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EPA OCS Air Quality Permitting in the Gulf of Mexic0

Kelly Fortin US EPA Region 4 November 16, 2012. EPA OCS Air Quality Permitting in the Gulf of Mexic0. Diamond ocean confidence. EPA’s Statutory Authority. Clean Air Act ( CAA) Section 328 - (Title 3)

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EPA OCS Air Quality Permitting in the Gulf of Mexic0

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  1. Kelly Fortin US EPA Region 4 November 16, 2012 EPA OCS Air Quality Permitting in the Gulf of Mexic0

  2. Diamond ocean confidence

  3. EPA’s Statutory Authority Clean Air Act (CAA) Section 328 - (Title 3) Control air pollution from OCS sources in order to attain and maintain Federal and State ambient air quality standards & Comply with the provisions of part C of Title I -PSD (Prevention of Significant Deterioration-PSD) OCS Air Regulations - 40 CFR 55 (mirror statute) OCS Activities include, but are not limited to, platform and drill ship exploration, construction, development, production, processing and transportation

  4. EPA CAA Jurisdiction BOEM CAA Jurisdiction

  5. Regulatory Regimes Within State Seaward Boundaries (3 miles, 9 miles FL & TX) State laws apply & under state jurisdiction (SIPs/NAAQS) Within 25 Miles of a State’s Seaward Boundaries (projects - CA, AK, FL) Same as onshore - must comply with the federal, state and local requirements incorporated into 40 CFR part 55 May be delegated to Corresponding Onshore Area (CA,NC) Beyond the 25 miles- (projects -AK, Central Gulf) Federal requirements of 40 CFR part 55 (NSPS, PSD, NESHAP and Part 71) May be delegated to Corresponding Onshore Area

  6. 7 Corresponding Onshore Area Shoreline State tidelands 3 or 9 miles Inner OCS 25 miles OCS Regulatory Regimes Outer OCS State seaward boundary

  7. Region 4 Recent permits 2011-12 • Anadarko (PSD) – Final 6/11 Temporary Source, single well (90 days) • Shell (PSD and Title V) – Final 11/11 Portable source, multiple wells & completion 3 rigs – (10 yrs) • Eni (PSD and Title V) – Final 10/11 Temporary source, single well and completion (2 yrs) • Murphy (PSD) – Final 5/12 Temporary source, single well and tie back (90 days) • BHP Billiton (PSD and Title V) – 5/12 Temporary source – multiple wells 2 rigs – (2 yrs)

  8. Point of Compliance for NAAQS & Increment Where to locate receptors? (onshore (BOEM), state seaward boundary vs. 25 miles “same as”) Ambient Air vs. AQCR • Emissions from vessels servicing OCS sources (within 25 miles) are considered direct emissions from source (BOEM). • Development of equipment & emissions inventories (independent drilling contractors) Impact assessment challenges

  9. Flexibility of PSD & Title V to allow for single wells, multi-wells, multi-rig permits • Actual emissions data from exploratory drilling rigs in the field • Operators getting real time data on emissions and fuel use. • Very cooperative & professional working relationship with good information exchange What’s working

  10. www.epa.gov/region4/air/permits/ocspermits/ Contact info: Kelly Fortin USEPA Region 4-Air Permits fortin.kelly@epa.gov Region 4’s OCS Website

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