      1.1
                                     0.01
                                     1,981
                                     7,125
                                      75
                                      42
                                      151
                                       2
                                     2,203
                                     7,276
                                      76
Gathering and Boosting Stations
                                      9.8
                                      35
                                     0.37
                                     5,003
                                    17,999
                                      188
                                     3,408
                                    12,259
                                      128
                                     8,411
                                    30,258
                                      317

Table 4-27. RACT-Impacted Oil and Natural Gas Well Site and Gathering and Boosting Station Fugitive Emission Reductions
                                Emission Source
                                Type of Control
                                       
          Emission Reductions Per Natural Gas Processing Plant (tpy)
RACT-Impacted Oil and Gas Well Site and Gathering and Boosting Station Fugitive Emission Reductions (tpy)

                                       

               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                       
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Natural Gas Well Sites
                                Semiannual OGI
                                     0.76
                                      2.7
                                     0.03
                                     4,231
                                    15,219
                                      159
                                     1,652
                                     5,944
                                      62
                                     5,883
                                    21,163
                                      222
Oil Well Sites
                                Semiannual OGI
                                     0.18
                                     0.65
                                     0.01
                                     1,188
                                     4,275
                                      45
                                      25
                                      90
                                       1
                                     1,214
                                     4,366
                                      46
Gathering and Boosting Stations
                                Semiannual OGI
                                      5.9
                                      21
                                     0.22
                                     3,002
                                    10,799
                                      113
                                     2,045
                                     7,356
                                      77
                                     5,047
                                    18,155
                                      190

 Table 4-28. Total Annual Costs and VOC Cost of Control Per Well Site/Station
                                Emission Source
                     Natural Gas Savings Per Source (Mcf)
             Total Value of Natural Gas Savings Per Source ($/yr)
                      Total Capital Costs Per Source ($)
                     Total Annual Costs Per Source ($/yr)
                  VOC Cost of Control ($/ton of VOC reduced)










                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings
Natural Gas Well Sites
                                      158
                                     $631 
                                     $801 
                                    $2,230 
                                    $1,599 
                                    $2,945 
                                    $2,111 
Oil Well Sites
                                      38
                                     $151 
                                     $801 
                                    $2,230 
                                    $2,079 
                                   $12,294 
                                   $11,460 
Gathering and Boosting Stations
                                     1,222
                                    $4,888 
                                   $10,993 
                                   $15,881 
                                   $10,993 
                                    $2,710 
                                    $1,876 

Table 4-29. RACT-Impacted Oil and Natural Gas Well Site and Gathering and Boosting Station Fugitive Emission Costs
                                Emission Point
               Moderate or Higher NA Areas Outside of OTR Areas
                                   OTR Areas
                  Moderate or Higher Ozone NA Areas/OTR Areas

                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
Natural Gas Well Sites
                                  $4,475,582 
                                 $12,460,517 
                                  $8,932,579 
                                  $1,748,024 
                                  $4,866,693 
                                  $3,488,789 
                                  $6,223,605 
                                 $17,327,210 
                                 $12,421,368 
Oil Well Sites
                                  $5,247,675 
                                 $14,610,112 
                                 $13,619,076 
                                   $110,928 
                                   $308,837 
                                   $287,888 
                                  $5,358,604 
                                 $14,918,949 
                                 $13,906,964 
Gathering and Boosting Stations
                                  $5,630,384 
                                  $8,133,758 
                                  $5,630,384 
                                  $3,834,910 
                                  $5,539,982 
                                  $3,834,910 
                                  $9,465,294 
                                 $13,673,740 
                                  $9,465,294 


5	SUMMARY OF THE VOC RACT EMISSION REDUCTIONS AND COSTS

	Table 5-1 presents a summary of the VOC RACT emission reductions and costs for storage vessels, natural gas-driven pneumatic controllers, natural gas-driven pneumatic pumps, reciprocating compressors, wet seal centrifugal compressors, natural gas processing plant equipment leaks, and fugitive emissions at well sites and gathering and boosting stations.  





Table 5-1. Summary of the Oil and Natural Gas Industry VOC RACT Emission Reductions and Costs
                                       
                                       



                                       



                                       

                                       
                                       
                                 ATTACHMENT 1
                                       
                       Moderate or Higher Ozone NA Areas

                       Moderate or Higher Ozone NA Areas
                                       
                                     State
                                  County Name
                                 NA Area Name
CA
Amador County
Amador and Calaveras Cos. (Central Mountain Cos.)
CA
Calaveras County
Amador and Calaveras Cos. (Central Mountain Cos.)
CA
El Dorado County
Sacramento Metro
CA
Fresno County
San Joaquin Valley
CA
Imperial County
Imperial County Area
CA
Kern County
Kern County (Eastern Kern)
CA
Kings County
San Joaquin Valley
CA
Los Angeles County
Los Angeles and San Bernardino Counties (Western Mojave Desert)
CA
Madera County
San Joaquin Valley
CA
Mariposa County
Mariposa and Tuolumne Cos. (Southern Mountain Counties)
CA
Merced County
San Joaquin Valley
CA
Nevada County
Nevada County (Western part)
CA
Orange County
Los Angeles-South Coast Air Basin
CA
Placer County
Sacramento Metro
CA
Riverside County
Los Angeles-South Coast Air Basin
CA
Sacramento County
Sacramento Metro
CA
San Bernardino County
Los Angeles and San Bernardino Counties (Western Mojave Desert)



