***DRAFT for Public Notice***

Statoil OCS

- EPA

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## UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Atlanta, Georgia

Permit to Construct and Operate Under the

Outer Continental Shelf Air Regulations

Permit No. OCS

- EPA

- R40 12

- M1

In accordance with the provisions of section 328 of the Clean Air Act (CAA), 42 U.S.C. § 7627 and the implementing Outer Continental Shelf (OCS) Air Regulations at title 40 Code of Federal Regulations (CFR) part 55, which incorporate by reference the Pre vention of Significant Deterioration (PSD) of Air Quality (PSD) R r egulations at 40 CFR § 52.21, and the T itle V Operating Permit Program regulations at
40 CFR part 71

. ,

Statoil Gulf Services, LLC 2103 CityWest Boulevard, Suite 800 Houston, Texas 77042

is hereby authorized to construct and operate air emissions units and to conduct other air pollutant emitting activities at an OCS source at multiple sites within the Gulf of Mexico, within the areas defined in this permit as the project location. DeSoto C anyon lease blocks 143, 187, 188, 230, 231, 625, 669, 670, 671, 715, 716, 759, 760, and 804

. The northwest corner of lease block 143, the closest point to any shoreline, is located on OCS waters of the Gulf of Mexico east of longitude 87.5 o W at latitude 28. 85 o N and longitude 86. 42 o W, approximately 160 miles southeast of the mouth of the Mississippi River and

200 miles southwest of Panama City, Florida

.

Upon commencing activities in the area defined in this permit as the project location initial start

- up , this

OCS source and associated support vessels shall be constructed and operated in accordance with the terms and conditions set forth in this permit.

This permit originally became effective on November 27, 2013. Modifications to t his This permit shall

become effective on November 27, 2013 [INSERT DATE ]

, 2014 unless review of the permit decision is requested in accordance with 40 CFR § 124.19 or 40 CFR § 71.11(l).

This permit shall expire on: November 27, 2018

.

This permit shall not relieve the owner or operator of the responsibility to comply fully with all applicable provisions of federal and state law.

__________ ______________________ Date Signed Beverly H. Banister

Director Air, Pesticides, and Toxics Management Division2

Statoil OCS

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- M1 1 AUTHORITY

The United States Environmental Protection Agency (EPA) issues this permit pursuant to section 328 of the CAA, 42 U.S.C. § 7627, and the implementing OCS Air Regulations at 40 CFR part 55, which incorporate by reference the PSD R r egulations at 4 0 CFR § 52.21 and the T itle V Operating Permit Program regulations at 40 CFR part 71. This permit is based upon application materials submitted to the EPA by Statoil Gulf Services, LLC ( Statoil ) dated September 5 , 201 2

, December 7, 2012, January 28,

2013

, and June 27 , 2013, and

, as revised

, March 27, 2014; all supplemental submittals and information

included in the administrative record for this permit action ;
, and upon the technical analysis performed by the EPA.

2 APPLICANT

Statoil Gulf Services, LLC

2103 CityWest Boulevard, Suite 800 Houston, Texas 77042

3 PROJECT LOCATION

Statoil’s project is located in the OCS waters of the Gulf of Mexico

. , The Transocean Discoverer

Americas will operate in the DeSoto Canyon area lease blocks 143, 187, 188, 230, 231, 625, 669, 670, 671, 715, 716, 759, 760, and 804

. The Maersk Developer will operate in the same DeSoto Canyon area or in any eastern Gulf of Mexico area located further from the Breton Wilderness Class I area, east of longitude 87.5, west of the Military Missio n Line (86°41’ west longitude), outside of the current Congressional moratoria area as specified by the Gulf of Mexico Energy Security Act of 2006, and not within 75 nautical miles of the state seaward boundary of Florida.

The northwest corner of lease b lock 143, the closest point within the specified lease blocks to any state’s shoreline, is located on OCS waters of the Gulf of Mexico east of longitude 87.5 o W at latitude 28.85o N and longitude 86.42 o W

.

4 PROJECT DESCRIPTION

Statoil will operate eithe r the Maersk Developer (Operating Scenario 1) or the Transocean Discoverer

Americas (Operating Scenario 2) deepwater drilling vessel and its associated support vessels to perform exploratory drilling activities for approximately 180 days per year at multip le locations within the DeSoto Canyon lease blocks listed in Section 3 above. D rilling operations are expected to occur for approximately five to ten years. This permit does not authorize the construction or establishment of any permanent production facilities.

Air pollutant emissions generated from the project include nitrogen dioxide (NO 2 ), carbon monoxide (CO), particulate matter (PM), particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM 2.5 ), particulate matter wit h an aerodynamic diameter less than or equal to 10 microns (PM 10 ) , and sulfur dioxide (SO 2 ) (known as criteria pollutants), as well as other regulated air pollutants including volatile organic compounds (VOC), oxides of nitrogen ( NO X ), and greenhouse gases (GHG)

. VOC and NO X are the measured precursors for the criteria pollutant ozone, and NO X and SO 2 are measured precursors for PM 2.5

.3

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- M1 GHG emissions for this project were calculated based on Global Warming Potential (GWP) factors from the GHG Reporting Rul e at 40 CFR Part 98, Subpart A, Table A

- 1

. The following GWP factors in

Table A

- 1 as of the date of the original permit remain applicable to the unmodified terms of the permit ( i.e , emissions related to the Transocean Discoverer Americas operating under Operating Scenario 2): that were required as of the date of this permit. Current GWP factors for applicable GHG pollutants

are:

GHG Pollutant GWP Factor

CO 2 1

CH 4 21

N 2 O 310

SF 6 23,900

GWP factors currently in 40 CFR Part 98, Su bpart A, Table A

- 1 and applicable to the modified permit

terms related to the Maersk Developer and support vessel emissions are:

GHG Pollutant GWP Factor

CO 2 1

CH 4 25

N 2 O 298

SF 6 22,800

E missions are primarily released from the combustion of diesel fuel in the drill ing vessel ’s main engines, as well as in engines t hat supply power for drilling equipment and support vessels. Emissions are also released from other equipment such as storage tanks, and from activities such as vessel maintenance, cementing the wells

, and the pumping of heavy lubricating mud.

Based on emissions estimates and the applicable pe rmitting thresholds, both operating scenarios will have significant emissions of NO X , and are considered major sources of NO X with respect to the PSD and title V regulations. Therefore, drilling operations conducted under either operating scenario are subj ect to the PSD and title V programs for NO X as the measured pollutant for criteria pollutants NO 2 and ozone and as a precursor to PM 2.5

. Based on stack testing data from October 2013 included in Statoil’s permit modification application dated March 27, 2014 , drilling under Operating Scenario 1 using the Developer also has emissions of PM 10 , PM 2.5 , and VOC that meet or exceed the respective PSD significant emission rates. In addition, either operating scenario will be considered an area source

of hazardou s air pollutants pursuant to 40 CFR 63 subpart ZZZZ.

Based on Statoil’s original permit application dated September 5, 2012 , PM 2.5 will be emitted at close to its significant emission rate in both o O perating s S cenario 2 s . Therefore, the EPA has also included a condition in the draft permit that limits the Discoverer America’s project’s total filterable and

condensable PM 2.5 emissions.

The Developer (Operating Scenario 1) is a self

- powered, dynamically positioned semi

- submersible drill

ri g constructed with pontoon structures below the water surface and columns supporting a platform above the surface. Rig positioning is achieved using a computer controlled sensor system and the vessel’s propellers and thrusters. Therefore, the rig will not require the use of towing or anchoring vessels as part of the support fleet.4

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- M1 The rig is equipped with eight main generator engines to provide propulsion and electrical power, two cementing unit engines, an emergency generator, four life boats, a fast resc ue boat (man overboard boat), and storage vessels for fuel and waste oil storage. Electric powered well logging (wireline) units

, forklifts, and cranes are used on the rig. However, since the electric units do not have combustion engines, they are not addr essed as a separate source of air emissions. Information regarding emissions

units for the Developer is provided in Table 1 below

.

The information provided in Tables 1 and 2 is for description and identification purposes and does not establish operating limits. Permit conditions may limit operation to less than rated capacity.

Table 1

– Developer Emissions Units (Operating Scenario 1)

Emissions

Unit ID Description Manufacturer

and Model Displacement

(L/cylinder) Rating

(kW) a Rating

(hp) b Manufacture

Date

GEN

- 1 Main Generator Engine 1 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

GEN

- 2 Main Generator Engine 2 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

GEN

- 3 Main Generator Engine 3 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

GEN

- 4 Main Generator Engine 4 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

GEN

- 5 Main Generator Engine 5 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

GEN

- 6 Main Generator Engine 6 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

GEN

- 7 Main Generator Engine 7 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

GEN

- 8 Main Generator Engine 8 Wärtsilä 16V26A 17.0 4960 4840 6651 8/2006

EGEN Emergency Generator

Engine Caterpillar 3516B 4.9 1902 2551 11/2006

CMU

- 1 Cement Unit Engine 1 Caterpillar C15 2.4 373 500 10/2006

CMU

- 2 Cement Unit Engine 2 Caterpillar C15 2.4 373 500 9 /2006

LB

- 1 Lifeboat 1 Engine BUKH or similar

--- 22 29 8/2007

LB

- 2 Lifeboat 2 Engine BUKH or similar

--- 22 29 8/2007

LB

- 3 Lifeboat 3 Engine BUKH or similar

--- 22 29 8/2007

LB

- 4 Lifeboat 4 Engine BUKH or similar

--- 22 29 8/2007

MOB

- 1 Fast Rescue Boat Engine Steyr Motors or similar --- 122 163 3/2007

a Kilowatt

b Horsepower

The Discoverer Americas (Operating Scenario 2) is a dynamically positioned drillship . Similar to the Developer in Operating Scenario 1, this drillship is equipped with a computer controlled sensor system to automatically maintain the vessel's position and heading over a location using its propellers and

thrusters. The drillship travels under the main generator engines’ power to the next drill site and does not require towing or anchoring vessels as part of the support fleet.

The Discoverer Americas’ equipment includes six main e ngines that power electrical equipment and serve as propulsion generators, an emergency generator, two emergency air compressors, two forklifts, six life boats, a fast rescue boat (man overboard boat), and storage vessels for fuel and waste oil. The ship is also equipped with electric

- powered wireline units , cementing units, and cranes . However, since these units do not have combustion engines, they are not addressed as separate sources of air emissions. Information regarding emissions units for the Discov erer Americas of Operating Scenario 2 is provided

in Table 2 below

.

