## Environmental so lutions delivered uncommonly well 

# Anadarko Petroleum Corporation

BlackHornet PSD/Tit le V Permit Application Operations in the Eastern Gulf of Mexico

Prepared By:

TRINITY CONSULTANTS

301 Main Street, Suite 900 Baton Rouge, LA 70816 (225) 292

- 2661

August 2013

Project No. 1 31901 .00 20Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants i 

## TABLE OF CONTENTS

1. INTRODUCTION 7 1.1. Location of the Proposed Project

................................ ................................ ................................ ................................ ................. 7 1.2. Air Permitting and Summary of Regulatory Requirements

................................ ................................ .............................. 8 1.3. Description of Emission Sources

................................ ................................ ................................ ................................ ............... 11 1.3.1. Emission Sources

................................ ................................ ................................ ................................ ................................ .... 11 1.4. Contents of the Application Addendum

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



### 2. PROCESS DESCRIPTION 18 2.1. Exploratory Drilling Description

................................ ................................ ................................ ................................ ............... 18 2.2. Well Completion

................................ ................................ ................................ ................................ ................................ ............... 19 2.3. Production Description (Well Maintenance)

................................ ................................ ................................ ....................... 20



### 3. EMISSIONS CALCULATIO NS 21 3.1. ‘Equivalency’ Determination

................................ ................................ ................................ ................................ ....................... 21 3.2. Operating Scenarios

................................ ................................ ................................ ................................ ................................ ........ 21 3.3. Drillship

................................ ................................ ................................ ................................ ................................ ................................ 22 3.3.1. M ain Engines (DR

- ME

- 01 through DR

- ME

- 08)

................................ ................................ ................................ ........... 22 3.3.2. Emergency Generator (DR

- GE

- 01)

................................ ................................ ................................ ................................ .. 24 3.3.3. Emergency Air Compressor (DR

- AC

- 01)

................................ ................................ ................................ ........................ 25 3.3.4. Life Boat Engines (DR

- LB

- 01 through DR

- LB

- 06)

................................ ................................ ................................ ..... 26 3.3.5. Fast Rescue Craft (DR

- FR

- 01)

................................ ................................ ................................ ................................ ............ 27 3.3.6. Mud degassing Vent (DR

- VG

- 01)

................................ ................................ ................................ ................................ ...... 28 3.3.7. Dust Collectors (DR

- DC

- 01 through DR

- DC

- 03)

................................ ................................ ................................ .......... 29 3.3.8. Storage Vessels (DR

- FT

- 01 through DR

- FT

- 18)

................................ ................................ ................................ .......... 30 3.3.9. Drillship Fugitive Emissions (DR

- FE

- 01)

................................ ................................ ................................ ....................... 30 3.3.10. Painting Operations (DR

- PO

- 01)

................................ ................................ ................................ ................................ ... 30 3.3.11. Welding Operations (DR

- WO

- 01)

................................ ................................ ................................ ................................ .. 31 3.3.12. Third Party Engines (DR

- TP

- 01 through DR

- TP

- 21)

................................ ................................ ............................. 32 3.3.13. Flowback Boiler (DR

- TP

- 22)

................................ ................................ ................................ ................................ ........... 33 3.3.14. Boom Flare (DR

- TP

- 23)

................................ ................................ ................................ ................................ ..................... 34 3.3.15. Well Completion Condensate Tanks (DR

- TP

- 24 through DR

- TP

- 26)

................................ ............................... 35 3.4. Support Vessels

................................ ................................ ................................ ................................ ................................ ................. 35 Supply B oats (HOS Coral) Combustion Sources

................................ ................................ ................................ ...................... 36 3.4.1. Marine Propulsion Engines 1 and 2 (SB

- ME

- 01 and SB

- ME

- 02)

................................ ................................ .......... 36 3.4.2. Marine Thruster Engines (SB

- TE

- 01 through SB

- TE

- 03)

................................ ................................ ........................ 37 3.4.3. Electrical Generator Engines (SB

- GE

- 01 and SB

- GE

- 02)

................................ ................................ ......................... 38 3.4.4. Emergency Electrical Generator Engine (SB

- GE

- 03)

................................ ................................ ................................ 39 3.4.5. ROV Electrical Generator Engine (SB

- GE

- 04)

................................ ................................ ................................ .............. 40 3.4.6. Well Evaluation Third Party Engine (SB

- TP

- 01 and SB

- TP

- 02)

................................ ................................ ........... 41 3.4.7. Well Evaluation Third Party Crane Motor Engine #1 (SB

- TP

- 03)

................................ ................................ ...... 42 3.4.8. Well Evaluation Third Party Crane Motor Engine #2 (SB

- TP

- 04)

................................ ................................ ...... 43 3.4.9. Third Party Well Evaluation Engines (SB

- TP

- 05 through SB

- TP

- 09)

................................ ................................ 44 Anchor Handling Boat (Kirt Chouest) Combustion Sources

................................ ................................ .............................. 45 3.4.10. Marine Propulsion Engines (AB

- ME

- 01 and AB

- ME

- 02)

................................ ................................ ...................... 45 3.4.11. Thruster Engines (AB

- TE

- 01 through AB

- TE

- 03)

................................ ................................ ................................ .... 46 3.4.12. Service Generator Engines (AB

- GE

- 01 through AB

- GE

- 05)

................................ ................................ ................. 47 3.4.13. Emergency Generator Engine (AB

- GE

- 06)

................................ ................................ ................................ ................. 47Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants ii 3.4.14. Winch Hydraulic Engines (AB

- GE

- 07 and AB

- GE

- 08)

................................ ................................ ............................ 48 3.4.15. Supply Boat Storage Tanks

................................ ................................ ................................ ................................ .............. 49 Tug Boat Combustion Sources

................................ ................................ ................................ ................................ ....................... 49 3.4.16. Tug Boat Main Engines (TB

- ME

- 01 to TB

- ME

- 03) and Generator Engines (TB

- GE

- 01 to TB

- GE

- 02) 49 Barge Combustion Sources

................................ ................................ ................................ ................................ ............................. 51 3.4.17. Barge Electrical Generat ors (BG

- LP

- 01thru BG

- LP

- 03)

................................ ................................ ........................ 51 Stimulation Vessel Combustion Sources

................................ ................................ ................................ ................................ .... 52 3.4.18. Stimulation Vessel Main Engines (SV

- ME

- 01 and SV

- ME

- 02)

................................ ................................ ............. 52 3.4.19. Bow Thruster Engine (SV

- BT

- 01)

................................ ................................ ................................ ................................ .. 54 3.4.20. Bow Drop

- Down Engine (SV

- DD

- 01)

................................ ................................ ................................ ............................ 54 3.4.21. Stern Thruster Engines (SV

- ST

- 01)

................................ ................................ ................................ ............................... 55 3.4.22. Representative Pump Engines (SV

- PE

- 01 through SV

- PE

- 08)

................................ ................................ ............ 56 3.4.23. Stimulation Vessel Generators (SV

- GE

- 01 and SV

- GE

- 02)

................................ ................................ .................... 57 3.4.24. Stimulation Vessel Generators (SV

- GE

- 03 and SV

- GE

- 04)

................................ ................................ .................... 58 Well Evaluation Vessel Combustion Sources

................................ ................................ ................................ ............................ 59 3.4.25. Well Evaluation Vessel Main Engines (WE

- ME

- 01and WE

- ME

- 02)

................................ ................................ . 59 3.4.26. Well Evaluation Vessel Auxiliary Engines (WE

- AE

- 01 and WE

-

AE

- 02)

................................ .......................... 61 3.4.27. Well Evaluation Vessel Emergency Generator #1 (WE

- GE

- 01)

................................ ................................ ......... 61 3.4.28. Well Evaluation Vessel Emergency Generator #2 (WE

- GE

- 02)

................................ ................................ ......... 62 3.4.29. Well Evaluation Vessel Emergency Generator #3 (WE

- GE

- 03)

................................ ................................ ......... 63



### 4. REGULATORY APPLICABI LIT Y ANALYSIS 65 4.1. Outer Continental Shelf Air Regulations (40 CFR 55)

................................ ................................ ................................ ...... 65 4.2. Prevention of Significant Deterioration (PSD) Regulations

................................ ................................ ........................... 67 4.3. New Source Performance Standards (NSPS)

................................ ................................ ................................ ....................... 68 4.3.1. 40 CFR Subpart A

– General Provisions

................................ ................................ ................................ .......................... 68 4.3.2. 40 CFR Subpart K

- Standards of Performance for Storage Vessels for Petroleum Liquids

........................ 68 4.3.3. 40 CFR 60 Subpart Ka

– Standards of Performance for Storage Vessels for Petroleum Liquids

.............. 69 4.3.4. 40 CFR 60 Subpart Kb

- Standards of Performance for Volatile Liquid Storage Vessels

.............................. 69 4.3.5. 40 CFR 60 Subpart IIII

– Stationary Compression Ignition Internal Combustion

................................ ......... 71 4.3.5.1. D rillship Main Engines (DR

- ME

- 01 through DR

- ME

- 08)

................................ ................................ ..................... 72 4.3.5.2. Drillship Emergency Generator (DR

- GE

- 01)

................................ ................................ ................................ ............. 73 4.3.5.3. Drillship Emergency Air Compressor (DR

- AC

- 01)

................................ ................................ ................................ .. 74 4.3.5.4. Drillship Temporary Third Party Well Evaluation Engines (DR

- TP

- 12 through DR

- TP

- 16)

................. 74 4. 3.5.5. Stimulation Vessel Pumps (SV

- PE

- 01 through SV

- PE

- 08)

................................ ................................ ................... 74 4.3.6. 40 CFR 60 Subpart JJJJ

– Stationary Spark Ignition Internal Combustion

................................ ........................ 75 4.3.7. 40 CFR 60 Subpart Dc

– Standards of Performance for Small Industrial

– Commercial

– Institutional Steam Generating Units

................................ ................................ ................................ ................................ ................................ ... 75 4.4. National Emission Standards For Hazardous Air Pollutants (NESHAP

- 40 CFR Part 61)

............................... 75 4.4.1. 40 CFR 61 Subpart A

- General Provisions

................................ ................................ ................................ ..................... 76 4.5. National Emission Standards For Hazardous Air Pollutants (NESHAP

– 40 CFR Part 63)

.............................. 76 4.5.1. 40 CFR 63 Subpart A

– General Provisions

................................ ................................ ................................ ................... 76 4.5.2. 40 CFR 63 Subpart ZZZZ

– Stationary Reciprocating Internal Combustion Engines

................................ ... 76 4.5.3. 40 CFR 63 Subpart HHHHHH

– Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

................................ ................................ ................................ ................................ ................................ ................................ ... 77 4.6. Federal Operating Permits Program (40 CFR Part 71)

................................ ................................ ................................ .... 77 4.7. Engangered Species Act

................................ ................................ ................................ ................................ ................................ 78



### 5. BACT ANALYSIS 79 5.1. NO X BACT Analysis

................................ ................................ ................................ ................................ ................................ .......... 81Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants iii 5.1.1. NO

X BACT Analysis for the Drillship Main Engines (DR

- ME

- 01 to DR

- ME

- 08)

................................ ............... 81 5.1.2. NO X BACT Analysis for Emergency Generators (DR

- GE

- 01)

................................ ................................ ................... 88 5.1.3. NO X BACT Analysis for Emergency Air Compressor Engine (DR

- AC

- 01)

................................ ........................... 90 5.1.4. NO

X BACT Analys is for Third Party Engines (DR

- TP

- 01 through DR

- TP

- 11 and DR

- TP

- 17 though DR

TP

- 21)

................................ ................................ ................................ ................................ ................................ ................................ ..... 92 5.1.5. NO X BACT Analysis for Third Party Well Evaluation Engines (DR

- TP

- 12 through DR

- TP

- 16)

................. 94 5.1.6. NO X BACT Analysis for Pumps on the St imulation Vessel (SV

- PE

- 01 through SV

- PE

- 08)

........................... 97 5.1.7. NO

X BACT Analysis for Flowback Boiler (DR

- TP

- 22)

................................ ................................ ............................. 100 5.1.8. NO X BACT Analysis for Boom Flare (DR

- TP

- 23)

................................ ................................ ................................ ...... 101 5.2. CO and VOC BACT Analysis

................................ ................................ ................................ ................................ ........................ 103 5.2.1. CO and VOC BACT Analysis for Drillship Main Propulsion El ectrical Generator Engines (DR

- ME

- 01 through DR

- ME

- 08)

................................ ................................ ................................ ................................ ................................ ........ 103 5.2.2. CO and VOC BACT Analysis for Drillship Emergency Generator (DR

- GE

- 01)

................................ ............... 105 5.2.3. CO and VOC BACT Analysis for Air Compressor Engine (DR

- AC

- 01)

................................ ................................ 107 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)

................................ ................................ ................................ ................................ ................................ ..... 108 5.2.5. CO and VOC BACT Analysis for Third Party Well Evaluation Engines (DR

- TP

- 12 through DR

- TP

- 16)

................................ ................................ ................................ ................................ ................................ ................................ ................ 110 5.2.6. CO and VOC BACT Analysis for Representative Stimulation Vessel Pumps (SV

- PE

- 01 thru SV

- PE

- 08)

................................ ................................ ................................ ................................ ................................ ................................ ................ 111 5.2.7. CO and VOC BACT Analysis for Flowback Boiler (DR

- TP

- 22)

................................ ................................ ............. 112 5.2.8. CO and VOC BACT Analysis for Boom Flare (DR

- TP

- 23)

................................ ................................ ....................... 113 5.3. PM/PM 10 /PM 2.5 BACT Analysis

................................ ................................ ................................ ................................ ................ 115 5.3.1. PM/PM 10

/PM 2.5 BACT Analysis for the Drillship Main Propulsion Electrical Generator Engines (DR

- ME

01 to DR

- ME

- 08)

................................ ................................ ................................ ................................ ................................ .............. 115 5.3.2. PM/PM 10

/PM 2.5 BACT Analysis for Drillship Emergency Generator (DR

- GE

- 01)

................................ ........ 118 5.3.3. PM/PM 10

/PM 2.5 BACT Analysis for the Air Compressor Engine (DR

- AC

- 01)

................................ ................ 119 5.3.4. PM/PM 10

/PM 2.5 BACT Analysis for Drillship Third Party Engines (DR

- TP

- 01 through DR

- TP

- 11 and DR

TP

- 17 though DR

- TP

- 21)

................................ ................................ ................................ ................................ .............................. 120 5.3.5. PM/PM 10

/PM 2.5 BACT Analysis for Third Party Well Evaluation Engines (DR

- TP

- 12 through DR

- TP

- 16)

................................ ................................ ................................ ................................ ................................ ................................ ................ 121 5.3.6. PM/PM 10

/PM 2.5 BACT Analysis for Representative Pump Engines on the Stimulation Vessel (SV

- PE

- 01 thru SV

- PE

- 08)

................................ ................................ ................................ ................................ ................................ ................. 123 5.3.7. PM/PM 10

/PM 2.5 BACT Analysis for Flowback Boiler (DR

- TP

- 22)

................................ ................................ ..... 124 5.3.8. PM/PM 10

/PM 2.5 BACT Analysis for Boom Flare (DR

- TP

- 23)

................................ ................................ ............... 125 5.3.9. PM/PM 10

/PM 2.5 BACT Analysis for Cement and Mud Mixing Operations (DR

- DC

- 01 thru DR

- DC

- 03)

................................ ................................ ................................ ................................ ................................ ................................ ................ 126 5.3.10. PM/PM 10

/PM 2.5 BACT Analysis for Painting Operations (DR

- PO

- 01)

................................ ........................... 126 5.3.11. PM/PM 10

/PM 2.5 BACT Analysis for Welding Operations (DR

- WO

- 01)

................................ .......................... 128 5.4. VOC BACT Analysis for Storage Tanks And Paints

................................ ................................ ................................ ........... 130 5.4.1. VOC BACT Analysis for Storage Tanks (DR

- DT

- 01 thru DR

- DT

- 09 and DR

- FT

- 01 thru DR

- FT

- 03)

..... 130 5.4.2. VOC BACT Analysis for Mud Degassing Operations (DR

- VG

- 01)

................................ ................................ ....... 131 5.4.3. VOC BACT Analysis for Painting Operations (DR

- PO

- 01)

................................ ................................ ..................... 132 5.5. Greenhouse Gas (GHG) BA CT Analysis

................................ ................................ ................................ ................................ . 132 5.5.1. GHG BACT Analysis for the Diesel Fired Internal Combustion Engines

................................ .......................... 133 5.5.2. GHG BACT Analysis for Mud Degassing Operations (DR

- VG

- 01)

................................ ................................ ....... 135 5.5.3. GHG BACT Analysis for Flowback Boiler (DR

- TP

- 22)

................................ ................................ ............................ 136 5.5.4. GHG BACT Analysis for Boom Flare (DR

- TP

- 23)

................................ ................................ ................................ ...... 136



### 6. PART 71 FORMS 139Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants iv 

### APPENDIX A

– PLOT PLAN

APPENDIX B

– EMISSION CALCULATION S

APPENDIX C

– LIST OF INSIGNI FICANT ACTIVITIES

APPENDIX D

– AIR DISPERSION MODEL ING ANALYSIS

APPENDIX E

– BACT ANALYSIS SUPPOR TING DOCUMENTATION

APPENDIX F

– ENVIRONMENTAL IMPACT ASSE SSMENT

APPENDIX G

- 1

– SPECIFICATION SHEETS : DRILLSHIP

APPENDIX G

- 2

– SPECIFICATION SHEETS : THIRD PARTY EPA TI ER II CERTIFIED ENGI NES

APPENDIX G

- 3

– SPECI FICATION SHEETS: NON

- EPA TIERED WELL EVAL UATION ENGINES

APPENDIX G

- 4

– TANKS 4.09 OUTPUT FO R DRILLSHIP TANKS

APPENDIX G

- 5

– SPECIFICATION SHEETS : DUST COLLECTORS

APPENDIX G

- 6

– SPECIFICATION SHEETS : MSDS

- PAINTS/BASE/THINNER

APPENDIX G

- 7

– TANKS 4.09 OUTPUT FO R SUPPLY BOAT TANKS

APPENDIX G

- 8

– DRILLSHIP MAIN ENGIN E MANUFACTURER MAINT ENANCE

APPENDIX G

- 9

– THIRD PARTY FLOWBACK BOILER

APPENDIX G

- 10

– SPECIFICATION SHEETS : SUPPLY BOAT

APPENDIX G

- 11

– ANCHOR HANDLING BOAT

APPENDIX G

- 12

– SPECIFICATION SHEETS : TUG

APPENDIX G

- 13

– SPECIFICATION SHEETS

– BARGE

APPENDIX G

- 14

– TANKS 4.09 OUTPUT FO R CONDENSATE TANKS

APPENDIX G

- 15

– SPECIFICATION SHEETS

– STIMULATION VESSEL

APPENDIX G

- 16

– SPECIFICATION SHEETS

– WELL EVALUATION VESS EL

APPENDIX G

- 17

– TANKS 4.09 OUTPUT FO R ANCHOR BOAT TANKS

APPENDIX G

- 18

– MSDS OF ULTRA LOW SU LFUR DIESELAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants v 

## LIST OF TABLES

Table 1

- 1. Location of Lease Blocks Relative to Nearest Class I Areas 7

Table 1

- 2. Project Potential

- to

- Emit (PTE) of Project 9

Table 1

- 3. Summary of Emission Units on the Drillship 11

Table 1

- 4. Summary of Temporary Third Party Emission Sources on the Drillship 13

Table 1

- 5. Summary of Emission Units on the Supply Boats 13

Table 1

- 6. Summary of Emission Units on the Anchor Handling Boats 15

Table 1

- 7. Summary of Emission Units on the Stimulation Vessel 16

Table 1

- 8. Summary of Emi ssion Units on the Tug Boats and Barges 16

Table 1

- 9. Summary of Emission Units on the Well Evaluation Vessel 17

Table 4

- 1

. NSPS Subpart Kb Applicability Determination for Fuel Storage Tanks 69

Table 4

- 2 . Applicable Engines Subject to Subpart IIII 72

Table 4

- 3 . Emergency Generator Offset Requirements 73

Table 4

- 4 . Emergency Generator Residual Emissions 74

Table 5

- 1. Ranks of Technologies Feasible for Main Engines 87

Table 5

- 2. Ranks of Technologies Feasible for Emergency Generators 89

Table 5

- 3. Ranks of Technologies Feasible for Emergency Air Compressor Engine 92

Table 5

- 4. Ranks of Technologies Feasible for Diesel Fired Engines 97

Table 5

- 5. Ranks of Technologies Feasible for Pumps on Stimulation Vessel 99

Table 5

- 6. Proposed NO X BACT Emission Limits 102

Table 5

- 7. Ranks of Technologies Feasible for Main Diesel Engines 105

Table 5

- 8. Ranks of Technologies Feasible for Emergency Engine 106

Table 5

- 9. Ranks of Technologies Feasible for Emergency Air Compressor Engine 108

Table 5

- 10. Ranks of Technologies Feasible for the Third Party Engines 109

Table 5

- 11. Ranks of Technologies Feasible for Pumps on Stimulation Vessel 112Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants vi Table 5

- 12 . Proposed CO & VOC BACT Emission Limits 113

Table 5

- 13. Ranks of Technologies Feasible f or Main Diesel Engines 117

Table 5

- 14. Ranks of Technologies Feasible for the Emergency Diesel Engine 118

Table 5

- 15. Ranks of Technologies Feasible for the Emergency Diesel Engine 120

Table 5

- 16. Ranks of Technologies Feasible for the Third Party Engines 121

Table 5

- 17. Ranks of Technologies Feasible for the Pumps on Stimulation Vessel 124

Table 5

- 18. Paint Application and Transfer Efficiencies 127

Table 5

- 19. Rank s of Technologies Feasible for the Welding Operations 128

Table 5

- 20. Proposed PM/PM 10 /PM 2.5 BACT Emission Limits 129

Table 5

- 21. Proposed VOC BACT Emission Limits 132

Table 5

- 22. Proposed CO 2 e BACT Emission Limits 138Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application Trinity Consultants 7 

## 1. INTRO DUCTION

Anadarko is proposing to conduct exploratory drilling, completion, and associated maintenance activities (the proposed project) on the Outer Continental Shelf (OCS) of the Eastern Gulf of Mexico (EGOM). The proposed project activity will consist of three phases

– (1) the drilling phase, (2) the well completion phase, and (3) production well maintenance (remedial well

- work) phase. The p roposed project will be conducted over a period of five years , with the proposed operation of approximately 2 00 days per year. As specified in the application, Anadarko requested operating limit in terms of fuel consumption in lieu of operating time restriction. With the submittal of application, Anadarko is applying for a pre

- construction permit and a Title V operating permit

.



