## WPXENERGY. May 31, 2012 Mr. Eric Wortman U.S. EPA, Region 8 1595 Wynkoop Avenue, 8P-AR Denver, CO 80202-1129 Submittal provided via e-mail to: wortman.eric@epa.gov

Re: WPXEnergy Williston, LLC Request fOl' Information Pertaining to Emissions Conh'ol Eqnipment at Oil and Gas PI'oduetion Facilities on FortBel'thold Indian Reservation DearMr. Wortman: WPX Energy Williston, LLC (WPX Energy) formerly Dakota-3 E&P Company, LLC (Dakota3) understands that the Environmental Protection Agency (EPA) is expediting the development ofa Reservation-specific Federal Implementation Plan (FIP) to establish federally enforceable requirements to control volatile organic compound (VOC) emissions from oil and gas production activities (i.e. storage tank and heater-treater emissions) within the exterior boundaries ofthe Fort Berthold Indian Reservation (FBlR) in North Dakota. EPA's action would require owners and operators of oil and gas well production facilities to reduce VOCs released during the extraction and storage ofhydrocarbon reservoir fluids prior to being transferred offsite for sale ortreatment. As part ofthis effort, EPA has requested information from WPX Energy that would facilitate determination of the associated cost impacts of the proposed emission control requirements. WPX Energy is providing the following information as requested. The cost information provided incorporates manufacturer quotes, contractor invoices, and best professionaljudgment based on WPX Energy's operational experience on FBlR. WPX Energy became an operator within FBIR in May 2011. In some instances, WPX Energy currently has not used some ofthe teclmologies indentified in the May 16, 2012 letter request and does not have cost data or the operating experience to provide average cost information. WPX Energy has provided the requested information and the basis ofthis information following each of the listed requests. If the requested information is not available, WPX Energy has provided an explanation ofwhy this information is not included. I. Please provide the average cost incurred to develop a synthetic minor permit application for an oil and gas exploration and production facility onthe FBIR. Reqllested [lIfol'lI/atioll: The average cost to prepare a synthetic minor permit application for an oil and gas exploration and production facility on the FBlR is $6,000. This estimate includes cost savings thatwere achieved from permitting multiple facilities. Ifa single permit application were developed, the costs would be closer to $25,000 per

100117· Street I Suite 1200 I Denver. Colorado 80202 I 303.572.3900 I ,wlW.wpxenergy.comMay 31,2012 Page 2 application. The average cost presented includes contractor fees and costs associated with contractor management, analytical data, evaluation of equipment specifications, developing productionprojections, meetings withEPA and contractors, site identification andplanning, reviews, and equipmentevaluations. 2. Please provide the average cost incurred on an annual basis for each ofthe following types ofcontrol equipment:
a. APitFlare capable ofachieving 90% VOC destruction efficiency; 

### RequestedInformation: The average costannual costis = $16,200 Based on:
• TCI = $27,500
• Annual O&M = $6,000
• Annual LaborCosts Monitoring/Recordkeeping/Reporting = $4,800
• AnnualNon-Labor Costs = $2,200 The costs provided above are based WPX Energy operating experience and best professionaljudgment. b. A utility flare that is manufacturer celiified for 98% VOC destruction efficiency orcompliantwiththe requirements for such flares at40 CFR 60.18(b); 

### RequestedInformation: The average costannual costis = $41,600 Basedon:
• TCI=$llO,OOO
• Annual O&M = $11,900
• Annual LaborCosts Monitoring/Recordkeeping/Reporting = $12,000
• AnnualNon-Labor Costs = $4,800 The costs provided above are based on manufacturer quotes, WPX Energy operating experience, and best professional judgment. The manufacturer quotes for three differenthigh efficiency flares have beenincluded withthis letter.
c. An enclosed combustor that is manufacturer certified for 98% VOC destruction efficiency; 

### RequestedInformation: WPX Energy has determined that enclosed combustors are not the best control device for our operations based on reliability, effectiveness, and cost. The estimated capital cost ofthese units is approximately $65,000. WPX has not implemented or does not currently plan to use any ofthese units on their FBIR facilities so we do nothave costdatathat would be applicable. d. An auto-ignition system that includes, an electronically controlled ignition device continuous recording device, malfunction alarm, and remote notification system to ensure the continuedpresence ofapilotflame during operation;May 31, 2012 Fage 3 