Table 2

– Discoverer Americas Emissions Units (Operating Scenario 2)

Emissions

Unit ID Description Manufacturer and

Model Displacement (L/cylinder) Rating

(kW) a Rating

(hp) b Manufacture

Date

GEN

- 1 Main Generator Engine

1 STX MAN 14V32/40 32.2 7000 9387 3/20085

Statoil OCS

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Unit ID Description Manufacturer and

Model Displacement (L/cylinder) Rating

(kW) a Rating

(hp) b Manufacture

Date

GEN

- 2 Main Generator Engine

2 STX MAN 14V32/40 32.2 7000 9387 3/2008

GEN

- 3 Main Generator Engine

3 STX MAN 14V32/40 32.2 7000 9387 3/2008

GEN

- 4 Main Generator Engine

4 STX MAN 14V32/40 32.2 7000 9387 3/2008

GEN

- 5 Main Generator Engine

5 STX MAN 14V32/40 32.2 7000 9387 4 /2008

GEN

- 6 Main Generator Engine

6 STX MAN 14V32/40 32.2 7000 9387 4 /2008

EGEN Emergency Generator

Engine STX MAN 7L27/38 21.8 2309 3097 2/2008

ACOMP

- 1 Emergency Air

Compressor Engine 1 Duetz F3L912 0.9 37 50 1/2007

ACOMP

- 2 Emergency Air

Compressor Engine 2 Duetz F4L912 0.9 51 68 1/2007

FORK

- 1 Forklift Engine 1 Mitsubishi

8MVKL.0AAD or similar 3.3 (engine total) 37 50 2008

FORK

- 2 Forklift Engine 2 Mitsubishi

8MVKL.0AAD

or similar 3.3 (engine total) 37 50 2008

LB

- 1 Lifeboat 1 Engine BUKH or similar

--- 27 36 9/2006

LB

- 2 Lifeboat 2 Engine BUKH or similar

--- 27 36 9/2006

LB

- 3 Lifeboat 3 Engine BUKH or similar

--- 27 36 8/2006

LB

- 4 Lifeboat 4 Engine BUKH or similar

--- 27 36 9/2006

LB

- 5 Lifeboat 5 Engine BUKH or similar

--- 27 36 9/2006

LB

- 6 Lifeboat 6 Engine BUKH or similar

--- 27 36 9/2006

MOB

- 1 Fast Rescue Boat Engine Steyr Motors or similar --- 158 212 9/2006

HTR Cargo Hold Heater

--- --- --- --- Post 1989

a Kilowatt

b Horsepower

The drillship s is are supported by various vessels operating within 25 miles. Support vessels will include crew boats and offshore support vessels (OSVs) that bring crew, supplies, and materials to the ship as needed during exploratory drilling activities

. A r epresentative vessel for each support vessel category,

the crew boat Sybil Graham and the OSV Peyton Candies , was used to calculate the worst case potential

emissions from the support fleet.

5 GENERAL CONDITIONS

5.1 Compliance

5.1.1 The permittee shall comply with all requirements of 40 CFR part 71, 40 CFR § 52.21,

40 CFR part 55 and this permit. Failure to do so shall be considered a violation of section 111(e) of the CAA. All enforcement provisions of the CAA, including, but not limited to, the provisions of sections 113, 114, 120, 303

, and 304 of the CAA, shall apply to the OCS source and permittee

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- M1 5.1.2 The p ermittee must comply with all conditions of this permit. All terms and conditions of this permit are enforceable by the EPA and citizens under the CAA. Any permit noncompliance cons titutes a violation of the CAA and is grounds for enforcement action; for p ermit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.

5.1.3 It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

[ 40 CFR §§ 55.8, 55.9(a), 55.9(b), 71.6(a)(6) (i), and 71.6(a)(6) (ii)]

5.2 Permit Shield

Compliance with the terms and conditions of this permit shall be deemed compliance with the applicable requirements that are included and are specifically identified in this permit. Nothing in this permit shall alter or affect the following:

 The provisions of CAA section 303 (emergency orders), including the authority of the

Administrator under that sectio n;

 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; or

 The ability of EPA to obtain information from a source pursuant to CAA section 114.

[40 CFR § 71.6(f)(1)]

5.3 Other Credible Evidence

For the purpose of submitting compliance certifications in accordance with Condition 5.21 of this permit, or establishing whether or not a person has violated or is in violation of any requirement of this permit, nothing shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

[CAA § § 113(a) and 113 (e)(1), 40 CFR §§ 60.11(g) and 61.12]

5.4 Construction and Operation

5.4.1 As approved and conditioned by this permit, all construction and operation, including equipment operations and maintenance of the OCS source and support vessels shall be

in a ccordance with the data, specifications, drawings, exhibits, and assumptions included with the application and supporting materials submitted by the permittee, which resulted in this permit (application materials). This permit is valid only for the specifi c processes and operations applied for and indicated in the application materials. Any unauthorized deviation from the application materials, or from any term or condition of this permit may constitute grounds for revocation or enforcement action by

EPA.7

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- M1 5.4.2 The permittee shall properly operate and maintain the OCS source and support vessels, including all systems of treatment and control (and related appurtenances) that are installed and used by the permittee to achieve compliance with the terms and conditio ns of this permit. This provision includes the operation of backup or auxiliary fa cilities or similar systems when necessary to minimize or prevent emissions in achieving compliance with the terms and conditions of the permit.

[ 40 CFR § 52.21(r)(1)]

5.5 Compliance and Other Requirements

This permit does not relieve the permittee of the responsibility to comply fully with applicable provisions of any other requirements under federal law.

[40 CFR § 55.6(a)(4)(iii)]

5.6 Notification to Owners, Operators

, and Co ntractors

The permittee must notify all other owners or operators, contractors, and the subsequent owners or operators associated with emissions from the OCS source and support vessels of the terms and conditions of this permit.

[40 CFR § 55.6(a)(4)(iv)]

5.7 Expiration of Approval to Construct and Permit Renewal

5.7.1 This approval to construct shall become invalid if: construction is not commenced within 18 months after the effective date of this permit, construction is discontinued for a period of 18 months or mo re, or construction is not completed within a reasonable

time. The EPA may extend the 18

- month period upon a satisfactory showing that an extension is justified. For the purposes of this pe rmit, periods greater than 18 months between drilling campaigns are not considered to be a discontinuation of construction.

[40 CFR § 52.21(r)(2)]

5.7.2 This permit shall expire on the expiration date on page one of this permit.

[40 CFR § 71.6(a)(2)]

5.7.3 Expiration of this permit terminates the permittee’s right to operate unless a timely and complete permit renewal application has been submitted at least six ( 6 ) months, but not more than 18 months, prior to the date of expiration of this permit. If the pe rmittee submits a timely and complete renewal application, and the EPA does not take final action on the renewal application before the end of the term of this permit, the permittee’s failure to have a permit is not a violation of 40 CFR part 71 until the permitting authority takes final action on the renewal application. Such protection will cease to apply if, subsequent to the EPA’s determination that the renewal application is complete, the permittee fails to submit by the deadline specified in writing b y the EPA any additional information identified as being needed to process the application.

[40 CFR §§ 71.5(a)(1)(iii), 71.7(b)

, and 71.7(c)(1)(ii)]8

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- M1 5.7.4 If the permittee submits a timely and complete permit application for renewal,

consistent with 40 CFR §§ 7 1.5(a)(1)(iii) and 71.5(a)(2), but the EPA does not take final action on the renewal application before the end of the term of this permit, then all the terms and conditions of this permit, including any permit shield granted pursuant to

40 CFR § 71.6(f), shall remain in effect until EPA takes final action on the renewal application.

[40 CFR §§ 71.7(c)(3) and 71.7(b)]

5.7.5 Renewal of this permit is subject to the same procedural require ments that apply to initial permit issuance, including those for public part icipation and affected State

review.

[40 CFR § 71.7(c)(1)(i)]

5.7.6 An application to the EPA for renewal shall include all information required pursuant to

40 CFR § 71.5(c), as well as the current permit number, a description of permit

revisions and off

- permit changes that occurred during the permit term and were not incorporated into the permit during the permit term, any applicable requirements that were promulgated and not incorporated into the permit during the permit term, and other information required by the application form.

[40 CFR §§ 71.5(a)(2) and 71.5(c)(5)]

5.8 Property Rights

This permit does not convey any property rights of any sort, or any exclusive privilege.

[40 CFR §71.6(a)(6)(iv)]

5.9 Inspections

The permittee, by accepting this permit, specifically agrees to allow authorized EPA personnel, upon presentation of credent ials or other documents as may be required by law and at reasonable times, access to the prem ises where the permitted activity is located or conducted or where any records a re required to be kept under the terms and conditions of this permit to:

 Have access to and copy any records that must be kept under the conditions of the permit,

in cluding but not limited to, information relating to the OCS source, support vessels,

monit oring data, or compliance or noncompliance with the permit;

 Inspect the OCS source, support vessels, equipment, practices, or operation regulated or required under this permit; an d

 Sample or monitor any substances or parameters at any location reasonably n ecessary to assure compliance with this permit or EPA rules.

Reasonable time may depend on the nature of the concern being investigated.

[40 CFR § § 71.6(c)(2) and 55.8 ]

5.10 Emergency Provisions9

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- M1 In addition to any emergency or upset provision contained in any applicable requirement, the permittee may seek to establish that noncompliance with a technology

- based emission limitation under this permit was due to an emergency. An emergency constitutes an affirmative defense to an action brought for noncompliance wi th such technology

- based emissions limitation. The permittee shall demonstrate the affirmative defense of emergency through properly signed, contemporaneous operating logs, or other

relevant evidence that:

 An emergency occurred and that the permittee can identify the cause(s) of the emergency;

 The permitted facility was at the time being properly operated;

 During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emissions standards, or o ther requirements in this permit; and

 The permittee submitted notice of the emergency to the EPA within two ( 2 ) working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This notice fulfills the requirements of Condition 5.17.2 of this permit, concerning prompt notification of deviations.

[40 CFR §§ 71.6(g)(2), 71.6(g) (3)

, and 71.6(g) (5)]

5.11 Burden of Proof for Emergencies

In any enforcement proceeding, the permittee attempting to establish the occurrence of an emergency has the burden of proof.

[40 CFR § 71.6(g)(4)]

5.12 Emergency Defined

An “emergency” means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology

- based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error.

[40 CFR § 71.6(g)(1)]

5.13 Certification Requirement

Any document required to be submitted under this permit shall be certified by a responsible official as to truth, accuracy

, and completeness. Such certifications shall state that based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

[40 CFR §§ 71.5(d), 71.6(c)(1)

, and 71.9(h)(2)]

5.14 Per mit Actions

This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or antic ipated noncompliance does not stay any permit condition.

[40 CFR § 71.6(a)(6)(iii)]10

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- M1 5.15 Reopening for Cause

The permit shall be reopened by the EPA and the permit revised prior to expiration under any of the circumstances described in 40 CFR § 71.7(f).

[40 CF R § 71.7(f)]

5.16 Recordkeeping Requirements

In accepting this permit, the permittee understands and agrees that all information relating to this permitted source which is submitted to the EPA may be used by the EPA as evidence in any

enforcement case involvin g the permitted source arising under federal statutes, EPA rules, or rules enforceable by the EPA.

5.16.1 This permit or a copy thereof shall be kept at the work site of the permitted activity.

5.16.2 The permittee shall furnish all r ecords required by this permit.

5.16.3 During enforcement actions, the retention period for all records required by this permit will be extended automatically until the permittee receives written notice from EPA that the permittee no longer needs to retain these records unless otherwise stipulat ed by

the EPA

.