### 1.1. L OCAT ION OF THE P ROPOSED PROJECT

The proposed project is planned to be conducted within a set of lease blocks available for exploratory drilling using a dynamically positioned Diamond Offshore Drilling, Inc. (Diamond) BlackHornet drillship and associated su pport vessels in the EGOM, east of the 87.5 degree longitude. The available lease blocks (i.e., the “wedge”) in the EGOM are identified by a boundary line within the map presented in Figure 1

- 1. Within the wedge, there are both active lease blocks (curre ntly leased or available for lease) and lease blocks that could potentially be available for lease by the Bureau of Ocean Energy Management (BOEM) in the future. The area within the boundary line identified as the “wedge” as shown in Figure 1

- 1, is bounde d by the following limits:

1. The 87.5 longitude line to the west (Environmental Protection Agency Jurisdiction); 2. The 86.88 longitude line to the east (Military Mission Line); 3. The limit of 100 miles to the shore in the BOEM Central Planning area; and 4. The lim it of 125 miles to the shore in the BOEM Eastern Planning area

Anadarko has identified all lease blocks currently available for the proposed project in the EGOM within the “wedge” and has determined which of these lease blocks are closest to Class I areas in the vicinity of 300 kilometers (i.e., Breton National Wildlife Refuge [Breton NWR], St. Marks National Wildlife Refuge [St. Marks NWR], an d Bradwell Bay Wilderness Area). Also, the distance between these blocks and the boundary separating inner OCS an d outer OCS is provided in the Table 1

- 1 below. Table 1

- 1 also presents the direction and approximate distance to the Class I area and the corresponding Federal Land Managers (FLM) for each Class I area. A map showing the location of
worst

- case lease blo cks relative to the nearest Class I areas and surrounding onshore areas is provided in Figure 1

- 1.

Table 1

- 1

. Location of Lease Blocks Relative to Nearest Class I Areas

Desoto Canyon Lease Block Nearest

Class I Area (State) Direction Distance (km) Federal Land Manager Distance

From The OCS Boundary (km) 141 Breton NWR

(LA) NW 167 U.S. Fish & Wildlife Service (FWS) 95 149 St. Marks NWR

(FL) NE 285 U.S. Fish & Wildlife Service (FWS) 101

149 Bradwell Bay Wilderness (FL) NE 281 U.S. Forest Service (FS) 101Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application Trinity Consultants 8 

### 1.2. AIR PERMITTING AND S UMMARY OF REGULATORY REQUIREMENTS

The drillship used for the proposed project activities will qualify as an OCS source, as defined in 40 CFR 55.2 as follows:

“OCS source means any equipment, activity, or facility which: (1) Emits or has the potential to emit any air pollutant; (2) Is regulated or authorized under Outer Continental Shelf Lands Act (“OCSLA”) (43 U.S.C. §1331 et seq.); and (3) Is located on the OCS or in or on waters above the OCS.

This definition shall include vessels only when they are: (1) Permanently or temporarily attached to the seabed and erected thereon and used for the purpose of exploring, developing or producing resources therefrom, within the meaning of section 4(a)(1) of OCSLA (43 U.S.C. §1331 et seq. ); or (2) Physically attached to an OCS facility, in which case only the stationary sources aspects of the vessels will be regulated.”

Therefore, when Anadarko will be conducting the propose d project, it will be considered an OCS source and will be subject to the requirements of 40 CFR 55. In addition, when a support vessel is attached to an OCS source, the stationary source aspects of that support vessel will also be regulated as an OCS sou rce.
Per 40 CFR 55.3(a), all OCS sources located in the EGOM are regulated by the OCS Air Regulations codified under 40 CFR 55. As the regulatory authority over the EGOM has not been delegated through the requirements of 40 CFR 55.11(j), the proposed O CS source falls under the regulatory jurisdiction of the United States Environmental Protection Agency (U.S. EPA) and U.S. EPA Region 4 will issue the applicable permits and implement and enforce the requirements of 40 CFR 55. As the proposed project acti vities will be carried out beyond 25 miles of the nearest State’s seaward boundary, it will be outside of the corresponding state and local regulatory authority.

As an OCS source subject to the requirements of 40 CFR 55, the proposed source will need to c omply with 40 CFR 55.13(d) which specifies that the PSD program (codified under 40 CFR 52.21), applies to OCS sources l ocated beyond 25 miles of State s ’ seaward boundaries. The PSD program is a pre

construction permitting program that regulates emissions from “major” sources of regulated air pollutants. Further, as specified in 40 CFR 55.2, the emissions from vessels servicing or associated with an OCS source shall be considered direct emissions from such a source while at the source, and while en route t o or from the source when within 25 miles of the source, and shall be included in the “potential to emit” (PTE) for an OCS source, when considered for complying with the requirements of 40 CFR 55.13.

An OCS source is considered PSD major if PTE of any P SD

- regulated pollutant exceed the major source threshold of 250 tons per year (tpy). The PSD program regulates the emissions of all criteria pollutants and several non

- criteria pollutants such as total reduced sulfur compounds, sulfuric acid mist, and flu orides (not including hydrogen fluoride).

The proposed potential to emit (PTE) of criteria pollutants and HAPs for the proje ct are summarized in Table 1

- 2. The proposed project will be subject to requirements of the PSD program since it is classified as a major source. As shown in Table 1

- 2, total particulate matter (PM), particulate matter with an aerodynamic diameter less than 10 microns (PM 10 ), particulate matter with an aerodynamic diameter less than 2.5 microns (PM 2.5 ), nitrogen oxide s (NO X ), carbon monoxide (CO), volatileAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application Trinity Consultants 9 organic compounds (VOC) , and greenhouse gases (GHG) exceed thei r respective Significant Emission Rates (SER)

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

sources with emissions o f 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 Rat e (SER) Tons/year Exceeds

SER?

NO X 1,208 40 Yes

CO 529 100 Yes

PM 35 25 Yes

PM 10 32 15 Yes

PM 2.5 31 10 Yes

SO 2 1 40 No

VOC 120 40 Yes

Pb 0.02 0.6 No

H 2 SO 4 0.03 7 No

GHG 1 09,692 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 operatio n).

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 impa ct 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 fe derally protected Class I areas and Class II areas ha ve been perfor med 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 Ap pendix 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.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application Trinity Consultants 10 Figure 1

- 1 . Anadarko’s EGOM Exploratory Project Lease Blocks in Eastern Gulf of MexicoAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 11 Trinity Consultants 

### 1.3. DESCRIPTION OF EMISS ION SOURCES

The proposed project will be conducted using the Diamond BlackHornet drillship and associated support vessels . The support vessels include a combination of supply boats (i.e. , work boats and/or crew boats)
, an anchor handling boat , tug boats, barges, stim ulation vessels, and well evaluation vessels

. The anchor handling boat will not be used to set anchors while on site. Hence, it was treated as a Supply Boat in this application. Supply boats will be used to transport personnel and supplies to the drills hip, as required for conducting the project activities. The tug boats, barges, stimulation vessels, and well evaluation vessels will be utilized under various operating scenario as described in Section 3 of this application.

The different support vessels will be used interchangeably depending on availability, and therefore it is not known which specific support vessel will be available during the proposed project operations. To accommodate this uncertainty, Anadarko selected the highest emitting vessels in each category of the support vessels to develop Potential t o Emit (PTE) calculation s

. Similarly, Anadarko will utilize various third party equipment ( e.g., internal combustion engines, flowback boiler, boom flare, and con densate storage tanks ,) on the drillship and/or support vessels during various operating scenarios as described in Section 3 of this application. The exact specifications of third party equipment to be utilized over the duration of the proposed project ar e currently unknown to Anadarko.

Air pollutant emissions generated from the project include the criteria pollutants of NO X , CO, PM, PM 10 , PM 2.5 , SO 2 , VOC , and GHG s . These emissions are primarily released from the combustion of diesel fuel in the internal combustion engines and a boiler, storage tanks, and miscellaneous activities.



### 1.3.1. Emission Sources

The emission sources on the BlackHornet drillship primarily consist of internal combustion engines, storage tanks, mud degasser, dust collectors, diesel fuel lines, welding, and painting. The emission sources on the support vessels primarily consist of internal combustion engines, storage tanks, and diesel fuel lines. S everal third party temporary emission sources (e.g., internal combustion engines, flowback boiler, boom flare, and condensate storage tanks ) will be utilized on the drillship and/or support vessels per project requirements . Table s 1

- 3 through 1

- 9 present a summary of the emission units proposed for this project

.

Table 1

- 3 . Summary of Emission Units on the Drillship

EPN Emission Unit

Description # of

units Model Rating or Capacity Fuel Type or Contents

DR

- ME

- 01
t o DR

- ME

- 06 Main Propulsion Electrical

Generator Engines or Main

Engines (#1 to #6) 6 HYUNDAI

- HiMSEN
, 9H32/40 6,035 HP Ultra Low Sulfur Diesel (ULSD)

DR

- ME

- 07 DR

- ME

- 08 Main Propulsion Electrical

Generator Engines or Main

Engines 2 HYUNDAI

- HiMSEN
, 18H32/40V 12,069 HP ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 12 Trinity Consultants EPN Emission Unit

Description # of

units Model Rating or Capacity Fuel Type or Contents (#7 and #8)

DR

- GE

- 01 Emergency Generator 1 Cummins QSK60DMGE 2,547 HP ULSD DR

- LB

- 01
t o DR

- LB

- 06 Life Boat Engines

(#1 TO #6) 6 SIYANG 485

- J 41 HP ULSD DR

- AC

- 01 Emergency Air Compressor 1 HATZ 2M41 39 HP ULSD DR

- FR

- 01 Fast Rescue Craft 1 SABB

- L4 Turbo 55 HP ULSD

DR

- FT

- 01 No. 1 Fuel Oil Storage Tank (Port) 1 -- 657 M 3 ULSD

DR

- FT

- 02 No. 1 Fuel Oil Storage Tank

(Starboard) 1 -- 6 57 M 3 ULSD

DR

- FT

- 03 No. 2 Fuel Oil Storage Tank (Port) 1 -- 1485 M 3 ULSD

DR

- FT

- 04 No. 2 Fuel Oil Storage Tank

(Starboard) 1 -- 1485 M 3 ULSD

DR

- FT

- 05 No. 3 Fuel Oil Storage Tank (Port) 1 -- 1439 M 3 ULSD

DR

- FT

- 06 No. 3 Fuel Oil Storage Tank

(Starboard) 1 -- 1439 M 3 ULSD

DR

- FT

- 07 No. 1 Fuel Oil Settling Tank

(Starboard) 1 -- 71 M 3 ULSD

DR

- FT

- 08 No. 2 Fuel Oil Settling Tank (Port) 1 -- 71 M 3 ULSD

DR

- FT

- 09 No. 1 Fuel Oil Servicing

Tank (#1 E/R) 1 -- 31 M 3 ULSD

DR

- FT

- 10 No. 2 Fuel Oil Servicing

Tank (#1 E/R) 1 -- 31 M 3 ULSD

DR

- FT

- 11 No. 1 Fuel Oil Servicing

Tank (#2 E/R) 1 -- 31 M 3 ULSD

DR

- FT

- 12 No. 2 Fuel Oil Servicing

Tank (#2 E/R) 1 -- 31 M 3 ULSD

DR

- FT

- 13 No. 1 Fuel Oil Servicing

Tank (#3 E/R) 1 -- 35 M 3 ULSD

DR

- FT

- 14 No. 2 Fuel Oil Servicing

Tank (#3 E/R) 1 -- 35 M 3 ULSD DR

- FT

- 15 Fuel Oil Over Tank 1

-- 46 M 3 ULSD DR

- FT

- 16 Fuel Oil Leak Tank 1

-- 23 M 3 ULSD DR

- FT

- 17 DR

- FT

- 18 Helicopter Fuel Tanks 2 -- 2
, 900 Liter Jet Fuel DR

- DC

- 01 DR

- DC

- 02 DR

- DC

- 03 Dust Collector 3 --

26 M 3 / M in

--Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 13 Trinity Consultants EPN Emission Unit

Description # of

units Model Rating or Capacity Fuel Type or Contents DR

- VG

- 01 Mud Degasser Vent 1

-- -- -- -- DR

- FE

- 01 Drillship Fugitive Emissions

-- -- -- -- -- DR

- PO

- 01 Painting Operations

-- various

-- -- -- DR

- WO

- 01 Welding Operations

-- various

-- -- --

Table 1

- 4

. Summary of Temporary Third Party E mission Sources on the Drillship

EPN Emission Unit

Description # of

units Model Rating or Capacity Fuel Type or Content

s DR

- TP

- 01 and DR

- TP

- 02 Third Party Engines 2 Various

- EPA Tier II Certified ≤ 860 HP ULSD DR

- TP

- 03 to DR

- TP

- 11 Third Party Engines 9 Various

- EPA Tier II Certified ≤ 300 HP ULSD DR

- TP

- 12 to DR

- TP

- 16 Third Party Well Evaluation Engines 5 Detroit Diesel ≤ 140 HP ULSD DR

- TP

- 17 to DR

- TP

- 21 Third Party Engines 5 Various

- EPA Tier II Certified ≤ 126 HP ULSD

DR

- TP

- 22 Flowback Boiler 1 various 8 MMBTU /Hr ULSD

DR

- TP

- 23 Boom Flare 1 various 60 MMSCF/ Day Natural

gas DR

- T P

- 24 DR

- T P

- 2 5 DR

- TP

- 26 Well Completion

Condensate Tanks (#1 to #3) 3

-- 21,000 Gallons Condens
ate

Table 1

- 5

. Summary of Emission Units on the Supply Boats

EPN Emission Unit Description # of units Model Rating or Capacity Fuel

Type or Contents SB

- ME

- 01 SB

- ME

- 02 Marine Propulsion Engines

(#1 and #2) 2 Caterpillar 3516C DITA or equivalent 3,004 HP ULSD SB

- TE

- 01 SB

- TE

- 02 SB

- TE

- 03 Marine Thruster Engines

(#1 to #3) 3 Caterpillar 3508C DITA or equivalent 1,100 HP ULSD SB

- GE

- 01 SB

- GE

- 02 Electrical Generator Engine

(#1 and #2) 2 Caterpillar C32 DITA or equivalent 1,047 HP ULSD

SB

- GE

- 03 Emergency Electrical

Generator #3 1 Caterpillar C9 DITA or equivalent 253 HP ULSD SB

- GE

- 04 ROV Electrical Generator 1 various 475 HP ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 14 Trinity Consultants EPN Emission Unit Description # of units Model Rating or Capacity Fuel

Type or Contents

SB

- DT

- 01 Vessel's Diesel Fuel Storage

Tanks #1 Port 1

-- 38,020 Gallons ULSD

SB

- DT

- 02 Vessel's Diesel Fuel Storage

Tanks #1 Starboard 1

-- 38,020 Gallons ULSD

SB

- DT

- 03 Vessel's Diesel Fuel Storage

Tank #2 Port 1

-- 38,424 Gallons ULSD

SB

- DT

- 04 Vessel's Diesel Fuel Storage

Tank #2 Starboard 1

-- 38,424 Gallons ULSD

SB

- DT

- 05 Vessel's Diesel Fuel Storage

Tank #3 Port 1

-- 42,398 Gallons ULSD

SB

- DT

- 06 Vessel's Diesel Fuel Storage

Tank #3 Starboard 1

-- 42,398 Gallons ULSD

SB

- DT

- 07 Vessel's Diesel Fuel Storage

Tank #4 Port 1

-- 42,346 Gallons ULSD

SB

- DT

- 08 Vessel's Diesel Fuel Storage

Tank #4 Starboard 1

-- 42,346 Gallons ULSD

SB

- DT

- 09 Vessel's Diesel Fuel Storage

Tank #5 Port 1

-- 6,572 Gallons ULSD

SB

- DT

- 10 Vessel's Diesel Fuel Storage

Tank #5 Starboard 1

-- 7,340 Gallons ULSD

SB

- DT

- 11 Vessel's Diesel Fuel Storage

Day Tank #1 Port 1

-- 6,027 Gallons ULSD

SB

- DT

- 12 Vessel's Diesel Fuel Storage

Day Tank #1 Starboard 1

-- 9,149 Gallons ULSD

SB

- DT

- 13 Vessel's Diesel Fuel Stern

Thruster Day Tank 1

-- 1,496 Gallons ULSD

SB

- DT

- 14 Vessel's Diesel Fuel

Overflow Port Storage Tank 1

-- 4,401 Gallons ULSD

SB

- DT

- 15 Vessel's Diesel Fuel

Overflow Standby Storage

Tank 1

-- 4,401 Gallons ULSD

SB

- FE

- 01 Work Boat Fugitive

Emissions

-- -- -- -- --

SB

- TP

- 0 1 SB

- TP

- 0 2 Well Evaluation Third Party

Engine (#6 and #7) 2 Caterpillar 3406C or equivalent 360 HP ULSD

SB

- TP

- 0 3 Well Evaluation Third Party

Crane Motor Engine #1 1 John Deere PE 4045D or equivalent 62 HP ULSD

SB

- TP

- 0 4 Well Evaluation Third Party

Crane Motor Engine #2 1 Cummins B 5.9

- C or equivalent 130 HP ULSD SB

- TP

- 05 to SB

- TP

09 Third Party Well Evaluation

Engines 5 Detroit Diesel ≤ 140 HP ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 15 Trinity Consultants

Table 1

- 6 . Summary of Emission Units on the Anchor Handling Boats

EPN Emission Unit Description # of units Model Rating or Capacity Fuel

Type or Contents AB

- ME

- 01 AB

- ME

- 02 Marine Propulsion Engine

(#1 and #2) 2 Caterpillar Model 3616 7,570 HP ULSD AB

- TE

- 01 AB

- TE

- 02 AB

- TE

- 03 Thruster Engines

(#1 to #3) 3 Caterpillar Model 3512B

- HD 1,674 HP ULSD AB

- GE

- 01 AB

- GE

- 02 AB

- GE

- 03 Service Generator Engines

(#1 to #3) 3 Caterpillar Model 3412C 716 HP ULSD

AB

- GE

- 04 AB

- GE

- 05 Service Generator Engines

Crane Dedicated (# 4 and #5) 2 Caterpillar Model 3508B 1,300 HP ULSD

AB

- GE

- 06 Emergency Generator Engine 1 Caterpillar Model 3406C 307 HP ULSD AB

- GE

- 07 AB

- GE

- 08 Winch Hydraulic Engines

(#7 and #8) 2 Caterpillar Model C32 1,300 HP ULSD

AB

- DT

- 01 Port Side Double Bottom

Diesel Fuel Tank #1 1

-- 12,842 Gallons ULSD

AB

- DT

- 02 Starboard Side Double

Bottom Diesel Fuel Tank #1 1

-- 12,852 Gallons ULSD

AB

- DT

- 03 Center Double Bottom

Diesel Fuel Tank #1 1

-- 15,706 Gallons ULSD

AB

- DT

- 04 Port Side Double Bottom

Diesel Fuel Tank #2 1

-- 31,483 Gallons ULSD

AB

- DT

- 05 Starboard Side Double

Bottom Diesel Fuel Tank #2 1

-- 31,483 Gallons ULSD

AB

- DT

- 06 Port Wing Diesel Fuel Tank #1 1

-- 16,321 Gallons ULSD

AB

- DT

- 07 Starboard Wing Diesel Fuel

Tank #1 1

-- 16,321 Gallons ULSD

AB

- DT

- 08 Port Side Double Bottom

Diesel Fuel Tank #3 1

-- 27,788 Gallons ULSD

AB

- DT

- 09 Starboard Side Double

Bottom Diesel Fuel Tank #3 1

-- 27,788 Gallons ULSD

AB

- DT

- 10 Port Wing Diesel Fuel Tank #2 1

-- 53,328 Gallons ULSD

AB

- DT

- 11 Starboard Side Double

Bottom Diesel Fuel Tank #4 1

-- 55,097 Gallons ULSD

AB

- DT

- 12 Starboard Wing Diesel Fuel Tank #2 1

-- 38,974 Gallons ULSD AB

- DT

- 13 AB

- DT

- 14 Port Side Double Bottom

Diesel Fuel Tank #4 and #5 1

-- 28,138 Gallons ULSD AB

- DT

- 15 Port Service Diesel Tank 1

-- 13,497 Gallons ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 16 Trinity Consultants EPN Emission Unit Description # of units Model Rating or Capacity Fuel

