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 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 Control Techniques Guidelines for the Oil and Natural Gas Industry, henceforth the CTG, finalizes recommendations for RACT for select emission sources in the oil and natural gas industry.

      The 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 CTG, 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 storage vessels, natural gas-driven pneumatic controllers, diaphragm natural gas-driven pneumatic pumps, compressors, equipment leaks at natural gas processing plants, and fugitive emissions at well sites and gathering and boosting 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.

Table 1-1. Summary of the Oil and Natural Gas Industry Emission Sources and Recommended RACT Included in this CTG
                                Emission Source
                                 Applicability
                             RACT Recommendations
1. Storage Vessels
Individual storage vessel with a potential to emit (PTE) greater than or equal to 6 tons per year (tpy) VOC.
95 percent reduction of VOC emissions from storage vessels.
OR

Maintain less than 4 tpy uncontrolled actual VOC emissions after having demonstrated that the uncontrolled actual VOC emissions have remained less than 4 tpy, as determined monthly, for 12 consecutive months.
2. Pneumatic Controllers
Individual continuous bleed, natural gas-driven pneumatic controller located at a natural gas processing plant.
Natural gas bleed rate of 0 standard cubic feet per hour (scfh) (unless there are functional needs, including but not limited to response time, safety and positive actuation, requiring a bleed rate greater than 0 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. Pneumatic Pumps
Individual natural gas-driven diaphragm pump located at a natural gas processing plant.
Zero VOC emissions.

Individual natural gas-driven diaphragm pump located at a well site.
Require routing of VOC emissions from the pneumatic pump to an existing on-site control device or process.

Require 95 percent control unless the on-site existing control device or process cannot achieve 95 percent.

If onsite existing device or process cannot achieve 95 percent, maintain documentation demonstrating the percent reduction the control device is designed to achieve.

If there is no existing control device at the location of the pneumatic pump, maintain records that there is no existing control device onsite.

Individual natural gas-driven diaphragm pump located at a well site that is in operation for any period of time each calendar day for less than a total of 90 days per calendar year.
RACT would not apply.
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 on or before 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.

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 leak detection and repair (LDAR) program for natural gas processing plants.
6. Fugitive Emissions

Individual well site with wells that produce, on average, greater than 15 barrel equivalents per day per well.
Develop and implement a semiannual optical gas imaging (OGI) monitoring and repair plan that covers the collection of fugitive emissions components at well sites with a gas to oil ratio (GOR) greater than or equal to 300 within a company defined area. Method 21 can be used as an alternative to OGI at a 500 ppm repair threshold level.

Individual gathering and boosting station located from the wellhead to the point of custody transfer to the natural gas transmission and storage segment or point of custody transfer to an oil pipeline.
Develop and implement a quarterly OGI monitoring and repair plan that covers the collection of fugitive emissions components at gathering and boosting stations within a company defined area. Method 21 can be used as an alternative to OGI at a 500 ppm repair threshold.

Individual well site with a GOR less than 300.
RACT would not apply.

      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 presented in the CTG for their particular Moderate or higher ozone nonattainment or OTR area. 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, the EPA's implementing regulations, and RACT policies.

      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 hypothetical situation wherein recommended RACTs, contained in the CTG, are 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 hypothetical situation where all affected oil and natural gas emission sources that existed in 2012 and 2014, respectively, adopt the recommended RACT. It is estimated that in this case VOC emissions would be reduced by approximately 80 thousand tons per year (tpy) at an annualized net cost to the industry of approximately $100 million dollars based on the CTG recommended RACT. Additionally, the recommended RACT is estimated to reduce methane emissions by approximately 200 thousand tpy and hazardous air pollutant (HAP) emissions by 3 thousand tpy.