5.16.4 The permittee shall hold at the corporate offices of Statoil Gulf Services

, LLC , located

at 2103 CityWest Boulevard, Suite 800

, Houston, Texas 770 42

, all records required by the permit, including, but not limited to, of all monitoring data and support information required by the permit, copies of all reports required by this permit, and records of all data used to complete the application for this permit. These materials shall be retained at least five years from the date of the sample, measurement, report, or application unless otherwise specified. Records of all data used to complete the permit application must be kept for five years from the date of the application, unless otherwise specified. Support information includes all calibra tion and maintenance records and all original strip chart recordings for continuous monitoring instrumentation and copies of all reports required by the permit.

[40 CFR § § 71.6(a)(3)(ii)(B) and 55.8 ]

5.16.5 Records of monitoring information shall include:

 D ate and time of sampling or measurements;

 E mission unit or other place as defined in this permit ;

 Name of the person who performed the sampling or measurements;

 Operating conditions as existing at the time of sample or measurement;

 Date(s) the analyses were p erformed;

 R esults of such analyses ; and

 A nalytical techniques or methods used.

[40 CFR § 71.6(a)(3)(ii)(A)]11

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- M1 5.16.6 When requested by the EPA, the permittee shall furnish any information required by law which is needed to determine compliance with the permit. If the permittee becomes aware that relevant facts were not submitted or were incorrect in the permit application or in any report to the EPA, such facts or information shall be corrected promptly.

[40 CFR § § 71.5(b) and 55.8 ]

All notifications, reporting or other communications relating to this permit shall be

submitted to:

Chief

Air & EPCRA Enforcement Branch Air, Pesticides and Toxics Management Division U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303

In addition, electronic copies of the above

- referenced notifications and communications shall be submitted to the following individuals at their corresponding email address:

Name Email Phone David Lloyd lloyd.david@epa.gov 404

- 562

- 9216

Jason Dressler dressler.jason@epa.gov 404

- 562

- 920 8 Kelly Fortin fortin.kelly@epa.gov 404

- 562

- 9117 Lori Shepherd lorinda.shepherd@epa.gov 404

- 562

- 8435

5.16.7 The permittee shall furnish to the EPA, within a reasonable time, any information that

the EPA may request in writing to determine whether cause exists for modifying, revoking, and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee shall also furnish to the EPA copies of records that are required to be kept pursuant to the terms of the permit, in cluding information

claimed to be confidential. Information claimed to be confidential must be accompanied by a claim of confidentiality according to the provisions of 40 CFR part 2, subpart B.

[40 CFR §§ 71.6(a)(6)(v), 71.5(a)(3)

, and 55.8 ]

5.17 General Reporting Requirements

5.17.1 The permittee shall submit to the EPA reports of any required monitoring for each six month reporting period from July 1 to December 31 and from January 1 to June 30, except that the first reporting period shall begin on the effecti ve date of this permit and end on either June 30 or December 31, whichever occurs first. All reports shall be

submitted to the EPA and shall be postmarked by the 30th day following the end of the reporting period. All instances of deviations from permit re quirements must be clearly identified in such reports. All required reports must be certified by a responsible o fficial

consistent with Condition 5.13.12

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- M1 5.17.2 The permittee shall promptly report to the EPA, by telephone or facsimile, deviations from permit condi tions, including those attributable to upset conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. The report shall be made using the following numbers:

Telephone: (404) 562

- 9 194 Facsimile: (404) 562

- 9019 Attn: Air Permits Part 71 Deviation Report

5.17.3 For the purposes of Condition 5.17.2 of the permit, prompt is defined as follows:

5.17.3.1 Any definition of prompt or a specific time frame for reporting deviations provided in an underlying applicable requirement as identified in this permit.

5.17.3.2 Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule:

 For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report must be made within

24 hours of the occurrence;

 For emissions of any regula ted pollutant excluding those referenced in the preceding bullet, that continue for more than two ( 2 ) hours in excess of permit requirements, the report must be made within 48 hours of the

occurrence; or

 For all other deviations from permit requirements, t he report shall be

submitted with the semi

- annual monitoring report required in Condition

5.17.1.

5.17.4 Within 10 working days of the occurrence of a deviation that requires 24

- hr or 48

- hr

notification as provided in Condition 5.17.3.2 above, the permittee shal l also submit a written notice, which shall include a narrative description of the deviation and updated

information as listed below to the EPA, certified consistent with Condition 5.13 of this permit. When reporting excess emissions or permit deviations, including those that are required to be submitted for the first time with the semi

- annual monitoring report, the permittee must report in writing the following information:

 OCS Source (Facility) Name;

 OCS Air Permit Number;

 Company Name;

 Date/Time when the deviation was discovered;

 Date/Time when the event began (24

- hour clock);

 Date/Time when the event ended (24

- hour clock);

 Duration of the event: (hours: minutes) or days (total number of hours, minutes or days, if intermittent then include only the dur ation of the deviation);

 If the deviation was intermittent or continuous;13

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 Brief description of what happened and the cause, including information regarding the operating conditions during the deviation;

 Identification of the emission unit(s) or source(s) involved in the event using the same identification number(s) and name(s) as in the permit;

 Identification of each emission limit potentially exceeded during the event and the level of exceedance, if applicable;

 Whether the deviation was unavoidable;

 Descr ibe corrective action taken and action taken to prevent future recurrence;

 If not corrected, the anticipated time the deviation is expected to continue and steps being taken to reduce, eliminate, and prevent recurrence of the deviation; and

 Certification: Based on information and belief formed after reasonable inquiry, certify that the statements and information reported are true, accurate, and complete.

5.17.5 For the purposes of Conditions 5.17.1 through 5.17. 6 , deviation means any situation in which the permi ttee fails to meet a permit term or condition. A deviation is not always a violation. A deviation can be determined by observation or through review of data obtained from any testing, monitorin g, or recordkeeping required by this permit. For a

situation la sting more than 24 hours, each 24

- hour period is considered a separate deviation. Included in the meaning of deviation are any of the following:

 A situation where emissions exceed an emission limitation or standard;

 A situation where process or emissions control device parameter values indicate that an emission limitation or standard has not been met;

 A situation in which observations or data collected demonstrate noncompliance with an emission limitation or standard or any work practice or operating con dition required by the permit (including indicators of compliance revealed through parameter monitoring); and

 A situation in which any testing, monitoring, recordkeeping or reporting required by this permit is not performed or not performed as required.

5.17.6 I f requested by the EPA, the permittee shall provide a more detailed written report as requested to follow up on an excess emissions/deviation report.

[40 CFR § § 55.8, 71.6(a)(3)(i)(B) , and 71.6(a)(3)(iii) ]

5.18 Off Permit Changes

The permittee is allowed to make certain changes without a permit revision, provided that the following requirements are met:

 Each change is not addressed or prohibited by this permit;

 Each change shall meet all applicable requirements and shall not violate any existing permit term or condition; and

 Each change may not include changes subject to any requirement under any provision of title

I of the Clean Air Act

.

5.18.1 The permittee shall pro vide contemporaneous written notice to the EPA of each change under this provision , except for changes that qualify as insignificant activities under 40 CFR § 71.5(c)(11). The written notice shall include the following:14

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 A descri ption of each change ;

 D ate of the change ;

 A ny change in emissions ;

 List of pollutants emitted ; and

 A ny applicable requirements that would apply as a result of the change

.

5.18.2 The permit shield in Condition 5.2 does not apply to changes made under this provision

.

5.18.3 The permittee shal l keep a record describing all changes that result in emissions of any regulated air pollutant subject to any applicable requirement not otherwise regulated under this permit, and the emissions resulting from those changes.

[40 CFR §71.6(a)(12)]

5.19 Operational Flexibility

The permittee is allowed to make a limited class of changes under section 502(b)(10) of the C lean A ir

A ct within this permitted facility without applying for a permit revision, provided the changes do not

exceed the emissions allow able under this permit (whether expressed therein as a rate of emissions or in terms of total emissions) and are not title I modifications. This class of changes does not include changes that would violate applicable requirements or changes that would cont ravene federally enforceable permit terms and conditions that are monitoring (including test methods), recordkeeping, reporting, or compliance certification requirements.

5.19.1 The permittee is required to send a notice to EPA at least 7 days in advance of any change made under this provision. The notice must describe the change, when it will occur and any change in emissions, and identify any permit terms or conditions made inapplicable as a result of the change. The permittee shall attach each notice to its co py thi s permit.

5.19.2 Any permit shield provided under 40 CFR § 71.6(f) and Condition 5.2 of this permit does not apply to changes made under this provision.

[40 CFR § § 71.2 and 71.6(a)(13)(i)]

5.20 Combined Operating Scenarios

In the event that more than one drilling vessel is constructed or operated during any compliance period,

such as a 12

- month rolling average, any applicable condition of this permit, including but not limited to emission limits, fuel consumption limits, ope rating limits, and fee calculati ons, shall be prorated based on the duration of the operation of each vessel during the compliance period. In no case does this

condi tion allow for the simultaneous operation of more than one drilling vessel concurrently within the lease blocks specified in Section 3 under the terms of this permit.

[40 CFR § 55.6]

5.21 Annual Compliance Certification

The permittee shall submit to the EPA a certification of compliance with permit terms and conditions, including emission limitations, standards, or work practice s, postmarked by February 28 of each year15

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t ruth, accuracy and completeness by a responsible official consistent with Condition 5.13 of this permit. The certification shall include the following:

 I dentification of each permit term or condition that is the basis of the certification;

 I dentification of the method(s) or other means used by the permittee for determining the compliance status with each term and condition during the certification period. Such methods and other means shall include, at a minimum, the methods and means required in this permit. If necessary, the permittee also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the CAA, which prohibits knowingly making a false certification or omitting mater ial information;

 S tatus of compliance with each term and condition of the permit for the period covered by the certification, including whether compliance during the period was continuous or

intermittent. The certification shall be based on the method or means designated above. The certification shall identify each deviation and take it into account in the compliance certification; and

 A summary of NO X , CO, PM/PM 10 /PM 2.5 , SO 2 , VOC, GHG

, and HAP emissions in tons per year emitted by each emissions unit regu lated under this permit during the duration of the reporting period based on recorded data, such as actual fuel usage and actual hours of operation.

[40 CFR § §71.6(c)(5), 55.6(a)(4) and 55.8 ]

5.22 Compliance Schedule

For applicable requirements with which the source is in compliance, the permittee will continue to comply with such requirements. For applicable requirements that will become effective during the permit term, the permittee shall meet such requirements on a timely basis.

[40 CFR §§ 71.6(c)(3) and 71 .5(c)(8)(iii)(A) and (B)]

5.23 Safe Shutdown

As provided in 40 CFR § 55.9(c), if this OCS source is ordered to cease operation of any piece of equipment due to enforcement action taken by the EPA, the shutdown will be coordinated by the EPA

with the DOI Bureau of Safety and Environmental Enforcement , the United States Coast Guard, the permittee, and the operator to assure that the shutdown will proceed in a safe manner. No shutdown

action will occur until after the EPA’s consultation with these agencies en tities , but in no case will initiation of the shutdown be delayed by more than 24 hours after the EPA consults with these agencies. The initiation of the shutdown process will not preclude well procedures necessary to ensure safety.

