MEMORANDUM

Date: April 8, 2013

To: Bruce Moore, EPA/OAQPS/SPPD/FIG

From: Heather Brown, EC/R Incorporated

Subject: Revised Analysis to Determine the Number of Storage Vessels Projected to be 

Subject to New Source Performance Standards for the Oil and Natural Gas Sector

INTRODUCTION

On August 16, 2012, the Environmental Protection Agency (EPA) promulgated final new source 

performance standards (NSPS) and national emission standards for hazardous air pollutants 

(NESHAP) for the oil and natural gas sector. Under the final rule, owners and operators of new, 

modified and reconstructed storage vessels with volatile organic compound (VOC) emissions 

greater than 6 tons per year (tpy) would be required to reduce emissions from each storage 

vessel by 95 percent. The EPA estimated that 304 new storage vessels per year would be 

subject to, and impacted by, the final NSPS.1 This estimate was, in part, based on the 

distribution of storage vessels across existing wells and the assumption that 36 percent of the 

new storage vessels would be subject to State regulations.

In October 2012, the EPA received Requests for Administrative Reconsideration of these final 

standards. One of the issues that formed the basis of industry’s request for reconsideration was 

EPA’s estimate of the number of storage vessels that would be impacted by the final rules. The 

industry disputed this estimate as being too low, and stated their belief that the correct 

estimate of new storage vessels was more likely to number in the tens of thousands. The 

industry voiced their concern that with such a large number of storage vessels, they would be 

unable to meet the compliance requirements. As a result, the EPA decided to reanalyze the 

number of affected storage vessels. The purpose of this memorandum is to document the 

analysis to determine the number of potential affected storage vessels. The analysis includes a 

revised estimate of the number of new storage vessels that would be subject to the NSPS 

(excluding those subject to State rules).

 

1 Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Production, Transmission, 

and Distribution - Background Supplemental Technical Support Document for the Final New Source Performance 

Standards. April 2012. EPA Docket Number EPA-HQ-OAR-2010-0505-4550.
2 

SUMMARY OF ANALYSIS

The purpose of this analysis was to estimate the total number of new, modified or 

reconstructed crude oil and condensate storage vessels that would be installed and would be 

subject to the NSPS from August 23, 2011 (the date upon which new, modified or reconstructed 

storage vessels become affected facilities under the NSPS), until October 15, 2015. The 

following is a summary of our analysis to estimate the number of storage vessels expected to 

be installed and subject to the NSPS: 

• An average of approximately 8,700 new, modified or reconstructed crude oil storage 

vessels are expected to be installed each yearand to be subject to the NSPS. 

• An average of approximately 3,400 new, modified or reconstructed condensate storage 

vessels are expected to be installed each year and to be subject to the NSPS.

• By the current NSPS compliance date of October 15, 2013, over 17,700 new, modified or 

reconstructed crude oil storage vessels and 7,200 condensate storage vessels will have 

come online since the original August 23, 2011, proposal date.

PROCEDURE USED TO DETERMINE THE NUMBER OF NEW STORAGE VESSELS 

In order to determine the number of new, modified or reconstructed storage vessels that 

would potentially be subject to the NSPS, we conducted this analysis using the following steps:

Steps

1. Estimate the number of wells completed (or to be completed) from 2011 through 2015.

2. Distribute the estimated number of completed wells identified across a series of 

production rate brackets.

3. Determine the total number of new, modified or reconstructed wells that would be 

completed between August 23, 2011, and October 15, 2015.

4. Determine the average number of storage vessels that would be associated with each 

new well completion.

5. Estimate emissions from a typical storage vessel within each production rate bracket.

6. Determine the number of storage vessels that would likely have VOC emissions greater 

than the NSPS applicability threshold of 6 tpy.

7. Estimate the number of storage vessels likely to have VOC emissions greater than 6 tpy 

that also would be subject to and controlled under State environmental regulations.

8. Subtract the number of storage vessels subject to and controlled under State 

environmental regulations from the number of storage vessels with VOC emissions 

greater than 6 tpy to determine the number of storage vessels that would be subject to 

the NSPS.
3 

Each of these steps will be discussed in detail in the following sections.

Step 1. Estimate the number of wells completed (or to be completed) for 2011 through 

2015

For this analysis, it was assumed that the large majority of new, modified or reconstructed 

storage vessels would be associated with new well completions. Therefore, the first step was to 

estimate the number of new wells that would be completed from 2011 to 2015. 

The Energy Information Administration (EIA) “...collects, analyzes, and disseminates 

independent and impartial energy information to promote sound policymaking, efficient 

markets, and public understanding of energy and its interaction with the economy and the 

environment.”

2 The EIA maintains the National Energy Modeling System (NEMS),3 a forecasting 

model used to produce the EIA’s Annual Energy Outlook (AEO), which provides detailed 

forecasts of the United States energy economy. The NEMS forecasting model was used to 

generate estimates and predictions for drilling activity for 2009 through 2015. Table 1 presents 

the number of completed onshore wells for the lower 48 States between 2009 and 2015. As 

shown in Table 1, the NEMS forecasting model also provided forecasts for successful 

exploration and development wells. The NEMS model also forecasts the drilling of dry wells, 

which were assumed to not be completed and needing storage vessels. A development well is 

defined by the EIA as “a well drilled within the proved area of an oil or gas reservoir to the 

depth of a stratigraphic horizon known to be productive.” Based on this definition, it was 

assumed that completed development wells would most closely represent new producing 

wells. Therefore, for this analysis, we used the number of development oil and gas wells from 

2009 through 2015 to represent the number of new producing wells.

Step 2. Distribute the estimated number of completed wells identified across a series of 

production rate brackets

As previously discussed, during the development of the final NSPS, we based our original 

estimate of the number of storage vessels expected to be impacted by the NSPS each year on a 

distribution of storage vessels across existing wells. The distribution was based on a range of 

production rates defined for the oil and natural gas production NESHAP (40 CFR part 63, 

subpart HH). These ranges were as follows: less than 15 barrels per day (bbl/day); between 15 

and 100 bbl/day; between 100 and 1,000 bbl/day; and greater than 1,000 bbl/day. 

 

2 “About EIA.” http://www.eia.gov/about/ 3 An overview of the model and complete documentation of NEMS can be found at 

<http://www.eia.doe.gov/oiaf/aeo/overview/index.html>. 
Table 1. Completed Onshore Wells from 2009 to 2015 for Lower 48 States a

2009 2010 2011 2012 2013 2014 2015

Lower 48 Onshore

 Exploration

   Total Wells 2,966 3,287 5,321 4,769 5,185 5,411 5,709

     Oil 610 764 1,035 954 1,012 1,068 1,136

     Gas 1,284 1,257 1,729 1,571 1,723 1,766 1,860

     Dry 1,072 1,266 2,558 2,244 2,450 2,577 2,713

 Development

   Total Wells 31,057 39,641 40,547 37,026 36,958 40,831 43,750

     Oil 10,855 18,440 18,023 16,445 17,452 18,519 19,567

     Gas 17,693 17,740 18,979 17,603 16,369 18,902 20,563

     Dry 2,509 3,461 3,545 2,977 3,137 3,410 3,620

 Exploration and Development

   Total Wells 34,023 42,928 45,868 41,795 42,143 46,242 49,459

     Oil 11,464 19,204 19,058 17,399 18,464 19,587 20,703

     Gas 18,978 18,997 20,708 19,175 18,092 20,668 22,423

     Dry 3,581 4,727 6,102 5,221 5,587 5,987 6,333

a Data obtained from the Energy Information Administration (EIA) NEMS 2012

forecasting model.

4

DRAFT
5 

The EIA publishes an historical distribution of wells by production rate bracket up to 2009 (see 

Attachment 1).4 We used these more narrow production rate brackets to define the categories 

for which a relative distribution of wells and their productivity would be developed.

In a separate memorandum (see Attachment 2), 5 the number of new wells within each of the 

identified production rate brackets was estimated. Drilling permit data (including well location, 

operator and production characteristics) collected by HPDI6 were used to develop crude oil and 

condensate production distributions across the defined production rate brackets for 2009. The 

development of the distribution across the production rate brackets is presented in Attachment 

2. Tables 2 and 3 present estimated distribution of oil and gas wells, respectively, within each 

production rate bracket from the HPDI database. 

As discussed in the memorandum provided in Attachment 2, the number of new wells in 2009 

that were identified in the HPDI represents approximately 44.1 percent and 82.8 percent of the 

EIA’s 2009 national estimate of new oil and gas well completions, respectively. Although a 

fraction of the national number of oil and gas wells completions is represented in the analysis, 

it was assumed that the estimated relative distribution would be representative of the U.S oil 

and gas well population.

Step 3. Determine the total number of new, modified or reconstructed wells that would 

be completed between August 23, 2011, and October 15, 2015.

The next step was to determine the total number of new wells that would be completed 

between August 23, 2011 (the date upon which new storage vessels would become affected 

facilities under the final NSPS), and October 15, 2015. Assuming that, on average, a constant 

number of wells would be completed each day throughout each year, the total number of wells 

for 2011 and 2015 were adjusted to represent the portion of each year contained in the period 

defined above. For 2011, there are 131 days from August 23 through December 31, 2011, or 

35.8 percent of the year. Therefore, the number of new oil wells and new gas wells completed 

in 2011 were multiplied by 35.8 percent. Similarly, there are 287 days from January 1 through 

October 15, 2015, or 78.6 percent of the year. Therefore, number of new oil wells and new gas 

wells completed between January 1 and October 15, 2015 were multiplied by 78.6 percent. 

Tables 2 and 3 present the number of new wells completed between August 23, 2011, and 

October 15, 2015. These estimates were calculated by applying the relative distribution from 

 

4 “US Total Distribution of Wells by Production Rate Bracket.” 

ftp://www.eia.doe.gov/pub/oil_gas/petrosystem/us_table.html 5 Memorandum from Robinson, et al., ICF International, to Brown, H., and D. Hendricks, EC/R Incorporated. Liquids 

Production Distribution for New Oil and Gas Wells in the US. March 25, 2013. (Included as Attachment 2) 6 HPDI is a data service company that provides data products and decision-support applications, which was

acquired by Drilling Info, Inc. HPDI collects drilling permit data from state and local governments. 
Table 2. Distribution of New Completed Oil Wells Across Production Rate Brackets

Oil Well Production

Rate Bracket

Number of New

Completed Oil Wells in

2009 HPDI

Distribution

of New Oil

Estimated Number of New Completed Oil Wells From

August 23, 2011 through October 15, 2015c

(BOE/day) Databasea Wellsb 2011d 2012 2013 2014 2015e

0 ‐ 1 30 0.64% 42 106 113 119 99

1 ‐ 2 45 0.96% 62 159 169 179 149

2 ‐ 4 109 2.33% 151 384 408 433 359

4 ‐ 6 110 2.35% 153 388 411 437 362

6 ‐ 8 140 3.00% 194 493 523 555 462

8 ‐ 10 135 2.89% 187 476 505 536 445

10 ‐ 12 137 2.93% 190 483 512 544 451

12 ‐ 15 215 4.60% 298 757 804 853 708

15 ‐ 20 373 7.98% 516 1,313 1,394 1,479 1,229

20 ‐ 25 374 8.01% 518 1,317 1,398 1,483 1,232

25 ‐ 30 358 7.66% 496 1,261 1,338 1,420 1,179

30 ‐ 40 546 11.7% 756 1,922 2,040 2,165 1,798

40 ‐ 50 340 7.28% 471 1,197 1,271 1,348 1,120

50 ‐ 100 733 15.7% 1,015 2,581 2,739 2,906 2,414

100 ‐ 200 558 11.9% 773 1,965 2,085 2,212 1,838

200 ‐ 400 325 6.96% 450 1,144 1,214 1,289 1,071

400 ‐ 800 112 2.40% 155 395 419 444 370

800 ‐ 1600 21 0.45% 29 74 79 84 69

1600 ‐ 3200 6 0.13% 9 22 23 24 20

3200 ‐ 6400 4 0.086% 6 15 15 16 13

6400 ‐ 12800 1 0.021% 14444

> 12800 0 0% 00000

Total 4,672 100% 6,472 16,456 17,464 18,530 15,394

BOE/day = Barrels of oil equivalent per day; the approximate energy released by burning one barrel of crude oil per day. a Calculated in separate memorandum, contained in Attachment 1.

b Relative distribution calculated by dividing number of wells for each rate class by total number of wells (4,672) identified in

the HPDI Database.

c

Number of new wells calculated by applying the distribution in each production rate bracket to the total number of wells

(from Table 1) in 2011 through 2015. Calculated number of wells was rounded up to the nearest whole well. d The total number of new wells in 2011 was adjusted by multiplying by 35.8 percent, which represents the percent of the year

from August 23 through December 31, 2011. e The total number of new wells in 2015 was adjusted by multiplying by 78.6 percent, which represents the percent of the year

from January 1 through October 15, 2015.

6

DRAFT
Table 3. Distribution of New Completed Gas Wells Across Production Rate Brackets

Gas Well

Production Rate

Bracket

Number of New

Completed Gas Wells

in 2009 HPDI

Distribution

of New Gas

Estimated Number of New Completed Gas Wells From

August 23, 2011 through October 15, 2015c

(BOE/day) Databasea Wellsb 2011d 2012 2013 2014 2015e

0 ‐ 1 464 3.34% 228 589 547 632 541

1 ‐ 2 255 1.84% 125 324 301 348 297

2 ‐ 4 474 3.41% 233 601 559 646 552

4 ‐ 6 560 4.03% 275 710 661 763 653

6 ‐ 8 468 3.37% 230 594 552 637 545

8 ‐ 10 384 2.76% 188 487 453 523 447

10 ‐ 12 298 2.15% 146 378 352 406 348

12 ‐ 15 412 2.97% 202 523 486 561 480

15 ‐ 20 554 3.99% 272 703 653 755 646

20 ‐ 25 493 3.55% 242 625 582 671 574

25 ‐ 30 388 2.79% 191 492 458 529 452

30 ‐ 40 678 4.88% 333 860 800 923 789

40 ‐ 50 546 3.93% 268 693 644 744 636

50 ‐ 100 1969 14.2% 966 2,496 2,321 2,680 2,293

100 ‐ 200 2780 20.0% 1,364 3,524 3,277 3,784 3,237

200 ‐ 400 1979 14.2% 971 2,509 2,333 2,694 2,305

400 ‐ 800 852 6.13% 418 1,080 1,005 1,160 992

800 ‐ 1600 254 1.83% 125 322 300 346 296

1600 ‐ 3200 50 0.36% 25 64 59 69 59

3200 ‐ 6400 27 0.19% 13 35 32 37 31

6400 ‐ 12800 3 0.022% 24454

> 12800 0 0% 00000

Total 13,888 100% 6,816 19,625 18,392 20,927 16,178

BOE/day = Barrels of oil equivalent per day; the approximate energy released by burning one barrel of crude oil per day.

a Calculated in separate memorandum, contained in Attachment 1.

b Relative distribution calculated by dividing number of wells for each rate class by total number of wells (13,888) identified

in the HPDI Database.

c

Number of new wells calculated by applying the distribution in each production rate bracket to the total number of wells

(from Table 1) in 2011 through 2015. Calculated number of wells was rounded up to the nearest whole well.

d The total number of new wells in 2011 was adjusted by multiplying by 35.8 percent, which represents the percent of the year

from August 23 through December 31, 2011.

e The total number of new wells in 2015 was adjusted by multiplying by 78.6 percent, which represents the percent of the year

from January 1 through October 15, 2015.

7

DRAFT
8 

Step 2 to the total number of new oil and gas well completions identified in Table 1 and 

adjusted to include portions of 2011 and 2015, as described above.

Step 4. Determine the average number of storage vessels that would be associated with 

each new well completion.

The next step in determining the number of storage vessels that would be potentially subject to 

Subpart OOOO was to estimate the number of storage vessels that would be associated with 

each new well completion. There were no reliable and verifiable data available to indicate an 

average number of storage vessels associated with each well. Therefore, the following 

assumptions were made to determine how many new storage vessels would be subject to the 

NSPS:

• The storage vessels with the highest emissions would be the first tank after the 

separator. This assumption was based on the fact that the first storage vessel after the 

separator experiences the highest pressure drop, resulting in the greatest potential for 

flashing emissions. 

• Any remaining storage vessels associated with the well would be likely to have 

significantly lower emissions related to working and breathing losses from the tank. 

• Additional tanks located at a well site are likely to be manifolded together for liquid 

level control.

Based on these assumptions, it was determined that an average of one tank per completed well 

would be subject to the NSPS. Therefore, the number of new oil and condensate storage 

vessels installed from 2011 through 2015 is equal to the number of new oil and gas wells 

presented in Tables 2 and 3, respectively.

Step 5. Estimate emissions from a typical storage vessel within each production rate 

bracket

Average storage vessel emission factors, in terms of mass of emissions per throughput, were 

developed under the final rule for both crude oil and condensate.7

 These emission factors were 

developed using the American Petroleum Institute’s (API’s) E&P Tanks program and more than 

100 storage vessels across the country with varying characteristics.

8 The VOC emissions factors 

used for this analysis are:

 

7 Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Production, Transmission, 

and Distribution - Background Supplemental Technical Support Document for the Final New Source Performance 

Standards. April 2012. EPA Docket Number EPA-HQ-OAR-2010-0505-4550. 8 Production Tank Emissions Model. E&P Tank Version 2.0. A Program for Estimating Emissions from Hydrocarbon 

Production Tanks. American Petroleum Institute. Software Number 4697. April 2000.
9 

Uncontrolled VOC Emissions from Crude Oil Storage Vessels = 0.214 tpy VOC/bbl/day

Uncontrolled VOC Emissions from Condensate Storage Vessels = 2.09 tpy VOC/bbl/day

To estimate the emissions from an average storage vessel within each production rate bracket, 

we developed average production rates for each bracket. This average was calculated using the 

EIA published nationwide production per well per day for each production rate bracket from 

2006 through 2009 (see Attachment 2). Table 4 presents the average oil production and 

condensate production in barrels per well per day, respectively. For this analysis, we considered 

the liquid produced (as reported by the EIA) from oil wells to be crude oil and from gas wells to 

be condensate.

