### From: Bart Brashers <bbrashers@environcorp.com>

Sent: Thursday, May 29, 2014 11:41 AM

To: Krivo, Stan

Cc: Shepherd, Lorinda; Michael Carbon Subject: RE: Statoil
Attachments: statoil_vis_modeling_2014

- 05

- 13.piz

Stan,

Here’s the zip, renamed *.piz. Let me know ASAP if you have any troubles opening it, and I’ll post in for downloading. I hope you’ll find time to review it today.

You already have the CALPUFF runs that used the max 1

- hour emission rates, should they become important. On the modeling CD , in the “conc” sub

- directory, there’s some text files that summarize all
the CALPOST runs. We calculate all sorts of “answers” for each run, and just report (in the write

- up) the relevant ones. I pointed this out in an email to you before the Incompleten ess Letter came out, trying to increase your comfort level with our proposed limits.

The relevant take

- home messages:

 We used the 12 operating scenarios only to calculate annual fuel usage.

 The requested annual fuel usage limit is actually less than the existing permit.

 The permit condition does not need to reference the 12 operating scenarios, and their loads.

 We’re far below the annual SILs

– it would take ~350 days of operating at the max 1

- hour
emission rates to come close.

 Even if the distribution of loads (and associated emission factors) from the past turns out to be inaccurate in the future, using an annual fuel usage limit will be adequately protective of the annual NAAQS.

Bart

Bart Brashers | Atmospheric Scientist Senior Manager, ENVIRON International Corporation
19020 33 rd Ave W Ste 310 | Lynnwood WA 98036 T: +1 425

- 412

- 1 812 | F: +1 425

- 412

- 1840 | M: +1 206

- 550

- 2606 bbrashers@environcorp.com

From: Krivo, Stan [ mailto:Krivo.Stanley@epa.gov ]
Sent: Wednesday, May 28, 2014 10:44 AM
To: Bart Brashers
Cc: Shepherd, Lorinda Subject: RE: Statoil

Bart,

I received your voice mail message. We are an organization that cannot accept ZIP files.Please rename the file and send the Class I modeling again.

Gi ven there are no changes to the permit proposed annual operating scenario (e.g., still 12 varying scenarios) and the provided results of using the short

- term emissions for the annual impacts (Response to Incompleteness Item 3), I leave the status of this i tem up to the permits section. If the provided annual modeling results using short

- term emissions becomes important, we should have the modeling files for review and inclusion in the permit record. The question asked in Incompleteness item 3 dealt
with ho w the gross annual fuel limit will ensure compliance with the short term and annual
standards. This item asked for details of a continual compliance demonstration given the 12 varying operating scenarios and no limit on the hours of operation.

Thanks fo r your help. ...sjk

From: Bart Brashers [ mailto:bbrashers@environcorp.com ]

Sent: Tuesday, May 27, 2014 5:08 PM

To: Krivo, Stan Subject: Statoil

Stan,

I'm traveling today, on my way to New Orleans. I hav e a few hours free in the morning, and will call you
then.

Bart

Bart Brashers

ENVIRON

425

- 412

- 1812 Office

206

- 550

- 2606 Mobile bbrashers@environcorp.com

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