CA
San Joaquin County
San Joaquin Valley
CA
Solano County
Sacramento Metro
CA
Stanislaus County
San Joaquin Valley
CA
Sutter County
Sacramento Metro
CA
Tulare County
San Joaquin Valley
CA
Tuolumne County
Mariposa and Tuolumne Cos. (Southern Mountain Counties)
CA
Ventura County
Ventura County
CA
Yolo County
Sacramento Metro
CT
Fairfield County
New York-N. New Jersey-Long Island Area
CT
Hartford County
Greater Connecticut Area
CT
Litchfield County
Greater Connecticut Area
CT
Middlesex County
New York-N. New Jersey-Long Island Area
CT
New Haven County
New York-N. New Jersey-Long Island Area
CT
New London County
Greater Connecticut Area
CT
Tolland County
Greater Connecticut Area
CT
Windham County
Greater Connecticut Area
DE
Kent County
Philadelphia-Wilmington-Atlantic City Area
DE
New Castle County
Philadelphia-Wilmington-Atlantic City Area
DE
Sussex County
Philadelphia-Wilmington-Atlantic City Area
DC
District of Columbia
Washington Area
MD
Anne Arundel County
Baltimore
MD
Baltimore County
Baltimore
MD
Calvert County
Washington Area
MD
Carroll County
Baltimore
MD
Cecil County
Philadelphia-Wilmington-Atlantic City Area
MD
Charles County
Washington Area
MD
Frederick County
Washington Area
MD
Harford County
Baltimore
MD
Howard County
Baltimore
MD
Montgomery County
Washington Area
MD
Prince George's County
Washington Area
MD
Baltimore city
Baltimore
MA
Barnstable County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Berkshire County
Springfield (W. Mass) Area
MA
Bristol County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Dukes County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Essex County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Franklin County
Springfield (W. Mass) Area
MA
Hampden County
Springfield (W. Mass) Area
MA
Hampshire County
Springfield (W. Mass) Area
MA
Middlesex County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Nantucket County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Norfolk County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Plymouth County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Suffolk County
Boston-Lawrence-Worcester (E. Mass) Area
MA
Worcester County
Boston-Lawrence-Worcester (E. Mass) Area















NJ
Atlantic County
Philadelphia-Wilmington-Atlantic City Area
NJ
Bergen County
New York-N. New Jersey-Long Island Area
NJ
Burlington County
Philadelphia-Wilmington-Atlantic City Area
NJ
Camden County
Philadelphia-Wilmington-Atlantic City Area
NJ
Cape May County
Philadelphia-Wilmington-Atlantic City Area
NJ
Cumberland County
Philadelphia-Wilmington-Atlantic City Area
NJ
Essex County
New York-N. New Jersey-Long Island Area
NJ
Gloucester County
Philadelphia-Wilmington-Atlantic City Area
NJ
Hudson County
New York-N. New Jersey-Long Island Area
NJ
Hunterdon County
New York-N. New Jersey-Long Island Area
NJ
Mercer County
Philadelphia-Wilmington-Atlantic City Area
NJ
Middlesex County
New York-N. New Jersey-Long Island Area
NJ
Monmouth County
New York-N. New Jersey-Long Island Area
NJ
Morris County
New York-N. New Jersey-Long Island Area
NJ
Ocean County
Philadelphia-Wilmington-Atlantic City Area
NJ
Passaic County
New York-N. New Jersey-Long Island Area
NJ
Salem County
Philadelphia-Wilmington-Atlantic City Area
NJ
Somerset County
New York-N. New Jersey-Long Island Area
NJ
Sussex County
New York-N. New Jersey-Long Island Area
NJ
Union County
New York-N. New Jersey-Long Island Area
NJ
Warren County
New York-N. New Jersey-Long Island Area
NY
Bronx County
New York-N. New Jersey-Long Island Area
NY
Chautauqua County
Jamestown
NY
Dutchess County
Poughkeepsie Area
NY
Erie County
Buffalo-Niagara Falls
NY
Jefferson County
Jefferson County Area
NY
Kings County
New York-N. New Jersey-Long Island Area
NY
Nassau County
New York-N. New Jersey-Long Island Area
NY
New York County
New York-N. New Jersey-Long Island Area
NY
Niagara County
Buffalo-Niagara Falls
NY
Orange County
Poughkeepsie Area
NY
Putnam County
Poughkeepsie Area
NY
Queens County
New York-N. New Jersey-Long Island Area
NY
Richmond County
New York-N. New Jersey-Long Island Area
NY
Rockland County
New York-N. New Jersey-Long Island Area
NY
Suffolk County
New York-N. New Jersey-Long Island Area
NY
Westchester County
New York-N. New Jersey-Long Island Area
PA
Allegheny County
Pittsburgh-Beaver Valley
PA
Armstrong County
Pittsburgh-Beaver Valley
PA
Beaver County
Pittsburgh-Beaver Valley
PA
Bucks County
Philadelphia-Wilmington-Atlantic City Area
PA
Butler County
Pittsburgh-Beaver Valley
PA
Chester County
Philadelphia-Wilmington-Atlantic City Area
PA
Delaware County
Philadelphia-Wilmington-Atlantic City Area
PA
Fayette County
Pittsburgh-Beaver Valley
PA
Montgomery County
Philadelphia-Wilmington-Atlantic City Area
PA
Philadelphia County
Philadelphia-Wilmington-Atlantic City Area
PA
Washington County
Pittsburgh-Beaver Valley
PA
Westmoreland County
Pittsburgh-Beaver Valley
RI
Bristol County
Providence (all of RI) Area
RI
Kent County
Providence (all of RI) Area
RI
Newport County
Providence (all of RI) Area
RI
Providence County
Providence (all of RI) Area
RI
Washington County
Providence (all of RI) Area
TX
Brazoria County
Houston-Galveston-Brazoria Area
TX
Chambers County
Houston-Galveston-Brazoria Area
TX
Collin County
Dallas-Fort Worth
TX
Dallas County
Dallas-Fort Worth
TX
Denton County
Dallas-Fort Worth
TX
Ellis County
Dallas-Fort Worth
TX
Fort Bend County
Houston-Galveston-Brazoria Area
TX
Harris County
Houston-Galveston-Brazoria Area
TX
Johnson County
Dallas-Fort Worth
TX
Kaufman County
Dallas-Fort Worth
TX
Liberty County
Houston-Galveston-Brazoria Area
TX
Montgomery County
Houston-Galveston-Brazoria Area
TX
Parker County
Dallas-Fort Worth
TX
Rockwall County
Dallas-Fort Worth
TX
Tarrant County
Dallas-Fort Worth
TX
Waller County
Houston-Galveston-Brazoria Area
TX
Wise County
Dallas-Fort Worth
VA
Arlington County
Washington Area
VA
Fairfax County
Washington Area
VA
Loudoun County
Washington Area
VA
Prince William County
Washington Area
VA
Alexandria city
Washington Area
VA
Fairfax city
Washington Area
VA
Falls Church city
Washington Area
VA
Manassas city
Washington Area
VA
Manassas Park city
Washington Area
WI
Sheboygan County
Sheboygan Area