[40 CFR § 55.9(c)]

5.24 Tran sfer of Ownership

In the event of any changes in control or ownership of the OCS source, this permit shall be binding on all subsequent owners and operators. Permittee shall notify the succeeding owner and operator of the existence of this permit and its conditions by letter, a copy of which shall be forwarded to EPA Region 4.

[40 CFR § 55.6(a)(4)(iv)]16

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The provisions of this permit are severable, and, in the event of any challenge to any portion of this permit or if any provision of the permi t is held invalid, the remainder of this permit shall remain valid

and in force

. [40 CFR §71.6(a)(5)]

5.26 General Testing Requirements

5.26.1 In addition to the specific testing requirements contained in the emission unit sections of this permit, the permittee shall compl y with the generally applicable testing requirements in Conditions 5.26.2 through 5.26.10 whenever conducting a performance test required by this permit unless specifically stated otherwise in this permit.

5.26.2 The permittee shall provide the EPA at least 30 d ays prior notice of any performance test, except as otherwise specified in this permit, to afford the EPA the opportunity to have an observer present. If after 30 days n otice for an initially scheduled performance test, there is a delay in co nduc ting the s cheduled performance test, the permittee shall notify the EPA as soon as possible of any delay in the original test date, either by providing at least seven ( 7 ) days prior notice of the rescheduled date of the performance test, or by arranging a rescheduled date with the EPA by mutual agreement.

5.26.3 The permittee shall submit to the EPA a source test plan 30 days prior to any required testing. The source test plan sh all include and address the following elements:

 Purpose and scope of testing;

 Sourc e description, including a description of the operating scenarios and mode of operation during testing and including fuel sampling and analysis procedures;

 Schedule/dates of testing;

 Process data to be collected during the test and reported with the resu lts, including

source

- specific data identified in the emission unit sections of this permit;

 Sampling and analysis procedures, specifically requesting approval for any proposed alternatives to the reference test methods, and addressing minimum test length ( e.g. , one hour, eight ( 8 ) hours, 24 hours, etc.) and minimum sample volume;

 Sampling location description and compliance with the reference test methods;

 Analysis procedures and laboratory identification;

 Quality assurance plan;

 Calibration procedures and frequency;

 Sample recovery and field documentation;

 Chain of custody procedures;

 Quality assurance/quality control project flow chart;

 Data processing and reporting;

 Description of data handling and quality control procedure s; and

 Report content and timing.17

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conditions may render the source test invalid.

5.26.5 For the duration of each test run (unless otherwise specified), the permittee shall record the following information:

 All data which is required to be monitored during the test in t he emission unit sections of this permit; and

 All continuous monitoring system data that is required to be routinely monitored in the emission unit sections of this permit for the emission unit being tested.

5.26.6 Each source test shall follow the reference test methods specified by this permit and

consist of at least three ( 3 ) valid test runs conducted under normal operating conditions.

5.26.7 If the reference test method yields measured pollutant concentration values at an oxygen concentration other than specified in the emission standard, the permittee shall correct the measured pollutant concentration to the oxygen concentration specified in the emission standard by using the following equation:

PC X = PC
m x (21

- X)

(21

- Y)

Where:

PC X = Pollutant concentration at X percent;

PC
m = Pollutant concentration as measured; X = the oxygen concentration specified in the standard; and Y = the measured average volumetric oxygen concentration.

5.26.8 Facilities for performing and observing the emission testing shall be provided that meet the requirements of 40 CFR § 60.8(e) and Reference Method 1 (40 CFR § 60, Appendix A).

5.26.9 Emission test reports shall be submitted to the EPA within 45 days of completing any emission test required by this permit along with items required to be recorded in

Condition 5.26.5 above.

5.26.10 Source test emission data shall be reported as the arithmetic average of all valid test runs and in the terms of any applicable emissi on limit, unless otherwise specified in the emission unit sections of this permit.

[40 CFR §§ 71.6(a)(3) and 71.6(c)(1)]

5.27 Fee Payment

5.27.1 No later than April 1 of the subsequent each year, th e permittee shall submit the following to the EPA:

 Full payment of the annual permit fee, as specified in Conditions 5.27.2 through 5.27.11;18

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 An updated fee calculation worksheet form and a photocopy of each fee payment check (or other confirmation of actual fee paid), as specified in Conditions 5.27.4

thr ough 5.27.8; and

 An annual emissions report of actual emissions, as specified in Condition 5.27.6, for the preceding calendar year.

5.27.2 The fee payment shall be in United States currency and shall be paid by money order, bank draft, certified check, corporate check, or electronic funds transfer payable to the order of the U.S. Environmental Protection Agency.

5.27.3 The permittee shall send fee payment and a completed fee filing form to either of the

addresses listed below.

If sent by Regular Mail through U.S. Postal Service (USPS)

, send to:

U.S. Environmental Protection Agency FOIA and Miscellaneous Payments

Cincinnati Finance Center

PO Box 979078 St. Louis, MO 63197

- 9000

If sent by Express Delivery (or when a physical address is required)

, send to:

U.S. Bank

Government Lockbox 979078 US EPA FOIA & Misc. Payments

1005 Convention Plaza

Mail Station SL

- MO

- C2GL St. Louis, MO 63101

Contact: Natalie Pearson (314

- 418

- 4087)

5.27.4 The permittee shall send an updated fee calculation worksheet form and a photocopy of

each fee payment check (or other confirmation of actual fee paid), submitted annually by the date specified in Condition 5.27.1, to:

Chief

Air Permits Section Air, Pesticides and Toxics Management Division U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303

5.27.5 The annual emissions fee shall be calculated by multiplying the total tons of actual emissions of all “regulated pollutants (for fee calculation),” emitted from the source by the presumptive emission fee (in dollars/ton) in effect at the time of cal culation. The presumptive emission fee is revised each calendar year and is available from the EPA prior to the start of each calendar year.19

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5.27.5.1 “Actual emissions” means the actual rate of emissions in tons per year (TPY) of any “regulated pollutant (for fee calculation),” as defined in 40 CFR § 71.2, emitted from a part 71 source over the preceding calendar year. Actual emissions shall be calculated using each emissions unit’s actual operating hours, production rates, in

- place control equipment, and types of materials processed, stored, or combusted during the preceding calendar

year.

5.27.5.1 5.27.5.2 Actual emissions shall be computed using methods required by the permit for determining compliance, such as monitoring or source testing

data.

5.27.5.2 5.27.5.3 If actual emissions cannot be det ermined using the compliance methods in the permit, the permittee shall use other federally recognized procedures.

5.27.5.3 5.27.5.4 The permittee shall exclude the following emissions from the

calculation of fees:

 The amount of actual emissions of each regulated pollutant (for fee calculation) that the source emits in excess of 4,000 tons per year;

 Actual emissions of any regulated pollutant (for fee calculation) already included in the fee calculation; and

 The ins ignificant quantities of actual emissions not required to be listed or calculated in a permit application pursuant to 40 CFR § 71.5(c)(11).

5.27.6 The permittee shall submit an annual emissions report of its actual emissions for the preceding calendar year. The annual emissions report shall be certified by a responsible official and shall be submitted each year to the EPA by the date specified in Con dition 5.27.1. The annual emissions report shall be submitted to the EPA at the address listed in Condition 5.27.3 of this permit.

5.27.7 Fee calculation worksheets shall be certified as to truth, accuracy, and completeness by a responsible official in accordanc e with Condition 5.13 of this permit.

5.27.8 The permittee shall retain in accordance with the provisions of Conditions 5.16.4 and 5.16.5 of this permit, all worksheets and other materials used to determine fee payments. Records shall be retained for five years following the year in which the

emissions data is submitted.

5.27.9 Failure of the permittee to pay fees in a timely manner shall subject the permittee to assessment of penalties and interest.

5.27.10 The permittee, when notified by the EPA of additional amounts due, s hall remit full payment within 30 days of receipt of an invoice from the EPA.

5.27.11 If the permittee thinks believes that an EPA

- assessed fee is in error and wishes to challenge such fee, the permittee shall provide a written explanation of the alleged error

to the EPA along with full payment of the EPA assessed fee.20

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6.1 Drill Site Notification

At least 10 days prior to entering the drill site, the permittee shall notify the EPA in writing

, in accordance with Condition 5.16.7 of this permit, of the following information:

 The location of the proposed drill site, using coordinates in latitude/longitude and Universal Transverse Mercator grid system formats ;

 The proposed date that the drilling vessel will enter the lease block and commence construction or operation and the probable duration of operation at that location;

 The certification of maintenance and no physical changes required by Condition 6. 5 .1. 1 2 (if applicable); and

 Not less than 24 hours prior to commencing construction or operation, of any changes to the information provided by the permittee in Condition 6.1

. [40 CFR §§ 71.6(a) (6)(v), 5 2.21 and 55.8 ]

6.2 Support Vessel Identification

The permittee shall maintain records

, in accordance with Condition 5.16

, of the engine specifications and number of hours operated within 25 miles of the drilling vessel for any support vessel used in place

of the Peyton Candies (offshore support vessel) and/ or the Sybil Graham (crew boat). These records , as well as engine emission factors and calculated mass emissions in tons per year of regulated pollutant,

shall be subm itted a s part of the Annual Compliance Certification in accordance with Condition 5.21.

6.2.1 A ny offshore suppo rt vessel used in place of the Peyton Candies shall meet Condition

6. 20 , and shall be selected to have worst case potential emissions less than thos e of the Peyton Candies

.

6.2.2 Any crew boat used in place of the Sybil Graham shall meet Condition 6. 21 , and shall be selected to have worst case potential emissions less than those of the Sybil Graham

. [40 CFR § 55

. 8 ]

6.3 Source

- wide SO2 Emission Limit s

The permittee shall not combust any diesel fuel with a sulfur content greater than 15 parts per million (ppm) by weight (0.0015%) , as determined by Condition 6. 3 .1, in any diesel fueled emission unit on the Developer, the Discoverer Americas , or any suppor t vessel.

6.3.1 The permittee shall obtain a certification of sulfur content for each shipment of fuel from the fuel supplier (the certification must indicate the sulfur content was determined by an approved EPA method ), o r the permittee shall obtain representa tive fuel samples using one of the methods in 40 CFR § 80.330 and shall determine the sulfur content of the fuel using one of the methods in 40 CFR § 80.580.

6.3.2 Prior to mobilizing the selected drilling vessel for activities covered by this permit, the permittee shall determine and record the sulfur content of the diesel fuel on the drilling

vessel and the support vessels using the procedures in Condition 6. 3 .1.22

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the drilling vessel and the support vessels using procedures in Condition 6. 3 .1 upon receiving each fuel shipment

.

6.3.4 The permitte e shall provide the results of all fuel sample analyses required by

Conditions 6. 3

. 2 and 6. 3

. 3 with the Annual Compliance Certification required by

Condition 5.21.

