### MEMORANDUM

DATE: March 17, 2011

SUBJECT: Cost Effectiveness and Impacts of Lean Oil Absorption for Control of Hazardous

Air Pollutants from Gasoline Loading - Promulgation

Residual Risk and Technology Review for the Marine Tank Vessel Loading

Operations Source Category

EPA Contract No.: EPD06118

EPA Project No.: 4-15

RTI Project No.: 0210426.004.015

FROM: David Green and Karen Sc haffner, RTI International

TO: Stephen Shedd, EPA

I. 

### Background

The purpose of this memorandum is to document and update the methods used to

estimate capital and annualized costs for reducin g hazardous air pollutant (HAP) emissions and

volatile organic compounds (VOC) from marine tank vessel loading operations (MTVLO) for

gasoline. 1 

### All cost estimates are based on the applic ation of an add-on control device to reduce

emissions. Potential control options and natio nwide impacts for add-on controls for MTVLO

facilities are presented.

II. 

### Total Capital Investment

Based on information obtained from one vendor, lean oil absorption systems are available

for control of hazardous air pollutants (HAP) and volatile organic compounds (VOC) emitted

during loading of gasoline to marine vessels. 2 

### The equipment cost is based on a typical unit cost

of $650,000 for a lean oil absorption system for a throughput of 5,000 gal/min associated with

barge loading of gasoline and a typical unit cost of $1,200,000 for a lean oil absorption system

for 15,000 gal/min associated with ship loading. The total capital invest ment (TCI) required was

estimated using EPA standard costing procedures . First, the purchased equipment cost (PEC)

was estimated by multiplying the vendor equipmen t costs by a factor of 1.08. The PEC includes

costs for auxiliary equipment, instrumentation, sa les, freight, etc. The TCI was then estimated

by multiplying the PEC by a factor of 1.15 to c over the installation co sts (i.e., foundation and

supports, handling and erection, piping, electrical, in stallation, engineering, construction, startup,

1 

### This memorandum is an update to the Cost Memorandum for proposal. Green, D. and K. Schaffner, RTI

International, to S. Shedd, EPA/OAQ PS/SPPD/CCG. Memorandum for Cost Effectiveness and Impacts of Lean Oil

Absorption for Control of Hazardous Air Pollutants from Gasoline Loading: Residual Risk and Technology Review

for the Marine Tank Vessel Loading Operations Source Category. August 19. 2010. See Docket Item No. EPAHQ-OAR-2010-0600-0003.

2 

### Telecon with B. Shine, EPA/ OAQPS/SPPD, with J. Rex Hewitt, Petrogas. July 8 and 15, 2010.

### and performance tests). Thus, the TCI was es timated to be 1.24 times the vendor equipment

costs.

For a typical MTVLO facil ity, the TCI ranged from $807,000 for barge loading to

$1,490,000 for ship loading. These values were base d on the vendor costs. The TCI for typical

MTVLO facilities is shown in Table 1. Ba sed on public comments on the October 21, 2010

proposal, commenters indicated that costs were significantl y higher for offshore loading

terminals and ranged from 1.3 to 2.3 times the costs for a typical MTVLO facility. 3

, 4 

### The

equipment costs were assumed to be approximate ly 2.3 times higher than the costs for a typical

MTVLO facility. 5 

### For offshore loading terminals, the TCI ranges from $1,860,000 for barge

loading to $3,430,000 for ship loadin g. The TCI for offshore loading facilities is shown in Table

2. Additional details on the TCI calcula tions are shown in Attachment A.

For comparison with a lean oil absorption system, capital costs for a refrigerated

condenser unit were estimated. Capital costs for lean oil absorption systems were roughly

comparable to costs for refrigerated gasoline va por recovery systems of similar capacity. Costs

for refrigerated gasoline vapor recovery sy stems were based on the OAQPS Control Cost

Manual, 6 

### escalated to 2010. The total capital inve stment of a refrigerated gasoline vapor

recovery system with a capacity of 5,000 ga l/min was estimated at $1,020,000 (2009$). The

total capital investment for a refrigerated gasolin e vapor recovery system with capacity of 15,000

gal/min was estimated to be $1,870,000 for ship load ing at a typical MTVLO. These costs are

within approximately 25 percent of a similarly si zed lean oil absorption sy stem for either barge

loading or ship loading.

III. 

