Environmental solutions delivered uncommonly well 

Anadarko Petroleum Corporation 

BlackHornet PSD/Title V Permit Application 

Operations in the Eastern Gulf of Mexico 

Revision 1 

Prepared	By:	

TRINITY CONSULTANTS

301	Main	Street,	Suite	900	

Baton	Rouge,	LA	70816	

(225)	292‐2661	

September	2013	

Project No. 131901.0021
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organic	compounds	(VOC),	and	greenhouse	gases	(GHG)	exceed	their	respective	Significant	Emission	

Rates	(SER).			Hence,	the	Best	Available	Control	Technology	(BACT)	review	for	all	air	emission	

sources	with	emissions	of	these	pollutants	has	been	conducted	and	is	included	in	this	permit	

application.	

Table 1‐2.		Project Potential‐to‐Emit (PTE) of Project		

Pollutant

Project Potential

to Emit		

Tons/year

Significant

Emission Rate

(SER)		

Tons/year

Exceeds

SER?

NOX 1,447	 40	 Yes

CO	 540	 100	 Yes

PM	 58	 25	 Yes

PM10 56	 15	 Yes

PM2.5 56	 10	 Yes

SO2 1	 40	 No	

VOC	 171	 40	 Yes

Pb	 0.02	 0.6	 No	

H2SO4 0.03	 7	 No	

GHG	 125,000	 75,000	 Yes

In	accordance	with	40	CFR	52.21(i)(3),	the	requirements	under	40	CFR	52.21(k),	(m),	and	(o)	do	not	

apply	to	a	major	stationary	source	or	major	modification	with	respect	to	a	particular	pollutant,	if	the	

allowable	emissions	of	that	pollutant	from	the	source,	or	the	net	increase	of	that	pollutant	from	the	

modification	would	not	impact	a	Class	I	area,	would	not	impact	an	area	where	an	applicable	

increment	is	known	to	be	violated,	and	when	the	source	would	be	temporary	(i.e.,	less	than	two	(2)	

years	of	operation).			

The	proposed	project	does	not	meet	these	criteria	and	does	not	qualify	for	an	exemption	from	40	

CFR	52.21(k),	(m),	and	(o)	as	explained	in	Section	4.2	of	this	permit	application	report.		Therefore,	

Class	II	area	modeling	analysis	and	additional	impact	analyses	are	included	in	this	permit	

application.	

Based	on	the	locations	of	the	proposed	operations	and	analysis	of	project	emissions,	air	quality	

modeling	analyses	of	the	impacts	on	federally	protected	Class	I	areas	and	Class	II	areas	have	been	

performed	to	demonstrate	compliance	with	PSD	Class	I	area	and	Class	II	area	Increment	standards	

and	air	quality	related	values	(AQRV)	thresholds.1		Accordingly,	a	Class	I	area	and	Class	II	area	

modeling	analysis	and	report	has	been	prepared	and	is	included	in	Appendix	D	of	this	permit	

application	report.	

																																																															

1 Anadarko’s EGOM Exploratory Project lease blocks are located within 300 kilometers of three federally protected Class I areas in the Southern United States. 
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The	proposed	emissions	sources	during	each	scenario	and	associated	operating	parameters	are	

provided	in	Appendix	B.		The	aforementioned	operation	scenarios	will	not	happen	concurrently.		Only	

one	out	of	these	scenarios	OR	any	‘equivalent’	combination	will	be	conducted	and	the	resulting	

emissions	from	activities	involved	in	the	scenario	will	not	exceed	the	worst‐case	emissions	among	the	

six	scenarios.		The	drillship	and	supply	boats	will	also	be	operating	on	an	as	required	basis.		The	

operation	of	the	aforementioned	scenarios	will	typically	involve	the	following	sources	as	listed	below.			

The	remainder	of	this	section	discusses	the	short	term	and	long	term	emission	calculation	

methodologies	for	each	equipment,	assumptions,	proposed	operating	parameters,	and	the	derivation	of	

the	fuel	based	emission	factors,	if	applicable.		Appendix	B	provides	a	summary	of	emissions	for	each	

operating	scenario	for	each	criteria	pollutant,	GHGs,	H2SO4,	and	HAPs.	

3.3. DRILLSHIP 

The	emission	calculation	methodologies	for	the	air	pollution	sources	on	the	BlackHornet	drillship	are	

discussed	below.	

3.3.1. Main Engines (DR-ME-01 through DR-ME-08) 

The	drillship	consists	of	eight	main	engines.		Six	of	the	eight	engines	are	identical	HYUNDAI‐HiMSEN,	

9H32/40V	6,035	HP	diesel‐fired	engines.		The	other	two	engines	are	HYUNDAI‐HiMSEN,	18H32/40V	

12,069	HP	diesel‐fired	engines.		The	specification	sheets	for	these	engines	are	provided	in	Appendix	G‐1.	

Emission Factors	–	The	sources	of	emission	factors	used	to	estimate	emissions	for	each	of	the	eight	

engines	are	summarized	below.	

AP‐42, Section 3.4.		Large Stationary Diesel and All Stationary Dual‐fuel Engines	–CO	and	

HAP	emissions	estimates	for	the	eight	main	engines	are	based	on	AP‐42,	Section	3.4	emission	

factors	(Table	3.4‐1,	Table	3.4‐2,	and	Table	3.4‐3).						

Stack Test Results –	NOx,	VOC,	PM,	PM10,	PM2.5,	and	GHG	emission	rates	are	based	on	the	

results	of	the	stack	tests	performed	in	June	2014.		As	discussed	in	the	“Hybrid	BACT	Approach”	

technical	memorandum,	submitted	to	EPA	on	July	18,	2014,	emission	factors	were	derived	for	

50%	load.		These	derived	emission	factors	were	used	for	emission	calculations.					

EPA Guidance Documents	–	Lead	emission	factor	is	obtained	from	EPA’s	guidance	document:	

Locating and Estimating Air Emissions from Sources of Lead and Lead Compounds, EPA 454/R‐98‐

006, May 1998, Section 5.2.2.		Emission	factor	for	distillate	oil‐fired	gas	turbines	was	used	as	a	

surrogate	for	distillate	oil‐fired	engines	due	to	unavailability	of	emission	factors.					

EPA Regulations – CO2,	CH4,	and	N2O	emission	factors	are	obtained	from	40	CFR	98	Subpart	C,	

Table	C‐1	(Default	CO2	Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fuel)	and	

Table	C‐2	(Default	CH4	and	N2O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor	for	

CO2e	has	been	calculated	using	the	GWPs	obtained	from	40	CFR	98	Subpart	A.				
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Mass Balance	–	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	combustion	sources.		

Therefore,	SO2	emissions	are	calculated	based	on	a	maximum	sulfur	content	of	15	ppm	in	diesel	

fuel	assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	SO2	and	2	percent	of	sulfur	in	the	

fuel	is	oxidized	to	sulfuric	acid	(H2SO4)	mist	based	on	Section	4.1.1	of	Draft	Regulatory	Impact	

Analysis:	Control	of	Emissions	from	Nonroad	Diesel	Engines,	EPA420‐R‐03‐008,	April	2003.		

Emissions	of	Hydrogen	sulfide	(H2S),	total	reduced	sulfur	(TRS),	and	reduced	sulfur	compounds	

resulting	from	sulfur	content	in	the	fuel	are	negligible.	

Fuel Based Emission Factor Derivation:	

Since	the	main	engines	operate	in	a	group,	the	PTE	is	calculated	for	the	group	of	main	engines	based	on	

the	maximum	power	requirements	for	all	operating	scenario.		Based	on	the	specifications	sheet	

provided,	all	of	these	engines	have	a	break	specific	fuel	consumption	(BSFC)	of	179	g/kW‐hr.		Since	the	

main	engines	are	the	highest	emitters	of	a	pollutant	on	a	lbs	of	pollutant/cubic	meter	of	fuel	consumed	

among	the	various	engines	on	the	drillship,	the	fuel	limits	established	on	the	fuel	based	emission	factors	

for	the	main	engines	represent	the	worst	case	emission	scenario.		Hence,	Anadarko	is	proposing	

drillship‐wide	fuel	limit	derived	using	the	main	engine	fuel	based	emission	factors	(i.e.,	lbs	of	pollutant	

per	cubic	meter	of	fuel.)			These	fuel	based	emission	factor	calculation	is	presented	in	Appendix	B.		

Proposed Operating Limits:	

Anadarko	proposes	a	drillship‐wide	fuel	cap	of	112	cubic	meters/day	(m3/day)	for	all	the	diesel	

combustion	sources	located	on	the	drillship.		This	fuel	cap	is	the	highest	fuel	usage	of	all	the	six	

scenarios.			

Also,	Anadarko	proposes	to	use	18,438	m3/year	fuel	for	all	the	diesel	combustion	sources	located	on	the

drillship.		The	annual	fuel	limit	is	calculated	based	on	approximately	200	days	of	operation	and	the	

power	requirement	of	86,400,000	KW.		However,	Anadarko	proposes	the	annual	fuel	limit	in	lieu	of	

annual	operating	time	limit.		In	case	Anadarko	does	not	consume	the	proposed	annual	fuel	in	200	days,	

Anadarko	proposes	to	maintain	the	flexibility	of	operating	more	than	200	days	as	long	as	total	fuel	

consumption	is	within	the	proposed	limit.		The	maximum	hourly,	daily,	and	annual	emissions	from	the	

main	engines	are	calculated	based	on	the	derived	fuel	based	emission	factor	as	described	below:	

Maximum Hourly Emissions – The	maximum	hourly	emissions	for	the	main	engines	are	based	on	the	

fuel	based	emission	factor	and	maximum	fuel	requirement	of	5.1	m3	of	fuel.		

Maximum Daily Emissions – The	maximum	daily	emissions	for	the	main	engines	are	based	on	the	fuel	

based	emission	factor	and	maximum	fuel	requirement	of	112	m3	of	fuel.

Annual Emissions –	The	annual	emissions	for	the	main	engines	are	based	on	the	fuel	based	emission	

factor	and	maximum	fuel	requirement	of	18,438	m3	of	fuel.		

3.3.2. Emergency Generator (DR-GE-01) 

The	drillship	includes	one	2,547	HP	Cummins	QSK60DMGE	diesel‐fired	emergency	generator.		Air	

emissions	are	generated	as	a	result	of	combustion	of	diesel	fuel	in	the	engine.			
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Since	this	emission	unit	will	be	a	part	of	drillship‐wide	fuel	consumption	limit,	no	separate	fuel	limit	is	

required	to	demonstrate	compliance.		Anadarko	will	maintain	adequate	records	to	comply	with	

proposed	daily	and	annual	operation	limits.	

3.3.3. Emergency Air Compressor (DR-AC-01) 

The	drillship	consists	of	one	39	HP	HATZ	2M41	diesel‐fired	emergency	air	compressor,	which	is	

compliant	with	EPA	Tier	3	standards	for	nonroad	engines.		The	specification	sheet	was	provided	as	a	

part	of	the	response	to	incompleteness	determination	submitted	on	November	26,	2013.		Emissions	are	

generated	as	a	result	of	combustion	of	diesel	fuel	in	the	engine.			

Emissions Factors	–	The	sources	of	emission	factors	used	to	estimate	emissions	for	each	of	the	

emergency	air	compressor	engine	is	summarized	below.	

40 CFR 89 Control Of Emissions From New And In‐Use Nonroad Compression‐Ignition

Engines –Particulate	matter	(PM,	PM10,	and	PM2.5),	NOX,	and	CO	emissions	estimates	for	the	

third	party	engines	are	based	on	40	CFR	89	Tier	3	exhaust	emission	standards.		NOX	emission	

factors	are	assumed	to	be	equal	to	the	NMHC	+	NOX	emission	factor.		Based	on	footnote	b	of	AP‐

42	Chapter	3,	Table	3.3‐1,	all	PM	is	assumed	to	be	<	1	μm.		Therefore,	it	is	assumed	PM2.5	=	PM10

=	PM.		

AP‐42, Section 3.3.		Gasoline and Diesel Industrial Engines	–	VOC	and	HAP	Emissions	are	

based	on	AP‐42	Section	3.3	emission	factors	(Table	3.3‐2.)		An	average	BSFC	of	7,000	Btu/HP‐hr	

has	been	used	to	convert	emission	factors	from	lb/MMBtu	to	lb/HP‐hr.	

EPA Guidance Documents	–	Lead	emission	factor	is	obtained	from	EPA	guidance	document:

Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and	Lead	Compounds,	EPA	454/R‐

98‐006,	May	1998,	Section	5.2.2.		Emission	factor	for	distillate	oil‐fired	gas	turbines	was	used	as	

a	surrogate	for	distillate	oil‐fired	engines	due	to	lack	of	emission	factors.					

EPA Regulations – CO2,	CH4,	and	N2O	emission	factors	are	obtained	from	40	CFR	98	Subpart	C,	

Table	C‐1	(Default	CO2	Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fuel)	and	

Table	C‐2	(Default	CH4	and	N2O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor	for	

CO2e	has	been	calculated	using	the	GWPs	obtained	from	40	CFR	98	Subpart	A.				

Mass Balance – Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	combustion	sources.		

Therefore,	SO2	emissions	are	calculated	based	on	a	maximum	sulfur	content	of	15	ppm	in	diesel	

fuel	assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	SO2	and	2	percent	of	sulfur	in	the	

fuel	is	oxidized	to	H2SO4	mist	based	on	Section	4.1.1	of	Draft	Regulatory	Impact	Analysis:	Control	

of	Emissions	from	Nonroad	Diesel	Engines,	EPA420‐R‐03‐008,	April	2003.		Emissions	of	H2S,	

TRS,	and	reduced	sulfur	compounds	resulting	from	sulfur	content	in	the	fuel	are	negligible.	