[40 CFR §§ 52.21, 60.42c(h) subpart Dc, 71.6(a)(3) , 71.6 (c)(1) , and 55.8 ]

6.4 Discoverer Americas Source

- Wide PM 2.5 Emission Limits

6.3.5 6.4.1 The permittee shall not discharge or cause the discharge into the atmosphere 10

TPY or more of total filterable and condensable PM 2.5 emissions from all emission

units on the Developer or the Discoverer Americas

, including any support vessels operating within 25 miles and used in service of the drilling vessel , on a 12

- month rolling basis

.

6.3.6 6.4.2 Compliance with this operating limit shall be demonstrated by calculating total

PM 2.5 emission s in TPY from all emission units using monthly fuel consumption

, as required by Condition s 6. 11 ( Developer )

, 6. 19 ( Discoverer Americas ), 6. 20 .2 (OSVs),

and 6. 21 .2 (crew boats)

, or hours of operation and verifi able equipment

- specific

emissions rates for total filterable and condensable PM 2.5 emissions determined in accordance with compliance demonstration methods set forth in Condition 6.22, or by using the most accurate equipment specific emission rate that may be obtained from among those included in the application , vendor data, or manufac turer emissions certification, if actual emissions rates are not available. The permittee shall calculate

total PM 2.5 emissions for the previous 12

- month period on a 12

- month rolling basis within 15 days following the end of each calendar month.

6.3.7 6.4.3 The perm ittee shall submit a written report in compliance with Condition 5.17.1 including the results of the PM 2.5 limit calculations performed in accordance with

Condition 6.4.2 for each 12

- month period completed in the report.

[40 CFR §§ 52.21 and 71.6(a)(1), ( a)(3) and (c)(1)]

6.5 General Stack Test Requirements

6.3.8 6.5.1 Within 90 days of the start of the first campaign that the subject drilling vessel operates under this permit, the eight main engines (GEN

- 1 through GEN

- 8) of the Developer or the six main engines of the Discoverer Americas (GEN

- 1 through GEN

6) shall have been stack tested under the requirements of this section Condition 6.5 and Condition 5.26 within the previous 12 month period.

6.3.8.1 6.5.1.1 If, after the initial stack tests, the drilling vessel discontinues

drillin g under the permit for more than 12 months, the permittee shall certify that a continuous maintenance program has been conducted and that no physical changes that could impact emissions have occurred since the latest stack test, or the permittee shall cond uct a new stack test prior to restarting drilling operations in accordance with the general stack testing requirements set forth in Condition 5.26 and Conditions 6.5.2 through 6.5.6.23

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6.3.8.2 6.5.1.2 If a continuous maintenance program is selected from the options

in Con dition 6.5.1.1, the certification shall be included with the drill site notification required pursuant to Condition 6.1. Maintenance records shall be kept in accordance with the recordkeeping requirements set forth in

Condition 5.16

6.3.9 6.5.2 Each stack test shall be conducted by using stack testing data collected according to an EPA approved source test plan set forth in Condition 5.26.

6.3.10 6.5.3 Each stack test shall be conducted at three different loads spanning the expected range of operations.

6.3.11 6.5.4 At a minimum, each stack test run shall test for emissions of CO, NO X , PM 2.5 , PM 10 , VOC, and visible emissions at a reference O 2 or CO 2 concentration

.

6.3.12 6.5.5 During each test run, the permittee shall monitor and record the following

information:

 Density of the fuel used (in lbs/gallon);

 Heat content of the fuel used (in Btu/gallon); and

 Electrical power produced (in kW

- hr).

6.3.13 6.5.6 For each engine, each load, and each pollutant (CO, CO 2 , NO X , PM, PM 2.5 , PM 10 , VOC) , the permittee shall determine emission rates in g/kW

- hr. Pollutan t test data obtained in accordance with Condition 6.5 or fuel usage monitoring data may be used

to calculate CO 2 and PM.

[40 CFR §§ 52.21 and 71.6(a)(1), (a)(3) and (c)(1)]

6.6 Developer Main Generator Engines (GEN

- 1 through GEN

- 8) NOX Emission and Operating

Limits

6.4

6.6.1 The permittee shall not discharge or cause the discharge of emissions into the

atmosphere in excess of the following from each of the main generator engines on a rolling 24

- hour average basis:

6.6.1.1 NO X BACT Emission Limit: The permittee shall not disc harge or cause the discharge of emissions into the atmosphere in e xcess of 8. 6 12.0 g/kW

- hr for each of the main generator engines on a rolling 24

- hour average basis

.

6.6.1.2 VOC BACT Emission Limit:

6.6.1.2.1 2.15 g/kW

- hr for engine loads < 55%, or

6.6.1.2.2 1.73 g/kW

- hr for engines loads ≥ 55%.24

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6.6.1.3 PM 10 BACT Emission Limit:

6.6.1.3.1 0.50 g/kW

- hr for engine loads < 55%; or

6.6.1.3.2 0.26 g/kW

- hr for engines loads ≥ 55%.

6.6.1.4 PM 2.5 BACT Emission Limit:

6.6.1.4.1 0.49 g/kW

- hr for engine loads < 55%; or

6.6.1.4.2 0.26 g/kW

- hr for engines loads ≥ 55%.

6.4.1

6.6.2 The permittee shall not discharge or cause the discharge of emissions into the

atmosphere in excess of the following from the eight main generator engines combined on a rolling 12

- month total basis.

6.6.2.1 NO X BACT Emission Limit: 416.15 TPY.

6.6.2.2 VOC BACT Emission Limit: 66.12 TPY.

6.6.2.3 PM 10 BACT Emission Limit: 12.81 TPY.

6.6.2.4 PM 2.5 BACT Emission Limit: 12.43 TPY.

6.4.2 6.6.3 The permittee shall use the following NO X BACT W w ork P p ractice S s tandards:

6.4.2.1 6.6.3.1 The permittee shall use m M ain generator engines with l ow NO X

e ngine tuning design

, includin g turbocharger, after cool er, open crankcase ventilation system, and high injection pressure fuel system ;

.

6.6.3.2 The permittee shall use g G ood combustion practices based on the most

recent manufacturer’s current s pecifications for these engines issued at the time that the engines are operating under this permit ;

.

6.6.3.3 Diesel fuel with sulfur content less than or equal to 15 ppm by weight

ultra

- low sulfur diesel;

6.4.2.2 6.6.3.4 Engines certified to 40 CFR part 94 Tier 1 or better emissions standards; and

6.4.2.3 6.6.3.5 The permittee shall use a A dditional enhanced work practice

standards as detailed in Section 5.3.1.16 of the September 2012 application ( provided in the administrative record ) . These practices shall includ ing e
, but are not limited to, specialized personnel trai ning, having an equipment maintenance specialist available at all times during drilling activities, conducting weekly engine inspections, adhering to manufacturer

recommended maintenance schedules, and providing access to engine

specific maintenance manuals.25

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- M1 6.4.3 6.6.4 Monitoring and Recordkeeping Compliance Demonstration Method : The permittee shall monitor NO X , VOC, PM 10 , and PM 2.5 emissions at a determined

reference O 2 or CO 2 concentration by the use of an EPA

- approved continuous emissions monitoring system, an EPA

- approved parametric monitoring method, or
, with prior written approval by the EPA, a n EPA approved stack testing emissions monitoring method

, or
, a n alternative parametric monitor ing method

, pursuant to
Condition 6. 22

.

6.4.4 6.6.5 Reporting: Monitoring and recordkeeping shall be conducted in accordance with

Condition 6. 22

. All information required to be collected, recorded, or maintained pursuant to Conditions 6.6 and 6.22 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Conditions 5.17.

[40 CFR §§ 52.21

, 71.6(a)(1), 71.6 (a)(3)

, and 71.6 (c)(1)]

6.5 6.7 Developer Emergency Generator Engine (EGEN) NOX Standards & Limits

6.5.1 6.7.1 The permittee shall use the following NO X BACT Work Practice Standards:

6.5.1.1 6.7.1.1 The permittee shall use a A n emergency generator engine with low

NO X engine design, including turbocharger, aftercooler, open crankcase ventilation system, and electronic fuel injection ;

.

6.5.1.2 6.7.1.2 The permittee shall use g G ood combustion practices based on the

most recent manufacturer’s current specifications for th is engine issued at the time that the engine is operating under this permit

. ;

6.7.1.3 Diesel fuel with sulfur content less than or equal to 15 ppm by weight ultra

low sulfur diesel;

6.7.1.4 Engines certified to 40 CFR part 89 Tier 1 or better emission standards; and

6.5.1.3 6.7.1.5 The permittee shall use a A dditional enhanced work practice

standards as detailed in Section 5.3.1.16 of the September 2012 application (provided in the administrative record). These practices shall includ ing e
, but are not limited to, specialized personnel training, having an equipment maintenance specialist available at all times during drilling activities, conducting weekly engine inspections, adhering to manufacturer

recommended maintenance schedules, and providing access to engine

specific maintenance manuals.

6.7.2 Operating Limit: This engine shall be operated no more than 3 9 hours per year of non

emergency, planned operation time on a rolling 12

- month average basis

.

6.7.3 Monitoring, Recordkeeping, and Reporting:

6.7.3.1 The permittee shall maintain a record of hours of operation and sum such hours on a rolling 12

- month basis in accorda nce with Condition 6.23.26

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6.7.3.2 All information required to be collected, recorded, or maintained pursuant to Conditions 6.7 and 6.23 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.5.2

6.5.2.1 Compliance Demonstration Method: Compliance with the operating limit

set forth in Condition 6.7.2 will be assured by maintaining a record of to tal monthly operating hours , identifying and describing any periods of

emergency use.

6.5.2.2 Monitoring and recordkeeping shall be conducted in accordance with

Condition 6. 23

. [40 CFR §§ 52.21, 71.6(a)(1), 71.6(a)(3), and 71.6(c)(1)]

6.6 6.8 Developer Cementing Unit Engines (CMU

- 1 and CMU

- 2) NOX Standards & Limits

6.6.1 6.8.1 The permittee shall use the NO X BACT W w ork P p ractice S s tandards:

6.6.1.1 6.8.1.1 The permittee shall use c C ementing unit engine s with low NO X engine design, including turbocharger, aftercooler, open crankcase ventilation system, and electronic fuel injection ;

.

6.8.1.2 The permittee shall use g G ood combustion practices based on the most

recent manufacturer’s current specifications issued for th ese engine s at the time that the engines are operating under this permit

. ;

6.8.1.3 Diesel fuel with sulfur content less than or equal to 15 ppm by weight ultra

low sulfur diesel;

6.6.1.2 6.8.1.4 Engines certified to 40 CFR part 94 Tier 2 or better emissions standards; and

6.6.1.3 6.8.1.5 The permittee shall use a A dditional enhanced work practice

standards as detailed in Section 5.3.1.16 of the September 2012 application (provided in the administrative record). These practices shall includ ing e
, but are not limited to, specialized personnel training, having an equipment maintenance specialist available at all times during drilling activities, conducting weekly engine inspections, adhering to manufacturer

recommended maintenance schedules, and providing access to engine

specific maintenance manuals.

6.8.2 Operating Limit: These engine s shall be operated no more than a combined total of 300 hours per year on a rolling 12

- month average basis

.