### Total Annual Costs

Annualized costs for the lean oil absorption system were developed based on information

provided by the vendor and EPA sta ndard costing procedures. The lean oil absorption system is

estimated to have a variable operating cost of $0.006 per gallon loaded, and the vendor indicated

that essentially all of this cost is attri butable to electricity. The labor costs for

running/maintaining the control device system were estimated based on an estimated labor

3 

### Todd, M., API, to Air and Radiation Docket. Docket ID No. EPA-HQ-OAR-2010-0600, Letter with Comments

on EPA’s Proposed Rule – Residual Risk and Technology Review (RTR) for National Emission Standards for

Marine Tank Vessel Loading Operations. Docket ite m no. EPA-HQ-OAR-2010-0600- 0359. Dated December 6,

2010.

4 

### Colman, C., Hovensa LLC, to Air and Radiation Dock et. Docket ID No. EPA-HQ-OAR-2010-0600, Letter with

Comments on EPA’s Proposed Rule – Residual Risk and Technology Review (RTR) for National Emission

Standards for Marine Tank Vessel Loading Operations. Docket item no. EPA-HQ-OAR-2010-0600-0280. Dated

December 6, 2010.

5 

### EPA received comments on the 1995 MTVLO NESHAP on the cost to control vapor emissions from offshore

loading facilities. In general, commenters cited that offshore loading costs would range from 2 to 5 times the costs

for typical MTVLO. One commenter that provided specific cost information at that time noted that TCI costs were

2 times the cost for a typical MTVLO. (See Federal Standards for Marine Tank Vessel Loading Operations and

National Emission Standards for Hazardous Air Pollutants for Marine Tank Vessel Loading Operations, Technical

Support Document for Final Standards: Summary of Public Comments and Responses . U.S. Environmental

Protection Agency. EPA Publication No. EPA-453/R-95-014. July 1995. See Docket No. A-90-44, item no. V-B01.)

6 

### OAQPS Control Cost Manual, Fourth Edition, EP A Publication No. EPA-450/3-90-006, January 1990.

### requirement of 1.5 hr/day and an assumed labor rate of $25.76/hr and an estimated maintenance

labor requirement of 1.5 hr/day and an assumed labor rate of $26.48/hr (these rates were loaded

with benefits and overhead). 7 

### The maintenance parts cost was estimated to be 1.0 times the

maintenance labor costs. Indirect annual costs included administrative charges, property tax, and

insurance at 4 percent of the TC I, and the capital recovery based on a capital recovery factor of

0.1424 (interest rate of 7 percent for an equipm ent life of 10 years). The assumptions for

estimating the annual costs are provided in Table 3.

Control options were developed based on annual gasoline throughput cutoffs, with a

control efficiency requirement or total organic carbon concentration limit for MTVLO that

exceed the threshold. Model MTVLO were considered for gasoline throughputs of 1,000,000

bbl/yr, 5,000,000 bbl/yr, and 7,000,000 bbl/yr. Th e TAC is dependent on the gasoline

throughput, since the variable operating cost is based on throughput. The TAC for each gasoline

throughput model, for both barges and ships at a typical MTVLO f acility, is shown in Table 1.

TAC for both barges and ships at offshore loadin g facilities is shown in Table 2. Additional

details on TAC calculations are shown in Attachment A.

IV. 

### Emission Reductions for Model MTVLO

The emissions and the emission reductions were estimated for barge and ship loading for

each gasoline throughput model. The VOC emissions from barge loading of gasoline are

assumed to be 3.4 pounds of VOC per 1,000 ga llons gasoline loaded (lb VOC/1,000 gal). 8 

### The

VOC emissions from ship loading of gasoline are assumed to be 1.8 lb VOC/1,000 gal. 5 

### The

HAP content of the VOC is assumed to be 5.0 percent by weight. 9 

### The overall recovery rate for

the lean oil absorption system is assumed to be 99 percent. The emissions reductions for VOC

and HAP for each model are shown in Tables 1 and 2.

Because the lean oil absorption system rec overs gasoline product, a product recovery

credit was included in the cost analysis. The va lue of the recovered product was assumed to be

$560/ton, which partially offsets the operating cost. The TAC considering the recovered

gasoline, is shown in Tables 1 and 2 for barges and ships, for each gasoline throughput model.

V. 

### Costs for Model MTVLO Impacts

Table 4 provides the TCI, TAC, the HAP and VOC emission reductions, and the gasoline

recovery credit for each gasoline throughput thres hold, for barges and ships, and for typical

MTVLO and for offshore loading terminals. Th e number of nationwide MTVLO facilities that

would be covered under each control option was based on information from the Waterborne

Commerce Statistics Center (WCSC) database. As shown in Table 5, there are 54 facilities with

7 

### Operator labor rate is for occupation group 51-0000, and maintenance labor rate is from occupation group 49-

0000; rates used in cost calculations include an additiona l 110 percent for benefits and overhead. Bureau of Labor

Statistics.

