Freeport LNG Responses to October 25, 2012 Data Request in CP12-509, et al

Ai IC I ILJ 5 Atkins North America, Inc. 6504 Bridge Point Parkway, Suite 200 Austin, Texas 78730 Telephone: +1.512.327.6840 Fax: +1.512.327.2453 www.atkinsglobal.com/northamerka 20 July 2012 Mr. Carl E. Eglund, P.E. Director, Multimedia Planning and Permitting Division U.S. Environmental Protection Agency, (6PD-R) 1445 Ross Ave Dallas, TX 75202-2733 ATKINS Project No. 044167600 RE: Response to Request for Information Application Completeness Determination Application for Prevention of Significant Deterioration (PSD) Permit for Greenhouse Gas Emissions Liquefaction Plant and Pretreatment Facility Freeport LNG Development, L.P., Brazoria County, Texas Dear Mr. Robinson: On behalf of Freeport LNG Development, L.P., (Freeport LNG), I am submitting the enclosed response to the request for information received from the U.S. Environmental Protection Agency (EPA) relating to the referenced application for a Greenhouse Gas PSD permit for Freeport LNGs proposed Liquefaction Project. As shown in the attached document, each comment received is listed followed by a response. I hope this information will allow you to continue your review of this application. I will contact your staff soon after submittal of this information to discuss the attached information. Thank you for your consideration. Should you have any questions regarding this updated information, please contact Mr. Mark Mallett, P.E., Freeport LNG Development, L.P., at (713) 333-4271 or me at (512) 342-3395 or by email: Ruben.velasquez@atkinsglobal.com. Sincerely, - 1 LL 7N Ruben I. Velasquez, P.E. Senior Engineer Air Quality - Atkins North America, Inc. 7-to. ZR>4P ATKINS TBPE REG. F-474 Enclosures cc: Mr. Mike Wilson, Director, Air Permits Division, TCEQ Mr. Mark Mallett, P.E., Vice-President, Freeport LNG Development, L.P ATKINS Response to EPA Request for Additional Information Application for Greenhouse Gas Prevention of Significant Deterioration Permit Proposed Liquefaction Project Freeport LNG Development, L.P., Brazoria County, Texas 1. The application includes potential BACT Limits for the liquefaction project in Table 10-1. Also, later in the BACT analysis, the applicant proposes to limit the frequency of start-up and shut down events to twice a year. Do the proposed BACT limits include all operating scenarios? Please provide additional information to clarify. Response: Emissions from routine and planned maintenance, shutdown, startup (MSS) activities are represented and included in the proposed BACT limits and emissions summary. The proposed BACT limits shown on Table 10-1 include emissions from the anticipated facility operations and MSS activities, as summarized below: Liquefaction Plant Flare (EPN: LIQFLARE) The Liquefaction Plant Flare will have one GHG emission limit, which ...