Type or Contents

AB

- DT

- 16 Starboard Service Diesel Tank 1

-- 13,497 Gallons ULSD AB

- DT

- 17 Port Diesel Settling Tank 1

-- 13,724 Gallons ULSD

AB

- DT

- 18 Starboard Diesel Settling Tank 1

-- 13,724 Gallons ULSD AB

- DT

- 19 Diesel Overflow Tank 1

-- 3,694 Gallons ULSD

AB

- FE

- 01 Anchor Handling Boat

Fugitive Emissions

-- -- -- -- --

Table 1

- 7 . Summary of Emission Units on the Stimulation Vessel

EPN Emission Unit Description # of units Model Rating or Capacity Fuel

Type or Contents

SV

- ME

- 01 SV

- ME

- 02 Stimulation Vessel Main

Propulsion Engines (#1 and #2) 2 various 3,634 HP ULSD SV

- BT

- 01 Bow Thruster Engine 1 various 1,675 HP ULSD SV

- DD

- 01 Bow Drop

- Down Engine 1 various 1,200 HP ULSD SV

- ST

- 01 Stern Thruster Engine 1 various 1,675 HP ULSD SV

- PE

- 01 through SV

- PE

- 08 Representative

Pump Engines (#1 to #8) 8 various 2,250 HP ULSD SV

- GE

- 01 SV

- GE

- 02 Generators (#1 and #2) 2 various 1,220 HP ULSD SV

- GE

- 03 SV

- GE

- 04 Generators (#3 and #4) 2 various 805 HP ULSD

Table 1

- 8 . Summary of Emission Units on the Tug Boats and Barges

EPN Emission Unit Description # of units Model Rating or Capacity Fuel Type

or Contents TB

- ME

- 01 TB

- ME

- 02 TB

- ME

- 03 Tug Boat Main Engines (#1 to #3) 3 various 2,200 HP ULSD TB

- GE

- 01 TB

- GE

- 02 Tug Generator Engine

(#1 and #2) 1 various 174 HP ULSD BG

- LP

- 01 BG

- LP

- 02 BG

- LP

- 03 Barge Electrical Generators

(# 1 to #3) 3 various 456 HP ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 17 Trinity Consultants

Table 1

- 9 . Summary of Emission Units on the Well Evaluation Vessel

EPN Emission Unit Description # of units Model Rating or Capacity Fuel

Type or Contents WE

- ME

- 01 WE

- ME

- 02 Well Evaluation Vessel Main

Engines (#1 and #2) 2 various 2,250 HP ULSD WE

- AE

- 01 WE

- AE

- 02 Well Evaluation Vessel Axillary

Engines (#1 and #2) 2 various 1,468 HP ULSD WE

- GE

- 01 Emergenc y Generator #1 1 various 272 HP ULSD WE_GE

- 02 Emergenc y Generator #2 1 various 212 HP ULSD WE

- GE

- 03 Generator Engine #3 1 various 200 HP ULSD



### 1.4. CONTENTS OF THE APPL ICATION ADDENDUM

This permit application is being submitted in accordance with 40 CFR 55.6(a)(1) and satisfies all applicable requirements of 40 CFR 52.21. This application includes the following:

Section 2 Proces s Description: contains a brief description of drilling and completion days; Section 3 Emission Calculations: contains the discussion of emission calculation methodology for all additional sources and operations in this application; Section 4 Regulatory A pplicability Analysis: contains the air regulatory applicability analysis for all emission sources related to the proposed drilling operations; Section 5 BACT Analysis: contains the BACT review for all emission sources in this application; Section 6 Part 7 1 forms: contains the Part 71 forms; and AppendicesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 18 Trinity Consultants 

## 2. PROCESS DESCRIPTION

This section describes the process involved in conducting the exploratory drilling, well completion, and production well maintenance operations, and associated source of air emissions as represented in this permit application.



### 2.1. EXPLORATORY DRILLING DESCRIP TION

The Diamond BlackHornet drillship is a dynamically

- positioned drillship that is designed for operation in the deep water (i.e., 10,000 feet of water or below. ) As a dynamically

- p ositioned drillship, the BlackHornet maintains its position over the desired location by using computer

- controlled thruster propellers rather than anchors and is not required to be attached to the seabed in order to establish or maintain its position like a traditional moored semi

- submersibl e drillship.

The dynamically positioned drillship transits to a particular drilling location and performs a bottom survey with a remotely operated vehicle (ROV) to mark the spud

- in location. The well is then spudded to initiate drilling operations at th e site. To accomplish this, a short length of pipe called the jet pipe is run to the seabed floor using a smaller multi

- purpose pipe called the drill pipe. The drill pipe is run through the jet pipe, terminating with a drill bit at the end. The drill bi t is spaced so that it extends just outside the jet pipe a few inches.

Seawater is pumped through the bit as the jet pipe is lowered into the seabed until approximately 12 feet of the end of the jet pipe remains above the seabed floor. The drill pipe i s then released from the jet pipe so that the drill bit can be used to drill the exploration well. Seawater or drilling fluid (mud) is pumped down the drill pipe out the bit to clean the hole as the drill bit is rotated with weight put down on the formati on. Once the drill bit has drilled to a designated depth, the drill bit is retrieved back to surface, leaving the jet pipe and a section of hole drilled below the jet pipe. Another pipe called the surface casing is then run through the jet pipe and into the open

- hole section. Cement is then pumped around the outside of the casing to cement it in place. Once surface casing has been set, the blow out preventer (BOP) is run.

The BOP is run on pipe called the drilling riser which is connected to the wellbo re at the seabed floor. This arrangement allows a closed loop system in which fluids pumped through the drill bit return to the drillship for reuse. The BOP also serves as a safety device protecting against a well blowout. The drill and cas ing process i s then repeated to progress the well to the well objective depth. Casings are run at designed intervals according to the subsurface data used to design the well. Each time a casing is run, the next section's casing will be smaller in order to fit inside the casing that has just been cemented.

Once the well objective depth in the potential reservoir is achieved, an evaluation program is carried out. This typically involves running a series of wire line tools to measure various properties of the formatio n. Depending upon the evaluation results, the well will either be sidetracked to another objective, abandoned, or a casing set. Once the exploratory work scope is completed, the well is plugged with cement and/or mechanical tools. The BOP is retrieved a long with the riser and an ROV bottom survey is performed. This will complete the exploratory drilling activity for one location.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 19 Trinity Consultants During the exploratory drilling, several diesel fired internal combustion engines are used to provide power for several acti vities. The main engines on the drillship are utilized to maintain a position of the drillship as well as to supply power to the drilling activity. Some of these engines are fixed on the drillship (such as main engines, emergency generators, and air comp ressors etc.) and remaining engines are brought onboard as required (i.e., third party engines such as wire line engines, casing units and electric line engines etc.). These engines emit criteria pollutants, GHG s , as well as hazardous air pollutants (HAP s) due to combustion of diesel fuel. Several diesel fuel storage tanks are located on the drillship and these tanks emit VOCs due to variation in ambient temperature (also known as ‘breathing losses’) and during fuel loading activity (also known as ‘worki ng losses’). These storage tanks are equipped with pumps, flanges, connectors, and/or other miscellaneous devices (also known as fugitive components of air emissions) for transferring the fuel from one location to other. The support vessels also operate s everal diesel fired internal combustion engines and fuel storage tanks contributing to air pollution. Other miscellaneous air pollution sources during the drilling activity include painting operations, mud degassing, and cement and mud mixing operations. Air emissions from these activities are described in details in Section 3 of this application.



### 2.2. WELL COMPLETION

Once a well has been drilled and evaluated, a decision must be made whether to complete the well or plug it. If the well is to be completed , a well head which serves as the pressure

- containing equipment will be installed subsea where casing strings are suspended and the BOP or subsea tree is connected.

Production casing is run down the hole and cemented. Once the casing is in place, holes a re perforated through the casing, cement, and into the reservoir. These holes are made to facilitate material transfer between the reservoir and the production casing. Tubing along with the packer is run into the casing. A plug is set above the perforat ions as a barrier between the production casing and the tubing.

For a gas well, a gravel pack completion assembly is typically installed to reduce the inflow of sand from the formation. The formation is perforated through the well casing to allow the ex pected natural gas into the well and then to the surface. During the well completion phase, a sub

- sea well head is installed on the sea floor and the production tubing, with down

- hole control valve, and packer is lowered into the finished well (inside the final casing string).

Thereafter, a production packer and a tubing are installed. Production packers are placed above the production zone. The packer isolates the annulus between the tubing and the inner casing and the foot of the well. It provides a seal to stop reservoir f luids from flowing up the full length of the casing and damaging it. Production tubing plays the role of the main conduit for transporting hydrocarbons from the reservoir to surface (or injection material the other way). It runs from the tubing hanger at the top of the wellhead down to a point generally just above the top of the production zone. Tubing hanger sits on top of the wellhead and serves as the main support for the production tubing.

A surface

- controlled sub

- surface safety valve (SCSSV) is ins talled in the production tubing and is held in the open position by a high

- pressure hydraulic line from surface contained in a control line that is attached to the down

- hole control valve's hydraulic chamber and terminated at surface to a hydraulic
actuato r. The high pressure is needed to overcome the production pressure in the tubing upstream of the choke on the tree. The SCSSV acts as a safety device in the event of the wellhead/tree/tubing failure. During temporary unloading/flowback phase, through po rtable well testing equipment on a drillship,Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 20 Trinity Consultants the hydrocarbons flow up the tubing and are processed through surface well test equipment. The hydrocarbons are separated and the gas flared and the liquids are directed to the barge or to the tanks

. After fl owback is completed and the well is cleaned up, the well is secured until flow lines are installed to the production facility.

During the well completion , several diesel fired internal combustion engines are used to provide power for different activities

. The drillship main engines supply power along with various third party equipment to perform different activities

. This phase could require use of supply boats, tug boats, barges, stimulation vessel, or well evaluation vessel to support the various acti vities . The different well completion scenario and associated sources of air emissions are described in the Section 3

.



### 2.3. PRODUCTION DESCRIPTI ON (WELL MAINTENANCE )

After completion activities, the well is brought on production, and the oil and gas is flowed back to the production facility for processing and then sent to shore via the sales pipeline. Downhole equipment failure or reservoir

- related issues (i.e., remedial well

- work/maintenance) may require drillship intervention to repair and restore prod uction to the well.

The drillship, the support vessels, and/or the stimulation vessel will conduct remedial well

- work if needed after the well is put in production. The air pollution sources during the well maintenance are similar to that of the drilling and the well completion phases. Emissions associated with well maintenance phase are lower compared to that of drilling and well completion phases and therefore, emissions associated with the well maintenance activities are not separately estimated in th is application.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 21 Trinity Consultants 

## 3. EMISSIONS CALCULATIO NS

This section presents a summary of the emissions calculation methodologies, emission factors, and operating parameter assumptions for estimating emissions from the sources of air pollution on the drillship, the sup ply boats
, the stimulation vessel, the well evaluation vessel, and miscellaneous activities. The detailed emissions calculations are included in Appendix B of this application.



### 3.1. ‘EQUIVALENCY’ DETERM INATION

As mentioned previously, Anadarko will operate var ious emission units for which exact specifications are not available at this time due to scheduling and other contractual agreements that will be completed in the future. Therefore, Anadarko has proposed the worst case emission units for each category of air pollution sources to develop the PTE while maintaining sufficient operational flexibility to provide Anadarko the ability to utilize various, ‘equivalent’ operational equipment. Also, Anadarko proposes the demonstration of ‘equivalency’ based on the f ollowing factors:

Equal or lower mass emissions for each criteria, toxic, and other regulated air pollutants on a short

term (e.g., lbs/day) and a long

- term (e.g., ton/year) basis; Compliance with applicable regulations (e.g., 40 CFR 60, 40 CFR 63); Compliance with applicable c ertifications (e.g., EPA Tier 2, IMO Tier 2 ); and Compliance with applicable BACT requirements identified for representative equipment.

A list of equipment for which Anadarko is requesting above

- mentioned flexibility is provid ed below.

Third party engines (DR

- TP

- 01 through DR

- TP

- 21) Supply boats and all a ssociated air pollution sources (all EPNs starting with SB and AB) Stimulation vessel and all a ssociated air pollution sources (all EPNs starting with SV) Well evaluation vess el and all associated air pollution sources (all EPNs starting with WE) Tug boats , barges and all associated air pollution sources (all EPNs starting with TB and BG) Other miscellaneous sources (such as painting , welding , etc.) as described in this applica tion.



### 3.2. OPERATING SCENARIOS

Various operating scenarios can occur during the drilling, well completion, and maintenance phases. The proposed project can be broadly classified in to six operating scenario . The goal of this classification is to represent the worst

- case hourly, 24

- hour , and annual air emissions for calculating Potential to Emit (PTE) . The following scenarios were derived for estimating the PTE

.

Worst

- case gas well flowback scenario; Wors t

- case oil well flowback scenario; Worst

- case s timulation vessel operations scenario; Well completion t hird part y equipment operations scenario; Well evaluation vessel operations scenario; and Worst

- case drilling scenario

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 22 Trinity Consultants 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

- cas e 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 typical ly 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, H 2 SO 4 , and HAPs.



### 3.3. DRILLSHIP

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



### 3.3.1. M ain Engines (DR

- ME

- 01 through DR

- ME

- 08)

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

- HiMSEN
, 9H32/40 6,035 HP diesel

- fired engines. The other two engines are HYUN DAI

- 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 belo w.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– CO, VOC, 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). Non

- methan e VOC emission factor has been taken as 91% of the total organic compounds (TOC) emission factor.

NSPS Subpart IIII

- Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

– Particulate Matter and NO X Emission estimate s for the eight main engines are based on the emission standards specified in 40 CFR 60.4204(c) for non

- emergency stationary CI engines with a displacement of greater than or equal to 30 liters per cylinder and installed after January 1, 2012 and before January 1, 2016 w here maximum engine speed is greater than 130 rpm but less than 2,000 rpm. Furthermore, based on AP

- 42 guidance, all of the particulate matter is assumed to be less than 1 μm. Therefore, it is assumed PM 2.5 = PM 10 = PM.

EPA Guidance Documents

– Lead emi ssion 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

– CO 2 , CH 4, and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of F uel) andAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 23 Trinity Consultants Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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 diese l combustion sources. Therefore, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to sulfuric acid (H 2 SO 4 ) 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 (H 2 S), total reduced sulfur (TRS), and reduced sulfur compounds resulting fr om 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 1 79 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 f actor s (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 123 cubic meters/day for all the diesel combustion sources located on the drillship. This fuel cap is the highest fuel usage of all the six scenarios. The daily fu el cap is derived based on the maximum daily power requirement of 576,000 KW.

Also , Anadarko proposes to use 18,438 cubic meters/year fuel for all the diesel combustion sources located on the drillship. The annual fuel limit is calculated based on approx imately 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 t o 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 calculated based on the fuel based emission factor and maximum fuel requirement of 5.1 cubic meter 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 123 cubic meter 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 cubic meter of fuel.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 24 Trinity Consultants 

### 3.3.2. Emergency Generator (DR

- GE

- 01)

The drillship includes one 2,547 HP Cummins QSK60DMGE d iesel

- fired emergency generator

. Air

e missions 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 the engine are

summ arized below.

IMO Tier 2 NO X Emission Limits

– The NO X , emissions factors are obtained from IMO Tier 2 Emission Limits since this engine is IMO Tier 2 ce rtified.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– PM VOC, and HAP emissions estimates for the emergency generator is based on AP

- 42, Section 3.4 emission factors (Table 3.4

- 1, Table 3.4

- 2, and Table 3.4

- 3). Non

- methane VOC emission factor has been taken as 91% of the TOC emission factor. All of the particulate matter is assumed to be less than 1 μm. Therefore, it is assumed PM 2.5 = PM 10 = PM.

Manufacturer Specification

– The CO emissions factors are obt ained from the manufacturer’s specification sheet.

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

– CO 2 , CH 4 , and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur comp ounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily , and annual emissions from the emergency generator are calculated as described below:

Maximum Hourly Emissions

– The maximum hourly emissions for the emergency generator are calculated based on one hour of operation.

Maximum Daily Emissions

– The maximum daily emissions for the emergency generator based on 2 hrs/day operation.

Annual Emissions

– The annual emissio ns for the emergency generator calculated based on annual operation of 100 hours

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 25 Trinity Consultants Proposed Operating Limits :

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 EPA Tier 2 certified. The specification sheet is provided in Appendix G

- 1. 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, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the third party engines are based on 40 CFR 89 Tier 2 exhau st emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X 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 PM 2.5 = PM 10 = 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 turbi nes was used as a surrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 , and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds r esulting 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:Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 26 Trinity Consultants Maximum Hourly Emissions

– The maximum hourly emissions for the air compressor are calculated based on 0.5 hours of operation.

Maximum Daily Emissions

– The maximum daily emissions for the air compressor calculated based on 0.5 hours of operation.

Annual Emissions

– The annual em issions for the air compressor calculated based o n 100 hours of operation

. Proposed Operating Limits :

Since this emission unit will be a part of drillship

- wide fuel consumption limit, no separate fuel limit is required to demonstrate compliance. Anadar ko will maintain adequate records to comply with proposed daily and annual operation limits.



### 3.3.4. Life Boat Engines (DR

- LB

- 01 through DR

- LB

- 06)

The drillship consists of six SIYANG 485

- J 41 HP, diesel

- fired life boat engines. The specification sheet is provide d in Appendix G

- 1. The life boats will be operated during emergency situations, drills and periodically operated for maintenance checks. Emissions are generated as a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission facto rs used to estimate emissions for the engines are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , VOC, CO, and HAP emissions estimates for the diesel

- fired life boat engines ar e based on AP

- 42, Section 3.3 emission factors. Based on AP

- 42 guidance, all of the particulate matter is assumed to be less than 1 μm. Therefore, it is assumed PM 2.5 = PM 10 = PM. All of the TOC is assumed to be VOC. TOC emission factor has been calculated as the sum of exhaust and crankcase emission factors. An average BSFC of 7,000 Btu/HP

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

- hr.

EPA Guida nce 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 wa s used as a surrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to sulfuric acid (H 2 SO 4 ) mist based on Section 4.1.1 of Draft Regulatory ImpactAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 27 Trinity Consultants Analysis: Control of Emissions from Nonroad Diesel Engines, EPA420

- R

- 03

- 008, April 2003. Emissions of Hydrogen sulfide (H 2 S), total reduced sulfur (TRS), and reduced sulfur compounds

res ulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions from the life boat engines are calculated as described below:

Maximum Hourly Emissions

– The maximum hourly emissions for the life boats are calculated based on 1 hour of operation per engine.

Maximum Daily Emissions

– The maximum daily emissions for the life boats are calculated based on 1 hour of operation per day per engine.

Annual Emissions

– The annual emissions for the life boats are calculated based on 100 hours of annual operation per engine

. Proposed Operating Limits :

Since th ese emission units will be a part of drillship

- wide fuel consumption limit, no separate fuel limit is required to demonstrate compliance. Anadarko will maintain adequ ate records to comply with proposed daily and annual operation limits.



### 3.3.5. Fast Rescue Craft (DR

- FR

- 01)

The drillship consists of one EPA Marine Tier 2 fast rescue craft with 55 HP power rating and SABB

- L4 Turbo engine. The specification sheet for the representative engine is provided in Appendix G

- 1. Emissions are generated as a result of combustion of diesel fuel used in the engine.

Emissions Factors

– The sources of emission factors used to e stimate emissions for the engine are summarized below.

40 CFR 89 Control Of Emissions From New And In

- Use Nonroad Compression

- Ignition Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the third party engines are based on 40 CFR 89 Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X 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 PM 2.5 = PM 10 = 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 Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

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

-Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 28 Trinity Consultants 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.

Mass Balance

– Anadarko proposed the use of ULS D fuel for all diesel combustion sources. Therefore, SO 2 emissions are calculated based on a maximum sulfur content of 15 ppm in diesel fuel and assuming that 98 percent of sulfur in the fuel will be converted to SO 2 and 2 percent of the sulfur in the fue l will be converted to H 2 SO 4 based on U.S. EPA guidance document.

The maximum hourly, daily, and annual emissions from the main engines are calculated as described below:

Maximum Hourly Emissions

– The maximum hourly emissions for the fast rescue craft a re calculated based on one hour operation.

Maximum Daily Emissions

– The maximum daily emissions for the fast rescue craft are calculated based on 1 hour/day operation.

Annual Emissions

– The annual emissions for the fast rescue craft are calculated base d on 100 hours per year operation.

Proposed Operating Limits :

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.



### 3.3.6. Mud degassing Vent (DR

- VG

- 01)
Drilling mud is used in the drilling process to cool and lubricate the drill bit. When the drilling mud returns to the surface, it may contain entrained hydrocarbons from the well. On reaching the surface, off

- gassing occurs, leading to VOC emissions. Also during this process, Anadarko may emit trace amounts of H 2 S during non

- routine conditions that could be encountered while drilling. At this juncture, Anadarko can not reasonably quantify the H 2 S amount emitted or anticipate how much H 2 S, if any, will be encountered during this operation as this would only occur during non

- routine, upset conditions. As such, H 2 S emitted during mud degassing operation would be consid ered an upset condition which is not required to be permitted under PSD (40 CFR 52.21) and Title V (40 CFR 71) regulations.

Emissions Factors

- The emission factor sources used in the development of emissions estimates for the mud degassing operations are summarized below.

MMS Guidance Document

– Emission factors for total hydrocarbon (THC) emissions during degassing for synthetic

- based muds, and the volume percent composition of the THC emissions were obtained based on a study commissioned by the for mers Mineral Management Services (MMS) that is currently the Bureau of Ocean Energy Management (BOEM). Specifically, theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 29 Trinity Consultants emission factors and volume % speciation were obtained from Year 2005 Gulfwide Emission Inventory Study, conducted by the Eastern Rese arch Group, Inc. 2



### Operating Parameters

- The maximum hourly, daily and average annual emissions from the mud degassing operations are calculated based on the following operating parameters.

