From: Adam Brame

- NOAA Federal [adam.brame@noaa.gov]

Sent: Tuesday, August 06, 2013 10:46 AM

To: Rahul Pendse

Cc: Kyle Baker

- NOAA Federal; Land, Eva 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 o ur 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 t he 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 c ritical 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 th e 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 mustuse 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 document ing 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 th e 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 she ets 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 recommend ed 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 Se ction

EPA

- Region 4 61 Forsyth St., SW
Atlanta, GA 30303

Phone: 404

- 562

- 9103

_________________________________________________________________________

The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or

entities other than the intended recipient is prohibited. If you Received this in error, please contact the sender and delete the material from any computer.

_________________________________________________________________________

--Adam Brame

National Marine Fisheries Service NOAA Southeast Regional Office

Protected Resources Division

263 13th Ave. South St. Petersburg, FL 33701 ph: (727) 209

- 5958

fax: (727) 824

- 5309

--

Adam Brame

National Marine Fisheries Service NOAA Southeast Regional Office

Protected Resources Division

263 13th Ave. South St. Petersburg, FL 33701 ph: (727) 209

- 5958 fax: (727) 824

- 5309