      This assessment uses general assumptions about potentially impacted sources to provide a reasonable estimate of the magnitude of expected emission reductions and net costs to the industry associated with the CTG. However, there are limitations, including some that suggest the cost estimates may be overestimated in some dimensions. While the analysis attempts to account for existing state regulations, we were not able to fully account for state permit limits for individual sources that meet or exceed the recommended RACT level of control. Additionally, in some instances we did not estimate the number of sources that would be subject to regulation. For example, EPA is aware that San Joaquin Valley Air Pollution Control District requires monitoring and repair of fugitive emission components at crude oil and natural gas production facilities based on a percent VOC-by-weight applicability threshold. However, for the purposes of this analysis, we did not review San Joaquin's approved SIP to determine the number of sources that would be subject to these requirements. Thus, the number of existing sources that are already achieving the recommended RACT level of control may be underestimated, which leads to fewer emission reductions and lower expected costs for owners and operators as a result of the CTG than what we estimated.
      In addition, this analysis is based on industry averages and does not account for heterogeneity across sources, which can affect costs and emission reductions. As noted previously, air agencies have the flexibility of determining RACT that may differ from what EPA recommends. This flexibility allows geographically different air agencies to consider their local conditions and implement a tailored RACT, which may lower costs for sources in their jurisdiction. In addition, the resulting state and local regulations may also require a lower level of control, or may affect a lower number of sources than are included in the analysis presented here. Finally, because the data set of existing sources we use comes from 2012 and 2014 reporting years, we may include some sources that are no longer in use, resulting in us overestimating costs and benefits. However, any small changes to the existing universe of sources 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.
          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.
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 RACT recommendations, we obtained information on U.S. ozone NA areas from the EPA's Greenbook (https://www3.epa.gov/airquality/greenbook/hindex.html, as of June 17, 2016). The list of the ozone NA areas included in this analysis is presented in Attachment 1 to this memorandum. The list of ozone NA areas includes areas that failed to attain the 2008 ozone NAAQS by the applicable attainment date of July 20, 2015 that EPA reclassified as Moderate for the 2008 ozone NAAQS (81 FR 26697, May 4, 2016).  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 Consolidated Metropolitan Statistical Area (CMSA) that includes the District of Columbia.

3	INFORMATION USED TO ESTIMATE 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. June 1, 2015. (2014 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 2014 (Data Year 2012) and 2016 (Data Year 2014) was used in this analysis. For the purposes of this document these data sources are referred to as "GHGRP" and "2014 GHG Inventory" and "2016 GHG Inventory".[,]
          The 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 Technical Support Document (TSD) for the 2015 proposed new source performance standards (NSPS) and 2016 final NSPS, referred to in this document as the "2015 NSPS TSD" and "2016 NSPS TSD", respectively.[,]
          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 memorandum 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 and provides parameters that describe location, operator, and production characteristics. The data extract from the DrillingInfo, Inc. database includes the population of all wells with gas and/or hydrocarbon liquid production during 2010 through 2012 and those with a recorded completion between 2010 and the date of the extract (February, 2014).

      The data is used to identify oil wells and natural gas wells in production in 2012 in RACT-impacted areas using their accompanying Federal Information Processing Standard (FIPS) codes. If the data show a well had had gas production but no liquids production, it is classified as a gas well. If a well had liquids production but no gas production, it is classified as an oil well. Most wells produce both oil and gas, however, so we use a ratio of gas production to liquids (or oil) production to classify wells producing both products. Gas wells are defined as wells with an average gas to oil ratio (GOR) greater than 100,000 standard cubic feet per barrel over the lifetime of the well, and oil wells sites with a GOR greater than or equal to 300 were defined as those wells with an average GOR greater than or equal to 300 standard cubic feet per barrel and less than 100,000 standard cubic feet per barrel over the lifetime of the well.

      As a result of the analysis of all producing wells in 2012, we identify 122,211 oil and gas wells (81,445 oil wells and 40,766 gas wells) in Moderate or higher ozone NA areas, and 90,232 oil and gas wells (23,074 oil wells and 67,158 gas wells) in OTR areas. An estimated 22,426 oil and gas wells (1,157 oil wells and 21,269 gas wells) are located in an OTR area that coincides with a Moderate or higher ozone NA area. Of the wells in a Moderate or higher ozone NA area, we identified 21,607 oil and gas wells (9,232 oil wells and 12,375 gas wells) with a GOR greater than or equal to 300 that produce, on average, greater than 15 barrel equivalents per day. Of the wells in OTR areas, we identified 4,634 oil and gas wells (247 oil wells and 4,387 gas wells) with a GOR greater than or equal to 300 that produce, on average, greater than 15 barrel equivalents per day. Of the wells with a GOR greater than 300 producing greater than 15 barrel equivalents per day, an estimated 928 oil and gas wells (222 oil wells and 706 gas wells) are located in OTR areas that are also Moderate or higher ozone NA areas. States that have wells with RACT-impacted areas include California, Maryland, New York, Pennsylvania, Texas, and Virginia.
      This information is 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),
          estimate the total number of oil well sites that have a GOR greater than or equal to 300, 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 area).