The	maximum	hourly,	daily,	and	annual	emissions	from	the	emergency	air	compressor	are	calculated	as	

described	below:	

Maximum Hourly Emissions – The	maximum	hourly	emissions	for	the	air	compressor	are	

calculated	based	on	0.5	hours	of	operation.		
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Table 4‐2. Applicable Engines Subject to Subpart IIII		

EPN Description ManufacturingYear

Engine Rating

(HP)

Displacement Per

Cylinder

Drillship

Main Engines		

DR‐ME‐01	 Main	Propulsion	Electrical	

Generator	Engine	#1	 2012	 6,035	 32.2	

DR‐ME‐02	 Main	Propulsion	Electrical	

Generator	Engine	#2	 2012	 6,035	 32.2	

DR‐ME‐03	 Main	Propulsion	Electrical	

Generator	Engine	#3	 2012	 6,035	 32.2	

DR‐ME‐04	 Main	Propulsion	Electrical	

Generator	Engine	#4	 2012	 6,035	 32.2	

DR‐ME‐05	 Main	Propulsion	Electrical

Generator	Engine	#5	 2012	 6,035	 32.2	

DR‐ME‐06	 Main	Propulsion	Electrical	

Generator	Engine	#6	 2012	 6,035	 32.2	

DR‐ME‐07	 Main	Propulsion	Electrical	

Generator	Engine	#7	 2012	 12,069	 32.2	

DR‐ME‐08	 Main	Propulsion	Electrical	

Generator	Engine	#8	 2012	 12,069	 32.2	

Emergency Engines		

DR‐GE‐01	 Emergency	Generator	 April	2012	 2,547	 3.8	

DR‐AC‐01	 Emergency	Air	Compressor		 September	2011	 38.5	 0.9	

4.3.5.1. Drillship Main Engines (DR-ME-01 through DR-ME-08) 

The	eight	main	engines	on	the	drillship	are	subject	to	40	CFR	60.4200(a)(2)(i)	because	they	were	

manufactured	after	April	1,	2006.		These	engines	are	required	to	comply	with	the	following	

requirements:	

NOX	and	PM	emission	standards	for	owners	and	operators	as	outlined	in	40	CFR	60.4204(c)		

Use	of	fuels	that	meet	a	maximum	per‐gallon	sulfur	content	of	1,000	ppm	[40	CFR	60.4207(d)].	

Operation	and	maintenance	requirements	as	specified	in	40	CFR	60.4211(a).			

Initial	and	annual	performance	tests	for	NOX	and	PM,	as	well	as	continuous	operating	parameter	

monitoring	per	40	CFR	60.4211(d),	and	40	CFR	60.4213.			

Notification	and	recordkeeping	requirements	as	specified	in	40	CFR	60.4214.	

Note	that	NOX	and	PM	emission	standards	specified	in	40	CFR	60.4204(c)	are	applicable	when	engine	is	

operating	at	the	maximum	design	load.		Anadarko	will	identify	the	highest	achievable	load	(e.g.,	90%	of	

the	design	load)	without	compromising	safety	of	the	vessel	and	personnel	and	conduct	the	stack	tests	to	

demonstrate	compliance	with	NOX	and	PM	emission	standards	specified	in	40	CFR	60.4204(c).			
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Table 4‐4. Emergency Generator Residual Emissions

Pollutant PTE Emissions (tpy) EPA Tier 2 (tpy)

Residual

Emissions

(tpy)

NOx	+	NMHC	 1.64	 1.34	 +0.30	

CO	 0.08	 0.73	 ‐‐	

PM	 0.089	 0.042	 +0.047	

4.3.5.3. Drillship Emergency Air Compressor (DR-AC-01) 

Since	the	emergency	air	compressor	engine	is	a	post	2007	non‐fire	pump	emergency	CI	engine	less	than	

50	HP	with	a	displacement	of	less	than	10	L	per	cylinder,	this	engine	must	comply	with	emission	

limitations	for	new	nonroad	CI	engines	as	specified	in	Table	2	of	NSPS	IIII,	40	CFR	1039.104,	40	CFR	

1039.105,	40	CFR	1039.107,	and	40	CFR	1039.115.		As	specified	in	the	submitted	EPA	certificate,	this	

engine	complies	with	the	requirements	of	40	CFR	1039.		

Table	2	of	NSPS	IIII	requires	this	engine	(i.e.,	38.5	HP	and	0.9	L/cylinder	displacement)	to	comply	with	

the	following	exhaust	emission	standards:	

NOX	–	7.5	g/kw‐hr	

CO	–	5.5	g/kw‐hr	

PM	–	0.3	g/kw‐hr	

Additionally,	the	emergency	air	compressor	must	comply	with	the	following	exhaust	opacity	limits	

specified	in	40	CFR	1039.105(b):	

20%	during	acceleration	mode	

15%	during	the	lugging	mode	

50%	during	the	peaks	in	acceleration	or	lugging	modes	

Since	the	emergency	air	compressor	is	an	EPA	Tier	3	certified	engine	compliance	with	the	above	

mentioned	emission	standard	is	demonstrated.		In	addition,	the	emergency	air	compressor	must	comply	

with	the	diesel	fuel	requirements	for	nonroad	diesel	under	40	CFR	80.510(b)	for	15	ppm	sulfur	content,	

a	minimum	cetane	index	of	40	or	a	maximum	aromatic	content	of	35	volume	percent.		Anadarko	will	

comply	with	the	specified	fuel	requirements	by	using	ULSD	for	all	diesel	combustion	sources.		

4.3.5.4. Drillship Temporary Third Party Well Evaluation Engines (DR-TP-12 

through DR-TP-16) 

Per	40	CFR	60.4200(a)(2)(i),	above	mentioned	CI	engines	are	not	subject	to	this	regulation	because	the	

engines	were	not	manufactured	after	April	1,	2006.		Also,	these	engines	were	not	constructed,	modified,	

or	reconstructed	after	July	11,	2005.			
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The	main	diesel	engines	will	not	be	able	to	sustain	constant	steady	state	loads/exhaust	temperatures	for	

sufficient	time	periods	that	are	critical	for	high	catalyst	performance,	resulting	in	inconsistent	emission	

control.		Several	non‐combustible	chemical	elements	that	may	be	present	in	engine	lube	oils,	such	as	

phosphorous,	lead	and	heavy	metals,	may	collect	over	time	and	damage	the	catalyst.		Therefore,	it	is	not	

technically	feasible	for	the	main	propulsion	engines.	

ITR	–	Infeasible.

Changing	ignition	timing	is	not	an	alternative	for	these	engines	due	to	intrinsic	engine	design.	Alterations	

of	 the	 injection	 timing	 can	 impact	 value	 and	 turbo	 charger	 performance.	 	 Additionally,	 use	 of	 this	

technology	can	 reduce	engine	power	and	combustion	stability	which	can	hinder	operations.	For	 these	

reasons	this	technology	is	infeasible	for	the	main	engines	on	BlackHornet	drillship.	

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

Table 5‐1. Ranks of Technologies Feasible for Main Engines

Technology Efficiency Rank

SCR	with	Urea	Injection	 79%13	 1	

Performance	management	system	including	

Turbocharger	with	Aftercooler	and	High	Fuel	

Injection	Pressure	System	

~30%	 2	

LNE	design		 Baseline	 3	

Good	Combustion	and	Manufacturer	

Recommended	Maintenance	Practices	

Baseline	 N/A	

All	feasible	technologies	for	the	main	propulsion	engines	are	listed	in	Table	5‐1.		Control	technologies	are	

ranked	by	efficiency	in	a	descending	order.	

Step 4 – Evaluate Most Effective Controls and Document Results

SCR	–	Based	on	the	very	conservative	cost	assumptions	(i.e.,	low	cost),	the	cost	effectiveness	analysis	of	

SCR	installation	is	estimated	to	be	approximately	$12,000	per	ton	of	NOX	reduced,	making	this	option	

cost	prohibitive.		A	detailed	control	cost	effectiveness	analysis	is	provided	in	Appendix	E.	

Performance Management System including Turbocharger with Aftercooler and High Fuel

Injection Pressure System and Low NOx Design –	The	main	engines	are	equipped	with	a	performance	

management	system	(also	called	as	“optimized	supercharger	with	miller	cycle	technology”	by	the	

manufacturer),	which	is	useful	to	reduce	the	NOX	emission	by	optimizing	the	intake	valve's	closing	

timing	especially,	result	in	changing	the	effective	compression	and	expansion	ratio.		In	order	to	apply	

this	technology,	the	high	pressure	ratio	turbocharger	is	required	to	increase	the	charge	air	pressure	and	

new	developed	Turbo	charger	with	high	pressure	ratio	is	mounted	on	the	main	engines.		The	optimized	

supercharging	with	miller	cycle	has	recently	been	designed	to	enhance	the	load	management	of	the	

engines.		Also,	the	main	engines	are	equipped	with	high	fuel	injection	pressure	and	low	NOX	design.		

Since	Anadarko	is	proposing	to	implement	this	technology,	a	control	cost	analysis	is	not	required.	

																																																															

13 Cost analysis presented in Appendix E 
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ITR	–	Infeasible.	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.1.1.	

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

Table 5‐3. Ranks of Technologies Feasible for Emergency Air Compressor Engine

Technology Efficiency Rank

Replacement	with	Newer	Engine	 varies	 1	

Good	Combustion	and	Manufacturer	

Recommended	Maintenance	Practices	

Baseline	 N/A	

All	feasible	technologies	for	the	air	compressor	are	listed	in	Table	5‐3.		Control	technologies	are	ranked	

by	efficiency	in	a	descending	order.	

Step 4 – Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89	Tier	3	standards	are	the	cleanest	available	engines	in	this	category	of	

equipment.		Anadarko’s	proposed	equipment	is	certified	to	40	CFR	89	Tier	3	standards.	

Step 5	‐	Select BACT

Anadarko	proposes	40	CFR	89,	EPA	Tier	3	standards	and	good	combustion	and	manufacturer	

recommended	maintenance	practices	as	BACT	for	the	emergency	air	compressor	engine.		

5.1.4. NOX BACT Analysis for Third Party Engines (DR-TP-01 through DR-TP-11 and 

DR-TP-17 though DR-TP-21)

The	temporary	EPA	Tier	2	certified	third	party	engines	are	divided	in	the	following	engine	categories:		

Third	party	engines	≤860	HP	

Third	party	engines	≤300	HP	

Third	party	engines	≤126	HP	

Step 1 – Identify all Control Technologies

The	third	party	engines	on	the	drillship	are	a	combination	of	small	(<500	HP)	and	large	(>500	HP)	diesel	

engines,	and	the	NOX	control	options	identified	for	the	drillship	main		engines	are	assumed	to	

sufficiently	account	for	all	the	possible	control	technologies	for	the	third	party	engines.		Therefore,	the	

same	options	identified	for	the	drillship	main	propulsion	engines	and	emergency	air	compressor	are	

considered	as	the	potential	control	technologies	for	the	third	party	engines	on	the	drillship.			

Step 2 – Eliminate Technically Infeasible Options

SCR	–	Infeasible.		

This	control	option	is	not	technically	feasible	for	use	on	the	third	party	diesel	engines,	which	only	
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 94 

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

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

brought	onboard	on	any	given	day.		Since	availability	of	the	EPA	Tier	3	and	Tier	4	engines	is	limited,	

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

these	third	party	engines	to	EPA	Tier	3	or	Tier	4	certified	engines	will	significantly	impact	the	

operations.		Hence,	this	control	technology	is	deemed	technically	infeasible	

LNE Design with Turbocharger, Aftercooler and High Pressure Fuel Injection System	–	Infeasible.			

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.1.3.		

CAM Shaft Replacement/ Retooling of Engines –	Infeasible.	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.1.1.		

4‐Way Catalyst Converter	–	Infeasible.	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.1.1.		

ITR	–	Infeasible.	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.1.1.	

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

Since	all	the	remaining	feasible	technologies	are	being	proposed	as	BACT,	no	ranking	is	required	

Step 4 – Evaluate Most Effective Controls and Document Results

Since	all	the	remaining	feasible	technologies	are	being	proposed	as	BACT,	a	cost	analysis	is	not	required.	

Step 5	‐	Select BACT

Anadarko	proposes	40	CFR	89	EPA	Tier	2	standards	along	with	good	combustion	and	manufacturer	

recommended	maintenance	practices	as	NOX	BACT	for	the	temporary	third	party	engines.		As	indicated	

previously,	the	third	party	engines	and	the	horsepower	ratings	shown	in	this	application	are	for	

representation	purposes	only.		However,	a	third	party	engine	brought	onto	the	drillship	will	at	least	be	

certified	to	40	CFR	89	EPA	Tier	2	standards,	with	equivalent	or	lower	emissions	than	the	engine	

represented.		Refer	to	“Third	Party	BACT	Clarification”	memorandum	submitted	on	August	8,	2014	for	

additional	details.	

