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 over the subject-to-regulation 100,000 C02e threshold (mass 

based) for the project. In the case of Statoil, since they were not over the 

GHG threshold, GHGs would not be a Regulated Air Pollutant and not 

subject to the 2 TPY threshold for the insignificant activities list 

Therefore, the drilling mud would still be an insignificant activity with 

respect to the title V portions of the permit I have not seen the emissions 

details for the forklifts yet, but the same principle would apply to those as 

well. 

Please let me know if you 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) Status 
Lori, 

Comment 22 is related to drilling mud emissions as insignificant activities. Mud 

degassing does result in potential C02e emissions greater than the insignificant 

criteria of 2 tpy. 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 for forklifts where emissions of all pollutants except GHGs are less 

than 2 tpy. 

If mud degassing is not considered an insignificant source because of C02e, 

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 letter that was mailed out in hard copy to you this morning 

regarding the completion status of Statoirs Air Permit Application. The 

comments enclosed in the letter include a number of 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 our ongoing technical review can be sent to us at 

any time. It does not necessarily have to be collected into one response 

document. If there 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 our comments, 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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