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## UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Atlanta, Georgia

Preliminary Determination & Statement of Bas is Outer Continental Shelf Air Permit OCS

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BHP Billiton Petroleum, Inc. Sake Prospect Drilling Project

May 23, 201 31

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## 1.0 Introduction

On May 30, 2012, the U.S. E nvironmental P rotection A gency (the EPA) issued an Outer Continental Shelf (OCS) permit ( Permit No. OCS

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- R4008) to BHP Billiton Petroleum, Inc. (BHPB) i n accordance with the provisions of s ection 328 of the Clean Air Act (CAA), 4 2 U.S.C. § 7627

, and the implementing Outer Continental Shelf (OCS) Air Regulations at t itle 40 Code of Federal Regulation s (CFR) part 55

. 1 This permit to construct and operate emissions units at exploratory drilling operations in the DeSoto Canyon area of the Eastern Gulf of Mexico ( known as the Sake Prospect Drilling Project or Sake Project ) became effective on June 30, 2012. Subsequently, a minor permit revision was made to this permit (Permit No. OCS

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- M1) on March 13, 2013, to in clude activities that were previously omitted from the original application ( e.g. , painting, welding, flaring, and seismic operations).

On May 3

, 2013, BHPB submitted to the EPA an application to update the po tential to emit estimates for their operation and to revise the Best Available Control Technology ( BACT ) emissions limits for the eight main engines of the Development Driller 1 ( DD1 )

, originally specified in Permit No. OCS

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, for particulate matter (PM)

, particulate matter with an aerodynamic diameter equal to or less than 10 microns (PM 10 ) and particulate matter with an aerodynamic diameter equal to or less than 2.5 microns (PM 2.5 )

, volatile organic compounds (VO C)

, and greenhouse gases (GHGs ), measured as CO 2 e. BHPB requested t he se revisions because the original permit limits for these pollutants were established using AP

- 42 emissions factors, and source test data is now available which more accurately reflects the emissions from the engines on the drilling rig operating under the terms and conditions of the permit

.
Following careful consideration and analyses of the data provided by BHPB, the EPA is proposing to revise the BACT limits for PM, PM 10 , PM 2.5 , VOC, and CO 2 e for units EU

- 001 through EU

- 008 on the DD1 as specified in Conditions 6.6.1.1.3 through 6.6.1.1.5 of Permit No. OCS

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, as summarized below. In general, the revised emission limits for PM

, VOC , and GHGs are higher than those in the original per mit. The EPA is also incorporating high and low load limits that are more reflective of the variable load operations of these engines when operating under the terms of the permit.

This revision does not constitute a modification of the facility nor a ch ange in the proposed drilling operations . While BHPB has made preparations to drill

, including source testing, BHPB has not yet begun drilling operations on the lease blocks covered by the permit. Rather, this action is a proposed revision to a limited nu mber of emissions limits , relating to specific engines on the DD1 , to reflect data that is more representati ve of operations of the engines when the facility is operating subject to the terms and conditions of the permit

. All other aspec ts of the permit re main the same

.
This document serves as a fact sheet, preliminary determination, and statement of basis for the draft permit revisions

. This document addresses the changes made to the original preliminary determination/statement of b asis as a result of this permit revision

. A description of the project, a summary of the applicable requirements, the legal and factual basis for the draft permit conditions, and the EPA’s analysis of key aspects of the application and permit such as the B ACT analysis and air quality impact analysis can be found in the original statement of basis for this permit, which is available in the administrative record for this project, as discussed in Section 9 of this document. 2 The EPA has

1 S ee CAA § 328

. EPA Region 4 is the agency responsible for implementing and enforcing CAA requirements for OCS sources in the Gulf of Mexico east of longitude 87 ° 30‘ (87.5 ° W ). The Department of Interior has jurisdiction for Clean Air Act implementation west of 87 ° 30 ’.