                                       

                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                 ATTACHMENT 2
                                       
ONG CTG  -  RACT-Impacted Population of Storage Vessels and RACT-Impacted Storage Vessel Baseline Emissions, Emission Reductions and Costs 





















                  Well Productivity Bracket (bbls/day range)
                           Representative (bbls/day)
               Number of RACT-Impacted Storage Vessels  -  2012
                Number of Storage Vessels Not Impacted by RACT












                                    >0-1
                                     0.385
                                       0
                                    34,577
                                      1-2
                                     1.34
                                       0
                                     8,727
                                      2-4
                                     2.66
                                       0
                                    10,589
                                      4-6
                                     4.45
                                       0
                                     6,174
                                      6-8
                                     6.22
                                       0
                                     4,228
                                     8-10
                                     8.08
                                       0
                                     3,361
                                     10-12
                                     9.83
                                       0
                                     2,592
                                     12-15
                                     12.1
                                       0
                                     2,880
                                     15-20
                                     15.4
                                       0
                                     3,177
                                     20-25
                                     19.9
                                       0
                                     2,017
                                     25-30
                                     24.3
                                       0
                                     1,306
                                     30-40
                                     30.5
                                     1,086
                                      423
                                     40-50
                                     39.2
                                      505
                                      197
                                    50-100
                                     61.6
                                      755
                                      279
                                    100-200
                                      120
                                      104
                                      64
                                    200-400
                                      238
                                      13
                                      21
                                    400-800
                                      456
                                       0
                                       2
                                   800-1600
                                      914
                                       0
                                       0
                                   1600-3200
                                     1,692
                                       0
                                       1
                                   3200-6400
                                     3,353
                                       0
                                       0
                                  6400-12800
                                     6,825
                                       0
                                       0
                                     TOTAL
 
                                     2,462
                                    80,616
                                       







Table A2-1.  Number of RACT-Impacted Oil Storage Vessels 
Total A2-2.  Number of RACT-Impacted Condensate Storage Vessels

                  Well Productivity Bracket (bbls/day range)
                           Representative (bbls/day)
                           CTG Covered Vessels 2012
                  Total Number of Vessels Not Covered by RACT












                                    >0-1
                                      635
                                       0
                                    80,133
                                      1-2
                                      349
                                       0
                                      257
                                      2-4
                                      648
                                       0
                                      127
                                      4-6
                                      766
                                       0
                                      48
                                      6-8
                                      640
                                       0
                                      10
                                     8-10
                                      525
                                       0
                                      12
                                     10-12
                                      408
                                       0
                                       9
                                     12-15
                                      564
                                       0
                                       7
                                     15-20
                                      758
                                       0
                                       5
                                     20-25
                                      674
                                       0
                                       2
                                     25-30
                                      531
                                       0
                                       0
                                     30-40
                                      927
                                       0
                                       1
                                     40-50
                                      747
                                       0
                                       0
                                    50-100
                                     2,691
                                       0
                                       0
                                    100-200
                                     3,800
                                       0
                                       0
                                    200-400
                                     2,705
                                       0
                                       0
                                    400-800
                                     1,165
                                       0
                                       0
                                   800-1600
                                      348
                                       0
                                       0
                                   1600-3200
                                      69
                                       0
                                       0
                                   3200-6400
                                      37
                                       0
                                       0
                                  6400-12800
                                       5
                                      0 
                                       0
                                   >12800
                                       0
                                       0
                                       0
                                     TOTAL
 
                                       0
                                    80,611

Table A2-3.  RACT-Impacted Oil Storage Vessel Baseline Emissions

                                       
                  Well Productivity Bracket (bbls/day range)
                           Representative (bbls/day)
                Average Baseline Emissions per Unit (tpy/unit)
                      Nationwide Baseline Emissions 2012










