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 A

928G Manual.pdf; Attachment C

- Bulk Cement & Air System P&IDs.PDF

Lori

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

Thanks
Michael

----------------------------------------------------------------------------------------------------------------------------- -------------

----------------------------------------------------- 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 (includi ng 3 rd 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 fin ding 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 t he above engine driven equipment that may be utilized by Statoil, including required 3 rd party equipment. Statoil will inform 3 rd parties to bring onboard only electric driven equipment. It should also be noted that in no event will any emissions emitti ng 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 inc lude 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 list ed 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 V OCs 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 effi ciencies 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 a n 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 th at 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 eithe r 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 incor porated 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 wit h 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 clean

out 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 p arameters (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 lim its 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 fi les, 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 | PrincipalENVIRON | 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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