From: Michael Carbon <mcarbon@environcorp.com>

Sent: Monday, June 23, 2014 7:26 PM

To: Shepherd, Lorinda; Fortin, Kelly

Cc: Michael Carbon; Todd Higginbotham; Kyle Heitkamp; Brian Glover; Bart 

Brashers; Foster Wade; Donald Evans

Subject: FW: Statoil Modification Conference Call Follow-up

Attachments: removed.txt; Attachment A - Process Data.pdf; Attachment B - Lemmer A928G Manual.pdf; Attachment C - Bulk Cement & Air System P&IDs.PDF

Lori

Please find the below responses (text in red and attached files) to EPA’s remaining items.

Thanks

Michael

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From: Shepherd, Lorinda [mailto:Shepherd.Lorinda@epa.gov] 

Sent: Thursday, June 19, 2014 4:22 PM

To: Michael Carbon; fwad@statoil.com

Cc: Brian Glover; Kyle Heitkamp; Todd Higginbotham

Subject: Statoil Modification Conference Call Follow-up

Thanks to everyone for taking the time to participate on the call today. I captured the following items 

for follow-up:

1) It is our understanding that the following additional engines (including 3rd party engines) may be 

used on drilling vessels as part of exploratory activities. Please verify that these engines will not 

be used on the Developer or will use electric vs. diesel engines. Some of these may have come 

up in past discussions, but finding new sources past this point in the process can create 

significant delays. Some extra caution now can help us avoid any surprises. 

Well stimulation vessels

Boomflares

Flowback boilers or heaters

Electric line engines

Casing unit engines

Tubing running engines

Fluid filtration pump

Eline or slick line powerpack engines

Water blasting engines

New transformers were installed on the Maersk Developer last year. With these new transformers 

installed, electric power can be supplied to any of the above engine driven equipment that may be 

utilized by Statoil, including required 3rd party equipment. Statoil will inform 3rd parties to bring onboard 

only electric driven equipment. It should also be noted that in no event will any emissions emitting 

equipment (i.e., Boomflares, flowback boilers or heaters, etc.) not addressed in the permit application 

be utilized during the proposed drilling campaign. 
2) If available, please provide the actual loads measured during each source test run from

Avogadro’s source test report. Some of this information was included as screen captures in 

Appendix C of the source test report, but much of it was unreadable. 

As noted, the screen captures in Appendix C of the Source Test Report previously provided include the 

actual loads the engines were running at during each stack test run. Please see Attachment A for screen 

shots in better quality than those provide in the application for your review. Note the engine numbers 

indicated on the screen shots are listed as “DG1” for main engine #1, “DG2” for main engine #2, 

etc. The target loads of 60%, 45%, and 30% are indicated on the first three screen shots, and the actual 

load is circled. The graphs depict the actual loads during the test run where the minimum, mean, and 

maximum loads during that period are provided above each line graph.

3) Please clarify if the paint sprayer(s) used on the Developer will be airless or air assisted (or a 

combination). Based on the assumptions in the application, it appears that use of a high 

efficiency (65%) airless paint sprayer was included in the emissions calculations for painting 

activity. Air assisted sprayers cannot achieve this level of transfer efficiency. Since this process is 

a source of VOCs and particulates, any assumptions will be used to determine BACT 

requirements as well as emissions estimates; and, it would be helpful to verify now if the 

equipment that will actually be used can realistically meet requirements included in the permit.

An example of how this may be included in BACT conditions in the permit can be found in the 

Anadarko EGOM permit that is being placed on public comment tomorrow. The draft permit is 

up at http://www.regulations.gov/#!docketDetail;D=EPA-R04-OAR-2014-0487 and should be on 

our website by the end of the day. 

The Lemmer A-928G is the type of paint spray gun used aboard the Maersk Developer. Please see the 

attached owner’s manual for the Lemmer A-928G paint spray gun (Attachment B). The Lemmer A-928G 

is a high volume low pressure (HVLP) gun, which is considered one of the most efficient types of paint 

spray guns. SCAQMD requires all paint spray guns to have transfer efficiencies equal to or better than a 

HVLP paint spray gun. Similarly, NESHAP Subpart 6H (Paint Stripping and Miscellaneous Surface Coating) 

requires use of an HVLP spray gun, electrostatic application, airless spray gun, air-assisted airless spray 

gun, or an equivalent to the above methods to comply with the regulation. Statoil’s contact at Lemmer 

stated that for a HVLP spray gun operating within the proper pressure range (10 psig or less), a transfer 

efficiency of up to 90% would be expected. He noted that the actual transfer efficiency of the paint 

spray gun can be very dependent on the operator following the manual and operating within the 

recommended pressure range.

Statoil is proposing the following permit condition:

“The permittee shall use either a high volume low pressure (HVLP) spray gun or paint application method 

with equivalent to or greater transfer efficiency (65%) than a HVLP spray gun for all coating operations.”

4) Since the dust collector that is part of cement handling is incorporated into the system 

specifically as a control technology, compliance conditions need to be associated with the unit. 

Please provide any information you have regarding the unit type or model of the cyclone 

collector (for example, a flow-through unit with pressure monitoring or a model that uses a 

knock-out mechanism with a collection bin). Based on our conversation earlier, the “knock-out” 
may be re-routed back to cement/barite material storage as either a direct flow or as a cleanout dump. That would be helpful to know as well.

Please see the attached P&IDs for the Bulk Cement and Bulk Air System (Attachment C). Unfortunately 

we do not have any specific specification sheets or design drawings for the dust cyclones. There are no 

specific monitoring parameters (e.g. pressure drop monitoring) set for the cyclones, thus Statoil is 

proposing the following permit condition:

“The permittee shall ensure that all exhaust from the cyclones is released below the surface of the ocean 

to ensure that all BACT limits are met.”

5) Stan Krivo is reviewing a discrepancy in a PM2.5 value reported in the air quality analysis. He 

will be re-checking his numbers and contacting Bart directly to resolve the issue. This is a matter 

of making sure that information included in the preliminary determination is clear and that the 

values are correct. It is very unlikely that the overall outcome of the air quality analysis will 

change as a result of resolving the discrepancy. We will keep you informed of any updates with

this.

Based on our call earlier today we believe that Stan’s potential discrepancy in PM2.5 value is related to 

the following:

In the CALPUFF modeling, PMF (PM Fine) is taken as PM2.5, and PMC (PM Course) is the difference 

between PM10 and PM2.5 (PMC = PM10 - PM2.5, or equivalently PM10 = PMC + PMF). The sum of the 

right-most column in Table 5.2.3-8 (the PM10) is 5.70 lb/hr, which is 0.72 g/s (or 7.2 x 10-1). Divide that 

into 100 VOLUME sources, and you get 7.2 x 10-3 g/s. Looking at the modeling files, the last two 

elements of line (100 lines, for the 100 volumes sources) is 2.14E-04 and 7.01E-03. Those are the PMC 

and PMF values, respectively. Add those to get 7.2 x 10-3 g/s per volume source, that number 

multiplied by hundred (to reflect the 100 volume sources) matches the PM10 total in Table 5.2.3-8.

Please call me or Kelly if you have any questions.

Thanks again,

Lori Shepherd

Environmental Scientist

Air Permits Section

EPA Region 4

61 Forsyth Street

Atlanta, GA 30303

(404) 562-8435

Michael Carbon | Principal
ENVIRON | www.environcorp.com

8235 YMCA Plaza Drive | Suite 300 | Baton Rouge, LA 70810

T: 225.408.2691| M: 225.907.3822 | mcarbon@environcorp.com

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