                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                    Methane
                                      HAP
                                    >0-1
                                     0.385
                                     0.083
                                     0.017
                                     0.003
                                       0
                                       0
                                     0.000
                                      1-2
                                     1.34
                                     0.287
                                     0.059
                                     0.009
                                       0
                                       0
                                     0.000
                                      2-4
                                     2.66
                                     0.570
                                     0.118
                                     0.018
                                       0
                                       0
                                     0.000
                                      4-6
                                     4.45
                                     0.953
                                     0.197
                                     0.030
                                       0
                                       0
                                     0.000
                                      6-8
                                     6.22
                                     1.33
                                     0.28
                                     0.04
                                       0
                                       0
                                     0.000
                                     8-10
                                     8.08
                                     1.73
                                     0.36
                                     0.05
                                       0
                                       0
                                     0.000
                                     10-12
                                     9.83
                                     2.11
                                     0.44
                                     0.07
                                       0
                                       0
                                     0.000
                                     12-15
                                     12.1
                                     2.59
                                     0.54
                                     0.08
                                       0
                                       0
                                     0.000
                                     15-20
                                     15.4
                                     3.31
                                     0.68
                                     0.10
                                       0
                                       0
                                     0.000
                                     20-25
                                     19.9
                                     4.27
                                     0.88
                                     0.13
                                       0
                                       0
                                     0.000
                                     25-30
                                     24.3
                                     5.22
                                     1.08
                                     0.16
                                       0
                                       0
                                     0.000
                                     30-40
                                     30.5
                                     6.54
                                     1.35
                                     0.21
                                     6,749
                                     1,397
                                      212
                                     40-50
                                     39.2
                                     8.41
                                     1.74
                                     0.26
                                     4,033
                                      835
                                      127
                                    50-100
                                     61.6
                                     13.2
                                      2.7
                                      0.4
                                     9,470
                                     1,960
                                      297
                                    100-200
                                      120
                                     25.6
                                      5.3
                                      0.8
                                     2,524
                                      522
                                      79
                                    200-400
                                      238
                                     51.0
                                     10.6
                                      1.6
                                      611
                                      126
                                      19
                                    400-800
                                      456
                                     97.7
                                     20.2
                                      3.1
                                       0
                                       0
                                     0.000
                                   800-1600
                                      914
                                     196.0
                                     40.6
                                      6.2
                                       0
                                       0
                                     0.000
                                   1600-3200
                                     1,692
                                     362.9
                                     75.1
                                     11.4
                                       0
                                       0
                                     0.000
                                   3200-6400
                                     3,353
                                     719.1
                                     148.8
                                     22.6
                                       0
                                       0
                                     0.000
                                  6400-12800
                                     6,825
                                    1463.7
                                     302.9
                                     45.9
                                       0
                                       0
                                     0.000
                                     TOTAL
 
 
 
 
                                    23,386
                                     4,840
                                      734
                                       





                                       
                                       
                                       





                                       
                                       

Table A2-4.  RACT-Impacted Condensate Storage Vessel Baseline Emissions
                                       
                                       
                          Well Productivity Bracket 
                               (bbls/day range)
                                Representative 
                                  (bbls/day)
                Average Baseline Emissions per Unit (tpy/unit)
Nationwide Baseline Emissions 2012


                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                    Methane
                                      HAP
                                    >0-1
                                      635
                                     0.038
                                     0.008
                                     0.001
                                       0
                                       0
                                       0
                                      1-2
                                      349
                                     0.168
                                     0.037
                                     0.005
                                       0
                                       0
                                       0
                                      2-4
                                      648
                                     0.318
                                     0.070
                                     0.009
                                       0
                                       0
                                       0
                                      4-6
                                      766
                                     0.573
                                     0.126
                                     0.017
                                       0
                                       0
                                       0
                                      6-8
                                      640
                                     0.82
                                     0.18
                                     0.02
                                       0
                                       0
                                       0
                                     8-10
                                      525
                                     1.04
                                     0.23
                                     0.03
                                       0
                                       0
                                       0
                                     10-12
                                      408
                                     1.37
                                     0.30
                                     0.04
                                       0
                                       0
                                       0
                                     12-15
                                      564
                                     1.53
                                     0.34
                                     0.04
                                       0
                                       0
                                       0
                                     15-20
                                      758
                                     2.10
                                     0.46
                                     0.06
                                       0
                                       0
                                       0
                                     20-25
                                      674
                                     3.32
                                     0.73
                                     0.10
                                       0
                                       0
                                       0
                                     25-30
                                      531
                                     3.85
                                     0.85
                                     0.11
                                       0
                                       0
                                       0
                                     30-40
                                      927
                                     5.33
                                     1.17
                                     0.16
                                       0
                                       0
                                       0
                                     40-50
                                      747
                                     7.59
                                     1.67
                                     0.22
                                       0
                                       0
                                       0
                                    50-100
                                     2,691
                                     11.7
                                      2.6
                                      0.3
                                       0
                                       0
                                       0
                                    100-200
                                     3,800
                                     25.4
                                      5.6
                                      0.7
                                       0
                                       0
                                       0
                                    200-400
                                     2,705
                                     49.8
                                     11.0
                                      1.5
                                       0
                                       0
                                       0
                                    400-800
                                     1,165
                                     92.3
                                     20.3
                                      2.7
                                       0
                                       0
                                       0
                                   800-1600
                                      348
                                     142.2
                                     31.3
                                      4.2
                                       0
                                       0
                                       0
                                   1600-3200
                                      69
                                     310.7
                                     68.5
                                      9.1
                                       0
                                       0
                                       0
                                   3200-6400
                                      37
                                     489.9
                                     107.9
                                     14.4
                                       0
                                       0
                                       0
                                  6400-12800
                                       5
                                    1864.4
                                     410.8
                                     54.7
                                       0
                                       0
                                       0
                                   >12800
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0

Table A2-5.  RACT-Impacted Oil Storage Vessel Emission Reductions

                          Well Productivity Bracket 
                               (bbls/day range)
                           Representative (bbls/day)
       Average Emission Reductions Per Unit (tpy) Assuming 95% Reduction
                     Nationwide Emissions Reductions 2012
                         Natural Gas Saved Mcf/yr/unit
                        Total Natural Gas Saved Mcf/yr


                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                    Methane
                                      HAP


