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 Incompleteness 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 33rd Ave W Ste 310 | Lynnwood WA 98036

T: +1 425-412-1812 | 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.

Given 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 item 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 how 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 for 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 have 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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