2 The procedures govering the issuance of both OCS and PSD permits are set forth at 40 CFR p art 124, s ubparts A and C

. See 40 CFR §§ 55.6(a)(3) and 124.1 . While these regulations do not address permit revisions

, given the nature of the revisions, the EPA has followed the2

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## 2.0 Applicant Information

2.1 Applicant Name and Address

BHP Billiton Petroleum, Inc. 1360 Post Oak Blvd., Suite 150 Houston, Texas 77056

2.2 Facility Location

BHPB plans to conduct exploratory drilling at multiple sites in the OCS waters of the Gulf of Mexico, DeSoto Canyon area, within lease blocks 499, 543

- 545, 586

- 592, 631

- 640, 676

- 685, 721

- 729, 768

- 773, and 815

- 817, Figure 2

- 2. These 49 contiguous lease blocks are located approximately within latitudes 28.15° to 28.50° N and longitudes 86.68° to 87.27° W, east of longitude 87.5° W. The center of the lease block area is located at latitude 28.31° N and longitude 86.96° W, approximately 120 miles sout heast of the nearest Louisiana shoreline, 139 miles south southeast of the nearest Mississippi shoreline, and 125 miles south of the nearest Alabama and Florida shorelines

.



## 3.0 Project Description

For the Sake Project, BHPB plans to conduct exploratory oil and natural gas drilling using a mobile offshore drilling unit (MODU) for a period of up to two years. For operati onal flexibility, BHPB will use either the Transocean ultra

- deepwater MODU C.R. Luigs (Operating Scenario 1) or the Transocean semi

- submer sible MODU DD1 (Operating Scenario 2) and an associated support fleet in multiple locations within its DeSoto Canyon lease blocks as discussed above. The project w ill last a maximum of two years and

, based on app licable permitting regulations, qualifies as a “temporary source” for
P revention of S ignificant D eterioration (PSD) permitting purposes

.
Air pollutant emissions generated from the Sake Project include carbon monoxide (CO), nitrogen dioxide (NO 2 )

, PM ( which includes PM 10 and PM 2.5 ), and sulfur dioxide (SO 2 ) (known as criteria pollutants), as well as other regulated air pollutants, including oxides of nitrogen (NO X ), VOC, and GHGs. VOC and NO X are the measured precursors for the criteria pollutant ozone, and NO X and SO 2

are measured pr ecursors for the criteria pollutant PM 2.5

.
These emissions are primarily released from the combustion of diesel fuel in the MODU’s main diesel engines used for electric power generation for dynamic position station

- keeping and drilling operations. Diesel engines are also used to run cranes, a black start compressor, cementing operations, wireline units , and support vessels operating within 25 miles of the MODU . The emergency generator, life boats, and the fast rescue craft are also powe red by diesel engines and are routinely operated for testing and

procedures of 40 CFR part 124 in issuing these draft permit revisions. The EPA is also following the procedures of 40 CFR part 7 1 governing the revision of federal operating permits. This Preliminary Determination describes the revisions to the permit conditions and the reasons for them as provided in 40 CFR § 124.7, and also serves as a Fact Sheet as provided in 40 CFR § 124.8 and a statement of basis required by 40 CFR § 71.11(b)

.3

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, there are additional PM/ PM 10 / PM 2.5 e missions from the mud and cement dust collectors

. Additional VOC and GHG e missions are released from a mud degas sing unit and the storage tanks used to store diesel fuel, hydraulic oil, base oil, and jet A helifuel.

Based on emissions estimates, the Sake P roject has the potential to emit the regulated New Source Review ( NSR ) pollutants CO, NO X , PM/ P M 10 / PM 2.5 , VOC, and GHGs above their PSD significant emission rates. Hence, the original permit incorporated the results of the PSD BACT analysis, air quality analysis, monitoring, reporting, and recordkeeping requirements for the applicable emission sources releasing these pollutants.

Included in their application to revise the BACT emission limits for the specified DD1 engines , BHPB performed a revised BACT analysis, a revised air quality analysis, and updated its Potential to Emit (PTE) for r egulat ed NSR p ollutants, as discussed below.