                                    >0-1
                                     0.385
                                     0.078
                                     0.016
                                     0.002
                                       0
                                       0
                                     0.000
                                      2.7
                                       0
                                      1-2
                                     1.34
                                     0.272
                                     0.056
                                     0.009
                                       0
                                       0
                                     0.000
                                      9.2
                                       0
                                      2-4
                                     2.66
                                     0.542
                                     0.112
                                     0.017
                                       0
                                       0
                                     0.000
                                     18.3
                                       0
                                      4-6
                                     4.45
                                     0.906
                                     0.187
                                     0.028
                                       0
                                       0
                                     0.000
                                     30.6
                                       0
                                      6-8
                                     6.22
                                     1.27
                                     0.26
                                     0.04
                                       0
                                       0
                                     0.000
                                     42.9
                                       0
                                     8-10
                                     8.08
                                     1.65
                                     0.34
                                     0.05
                                       0
                                       0
                                     0.000
                                     55.7
                                       0
                                     10-12
                                     9.83
                                     2.00
                                     0.41
                                     0.06
                                       0
                                       0
                                     0.000
                                     67.8
                                       0
                                     12-15
                                     12.1
                                     2.46
                                     0.51
                                     0.08
                                       0
                                       0
                                     0.000
                                     83.2
                                       0
                                     15-20
                                     15.4
                                     3.14
                                     0.65
                                     0.10
                                       0
                                       0
                                     0.000
                                     106.3
                                       0
                                     20-25
                                     19.9
                                     4.05
                                     0.84
                                     0.13
                                       0
                                       0
                                     0.000
                                     137.1
                                       0
                                     25-30
                                     24.3
                                     4.96
                                     1.03
                                     0.16
                                       0
                                       0
                                     0.000
                                     167.7
                                       0
                                     30-40
                                     30.5
                                     6.21
                                     1.29
                                     0.20
                                     6755
                                     1398
                                      212
                                     210.1
                                     22847
                                     40-50
                                     39.2
                                     7.99
                                     1.65
                                     0.25
                                     4033
                                      835
                                      127
                                     270.3
                                     13638
                                    50-100
                                     61.6
                                     12.5
                                      2.6
                                      0.4
                                     9470
                                     1960
                                      297
                                     424.2
                                     32028
                                    100-200
                                      120
                                     24.4
                                      5.0
                                      0.8
                                     2524
                                      522
                                      79
                                     823.9
                                     8536
                                    200-400
                                      238
                                     48.5
                                     10.0
                                      1.5
                                      611
                                      126
                                      19
                                    1638.9
                                     2065
                                    400-800
                                      456
                                     92.8
                                     19.2
                                      2.9
                                       0
                                       0
                                     0.000
                                    3139.0
                                       0
                                   800-1600
                                      914
                                     186.2
                                     38.5
                                      5.8
                                       0
                                       0
                                     0.000
                                    6297.8
                                       0
                                   1600-3200
                                     1,692
                                     344.8
                                     71.4
                                     10.8
                                       0
                                       0
                                     0.000
                                    11660.3
                                       0
                                   3200-6400
                                     3,353
                                     683.2
                                     141.4
                                     21.4
                                       0
                                       0
                                     0.000
                                    23105.8
                                       0
                                  6400-12800
                                     6,825
                                    1390.5
                                     287.8
                                     43.6
                                       0
                                       0
                                     0.000
                                    47028.1
                                       0
                                     TOTAL
 
 
 
 
                                    23,392
                                     4,842
                                      734
                                       
                                    79,114

Table A2-6.  RACT-Impacted Condensate Storage Vessel Emission Reductions

                  Well Productivity Bracket (bbls/day range)
                           Representative (bbls/day)
       Average Emission Reductions Per Unit (tpy) assuming 95% reduction
                     Nationwide Emissions Reductions 2012
                                       




                         Natural Gas Saved Mcf/yr/unit
                        Total Natural Gas Saved Mcf/yr








                                      VOC
                                    Methane
                                      HAP
                                      VOC
                                    Methane
                                      HAP


                                    >0-1
                                      635
                                     0.036
                                     0.008
                                     0.001
                                       0
                                       0
                                       0
                                     1.151
                                       0
                                      1-2
                                      349
                                     0.159
                                     0.035
                                     0.005
                                       0
                                       0
                                       0
                                     5.051
                                       0
                                      2-4
                                      648
                                     0.302
                                     0.067
                                     0.009
                                       0
                                       0
                                       0
                                     9.558
                                       0
                                      4-6
                                      766
                                     0.545
                                     0.120
                                     0.016
                                       0
                                       0
                                       0
                                    17.252
                                       0
                                      6-8
                                      640
                                     0.78
                                     0.17
                                     0.02
                                       0
                                       0
                                       0
                                    24.818
                                       0
                                     8-10
                                      525
                                     0.99
                                     0.22
                                     0.03
                                       0
                                       0
                                       0
                                    31.423
                                       0
                                     10-12
                                      408
                                     1.30
                                     0.29
                                     0.04
                                       0
                                       0
                                       0
                                     41.27
                                       0
                                     12-15
                                      564
                                     1.46
                                     0.32
                                     0.04
                                       0
                                       0
                                       0
                                     46.16
                                       0
                                     15-20
                                      758
                                     1.99
                                     0.44
                                     0.06
                                       0
                                       0
                                       0
                                     63.11
                                       0
                                     20-25
                                      674
                                     3.15
                                     0.70
                                     0.09
                                       0
                                       0
                                       0
                                     99.91
                                       0
                                     25-30
                                      531
                                     3.65
                                     0.81
                                     0.11
                                       0
                                       0
                                       0
                                    115.68
                                       0
                                     30-40
                                      927
                                     5.07
                                     1.12
                                     0.15
                                       0
                                       0
                                       0
                                     160.4
                                       0
                                     40-50
                                      747
                                     7.21
                                     1.59
                                     0.21
                                       0
                                       0
                                       0
                                     228.4
                                       0
                                    50-100
                                     2,691
                                     11.1
                                      2.5
                                      0.3
                                       0
                                       0
                                       0
                                     352.6
                                       0
                                    100-200
                                     3,800
                                     24.1
                                      5.3
                                      0.7
                                       0
                                       0
                                       0
                                      763
                                       0
                                    200-400
                                     2,705
                                     47.3
                                     10.4
                                      1.4
                                       0
                                       0
                                       0
                                     1498
                                       0
                                    400-800
                                     1,165
                                     87.7
                                     19.3
                                      2.6
                                       0
                                       0
                                       0
                                     2777
                                       0
                                   800-1600
                                      348
                                     135.1
                                     29.8
                                      4.0
                                       0
                                       0
                                       0
                                     4277
                                       0
                                   1600-3200
                                      69
                                     295.1
                                     65.0
                                      8.7
                                       0
                                       0
                                       0
                                     9346
                                       0
                                   3200-6400
                                      37
                                     465.4
                                     102.5
                                     13.6
                                       0
                                       0
                                       0
                                     14737
                                       0
                                  6400-12800
                                       5
                                    1771.2
                                     390.3
                                     51.9
                                       0
                                       0
                                       0
                                     56086
                                       0
                                   >12800
                                       0
                                      0.0
                                      0.0
                                      0.0
                                       0
                                       0
                                       0
                                     0.000
                                       0