8 

### U. S. Environmental Protection Agency. Compilation of Air Pollutant Emissions Factors, Volume I, Stationary

Point and Area Sources. AP-42, Fifth addition. See Section 5.2, Transportation and Marketing of Petroleum

Liquids.

9 

### Schaffner, K. and J. Coburn, RTI International, to S. Shedd and B. Shin e, EPA/OAR/OAQPS/SPPD. HAP

Content in Vapor Phase of Gasoline. March 9, 2011.

### annual gasoline throughput of 1,000,000 bbl to 5,000,000 bbl; 8 fac ilities with 5,000,000 to

7,000,000 bbl throughput; and 9 facilities w ith throughput of 7,000,000 bbl to 10,000,000 bbl.

The nationwide cost and cost effectiveness estimates, on an average facility basis, are

shown in Attachment B. A summary of the natio nwide costs and cost effectiveness is provided

in Attachment C.

VI. Secondary Impacts Estimates for Controlling MTVLO for Gasoline Loading

The operation of lean oil absorption systems ha s an impact on electricity consumption. It

is estimated, based on information from the vendor , that the lean oil absorption systems consume

approximately 0.1 kWhr/gallon of gasoline loaded. Thus, electrical consum ption associated with

a 1,000,000 bbl/yr applicability th reshold would be approximately 9.3 million kWhr/yr on

average per facility. The elec trical consumption associated with a 7,000,000 bbl/y r applicability

threshold would be 29 million kWhr/yr on averag e per facility. These impacts and secondary

emissions for SO 2 

### , NOx, and CO 2 

### associated with this electrical consumption are given in Table

6.