### RequestedInformatiou: The auto-ignition systems are built into the utility flares so the costs have beenincludedwiththe utility flare cost estimates as they are partofthe flare designprovidedby the manufacturer.
e. A continuous pilot flame system that includes a thermocouple, continuous recording device malfunction alarm, and remote notification system to ensure the continuedpresence ofapilot flame; and 

### RequestedIUformation: The average cost annual costis = $28,100 Based on:
• TCI = $13,200
• Annual O&M = $9,000
• Annual Labor Costs Monitoring/Recordkeeping/Reporting = $12,000
• Annual Non-Labor Costs = $4,200 The costs provided above are based WPX Energy operating experience with measurement equipment, SCADA system, compliance tracking software, and best professionaljudgment. f. A vaporrecovery system (VRU) for capture andrecovery ofstoragetank gases. 

### RequestedInformatiou: WPX Energy has not operated a vapor recovery system on the FBIR and does not have cost or operational data to estimate the requested information. Based on manufacturer estimates, the capital cost ofan 11-70 MSCFD unit ranges between $115,000 to $125,000. Use ofa VRU will be evaluated as wells are added and production increases. IfWPX Energy implements a VRU; the system willbe operate as process equipment notemissioncontrol equipment. 3. Please describe the source ofthe data andthe methodology used in calculating items 2(a) through 2(f). The average annual cost incurred should include, but is not limited to the following list ofcostelements: 

### RequestedInformation: The information requested in Item 3 has been provided above in the requested information for Items 2(a) through 2(f). Total capital investment costs have been annualized based on a discount factor of 3 percent and the estimated life of the equipment.
a. The total capital investment (TCI) cost, which includes but is not limited to, the capital cost for the primary control device, auxiliary equipment and instrumentation, piping, performance testing, associated utilities, engineering and system design, freight, site preparation, foundation, construction and field expenses, installation, etc. b. The operation and maintenance (O&M) cost (equipment, pilotfuel, etc.);May 31,2012 Fage 4
c. The annualized labor costs such as salary and benefits associated with monitoring/recordkeeping/reporting requirements and O&M activities; and d. The alUlUalized non-labor costs such as office supplies, vehicle costs, and information teclUlology. 4. For each piece ofequipment identified in 2(a) through 2(f), please provide the expected life for each component. Any costs associated with maintenance over the life ofthe unit should be alUlUalized and included as partofthe alUllIal O&M costs reported. RequestedIUfol'lI/atiou: The estimated life ofthe equipment is provided below: a. PitFlare

- 10 years b. Utility Flare

- 10 years (Replace tips every 5 years, Replace/rebuild flare turbine meter annually) c. Enclosed Combustor

- (Not applicable. Notplanning on using these) d. Auto Ignition System- 5 year e. Continuous Flame/Monitor- 5 years (Thermocouple replaced annually) f. VaporRecoveryUnit

- (No data. No operating experience) 5. Please provide the average cost associated with the sale ofrecoverable product from a VRU. Requested IUfol'lI/atiou: WPX Energy has not operated a vapor recovery system on the FBIR. We do noLhave any operational experience to provide this dataas it is unclear how well these systems will work in this area. WhenWPX Energy implements a VRU the system will operate as process equipmentnotemission control equipment. The signed Statement of Certification (Attachment A) is included with this submittal as requested. WPX Energy has also included the available manufacturer equipment quotes (Attachment B) for Utility Flares and Vapor Recovery Units. Ifyou have specific questions associated with this informationplease do not hesitate to contact JoDell Mizoue (303) 606-4056 ormyself. Sincerely, 

# WPX:::;;;X' LLC
Williams K. Stenzel Vice President

cc: file AttaclunentsMay 31, 2012 Page 5 

### AttachmentA
IcertifYunderpenalty oflaw that Ihave personally examined and am familiarwith the information submitted in this documentand all attachments and that, based on my inquiry ofthose individuals immediatelyresponsible for obtaining information, Ibelievethatthe information is true, accurate, and complete. Iam aware thatthere are significantpenalties for submittingfalse information, including the possibility offine orimprisonment.

Signature
Vice President Title

Date