OGJ Worldwide Gas Processing Survey (Oil & Gas Journal, June 1, 2015)

      The OGJ Gas Processing Survey, reflecting companies and locations for natural gas processing plants is used to obtain location information of natural gas processing plants in OTR and Moderate or higher ozone NA areas. Of the estimated 668 natural gas processing plants in the U.S., an estimated 13 natural gas processing plants are located in OTR areas and 57 are located in Moderate or higher ozone NA areas. Only 2 of the 57 natural gas processing plants in Moderate or higher ozone NA areas are located in OTR areas. States that have processing plants with RACT-impacted areas include California, Colorado, Pennsylvania, and Texas.

      This information is 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, natural gas-driven pneumatic controllers, diaphragm natural gas-driven pneumatic pumps, compressors, equipment leaks at natural gas processing plants, and fugitive emissions at well sites and gathering and boosting stations.

4.1	Storage Vessels

4.1.1 	Approach

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

          Estimate the number of existing wells located in RACT-impacted areas in 2012 (assuming one controlled storage vessel per well) based on 2012 DI Desktop location information.
          Subtract the wells completed in 2012 from this number (assuming that these storage vessels would be subject to the NSPS).
          Subtract the number of storage vessels presumed to be controlled under state air regulations from the number of storage vessels that would be impacted by RACT,
          Use the emission factor from a typical storage vessel within each throughput bracket included in Table 4-2 of the CTG to estimate emissions based on 2012 DI Desktop production information.
          Determine the number of storage vessels that likely have VOC emissions greater than or equal to the RACT recommended applicability threshold of 6 tons per year (tpy).
          Estimate the number of storage vessels likely to have VOC emissions greater than or equal to 6 tpy that are also subject to, and controlled under, state air regulations.
          We use information on state environmental regulations developed for the CTG to subtract 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 potentially 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
                                     2,754
                                      40
                                     2,794

      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 included in Table 4-2 of the CTG and 2012 DI Desktop production information, we calculate the RACT-impacted number of storage vessels and baseline VOC, methane and HAP emissions. RACT-impacted storage vessel emission reductions are 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 estimate 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
                                    28,291
                                     5,856
                                      888
                                      317
                                      66
                                      10
                                    28,608
                                     5,921
                                      898

        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
                                    26,876
                                     5,563
                                      844
                                      302
                                      62
                                       9
                                    27,178
                                     5,625
                                      853
  [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 and vapor recovery unit (VRU) developed for the CTG, we multiply 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 VRU. The capital costs and annual costs used for a combustion device are $100,986 and $25,194, respectively. The capital costs and annual costs used for a VRU are $171,538 and $28,230, respectively. Gas savings is individual to production and emission rate class. Gas savings is estimated for storage vessels using a VRU only, assuming gas recovered would be valued at $4 per million cubic feet (Mcf) of recovered natural gas. No gas savings is 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
                                 $289,762,935
                                 $69,883,407
                                 $69,665,250
                                  $4,208,765
                                  $1,015,046
                                  $1,012,599
                                 $293,971,699
                                 $70,898,453
                                 $70,677,849
[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 are calculated by multiplying the number of uncontrolled natural gas-driven pneumatic controllers reported in the 2014 GHG Inventory (assuming that they were natural gas-driven) by emissions and emission reductions per controller. The RACT-impacted area costs are 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 2014 GHG Inventory, there were an estimated 135 natural gas-driven pneumatic controllers in the processing segment nationally. There were no natural gas-driven pneumatic controllers reported for the processing segment in the 2016 GHG Inventory. The 2014 GHG Inventory nationwide number of 135 natural gas-driven controllers in the processing segment was adjusted to 149 based on an increase in the nationwide number of natural gas processing plants from 606 in the 2014 GHG Inventory to 668 in the 2016 GHG Inventory (assumes that there would be an increase in the number of natural gas-driven pneumatic controllers in the processing segment proportionate to the increase in the number of natural gas processing plants). The percentage of natural gas processing plants located in RACT-impacted areas based on the 2014 Gas Processing Survey is used to estimate the number of RACT-impacted natural gas-driven pneumatic controllers.

