( 

Shell Offshore Inc. 

3601 C Street, Suite 1000 

Anchorage, AK 99503 

December 10, 2010 

Natasha Greaves 

Project Manager/Permit Writer 

United States Environmental Protection Agency, Region 10 

1200 Sixth Avenue 

Seattle, Washington, 98101 

Re: Notice of Intent to Submit an Air Permit Application for Kulluk Floating 

Drilling Platform – Beaufort Sea 

Dear Ms. Greaves: 

Shell Offshore Inc. (Shell) submits the attached Notice of Intent (NOI) to submit a 

minor source permit application to EPA Region 10. This application will be for 

operation of the Kulluk floating drilling platform (Kulluk) in the Beaufort Sea. 

Please contact Mark Schindler (336-279-0763), Rodger Steen (303-807-8024), or me 

(907-646-7112) for any additional detail EPA should need related to this NOI. 

We appreciate your attention to this matter. 

Sincerely, 

Susan Childs 

Regulatory Affairs Manager, Alaska Venture 

Attachments: 

cc: Jeff Walker, BOEMRE 

 Jan Hastings, R10 

 Dave Bray, R10 

 Herman Wong, R10 

Doug Hardesty, R10 

 Paul Boys, R10 

Lance Tolson, Shell 

Mark Duplantis, Shell 
Nicole St. Amand, Shell 

Chuck Centore, Shell 

Kirk Lilley, Kirk Lilley, PLLC 

Alan Schuler, ADEC, DAQ 

Gene Pavia, UIC 

Mark Schindler, Octane, LLC 

Rodger Steen, Air Sciences Inc. 

 Eric Hansen, ENVIRON International Corporation 
Kulluk NOI 

December 10, 2010 

Page 1 of 4 

Notice of Intent to Submit an Application for a Minor Source Preconstruction Permit 

Kulluk Floating Drilling Platform - Beaufort Sea, Alaska Exploratory Drilling Program

Shell Offshore Inc. (Shell) submits the information below pursuant to the 40 CFR Part 55 Outer 

Continental Shelf (OCS) Air Regulations, Section 55.4 Requirements to submit a Notice of Intent (NOI). 

Paragraph 55.4(b) lists nine specific requirements for exploratory sources to be included in the NOI. Each 

of the requirements is paraphrased below followed by Shell’s response. 

Requirement No. 1 - 40 CFR 55.4(b)(1): General company information. 

The pertinent owner, owner’s agent, and facility contact information is presented in Table 1. 

Table 1: Company Information 

Owner and Facility Contact 

Name Shell Offshore Inc. 

Address 3601 C Street, Suite 1314, Anchorage, AK 99503 

Contact Mark Duplantis 

Contact phone number (907) 646-7122 

Contact e-mail address Mark.Duplantis@shell.com 

Owner’s Agent 

Name Shell Offshore Inc. 

Address 3601 C Street, Suite 1314, Anchorage, AK 99503 

Contact Susan Childs 

Contact phone number (907) 646-7112 

Contact e-mail address susan.childs@shell.com

Requirement No. 2 - 40 CFR 55.4(b)(2): Facility description. 

The Kulluk Floating Drilling Platform (Kulluk) will be an exploratory oil and gas drilling operation (North 

American Industry Classification System [NAICS] code 211111 Crude Petroleum and Natural Gas 

Extraction) which will operate on any of the current oil and gas leases of record , regardless of ownership, 

on federal OCS waters located in the Beaufort Sea. These leases are shown on Figure 1.

Each exploration drilling season will fall within the period from July through December, with the Kulluk

being an OCS source for up to 120 days within that period, weather and ice conditions permitting. 

The Kulluk, as an OCS source, will have a fleet of associated vessels and it, with its associated fleet, will 

operate independently of other possible exploration drilling programs and OCS sources. Exploration 

drilling activities will be conducted from the Kulluk, an Arctic Class IV hull design drilling vessel without 

self propulsion. The Kulluk is equipped with a drilling derrick, a set of generators to power the drill 

motors, and other engines for related activities. It will also have boilers for heat and an incinerator. The 

engines and boilers will be diesel-fueled. The Kulluk’s associated fleet will consist of an ice management 

component, an oil spill response (OSR) component, possible quartering vessel, and resupply vessels. The 

purposes of the two ice management vessels are to re-direct ice floes around the Kulluk when it is drilling 

and to handle the Kulluk’s anchors during connection and separation from the sea floor. The OSR fleet is 

expected to consist of one management vessel and several smaller (under 50-foot craft) for placing and 

moving containment floats, if needed. These small crafts will normally be stored on the management 

vessel and will only be in the water for exercises and emergency oil spills. A more complete description 
Kulluk NOI 

December 10, 2010 

Page 2 of 4 

of the Kulluk and associated fleet, including photographs and diagrams, will be provided in the air permit 

application. 

Requirement No. 3 - 40 CFR 55.4(b)(3): Estimate of the proposed project’s potential emissions (PTE) 

and Requirement No. 4 – 40 CFR 55.4(b)(4): Description of all emission points including associated 

vessels. 