The average VOC emissions for each new storage vessel within each production rate bracket 

were calculated by applying the average production rate (bbl/day) to the VOC emission factor 

(tpy VOC/bbl/day) and are presented in Table 4. 

Step 6. Determine the number of storage vessels that would likely have VOC emissions 

greater than the NSPS applicability threshold of 6 tpy

The next step was to determine the number of storage vessels that would potentially be subject 

to the NSPS by having VOC emission greater than 6 tpy. As shown in Table 4, crude oil storage 

vessels in the production rate bracket of 30 to 40 BOE/day and higher have average emissions 

greater than 6 tpy, meaning these storage vessels would be potentially subject to the NSPS. 

Similarly, condensate storage vessels in the production rate bracket of 40 to 50 BOE/day and 

higher have emissions greater than 6 tpy.

Tables 5 and 6 present the total number of new oil and condensate storage vessels, 

respectively, expected to be installed each year that could potentially be subject to the NSPS. 

As shown in Table 5, approximately 42,000 new oil storage vessels could be potentially subject 

to the NSPS over the August 23, 2011, to October 15, 2015 time period. Over the same period, 

approximately 46,000 new condensate storage vessels could be potentially subject to the NSPS, 

as presented in Table 6. 

Step 7. Estimate the number of storage vessels likely to have VOC emissions greater than 

6 tpy that also would be subject to and controlled under State environmental 

regulations

The next step was to determine the number of storage vessels that would already be subject to 

and controlled under State environmental regulations. It was assumed that storage vessels 

subject to State regulations would not be subject to the NSPS. The environmental regulations in 

the 11 States that represented 95 percent of the total production of crude oil and condensate 
Table 4. Average Oil and Condensate Production and Emissions per Production Rate Bracket

Oil Wells Condensate Wells

Oil Production Rate per Oil Well (bbl/day)a

Crude Oil

Storage Vessel

VOC Emissions Condensate Production Rate per Gas Well (

2006 2007 2008 2009 Average (tpy) 2006 2007 2008 2009 

0 ‐ 1 0.395 0.372 0.380 0.394 0.385 0.083 0.0175 0.0184 0.0213 0.0159 

1 ‐ 2 1.34 1.32 1.34 1.34 1.34 0.287 0.0792 0.0696 0.0912 0.0809 

2 ‐ 4 2.63 2.67 2.66 2.68 2.66 0.570 0.148 0.165 0.155 0.140 

4 ‐ 6 4.52 4.46 4.43 4.37 4.45 0.953 0.269 0.307 0.256 0.264 

6 ‐ 8 6.28 6.25 6.17 6.20 6.22 1.33 0.406 0.322 0.440 0.409 

8 ‐ 10 8.10 8.08 8.03 8.13 8.08 1.73 0.448 0.461 0.548 0.539 

10 ‐ 12 9.84 9.81 9.85 9.84 9.83 2.11 0.633 0.670 0.624 0.694 12 ‐ 15 12.2 12.1 12.1 11.9 12.1 2.59 0.675 0.725 0.709 0.824 15 ‐ 20 15.5 15.4 15.4 15.4 15.4 3.31 1.19 0.883 0.917 1.02 20 ‐ 25 19.7 20.0 20.2 19.7 19.9 4.27 1.74 1.49 1.51 1.60 25 ‐ 30 24.7 24.7 24.0 24.0 24.3 5.22 1.79 1.94 1.92 1.69 30 ‐ 40 31.0 30.0 30.4 30.6 30.5 6.54 2.39 2.38 2.55 2.88 40 ‐ 50 39.2 39.5 39.5 38.6 39.2 8.41 3.87 3.34 4.08 3.22 

50 ‐ 100 60.8 62.2 60.2 63.1 61.6 13.2 5.21 6.17 5.23 5.79 

100 ‐ 200 120 120 119 120 120 25.6 13.1 12.7 11.7 11.0 200 ‐ 400 242 242 232 236 238 51.0 24.2 25.1 23.3 22.6 400 ‐ 800 442 460 462 459 456 97.7 46.0 47.7 42.8 40.0 

800 ‐ 1600 995 916 826 919 914 196 72.7 64.7 73.0 61.3 

1600 ‐ 3200 1,771 1,662 1,618 1,719 1,692 363 156 141 139 158 3200 ‐ 6400 3,001 3,123 3,738 3,551 3,353 719 222 208 262 244 

6400 ‐ 12800 5,736 6,495 8,501 6,569 6,825 1,464 733 604 603 1,625 

> 12800c 00000 0 0000

a Oil and condensate production rates published by EIA. “US Total Distribution of Wells by Production Rate Bracket.” ftp://www.eia.doe.gov/pub/oil_gas/petrosystem/us_table.html (see Atb Oil storage vessel VOC emission factor = 0.214 tpy VOC/bbl/day. Condensate storage vessel VOC emission factor = 2.09 tpy/bbl/day. (See Reference 6, EPA Docket Number EPA‐HQ‐OAR‐20c There were no new oil and gas well completions in 2009 for this rate category. Therefore, average production rates were set to zero.

Production

Rate Bracket

(BOE/day)

10
Table 5. Number of Oil Storage Vessels Potentially Subject to the NSPS (VOC Emissions greater than 6 tpy)

2011

(08/23/2011 to 12/31/2011) 2012 2013 2014

Rate Class

(BOE/day)

Uncontrolled

VOC Emissions

per New Oil

Storage Vessel

(tpy)a

Total Number

of New Oil

Storage

Vessels per

Rate Classb

Number of Oil

Storage Vessels with

Emissions greater

than NSPS Cutoff of

6 tpy

Total Number

of New Oil

Storage

Vessels per

Rate Classb

Number of Oil

Storage Vessels with

Emissions greater

than NSPS Cutoff of

6 tpy

Total Number

of New Oil

Storage

Vessels per

Rate Classb

Number of Oil

Storage Vessels with

Emissions greater

than NSPS Cutoff of

6 tpy

Total Number

of New Oil

Storage

Vessels per

Rate Classb

Number of Oil

Storage Vessels with

Emissions greater

than NSPS Cutoff of

6 tpy

0 ‐ 1 0.083 42 0 106 0 113 0 119 0 

1 ‐ 2 0.287 62 0 159 0 169 0 179 0 

2 ‐ 4 0.570 151 0 384 0 408 0 433 0 

4 ‐ 6 0.953 153 0 388 0 411 0 437 0 

6 ‐ 8 1.33 194 0 493 0 523 0 555 0 

8 ‐ 10 1.73 187 0 476 0 505 0 536 0 

10 ‐ 12 2.11 190 0 483 0 512 0 544 0 

12 ‐ 15 2.59 298 0 757 0 804 0 853 0 

15 ‐ 20 3.31 516 0 1,313 0 1,394 0 1,479 0 20 ‐ 25 4.27 518 0 1,317 0 1,398 0 1,483 0 25 ‐ 30 5.22 496 0 1,261 0 1,338 0 1,420 0 30 ‐ 40 6.54 756 756 1,922 1,922 2,040 2,040 2,165 2,165 

40 ‐ 50 8.41 471 471 1,197 1,197 1,271 1,271 1,348 1,348 

50 ‐ 100 13.2 1,015 1,015 2,581 2,581 2,739 2,739 2,906 2,906 

100 ‐ 200 25.6 773 773 1,965 1,965 2,085 2,085 2,212 2,212 

200 ‐ 400 51.0 450 450 1,144 1,144 1,214 1,214 1,289 1,289 

400 ‐ 800 97.7 155 155 395 395 419 419 444 444 

800 ‐ 1600 196 29 29 74 74 79 79 84 84 

1600 ‐ 3200 363 9 9 22 22 23 23 24 24 

3200 ‐ 6400 719 6 6 15 15 15 15 16 16 

6400 ‐ 12800 1,464 1 1 4 4 4 4 4 4

> 12800b N/A0 0 0 0 0 0 0 0 

Total 6,472 3,665 16,456 9,319 17,464 9,889 18,530 10,492 

Total number of new oil tanks installed between August 23, 2011, and Octob

Total number of new oil tanks subject to NSPS (VOC emissions greate

a Uncontrolled VOC emissions presented in Table 4.bNumber of new storage vessels installed each year across production rate brackets (see Table 2).cThere are no new storage vessels projected to be in this bracket

11
Table 6. Number of Condensate Storage Vessels Potentially Subject to the NSPS (VOC Emissions greater than 6 tpy)

2011

(08/23/2011 to 12/31/2011) 2012 2013 2014

Rate Class

(BOE/day)

Uncontrolled

VOC Emissions

per New

Condensate

Storage Vessel

(tpy)a

Total Number

of New

Condensate

Storage Vessel

per Rate

Classb

Number of

Condensate Storage

Vessel with

Emissions greater

than NSPS Cutoff of

6 tpy

Total Number

of New

Condensate

Storage Vessel

per Rate Classb

Number of

Condensate Storage

Vessel with

Emissions greater

than NSPS Cutoff of

6 tpy

Total Number

of New

Condensate

Storage Vessel

per Rate

Classb

Number of

Condensate Storage

Vessel with

Emissions greater

than NSPS Cutoff of

6 tpy

Total Number

of New

Condensate

Storage Vessel

per Rate

Classb

Number of

Condensate Storage

Vessel with

Emissions greater

than NSPS Cutoff of

6 tpy

0 ‐ 1 0.038 228 0 589 0 547 0 632 0 

1 ‐ 2 0.168 125 0 324 0 301 0 348 0 

2 ‐ 4 0.318 233 0 601 0 559 0 646 0 

4 ‐ 6 0.573 275 0 710 0 661 0 763 0 

6 ‐ 8 0.82 230 0 594 0 552 0 637 0 

8 ‐ 10 1.04 188 0 487 0 453 0 523 0 

10 ‐ 12 1.37 146 0 378 0 352 0 406 0 

12 ‐ 15 1.53 202 0 523 0 486 0 561 0 

15 ‐ 20 2.10 272 0 703 0 653 0 755 0 

20 ‐ 25 3.32 242 0 625 0 582 0 671 0 

25 ‐ 30 3.85 191 0 492 0 458 0 529 0 

30 ‐ 40 5.33 333 0 860 0 800 0 923 0 

40 ‐ 50 7.59 268 268 693 693 644 644 744 744 

50 ‐ 100 11.7 966 966 2,496 2,496 2,321 2,321 2,680 2,680 

100 ‐ 200 25.4 1,364 1,364 3,524 3,524 3,277 3,277 3,784 3,784 

200 ‐ 400 49.8 971 971 2,509 2,509 2,333 2,333 2,694 2,694 

400 ‐ 800 92.3 418 418 1,080 1,080 1,005 1,005 1,160 1,160 

800 ‐ 1600 142 125 125 322 322 300 300 346 346 

1600 ‐ 3200 311 25 25 64 64 59 59 69 69 

3200 ‐ 6400 490 13 13 35 35 32 32 37 37 

6400 ‐ 12800 1,864 2 2 4 4 4 4 5 5

> 12800b N/A0 0 0 0 0 0 0 0 

Total 6,816 4,151 17,613 10,727 16,379 9,975 18,913 11,519 

Total number of new oil tanks installed between August 23, 2011, and Octob

Total number of new oil tanks subject to NSPS (VOC emissions greate

a Uncontrolled VOC emissions presented in Table 4.bNumber of new storage vessels installed each year across production rate brackets (see Table 3).cThere are no new storage vessels projected to be in this bracket

12
13

in the US (according to production information published by the EIA) were analyzed. These 

States were Alaska, California, Colorado, Kansas, Louisiana, Montana, North Dakota, New 

Mexico, Oklahoma, Texas and Wyoming. Table 7 presents the oil and condensate production 

for each of these 11 States (for which data were available), as well as the percent of total 

production.

Table 8 presents a brief summary of the storage vessel regulations from these 11 States. Two 

States, New Mexico and Alaska, do not have regulations specific to storage vessels. Four States 

(Colorado, Montana, Texas, and Wyoming) have applicability thresholds in terms of VOC 

emissions. The remaining five States have storage vessel regulations that are in terms of tank 

characteristics, such as vapor pressure, tank size, or tank contents. 

Because the NSPS applicability threshold is in terms of VOC emissions, only the States with 

applicability thresholds in terms of VOC emissions (Colorado, Montana, Texas, and Wyoming) 

were used to determine what percent of storage vessels were already subject to and controlled 

under State regulations. We applied the distribution of storage vessels within each production 

rate bracket for each State to the total number of new storage vessels for 2009 (see 

Attachment 3). We then calculated how many storage vessels in Colorado, Montana, Texas, and 

Wyoming would have VOC emissions greater than the NSPS applicability threshold of 6 tpy. 

Table 9 presents a summary of this analysis. As shown in Table 9, 30 percent of the crude oil 

storage vessels and 78 percent of the condensate storage vessels in Colorado, Montana, Texas, 

and Wyoming would be subject to both the NSPS and State regulations.

In order to estimate the number of storage vessels subject to both NSPS and State regulations 

in States that did not have applicability thresholds in terms of VOC emissions, we assumed that 

these applicability thresholds would be equivalent to the VOC emission thresholds in Colorado, 

Montana, Texas, and Wyoming. Therefore, we applied the percent of storage vessels subject to 

both NSPS and State regulations calculated for Colorado, Montana, Texas, and Wyoming (i.e., 

30 percent for crude oil storage vessels and 78 percent for condensate storage vessels) to the 

number of storage vessels in five States (California, Kansas, Louisiana, North Dakota, and 

Oklahoma) to determine the total number of storage vessels that would be subject to State 

regulations. This calculation is presented in Table 10. 

Finally, we estimated the percent of storage vessels from all 11 States that would be subject to 

both State regulations and the NSPS. This calculation is presented in Table 11. As shown in 

Table 11, 22 percent of crude oil storage vessels and 73 percent of condensate storage vessels 

in the top 11 oil and condensate producing States would be subject to both the NSPS and State 

regulations. 
 14

Table 7. Oil and Condensate Production by State

State

2009 Crude Oil 

Production 

(106 bbl/yr)a

2009 

Condensate 

Production 

(106

 bbl/yr)a

2009 Combined Oil 

and Condensate 

Production

(106 bbl/yr)

Percent of 

total US 

production

Cumulative 

Percent of 

Total US 

Production

Percent of Total 

US New Oil 

Wellsb

Percent of 

Total US New 

Gas Wellsb

TX 325 75 400 30.1% 30% 22.8% 33.2%

AK 141 94 235 17.7% 48% 0.899% 0.360%

CA 203 4 207 15.6% 63% 16.5% 0.878%

ND 78 1 79 5.94% 69% 10.4% 0.022%

LA 53 15 68 5.11% 74% 2.35% 4.49%

NM 50 11 61 4.59% 79% 14.7% 6.73%

OK 43 17 60 4.51% 83% 5.35% 5.70%

WY 35 16 51 3.83% 87% 0.86% 11.5%

KS 39 0 39 2.93% 90% 0.000% 3.54%

CO 16 13 29 2.18% 92% 19.6% 12.7%

MT 28 0 28 2.11% 95% 0.578% 1.70%

Subtotal 1,011 246 1,257 94.51% 94% 81%

MS 23 1 24 1.80% 96% 0% 0%

UT 19 4 23 1.73% 98% 4.54% 3.11%

AL 5 2 7 0.526% 99% 0% 1.07%

MI 5 1 6 0.451% 99% 0% 0%

AR 5 0 5 0.376% 99% 0% 7.57%

OH 3 1 4 0.301% 100% 0% 0%

SD 1 1 2 0.150% 100% 0% 0%

WV 1 0 1 0.075% 100% 0% 0%

FL 1 0 1 0.075% 100% 0% 0%

NE 0 0 0 0% 100% 0% 0%

NV 0 0 0 0% 100% 0% 0%

NY 0 0 0 0% 100% 0% 0%

MO 0 0 0 0% 100% 0% 0%

PA 0 0 0 0% 100% 0% 2.69%

AZ 0 0 0 0% 100% 0% 0%

VA 0 0 0 0% 100% 0% 3.79%

MD 0 0 0 0% 100% 0% 0%

OR 0 0 0 0% 100% 0% 0%

Total 1,074 256 1,330 100% 100% 100% a

 Historical oil and condensate production data published by EIA up until 2009. "Distribution and Production of Oil and Gas Wells by State"

http://www.eia.gov/pub/oil_gas/petrosystem/petrosysog.html

b

 Percent of total US new oil and gas wells within each State calculated from data in HPDI. See Attachments 1 and 3.
15

Table 8. Brief Summary of Storage Vessel Regulations in Top 11 Producing States

State/Local Authoritya Applicability Threshold

Texas Applies to storage vessels with total VOC emissions greater 

than 25 tpy

Alaska none found

California

Bay Area AQMD

Applies to storage vessels with capacity greater than 

264 gallons 

California

Feather River AQMD

Applies to storage vessels with capacity greater than 

39,630 gallons 

California

Monterey Bay Unified 

APCD

Applies to storage vessels with capacity greater than 

39,630 gallons 

California

Sacramento 

Metropolitan AQMD

Applies to storage vessels with capacity greater than 

40,000 gallons 

California

San Joaquin Valley 

Unified APCD

Applies to storage vessels with capacity greater than 1,100 

gallons 

California

Santa Barbara County 

APCD

Applies to all storage vessels in tank battery (including 

wash tanks, produced water tanks, and wastewater tanks)

California

South Coast AQMD

Applies to storage vessels with capacity greater than 

39,630 gallons with a true vapor pressure of 0.5 psia or 

greater and storage vessels with a capacity greater than 

19,815 with a true vapor pressure of 1.5 psia or greater 

California

Ventura County APCD

California

Yolo-Solano AQMD

Applies to storage vessels with capacity greater than 

40,000 gallons 

North Dakota NDAC 33-15-07: submerged filling requirements to control 

VOCs for tanks >1,000 gal.