Similarly, based on information in the 2016 GHG Inventory, there are an estimated 72,217 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 is 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
                                     5,634
                                     5,095
                                    10,729
Processing Plants
                                      13
                                       3
                                      16
      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 are 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 estimate 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 use the emission reductions and costs associated with the use of an existing instrument air system. For production segment natural gas-driven pneumatic controllers, we use 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 estimate 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
                                     1.47
                                      5.3
                                     0.055
                                     8,301
                                    29,860
                                      313
                                     7,506
                                    27,001
                                      283
                                    15,807
                                    56,861
                                      595
Processing Plants
                                     0.28
                                      1.0
                                     0.01
                                      3.6
                                     12.7
                                     0.13
                                     0.81
                                      2.9
                                     0.03
                                      4.4
                                      16
                                     0.16

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
                                     1.41
                                     5.10
                                     0.05
                                     7,963
                                    28,733
                                      301
                                     7,201
                                    25,982
                                      272
                                    15,164
                                    54,716
                                      573
Processing Plants
                        Existing Instrument Air System
                                     0.28
                                     1.00
                                     0.01
                                      3.6
                                     12.7
                                     0.13
                                     0.81
                                      2.9
                                     0.03
                                      4.4
                                      16
                                     0.16

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
                                    $1,182
                                    $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
                                 $15,200,413
                                  $1,668,924
                                  -$4,991,666
                                 $13,745,189
                                  $1,509,148
                                  -$4,513,785
                                 $28,945,602
                                  $3,178,072
                                  -$9,505,450
Processing Plants
                                   $25,428
                                    $3,624
                                     $676
                                    $5,799
                                     $826
                                     $154
                                   $31,228
                                    $4,450
                                     $831

4.3	Diaphragm Natural Gas-Driven Pneumatic Pumps
4.3.1 	Approach
RACT-impacted diaphragm 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 2014 GHG Inventory (assuming they are all natural gas-driven pumps) by emissions and emission reductions per pump. The RACT-impacted natural gas-driven pneumatic pump costs are 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 2016 GHG Inventory for oil production, there are an estimated 127,733 pneumatic pumps. The number of pneumatic pumps reported in the 2016 GHG Inventory for gas production is an estimated 83,249 pneumatic pumps. Similar to the assumption used in the 2016 NSPS TSD, we assume that 50 percent of the pneumatic pumps are diaphragm pumps and 50 percent of the pumps are piston pumps. Based on these assumptions, and assuming that all of the reported pumps are natural gas-driven, we estimate that there are 105,367 diaphragm natural gas-driven pneumatic pumps in the production segment nationally. The percentage of RACT-impacted wells based on 2012 DI Desktop location information is used to estimate the number of RACT-impacted high bleed natural gas-driven diaphragm pneumatic pumps.

The 2016 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 Diaphragm 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
                                     8,220
                                     7,433
                                    15,653

4.3.3	RACT-Impacted Natural Gas-Driven Diaphragm Pneumatic Pump Baseline Emissions, Emission Reductions and Costs

RACT-impacted diaphragm natural gas-driven pneumatic pump baseline emissions are estimated by multiplying the estimated population of diaphragm natural gas-driven pneumatic pumps and the VOC, methane and HAP baseline emissions per diaphragm natural gas-driven pneumatic pump. We assume 75 percent of diaphragm pumps in RACT-impacted areas will be in operation for any period of time each calendar day for more than or equal to 90 days per calendar year, and will be located where there is an existing combustion control device or VRU that is technically feasible to route to. Using the emission reductions and retrofit costs developed for the CTG for use of a VRU or combustion control device, we estimate the emission reductions and costs by multiplying the estimated number of diaphragm natural gas-driven pneumatic pumps that RACT would apply to where it would be technically feasible to route to an existing control device by the emission reductions and costs associated with routing emissions to an existing combustion control device or VRU. Gas savings would only occur with the use of a VRU. We assume 94 percent of the pumps would use combustion and 6 percent would use a VRU. Using methane to HAP ratios developed for the oil and natural gas industry as presented in the 2011 Gas Composition memorandum, we estimate RACT-impacted diaphragm 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. The cost savings presented in Tables 4-13 and 4-14 would only be realized if a VRU is used as a control device.
Table 4-11. RACT-Impacted Diaphragm 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
                                     7,891
                                    28,442
                                      298
                                     7,136
                                    25,719
                                      269
                                    15,027
                                    54,160
                                      567