5.1.5. NOX BACT Analysis for Third Party Well Evaluation Engines (DR-TP-12 

through DR-TP-16) 

Step 1 – Identify all Control Technologies

EPA's	RBLC	search	was	used	to	obtain	potential	control	technologies	for	NOX	from	smaller	diesel	
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 102 

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Table 5‐6. Proposed NOX BACT Emission Limits

Emission Unit

BACT

Emission

Limit

BACT Basis BACT Control Technologies

Drillship	Main		Engines		

(DR‐ME‐01	thru	DR‐ME‐06)	

10.57	g/kW‐

hr	for	engine	

loads	50%	

and	above	

and	52.41	

lbs/hr	for	

engine	loads	

less	than	

50%	

June	2014	

BlackHawk	

Source	Test	

Results	and	

Hybrid	BACT	

Approach	

technical	

Memorandum	

EPA	40	CFR	1042	Tier	2	Standards,	

NSPS	IIII,	IMO	Tier	2	standards,	

LNE	Design,	Performance	

Management	System	including	

Turbocharger	with	Aftercooler	

and	High	Fuel	Injection	Pressure,	

good	combustion	and	

manufacturer	recommended	

maintenance	practices

Drillship	Main		Engines		

(DR‐ME‐07	thru	DR‐ME‐08)	

10.57	g/kW‐

hr	for	engine	

loads	50%	

and	above	

and	104.82	

lbs/hr	for	

engine	loads	

less	than	

50%	

June	2014	

BlackHawk	

Source	Test	

Results	and	

Hybrid	BACT	

Approach	

technical	

Memorandum	

EPA	40	CFR	1042	Tier	2	Standards,	

NSPS	IIII,	IMO	Tier	2	standards,	

LNE	Design,	Performance	

Management	System	including	

Turbocharger	with	Aftercooler	

and	High	Fuel	Injection	Pressure,	

good	combustion	and	

manufacturer	recommended	

maintenance	practices

Drillship	Emergency		

Generators	(DR‐GE‐01)	

‐‐ IMO	Tier	2	

Standard	

IMO	Tier	2	standards,	

Turbocharger	with	Aftercooler	&	

High	Injection	Pressure,	good	

combustion	and	manufacturer	

recommended	maintenance	

practices		

Emergency	Air	Compressor		

Engine	(DR‐AC‐01)	

‐‐ 40	CFR	89	

EPA	Tier	3	

Standard		

40	CFR	89	EPA	Tier	3	Standard,	

good	combustion	and	

manufacturer	recommended	

maintenance	practices	

Third	Party	Engines	(DR‐TP‐01	

through	DR‐TP‐11	and	DR‐TP‐

17	through	DR‐TP‐21)	

‐‐ 40	CFR	89	

EPA	Tier	2	

Standard	

40	CFR	89	EPA	Tier	2	Standard,	

good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Third	Party	Well	Evaluation	

Engines	(DR‐TP‐12	through	

DR‐TP‐16)	

‐‐ AP‐42,	

Chapter	3,	

Table	3.3‐1	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices	

Stimulation	Vessel	Pumps	(SV‐

PE‐01	thru	SV‐PE‐08)	

‐‐ AP‐42,	

Chapter	3,	

Table	3.4‐1	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Flowback	Boiler	(DR‐TP‐22)	 ‐‐ AP‐42,	

Chapter	1,	

Table	1.3‐1	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices	

Boom	Flare	(DR‐TP‐23)	 ‐‐ AP‐42,	

Chapter	13,	

Table	13.5‐1	

Compliance	with	40	CFR	60.18	and	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices	
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 108 

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Positive Crankcase Ventilation System (for VOCs only) –	Infeasible.		

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.2.1.	

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

Table 5‐9. Ranks of Technologies Feasible for Emergency Air Compressor Engine

Technology Efficiency Rank

Replacement	of	Engine	to	meet	higher	EPA	

Tier	standards

1	

Good	Combustion	Practices	 Baseline	 N/A	

All	feasible	technologies	for	the	air	compressor	are	listed	in	Table	5‐9.		Control	technologies	are	ranked	

by	efficiency	in	a	descending	order.	

Step 4 – Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89	Tier	3	standards	are	the	cleanest	available	engines	in	this	category	of	

equipment.		Anadarko’s	proposed	equipment	is	certified	to	40	CFR	89	Tier	3	standards.	

Step 5	‐	Select BACT

Anadarko	proposes	40	CFR	89,	EPA	Tier	3	standards	and	good	combustion	and	manufacturer	

recommended	maintenance	practices	as	BACT	for	the	emergency	air	compressor	engine.			

5.2.4. CO and VOC BACT Analysis for Drillship Third Party Engines (DR-TP-01 

through DR-TP-11 and DR-TP-17 though DR-TP-21) 

The	temporary	EPA	Tier	2	certified	third	party	engines	include	the	following	engine	categories:		

Third	party	engines	≤860	HP		(DR‐TP‐01	and	DR‐TP‐02)	

Third	party	engines	≤300	HP		(DR‐TP‐03	to	DR‐TP‐11)	

Third	party	engines	≤126	HP		(DR‐TP‐17	to	DR‐TP‐21)	

Step 1 – Identify all Control Technologies

The	third	party	engines	on	the	drillship	are	a	combination	of	small	(<500	HP)	and	large	(>500	HP)	diesel	

engines,	and	the	CO	and	VOC	control	options	identified	for	the	main	propulsion	electrical	generator	

engines	are	assumed	to	sufficiently	account	for	all	the	possible	control	technologies	for	the	third	party	

engines.		Therefore,	the	same	options	identified	for	the	drillship	main	diesel	engines	are	considered	as	

the	potential	control	technologies	for	the	third	party	engines	on	the	drillship.		

Step 2 – Eliminate Technically Infeasible Options

DOC	–	Infeasible.	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.2.1.
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 113 

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5.2.8. CO and VOC BACT Analysis for Boom Flare (DR-TP-23) 

Step 1 – Identify all Control Technologies

EPA's	RBLC	search	was	used	to	obtain	potential	control	technologies	for	CO	from	flares	and	review	of	

the	permits	recently	proposed/issued	by	U.S.	EPA	Region	4	and	Region	10	(and	corresponding	permit	

applications)	for	similar	OCS	sources	was	conducted	to	obtain	potential	control	technologies	for	CO	from	

flares.		The	most	recent	10‐year	period	was	used	to	identify	applicable	control	technologies.		The	results	

of	the	RBLC	search	are	included	in	Appendix	E.		The	search	results	for	potential	control	technologies	for	

CO	from	flares	are	listed	below.	

Comply	with	40	CFR	60.18	

Good	Combustion	Practices	(Manufacturer	recommended	operation	and	maintenance)	

Step 2 – Eliminate Technically Infeasible Option

Comply	with	40	CFR	60.18	–	Feasible.	

Good	Combustion	Practices	–	Feasible.	

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

Since	both	the	identified	technologies	are	being	proposed	as	BACT,	no	ranking	is	required	

Step 4 – Evaluate Most Effective Controls and Document Results

Since	both	the	identified	technologies	are	being	proposed	as	BACT,	a	cost	analysis	is	not	required.	

Step 5	‐	Select BACT

Anadarko	proposes	compliance	with	the	requirements	of	40	CFR	60.18	and	good	combustion	practices	

(manufacturer	recommended	operation	and	maintenance)	as	the	BACT	for	the	boom	flare.	

A	summary	of	the	proposed	CO	and	VOC	BACT	emission	limitation	for	each	source	associated	with	the	

project	is	provided	below	in	Table	5‐12.	

Table 5‐12. Proposed CO & VOC BACT Emission Limits

Emission Unit BACT Emission Limit BACT Basis BACT Control

Technologies

Drillship	Main	Propulsion	

Electrical	Engines		

(DR‐ME‐01	thru	DR‐ME‐06)	

CO‐ 3.39 g/kW‐hr	for	

engine	loads	50%	and	

above	and	16.56	lbs/hr	

for	engine	loads	less	than	

50%	

VOC‐	0.92	g/kW‐hr	for	

engine	loads	50%	and	

above	and	4.58	lbs/hr	for	

engine	loads	less	than	

50%	

June	2014	

BlackHawk	

Source	Test	

Results	and	

Hybrid	BACT	

Approach	

technical	

Memorandum		

LNE	design	including	

Turbocharger	with	

Aftercooler	and	High	

Fuel	Pressure	

Injection,	and	Good	

Combustion	Practices	
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 114 

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Emission Unit BACT Emission Limit BACT Basis BACT Control

Technologies

Drillship	Main	Propulsion	

Electrical	Engines		

(DR‐ME‐07	thru	DR‐ME‐08)	

3.39 g/kW‐hr	for	engine	

loads	50%	and	above	and	

33.12	lbs/hr	for	engine	

loads	less	than	50%	

VOC‐	0.92	g/kW‐hr	for	

engine	loads	50%	and	

above	and	9.16	lbs/hr	for	

engine	loads	less	than	

50%	

June	2014	

BlackHawk	

Source	Test	

Results	and	

Hybrid	BACT	

Approach	

technical	

Memorandum		

LNE	design	including	

Turbocharger	with	

Aftercooler	and	High	

Fuel	Pressure	

Injection,	and	Good	

Combustion	Practices	

Drillship	Emergency	Diesel	

Engine	(DR‐GE‐01)	

‐‐ AP‐42,	Chapter	

3,	Table	3.4‐1	

LNE	design	and	Good	

Combustion	Practices	

Emergency	Air	Compressor	

Engine	(DR‐AC‐01)	

‐‐ 40	CFR	89 EPA	

Tier	3	Standard	

EPA	Tier	3	Standard

Good	Combustion	

Practices	

Third	Party	Engines	(DR‐TP‐

01	through	DR‐TP‐11	and	

DR‐TP‐17	through	DR‐TP‐21)	

‐‐ 40	CFR	89	EPA	

Tier	2	Standard	

(CO)	

AP‐42,	Chapter	

3,	Table	3.4‐1	

(VOC)	

40	CFR	89	EPA	Tier	2	

Standard	and	LNE	

design	

Third	Party	Well	Evaluation	

Engines	(DR‐TP‐12	through	

DR‐TP‐16)	

‐‐ AP‐42,	Chapter	

3,	Table	3.3‐1	

Good	Combustion	

Practices	

Stimulation	Vessel	Pumps	

(SV‐PE‐01	thru	SV‐PE‐08)	

‐‐ AP‐42,	Chapter	

3,	Table	3.4‐1	

Good	Combustion	

Practices	

Flowback	Boiler	(DR‐TP‐22)	 ‐‐ AP‐42,	Chapter	

1,	Table	1.3‐1	

Good	Combustion	

Practices	

Boom	Flare	(DR‐TP‐23)	 ‐‐ AP‐42,	Chapter	

13,	Table	13.5‐1	

Compliance	with	40	

CFR	60.18	and	Good	

Combustion	Practices	

	 	
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 120 

Trinity Consultants

Table 5‐15. Ranks of Technologies Feasible for the Emergency Diesel Engine

Technology Efficiency Rank

Replacement	of	Engines	to	meet	higher	EPA	Tier	

standards	 varies	 1	

ULSD	 N/A	 N/A	

Good	Combustion	Practices	 Baseline	 N/A	

Step 4 – Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89	Tier	3	standards	are	the	cleanest	available	engines	in	this	category	of	

equipment.		Anadarko’s	proposed	equipment	is	certified	to	40	CFR	89	Tier	3	standards.

Step 5	‐	Select BACT

Anadarko	proposes	40	CFR	89,	EPA	Tier	3	standards	and	good	combustion	and	manufacturer	

recommended	maintenance	practices	as	BACT	for	the	emergency	air	compressor	engine.		

5.3.4. PM/PM10/PM2.5 BACT Analysis for Drillship Third Party Engines (DR-TP-01 

through DR-TP-11 and DR-TP-17 though DR-TP-21) 

Step 1 – Identify all Control Technologies

The	third	party	engines	on	the	drillship	are	a	combination	of	small	(<500	HP)	and	large	(>500	HP)	diesel	

engines,	and	the	PM/PM10/PM2.5	control	options	identified	for	the	main	drillship	engines	are	assumed	to	

sufficiently	account	for	all	the	possible	control	technologies	for	the	third	party	engines.		Therefore,	the	

same	options	identified	for	the	drillship	main	diesel	engines	are	considered	as	the	potential	control	

technologies	for	the	third	party	engines	on	the	drillship.		

Step 2 – Eliminate Technically Infeasible Options

DOC	–	Infeasible	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.3.1.

CDPF	–	Infeasible.	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.3.1.

4‐Way Catalyst Converter	–	Infeasible.	

This	control	technology	is	deemed	technically	infeasible	for	the	same	reasons	identified	in	Section	5.3.1.

Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042)	–	

Infeasible.	
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 129 

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A	summary	of	the	proposed	PM/PM10/PM2.5	BACT	emission	limitation	for	each	source	associated	with	the	

project	is	provided	below	in	Table	5‐20.	

Table 5‐20. Proposed PM/PM10/PM2.5BACT Emission Limits

Emission Unit BACT Emission Limit BACT Basis BACT Control

Technologies

Drillship	Main	Diesel	Engines		

(DR‐ME‐01	thru	DR‐ME‐06)	

0.4	g/kW‐hr	for	

engine	loads	50%	and	

above	and	1.97	lbs/hr	

for	engine	loads	less	

than	50%	

June	2014	

BlackHawk	Source	

Test	Results	and	

Hybrid	BACT	

Approach	technical	

Memorandum		

NSPS	IIII	standards,	LNE	

design	including	

Turbocharger	with	

Aftercooler	and	High	Fuel	

Pressure	Injection,	ULSD	

and	Good	Combustion	

Practices	

Drillship	Main	Diesel	Engines		

(DR‐ME‐07	thru	DR‐ME‐08)	

0.4	g/kW‐hr	for	

engine	loads	50%	and	

above	and	3.94	lbs/hr	

for	engine	loads	less	

than	50%	

June	2014	

BlackHawk	Source	

Test	Results	and	

Hybrid	BACT	

Approach	technical	

Memorandum		

NSPS	IIII	standards,	LNE	

design	including	

Turbocharger	with	

Aftercooler	and	High	Fuel	

Pressure	Injection,	ULSD	

and	Good	Combustion	

Practices	

Drillship	Emergency	Diesel	

Engine	(DR‐GE‐01)	

‐‐ AP‐42,	Chapter	3,	

Table	3.4‐1	

EPA	Tier	2,	LNE	design,	

ULSD	and	Good	

Combustion	Practices	

Air	Compressor	Diesel	Engine	

(DR‐AC‐01)	

‐‐ 40	CFR	94	EPA	Tier	

3	Standard	

Use	of	ULSD,	EPA	Tier	3

Standard,	Good	

Combustion	Practices	

Third	Party	Engines	(DR‐TP‐01	

through	DR‐TP‐11	and	DR‐TP‐17	

through	DR‐TP‐21)	

‐‐ 40	CFR	89	EPA	Tier	

2	Standard	

40	CFR	89	EPA	Tier	2	

Standard	and	LNE	design	

Third	Party	Well	Evaluation	

Engines	(DR‐TP‐12	through	DR‐

TP‐16)	

‐‐ AP‐42,	Chapter	3,	

Table	3.3‐1	

Good	Combustion	

Practices	

Stimulation	Vessel	Pumps	(SV‐

PE‐01	thru	SV‐PE‐08)	

‐‐ AP‐42,	Chapter	3,	

Table	3.4‐1	

Good	Combustion	

Practices	

Flowback	Boiler	(DR‐WC‐05)	 ‐‐ AP‐42,	Chapter	1,	

Table	1.3‐1	

Good	Combustion	

Practices	

Boom	Flare	(DR‐WC‐06)	 ‐‐ AP‐42,	Chapter	1,	

Table	1.4‐2	

Compliance	with	40	CFR	

60.18	and	Good	

Combustion	Practices	

Cement	and	Mud	Mixing	

Operations	(DR‐DC‐01	thru		

DR‐DC‐03)	

‐‐ AP‐42,	Chapter	11,	

Table	11.12‐2	

Dust	Collectors

Painting	Operations	(DR‐PO‐01)	 ‐‐ Paint	Composition Best	Management	

Practices	

Welding	Operations	(DR‐WO‐01)	 ‐‐ AP‐42,	Chapter	12,	

Table	12.19‐1	

Best	Management	

Practices	

	 	
Anadarko Petroleum Corporation| Diamond BlackHornet EGOM PSD/Title V Permit Application 138 

Trinity Consultants 

A	summary	of	the	proposed	GHG	BACT	emission	limitation	for	each	source	associated	with	the	project	

is	provided	below	in	Table	5‐22.	

