Air
Quality Permit Proposed to Shell Gulf of Mexico
to Operate the Frontier Discoverer Drillship
in the
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,
You are invited to comment on
the proposed Shell OCS/PSD permit for the
Send comments on the
proposed permit to:
EPA Region 10
Shell Chukchi OCS Air
Permit
Fax: 206-553-0110
Email: R10ocsairpermits@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
Informational meeting: 3 p.m.
– 5 p.m.
Public hearing: 5 p.m. – (until
end of comments)
September 25, 2009
Loussac Public Library Assembly Chamber
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, Wainwright, Point Lay, and Point Hope.
For More Information
Suzanne Skadowski, Community
Involvement Coordinator
EPA Region 10,
206-553-6689 or toll-free
800-424-4372
Email: skadowski.suzanne@epa.gov
Web: http://yosemite.epa.gov/R10/airpage.nsf/Permits/chukchiap
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.
Point Hope City Office,
EPA Alaska Office,
The permit application,
statement of basis, proposed permit and a permit information sheet are also
available on the web at: http://yosemite.epa.gov/R10/airpage.nsf/Permits/chukchiap.
The permit record is available at the EPA Region 10 Library,
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 drillship 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 (SO2), 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 SO2,
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 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 (SO2): 14.45 %; 24-hour SO2:
30.77%; annual SO2: 10.50%;
annual Nitrogen Dioxide (NO2): 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 below.
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 (SO2) 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 in the
Shell’s notices of intent and
information about the Arctic General Permit are available at: http://yosemite.epa.gov/R10/WATER.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
Suzanne Skadowski
Community Involvement
Coordinator
EPA Region 10, Seattle,
Washington
206-553-6689 or toll-free
800-424-4372
email: skadowski.suzanne@epa.gov.