Table A2-7.  RACT-Impacted Oil Storage Vessel VRU and Combustor Costs

                          Well Productivity Bracket 
                               (bbls/day range)
                           Route Emissions to a VRU
                        Route Emissions to a Combustor
                                       
                        Total Capital Cost Per Unit ($)
                       Total Annual Cost Per Unit ($/yr)
                   VOC Cost of Control              ($/ton)
                        Total Capital Cost Per Unit ($)
                       Total Annual Cost Per Unit ($/yr)
                    VOC Cost of Control             ($/ton)


                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings

                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings
                                    >0-1
                                   $171,538
                                    $28,230
                                    $28,219
                                   $359,638
                                   $359,503
                                   $100,986
                                    $22,228
                                    $22,228
                                   $283,175
                                   $283,175
                                      1-2
                                   $171,538
                                    $28,230
                                    $28,193
                                   $103,714
                                   $103,579
                                   $100,986
                                    $22,228
                                    $22,228
                                    $81,663
                                    $81,663
                                      2-4
                                   $171,538
                                    $28,230
                                    $28,157
                                    $52,104
                                    $51,969
                                   $100,986
                                    $22,228
                                    $22,228
                                    $41,026
                                    $41,026
                                      4-6
                                   $171,538
                                    $28,230
                                    $28,107
                                    $31,170
                                    $31,035
                                   $100,986
                                    $22,228
                                    $22,228
                                    $24,543
                                    $24,543
                                      6-8
                                   $171,538
                                    $28,230
                                    $28,058
                                    $22,261
                                    $22,126
                                   $100,986
                                    $22,228
                                    $22,228
                                    $17,528
                                    $17,528
                                     8-10
                                   $171,538
                                    $28,230
                                    $28,007
                                    $17,144
                                    $17,009
                                   $100,986
                                    $22,228
                                    $22,228
                                    $13,499
                                    $13,499
                                     10-12
                                   $171,538
                                    $28,230
                                    $27,959
                                    $14,092
                                    $13,957
                                   $100,986
                                    $22,228
                                    $22,228
                                    $11,096
                                    $11,096
                                     12-15
                                   $171,538
                                    $28,230
                                    $27,897
                                    $11,478
                                    $11,342
                                   $100,986
                                    $22,228
                                    $22,228
                                    $9,037
                                    $9,037
                                     15-20
                                   $171,538
                                    $28,230
                                    $27,805
                                    $8,986
                                    $8,851
                                   $100,986
                                    $22,228
                                    $22,228
                                    $7,075
                                    $7,075
                                     20-25
                                   $171,538
                                    $28,230
                                    $27,682
                                    $6,963
                                    $6,828
                                   $100,986
                                    $22,228
                                    $22,228
                                    $5,483
                                    $5,483
                                     25-30
                                   $171,538
                                    $28,230
                                    $27,559
                                    $5,692
                                    $5,557
                                   $100,986
                                    $22,228
                                    $22,228
                                    $4,482
                                    $4,482
                                     30-40
                                   $171,538
                                    $28,230
                                    $27,390
                                    $4,544
                                    $4,409
                                   $100,986
                                    $22,228
                                    $22,228
                                    $3,578
                                    $3,578
                                     40-50
                                   $171,538
                                    $28,230
                                    $27,149
                                    $3,532
                                    $3,397
                                   $100,986
                                    $22,228
                                    $22,228
                                    $2,781
                                    $2,781
                                    50-100
                                   $171,538
                                    $28,230
                                    $26,533
                                    $2,251
                                    $2,115
                                   $100,986
                                    $22,228
                                    $22,228
                                    $1,772
                                    $1,772
                                    100-200
                                   $171,538
                                    $28,230
                                    $24,934
                                    $1,159
                                    $1,024
                                   $100,986
                                    $22,228
                                    $22,228
                                     $912
                                     $912
                                    200-400
                                   $171,538
                                    $28,230
                                    $21,675
                                     $583
                                     $447
                                   $100,986
                                    $22,228
                                    $22,228
                                     $459
                                     $459
                                    400-800
                                   $171,538
                                    $28,230
                                    $15,674
                                     $304
                                     $169
                                   $100,986
                                    $22,228
                                    $22,228
                                     $239
                                     $239
                                   800-1600
                                   $171,538
                                    $28,230
                                    $3,039
                                     $152
                                      $16
                                   $100,986
                                    $22,228
                                    $22,228
                                     $119
                                     $119
                                   1600-3200
                                   $171,538
                                    $28,230
                                   -$18,411
                                      $82
                                     -$53
                                   $100,986
                                    $22,228
                                    $22,228
                                      $64
                                      $64
                                   3200-6400
                                   $171,538
                                    $28,230
                                   -$64,193
                                      $41
                                     -$94
                                   $100,986
                                    $22,228
                                    $22,228
                                      $33
                                      $33
                                  6400-12800
                                   $171,538
                                    $28,230
                                   -$159,882
                                      $20
                                     -$115
                                   $100,986
                                    $22,228
                                    $22,228
                                      $16
                                      $16











