The U.S. Environmental Protection Agency has issued air quality control minor permits for Shell’s planned drilling program in the Beaufort Sea. There are separate permits for operations by the Kulluk drilling platform and for the Frontier Discoverer drilling vessel. The permits also encompass a support fleet that includes 18 other vessels.
Initially Shell plans to use the Beaufort Sea fleet for exploratory drilling at its Sivulliq prospect, formerly Hammerhead, on the western side of Camden Bay in the summer of 2007.
During the public review period for the draft permits, EPA received comments both in favor of and against issuing the permits.
“After thorough review and careful consideration of the comments requesting that the permits be denied, EPA has decided to issue the permits allowing Shell to conduct exploratory drilling in the Beaufort Sea,” EPA said. “… The final permits that EPA is issuing for Shell are designed to meet the requirements of the Clean Air Act and to protect the members and natural resources of the Alaska Native villages.”
In its permit applications Shell provided data supporting limits on total NOX and sulfur dioxide limits below the levels that would trigger what EPA terms a “prevention of significant deterioration.” By voluntarily keeping emissions below the prevention of significant deterioration level Shell may not be able to complete some drilling operations, especially under heavy ice conditions, EPA said in response to one comment on draft versions of the permits.
Particulate concernsIn response to the draft permits, the Alaska Department of Environmental Conservation had expressed concerns about the particulate emissions at “worst-case operating conditions.” EPA determined that the particulate issue relates to the Kulluk. The agency now requires that Shell test a Kulluk engine at all required load conditions and then use the resulting test data to ensure compliance with particulate limits during Beaufort operations.
ADEC also questioned possible uncertainties in the calculated NOX emissions. However, EPA upheld those estimates.
Some organizations questioned the use in the permits of baseline air quality data gathered in 1999 in the area of the onshore Badami oil field.
“Collecting site specific air quality data is unnecessary for Shell’s proposed project,” EPA responded. “The ADEC and EPA determined that the air quality data at Badami met EPA’s quality assurance requirements and are adequately representative of background air quality levels in the impact area of the proposed sources.”
And in response to several questions regarding the adequacy of the emissions estimates for the Shell operations, EPA said that the modeling of the anticipated emissions was sufficient to assess the maximum emissions.
Community impacts?EPA rejected a claim by the North Slope Borough that, by staying under the prevention of significant deterioration limit, Shell was avoiding an assessment of the potential impact of air pollution on subsistence wildlife resources. The agency also responded to concerns from the North Slope Borough and the village of Nuiqsut about potential impacts of air emissions on the health of North Slope residents, by saying that permitted emissions will meet the requirements of the Clean Air Act.
And some commenters questioned the issuing of separate permits for the two drilling vessels, rather than aggregating the air quality requirements into a single permit — EPA has taken a view that the drillship operations can be permitted separately, provided that drilling operations are separated by a distance of at least 500 meters.
People who commented on the draft permits may petition the EPA decision before July 16, at which time the permits will become effective.