From: Land, Eva

Sent: Thursday, February 20, 2014 4:17 PM

To: Rahul Pendse; Carlson, Sara; Kathryn Maness 

(Kathryn.Maness@anadarko.com)

Cc: Fortin, Kelly

Subject: BlackHawk/BlackHornet Completeness Letter

Attachments: Completeness Letter 022014.pdf

The BlackHawk and BlackHornet applications were deemed complete, and a completeness letter is 

attached. 

From: Rahul Pendse [mailto:RPendse@trinityconsultants.com] 

Sent: Thursday, February 20, 2014 3:12 PM

To: Krivo, Stan

Cc: Land, Eva; Carlson, Sara; Kathryn Maness (Kathryn.Maness@anadarko.com); Fortin, Kelly

Subject: RE: Anadarko - BlackHawk/BlackHornet 

Hello Stan,

Thanks for the update. On behalf of Anadarko, I would like to thank you and your team for working with 

us in getting the questions resolved. Feel free to contact me or Sara Carlson in case of questions during 

the detailed review. 

Regards,

Rahul

................................................................................................................

Rahul Pendse

Managing Consultant

Trinity Consultants – Baton Rouge

301 Main Street, Suite 900 | Baton Rouge, Louisiana 70825

Office: 225-346-4003 | Mobile: 714-454-0518

Email: rpendse@trinityconsultants.com

From: Krivo, Stan [mailto:Krivo.Stanley@epa.gov] 

Sent: Thursday, February 20, 2014 2:03 PM

To: Rahul Pendse

Cc: Land, Eva

Subject: RE: Anadarko - BlackHawk/BlackHornet 

Rahul,

Thanks for the responses to the remaining review comments. I believe Anadarko’s responses have 

resolved outstanding comments # 19, 21, 22, and 24. I have provided this information to Eva.

I appreciate your help in resolving these and the other air quality impact related review comments. 

Again thanks...sjk
From: Rahul Pendse [mailto:RPendse@trinityconsultants.com] 

Sent: Friday, February 07, 2014 2:52 PM

To: Krivo, Stan

Cc: Land, Eva; Carlson, Sara; Kathryn Maness (Kathryn.Maness@anadarko.com)

Subject: RE: Anadarko - BlackHawk/BlackHornet 

Hello Stan,

Please find a response to the comment no. 19 in your email below attached herewith. With this 

submittal, Anadarko has provided responses to all the comments. Let me or Sara Carlson know if you 

have any questions.. Thanks for your help.

Regards,

Rahul

................................................................................................................

Rahul Pendse

Managing Consultant

Trinity Consultants – Baton Rouge

301 Main Street, Suite 900 | Baton Rouge, Louisiana 70825

Office: 225-346-4003 | Mobile: 714-454-0518

Email: rpendse@trinityconsultants.com

From: Rahul Pendse 

Sent: Wednesday, February 05, 2014 12:33 PM

To: 'Krivo, Stan'

Cc: Land, Eva; 'Carlson, Sara'; Kathryn Maness (Kathryn.Maness@anadarko.com)

Subject: RE: Anadarko - BlackHawk/BlackHornet 

Hello Stan,

Please find responses to the comments (except for comment no. 19) in your email below attached 

herewith. Let me or Sara Carlson know if you have any questions. Sara and I are working on a response 

for comment no. 19 and we will get back to you as soon as possible. Thanks for your help.

................................................................................................................

Rahul Pendse

Managing Consultant

Trinity Consultants – Baton Rouge

301 Main Street, Suite 900 | Baton Rouge, Louisiana 70825

Office: 225-346-4003 | Mobile: 714-454-0518

Email: rpendse@trinityconsultants.com

From: Krivo, Stan [mailto:Krivo.Stanley@epa.gov] 

Sent: Thursday, January 16, 2014 2:44 PM

To: Rahul Pendse
Cc: Land, Eva

Subject: RE: Anadarko - BlackHawk/BlackHornet 

Rahul,

We keep trying to catch each other concerning the remaining air quality impact concerns from the 

comments/clarification requests provided in the incompleteness letter for the BlackHawk and

BlackHornet PSD permit applications. Similar to the Bob Douglas application, the provided responses to 

our incompleteness comments did not resolve all items.

To facilitate our discussion and completing the records for these applications, the following provides 

the remaining comments not resolved by Anadarko’s 12 November 2013 response. 

19. Provide reason the impact assessment using a single supply boat is appropriate given simultaneous 

operation of multiple supply boats is planned.

The total fuel limit provided for all utilized supply boats is provided as justification. The emissions from 

the modeled supply boat was indicated to be based on the proposed fuel limit so the impact modeling 

properly represents the impacts from one or more supply boat operations.

The fuel limit for the all supply boats is based on 24-hour and annual periods. Considering the short 

term standards (e.g. 1-hour NAAQS), the only way the modeled single supply boat would represent the 

worst-case supply boat impact would be if the fuel limit included an hourly value and the emissions used 

in the modeling were based on the hourly fuel limit consumed by the single boat.

The application indicates the shortest period for supply boat fuel limit was 24-hours. Multiple supply 

boats could operate under the 24-hour fuel limit, although not for the full 24-hours period, producing 

larger hourly emissions and greater impacts than that associated with a single boat. 

21. Ozone data used in CALPUFF modeling analyses

The use of ozone data representative of the modeling domain and/or the PSD Class I area is 

appropriate. Data acquired at Sumatra, FL would be appropriate for St. Marks and Bradwell Bay Class I 

impact analyses. The appropriateness for application at the Breton PSD Class I area has not been 

addressed.

22. Screening ambient concentration levels for soils and vegetation.

The EPA referenced screening ambient concentration levels were not addressed in the response. Rather 

the response reiterated the fact that the provided qualitative conclusion was based on the Secondary 

NAAQS. Comparison of the screening levels in “A Screening Procedure for Impacts of Air Pollution 

Sources on Plants, Soils, and Animals” were not provided.

24. Confirm the Breeze software used the unmodified versions of the regulatory CALPUFF modeling 

system.
The response indicates the approved versions of the CALPUFF modeling system were 

used. Confirmation is needed that the BREEZE modeling system uses for this analysis incorporates the 

unmodified regulatory versions of CALMET, CALPUFF, and CALPOST.

I suggest we discuss these items and the needed additional information before you prepare any 

response.

Thanks...sjk

From: Rahul Pendse [mailto:RPendse@trinityconsultants.com] 

Sent: Thursday, January 16, 2014 11:08 AM

To: Krivo, Stan

Cc: Land, Eva; Carlson, Sara; Kathryn Maness (Kathryn.Maness@anadarko.com)

Subject: Anadarko - BlackHawk/BlackHornet 

Hello Stan,

Eva Land informed me that you have a few follow up questions related to the BlackHawk-BlackHornet 

incompleteness letter responses submitted by Anadarko and Trinity. Please let me know if you have 

availability tomorrow or next week to discuss your questions. Thanks for your help.

................................................................................................................

Rahul Pendse

Managing Consultant

Trinity Consultants – Baton Rouge

301 Main Street, Suite 900 | Baton Rouge, Louisiana 70825

Office: 225-346-4003 | Mobile: 714-454-0518

Email: rpendse@trinityconsultants.com

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