### Table 1. Model Costs - Typical MTVLO

Barge EF of 3.4 lb VOC/1000 gal gasoline loaded

Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

TCI $807,300 $807,300 $807,300

TAC $489,760 $1,497,760 $2,001,760

3.4 lb VOC/1000 gal loaded VOC emissions, ton/yr 71.4 357.0 499.8

0.17 lb HAP/1000 gal loaded HAP emissions, ton/yr 3.57 17.85 24.99

5.0 % HAP

Assume 99% control VOC reduction, ton/yr 70.69 353.4 494.8

HAP reduction, ton/y 3.53 17.67 24.74

560 $/ton gasoline

$/ton * ton recovered VOC recovery credit, $/yr $39,584 $197,921 $277,089

TAC w/recovered $450,175 $1,299,839 $1,724,670

Cost Effectiveness, $/ton VOC $6,369 $3,678 $3,486

Cost Effectiveness, $/ton HAP $127,373 $73,556 $69,712

Ship EF of 1.8 lb VOC/1000 gal gasoline loaded

Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

TCI $1,490,400 $1,490,400 $1,490,400

TAC $614,357 $1,622,357 $2,126,357

1.8 lb VOC/1000 gal loaded VOC emissions, ton/yr 37.8 189.0 264.6

0.09 lb HAP/1000 gal loaded HAP emissions, ton/yr 1.89 9.45 13.23

5.0 % HAP

Assume 99% control VOC reduction, ton/yr 37.42 187.11 261.95

HAP reduction, ton/y 1.87 9.36 13.10

560 $/ton gasoline

$/ton * ton recovered VOC recovery credit, $/yr $20,956 $104,782 $146,694

TAC w/recovered $593,401 $1,517,575 $1,979,663

Cost Effectiveness, $/ton VOC $15,698 $8,029 $7,482

Cost Effectiveness, $/ton HAP $317,140 $162,212 $151,146

### Table 2. Model Costs - OFFSHORE LOADING

Barge EF of 3.4 lb VOC/1000 gal gasoline loaded

Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

TCI $1,856,790 $1,856,790 $1,856,790

TAC $681,186 $1,689,186 $2,193,186

3.4 lb VOC/1000 gal loaded VOC emissions, ton/yr 71.4 357.0 499.8

0.17 lb HAP/1000 gal loaded HAP emissions, ton/yr 3.57 17.85 24.99

5.0 % HAP

Assume 99% control VOC reduction, ton/yr 70.69 353.4 494.8

HAP reduction, ton/y 3.53 17.67 24.74

560 $/ton gasoline

$/ton * ton recovered VOC recovery credit, $/yr $39,584 $197,921 $277,089

TAC w/recovered $641,602 $1,491,266 $1,916,097

Cost Effectiveness, $/ton VOC $9,077 $4,219 $3,872

Cost Effectiveness, $/ton HAP $181,536 $84,388 $77,449

Ship EF of 1.8 lb VOC/1000 gal gasoline loaded

Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

TCI $3,427,920 $3,427,920 $3,427,920

TAC $967,761 $1,975,761 $2,479,761

1.8 lb VOC/1000 gal loaded VOC emissions, ton/yr 37.8 189.0 264.6

0.09 lb HAP/1000 gal loaded HAP emissions, ton/yr 1.89 9.45 13.23

5.0 % HAP

Assume 99% control VOC reduction, ton/yr 37.42 187.11 261.95

HAP reduction, ton/y 1.87 9.36 13.10

560 $/ton gasoline

$/ton * ton recovered VOC recovery credit, $/yr $20,956 $104,782 $146,694

TAC w/recovered $946,804 $1,870,979 $2,333,066

Cost Effectiveness, $/t on VOC $25,300.74 $9,999.35 $8,906.40

Cost Effectiveness, $/ton HAP $506,015 $199,987 $178,128

### Table 3. Assumptions for Annual Costs for Lean Oil Absorption Systems

Factor Value

Interest rate 7.0%

Useful life 10

Capital Recovery Factor 0.1424

Variable Operating Cost, $ per gallon loaded 0.006

Operator Labor rate, $/hr 25.76

Maintenance labor rate, $/hr 26.48

Operating Labor, hr/day 1.5

Maintenance Labor, hr/day 1.5

Recovery Credit, $/ton gasoline 560

VOC emission factor for barges, lb/1000 gal loaded 3.4

HAP emission rate for barges, lb/1000 gal loaded 0.17

VOC emission factor for ships, lb/1000 gal loaded 1.8

HAP emission rate for ships, lb/1000 gal loaded 0.09

VOC recovery rate, % 99%

HAP content of VOC, wt % 5.0%

### Table 4. Costs for Model MTVLO for Sources with Gasoline Loading.

Gasoline

Loading

Threshold

(million

bbl/yr) Total

Capital

Investment

($) Total

annualized

cost ($) Recovery

Credit ($) Net

annualized

cost ($) HAP

emission

reduction

(TPY) VOC

emission

reduction

(TPY)

Typical MTVLO facility

Barges

7,000,000 807,000 490,000 39,600 450,000 3.6 71

5,000,000 807,000 1,500,000 198,000 1,300,000 18 350

1,000,000 807,000 2,000,000 277,000 1,720,000 25 490

Ships

7,000,000 1,490,000 614,000 21,000 593,000 1.9 37

5,000,000 1,490,000 1,620,000 105,000 1,520,000 9.4 190

1,000,000 1,490,000 2,130,000 147,000 1,980,000 13 260

Offshore loading facility

Barges

7,000,000 1,860,000 680,000 39,600 642,000 3.5 71

5,000,000 1,860,000 1,690,000 198,000 1,490,000 18 350

1,000,000 1,860,000 2,190,000 277,000 1,920,000 25 490

Ships

7,000,000 3,430,000 968,000 21,000 947,000 1.9 37

5,000,000 3,430,000 1,980,000 105,000 1,870,000 9.4 190

1,000,000 3,430,000 2,480,000 147,000 2,330,000 13 260



### Table 5. Facilities by Gasoline Loading Rate.

Gasoline Loading Rate

(million bbl/yr) Total Number of Facilities

7 to 10 9

5 to 7 8

1 to 5 54

### Table 6. Nationwide Secondary Impacts of Operating Lean Oil Absorption

Systems for an Average Facility

Option

Annual gasoline threshold, bbl/yr 1,000,000 7,000,000

Annual gasoline loaded, gal/yr (a vg per facility) 2,210,000 7,000,000

Electricity, kWhr/yr (avg per facility) 9,290,000 29,400,000

SO 2 

### emissions due to electric genera tion, ton (avg per facility) 18 56

NOx emissions due to electric generation, ton (avg per facility) 7.0 22

CO 2 

### emissions due to electric generation, ton (avg per facility) 6,100 19,000

Note:

