# eogresources May 30,2012



### VIA HAND DELIVERY
Mr. Eric Wortman U.S. Environmental Protection Agency-Region 8 Mail Code 8P-AR 1595 Wynkoop Street Denver, Colorado 80202-1129 

### 'I""M""'Ay'--"F-"-C.JiL 

## 20'=2 

# 8P AR EOG Resources, Inc. 600 Seventeenth StrNt Suite fOOON Denver; CO 80202 Main: 303-572·9000 Fax: 303-824-5400

Re: EGG Resources, Inc.'s Voluntary Response to Request for Information Pertaining to Emissions Control Equipment at Oil and Gas Production Faci ities on the Fort Berthold Indian Reservation Dear Mr. Wortman: EOG Resources, Inc. ("EOG") voluntarily responds to the May 16, 2012, infonnation request sent by Mr. Carl Daly, Director, Air Program, EP!A. Region 8 ("EPA"), concerning EGG's emissions control equipment at oil and gas produdion facilities on the Fort Berthold Indian Reservation ("FBIR"). EOG respectfully submits that due to the 14-day time constraint set forth in EPA's request, components of the data requesled have been difficult to ascertain with precision. 

# I Nonetheless, EOG has acted diligently to compile anq review available data, and provide its best estimates as to other data, in order to comply with EPA's request in good faith. I, David Long, EOG Environmental Manager, have signed the

### State~1 ent ofCertification, Attachment A to this response, acknowledging that EOG personnel have w, rked diligently to obtain available past and current information, and that such information i true, accurate, and complete based on information known at this time. Regarding responses where it was necessary for EOG to 

## , estimate costs, such estimations were made in good faith, based on relevant data and good faith assumptions. EOG submits this information, which is limited**t~** its operations in the FBIR, in order to voluntarily provide infonnation for use in EPA's eXPf.cted rulemaking regarding air emissions at oil and gas production facilities on the FBIR. Such rttlemaking is anticipated to be in the form of a Federal Implementation Plan ("FIP") for oil and**~s** exploration and production facilities on the FBIR. As such, EOG does not intend for this inf0rmation to apply to orbe representative of any ofEOG's other exploration and production

### facil~ties located throughout the nation, or to be used for purposes otherthan EPA's FIP rulemaking.

energy opportunl y growthEOG asserts no business confidentiality aim as to any ofthe information it is providing in this response. EOG's responses to the numbered EPA requests are as follows: J. Please provide tile average

# J~t incurred to develop a .lytJIlletic minor permit applicationfor an oilandgas exploration andproductionfacility on tire FBIR
.. EOG calculates that the average cost incuLed to develop a synthetic minor pennit application for an oil and gas exploration and production facility on the FBIR is approximately $8,000 to $10,000 in capital costs, plus annual oper!tional costs ofapproximately $5,000 for an anticipated duration offive years. 2. Plea!J'eprovide tire average CO• ..,·t incurred on an annual basisfor each of thefollowing types of controlequipment:
a. Apit flare capable of achieving 90% VOCdestruction efficiency. EOG estimates the average annualized Cj1st basis for a pit flare capable ofachieving 90% VOC destruction efficiency to be approximatel $1,250 to $1,300, over a 20-yearlife expectancy. b. A utility flare that is manfacturercertified for 98% VOCdestruction efficiency orcompliantwith the requirement8for s chflares at40 CFR 60.18(b). EOG estimates the average annualized c st basis for a utility flare that is manufacturer certified for 98% VOC destruction efficiency to**~e** approximately $2,700 to $3,200, over a 10·year life expectancy. 

# J

c. An enclosedcombu
. .,·torthat is manufacturercertified for 98% VOCdestruction efficiency. EOG estimates the average annualized cost basis for an enclosed combustor that is manufacturer certified for 98% VOC destruction efficibncy to be approximately $3,400 to $4,000, over a 10- year life expectancy, d. An auto-ignition sy!t;tem tlrat includes, an electronically controlled ignition device, continuous recording device, mal/unction alarm, and remote IIotijication !t,y

. ..,'tem to ensure the continuedpresence of aPilotr l ame during operation. EOG estimates the average annualized st basis for an auto-ignition system that includes, an electronically controlled ignition device.lcontinuous recording device, malfunction alarm, and remote notification system to ensure the ontinued presence ofa pilot flame during operation to be approximately $2,200, over a 10to 20tearlife expectancy.
e. A continuous pilotflame
. ..,y.\'tem that includes a thermocouple, continuou
. ..,· recording device malfunction alarm, UlJd remote Iwtification system to ensure the continued presence of apilot flame. EOG estimates the average annualized cost basis for a continuous pilot flame system that includes a thennocouple, continuous recording device malfunction alann, and remote

energ opportunitygrowthnotification system to ensure the continued presence f a pilot flame to be approximately $2,200, over a 10 to 20-year life expectancy. 

### f. A vapor recovery**~Y!J'tem** 

### (VRU)ftJr capture and recovery o/storage tankga... ;es. EOG estimates the average annualized cost basis for

# 1 vapor recovery system (VRU) for capture and recovery ofstorage tank gases to be approximatbly $19,000 to $34,000, over a 5 year lifeexpectancy. 

