## EMISSIONS TEST PRO TOCOL

Anadarko Petroleum Corporation

Stack Testing of the Main Engines on the
Diamond Offshore BlackHawk Drillship in the Gulf of Mexico

Prepared for:

Anadarko Petroleum Corporation

120 1 Lake Robbins Road The Woodlands, TX 77380

Prepared by:

5540 Centerview Drive Raleigh, NC 27606 ( 919 ) 256

- 6231

TRC Project No. 2 15228

- 002 0

April 4 , 201 4Anadarko
BlackHawk

- GOM Drilling Program

Table of Contents

215228 i TABLE OF CONTENTS

1.0 INTRODUCTION & OVERVIEW

................................ ................................ ..................... 1

1.1 Purpose of Test Program

................................ ................................ ................................ ................ 1

1. 2 Source Description

................................ ................................ ................................ .......................... 1 Table 1.2.1

– Source Identifications

................................ ................................ ............................... 1

1. 3 Scope of Test Program

................................ ................................ ................................ .................... 1 Table 1.3.1

– Scope of Work

................................ ................................ ................................ ............ 2
1.4 Proposed Test Schedule

................................ ................................ ................................ .................. 2
1.5 Discussion of Test Method Deviations and/or Exceptions

................................ .......................... 2
1.5.1 Substitution of EPA Method 5 for EPA Method 201A

................................ ................... 2
1.5.2 Sampling Location in Stacks at Unusual Angles or with Sample Train Obstructions

............... 2
1.5.3 Sampling for Gaseous Pollutants in Engine Exhaust Stacks

................................ ......... 3 1.6 List of Projec

t Participants

................................ ................................ ................................ ............. 3

2.0 DESCRIPTION OF SOURCES & COLLECTION OF PROCESS DATA

............................... 4

2.1 List of Emission Units/Sources

................................ ................................ ................................ ..... 4

2.2 Process Data Collection

................................ ................................ ................................ .................. 4
2.3 Emission Unit Load Levels

................................ ................................ ................................ ............. 4
2.4 Emission Unit Loading Methods

................................ ................................ ................................ ... 4
2.5 Fuel Certifications or Analysis

................................ ................................ ................................ ....... 4

3 .0 DISCUSSION OF SAMPLING LOCATION S

................................ ................................ ..... 5
3.1 Engine Stacks

................................ ................................ ................................ ................................ ... 5

4 .0 SAMPLING AND ANALYSIS PROCEDURES

................................ ................................ .. 6

4 .1 Traverse Point Location (EPA Method 1)

................................ ................................ ...................... 6

4 .2 Stack Gas Velocity & Volumetric Flow Rate (EPA Method 2)

................................ ..................... 6

4 .3 O 2 & CO 2 Concentrations (EPA Method 3A)

................................ ................................ ................. 6

4.4 M oisture Content (EPA Method 4)

................................ ................................ ................................ 7
4.5 Filterable and Condensable Particulate Matte r Emissions (EPA Method 5/202)

..................... 7
4.5.1 Sample Collection

................................ ................................ ................................ ............. 7
4.5.2 Sample Recovery

................................ ................................ ................................ ............... 8

4.5.3 Sample Analysis

................................ ................................ ................................ ................ 8 4.6 TRC CEMS

................................ ................................ ................................ ................................ ....... 8

4. 6 .1 Instrument Checks and System Integrity; Setup Day

................................ .................... 9
4. 6 .2 CEMS Calibrations

– Methods 3A, 7E , 10 & 25A

................................ ........................... 9

4. 6 .3 Bias Checks

– Methods 3A, 7E , 10 & 25A

................................ ................................ ....... 9 4.6 .4 CEMS Data Acquisition System

................................ ................................ ..................... 10 4.6 .5 CEMS Components

................................ ................................ ................................ ......... 10 4.6 .5.1 O 2 and CO 2 Measurements (EPA Method 3A)

................................ .................. 11 Table 4.6 .5.1

– TRC O 2 /CO 2 CEMS Zero and Span Gas Ranges

................................ . 12
4. 6 .5 .2 NOx Measurements (EPA Method 7E)

................................ ............................ 12 Table 4. 6 .5.2

– TRC NO x CEMS Zero and Span Gas Ranges

................................ ...... 12
4. 6 .5.3 CO Measurements (EPA Method 10)

................................ ............................... 12 Table 4. 6 .5.3

– TRC CO CEMS Zero and Span Gas Ranges

................................ ........ 13 4.6. 5.4

– VOC Measurements (EPA Method 25A )

................................ ....................... 13 Table 4.6.5.4 TRC VOC CEMS Zero and Span Ranges

................................ ................ 14 4.6 .6 Gaseous Pollutant Sampling with 3 Point Traverse

................................ ..................... 14Anadarko
BlackHawk

- GOM Drilling Program

Table of Contents

215228 ii TABLE OF CONTENTS (continued)

5 .0 QUALITY ASSURANCE PLAN

................................ ................................ ...................... 15
5.1 QA/QC Procedures, Organization & Flow Chart

................................ ................................ ........ 15
5.2 Calibration Procedures and Frequency

................................ ................................ ....................... 15
5.2.1 Calibration Gases

................................ ................................ ................................ ............ 15
5.2.2 Reagent Certifications

................................ ................................ ................................ .... 15
5.2.3 Instrument Calibrations

................................ ................................ ................................ . 15
5.3 Sample Recovery and Chain of Custody Procedures

................................ ................................ .. 16

5.3.1 Sh ipping and Packing of Samples

................................ ................................ .................. 16

5.3.2 Sample Traceability

................................ ................................ ................................ ........ 16

5.3.3 Chain

- of

- Custody Documentation

................................ ................................ ................. 16 5.3.3.1 Labeling

................................ ................................ ................................ ............... 16 5.3.3.2 Integrity Seals

................................ ................................ ................................ .... 16 5.3.3.3 Chain