Louisiana Applies to storage vessels more than 250 gallons up to 

40,000 gallons with a maximum true vapor pressure of 1.5 

psia or greater

New Mexico none found

Oklahoma Applies to storage vessels with capacity greater than 

40,000 gallons 

Applies to storage vessels with capacity between 400 and 

40,000 gallons
Table 8 (continued)

16

State/Local Authoritya Applicability Threshold

Oklahoma

Tulsa County

Applies to storage vessels with capacity between 2,000 

and 40,000 gallons located at a facility that dispenses 

greater than 120,000 gal/yr of gasoline or other VOCs 

Wyoming – Statewide Applies to storage vessels with greater than or equal to 10 

tpy VOC within 60 days of startup/modification.

Wyoming –

Concentrated 

Development Area

Applies to storage vessels with greater than or equal to 8 

tpy VOC, within 60 days of startup/modification.

Wyoming – JonahPinedale Anticline 

Development Area

None

Kansas Permanent fixed roof storage tanks >40,000 gallons and 

external floating roof storage tanks

Colorado Condensate tanks with uncontrolled VOC emissions > 20 

tpy (2 tpy located at gas processing plants in ozone nonattainment areas)

Montana Applies to O&G oil or condensate storage tanks with a PTE 

greater than 15 tpy VOC 
17

Table 9. Number of Crude Oil and Condensate Storage Vessels Subject to State Regulations and NSPS

(States with Applicability Thresholds in Terms of VOC Emissions)

State

Crude Oil Storage Vessels Condensate Storage Vessels

Total Number 

of Crude Oil 

Storage 

Vessels in 

State (2009)

State 

Applicability 

Threshold 

(tpy VOC)

Number of 

Crude Oil 

Storage Vessels 

subject to NSPSa

Number of Crude 

Oil Storage 

Vessels Subject 

to State 

Regulationb

Total Number 

of Condensate 

Storage 

Vessels in 

State (2009)

State 

Applicability 

Threshold 

(tpy VOC)

Number of 

Condensate 

Storage Vessels 

subject to NSPSa

Number of 

Condensate 

Storage Vessels 

Subject to State 

Regulationb

CO 2,130 20 1,206 153 2,251 20 1,414 1,177

MT 63 15 53 19 301 15 11 1

TX 2,472 25 1,594 658 5,874 25 4,526 3,316

WY 93 10 44 30 2,037 10 1,085 1,001

Total 4,758 2,897 860 10,463 7,036 5,495

Percent of Storage Vessels Subject to State Regulations and 

NSPS in each State

30% Percent of Storage Vessels Subject to State 

Regulations and NSPS in each State

78%

a Storage vessels with emissions greater than the NSPS applicability threshold (i.e., 6 tpy). b Storage vessels with emissions greater than the applicability threshold for that State (refer to Attachment 4 for the detailed analysis).
18

Table 10. Number of Crude Oil and Condensate Storage Vessels Subject to State Regulations and NSPS

(States with Applicability Thresholds in Terms of Tank Characteristics)

State

Crude Oil Storage Vessels Condensate Storage Vessels

Total Number of 

Crude Oil Storage

Vessels in State 

(2009)

Number of Crude 

Oil Storage Vessels 

subject to NSPSa

Number of Crude Oil 

Storage Vessels 

Subject to State 

Regulationb

Total Number of 

Condensate Storage 

Vessels in State 

(2009)

Number of Condensate 

Storage Vessels subject 

to NSPSa

Number of Condensate 

Storage Vessels Subject 

to State Regulationb

CA 1,796 841 132 155 104 70

KSa 0 0 0 627 66 35

LA 256 163 37 795 715 554

ND 1,127 1,106 321 4 0 0

OK 581 330 66 1,008 646 467

Total 3,760 2,440 556 2,589 1,531 1,126 a

No data were available for new crude oil wells for Kansas in 2009 (see Attachment 3).
19

Table 11. Percent of Crude Oil and Condensate Storage Vessels in Top 11 Producing States Subject to NSPS and State Regulations

State

Crude Oil Storage Vessels Condensate Storage Vessels

Total Number of 

Crude Oil Storage 

Vessels in State 

(2009)

Number of Crude 

Oil Storage Vessels 

subject to NSPSa

Number of Crude Oil 

Storage Vessels 

Subject to State 

Regulationb

Total Number of 

Condensate Storage 

Vessels in State (2009)

Number of Condensate 

Storage Vessels subject 

to NSPSa

Number of Condensate 

Storage Vessels Subject

to State Regulationb

AK 98 98 0 64 61 0

CA 1,796 841 132 155 104 70

CO 2,130 1,206 153 2,251 1,414 1,177

KS 0 0 0 627 66 35

LA 256 163 37 795 715 554

MT 63 53 19 301 11 1

ND 1,127 1,106 321 4 0 0

NM 1,598 894 0 1,191 431 0

OK 581 330 66 1,008 646 467

TX 2,472 1,594 658 5,874 4,526 3,316

WY 93 44 30 2,037 1,085 1,001

Total 10,214 6,329 1,416 14,307 9,059 6,621

Percent of Crude Oil Storage Vessels in Top 11 

Producing States subject to both NSPS and 

State Regulations

22% Percent of Condensate Storage Vessels in Top 11 

Producing States subject to both NSPS and State 

Regulations

73%

a Storage vessels with emissions greater than the lowest State applicability threshold (i.e., 10 tpy).

b Storage vessels with emissions greater than the applicability threshold for that State (refer to Attachment 4 for the detailed analysis).
20

On an nationwide basis, storage vessels could be subject to other regulations, such as the 

national emissions standards for hazardous air pollutants (NESHAP) for oil and natural gas 

production (40 CFR part 63, subpart HH), part 70 operating permit program, prevention of 

significant deterioration (PSD), other State regulations outside of the top 11 producing States, 

and voluntary reductions. These percentages were then extrapolated to the nationwide storage

vessel population, assuming that the same percentages of storage vessels would be subject to 

some sort of regulation absent the NSPS. Attachment 4 shows the detailed calculation.

Step 8. Subtract the number of storage vessels subject to and controlled under State

environmental regulations from the number storage vessels with VOC emissions 

greater than 6 tpy to determine the number of storage vessels that would be 

subject to the NSPS.

The number of storage vessels subject to State regulations, identified in Step 7, was then 

subtracted from the overall count of storage vessels that would be subject to the final rule.

Tables 12 and 13 show the total number of new crude oil and condensate storage vessels that 

would be installed and would be subject to the NSPS from August 23, 2011 (the date upon 

which new, modified or reconstructed storage vessels become affected facilities under the 

NSPS), until October 15, 2015. As shown in Table 12, approximately 36,000 new oil storage 

vessels that would be subject to the NSPS expected to be installed during this period. This is an 

average of approximately 8,700 crude oil storage vessels per year, or about 720 per month. 

Table 13 shows that between approximately 14,000 new condensate storage vessels subject to 

the NSPS are expected to be installed between August 23, 2011 and October 15, 2015. This is 

an average of about 3,400 condensate storage vessels per year, or about 290 per month. 

Attachment 5 contains a sample calculation for 2011.
Table 12. Number of Oil Tanks Subject to the NSPS after Considering State Regulationsa

2011 (from 08/23/2011 until 12/31/2011)

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions per New Oil

Storage Vessel (tpy)

Total Number of New

Oil Storage Vessels

per Rate Class (see

Table 2)

Number of Oil Storage

Vessels with Emissions

greater than NSPS Cutoff

of 6 tpy (see Table 5)

Number of Oil

Storage Vessels

Subject to State

Regulationb

Number of New

Oil Storage

Vessels Subject to

NSPSc

0 ‐ 1 0.083 42 0 0 0

1 ‐ 2 0.287 62 0 0 0

2 ‐ 4 0.570 151 0 0 0

4 ‐ 6 0.953 153 0 0 0

6 ‐ 8 1.33 194 0 0 0

8 ‐ 10 1.73 187 0 0 0

10 ‐ 12 2.11 190 0 0 0

12 ‐ 15 2.59 298 0 0 0

15 ‐ 20 3.31 516 0 0 0

20 ‐ 25 4.27 518 0 0 0

25 ‐ 30 5.22 496 0 0 0

30 ‐ 40 6.54 756 756 0 756

40 ‐ 50 8.41 471 471 0 471

50 ‐ 100 13.2 1,015 1,015 227 788

100 ‐ 200 25.6 773 773 173 600

200 ‐ 400 51.0 450 450 101 349

400 ‐ 800 97.7 155 155 35 121

800 ‐ 1600 196 29 29 7 23

1600 ‐ 3200 363 9 9 2 6

3200 ‐ 6400 719 6 6 1 4

6400 ‐ 12800 1,464 1 1 0 1

> 12800d N/A 0 0 0 0

6,472 3,665 547 3,119

Total number of storage vessels installed =                     35,806

Avg crude oil storage vessels installed per year =                       8,632

Avg crude oil storage vessels installed per month =                           719

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 22 percent of the number of tanks with

emissions greater than 6 tpy (only for storage vessels

with emissions greater than the lowest State

applicability threshold of 10 tpy)

d

There are no new tanks projected to be in this bracket

c

Number of storage vessels subject to State regulations

subtracted from number of tanks with emissions

greater than 6 tpy

21
Table 12. Number of Oil Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions per New Oil

Storage Vessel (tpy)

0 ‐ 1 0.083

1 ‐ 2 0.287

2 ‐ 4 0.570

4 ‐ 6 0.953

6 ‐ 8 1.33

8 ‐ 10 1.73

10 ‐ 12 2.11

12 ‐ 15 2.59

15 ‐ 20 3.31

20 ‐ 25 4.27

25 ‐ 30 5.22

30 ‐ 40 6.54

40 ‐ 50 8.41

50 ‐ 100 13.2

100 ‐ 200 25.6

200 ‐ 400 51.0

400 ‐ 800 97.7

800 ‐ 1600 196

1600 ‐ 3200 363

3200 ‐ 6400 719

6400 ‐ 12800 1,464

> 12800d N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 22 percent of the number of tanks with

emissions greater than 6 tpy (only for storage vessels

with emissions greater than the lowest State

applicability threshold of 10 tpy)

d

There are no new tanks projected to be in this bracket

c

Number of storage vessels subject to State regulations

subtracted from number of tanks with emissions

greater than 6 tpy

2012

Total Number of New

Oil Storage Vessels

per Rate Class (see

Table 2)

Number of Oil Storage

Vessels with Emissions

greater than NSPS Cutoff

of 6 tpy (see Table 5)

Number of Oil

Storage Vessels

Subject to State

Regulationb

Number of New

Oil Storage

Vessels Subject to

NSPS

106 0 0 0

159 0 0 0

384 0 0 0

388 0 0 0

493 0 0 0

476 0 0 0

483 0 0 0

757 0 0 0

1,313 0 0 0

1,317 0 0 0

1,261 0 0 0

1,922 1,922 0 1,922

1,197 1,197 0 1,197

2,581 2,581 578 2,003

1,965 1,965 440 1,525

1,144 1,144 256 888

395 395 89 306

74 74 17 57

22 22 5 17

15 15 4 11

4 4 13

0 0 00

16,456 9,319 1,390 7,929

22
Table 12. Number of Oil Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions per New Oil

Storage Vessel (tpy)

0 ‐ 1 0.083

1 ‐ 2 0.287

2 ‐ 4 0.570

4 ‐ 6 0.953

6 ‐ 8 1.33

8 ‐ 10 1.73

10 ‐ 12 2.11

12 ‐ 15 2.59

15 ‐ 20 3.31

20 ‐ 25 4.27

25 ‐ 30 5.22

30 ‐ 40 6.54

40 ‐ 50 8.41

50 ‐ 100 13.2

100 ‐ 200 25.6

200 ‐ 400 51.0

400 ‐ 800 97.7

800 ‐ 1600 196

1600 ‐ 3200 363

3200 ‐ 6400 719

6400 ‐ 12800 1,464

> 12800d N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 22 percent of the number of tanks with

emissions greater than 6 tpy (only for storage vessels

with emissions greater than the lowest State

applicability threshold of 10 tpy)

d

There are no new tanks projected to be in this bracket

c

Number of storage vessels subject to State regulations

subtracted from number of tanks with emissions

greater than 6 tpy

2013

Total Number of New

Oil Storage Vessels

per Rate Class (see

Table 2)

Number of Oil Storage

Vessels with Emissions

greater than NSPS Cutoff

of 6 tpy (see Table 5)

Number of Oil

Storage Vessels

Subject to State

Regulationb

Number of New

Oil Storage

Vessels Subject to

NSPS

113 0 0 0

169 0 0 0

408 0 0 0

411 0 0 0

523 0 0 0

505 0 0 0

512 0 0 0

804 0 0 0

1,394 0 0 0

1,398 0 0 0

1,338 0 0 0

2,040 2,040 0 2,040

1,271 1,271 0 1,271

2,739 2,739 613 2,126

2,085 2,085 467 1,618

1,214 1,214 272 942

419 419 94 325

79 79 18 61

23 23 6 17

15 15 4 11

4 4 13

0 0 00

17,464 9,889 1,475 8,414

23
Table 12. Number of Oil Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions per New Oil

Storage Vessel (tpy)

0 ‐ 1 0.083

1 ‐ 2 0.287

2 ‐ 4 0.570

4 ‐ 6 0.953

6 ‐ 8 1.33

8 ‐ 10 1.73

10 ‐ 12 2.11

12 ‐ 15 2.59

15 ‐ 20 3.31

20 ‐ 25 4.27

25 ‐ 30 5.22

30 ‐ 40 6.54

40 ‐ 50 8.41

50 ‐ 100 13.2

100 ‐ 200 25.6

200 ‐ 400 51.0

400 ‐ 800 97.7

800 ‐ 1600 196

1600 ‐ 3200 363

3200 ‐ 6400 719

6400 ‐ 12800 1,464

> 12800d N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 22 percent of the number of tanks with

emissions greater than 6 tpy (only for storage vessels

with emissions greater than the lowest State

applicability threshold of 10 tpy)

d

There are no new tanks projected to be in this bracket

c

Number of storage vessels subject to State regulations

subtracted from number of tanks with emissions

greater than 6 tpy

2014

Total Number of New

Oil Storage Vessels

per Rate Class (see

Table 2)

Number of Oil Storage

Vessels with Emissions

greater than NSPS Cutoff

of 6 tpy (see Table 5)

Number of Oil

Storage Vessels

Subject to State

Regulationb

Number of New

Oil Storage

Vessels Subject to

NSPS

119 0 0 0

179 0 0 0

433 0 0 0

437 0 0 0

555 0 0 0

536 0 0 0

544 0 0 0

853 0 0 0

1,479 0 0 0

1,483 0 0 0

1,420 0 0 0

2,165 2,165 0 2,165

1,348 1,348 0 1,348

2,906 2,906 651 2,255

2,212 2,212 495 1,717

1,289 1,289 289 1,000

444 444 100 344

84 84 19 65

24 24 6 18

16 16 4 12

4 4 13

0 0 00

18,530 10,492 1,565 8,927

24
Table 12. Number of Oil Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions per New Oil

Storage Vessel (tpy)

0 ‐ 1 0.083

1 ‐ 2 0.287

2 ‐ 4 0.570

4 ‐ 6 0.953

6 ‐ 8 1.33

8 ‐ 10 1.73

10 ‐ 12 2.11

12 ‐ 15 2.59

15 ‐ 20 3.31

20 ‐ 25 4.27

25 ‐ 30 5.22

30 ‐ 40 6.54

40 ‐ 50 8.41

50 ‐ 100 13.2

100 ‐ 200 25.6

200 ‐ 400 51.0

400 ‐ 800 97.7

800 ‐ 1600 196

1600 ‐ 3200 363

3200 ‐ 6400 719

6400 ‐ 12800 1,464

> 12800d N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 22 percent of the number of tanks with

emissions greater than 6 tpy (only for storage vessels

with emissions greater than the lowest State

applicability threshold of 10 tpy)

d

There are no new tanks projected to be in this bracket

c

Number of storage vessels subject to State regulations

subtracted from number of tanks with emissions

greater than 6 tpy

2015 (from 01/01/2015 until 10/15/2015)

Total Number of New

Oil Storage Vessels

per Rate Class (see

Table 2)

Number of Oil Storage

Vessels with Emissions

greater than NSPS Cutoff

of 6 tpy (see Table 5)

Number of Oil

Storage Vessels

Subject to State

Regulationb

Number of New

Oil Storage

Vessels Subject to

NSPS

99 0 0 0

149 0 0 0

359 0 0 0

362 0 0 0

462 0 0 0

445 0 0 0

451 0 0 0

708 0 0 0

1,229 0 0 0

1,232 0 0 0

1,179 0 0 0

1,798 1,798 0 1,798

1,120 1,120 0 1,120

2,414 2,414 540 1,874

1,838 1,838 412 1,426

1,071 1,071 240 831

370 370 83 286

69 69 16 53

20 20 5 16

13 13 3 10

4 4 22

0 0 00

15,394 8,718 1,301 7,417

25
Table 13. Number of Condensate Tanks Subject to the NSPS after Considering State Regulationsa

2011 (from 08/23/2011 until 12/31/2011)

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions  per

Condensate Storage

Vessel (tpy)

Total Number of New

Condensate Storage

Vessel per Rate Class

(see Table 3)

Number of Condensate

Storage Vessels with

Emissions greater than

NSPS Cutoff of 6 tpy

(see Table 6)

Number of

Condensate Storage

Vessels Subject to

State Regulationb

Number of New

Condensate

Storage Vessels

Subject to NSPSc

0 ‐ 1 0.038 228 0 0 0

1 ‐ 2 0.168 125 0 0 0

2 ‐ 4 0.318 233 0 0 0

4 ‐ 6 0.573 275 0 0 0

6 ‐ 8 0.825 230 0 0 0

8 ‐ 10 1.04 188 0 0 0

10 ‐ 12 1.37 146 0 0 0

12 ‐ 15 1.53 202 0 0 0

15 ‐ 20 2.10 272 0 0 0

20 ‐ 25 3.32 242 0 0 0

25 ‐ 30 3.85 191 0 0 0

30 ‐ 40 5.33 333 0 0 0

40 ‐ 50 7.59 268 268 0 268

50 ‐ 100 11.7 966 966 706 260

100 ‐ 200 25.4 1,364 1,364 997 367

200 ‐ 400 49.8 971 971 710 261

400 ‐ 800 92.3 418 418 306 112

800 ‐ 1600 142 125 125 92 33

1600 ‐ 3200 311 25 25 18 6

3200 ‐ 6400 490 13 13 10 3

6400 ‐ 12800 1,864 2 2 1 0

> 12800b N/A 0 0 0 0

6,816 4,151 2,839 1,312

Total number of storage vessels installed =                      14,145

Avg condensate storage vessels installed per year =                        3,410

Avg condensate storage vessels installed per month =                           284