Maximum Hourly/Daily Emissions

– Based on the expected throug hp u ts of synthetic

- based muds for the proposed operations and based on the emission factors provided in the guidance document referenced above, a weighted average THC (lb/day) emission factor has been developed. Also, the volume % composition obtained from t he MMS guidance document have been converted to weight % based on molecular weights of the components.

As shown in Appendix B, m aximum hourly speciated emissions are calculated based on the weighted average THC emission factor and weight % of the specia ted components, using 24 hours of operation per day. Maximum hourly VOC emissions are obtained as the sum of all speciated hourly emissions except methane and ethane.

Annual Emissions

– Annual emissions for the mud degassing operation have been estimat ed similar to the maximum hourly emissions. Annual emissions are calculated using pound per day emission factors and a worst

- case 4, 800 hours of operation per year.



### 3.3.7. Dust Collectors ( DR

- DC

- 01 through DR

- DC

- 03)
Mud and cement mixing operations on the drillship are controlled by three National Oilwell Varco dust collectors. The specification sheet for these dust collectors is provided in Appendix G

- 1.

Emissions Factors

- The emission factor sources used in the d evelopment of emissions estimates for the dust collectors are summarized below.

AP

- 42, Section 11.12

. Concrete Batching

– Particulate matter (PM, PM 10 , and PM 2.5 ) emissions estimates for the cement mixing operations are based on the controlled emission fa ctor provided in AP

42, Section 11.12 Concrete Batching emission factors (Table 11.12

- 2)

. Operating Parameters

– The maximum hourly , daily and annual emissions from the dust collectors are calculated based on the following operating parameters.

Maximum Hourly Emissions

– Maximum hourly emissions are estimated based on 150 tons/hr of maximum process rate

. Maximum Daily Emissions

– Maximum dai ly emissions are estimated based on 150 tons/hr of maximum process rate and 24 hrs/day operation

.

Annual Emissions

– Maximum annual emissions are estimated based on 150 tons/hr of maximum process rate and 4,800 hrs/ year operation

.

2 Wilson, Darcy, Richard Billings, Regi Oomen, and Roger Change; Eastern Research Group, Inc.; Year 2005 Gulfwide Emission Inventory Study; US Department of Interior, Minerals Management Service; Gulf of Mexico OCS Region, New Orleans, December 2007.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 30 Trinity Consultants 

### 3.3.8. Storage Vessels (DR

- FT

- 01 through DR

- FT

- 18)

The drillship includes following fuel storage tanks :
Diesel fuel storage vessels (16)

– various capacities Helicopter fuel storage tanks (2)

– 2,900 gallons each

Emissions from all storage vessels on the Drillship have been estimated using EPA’s TANKS 4.0.9d (TANKS) program. Default TANKS properties for distillate fuel oil No. 2 were use d to model the contents of the diesel tanks. Default speciation profile and physical and chemical properties for Jet Naphtha (JP

4) in TANKS 4.09d program are used to model the contents of the helicopter fuel storage tanks. Refer Appendix G

- 4 for Tanks p rogram output.

The maximum diesel fuel usage for the Drillship is 123 cubic meters/day. To represent conservative scenario, a throughput equal to twice the fuel usage restriction. It was assumed that all fuel will be loaded into the largest tank DR

- DT

- 0 4 to calculate the maximum total tank VOC emissions (tpy) on the drillship.

Maximum hourly emissions was calculated using EPA TANKS 4.09d program for the month of June, since June results in the highest daily emissions.



### 3.3.9. Drillship Fugitive Emissions (DR

- FE

- 01)
The fugitive emissions on the drillship occur from the diesel fuel lines and associated components

. Emissions from the lines are based on an estimated number of components and heavy oil emission factors from Table 2

- 4 of the EPA Protocol for Equipmen t Leak Emission Estimates. Since t he exact component counts were not available, component count were conservatively estimated using engineering judgments and based on the component counts for the other drillship currently leased by Anadarko.

Operating Parameters

– The maximum hourly , daily and annual fugitive emissions are calculated based on the following operating parameters.

Maximum Hourly Emissions

– Maximum hourly emissions are estimated based on one hour operation

. Maximum Daily Emissions

– Maximum dai ly emissions are estimated based on 24 hrs/day operation

.

Annual Emissions

– Maximum annual emissions are estimated based on 4,800 hrs/ year operation

.



### 3.3.10. Painting Operations (DR

- PO

- 01)
As part of maintenance activity, painting happens on the Bl ackHornet drillship. PM/PM 10 /PM 2.5 , VOC, and HAP emissions are calculated based on the average thinner usage, average primer usage, 3 0% air assisted spray transfer efficiency and paint/primer usage of maximum 40 gal/day and thinner usage ofAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 31 Trinity Consultants maximum 10 gal/ day. Total emissions are estimated based on the sum of worst

- case primer and thinner components. Anadarko proposes to maintain the flexibility of using the aforementioned air assisted or an air less spray gun with a 5 0% spray transfer efficiency (i.e., m ore efficient in transferring the material.) The PTE of PM/PM 10 /PM 2.5 , VOC, and HAP were estimated for air assisted spray gun operations to represent the worst case scenario. The specification sheet for the airless and air assisted spray gun s along with the MSDS sheets for the paints, primers and thinn ers are provided in Appendix G

- 6

. Refer to Appendix B for assumptions, material usage limits, and detailed calculations.

Proposed Operating Limits :
Anadarko proposes annual limits of 5,200 gallons and 1,300 gallons for paints (i.e., any combination of paints, base, primer etc.) and thinner, respectively. Anadarko will maintain adequate records to comply with proposed daily and annual operation limits.



### 3.3.11. Welding Operations (DR

- WO

- 01)

Anadarko proposes to carry out welding operations as part of the maintenance activities on the drillship. The proposed welding activity will use 8 0 lbs of welding rods per day, and 20 0 days per year.

Emissions Factors

– Anadarko proposes to use several different types of wel ding rods. The welding rods resulting in maximum emissions are included in the emission calculations in Appendix B

. Anadarko proposes to maintain a flexibility to utilize any other welding rod as long as the resulting emissions are less than the proposed maximum emissions.

AP

- 42, Section 12.19 Electric Arc Welding

– PM 10 and HAPs emissions estimates for the proposed welding activity are based on AP

- 42, Section 12.19 emission factors (Table 12.19

- 1). PM and PM 2.5 emissions are assumed to be same as PM 10 . Operating Parameters

– The project emissions from the welding operations are calculated based on the following operating parameters.

Maximum Hourly Emissions

– Maximum hourly emissions for the welding operati ons are calculated based on 3.33 lbs of wel ding rod usage per hour.

Maximum Daily Emissions

– Maximum daily emissions for the welding operations are calculated based on 80 lbs of welding rod usage per day

.

Annual Emissions

– Maximum annual emissions for the welding operations are calculated based on 16,000 lbs of welding rod usage per year

.
Proposed Operating Limits :
Anadarko proposes annual welding rod usage limit of 16,000 lbs. Anadarko will maintain adequate records to comply with pro posed daily and annual operation limits.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 32 Trinity Consultants 

### 3.3.12. Third Party Engines (DR

- TP

- 01 through DR

- TP

- 21)
Various third party engines are required during the drilling and well completion operations. These engines are EPA Tier 2 certified engines (except DR

- TP

- 12 and DR

- T P

- 16) and can be grouped in the following categories:

Third Party Engines ≤ 860 HP (DR

- TP

- 01 and DR

- TP

- 02) Third Party Engines ≤ 300 HP (DR

- TP

- 03 through DR

- TP

- 11) Third Party Engines ≤ 140 HP ( DR

- TP

- 12 through DR

- TP

- 16) Third Party Engines ≤ 126 HP (DR

- TP

- 17 through DR

- TP

- 21 )

N ote that the third party engines shown in this application are for representation purposes only, and Anadarko may replace these engines with equivalent engines as specified in Section 3.1 with equal or lesser emissions. The s pecification sheets for the equivalent engines are provided in Ap pendix G

- 2 and Appendix G

- 3 . Emissions from third party engines will be a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for each of these engines are summarized below.

40 CFR 89 Control Of Emissions From New And In

- Use Nonroad Compression

- Ignition Engines

– Except for engine s DR

- TP

- 12 through DR

- TP

- 16 , Parti culate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the third party engines are based on 40 CFR 89 Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X 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 PM 2.5 = PM 10 = PM.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– VOC and HAP emissions are based on emission factors from AP

- 42 Chapter 3.3, Table 3.3

- 2: Speciated Organic Compound Emission Factors for Uncontrolled Diesel Engines. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions. Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the third party engine s DR

- TP

- 12 through DR

- TP

- 16 are based on AP

- 42, Chapter 3, Table 3.3.1, Emission Factors for Uncontrolled Gasoline and Diesel Industrial Engines.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

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

s urrogate for distillate oil

- fired engines due to lack of emission factors.

Mass Balance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions are calculated based on a maximum sulfur content of 15 pp m in diesel fuel assuming that 98 percent of sulfur in the fuel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to sulfuric acid (H 2 SO 4 ) mist based on Section 4.1.1 of Draft Regulatory Impact Analysis: Control of Emissions from Nonroad D iesel Engines, EPA420

- R

- 03

- 008, April 2003. Emissions ofAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 33 Trinity Consultants Hydrogen sulfide (H 2 S), total reduced sulfur (TRS), and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions from the t hird party engines are calculated based on the derived fuel based emission factor as described below:

Maximum Hourly Emissions

– The maximum hourly emissions are calculated based on 1 hour operation per engine.

Maximum Daily Emissions

– The maximum daily emissions are calculated based on 24 hours/day operation per engine.

Maximum Daily Emissions

– The maximum a nnual emissions are calculated based on 4,800 hours /year operation per engine.

Proposed Operating Limits :

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.



### 3.3.13. Flowback Boiler (DR

- TP

- 22)

A "SIGMA FIRED" SF

- 2 00SE, 8 MMBtu/hr flowback boiler or equivalent will be used for certain well completion operations. A copy of the specification s heet is provided in Appendix G

- 9

.

Emissions Factors

– The sources of emission factors used to estimate emissions for this boi ler are summarized below.

AP

- 42, Section 1.3 Fuel Oil Combustion

- The sources of emission factors used to estimate emissions for this boiler are cited from AP

- 42, Section 1.3. Fuel Oil Combustion and emission Factors for No.2 fuel oil was used. PM, SO 2 , NO X , and CO emissions are based on emission factor s from AP

- 42 Chapter 1.3, Table 1.3

- 1 Criteria Pollutant Emissions Factors for Fuel Oil Combustion and 1.3

- 2, Condensable Particulate Matter Emission Factors for Oil Combustion. Total particulate emissio ns are the sum of filterable and total condensable particulate emissions. All PM is assumed to be < 1 um, therefore, it is assumed PM 2.5 = PM 10 = PM. VOC emission factors are obtained from AP

- 42 Section 1.3, Table 1.3

- 3 Emission Factors for Total Organic compounds from Uncontrolled Fuel Oil Combustion. All non

- methane TOC is assumed to convert to VOC. HAP Emission Factors are obtained from AP

- 42 Section 1.3, Table 1.3

- 9 Emission Factors for Speciated Organic Compounds from Fuel Oil Combustion, and Table 1 .3

- 10 Emission Factors for Trace Elements from Distillate Fuel oil Combustion Sources.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 34 Trinity Consultants Operating P arameters

– The maximum hourly, daily and annual emissions from the boiler are calcul ated based on the following operating parameters.

Maximum Hourly Emissions

– Maximum hourly emissions for the boiler are calculated based on related emission factors and 8 MMBtu/hr of rated heat input.

Maximum Daily Emissions

– Maximum daily emissions for this boiler are calculated based on 192 MMBtu/day.

Annual Emissions

– The annual emissions from the boiler are calculated based on 1152 MMBtu/year.

Proposed Operatin g Limits :

A nadarko proposes annual heat input limit of 1152 MMBtu . Anadarko will maintain adequate records to comply with proposed daily and annual operation limits.



### 3.3.14. Boom Flare (DR

- TP

- 23 )

A gas fired Boom Flare capable of processing 60 MMScf/day could be used during the well completion operation. Since the exact equipment specifications are not known, a typical VOC reduction efficiency of 98% is a ssumed. Emissions are generated as a result of combustion process.

Emissions Factors

– The sources of e mission factors used to estimate emissions for the representative flare are summarized below.

AP

- 42, Section 13.5 Industrial Flares

- NO X , CO, and VOC emission factors are based on AP 42 Section 13.5, Table 13.5

- 1 Emission Factors for Flare Operations. To tal hydrocarbon are assumed to be VOC.

AP

- 42, Section 1.4, Natural Gas Combustion

- SO 2 and Particulate Matter (PM, PM 10 , and PM 2.5 ) emission factors are obtained from AP

- 42 Section 1.4, Table 1.4

- 2 Emission Factors For Criteria Pollutants And Greenhouse Gases From Natural Gas Combustion . Total particulate emission is the sum of filterable and total condensable particulate emissions. All PM is assumed to be < 1 um, therefore, it is assumed PM 2.5 = PM 10 = PM. Each individual HAP emission facto r (except total POM emission factor) is based on AP

- 42 Section 1.4, Table 1.4

- 4 Emission Factors for Metals from Natural Gas Combustion. Per footnote b and c of AP

- 42 Section 1.4, Table 1.4

- 3 Emission Factors for Speciated Organic Compounds from Natural Ga s Combustion , all individual species of POM have been conservatively added and represented as HAP. The emission factor for POM is calculated as the sum of the emission factors for all the individual species of POM.

EPA Regulations

– CO 2 , CH 4 and N 2 O emis sion factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been c alculated using the GWPs obtained from 40 CFR 98 Subpart A.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 35 Trinity Consultants Operating Parameters

– The maximum hourly, daily and annual emissions from the representative flare are calculated based on the following operating parameters.

Maximum Hourly Emissions

– Maximum hourly emissions for the representative flare are calculated based on a process rate of 2.5 MMscf/ hr

. Maximum Daily Emissions

– Maximum daily emissions for this representativ e flare are calculated based on a gas process rate of 60 MMscf/ day

.

Annual Emissions

– The annual emissions from the representative flare are calculated based on a gas process rate of 360 MMscf/year.

Proposed Operating Limit

– Anadarko proposes to demonstrate compliance with a maximum firing rate of 60 MMScf/day or 360 MM Scf/year. Anadarko proposes to maintain the flexibility of flaring at a higher flow rate as long as they stay at or below the mass emission limits as established in Appendix B.

Proposed Operating Limits :
Anadarko proposes a n annual gas process limit of 360 MMScf.



### 3.3.15. Well Completion Condensate Tanks ( DR

- TP

- 24 through DR

- TP

- 26 )

There are three condensate tanks in the well completion operation

Emissions from three condensate tanks in the well completion have been estimated using EPA’s TANKS 4.0.9d (TANKS) program. Default TANKS properties for Gasoline RVP 13 were used to model the contents of the condensate tanks. To represent conservative scen ario, a throughput equal to twice the fuel usage was used

. The TANKS output files are presented in Appendix B.

The m aximum hourly emissions w ere calculated using EPA TANKS 4.09d program for the month of June, since June results in the highest daily emiss ions. They could be used during every completion so I don’t think I’d say this. I’d double the capacity as throughput to be safe.



### 3.4. SUPPORT VESSELS

As discussed under Section 2 of the application, the associated support vessels proposed for this project will include a combination of supply boats (work boat and crew boat) , well evaluation vessels, well stimulation vessels, tug boats and barges, and an anchor handling boat

. These vessels will be used for transport of fuel and equipment as well as performin g various operations. Except for barges, Anadarko is proposing fuel consumption limit for each category of support vessel as described below.

E missions from support vessels while the support vessels are at the drillship, and while enroute to or from the drillship when within 25 m iles of the drillship

. For purposes of the air permit application, representative emissions from the support vessels potentially available to support operations of the BlackHornet drillship have been quantified. Based on review of all available supply boats, the HOS Coral supply boat was found to be the worst case supply boat for emission estimations. If anchor handlingAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 36 Trinity Consultants boat is utilized as a supply boat then it will be subject to same short term and long term emission limits
est ablished for the HOS Coral. Anadarko proposes to maintain the flexibility of utilizing any supply boat as long as it meets the criteria of equivalency specified in Section 2.1. While complying with mass emissions to demonstrate equivalency, Anadarko prop oses to use equal or lower emission for the entire supply boat and not on equipment by equipment basis.



### Supply Boats (HOS Coral) Combustion Sources

3.4.1. Marine Propulsion Engines 1 and 2 (SB

- ME

- 01 and SB

- ME

- 02)

HOS Coral supply boat consists of two 3,004 HP (2,240kW) Caterpillar 3516C DITA diesel

- fired marine propulsion engines. Emissions are generated as a result of combustion of diesel fuel from the engines. The specification sheets for these engi nes are provided in Appendix G

- 10

.

Emissions Factors

– The sources of emission factors used to estimate emissions for these engines are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– VOC and HAP emissions estimates for the engin es are based on AP

- 42, Section 3.4 emission factors. Non methane VOC emission factor has been taken as 91% of TOC emission factor. A calculated heat rate of 19.16 MMBtu/hr was used to convert from lb/MMBtu to lb/hr to calculate emissions.

40 CFR 94 Cont rol of Emissions From Marine Compression

- Ignition

- Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the main propulsion engines are based on 40 CFR 94 Marine Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X emission factor. Emission factor of PM 2.5 and PM 10 are calculated based on ratio of PM/PM 2.5 and PM/PM 10 which are obtained from AP

- 42 Chapter 3, Table 3.4

- 2. Total particulate emission factor used in the ratio has been taken as the sum of filterable and condensable particulate emissions.

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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 S ubpart A.

Mass Balance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 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 ox idized to SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 37 Trinity Consultants Fuel Based Emission Factor Derivation :
Based on the specifications sheets for each engine, the BSFC was used to convert the above mentioned emission factors to lbs of pollutant/bb l of fuel consumed for all permanent diesel combustion sources on the supply boat as shown in Appendix B. Hence, Anadarko is proposing supply boat

- wide fuel limit, derived using the fuel based emission factors, to establish operating limits and PTE calcul ations for supply boats.

Proposed Operating Limits :
Anadarko proposes a supply boat

- wide fuel limit of 200 bbl/day and 40,000 bbl/year based on the historical fuel consumption records for comparable supply boats

. Note that certain operating situation require more than one supply boats simultaneously within 25 nautical miles from the drillship. In that case, the proposed fuel limit will serve as a combined fuel limit for all supply boats. For example, if two supply boats provide support to the drill ship operations during the same day simultaneously then total fuel consumption on both the supply boats will not exceed 200 bbl/day and both the supply boats will meet “equivalency” criteria specified above.

The maximum hourly, daily, and annual emissi ons 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 calculated based on the fuel based emission factor and maximum fu el requirement of 8 bbl 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 200 bbl/day of fuel.

Annual Emissions

– The annual emissions for the main engines are based on the fuel based emission factor and maximum fuel requirement of 40,000 bbl/year of fuel.



### 3.4.2. Marine Thruster Engines (SB

- TE

- 01 through SB

- TE

- 03)

HOS Coral supply boat includes three 1,100 HP ( 820 kW) Caterpillar 3508C DITA diesel

- fired marine thruster engines. Emissions are generated as a result of combustion of diesel fuel from the engine.

Emissions Factors

– The sources of emission factors used to estimate emissions for this engine are

summar ized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– VOC and HAP emissions estimates for the engines are based on AP

- 42, Section 3.4 emission factors. Non methane VOC emission factor has been taken as 91% of TOC emission factor. A calculated heat rate of 7.01 MMBtu/hr was used to convert from lb/MMBtu to lb/hr to calculate emissions.

40 CFR 94 Control of Emissions From Marine Compression

- Ignition Engines

- Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for thruster engines are based on 40 CFR 94 Marine Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the THC + NO X emission factor. Emission factor of PM 2.5 and PM 10 are calculated based on ratio of PM/PM 2.5 and PM/PM 10 which are obtained from AP

- 42 Chapter 3, Table 3.4

- 2.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 38 Trinity Consultants 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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 emissions are calculated based on a maximum sulfur content of 15 ppm in diesel fuel assuming that 98 percent of sulfur in the f uel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and redu ced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions from the supply boat main propulsion engines were calculated based on one hour, 24 hours, and 4,800 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- 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.



### 3.4.3. Electric al Generator Engines (SB

- GE

- 01 and SB

- GE

- 02)

HOS Coral supply boat consists of two 1,047 HP (781 kW) Caterpillar C32 DITA diesel

- fired electrical generator engines. Emissions are generated as a result of combust ion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for this engine are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– VOC and HAP emissions estim ates for the engines are based on AP

- 42, Section 3.4 emission factors. Non methane VOC emission factor has been taken as 91% of TOC emission factor. A calculated heat rate of 6.56 MMBtu/hr was used to convert from lb/MMBtu to lb/hr to calculate emissions

. 40 CFR 94 Control of Emissions From Marine Compression

- Ignition Engines

- Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for electric generator engines are based on 40 CFR 94 Marine Tier 2 exhaust emission standards. NO X emis sion factors are assumed to be equal to the THC + NO X emission factor. Emission factor of PM 2.5 and PM 10 are calculated based on ratio of PM/PM 2.5 and PM/PM 10 which are obtained from AP

- 42 Chapter 3, Table 3.4

- 2.

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

-Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 39 Trinity Consultants 006, May 1998, Section 5.2.2. Emission factor for distillate oil

- fired gas turbines was used as a

s urrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 perc ent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting fr om sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions from the supply boat main propulsion engines were calculated based on one hour, 24 hours, and 4,800 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- 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.