- of

- Custody Procedures

................................ ................................ ........... 16 5.3.3.4 Sampling Trains and Spare Equipment

................................ ........................... 16

5.4 Data Handling & Reduction Procedures

................................ ................................ ..................... 16

5.5 Report Content and Timing

................................ ................................ ................................ .......... 17

TABLES & FIGURES Number Description

1.2.1 Source Identifications for Main Propulsion Engines

................................ ................................ ... 1
1.3.1 Scope of Work

................................ ................................ ................................ ................................ .. 2

4. 6 .5.1 TRC O 2 /CO 2 CEMS Zero and Span Gas Ranges

................................ ................................ ......... 12
4. 6 .5.2 TRC NO x CEMS Zero and Span Gas Ranges

................................ ................................ .............. 12
4. 6 .5.3 TRC CO CEMS Zero and Span Gas Ranges

................................ ................................ ................. 13 4.6. 5.4 TRC VOC CEMS Zero and Span Gas Ranges

................................ ................................ .............. 14Anadarko
BlackHawk

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Table of Contents

215228 iii ABBREVIATIONS

< Less than

> Greater than

% Percent
AC Alternating current

a cfm Actual cubic feet per minute

ACS American Chemical Society

ASTM American Society for Testing and Materials

Btu British thermal units

° C Degrees Celsius

CEMS Continuous Emission Monitoring System

c fm Cubic feet per minute

CFR Code of Federal Regulations

CH 4 Methane

CAA Clean Air Act

CO Carbon monoxide

CO 2 Carbon dioxide

CPM Condensable particulate matter

DAS Data acquisition system

DC Direct current

DI H 2 O Deionized water
d scfm Dry standard cubic feet per minute

EPA Environmental Protection Ag ency ° F Degrees Fahrenheit

FIA Flame ionization analyzer

GFC Gas filter correlation gr/dscf Grai ns per dry standard cubic meter g/kW

- hr Grams per kilowatt

- hour

H 2 O Water hp Horsepower hr Hour kW Kilowatt lb/hr Pounds per hour lb/kW

- hr Pounds per kilowatt

- hour

IR Infrared
kW Kilowatt

MMBtu Million British thermal units of heat input

MSDS Material Safety Data Sheet

MW Megawatt

NDIR Non

- dispersive infrared

N 2 Nitrogen
NO Nitric oxide

NO 2 Nitrogen dioxide

NO x Nitrogen oxides

O 2 Oxygen
O 3 Ozone
OCS Outer continental shelf

PC Personal computer

PM Particulate Matter as measured by EPA Method 5Anadarko
BlackHawk

- GOM Drilling Program

Table of Contents

215228 iv ABBREVIATIONS (continued)

PM10 Particulate matter less than 10 microns PM2.5 Particulate matter less than 2.5 microns

PMT Photomultiplier tube

ppm Parts per mi llion

ppmv Parts per million by volume ppmvd Parts per million by volume, dry

ppmvw Parts per million by volume, wet

PSD Prevention of Significant Deterioration QA Quality Assurance QC Quality Control

RM Reference Method

SCR Selective catalytic reduction

SO 2 Sulfur dioxide

SOP Standard Operating Procedure

SRM Standard Reference Material

USEPA United States Environmental Protection Agency

VAC Volts alternating current

VDC Volts direct current

VE Visible Emissions

VOC Volatile Organic CompoundsAnadarko
BlackHawk

– GOM Drilling Program
Section 2

– Description of Sources & Collection of Process Data

1
215228 

## 1.0

- INTRODUCTION & OVERVIEW

1.1 Purpose of Test Program Anadarko Petroleum Corporation (Anadarko) submitted a PSD Pre

- Construction and Title V Operating Permit Application to conduct exploratory, completion, and associated maintenance activities using the Diamond Offshore Ocean BlackHawk drillship to EPA Region IV in August

2013

. Anadarko has retained TRC Envir onmental Corporation to conduct source testing of
certain emission units on the BlackHawk drillship

.

This test protocol describes the emissions testing to be performed on two of the eight drillship main engines

. S ix of the main engines are identical Hyundai HiMSEN 9H32/40 4,500 kW
diesel

- fired engines. Two of the main engines are identical Hyundai HiMSEN 18H32/40V 9,000 kW diesel

- fired engines. One of each type (size) of engine will be tested.

Anadarko and TRC propose to measure NOx

, CO2, CO, PM

, and VOC emissions that may be required by the current PSD and Title V Major Source Permit Application that Anadarko submitted to EPA Region IV in September 2013

.

1.2 Source Description
Included in Table 1. 2. 1 is a description of the sources to be tested :

Table 1. 2.1

– Source Identifications for Main Engines

ID DESCRIPTION MAKE AND MODEL RATING

DR

- M E

- 01 Drillship Main Engine Hyundai Hi MSEN 9H32/40 4,500 kW

DR

- ME

- 07 Drillship Main Engine Hyundai HiMSEN 18H32/40V 9,000 kW

1.3 Scope of Test Program Included in this section are tables with detailed descriptions of the scope of work at each

emissions source. As referenced below in the last column of each table, the total number of test runs are calculated for each emission source. For example, an engine that will be tested at 4 different load conditions, 3 test runs will be conducted at each load. Hence, t here will be 12 “tests” conducted at that specific emission source. Note that each test run will include simultaneous sampling for all of the pollutants for which that emission source must be tested. As an example, simultaneously testing for NOx, CO

, CO2

, VOC, and PM is considered one test

run. Table 1. 3.1

– Scope of Work for BlackHawk

ID DESCRIPTION PARAMETER TOTAL # OF LOAD
CONDITIONS TOTAL # OF
TESTS

DR

- M E

- 01 Drillship Main Engine 9H32/40 NOx, CO, CO2, VOC, PM 2 0%, 40%, 6 0% *

, 9 0% * 1 2

DR

- M E

- 0 7 Drillship Main Engin e 18H32/40V NOx, CO, CO2, VOC, PM 20%, 40%, 6 0% *

, 9 0% * 12

TOTAL # of RUNS 2 4

* These loads may be decreased or not performed depending on current operations when stack testing is being performed.Anadarko
BlackHawk

– GOM Drilling Program
Section 2

– Description of Sources & Collection of Process Data

2
215228 1. 4 Proposed Test Schedule Anadarko and TRC plan to conduct the emission tests starting in early June following the completion of the Noble Bob Douglas stack testing

. One engine will be tested at a time. Each
test run will be 60

- minutes in duration. Three test runs will be conduc ted at each of four (4) engine loads. Hence 12 test runs will be conducted on each engine. Emission tests will be conducted 24

- hours per day using two test crews each working 12

- hour shifts. It is anticipated
that one engine will be completed per test day.