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 73 percent of the number of tanks

with emissions greater than 6 tpy (only for storage

vessels with emissions greater than the lowest State

applicability threshold of 10 tpy)

c

Number of storage vessels subject to State

regulations subtracted from number of tanks with

emissions greater than 6 tpy

d

There are no new tanks projected to be in this

bracket

26
Table 13. Number of Condensate Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions  per

Condensate Storage

Vessel (tpy)

0 ‐ 1 0.038

1 ‐ 2 0.168

2 ‐ 4 0.318

4 ‐ 6 0.573

6 ‐ 8 0.825

8 ‐ 10 1.04

10 ‐ 12 1.37

12 ‐ 15 1.53

15 ‐ 20 2.10

20 ‐ 25 3.32

25 ‐ 30 3.85

30 ‐ 40 5.33

40 ‐ 50 7.59

50 ‐ 100 11.7

100 ‐ 200 25.4

200 ‐ 400 49.8

400 ‐ 800 92.3

800 ‐ 1600 142

1600 ‐ 3200 311

3200 ‐ 6400 490

6400 ‐ 12800 1,864

> 12800b N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 73 percent of the number of tanks

with emissions greater than 6 tpy (only for storage

vessels with emissions greater than the lowest State

applicability threshold of 10 tpy)

c

Number of storage vessels subject to State

regulations subtracted from number of tanks with

emissions greater than 6 tpy

d

There are no new tanks projected to be in this

bracket

2012

Total Number of New

Condensate Storage

Vessel per Rate Class

(see Table 3)

Number of Condensate

Storage Vessels with

Emissions greater than

NSPS Cutoff of 6 tpy

(see Table 6)

Number of

Condensate Storage

Vessels Subject to

State Regulationb

Number of New

Condensate

Storage Vessels

Subject to NSPSc

589 0 0 0

324 0 0 0

601 0 0 0

710 0 0 0

594 0 0 0

487 0 0 0

378 0 0 0

523 0 0 0

703 0 0 0

625 0 0 0

492 0 0 0

860 0 0 0

693 693 0 693

2,496 2,496 1,825 671

3,524 3,524 2,576 948

2,509 2,509 1,834 675

1,080 1,080 790 290

322 322 236 86

64 64 47 17

35 35 26 9

4 4 31

0 0 00

17,613 10,727 7,337 3,390

27
Table 13. Number of Condensate Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions  per

Condensate Storage

Vessel (tpy)

0 ‐ 1 0.038

1 ‐ 2 0.168

2 ‐ 4 0.318

4 ‐ 6 0.573

6 ‐ 8 0.825

8 ‐ 10 1.04

10 ‐ 12 1.37

12 ‐ 15 1.53

15 ‐ 20 2.10

20 ‐ 25 3.32

25 ‐ 30 3.85

30 ‐ 40 5.33

40 ‐ 50 7.59

50 ‐ 100 11.7

100 ‐ 200 25.4

200 ‐ 400 49.8

400 ‐ 800 92.3

800 ‐ 1600 142

1600 ‐ 3200 311

3200 ‐ 6400 490

6400 ‐ 12800 1,864

> 12800b N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 73 percent of the number of tanks

with emissions greater than 6 tpy (only for storage

vessels with emissions greater than the lowest State

applicability threshold of 10 tpy)

c

Number of storage vessels subject to State

regulations subtracted from number of tanks with

emissions greater than 6 tpy

d

There are no new tanks projected to be in this

bracket

2013

Total Number of New

Condensate Storage

Vessel per Rate Class

(see Table 3)

Number of Condensate

Storage Vessels with

Emissions greater than

NSPS Cutoff of 6 tpy

(see Table 6)

Number of

Condensate Storage

Vessels Subject to

State Regulationb

Number of New

Condensate

Storage Vessels

Subject to NSPSc

432 0 0 0

238 0 0 0

441 0 0 0

522 0 0 0

436 0 0 0

357 0 0 0

278 0 0 0

383 0 0 0

515 0 0 0

459 0 0 0

361 0 0 0

631 0 0 0

508 508 0 508

1,831 1,831 1,339 492

2,586 2,586 1,890 696

1,841 1,841 1,345 496

793 793 580 213

237 237 174 63

47 47 35 12

25 25 19 6

3 3 21

0 0 00

12,924 7,871 5,384 2,487

28
Table 13. Number of Condensate Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions  per

Condensate Storage

Vessel (tpy)

0 ‐ 1 0.038

1 ‐ 2 0.168

2 ‐ 4 0.318

4 ‐ 6 0.573

6 ‐ 8 0.825

8 ‐ 10 1.04

10 ‐ 12 1.37

12 ‐ 15 1.53

15 ‐ 20 2.10

20 ‐ 25 3.32

25 ‐ 30 3.85

30 ‐ 40 5.33

40 ‐ 50 7.59

50 ‐ 100 11.7

100 ‐ 200 25.4

200 ‐ 400 49.8

400 ‐ 800 92.3

800 ‐ 1600 142

1600 ‐ 3200 311

3200 ‐ 6400 490

6400 ‐ 12800 1,864

> 12800b N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 73 percent of the number of tanks

with emissions greater than 6 tpy (only for storage

vessels with emissions greater than the lowest State

applicability threshold of 10 tpy)

c

Number of storage vessels subject to State

regulations subtracted from number of tanks with

emissions greater than 6 tpy

d

There are no new tanks projected to be in this

bracket

2014

Total Number of New

Condensate Storage

Vessel per Rate Class

(see Table 3)

Number of Condensate

Storage Vessels with

Emissions greater than

NSPS Cutoff of 6 tpy

(see Table 6)

Number of

Condensate Storage

Vessels Subject to

State Regulationb

Number of New

Condensate

Storage Vessels

Subject to NSPSc

614 0 0 0

338 0 0 0

628 0 0 0

741 0 0 0

619 0 0 0

508 0 0 0

395 0 0 0

545 0 0 0

733 0 0 0

652 0 0 0

514 0 0 0

897 0 0 0

723 723 0 723

2,604 2,604 1,904 701

3,677 3,677 2,688 989

2,618 2,618 1,913 705

1,127 1,127 824 303

336 336 246 90

67 67 50 17

36 36 27 9

5 5 41

0 0 00

18,378 11,193 7,655 3,538

29
Table 13. Number of Condensate Tanks Subject to the NSPS after Considering State Regulationsa

Production Rate Bracket

(BOE/day)

Uncontrolled VOC

Emissions  per

Condensate Storage

Vessel (tpy)

0 ‐ 1 0.038

1 ‐ 2 0.168

2 ‐ 4 0.318

4 ‐ 6 0.573

6 ‐ 8 0.825

8 ‐ 10 1.04

10 ‐ 12 1.37

12 ‐ 15 1.53

15 ‐ 20 2.10

20 ‐ 25 3.32

25 ‐ 30 3.85

30 ‐ 40 5.33

40 ‐ 50 7.59

50 ‐ 100 11.7

100 ‐ 200 25.4

200 ‐ 400 49.8

400 ‐ 800 92.3

800 ‐ 1600 142

1600 ‐ 3200 311

3200 ‐ 6400 490

6400 ‐ 12800 1,864

> 12800b N/A

a Only storage vessels installed from 08/23/2011 until

10/15/2015 that would be subject to the NSPS are

included in this table.

b

Calculated as 73 percent of the number of tanks

with emissions greater than 6 tpy (only for storage

vessels with emissions greater than the lowest State

applicability threshold of 10 tpy)

c

Number of storage vessels subject to State

regulations subtracted from number of tanks with

emissions greater than 6 tpy

d

There are no new tanks projected to be in this

bracket

2015 (from 01/01/2015 until 10/15/2015)

Total Number of New

Condensate Storage

Vessel per Rate Class

(see Table 3)

Number of Condensate

Storage Vessels with

Emissions greater than

NSPS Cutoff of 6 tpy

(see Table 6)

Number of

Condensate Storage

Vessels Subject to

State Regulationb

Number of New

Condensate

Storage Vessels

Subject to NSPSc

674 0 0 0

371 0 0 0

688 0 0 0

814 0 0 0

679 0 0 0

558 0 0 0

433 0 0 0

599 0 0 0

805 0 0 0

716 0 0 0

564 0 0 0

984 0 0 0

793 793 465 328

2,858 2,858 2,089 769

4,035 4,035 2,949 1,086

2,873 2,873 2,100 773

1,237 1,237 905 332

369 369 270 99

74 74 54 20

39 39 29 10

5 5 41

0 0 00

20,168 12,284 8,866 3,418

30
ATTACHMENT 1

US Distribution of Wells by Production Rate Bracket
Home > Petroleum > Distribution and Production of Oil and Gas Wells by State > United States Total Distribution of Wells by Production Rate Bracket

United States Total 2009

Distribution of Wells by Production Rate Bracket

Oil Wells Gas Wells

Prod.

Rate

Bracket

(BOE/Day)

|

|

|

|

# of

Oil

Wells

% of

Oil

Wells

Annual

Oil

Prod.

(MMbbl)

% of

Oil

Prod.

Oil

Rate

per Well

(bbl/Day)

Annual

Gas

Prod.

(Bcf)

Gas

Rate

per Well

(Mcf/Day)

|

|

|

|

# of

Gas

Wells

% of

Gas

Wells

Annual

Gas

Prod.

(Bcf)

% of

Gas

Prod.

Gas

Rate

per Well

(Mcf/Day)

Annual

Oil

Prod.

(MMbbl)

Oil

Rate

per Well

(bbl/Day)

0 - 1 | 127,734 35.1 15.4 0.9 0.4 4.8 0.1 | 91,005 19.7 73.4 0.3 2.4 0.7 0.0

1 - 2 | 45,649 12.6 21.8 1.3 1.4 9.5 0.6 | 45,034 9.8 131.1 0.5 8.3 1.3 0.1

2 - 4 | 47,803 13.2 45.3 2.8 2.7 22.3 1.3 | 60,930 13.2 358.3 1.5 16.6 3.6 0.2

4 - 6 | 27,625 7.6 43.6 2.7 4.4 29.4 3.0 | 43,009 9.3 428.4 1.8 28.0 4.4 0.3

6 - 8 | 21,816 6.0 48.3 2.9 6.2 36.7 4.7 | 32,564 7.1 457.8 1.9 39.4 4.5 0.4

8 - 10 | 15,482 4.3 42.9 2.6 7.7 40.0 7.2 | 24,829 5.4 451.1 1.9 50.8 4.3 0.5

Subtotal <=10 | 286,109 78.7 217.3 13.2 2.2 142.7 1.4 | 297,371 64.5 1,900.0 7.9 18.3 18.8 0.2

10 - 12 | 12,642 3.5 43.8 2.7 9.7 33.5 7.4 | 18,967 4.1 420.5 1.8 62.1 4.1 0.6

12 - 15 | 11,801 3.2 50.3 3.1 11.9 37.3 8.8 | 21,718 4.7 591.1 2.5 76.2 5.7 0.7

Subtotal <=15 | 310,552 85.4 311.5 19.0 2.9 213.6 2.0 | 338,056 73.3 2,911.7 12.2 24.6 28.6 0.2

15 - 20 | 13,895 3.8 75.1 4.6 15.2 60.8 12.3 | 23,974 5.2 841.3 3.5 98.5 7.7 0.9

20 - 25 | 8,157 2.2 56.6 3.4 19.6 46.2 16.1 | 16,539 3.6 744.2 3.1 126.5 7.5 1.3

25 - 30 | 6,276 1.7 52.3 3.2 23.7 46.5 21.1 | 11,638 2.5 644.9 2.7 156.7 5.1 1.2

30 - 40 | 7,207 2.0 75.3 4.6 30.0 69.0 27.5 | 16,083 3.5 1,122.3 4.7 197.4 9.5 1.7

40 - 50 | 3,684 1.0 49.0 3.0 39.1 42.1 33.5 | 9,959 2.2 895.6 3.7 255.6 7.1 2.0

50 - 100 | 7,934 2.2 159.7 9.7 59.4 171.4 63.7 | 22,546 4.9 3,156.6 13.2 402.7 22.4 2.9

100 - 200 | 3,070 0.8 119.1 7.3 118.3 115.9 115.1 | 13,444 2.9 3,520.4 14.7 782.4 30.8 6.8

200 - 400 | 1,469 0.4 109.9 6.7 233.9 122.3 260.3 | 5,528 1.2 2,572.2 10.7 1,545.1 22.3 13.4

400 - 800 | 663 0.2 92.3 5.6 447.9 128.5 623.6 | 2,038 0.4 1,708.3 7.1 3,007.9 22.2 39.0

800 - 1600 | 264 0.1 77.8 4.7 900.8 114.4 1,325.0 | 816 0.2 1,342.4 5.6 6,039.3 25.0 112.6

1600 - 3200 | 145 0.0 86.8 5.3 1,770.4 121.8 2,485.6 | 460 0.1 1,633.2 6.8 11,907.5 35.8 261.0

3200 - 6400 | 66 0.0 88.1 5.4 3,950.0 92.9 4,167.6 | 247 0.1 1,913.3 8.0 22,917.6 46.1 552.0

6400 - 12800 | 47 0.0 112.4 6.8 7,428.9 132.1 8,729.2 | 51 0.0 725.3 3.0 46,468.5 9.9 635.0

> 12800 | 30 0.0 176.5 10.7 18,162.2 136.8 14,083.1 | 9 0.0 227.5 0.9 84,081.9 3.3 1,204.3

Total | 363,459 100.0 1,642.3 100.0 12.9 1,614.4 12.7 | 461,388 100.0 23,959.1 100.0 148.5 283.2 1.8

Notes:

1) State Government agencies and commercial sources provided base data.

2) This U.S. total does not include pre-2003 oil wells from NY, post-2004 wells from PA, 2009 wells from KY, most post-2005 TN wells, and all wells from IL and IN.

3) The Reserves and Production Division, Office of Oil and Gas, EIA has reviewed and edited inaccurate production data.

4) To be consistent between states a GOR of 6,000 (cf/bbl) for each years production was used to classify wells.

 If the GOR was less than 6,000 (cf/bbl) the well was classed an oil well, greater than or equal 6,000 (cf/bbl) were gas wells.

5) To determine production rate brackets for the first and last year of a wells life the annual production was divided

 by the number of days in the productive months. For other years the annual production was divided by 365 or 366 days.

6) Gas volumes have been converted from the various state pressure bases to the Federal base (14.73 psia).

 29DEC10



http://www.eia.gov/pub/oil_gas/petrosystem/us_table.html

1 of 15 3/29/2013 4:06 PM

ATTACHMENT 1 

US Distribution of Wells by Production Rate Bracket 

Page 1
United States Total 2008

Distribution of Wells by Production Rate Bracket

Oil Wells Gas Wells

Prod.

Rate

Bracket

(BOE/Day)

|

|

|

|

# of

Oil

Wells

% of

Oil

Wells

Annual

Oil

Prod.

(MMbbl)

% of

Oil

Prod.

Oil

Rate

per Well

(bbl/Day)

Annual

Gas

Prod.

(Bcf)

Gas

Rate

per Well

(Mcf/Day)

|

|

|

|

# of

Gas

Wells

% of

Gas

Wells

Annual

Gas

Prod.

(Bcf)

% of

Gas

Prod.

Gas

Rate

per Well

(Mcf/Day)

Annual

Oil

Prod.

(MMbbl)

Oil

Rate

per Well

(bbl/Day)

0 - 1 | 129,760 35.2 15.8 1.0 0.3 4.9 0.1 | 102,698 21.3 78.5 0.3 2.2 0.7 0.0

1 - 2 | 45,543 12.3 22.1 1.5 1.4 9.5 0.6 | 48,363 10.0 143.4 0.6 8.3 1.4 0.1

2 - 4 | 48,890 13.2 46.7 3.1 2.7 22.7 1.3 | 63,897 13.3 378.1 1.6 16.6 3.7 0.2

4 - 6 | 27,976 7.6 44.5 2.9 4.4 29.1 2.9 | 44,401 9.2 444.3 1.9 28.0 4.3 0.3

6 - 8 | 20,663 5.6 45.8 3.0 6.2 34.1 4.6 | 33,061 6.9 466.9 2.0 39.6 4.3 0.4

8 - 10 | 17,214 4.7 47.2 3.1 7.6 45.8 7.4 | 24,957 5.2 452.6 1.9 50.8 4.3 0.5

Subtotal <=10 | 290,046 78.6 222.2 14.7 2.1 146.1 1.4 | 317,377 65.8 1,963.9 8.2 17.4 18.7 0.2

10 - 12 | 12,627 3.4 44.0 2.9 9.7 32.7 7.2 | 19,395 4.0 430.5 1.8 62.3 4.1 0.6

12 - 15 | 12,236 3.3 52.0 3.4 11.9 37.6 8.6 | 21,272 4.4 577.2 2.4 76.5 5.2 0.7

Subtotal <=15 | 314,909 85.3 318.1 21.1 2.8 216.4 1.9 | 358,044 74.3 2,971.6 12.5 23.4 28.0 0.2

15 - 20 | 14,036 3.8 76.2 5.0 15.4 57.6 11.6 | 24,097 5.0 837.5 3.5 98.6 7.5 0.9

20 - 25 | 8,729 2.4 60.9 4.0 19.9 48.2 15.7 | 16,136 3.3 719.4 3.0 126.6 7.0 1.2

25 - 30 | 6,389 1.7 53.3 3.5 24.1 42.7 19.2 | 11,312 2.3 616.6 2.6 156.2 5.3 1.3

30 - 40 | 7,118 1.9 72.7 4.8 30.0 65.0 26.8 | 15,166 3.1 1,033.3 4.3 197.5 9.0 1.7

40 - 50 | 4,098 1.1 53.9 3.6 39.2 43.3 31.5 | 9,910 2.1 864.5 3.6 255.3 7.4 2.2

50 - 100 | 8,167 2.2 160.2 10.6 59.1 166.0 61.3 | 22,566 4.7 3,010.4 12.6 404.5 22.6 3.0

100 - 200 | 3,082 0.8 115.5 7.6 117.9 114.4 116.8 | 14,824 3.1 3,520.4 14.8 782.4 33.1 7.4

200 - 400 | 1,349 0.4 97.0 6.4 229.3 117.3 277.2 | 6,367 1.3 2,726.2 11.4 1,549.4 23.2 13.2

400 - 800 | 692 0.2 98.9 6.5 446.2 132.5 598.1 | 2,159 0.4 1,697.2 7.1 3,010.3 23.5 41.8

800 - 1600 | 294 0.1 82.0 5.4 873.9 129.1 1,375.5 | 754 0.2 1,251.2 5.3 5,858.1 24.5 114.6

1600 - 3200 | 147 0.0 87.3 5.8 1,725.3 130.1 2,572.1 | 425 0.1 1,540.4 6.5 11,723.5 37.1 282.0

3200 - 6400 | 63 0.0 79.9 5.3 3,759.0 95.2 4,477.6 | 248 0.1 1,932.3 8.1 22,992.3 44.8 532.5

6400 - 12800 | 42 0.0 93.4 6.2 7,301.6 102.9 8,045.8 | 63 0.0 977.6 4.1 44,276.1 19.3 872.2

> 12800 | 13 0.0 60.8 4.0 15,461.2 50.9 12,937.3 | 5 0.0 126.7 0.5 76,859.0 3.0 1,826.8

Total | 369,128 100.0 1,510.2 100.0 11.5 1,511.6 11.6 | 482,076 100.0 23,825.2 100.0 141.4 295.1 1.8

Notes:

1) State Government agencies and commercial sources provided base data.