6.6.2 6.8.3 Monitor ing, Recordkeeping , and Reporting :

6.8.3.1 The permittee shall maintain a record of hours of operation and sum such hours on a rolling 12

- month basis in accordance with Condition 6.23.27

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6.6.2.1 Compliance Demonstration Method: Compliance with the operating limit

set forth in Condition 6.8. 2 will be assured by maintaining a record of monthly hours of operation.

6.6.2.2 Monitoring and recordkeeping sh a ll be conducted in accordance with

Condition 6. 23

. 6.8.3.2 All information required to be collected, recorded, or maintained pursuant to Conditions 6.8 and 6.23 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17. [40 CFR §§ 52. 21, 71.6(a)(1), 71.6(a)(3), and 71.6(c)(1)]

6.7 6.9 Developer Life Boat Engines (LB

- 1 through L B

- 4) NOX and Fast Rescue Boat Engine (MOB) Standards and Operating Limits

6.7.1 6.9.1 Operating Limit: These engine s shall be operated no more than 12 hours for each unit per year of non

- emergency, planned operation time on a rolling 12

- month total

basis.

6.9.2 The permittee shall use good combustion practices based on the most recent manufacturer’s specifications issued for these engines at the time that the engines are operating under this permit.

6.9.3 Monitoring, Recordkeeping, and Reporting:

6.9.3.1 The permittee shall maintain a record of hours of operation and sum such hours on a rolling 12

- month basis in accordance with Condition 6.23.

6.9.3.2 All information required to be collected, recorded, or maintained pursuant to Condition 6.9 and 6.23 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.7.2 Compliance Demonstration Method: Compliance with this operating limit will be assured by maintaining a record of total monthly operating hours

, identifying and describing any periods of emergency use.

6.7.3 Monitoring and recordkeeping shall be conducted in accordance with Condition 6. 23

. [40 CFR §§ 52.21 and 71.6(a)(1), (a)(3) and (c)(1)]

6.8 6.10 Developer Fast Rescue Boat Engine (MOB) NOX Non

- engine Related Standards

and Operating Limits

6.10.1 Source Identification: Cement and Barite Transfer Activities (CEMENT

- BARITE)

6.10.1.1 As a BACT work practice standard, the permittee shall use proper maintenance and operation of the enclosed pneumatic conveyance dust

collector system based on t he most recent manufacturer’s specifications for the system issued at the time that project activities are conducted under this permit.

6.10.1.2 The permittee shall vent all system exhaust under the ocean surface.28

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6.10.1.3 The permittee shall perform a daily visual check of the dust collector system and maintain a record of daily inspections and system maintenance.

6.10.2 Source Identification: Welding Activities (WELD)

6.10.2.1 As a BACT work practice standard, the permittee shall use best management practices including, but not limite d to, following the most recent manufacturer’s specifications for all equipment used in welding operations issued at the time that project activiti es are conducted under this permit

.

6.10.2.2 The permittee shall maintain an accurate record of the types and quantity (in pounds) of welding rods used on a rolling 12

- month basis for the purpose of calculating actual emissions pursuant to Condition 5.21.

6.10.3 Source Identification: Painting Activities (PAINT)

6.10.3.1 As BACT work practice standards, the permittee shall use b est management practices that include, but are not limited to, the following :

6.10.3.1.1 Limit the amount of painting that is performed on the vessel;

6.10.3.1.2 Use of paint rollers instead of sprayers where practical;

6.10.3.1.3 Use of high volume, low pressure paint sprayers with a

minimum transfer efficiency of 65%, operated within the manufacturer’s recommended pressure range, and following the most recent manufacturer’s specifications issued at the time that coating operations are conducted under this permit;

6.10.3.1.4 Down spraying of pai nt where possible;

6.10.3.1.5 Use of a containment system such as a shroud or a barrier

around the section of the drillship being painted whenever practical to reduce airborne particulate matter;

6.10.3.1.6 Proper storage of coatings and thinners in appropriately labeled,

non

- leaking containers; and

6.10.3.1.7 The permittee shall maintain and record the types and amounts

(in gallons) of coatings and thinners used on a weekly basis.

6.10.3.1.8 Maintenance of MSDS information for all paints and thinners

used while conducting painting activities u nder this permit.29

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6.10.3.2 The permittee shall record the following:

6.10.3.2.1 Types and quantity (in gallons) of all paints and thinne rs used

on a rolling 12

- month basis;

6.10.3.2.2 Method of application (sprayed or rolled); and

6.10.3.2.3 Location where painting activity occurs (inside or outside).

6.10.4 Source Identification: Mud Degassing (MUD)

6.10.4.1 As a BACT work practice standard, the permittee shall use proper maintenance and operation of the mud degassing operations units in accordance with the most recent manufacturer’s specifications for all equipment used in mud handling operations issued at the time that project activities are conducted under this permit.

6.10.4.2 The permittee shall monitor and record the type of mud used and throughput for each type on a rolling 12

- month basis.

6.10.5 Source Identific ation: Fugitive Emissions (FUG)

6.10.5.1 As a BACT work practice standard, the permittee shall use good maintenance practices to minimize fugitive emissions from valves, pump seals, and flanges, including a daily visual inspection and prompt repair of leaking comp onents.

6.10.5.2 The permittee shall visually inspect components daily and maintain the following information:

 Date of inspection;

 Type of component;

 Method of leak detection used;

 Date and duration of any leak detected from critical components;

 Corrective action taken;

 Date of corrective action;

 Date of component re

- inspection;

 Name of person inspecting equipment (printed); and

 Signature of person inspecting equipment.

6.10.6 Source Identification: Storage Tank Emissions (FO CMV ST, FO MOB ST, FO SER ST 1 and 2, FO SET ST 3 and 4, FO ST 1 through 4, FO LB ST 1 through 4, FO EGEN ST, AV ST 1 through 3, WO ST 1 and 2)30

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6.10.6.1 As a BACT work practice standard, the permittee shall use good maintenance practices in accordance with the most recent manufacturer’s specifications for all storage tanks on the drilling vessel at the time that project activities are conducted under this permit

.

6.10.6.2 Th e permittee shall use a submerged fill system for tanks FO ST 1 through

4 and FO SER ST 1 and 2

.

6.10.6.3 The permittee shall use EPA’s TANKS 4.0.9d program to calculate emissions for annual reporting.

6.10.6.4 The permittee shall maintain the following information:

 Storage tank ID;

 Tank dimensions;

 Fuel type stored; and

 Capacity of each storage tank.

6.8.1 Operating Limit: This engine shall be operated no more than 12 hours per year of non

emergency, planned operation time on a rolling 12

- month total basis.

6.8.2 Compliance Demonstration Method: Compliance with this operating limit will be assured by maintaining a record of total monthly operating hours , identifying and describing any periods of emergency use.

6.8.3 Monitoring and recordkeeping shall be conducted in accordance with Condition 6. 23

. [40 CFR §§ 52.21 and 71.6(a)(1), (a)(3) and (c)(1)]

6.9 6.11 Developer Fuel Consumption Limits

6.9.1 6.11.1 The drill rig is limited to an annual consumption of 2, 65 4 459

, 931 150 gallons of diesel fuel on a rolling 12

- month total basis.

6.9.1.1 6.11.2 In the event that Developer and Discoverer Americas are operated sequentially during any rolling 12

- month basis, the emission fuel consumption limits in

Conditions 6.11.1 and 6.19.1 shall be prorated based on daily vessel usage. The permittee shall not operate Developer and Discoverer Americas concurrently with in the lease blocks specified in section 3 of this permit.

6.9.2 6.11.3 Compliance with this operating limit will be demonstrated by calculating and maintaining a record of monthly fuel consumption based on information obtained pursuant to Condition 6. 1 1

. 4 3 for the duration of the drilling campaign to obtain the

annual fuel us age.

6.9.3 6.11.4 The permittee shall monitor and maintain a contemporaneous record of the following information:

 N umber of barrels/gallons of diesel fuel on the rig at the start of drilling operations ;

 Date of each diesel fuel delivery;

 Number of barrels/gallons of diesel fuel in each delivery;31

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 Name of person recording delivery (printed);

 Signature of recorder; and

 N umber of barrels/gallons of diesel fuel on the rig at the end of each month.

[40 CFR §§ 52.21 and 71.6(a)(1), (a)(3) and (c)(1)]

6.12 Discoverer Americas Main Generator Engines (GEN

- 1 through GEN

- 6) NO X Emission

Limits

6.10

6.10.1 6.12.1 NO X BACT Emission Limit: The permittee shall not discharge or cause the

discharge of emissions into the atmosphere in excess of 12. 7 g/kW

- hr for each of the main generator engines on a roll ing 24

- hour average basis.

6.10.2 6.12.2 NO X BACT Work Practice Standards:

6.10.2.1 6.12.2.1 The permittee shall use main generator engines with low NO X engine design, including turbocharger, aftercooler, and high injection

pressure.

6.10.2.2 6.12.2.2 The permittee shall use good combustion practices based on the manufacturer’s current specifications for these engines.

6.10.2.3 6.12.2.3 The permittee shall use additional enhanced work practice standards as detailed in Section 5.3.1.16 of the September 2012 application (provided in the administrative record)

. These pr actices shall include, but are not limited to, specialized personnel training, having an equipment maintenance specialist available at all times during drilling activities, conducting weekly engine inspections, adhering to m anufacturer

recommended maintena nce schedules, and providing access to engine

specific maintenance manuals.

6.10.2.4 6.12.2.4 The permittee shall use an engine performance management and monitoring system that employs parametric or continuous emissions monitoring, such as described in Condition 6.22, to establish indicator ranges for mainten ance evaluation and repair

.

6.10.3 6.12.3 Compliance Demonstration Method: The permittee shall monitor NO X emissions by the use of an EPA

- approved continuous emissions monitoring system, an EPA

approved parametric monitoring method

, or, with prior written approval by the EPA, an EPA approved stack testing emissions monitoring method, or, an alternative parametric monitoring method

, pursuant to Condition 6. 22

.

6.10.4 6.12.4 Monitoring and recordkeeping shall be conducted in accordance with Condit ion

6. 22

. [40 CFR §§ 52.21, 71.6(a)(1), 71.6(a)(3), and 71.6(c)(1)]

6.13 Discoverer Americas Emergency Generator Engine (EGEN) NO X Standard s & Limits

6.11

6.11.1 6.13.1 NO X BACT Work Practice Standards:32

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6.11.1.1 6.13.1.1 The permittee shall use an emergency generator engine with low

NO X engine design, including turbocharger, aftercooler, and high injection

pressure

.

6.11.1.2 6.13.1.2 The permittee shall use good combustion practices based on the manufacturer’s current specifications for this engine.

6.11.1.3 6.13.1.3 The permittee shall use additional enhanced work pract ice standards as detailed in Section 5.3.1.16 of the September 2012 application (provided in the administrative record). These practices shall include, but are not limited to, specialized personnel training, having an equipment maintenance specialist avail able at all times during drilling activities, conducting weekly engine inspections, adhering to manufacturer

recommended maintenance schedu les, and providing access to engine

specific maintenance manuals.