Table 5‐22. Proposed CO2e BACT Emission Limits

Emission Unit BACT Emission

Limit BACT Basis BACT Control Technologies

Drillship	Main		Engines		

(DR‐ME‐01	thru	DR‐ME‐06)	

837	g/kW‐hr	for	

engine	loads	50%	

and	above	and	

4,149	lbs/hr	for	

engine	loads	less	

than	50%	

June	2014	

BlackHawk	

Source	Test	

Results	and	

Hybrid	BACT	

Approach	

technical	

Memorandum		

LNE	Design	with	Turbocharger	

with	Aftercooler	&	High	

Injection	Pressure,	Optimized	

Supercharger	with	Miller	

Cycle,	Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Drillship	Main		Engines		

(DR‐ME‐07	thru	DR‐ME‐08)	

837	g/kW‐hr	for	

engine	loads	50%	

and	above	and	

8,299	lbs/hr	for	

engine	loads	less	

than	50%	

June	2014	

BlackHawk	

Source	Test	

Results	and	

Hybrid	BACT	

Approach	

technical	

Memorandum		

LNE	Design	with	Turbocharger	

with	Aftercooler	&	High	

Injection	Pressure,	Optimized	

Supercharger	with	Miller	

Cycle,	Good	combustion	and	

manufacturer	recommended	

maintenance	practices	

Drillship	Emergency	

Generators	(DR‐GE‐01)	

‐‐ 40	CFR	98	

Subpart	C	

Turbocharger	with	Aftercooler	

&	High	Injection	Pressure,				

Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Emergency	Air	Compressor		

Engine	(DR‐AC‐01)	

‐‐ 40	CFR	98	

Subpart	C	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Third	Party	Engines		 ‐‐ 40	CFR	98	

Subpart	C	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Stimulation	Vessel	Pumps	(SV‐

PE‐01	thru	SV‐PE‐07)	

‐‐ 40	CFR	98	

Subpart	C	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Flowback	Boiler	(DR‐TP‐22)	 ‐‐ 40	CFR	98	

Subpart	C	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Boom	Flare	(DR‐TP‐23)	 ‐‐ 40	CFR	98	

Subpart	C	

Good	combustion	and	

manufacturer	recommended	

maintenance	practices		

Mud	degasser	Vent	(DR‐VG‐01)	 ‐‐ 40	CFR	98	

Subpart	C	

Best	management	practices	

and	manufacturer	

recommended	maintenance	

practices	
Economic Parameters Factors and Reference

Equipment Life (n), year Term of Anadarko lease [1] 5

Annual Interest Rate (I) Estimation [2] 7%

Consumer Price Index, CPI CPI to convert 2009 USD to 2013 USD [3] 1.09

Consumer Price Index, CPI CPI to convert 1998 USD to 2013 USD [3] 1.43

Total Direct Costs (TDC) Factor and reference Cost

Purchased Equipment Cost

SCR Equipment Cost (A) Equipment for 8 SCRs [4] $2,580,000

Instrumentation (Instr) 0.1A [5] $258,000

Sales Tax (ST) 0.03A [5] $77,400

Freight (Fr) 0.05A [5] $129,000.00

B= A + Instr + ST + Fr $3,044,400

Direct Installation Cost (DI)

Foundations and Support (F&S) 0.08 B [6] $243,552

Total Purchased Equipment Installation (Install)

[4] Per phone call with vendor, up to 15% discount in unit installation cost is applied for

installation of eight units. $310,000 per unit installation. Hence, total installation for 8 units = 

(1-0.15)*310,000*8 $2,108,000

Installation Cost at Dock $495,000/day for 25 days [7],[4] $12,375,000

Daily Spread Rate Above Rig Cost (spr) $136,753/day for 25 days and 9% increase to adjust 2009 rate to 2013 [8] $3,726,519

Electrical (Electric) 0.04B [6] $121,776

Piping (Pipe) 0.02B [6] $60,888

Insulation for Ductwork (Insul) 0.01B [6] $30,444

Painting (Paint) 0.01B [6] $30,444

DI = F&S + Install + Dock +spr+ electric + Pipe + Insul + Paint $18,696,623

Total Direct Cost (TDC) = B + DI $21,741,023

Indirect Costs (IC)

Construction Expenses (CE) 0.05 B [6] $152,220

Engineering and Supervision (E&S) 0.1 B [6] $304,440

Contractor Fee (Contract) 0.1 B [6] $304,440

Startup (SU) 0.02 B [6] $60,888

Total Indirect Costs (TIC) = CE + E&S + Contract + SU $821,988

Total Capital Investment (TCI) TCI = TDC + TIC $22,563,011

Direct Annual Costs (DAC) Factor and reference Cost

Operating Labor (L) 0.5 hr/8 hr shift * $12.95/hr * 200 days *3 shift/day *CPI for 1998 [9] $5,556

Supervisory Labor (S) 0.15L [9] $833

Maintenance (M) 0.015 * TCI [10] $338,445

Urea cost (U) 20 g/KW-hr of Urea @ $(0.85*3)/gal urea [11] $881,840

Catalyst Replacement (Cat) Assumed one replacement over 5-year duration. Assumed catalyst cost is 50% of equipment co $1,290,000

Utility (electricity cost, E) 0.059 $/kW-hr * engine rating (kW) * engine load % * Operating hours * 0.5% [9] $25,488

DAC= L + S+ M + U+ Cat + E $2,542,162

Indirect Annual Costs (IAC)

Overhead (O) 0.6 (L+S + M) [9] $206,900

Administrative Charges (A) 2% of TCI [9] $451,260

Property Taxes (P) 1% of TCI [9] $225,630

insurance (Ins) 1% of TCI [9] $225,630

Capital Recovery Factor, CRF (i * (1 + i)^n) / ((1 + i)^n - 1) [12] 0.24389

Capital recovery (CR) CRF * [TCI -1.08(cat.cost)] [9] $5,163,120

IAC = O + A + P + Ins + CR $6,272,541

Total Annual Cost (TAC) TAC = DAC + IAC $8,814,702

NOx factor before SCR, g/kW-hr IMO Tier II (NOx) 10.57

NOx factor after SCR, g/kW-hr [13] 2

SCR NOx Removal Efficiency, eff% 100 - (post control EF / pre control EF*100) [14] 81%

Average Annual Power Requirement, kW Based on application [15] 86,400,000 

NOx emissions without SCR, tpy Refer to Emission Calculations in Appendix B 1,006.67

NOx emissions with SCR, tpy emission without SCR * (1-eff%) 190.48

NOx reduced, tpy 816.19

Cost Effectiveness of SCR TAC/NOx reduced $10,800

Drillship Main Engines - HHI 9H32/40V and 18H32/40V 

DESIGN CONDITIONS

TOTAL CAPITAL INVESTMENT (TCI)

TOTAL ANNUAL COSTS

NOx REDUCTION EFFECTIVENESS

EPN: DR-ME-01 thru DR-ME-08

[15] Annual emissions were estimated based on the annual power output requirements for the drillship.

Control Cost Analysis for Selective Catalyst Reduction (SCR) Installation

[1] Anadarko holds the lease for five years for this drillship.

[2] Estimated using guidance from EPA AIR POLLUTION CONTROL COST MANUAL , Sixth Edition, EPA/452/B-02-001, January 2002..

[3] http://www.bls.gov/data/inflation_calculator.htm 

[13] Based on the vendor (Wartsila) guarantee for post-control emission factor of 2 g/kW-hr. The vendor guarantee is provided in Appendix E-2.

[4] Based on budgetary proposal provided by Wartsila, dated 8/27/2013. The amount quoted in the proposal was converted from Euros ( €) to Dollars ($) using a factor of 1.29 (per exchange rate on 

8/22/2013). The proposal is provided in Appendix E. Installation time for one SCR is 14 to 25 days. Hence, it is conservatively assumed that 8 SCRs will be installed in 8 days.

[9] Based on example shown on page 2-45 of Section 3.2, Chapter 2 of EPA AIR POLLUTION CONTROL COST MANUAL, Sixth Edition, 

EPA/452/B-02-001 , January 2002.

[10] Based on equation 2.46 shown on page 2-45 of Section 4.2, Chapter 2 of EPA AIR POLLUTION CONTROL COST MANUAL, Sixth Edition, 

EPA/452/B-02-001 , January 2002.

[11] The cost of urea is based on example shown on page 1-39 of Section 4.2, Chapter 1 of EPA AIR POLLUTION CONTROL COST MANUAL, Sixth Edition, EPA/452/B-02-001, January 2002. 

The price of urea has more than tripled since 2002. Hence, the cost of urea provided in the air pollution cost manual is multiplied by 3. Source: 

http://www.indexmundi.com/commodities/?commodity=urea&months=180

[12] Based on equation 2.55 shown on page 2-49 of Section 4.2, Chapter 2 of EPA AIR POLLUTION CONTROL COST MANUAL, Sixth Edition, 

EPA/452/B-02-001 , January 2002 as shown below.

[5] Based on general cost ranges as presented on page 2-27 of Section 1, Chapter 2 of EPA AIR POLLUTION CONTROL COST MANUAL, Sixth Edition, EPA/452/B-02-001 , January 2002.

[6] Based on factors used on page 1-22 of Section 3.1, Chapter 1 of EPA AIR POLLUTION CONTROL COST MANUAL, Sixth Edition, EPA/452/B-02-001 , January 2002.

[7] Based on Personal Communication, E-mail from Ms.Sara Carlson (Anadarko) to Mr. Rahul Pendse (Trinity), 8/23/13.

[8] Based on budgetary proposal provided on 11/4/2009. However, "Rig Contingencies" and "Project Contingencies" costs are not included as part of "Daily Spread Rate Above Rig Cost" for control 

cost analysis purposes. The proposal is provided in Appendix E.

[14] The control efficiency is determined based on pre-control emission factor of 10.57 g/kW-hr and the vendor guarantee for post-control emission factor of 2 g/kW-hr. The vendor guarantee is 

provided in Appendix E-2.

Anadarko Petroleum Corporation

Diamond Blackhornet EGOM PSD/Title V Permit Application 1 of 1

Trinity Consultants

131901.0021

SCR Cost Final
Anadarko Petroleum Corporation 2-1 Trinity Consultants 

 

2. REPRESENTATION OF MODELED SOURCES 

2.1. EMISSIONS SOURCES AND POTENTIAL TO EMIT 

The	sources	of	emissions	for	the	proposed	project	primarily	consist	of	internal	combustion	engines,	

painting	operation,	welding	operation,	dust	collectors,	mud‐degassing,	water	blasting	operation,	

miscellaneous	equipment,	and	fuel	storage	tanks.		For	the	support	vessels,	the	only	emission	sources	

are	internal	combustion	engines	and	fuel	storage	tanks.		Anadarko	will	use	the	“worst‐case”	

potential‐to‐emit	scenario	among	all	the	operating	scenario	discussed	in	the	Section	3	for	assessing	

air	quality	impacts	to	demonstrate	compliance	with	the	Class	I	Increments,	AQRVs	and	Class	II	SILs.		

This	will	give	Anadarko	the	flexibility	to	drill	and	operate	at	any	location	within	the	worse‐case	lease	

block	(nearest	to	respective	Class	I	and	Class	II	areas)	or	at	any	other	location	further	away	from	a	

Class	I	area	within	the	“wedge.”		

As	described	in	the	Section	3	of	this	report,	the	project	includes	six	possible	operating	scenario	or	an	

equivalent	combination	thereof.		Refer	to	Section	3	for	the	details	of	each	operating	scenario	and	the	

proposed	air	emission	sources	and	their	operating	conditions	associated	with	it.			

Among	all	the	support	vessels,	the	supply	boats	will	be	very	frequently	used.		All	other	support	

vessels	such	as	well	evaluation	vessels,	stimulation	vessels,	tugs,	and	barges,	will	be	used	in	a	

specific	operating	scenario.		Moreover,	the	supply	boats	generate	higher	emissions	when	they	are	in	

transit	arriving/departing	from	the	drill	ship	than	emissions	generated	when	the	supply	boats	are	

located	adjacent	to	the	drill	ship	during	loading/unloading	operations.		The	other	support	vessels	

generally	generate	more	emissions	during	performing	operations	in	the	vicinity	of	the	drill	ship	

when	compared	against	the	emissions	generated	during	their	transit.		Hence,	placing	a	supply	boat	

source	at	a	distance	of	25	nautical	miles	from	the	worst‐case	drillship	location	in	the	direction	of	

nearest	receptor	should	represent	the	worst	case	support	vessel	emission	scenario	for	air	

dispersion	modeling	analysis.		The	worst‐case	support	vessels	emissions	(i.e.,	supply	boats	with	

highest	PTE)	were	utilized	for	this	modeling	analysis.			

