Fort Berthold Federal Implementation Plan Emissions Control Cost Data Analysis

July 2012

Cost Parameter EOG XTO - Dual Tip Scenario XTO - Single

Tip Utility Scenario Enerplus QEP Slawson WPX - Dual Tip Scenario Dual Tip

Utility Flare Scenario Average Single Tip

Utility Flare Scenario Average Single Tip

Utility Flare Scenario Average w/out Slawson Single Tip

Average with 2 combustors & 2 auto ignition w/out Slawson Pit Flare - Total Capital Investment $6,000.00 $6,000.00 $6,000.00 $6,208.00 $15,000.00 $4,770.45 $27,500.00 Pit Flare - Life Expectancy 20 20 20 15 5 10 Pit Flare CRF Factor @ 7% 0.09439 0.09439 0.09439 0.10979 0.24389 0.14238 Pit Flare - TCI annual cost $566.34 $566.34 $566.34 $681.58 $3,658.35 $3,915.45 Pit Flare - other annual cost $1,000.00 $1,439.00 $5,000.00 $55,159.42 $13,000.00 Pit Flare Total Annual Cost $1,566.34 $566.34 $566.34 $2,120.58 $8,658.35 $55,159.42 $16,915.45 $8,740.90 $13,614.21 $3,227.90 $3,227.90 Single Tip Utility Flare - Total Capital

Investment $20,000.00 $15,000.00 $38,701.00 $45,000.00 $82,990.00 Single Tip Utility Flare - Life Expectancy 10 10 10 10 Single Tip Utility Flare CRF Factor @

7% 0.14238 0.14238 0.14238 0.14238 Single Tip Utility Flare - TCI annual

cost $2,847.60 $2,135.70 $5,510.25 $6,407.10 Single Tip Utility Flare - other annual

cost $1,200.00 $23,250.00 $6,289.00 $8,500.00 $58,288.00 Single Tip Utility Flare Total Annual

Cost $4,047.60 $25,385.70 $11,799.25 $14,907.10 $58,288.00 $22,885.53 $14,034.91 $14,034.91 Dual Tip Utility Flare - Total Capital

Investment $81,520.00 $110,000.00
Dual Tip Utility Flare - Life Expectancy 10 10 Dual Tip Utility Flare CRF Factor @ 7% 0.14238 0.14238 Dual Tip Utility Flare - TCI annual cost $11,606.82 $15,661.80 Dual Tip Utility Flare - other annual

cost $46,500.00 $28,700.00
Dual Tip Utility Flare Total Annual Cost $58,106.82 $44,361.80 $51,234.31 Enclosed Combustor - Total Capital

Investment $25,000.00 $20,250.00 $32,957.00 $43,000.00 $103,708.99
Enclosed Combustor - Life Expectancy 10 10 10 10
Enclosed Combustor CRF Factor @ 7% 0.14238 0.14238 0.14238 0.14238 Enclosed Combustor - TCI annual cost $3,559.50 $2,883.20 $4,692.42 $6,122.34 Enclosed Combustor - other annual

cost $1,500.00 $23,250.00 $6,289.00 $8,500.00 $59,116.96 Enclosed Combustor Total Annual

Cost $5,059.50 $26,133.20 $10,981.42 $14,622.34 $59,116.96 $23,182.68 $14,199.11 $28,398.23 Auto ignition - Total Capital Investment $12,000.00 $27,000.00 $10,000.00 $4,100.00 Auto Ignition - Life Expectancy 10 10 10 10 Auto Ignition CRF Factor @ 7% 0.14238 0.14238 0.14238 0.14238 Auto Ignition - TCI annual cost $1,708.56 $3,844.26 $1,423.80 $583.76 Auto ignition - other annual cost $1,000.00 Auto ignition - Total Annual Cost $2,708.56 $3,844.26 $1,423.80 $583.76 $2,140.09 $2,140.09 $4,280.19 Continuous Pilot - Total Capital

Investment $12,000.00 $27,000.00 $10,000.00 $4,500.00
Continuous Pilot - Life Expectancy 10 10 10 10 Continuous Pilot CRF Factor @ 7% 0.14238 0.14238 0.14238 0.14238 Continuous Pilot - TCI annual cost $1,708.56 $3,844.26 $1,423.80 $640.71 Continuous Pilot - other annual cost $1,000.00

Continuous Pilot - Total Annual Cost$2,708.56 $3,844.26 $1,423.80 $640.71 $2,154.33 $2,154.33 $2,154.33

### Total for Operator Scenario (Dualtip or 1 single-tip with 1 combustor) $16,090.56 $58,673.16 $59,773.76 $27,748.84 $39,412.26 $172,564.38 $61,277.25 $59,975.20 $63,117.96 $35,756.35 $52,095.56

Max values used from EOG Range Provided Life expectancy of equipment for XTO was assumed to be the same as EOG, due to such close capital cost equipment values Total value of automation equipment provided by XTO was $54K. Divided this by 2 for auto-ignite and continuous pilot columns for each combustion device XTO did not provide annual O&M labor cost for each type of equipment, only a total cost per pad. 46,500 added to dual tip utility flare cost and divided by 2 for single tip/enclosed combustor Equipment cost of $54K (auto-ignitition/continuos pilot) was added to the dual tip XTO capital cost ($27520) to allow for comparison to WPX since the WPX captial cost included the auto flame system. Auto-ignition or continuous pilot monitoring was included in Slawson's estimates for flare/combustor pricing Marathon's submittal was claimed as CBI and is not included in this analysis PetroHunt provided a total cost including one time equipment & install with annual labor and O&M of $22,000 for a pit flare and $87,000 for a enclosed combustor. PetroHunt claimed they had no other data other than the 3 cost numbers provided, so their data was not used in analysis. Slawson's estimates included CRF of total capital cost in annual cost, therefore this was not calculated separately above. WPX indicated that the cost of an auto-ignition system is included in the price of the utility flare, therefore the cost for this or continuous pilot was not added to their operating scenario WPX does not use enclosed combustors, supporting documentation indicated utility flare was a tandem, or dual tip utility flare Since cost for auto-ignition and continuous pilot were similar, one of each was included for total cost to assume 1 for flare, 1 for combustor. Both were included XTO dual-tip due to division in table Slawson included 1272 labor hours for pit flare, utility flare, and enclosed combustor totaling 3,816 labor hours per well pad scenario. A 40 hour work week for 52 weeks is 2,080 hours. Due to unrealistic scenario that annual labor cost per site are approximately 2 full time FTE, Slawson's high cost estimates were considered to be an outlier and not included in final cost figures forTSD.