### 3.4.4. Emerg ency Electric al Generator Engine (SB

- GE

- 03)

HOS Coral supply boat consists of one 253 HP (189 kW) Caterpillar C9 DITA diesel

- fired, emergency electrical generator engine. Emissions from the emergency generator engine will be a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for the engine are summarized below.

40 CFR 94 Control Of Emi ssions From Marine Compression

- Ignition Engines

- Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the two representative Main Engines (SV

- ME

- 01 and SV

- ME

- 02) are based on 40 CFR 94 Marine Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X emission factor. PM 10 and PM 2.5 emission factors are obtained by applying the ratio of PM/PM 10 and PM/PM 2.5 from AP

- 42 Chapter 3, Table 3.4

- 1 and Table 3.4

- 2 on EPA Tier 2 PM emission factor.

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 Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 40 Trinity Consultants (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel ). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

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.

Mass Balance

– Anadarko proposed the use of ULSD fu el for all diesel combustion sources. Therefore, SO 2 emissions are calculated based on a maximum sulfur content of 15 ppm in diesel fuel and assuming that 98 percent of sulfur in the fuel will be converted to SO 2 and 2 percent of the sulfur in the fuel wi ll be converted to H 2 SO 4 based on U.S. EPA guidance document.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 2 hours, and 1 00 hours of operation respectively.

Proposed Operating Limits :

Since this emission unit will b e a part of supply boat

- 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.



### 3.4.5. ROV Electric al Generator Engine (SB

- GE

- 04)

HOS Coral supply boat includes one 475 HP (354 kW) diesel

- fired, ROV electric al generator engine. Emissions from the ROV electric generator engine will be a result of combustion of diesel fuel in the engine.

Emissions Factors

– The sources of emission factors used to estimate emissions for this engine are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– VOC and HAP emissions estimates for the ROV electric generator engine are based on AP

- 42, Section 3.3 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

40 CFR 89 Control Of Emissions From New And In

- Use Nonroad Compression

- Ignition Engines

- Particulate matter (PM , PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the electric generator engine are based on 40 CFR 89 Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X emission factor. Based on footnote b of AP

- 42 Ch apter 3, Table 3.3

- 1, all PM is assumed to be < 1 μm. Therefore, it is assumed PM 2.5 = PM 10 = PM.

EPA Guidance Documents

– Lead emission factor is obtained from EPA guidance document: Locating and Estimating Air Emissions from Sources of Lead and Lead Co mpounds, 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.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 41 Trinity Consultants EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are ob tained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- wide fuel consumption limit, no separate fuel limit is required to demonstrate compliance. Anadarko will maintain adequate records to comply with proposed d aily and annual operation limits.



### 3.4.6. Well Evaluation Third Party Engine (SB

- TP

- 01 and SB

- TP

- 02)

Two temporary third party Well Evaluation Electrical Generator Engines, Caterpillar 3406C or equivalent

- 360 HP
, could be brought on the support vessels for well evaluation activities

. These engines will be temporarily brought onboard and operated on the supply boat as required. Emissions from the electric generator engine s will be a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for this engine are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the electric generator engine s are based on AP

- 42, Section 3.3 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel) . Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 42 Trinity Consultants Mass Balance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions are calculated based on a maximum su lfur content of 15 ppm in diesel fuel assuming that 98 percent of sulfur in the fuel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 mist based on Section 4.1.1 of Draft Regulatory Impact Analysis: Control of Emissions from Nonr oad Diesel Engines, EPA420

- R

- 03

- 008, April 2003. Emissions of H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- 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.



### 3.4.7. Well Evaluation Third Party Crane Motor Engine #1 (SB

- TP

- 0 3 )

One Well Evaluation Crane motor Engine #1, John Deere PE 4045D or equivalent

- 62 HP , could be brought on the support vessels for well evaluation activities . Emissions from the crane motor engine #1 will be a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for this engine are summarized below.

AP

- 42, Sec tion 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the Crane motor engine are based on AP

- 42, Section 3.3 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr t o calculate emissions.

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 dis tillate oil

- fired gas turbines was used as a surrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

Mass Balanc e

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 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 SO 2 and 2 pe rcent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 43 Trinity Consultants The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part o f supply boat

- 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.



### 3.4.8. Well Evaluation Third Party Crane Motor Engine #2 ( SB

- TP

- 0 4 )

One Well Evaluation Crane motor Engine #2, Cummins B 5.9

- C or equivalent

- 130 HP, could be brought on the support vessels for well evaluation activities . Emissions from the crane motor engine #2 will be a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for this engine are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the crane motor engine #2 are based on AP

- 42, Section 3.3 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fu el). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 mist based on Section 4.1.1 of Draft Regulatory Impact Analysis: Control of Emissions from N onroad Diesel Engines, EPA420

- R

- 03

- 008, April 2003. Emissions of H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation, respectively.

Proposed Operating Limits :Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 44 Trinity Consultants Since this emission unit will be a part of supply boat

- 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.



### 3.4.9. Third Party Well Evaluation Engines (SB

- TP

- 05 through SB

- TP

- 09)

Five well evaluation third party engines are required for well evaluation activities

.

N ote that the third party engines shown in this application are for representation purposes only, and Anadarko may replace these engines with equivalent engines as specified in Section 3.1 with equal or lesser emissions. The specification sheets for the equivalent engines are provided in Appendix G

- 1 0

. Emissions from third party engines will be a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for each of these engines are summarized below.

AP

- 42, Section 3.3. Ga soline and Diesel Industrial Engines

– VOC and HAP emissions are based on emission factors from AP

- 42 Chapter 3.3, Table 3.3

- 2: Speciated Organic Compound Emission Factors for Uncontrolled Diesel Engines. An average BFSC of 7,000 Btu/HP

- hr was used to con vert from lb/MMBtu to lb/HP

- hr to calculate emissions. Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions are based on AP

- 42, Chapter 3, Table 3.3.1, Emission Factors for Uncontrolled Gasoline and Diesel Industrial Engines. . Based on footno te b of AP

- 42 Chapter 3, Table 3.3

- 1, all PM is assumed to be < 1 μm. Therefore, it is assumed PM 2.5 = PM 10 = PM

.
EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

EPA Guidanc e 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.

Mass Balance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions are calculated based on a maximum sulfur conte nt of 15 ppm in diesel fuel assuming that 98 percent of sulfur in the fuel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to sulfuric acid (H 2 SO 4 ) mist based on Section 4.1.1 of Draft Regulatory Impact Analysis: Control of Emissions fro m Nonroad Diesel Engines, EPA420

- R

- 03

- 008, April 2003. Emissions of Hydrogen sulfide (H 2 S), total reduced sulfur (TRS), and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation, respectively.

Proposed Operating Limits :Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 45 Trinity Consultants Since this emission unit will be a part of supply boat

- wide fuel consumption limit, no separate fuel limit is required to demonstrate com pliance. Anadarko will maintain adequate records to comply with proposed daily and annual operation limits

. 

### Anchor Handling Boat (Kirt Chouest) Combustion Sources

The Kirt Chouest is the worst case anchor handling boat which will be used as a supply boat when required to perform specific operations

. The fuel consumption and emissions from this boat will be counted against the supply boat fuel limits. The emission estimation procedures for several diesel engines on the anchor handling boat are described b elow.



### 3.4.10. Marine Propulsion Engines (AB

- ME

- 01 and AB

- ME

- 02)

The Kirt Chouest includes two 7,570 HP (5,650 kW) Caterpillar 3616 diesel

- fired marine propulsion engines. Emissions are generated as a result of combustion of diesel fuel

.

Emissions Factors

– The sources of emission factors used to estimate emissions for these engines are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC, and HAP emissions estimates for the engine s are based on AP

- 42, Section 3.4 emission factors. Non methane VOC emission factor has been taken as 91% of TOC emission factor. Total particulate emissions have been taken as the sum of filterable and condensable particulate emiss ions. 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 has been 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.

Mass Balance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions have been 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 SO 2 and 2 percent of sulfur in the fu el is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation respectively

. Proposed Operating Limits :Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 46 Trinity Consultants Since this emission unit will be a part of supply boat

- 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.



### 3.4.11. Thruster Engines (AB

- TE

- 01 through AB

- TE

- 03)

The Kirt Chouest includes three 1,674 HP (1,249 kW) Caterpillar 3512B

- HD diesel

- fired thruster engines. Emissions are generated as a result of combustion of diesel

.

Emissions Factor s

– The sources of emission factors used to estimate emissions for these engines are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC, and HAP emissions estimates for the engine s are based on AP

- 42, Section 3.4 emission factors. Non methane VOC emission factor has been taken as 91% of TOC emission factor. Total particulate emissions have been taken as the sum of filterable and condensable particu late emissions. 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 has been 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.

Mass Balance

– Anadarko is prop osing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions have been 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur cont ent in the fuel are negligible.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission F actors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- wide fuel consumption limit, no separate fuel limit is required to demonstrate compliance. Anadarko will maintain adequate records to comply with proposed da ily and annual operation limits.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 47 Trinity Consultants 

### 3.4.12. Service Generator Engines (AB

- GE

- 01 through AB

- GE

- 05)

The Kirt Chouest includes of three 716 HP (534 kW) Caterpillar 3412C diesel

- fired service generator engines and two 1,300 HP (968 kW) Caterpillar 3508B crane dedicated diesel

- fired service generator engines. Emissions are generated as a result of combustion of diesel fuel.

Emi ssions Factors

– The sources of emission factors used to estimate emissions for these engines are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC, and HAP emissions estimates for the generator engine s are based on AP

- 42, Section 3.4 emission factors. Non methane VOC emission factor has been taken as 91% of TOC emission factor. Total particulate emissions have been taken as the sum of filte rable and condensable particulate emissions. 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 has been 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.

M ass Balance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions have been 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compou nds resulting from sulfur content in the fuel are negligible.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 4,800 hours of operation respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- wide fuel consumption limit, no separate fuel li mit is required to demonstrate compliance. Anadarko will maintain adequate records to comply with proposed daily and annual operation limits.



### 3.4.13. Emergency Generator Engine (AB

- GE

- 06)

The Kirt Chouest includes one 307 HP (229 kW) Caterpillar 3406C diesel

- fire d, emergency generator engine. The emergency generator engine will be operated during emergencies, and periodically operated for maintenance checks. Emissions from the emergency generator engine will be a result of combustion of diesel fuel

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 48 Trinity Consultants Emissions Factors

– The sources of emission factors used to estimate emissions for this engine are summarized below.

AP

- 42, Section 3.3

. Gasoline and Diesel Industrial Engines

– Particulate (PM, PM10, PM2.5), VOC, CO, NO X , and HAP emissions estimates for the emergency generator engine are based on AP

- 42, Section 3.3 emission factors. Based on AP

- 42 guidance, all of the particulate matter is assumed to be less than 1 μm. All of the TOC is assumed to be VOC. TOC emission factor has been calculated as the sum of exhaust and crankcase emission factors.

EPA Guidance Documents

– Lead emission factor has been obtained from EPA guidance document: Locating and Estimating Air Emissions from Sources of Lead and Lead Compounds , E PA 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.

Mass Balance

– Anadarko is proposing the use of ULSD fuel for all di esel combustion sources. Therefore, SO 2 emissions have been 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 mis t 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). E mission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

The maximum hourly, daily, and annual emissions were calculated based on one hour, one hour, and 100 hours of operation respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- 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.



### 3.4.14. Winch Hydraulic Engines (AB

- GE

- 07 and AB

- GE

- 08)

The Kirt Chouest includes two 1,300 HP (969 kW) Caterpillar C32 diesel

- fired hydraulic engines. Emissions are generated as a result of combustion of diesel

.

Emissions Factors

– The sources of emission factors u sed to estimate emissions for these engines are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC, and HAP emissions estimates for the engine s are based on AP

- 42, Section 3.4 emission factors. Non methane VOC emission factor has been taken as 91% of TOC emission factor. Total particulate emissions have been taken as the sum of filterable and condensable particulate emissions. An average BSFC of 7,000 Btu/HP

- hrAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 49 Trinity Consultants has been used to convert emission factors from lb/MMBtu to lb/HP

- hr.

EPA Guidance Documents

– Lead emission factor has been 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.

Mass Balance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions have been 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel) . Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

The maximum hourly, daily, and annual emissions from the anchor handling boat winch hydraulic engines were calculated based on one hour, 24 hours, and 4,800 hours of operation respectively.

Proposed Operating Limits :

Since this emission unit will be a part of supply boat

- wide fuel consumption limit, no separate fuel limit is required to demonstrate compliance. Anadarko will maintain adequate records to comp ly with proposed daily and annual operation limits.



### 3.4.15. Supply Boat Storage Tanks

The supply boat (HOS Coral ) includes 15 diesel fuel storage vessels and t he anchor handling boat ( Kirt Chouest ) includes 19 diesel fuel storage vessels. Emissions from all stora ge vessels on the support vessels have been estimated using EPA’s TANKS 4.0.9d program. Default TANKS properties for distillate fuel oil No. 2 were used to model the contents of the diesel tanks. The tank emissions calculations (including the EPA TANKS 4 .09d runs) are included in Appendix G

- 7 of this application.



### Tug Boat Combustion Sources

3.4.16. Tug Boat Main Engines (TB

- ME

- 01 to TB

- ME

- 03) and Generator Engines (TB

GE

- 01 to TB

- GE

- 02)
The Tug Boat includes Main Engines (TB

- ME

- 01 through TB

- ME

- 03) and Generator Engines (TB

- GE

- 01 and TB

- GE

- 02) or equivalent engines for this operation. The Main E ngines and Generator Engines as presented in this application have 2,200 HP (1,641 KW) rating and 174 HP (130 KW) rating
, respectively. Emissions are generated as a resu lt of combustion of diesel fuel.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 50 Trinity Consultants Emissions Factors

– The sources of emission factors used to estimate emissions Main Engines (TB

- ME

01 through TB

- ME

- 03) and Generators (TB

- GE

- 01 and TB

- GE

- 02) are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC and HAPs estimates for the representative Generators (TB

- GE

- 01 and TB

- GE

02) are based on AP

- 42, Section 3.3 emission factors. Based on AP

- 42 guidance, all of the particulate
mat ter is assumed to be less than 1 μm. All of the TOC is assumed to be VOC. TOC emission factor has been calculated as the sum of exhaust and crankcase emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to ca lculate emissions.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), CO, VOC and HAPs emissions estimates for the representative Main Engines (TB

- ME

- 01 through TB

- ME

- 03) are base d on AP

- 42, Section 3.4 emission factors (Table 3.4

- 1, Table 3.4

- 2 and table 3.4

- 3). Non methane VOC emission factor has been taken as 91% of the total organic compounds (TOC) emission factor. Emission factor of PM 2.5 and PM 10 are calculated based on rat io of PM/PM 2.5 and PM/PM 10 which are obtained from AP

- 42 Chapter 3, Table 3.4

- 2. Total particulate emission factor used in the ratio has been taken as the sum of filterable and condensable particulate emissions. PM < 3um are taken as PM 2.5 . An average brak e
- specific fuel consumption (BSFC) of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr.

IMO Tier 2

– NO X emissions estimates for the representative Main Engines (TB

- ME

- 01 through TB

ME

- 03) are based on IMO Tier 2 emission factors for an eng ine speed of 1,800 rpm.

EPA Guidance Documents

– Lead emission factor for Main Engines (TB

- ME

- 01 through TB

- ME

- 03) and Generators (TB

- GE

- 01 and TB

- GE

- 02) 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, S ection 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

– CO 2 , CH 4 and N 2 O emission factors for Main Engines (TB

- ME

- 01 through TB

- ME

03) and Generators (TB

- GE

- 01 and TB

- GE

- 02) are obtained from 40 CFR 98 Subpart C, Table C

1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emiss ion factor for CO 2 e 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, SO 2 emissions are calculated based on a maximum sulfur co ntent of 15 ppm in diesel fuel assuming that 98 percent of sulfur in the fuel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to sulfuric acid (H 2 SO 4 ) 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 (H 2 S), total reduced sulfur (TRS), and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

Fuel Based Emission Factor Derivation :

Base d on the specifications sheets for each engine
, the BSFC was used to convert the above mentioned emission factors to lbs of pollutant/bbl of fuel consumed as shown in the Appendix B. Hence, AnadarkoAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 51 Trinity Consultants is proposing tug boat

- wide fuel limit
, based on the fuel based emission f actor s, to establish operating limits and PTE calculations for tug boats

. Proposed Operating Limits :
Anadarko proposes a tug boat

- wide fuel cap of 125 bbl/day and 25,000 bbl/year based on the historical fuel consumption records for comparable tug boats

. 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 calculated based on the fuel based emission factor and maximum fuel requirement of 5.1 bbl of fuel.

Maximum Daily Emissions

– The maximum daily emissions for the main engines are based on the fuel b ased emission factor and maximum fuel requirement of 125 bbl/day of fuel.

Annual Emissions

– The annual emissions for the main engines are based on the fuel based emission factor and maximum fuel requirement of 25,000 bbl/year of fuel.



### Barge Combustion S ources

3.4.17. Barge Electrical Generators (BG

- LP

- 01thru BG

- LP

- 03)
The Barge electrical generator engines represented in this application include three 456 HP electrical generator engines. Emissions are generated as a result of combustion of diesel fuel in the en gines.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative engines are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the elect rical generator engines are based on AP

- 42, Section 3.3 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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

s urrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

Mass Balanc e

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 emissions are calculated based on a maximum sulfur content of 15 ppm in diesel fuelAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 52 Trinity Consultants assuming that 98 percent of sulfur in the fuel is oxidized to SO 2 and 2 pe rcent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

Proposed Operating Limits :
The maximum hourly, daily, and annual emissions from the barge electrical generator engines are calculated based on the hours of operation as described below:

Maximum Hourly Emi ssions

– The maximum hourly emissions for the barge electrical generator engines operations are calculated based on one hour operation per engine.

Maximum Daily Emissions

– The maximum daily emissions for the barge electrical generator engines operations are calculated based on 24 hours operation per engine.

Annual Emissions

– The maximum annual emissions for the barge electrical generator engines operations are calculated based on 4800 hours of operation per engine.



### Stimulation Vessel Combustion Sources

The representative Stimulation Vessel Engines includes Main Propulsion Engines (SV

- ME

- 01 and SV

- ME

02), representative Thrusters (SV

- BT

- 01 through SV

- ST

- 01), representative Drop

- down Engines (SV

DD

- 01) representative Pump Engines (SV

- PE

- 01 through SV

- PE

- 0 8 ), and representative Generator Engines (SV

- GE

- 01 through SV

- GE

- 04) as presented in this application. Emissions are generated as a result of combusti on of diesel fuel

.



### 3.4.18. Stimulation Vessel Main Engines (SV

- ME

- 01 and SV

- ME

- 02)

The Stimulation Vessel includ es two 3,634 HP (2,710 kW) Caterpillar C280

- 8 main engines. Emissions are generated as a result of combustion of diesel fuel in the engines.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative stimulation ves sel main engines are summarized below.

40 CFR 94 Control Of Emissions From Marine Compression

- Ignition Engines

- Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the two representative Main Engines (SV

- ME

- 01 and SV

- ME

- 02) are based on 40 CFR 94 Marine Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X emission factor. PM 10 and PM 2.5 emission factors are obtained by applying the ratio of PM/PM 10 and PM/PM 2.5 from AP

- 42 Chapter 3, Table 3.4

- 1 and Table 3.4

- 2 on EPA Tier 2 PM emission factor.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– VOC and HAP emissions estimates for the two main engines are based on AP

- 42, Section 3.4 Table 3.4

- 1 and Table 3.4

- 3. All of the TOC is assumed to be VOC. TOC emission factor has been calculated as the sum of exhaust and crankcase emission factors. Pe r footnote f of AP

- 42 Chapter 3, Table 3.4

- 1, non

-Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 53 Trinity Consultants methane VOC emission factor has been taken as 91% of TOC emission factor. An average BSFC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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

surr ogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and T able C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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 combustio n sources. Therefore, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

Fuel Based Emission Factor Derivation :

Based on the specifications sheets for each engine
, the BSFC was used to convert the above mentioned emission factors to lbs of pollutant/bbl of fuel consumed as shown in the Appendix B. Hence, Anadarko is proposing stimulation vessel

- wide fuel limit
, based on the fuel based emission f actor s, to establish operating limits and PTE calculations for stimulation vessel

. Proposed Operating Limits :
Anadarko proposes a stimulation vessel

- wide fuel cap of 225 bbl/day and 4725 bbl/year based on the historical fuel consumption records for comparable vessel and expected operating time for this vessel

. The maximum hourly, daily, and annual emissions from the stimulation vessel are calculated based on the derived fuel based emission factor as de scribed below:

Maximum Hourly Emissions

– The maximum hourly emissions for the main engines are calculated based on the fuel based emission factor and maximum fuel requirement of 9.37 bbl of fuel.

Maximum Daily Emissions

– The maximum daily emissions fo r the main engines are based on the fuel based emission factor and maximum fuel requirement of 225 bbl/day of fuel.

Annual Emissions

– The annual emissions for the main engines are based on the fuel based emission factor and maximum fuel requirement of 4, 725 bbl/year of fuel.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 54 Trinity Consultants 

### 3.4.19. Bow Thruster Engine (SV

- BT

- 01)

The Stimulation Vessel includes one 1,675 HP (1,249 kW) bow thruster engine. Emissions are generated as a result of combustion of diesel fuel in the engines.