Table 4-12. RACT-Impacted Diaphragm 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 or VRU
                                     0.91
                                      3.3
                                     0.034
                                     5,633
                                    20,265
                                      212
                                     5,094
                                    18,325
                                      192
                                    10,727
                                    38,589
                                      404

Table 4-13. Total Annual Costs and VOC Cost of Control Per Diaphragm 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
                                      187
                                     $748
                                    $2,000
                                     $774
                                     $26
                                     $847
                                     $28

  Table 4-14. RACT-Impacted Diaphragm 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)[a]
Diaphragm
                                 $12,330,135
                                  $4,769,200
                                  $4,759,736
                                 $11,149,699
                                  $4,312,617
                                  $4,304,059
                                 $23,479,834
                                  $9,081,817
                                  $8,554,929
[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.

4.4	Compressors
4.4.1 	Approach
RACT-impacted reciprocating compressor and wet seal centrifugal compressor baseline emissions and emission reductions are calculated by multiplying the number of uncontrolled compressors based on information reported in the 2014 GHG Inventory by emissions and emission reductions by compressor. The RACT-impacted reciprocating compressor and wet seal centrifugal compressor costs are 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
The 2016 GHG Inventory does not include an estimate of the number of reciprocating compressors at gathering and boosting stations. Therefore, we use the 2014 GHG Inventory estimate of 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 2014 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 is used to estimate the number of RACT-impacted reciprocating compressors located at gathering and boosting stations.

Based on information in the 2016 GHG Inventory, there are an estimated 6,020 reciprocating compressors in the processing segment. The percentage of the total number of RACT-impacted natural gas processing plants based on the 2014 Gas Processing Survey is used to estimate the number of RACT-impacted reciprocating compressors in the processing segment.

Based on information in the 2016 GHG Inventory, there are an estimated 665 wet seal compressors in the processing segment. The percentage of the total number of RACT-impacted natural gas processing plants based on the 2014 Gas Processing Survey is 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
                                     2,946
                                     1,623
                                     4,569
Reciprocating Compressors - Processing Plants
                                      514
                                      117
                                      631
Centrifugal Compressors - Wet Seals Processing Plants
                                      57
                                      13
                                      70

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

	RACT-impacted compressor baseline emissions are 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 estimate emission reductions and costs by multiplying the number of compressors by the emission reductions and costs per compressor. For reciprocating compressors, we use the emission reductions and costs associated with replacing reciprocating compressor rod packing on or before 26,000 hours of operation, or 36 months since the most recent rod packing replacement. For wet seal compressors, we use 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 estimate 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
                                    10,086
                                    36,285
                                      380
                                     5,558
                                    19,994
                                      209
                                    15,644
                                    56,279
                                      589
Reciprocating Compressor  -  Processing
                                      6.1
                                      22
                                     0.23
                                     3,142
                                    11,301
                                      118
                                      717
                                     2,577
                                      27
                                     3,858
                                    13,878
                                      145
Wet Seal Compressor  -  Processing
                                      19
                                      211
                                      2.2
                                     1,084
                                    11,946
                                      125
                                      247
                                     2,725
                                      29
                                     1,331
                                    14,671
                                      154

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
 CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
                                      VOC
                                      CH4
                                      HAP
Reciprocating Compressor  -  Gathering and Boosting Station
                   Replace Packing On or Before Three Years
                                      1.9
                                      6.8
                                     0.07
                                     5,604
                                    20,161
                                      211
                                     3,088
                                    11,109
                                      116
                                     8,692
                                    31,270
                                      327
Reciprocating Compressor  -  Processing
                   Replace Packing On or Before Three Years
                                      4.9
                                      18
                                     0.18
                                     2,510
                                     9,029
                                      95
                                      572
                                     2,059
                                      22
                                     3,083
                                    11,088
                                      116
Wet Seal Compressor  -  Processing
                95 Percent Control; Existing Combustion Device
                                      18
                                      200
                                      2.1
                                     1,030
                                    11,374
                                      119
                                      235
                                     2,594
                                      27
                                     1,264
                                    13,968
                                      146