SO 2 

### emission factor, ton/kwhr 1.90E-06

NOx emission factor, ton/kwhr 7.50E-07

CO 2 

### emission factor, ton/kwhr 6.56E-04AttachmentATYPICALMTVLOFACILITYBarges Ships/OceanBargesCAPITALCOSTSPre‐packagedunits1,000,000 5,000,000 7,000,0001,000,000 5,000,000 7,000,000RefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐ShipDirectCostsPurchasedequipmentcostsUnit+auxiliaryequipment A $650,000 $650,000 $650,000 $1,200,000 $1,200,000 $1,200,000Instrumentation $0 $0 $0 $0 $0 $0Salestax 0.03A $19,500 $19,500 $19,500 $36,000 $36,000 $36,000Freight 0.05A $32,500 $32,500 $32,500 $60,000 $60,000 $60,000Purchasedequipmentcosts,PEC B=1.08A $702,000 $702,000 $702,000 $1,296,000 $1,296,000 $1,296,000Directinstallationcosts 0.075B $52,650 $52,650 $52,650 $97,200 $97,200 $97,200TotalDirectCosts,DC 1.075B $754,650 $754,650 $754,650$1,393,200 $1,393,200 $1,393,200IndirectCosts(Installation)TotalIndirectCosts,IC 0.075B $52,650 $52,650 $52,650 $97,200 $97,200 $97,200TotalCapitalInvestment,TCI 1.15B $807,300 $807,300 $807,300 $1,490,400 $1,490,400 $1,490,400ANNUALCOSTSRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐ShipDirectAnnualCostsOperatingLabor 0.5hr/shift $29,618 $29,618 $29,618 $29,618 $29,618 $29,618Operator 0.15ofOperatorSupervisorOperatingMaterialsMaintenanceLabor 0.5hr/shift $30,445 $30,445 $30,445 $30,445 $30,445 $30,445Material 1.0maintenance$30,445 $30,445 $30,445 $30,445 $30,445 $30,445Utilities/Electricity $0.006/gallonloa $252,000 $1,260,000 $1,764,000 $252,000 $1,260,000 $1,764,000IndirectAnnualCostsAdministrativeCharges,PropertyTax,andInsurance0.04TCI $32,292 $32,292 $32,292 $59,616 $59,616 $59,616CapitalRecovery CRFTCI $114,960 $114,960 $114,960 $212,233 $212,233 $212,233TotalAnnualCost,TAC $489,760 $1,497,760 $2,001,760 $614,357 $1,622,357 $2,126,357CompareCosts_2011March17.xlsxAttA_CompareAttachmentACAPITALCOSTSPre‐packagedunitsDirectCostsPurchasedequipmentcostsUnit+auxiliaryequipment AInstrumentationSalestax 0.03AFreight 0.05APurchasedequipmentcosts,PEC B=1.08ADirectinstallationcosts 0.075BTotalDirectCosts,DC 1.075BIndirectCosts(Installation)TotalIndirectCosts,IC 0.075BOFFSHORELOADINGFACILITYBarges Ships/OceanBarges1,000,000 5,000,000 7,000,0001,000,000 5,000,000 7,000,000RefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐Ship$1,495,000 $1,495,000 $1,495,000$2,760,000 $2,760,000 $2,760,000$0 $0 $0 $0 $0 $0$44,850 $44,850 $44,850 $82,800 $82,800 $82,800$74,750 $74,750 $74,750 $138,000 $138,000 $138,000$1,614,600 $1,614,600 $1,614,600$2,980,800 $2,980,800 $2,980,800$121,095 $121,095 $121,095 $223,560 $223,560 $223,560$1,735,695 $1,735,695 $1,735,695$3,204,360 $3,204,360 $3,204,360$121,095 $121,095 $121,095 $223,560 $223,560 $223,560TotalCapitalInvestment,TCI 1.15BANNUALCOSTSDirectAnnualCostsOperatingLabor 0.5hr/shiftOperator 0.15ofOperatorSupervisorOperatingMaterialsMaintenanceLabor 0.5hr/shiftMaterial 1.0maintenanceUtilities/Electricity $0.006/gallonloaIndirectAnnualCostsAdministrativeCharges,PropertyTax,andInsurance0.04TCICapitalRecovery CRFTCITotalAnnualCost,TAC$1,856,790 $1,856,790$1,856,790 $3,427,920$3,427,920 $3,427,920RefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐BargeRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐ShipRefrigeratedLeanOilAbsorption‐Ship$29,618 $29,618 $29,618 $29,618 $29,618 $29,618$30,445 $30,445 $30,445 $30,445 $30,445 $30,445$30,445 $30,445 $30,445 $30,445 $30,445 $30,445$252,000 $1,260,000 $1,764,000$252,000 $1,260,000 $1,764,000$74,272 $74,272 $74,272 $137,117 $137,117 $137,117$264,407 $264,407 $264,407 $488,136 $488,136 $488,136$681,186 $1,689,186 $2,193,186$967,761 $1,975,761 $2,479,761CompareCosts_2011March17.xlsxAttA_Compare