For	performing	air	dispersion	analysis,	maximum	total	emissions	(i.e.,	sum	of	the	drillship	and	

supply	boat	emissions)	for	each	pollutant	were	considered.		Table	2‐1	compares	the	emissions	from	

different	operational	scenarios	and	modeled	emission	rates.		The	modeled	emission	rates	represent	

the	worst	case	combination	among	the	different	operating	scenario.			

Table 2‐1.		Emission Rates Comparison		

Pollutant Source Emission Rates (lb/hr)

Model

ed		

Gas

Flowback

Scenario

Oil

Flowback

Scenario

Stimulat

ion

Vessel

Scenario

General

Well

Complet

ion

Scenario		

Well

Evaluatio

n Vessel

Scenario

Drilling		

NOx

Supply	

Boats	 84	 42 42 42 84 42 84

Drill	

ship	 540	 421 509	 572	 510	 569 531

Total 624 463 551 614 594 611 615
Anadarko Petroleum Corporation 2-2 Trinity Consultants 

 

Pollutant Source Emission Rates (lb/hr)

Model

ed		

Gas

Flowback

Scenario

Oil

Flowback

Scenario

Stimulat

ion

Vessel

Scenario

General

Well

Complet

ion

Scenario		

Well

Evaluatio

n Vessel

Scenario

Drilling		

PM10

Supply	

Boats	 3	 1 1 1 2 1 2

Drill	

ship	 27	 29 29 19 20 20 21

Total 30 30 30 20 22 21 23

SO2

Supply	

Boats	 0.5	 0.04	 0.04	 0.04	 0.08	 0.04	 0.08	

Drill	

ship	 1.5	 1.64	 1.25	 0.36	 0.33	 0.34	 0.33	

Total 2 1.68 1.29 0.4 0.41 0.38 0.41

CO

Supply	

Boats	 100	 29	 29	 29	 58	 29	 58	

Drill	

ship	 1,000	 1,004	 696	 180	 161	 168	 166	

Total	 1,100	 1,033	 775	 209	 219	 197	 224	

2.2. Q/D ANALYSIS 

Anadarko	has	completed	a	Q/d	calculation	to	assess	potential	impacts	of	the	proposed	drilling	and	

well	completion	operations	on	the	nearest	Class	I	area.		The	Q/d	analysis	compares	the	ratio	of	the	

sum	of	proposed	annualized	maximum	24‐hour	emission	rates	of	all	visibility	impairing	pollutants	

(in	tons	per	year)	and	the	distance	to	the	nearest	Class	I	area	(in	km)	to	a	threshold	value	of	10,	as	

determined	by	the	FLM.		The	“Q”	is	the	combined	emissions	increase	from	a	source	of	SO2,	NOX,	

PM10,	and	H2SO4	in	tons	per	year	(tpy)	based	on	the	maximum	hourly	emissions	and	“d”	is	the	

nearest	distance	to	a	Class	I	area	in	km	from	the	source.	11		Emissions	from	sources	that	operate	

intermittently	or	seasonally	will	be	adjusted	to	account	for	year	round	operation.			The	emissions	

represented	in	the	Q/d	analysis	are	conservatively	based	on	the	highest	emissions	between	the	

drilling	and	well	completion	operations.		Based	on	the	results,	a	Class	I	area	AQRV	analysis	is	

required	for	the	project	because	the	Q/d	ratio	for	the	proposed	source	is	greater	than	10.		A	copy	of	

the	Q/d	analysis	is	provided	in	Appendix	F.

2.3. MODELED PARAMETERS 

As	mentioned	previously,	Anadarko	is	requesting	the	flexibility	to	drill	and	complete	one	or	more	

wells	in	any	of	the	lease	blocks	within	the	“wedge”	while	complying	with	any	operational	and	

emission	limitations	prescribed	in	the	air	permits	that	will	be	issued.		Therefore,	the	Class	I	area	

modeling	analysis	was	performed	for	each	Class	I	area	with	the	drillship	assumed	to	be	located	at	

the	closest	point	within	the	“wedge”	of	the	project	(worst‐case	location)	to	the	Class	I	areas.			

For	Breton‐NWR,	the	NW	corner	of	the	Desoto	Canyon	lease	block	141	was	determined	to	be	the	

worst‐case	drillship	location.		For	St.	Marks	NWR	and	Bradwell	Bay	Wilderness,	the	NE	corner	of	the	

																																																															

11 U.S. Forest Service – Air Quality Program, National Park Service – Air Resources Division, U.S. Fish and Wildlife 

Service – Air Quality Branch, Phase I Report of the Federal Land Managers’ Air Quality Related Values Workgroup 

(FLAG)--Revised, 2010. 
Anadarko Petroleum Corporation

Potential to Emit (PTE)

lb/hr lb/day ton/yr lb/hr lb/day ton/yr lb/hr lb/day ton/yr lb/hr lb/day ton/yr lb/hr lb/day 

PM 30 721 43 32 770 58 22 532 44 22 533 45 23 545 

PM10 30 716 43 30 718 56 19 456 40 22 520 44 21 499 

PM2.5 30 716 43 30 716 56 19 453 43 22 523 44 21 500 

NOx 463 11119 1120 551 13218 1418 614 14733 1162 594 14244 1208 611 14670 

CO 1033 24793 455 775 18608 540 209 5009 405 219 5260 458 197 4718 

VOC 394 9462 162 287 6884 171 61 1460 128 69 1660 132 64 1547 

Pb 3.69E‐03 8.86E‐02 1.34E‐02 5.49E‐03 1.32E‐01 1.73E‐02 7.16E‐03 1.72E‐01 1.40E‐02 7.34E‐03 1.76E‐01 1.51E‐02 6.86E‐03 1.65E‐01 1

SO2 1.68E+00 4.04E+01 8.49E‐01 1.29E+00 3.10E+01 1.02E+00 3.95E‐01 9.49E+00 7.74E‐01 4.06E‐01 9.74E+00 8.34E‐01 3.79E‐01 9.10E+00 8

H2SO4 6.24E‐03 1.50E‐01 2.32E‐02 9.36E‐03 2.25E‐01 2.98E‐02 1.24E‐02 2.96E‐01 2.42E‐02 1.27E‐02 3.04E‐01 2.61E‐02 1.18E‐02 2.84E‐01 2

GHG 3.16E+05 7.59E+06 1.10E+05 2.29E+05 5.50E+06 1.25E+05 4.51E+04 1.08E+06 9.24E+04 4.80E+04 1.15E+06 9.81E+04 4.44E+04 1.07E+06 1

HAPs 12 280 13 10 246 13 7 174 12 7 175 12 7 174 

Note:

The	Potential	To	Emit	calculation	includes	the	sum	of	emissions	from	the	following	emission	sources:

*Drillship	Main	Propulsion	Engines	&	Emergency	Electrical	Generator*Cement	and	Mud	Mixing	Dust	collectors*Mud	Degasser	Vent*Painting	Operations*Welding	Operations*Third	Party	Well	Evaluation	Engines*Flowback	Boiler*Boomflare*Condensate	Tanks*Support	Vessels

*Drillship	Diesel	and	Jet	Fuel	Tanks*Drillship	Fugitive	Components

Pollutant Gas Flowback Oil Flowback Stimulation Vessel Completion Well Evaluation Vess

Scenario 1 Scenario 2 Scenario 3 Scenario 4 Scenario 5

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

Matrix Calculator

Units/hr Units/day Units/year Units/hr Units/day Units/year Units/hr Units/day Units/year Units/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01

m3 2.3 55 18438 2.5 59 18438 3.2 78 18438 4.7 

Emergency	Air	Compressor	 DR‐AC‐01 hours 0.5 0.5 100 0.5 0.5 100 0.5 0.5 100 0.5 Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours* 1.0 1 100 1.0 1.0 100 1.00 1.0 100 1.0 Fast	Rescue	Craft DR‐FR‐01 hours 1.0 1 100 1.0 1.0 100 1.00 1.0 100 1.0 Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours* 1.0 24 4800 1.0 24 4800 1.0 24 4800 1.0 Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours* 1.0 24 4800 1.0 24 4800 1.0 24 4800 1.0 Drillship	Fugitive	Emissions DR‐FE‐01 hours 1.0 24 4800 1.0 24 4800 1.0 24 4800 1.0 Mud	Degasser	Vent DR‐VG‐01 hours 1.0 24 4800 1.0 24 4800 1.0 24 4800 1.0 Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 2.1 50 6500 2.1 50 6500 2.1 50 6500 2.1 Welding	Operations DR‐WE‐01 lbs 3.3 80 16000 3.3 80 16000 3.3 80 16000 3.3 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 1.0 24 4800 1.0 24 4800 1.0 24 4800 1.0 EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 1.0 24 4800 1.0 24 4800 1.0 24 4800 1.0 Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0 0 0 0 0 0 0 0 0 0 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0 0 0 0 0 0 0 0 0 0 

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0 0 0 0 0 0 0 0 0 0 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0 0 0 0 0 0 0 0 0 0 

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 0 0 0 0 0 0 0 0 0 1 	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 0 0 0 0 0 0 1 24 4800 1 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 0 0 0 0 0 0 0 0 0 1 Flowback	Boiler DR‐TP‐22 MMBtu 8.0 192 1152 8.0 192 1152 0 0 0 0 Boom	Flare DR‐TP‐23 MMscf 2.5 60 360 1.7 40 240 0 0 0 0 EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 0 0 0 0 0 0 0 0 0 1 EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 0 0 0 0 0 0 0 0 0 1 EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 0 0 0 0 0 0 0 0 0 1 Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 1 24 0 1 24 0 0 0 0 0 Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 9 225 4725 0 Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 1 24 4800 0 0 0 0 Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 5 125 25000 0 0 0 0 

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 Supply	Boats Various bbl 4.2 100 20000 4.2 100 20000 4 100 20000 8 

						*	Hours	per	unit.

Gas	Flowback Oil	Flowback Stimulation	Vessel 

Scenario 1 Scenario 2 Scenario 3 

Air Emission Sources Unit EPN

Drill Ship

Temporary Third Party Engines

Support Vessels

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

NOx Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 250 6,005 1,007 268 6,442 1,007 355 8,517 1,007 510 

Emergency	Air	Compressor	 DR‐AC‐01 hours 0.1 0.1 0.01 0.1 0.1 0.01 0.1 0.1 0.01 0.1 

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 7.6 7.6 0.4 7.6 7.6 0.4 7.6 7.6 0.4 7.6 Fast	Rescue	Craft DR‐FR‐01 hours 0.7 0.7 0.0 0.7 0.7 0.0 0.7 0.7 0.0 0.7 Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 0 0 0 0 0 0 0000

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 0 0 0 0 0 0 0000

Drillship	Fugitive	Emissions DR‐FE‐01 hours 0 0 0 0 0 0 0000

Mud	Degasser	Vent DR‐VG‐01 hours 0 0 0 0 0 0 0000

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 000 0 00 0 0 0 0 Welding	Operations DR‐WE‐01 lbs 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 3 78 7.82 3 78 7.82 3 78 7.82 3 EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 1 33 3.28 1 33 3.28 1 33 3.28 1 Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 0 0 0 0 0 0 0 0 0 1 	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 0 0 0 0 0 0 1 33 3.28 1 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 0 0 0 0 0 0 0 0 0 7 Flowback	Boiler DR‐TP‐22 MMBtu 1 27 0.08 1 27 0.08 0000

Boom	Flare DR‐TP‐23 MMscf 170 4078 12.24 113 2719 8.16 0000

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 0 0 0 0 0 0 0 0 0 9 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 0 0 0 0 0 0 0 0 0 9 EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 0 0 0 0 0 0 0 0 0 7 Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 0 0 0 0 0 0 0000

Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 217 5209 54.70 0Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 42 1018 101.78 0000

Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 84 2004 200.41 0000

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 Supply	Boats Various bbl 42 1008 101 42 1008 101 42 1008 101 84 

Total 463 11119 1120 551 13218 1418 614 14733 1162 594 

Air Emission Sources Unit

Support Vessels

Third Party Engines

EPN

Drill Ship

Scenario 2 Scenario 3 

Gas	Flowback Oil	Flowback Stimulation	Vessel 

Scenario 1

NOx NOx NOx 

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

PM Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 9 227 38 10 244 38 13 322 38 19 

Emergency	Air	Compressor	 DR‐AC‐01 hours 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 Fast	Rescue	Craft DR‐FR‐01 hours 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 00000000 0 0

Drillship	Fugitive	Emissions DR‐FE‐01 hours 00000000 0 0

Mud	Degasser	Vent DR‐VG‐01 hours 00000000 0 0

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 

Welding	Operations DR‐WE‐01 lbs 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 

EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 

Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 00000000 0 6.22E‐02 

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 000000 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 00000000 0 1.98E‐01 

Flowback	Boiler DR‐TP‐22 MMBtu 1.89E‐01 4.53E+00 1.36E‐02 1.89E‐01 4.53E+00 1.36E‐02 0 0 0 0 

Boom	Flare DR‐TP‐23 MMscf 1.86E+01 4.47E+02 1.34E+00 1.24E+01 2.98E+02 8.94E‐01 0 0 0 0 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 00000000 0 2.83E‐01 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 00000000 0 2.83E‐01 

EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 00000000 0 1.98E‐01 

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 00000000 0 0

Stimulation	Vessel	Engines Various bbl 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 6.98E+00 1.68E+02 1.76E+00 0.00E+00 

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0.00E+00 0.00E+00 0.00E+00 3.01E+00 7.22E+01 7.22E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02

bbl 0.00E+00 0.00E+00 0.00E+00 4.53E+00 1.09E+02 1.09E+01 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

Well	Evaluation	Vessel Various bbl 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 

Supply	Boats Various bbl 1.17E+00 2.81E+01 2.81E+00 1.17E+00 2.81E+01 0.00E+00 1.17E+00 2.81E+01 2.81E+00 2.34E+00 