     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
                                 $16,641,322
                                  $6,341,203
                                  $1,668,021
                                  $9,169,802
                                  $3,494,168
                                   $919,123
                                 $25,811,123
                                  $9,835,372
                                  $2,587,144
Reciprocating Compressor  -  Processing
                                  $2,198,562
                                   $837,816
                                  -$1,255,071
                                   $501,426
                                   $191,081
                                   -$286,244
                                  $2,699,988
                                  $1,028,897
                                  -$1,541,315
Wet Seal Compressor  -  Processing
                                  $1,319,412
                                   $187,879
                                   $187,879
                                   $300,918
                                   $42,850
                                   $42,850
                                  $1,620,330
                                   $230,729
                                   $230,729

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 are 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 are 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 is obtained from information in the 2014 Gas Processing Survey. There are 57 natural gas processing plants located in Moderate or higher ozone NA areas and 13 natural gas processing plants in OTR areas in 2014. Two of the natural gas processing plants located in an OTR area are also located in a Moderate or higher ozone NA area. 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
                                      55
                                      13
                                      68

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 are 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 estimate 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 estimate 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
                                     1,922
                                     6,912
                                      72
                                      454
                                     1,634
                                      17
                                     2,376
                                     8,546
                                      90

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
                                      251
                                      902
                                       9
                                      59
                                      213
                                       2
                                      310
                                     1,115
                                      12

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
                                   $467,445
                                   $712,753
                                   $503,771
                                   $110,487
                                   $168,469
                                   $119,073
                                   $577,931
                                   $881,222
                                   $622,844

4.6	Fugitive Emissions at Well Sites and Gathering and Boosting Stations

4.6.1	Approach

RACT-impacted fugitive emissions at natural gas well sites and oil well sites with a GOR greater than or equal to 300 that produce, on average, greater than 15 barrel equivalents per day per well, and gathering and boosting stations baseline emissions and emission reductions are calculated by multiplying the number of applicable well sites and gathering and boosting stations by the baseline emissions and emission reductions per site/station. The RACT-impacted applicable well sites and gathering and boosting station costs are estimated by multiplying the calculated RACT VOC emission reductions by costs per applicable well site/gathering and boosting station.

4.6.2 	RACT-Impacted Population of Wells Sites and Gathering and Boosting Stations
      The DI Desktop database is used to obtain information on the number of oil and natural gas wells with a GOR greater than or equal to 300 in 2012 in the U.S that produce, on average, greater than 15 barrel equivalents per day. Although we have insufficient information to do a comprehensive equivalency analysis between our recommended RACT and Colorado's existing regulations, for the purposes of this analysis, Colorado Moderate or higher NA area well sites were removed as RACT-impacted sites based on their existing regulation of these sources. The number of natural gas wells in RACT impacted areas is estimated to be 16,056. The number of oil wells with a GOR greater than or equal to 300 located in RACT-impacted areas is estimated to be 9,257. Using information developed for the 2016 NSPS TSD and CTG, we estimate 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 2016 GHG Inventory, there are an estimated 4,999 gathering and boosting stations nationally. The average of the percentage of the total RACT-impacted number of natural gas processing plants based on the 2014 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 is 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
                                     6,115
                                     1,841
                                     7,956
Oil Well Sites with a GOR >= 300
                                     2,686
                                      13
                                     2,699
Gathering and Boosting Stations
                                      408
                                      225
                                      633

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 are 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 2016 NSPS TSD and CTG, we estimate 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 estimate 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
                                     1.53
                                     5.50
                                     0.06
                                     9,342
                                    33,606
                                      352
                                     2,811
                                    10,114
                                      106
                                    12,153
                                    43,720
                                      458
Oil Well Sites with a GOR
>= 300
                                     0.75
                                     2.75
                                     0.03
                                     2,021
                                     7,387
                                      76
                                       9
                                      34
                                       0
                                     2,030
                                     7,421
                                      76
Gathering and Boosting Stations
                                     9.77
                                     35.14
                                     0.37
                                     3,988
                                    14,348
                                      150
                                     2,198
                                     7,906
                                      83
                                     6,186
                                    22,254
                                      233

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
                                     0.92
                                      3.3
                                     0.03
                                     5,605
                                    20,164
                                      211
                                     1,687
                                     6,068
                                      64
                                     7,292
                                    26,232
                                      275
Oil Well Sites with a GOR
>= 300
                                Semiannual OGI
                                     0.45
                                     1.65
                                     0.02
                                     1,213
                                     4,432
                                      46
                                       6
                                      21
                                       0
                                     1,218
                                     4,453
                                      46
Gathering and Boosting Stations
                                 Quarterly OGI
                                      7.8
                                      28
                                     0.29
                                     3,191
                                    11,478
                                      120
                                     1,758
                                     6,325
                                      66
                                     4,949
                                    17,803
                                      186

