From: Rahul Pendse <RPendse@trinityconsultants.com>

Sent: Wednesday, February 05, 2014 1:33 PM

To: Krivo, Stan

Cc: Land, Eva; Carlson, Sara; Kathryn Maness 

(Kathryn.Maness@anadarko.com)

Subject: RE: Anadarko - BlackHawk/BlackHornet 

Attachments: Anadarko PSD-Title V EGOM BHBH application - Response to Email 

Response from Stan Krivo v5.pdf

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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