RE: BHPB -Sake Air Permit Application - Scheduled Meeting 1/25112

Kelly Fortin to: Wilson, Susan 01/18/2012 12:47 PM

Cc: Andrew Porter, Art Hofmeister, Bill Bruscino

SusanThanks for the update. We understand that you would like to cancel the meeting previously scheduled for

next Thursday. We’ll let folks know in our group that the meeting is cancelled.

In our review of the package that was submitted in December, we note that a few unit changes were made -

of note one emissions unit was added to the application and several wireline diesel engines were

removed from the BACT analysis. We have concerns regarding the exclusion of the wireline diesel

engines - the effect being that they seem to be treated more as support vessels, rather than part of the

OCS source. Given that the OCS source definition includes “any equipment, activity, or facility,” we do

not believe these units should be excluded - and assume you would rather us move forward with including

BACT for these units, rather than deeming some portion of the application incomplete. Andy and I spoke

briefly with Bill Bruscino last Friday to find out why this change was made to the application at this point.

Bill explained that there was some difficultly getting requested information from the wireline supplier. I

suggested that we may not be that far off with respect to getting this resolved - and perhaps we could

discuss in more detail the specific units of concern (i.e. the 1 978 Detroit diesels), rather than spending

more time with further analysis on your end. We would also like more info on the flexibility you have in the

use of specific wireline units. If the wireline supplier with be changing out their inventory, I would like to

build that flexibility into the permit, rather than running into the situation where a change-out of a wireline

unit would trigger a permit modification.

We discussed with Bill the possibility of having a call to discuss the wireline units this week. However, I

didn’t realize that Art is out of the office for the rest of the week. Given that he has written the BACT

section of the permit, I would like to have him on the call when we discuss the wireline approach. Please

let me know of some times you would have available next week to discuss the wireline units. If you would

like to touch base with me before that, please feel free to give me a call. I can get back to you when I

have a break in the training course we are taking this week.

ThanksKelly

Wilson, Susan” BHPBIWOnPeokm(GOMc3kePfäj

From: ‘Wilson, Susan” <Susan.Wilson@bhpbilliton.com>

To:. Kelly Fortin/R4/USEPA/US@EPA, Andrew Porter/R4/USEPAIUS@EPA, Art

Hofmeister/R4/USEPAIUS@EPA

Cc: ‘Wilson, Susan” <Susan.Wilson@bhpbilliton.com>

Date: 01/17/2012 02:32 PM

Subject: RE: BHPB -Sake Air Permit Application -Scheduled Meeting 1/25/12

BHP Billion Petroleum (GOM) Inc

Sake Prospect Drilling Prospect

PSD/Title V major Source Permit Application

Afternoon All,
A meeting had been scheduled for January 25, 201 2 for BHPB, Transocean and Trinity

Consultants to present our responses from the teleconference call and email that

occurred on November 10, 2012. As a reminder, there were 8 comments generated

from our September 30, 201 1 submittal.

BHPB submitted an addendum to the application on December 21 , 2012 that

addressed 7 of the 8 comments. The following sections of the Application were

revised:

. Section 3 (Emission Calculations);

. Section 4 (Regulatory Applicability Analysis);

. Section 5 (BACT Analysis);

. Section 6 (Part 71 Forms);

. Appendix A (only C. ft Luigs and DDI emission calculations); and

. Appendix B (additional engine certifications).

The remaining comment on the SINOx Control Technology will be submitted to EPA on

January 19, 2012.

BHPB believes it would be beneficial for EPA be given an opportunity to review the data

and either ask for additional information at which time it can be determined whether a

meeting would be the preferred venue. Therefore, BHPB requests to cancel the

meeting on January 25, 2012.

Thank you for your consideration with this matter and your assistance and guidance

throughout the permit process.

Susan Wilson

Senior Regulatory Specialist

BHP Billiton Petroleum

1360 Post Oak Boulevard, Suite 150

Houston, Texas 77056-3030 USA

Mail to Susan.Wilsoncbhpbilliton.com

Internet http:llwww.bhDbilliton.com

Phone +1 713-599.6349

Cell +1 832-526-3298

Fax +1 713-499-5535

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