 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
                                      191
                                     $764
                                     $801
                                    $2,285
                                    $1,521
                                    $2,494
                                    $1,660
Oil Well Sites with a GOR >= 300
                                      96
                                     $382
                                     $801
                                    $2,285
                                    $1,903
                                    $5,062
                                    $4,215
Gathering and Boosting Stations
                                     1,629
                                    $6,517
                                    $2,393
                                   $25,049
                                   $18,532
                                    $3,205
                                    $2,371

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
                                  $4,898,063
                                 $13,976,476
                                  $9,302,346
                                  $1,474,107
                                  $4,206,319
                                  $2,799,607
                                  $6,372,169
                                 $18,182,796
                                 $12,101,953
Oil Well Sites with a GOR >= 300
                                  $2,151,291
                                  $6,138,644
                                  $5,111,261
                                   $10,012
                                   $28,568
                                   $23,787
                                  $2,161,302
                                  $6,167,212
                                  $5,135,048
Gathering and Boosting Stations
                                   $977,008
                                 $10,226,939
                                  $7,566,196
                                   $538,357
                                  $5,635,310
                                  $4,169,171
                                  $1,515,364
                                 $15,862,249
                                 $11,735,366

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 diaphragm 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.

                                 ATTACHMENT 1

                       Moderate or Higher Ozone NA Areas

                       Moderate or Higher Ozone NA Areas

                                     State
                                  County Name
                                 NA Area Name
AZ
Maricopa County
Phoenix-Mesa, AZ
AZ
Pinal County
Phoenix-Mesa, AZ
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 Diego County
San Diego County
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
CO
Adams County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Arapahoe County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Boulder County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Broomfield County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Denver County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Douglas County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Jefferson County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Larimer County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
CO
Weld County
Denver-Boulder-Greeley-Fort Collins-Loveland, CO
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
GA
Bartow County
Atlanta, GA
GA
Cherokee County
Atlanta, GA
GA
Clayton County
Atlanta, GA
GA
Cobb County
Atlanta, GA
GA
Coweta County
Atlanta, GA
GA
De Kalb County
Atlanta, GA
GA
Douglas County
Atlanta, GA
GA
Fayette County
Atlanta, GA
GA
Forsyth County
Atlanta, GA
GA
Gwinnett County
Atlanta, GA
GA
Henry County
Atlanta, GA
GA
Newton County
Atlanta, GA
GA
Rockdale County
Atlanta, GA
IL
Cook County
Chicago-Naperville, IL-IN-WI
IL
Du Page County
Chicago-Naperville, IL-IN-WI
IL
Grundy County
Chicago-Naperville, IL-IN-WI
IL
Kane County
Chicago-Naperville, IL-IN-WI
IL
Kendall County
Chicago-Naperville, IL-IN-WI
IL
Lake County
Chicago-Naperville, IL-IN-WI
IL
Mc Henry County
Chicago-Naperville, IL-IN-WI
IL
Will County
Chicago-Naperville, IL-IN-WI
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
                                    42,435
                                      1-2
                                     1.34
                                       0
                                    13,358
                                      2-4
                                     2.66
                                       0
                                    14,890
                                      4-6
                                     4.45
                                       0
                                     8,123
                                      6-8
                                     6.22
                                       0
                                     5,409
                                     8-10
                                     8.08
                                       0
                                     4,136
                                     10-12
                                     9.83
                                       0
                                     3,110
                                     12-15
                                     12.1
                                       0
                                     3,439
                                     15-20
                                     15.4
                                       0
                                     3,720
                                     20-25
                                     19.9
                                       0
                                     2,307
                                     25-30
                                     24.3
                                       0
                                     1,518
                                     30-40
                                     30.5
                                     1,198
                                      535
                                     40-50
                                     39.2
                                      588
                                      277
                                    50-100
                                     61.6
                                      866
                                      517
                                    100-200
                                      120
                                      124
                                      220
                                    200-400
                                      238
                                      14
                                      55
                                    400-800
                                      456
                                       3
                                       2
                                   800-1600
                                      914
                                       1
                                       0
                                   1600-3200
                                     1,692
                                       0
                                       1
                                   3200-6400
                                     3,353
                                       0
                                       0
                                  6400-12800
                                     6,825
                                       0
                                       0
                                     TOTAL