Emissions Factors

– The sources of emissio n factors used to estimate emissions for representative Stimulation Vessel Bow Thruster Engine are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC and HAP emissions estimates for thruster engine are based on AP

- 42, Section 3.4 Table 3.4

- 1 through Table 3.4

- 4. PM < 3um is taken as PM 2.5 . Total particulate emission is the sum of filterable and condensable particulate emissions. Per footnote f of AP

- 4 2 Chapter 3, Table 3.4

- 1, non

- methane VOC emission factor has been taken as 91% of TOC emission factor. An average BSFC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

hr to calculate emissions.

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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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. Therefor e, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 mist based on Section 4.1.1 of Draft Regul atory Impact Analysis: Control of Emissions from Nonroad Diesel Engines, EPA420

- R

- 03

- 008, April 2003. Emissions of H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emis sions were calculated based on one hour, 24 hours, and 504 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of stimulation vessel

- 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.



### 3.4.20. Bow Drop

- Down Engine (SV

- DD

- 01)

The Stimulation Vessel has one 1,200 HP (895 kW) bow drop down engine. Emissions are generated as

a result of combustion of diesel fuel in the engines.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 55 Trinity Consultants Emissions Factors

– The sources of emission factors used to estimate emissions for representative Stimulation Vessel Bow Drop

- Down Engine are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC and HAP emissions estimates for the bow drop

- down engine are based on AP

- 42, Section 3.4 Table 3.4

- 1 through Table 3.4

- 4. PM < 3um is taken as PM 2.5
. Tota l particulate emission is the sum of filterable and condensable particulate emissions. Per footnote f of AP

- 42 Chapter 3, Table 3.4

- 1, non

- methane VOC emission factor has been taken as 91% of TOC emission factor. An average BSFC of 7,000 Btu/HP

- hr was use d to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Tab le C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 oxidiz ed to SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 504 hours of operation, respectively.

Proposed Operating Limits :

Since this emission uni t will be a part of stimulation vessel

- 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.



### 3.4.21. Stern Thruster Engines (SV

- ST

- 01)

The Stimulation Vessel includes one 1,675 HP (1,249 kW) Stern thruster engine. Emissions are generated as a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative Stimulation Vessel Stern Thruster Engine are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 1 0 , and PM 2.5 ), NO X , CO, VOC and HAP emissions estimates for thruster engine areAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 56 Trinity Consultants based on AP

- 42, Section 3.4 Table 3.4

- 1 through Table 3.4

- 4. PM < 3um is taken as PM 2.5 . Total particulate emission is the sum of filterable and condensable particulate emissions. Per footnote f of AP

- 42 Chapter 3, Table 3.4

- 1, non

- methane VOC emission factor has been taken as 91% of TOC emission factor. An average BSFC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

hr to calculate emissions.

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 u sed as a surrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types o f Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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 die sel combustion sources. Therefore, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 mist base d 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maxim um hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 504 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of stimulation vessel

- wide fuel consumption limit, no separat e fuel limit is required to demonstrate compliance. Anadarko will maintain adequate records to comply with proposed daily and annual operation limits.



### 3.4.22. Representative Pump Engines (SV

- PE

- 01 through SV

- PE

- 08)

The Stimulation Vessel includes eight 2,250 HP ( 1,678 kW) pump engines . Emissions are generated as a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for these pumps are summarized below.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , CO, VOC and HAP emissions estimates for the pump engines are based on AP

- 42, Section 3.4 Table 3.4

- 1 through Table 3.4

- 4. PM < 3um is taken as PM 2.5 . Total particulate e mission is the sum of filterable and condensable particulate emissions. Per footnote f of AP

- 42 Chapter 3, Table 3.4

- 1, non

- methane VOC emission factor has been taken as 91% of TOC emission factor. An average BSFC of 7,000 Btu/HP

- hr was used to convert fr om lb/MMBtu to lb/HP

hr to calculate emissions.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 57 Trinity Consultants 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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

Mass Bal ance

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulti ng from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 10 hours, and 210 hours of operation, respectively. Anadarko proposes to maintain flexibility of operating fewer pumps for longer duration than specified above as long as total daily and annual operations are within the proposed daily and annual operating limits, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of stimulation vessel

- wide f uel 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.



### 3.4.23. Stimulation Vessel Generators (SV

- GE

- 01 and SV

- GE

- 02)

The Stimulation Vessel includes two 1,220 HP (910 kW) generator engines. Emissions are generated as a result of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for th e generator engine s

are summ arized below.

40 CFR 89 Control Of Emissions From New And In

- Use Nonroad Compression

- Ignition Engines

- Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the Generators are based on 40 CFR 89 Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X emission factor. PM 10 and PM 2.5 emission factors are obtained by applying the ratio of PM/PM 10 and PM/PM 2.5 from AP

- 42 Chapter 3, Table 3.4

- 1 and Table 3.4

- 2 on EPA Tier 2 PM emission factor.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– VOC and HAP emissions estimates for the g enerator engines are based on AP

- 42, Section 3.4 Table 3.4

- 1 and Table 3.4

- 3. All of the TOC is assumed to be VOC. TOC emission factor has been calculated as theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 58 Trinity Consultants sum of exhaust and crankcase emission factors. Per footnote f of AP

- 42 Chapter 3, Table 3.4

- 1, non

methane VOC emission factor has been taken as 91% of TOC emission factor. An average BSFC of 7,000 Btu/HP

- hr was used to c onvert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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, Secti on 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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1 (Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compound s resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 504 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of stimulation vessel

- 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.



### 3.4.24. Stimulation Vessel Generators (SV

- GE

- 03 and SV

- GE

- 04)

The Stimulation Vessel includes two 805 HP (600 kW) Caterpillar C18 ATAAC engines. Emissions are generated as a resu lt of combustion of diesel fuel.

Emissions Factors

– The sources of emission factors used to estimate emissions for t he g enerator engines are summarized below.

40 CFR 89 Control Of Emissions From New And In

- Use Nonroad Compression

- Ignition Engines

- Particulate matter (PM, PM 10 , and PM 2.5 ), NO X , and CO emissions estimates for the g enerator engines are based on 40 CFR 89 Tier 2 exhaust emission standards. NO X emission factors are assumed to be equal to the NMHC + NO X emission factor. PM 10 and PM 2.5 emission factors are obtained by applying the ratio of PM/PM 10 and PM/PM 2.5 from AP

- 42 Chapter 3, Table 3.4

- 1 and Table 3.4

- 2 on EPA Tier 2 PM emission factor.

AP

- 42, Section 3.4. Large Stationary Diesel and All Stationary Dual

- fuel Engines

– VOC and HAP emissions estimates for the Generators Baker Hughes engines are based on AP

- 42, SectionAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 59 Trinity Consultants 3.4 Table 3.4

- 1 and Table 3.4

- 3 . All of the TOC is assumed to be VOC. TOC emission factor has been calculated as the sum of exhaust and crankcase emission factors. Per footnote f of AP

- 42 Chapter 3, Table 3.4

- 1, non

- methane VOC emission factor has been taken as 91% of TOC emission fac tor. An average BSFC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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

– CO 2 , CH 4 and N 2 O emission fa ctors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculate d 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 mist based on Section 4.1.1 of Draft Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines, EPA420

- R

- 03

- 008, April 200 3. Emissions of H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 504 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of stimulation vessel

- 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.



### Well Evaluation Vessel Combustion Sources

The Well Evaluation Vessel will consist of Main Engines (WE

- ME

- 01 and WE

- ME

- 02), Auxiliary Engines ( WE

- AE

- 01 and WE

- AE

- 02), and Emergency Generators (WE

- GE

- 01, WE

- GE

- 02, and WE

- GE

- 03). Emissions from each air pollution source are estimated using the methodology as shown below.



### 3.4.25. Well Evaluation Vessel Main Engines (WE

- ME

- 01and WE

- ME

- 02)

The Well Evaluation Vessel Main Engine s represented in this application consist of two 2,250 HP engi nes . Emissions are generated as a result of combustion of diesel fuel in the engines.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative well evaluation vessel main engines are summarized below.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 60 Trinity Consultants AP

- 42, Sect ion 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the well evaluation main engine s are based on AP

- 42, Section 3.3 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to l b/HP

- hr to calculate emissions.

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

s urrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e has been calculated using the GWPs obtained from 40 CFR 98 Subpart A.

Mass Balanc e

– Anadarko is proposing the use of ULSD fuel for all diesel combustion sources. Therefore, SO 2 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 SO 2 and 2 pe rcent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

Fuel Based Emission Factor Derivation :
Based on the specifications sheets for each engine, the BSFC was used to convert the above mentioned emission factors to lbs of pollutant/bbl of fuel consumed as show n in Appendix B. The fuel consumption resulting in highest emissions for the presented well evaluation vessel engines is 194 g/kW

- hr as shown in Appendix B. Based on a conservative estimate, Anadarko proposes well evaluation vessel

- wide fuel limit of 144 bbls/day.

Proposed Operating Limits :
Anadarko proposes a well evaluation vessel

- wide fuel cap of 144 bbl/day and 28,000 bbl/year based on the engineering estimates and expected operating time for this vessel

. The maximum hourly, daily, and annual emissions from the stimulation vessel 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 calculated based on the fuel based emission factor an d maximum fuel requirement of 6 bbl 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 144 bbl/day of fuel.

Annual Emissions

– The annual emissi ons for the main engines are based on the fuel based emission factor and maximum fuel requirement of 750 bbl/year of fuel.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 61 Trinity Consultants 

### 3.4.26. Well Evaluation Vessel Auxiliary Engines (WE

- AE

- 01 and WE

- AE

- 02)

The Well Evaluation Vessel Auxiliary Engine s represented in this application consist of two 1,468 HP engines . Emissions are generated as a result of combustion of diesel fuel in the engines.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative well eval u ation vessel auxiliary engines are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the well evaluation auxiliary engine s are based on AP

- 42, Section 3.3 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel) . Emission factor for CO 2 e 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, SO 2 emissions are calculated based on a maximum su lfur content of 15 ppm in diesel fuel assuming that 98 percent of sulfur in the fuel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 mist based on Section 4.1.1 of Draft Regulatory Impact Analysis: Control of Emissions from Nonr oad Diesel Engines, EPA420

- R

- 03

- 008, April 2003. Emissions of H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, a nd 125 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of the well evaluation vessel

- 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.



### 3.4.27. Well Evaluation Vessel Emergency Generator #1 (WE

- GE

- 01)

The Well Evaluation Vessel Emergency Generator represented in this application consist of one 272 HP engine . Emissions are generated as a result of combusti on of diesel fuel in the engine

.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative well

eva l u ation emergency generator are summarized below.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 62 Trinity Consultants AP

- 42, Section 3.3. Gasoline a nd Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the well evaluation emergency generator #1 are based on AP

- 42, Section 3.4 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

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 dist illate oil

- fired gas turbines was used as a surrogate for distillate oil

- fired engines due to lack of emission factors.

EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 an d 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resu lting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 125 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a p art of the well evaluation vessel

- 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.



### 3.4.28. Well Evaluation Vessel Emergenc y Generator #2 (WE

- GE

- 02)

The Well Evaluation Vessel Emergency Generator #2 represented in this application consist of one 212 HP engine . Emissions are generated as a result of combusti on of diesel fuel in the engine

.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative well

eva l u ation emergency generator #2 are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the well evaluation emergency generator #2 are based on AP

- 42, Section 3.4 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

EPA Guidance Documents

– Lead emission factor is obtained f rom 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 eng ines due to lack of emission factors.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 63 Trinity Consultants EPA Regulations

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 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 SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 125 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of the well evaluation vessel

- wide fuel consumption limit, no separate fuel limit is required to de monstrate compliance. Anadarko will maintain adequate records to comply with proposed daily and annual operation limits.



### 3.4.29. Well Evaluation Vessel Emergency Generator #3 (WE

- GE

- 03)

The Well Evaluation Vessel Emergency Generator #3 represented in this applica tion consist of one 200 HP engine . Emissions are generated as a result of combusti on of diesel fuel

.

Emissions Factors

– The sources of emission factors used to estimate emissions for representative well

eva l u ation emergency generator #3 are summarized below.

AP

- 42, Section 3.3. Gasoline and Diesel Industrial Engines

– PM, NO X , CO, VOC and HAP emissions estimates for the well evaluation emergency generator #3 are based on AP

- 42, Section 3.4 emission factors. An average BFSC of 7,000 Btu/HP

- hr was used to convert from lb/MMBtu to lb/HP

- hr to calculate emissions.

EPA Guidance Documents

– Lead emission factor is obtained from EPA guidance document: Locating and Estimating Air Emissions from S ources 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

– CO 2 , CH 4 and N 2 O emission factors are obtained from 40 CFR 98 Subpart C, Table C

- 1(Default CO 2 Emission Factors and High Heat Values for Various Types of Fuel) and Table C

- 2 (Default CH 4 and N 2 O Emission Factors for Various Types of Fuel). Emission factor for CO 2 e 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, SO 2 emissions are calculated based on a maximum sulfur content of 15 ppm in diesel fuelAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 64 Trinity Consultants assuming that 98 percent of sulfur in the fuel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 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 H 2 S, TRS, and reduced sulfur compounds resulting from sulfur content in the fuel are negligible.

The maximum hourly, daily, and annual emissions were calculated based on one hour, 24 hours, and 125 hours of operation, respectively.

Proposed Operating Limits :

Since this emission unit will be a part of the well evaluation vessel

- wide fuel consumption limit, no separate fuel limit is required to de monstrate compliance. Anadarko will maintain adequate records to comply with proposed daily and annual operation limits.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 65 Trinity Consultants 

## 4. REGULATORY APPLICABI LITY ANALYSIS

To assist U.S. EPA Region 4 in drafting the pre

- construction permit for the proposed project, this section of the application provides a review of pertinent federal air quality regulations that potentially apply to the emission sources associated with the proposed project. As the proposed project will be carried out beyond 25 miles of the nearest States’ seaward boundary, it will be outside of the corresponding state and local regulatory jurisdictions and will not be subject to any state or local regulatio ns.



### 4.1. OUTER C ONTINENTAL S HELF AIR R EGULATIONS (40 CFR 55)

The BlackHornet drillship used for the proposed exploratory drilling operations will qualify as an OCS source, as defined in 40 CFR Part 55.2. An OCS source is defined in 40 CFR 55.2 as follows:

“ OCS source means any equipment, activity, or facility which: (1) Emits or has the potential to emit any air pollutant; (2) Is regulated or authorized under Outer Continental Shelf Lands Act (“OCSLA”) (43 U.S.C. §1331 et seq.); and (3) Is located on the OC

S or in or on waters above the OCS.

This definition shall include vessels only when they are: (1) Permanently or temporarily attached to the seabed and erected thereon and used for the purpose of exploring, developing or producing resources therefrom, wit hin the meaning of section 4(a)(1) of OCSLA (43 U.S.C. §1331 et seq . ); or (2) Physically attached to an OCS facility, in which case only the stationary sources aspects of the vessels will be regulated.”

Therefore, when the BlackHornet drillship is conduc ting the proposed project, it will be considered an OCS source and shall be subject to the requirements of 40 CFR 55. In addition, when an associated vessel is physically attached to an OCS source, the stationary source aspects of the vessel will also be regulated as an OCS source.

The main engines on the support vessels are solely used for propulsion purposes and/ or for maintaining the position of the respective vessel. The generators on the support vessels and the barge are not used for OCS activity; rather, they are used only for non
- process ancillary activities such as operating HVAC System, maintaining the GPS position and other such similar functions. The ROV electric generator diesel engine on the Supply Boat is not operated while physically conn ected to the drillship. Therefore, these engines do not meet the definition of stat ionary aspects of these vessels.

As specified in Section 1 of this application, per 40 CFR 55.3(a), all OCS sources located in the EGOM are regulated by the OCS Air Regul ations codified under 40 CFR 55. As the regulatory authority over the EGOM has not been delegated through the requirements of 40 CFR 55.11(j), the proposed OCS source falls under the regulatory jurisdiction of the U.S. EPA and U.S. EPA Region 4 will issue the applicable permits and implement and enforce the requirements of 40 CFR 55

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 66 Trinity Consultants As specified at 40 CFR 55.13, OCS sources subject to the requirements of 40 CFR 55 must comply with the following federal requirements, as applicable:

40 CFR 52.21

- Prevention of Significant Deterioration (PSD); 40 CFR Part 60

- New Source Performance Standards (NSPS); 40 CFR Part 61

- National Emission Standards for Hazardous Air Pollutants (NESHAP), which represent pollutant

- specific standards established pursuant t o Section 112 of the Clean Air Act (CAA) for those pollutants for which a standard is prescribed under 40 CFR 61; 40 CFR Part 63

- Maximum Achievable Control Technology (MACT), which represent standards established pursuant to Section 112 of the CAA to regulate specific categories of stationary sources that emit (or have the potential to emit) one or more HAPs; and 40 CFR Part 71

- Federal Operating Permits Program.

Based on the definition of the OCS source, support vessels are subject to applicable reg ulatory requirements when they are physically attached to the OCS source, in which case only the stationary source aspects of the vessels will be regulated.

Therefore, detailed regulatory applicability determinations in this section are only needed for the following emission units on the BlackHornet d rillship:

Eight Main Engines (DR

- ME

- 01 to DR

- ME

- 08 ) One E mergency G enerator (DR

- GE

- 01) One Emergency Air C ompressor (DR

- AC

- 01) Three Well Completion Condensate Tanks (DR

- TP

- 24 to DR

- TP

- 26) Five Third Party Well Evaluation Engines (DR

- TP

- 12 to DR

- TP

- 16) One Flowback Boiler (DR

- TP

- 22) One Boom Flare (DR

- TP

- 23 ) Fuel Storage tanks (several EPNs) Painting (DR

- PO

- 01) Welding (DR

- WO

- 01)

Under certain operati ng scenario s , the following sources of air pollution will constitute stationary source aspects of the vessels when the support vessels are physically attached to the OCS source :
Fuel Storage Tanks on the supply boats and the anchor handling boat (several EPNs) Eight pumps on the stimulation vessel (SV

- PE

- 01 through SV

- PE

- 08)

The L ife B oats (DR

- LB

- 01 and DR

- LB

- 06) and the Fast R escue Craft (DR

- FR

- 01) are included in the PTE calculations and air dispersion modeling as specified in 40 CFR part 55 and these sources are subject to operating limits, monitoring, r ecordkeeping and reporting requirements to ensure they will not exceed the potential emissions assumed in the application and impact review. Per 40 CFR 55.2 , the support

v essels operating within 25 miles of the OCS source are not subject to BACT requirem ents unless they are attached to the OCS . If attached
, o nly the stationary source aspects of the vessel are regulated. These units do not have any stationary source aspects with respect to air pollutant emissions, as they are used for man overboard and emergency escape scenarios only. Hence, these units are not subject to NSPS and MACT regulations.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 67 Trinity Consultants Additionally, details (e.g., model year, exact power rating etc.) of the Temporary Third Party Emission Sources (DR

- TP

- 01 through DR

- TP

- 11 and DR

- TP

- 17 through DR

- TP

- 21) were not available at the time of this application since these engines are brought onboard as required. Therefore, regulatory determinations for these engines will be made before selecting the engines. A detailed overview of the applica bility of each federal air quality regulation is provided in the following sections.



### 4.2. PREVENTION OF SIGNIF ICANT DETERIORATION (PSD) R E GULATIONS

As an OCS source subject to the requirements of 40 CFR 55, the proposed p roject will need to comply with 40 CFR 55.13(d) which specifies that the PSD program (codified under 40 CFR 52.21), applies to OCS sources located beyond 25 miles of State’s seaward boundaries. The requirements of the PSD program apply to the construction of any new major stationary source or any project at an existing major stationary source in an area designated as attainment or unclassifiable under Sections 107(d)(1)(A)(ii) or (iii) of the CAA. The pollutants regulated by the PSD program include all criteria pollutants and several non

- crite ria pollutants such as total reduced sulfur compounds, sulfuric acid mist, and fluorides (not including hydrogen fluoride).

An OCS source is considered a PSD major source if the potential emission of any PSD

- regulated pollutant exceeds the major source threshold of 250 tons per year (tpy). For a PSD regulated pollutant emitted from a new PSD major source whose source

- wide pote ntial emissions exceed the respective Significant Emission Rates (SERs) defined in 40 CFR 52.21(b)(23)(i) , PSD review is required.

On May 13, 2010, the U.S. EPA issued the final “Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule” specifying that as of January 2, 2011, all new industrial sources that are major sources for any new source review (NSR) regulated pollutants other than GHGs, and will emit or have the potential to emit 75,000 tons per year or more of total GHGs, on a CO 2 e basis will need to determine the Best Available Control Technology for their GHG emissions. 3

To determine the applicability of PSD permitting requirements and the pollutants to which these requirements would apply
, the emissions estimates from t he proposed EGOM Exploratory Project were compared to the respective PSD major source threshold and SER. As required by 40 CFR 55.13, the

source
- wide potential emissions were calculated by including the emissions from sources associated with the proposed exploratory drilling operations along with the associated support vessels while at the source, and while enroute to or from the source when within 25 miles of the source. Table 1

- 2 lists the

source
- wide potential emission rates of each regulated air pollu tant for the EGOM Exploratory Prospect against the respective PSD SER.

As shown in Table 1

- 2, the proposed OCS source qualifies as a major source under the PSD program because potential annual emissions of NO X and CO are each greater than the 250 tpy major source threshold. Additionally, PSD review is required for PM, PM 10 , PM 2.5 , NO X , GHGs, and VOCs since emissions of these pollutants exceed their respective PSD SERs.