Anadarko will notify EPA o f the test date when the test schedule is determined

.

1.5 Discussion of Test Method Deviations and/or Exceptions

1.5.1 Substitution of EPA Method 5 for Method 201A Based on TRC’s pas t experiences, EPA Method 201 A to determine the filterable portions of PM 10 and PM 2.5 c an not be effectively used on the MODU engines due to severe source test conditions
as well as limitations of this test method. The high stack temperature and the low sa mpling rate required by Method 201A cyclones make it impractical to use Method 201A. Hence, Anadarko proposes to use EPA Method 5 to determine total filterable particulate emissions and EPA Method 202 to determine condensable particulate emissions.

Diese l engine particle matter is typically all less than 2.5 microns in size. Typically, for diesel engines the Method 5 filterable PM catch is all considered to be less than 2.5 microns.

1.5.2 Sampling Locations in Stacks at Unusual Angles or wit h Sample Train
Obstructions At stacks where there are obstructions that limit access of the sample train or at stacks that are at unusual angles , a “split sample train” will be used. A split sample train consists of a heated sample probe connected to a heat ed “mini hot box” or heated filter housing, which in turn will be connected by a flexible Teflon ® sample line to the back

- half impinger train. The Teflon ® sample line connecting the heated filter to the Method 202 condenser and impingers will be
unheated. This Teflon ® “jumper” will be rinsed and recovered with the rinse solvents as specified in Method 202.

1.5.3 Sampling for Gaseous Pollutants in Engine Exhaust Stacks
The “Revisions to Test Methods and Testing Regulations” published in the Federal Register on January 9, 2012, specified that engine exhausts could be sampled at the centroid of the exhaust. More recently, (March 10, 2014) EPA withdrew the waiver of stratific ation tests on engine stacks except for stacks less than 6 inches in diameter

. For engine stacks equal to or greater than 12
inches in diameter that meet the EPA Method 1 criterion for minimum distance of 2 duct diameters downstream of a flow disturbance, a 3

- point traverse for gaseous pollutants will be performed.Anadarko
BlackHawk

– GOM Drilling Program
Section 2

– Description of Sources & Collection of Process Data

3
215228 1.6 List of Project Participants

The following individuals should be contacted if there are questions about the test program:

Anadarko Petroleum Corporation:
Sara Carlson Sara.Carlson@anadarko.com

Sr HSE Representative, Gulf of Mexico (832) 636

- 1273 (office) (832) 506

- 0888 (cell)

Katie Maness

HSE Manager , Gulf of Mexico Kathyr n.Maness@anadarko.com ( 832 ) 636

- 2582 ( office ) ( 281 ) 639

- 1660 ( cell )

TRC Environmental Corporation Jim Serne, PE, QSTI JSerne@TRCSolutions.com (919) 256

- 6231 (office) (919) 302

- 2529 (cell)

Diamond Offshore BlackHawk
Chad Williams Operations Manager cwilliams@dodi.comAnadarko
BlackHawk

– GOM Drilling Program
Section 2

– Description of Sources & Collection of Process Data

4
215228 

## 2.0

– DESCRIPTION OF SOURCES &
COLLECTION OF PROCESS DATA

2.1 List of Emission Units/Sources Only two of the 8 drillship main engines will be tested on the BlackHawk . DR

- M E

- 01 through

DR

- M E

- 06 are the six (6) drillship main engines each rated at 4,500 hp and DR

- ME

- 07 and DR

ME

- 08 are the two (2) drillship main engines each rated at 9,000 hp . These diesel

- fired engine s are all H yundai HiMSEN V

– type diesel engines driving AC generators

.

2. 2 Emission Unit Load Levels
Anadarko intends to test each engine at four operating loads. These engines will typically operate at relatively low loads. The four target loads are 20%, 40%, 6 0% and 9 0%. Depending on the current operations 60% and 90% loads may be decrease or not performed. The measured pollutant emission rate data will plotted versus these loads and a graph drawn

. .

2. 4 Emission Unit Loading Methods Management of the load l evels and durations will be done under the direction of the BlackHawk personnel.

2. 5 Fuel Certification & Analysis
Anadarko will provide certification of sulfur content for each shipment of fuel from the fuel supplier, or they will obtain a representative fuel sample and determine the sulfur content

.Anadarko
BlackHawk

- GOM Drilling Program Section 3

– Discussion of Sampling Locations

5
215228 

## 3 .0

– DISCUSSION OF SAMPLING LOCATIONS

Emissions testing on sea going v essels present s some very unique access and mobility challenges

as e xhaust stacks often run inside of or next to inhabited spaces. Due to the gases that can be emitted, v essel operators cannot allow e xhaust lines to be opened inside of an inhabited space. Further, testing of vessel main engines is typically performed at sea where vessel motions can be quite significant. In all situations, t he test ports have to be located in an area that best provide s safe access for all per sonnel in dynamic situations.

