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Subject: Fw: Additional Information for the Anadarko EGOM PSD and Title V permit

From: Adam Brame - NOAA Federal <adam.brame@noaa.gov>

To: Rahul Pendse <rpendse@trinityconsultants.com>, 

Cc: Kyle Baker - NOAA Federal <kyle.baker@noaa.gov>, "Land, Eva" <Land.Eva@epa.gov>

Date: 08/06/2013 09:46 AM

Subject: Re: Additional Information for the Anadarko EGOM PSD and Title V permit

Mr. Pendse,

In response to your question, no new protected species have been listed in the Gulf of Mexico 

since the 2007 biological opinion. However, the 2007 opinion did not consider effects related to air 

emissions and therefore should not be relied upon. Options for your present project include making a "no 

effect" determination (producing a record that the emissions will have no effect on protected species), or 

making a "may affect" determination at which point the EPA will enter into informal consultation with our 

office. It is the federal action agency's (EPA) responsibility to make this determination.

If you have any questions concerning this process don't hesitate to call.

On Thu, Aug 1, 2013 at 3:23 PM, Adam Brame - NOAA Federal <adam.brame@noaa.gov> 

wrote:

Mr. Pendse,

While we acknowledge that no new protected species have been listed in the Gulf of Mexico 

since the 2007 biological opinion, that opinion did not consider effects related to air emissions 

and therefore should not be relied upon. Options for your present project include making a "no 

effect" determination (producing a record that the emissions will have no effect on protected 

species), or making a "may affect" determination at which point the EPA will enter into 

informal consultation with our office. It is the federal action agency's (EPA) responsibility to 

make this determination.

If you have any questions concerning this process don't hesitate to call.

Adam 

On Wed, Jul 31, 2013 at 3:42 PM, Rahul Pendse <rpendse@trinityconsultants.com> wrote:

Adam,

Thank you for your time in speaking with me. Per our discussion, I am forwarding 

you an email from Eva Land of EPA Region 4. Please refer to Endangered Species 

section in the email below. Specifically, please respond to EPA's question

"....EPA requests that Anadarko confirm with the USFWS and NMFS, in an informal

consultation, that no new endangered or threatened species or critical habitat have been

listed or are proposed to be listed since the prior consultation......"

 My contact information is listed in the digital signature below. Please let me know if 
you have any questions for me.

Best Regards,

Rahul Pendse

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

Rahul Pendse│Managing Consultant│rpendse@trinityconsultants.com 

Trinity Consultants│301 Main Street, Suite 900 │Baton Rouge, LA 70825

Office: 225-346-4003 │Fax: 225-346-4032│Cell: (714) 454-0518

----- Forwarded by Rahul Pendse/Trinity Consultants on 07/31/2013 02:38 PM -----

From: "Land, Eva" <Land.Eva@epa.gov>

To: "Rahul Pendse (rpendse@trinityconsultants.com)" <rpendse@trinityconsultants.com>, 

Cc: "Fortin, Kelly" <Fortin.Kelly@epa.gov>, "Ceron, Heather" <Ceron.Heather@epa.gov>

Date: 07/30/2013 03:55 PM

Subject: Additional Information for the Anadarko EGOM PSD and Title V permit

Rahul,

After looking  back through the EGOM PSD and Title V permit application we have two

additional requests for information. In regards to the Endangered Species Act, it appears

that the BOEM was contacted instead of the National Oceanic and Atmospheric

Administration (NOAA). The contacts at NOAA are Kyle Baker (kyle.baker@noaa.gov) or

Adam Brame (adam.brame@noaa.gov). Also, we would appreciate additional information

concerning the proposed actions that would be considered good combustion practices for

the units identified in the BACT analysis.

Endangered Species:

Under Section 7 of the Endangered Species Act (ESA), 16 U.S.C. § 1536, EPA has a

responsibility to ensure that any action authorized or permitted by EPA is not likely to

jeopardize the continued existence of any federally‐listed endangered or threatened

species or result in the destruction or adverse modification of such species’ designated

critical habitat.  The BOEM has performed an ESA formal consultation with United States

Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS) and

prepared a biological assessment as part of the National Environmental Policy Act reviews

for the OCS Leasing program for exploratory drilling activities on the lease blocks proposed

in this application.  

EPA may rely upon an ESA consultation or prepared biological assessment performed as

part of another agency’s action on the same activities.  However, since the MMS, NMFS and
USFWS consultations last occurred in the 2007‐2008 timeframe, EPA requests that

Anadarko confirm with the USFWS and NMFS, in an informal consultation, that no new

endangered or threatened species or critical habitat have been listed or are proposed to be

listed since the prior consultation.

If there are newly protected resources that could be affected by the project, the applicant

must use this information to prepare a Biological Assessment for the project and provide a

copy with the PSD application in order for EPA to carry out our responsibilities under ESA.  If

USFWS and NMFS indicate there are no newly protected species that could be impacted by

the project, the applicant should provide a copy of the letter documenting such to EPA.  

Good Combustion Practices:

The applicant has identified Good Combustion Practices as part of their best available

control technology (BACT) analysis for several emission units. The application dated

December 26, 2012, contains the specification sheets for the emission units in Appendix G

of the application. The application dated July 2, 2013, contains the specification sheets for

the emission units in the project in Appendix C of the application. However, the majority of

these sheets do not contain the manufacturer required and recommended maintenance

practices. The specification sheets for the wireline engines, (DR‐WC‐09 and DR‐WC‐10 as

well as DR‐WL‐01 and DR‐WL‐02,) do contain the required maintenance intervals. If the

recommended maintenance and good combustion practices are available for the remaining

engines and the flow back boiler identified in the BACT analyses the EPA would appreciate

this information to help make an informed decision.

Eva Land

Air Permits Section

EPA ‐ Region 4

61 Forsyth St., SW

Atlanta, GA 30303

Phone: 404‐562‐9103

______________________________________________________________

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