                                     2,794
                                    104,051

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)
                 Number of RACT-Impacted Storage Vessels  2012
                 Number of Storage Vessels Not Covered by RACT

                                    >0-1
                                      635
                                       0
                                    82,558
                                      1-2
                                      349
                                       0
                                      318
                                      2-4
                                      648
                                       0
                                      168
                                      4-6
                                      766
                                       0
                                      59
                                      6-8
                                      640
                                       0
                                      23
                                     8-10
                                      525
                                       0
                                      20
                                     10-12
                                      408
                                       0
                                      11
                                     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
                                   >12800
                                       0
                                       0
                                       0
                                     TOTAL

                                       0
                                    83,172

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
                                      0.0
                                      1-2
                                     1.34
                                     0.287
                                     0.059
                                     0.009
                                       0
                                       0
                                      0.0
                                      2-4
                                     2.66
                                     0.570
                                     0.118
                                     0.018
                                       0
                                       0
                                      0.0
                                      4-6
                                     4.45
                                     0.953
                                     0.197
                                     0.030
                                       0
                                       0
                                      0.0
                                      6-8
                                     6.22
                                     1.33
                                     0.28
                                     0.04
                                       0
                                       0
                                      0.0
                                     8-10
                                     8.08
                                     1.73
                                     0.36
                                     0.05
                                       0
                                       0
                                      0.0
                                     10-12
                                     9.83
                                     2.11
                                     0.44
                                     0.07
                                       0
                                       0
                                      0.0
                                     12-15
                                     12.1
                                     2.59
                                     0.54
                                     0.08
                                       0
                                       0
                                      0.0
                                     15-20
                                     15.4
                                     3.31
                                     0.68
                                     0.10
                                       0
                                       0
                                      0.0
                                     20-25
                                     19.9
                                     4.27
                                     0.88
                                     0.13
                                       0
                                       0
                                      0.0
                                     25-30
                                     24.3
                                     5.22
                                     1.08
                                     0.16
                                       0
                                       0
                                      0.0
                                     30-40
                                     30.5
                                     6.54
                                     1.35
                                     0.21
                                     7837
                                     1622
                                     246.0
                                     40-50
                                     39.2
                                     8.41
                                     1.74
                                     0.26
                                     4942
                                     1023
                                     155.1
                                    50-100
                                     61.6
                                     13.2
                                      2.7
                                      0.4
                                     11431
                                     2366
                                     358.8
                                    100-200
                                      120
                                     25.6
                                      5.3
                                      0.8
                                     3180
                                      658
                                     99.8
                                    200-400
                                      238
                                     51.0
                                     10.6
                                      1.6
                                      729
                                      151
                                     22.9
                                    400-800
                                      456
                                     97.7
                                     20.2
                                      3.1
                                      293
                                      61
                                      9.2
                                   800-1600
                                      914
                                     196.0
                                     40.6
                                      6.2
                                      196
                                      41
                                      6.2
                                   1600-3200
                                     1,692
                                     362.9
                                     75.1
                                     11.4
                                       0
                                       0
                                      0.0
                                   3200-6400
                                     3,353
                                     719.1
                                     148.8
                                     22.6
                                       0
                                       0
                                      0.0
                                  6400-12800
                                     6,825
                                    1463.7
                                     302.9
                                     45.9
                                       0
                                       0
                                      0.0
                                     TOTAL

                                    28,608
                                    5,921
                                     897.9

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 Emission 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
                                     7445
                                     1541
                                      234
                                     210.1
                                     15107
                                     40-50
                                     39.2
                                     7.99
                                     1.65
                                     0.25
                                     4695
                                      972
                                      147
                                     270.3
                                     9527
                                    50-100
                                     61.6
                                     12.5
                                      2.6
                                      0.4
                                     10860
                                     2248
                                      341
                                     424.2
                                     22037
                                    100-200
                                      120
                                     24.4
                                      5.0
                                      0.8
                                     3021
                                      625
                                      95
                                     823.9
                                     6130
                                    200-400
                                      238
                                     48.5
                                     10.0
                                      1.5
                                      693
                                      143
                                      22
                                    1638.9
                                     1406
                                    400-800
                                      456
                                     92.8
                                     19.2
                                      2.9