At each source, emissions will be sampled via two or more sample ports located on circular stacks. The samples ports will be located 90 degrees apart. If adequate straight sections of stack exist, ports will be located such that they are more than eight (8) stack diameters downstream from the nearest flow disturbance and more than two (2) stack diameters upstream from the nearest flow disturbance (stack exit). If an adequate straight run of pipe or stack is not available

to meet the “8 and 2 criteria, ” the ports will be located such that the sample ports will be located a minimum of 2 diameters after a flow disturbance and a minimum of 0.5 diameters before a
flow disturbance. The stack diameter and distances to flow distur bances will be measured prior to commencing the emissions tests. The minimum allowable number of sample points will be
utilized to conduct the emissions tests

. Method 1 data sheets with the actual diameter will be prepared in the field and included in th e test reports. A diagram of the stack and sample port location will also be included on the field data sheet for inclusion in the test report. If the sample ports are not labeled, TRC will designate left and right ports as looking from the sample probe, for testing purposes. To illustrate the typical size, orientation, and location of sample ports,

p hotographs of t he actual stacks will be provided in the Test Report . Note that many marine engine stacks are oriented at an angle rather than vertically. In some cases access to one of the ports may be blocked or limited such that only a single sample port can be accessed with a Method 5 sample train.

3.1 Engine Stacks For gaseous pollutants, p er the March 10, 2014 guidance issued by EPA’s Emissions

Measurement Center

, the engine stacks will be sampled using a 3

- point traverse of the exhaust
stack

.

For particulate sampling, the e ngine stacks equal to or larger than 12

- inches in diameter will be
traversed.

The 4,500 hp engines have stacks that are 750 mm (approx. 29.5

- inches) in diameter. The 9,000 hp engines have st acks that are 1,100 mm (approx. 43.3

- inches) in diameter.Anadarko
BlackHawk

- GOM Drilling Program Section 4

– Sampling and Analysis Procedures

6
215228 

## 4.0

– SAMPLING AND ANALYSIS PROCEDURES

All sampling and analytical procedures used in this test program will be based on procedures published by the EPA in accordance with the guidelines published in Title 40, Code of Federal Regulations, Part 60 (40 CFR 60), Appendix A; and in Subpart M of 40 CFR 51. Copies of these
methods are available from the EPA EMTIC electronic bulletin board or the Code of Federal Regulations which can be obtained online.

 Method 1 Sample and Velocity Traverses for Stationary Sources

 Method 2 Determination of Stack Gas Velocity and Volumetric Flow Rate (Type S Pitot Tube)

 Method 3A Determination of Oxygen and Carbon Dioxide Concentrations in Emissions from Stationary Sources (Instrumental Analyzer Procedure)

 Method 4 Determina tion of Moisture Content in Stack Gases

 Method 5 Determination of Particulate Matter Emissions from Stationary Sources

 Method 7E Determination of Nitrogen Oxides Emissions from Stationary Sources (Instrumental Analyzer Procedure)

 Method 10 Determination of Carbon Monoxide Emission from Stationary Sources (Instrumental Analyzer Procedure)

 Method 25A Determination of Total Hydrocarbons by Flame Ionization Analyzer

 Method 202 Dry Impinger Method for Determining Condensable Particulate Matter Emissions

From Sta tionary Sources

4 .1 Traverse Point Location (EPA Method 1 )

As described in Section 3, the engine stacks will be sampled for the gaseous pollutants using a 3

- point traverse

. For determining the PM emissions the engine stacks will be traversed to determine the gas velocity and volumetric flow rate. The procedures specified by EPA Method 1, “Sample and Velocity Traverses for Stationary Sources will be used to select representative flow and pollutant measurement locations. A me asurement site where the exhaust stream is flowing in a known direction will be selected, and the cross section of the stack will be divided into a number of equal areas. A traverse point will then be located within each of these equal areas. The samplin g traverse points for EPA Method 1 will only need to be determined once. Copies of the stack schematics with the actual traverse points will be included in the final report.

4 .2 Stack Gas Velocity and Volumetric Flow Rate (EPA Method 2)
This method is a pplicable for the determination of the average velocity and volumetric flow rate of a gas stream. The average gas velocity in a stack will be determined from the gas density and from measurement of the average velocity head with a Type S (Stausscheibe or r everse type) pitot tube.

4 .3 O 2 & CO 2 Concentrations (EPA Method 3A) During each Method 5 test period, percent dry O 2 and CO 2 emission concentration data will be collected for use in supporting flow rate, emission concentration, and emission rate calculations.Anadarko
BlackHawk

- GOM Drilling Program Section 4

– Sampling and Analysis Procedures

7
215228 For each test run, the molecular weight of the stack gas will be calculated per Method 3 based on

concurrent O 2 and CO 2 stack gas concentrations.

4 .4 Moisture Content (EPA Method 4) The moisture content of the stack gas will be determined gravimetrically from the weight gain in each impinger and the weight gain of the silica gel impinger from the Method 5/202 sampling

t rain s

. If PM sampling is not performed, then EPA Method 4 sample trains will be used to determine the stack gas moisture content , or alternatively the appropriate Method 19 F

- factor
will be used to determine the exhaust flow rate

.

4.5 Filterable and Condensable Particulate Matter Emissions (EPA Method 5/202)

4. 5.1 Sample Collection Samples will be collected isokinetically from the stack using an EPA Method 5 sampling train. The sampling train consists of a stainless steel or glass / quartz nozzle, and a stainless steel or

g lass

- lined probe and a quartz fiber filter supported by a Teflon ® frit and maintained at a temperature of 248 o F ± 25 o F, chilled impingers, and a metering console. Condensable particulate matter (CPM) emissions will be determined usin g Method 202 procedures.

This procedure for determining CPM involves recovering the back

- half of the sampling train. As specified in EPA Method 202, the CPM w ill be collected in the two empty impingers which will be maintained at 85°F or less by use of a chilled water recirculating pump and non

- contact condenser. These two empty impingers are followed by a Teflon ® membrane filter maintained between 65°F and 85°F or less. This Teflon ® filter is the final sample fraction in the Method 202 sample train. The filter is followed by two impingers in an ice bath which serve to condense any remaining moisture so that the stack gas moisture content can be determined. Organic condensable PM and inorganic condensable PM are quantified per EPA Method 202 procedur es. Prior to sample train assembly, each of the impingers will be weighed. As previously noted, a
Teflon ® jumper may be used to connect the Method 5 front

- half and the back

- half Method 202

trains.