## 4.0 Regulatory Applicability

4.3 Prevention of Significant Deterioration

The project potential to emit values shown in Table 4

- 1 have been updated following the receipt of the stack test data for PM, PM 10 , PM 2.5 , VOC, and CO 2 e emissions for the DD1 ’s main engines and the revision of the respective BACT limits for these pollutants, as detailed in Section 6. With respect to the PM, PM 10 , and PM 2.5 emissions, BHPB proposed in this permit amendment to use filterable P M results and particle size distribution information from AP

- 42 to calculate PM 10 and PM 2.5 emission rates. However, based on the preliminary s tack test data , the condensable particulate appears to be a substantially higher percentage (upwards of 82 percen t) of the filterable particulate than what is predicted by AP

- 42 (approximately 12 percent) for large diesel engines. In other words, it is difficult to differentiate between the condensable and fil terable particulate. Given that the AP

- 42 factors have an “E” rating (i.e

. are based upon testing conducted on a single engine), and absent more reliable data, the EPA believes a more appropriate methodology for calculating potential particulate emissions is to assume that all filterable particulate is PM 10 /PM 2.5 and, thus, total PM is PM 10 /PM 2.5 for the main engines of the DD1 . The resulting PM 10 /PM 2.5 PTE for the project , as calculated by the EP A is, therefore, higher than that estimated by BHPB in the application (see Table s 4

- 1 and 5

- 2 below ). It should be noted that since these limits are based on the worst

- case emission rates, which the variable load drilling rig does not operate at continuously, the EPA believes these estimates are con s ervative

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Table 4

- 1 : Potential to Emit for Regulated NSR Pollutants

Pollutant C.R. Luigs

PTE (TPY) DD1

PTE (TPY) Significant

Emission Rate (TPY) PSD

Review Required?
PM 66.02 77.28 25 Yes
PM 10 41.15 72.44 15 Yes
PM 2.5 40.16 72.26 10 Yes NO X a 1

, 699.60 1

, 30 9

. 61 40 Yes SO 2 b 0.91 0.88 40 No
H 2 SO 4 0.03 0.03 7 No CO 373.69 3 10

. 64 100 Yes VOC c 81.61 110.48 40 Yes

GHGs (CO 2 e) 101,574.72 111,088.86 75,000 (subject to regulation threshold) Yes

Lead 0.02 0.02 0.60 No

a NO X is a measured pollutant for the criteria pollutants ozone and NO 2 and a precursor for PM 2.5 . b SO 2 is a precursor for the criteria pollutant PM 2.5 . c VOC is a measured pollutant for the criteria pollutant ozone.

4.4 Title V

The requirements of the t itle V operating permit program, as set forth at 40 CFR part 71, apply to major OCS sources located beyond 25 miles of states ’ seaward boundaries. Because the PTE for this project is greater than 100 TPY for NO X and CO, it is considered a major source unde r tit le V and part 71. The title V permit requirements were included in the OCS permit issued for this source on May 30, 2012

. The proposed permit changes constitute a significant modification to the title V permit because they do not meet the criteria set out for a minor modification under 40 CFR 71.7(e)(1). More specifically, the revis i ons require a case

- by

- case determination of emissions limits. As discussed in Section 1, above, while the permit revisions constitute a “modification” pursuan t to part 71 , th ey do not constitute a modification to the emissions units or pl anned operation of the facility (i.e.

, this is not a physical change

or a change in the method of operation, as defined under PSD )

. The required Part 71 forms are included in Section 7 of BHPB’s permit modification applicat ion received by the EPA on May 3, 2013. The permit continues to include all the permit terms necessary to meet the requirements of the applicable title V operating permits program

. For example, t he permit includes req uirements for submittal of annual compliance certifications and annual fee payments, based on actual emissions, as well as monitoring, recordkeeping

, and reporting requirements.

4.6 National Emission Standards for Hazardous Air Pollutants (NESHAP)

Since t he original permit was issued, proposed amendments to the reciprocating internal combustion engine (RICE) maximum achievable control technology (MACT) rule (40 CFR part 63, subpart ZZZZ) were made final (on January 30, 2013). Basically, units that are exis ting stationary, non

- emergency, compression

- ignition RICE with a site rating of more than 300 horsepower, located on an offshore vessel that is an area source of HAP, and is a non

- road vehicle that is an OCS source (as defined in 40 CFR § 55.2), are no lon ger subject to the numerical CO emission limits of Table 2d of the MACT. However, the following management practices must be met:

 Change oil every 1,000 hours of operation or annually, whichever comes first. Or, utilize an oil analysis program as prescrib ed in 40 CFR § 63.6625(i) in order to extend the specified oil change requirement;5

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 Inspect fuel filters and belts, if installed, every 750 hours of operation or annually, whichever comes first, and replace as needed; and

 Inspect all flexible hoses every 1,000 hours of operation or annually, whichever comes first, and replace as needed.