2) This U.S. total does not include pre-2003 oil wells from NY, post-2004 wells from PA, 2009 wells from KY, most post-2005 TN wells, and all wells from IL and IN.

3) The Reserves and Production Division, Office of Oil and Gas, EIA has reviewed and edited inaccurate production data.

4) To be consistent between states a GOR of 6,000 (cf/bbl) for each years production was used to classify wells.

 If the GOR was less than 6,000 (cf/bbl) the well was classed an oil well, greater than or equal 6,000 (cf/bbl) were gas wells.

5) To determine production rate brackets for the first and last year of a wells life the annual production was divided

 by the number of days in the productive months. For other years the annual production was divided by 365 or 366 days.

6) Gas volumes have been converted from the various state pressure bases to the Federal base (14.73 psia).

 29DEC10

t http://www.eia.gov/pub/oil_gas/petrosystem/us_table.html

2 of 15 3/29/2013 4:06 PM

ATTACHMENT 1 

US Distribution of Wells by Production Rate Bracket 

Page 2
United States Total 2007

Distribution of Wells by Production Rate Bracket

Oil Wells Gas Wells

Prod.

Rate

Bracket

(BOE/Day)

|

|

|

|

# of

Oil

Wells

% of

Oil

Wells

Annual

Oil

Prod.

(MMbbl)

% of

Oil

Prod.

Oil

Rate

per Well

(bbl/Day)

Annual

Gas

Prod.

(Bcf)

Gas

Rate

per Well

(Mcf/Day)

|

|

|

|

# of

Gas

Wells

% of

Gas

Wells

Annual

Gas

Prod.

(Bcf)

% of

Gas

Prod.

Gas

Rate

per Well

(Mcf/Day)

Annual

Oil

Prod.

(MMbbl)

Oil

Rate

per Well

(bbl/Day)

0 - 1 | 126,018 35.2 15.4 1.0 0.3 4.6 0.1 | 89,127 20.0 74.9 0.3 2.4 0.7 0.0

1 - 2 | 43,839 12.2 21.5 1.4 1.4 8.9 0.6 | 45,421 10.2 134.4 0.6 8.3 1.4 0.1

2 - 4 | 47,166 13.2 45.1 2.9 2.7 21.7 1.3 | 59,311 13.3 350.4 1.5 16.6 3.4 0.2

4 - 6 | 27,071 7.6 43.4 2.8 4.5 27.2 2.8 | 41,528 9.3 414.5 1.8 28.0 4.0 0.3

6 - 8 | 20,576 5.7 44.9 2.9 6.1 36.9 5.0 | 31,000 7.0 435.6 1.9 39.5 4.0 0.4

8 - 10 | 15,764 4.4 43.5 2.8 7.7 42.0 7.4 | 24,118 5.4 435.5 1.9 50.9 4.0 0.5

Subtotal <=10 | 280,434 78.3 213.8 13.9 2.1 141.3 1.4 | 290,505 65.2 1,845.4 8.1 17.9 17.5 0.2

10 - 12 | 12,093 3.4 42.4 2.8 9.8 31.9 7.4 | 18,646 4.2 414.1 1.8 62.6 3.5 0.5

12 - 15 | 12,884 3.6 54.4 3.5 11.8 40.5 8.8 | 20,999 4.7 566.3 2.5 76.1 5.4 0.7

Subtotal <=15 | 305,411 85.2 310.6 20.3 2.8 213.7 2.0 | 330,150 74.1 2,825.7 12.4 24.1 26.4 0.2

15 - 20 | 12,843 3.6 70.0 4.6 15.4 51.6 11.3 | 23,001 5.2 798.5 3.5 98.6 7.0 0.9

20 - 25 | 8,874 2.5 62.3 4.1 20.0 45.8 14.7 | 15,189 3.4 674.5 3.0 126.7 6.4 1.2

25 - 30 | 5,946 1.7 50.7 3.3 24.5 37.8 18.2 | 10,654 2.4 579.3 2.6 156.6 4.8 1.3

30 - 40 | 7,963 2.2 83.7 5.5 30.4 79.5 28.8 | 14,328 3.2 973.6 4.3 197.5 8.1 1.6

40 - 50 | 3,988 1.1 53.0 3.5 39.0 45.1 33.2 | 9,133 2.0 791.8 3.5 255.6 6.6 2.1

50 - 100 | 7,813 2.2 157.6 10.3 59.9 155.8 59.3 | 20,656 4.6 2,704.7 11.9 399.8 21.6 3.2

100 - 200 | 2,878 0.8 110.5 7.2 118.6 110.7 118.8 | 13,477 3.0 3,150.5 13.9 769.5 33.1 8.1

200 - 400 | 1,379 0.4 107.1 7.0 234.9 123.5 270.8 | 5,571 1.2 2,379.7 10.5 1,540.7 22.9 14.9

400 - 800 | 668 0.2 96.3 6.3 441.6 140.1 642.9 | 2,073 0.5 1,675.2 7.4 3,013.0 24.3 43.7

800 - 1600 | 279 0.1 79.0 5.1 893.5 114.7 1,298.3 | 822 0.2 1,429.7 6.3 6,002.5 25.6 107.5

1600 - 3200 | 144 0.0 87.3 5.7 1,854.0 126.1 2,677.8 | 408 0.1 1,565.1 6.9 11,841.8 37.3 282.4

3200 - 6400 | 90 0.0 101.0 6.6 3,602.9 135.2 4,822.9 | 243 0.1 1,879.6 8.3 22,930.6 44.6 544.5

6400 - 12800 | 49 0.0 119.9 7.8 7,363.1 163.0 10,013.6 | 88 0.0 1,182.7 5.2 43,664.0 24.2 892.8

> 12800 | 9 0.0 44.5 2.9 14,192.1 53.9 17,205.7 | 3 0.0 89.7 0.4 81,903.3 3.1 2,799.4

Total | 358,334 100.0 1,533.3 100.0 12.0 1,596.6 12.5 | 445,796 100.0 22,700.4 100.0 145.8 296.0 1.9

Notes:

1) State Government agencies and commercial sources provided base data.

2) This U.S. total does not include pre-2003 oil wells from NY, post-2004 wells from PA, 2009 wells from KY, most post-2005 TN wells, and all wells from IL and IN.

3) The Reserves and Production Division, Office of Oil and Gas, EIA has reviewed and edited inaccurate production data.

4) To be consistent between states a GOR of 6,000 (cf/bbl) for each years production was used to classify wells.

 If the GOR was less than 6,000 (cf/bbl) the well was classed an oil well, greater than or equal 6,000 (cf/bbl) were gas wells.

5) To determine production rate brackets for the first and last year of a wells life the annual production was divided

 by the number of days in the productive months. For other years the annual production was divided by 365 or 366 days.

6) Gas volumes have been converted from the various state pressure bases to the Federal base (14.73 psia).

 29DEC10

http://www.eia.gov/pub/oil_gas/petrosystem/us_table.html

3 of 15 3/29/2013 4:06 PM

ATTACHMENT 1 

US Distribution of Wells by Production Rate Bracket 

Page 3
United States Total 2006

Distribution of Wells by Production Rate Bracket

Oil Wells Gas Wells

Prod.

Rate

Bracket

(BOE/Day)

|

|

|

|

# of

Oil

Wells

% of

Oil

Wells

Annual

Oil

Prod.

(MMbbl)

% of

Oil

Prod.

Oil

Rate

per Well

(bbl/Day)

Annual

Gas

Prod.

(Bcf)

Gas

Rate

per Well

(Mcf/Day)

|

|

|

|

# of

Gas

Wells

% of

Gas

Wells

Annual

Gas

Prod.

(Bcf)

% of

Gas

Prod.

Gas

Rate

per Well

(Mcf/Day)

Annual

Oil

Prod.

(MMbbl)

Oil

Rate

per Well

(bbl/Day)

0 - 1 | 126,267 35.4 15.5 1.0 0.3 4.6 0.1 | 86,397 20.3 72.6 0.3 2.4 0.7 0.0

1 - 2 | 42,740 12.0 21.0 1.4 1.4 8.6 0.6 | 43,322 10.2 127.9 0.6 8.3 1.2 0.1

2 - 4 | 47,273 13.3 45.3 2.9 2.7 22.0 1.3 | 56,146 13.2 329.5 1.5 16.5 3.4 0.2

4 - 6 | 27,418 7.7 43.8 2.8 4.5 26.9 2.7 | 38,460 9.1 382.4 1.8 28.0 3.8 0.3

6 - 8 | 18,793 5.3 42.0 2.7 6.2 29.2 4.3 | 29,093 6.8 406.4 1.9 39.4 4.0 0.4

8 - 10 | 14,512 4.1 40.7 2.6 7.8 33.6 6.5 | 22,611 5.3 407.7 1.9 50.9 3.7 0.5

Subtotal <=10 | 277,003 77.7 208.3 13.4 2.1 124.9 1.3 | 276,029 65.0 1,726.4 8.0 17.7 16.9 0.2

10 - 12 | 12,951 3.6 42.7 2.8 9.2 45.5 9.8 | 18,047 4.2 398.3 1.8 62.2 3.7 0.6

12 - 15 | 13,634 3.8 58.1 3.7 11.9 41.9 8.6 | 20,621 4.9 557.2 2.6 76.5 4.9 0.7

Subtotal <=15 | 303,588 85.1 309.1 19.9 2.8 212.4 2.0 | 314,697 74.1 2,681.9 12.4 24.1 25.5 0.2

15 - 20 | 13,519 3.8 74.4 4.8 15.5 52.5 10.9 | 22,928 5.4 792.8 3.7 98.5 7.4 0.9

20 - 25 | 8,428 2.4 59.3 3.8 20.0 43.1 14.5 | 14,823 3.5 659.2 3.0 127.4 5.7 1.1

25 - 30 | 5,846 1.6 50.0 3.2 24.4 35.6 17.3 | 10,561 2.5 570.4 2.6 155.9 4.9 1.3

30 - 40 | 7,209 2.0 75.6 4.9 30.2 63.4 25.3 | 13,631 3.2 926.0 4.3 197.9 7.4 1.6

40 - 50 | 4,792 1.3 62.8 4.1 38.1 60.4 36.7 | 8,753 2.1 754.9 3.5 254.2 6.9 2.3

50 - 100 | 7,687 2.2 153.6 9.9 58.9 181.0 69.4 | 19,159 4.5 2,500.6 11.6 400.3 20.2 3.2

100 - 200 | 2,969 0.8 112.5 7.3 113.4 123.1 124.1 | 11,606 2.7 2,781.3 12.9 795.1 21.5 6.1

200 - 400 | 1,335 0.4 100.8 6.5 233.2 118.2 273.3 | 5,211 1.2 2,346.6 10.9 1,549.5 21.3 14.1

400 - 800 | 601 0.2 89.3 5.8 449.3 109.9 552.8 | 1,859 0.4 1,576.5 7.3 3,043.8 23.6 45.6

800 - 1600 | 253 0.1 74.3 4.8 891.2 112.3 1,346.9 | 814 0.2 1,446.6 6.7 5,991.5 27.9 115.7

1600 - 3200 | 161 0.0 98.6 6.4 1,887.0 137.4 2,628.7 | 452 0.1 1,766.2 8.2 11,948.9 42.1 284.9

3200 - 6400 | 96 0.0 114.0 7.4 3,640.1 150.3 4,799.8 | 228 0.1 1,800.8 8.3 23,391.1 43.5 564.6

6400 - 12800 | 47 0.0 110.4 7.1 7,016.0 150.5 9,565.7 | 55 0.0 837.2 3.9 43,472.2 17.9 931.0

> 12800 | 13 0.0 66.3 4.3 13,969.7 94.5 19,918.6 | 6 0.0 174.1 0.8 81,676.2 6.3 2,954.4

Total | 356,544 100.0 1,551.0 100.0 12.2 1,644.4 13.0 | 424,783 100.0 21,615.0 100.0 145.9 282.1 1.9

Notes:

1) State Government agencies and commercial sources provided base data.

2) This U.S. total does not include pre-2003 oil wells from NY, post-2004 wells from PA, 2009 wells from KY, most post-2005 TN wells, and all wells from IL and IN.

3) The Reserves and Production Division, Office of Oil and Gas, EIA has reviewed and edited inaccurate production data.

4) To be consistent between states a GOR of 6,000 (cf/bbl) for each years production was used to classify wells.

 If the GOR was less than 6,000 (cf/bbl) the well was classed an oil well, greater than or equal 6,000 (cf/bbl) were gas wells.

5) To determine production rate brackets for the first and last year of a wells life the annual production was divided

 by the number of days in the productive months. For other years the annual production was divided by 365 or 366 days.

6) Gas volumes have been converted from the various state pressure bases to the Federal base (14.73 psia).

 29DEC10

http://www.eia.gov/pub/oil_gas/petrosystem/us_table.html

4 of 15 3/29/2013 4:06 PM

ATTACHMENT 1 

US Distribution of Wells by Production Rate Bracket 

Page 4
ATTACHMENT 2

Relative Distribution of Wells within Production Rate Brackets
1 

TO: Heather Brown and David Hendricks, EC/R Incorporated 

FROM: Don Robinson, Eric Stricklin, and Tarang Mehta 

DATE: March 25, 2013 

RE: Liquids Production Distribution for New Oil and Gas Wells in the U.S. 

 

The purpose of this memorandum is to document the development of crude and condensate production distributions 

across certain production rate categories for new oil and gas wells completed in 2009. These distributions will be 

used to estimate the number of new storage tanks impacted by the new source performance standards (NSPS) for 

crude oil and natural gas production, transmission and distribution (40 CFR part 60, subpart OOOO). 

Methodology

ICF used drilling permit data collected by HPDI to develop crude oil and condensate production distributions across 

specific rate categories for new oil and gas wells in 2009. This was done in the following three steps: 

1) Query the HPDI Database for New Wells with a “First Date of Production” in 2009 

2) Sum the Liquids Production for Twelve Consecutive Months since the “First Date of Production” in 2009 

3) Plot the Summed Liquids Production in a Histogram 

HPDI Database 

The crude oil and condensate production data used in this analysis was gathered from drilling permit data collected 

by HPDI. HPDI is a data service company that provides data products and decision-support applications, which was 

acquired by Drilling Info, Inc. HPDI collects drilling permit data from state and local governments describing the 

location, operator, and production characteristics of individual well properties. Henceforth referred to as the “HPDI 

database,” the aggregated drilling permit data is used in this analysis to plot the distribution of crude oil and 

condensate production for new wells in 2009. 

1) Query the HPDI Database for New Wells with a “First Date of Production” in 2009 

In order to construct a distribution of the crude oil and condensate production from new oil and gas wells in 2009, 

ICF first queried the HPDI database for oil and gas wells that were marked with a “first date of production” in 2009. 

ICF defines gas wells in the HPDI database as wells with an average gas to liquids ratio greater than 12,500 standard 

cubic feet per barrel over the lifetime of the well and defines oil wells in the HPDI database as wells with an average 

gas to liquids ratio less than 12,500 standard cubic feet per barrel over the lifetime of the well. This analysis assumes 

that liquids produced from gas wells is condensate and liquids produced from oil wells is crude oil. Finally, not all 

the drilling permits are marked with a “first date of production.” Therefore, for this analysis, the number of new oil 

and gas wells is limited to the number of drilling records with a “first date of production.” 

2) Sum the Liquids Production for Twelve Consecutive Months since the “First Date of Production” 

in 2009 

Second, ICF summed the crude oil volumes for new 2009 oil wells and condensate volumes for new 2009 gas wells 

over 12 months since the “first date of production.” The crude oil and condensate (i.e., liquids) volumes were 

summed over 12 consecutive months since the “first date of production” in 2009 to make the comparison of liquids 

production from one well to another equivalent. For example, if an oil well was completed in March 2009, the well 

would have been producing in 2009 for 10 months, and if an oil well was completed in November 2009, the well 

would have been producing in 2009 for 2 months. It would be unfair to compare the production from these two 

example wells based on their production in 2009 alone. Therefore, this analysis sums the liquids production for each 

oil and gas well over 12 consecutive months. For the example oil well completed in March 2009, this assumption 

ATTACHMENT 2 

Relative Distribution of Wells Within Production Rate Brackets 
2 

would entail summing the crude oil production from March 2009 to March 2010, and for the example crude oil well 

completed in November 2009, it would entail summing the crude oil production from November 2009 to November 

2010. Finally, depending on the source of the production records containing the gas and oil production (e.g., state 

governments) not all the new wells in 2009 had 12 consecutive months of production records. Therefore, the number 

of new oil and gas wells plotted in this analysis is limited to the number of wells with production records for 12 

consecutive months since the “first date of production”. 