Prior to mobilizing for each test program, the glassware used for the Method 202 sample trains will be prepared by cleaning and baking as specified in EPA Method 202 in one of TRC’s
laboratories. As an alternative to baking glassware, Method 202 allows th e test crew to perform a proof blank of the sampling train while onsite. Field train proof blanks (FTPB) are recovered

on

- site from a clean, fully assembled sampling train prior to the first emissions test. Field train proof blanks will be used in lieu of the glassware baking when it is not practical to have baked glassware at remote locations.

As required by Method 202, for each source category one field train recovery blank (FTRB) will be recovered from a sampling train after it has been used to col lect emissions samples and has been rinsed in preparation for the second or third test in a series at a particular source. ThisAnadarko
BlackHawk

- GOM Drilling Program Section 4

– Sampling and Analysis Procedures

8
215228 FTRB train will be purged with nitrogen. Prior to the purge, 100 ml of DI water will be added t o the f irst impinger

. TRC will collect and analyze a field train recovery blank (FTRB) and a field train proof blank (FTP B) onboard the Diamo nd BlackHawk

. The appropriate blank value, up to the maximum value stated in the April 8 th guidance, will be used to calculate the CPM emission

rates

. Si nce all of the eight engines are the same and the same fuel is used, only one FTRB will be collected on the drillship

.

4.5 .2 Sample Recovery
The front

- half filter will be removed from the filter holder and placed in a petri dish. The nozzle, probe, and front

- half of the filter holder will be rinsed with acetone into a glass jar. The filter
and the front

- half acetone r inse will be analyzed per Method 5 procedures to determine the filterable PM. Immediately following the test run, each of the impingers will be weighed to determine the post

- test weight. The weight of water vapor condensed in the impingers and the weight of water vapor collected in the silica gel will be summed and subsequently entered into
moisture content calculations.

The impinger trains will be purged with filtered ultra

- pure nitrogen for 60 minutes at a minimum rate of 14 liters per minute. The m aterial collected in the two empty impingers of the
Method 202 sample train will be placed in a glass sample jar. The back

- half of the filter holder, impingers , and connecting glassware will be rinsed twice with DI water into the jar containing
the back

- half impinger catch. Next the back portion of the filter holder, the two impingers, and the connecting glassware will be rinsed once with acetone and then twi ce with hexane . These solvent rinses placed into a separate glass jar. In cases where a split sample train is used, the
Teflon ® jumper will be rinsed and recovered along with the components of the back

- half sample

train.

4.5. 3 Sample Analysis
EPA Method 5 analytical procedures will be used to analyze the filter and front

- half acetone rinse for filterable particulate. If a quick turnaround is needed, an onsite TRC Air
Measurements lab may perform the Method 5 gravimetric analyses. EPA Method 5 analytica l procedures (gravimetric) will be used to analyze the front

- half PM catch, which consists of the filter and acetone rinse of the nozzle, probe liner, and front portion of the filter housing. EPA 202 analytical procedures will be used to analyze the comb ined DI water reagent/DI water rinses and the acetone/ hexane rinses for condensable particulate matter. The water fraction will be extracted

with hexane to separate organic material from the aqueous phase. The aqueous phase (after solvent extraction) will be dried down and the remaining residue weighed and reported as the inorganic condensable PM. The hexane rinse fraction and solvent extract will be eva porated and the remaining residue weighed and reported as the organic condensable PM. Resolution Analytics

, Inc. in Fuquay

- Varina , North Carolina, will perform the Method 5 and Method 202 gravimetric analyses, sample extractions and separations.

4. 6 TRC CEMSAnadarko
BlackHawk

- GOM Drilling Program Section 4

– Sampling and Analysis Procedures

9
215228 Gaseous measurements will be conducted with continuous emissions monitors (CEMS). Each TRC CEM system i ncludes the reference method ( RM ) instrumentation and a data acquisition system necessary to support continuous stack gas measurements. TRC uses an extractive system for sample gas collection and measurement, and reports pollutant concentration data o n a dry basis.

4. 6 .1 Instrument Checks and System Integrity; Setup Day

EPA Methods 3A

, 7E , 10 , and 25A include strict quality control performance specifications for the CEMS measurement system. EPA Method s 3A and 10 reference EPA Method 7E for applicable CEMS calibration specifications. Prior to the initiation of the field sampling, TRC will conduct a “setup period” that will involve a number of initial system checks, site evaluations, and general acceptance runs. A ll of these checks will be guided by TRC Standard Operating Procedures and will be completed prior to conducting the official test runs.

4. 6 .2 CEMS Calibrations

- Methods 3A , 7E , 10 & 25A The following sequence of operations will be conducted to calibrat e each Method 3A , 7E, 10 , and
25A analyzer. This activity will precede the system bias, response time, stratification, or other measurements made through the CEMS.

 Complete the analyzer setup as described by the manufacturer’s specifications and allow the instruments to stabilize. Adjust each analyzer by introducing zero and calibration gases in any sequence making all necessary adjustments.

 After the measurement system for the Method 3A , 7E, 10 , and 25A analyzers have been prepared for use, perform a calibration error test by introducing the zero or
low

- range (< 20% of the analyzer span), mid

- range ( 40 to 60 percent of the analyzer span), and high

- range ( 100 perce nt of the analyzer span) calibration gases to each analyzer. During this check, no adjustments are made to the system except those necessary to achieve the correct calibration gas flow rate to the analyzers. Allow the analyzers to stabilize and record th e result.

 Calculate the analyzer percent difference or calibration error. Calibration responses for the Method 3A , 7E, 10, and 25A analyzers must be within 2 percent of the span value for the analyzers.