6.11.2 6.13.2 Operating Limit: This engine shall be operated no more than 41 hours per year of

non

- emergency, planned operation time on a rolling 12

- month average basis

.

6.11.2.1 6.13.2.1 Compliance Demonstration Method: Compliance with the operating limit set forth in Condition 6. 1 3

. 2 will be assured by maintaining

a record of total monthly operating hours, identifying and describing any periods of emergency use.

6.11.2.2 6.13.2.2 Monitoring and recordkeeping shall be conducted in accordance

with Condition 6. 23

.

[40 CFR §§ 52.21, 71.6(a)(1), 71.6(a)(3), and 71.6(c)(1)]

6.12 6.14 Discoverer Americas Forklift Eng ines (FORK

- 1 and FORK

- 2) NO X Standards &

Limits

6.12.1 6.14.1 NO X BACT Work Practice Standards:

6.12.1.1 6.14.1.1 The permittee shall use forklift engines with EPA rated interim

Tier 4 or better engine s

.

6.12.1.2 6.14.1.2 The permittee shall use good combustion practices based on the

manufacturer’s current specifications for these engines.

6.12.1.3 6.14.1.3 The permittee shall use additional enhanced work practice standards as detailed in Section 5.3.1.16 of the September 2012 application (provided in the administrative record). These practices shall include, but

are not limited to, specialized personnel training, having an equipment maintenance specialist available at all times during drilling acti vities, conducting weekly engine inspections, adhering to manufacturer

recommended maintenance schedules, and providing a ccess to engine

specific maintenance manuals.33

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- M1 6.12.2 6.14.2 Operating Limit: These engine s shall be operated no more than 237 hours per year for each engine on a rolling 12

- month average basis

.

6.12.2.1 6.14.2.1 Compliance Demonstration Method: Compliance with the operating limit set forth in Condition 6. 1 4

. 2 will be assured by maintaining

a record of total monthly operating hours

.

6.12.2.2 6.14.2.2 Monitoring and recordkeeping shall be conducted in accordance

with Condition 6. 23

.

[40 CFR §§ 52.21, 71.6(a)(1), 71.6(a)(3), and 71.6(c)(1)]

6.13 6.15 Discoverer Americas Emergency Air Compressor Engines (ACOMP

- 1 and

ACOMP

- 2) NO X Standards & Limits

6.13.1 6.15.1 NO X BACT Emission Limit: The permittee shall not discharge or cause the discharge of emissions into the atmosphere in excess of a combined 0.01 tons of NO X
per year on a rolling 12

- month total basis.

6.13.2 6.15.2 NO X BACT Work Practice Standards:

6.13.2.1 6.15.2.1 The permittee shall use emergency air compressor engines with

low NO X engine design, including turbocharger and aftercooler.

6.13.2.2 6.15.2.2 The permittee shall use good combustion practices based on the manufacturer’s current specifications for these engines.

6.13.2.3 6.15.2.3 The permittee shall use additional enhanced work practice standards as detailed in Section 5.3.1.16 of the September 2012 application (provided in the administrative record). These practices sha ll include, but are not limited to, specialized personnel training, having an equipment maintenance specialist available at all times durin g drilling activities, conducting weekly engine inspections, adhering to manufacturer

recommended maintenance schedul es, and providing access to engine

specific maintenance manuals.

6.13.3 6.15.3 Operating Limit: These engine s shall be operated no more than 3 hours per year for each engine of non

- emergency, planned operation time on a rolling 12

- month average basis

.

6.13.3.1 6.15.3.1 Compliance Demonstration Method: Compliance with the operating limit set forth in Condition 6.1 5 .3 will be assured by maintaining

a record of total monthly operating hours, identifying and describing any periods of emergency use.

6.13.3.2 6.15.3.2 Monitoring and recordkeeping shall b e conducted in accordance

with Condition 6. 23

.

[40 CFR §§ 52.21, 71.6(a)(1), 71.6(a)(3), and 71.6(c)(1)]

6.14 6.16 Discoverer Americas Cargo Hold Heater (HTR) Standards & Limits34

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6.14.1.1 6.16.1.1 The permittee shall use good combustion practices based on the manufacturer’s current specifications for this unit

.

6.14.1.2 6.16.1.2 The permittee shall use additional enhanced work practice standards as detailed in Section 5.3.1.16 of the September 2012 application (prov ided in the administrative record). These practices shall include, but are not limited to, specialized personnel training, having an equipment maintenance specialist available at all times during drilling activities, conducting weekly inspections, adhering to manufacturer

- recommended maintenance schedules, and providing access to a unit

- specific maintenance

manual.

6.14.2 6.16.2 Operating Limit: Th is unit shall be operated no more than 2 hours per year on a rolling 12

- month average basis

.

6.16.2.1 Compliance Demonstration Meth od: Compliance with the operating limit

set forth in Condition 6.1 6

. 2 will be assured by maintaining a record of total monthly operating hours

. 6.14.2.1

6.14.2.2 6.16.2.2 Monitoring and recordkeeping shall be conducted in accordance

with Condition 6.23.

[40 CFR §§ 52.21 and 71.6(a)(1), 71.6(a)(3) and 71.6(c)(1)]

6.15 6.17 Discoverer Americas Life Boat Engines (LB

- 1 through LB

- 6 ) NO X Operating Limits

6.15.1 6.17.1 Operating Limit: These engine s shall be operated no more than 12 hours for each unit per year of non

- emergency, planned operation time on a rolling 12

- month total

basis.

6.15.2 6.17.2 Compliance Demonstration Method: Compliance with this operating limit will be assured by maintaining a record of total monthly operating hours, identifying and describing any periods of emergency use.

6.15.3 6.17.3 Monitoring and recor dkeeping shall be conducted in accordance with Condition

6.23.

[40 CFR §§ 52.21 and 71.6(a)(1), 71.6 (a)(3) and 71.6 (c)(1)]

6.16 6.18 Discoverer Americas Fast Rescue Boat Engine (MOB) NO X Operating Limits

6.16.1 6.18.1 Operating Limit: This engine shall be operated no more than 12 hours per year of

non

- emergency, planned operation time on a rolling 12

- month total basis.

6.16.2 6.18.2 Compliance Demonstration Method: Compliance with this operating limit will be assured by maintaining a record of total monthly op erating hours, identifying and

d escribing any periods of emergency use.35

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- M1 6.16.3 6.18.3 Monitoring and recordkeeping shall be conducted in accordance with Condition

6. 23

. [40 CFR §§ 52.21 and 71.6(a)(1), (a)(3) and (c)(1)]

6.17 6.19 Discoverer Americas Fuel Consumption Limits

6.17.1 6.19.1 The drill rig is limited to an annual consumption of 2,1 79

, 98 3 gallons of diesel fuel on a rolling 12

- month total basis.

6.17.2 6.19.2 Compliance with this operating limit will be demonstrated by calculating and maintaining a record of monthly fuel consumption based on information obtained pursuant to Condition 6. 1 9 .3 for the duration of the drilling campaign to obtain the annual fuel usage.

6.17.2.1 6.19.2.1 In the event that Developer and Discoverer Americas are operated sequentially during any rolling 12

- month basis, the emission limits in 6.11.1 and 6.19.1 shall be prorated based on daily vessel usage. The permittee shall not operate Developer and Discoverer Americas concurrently within the lease blocks sp ecified in section 3 of this permit.

6.17.3 6.19.3 The permittee shall monitor and maintain a contemporaneous record of the following information:

 Number of barrels/gallons of diesel fuel on the rig at the start of drilling operations;

 Date of each diesel fuel delive ry;

 Number of barrels/gallons of diesel fuel in each delivery;

 Name of person recording delivery (printed);

 Signature of recorder; and

 Number of barrels/gallons of diesel fuel on the rig at the end of each month.

[40 CFR §§ 52.21 and 71.6(a)(1), (a)(3) and (c)(1)]

6.20 Offshore Support Vessels Operating Limits

6.18

6.18.1 6.20.1 Offshore support vessel s like the Peyton Candies or any substitute OSV shall not

exceed a total of 2

, 570 hours per year on a rolling 12

- month total basis when within 25

mile s of the drilling vessel

.

6.18.2 6.20.2 Offshore support vessels like the Peyton Candies or any substitute OSV shall not

exceed a total of 621

, 468 gallons of diesel fuel per year on a rolling 12

- month total basis when within 25 miles of the drilling vessel.

6.18.3 6.20.3 Offshore support vessels like the Pey ton Candies or any substitute OSV shall not combust any diesel fuel with sulfur content greater than 0.0 01 5 percent by weight.

6.18.4 6.20.4 Compliance with this operating limit will be demonstrated through the monitoring

and recordkeeping conditions as set forth in Condition 6. 24

.36

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, 71.6(a)(1), 71.6 (a)(3)

, and 71.6 (c)(1)]

6.21 Crew Boats Operating Limits

6.19

6.19.1 6.21.1 Crew boats like the Sybil Graham or any substitute crew boat shall not exceed a

total of 618 hours per year on a rolling 12

- month total basis when within 25 miles of the drilling vessel.

6.19.2 6.21.2 Crew boats like the Sybil Graham or any substitute crew boat shall not exceed a

total of 235

, 176 gallons of diesel fuel per year on a rolling 12

- month total basis when within 25 miles of the drilling vessel.

6.19.3 6.21.3 Crew boats like the Sybil Graham or any substitute crew boat shall not combust any diesel fuel with sulfur content greater than 0.0 015 percent by weight.

6.19.4 6.21.4 Compliance with this operating limit will be demonstrated through the monitoring

and recordk eeping conditions as set forth in Conditi on 6. 24

.

[40 CFR §§ 52.21, 55.2, 55.6(a)(4), 71.6(a)(1), 71.6(a)(3), and 71.6(c)(1)]

6.20 6.22 Compliance Monitoring and Recordkeepin g Requirements for Main Generator Engines

In accordance with Condition 5.16 , the permittee shall monitor and record NO X , CO 2 , CO, VOC

, and

PM/PM 10 /PM 2.5 emissions (at a determined reference O 2 concentration) from the main generator diesel engines (GEN

- 1 through GEN

- 8 on the Developer and GEN

- 1 through GEN

- 6 on the Discoverer

Americas ) by the us e of an EPA

- approved parametric monitoring method as described in Condition

6. 22 .1 , or an EPA

- approved continuous emissions monitoring system described in Condition 6. 22 .2, or, with prior written approval by the EPA, a stack testing emissions monitoring sy stem as described in

Condition 6. 22 .3 , or a combination of these methods , as necessary for different pollutants or engines.

6.20.1 6.22.1 Parametric Monitoring (Compliance Monitoring Option #1)

6.20.1.1 6.22.1.1 The permittee shall properly monitor and record emissions of one

of more of the subject regulated air pollutan ts ( NO X , CO 2 , CO, VOC, and

PM/PM 10 /PM 2.5 ) from the main generator diesel engine s specified in

Condition 6. 22 by using a parametric monitoring system such as the Transocean Diesel Engines with Turbochargers (DEWT) monitoring system or its equivalent upon prior written approval by EPA.