40 CFR 52.21(k) requires that Anadarko d emonstrate that for all regulated air pollutants that would be emitted at or in excess of the SER would not cause or contribute to a violation of any NAAQS or cause or contribute to a violation of any applicable PSD increments. Therefore, for pollutants s ubject to PSD

3 CO 2 equivalent encompasses a list of six g reenhouse g ases, including carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 68 Trinity Consultants review, the following requirements of the PSD regulations applicable to the EGOM Exploratory Project are addressed in this application:

A determination of BACT for each applicable emission unit as detailed in Section 5 of this report. Air d ispersion modeling analysis as detailed in Appendix D of this report

The air dispersion modeling analysis is performed for Class I and Class II areas to address following requirements in this regulation :
An analysis of the source’s impact on total air qu ality to ensure compliance with the NAAQS and the applicable maximum allowable increase over the baseline concentration in any area, per 40 CFR 52.21(k); Ambient air quality analysis per 40 CFR 52.21(m); and An analysis of source related growth impacts as well as an analysis of the impairment to soils, vegetation, and visibility per 40 CFR 52.21(o)

.



### 4.3. NEW SOURCE P ERFORMANCE S TANDARDS (NSPS)

NSPS require new, modified, or reconstructed sources in applicable source categories to control emissions to the level achievable by the best demonstrated technology as specified in the applicable provisions. A regulatory applicability determination and a summary of potentially applicable NSPS subparts for the equipment associated with the proposed EGOM Exploratory Projec t operations are provided in the following subsections.



### 4.3.1. 40 CFR Subpart A

– General Provisions

All affected sources subject to an NSPS are also subject to the general provisions of NSPS Subpart A unless specifically excluded by the source

- specific NSPS. NSPS Subpart A requires the following of facilities subject to a source

- specific NSPS:

Initial construction/reconstruction notification Initial startup notification Performance tests Performance test date initial notification General monitoring requiremen ts General recordkeeping requirements Semiannual monitoring system and/or excess emission reports General control device and work practice requirements

Source

- specific NSPS provisions can supersede NSPS Subpart A as noted in the relevant NSPS Subpart.



### 4.3.2. 40 CFR Subpart K

- Standards of Performance for Storage Vessels for

Petroleum Liquids
NSPS Subpart K, Standards of Performance of Storage Vessels for Petroleum Liquids for which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and P rior to May 19,Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 69 Trinity Consultants 1978, provides standards of performance for storage vessels for petroleum liquids with a storage capacity greater than or equal to 40,000 gallons but less than 65,000 gallons for which the construction or modification is commenced after Mar ch 8, 1974 and prior to May 19, 1978. Requirements of this Subpart also apply to storage vessels with a capacity greater than 65,000 gallons for which construction or modification commenced after June 11, 1973 and prior to May 19, 1978.

All storage tank s represented in this application are exempt from NSPS subpart K since all of them were constructed after 1978.



### 4.3.3. 40 CFR 60 Subpart Ka

– Standards of Performance for Storage Vessels for

Petroleum Liquids

NSPS Subpart Ka, Standards of Performance of Storage Vessels for Petroleum Liquids for which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984, provides standards of performance for storage vessels for petroleum liquids with a storage capacity greater than or equal to 40,000 gallons for which construction is commenced after May 18, 1978 and prior to July 23, 1984. 4

All storage tanks represented in this application are exempt from NSPS subpart Ka since all of them were constructed after 1984.



### 4.3.4. 40 CFR 60 Subpart Kb

- Standards of Performance for Volatile Liquid Storage Vessels

NSPS Subpart Kb, Standards of Performance of Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modificati on Commenced After July 23, 1984 , provides standards of performance for storage vessels storing petroleum liquids with a capacity of greater than or equal to 75 m 3 (19,812 gallons) for which construction, reconstruction, or modification is commenced after July 23, 1984. 5

All bulk fuel storage tanks in this project were constructed after 1984 and hence are potentially subject to NSPS Subpart Kb. However, per 40 CFR 60.110 (b) these tanks are exempt from the requirements of NSPS Subpart Kb. Table 4

- 1 lists all tanks in this project that were constructed after 1984 and includes the non

- applicability determination for each tank with NSPS Subpart Kb.

Table 4

- 1

. NSPS Subpart Kb Applicability Determination f or Fuel Storage Tanks

4 40 CFR 60.110a(a)

5 40 CFR 60.110b(a)Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 70 Trinity Consultants Tank ID Description Capacity of the Tank (m 3 ) NSPS Subpart Kb

Non

- applicability Determination
DR

- FT

- 01 No. 1 Fuel Oil Storage Tank (Port) 657

Per 40 CFR 60.110b(b), NSPS Subpart Kb does not apply to storage tanks with a capacity greater than or equal to 151 m3 storing a liquid with a maximum true vapor pressure less than 3.5 kPa (0.5 psia). These tanks store diesel fuel which has a vapor pressure lesser than or equal to 0.012 psi at 78  ̊F based on Tank 4.0.9d program. DR

- FT

- 02 N o. 1 Fuel Oil Storage Tank (Starboard) 657
DR

- FT

- 03 No. 2 Fuel Oil Storage Tank (Port) 1485
DR

- FT

- 04 No. 2 Fuel Oil Storage Tank (Starboard) 1485
DR

- FT

- 05 No. 3 Fuel Oil Storage Tank (Port) 1439 DR

- FT

- 06 No. 3 Fuel Oil Storage Tank (Starboard) 1439
SB

- DT

- 05 Vessel's Diesel Fuel Storage Tank #3 Port 161
SB

- DT

- 06 Vessel's Diesel Fuel Storage Tank #3 Starboard 161
SB

- DT

- 07 Vessel's Diesel Fuel Storage Tank #4 Port 160
SB

- DT

- 08 Vessel's Diesel Fuel Storage Tank #4 Starboard 160
AB

- DT

- 12 Starboard Wing Diesel Fuel Tank #2 148
AB

- DT

- 13 Port Side Double Bottom Diesel Fuel Tank #4 107
AB

- DT

- 14 Starboard Side Double Bottom Diesel Fuel Tank #5 107
AB

- DT

- 10 Port Wing Diesel Fuel Tank #2 202
AB

- DT

- 11 Starboard Side Double Bottom Diesel Fuel Tank #4 209 DR

- FT

- 09 No. 1 Fuel Oil Servicing Tank (#1 E/R) 31

Per 40 CFR 60.110b ( a), NSPS Subpart Kb does not apply to storage tanks with capacity less than 75 m3. DR

- FT

- 10 No. 2 Fuel Oil Servicing Tank (#1 E/R) 31 DR

- FT

- 11 No. 1 Fuel Oil Servicing Tank (#2 E/R) 31 DR

- FT

- 12 No. 2 Fuel Oil Servicing Tank (#2 E/R) 31 DR

- FT

- 13 No. 1 Fuel Oil Servicing Tank (#3 E/R) 35 DR

- FT

- 14 No. 2 Fuel Oil Servicing Tank (#3 E/R) 35 DR

- FT

- 15 Fuel Oil Over Tank 46 DR

- FT

- 16 Fuel Oil Leak Tank 23
DR

- FT

- 17 Helicopter Fuel Tank 1 2.9 DR

- FT

- 18 Helicopter Fuel Tank 2 2.9

Per 40 CFR 60.110b(a), NSPS Subpart Kb does not apply to storage tanks with capacity less than 75 m3. SB

- DT

- 09 Vessel's Diesel Fuel Storage Tank #5 Port 24.88
SB

- DT

- 10 Vessel's Diesel Fuel Storage Tank #5 Starboard 27.79
SB

- DT

- 11 Vessel's Diesel Fuel Storage Day Tank #1 Port 22.81
SB

- DT

- 12 Vessel's Diesel Fuel Storage Day Tank #1 Starboard 34.63
SB

- DT

- 13 Vessel's Diesel Fuel Stern Thruster Day Tank 5.66

SB

- DT

- 14 Vessel's Diesel Fuel Overflow Port Storage Tank 16.66
SB

- DT

- 15 Vessel's Diesel Fuel Overflow Standby Storage Tank 16.66
AB

- DT

- 01 Port Side Double Bottom Diesel Fuel Tank #1 48.63
AB

- DT

- 02 Starboard Side Double Bottom Diesel Fuel Tank #1 48.66
AB

- DT

- 03 Center Double Bottom Diesel Fuel Tank #1 59.45
AB

- DT

- 06 Port Wing Diesel Fuel Tank #1 61.78
AB

- DT

- 07 Starboard Wing Diesel Fuel Tank #1 61.78
AB

- DT

- 15 Port Service Diesel Tank 51.09
AB

- DT

- 16 Starboard Service Diesel Tank 51.09
AB

- DT

- 17 Port Diesel Settling Tank 51.95Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 71 Trinity Consultants AB

- DT

- 18 Starboard Diesel Settling Tank 51.95
AB

- DT

- 19 Diesel Fuel Overflow Tank 13.98
DR

- FT

- 07 No. 1 Fuel Oil Settling Tank (Starboard) 71 Per 40 CFR 60.110b(b), NSPS Subpart Kb does not apply to storage tanks with

a capacity greater than or equal to 75 m 3 but less than 151 m 3 storing a liquid with a maximum true vapor pressure of less than 15 kPa (2.2 psia). These tanks store diesel fuel which has a vapor pressure lesser than or equal to 0.012 psi at 78  ̊F based on Ta nk 4.0.9d program. DR

- FT

- 08 No. 2 Fuel Oil Settling Tank (Port) 71
SB

- DT

- 01 Vessel's Diesel Fuel Storage Tank #1 Port 143.92
SB

- DT

- 02 Vessel's Diesel Fuel Storage Tank #1 Starboard 143.92
SB

- DT

- 03 Vessel's Diesel Fuel Storage Tank #2 Port 145.46
SB

- DT

- 04 Vessel's Diesel Fuel Storage Tank #2 Starboard 145.46

AB

- DT

- 04 Port Side Double Bottom Diesel Fuel Tank #2 119.18

AB

- DT

- 05 Starboard Side Double Bottom Diesel Fuel Tank #2 119.18

AB

- DT

- 08 Port Side Double Bottom Diesel Fuel Tank #3 105.19

AB

- DT

- 09 Starboard Side Double Bottom Diesel Fuel Tank #3 105.19

Well Completion Tanks

DR

- TP

- 24 Well Completion Condensate Tank 1 80 Per 40 CFR 60.110(d)(4), condensate tanks are exempt from the requirements of NSPS Subpart Kb since the tank volume is less than 1,589.87m3, and condensate is stored prior to custody transfer. DR

- TP

- 25 Well Completion Condensate Tank 2 80

DR

- TP

- 26 Well Completion Condensate Tank 3 80



### 4.3.5. 40 CFR 60 Subpart IIII

– Stationary Compression Ignition Internal Combustion

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 (ICE). This subpart pro vides standards for owners and operators of stationary CI ICE that commence construction after July 11, 2005 where the stationary IC engines are:

Manufactured after April 1, 2006 and are not fire pump engines [40 CFR 60.4200(a)(2)(i)]; or Manufactured as a certified National Fire Protection Association (NFPA) fire pump engine after July 1, 2006 [40 CFR 60.4200(a)(2)(ii)].Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 72 Trinity Consultants Table 4

- 2

. Applicable Engines Subject to Subpart IIII

EPN Description Manufacturing Year Engine Rating

(HP) Displacement Per

Cylinder
Drillship Main Engines

DR

- M E

- 01 Main Propulsion Electrical

Generator Engine #1 2012 6,035 32.2

DR

- M E

- 02 Main Propulsion Electrical

Generator Engine #2 2012 6,035 32.2

DR

- M E

- 03 Main Propulsion Electrical

Generator Engine #3 2012 6,035 32.2

DR

- M E

- 04 Main Propulsio n Electrical

Generator Engine #4 2012 6,035 32.2

DR

- M E

- 05 Main Propulsion Electrical

Generator Engine #5 2012 6,035 32.2

DR

- M E

- 06 Main Propulsion Electrical

Generator Engine #6 2012 6,035 32.2

DR

- ME

- 07 Main Propulsion Electrical

Generator Engine #7 2012 12,069 64.3

DR

- ME

- 08 Main Propulsion Electrical

Generator Engine #8 2012 12,069 64.3 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)
Per 40 CFR 60.4200(a)(2)(i), the eight main engines on the drillship are subject to this regulation because they were manufactured after April 1, 2006. These engines are required to comply with the following requirements:



### NO X 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 NO X 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

. Anadarko will comply with the NO X emiss ion standard of 9.69 g/kw

- hr and will comply with the PM emission standard of 0.15 g/kw

- hr. Anadarko will demonstrate compliance with th ese standards during the initial performance test as required and will comply with notification and recordkeeping requirements. Furthermore, Anadarko will comply with the fuel sulfur content requirement by using ULSD, which has a maximum of 15 ppm sulfur content. Anadarko is proposing to install an emission monitoring system to comply with the requirements of 40 CFR 60.4211(d), and 40 CFR 60.4213 . The details of the emission monitoring system will be submitted as they become available.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 73 Trinity Consultants 

### 4.3.5.2. 

### Drillship Emergency Generator (DR

- GE

- 01)

T he drillship emergency generator is a 20 11 model year wit h a displacement of less than 10 liters per cylinder CI engine . Per requirements of NSPS IIII for this category of engine, this engine must comply with emission limitations for new nonroad CI engines as specified in 40 CFR 89.112 and 40 CFR 89.113, for all pollutants.

Currently, this engine is not certified as per requirements specified in the 40 CFR 89.112 . However, this eng ine is compliant with IMO Tier II standard, which is more commonly applicable standards for a non U.S. flagged vessels such as the BlackHornet

. Since certification is an engine manufacturer process, it is not possible for these engines to obta in an EPA Ti er certificate

. The IMO Tier II standard only limits emissions of NO X and the NO X emission standard for this engine is less conservative than the EPA Tier 2 standard for this engine. Hence this engine currently does not comply with the EPA Tier 2 standar ds. Since an EPA Tier 2 certified engine is the only compliance option ava ilable to meet the requirements of 40 CFR 60 Subpart IIII for this category of engines , a new engine would have to be purchased and installed by the operator to replace the existing engine to comply with NSPS IIII

. Pursuant to 40 CFR § 55.7, the EPA may grant an exemption from a part 55 requirement, if the Administrator or the delegated agency finds that compliance is technically infeasible or will cause an unreasonable threat to health and safety. Since the existing emergency generator was sized to meet the drillship’s stringent space and weight distribution requirements in the vessel’s design phase, any replacement engine would have to meet similar physical characteristics and r estrictions dictated by the vessel’s design. It is very difficult, if not impossible, to find a replacement EPA Tier 2 certified engine meeting the constraints discussed above. Moreover, such a replacement will require significant redesign and recertific ation of the drillship.

As shown in Table 4

- 3 and Table 4

- 4 below, the emergency engine’s emission levels for NO X and PM are higher than that of the EPA Tier 2 emissions standards. Given the minimal operations of this equipment resulting in low emissions , Anadarko believes that replacement of the existing emergency engine with an EPA Tier 2 certified engine is cost prohibitive and therefore, requests an exemption from the requirements of 40 CFR Subpart IIII for the emergency generator engine.

Table 4

- 3

. Emergency Genera tor Offset Requirements

Pollutant PTE Emissions

(g/KW

- hr) EPA Tier 2 Standard (g

- KW

- hr) Emission Offsets Required

NO X + NMHC 10.1 6.4 Yes

CO 0.38 3.5 No

PM 0.43 0.2 Yes

Notes: 1) Vendor supplied CO emissions data are less than Tier 2 emission standard s for CO. 2) Vendor data unavailable for PM emissions, therefore Anadarko proposed PTE calculations for PM are based on AP

- 42 factor.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 74 Trinity Consultants Table 4

- 4

. Emergency Generator Residual Emissions

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

NOx + NMHC 1.51 0.96 +0.55

CO 0.57 0.57

--

PM 0.004 0.001 +0.003



### 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 40 C FR 89.112 and 40 CFR 89.113. Table 1 of 40 CFR 89.112(a) requires the engine to comply with the following EPA Tier 2 exhaust emission standards:



### NO X – 7.5 g/kw

- hr CO

– 5.5 g/kw

- hr PM

– 0.6 g/kw

- hr

Additionally, the emergency air compressor must comply with the following exhaust opacity limits specified in 40 CFR 89.113(a):

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 2 certified engine c ompliance 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.



### 4.3.5.5. 

### Stimulation Vessel Pumps (SV

- PE

- 01 through SV

- PE

- 08)
The only sources utilized for the well completion activity which are potentially subject to NSPS subpart IIII are eight pumps (SV

- PE

- 01 thru SV

- PE

- 08) on the Stimulation VesselAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 75 Trinity Consultants Per 40 CFR 60.4200(a)(2)(i), all the engine s above 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.

With regard to the pumps on the stimulation vessel, they are “representative” pumps only (i.e., available at the time of this report preparation) , and Anadarko may replace these engines with substitute engines with equal or lesser emissions. Therefore, in cases where the substitute engines are subject to 40 CFR 60 Subpart IIII, Anadarko will comply with all applicable requirements.



### 4.3.6. 40 CFR 60 Subpart JJJJ

– Stationary Spark Ignition Internal Combustion

NSPS Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
, provides standards for manufacturers, owners, and operators of stationary spark ignition (SI) ICE. For emergency engines with a maximum power greater than 25 HP, this subpart provides standards for owners and operators of stationary SI ICE that commence constructi on after June 12, 2006, where the stationary SI ICE are manufactured on or after July 1, 2009 [40 CFR 60.4230(a)(4)(iv)]. This subpart is also applicable to owners and operators of stationary SI ICE that modify or reconstruct their stationary SI ICE after June 12, 2006 [40 CFR 60.4230(a)(5)].

There are no stationary SI engines proposed for this project. Therefore, NSPS Subpart JJJJ does not apply to any source included in this permit application.



### 4.3.7. 40 CFR 60 Subpart Dc

– Standards of Performance for Small Industrial

– Commercial

– Institutional Steam Generating Units

A typical f

low back b oiler ( "SIGMA FIRED" SF

- 200SE or equivalent) will be used for the well completion activity. Based on the firing capacity, it could be potentially subject to 40 CFR 60 Subp art Dc.

Per 40 CFR 60.40c(a), owners and operators of each steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 29 megawatts (MW) (100 million British thermal units per hour (MMBtu/hr)) or less, but greater than or equal to 2.9 MW (10 MMBtu/hr) should comply to standards in the subpart.

T he maximum design heat input capacity of th e proposed flowback boiler is 8 MMBtu/hr which is less than 10 M MBtu/hr. Therefore, NSPS Subpart Dc does not apply to this equipment

.


### 4.4. N ATIONAL E MISSION S TANDARDS F OR H AZARDOUS AIR P OLLUTANTS (NESHAP

- 40 CFR PART 61)

Per 40 CFR 55.13(e), 40 CFR Part 61 together with any other provisions promulgated pursuant to section 112 of the Clean Air Act shall apply to OCS sources if rationally related to the attainment and maintenance of federal or state ambient air quality standards or the requirements of part C of title I of the Clean Air Act (PSD).Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 76 Trinity Consultants 

### 4.4.1. 40 CFR 61 Subpart A

- General Provisions

40 CFR 61 Subpart A provides the general provisions to which each source subject to another Part 61 subpart must comply unless specifically excluded by the applicable subpart. These provisions include initial notification and performan ce testing, recordkeeping, and monitoring requirements for all other subparts as applicable. Part 61 applies to owners or operators of any stationary source for which a pollutant

- specific standard is prescribed under this part. There are no subparts unde r the 40 CFR Part 61 that applies to the exploratory drilling operations proposed in this application.



### 4.5. N ATIONAL E MISSION S TANDARDS FOR H AZARDOUS A IR P OLLUTANTS (NESHAP

– 40 CFR PART 63)

NESHAP apply to major sources of HAP or specifically designated area s ources of HAP. A HAP major source is defined as having potential emissions in excess of 10 tons per year for any individual HAP and/or 25 tons per year for total HAPs. The proposed project results in an area source of HAP, because potential HAP emissions are less than the major source thresholds. Potentially applicable NESHAP subparts are discussed below.



### 4.5.1. 40 CFR 63 Subpart A

– General Provisions

All affected sources are subject to the general provisions of Part 63 NESHAP Subpart A unless specifically ex cluded by the source

- specific NESHAP. These provisions include initial notification and performance testing, recordkeeping, reporting, monitoring, and control device and work practice standards for all other subparts as applicable.



### 4.5.2. 40 CFR 63 Subpart ZZZ Z

– Stationary Reciprocating Internal Combustion

Engines

NESHAPs Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines , provides national emission limitations and operating limitations for HAPs emitted from stationary reciprocating internal combustion engines (RICE) located at major sources and area sources of HAP emissions. Anadarko's proposed exploratory drilling operations will be an area source for HAPs and therefore thi s Subpart would be potentially applicable.

Per CFR 63.6590(a)(1)(iii), stationary RICE located at an area source of HAP emissions would be defined as an existing source under the requirements of this Subpart if the construction or reconstruction of the st ationary RICE is commenced before June 12, 2006. The third party well evaluation engines (DR

- TP

- 12 through DR

- TP

- 16 ) qualify as existing non

- emergency stationary RICE under 40 CFR 63, Subpart ZZZZ. These engines will be subject to the following requirem ents:

Operate and maintain the stationary RICE and after

- treatment control device (if any) according to the manufacturer's emission

- related written instructions or develop own maintenance plan which provides to the extent practicable for the maintenance a nd operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions [40 CFR 63.6625(e)]. Minimize the engine's time spent at idle during startup and minimize the engine'sAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 77 Trinity Consultants

startup time to a period needed for a ppropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non

- startup emission standards apply [40 CFR 63.6625(h)]. Comply with the recordkeeping requirements of 40 CFR 63.6655(e). Comply with the management practices applic able requirements in Table 2d of this Subpart:

 change oil and filter every 1,000 hours of operation or annually, whichever comes first;

 inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as needed; and

 inspec t all flexible hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as needed. Per 40 CFR 63.6660, records of management practices discussed above need to be kept in readily accessible hard or electronic form for at least 5 years following the date of each maintenance activity. At a minimum, the most recent 2 years of data shall be retained on site and the remaining 3 years of data may be retained off site.