4.6 .3 Bias Checks

- Methods 3A , 7E , 10 & 25A
The following sequence of operations will be conducted to determine the b i as of the sampling system for the specific source and setup configuration. This activity will precede the system calibration and will be conducted before the response time or other measu rements made through the CEMS.

 Align the sampling system for calibration.Anadarko
BlackHawk

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– Sampling and Analysis Procedures

10
215228  Document the system bias checks using the DAS.

 The DAS will record the start and stop of the CEMS bias check procedure. Zero air or calibration gas will be introduced into the sampling system. The analyzer(s) will then be allowed to reach a stable output. The analyzer response for the zero gas will be recorded on the DAS printout.

 An upscale calibration gas (either the high

- range or mid

- range calibration,
whichever most close ly matches the stack gas concentration for that parameter) will be introduced to the sampling system. The analyzer will be allowed to reach a stable output. The analyzer response will be recorded on the DAS printout for the upscale calibration gas.

 The procedures will be repeated for each parameter. It should be noted that zero gas can be used as a zero for multiple analyzers, and it is not necessary to repeat this procedure as long as the zero measurement is made for each analyzer.

 The CEMS bias will be calculated for each analyzer. The system bias for each Method 3A

, 7E

, 10, and 25A analyzer must be within ± 5 percent of the span
value.

 Method 3A

, 7E

, 10, and 25A CEMS system drifts will be calculated by comparing the system response to the zero and upscale calibration gas from the system response during the previous bias check. Zero and calibration drift must be within ± 3 percent of the analyzer span value.

4.6 .4 CEMS Data Acquisition System
The TRC CEMS DAS is a PC

- based system with hard disk storage and an external 8

- channel analog

- to

- digital converter. The specific instrument voltage inputs are linear and directly proportional to the concentration of the specific gas being measured. In addition to providing an instantaneous display of analyzer responses, the DAS compiles and averages the analyzer
data collected once each second and prints one

- m inute data averages. Data for the test period
will be averaged and corrected for calibration error and drift using the DAS software and a Microsoft Excel spreadsheet program. The CEMS calibrations and run summaries are documented with DAS printout.

4.6 .5 CEMS Components The CEMS sample collection system for O 2 and CO 2 (EPA Method 3A), NO2 and NO

x (EPA Method 7E)

, CO (Method 10) , and VOC (Method 25A) will consist of a (heated, if necessary) stainless steel probe with a heated particulate filter, heated sample lines, a moisture removal trap, and a sample pump. All samples are routed through a distribution manifold board forAnadarko
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215228 delivery to the analyzers. The gas sample is distributed to the individual gas analyzers at near atmospheric pressure and excess sample flow from the system is vented outside the system.

C alibration gases from the control panel inside the trailer are delivered through a separate li ne to the exit of the probe. During calibration, the gas flow is adjusted to be slightly greater than the total sample collection system flow and the small amount of excess calibration gas is vented through the probe assembly. The configuration of the sa mpling system allows for the injection of calibration gases either directly to the analyzers or through the entire sampling system.

4.6 .5.1 O 2 and CO 2 Measurements (EPA Method 3A)

O 2 concentrations will be determined using a paramagnetic oxygen analyzer. The analyzer measures the paramagnetic susceptibility of the sample gas by means of a magneto

- dynamic
type

- measuring cell. The measuring cell consists of a dumbbell of diamagnetic m aterial, which is temperature controlled electronically at 50oC. The higher the oxygen concentration, the greater the dumbbell is deflected from its rest position. This deflection is detected by an optical system connected to an amplifier. Surrounding t he dumbbell is a coil of wire. A current is passed through this coil to return the dumbbell to its original position. The current applied is linearly proportional to the percent oxygen concentration in the sample gas.

CO 2 concentration will be measured u sing a NDIR analyzer. The analyzer measures gas concentration based on the principal that each type of gas component shows a unique absorption line spectrum in the infrared region. The instrument consists of an infrared light source, a chopper, a measurin g cell and a detector filled with a gas mixture containing the gas component to be measured. The infrared light source emits infrared light in all directions. The light emitted forward is transmitted and reflected into the detectors.

The infrared light emitted backward is reflected be a reflecting surface and is added to the infrared light emitted forward. Arranged between the infrared light source and measuring cell is a chopper blade which rotates to modulate the infrared light beam at regular frequen cy. The modulated infrared light beam thus formed passes through the measuring cell filled with a sample gas where the light energy is partially absorbed or attenuated before it reaches the front
chamber of the detector. Both the front and the rear chamb ers of the detector are filled with the gas component to be measured.

The infrared light energy is partially absorbed in the front chamber and residual light is absorbed in the rear chamber, thereby increasing pressures in both the chambers, respectively. Since the detector is designed to produce a pressure difference between the front and rear chambers, a slight gas flow is produced through a path c orrecting these chambers with each
other.

The slight flow is converted into an AC electrical signal by a m icroflow sensor arranged in the communicating path. The AC signal is amplified and rectified to a DC voltage supplied to the output terminals and indicator.Anadarko
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215228 Table 4.6 .5.1

- TRC O 2 /CO 2 CEMS Zero and Span Gas Ranges

RANGE O 2 ANALYZER CO 2 ANALYZER

Zero

- range Nitrogen gas Nitrogen gas

Mid

- range 40 to 60% of calibration span 40 to 60% of calibration span High

- range equal to calibration span equal to calibration span All readings will be reported within EPA Method 3A criteria.

