Air Quality Permit proposed to Shell Gulf of Mexico to Operate the Frontier Discoverer Drillship in the Chukchi Sea, Alaska PUBLIC COMMENT PERIOD: AUGUST 20 - OCTOBER 5, 2009 The U.S. Environmental Protection Agency (EPA) is seeking public comment on a proposed Clean Air Act permit for Shell Gulf of Mexico Inc. (Shell), 3601C Street, Suite 1000, Anchorage. Alaska 99503. The proposed permit will allow Shell to operate the Frontier Discoverer drillship and its fleet for a multi-year exploratory oil and gas drilling program within its current lease blocks from lease sale 193 on the Chukchi Sea outer continental shelf (OCS), beyond 25 miles from Alaska's seaward boundary. Because the drillship operations would be a "major" source, the permit must ensure that the operations meet the requirements of the Prevention of Significant Deterioration (PSD) program. The proposed permit is also based on non-guideline ISC3-PRIME modeling system used to predict air pollutant concentrations. You are invited to comment on the proposed Shell OCS/PSD permit for the Chukchi Sea. You may also comment on the non-guideline methodology used to determine ambient air quality impacts. You may submit oral or written comments on the proposed permit at the public hearings. You do not need to attend the public hearings in order to submit written comments. You may send written comments to the address above. All comments must be received by EPA by the end of the public comment period October 5, 2009. Send comments on the proposed permit to: EPA Region 10 Shell Chukchi OCS Air Permit 1200 6th Ave, Ste. 900, AWT-107 Seattle, Washington 98101 Fax: 206-553-0110 Email: R10ocsairpennits@epa.gov For questions about the proposed permit, contact: Pat Nair, Permit Writer EPA Region 10 Phone: 208-378-5754 Fax: 208-378-5744 Email: nair.pat@epa.gov PUBLIC HEARINGS AND INFORMATIONAL MEETINGS September 23, 2009 North Slope Borough Assembly Room 1689 Okpik Street, Barrow, Alaska Informational meeting: 3 p.m. - 5 p.m. Public hearing: 5 p.m. - (end of comments) September 25, 2009 Loussac Public Library Assembly Chamber 3600 Denali Street, Anchorage, Alaska Informational meeting: 10 a.m. - 11 a.m. Public hearing: 11 a.m. - 2 p.m. Inupiat translation will be available at the meeting and hearing in Barrow. You can also participate in the public hearing by telephone at the teleconference centers in Atqasuk, Wainwriglit. Point Lay, and Point Hope. For More Information Suzanne Skadowski, Community Involvement Coordinator EPA Region 10, Seattle, Washington 206-553-6689 or toll-free 800-424-4372 Email: skadowski.suzanne@epa. go v Web: http://vosemite.epa.gov/R10/airoage.nsf/Pennits/chukchiaD EPA Air Permit Information Sheet 1 ------- PERMIT DOCUMENTS AVAILABLE EPA has prepared a detailed document called a "statement of basis" that explains the derivation of the proposed permit conditions and the reasons for them. The record for this permit action includes Shell's application and addendums, all supplemental information submitted by Shell, the statement of basis, the proposed OCS/PSD permit and all other materials relied on by EPA. The permit application, the statement of basis for the permit, and the proposed OCS/PSD permit are available at the locations listed below. Please call in advance for available viewing times. Barrow City Office, 2022 Ahkovak Street, Barrow, Alaska, 907-852-4050 Wainwright City Office, 1217 Airport Road, Wainwright, Alaska, 907-763-2815 Atqasuk City Office, 5010 Ekosik Street, Atqasuk, Alaska, 907-633-6811 Kali School Library, 1029 Ugrak Ave, Point Lay, Alaska, 907-833-2312 Point Hope City Office, 530 Natchiq Street, Point Hope, Alaska, 907-368-2537 EPA Alaska Office, Federal Building, 222 West 7th Ave, Anchorage, Alaska, 907-271-5083 The permit application, statement of basis, proposed permit and a permit information sheet are also available on the web at: http://vosemite.epa.gov/R10/airpage.nsf/Permits/chukcliiap. The permit record is available at the EPA Region 10 Library, 1200 6th Ave, Seattle, Washington, 206-553-1259. To request a copy of these materials or a copy of the permit record, contact Suzanne Skadowski as described above. Any interested person may submit written comments on the proposed permit during the public comment period. If you believe any condition of this permit is inappropriate, you must raise all reasonably ascertainable issues and submit all reasonably available arguments supporting your position by the end of the comment period. Any documents supporting your comments must be included in full and may not be incorporated by reference unless they are already part of the record for this permit or consist of state or federal statutes or regulations, EPA documents of general applicability, or other generally available referenced materials. These proceedings are subject to the requirements of 40 C.F.R. Part 124. All timely comments will be considered in making the final decision, included in the record, and responded to by EPA. EPA will prepare a statement of reasons for changes made in the final permit and a response to