Pursuant to 40 CFR 55.2, Shell currently defines the Kulluk as an OCS source between the time the Kulluk

is declared by the Kulluk’s on-site company representative to be secure and stable in a position to 

commence exploratory activity at the drill site through the time that the Kulluk’s on-site company 

representative declares that, due to retrieval of anchors or disconnection of anchors, it is no longer 

sufficiently stable to conduct exploratory activity at the drill site. 40 CFR 55.2 also specifies that vessels 

servicing or associated with the OCS source shall be considered as part of the OCS source’s potential to 

emit (PTE) determination while at the source and en route to or from the source, when they are within 25 

miles (40 km) of the source. The project’s primary air contaminants include nitrogen oxides (NOx), 

carbon monoxide (CO), small-diameter particulate matter (PM2.5), volatile organic compounds (VOC), 

and sulfur dioxide (SO2). Emissions of each criteria pollutant during the time that the Kulluk is an OCS 

source as defined above, including emissions from its associated fleet, are estimated to be less than the 

250-ton per year threshold for major source (PSD) New Source Review so the Kulluk will be a minor OCS 

source. The project’s annual emissions of hazardous air pollutants (HAPs) will be well below the 

applicable 10-ton single HAP/25-ton all HAPs major source MACT threshold. 

The Kulluk’s sources are expected to consist of six emission unit groups. Four of the emission unit groups 

consist of diesel engines, the fifth consists of boilers, and the sixth consists of an incinerator. Of the four 

engine groups, the first consists of the primary generators used for drilling, and the second consists of the 

engines powering the hydraulic pump units [HPUs] which are used only for drilling the mud line cellars. 

The third group consists of the cranes, and the fourth group consists of unspecified small and seldom 

used engines. The associated fleet of vessels includes ice management vessels, an oil spill response 

vessel, possible quartering vessel, and resupply vessels; all of which have propulsion engines, generators 

and other miscellaneous sources of emissions. Current estimates of the project’s potential annual 

emissions, including both Kulluk sources and associated fleet sources are presented in Table 2. 

Table 2: Kulluk Estimated Potential Annual Emissions (PTE) 

Emissions 

NOx

(tpy) 

CO 

(tpy) 

PM10

(tpy) 

SO2

(tpy) 

VOC 

(tpy) 

HAPs 

(tpy) 

Kulluk 

Ice Management Fleet 

OSR Fleet    

Quartering Vessel 

Total Kulluk and Fleet 240 160 70 3 36 3 

Notes: < = less than 

 CO = carbon monoxide 

 HAPs = hazardous air pollutants 

 NOx = nitrogen oxide 

 PM10 = particulate matter the size of 10 micrometers or less 

 SO2 = sulfur dioxide 

 VOC= non-ethane and non-methane volatile organic compounds 

 tpy = tons per year 
Kulluk NOI 

December 10, 2010 

Page 3 of 4 

Requirement No. 5 – 40 CFR 55.4(b)(5): Estimate of quantity and type of fuels and raw materials to be 

used. 

The estimated annual diesel fuel consumption is six million gallons. Shell would only purchase UltraLow-Sulfur-Diesel (ULSD) for both the Kulluk and its associated fleet sources. ULSD contains a 

maximum of 15 parts per million (ppm) sulfur grade of fuel. 

Requirement No. 6 – 40 CFR 55.4(b)(6): Description of proposed air pollution control equipment. 

In addition to the purchase of ULSD as stated above, and subject to additional engineering evaluation, 

Shell intends to employ the following control equipment: 

 Selective catalytic reduction (SCR)/oxidation catalysts on the Kulluk primary generators which 

are the drilling engines to control NOx, PM, VOCs, and CO emissions. 

 Selective catalytic reduction (SCR)/oxidation catalyst on the ice management vessels’ 

main propulsion engines to control NOx, PM, VOCs, and CO emissions, if vessels are available on 

which these controls are already or can be installed. 

 Oxidation catalysts on the larger of the remaining Kulluk engines. 

Requirement No. 7 – 40 CFR 55.4(b)(7): Proposed limitations on source operations or any work 

practice standards affecting emissions. 

Shell will seek several enforceable permit limits on emissions that could include, but not be limited to, 

one or more of the following: 

 Diesel fuel quality: Kulluk and associated fleet will use only ULSD fuel. 

 Daily NOx and PM emissions from each emission unit group will be capped. 

 The OCS source will be limited to 120 days per year. 

Requirement No. 8 – 40 CFR 55.4(b)(8): Other information affecting emissions. 

None at this time. 

Requirement No. 9 – 40 CFR 55.4(b)(9): Such other information as may be necessary to determine the 

applicability of onshore requirements. 

Most of the Beaufort Sea leases are within 25 miles of the Alaska seaward boundary and are subject to 

Alaska regulation. The Corresponding Onshore Area for the Kulluk in the Beaufort Sea and within 25 

miles of the Alaska seaward boundary is the Northern Alaska Intrastate Air Quality Control Region that 

has been classified by the Alaska Department of Environmental Conservation (ADEC) as an Air Quality 

Class II area. 

 

Requirement No. 9 – 40 CFR 55.4(b)(10): Such other information as may be necessary to determine the 

source's impact in onshore areas. 

Information needed to determine the impact of the Kulluk OCS source in onshore areas will be provided 

later in a permit application to EPA Region 10. 

 
Kulluk NOI 

December 10, 2010 

Page 4 of 4 

Figure 1: Beaufort Sea Current Lease Block