### RE: Staton OCS Air Permit Application (September 2012) Status Brian Glover to: Lorinda Shepherd 11/29/2012 09:14AM This message has been forwarded.

Great. Thanks.

From: Shepherd.Lorinda@epamail.epa.gov [ mailto:Shepherd.Lorinda@epamail.epa.gov] Sent: Thursday, November 29, 2012 8:13AM To: Brian Glover Cc: Fortin.Kelly@epamail.epa.gov; Michael carbon; Kyle Heitkamp; Forney.Kathleen@epamail.epa.gov Subject: RE: Statoil OCS Air Permit Application (September 2012) Status

Hi Brian,

GHGs will only be categorized as a Regulated Air Pollutant in Title V if they are overthe subject-to-regulation 100,000 C02ethreshold (mass based) forthe project. In the case of Statoil, since they were not overthe GHG threshold, GHGs would not be a Regulated Air Pollutant and not subject to the 2 TPY threshold forthe insignificant activities list Therefore, the drilling mud would still be an insignificant activity with respect to the title V portions ofthe permit I have not seen the emissions details forthe forklifts yet, but the same principle would apply to those as well.

Please let me know ifyou have any more questions.
Thanks, Lorinda (Lori) Shepherd Environmental Scientist Air Permits Section EPA Region4 61 Forsyth Street Atlanta, GA 30303 (404) 562-8435

""'Brian Glover---11/27/2012 05:32:49 PM---Lori, Comment 22 is related to drilling mud emissions as insignificant activities. Mud degassing do

From: Brian Glover <bglover@environcorp.com> To: Lorinda Shepherd/R4/USEPAIUS@EPA Cc: Kelly Fortin/R4/USEPAIUS@EPA, Michael Carbon <mcarbon@environcorp.com>, Kyle Heitkamp <kheitkamp@environcorp.com> Date: 11/27/2012 05:32PM Subject: RE: Statoil OCS Air Permit Application (September 2012) StatusLori,

Comment 22 is related to drilling mud emissions as insignificant activities. Mud degassing does result in potential C02e emissions greaterthan the insignificant criteria of 2tpy. Do you have any further guidance on whether or not C02e should be considered with regards to determining whether a source can be deemed an insignificant emissions unit under Part 71? We have a similar situation forforklifts where emissions ofall pollutants except GHGs are less than 2 tpy.

Ifmud degassing is not considered an insignificant source because ofC02e, should we include those sources on the EUD-2 form? We have already included them (MUD) on the EMISS and PTE forms in the original application.

Thanks for any guidance you can offer on this matter. Brian

From: Lorinda Shepherd [mailto:Shepherd.Lorinda@epamail.epa.gov] Sent: Thursday, October 11, 2012 12:43 PM To: DOEV@statoil.com; Michael Carbon; Kyle Heitkamp; Brian Glover 

### Cc: Kelly Fortin Subject: Statoil OCS Air Permit Application (September 2012) Status

Attached is a letterthat was mailed out in hard copy to you this morning regarding the completion status ofStatoirs Air Permit Application. The comments enclosed in the letter include a numberof requests for additional information. While we have requested a response within 60 days in the letter, I would like to emphasize that any information that might help us continue ourongoing technical review can be sentto us at any time. It does not necessarily have to be collected into one response document. Ifthere is any information that you feel may require more time to obtain, please give me or Kelly a call to discuss it Once you have reviewed ourcomments, we can set up a time to discuss any questions you may have.
Thanks, Lorinda(Lori)Shepherd Environmental Scientist Air Permits Section EPA Region4 61 Forsyth Street Atlanta, GA 30303 (404) 562-8435



### (See attached file: Statoil Application Incomplete Ltr 101012.PDF)

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