Additionally, pursuant to 40 CFR § 63.6655, records of the above management practices need to be maintained in readily

- accessible, hard

, or electronic form for at least five years following the date of each maintenance activity. No change is necessary to the permit to reflect this change. However, the EPA is including this information to update the Statement of Basis to reflect the current applicability of the RICE MACT.



## 5

. 0 Project Emissions

The t able below provides the revised PTE of the project using the DD1 Operating Scenario, based on the recent source testing results for the eight main diesel engines. No changes are proposed for the other emissions units.

Table 5

- 2 : Potential to Emit Emissions

– DD1 Operating Scenario 2

Emission Source PM

(TPY) PM 10

(TPY) PM 2.5

(TPY) NO X

(TPY) SO 2

(TPY) H 2 SO 4

(TPY) CO (TPY) Total

VOC (TPY) Lead

(TPY) GHGs

(CO 2 e) (TPY)

Main Diesel Engines (8) 61.92 61.92 61.92 1

, 007.02 0. 70 0.02 215.09 66.99 1. 34 E

- 02 90,056.47

Emergency Generator Engine (1) 0.05 0.03 0.03 1. 60 0.001 2. 21E

- 05 0. 37 0. 04 1. 36E

- 05 77.84

Lifeboat Engines (4) 1.21E

- 02 1.21E

- 02 1.21E

- 02 1.71E

- 01 5.82E

- 05 1.82E

- 06 3.67E

- 02 1.38E

- 02 1.12E

- 06 6.35

Fast Rescue Craf

t Engine (1) 3.91 E

- 03 3.91E

- 03 3.91E

- 03 5.50 E

- 02 1.88 E

- 05 5.87E

- 07 0.01 4.46 E

- 03 3.06 E

- 07 2.05
Cementing Unit Engines (4) 0. 41 0.2 5 0. 25 9. 50 0.01 2.03E

- 04 3. 73 0. 57 1.25E

- 04 715.48

Mud & Cement Dust Collectors ( 2 ) 1.08 1.08 1.08

- - - - - - - Mud Degassing Operation (1) - - - - - - - 19.39

- 982.67

Wireline Unit Engines ( 4 ) 0.60 0.60 0.60 8.92 0.005 1.54E

- 04 2.90 1.17 9.44E

- 05 536.63

MODU Storage Tanks (26) - - - - - - - 0.44

- -

Work Boats (2) 9.70 5.58 5.42 246.82 0.15 4.57E

- 03 76.01 8.90 2.80E

- 03 16,080.92
Work Boats Storage Tanks ( 52 ) - - - - - - - 9.47E

- 02

- -
Fast Crew Boats (1) 1.41 0.87 0.85 31.94 0.02 6.19E

- 04 10.38 1.33 3.80E

- 04 2,180.77 Crew Boat Storage Tanks (2) - - - - - - - 6.02E

- 03

- - Flaring Operations

- - - 0.03

- - 0.18 0.07

- 64.72 Welding Operations 0.02 0.02 0.02

- - - - - - - Painting Operations 1.96 1.96 1.96

- - - - 4.79

- - Seismic Operations (3 Engines) 0.11 0.11 0.11 3.54 3.77E

- 03 1.18E

- 04 1.94 6.67 6.82E

- 05 384.97

Emission Unit Totals: 77.28 72.4 4 72.26 1,30 9.61 0. 88 0.03 3 10.64 110.48 0.02 111,088.866

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## 6.0 Best Available Control Technology (BACT)

The top

- down BACT analysis conducted by the applicant in conjunction with this latest revision was essentially unchanged from the original application

, and did not result in any significant changes to the respective control technology determinations for th e main engines of the DD1

. This is as expected, since the applicant has not proposed to change any emissions units nor the method of operation. BHPB requested revisions to certain BACT limits because the original permit limits for these pollutants were

est ablished using AP

- 42 emissions factors, and source test data is now available which more accurately reflects the emissions from the engines on the drilling rig operating under the terms and conditions of the permit. Following careful consideration and ana lyses of the data provided by BHPB, the EPA is proposing to revise the BACT limits for PM, PM 10 , PM 2.5 , VOC, and CO 2 e for units EU

- 001 through
EU

- 008 on the DD1 as discussed below.