30 721 43 32 770 58 22 532 44 22 

Scenario 1 Scenario 2 Scenario 3

Air Emission Sources EPN Unit

Gas	Flowback Oil	Flowback Stimulation	Vessel 

PM PM PM

Drillship

Support Vessels

Third Party Engines

Total

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

PM10 Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 9 227 38 10 244 38 13 322 38 1

Emergency	Air	Compressor	 DR‐AC‐01 hours 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 4.68E‐03 4.68E‐04 4.68E

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 5.41E‐01 2.71E‐02 2.71E

Fast	Rescue	Craft DR‐FR‐01 hours 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 5.42E‐02 2.71E‐03 2.71EDust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 3.56E+00 3.56E‐01 0

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 0 0 00000000

Drillship	Fugitive	Emissions DR‐FE‐01 hours 0 0 00000000Mud	Degasser	Vent DR‐VG‐01 hours 0 0 00000000Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 6.26E+00 4.07E‐01 2.61E

Welding	Operations DR‐WE‐01 lbs 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 4.56E+00 4.56E‐01 1.90E

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 2.37E+00 2.37E‐01 9.88E

EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 1.49E+00 1.49E‐01 6.22EThird	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0.00E+00 0 00000000

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0.00E+00 0 00000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0.00E+00 0 00000000

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0.00E+00 0 00000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 0.00E+00 0 0000000 6.22E

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 0.00E+00 0 0000 6.22E‐02 1.49E+00 1.49E‐01 6.22E

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 0.00E+00 0 0000000 1.98E

Flowback	Boiler DR‐TP‐22 MMBtu 1.89E‐01 4.53E+00 1.36E‐02 1.89E‐01 4.53E+00 1.36E‐02 0000Boom	Flare DR‐TP‐23 MMscf 1.86E+01 4.47E+02 1.34E+00 1.24E+01 2.98E+02 8.94E‐01 0000EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 0.00E+00 0 0000000 1.62E

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 0.00E+00 0 0000000 1.62E

EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 0 0 0000000 1.98E

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 0 0 00000000

Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 4.00E+00 9.60E+01 1.01E+00 0

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 3.01E+00 7.22E+01 7.22E+00 0000

Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 2.60E+00 6.23E+01 6.23E+00 0000

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 9.71E‐01 2.33E+01 2.33E+00 9.71E‐01 2.33E+01 2.33E+00 9.71E‐01 2.33E+01 0.00E+00 1.94E

Total 29.9 716 43.0 29.9 718 56.0 19.0 456 40.3 21

Drillship

Air Emission Sources EPN Unit

Third Party Engines

Support Vessels

Gas	Flowback Oil	Flowback Stimulation	Vessel 

PM10 PM10 PM10 

Scenario 1 Scenario 2 Scenario 3 

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

PM2.5 Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 9 227 38 10 244 38 13 322 38 19 

Emergency	Air	Compressor	 DR‐AC‐01 hours 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 4.68E‐03 4.68E‐04 4.68E‐03 

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 5.41E‐01 2.71E‐02 5.41E‐01 

Fast	Rescue	Craft DR‐FR‐01 hours 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 5.42E‐02 2.71E‐03 5.42E‐02 

Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 3.56E+00 3.56E‐01 1.49E‐01 

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 0000000000

Drillship	Fugitive	Emissions DR‐FE‐01 hours 0000000000

Mud	Degasser	Vent DR‐VG‐01 hours 0000000000

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 6.26E+00 4.07E‐01 2.61E‐01 

Welding	Operations DR‐WE‐01 lbs 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 4.56E+00 4.56E‐01 1.90E‐01 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 2.37E+00 2.37E‐01 9.88E‐02 

EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 

Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0000000000

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0000000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0000000000	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0000000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 000000000 6.22E‐02 

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 000000 6.22E‐02 1.49E+00 1.49E‐01 6.22E‐02 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 000000000 1.98E‐01 

Flowback	Boiler DR‐TP‐22 MMBtu 1.89E‐01 4.53E+00 1.36E‐02 1.89E‐01 4.53E+00 1.36E‐02 0000Boom	Flare DR‐TP‐23 MMscf 1.86E+01 4.47E+02 1.34E+00 1.24E+01 2.98E+02 8.94E‐01 0000

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 000000000 1.57E‐01 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 000000000 1.57E‐01 EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 000000000 1.98E‐01 

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 0000000000Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 3.88E+00 9.31E+01 9.78E‐01 0

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 3.01E+00 7.22E+01 7.22E+00 0000Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 2.52E+00 6.04E+01 6.04E+00 0000

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 9.44E‐01 2.27E+01 2.27E+00 9.44E‐01 2.27E+01 2.27E+00 9.44E‐01 2.27E+01 2.27E+00 1.89E+00 

29.8 716 43 29.8 716 56 18.9 453 43 21.8 

Scenario 1 Scenario 2 Scenario 3 

Gas	Flowback Oil	Flowback Stimulation	Vessel 

PM2.5 PM2.5 PM2.5 

Third Party Engines

Total

Air Emission Sources Unit EPN

Drillship

Support Vessels

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

CO Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01

m3 79 1901 319 85 2039 319 112 2696 319 161 

Emergency	Air	Compressor	 DR‐AC‐01 hours 8.58E‐02 8.58E‐02 8.58E‐03 8.58E‐02 8.58E‐02 8.58E‐03 8.58E‐02 8.58E‐02 8.58E‐03 8.58E‐02 

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 1.64E+00 1.64E+00 8.22E‐02 1.64E+00 1.64E+00 8.22E‐02 1.64E+00 1.64E+00 8.22E‐02 1.64E+00 

Fast	Rescue	Craft DR‐FR‐01 hours 4.97E‐01 4.97E‐01 2.49E‐02 4.97E‐01 4.97E‐01 2.49E‐02 4.97E‐01 4.97E‐01 2.49E‐02 4.97E‐01 

Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 0000000000Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 0000000000Drillship	Fugitive	Emissions DR‐FE‐01 hours 0000000000Mud	Degasser	Vent DR‐VG‐01 hours 0000000000Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 0000000000Welding	Operations DR‐WE‐01 lbs 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 1.73E+00 4.15E+01 4.15E+00 1.73E+00 4.15E+01 4.15E+00 1.73E+00 4.15E+01 4.15E+00 1.73E+00 

EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 1.04E+00 2.49E+01 2.49E+00 1.04E+00 2.49E+01 2.49E+00 1.04E+00 2.49E+01 2.49E+00 1.04E+00 

Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0000000000

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0000000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0000000000

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0000000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 000000000 1.04E+00 

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 000000 1.04E+00 2.49E+01 2.49E+00 1.04E+00 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 000000000 3.46E+00 

Flowback	Boiler DR‐TP‐22 MMBtu 2.86E‐01 6.86E+00 2.06E‐02 2.86E‐01 6.86E+00 2.06E‐02 0000

Boom	Flare DR‐TP‐23 MMscf 9.25E+02 2.22E+04 6.66E+01 6.16E+02 1.48E+04 4.44E+01 0000

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 000000000 4.95E+00 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 000000000 4.95E+00 

EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 000000000 3.46E+00 

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 0000000000Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 6.75E+01 1.62E+03 1.70E+01 0Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 9.14E+00 2.19E+02 2.19E+01 0000Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02

bbl 0 0 0 3.56E+01 8.54E+02 8.54E+01 0000

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 29 694 69 29 694 69 29 694 69 58 

1033 24793 455 775 18608 540 209 5009 405 219 

Support Vessels

Total

Air Emission Sources EPN Unit

Scenario 1 Scenario 2 Scenario 3 

Gas	Flowback Oil	Flowback Stimulation	Vessel 

CO CO CO 

Drillship

Third Party Engines

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

VOC Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 22 523 88 23 561 88 31 741 88 44 

Emergency	Air	Compressor	 DR‐AC‐01 hours 2.39E‐02 2.39E‐02 2.39E‐03 2.39E‐02 2.39E‐02 2.39E‐03 2.39E‐02 2.39E‐02 2.39E‐03 2.39E‐02 

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 6.18E‐01 6.18E‐01 3.09E‐02 6.18E‐01 6.18E‐01 3.09E‐02 6.18E‐01 6.18E‐01 3.09E‐02 6.18E‐01 Fast	Rescue	Craft DR‐FR‐01 hours 1.38E‐01 1.38E‐01 6.91E‐03 1.38E‐01 1.38E‐01 6.91E‐03 1.38E‐01 1.38E‐01 6.91E‐03 1.38E‐01 Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 0 0 0 0000000

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 0 0 6.93E‐01 0000000

Drillship	Fugitive	Emissions DR‐FE‐01 hours 1.08E‐02 2.60E‐01 2.60E‐02 1.08E‐02 2.60E‐01 2.60E‐02 1.08E‐02 2.60E‐01 2.60E‐02 1.08E‐02 Mud	Degasser	Vent DR‐VG‐01 hours 2.23E+00 5.36E+01 5.36E+00 2.23E+00 5.36E+01 5.36E+00 2.23E+00 5.36E+01 5.36E+00 2.23E+00 

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 1.82E+01 4.36E+02 2.84E+01 1.82E+01 4.36E+02 2.84E+01 1.82E+01 4.36E+02 2.84E+01 1.82E+01 

Welding	Operations DR‐WE‐01 lbs 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 7.54E‐01 1.81E+01 1.81E+00 7.54E‐01 1.81E+01 1.81E+00 7.54E‐01 1.81E+01 1.81E+00 7.54E‐01 EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 3.16E‐01 7.59E+00 7.59E‐01 3.16E‐01 7.59E+00 7.59E‐01 3.16E‐01 7.59E+00 7.59E‐01 3.16E‐01 Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0 0 0 0000000

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0 0 0 0000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0 0 0 0000000

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0 0 0 0000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 0 0 0 0000000

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 0 0 0 0 0 0 3.16E‐01 7.59E+00 7.59E‐01 3.16E‐01 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 0 0 0 000000 1.51E+00 

Flowback	Boiler DR‐TP‐22 MMbtu 1.14E‐02 2.74E‐01 8.23E‐04 1.14E‐02 2.74E‐01 8.23E‐04 0000

Boom	Flare DR‐TP‐23 MMscf 3.50E+02 8.40E+03 2.52E+01 2.33E+02 5.60E+03 1.68E+01 0000EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 0 0 0 000000 5.52E‐01 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 0 0 0 000000 5.52E‐01 EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 0 0 0 000000 1.51E+00 

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 0 0 9.65E+00 0 0 9.65E+00 0000Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 7.32E+00 1.76E+02 1.84E+00 0Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 3.44E+00 8.25E+01 8.25E+00 0000Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 4.15E+00 9.96E+01 9.96E+00 0000

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 2.19E+00 5.27E+01 5.27E+00 2.19E+00 5.27E+01 5.27E+00 2.19E+00 5.27E+01 5.27E+00 4.39E+00 

394 9462 162 287 6884 171 61 1460 128 69 

Scenario 1 Scenario 2 Scenario 3 S

Gas	Flowback Oil	Flowback Stimulation	Vessel C

VOC VOC VOC 

Third Party Engines

Total

Air Emission Sources Unit EPN

Drillship

Support Vessels

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

Pb Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 2.92E‐03 7.02E‐02 1.18E‐02 3.14E‐03 7.53E‐02 1.18E‐02 4.15E‐03 9.95E‐02 1.18E‐02 5.95E‐03 

Emergency	Air	Compressor	 DR‐AC‐01 hours 1.93E‐06 1.93E‐06 1.93E‐07 1.93E‐06 1.93E‐06 1.93E‐07 1.93E‐06 1.93E‐06 1.93E‐07 1.93E‐06 

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 4.99E‐05 4.99E‐05 2.50E‐06 4.99E‐05 4.99E‐05 2.50E‐06 4.99E‐05 4.99E‐05 2.50E‐06 4.99E‐05 

Fast	Rescue	Craft DR‐FR‐01 hours 1.12E‐05 1.12E‐05 5.58E‐07 1.12E‐05 1.12E‐05 5.58E‐07 1.12E‐05 1.12E‐05 5.58E‐07 1.12E‐05 

Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 00000000 0 0

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 00000000 0 0

Drillship	Fugitive	Emissions DR‐FE‐01 hours 00000000 0 0

Mud	Degasser	Vent DR‐VG‐01 hours 00000000 0 0

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 00000000 0 0

Welding	Operations DR‐WE‐01 lbs 0 0 0 0 0 0 0 0 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 6.09E‐05 1.46E‐03 1.46E‐04 6.09E‐05 1.46E‐03 1.46E‐04 6.09E‐05 1.46E‐03 1.46E‐04 6.09E‐05 EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 2.56E‐05 6.14E‐04 6.14E‐05 2.56E‐05 6.14E‐04 6.14E‐05 2.56E‐05 6.14E‐04 6.14E‐05 2.56E‐05 

Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 00000000 0 2.56E‐05 

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 000000 2.56E‐05 6.14E‐04 6.14E‐05 2.56E‐05 

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 00000000 0 1.22E‐04 

Flowback	Boiler DR‐TP‐22 MMbtu 7.20E‐05 1.73E‐03 5.18E‐06 7.20E‐05 1.73E‐03 5.18E‐06 0 0 0 0

Boom	Flare DR‐TP‐23 MMscf 00000000 0 0

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 00000000 0 1.75E‐04 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 00000000 0 1.75E‐04 

EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 00000000 0 1.22E‐04 

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 00000000 0 0

Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 2.32E‐03 5.56E‐02 5.84E‐04 0

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 2.78E‐04 6.66E‐03 6.66E‐04 0 0 0 0

Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 1.31E‐03 3.15E‐02 3.15E‐03 0 0 0 0

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 6.94E‐04 1.67E‐02 1.67E‐03 6.94E‐04 1.67E‐02 1.67E‐03 6.94E‐04 1.67E‐02 1.67E‐03 1.39E‐03 

3.69E‐03 8.86E‐02 1.34E‐02 5.49E‐03 1.32E‐01 1.73E‐02 7.16E‐03 1.72E‐01 1.40E‐02 7.34E‐03 

Air Emission Sources EPN Unit

Drillship

Third Party Engines

Scenario 2 Scenario 3 

Gas	Flowback Oil	Flowback Stimulation	Vessel 

Scenario 1

Pb Pb Pb 

Support Vessels

Total

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

GHG Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 1.99E+04 4.77E+05 7.99E+04 2.13E+04 5.12E+05 7.99E+04 2.82E+04 6.76E+05 7.99E+04 4.05E+04 

