Megee Consulting

Air Quality Permitting 4341 west 40'h Street

Environmental and Regulatory Consulting Casper, Wyoming 82604

Phone 307-232-0303 Cell Phone 307-262-0270 Email I rei,l,re.oirsllllrrlq ! el\'r',r:i!1i(e li!

May 30,2012

Mr. Eric Wortman

United States EPA Region 8

1595 Wynkoop Street

Denver, Colorado 80202-1 129

RE: Petro-Hunt, LLC

Response To EPA's Request For Information On Control Equipment Cost

Dear Mr. Wortman:

On behalf of our Client. Petro-Hunt, LLC (Petro-Hrm|, this letter is in response to the

request for information sent May 16,2012 to Mr. David Clark of Petro-Hunt. The cost

information provided herein was derived from records of actual purchase and installations

occurring on the Fort Berthold reservation, as well as estimates of overhead and other associated

costs. The annual costs include the whole initial purchase capital cost for the equipment, as well

as the other classes ofcosts set forth in item 3. Of EPA's request.

Item l. The average cost to develop an individual synthetic minor permit application for

a facility on the Fort Berthold reservation is approximately $4,000. This cost includes

preparation, submission, amendments as required, and management review.

Item 2.a. The cost of installation of a standard pit flare, including equipment, installation,

piping, controls, annual operating/maintenance, amual recordkeeping and overhead is

approximately $22.000.

Item 2.b. Pefio-Hunt does not use utility flares and therefore has no cost information on

this itemItem 2.c. The cost for a tank VOC combustor purchase, installation, annual

operating/maintenance, monitoring, recordkeeping and overhead is approximately $87,000.

These costs include the controls and pilot systems referred to in Items d. and e. since these are a

part of the quoted cost for the combustor unit itselfand are not broken out separately.

Item 2.d. These costs are included in the purchase cost ofthe enclosed combustor unit

and are not available separately. See Item 2.c. above.
Mr. Eric Wortman

May 30,2012

Page 2

Item 2.e. These costs are included in the purchase cost ofthe enclosed combustor unit

and are not available separately. See Item 2.c. above.

Item 2.f. Petro-Hunt does not use vapor recovery units and therefore has no cost

information on this item.

Item 4. Petro-Hunt does not have suffrcient experience with these types of control

equipment to have developed an estimate of the useful life for the equipment. However, the

undersigned does have experience with similar tank VOC combustors and control equipment

used in other locations which has been in service for approximately 8 years and is still

firnctioning as designed.

Item 5. Petro-Hunt does not use vapor recovery equipment and therefore has no

information on this item.

As requested in your letter, a signed Statement of Certification is attached. If we can

provide any clarifications or additional information on this response, please contact me at the

letterhead address, telephone, or email.

Authorized Representative for Petro-Hunt, LLC

Attachment

Copy to: D. Clark

D. Hanson
Attachment A

STATEMENT OF CERTIFICATION

I certily under penaltl,of law that I have personally examined and am familiar with the information

suhmitted in this docurnent and all attachments and that, based on my inquiry of those individuals

immediately responsible for obtaining information, I believe that the information is true. accurate, and

complete. I am aware that there are significant penalties far submitting false information. including the

possibility al' fi ne or imprisonment.

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