Anadarko Petroleum Corporation

OCS Air Permit Application for Drilling, Exploration, and Maintenance Activities in the EGOM 

EPA’s Incompleteness Determination Letter Dated February 27, 2013

Trinity Consultants

Page 1 of 3

Additional Information Regarding Comment No. 2

2. The BACT analyses for diesel engines in section 5 of the application identified Replacement of 

Older Engines with Newer Engines and EPA Tier 2 Standards as available control technologies. 

The Replacement of Older Engines with Newer Engines should identify the cleanest engines that 

are currently available; this may be EPA Tier 2, EPA Tier 3 compliant engines, or another cleaner 

engine. The BACT analyses for the diesel engines, (specifically DR-GE-07, DR-GE-08, DR-AC-01, 

DR-AC-02, third party engines, and SV-PE-01 through SV-PE-08), should identify what the 

cleanest engines are for each applicable unit, and the use of cleanest available engine in the topdown BACT analyses.

Anadarko Response: Anadarko responded to EPA’s comments regarding BACT for DR-GE-07, DR-AC01, DR-AC-02, and SV-PE-01 through SV-PE-08 in the response letter submitted on March 27, 2013. This 

letter provides a response to EPA’s Best Available Control Technology (BACT) comments regarding third 

party engines, the water blasting engine, and the Remotely Operated Vehicle (ROV) emergency 

generator.

Third Party Engines

The third party engines do not permanently reside on the drillship. These engines will be leased and 

brought onboard when they are needed for use and then removed. BACT for the third party engines

(DR-WL-01, DR-WL-02, DR-EL-01, DR-EL-02, DR-CU-01, DR-CU-02, DR-WC-01 through DR-WC-04, 

DR-WC-07, and DR-WC-08) has been qualitatively determined as compliance with 40 CFR 89 Tier 2 

Standard and low NOx engine (LNE) design. 

It is important to note that these third party engines need to go through several certification pathways 

before being employed on the drillship. The certifications could include approval from several 

authorities such as International Maritime Organization (IMO), Lloyd’s Register (LR), Det Norske Veritas 

(DNV), Germanischer Lloyd (GL), American Buraeau of Shipping (ABS), and/or Nippon Kaiji Kyokai 

(NK). These certification requirements could take significant time to accomplish. 

Anadarko contacted two vendors for each third party engine category to gather information regarding 

the inventory and identify cleanest available engine for each category of the third party equipment. The 

vendors contacted have been utilized in the past by Anadarko to lease similar third party engines. The 

Table below summarizes Anadarko’s findings regarding the cleanest available engine in the vendors’ 

inventory for each category of third party engines. The engines complying with all necessary 

certifications (i.e., engines ready to be used onboard) are included in the Table below.

EPN

Third Party IC 

Engine Equipment 

Type

Cleanest 

Available 

Engine in the 

Category

Anadarko 

Proposed 

BACT

% of inventory if the 

Cleanest Available Engine 

is Tier III or Tier IV

DR-WC-01 Tubing Running Tier II Tier II Not Applicable

DR-WC-02 Fluid Filtration Pump Tier IV Tier II ~5%

DR-WC-04 Slickline Power Pack Tier III Tier II ~15%
Anadarko Petroleum Corporation

OCS Air Permit Application for Drilling, Exploration, and Maintenance Activities in the EGOM 

EPA’s Incompleteness Determination Letter Dated February 27, 2013

Trinity Consultants

Page 2 of 3

EPN

Third Party IC 

Engine Equipment 

Type

Cleanest 

Available 

Engine in the 

Category

Anadarko 

Proposed 

BACT

% of inventory if the 

Cleanest Available Engine 

is Tier III or Tier IV

DR-WC-07 CT Power Pack Tier II Tier II Not Applicable

DR-WC-08 CT Pump Tier II Tier II Not Applicable

DR-EL-01, DREL-02, and 

DR-WC-03

Eline Power Pack Tier III Tier II ~9%

DR-WL-01 and 

DR-WL-02 Wireline Tier III Tier II ~20%

DR-CU-01 and 

DR-CU-02 Casing Unit Tier II Tier II Not Applicable

As shown in the Table above, EPA Tier II certified engines were found to be the cleanest available engine 

for the Tubing Running engine, CT Power Pack engine, CT Pump engine, and Casing Unit engine 

categories based on Anadarko’s survey. Anadarko proposed to meet the BACT requirements for these 

engines by the use of EPA Tier II certified engines, which is the cleanest available engine for these third 

party engine categories.