3) Plot the Summed Liquids Production in a Histogram 

ICF plotted the number of new oil wells completed in 2009 and the number of new gas wells completed in 2009 on 

two histograms within defined production rate brackets. ICF also developed two tables showing the number of new 

oil wells completed in 2009 and new gas wells completed in 2009 by state within each production rate bracket. 

The production rate brackets in the histograms were developed to align with the production rate brackets from the 

Energy Information Administration (EIA) “Distribution of Wells by Production Rate Bracket.”1

 The production rate 

brackets are defined by barrels of oil equivalent per day (BOE/day), which is based on the approximate energy 

released by burning one barrel of crude oil per day. 

In order to develop the histograms and tables, ICF determined the BOE/day for each oil and gas well by converting 

the natural gas production in thousand cubic feet (Mcf) per oil or gas well to BOE and the condensate production (in 

barrels) per gas well to BOE. These values were converted to BOE/day using conversions from the 2013 EIA 

Annual Energy Outlook. For natural gas the 2013 EIA Annual Energy Outlook assumes 5.66 thousand cubic feet per 

BOE for natural gas and 1.35 barrels per BOE for condensate.2

Results

Exhibit 1 and Exhibit 2 show the production distributions for new oil and gas wells completed in 2009 respectively 

for the entire U.S. Exhibit 3 and Exhibit 4 show the production distributions for new oil and gas wells completed in 

2009 respectively by state. Exhibit 1 through Exhibit 4 include 4,672 new oil wells and 13,977 new gas wells 

respectively, which are new wells marked with a “first date of production” and with 12 consecutive months of 

production records. According to HPDI, the total number of new oil wells and gas wells in 2009 was 4,922 and 

14,930 respectively. Therefore, the histograms represent 94.9% and 93.6% of the national count of new oil wells and 

new gas wells respectively for 2009 according to HPDI. The EIA estimates the total number of development oil 

wells and development gas wells drilled in 2009 was 10,585 and 16,882, respectively.3

 Therefore, the well counts 

from this analysis represent 44.1% and 82.8% of the national count of new oil wells and gas wells respectively for 

2009 according to the EIA. This calculated representation is due to several factors which may include: 

• The wells drilled count reported by the EIA may include wells that are not productive. This analysis 

estimates the total number of new wells including only wells with 12 months of consecutive production 

marked with a “first date of production”. 

• Production data from the HPDI database is collected by property and not per well. Some states submit well 

counts for their properties. However, for those states without well counts for individual properties, ICF has 

assumed one well per property where there is reported oil or gas production. 

• The representativeness of the HPDI database is limited to the state and local governments which have 

collected and provided data that meet the requirements of this analysis. 

Although a fraction of the total number of oil and gas wells in the U.S. is represented in this analysis, the 

distribution of wells in each production rate bracket is assumed to be representative for the U.S. oil and gas well 

population. The NSPS 40 CFR part 60, subpart OOOO ruling only uses the distribution of wells resulting from this 

analysis to estimate the number of new tanks impacted by the rule. 

 

1

 EIA (2010). United States Total 2009: Distribution of Wells by Production Rate Bracket.

<www.eia.gov/pub/oil_gas/petrosystem/us_table.html> 

2

 EIA (2012) Annual Energy Outlook. < www.eia.gov/forecasts/aeo/er/pdf/0383er(2013).pdf> 3

 EIA (2012). Crude Oil and Natural Gas Exploratory and Development Wells.

<www.eia.gov/dnav/ng/ng_enr_wellend_s1_a.htm> 

ATTACHMENT 2 

Relative Distribution of Wells Within Production Rate Brackets 
3 

Exhibit 1. Production Range Distribution for New Oil Wells in 2009

0

30

45

109

110

140

135

137

215

373

374

358

546

340

733

558

325

112

21

6

4

1

0

0 100 200 300 400 500 600 700 800

0

>0-1

1-2

2-4

4-6

6-8

8-10

10-12

12-15

15-20

20-25

25-30

30-40

40-50

50-100

100-200

200-400

400-800

800-1,600

1,600-3,200

3,200-6,400

6,400-12,800

12,800-25,600

Number of New Oil Wells

BOE/day

ATTACHMENT 2 

Relative Distribution of Wells Within Production Rate Brackets 
4 

Exhibit 2. Production Range Distribution for New Gas Wells in 2009

89

464

255

474

560

468

384

298

412

554

493

388

678

546

1969

2780

1979

852

254

50

27

3

0

0 500 1000 1500 2000 2500 3000

0

>0-1

1-2

2-4

4-6

6-8

8-10

10-12

12-15

15-20

20-25

25-30

30-40

40-50

50-100

100-200

200-400

400-800

800-1,600

1,600-3,200

3,200-6,400

6,400-12,800

12,800-25,600

Number of New Gas Wells

BOE/day

ATTACHMENT 2 

Relative Distribution of Wells Within Production Rate Brackets 
5 

Exhibit 3. Production Range Distribution for New Oil Wells in 2009 by State

Production 

Range Brackets 

(BOE/day) 

New Oil Wells in 2009 

AK AL AR CA CO FL KS LA MI MO MS MT ND NE NM OH OK PA S

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

>0-1 0 0 0 3 4 0 0 0 0 0 0 0 0 0 10 6 2 0 0 

1-2 0 0 0 11 2 0 0 1 0 0 0 0 1 0 14 3 1 0 0 2-4 0 1 0 21 13 0 0 0 0 0 0 0 1 0 28 1 8 0 0 4-6 0 0 1 33 17 0 0 3 0 0 0 1 0 0 16 0 5 0 0 6-8 0 0 0 42 22 0 0 6 0 0 1 0 1 0 24 2 6 0 0 

8-10 0 0 0 29 21 0 0 2 0 0 0 0 0 0 30 0 9 0 0 

10-12 0 0 2 41 20 0 0 4 0 0 0 2 0 0 19 1 11 0 0 12-15 0 1 0 54 40 0 0 6 0 0 1 0 2 0 27 0 18 0 0 15-20 0 0 0 92 116 0 0 5 0 0 0 0 2 0 44 1 21 0 0 20-25 0 0 0 85 143 0 0 8 0 0 1 0 0 0 46 0 16 2 0 25-30 0 1 1 72 146 0 0 5 0 0 0 1 2 0 45 0 11 1 0 30-40 0 0 1 98 213 0 0 6 0 0 0 4 4 0 58 0 25 0 40-50 0 0 0 58 94 0 0 11 0 0 1 0 6 0 56 0 21 0 0 

50-100 1 2 0 99 58 0 0 19 5 0 4 11 50 0 165 0 40 0 

100-200 2 2 0 33 5 0 0 23 11 0 4 6 193 0 73 0 31 0 0 200-400 7 2 0 2 3 0 0 8 1 0 2 2 167 0 29 0 14 0 0 400-800 16 0 0 0 0 0 0 2 0 0 0 0 54 0 4 0 4 0 0 

800-1600 10 0 0 0 0 0 0 0 0 0 0 0 2 0 0 0 7 0 0 

1600-3200 3 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 3200-6400 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

6400-12800 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

12800-25600 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

ATTACHMENT 2 

Relative Distribution of Wells Within Production Rate Brackets 
6 

Exhibit 4. Production Range Distribution for New Gas Wells in 2009 by State

Production 

Range Brackets 

(BOE/day) 

New Gas Wells in 2009 

AK AL AR CA CO FL KS LA MI MO MS MT ND NE NM OH OK PA SD 

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

>0-1 0 3 2 2 25 0 25 1 0 0 0 4 1 0 26 20 11 8 0 

1-2 0 5 5 0 8 0 57 5 0 0 0 5 0 2 13 7 8 7 0 2-4 0 23 5 2 42 0 86 5 4 1 0 25 0 7 35 3 26 24 0 4-6 0 18 11 3 113 0 82 5 1 0 0 28 0 3 31 1 22 20 0 6-8 0 16 9 3 82 0 50 1 3 0 1 36 0 12 34 2 30 25 0 

8-10 0 17 12 5 55 0 34 4 1 0 0 30 0 1 28 0 18 20 0 

10-12 0 14 10 2 41 0 27 0 1 0 0 14 1 0 25 1 19 16 0 12-15 0 12 15 3 66 0 28 8 1 0 1 32 0 1 41 0 20 13 0 15-20 0 14 23 5 66 0 25 7 1 0 2 35 1 0 89 2 33 18 1 20-25 0 8 11 6 83 0 15 7 2 0 1 14 0 0 65 1 35 23 1 25-30 0 4 19 9 76 0 11 4 0 0 0 2 0 0 77 0 26 8 0 30-40 0 3 23 12 108 0 17 16 2 0 4 2 0 0 133 0 36 31 0 40-50 0 4 21 15 78 0 7 4 1 0 1 5 0 0 93 0 38 14 0 

50-100 2 3 122 34 310 0 16 56 9 0 7 3 0 0 166 0 112 44 0 

100-200 5 4 250 15 554 0 6 103 0 0 10 1 0 0 39 0 147 64 0 200-400 2 1 413 3 57 0 4 65 0 0 4 0 0 0 30 0 132 31 0 400-800 5 0 99 3 3 0 2 150 0 0 3 0 0 0 10 0 65 6 0 

800-1600 3 0 2 0 0 0 0 164 0 0 0 0 0 0 0 0 9 1 0 

1600-3200 11 0 0 0 0 0 0 19 0 0 0 0 0 0 0 0 4 0 0 3200-6400 20 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

6400-12800 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

12800-25600 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

ATTACHMENT 2 

Relative Distribution of Wells Within Production Rate Brackets 
ATTACHMENT 3

Distribution of New Wells Identified in HPDI Database across Production Rate 

Brackets - By State
ATTACHMENT 3

Distribution of New Wells Identified in HPDI Database Across Production Rate Brackets - by State

OIL WELL COMPLETIONS

Number of Oil well completions 

Production Rate 

Bracket (BOE/day) Nationwide AK AL AR CA CO FL KS LA MI MO MS

0 0 0 0 0 0 0 0 0 0 0 0 0

>0-1 30 0 0 0 3 4 0 0 0 0 0 0

1-2 45 0 0 0 11 2 0 0 1 0 0 0

2-4 109 0 1 0 21 13 0 0 0 0 0 0

4-6 110 0 0 1 33 17 0 0 3 0 0 0

6-8 140 0 0 0 42 22 0 0 6 0 0 1

8-10 135 0 0 0 29 21 0 0 2 0 0 0

10-12 137 0 0 2 41 20 0 0 4 0 0 0

12-15 215 0 1 0 54 40 0 0 6 0 0 1

15-20 373 0 0 0 92 116 0 0 5 0 0 0

20-25 374 0 0 0 85 143 0 0 8 0 0 1

25-30 358 0 1 1 72 146 0 0 5 0 0 0

30-40 546 0 0 1 98 213 0 0 6 0 0 0

40-50 340 0 0 0 58 94 0 0 11 0 0 1

50-100 733 1 2 0 99 58 0 0 19 5 0 4

100-200 558 2 2 0 33 5 0 0 23 11 0 4

200-400 325 7 2 0 2 3 0 0 8 1 0 2

400-800 112 16 0 0 0 0 0 0 2 0 0 0

800-1600 21 10 0 0 0 0 0 0 0 0 0 0

1600-3200 6 3 0 0 0 0 0 0 1 0 0 0

3200-6400 4 3 0 0 0 0 0 0 0 0 0 0

6400-12800 1 0 0 0 0 0 0 0 0 0 0 0

12800-25600 0 0 0 0 0 0 0 0 0 0 0 0

Total 4672 42 9 5 773 917 0 0 110 17 0 14

Percent of 

Nationwide wells

100% 0.90% 0.19% 0.11% 16.55% 19.63% 0.00% 0.00% 2.35% 0.36% 0.00% 0.30%

Queried from HPDI database using two criteria: wells that had a date stamp and wells that

have 12 months of continuous production (See Attachment 2). It is assumed that all of the

wells represented in this table are development wells, even though they may have originally

been considered exploratory wells (and are labelled as such in the HPDI database)

Shaded columns highlight the top 11 oil and condensate producing States.

Page 1
ATTACHMENT 3

Distribution of New Wells Identified in HPDI Database Across Production Rate Brackets - by State

OIL WELL COMPLETIONS

Number of Oil well completions

Production Rate 

Bracket (BOE/day)

0

>0-1

1-2

2-4

4-6

6-8

8-10

10-12

12-15

15-20

20-25

25-30

30-40

40-50

50-100

100-200

200-400

400-800

800-1600

1600-3200

3200-6400

6400-12800

12800-25600

Total 

Percent of 

Nationwide wells

Shaded columns highlight the top 11 oil and condensate producing States.

Number of Oil well completions

MT ND NE NM OH OK PA SD TX UT VA WY

0 0 0 0 0 0 0 0 0 0 0 0

0 0 0 10 6 2 0 0 4 0 0 1

0 1 0 14 3 1 0 0 10 1 0 1

0 1 0 28 1 8 0 0 34 0 0 2

1 0 0 16 0 5 0 0 27 4 0 3

0 1 0 24 2 6 0 0 32 3 0 1

0 0 0 30 0 9 0 0 32 10 0 2

2 0 0 19 1 11 0 0 27 10 0 0

0 2 0 27 0 18 0 0 56 8 0 2

0 2 0 44 1 21 0 0 59 30 0 3

0 0 0 46 0 16 2 0 50 20 0 3

1 2 0 45 0 11 1 0 47 23 0 3

4 4 0 58 0 25 0 1 101 31 0 4

0 6 0 56 0 21 0 0 76 15 0 2

11 50 0 165 0 40 0 1 226 43 0 9

6 193 0 73 0 31 0 0 162 10 0 3

2 167 0 29 0 14 0 0 84 3 0 1

0 54 0 4 0 4 0 0 31 1 0 0

0 2 0 0 0 7 0 0 2 0 0 0

0 0 0 0 0 0 0 0 2 0 0 0

0 0 0 0 0 0 0 0 1 0 0 0

0 0 0 0 0 0 0 0 1 0 0 0

0 0 0 0 0 0 0 0 0 0 0 0

27 485 0 688 14 250 3 2 1064 212 0 40

0.58% 10.38% 0.00% 14.73% 0.30% 5.35% 0.06% 0.04% 22.77% 4.54% 0.00% 0.86%

Queried from HPDI database using two criteria: wells that had a date stamp and wells that

have 12 months of continuous production (See Attachment 2). It is assumed that all of the

wells represented in this table are development wells, even though they may have originally

been considered exploratory wells (and are labelled as such in the HPDI database)

Shaded columns highlight the top 11 oil and condensate producing States.

Page 2
ATTACHMENT 3

Distribution of New Wells Identified in HPDI Database Across Production Rate Brackets - by State

OIL WELL COMPLETIONS

Number of Gas Well Completions 

Production Rate 

Bracket (BOE/day) Nationwide AK AL AR CA CO FL KS LA MI MO MS

0 89 0 0 0 0 0 0 0 0 0 0 0

>0-1 464 0 3 2 2 25 0 25 1 0 0 0

1-2 255 0 5 5 0 8 0 57 5 0 0 0

2-4 474 0 23 5 2 42 0 86 5 4 1 0

4-6 560 0 18 11 3 113 0 82 5 1 0 0

6-8 468 0 16 9 3 82 0 50 1 3 0 1

8-10 384 0 17 12 5 55 0 34 4 1 0 0

10-12 298 0 14 10 2 41 0 27 0 1 0 0

12-15 412 0 12 15 3 66 0 28 8 1 0 1

15-20 554 0 14 23 5 66 0 25 7 1 0 2

20-25 493 0 8 11 6 83 0 15 7 2 0 1

25-30 388 0 4 19 9 76 0 11 4 0 0 0

30-40 678 0 3 23 12 108 0 17 16 2 0 4

40-50 546 0 4 21 15 78 0 7 4 1 0 1

50-100 1969 2 3 122 34 310 0 16 56 9 0 7

100-200 2780 5 4 250 15 554 0 6 103 0 0 10

200-400 1979 2 1 413 3 57 0 4 65 0 0 4

400-800 852 5 0 99 3 3 0 2 150 0 0 3

800-1600 254 3 0 2 0 0 0 0 164 0 0 0

1600-3200 50 11 0 0 0 0 0 0 19 0 0 0

3200-6400 27 20 0 0 0 0 0 0 0 0 0 0

6400-12800 3 2 0 0 0 0 0 0 0 0 0 0

12800-25600 0 0 0 0 0 0 0 0 0 0 0 0

Total 13888 50 149 1052 122 1767 0 492 624 26 1 34

Percent of 

Nationwide wells

100% 0.36% 1.07% 7.57% 0.88% 12.72% 0.00% 3.54% 4.49% 0.19% 0.01% 0.24%

Queried from HPDI database using two criteria: wells that had a date stamp and wells that

have 12 months of continuous production (See Attachment 2). It is assumed that all of the

wells represented in this table are development wells, even though they may have originally

been considered exploratory wells (and are labelled as such in the HPDI database)

Shaded columns highlight the top 11 oil and condensate producing States.