Initial compliance stack testing, which commenced on March 31, 2013, in accordance with Condition 6.9.1.3, yielded data that was generally higher than the respective BACT limits for PM/PM 10 /PM 2.5 , VOC, and CO 2 e, especially at low loads. The original emission estimates and BACT limits were based on AP

- 42 emission factors due t o the lack of actual emissions data for the aforementioned pollutants on this drilling rig or like drilling rigs . The AP

- 42 factors that were relied upon by the applicant (Section 3.4, Large Stationary Diesel and All Stationary Duel

- Fuel Engines ) are from a very limited sampling ( i.e. , the testing of one engine only) and, thus, do not carry a very favorable rating in terms of accuracy/reliability. Furthermore, the AP

- 42 factors are more representative of land

- based rather than marine

- based applications and specifically do not account for the frequent variable load scenarios and operating characteristics associated with drilling operations. Nonetheless, these factors were the best available at the time the permit was written. P reliminary results from the recent stack tests on the DD1 drilling rig showed the emission s of NO X and CO from the main engines will be in compliance with the BACT l imits established in the original permit. These limits were established using source test d ata from this source and other like engines

.
BHPB proposed revised BACT emission limits for PM, PM 10 , PM 2.5 , VOC, and CO 2 e for units EU

- 001 through EU

- 008 on the DD1 based o n compliance stack test results. The stack test was performed for three runs each at high, medium and low loads. A single BACT limit was proposed by BHPB for each pollutant that generally correlated to highest 3

- run average test result from a single engine, irrespective of the operating load. Upon analysis of the data , however, EPA d etermined that separate emission limits for low load and high load operations are more appropriate for the particulate matter emission limits as well as VOC. While emission rates at high and medium load are similar for these pollutants, the re is a signifi cant difference in the emission rates when tested at low loads . This is expected due to the combustion characteristics of the diesel engines. In addition, in establishing the BACT limits, EPA considered correlation of the data across the test runs, as si gnificant deviations may be an indicator of poor test results or operations outside of optimum performance.

The revised BACT limits for PM/PM 10 /PM 2.5 and VOC were established for low and high engine load scenarios (i.e., less than 55 percent and greater than or equal to 55 percent loads) (see Tables 6

- 3 and 6

- 4)

. The EPA has established high and low load emission rates to ensure that when the engines are operating at high loads, they will continue to be required to be maintained, employ the best combusti on practices, meet the emission rates achievable through the use of the prescribed BACT control technologies.

O ne update to the original c ontrol technology analysis has now been incorporated into the permit . H igh

pressure fuel injection (HPFI)/high

- efficiency fuel injection (HEFI) has been now deemed to be BACT7

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, as necessary to comply with the permit terms and conditions

.
6.1 BACT Analysis for Internal Combustion Engines

The EPA refers interested parties March 30, 2012 statement of basis, included in the permit record, for the EPA’s comprehensive BACT analy sis. The revised BACT emissions limits that were incorporated in the permit are given in the tables below. It should be noted that these BACT limits may again change as more representative emissions data is acquired by the source and similar drilling rigs during the permit

term.

6.1.2 CO and VOC BACT Analyses for Internal Combustion Engines

Table 6

- 3: VOC BACT Conclusions Emissions Unit ID BACT Control Options VOC BACT Limits*
Vessel: DD1
EU

- 001 through

- 008 PCV, HPFI w/ a ftercooler, and

g ood c ombustion p ractices with use of DEWT measurement system 1.02 x 10 - 3 lb/hp

- hr ( 0. 62 g/kW

- hr) for engine loads < 55 % 8. 2 2 x 10 - 4 lb/hp

- hr ( 0.5 0 g/kW

- hr) for engine loads ≥ 55 %
*Short

- term limits are based on a rolling 24

- hour average and long

- term limits (including hours of operation) are based on a rolling 12

- month period.