Table A2-8.  RACT-Impacted Condensate Storage Vessel VRU and Combustor Costs

                           Well Productivity Bracket
                               (bbls/day range)
                          Routing Emissions to a VRU
                            Routing to a Combustor
                                       
                        Total Capital Cost Per Unit ($)
                       Total Annual Cost Per Unit ($/yr)
                 VOC Cost Effectiveness               ($/ton)
                        Total Capital Cost Per Unit ($)
                       Total Annual Cost Per Unit ($/yr)
                 VOC Cost Effectiveness               ($/ton)
                                       

                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings

                                  w/o savings
                                  w/ savings
                                  w/o savings
                                  w/ savings
                                    >0-1
                                   $171,538
                                    $28,230
                                    $28,225
                                   $776,897
                                   $776,770
                                   $100,986
                                    $22,228
                                    $22,228
                                   $611,720
                                   $611,720
                                      1-2
                                   $171,538
                                    $28,230
                                    $28,210
                                   $176,996
                                   $176,870
                                   $100,986
                                    $22,228
                                    $22,228
                                   $139,365
                                   $139,365
                                      2-4
                                   $171,538
                                    $28,230
                                    $28,192
                                    $93,529
                                    $93,402
                                   $100,986
                                    $22,228
                                    $22,228
                                    $73,643
                                    $73,643
                                      4-6
                                   $171,538
                                    $28,230
                                    $28,161
                                    $51,817
                                    $51,690
                                   $100,986
                                    $22,228
                                    $22,228
                                    $40,800
                                    $40,800
                                      6-8
                                   $171,538
                                    $28,230
                                    $28,131
                                    $36,020
                                    $35,893
                                   $100,986
                                    $22,228
                                    $22,228
                                    $28,362
                                    $28,362
                                     8-10
                                   $171,538
                                    $28,230
                                    $28,104
                                    $28,449
                                    $28,322
                                   $100,986
                                    $22,228
                                    $22,228
                                    $22,400
                                    $22,400
                                     10-12
                                   $171,538
                                    $28,230
                                    $28,065
                                    $21,663
                                    $21,537
                                   $100,986
                                    $22,228
                                    $22,228
                                    $17,057
                                    $17,057
                                     12-15
                                   $171,538
                                    $28,230
                                    $28,045
                                    $19,367
                                    $19,240
                                   $100,986
                                    $22,228
                                    $22,228
                                    $15,249
                                    $15,249
                                     15-20
                                   $171,538
                                    $28,230
                                    $27,978
                                    $14,166
                                    $14,039
                                   $100,986
                                    $22,228
                                    $22,228
                                    $11,154
                                    $11,154
                                     20-25
                                   $171,538
                                    $28,230
                                    $27,830
                                    $8,948
                                    $8,821
                                   $100,986
                                    $22,228
                                    $22,228
                                    $7,045
                                    $7,045
                                     25-30
                                   $171,538
                                    $28,230
                                    $27,767
                                    $7,727
                                    $7,601
                                   $100,986
                                    $22,228
                                    $22,228
                                    $6,085
                                    $6,085
                                     30-40
                                   $171,538
                                    $28,230
                                    $27,588
                                    $5,573
                                    $5,446
                                   $100,986
                                    $22,228
                                    $22,228
                                    $4,388
                                    $4,388
                                     40-50
                                   $171,538
                                    $28,230
                                    $27,316
                                    $3,914
                                    $3,787
                                   $100,986
                                    $22,228
                                    $22,228
                                    $3,082
                                    $3,082
                                    50-100
                                   $171,538
                                    $28,230
                                    $26,820
                                    $2,535
                                    $2,409
                                   $100,986
                                    $22,228
                                    $22,228
                                    $1,996
                                    $1,996
                                    100-200
                                   $171,538
                                    $28,230
                                    $25,177
                                    $1,171
                                    $1,045
                                   $100,986
                                    $22,228
                                    $22,228
                                     $922
                                     $922
                                    200-400
                                   $171,538
                                    $28,230
                                    $22,239
                                     $597
                                     $470
                                   $100,986
                                    $22,228
                                    $22,228
                                     $470
                                     $470
                                    400-800
                                   $171,538
                                    $28,230
                                    $17,120
                                     $322
                                     $195
                                   $100,986
                                    $22,228
                                    $22,228
                                     $253
                                     $253
                                   800-1600
                                   $171,538
                                    $28,230
                                    $11,122
                                     $209
                                      $82
                                   $100,986
                                    $22,228
                                    $22,228
                                     $165
                                     $165
                                   1600-3200
                                   $171,538
                                    $28,230
                                    -$9,152
                                      $96
                                     -$31
                                   $100,986
                                    $22,228
                                    $22,228
                                      $75
                                      $75
                                   3200-6400
                                   $171,538
                                    $28,230
                                   -$30,717
                                      $61
                                     -$66
                                   $100,986
                                    $22,228
                                    $22,228
                                      $48
                                      $48
                                  6400-12800
                                   $171,538
                                    $28,230
                                   -$196,116
                                      $16
                                     -$111
                                   $100,986
                                    $22,228
                                    $22,228
                                      $13
                                      $13
                                   >12800
                                   $171,538
                                    $28,230
                                    $28,230
                                      $0
                                      $0
                                   $100,986
                                    $22,228
                                    $22,228
                                      $0
                                      $0