Page 3
ATTACHMENT 3

Distribution of New Wells Identified in HPDI Database Across Production Rate Brackets - by State

OIL WELL COMPLETIONS

Number of Gas Well Completions

Production Rate 

Bracket (BOE/day)

0

>0-1

1-2

2-4

4-6

6-8

8-10

10-12

12-15

15-20

20-25

25-30

30-40

40-50

50-100

100-200

200-400

400-800

800-1600

1600-3200

3200-6400

6400-12800

12800-25600

Total 

Percent of 

Nationwide wells

Number of Gas Well Completions

MT ND NE NM OH OK PA SD TX UT VA WY

0 0 0 0 0 0 0 0 0 0 0 89

4 1 0 26 20 11 8 0 49 5 9 273

5 0 2 13 7 8 7 0 51 2 19 61

25 0 7 35 3 26 24 0 79 5 49 53

28 0 3 31 1 22 20 0 74 4 96 48

36 0 12 34 2 30 25 0 67 3 59 35

30 0 1 28 0 18 20 0 70 4 61 24

14 1 0 25 1 19 16 0 50 7 37 33

32 0 1 41 0 20 13 0 70 8 66 27

35 1 0 89 2 33 18 1 123 5 59 45

14 0 0 65 1 35 23 1 141 7 29 44

2 0 0 77 0 26 8 0 93 15 10 34

2 0 0 133 0 36 31 0 191 17 13 70

5 0 0 93 0 38 14 0 168 25 6 66

3 0 0 166 0 112 44 0 782 118 6 179

1 0 0 39 0 147 64 0 1252 149 6 175

0 0 0 30 0 132 31 0 912 56 1 268

0 0 0 10 0 65 6 0 348 2 0 156

0 0 0 0 0 9 1 0 68 0 0 7

0 0 0 0 0 4 0 0 16 0 0 0

0 0 0 0 0 0 0 0 6 0 0 1

0 0 0 0 0 0 0 0 1 0 0 0

0 0 0 0 0 0 0 0 0 0 0 0

236 3 26 935 37 791 373 2 4611 432 526 1599

1.70% 0.02% 0.19% 6.73% 0.27% 5.70% 2.69% 0.01% 33.20% 3.11% 3.79% 11.51%

Queried from HPDI database using two criteria: wells that had a date stamp and wells that

have 12 months of continuous production (See Attachment 2). It is assumed that all of the

wells represented in this table are development wells, even though they may have originally

been considered exploratory wells (and are labelled as such in the HPDI database)

Shaded columns highlight the top 11 oil and condensate producing States.

Page 4
ATTACHMENT 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation
ATTACHMENT 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CRUDE OIL STORAGE VESSELS

2009

Total Lower 48 Oil Wells Completions (thousands)* 10.85

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Total Number 

of New Tanks 

in State

Number of 

Tanks 

subject to 

NSPS

Number of 

Tanks subject to 

State 

Regulations

0.90% AK 0 - 1 0.385 0.08 0.0% 0

1 - 2 1.34 0.29 0.0% 0

2 - 4 2.66 0.57 0.0% 0

4 - 6 4.45 0.95 0.0% 0

6 - 8 6.22 1.33 0.0% 0

8 - 10 8.08 1.73 0.0% 0

10 - 12 9.83 2.11 0.0% 0

12 - 15 12.1 2.59 0.0% 0

15 - 20 15.4 3.31 0.0% 0

20 - 25 19.9 4.27 0.0% 0

25 - 30 24.3 5.22 0.0% 0

30 - 40 30.5 6.54 0.0% 0 0

40 - 50 39.2 8.41 0.0% 0 0

50 - 100 61.6 13.20 0.0% 0 0

100 - 200 120 25.64 2.4% 2 2

200 - 400 238 51.01 4.8% 5 5

400 - 800 456 97.70 16.7% 16 16

800 - 1600 914 196.01 38.1% 37 37

1600 - 3200 1692 362.91 23.8% 23 23

3200 - 6400 3353 719.14 7.1% 7 7

6400 - 12800 6825 1463.69 7.1% 7 7

> 12800 0.0 0.00 0.0% 0

1 98 98 0

16.55% CA 0 - 1 0.385 0.08 0.0% 0

1 - 2 1.34 0.29 0.4% 7

2 - 4 2.66 0.57 1.4% 26

4 - 6 4.45 0.95 2.7% 49

6 - 8 6.22 1.33 4.3% 77

8 - 10 8.08 1.73 5.4% 98

10 - 12 9.83 2.11 3.8% 67

12 - 15 12.1 2.59 5.3% 95

15 - 20 15.4 3.31 7.0% 125

20 - 25 19.9 4.27 11.9% 214

25 - 30 24.3 5.22 11.0% 197

30 - 40 30.5 6.54 9.3% 167 167

40 - 50 39.2 8.41 12.7% 228 228

50 - 100 61.6 13.20 7.5% 135 135 40

100 - 200 120 25.64 12.8% 230 230 68

200 - 400 238 51.01 4.3% 77 77 23

400 - 800 456 97.70 0.3% 5 5 1

800 - 1600 914 196.01 0.0% 0 0 0

1600 - 3200 1692 362.91 0.0% 0 0 0

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

0.00 1 1,796 841 132NO STATE REGULATIONS

Page 1
ATTACHMENT 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CRUDE OIL STORAGE VESSELS

2009

Total Lower 48 Oil Wells Completions (thousands)* 10.85

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Total Number 

of New Tanks 

in State

Number of 

Tanks 

subject to 

NSPS

Number of 

Tanks subject to 

State 

Regulations

19.63% CO 0 - 1 0.385 0.08 0.0% 0

1 - 2 1.34 0.29 0.4% 9

2 - 4 2.66 0.57 0.2% 5

4 - 6 4.45 0.95 1.4% 30

6 - 8 6.22 1.33 1.9% 39

8 - 10 8.08 1.73 2.4% 51

10 - 12 9.83 2.11 2.3% 49

12 - 15 12.1 2.59 2.2% 46

15 - 20 15.4 3.31 4.4% 93

20 - 25 19.9 4.27 12.6% 270

25 - 30 24.3 5.22 15.6% 332

30 - 40 30.5 6.54 15.9% 339 339

40 - 50 39.2 8.41 23.2% 495 495

50 - 100 61.6 13.20 10.3% 218 218

100 - 200 120 25.64 6.3% 135 135 135

200 - 400 238 51.01 0.5% 12 12 12

400 - 800 456 97.70 0.3% 7 7 7

800 - 1600 914 196.01 0.0% 0 0 0

1600 - 3200 1692 362.91 0.0% 0 0 0

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 2,130 1,206 153

0.00% KS 0 - 1 0.385 0.08 0.0% 0

1 - 2 1.34 0.29 0.0% 0

2 - 4 2.66 0.57 0.0% 0

4 - 6 4.45 0.95 0.0% 0

6 - 8 6.22 1.33 0.0% 0

8 - 10 8.08 1.73 0.0% 0

10 - 12 9.83 2.11 0.0% 0

12 - 15 12.1 2.59 0.0% 0

15 - 20 15.4 3.31 0.0% 0

20 - 25 19.9 4.27 0.0% 0

25 - 30 24.3 5.22 0.0% 0

30 - 40 30.5 6.54 0.0% 0 0

40 - 50 39.2 8.41 0.0% 0 0

50 - 100 61.6 13.20 0.0% 0 0 0

100 - 200 120 25.64 0.0% 0 0 0

200 - 400 238 51.01 0.0% 0 0 0

400 - 800 456 97.70 0.0% 0 0 0

800 - 1600 914 196.01 0.0% 0 0 0

1600 - 3200 1692 362.91 0.0% 0 0 0

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

0.00 0 0 0 0

Page 2
ATTACHMENT 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CRUDE OIL STORAGE VESSELS

2009

Total Lower 48 Oil Wells Completions (thousands)* 10.85

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Total Number 

of New Tanks 

in State

Number of 

Tanks 

subject to 

NSPS

Number of 

Tanks subject to 

State 

Regulations

2.35% LA 0 - 1 0.385 0.08 0.0% 0

1 - 2 1.34 0.29 0.9% 2

2 - 4 2.66 0.57 0.0% 0

4 - 6 4.45 0.95 2.7% 7

6 - 8 6.22 1.33 5.5% 14

8 - 10 8.08 1.73 1.8% 5

10 - 12 9.83 2.11 3.6% 9

12 - 15 12.1 2.59 5.5% 14

15 - 20 15.4 3.31 4.5% 12

20 - 25 19.9 4.27 7.3% 19

25 - 30 24.3 5.22 4.5% 12

30 - 40 30.5 6.54 5.5% 14 14

40 - 50 39.2 8.41 10.0% 26 26

50 - 100 61.6 13.20 17.3% 44 44 13

100 - 200 120 25.64 20.9% 53 53 16

200 - 400 238 51.01 7.3% 19 19 6

400 - 800 456 97.70 1.8% 5 5 1

800 - 1600 914 196.01 0.0% 0 0 0

1600 - 3200 1692 362.91 0.9% 2 2 1

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 256 163 37

0.58% MT 0 - 1 0.385 0.08 0.0% 0

1 - 2 1.34 0.29 0.0% 0

2 - 4 2.66 0.57 0.0% 0

4 - 6 4.45 0.95 3.7% 2

6 - 8 6.22 1.33 0.0% 0

8 - 10 8.08 1.73 0.0% 0

10 - 12 9.83 2.11 7.4% 5

12 - 15 12.1 2.59 0.0% 0

15 - 20 15.4 3.31 0.0% 0

20 - 25 19.9 4.27 0.0% 0

25 - 30 24.3 5.22 3.7% 2

30 - 40 30.5 6.54 14.8% 9 9

40 - 50 39.2 8.41 0.0% 0 0

50 - 100 61.6 13.20 40.7% 26 26

100 - 200 120 25.64 22.2% 14 14 14

200 - 400 238 51.01 7.4% 5 5 5

400 - 800 456 97.70 0.0% 0 0 0

800 - 1600 914 196.01 0.0% 0 0 0

1600 - 3200 1692 362.91 0.0% 0 0 0

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 63 53 19

Page 3
ATTACHMENT 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CRUDE OIL STORAGE VESSELS

2009

Total Lower 48 Oil Wells Completions (thousands)* 10.85

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Total Number 

of New Tanks 

in State

Number of 

Tanks 

subject to 

NSPS

Number of 

Tanks subject to 

State 

Regulations

10.38% ND 0 - 1 0.385 0.08 0.0% 0

1 - 2 1.34 0.29 0.2% 2

2 - 4 2.66 0.57 0.2% 2

4 - 6 4.45 0.95 0.0% 0

6 - 8 6.22 1.33 0.2% 2

8 - 10 8.08 1.73 0.0% 0

10 - 12 9.83 2.11 0.0% 0

12 - 15 12.1 2.59 0.4% 5

15 - 20 15.4 3.31 0.4% 5

20 - 25 19.9 4.27 0.0% 0

25 - 30 24.3 5.22 0.4% 5

30 - 40 30.5 6.54 0.8% 9 9

40 - 50 39.2 8.41 1.2% 14 14

50 - 100 61.6 13.20 10.3% 116 116 34

100 - 200 120 25.64 39.8% 448 448 133

200 - 400 238 51.01 34.4% 388 388 115

400 - 800 456 97.70 11.1% 125 125 37

800 - 1600 914 196.01 0.4% 5 5 1

1600 - 3200 1692 362.91 0.0% 0 0 0

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 1,127 1,106 321

14.73% NM 0 - 1 0.385 0.08 1.5% 23

1 - 2 1.34 0.29 2.0% 33

2 - 4 2.66 0.57 4.1% 65

4 - 6 4.45 0.95 2.3% 37

6 - 8 6.22 1.33 3.5% 56

8 - 10 8.08 1.73 4.4% 70

10 - 12 9.83 2.11 2.8% 44

12 - 15 12.1 2.59 3.9% 63

15 - 20 15.4 3.31 6.4% 102

20 - 25 19.9 4.27 6.7% 107

25 - 30 24.3 5.22 6.5% 105

30 - 40 30.5 6.54 8.4% 135 135

40 - 50 39.2 8.41 8.1% 130 130

50 - 100 61.6 13.20 24.0% 383 383

100 - 200 120 25.64 10.6% 170 170

200 - 400 238 51.01 4.2% 67 67

400 - 800 456 97.70 0.6% 9 9

800 - 1600 914 196.01 0.0% 0 0

1600 - 3200 1692 362.91 0.0% 0 0

3200 - 6400 3353 719.14 0.0% 0 0

6400 - 12800 6825 1463.69 0.0% 0 0

> 12800 0.0 0.00 0.0% 0

1 1,598 894 0NO STATE REGULATIONS

Page 4
ATTACHMENT 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CRUDE OIL STORAGE VESSELS

2009

Total Lower 48 Oil Wells Completions (thousands)* 10.85

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Total Number 

of New Tanks 

in State

Number of 

Tanks 

subject to 

NSPS

Number of 

Tanks subject to 

State 

Regulations

5.35% OK 0 - 1 0.385 0.08 0.8% 5

1 - 2 1.34 0.29 0.4% 2

2 - 4 2.66 0.57 3.2% 19

4 - 6 4.45 0.95 2.0% 12

6 - 8 6.22 1.33 2.4% 14

8 - 10 8.08 1.73 3.6% 21

10 - 12 9.83 2.11 4.4% 26

12 - 15 12.1 2.59 7.2% 42

15 - 20 15.4 3.31 8.4% 49

20 - 25 19.9 4.27 6.4% 37

25 - 30 24.3 5.22 4.4% 26

30 - 40 30.5 6.54 10.0% 58 58

40 - 50 39.2 8.41 8.4% 49 49

50 - 100 61.6 13.20 16.0% 93 93 28

100 - 200 120 25.64 12.4% 72 72 21

200 - 400 238 51.01 5.6% 33 33 10

400 - 800 456 97.70 1.6% 9 9 3

800 - 1600 914 196.01 2.8% 16 16 5

1600 - 3200 1692 362.91 0.0% 0 0 0

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 581 330 66

22.77% TX 0 - 1 0.385 0.08 0.4% 9

1 - 2 1.34 0.29 0.9% 23

2 - 4 2.66 0.57 3.2% 79

4 - 6 4.45 0.95 2.5% 63

6 - 8 6.22 1.33 3.0% 74

8 - 10 8.08 1.73 3.0% 74

10 - 12 9.83 2.11 2.5% 63

12 - 15 12.1 2.59 5.3% 130

15 - 20 15.4 3.31 5.5% 137

20 - 25 19.9 4.27 4.7% 116

25 - 30 24.3 5.22 4.4% 109

30 - 40 30.5 6.54 9.5% 235 235

40 - 50 39.2 8.41 7.1% 177 177

50 - 100 61.6 13.20 21.2% 525 525

100 - 200 120 25.64 15.2% 376 376 376

200 - 400 238 51.01 7.9% 195 195 195

400 - 800 456 97.70 2.9% 72 72 72

800 - 1600 914 196.01 0.2% 5 5 5

1600 - 3200 1692 362.91 0.2% 5 5 5

3200 - 6400 3353 719.14 0.1% 2 2 2

6400 - 12800 6825 1463.69 0.1% 2 2 2

> 12800 0.0 0.00 0.0% 0

1 2,472 1,594 658

Page 5
ATTACHMENT 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CRUDE OIL STORAGE VESSELS

2009

Total Lower 48 Oil Wells Completions (thousands)* 10.85

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Total Number 

of New Tanks 

in State

Number of 

Tanks 

subject to 

NSPS

Number of 

Tanks subject to 

State 

Regulations

0.86% WY 0 - 1 0.385 0.08 2.5% 2

1 - 2 1.34 0.29 2.5% 2

2 - 4 2.66 0.57 5.0% 5

4 - 6 4.45 0.95 7.5% 7

6 - 8 6.22 1.33 2.5% 2

8 - 10 8.08 1.73 5.0% 5

10 - 12 9.83 2.11 0.0% 0

12 - 15 12.1 2.59 5.0% 5

15 - 20 15.4 3.31 7.5% 7

20 - 25 19.9 4.27 7.5% 7

25 - 30 24.3 5.22 7.5% 7

30 - 40 30.5 6.54 10.0% 9 9

40 - 50 39.2 8.41 5.0% 5 5

50 - 100 61.6 13.20 22.5% 21 21 21

100 - 200 120 25.64 7.5% 7 7 7

200 - 400 238 51.01 2.5% 2 2 2

400 - 800 456 97.70 0.0% 0 0 0

800 - 1600 914 196.01 0.0% 0 0 0

1600 - 3200 1692 362.91 0.0% 0 0 0

3200 - 6400 3353 719.14 0.0% 0 0 0

6400 - 12800 6825 1463.69 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 93 44 30

10,213

** See Attachments 2 and 3 for distribution and percent of wells within each State

2,897 860

Percent of regulated States 30%

6329 1416

Percent of regulated States 22%

Sum of the number of tanks with non-emission related cutoffs 2,439 556

Sum of the number of tanks with emissions greater than the NSPS Cutoff and in states with TPY-type cutoffs 

Percent of all tanks that are subject to State Regulations (above 6 tpy)

Page 6
Attachment 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CONDENSATE STORAGE VESSELS

2009

Total Lower 48 Condensate Wells Completions (thousands)* 17.69

``

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Number of 

New Wells 

per State

Number of 

Tanks subject 

to NSPS

Number of Tanks 

subject to State 

Regulations

0.36% AK 0 - 1 0.018 0.04 0.0% 0

1 - 2 0.08 0.17 0.0% 0

2 - 4 0.15 0.32 0.0% 0

4 - 6 0.27 0.57 0.0% 0

6 - 8 0.39 0.82 0.0% 0

8 - 10 0.50 1.04 0.0% 0

10 - 12 0.66 1.37 0.0% 0

12 - 15 0.7 1.53 0.0% 0

15 - 20 1.0 2.10 0.0% 0

20 - 25 1.6 3.32 0.0% 0

25 - 30 1.8 3.85 0.0% 0

30 - 40 2.5 5.33 0.0% 0

40 - 50 3.6 7.59 0.0% 0 0

50 - 100 5.6 11.72 0.0% 0 0

100 - 200 12 25.37 4.0% 3 3

200 - 400 24 49.79 10.0% 6 6

400 - 800 44 92.32 4.0% 3 3

800 - 1600 68 142.17 10.0% 6 6

1600 - 3200 148 310.66 6.0% 4 4

3200 - 6400 234 489.87 22.0% 14 14

6400 - 12800 891 1864.37 40.0% 25 25

> 12800 0.0 0.00 4.0% 3

1 64 61 0

0.88% CA 0 - 1 0.018 0.04 0.0% 0

1 - 2 0.08 0.17 1.6% 3

2 - 4 0.15 0.32 0.0% 0

4 - 6 0.27 0.57 1.6% 3

6 - 8 0.39 0.82 2.5% 4

8 - 10 0.50 1.04 2.5% 4

10 - 12 0.66 1.37 4.1% 6

12 - 15 0.7 1.53 1.6% 3

15 - 20 1.0 2.10 2.5% 4

20 - 25 1.6 3.32 4.1% 6

25 - 30 1.8 3.85 4.9% 8

30 - 40 2.5 5.33 7.4% 11

40 - 50 3.6 7.59 9.8% 15 15

50 - 100 5.6 11.72 12.3% 19 19 15

100 - 200 12 25.37 27.9% 43 43 34

200 - 400 24 49.79 12.3% 19 19 15

400 - 800 44 92.32 2.5% 4 4 3

800 - 1600 68 142.17 2.5% 4 4 3

1600 - 3200 148 310.66 0.0% 0 0 0

3200 - 6400 234 489.87 0.0% 0 0 0

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 155 104 70NO STATE REGULATIONS