6.20.1.2 6.22.1.2 The permittee shall monitor and record the following parameters once every 30 seconds for 30 minutes twice a day:

 Charge Air Pressure (k P a) after air cooler;

 Charge Air Temperature ( Celsius) after air cooler;

 Turbocharger RPM A&B (RPM);

 Engine Air Inlet Pressure ( kPa );

 Engine Air Inlet Temperature (Celsius);

 Engine Air Inlet Relative Humidity ( % );

 Generator Load (kW); and37

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- M1  Regulated pollutant Emission Concentration s (ppm) and O 2 or CO 2 concentration (%)

6.22.1.3 The permittee shall record the date and time of the most recent NOx NO X analyzer calibration method used to calibrate and the results.

6.20.1.3

6.20.1.4 6.22.1.4 permittee shall determine the average emission rate of the monitored air pollutant (g/kW

- hr) for each engine from the emission rate results in each rolling 24

- hour period , and total annual emissions in TPY on

a 12

- month rolling basis

.

6.20.2 6.22.2 Continuous Emissions Monitoring (Compliance Monitoring Option #2)

6.20.2.1 6.22.2.1 The permittee shall install, calibrate, maintain, and operate a continuous emissions monitoring system with a plan approved by the EPA

to monitor and record emissions from the main generator engines specified

in Condition 6 .22

.

6.20.2.2 6.22.2.2 The permittee shall obtain stack gas volumetric flow rat es using a

calibrated flow monitor that records data on a continuous basis.

6.20.2.3 6.22.2.3 The permittee shall monitor and record engine electric power output in kW

- hr.

6.20.2.4 6.22.2.4 The quality assurance plan used by the permittee for the certification and operation of the continuous emissions monitoring system

shall be made available to the EPA upon request.

6.20.2.5 6.22.2.5 The permittee shall determine the average emission rate in g/kW

hr for each engine from the hourly emission rate results in each rolling 24

- hour period , and total annual emissions in TPY on a 12

- month rolling basis.

6.20.3 6.22.3 Stack Testing Emissions Monitoring (Compliance Monitoring Option #3)

6.22.3.1 The permittee shall properly monitor and record emissions from diesel engines specified in Condition 6.2 2 by collecting stack testing data within the previous 12 months according to an EPA approved protocol and in

accordance with Conditions 5.26 and 6.2 2

. 3 .2 through 6.2 2 .3. 7

. Data collected prior to issuance of this permit may be used with EPA approval. After three annual/periodic stack tests of the same drilling vessel, stack test frequency may be reduced upon written approval by the EPA.

6.20.3.1

6.20.3.2 6.22.3.2 Each stack test shall be conducted at three different loads spanning the expected range of operations.

6.20.3.3 6.22.3.3 During each test run, the permittee shall monitor and record the following information:38

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- M1  Density of the fuel used in lbs/gallon ;

 Heat content of the f

uel used in Btu/gallon ; and

 Electrical power produc ed in kW

- hr

.

6.20.3.4 6.22.3.4 The permittee shall prepare a graph of engine load versus emission rates expressed in g/kW

- hr for each engine. Plot the engine load as the independent (or x) variable and the pollutant emis sion rates as the dependent (or y) variable for each load point tested. Construct the graph by drawing s traight

- line segments between each load point. Draw a horizontal line to the y

- axis from the minimum load point tested.

6.20.3.5 6.22.3.5 The permittee shall u se the loa d information with the graph of engine load versus emission rates to de termine the emission rate in g/kW

- hr for each engine load recorded. Linear interpolation shall be used to

determine the emission rate when the actual load falls between two tested

load points

. When the engine load exceeds the maximum load measured during the stack testing, the g/kW

- hr emission rate obtained for the highest load point tested during the most recent stack test may be used

. When records of engine load are not available, the highest g/kW

- hr emission rate calculated for all the load points tested during the most recent stack test may be substituted. T he average emission rate for each hour of operation from all individual emission rate results recorded during the hour will then

be calculated

.

6.20.3.6 6.22.3.6 The permittee shall determine t he average emission rate in g/kW

hr for each engine from the hourly emission rate results in each rolling 24

- hour period and total annual emissions in TPY on a 12

- month rolling basis.

[40 CFR §§ 52.21, and 71.6(a)(1), (a)(3) and (c)(1)]

6.21 6.23 Compliance Monitoring and Recordkeeping Req uirements for Emergency

Generators

, Small (<500 hp) Engines , and Cargo Hold Heater

Pursuant to Conditions 6. 7 through 6.10 and 6.1 3 through 6. 1 8 and in accordance with Condition

5.16 , the permittee shall monitor and maintain a contemporaneous record of the mont h ly hours of operation of the emergency generator engine s ( EGEN on both the drill rig Developer and the drillship Discoverer Americas ) , the cargo hold heater on the Discoverer Americas

, and the small

on

- board diesel engines ( CMU

- 1 and CMU

- 2, LB

- 1 through LB

- 4, and MOB on the Developer

and FORK

- 1 and FORK

- 2, ACOMP

- 1 and ACOMP

- 2, LB

- 1 through LB

- 6 and MOB on the

Discoverer Americas ) . Hours of operation shall be recorded monthly determined from a non

resettable hour meter or, if such a meter is not available, by recording monitoring and maintaining a contemporaneous record of the following data information:

 Unit ID;

 Date/time equipment started;

 Date/time equipment shut down;

 Name of person operating equipment (printed); and

 Signature of person operating equipment.

[40 CFR §§ 52.21 , 55.8, and 71.6(a)(1), (a)(3) and (c)(1)]39

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- M1 6.22 6.24 Compliance Monitoring and Recordkeeping Requirements for Support Vessel Engines

In accordance with Condition 5.16 , t he permittee shall demonstrate compliance with support vessel operational limits pursuant to Conditions 6. 20 and 6 .21 by maintaining a record of support vessel operating time and diesel fuel use within a 25 mile radius o f the drilling vessel and during standby time at the drilling vessel. The permittee shall monitor and maintain a contemporaneous record of

the following information for vessels used in support of the permitted activities :

 Date/time entering the 25 mile radius;

 Date/time exiting the 25 mile radius;

 Sulfur content of all fuel used in any engine as specified in Condition 6. 3 ;

 Gallons of diesel fuel on the support vessel entering the 25 mile radius; and

 Gallons of diesel fuel on the support vessel exiting th e 25 mile radius. and

 Gallons of diesel fuel loaded on to the support vessel within the 25 mile radius.

[40 CFR §§ 52.21, 55.2, 55.6(a)(4) , 55.8, and 71.6(a)(1), (a)(3) and (c)(1)]

6.23 6.25 Reporting Requirements

All information required to be collected, recorded, or maintained pursuant to Conditions 6.3 through 6.21 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17. The permittee shall submit the information required in

Conditions 6. 3 through 6. 2 1 in accorda nce with reporting specifications detailed in Condition 5.17.

[40 CFR § 71.6(a)(3)(iii) and 55.8 ]

6.24 6.26 New Source Performance Standards and National Emission Standard for Hazardous Air Pollutants (HA P) Requirements

6.24.1 6.26.1 The main generator engines

, emergency generator engine, and cementing unit engines on the Developer drill rig (Units GEN

- 1 through GEN

- 8

, EGEN , CMU

- 1, and

CMU

- 2 ) and the main generator engines, emergency generator engine, and forklift engines, on the Discoverer Americas (GEN

- 1 through GEN

- 6, FORK

- 1, and FORK

- 2) are subject to 40 CFR part 60, subpart IIII based on engine size, per cylinder displacement

, and model year. The permittee shall demonstrate compliance with the applicable requirements through the following:

6.24.1.1 6.26.1.1 The permittee shall maintain documentation in a ccordance with Condition 5.16 that engines specified in Condition 6. 2 6 .1 were installed and configured according to manufacturer’s specifications.

6.24.1.2 6.26.1.2 The permittee shall maintain records in accordance with Condition 5.16 of manufacturer data indicating compliance with EPA Tier standards

, if applicable

, to the engine

.40

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6.24.1.3 6.26.1.3 The permittee shall operate a nd maintain the engines according to the manufacturer's written instructions or procedures developed by the permittee that are approved in writing by the engin e manufacturer. The permittee shall only change those settings that are approved by the

manufact urer. The pe rmittee shall maintain records of the manufacturer’s written instructions for operation and maintenance of the engine or the procedures the permittee developed that are approved in writing by the

manufacturer in accordance with Condition 5.16

.

6.24.1.4 6.26.1.4 The permitted engines shall not combust any diesel fuel that does not meet the requirements of Condition 6. 3

.

6.24.2 6.26.2 The emergency generator and emergency air compr essor engines on the

Discoverer Americas (EGEN, ACOMP

- 1, and ACOMP

- 2) are subject to 40 CFR part 60, subpart IIII based on the per cylinder displacement and model year. The permittee has been granted a technical exemption pursuant to 40 CFR § 55.7 from the emission standard certification requirement of 40 CFR 60, subpart IIII and must comply with the following:

6.26.2.1 The permittee shall demonstrate compliance with alternate emissions standards as specified in Condition 6. 1 5

. 6.24.2.1

6.24.2.2 6.26.2.2 The permittee shall comply with requirements defined in Conditions

6.2 6 .1.1 through 6.2 6 .1.4.

6.24.3 6.26.3 Based on engine model years and engine use (summarized in Tables 1 and 2 of

Section 4), the main generator engines, emergency generator engine, and cementing unit engines on the Developer drill rig (Units GEN

- 1 through GEN

- 8, EGEN, CMU

- 1,

and CMU

- 2) and the main generator engines, emergency generator engine, forklift engines, and emergency air compressor engines on the Discoverer Americas (GEN

- 1 through GEN

- 6, EGEN, FORK

- 1, FORK

- 2, ACOMP

- 1 , and ACOMP

- 2) are subject to and shall comply with the applicable requirements of 40 CFR part 63, subpart ZZZZ. The permittee shall demonstrate compliance with subpart ZZZZ for each engine by demonstrating compliance with the applicable requirements of 40 CFR part 60, subpart

IIII and Condition s 6.2 6 .1 and 6.2 6 .2 .]

6.24.4 6.26.4 Compliance with the requirements of Condition 6. 2 6 shall be determined based upon recordkeeping required by the Annual Compliance Certification set forth in

Condition 5.21.

6.24.5 6.26.5 Any new, modified, or reconstructed engine shall comply with all applicable

NESHAP and NSPS , including but not limited to 40 CFR part 60, subpart IIII and

40 CFR part 63, subpart ZZZZ, or obtain a technical exemption under 40 CFR § 55.7.41

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- M1 6.24.6 6.26.6 The permittee shall notify EPA prior to use of any new, modified, or reconstructed engine intended to be used on the drilling vessel or in replacement of an engine in Tables 1 and 2 of Section 4 of this permit

, and shall submit to EPA a reevaluation of the applicability of pertinent NESHAP and NSPS regulations , as well as copies of the manufacturer engine certification to EPA standards.

[40 CFR §§ 55.7, 55.8, 60 subpart IIII, 63 subpart ZZZZ, 71.6(a)(1), 71.6 (a)(3) and

71.6 (c)(1)]