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May 31, 2012

United States Environmental Protection Agency Region 8

Attn: Mr. Eric Wortman (wortman.eric@epa.gov)

1595 Wynkoop Street

Denver, CO 80202‐1129

RE: Request for Information Pertaining to Emissions Control Equipment at Oil and Gas  

Production Facilities on the Fort Berthold Indian Reservation

Dear Mr Wortman:

This letter and associated documents are being submitted to you in response to the request for

information received by Enerplus Resources (USA) Corporation (Enerplus) on May 16, 2012 to provide

information pertaining to emissions control equipment at oil and gas production facilities on the Fort

Berthold Indian Reservation (FBIR).  

Enerplus is not asserting a business confidentiality claim covering any part of the enclosed information

and understands that the information submitted with this letter is subject to public disclosure upon

request and without further notice to Enerplus. The cost information has been estimated for the

operation of a single well on FBIR and was derived from 3rd party manufacturer quotations and

estimated cost of field services, installation, maintenance and operation. Due to time constraints

associated with the requested information, some cost items were not available for inclusion; therefore,

these costs are not intended to be used for any purpose other than establishing an estimated range of

pricing for emissions control equipment and actual costs could vary above or below the provided

investment.

An explanation of the data and methodology used to calculate the costs as requested is included herein

and summarized in Table A‐1 of Attachment A.

Average Cost Incurred to Develop a Synthetic Minor Permit Application

The average cost incurred to develop a synthetic minor permit application for an oil and gas

exploration and production facility has been calculated and is presented in Table A‐1. Cost

considerations include Enerplus and contractor time to prepare a complete application including

emission calculations, for meetings with regulatory officials, and review regulatory comments.

Additional costs such as shipping, administrative, and overhead expenses, such as paper and copier

supplies, have also been factored in as the typical NSR permit application exceeds 200 pages of color

and black and white printing.

Average Cost Incurred on an Annual Basis for Emissions Control Equipment

The average cost incurred on an annual basis for the following emissions control equipment has

been summarized in Table A‐1:
ener

• A pit flare capable of achieving 90% VOC destruction efficiency;

• A utility flare that is manufacturer certified for 98% VOC destruction efficiency or compliant

with the requirements for such flares at 40 CFR 60.l8(b);

• An enclosed combustor that is manufacturer certified for 98% VOC destruction efficiency;

• An auto-ignition system;

• A continuous pilot flame system; and

• A vapor recovery system (VRU) for capture and recovery of storage tank gases.

Expected Life ofEach Emission Control Component

The expected life for the listed emission control equipment has been recorded on Table A-l.

Average Cost Associated with the Sale of Recoverable Product from a VRU

An approximate cost for a VRU for capture and recovery of storage tank gases has been recorded on

Table A-l; however, because Enerplus does not currently utilize VRUs, the provided estimate is

based solely on comments from industry and is not based on actual costs as provided by

manufacturers.

A Statement of Certification has not been included with this response because the costs provided herein

have been derived from 3rd party manufacturer quotations and estimated costs for field services,

installation, maintenance and operation. Due to time constraints associated with the requested

information, some cost items were not available for inclusion; therefore, these costs are not intended to

be used for any purpose other than establishing an estimated range of pricing for emission control

equipment. Actual costs may vary above or below the estimate provided with this correspondence.

Again, this response has been prepared on a voluntary basis and in response to a request by the Air

Program at EPA Region 8. Please don't hesitate to contact me if I can be of any further assistance.

Respectfully,

Robert Bleil

Enerplus Resources (USA) Operations

Regulatory Coordinator

950 17th Street, Suite 2200

Denver, CO 80202

720-279-5500

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Attachment A

Summary of Emission Control Summary of Information
Table A‐1

Summary of Information Pertaining to Emissions Control Equipment at Oil and

Gas Production Facilities on Fort Berthold Indian Reservation

Cost Category

NSR Permit

Application Pit Flare Utility Flare Enclosed Combustor

Auto‐Ignition

System1

Co

Fl

Total Capital Investment N/A $ 6,208 $ 38,701 $ 32,957 $ 10,000 $ 

Operation & Maintenance Cost N/A $ 1,439 $ 6,289 $ 6,289 N/A 

Total Investment3,4,5 $ 23,730 $ 7,647 $ 44,990 $ 39,246 $ 10,000 $ 

Expected Life of Control Equipment (years) N/A 15 10 10 10 

Notes:1Cost information for an auto‐ignitition system and/or a continuous pilot flame system includes the cost to purchase/install a SCADA pack and incorporate remote capabilities.4Indirect costs such as office supplies, salary, and information technology are based on assumed values.5An approximate cost for a VRU for capture and recovery of storage tank gases has been recorded on Table A‐1; however, because Enerplus does not currently utilize VRUs, the provided estimate is based solely on comments from i

provided by manufacturers.

2Costs to install, operate and maintain a vapor recovery unit are highly variable based on factors such as the price of natural gas and increased time for operation & maintenance in extreme weather conditions; therefore, an econom

unit would require an extended period of time to complete.

3Cost information has been derived from manufacturer quotations and estimated cost of field services, installation, maintenance and operation. Due to time constraints associated with the requested information, some cost items w

costs are not intended to be used for any purpose other than establishing an estimated range of pricing for emissions control equipment and actual costs could vary above or below the provided investment.