## Attachment B. Nationwide Costs (Typical MTVLO; use 3.4 lb VOC/1000 gal for Barges)

Assumption: 5.0 % HAP content in gasoline

Gasoline throughput, bbl/yr 1,000,000 5,000,000 7,000,000

Total facilities covered 71 17 9

facilities loading 7 to 10 million bbl/y r 999

facilities loading 5 to 7 million bbl/y r 8 8 not covered

facilities loading 3 to 5 million bbl/y r 10 not covered not covered

facility loading 1 to 3 million bbl/y r 44 not covered not covered

HAP at 5.0% HAP at 5.0% HAP at 5.0%

TCI $57,318,300 $13,724,100 $7,265,700

TAC w/recovered $54,478,530 $25,920,743 $15,522,034

Average TAC (with recovery) per facilit y $767,303 $1,524,750 $1,724,670

VOC recovered 12,511 7,281 4,453

HAP recovered 625.6 364.0 222.7

Cost Effectiveness, $/ton VOC $4,354 $3,560 $3,486

Cost Effectiveness, $/ton HAP $87,086 $71,204 $69,712

CompareCosts_2011March17.xlsx

AttB_Nationwide Cost 

## Nationwide Costs (Typical MTVLO; use 1.8 lb VOC/1000 gal for Ships/Ocean Barges)

Assumption: 5.0 % HAP content in gasoline

Gasoline throughput, bbl/yr 1,000,000 5,000,000 7,000,000

Total facilities covered 71 17 9

facilities loading 7 to 10 million bbl/y r 999

facilities loading 5 to 7 million bbl/y r 8 8 not covered

facilities loading 3 to 5 million bbl/y r 10 not covered not covered

facility loading 1 to 3 million bbl/y r 44 not covered not covered

HAP at 5.0% HAP at 5.0% HAP at 5.0%

TCI $105,818,400 $25,336,800 $13,413,600

TAC w/recovered $66,622,076 $29,957,567 $17,816,964

Average TAC (with recovery) per facilit y $938,339 $1,762,210 $1,979,663

VOC recovered 6,624 3,854 2,358

HAP recovered 331.2 192.7 117.88

Cost Effectiveness, $/ton VOC $10,058 $7,772 $7,557

Cost Effectiveness, $/ton HAP $201,163 $155,443 $151,146

CompareCosts_2011March17.xlsx

AttB_Nationwide CostAttachmentC.NationwideCostforOptions(AverageperFacility)(Barge to Ship) (Barge to Ship) (Barge to Ship) (Barge to Ship) (Barge to Ship) (Barge to Ship)7,000,000Offshore $1,856,790 to $3,427,920 $1,916,097 to $2,333,066 24.74 to 13.10 494.8 to 262.0 $77,449 to $178,128 $3,872 to $8,906Existing<10/25ton $807,300 to $1,490,400 $1,724,670 to $1,979,663 24.74 to 13.10 494.8 to 262.0 $69,712 to $151,146 $3,486 to $7,5571,000,000Offshore $1,856,790 to $3,427,920 $641,602 to $946,804 3.570 to 1.871 70.69 to 37.42 $181,536 to $506,015 $9,077 to $25,301Existing<10/25ton $807,300 to $1,490,400 $767,303 to $938,339 8.811 to 4.665 176.2 to 93.3 $87,086 to $201,163 $4,354 to $10,058"Existing<10/25ton"subcategoryisbasedontheNationwideCostsandNationwideEmissionreductions,andthen"averaged"bydividingbythenumberoffacilitiesaffected"Offshore"subcategoryisbasedonthemodelcosts(capitalmultipliedby1.3xto2.3x;nochangetomostAnnualcosts,excepttheannualizedcapitalcost)andthemodelemissionreductionsHAPreduction,ton(Avgperfacility)VOCreduction,ton(Avgperfacility)Costeffectiveness,$/tonVOCCosteffectiveness,$/tonHAPGasolinethroughput,bbl/yr SubcategoryTCI(Avgperfacility)TAC,withrecovery(Avgperfacility)CompareCosts_2011March17.xlsxAttC_Optionstable_2011Jan18