Table A2-9.  RACT-Impacted Oil Storage Vessel Nationwide Costs

                           Well Productivity Bracket
                                (bbls/day range)
                                Representative 
                                  (bbls/day)
                            Total Nationwide Costs








                                  Capital ($)
                              Annual w/o savings 
                                    ($/yr)
                           Annual w/ savings ($/yr)
                                    >0-1
                                     0.385
                                      $0
                                      $0
                                      $0
                                      1-2
                                     1.34
                                      $0
                                      $0
                                      $0
                                      2-4
                                     2.66
                                      $0
                                      $0
                                      $0
                                      4-6
                                     4.45
                                      $0
                                      $0
                                      $0
                                      6-8
                                     6.22
                                      $0
                                      $0
                                      $0
                                     8-10
                                     8.08
                                      $0
                                      $0
                                      $0
                                     10-12
                                     9.83
                                      $0
                                      $0
                                      $0
                                     12-15
                                     12.1
                                      $0
                                      $0
                                      $0
                                     15-20
                                     15.4
                                      $0
                                      $0
                                      $0
                                     20-25
                                     19.9
                                      $0
                                      $0
                                      $0
                                     25-30
                                     24.3
                                      $0
                                      $0
                                      $0
                                     30-40
                                     30.5
                                 $117,473,197
                                  $24,821,102
                                  $24,729,715
                                     40-50
                                     39.2
                                  $54,517,590
                                  $11,519,110
                                  $11,464,556
                                    50-100
                                     61.6
                                  $81,571,106
                                  $17,235,291
                                  $17,107,178
                                    100-200
                                      120
                                  $11,193,068
                                  $2,365,002
                                  $2,330,858
                                    200-400
                                      238
                                  $1,361,319
                                   $287,635
                                   $279,375
                                    400-800
                                      456
                                      $0
                                      $0
                                      $0
                                   800-1600
                                      914
                                      $0
                                      $0
                                      $0
                                   1600-3200
                                     1,692
                                      $0
                                      $0
                                      $0
                                   3200-6400
                                     3,353
                                      $0
                                      $0
                                      $0
                                  6400-12800
                                     6,825
                                      $0
                                      $0
                                      $0
                                     TOTAL
 
                                 $266,116,280
                                  $56,228,139
                                  $55,911,683
                                       


                                       
                                       
Table A2-10.  RACT-Impacted Condensate Storage Vessel Nationwide Costs

                          Well Productivity Bracket 
                               (bbls/day range)
                                Representative 
                                  (bbls/day)
                            Total Nationwide Costs








                                  Capital ($)
                           Annual w/o savings ($/yr)
                           Annual w/ savings ($/yr)
                                    >0-1
                                      635
                                      $0
                                      $0
                                      $0
                                      1-2
                                      349
                                      $0
                                      $0
                                      $0
                                      2-4
                                      648
                                      $0
                                      $0
                                      $0
                                      4-6
                                      766
                                      $0
                                      $0
                                      $0
                                      6-8
                                      640
                                      $0
                                      $0
                                      $0
                                     8-10
                                      525
                                      $0
                                      $0
                                      $0
                                     10-12
                                      408
                                      $0
                                      $0
                                      $0
                                     12-15
                                      564
                                      $0
                                      $0
                                      $0
                                     15-20
                                      758
                                      $0
                                      $0
                                      $0
                                     20-25
                                      674
                                      $0
                                      $0
                                      $0
                                     25-30
                                      531
                                      $0
                                      $0
                                      $0
                                     30-40
                                      927
                                      $0
                                      $0
                                      $0
                                     40-50
                                      747
                                      $0
                                      $0
                                      $0
                                    50-100
                                     2,691
                                      $0
                                      $0
                                      $0
                                    100-200
                                     3,800
                                      $0
                                      $0
                                      $0
                                    200-400
                                     2,705
                                      $0
                                      $0
                                      $0
                                    400-800
                                     1,165
                                      $0
                                      $0
                                      $0
                                   800-1600
                                      348
                                      $0
                                      $0
                                      $0
                                   1600-3200
                                      69
                                      $0
                                      $0
                                      $0
                                   3200-6400
                                      37
                                      $0
                                      $0
                                      $0
                                  6400-12800
                                       5
                                      $0
                                      $0
                                      $0
                                   >12800
                                       0
                                      $0
                                      $0
                                      $0
                                     TOTAL
 
                                      $0
                                      $0
                                      $0








                                       
                                       
                                       
                                       
                                       
                                 ATTACHMENT 3
                                       
    Oil and Natural Gas CTG  -  Storage Vessels Covered By State Regulation
























	This attachment presents an analysis of state regulations that estimates the number of existing storage vessels that are subject to a RACT-equivalent or greater level of control. The number of storage vessels determined to be subject to a RACT-equivalent or greater level of control was subtracted from the number of storage vessels that were located in RACT-impacted areas that we assumed emit greater than or equal to six tpy. There may be more storage vessels regulated or permitted at a greater or equivalent level of control to the recommended RACT that have not been accounted for in this analysis (e.g., based on case-by-case permit limits). 









                                                                               
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                                                               
                                       
                                       
           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