From: Krivo, Stan

Sent: Thursday, October 24, 2013 9:57 AM

To: Shepherd, Lorinda

Subject: RE: Statoil Additional Information - Developer Cement Unit Engines Hours of 

Operation

Categories: OCS

Lori,

I have reviewed ENVIRON’s 17 September 2013 letter requesting changes to the operating hours for the 

Maersk Developer cement engines (CMU-1 and CMU-2). They indicate no hourly emission changes so 

there are no changes to the short-term modeling results. The change requested was a yearly increase in 

the total hours of operation for the 2 units from 120 hour/rolling 12 months to 300 hours/rolling 12 

months. This would only change emission rate used in the annual impact assessment.

This letter indicate the expected changes to the annual impacts are minimal so no updated annual 

modeling was performed. They only provide the annual modeling results from the previous provided 

(June and July 2013 submittals) analyses.

Based on the small emission rates for these two units and the 2.5 factor increase in annual hours of 

operation, I agree with their assessment that this increase would not increase the annual impact 

concentrations above the applicable significant impact levels (SIL). This small increase in the annual 

operation hours for these small emission units should not require updated annual impact modeling 

assessment. [Note: A very conservative updated estimated impact using the 2.5 factor increase in the 

reported annual impacts still shows concentrations less than the EPA SIL.]

Let me know if you have questions.

...sjk

From: Shepherd, Lorinda 

Sent: Thursday, October 17, 2013 2:55 PM

To: Krivo, Stan

Subject: FW: Statoil Additional Information - Developer Cement Unit Engines Hours of Operation

Hi Stan,

Have you had a chance to look at the Statoil changes? Or, can you give me an estimate for when you will 

be able to get to it?

Welcome Back!

Lori Shepherd

Environmental Scientist

Air Permits Section

EPA Region 4

61 Forsyth Street

Atlanta, GA 30303

(404) 562-8435
From: Shepherd, Lorinda 

Sent: Wednesday, September 18, 2013 8:36 AM

To: Krivo, Stan

Subject: FW: Statoil Additional Information - Developer Cement Unit Engines Hours of Operation

Stan, 

Please take a look at these changes Statoil is requesting.

Thanks,

Lori Shepherd

Environmental Scientist

Air Permits Section

EPA Region 4

61 Forsyth Street

Atlanta, GA 30303

(404) 562-8435

From: Brian Glover [mailto:bglover@environcorp.com] 

Sent: Tuesday, September 17, 2013 7:08 PM

To: Shepherd, Lorinda

Cc: Fortin, Kelly; Michael Carbon; Jill Webster (Jill_Webster@fws.gov); Kjersti Seim (Statoil); Donald 

Evans (Statoil); Kyle Heitkamp

Subject: Statoil Additional Information - Developer Cement Unit Engines Hours of Operation

Lori,

Please find attached additional information to be incorporated into Statoil’s pending permit number 

OCS-EPA-R4012. Specifically, Statoil requests the hours of operation be increased for the Maersk 

Developer (Developer) Cement Unit Engines 1 and 2 (CMU-1 and CMU-2) from 120 hours per year to 300 

hours per year (combined). The proposed change results in minimal increases in annual emissions, and 

has no impact on the PSD applicability analysis, BACT analysis, or air quality analysis for the project as 

described further in the attached submittal.

Thank you for your attention to this matter and please let us know if you have any questions or need 

any additional information.

Brian 

Brian Glover | Senior Manager

ENVIRON International Corporation

8235 YMCA Plaza Drive | Suite 300

Baton Rouge, LA 70810

T: +1 225 408 2741 | F: +1 225 408 2747 | M: +1 225 252 6562
bglover@environcorp.com

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