Emergency	Air	Compressor	 DR‐AC‐01 hours 11 11 1.09 11 11 1.09 11 11 1.09 11 Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 282 282 14.09 282 282 14.09 282 282 14.09 282 

Fast	Rescue	Craft DR‐FR‐01 hours 63 63 3.15 63 63 3.15 63 63 3.15 63 Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 0000000000

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 0000000000Drillship	Fugitive	Emissions DR‐FE‐01 hours 0000000000

Mud	Degasser	Vent DR‐VG‐01 hours 113 2714 271 113 2714 271 113 2714 271 113 

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 0000000000Welding	Operations DR‐WE‐01 lbs 0 0 0 0 0 0 0 0 0 0 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 348 8342 834 348 8342 834 348 8342 834 348 EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 144 3463 346 144 3463 346 144 3463 346 144 Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0000000000	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0000000000	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0000000000	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0000000000	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 000000000 1.44E+02 	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 000000 1.44E+02 3.46E+03 3.46E+02 1.44E+02 	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 000000 0.00E+00 0.00E+00 0.00E+00 6.95E+02 Flowback	Boiler DR‐TP‐22 MMbtu 5.45E+01 1.31E+03 3.93E+00 5.45E+01 1.31E+03 3.93E+00 0000Boom	Flare DR‐TP‐23 MMscf 2.92E+05 7.02E+06 2.11E+04 1.95E+05 4.68E+06 1.40E+04 0000

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 000000000 9.85E+02 

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 000000000 9.85E+02 

EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 000000000 6.95E+02 

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 0000000000Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 13068 313627 3293 0

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 1567 37600 3760 0000

Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 7410 177846 17785 0000

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 Supply	Boats Various bbl 3719 89264 8926 3719 89264 8926 3719 89264 8926 7439 

3.16E+05 7.59E+06 1.10E+05 2.29E+05 5.50E+06 1.25E+05 4.51E+04 1.08E+06 9.24E+04 4.80E+04 

Scenario 1 Scenario 2 Scenario 3

EPN

Gas	Flowback Oil	Flowback Stimulation	Vessel 

GHG GHG GHG 

Third Party Engines

Total

Air Emission Sources Unit

Drillship

Support Vessels

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

SO2 Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 1.62E‐01 3.88E+00 6.50E‐01 1.73E‐01 4.16E+00 6.50E‐01 2.29E‐01 5.50E+00 6.50E‐01 3.29E‐0

Emergency	Air	Compressor	 DR‐AC‐01 hours 1.06E‐04 1.06E‐04 1.06E‐05 1.06E‐04 1.06E‐04 1.06E‐05 1.06E‐04 1.06E‐04 1.06E‐05 1.06E‐0

Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 2.76E‐03 2.76E‐03 1.38E‐04 2.76E‐03 2.76E‐03 1.38E‐04 2.76E‐03 2.76E‐03 1.38E‐04 2.76E‐0

Fast	Rescue	Craft DR‐FR‐01 hours 6.17E‐04 6.17E‐04 3.08E‐05 6.17E‐04 6.17E‐04 3.08E‐05 6.17E‐04 6.17E‐04 3.08E‐05 6.17E‐0

Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 00000000 0 0

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 00000000 0 0

Drillship	Fugitive	Emissions DR‐FE‐01 hours 00000000 0 0

Mud	Degasser	Vent DR‐VG‐01 hours 00000000 0 0

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 00000000 0 0Welding	Operations DR‐WE‐01 lbs 0 0 0 0 0 0 0 0 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 3.36E‐03 8.08E‐02 8.08E‐03 3.36E‐03 8.08E‐02 8.08E‐03 3.36E‐03 8.08E‐02 8.08E‐03 3.36E‐0

EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 1.41E‐03 3.39E‐02 3.39E‐03 1.41E‐03 3.39E‐02 3.39E‐03 1.41E‐03 3.39E‐02 3.39E‐03 1.41E‐0Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 00000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 00000000 0 0	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 00000000 0 0	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 00000000 0 0	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 00000000 0 1.41E‐0	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 000000 1.41E‐03 3.39E‐02 3.39E‐03 1.41E‐0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 00000000 0 6.73E‐0

Flowback	Boiler DR‐TP‐22 MMbtu 1.22E‐02 2.92E‐01 8.76E‐04 1.22E‐02 2.92E‐01 8.76E‐04 0 0 0 0

Boom	Flare DR‐TP‐23 MMscf 1.47E+00 3.53E+01 1.06E‐01 9.80E‐01 2.35E+01 7.06E‐02 0 0 0 0

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 00000000 0 9.65E‐0EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 00000000 0 9.65E‐0EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 00000000 0 6.73E‐0

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 00000000 0 0Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 1.28E‐01 3.07E+00 3.23E‐02 0

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 1.53E‐02 3.68E‐01 3.68E‐02 0 0 0 0Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 7.26E‐02 1.74E+00 1.74E‐01 0 0 0 0

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 3.84E‐02 9.21E‐01 9.21E‐02 3.84E‐02 9.21E‐01 9.21E‐02 3.84E‐02 9.21E‐01 9.21E‐02 7.67E‐0

Total 1.68E+00 4.04E+01 8.49E‐01 1.29E+00 3.10E+01 1.02E+00 3.95E‐01 9.49E+00 7.74E‐01 4.06E‐

Air Emission Sources EPN Unit

Drillship

Third Party Engines

Scenario 2 Scenario 3 

Gas	Flowback Oil	Flowback Stimulation	Vessel 

Scenario 1

SO2 SO2 SO2 

Support Vessels

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

H2SO4 Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr 

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 5.05E‐03 1.21E‐01 2.03E‐02 5.41E‐03 1.30E‐01 2.03E‐02 7.16E‐03 1.72E‐01 2.03E‐02 1.03E‐0

Emergency	Air	Compressor	 DR‐AC‐01 hours 3.32E‐06 3.32E‐06 3.32E‐07 3.32E‐06 3.32E‐06 3.32E‐07 3.32E‐06 3.32E‐06 3.32E‐07 3.32E‐0Life	Boat	Diesel	Engines	no.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 8.62E‐05 8.62E‐05 4.31E‐06 8.62E‐05 8.62E‐05 4.31E‐06 8.62E‐05 8.62E‐05 4.31E‐06 8.62E‐0Fast	Rescue	Craft DR‐FR‐01 hours 1.93E‐05 1.93E‐05 9.64E‐07 1.93E‐05 1.93E‐05 9.64E‐07 1.93E‐05 1.93E‐05 9.64E‐07 1.93E‐0Dust	Collectors	no.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 00000000 0 0

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 00000000 0 0

Drillship	Fugitive	Emissions DR‐FE‐01 hours 00000000 0 0

Mud	Degasser	Vent DR‐VG‐01 hours 00000000 0 0

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 00000000 0 0

Welding	Operations DR‐WE‐01 lbs 0 0 0 0 0 0 0 0 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 1.05E‐04 2.52E‐03 2.52E‐04 1.05E‐04 2.52E‐03 2.52E‐04 1.05E‐04 2.52E‐03 2.52E‐04 1.05E‐0EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 4.41E‐05 1.06E‐03 1.06E‐04 4.41E‐05 1.06E‐03 1.06E‐04 4.41E‐05 1.06E‐03 1.06E‐04 4.41E‐0Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 00000000 0 0	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 00000000 0 0	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 00000000 0 0	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 00000000 0 0	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 00000000 0 4.41E‐0

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 000000 4.41E‐05 1.06E‐03 1.06E‐04 4.41E‐0	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 00000000 0 2.10E‐0

Flowback	Boiler DR‐TP‐22 MMBtu 00000000 0 0

Boom	Flare DR‐TP‐23 MMscf 00000000 0 0

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 00000000 0 3.01E‐0

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 00000000 0 3.01E‐0

EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 00000000 0 2.10E‐0

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 00000000 0 0

Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 4.00E‐03 9.60E‐02 1.01E‐03 0

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 4.79E‐04 1.15E‐02 1.15E‐03 0 0 0 0

Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02 bbl 0 0 0 2.27E‐03 5.44E‐02 5.44E‐03 0 0 0 0

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 1.20E‐03 2.88E‐02 2.88E‐03 1.20E‐03 2.88E‐02 2.88E‐03 1.20E‐03 2.88E‐02 2.88E‐03 2.40E‐0

6.24E‐03 1.50E‐01 2.32E‐02 9.36E‐03 2.25E‐01 2.98E‐02 1.24E‐02 2.96E‐01 2.42E‐02 1.27E‐

Air Emission Sources Unit EPN

Drillship

Third Party Engines

Scenario 2 Scenario 3 

Gas	Flowback Oil	Flowback Stimulation	Vessel 

Scenario 1

H2SO4 H2SO4 H2SO4 

Support Vessels

Total

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
Anadarko Petroleum Corporation

HAP Emissions Matrix

lb/hr lb/day ton/year lb/hr lb/day ton/year lb/hr lb/day ton/year lb/h

Drillship	Main	Propulsion	Electrical	Generator	Engines	and	Emergency	Generator

DR‐ME‐01	to	DR‐ME‐08	and	DR‐GE‐01 m3 1.59E‐01 3.81E+00 6.38E‐01 1.70E‐01 4.08E+00 6.38E‐01 2.25E‐01 5.40E+00 6.38E‐01 3.23E‐

Emergency	Air	Compressor	 DR‐AC‐01 hours 2.57E‐04 2.57E‐04 2.57E‐05 2.57E‐04 2.57E‐04 2.57E‐05 2.57E‐04 2.57E‐04 2.57E‐05 2.57E‐Life	Boat	Diesel	Engines	No.	1	to	6 DR‐LB‐01	to	DR‐LB‐06 hours 6.67E‐03 6.67E‐03 3.34E‐04 6.67E‐03 6.67E‐03 3.34E‐04 6.67E‐03 6.67E‐03 3.34E‐04 6.67E‐Fast	Rescue	Craft DR‐FR‐01 hours 1.49E‐03 1.49E‐03 7.46E‐05 1.49E‐03 1.49E‐03 7.46E‐05 1.49E‐03 1.49E‐03 7.46E‐05 1.49E‐Dust	Collectors	No.	1	to	3 DR‐DC‐01	to	DR‐DC‐03 hours 0 0000000 0 0

Drill	Ship	Diesel		and	Jet	Fuel	Storage	Tanks DR‐FT‐01	to	DR‐FT‐18 hours 7.59E‐06 1.82E‐04 3.65E‐02 7.59E‐06 1.82E‐04 3.65E‐02 7.59E‐06 1.82E‐04 3.65E‐02 7.59E‐

Drillship	Fugitive	Emissions DR‐FE‐01 hours 0 0000000 0 0

Mud	Degasser	Vent DR‐VG‐01 hours 0 0000000 0 0

Painting	(paint	+	thinner)	Operations DR‐PO‐01 gals 6.61E+00 1.59E+02 1.03E+01 6.61E+00 1.59E+02 1.03E+01 6.61E+00 1.59E+02 1.03E+01 6.61E+

Welding	Operations DR‐WE‐01 lbs 2.67E‐01 6.42E+00 6.42E‐01 2.67E‐01 6.42E+00 6.42E‐01 2.67E‐01 6.42E+00 6.42E‐01 2.67E‐

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐03 hours 8.13E‐03 1.95E‐01 1.95E‐02 8.13E‐03 1.95E‐01 1.95E‐02 8.13E‐03 1.95E‐01 1.95E‐02 8.13E‐EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐17 hours 3.42E‐03 8.20E‐02 8.20E‐03 3.42E‐03 8.20E‐02 8.20E‐03 3.42E‐03 8.20E‐02 8.20E‐03 3.42E‐Third	Party	Well	Evaluation	Engines	≤	140	HP DR‐TP‐12	to	DR‐TP‐16 hours* 0 0000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐04	and	DR‐TP‐05 hours* 0 0000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐18	and	DR‐TP‐19 hours* 0 0000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐06	and	DR‐TP‐07 hours* 0 0000000 0 0

	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐20 hours 0 0000000 0 3.42E‐	EPA	Tier	II	Third	Party	Engines	≤	126	HP DR‐TP‐21 hours 0 00000 3.42E‐03 8.20E‐02 8.20E‐03 3.42E‐	EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐08	and	DR‐TP‐09 hours 0 0000000 0 1.63E‐Flowback	Boiler DR‐TP‐22 MMBtu 1.89E‐04 4.53E‐03 1.36E‐05 1.89E‐04 4.53E‐03 1.36E‐05 0 0 0 0

Boom	Flare DR‐TP‐23 MMscf 4.61E+00 1.11E+02 3.32E‐01 3.07E+00 7.37E+01 2.21E‐01 0 0 0 0

EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐01 hours 0 0000000 0 1.03E‐EPA	Tier	II	Third	Party	Engines	≤	860	HP DR‐TP‐02 hours 0 0000000 0 1.03E‐EPA	Tier	II	Third	Party	Engines	≤	300	HP DR‐TP‐10	and	DR‐TP‐11 hours* 0 0000000 0 1.63E‐

Condensate	Tanks DR‐TP‐25	to	DR‐TP‐27 hours* 7.59E‐06 1.82E‐04 5.02E‐01 7.59E‐06 1.82E‐04 5.02E‐01 7.59E‐06 1.82E‐04 1.82E‐05 7.59E‐

Stimulation	Vessel	Engines Various bbl 0 0 0 0 0 0 1.26E‐01 3.02E+00 3.17E‐02 0

Barges BG‐LP‐01	to	BG‐LP‐03 hours 0 0 0 3.71E‐02 8.90E‐01 8.90E‐02 0 0 0 0Tug	Boats

TG‐ME‐01	to	TG‐ME‐03	&	TG‐GE‐01	to	TG‐GE‐02

bbl 0 0 0 7.13E‐02 1.71E+00 1.71E‐01 0 0 0 0

Well	Evaluation	Vessel Various bbl 0 0 0 0 0 0 0 0 0 0 

Supply	Boats Various bbl 3.81E‐02 9.14E‐01 9.14E‐02 3.81E‐02 9.14E‐01 9.14E‐02 3.81E‐02 9.14E‐01 9.14E‐02 7.62E‐

1.17E+01 2.80E+02 1.26E+01 1.03E+01 2.46E+02 1.27E+01 7.26E+00 1.74E+02 1.17E+01 7.28E+

Note:	Highest	single	HAP	emission: Xylene 5.71E+00 tpy

Air Emission Sources EPN Unit

Drillship

Third Party Engines

Scenario 2 Scenario 3 

Gas	Flowback Oil	Flowback Stimulation	Vessel 

Scenario 1

HAP HAP HAP 

Support Vessels

Total

Anadarko	Petroleum	CorporationEGOM	Exploratory	Project	‐	Blackhornet 1	of	1
MEMORANDUM 

To:	 Kelly	Fortin,	EPA	Region	4		

CC:	 Sara	Carlson	and	Katie	Maness,	Anadarko	 	 	 	 	 	

From:	 Rahul	Pendse,	Trinity			

Date:	 August	27,	2014	

RE:	 BlackHornet	PSD/Title	V	Application:	Proposed	Parametric	Emissions	Monitoring	System	and	BACT	

Limits	Compliance	Demonstration		

BACKGROUND 

New	Source	Performance	Standards	(NSPS)	Subpart	IIII,	Standards	of	Performance	for	Stationary	Compression	

Ignition	Internal	Combustion	Engines,	provides	standards	for	manufacturers,	owners,	and	operators	of	

stationary	compression	ignition	(CI)	internal	combustion	engines.			As	described	in	the	regulatory	applicability	

section	of	the	BlackHornet	PSD/Title	V	permit	application	package	submitted	in	September	2013,	the	main	

engines	on	the	BlackHornet	drillship	are	subject	to	NSPS	Subpart	IIII.			