### 3. Please describe the source ofthe data and the methodology used in calculating items 2(a) through 2(/). 

### The average annual

### C(J~·t ;,rcurrerlshould include, butis notlimited to, the following list

### 0/ costelements:
a. The total capital investmellt (Tel) 

### co t. which includes butis not limitedto, tire capital costfor theprimary) controldevice, auxiliar equipmentandim·trumelltatiOll, piping, performance**te~·ting,** 

### as.\"Ociated uti!itie.'t, engitrerring and sy.\'tem design, freight. site preparation,foundation, COIl.\,truction and field**expem'e~',** 

### illstallation, etc.; 

# I b. Tire operatioll andmailltenance (O&M) 

### cost(equipment, pilot/uel, etc.);
c. Tire a",malized labor costs suclr

# ls salary and benefits associated witlr monitoringlrecordkeepinglreporting requirements a),d O&M

### activities; and d. Tire a",maUzed non-labor costs su

## IIJ as office supplies, vehicle cO.\'ts, and information technology. from accumulating. Cost data described herein is derived from multiple urces, including invoices, rate sheets, and estimated cost offield services, site prep and enginee+ng. It was not possible to ascertain certain specific items of cost data due to the time constrains presented by this expedited request. Nonetheless, EOG has estimated in good faith certai1 ofthese costs based on general knowledge ofits FBlR operations and such estimates are not intended to be used for any purpose other than establishing arange oflikely costs incurred for each trre ofcontrol equipment in this region. As such, actual full costing ofcontrol equipment could bel more or less than the ranges provided for a given piece of control equipment in the FBIR. Specifically, particularly given the time constraints, EOG was not able to precisely quantify expenses such as labor and non-labor costs, including office supplies, vehicle costs, and infonnatron technology-inclusion ofsuch costs in the total annualized O&M expenses is based on assumed or estimated prices and salaries.


### a. Apit flare, perNo. 2(0).
a. total capital investment: approximately $5,000 to $10,000. b-d. annualized O&M, labor costs, and non-labor cos s combined: approximately $1,000.

energy opportuni ., growthb. A utility flare, perNo. 2(b).
a. total capital investment: approximately $15,000 to $20,000, including associated components necessary for operation. b-d. annualized O&M, laborcosts, and n n-Iabor costs combined: approximately $1,200.

c. An enclo.'iedcombustor, p rNo. 2(c).
a. total capital investment: approximatel $19,000 to $25,000. b-d. annualized O&M, labor costs, and nJn-labor costs combined: approximately $1 ,500. d. An auto-ignition system,p r No. 2(d).
a. total capital investment approximatcl $12,000, including associated components necessary for system operation. b-d. annualized O&M, labor costs, and n n-Iabor costs combined: approximately $1,000.

e. A continuouspilot flame ystem, perNo. 2(e).
a. total capital investment: approximatel $12,000, including associated components necessary for system operation. b-d. annualized O&M. laborcosts. and n n-Iabor costs combined: approximately S1.000. 

### f. A vaporrecovery**~ystem** (VRU), perNo. 2(j).
a. total capital investment: approximatel1s70,000 to $120,000. b-d. annualized O&M, labor costs. an non-labor costs combined: $10,000. approximately $5,000 to

4. Please each piece ofequip",en 

## I identified ill 2(a) through 2(j), please provide the expected lifefor each component. AllYfosts associated with ",a;,rtellallce overthe life of the ullitshouldbe allllllalizedalldincludedaspartof the annual O&Mcosts reported.


### a. A pit flare, perNo. 2(0). Expected life is 20 year.;. b. A utility flare, perNo. 2(b
. Expected life is 10 years.

energ jopportunity growth

### c. An enclosedcombustor, perNo. 2(c). Expected life is 10 years, 

### d. An auto-ignition ,\Y!J'tem,perNo. 2(d). Expected life is 10-20 years.


### e. A contimlOuspilot flame !Jystem, perNo. 2(e). Expected life is 10-20 years. 

### f. A vapor recoverysystem (VRU), perNo. 2(j). Expected life is 5 years.



### 5. Pleaseprovide the average cost associated with the !J'ale ofrecoverableproduct from a VRU. Due to the wide range of unit cost and the variability of commodity pricing, establishing an economic analysis ofinstallation ofa VRU as facility1equipment is not feasible at this time.

Please do not hesitate to contact me at 303-262-9448 ifyou have any questions or comments about the above responses. Sincerely, 

# c_r

__

# ~",- David Long Environmental Manager, EOG Resources

cc: file

energy opportun,t growthttachment A



### STATEME1TOFCERTIFICATION I certify under penalty of law that I Have personally examined and am familiar with the

### ~nfonn~tion**submitt~** in this

### doc~~entl and

### tha~, based

### o~ my inquiry ?f those. indi.viduals Immediately responsible for obtammg**~nfonnat1on,** I beheve that the mfonnatlon IS true, accurate, and complete based on**availabl~** infonnation known at this time. I am aware that there are significant penalties for submitting false infonnation, including the possibility of fine or imprisonment.

David Long Name

Environmental Manager, EOG Resources, Inc. Title

May 30,2012 Date

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