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 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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which it is addressed and may contain confidential and/or privileged

material. Any review, retransmission, dissemination or other use of, or

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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