Per	§	60.4211(d)(2),	an	owner	or	operator	must	establish	operating	parameters	to	be	monitored	continuously	

to	ensure	the	stationary	internal	combustion	engine	continues	to	meet	the	emission	standards.		The	owner	or	

operator	must	petition	the	Administrator	(i.e.,	EPA	in	this	case)	for	approval	of	operating	parameters	to	be	

monitored	continuously.		The	petition	must	include	the	information	specified	below:	

 Identification	of	the	specific	parameters	proposed	to	be	monitored	continuously;		

 A	discussion	of	the	relationship	between	these	parameters	and	oxides	of	nitrogen	(NOX)	and	particulate	

matter	(PM)	emissions,	identifying	how	the	emissions	of	these	pollutants	change	with	changes	in	these	

parameters,	and	how	limitations	on	these	parameters	will	serve	to	limit	NOX	and	PM	emissions;		

 A	discussion	of	how	the	upper	and/or	lower	values	for	these	parameters	were	established;		

 A	discussion	identifying	the	methods	and	the	instruments	you	will	use	to	monitor	these	parameters,	as	

well	as	the	relative	accuracy	and	precision	of	these	methods	and	instruments;	and		

 A	discussion	identifying	the	frequency	and	methods	for	recalibrating	the	instruments	you	will	use	for	

monitoring	these	parameters.		

Moreover,	EPA	has	included	an	emissions	monitoring	system	as	the	BACT	limits	compliance	demonstration	

option.		Anadarko	is	proposing	to	utilize	a	combination	of	engine	load	vs.	exhaust	flow	plot	and	a	Parametric	

Emissions	Monitoring	System	(PEMS),	developed	by	Air	Hygiene,	Inc.,	for	demonstrating	compliance	with	the	

requirements	specified	in	§	60.4211(d)(2)	and	the	BACT	limits	for	certain	pollutants	as	described	in	this	

technical	memorandum.	

PEMS DIRECT MEASUREMENTS 

The	proposed	PEMS	has	the	capability	to	monitor	concentrations	of	the	following:	

 Oxides	of	nitrogen	(NO	and	NO2	–	collectively	referred	as	NOx)	in	parts	per	million	by	volume	(ppmv),		

 Carbon	monoxide	(CO)	in	ppmv,	and		

 Oxygen	(O2)	in	volume	percent.		
The	proposed	PEMS	does	not	have	the	capability	to	monitor	the	following:	

		

 Carbon	dioxide	(CO2)	concentrations,	

 Volatile	organic	compounds	(VOCs)	concentrations,	

 Particulate	matter	species	(PM/PM10/PM2.5)	concentrations,		

 Exhaust	flow	rate,	and	

 Moisture	content	of	the	exhaust.		

Since	the	PEMS	is	not	capable	of	monitoring	VOCs	and	particulate	matter,	Anadarko	is	proposing	to	utilize	the	

compliance	stack	test	results	along	with	the	continuous	monitoring	of	engine	load	to	demonstrate	ongoing	

compliance	with	the	BACT	limits	for	VOCs	and	particulate	matter.		Although	the	proposed	PEMS	does	not	have	

the	capability	to	monitor	CO2	concentrations,	CO2	concentrations	will	be	calculated	using	the	monitored	O2

concentrations	as	described	below.	

CO2 CONCENTRATION DETERMINATION 

Appendix	F	to	Code	of	Federal	Regulations	Title	40	Part	75	provides	an	equation	to	calculate	CO2	on	a	dry	basis:	

ܥܱଶௗ ൌ 100

௖ܨ

൬ ܨ

20.9 െ ܱଶௗ

20.9 ൰	 (1)

Where:	

 CO2d	is	the	hourly	average	CO2	concentration	during	operation,	volume	percent,	dry	basis;		

 Fc	and	F	are	the	F‐Factors	as	shown	in	Table	1	below;		

 O2d	is	the	hourly	average	O2	concentration	during	operation,	volume	percent,	dry	basis.	

Table 1: F and Fc‐Factors for Fuel Oil

F‐Factor Value Unit

F	 9,190	 dscf/MMBtu	

Fc	 1,420	 scf	CO2/MMBtu	

Note: These	values	were	determined	at	the	standard	conditions	20	°C	(68	°F)	and	

760	mmHg	(29.92	in.	Hg)

ENGINE LOAD MONITORING 

Since	the	BACT	limits	for	NOx,	CO,	and	greenhouse	gases	(measured	as	CO2)	are	proposed	in	g/kW‐hr	and	lbs/hr,	

a	flow	rate	and	an	engine	load	are	required	to	convert	the	concentrations	(in	ppmv	or	volume	%)	to	emission	

rates	in	grams	of	pollutant/kW‐hr	of	engine	output.			

The	PEMS	on	the	drillship	will	have	the	capability	of	continuously	monitoring	a	power	output	in	electrical	

kilowatts	(kWe).		Anadarko	proposes	to	utilize	the	PEMS	for	documenting		power	output	at	least	once	every	

operational	hour	for	each	main	engine.		Anadarko	will	convert	a	power	output	in	electrical	kilowatts	(kWe)	to	a	

power	output	in	mechanical	kilowatts	(kWm)	by	using	a	typical	conversion	factor	of	1 kWm output = 0.95 kWe

output.

Since	the	PEMS	does	not	have	the	capability	to	monitor	the	exhaust	flow	rate,	Anadarko	proposes	to	develop	a	

plot	of	exhaust	flow	rate	vs.	engine	load	during	the	compliance	stack	tests	as	discussed	below.			
EXHAUST FLOW RATE VS. ENGINE LOAD PLOT 

Anadarko	expects	the	main	engine	loads	to	vary	from	20%	to	60%	during	the	operations.		Anadarko	proposes	to	

measure	the	flow	rate	at	a	minimum	of	three	loads	within	20%	to	60%		using	an	EPA	approved	exhaust	flow	

measurement	method(s)	during	the	compliance	stack	tests.		Using	the	engine	loads	and	the	measured	flow	rates,	

an	exhaust	flow	rate	vs.	an	engine	load	plot	could	be	developed	as	shown	in	Figure	1	below.		The	flow	rate	will	

be	referenced	at	a	fixed	oxygen	content	so	that	an	exhaust	flow	at	any	other	oxygen	content	could	be	normalized	

to	the	reference	oxygen	content.		

EMISSION RATE CALCULATION PROCEDURES 

Using	the	monitored	or	calculated	data	as	described	in	the	sections	above,	emission	rates	for	comparison	against	

NSPS	Subpart	IIII	standards	as	well	as	the	BACT	limits	could	be	calculated	as	shown	in	the	example	below.			

 NOx	concentration	dry	basis	(monitored)	–	800	ppmv	(source	–	PEMS	direct	measurement)	

 NOx	concentration	dry	basis	(calculated)	–	0.043	grams/dry	standard	cubic	feet	(dscf)	

 Power	output	(monitored)	–	2,565	kWe	(source	–	PEMS)	

 Power	output	(calculated)	–	2,700	kWm	(source	–	conversion	factor	1	kWm	output	=	0.95	kWe	output)	

 Engine	load	(calculated)	–	2,700	kWm/4,500	kWm	=	60%	(maximum	engine	output	=	4,500	kWm)	

 Exhaust	Flow	(calculated)	–	10,500	dscfm	(source	–	exhaust	flow	rate	vs.	engine	load	plot)	

 NOx	mass	emissions	(calculated)	–	0.043	grams/dscf	*	10,500	dscfm	*	60	minutes/hour	=	27,000	

grams/hr	

 NOx	mass	emission	rate	(calculated)	–	27,000	grams/hr	*	1/2,700	kWm	=	10	grams/kW‐hr	

Similar	calculations	will	be	performed	to	demonstrate	compliance	with	BACT	limits	on	24‐hr	rolling	basis.		

PEMS MONITORING AND CALIBRATION FREQUENCY 

Anadarko	is	proposing	to	monitor	the	NOx,	CO,	and	O2	concentrations	at	least	once	per	operational	hour	per	

engine	using	the	PEMS.		Anadarko	proposes	to	calibrate	the	PEMS	at	least	once	per	operational	week.		The	

calibration	tests	will	be	performed	using	the	manufacturer	recommended	calibration	gases.		These	calibration	

gases	need	to	be	stored	in	a	temperature	controlled	room	on	the	drillship.		Moreover,	transportation	and	storage	

of	the	calibrations	gases	poses	challenges	due	to	the	area	the	PEMS	is	located	on	the	drillship	and	could	pose	a	

safety	threat	to	the	drillship	and	personnel.		Hence,	Anadarko	believes	more	frequent	calibration	than	the	

0

5000

10000

15000

20000

0 20 40 60 80 100

Flow	Rate	(dscfm)

Engine	Load	(%)

Figure	1:	Typical	Flow	Rate	vs	Engine	Load
proposed	frequency	could	be	difficult	to	manage.		Should	more	frequent	calibration	be	required	due	to	

unforeseen	issues	or	malfunctions,	Anadarko	will	perform	the	calibration	at	a	higher	frequency.	

PEMS MISSING DATA PROCEDURES 

If	the	PEMS	monitored	data	is	missing	due	to	malfunctions	or	any	unforeseen	issues,	the	missing	concentration	

value(s)	will	be	substituted	with	the	previously	monitored	concentration	for	the	same	engine	load.		Moreover,	in	

order	to	conservatively	estimate	the	emission	rate	associated	with	the	missing	concentration,	the	engine	load	

will	be	increased	by	10%	while	obtaining	the	exhaust	flow	rate	for	the	emission	rate	calculation.		For	example,	if	

the	concentration	of	NOx	is	missing	for	a	particular	hour	with	an	engine	load	of	60%	then	the	NOx	emission	rate	

for	that	hour	will	be	calculated	by	replacing	the	concentration	of	NOx	by	previously	monitored	concentration	for	

60%	engine	load	and	using	a	flow	rate	for	66%	engine	load	(60%	+	10%	of	60%).	

SUMMARY 

Anadarko	believes	a	combination	of	the	engine	load	vs.	exhaust	flow	curve	and	the	proposed	PEMS	satisfies	the	

requirements	specified	in	§	60.4211(d)	(2).		A	few	requirements	specified	in	§	60.4211(d)	(2),	not	address	

previously,	are	discussed	below:

 A	discussion	of	the	relationship	between	these	parameters	and	NOX	and	PM	emissions,	identifying	how	

the	emissions	of	these	pollutants	change	with	changes	in	these	parameters,	and	how	limitations	on	these	

parameters	will	serve	to	limit	NOX	and	PM	emissions;		

As	engine	load	increases,	the	exhaust	flow	rate	as	well	as	the	mass	emission	rates	of		NOX	and	PM	

increase.		The	proposed	methodology	of	calculating	emission	rate	is	valid	for	engines	operating	at	any	

load.		However,	the	accuracy	of	the	results	increases	between	the	expected	operation	load	ranges	of	

20%	to	60%.	

 A	discussion	of	how	the	upper	and/or	lower	values	for	these	parameters	were	established;		

the	proposed	methodology	of	calculating	emission	rate	is	valid	for	engines	operating	at	any	load.		

However,	the	accuracy	of	the	results	increases	between	the	expected	operation	load	ranges	of	20%	to	

60%.		The	expected	operation	load	range	was	obtained	from	historical	data	while	performing	similar	

projects	outside	of	the	Eastern	Gulf	of	Mexico.	

 A	discussion	identifying	the	methods	and	the	instruments	you	will	use	to	monitor	these	parameters,	as	

well	as	the	relative	accuracy	and	precision	of	these	methods	and	instruments	

the	system	is	not	installed	on	the	drillship	yet.		Anadarko	will	provide	the	details	of	the	PEMS	

instruments	as	well	as	information	about	the	relative	accuracy	and	precision	after	completion	of	

installation	on	the	drillship.	

Anadarko	also	believes	a	combination	of	the	engine	load	vs.	exhaust	flow	curve	and	the	proposed	PEMS	could	be	

effectively	utilized	to	satisfy	ongoing	compliance	demonstration	with	the	BACT	limits	as	discussed	in	this	

technical	memorandum.