6.1.3 PM/PM

10 /PM 2.5 BACT Analysis for Internal Combustion Engines

Table 6

- 4: PM/PM 10 /PM 2.5 BACT Conclusions Emissions Unit ID BACT Control Options PM/PM 10 /PM 2.5 BACT Limits *
Vessel: DD1
EU

- 001 through

- 008 Turbocharger and a ftercooler,

PCV, HPFI w/ a ftercooler, g ood

c ombustion p ractices with the use of DEWT measurement system , and u ltra l ow s ulfur f uel 9.3 7 x 10 - 4 lb/hp

- hr ( 0. 57 g/kW

- hr) for engine loads

< 55% 7.07 x 10 - 4 lb/hp

- hr ( 0.4 3 g/kW

- hr) for engine loads
≥ 55 %

*Short

- term limits are based on a rolling 24

- hour average and long

- term limits (including hours of operation) are based on a rolling 12

- month period.8

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Table 6

- 5: GHG BACT Conclusions Emissions Unit ID BACT Control Options BACT Limits * (as CO 2 e)
Vessel: DD1
EU

- 001 through

- 008 HPFI/HEFI , g ood

c ombustion p ractices with use of DEWT measurement system 1. 36 lb/hp

- hr ( 829 g/kW

- hr) 90,056.47 tons per year 6,570 hours of operation

*Short

- term limits are based on a rolling 24

- hour average and long

- term limits (including hours of operation) are based on a rolling 12

- month period. All GHG emission limits are in the form of CO 2 e.



## 7.0 Air Quality Impact Analyses Summary

7.2.6 Modeling Results

Because the permit continues to limit BHPB’s exploratory drilling project in the Desoto Canyon lease blocks to no more than two years, the project qualifies as a temporary emissions source for purpose s of PSD permitting. Because the revised emissions for particulate matter are higher than those originally proposed for the project, t he applicants submitted a revised PM / PM 10 / PM 2.5 modeling analysis.

B HPB used the same modeling approach and stack paramet ers as used in the original application . A Class I area modeling analysis was performed with the revised worst case project emission rates for the Breton National Wildlife Refuge (NWR), the St. Marks NWR and the Bradwell Bay Wilderness Area

. The worst

- cas e mass emission rates (38.62 lb/hr for both PM 10 and PM 2.5 ) conservatively include an emission rate for DD1 ’s main engines which is higher (0.63 g/kW

- hr) than the new PM 10 /PM 2.5 BACT limits (0.57 and 0.43 g/kW

- hr). Ba sed on the EPA’s review of this modeling and input received from the
F ederal L and M anager regarding their review of the A ir Q uality R elated V alues and visibility impact modeling assessment , the project applicant has continued to demonstrate that the propos ed project does not impact any PSD Class I area. This analysis is available in the administrative record, as discussed in Section 9 below.



## 9.0 Public Participation

9 .1 Opportunity for Public Comment

The EPA is using the procedures for decision making, set forth at 40 CFR part 124 to process this permit revision

. While neither the OCS nor PSD regulations address the administrative procedures for permit revisions , given that the revisions change the BACT emission limits previously offered for public

comment

, the EPA is following the procedures of 40 CFR p art 124 and 40 CFR part 71 in processing this revision. As required by these provisions , the EPA is seeking public comment on the revisio ns incorporated into BH PB OCS air permit OCS

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- M2 Any interested person may submit writ ten comments on the draft revisions to the permit during the public comment period. If you believe that the revisions to the permit are inappropriate, you mus t raise all reasonably ascertainable issues and submit all reasonably available arguments supporting your position by the end of the comment period. Any documents supporting your comments must be included in full and may not be incorporated by reference un less they are already part of the record for this permit or consist of state or federal statutes or regulations, EPA documents of general applicability, or other generally available referenced materials.