comments received and will provide all commenters with notice of the final permit decision. INFORMATION ABOUT THE PROPOSED PERMIT Sources of Air Emissions The Discoverer is a turret-moored drillsliip with air emission sources that include generators for the drilling systems and associated self-powered equipment (such as air compressors, hydraulic pumps, cranes, boilers and other small sources), small boilers for heating and a small incinerator. The Discoverer's operations at an exploratory drill site will be supported by an associated fleet that consist of a primary icebreaker, a secondary icebreaker, a supply ship, an oil spill response ship, and oil spill workboats. The supply ship will make up to eight trips a year from Wainwright or Barrow to the Discoverer. As provided in the OCS regulations, emissions from a support vessel are counted as emissions from the OCS source when the Discoverer is anchored at a drill site and the support vessel is within 25 miles of the Discoverer. The main pollutants that will be emitted from the Discoverer and its support vessels are nitrogen oxides (NOx), sulfur dioxide (S02), particulate matter (PM, PM10, and PM2.5), carbon monoxide (CO), and volatile organic compounds (VOC). Air Pollution Controls The proposed OCS/PSD permit requires Best Available Control Technology (BACT) on the Discoverer, to limit emissions of air pollutants while the Discoverer is anchored at a drill site. Control measures on the Discoverer include the use of ultra-low sulfur diesel fuel to reduce emissions of S02, Selective Catalytic Reduction controls and an oxidation catalyst on the six largest engines to reduce emissions of NOx, and catalyzed diesel particulate filters on all smaller, older engines to limit emissions of VOC, CO, and particulate EPA Air Permit Information Sheet 2 ------- matter (PM, PM10, and PM2.5). The proposed permit also requires the use of good operation and maintenance procedures and good combustion practices on the Discoverer and the support vessels to ensure emission limits are met. The permit also requires record-keeping and reporting necessary to determine compliance with the permit terms and conditions. Air Quality Demonstration As part of the permit application process. Shell is required to use air quality monitoring information and modeling to demonstrate that air quality in the vicinity of their drilling operations in the Chukchi Sea will continue to meet the National Ambient Air Quality Standards and PSD increments. In addition to emission limitations and permit requirements that impose BACT, the proposed Shell OCS/PSD permit also includes annual emission limits for NOx, daily emission limits for PM10 and PM2.5, and other operational restrictions to ensure that emissions from the Discoverer and its support vessels do not exceed the National Ambient Air Quality Standards or PSD increments while the Discoverer is anchored at a drill site. Examples of operational restrictions include: a limit on drilling to a total of 168 days between July 1 and December 31 of each year, and limits on the amount of fuel that can be combusted. The proposed permit is based on the non-guideline ISC3 -PRIME modeling system used to predict air pollutant concentrations. This modeling system has not been approved by the EPA for general use, but has been tested for use in arctic conditions. PSD increments are limits on the amount that air quality can be degraded by actual emissions. The following percentages of the applicable PSD increments are predicted to be consumed by Shell's operations: 3-hour Sulfur Dioxide (S02): 14.45 %; 24-hour S02: 30.77%; annual S02: 10.50%; annual Nitrogen Dioxide (N02): 83.20%; 24-hour Particulate Matter Less than 10 (PM10): 94.00%; and annual PM10 11.18%. The proposed permit, if effective, would allow the Discoverer and the support vessels to emit air pollutants as specified in Table 1. Table 1 - Permitted Air Pollutant Emissions from Discoverer and Associated Fleet as OCS Source at all Locations Air Pollutant Emissions (tons per year) Carbon Monoxide 762 Nitrogen Oxides (NOx) 1965 Particulate Matter Less than 2.5 (PM2.5) 184 Particulate Matter Less than 10 (PM10) 210 Particulate Matter 260 Sulfur Dioxide (S02) 181 Volatile Organic Compounds (VOC) 166 Additional Project Information EPA Region 10 has also received five notices of intent from Shell requesting authorization for coverage under the Arctic General Permit (AKG-28-0000) for exploration activities in its current leases blocks from lease sale 193 within the Chukchi Sea. Shell's notices of intent and information about the Arctic General Permit are available at: http://vosemite.epa.gov/RlOAVATER.NSF/NPDES+Permits/General+NPDES+Permits. Mailing List If you would like to be added to our mailing list to receive future information about this air permit or other EPA permits in the Chukchi and Beaufort Seas, contact: Suzanne Skadowski, Community Involvement Coordinator EPA Region 10, Seattle, Washington 206-553-6689 or toll-free 800-424-4372 Email: skadowski.suzanne@epa.gov EPA Air Permit Information Sheet 3 ------- |