From: Brian Glover [bglover@environcorp.com]

Sent: Thursday, October 24, 2013 11:48 AM

To: Shepherd, Lorinda

Cc: Brian Glover; Michael Carbon; Kyle Heitkamp

Subject: Revised Fuel Usage Estimate for Developer

Categories: OCS

Thanks Lori. There may be some room in the previous fuel usage estimates, but I think it would be best

to reflect the revised usage estimate in the permit. Like you said, there is a direct correlation to

emissions and we have concluded the increase falls within the previous analys es and determinations.

The increased hours for the cement unit engines (120 hours total to 300 hours total) would result in a

slight increase in potential fuel usage over a 180 day campaign.

Developer total fuel usage with cement units at 120 hours t otal: 2,650,333 gallons of diesel per year.

Developer total fuel usage with cement units at 300 hours total: 2,654,931 gallons of diesel per year.

 Increase of 4,598 gallons per year.

Please update the permit to reflect the Developer annual fuel consumption limit to be 2,654,931 gallons

of diesel on a rolling 12

- month total basis.

Thanks,

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

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

Sent: Thursday, October 24, 2013 10:23 AM

To: Brian Glover

Subject: RE: Proposed Revisions to GWPs

Hi Brian,

My initial reaction is that it would not be an issue because of the direct correlation with only the annual

emissions. And since those have been calculated and determined to still fall under the analyses and

det erminations we have already made, it would be a similar revision. I would need to look at the new

total fuel numbers before I can say for certain. Since so much of the fuel usage in the application was

based on typical operations, I wondered if the calcula ted fuel usage already included enough to account

for the more realistic operating time for the cementing units on Developer.On a scheduling note, I spoke with Stan and he does not have any concerns with the cementing unit

change affecting the existing modeling. I started routing the revised permit and final determination for

internal review already. So, please let me know as soon as you have information on the fuel usage.

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, October 22, 2013 4:22 PM

To: Shepherd, Lorinda

Subject: RE: Proposed Revisions to GWPs

Good question. Would you be able to adjust the usage specified in the draft permit without issue?

I will run some numbers to see the difference but please let me know if this is an easy change or not.

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

Sent: Tuesday, October 22, 2013 1:51 PM

To: Brian Glover

Subject: RE: Proposed Revisions to GWPs

Brian,

The Statoil letter requesting a revision to the Developer cement engine usage does not mention any

change to overall fuel usage. Do you know if the increased hours will necessitate additional fuel beyond

what is specified in the draft permit? Or, can they realistically operate under the same fuel limits?

Thanks

, Lori Shepherd

Environmental Scientist

Air Permits Section

EPA Region 4

61 Forsyth Street

Atlanta, GA 30303

(404) 562

- 8435



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