Page 7
Attachment 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CONDENSATE STORAGE VESSELS

2009

Total Lower 48 Condensate Wells Completions (thousands)* 17.69

``

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Number of 

New Wells 

per State

Number of 

Tanks subject 

to NSPS

Number of Tanks 

subject to State 

Regulations

12.72% CO 0 - 1 0.018 0.04 0.0% 0

1 - 2 0.08 0.17 1.4% 32

2 - 4 0.15 0.32 0.5% 10

4 - 6 0.27 0.57 2.4% 54

6 - 8 0.39 0.82 6.4% 144

8 - 10 0.50 1.04 4.6% 104

10 - 12 0.66 1.37 3.1% 70

12 - 15 0.7 1.53 2.3% 52

15 - 20 1.0 2.10 3.7% 84

20 - 25 1.6 3.32 3.7% 84

25 - 30 1.8 3.85 4.7% 106

30 - 40 2.5 5.33 4.3% 97

40 - 50 3.6 7.59 6.1% 138 138

50 - 100 5.6 11.72 4.4% 99 99

100 - 200 12 25.37 17.5% 395 395 395

200 - 400 24 49.79 31.4% 706 706 706

400 - 800 44 92.32 3.2% 73 73 73

800 - 1600 68 142.17 0.2% 4 4 4

1600 - 3200 148 310.66 0.0% 0 0 0

3200 - 6400 234 489.87 0.0% 0 0 0

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 2,251 1,414 1177

3.54% KS 0 - 1 0.018 0.04 0.0% 0

1 - 2 0.08 0.17 5.1% 32

2 - 4 0.15 0.32 11.6% 73

4 - 6 0.27 0.57 17.5% 110

6 - 8 0.39 0.82 16.7% 104

8 - 10 0.50 1.04 10.2% 64

10 - 12 0.66 1.37 6.9% 43

12 - 15 0.7 1.53 5.5% 34

15 - 20 1.0 2.10 5.7% 36

20 - 25 1.6 3.32 5.1% 32

25 - 30 1.8 3.85 3.0% 19

30 - 40 2.5 5.33 2.2% 14

40 - 50 3.6 7.59 3.5% 22 22

50 - 100 5.6 11.72 1.4% 9 9 7

100 - 200 12 25.37 3.3% 20 20 16

200 - 400 24 49.79 1.2% 8 8 6

400 - 800 44 92.32 0.8% 5 5 4

800 - 1600 68 142.17 0.4% 3 3 2

1600 - 3200 148 310.66 0.0% 0 0 0

3200 - 6400 234 489.87 0.0% 0 0 0

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 627 66 35

Page 8
Attachment 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CONDENSATE STORAGE VESSELS

2009

Total Lower 48 Condensate Wells Completions (thousands)* 17.69

``

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Number of 

New Wells 

per State

Number of 

Tanks subject 

to NSPS

Number of Tanks 

subject to State 

Regulations

4.49% LA 0 - 1 0.018 0.04 0.2% 1

1 - 2 0.08 0.17 0.8% 6

2 - 4 0.15 0.32 0.8% 6

4 - 6 0.27 0.57 0.8% 6

6 - 8 0.39 0.82 0.2% 1

8 - 10 0.50 1.04 0.6% 5

10 - 12 0.66 1.37 0.0% 0

12 - 15 0.7 1.53 1.3% 10

15 - 20 1.0 2.10 1.1% 9

20 - 25 1.6 3.32 1.1% 9

25 - 30 1.8 3.85 0.6% 5

30 - 40 2.5 5.33 2.6% 20

40 - 50 3.6 7.59 0.6% 5 5

50 - 100 5.6 11.72 9.0% 71 71 56

100 - 200 12 25.37 16.5% 131 131 102

200 - 400 24 49.79 10.4% 83 83 65

400 - 800 44 92.32 24.0% 191 191 149

800 - 1600 68 142.17 26.3% 209 209 163

1600 - 3200 148 310.66 3.0% 24 24 19

3200 - 6400 234 489.87 0.0% 0 0 0

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 795 715 554

1.70% MT 0 - 1 0.018 0.04 1.7% 5

1 - 2 0.08 0.17 2.1% 6

2 - 4 0.15 0.32 10.6% 32

4 - 6 0.27 0.57 11.9% 36

6 - 8 0.39 0.82 15.3% 46

8 - 10 0.50 1.04 12.7% 38

10 - 12 0.66 1.37 5.9% 18

12 - 15 0.7 1.53 13.6% 41

15 - 20 1.0 2.10 14.8% 45

20 - 25 1.6 3.32 5.9% 18

25 - 30 1.8 3.85 0.8% 3

30 - 40 2.5 5.33 0.8% 3

40 - 50 3.6 7.59 2.1% 6 6

50 - 100 5.6 11.72 1.3% 4 4

100 - 200 12 25.37 0.4% 1 1 1

200 - 400 24 49.79 0.0% 0 0 0

400 - 800 44 92.32 0.0% 0 0 0

800 - 1600 68 142.17 0.0% 0 0 0

1600 - 3200 148 310.66 0.0% 0 0 0

3200 - 6400 234 489.87 0.0% 0 0 0

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 301 11 1

Page 9
Attachment 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CONDENSATE STORAGE VESSELS

2009

Total Lower 48 Condensate Wells Completions (thousands)* 17.69

``

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Number of 

New Wells 

per State

Number of 

Tanks subject 

to NSPS

Number of Tanks 

subject to State 

Regulations

0.02% ND 0 - 1 0.018 0.04 33.3% 1

1 - 2 0.08 0.17 0.0% 0

2 - 4 0.15 0.32 0.0% 0

4 - 6 0.27 0.57 0.0% 0

6 - 8 0.39 0.82 0.0% 0

8 - 10 0.50 1.04 0.0% 0

10 - 12 0.66 1.37 33.3% 1

12 - 15 0.7 1.53 0.0% 0

15 - 20 1.0 2.10 33.3% 1

20 - 25 1.6 3.32 0.0% 0

25 - 30 1.8 3.85 0.0% 0

30 - 40 2.5 5.33 0.0% 0

40 - 50 3.6 7.59 0.0% 0 0

50 - 100 5.6 11.72 0.0% 0 0 0

100 - 200 12 25.37 0.0% 0 0 0

200 - 400 24 49.79 0.0% 0 0 0

400 - 800 44 92.32 0.0% 0 0 0

800 - 1600 68 142.17 0.0% 0 0 0

1600 - 3200 148 310.66 0.0% 0 0 0

3200 - 6400 234 489.87 0.0% 0 0 0

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 4 0 0

6.73% NM 0 - 1 0.018 0.04 2.8% 33

1 - 2 0.08 0.17 1.4% 17

2 - 4 0.15 0.32 3.7% 45

4 - 6 0.27 0.57 3.3% 39

6 - 8 0.39 0.82 3.6% 43

8 - 10 0.50 1.04 3.0% 36

10 - 12 0.66 1.37 2.7% 32

12 - 15 0.7 1.53 4.4% 52

15 - 20 1.0 2.10 9.5% 113

20 - 25 1.6 3.32 7.0% 83

25 - 30 1.8 3.85 8.2% 98

30 - 40 2.5 5.33 14.2% 169

40 - 50 3.6 7.59 9.9% 118 118

50 - 100 5.6 11.72 17.8% 211 211

100 - 200 12 25.37 4.2% 50 50

200 - 400 24 49.79 3.2% 38 38

400 - 800 44 92.32 1.1% 13 13

800 - 1600 68 142.17 0.0% 0 0

1600 - 3200 148 310.66 0.0% 0 0

3200 - 6400 234 489.87 0.0% 0 0

6400 - 12800 891 1864.37 0.0% 0 0

> 12800 0.0 0.00 0.0% 0

1 1,191 431 0NO STATE REGULATIONS

Page 10
Attachment 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CONDENSATE STORAGE VESSELS

2009

Total Lower 48 Condensate Wells Completions (thousands)* 17.69

``

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Number of 

New Wells 

per State

Number of 

Tanks subject 

to NSPS

Number of Tanks 

subject to State 

Regulations

5.70% OK 0 - 1 0.018 0.04 1.4% 14

1 - 2 0.08 0.17 1.0% 10

2 - 4 0.15 0.32 3.3% 33

4 - 6 0.27 0.57 2.8% 28

6 - 8 0.39 0.82 3.8% 38

8 - 10 0.50 1.04 2.3% 23

10 - 12 0.66 1.37 2.4% 24

12 - 15 0.7 1.53 2.5% 25

15 - 20 1.0 2.10 4.2% 42

20 - 25 1.6 3.32 4.4% 45

25 - 30 1.8 3.85 3.3% 33

30 - 40 2.5 5.33 4.6% 46

40 - 50 3.6 7.59 4.8% 48 48

50 - 100 5.6 11.72 14.2% 143 143 111

100 - 200 12 25.37 18.6% 187 187 146

200 - 400 24 49.79 16.7% 168 168 131

400 - 800 44 92.32 8.2% 83 83 65

800 - 1600 68 142.17 1.1% 11 11 9

1600 - 3200 148 310.66 0.5% 5 5 4

3200 - 6400 234 489.87 0.0% 0 0 0

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 1,008 646 467

33.20% TX 0 - 1 0.018 0.04 1.1% 62

1 - 2 0.08 0.17 1.1% 65

2 - 4 0.15 0.32 1.7% 101

4 - 6 0.27 0.57 1.6% 94

6 - 8 0.39 0.82 1.5% 85

8 - 10 0.50 1.04 1.5% 89

10 - 12 0.66 1.37 1.1% 64

12 - 15 0.7 1.53 1.5% 89

15 - 20 1.0 2.10 2.7% 157

20 - 25 1.6 3.32 3.1% 180

25 - 30 1.8 3.85 2.0% 118

30 - 40 2.5 5.33 4.1% 243

40 - 50 3.6 7.59 3.6% 214 214

50 - 100 5.6 11.72 17.0% 996 996

100 - 200 12 25.37 27.2% 1,595 1,595 1595

200 - 400 24 49.79 19.8% 1,162 1,162 1162

400 - 800 44 92.32 7.5% 443 443 443

800 - 1600 68 142.17 1.5% 87 87 87

1600 - 3200 148 310.66 0.3% 20 20 20

3200 - 6400 234 489.87 0.1% 8 8 8

6400 - 12800 891 1864.37 0.0% 1 1 1

> 12800 0.0 0.00 0.0% 0

1 5,874 4,526 3316

Page 11
Attachment 4

Analysis to Determine Percent of Storage Vessels Subject to State Regulation

CONDENSATE STORAGE VESSELS

2009

Total Lower 48 Condensate Wells Completions (thousands)* 17.69

``

2009 2009

Percent of 

total number 

of wells** State Rate Class (BOE/day)

Avg Throughput 

per Rate Category 

(bbl/day)

VOC Emissions 

per Tank (tpy)

Distribution of 

new wells**

Number of 

New Wells 

per State

Number of 

Tanks subject 

to NSPS

Number of Tanks 

subject to State 

Regulations

11.51% WY 0 - 1 0.018 0.04 17.1% 348

1 - 2 0.08 0.17 3.8% 78

2 - 4 0.15 0.32 3.3% 68

4 - 6 0.27 0.57 3.0% 61

6 - 8 0.39 0.82 2.2% 45

8 - 10 0.50 1.04 1.5% 31

10 - 12 0.66 1.37 2.1% 42

12 - 15 0.7 1.53 1.7% 34

15 - 20 1.0 2.10 2.8% 57

20 - 25 1.6 3.32 2.8% 56

25 - 30 1.8 3.85 2.1% 43

30 - 40 2.5 5.33 4.4% 89

40 - 50 3.6 7.59 4.1% 84 84

50 - 100 5.6 11.72 11.2% 228 228 228

100 - 200 12 25.37 10.9% 223 223 223

200 - 400 24 49.79 16.8% 341 341 341

400 - 800 44 92.32 9.8% 199 199 199

800 - 1600 68 142.17 0.4% 9 9 9

1600 - 3200 148 310.66 0.0% 0 0 0

3200 - 6400 234 489.87 0.1% 1 1 1

6400 - 12800 891 1864.37 0.0% 0 0 0

> 12800 0.0 0.00 0.0% 0

1 2,037 1,085 1001

14,307

** See Attachments 2 and 3 for distribution and percent of wells within each State

7,038 5,496

Percent of regulated States 78%

9061 6621

Percent of regulated States 73%

Sum of the number of tanks with non-emission related cutoffs 1,531 1,125

Sum of the number of tanks with emissions greater than the NSPS Cutoff and in states with 

TPY-type cutoffs 

Percent of all tanks that are subject to State Regulations (above 6 tpy)

Page 12
ATTACHMENT 5

Sample Calculation for 2011
ATTACHMENT 5

Sample Calculation (Oil Wells)

Number of New Development Oil Wells Completed in 2011 = 18,023 (see Table 1)

Production 

Rate Bracket 

(BOE/day)

Distribution 

of new wells 

from Table 2

Number of New 

Completed Oil 

Wells in 2011 (a)

Number of New 

Affected Storage 

Vessels in 2011 

(b)

Average 

Production 

Rate from 

Table 4 

(bbl/day)

Average Oil Storage 

Vessel VOC 

Emissions (tpy) (c)

Number of Oil 

Storage 

Vessels with 

Emissions 

Greater than 

Number of Oil 

Storage Vessels 

Subject to State 

Regulation (d)

Number of New 

Oil Tanks Subject 

to NSPS (e)

0 - 1 0.64% 116 42 0.385 0.083 0 0 0

1 - 2 0.96% 174 62 1.34 0.287 0 0 0

2 - 4 2.33% 421 151 2.66 0.570 0 0 0

4 - 6 2.35% 425 153 4.45 0.953 0 0 0

6 - 8 3.00% 541 194 6.22 1.33 0 0 0

8 - 10 2.89% 521 187 8.08 1.73 0 0 0

10 - 12 2.93% 529 190 9.83 2.11 0 0 0

12 - 15 4.60% 830 298 12.1 2.59 0 0 0

15 - 20 7.98% 1,439 516 15.4 3.31 0 0 0

20 - 25 8.01% 1,443 518 19.9 4.27 0 0 0

25 - 30 7.66% 1,382 496 24.3 5.22 0 0 0

30 - 40 11.7% 2,107 756 30.5 6.54 756 0 756

40 - 50 7.28% 1,312 471 39.2 8.41 471 0 471

50 - 100 15.7% 2,828 1,015 61.6 13.2 1,015 228 787

100 - 200 11.9% 2,153 773 120 25.6 773 173 600

200 - 400 6.96% 1,254 450 238 51.0 450 101 349

400 - 800 2.40% 433 155 456 97.7 155 35 120

800 - 1600 0.45% 82 29 914 196 29 7 22

1600 - 3200 0.13% 24 9 1,692 363 9 2 7

3200 - 6400 0.086% 16 6 3,353 719 6 2 4

6400 - 12800 0.021% 4 1 6,825 1,464 1 1 0

> 12800* 0% 0 0 0 0 0 0 0

Total 100% 18,034 6,472 3,665 549 3,116

Page 1
ATTACHMENT 5

Sample Calculation (Oil Wells)

Sample Calculation for Production Rate Bracket 200 - 400 BOE/day (2011):

(a) 

Number of New Completed Oil Wells in 2011 = 7.0% (percent of 

new wells 

within rate 

bracket)

x 18,023 new 

development 

oil wells 

completed in 

1,254 wells within Production Rate Bracket: 30 - 40 BOE/day 2011

(b) Calculated using assumption of number of storage vessels per well = 1

Number of storage vessels installed in 2011 from August 23, 2011 (date upon which storage vessels become affected facilities under the NSPS)

until December 31, 2011.

Number of Days in 2011 new affected storage vessels could be installed = 131

36% percent of the year

Number of affected storage vessels installed in 2011 = 1,254 storage vessels installed in all of 2011 x 36%

450

(c) Calculated using VOC Emission Factor for Crude oil = 0.214 tpy/bbl/day

Sample Calculation for Production Rate Bracket 200 - 400 BOE/day:

Average Oil Storage Vessel VOC Emissions = 0.214 tpb/bbl/day x 237.8 bbl/day

51.0 tpy

(d) 

Percent of Oil Storage Vessels subject to State Regulations = 22% (see Table 9)

Number of Storage Vessels Subject to State Regulations = 450 storage vessels that meet the NSPS applicability threshold * 22%

101

Only includes storage vessels with VOC emissions greater than the lowest State regulation applicability threshold

Lowest State Regulation Applicability Threshold (Wyoming) = 10 tpy

(e) 

Number of storage vessels subject to NSPS = [storage vessels with emissions > NSPS Applicability threshold] - [storage vessels with emissions > 10 tpy (WY

statewide applicability threshold)]

Number of storage vessels with VOC emissions > 6 tpy = 450

Number of storage vessels with VOC emissions > 10 tpy = - 101

Number of storage vessels subject to NSPS = 349

Page 2