4.6 .5.2 NO
x Measurements (EPA Method 7E) The analyzer used to measure NO

x will be a chemiluminescent NO/NO

x monitor. The instrument operation is based on the principal of the chemiluminescent reaction of NO and O 3 . When NO and O3 react light is emi tted and the amou nt of light emitted is proportional to the concentration of NO in the sample gas stream. To measure NO concentrations, the gas sample to be analyzed is blended with O 3 in the instrument's reaction chamber. The resulting
chemiluminescence is monitored thr ough an optical filter by a highly sensitive photomultiplier tube ( PMT ) positioned at one end of the reaction chamber. The filter/photomultiplier combination responds to light in a narrow wavelength band unique to this chemiluminescent reaction (detailed below) the filter assists and eliminates interferences in this wavelength:

NO + O 3 → NO 2 + O 2 + hv

To measure NO
x concentrations (NO plus NO 2 ), the sample gas flow is diverted through a NO 2 -
to

- NO converter. The chemiluminescent response in the reaction chamber to the converter effluent is linearly proportional to the NO

x concentration entering the converter (sample gas).

Table 4. 6 .5.2

- TRC NO
x CEMS Zero and Span Gas Ranges

RANGE NO x ANALYZER

Zero

- range Nitrogen gas

Mid

- range 40 to 60% of calibration span High

- range equal to calibration span The calibration gases for the NO X analyzer will have Protocol certified values for NO and NO X
. An NO 2 to NO Conversion Efficiency Test per Section 8.2.4 of EPA Method 7E will be conducted to verify that the analyzer accurately converts NO 2 to NO in the NO
x mode. All readings will be reported within EPA Method 7E criteria.

4.6 .5. 3 CO Measurements (EPA Method 10) An analyzer based on the principle of GFC will be utilized for the measurement of CO. GFC offers improved specificity and sensitivity over conventional NDIR techniques. GFC spectroscopy is based upon comparison of the detailed structure of the infrared a bsorption spectrum of the measured gas to that of other gases also present in the sample being analyzed.Anadarko
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215228 The technique is implemented by using a high concentration sample of the measured gas, through the analyzer, hence the term GFC.

Radiation from an I R source is chopped and then passed through a gas filter alternating between
CO and N 2 due to rotation of the filter wheel. The radiation then passes through a narrow bandpass interference filter and enters a multiple optical pass cell where absorption by the sample gas occurs. The IR radiation then exits the sample cell and falls on an IR detector.

The CO gas filter acts to produce a reference beam, which cannot be further attenuated by CO in the sample cell. The N 2 side of the filter wheel is transparent to the IR radiation and therefore produces a measure beam that can be absorbed by CO in the cell. The chopped detector signal is modulated by the alternation between the two gas filters with amplitude related to th e concentration of CO in the sample cell. Other gases do not cause modulation of the detector signal since they absorb the reference and measure beams equally. In this way, the GFC system responds specifically to CO.

Table 4. 6 .5. 3

- TRC CO CEMS Zero and Span Gas Ranges

RANGE CO ANALYZER

Zero

- range Nitrogen gas

Mid

- range 40%

– 60% of Span High

- range 100% of Span

4.6 .5. 4 VOC Measurements (EPA Method 25A ) An analyzer based on the principle of Flame Ionization will be utilized for the measurement of

VOC. Heated flame ionization detectors (FID) and the procedures described in EPA Method 25A will be used to simultaneously m easure the total hydrocarbon emissio n concentration from the engines

. The engine exhaust gas will be transported to the analyzer through heated sample lines. The FIDs will be California Analytical Instruments Model 200 HFID analyzers or a similar heated

FID . The FID will be calibrated wit h EPA Protocol propane calibration gases. Heated sample lines, designed to eliminate possible condensation of the gas stream, will be utilized to transport the sample streams to the analyzer. The length of heated sample line from the sampling location to the

TRC analyzer will be approximately 100 feet or less. All of the exposed connections between the sample line and probe will be insulated to prevent any cold spots in the sample transport system

. The temperature of the sample transport system will be maintained above 250  F at all times.

The THC concentration data as measured by the FIDs will be processed and gathered by a digital data logger and 1

- minute averages will be stored on a personal computer. The data logger will record the output from the FIDs at a rate of once per second and these 1

- second values will be used
to form one

- minute averages, which will be stored in an electronic data file for each test run. At the
end of each one

- hour test, the 60 separate one

- minute averages will be stored in a spreadsheet andAnadarko
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215228 output to a printer and the one

- hour average THC concentration will be computed for each sampling location. Method 7E equations will be used to correct the VOC data for bias and drift.

The VOC analyzer will be calibrated with compre ssed gas cylinder standards. The zero reference will be established with ultra high purity (UHP) hydrocarbon

- free nitrogen. The instrument response will be established using propane EPA Protocol gases. Three calibration standards (zero, mid

- range, and spa n) will be used. The zero and span response of the THC analyzer will be checked before and after the test program. The system bias will be checked by introducing zero and span gas standards at the end of the sample probe. The entire sampling system
calib ration bias will be checked by routing the calibration gases through a separate Teflon line to the sample probe and back through the heated sample line to the FID. A calibration check will be conducted before and after each test run to insure the sample l ine integrity and to evaluate analyzer drift during each test run. Records of all calibrations and calibration checks will be provided in an appendix to the Test Report. The VOC emissions are expected to be between zero and 100 ppmv.

Table 4. 6 .5. 4

- TRC VOC CEMS Zero and Span Gas Ranges

RANGE CO ANALYZER

Zero

- range Nitrogen gas

Mid

- range 40%

– 60% of Span High

- range 100% of Span

4. 6

. 6 Gaseous Pollutant Sampling with 3 Point Traverse

EPA recently revised its requirements for gaseous pollutant sampling in engine stacks. The
waiver of the requirement for stratif ication checks on engine stacks was withdrawn. Per the March 10, 2014 guidance issued by Steffan Johnson of EPA’s Emission Measure ment Center, the gaseous pollutant sampling will be conducted at 3 traverse points. The engine stacks are greater than 12 inched in diameter and are located more than the minimum of 2 duct diameters
downstream from flow disturbances.Anadarko
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215228 

## 5 .0

– QUALITY ASSURANCE PLAN

5

. 1 QA/QC Organization and Procedures
TRC’s air measurements services are backed by a proven Quality Assurance and Quality Control (QA/QC) Program which has the full support of corporate management. Implementation of the QA/QC Program is accomplished through the use of approved procedures that define the systems and practices that will be used to ensure quality and reliability of the test data

.

