PROVISIONS IN THE REVISED NPR: Facility Definition: Includes crew and supply boats and tankers when at the facility, for both attainment and nonattaiment pollutants. For nonattainment pollutants, crew and supply vessel emissions will be counted as part of a facility's emissions inventory. Crew and Supply Boats: All boats would be required to install BACT if they service a new facility. Boats that only service existing facilities would install RACT. Nonattainment pollutants from a crew and supply boat, in transit from home port and while at a facility, will be counted in the facility's emissions inventory, from which offsets are calculated. Cumulative Assessments: MMS will participate with local air pollution control agencies in cumulative AQ analyses. The MMS RD will coordinate with local agencies on appropriate onshore and offshore control strategies. Once a strategy is agreed, the RD will have no discretion whether or not to require implementation. Discretion of the RD: The revised NPR reduces the discretion the RD has on several items like electrification analysis (no longer required), setting reporting and inspection requirements, and control strategies following a cumulative assessment. The RD retains BACT and RACT determinations, subject to proper administrative procedures. Potential Mitigation: Traditional and non-traditional offsets are included but the advanced control technology option is dropped. Interpollutant offsets would be available based on what can be worked out with local air pollution agencies. With reduced mitigation triggers, a Mitigation Fee program is proposed, the particulars of which would be set out in rules of particular application that would be worked out with basin-by-basin advisory groups. Air Quality Advisory Committee: The CAQAC has been dropped and replaced by a basin-wide advisory committee, whose functions would be similar to the CAQAC, but include the mitigation fee program. Designation of OCS Air Basins: The only change from the January NPR is combining the San Luis Obispo/N. Santa Barbara air basin with the Santa Barbara/Ventura Air Basin. Only the North Coast air basin would be attainment. Monitoring: Annual inventories of actual and projected emissions are required, and monthly emissions monitoring and meteorological data collection may be prescribed by the Director, MMS. Information will be provided to State and local air quality agencies. Inspection and Enforcement: The NPR would require third party source testing for new and existing facilities with annual updates, and lessee inspection and maintenance plans. All data available to State and locals. Upset Conditions: The times allowed for notification--24 hours--and action by the operator and the RD--72 hours-- have been reduced from the January NPR. Upsets in excess of 5 TPY for 2 consecutive years requires modification of the plan and shall require offsets. MMS seeks input on defining major and minor upsets. Initial Control Requirement: OCS BACT for all new sources, and OCS RACT for all existing sources. Equipment specific lists will eliminate RD discretion in determining OCS BACT and OCS RACT. Questions are posed regarding what suitable performance standards might be for OCS BACT and OCS RACT lists. Exploration Activities: All exploration activity will require "clean" drilling vessels/rigs that can meet an 8gm/hp-hr performance standard for all main engines. An operational limit is imposed of not more than one operation per year on a single block, and not more than one operation at a time on a multiple block unit. Electrification Analysis: This analysis has been dropped from the revised NPR. With the lower emissions allowances and full mitigation of nonattainment pollutants, MMS believes electrification will be considered as a routine part of an applicant's project planning and design for their Development and Production Plan. Nonattainment Pollutants--Construction/Development/Production: Full mitigation of all nonattainment (and PM10 Group 1) emissions from OCS projects, including: construction, development & production, crew and supply vessels in transit and at the platform, and tankers at the platform (if permitted). With a 0 trigger and 0 mitigation level, offset ratios are 1:1 for traditional offsets. Attainment for Ozone Precursors--Construction/Development/Production: The NPR sets a trigger of 46 TPY for each precursor pollutant. Emissions over 46 TPY are mitigated to 46 TPY at a 1:1 ratio. The 46TPY trigger is conditioned upon the ability of companies to obtain permits to electrify the platform from the onshore grid. If permits are not avaiable, the trigger is 100 TPY. Attainment for Inerts--Construction/Development/Production: The revised NPR retains De Minimus onshore concentrations for inert pollutants. Inert pollutants modelled to exceed thresholds shall be mitigated. Includes Groups 2 and 3 for PM10. PSD Provisions: If modeling shows that OCS emissions would cause an exceedance of PSD increments for TSP, NOx, and SO2, then emissions would have to be reduced/mitigated so as not to exceed the available increments. OCS activities would be allocated not more than 20% of the available increment. Toxic Pollutants: The revised NPR would add arsenic to the other five toxic pollutants--benzene, formaldehyde, chromium, nickel, and polycyclic aromatic hydrocarbons--proposed in the January NPR. If emissions of any toxic exceed 1 pound per day, then a risk assessment must be prepared as prescribed by CAPCOA. Risks of 1 fatality in 100,000 shall require further controls to reduce emissions. Existing Sources: Except for the OS&T, OCS RACT for all existing sources in nonattainment areas to control nonattainment pollutants. Cumulative assessment modeling will determine the need for OCS RACT in an attainment area. Except for OS&T, OCS RACT reductions won't count as offsets. Modifications to Existing Facilities: OCS BACT will be required for all new sources of pollutants or replacement equipment that increases emissions. Increases in nonattainment pollutants must be fully mitigated; for ozone precursors and inert pollutants in attainment areas, the same requirements apply as for new activities. |