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Shell Alaskan Meltdown: U.S. EPA takes action against Shell

1200 Sixth Avenue. Suite 900
Seattle, Washington 98101-3140

JAN 10 2013


Reply to: OCE-127

Certified Mail Return Receipt Requested

C T Corporation System Registered Agent for
Shell Gulf of Mexico Inc.
9360 Glacier Hwy, Suite 202 Juneau,
Alaska 9980 I

Re: Notice of Violation issued to Shell Gulf of Mexico Inc.
Notice of Termination of Administrative Compliance Order on Consent
Docket No. CAA-10-2012-0195

Dear Registered Agent:

The U.S. Environmental Protection Agency (“‘EPA”) is issuing the enclosed Notice of Violation (”Notice”) to Shell Gulf of Mexico Inc. (“Shell”) in accordance with Section 113(a) of the Clean Air Act (“CAA”), 42 U.S.C. § 7413(a), regarding operation of the Discoverer drillship (“Discoverer”) and its fleet of associated vessels (“Associated Fleet”) in the Chukchi Sea. EPA is also notifying Shell that EPA is terminating the Administrative Compliance Order on Consent, Docket No. CAA-10-201200195, issued to Shell on September 7. 2012 (“COC”).

EPA has determined that Shell has violated Outer Continental Shelf/Prevention of Significant Deterioration Permit No. RI0OCS/PSD-AK-09-01 issued on September 19,2012 and effective on January 27. 2012 (the “Permit”). The Permit authorizes air emissions from exploratory oil and gas drilling operations on the Outer Continental Shelf (“OCS”) in the Chukchi Sea by the Discoverer and the Associated Fleet. Based on information in Excess Emission/Permit Deviation Reports. other reports and information submitted by Shell, and observations during an EPA inspection of the Discoverer during September 2012, EPA has determined that Shell violated numerous conditions in the Permit during the 2012 drilling season. Violations of the Permit constitute violations of Section 111(e) of the CAA, 42 U.S.C. §§7411(e).

As also discussed in the Notice, EPA has also determined that Shell has violated emission limits in the COC. Accordingly, as provided in Paragraph 6.10.3 of the COC, EPA is notifying Shell that, based on EPA’s findings in Paragraphs 43-48 and 52-54 of the Notice, EPA has determined that Shell has not complied with the material provisions of the COC. EPA, therefore, is terminating the COC intermediately upon receipt of this letter.

If Shell wishes to request an opportunity to confer on this Notice. please contact Ms. Julie Vergeront, Office of Regional Counsel, at 206-553-1497 within seven days days of receipt of this letter. Please also contact Ms. Vergeront if you have any questions regarding this Notice.


Edward J Kowalski


cc: Pete Slaiby
Shell (Gulf of Mexico Inc.

Susan Childs
Shell Gulf of Mexico Inc.

Lance Tolson
Shell Gulf of Mcxico Inc.

Justin Savage
U.S. Department of Justice

Full 18 page notification letter and legal notice

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