For the Fluid Filtration Pump engine, Slickline Power Pack engine, Eline Power Pack engine, and 

Wireline engine, the cleanest available engine was found to be EPA Tier III or Tier IV certified. However, 

upon further investigation, the vendors noted that EPA Tier III and Tier IV certified engines constitute a 

small percentage (i.e., approximately less than 20%) of the total inventory. 

Due to constantly changing schedules during the proposed operations, the availability of these third 

party engines changes on short notice. Hence, it is difficult to determine which specific engine would be 

brought onboard on any given day. Since availability of the EPA Tier III and Tier IV engines is limited, 

there is no guarantee that these engines will be available when Anadarko would need them. Restricting

these third party engines to EPA Tier III or Tier IV certified engines will significantly impact the 

operations. Since EPA Tier II certified engines are more readily available for these engine categories, 

Anadarko proposes the use of EPA Tier II certified engines for the Fluid Filtration Pump engine, Slickline 

Power Pack engine, Eline Power Pack engine, and Wireline engine categories to meet BACT 

requirements.

Water Blasting Engine (DR-WB-01)

EPA requested identifying the cleanest available engine in this category as well as a cost of replacement 

of this engine with the cleanest available engine. 

EPA Tier III certified engine is the cleanest available engine in this category based on the information 

Anadarko gathered. Anadarko proposed use of an EPA Tier II certified engine to meet the BACT 

requirements for this engine in the submitted application. However, Anadarko would like to update the 

proposed BACT for this engine to reflect the recent changes. For this application, Anadarko proposes 

use of an EPA Tier III certified engine to meet the BACT requirements for this engine.
Anadarko Petroleum Corporation

OCS Air Permit Application for Drilling, Exploration, and Maintenance Activities in the EGOM 

EPA’s Incompleteness Determination Letter Dated February 27, 2013

Trinity Consultants

Page 3 of 3

DR-GE-08 – ROV Emergency Generator

DR-GE-08 is an EPA Tier 2 certified Remotely Operated Vehicle (ROV) emergency generator. It operates 

intermittently during non emergency situations primarily for maintenance and testing. The proposed 

operating time for this engine is 1 hr/day and 100 hrs/yr. Given the engine’s minimal operating time, 

emissions are minimal. For example, the NOX emissions are 0.22 tons tpy. Therefore, Anadarko 

believed detailed cost infeasibility was not warranted. 

EPA agreed that a comprehensive cost infeasibility analysis is not required for this equipment; however, 

EPA requested Anadarko to identify the cleanest available engine in that category and provide a cost of 

replacement of this engine with the cleanest available engine. Accordingly, Anadarko contacted the 

engine vendor (i.e. Cummins, Inc.) and confirmed that an engine complying with EPA Tier II standards is

the cleanest available engine in this category. Hence, Anadarko proposes the use of an EPA Tier II 

certified engine to meet the BACT requirements.

Additional Information Regarding Comment No. 6

6. Please confirm that there are no welding activities that will generate emissions on the OCS 

source. If welding activities do occur, the emissions should be accounted for in the emission 

calculations and in any other applicable sections in the application. 

Anadarko Response: The welding operations will be performed as a part of maintenance activities. 

The proposed welding operations will result in minimal increase in short term and long term emissions 

of PM, PM10, PM2.5, and HAPs. Moreover, Anadarko would like to add Vertical Seismic Profile (VSP) 

engines as additional sources of air pollution and increase operational flexibility of certain air pollution 

sources, such as the water blasting engine (DR-WB-01) and Emergency Generator engine (DR-GE-07), 

by increasing currently requested operating time.

Due to the changes indicated above, the revised Potential to Emit (PTE) of a few pollutants (e.g., PM10) 

will be greater than the emission rates used for performing air dispersion modeling analysis for 

respective pollutants. Hence, Anadarko will submit a permit application addendum including emission 

calculations for requested changes, revised air dispersion modeling analysis, and other relevant 

PSD/Title V application package contents in four to six weeks.