TRC ’s AMS complies with the criteria specified in ASTM D7036

- 04, and each TRC test crew will include at least one person with QSTI or QI credentials.

The TRC Quality Assurance orga nization consists of three levels:

 Corporate Quality Assurance Director, who is responsible for establishing and overseeing the company’s quality management systems, assisting practice groups in setting up area

- specific programs, and serving as a company resource on quality

- related issues . Ms. Robin Nelson is the TRC Corporate QA Director.

 Air Measurements Quality Assurance Director, who is responsible for establishing and implementing the Air Measurements Quality Program, overseeing the self

- assessment and quality training programs, and serving as a resource for addressing quality

- related i ssues from group managers and project

managers. Mr. Ed MacKinnon is the TRC Air Measurements QA Director.

 Project Quality Assurance Manager, who will be directly responsible for the QA procedures and data quality of this testing program. Mr. Carl Fink w ill serve as the Project QA Manager.

5.2 Calibration Procedures and Frequency

5 .2.1 Calibration Gases All calibration gases used to conduct instrument calibrations are prepared in accordance
with EPA Protocol 1 and are traceable to National Institute of S tandards and Technology
Reference Materials. C opies of the pertinent calibration gas certifications will be
included in the test reports

.

5.2.2 Reagent Certifications All reagents used for this project will conform to the specifications established by the Committee on Analytical Reagents or the ACS, or the best available grade.

5 .2.3 Instrument Calibrations All instrument calibrations will meet the performance criteria defined in 40 CFR 60 Appendix A, Method 3A, 7E

, 10, and 25A

.Anadarko
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215228 5.3 Sample Recovery and Chain of Custody Procedures

5.3.1 Shipping and Packing of Samples All samples will be transported to a subcontract laboratory under custody and in accordance with IATA guidelines. The samples will be transported offsite on a daily basis, when possible, following completion of all testing.

5.3. 2 Sample Traceability Custody records will trace a sample from the time of train setup through all transfers of custody until it is received by the analytical laboratory. Internal laboratory records then
docume nt the custody of the sample through its final disposition. These records will be presented with the final analytical data package.

5. 3.3 Chain

– of

- Custody Documentation

5.3.3.1 Labeling Preprinted sample identification labels will be used to ensure that the required information is entered in the field. When sample batches are shipped to the specified laboratory, a sample

- packing list will accompany the shipment. This form is based on established laboratory format and will be used to document sample tra nsfer in the field and from sampling personnel to the laboratory.

5.3.3.2 Integrity Seals Integrity seals will be placed over the top of the sample shipment containers to detect unauthorized sample handling. Gummed labels or equivalent are acceptable for this purpose. The seal will include the following information: sample number and the signature of the person recovering the sample.

5.3.3.3 Chain

- of

- Cust ody Procedures
All recover e d samples will be recorded on the Chain

- of

- Custody Form. Each onsite recovery person will maintain a separate data sheet for the samples that he or she recovers. As each sample is recovered, the samples will be labeled and seal ed. All chain

of

- custody sheets will be maintained by TRC.

5.3.3.4 Sampling Trains and Spare Equipment TRC will have redundant equipment onsite in the event of equipment failure or breakage. Replacement for any equipment without on

- site backup will be d elivered within 24 hour s, if possible . A complete inventory of spare equipment, reagents and other expendables will be onsite during the test campaign to reduce delays.

5.4 Data Handling & Reduction Procedures
The data collected in the field will be rec orded on standardized data sheets or printed directly from the Reference CEMS system. The Field Team Leader will review theAnadarko
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215228 collected data in the field and ma ke note of any discrepancies or errors. The Project Quality Assurance Manager will review and va lidate the test data based on the test protocol and the standard operating procedures for each method

. All data will be reported in standard units as follows: Stack Exhaust (pollutants based on permit conditions)

1 Methods 1 & 2

- Stack exhaust flow rates (reported in dscfm and acfm)

2 Method 4

- Stack exhaust moisture content (percent)

3 Gas Diluents and Pollutants

a. Method 3A

- O 2 and CO 2 - percent, dry , lb/hr, g/kw

- hr b. Method 5/202

– PM

– gr/dscf, g/dscm, lb/hr

, g/kW

- hr

c

. Method 7E

– NO 2 , NOx

– ppm v , lb/hr , g/ k W

- hr , lb/kW

- hr
d

. Method 10

– CO

- ppm v , lb/hr, g/kW

- hr, lb/kW

- hr

e. Method 25A

– VOC

– ppmv, lb/hr, g/kW

- hr, lb/kW

- hr

Emission rate plots versus engine load will be provided.

5.5 Report Content and Timing

Within 45 days of completion of the field effort, TRC will prepare and submit three (3)
hard copies and an electronic version of the test report to Anadarko

. It should be noted that sample transportation issues, beyond TRC’s control, from overseas projects may cause delays in the report preparation schedule.

Each test report will include an introduction, summary of results for each unit tested, descriptions of all sampling and analytical methods, QA/QC data, example calculations, and copies of all field and ana lytical data. Listed below is a minimum of the following reporting components:

1 Introduction

2 Summary of Results (narrative plus table of results in comparison to emissions limits)

3 Source Description

4 Sampling and Analytical Procedures

a. Overview
b. Field Progra m Description

c. Testing Methodology
d. TRC CEMS

5 Quality Assurance

a. Overview
b. Field Quality Control Summary

c. Data Reduction, Validation, and Reporting Appendix A

– Printouts of Results Appendix B

– Laboratory Analysis Results (PM) Appendix C

– Engine Operating and DEWT DataAnadarko
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215228 Appendix D

– Manual Calculations & Field Data

Appendix E

– Equipment Calibration & Gas Certification Information Appendix F

– Project Participants