Comments should focus on the revisions to the air quality permit. If you have general comments regarding non

- air q uality impacts, leasing, drilling safety, discharge

, or other similar issues not subject to this public comment period, you should submit them during the leasing and permitting proceedings of the B ureau of O cean E nergy M anagement , which is the lead approval agency for offshore drilling

.
All timely comments on the draft revisions will be considere d in making the final decision and will be included in the record, and responded to by the EPA. The EPA may group similar co mments together in

our response and will not respond to individual commenters directly.

All comments on the draft permit must be received by email , submitted electronically at

www. regulations.gov, or postmarked by June 24 , 2013

. Requests for a Public Hearing (see below) must be received by email or mail by June 10

, 2013 . An extension of the 30

- day comment period may be granted if the request for an extension adequately demonstrates why additional time is required to

prepare commen ts. Comments can be sent by email, delivered in writing to the address below or submitted electronically via www.regulations.gov , which can be accessed through the EPA Regi on 4 website listed below . All comments wil l be included in the publ ic docket without change and will be made available to the public, including any personal information provided, unless the comment includes Confidential Business Information or other information in which disclosure is restricted by statute. Information that you consider Confidential Business Information or otherwise protected should be clearly identified as such and should not be submitted through e

- mail. If you send e

- mail directly to the EPA, your email address will be captured au tomatically and included as part of the public comment. Please note that an e

- mail or postal address must be provided with your comments if you wish to receive direct notification of the EPA’s final decision regarding the permit and the EPA’s response to c omments submitted during the public comment period. For questions on the draft permit, please contact: Mr. Art Hofmeister at 404

- 562

- 9115 or hofmeister.art@epa.gov

. Submit comments on the draft permit and

reque sts for a public hearing to:

EPA Region 4, APTMD Air Permits Section 61 Forsyth Street, SW Atlanta, GA 30303 ATTN: Art Hofmeister

Fax: (404) 562

- 9019 Email: h ofmeister.art@epa.gov

9.2 Public Hearing

The EPA will hold a public hearing if the Agency determine s that there is a significant degree of public interest in the draft permit. Requests for a public hearing must be received by the EPA by email or mail by June 10, 2013 , at the addr ess given above, and state the nature of the issues proposed to be raised in10

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- M2 the hearing. You may submit oral or written comments on the draft permit at the public hearing. You do not need to attend the public hearing to submit written comments. If EPA det ermines that there is a significant degree of public interest, the EPA will hold a public hea ring the week of June 24, 2013 , at the loc ation given on the EPA’s website (see below)

. If no timely request for a public hearing is received, or the EPA determine s that there is not a significant degree of public interest, a n announcement will be posted on the EPA’s website by June 12, 2013, at:

http://www.epa.gov/region4/air/permits/ocspermits/ocspermits.html

,

or , you may call the EPA at the contact number above to determine if the public hearing will be held.

9.3 Administrative Record

The administrativ e record contains the application, supplemental information and data submitted by BHPB, and correspondence, including e

- mails b etween BHPB and its consultants and the EPA clarifying various aspects of BHPB’s application. The EPA’s draft permit revisions an d preliminary determination/statement of basis, comments received from the public or other government agencies and the applicant during the public comment period

, become part of the administrative record for the permit. The draft permit revision and the ad ministrative record are available for public review on the EPA’s website at :

http://www.epa.gov/region4/air/permits/ocspermits/ocspermits.html

and at the EPA Region 4 office at the addresses listed below. Please call in advance for available viewing times.

EPA Region 4 Office 61 Forsyth Street, SW Atlanta, GA 30303 Phone: (404) 562

- 9643

To request a copy o f the draft permit, preliminary determination or notice of the final permit action, please contact: Ms. Rosa Yarbrough, Permit Support Specialist at ( 404 ) 562

- 9643 or yarbrough.rosa@epa.gov

.

9.4 Final Determination

A final decision to issue the final permit revision , or to deny the application for the permit revisions

, shall be made after all timely comments have been considered. Notice of the final decision shall be sent to each person who has submitted written comments or requested notice of the final permit decision,

pro vided the EPA has adequate contact information.