T he following engines on the Drillship qualify as new stationary RICE under this regulation because the engines were constructed after June 12, 2006

. Drillship Main engines (DR

- ME

- 01 thr o u gh DR

- GE

- 08 ) Drillship E mergency Generator (DR

- GE

- 01) Drillship Emergency Air Compressor (DR

- AC

- 01)

Pursuant to § 63.6590(c)(1) of this subpart, a new CI RICE located at an area source must comply with 40 CFR part 60, subpart IIII, and no further requirements apply for such engines under 40 CFR part 63. Therefore, the engines will comply with 40 CFR part 60, subpart I III, and will not be subject to any further requirements under this subpart.



### 4.5.3. 40 CFR 63 Subpart HHHHHH

– Paint Stripping and Miscellaneous Surface

Coating Operations at Area Sources
NESHAPs Subpart HHHHHH provides national emission limitations and operating limitations for HAPs emitted from paint stripping and miscellaneous surface coating operations performed at area sources of HAP emissions.

Anadarko's proposed exploratory drilling operations will be an area source for HAPs and therefore this Subpart wo uld be potentially applicable. The spray painting operation performed on the drillship is part of the routine maintenance to protect the vessel from the harsh environment so that the drillship functions in its intended capacity. Therefore, this activity meets the definition of “facility maintenance” provided in 40 CFR 63.11180. Pursuant to 40 CFR 63.11170(a)(3), spray painting operations on the drillship are not subject to the requirements of this regulation.



### 4.6. FEDERAL OPERATING P ERMITS P ROGRAM (40 CFR PAR T 71)

The Federal Operating Permits Program (40 CFR 71) sets forth the comprehensive Federal air quality operating permits permitting program consistent with the requirements of Title V of the Clean Air ActAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 78 Trinity Consultants and defines the requirements and the correspondin g standards and procedures by which the Administrator will issue operating permits. 6 Using the procedures of 40 CFR 71, the Administrator will issue permits to any source which is an OCS source that is located beyond 25 miles of States' seaward boundaries , as defined under 40 CFR 55.2. 7

A major source is defined under 40 CFR 71 as, “A major stationary source of air pollutants or any group of stationary sources as defined in section 302 of the CAA, that directly emits, or has the potential to emit, 100 t py or more of any air pollutant.” 8 Per this definition, the proposed project is a major source under 40 CFR 71 and shall obtain a Title V Operating Permit.

All major sources under this subpart shall be subject to the general monitoring, recordkeeping, and reporting requirements as provided under 40 CFR 71, unless otherwise specified. In addition, each Part 71 source is required to submit an annual report containing the actual emissions for the preceding calendar year, a fee calculations work sheet, and a full payment of the annual fee as required under 40 CFR 71.9(h). Anadarko will comply with the requirement to submit annual emission report and pay such annual fees as required.



### 4.7. ENDANGERED SPECIES A CT

Under Section 7 of the Endangered Species Act (ESA ), 16 U.S.C. § 1536, EPA has a responsibility to ensure that any action authorized or permitted by EPA is not likely to jeopardize the continued existence of any federally

- listed endangered or threatened species or result in the destruction or adverse modi fication of such species’ designated critical habitat. If EPA’s action (i.e., permit issuance) may affect a federally

- listed species or critical habitat, Section 7 of the ESA sets up a procedure for consultation between EPA and U.S. Fish and Wildlife Serv ice (USFWS) and/or the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NMFS).

BOEM issued an environmental assessment (EA) for the Central and Western Planning Areas i n 2012 (Post Macondo Oil Spill). Currently, BOEM is preparing a draft for the Eastern Planning Area which is expected to be completed by the end of 2013. Per a dis cussion between Trinity and the National Oceanic and Atmospheric Administration (NOAA) 9 , no new protected species have been listed in the Gulf of Mexico since the 2007 biological opinion ; hence, no further action is required from Anadarko to demonstrate compliance

6 40 CFR 71.1(a)

7 40 CFR 71.4(d)(1)

8 40 CFR 71.2 9 Per phone email communication with Mr. Rahu l Pendse and Mr. Adam Brame on 08/06/2013Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 79 Trinity Consultants 

## 5. BACT A NALYSIS

As required by 40 CFR §52, Best Available Control Technology (BACT) must be applied to reduce or eliminate air emissions from a new or modified facility. PSD BACT is defined 40 CFR §52.21(b)(12) as:

“An emissions limitation (including a visible emission standard) based on the maximum degree of reduction for each pollutant subject to regulation under Act which would be emitted from any proposed major stationary source or major modification which the Administrator, on a case

- by

- case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such source or modification through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such pollutant. In no event shall application of best available control technology result in emissions of any pollutant, which would exceed the emissions allowed by any applicable standard under 40 CFR parts 60 and 61. If the Administrator determines that technological or economic limitations on the ap plication of measurement methodology to a particular emissions unit would make the imposition of an emissions standard infeasible, a design, equipment, work practice, operational standard, or combination thereof, may be prescribed instead to satisfy the re quirement for the application of best available control technology. Such standard shall, to the degree possible, set forth the emissions reduction achievable by implementation of such design, equipment, work practice or operation, and shall provide for co mpliance by means which achieve equivalent results.”

EPA has developed a “top

- down” process that can be used to ensure that a BACT analysis satisfies the applicable legal criteria. Presented below are the five basic steps of a top

- down BACT review as ide ntified by the EPA. 10

STEP 1

– IDENTIFY ALL CONTROL TECHNOLOGIES Step 1 of the top

- down approach requires that all available control options that are potentially applicable to the proposed source are identified. It is the applicant’s responsibility to ide ntify available control options by consulting the EPA’s Reasonably Available Control Technology ( RACT ) /BACT/ Least Achievable Emission Rate ( LAER ) clearinghouse (RBLC) , along with other reliable sources. Viable control options are those technologies that h ave a practical potential for application to the emissions unit and the regulated pollutant under evaluation.

STEP 2

– ELIMINATE TECHNICALL Y INFEASIBLE OPTIONS Step 2 of the top

- down approach allows for the elimination of control options that are technica lly infeasible. Also, each technology should be “demonstrated” (previously installed and operated successfully on a similar facility); or if undemonstrated, then the applicant must determine whether the technology is both “available” and “applicable.” Te chnologies identified in Step 1 that are neither demonstrated nor found to be both available and applicable are eliminated under Step 2.

STEP 3

– RANK REMAINING CONTR OL TECHNOLOGIES Step 3 of the top

- down approach requires ranking of the remaining control technologies based on control effectiveness. If there is only one remaining option or if all of the remaining technologies could achieve equivalent control efficiencies, ranking based on control efficiency is not required.

10 U.S. EPA. Draft New Source Review Workshop Manual , Chapter B. Research Triangle Park, North Carolina, October 1990.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 80 Trinity Consultants STEP 4

– EVALUATE MOST EFFECTIVE CONTROLS Step 4 of the top

- down approach allows for the elimination of control options based on collateral impacts. In descending order, the applicant should evaluate and compare the collateral impacts of each control option. The permitting aut hority (EPA) has discretion on weighting each area of collateral impact. This step validates the suitability of the top control option identified or provides a clear justification as to why the top option should not be selected as BACT. Costs of installi ng and operating control technologies are estimated and annualized following the methodologies outlined in the U.S. EPA’s OAQPS Control Cost Manual (CCM). 11

STEP 5

– SELECT BACT Step 5 of the top

- down approach requires selection of BACT for the emissions u nit and the regulated pollutant under evaluation. The most effective control alternative not eliminated in Step 4 is selected as BACT with a corresponding emission limit established . The selection of BACT in the fifth step involves an evaluation of emiss ion rates achievable with the selected control technology. BACT is an emissions limit unless technological or economic limitations of the measurement methodology would make the imposition of an emissions standard infeasible, in which case a work practice or operating standard can be imposed. Selected BACT can be no less stringent than an applicable NSPS, MACT, or RACT.

The emissions of NO X , CO, PM, PM 10 , PM 2.5 , VOC, and GHG exceed the applicable SERs. Therefore PSD BACT must be determined for each emiss ion unit at the facility that emits NO X , CO, PM, PM 10 , PM 2.5 , VOC or GHG when conducting the proposed operations

.

The emission sources on the drillship subject to BACT analysis are as listed below:

Eight main engines (DR

- ME

- 01 to DR

- ME

- 08 ) One emergency generator (DR

- GE

- 01) One emergency air compressor engine (DR

- AC

- 01) Third party engines: Third party EPA Tier II certified engines ≤860 HP (DR

- TP

- 01 and Dr

- TP

- 02) Third party EPA Tier II certified engines ≤300 HP (DR

- TP

- 03 to DR

- TP

- 11) Third party well evaluation engines ≤140 HP (DR

- TP

- 12 to DR

- TP

- 16 and SB

- TP

- 05 to SB

- TP

- 09) Third party EPA Tier II certified engines ≤126 HP (DR

- TP

- 17 to DR

- TP

- 21) One flowback boiler (DR

- TP

- 22 ) One boom flare (DR

- TP

- 23 ) Fuel s torage tanks (several EPNs) Pai nting (DR

- PO

- 01) Welding (DR

- WO

- 01)

Under certain operati ng scenario s , the following sources of air pollution will constitute stationary source aspects of the vessels when the support vessels are physically attached to the OCS source ; hence, BACT analysis is performed for these sources.

Fuel Storage Tanks on the supply boats and the anchor handling boat (several EPNs)

11 Office of Air Quality Planning and Standards (OAQPS), EPA Air Pollution Control Cost Manual
, Sixth Edition, EPA 452

- 02

- 001 (http://www.epa.gov/ttn/catc/products.html#cccinfo), Daniel C. Mussatti & William M. Vatavuk, January 2002.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 81 Trinity Consultants Eight pump engines on the S timulation Vessel (SV

- PE

- 01 thru SV

- PE

- 08)

The life boats (DR

- LB

- 01 and DR

- LB

- 06) and the fast rescue boat (DR

- FR

- 01) are included in the PTE calculations and air dispersion modeling as specified in 40 CFR part 55 and these sources are subject to operating limits, monitoring, recordkeeping and reporting requirements to ensure they will not exceed the potential emissions assumed in the application and impact review. Per 40 CFR § 55.2 , the support

v essels operating within 25 miles of the OCS source are not subject to BACT requirements unless they are attached to the OCS . If attached
, o nly the stationary source aspects of the vessel are regulated. These units do not have any stationary source aspects with respect to BACT subject pollutant emissions, as they are used for man overboard and emergency escape scenarios only.



### 5.1. NO X 

### B ACT A NALYSIS

The emission sources o f NO X on the drillship subject to BACT analysis are as listed below:

Eight main engines (DR

- ME

- 01 to DR

- ME

- 08 ) One emergency generator (DR

- GE

- 01) One emergency air compressor engine (DR

- AC

- 01) Third party engines:

 Third party EPA Tier II certified engines ≤860 HP (DR

- TP

- 01 and DR

- TP

- 02)

 Third party EPA Tier II certified engines ≤300 HP (DR

- TP

- 03 to DR

- TP

- 11)

 Third party well evaluation engines ≤140 HP (DR

- TP

- 12 to DR

- TP

- 16 and SB

- TP

- 05 to SB

- TP

- 09)

 Third party EPA Tier II certified eng ines ≤126 HP (DR

- TP

- 17 to DR

- TP

- 21) One flowback boiler (DR

- TP

- 22 ) One boom flare (DR

- TP

- 23 ) Eight pump engines on the S timulation Vessel (SV

- PE

- 01 thru SV

- PE

- 08)



### 5.1.1. NO X 

### BACT Analysis for the Drillship Main Engines (DR

- ME

- 01 to DR

- ME

- 08)

Deepwater drilling with a dynamically positioned drillship presents a unique set of challenges in managing power while conducting work. The drillship is designed to operate in deep water in highly vari able operational and environmental conditions. The need for power redunda ncy to manage the operating risks affects the power use levels, which in turn affects the air emissions.

The main propulsion engines are used to power the thrusters that hold the ship on location, as well as power the drilling equipment and other operatio nal needs of the ship. The main propulsion engines operate at variable loads based on drilling and operational power demand, and extensive “reserve” power is required to adjust for loop currents and storms which can cause large variations in thruster power used . Hence, NO X emissions are not emitted from these engines at a steady state

. These factors are important considerations in the BACT analysis for these engines.



### Step 1

– Identify all Control Technologies The first step in the EPA top

- down, five

- step analysis is to identify all available control technologies that are potentially suitable for the affected sources. EPA's RBLC search was used to obtain potential controlAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 82 Trinity Consultants technologies for NO X from main propulsion engines at offshore sources. The most recent 10

- year period was used to identify applicable control technologies. The results of the RBLC search are included in Appendix E. However, it should be noted that the control technologies evaluated in the “topdown” analysis for main engines were no t limited to the controls listed in the RBLC database. The permits recently proposed/issued by U.S. EPA Region 4 and Region 10 (and corresponding permit applications) for similar OCS sources in Gulf of Mexico have also been reviewed in addition to surveyi ng available literature to identify potential control technologies . The search results for potential control technologies for NO X from the main engines are listed below.

1. Selective Catalytic Reduction (SCR)
2. Selective Non

- Catalytic Reduction (SNCR)
3. Direct Water Injection (DWI)
4. Exhaust Gas Recirculation (EGR)
5. Derate Engines
6. Water

- in

- fuel Emulsions
7. Intake Air Humidification/Cooling
8. NO X Adsorber
9. CSNO x Emissions Abatement System
10. Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042)
11. CAM Shaft Replacement/ Retooling of Engines
12. Lean De

- NO X Catalyst (LNC) or Hydrocarbon SCR (HC

- SCR)
13. Low NO X Engine (LNE) design
14. Perf o rmance management system including Turbocharger with Aftercooler and High Fuel Injection Pressure System
15. 4

- Way Cat alyst Converter
16. Good Combustion and Manufacturer Recommended Maintenance Practices
17. Ignition Timing Retard (ITR)



### Step 2

– Eliminate Technically Infeasible Option

SCR

– Infeasible.

SCR is a post

- combustion NO X control technology. In SCR, ammonia (NH 3 ) or urea diluted with air or steam is injected into the flue gas upstream of a catalytic reactor. The catalyst bed operates at temperatures between 600 and 800 °F, depending on the catalyst. On the catalyst surface, the NH 3 reacts with NO X to form molecular nitrogen and water.

The primary variable affecting NO X reduction is temperature of the gas stream. If operating below the optimum temperature range, the catalyst activity is reduced allowing unreacted NH 3 to slip through. If operating above the optimum temperature range, NH 3 is oxidized, forming additional NO X and the catalyst may suffer thermal stress damage.

The highly variable power use inherent to operations on a dynamically positioned drillship creates circumstances that are unfavorable for the SC R process. The power load variability requires a corresponding high level of power redundancy to ensure reliable station keeping. This redundancy can result in lower levels of power capacity used over extended periods (e.g. during strong loop currents orAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 83 Trinity Consultants winter storms). When the engines are run at lower capacity, the engine exhaust temperatures can drop to levels that reduce the effectiveness of SCR technology.

Urea slip rates can occur that do not allow the catalytic reduction of NO X to the predicted levels. The volume of urea required for optimal SCR performance is substantial; approximately 20 to 25 g of urea solution/KW

- hr engine output. Hence, additional tanks w ould be added onboard for urea storage. Since these additional storage tanks were no t a part of initial drillship design, addition of these tanks will require considerable redesign to ensure load balancing and other critical criteria are complied with. Moreover, since limited space is available for critical drilling equipment, tubulars a nd consumables, the handling and storage of urea onboard presents difficult operational challenges.

Although SCR technology has been utilized at onshore sources, it has not been successfully proven as a viable control technology for sources such as main e ngines on the drillship. This technology has been proven successful for steady state load conditions. However, due to nature of operations, main engines on the drillship have frequent load variations, which could significantly impact emission control eff iciency of SCR technology.

While the accommodation of SCRs is less difficult in the design stage of a drillship, post design addition of SCRs would require significant space reassignment and will impact deck load capacity and stability (i.e., center of gravity) of the currently desi gned drillship. However for completeness, Anadarko is including the cost analysis for SCR installation below which reaffirms the cost prohibitive nature of installing an SCR.

SNCR

– Infeasible

. This technology is technically infeasible to operate o n th e main engines of the BlackHornet drillship

. This method of NO X reduction introduces new compounds (most commonly ammonia or urea) to the diesel exhaust which break down NO X molecules into nitrogen and oxygen, much like an SCR. SNCR systems can realize N O X reductions of 60%, but only at temperatures greater than 1,700 °F. At lower temperatures, the reaction proceeds too slowly, resulting in unused ammonia emitting from the stack. Because this temperature is well above the exhaust gas temperature range o f the main engines, this option was not deemed to be technically feasible for this application.

In addition, this technology is also infeasible for the reasons provided for SCR above, pertaining to urea storage requirements and significant structural changes that will impact deck load capacity and stability. 

### Due to the reasons discussed above, this technology is deemed as technologically infeasible.

DWI

– Infeasible

. This control technology involves reduction in combustion temperature by mixing st eam or water with the air flow. Steam or water acts as a heat sink to reduce peak temperatures, thereby reducing the formation of NO X . NO X reductions of 25

- 35 percent can be achieved with water injection. 12 

### This technology is in development stages for marine applications and cannot be used reliably at low loads (30

- 50%) or variable loads

.

12 Based on Memorandum from Tanya Parise, Alpha

- Gamma Technologies, Inc. to Sims Roy, EPA OAQPS ESD Combustion Group, titled NOx Control Technologies for Stationary Diesel ICE

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 84 Trinity Consultants 

### Also, fresh water is necessary for this NO X 

### reduction technology. Introducing salt water into the engines could result in serious deterioration due to corrosion an d fouling. For this reason, implementing this strategy would require either production of fresh water through the use of desalination or distillation system or the storage of fresh water on board. Therefore, either pure water storage tanks would need to be constructed or the alternative of installing a desalination or distillation unit would incur additional costs for the unit. Both alternatives would also require additional space and would potentially require recertification of the vessel.

Another co ncern with the use of water in the combustion process is the effect on PM/PM 10 /PM 2.5 emissions. The water in the cylinder reduces NO X , which is formed at high temperatures, by reducing the temperature in the cylinder during combustion. However, PM/PM 10 /P M 2.5 oxidation is most efficient at high temperatures. Therefore, while water injection may lead to reduction in NO X emissions, there may be an increase in PM/PM 10 /PM 2.5 emissions. There is also a potential for engine damage to occur as a result of the w ater contacting the combustion cylinder surface causing disintegration of lubricating oil film. Due to the reasons discussed above, this technology is deemed as technologically infeasible.

EGR

– Infeasible

. EGR works by re

- circulating a fraction of an engine's exhaust gas back to the en gine cylinders. In this technology, the amount of oxygen in the air/fuel mixture is reduced causing the engine to run less lean. This in turn lowers the operating temperature of the engine. Because NO X formation incre ases at higher temperature, a reduction in the operating temperature will result in a reduction in NO X formation.

Applying EGR to a diesel RICE can reduce the power that is generated by the engine. This is because the EGR system reduces the specific he at ratio of the combustion gases in the power stroke, which in turn reduces the amount of power or work that can be extracted by the piston. The reduction in power generation could lead to potential safety hazards.

Applying EGR may reduce the amount of fuel that is completely combusted thereby increasing the PM/PM 10 / PM 2.5 emission rate. Due to the reasons discussed above, this technology is deemed as technologically infeasible. In addition, the technology is still under development for marine applicat ions; hence, this technology is considered as technologically infeasible.

Derate Engines

– Infeasible

. An engine can be derated by restricting its operation to lower levels of power than normal for the given application. Derating reduces cylinder pressures and temperatures and can lower NO X formation rates. Engine derating is accomplished by changing the injector nozzles with smaller holes to atomize the smaller amount of fuel used and the turbocharger nozzle rings can be allowed a lower exhaust g as spin the turbocharger faster, thus compressing a greater volume of air for a given volume of gas.

Derating reduces the engine's operating temperature, which can result in higher CO and VOC emissions. Further derating the engines will decrease the avai lable power, which would cause an unreasonable safety risk. The safety concern would be that the drillship must have adequate power to handle storms (e.g., winter weather or hurricanes) and loop currents that periodically occur at the location. Due to th e reasons discussed above, this technology is deemed as technologically infeasible.

Water

- in

- fuel Emulsions (emulsified diesel)

– Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 85 Trinity Consultants This technology would require derating of the engines, and emulsified diesel in marine vessels can cause fuel tank corrosion issues. Additionally, emulsified fuel systems were designed for and installed on slow

- speed engines burning heavy fuel oil. The e xisting main engines on the BlackHornet drillship are designed and will be burning medium density fuel (diesel). Several significant engineering hurdles must be overcome in order to install a diesel/water emulsion system on board the BlackHornet drillship

. The primary hurdle is the installation of a mixing tank. The current design of the drillship does not include a space for a mixing tank. The installation of a new tank would require extensive analysis, pipe fitting and modification to monitoring sys tems aboard the rig. The tank may also need to be pressurized to maintain the emulsion which would require the installation of booster pumps and the associated piping, power and monitoring systems inherent in such a configuration. The pressurized fuel wo uld increase pressure head that already exists in the fuel lines and could lead to excessive fuel pressure to the engines. Over

- pressurized fuel lines subjected to loads in excess of their design criteria would potentially fail with catastrophic results s uch as spilled fuel, engine room fires or worse. Such a problem would place the safety of the rig, personnel and environment in jeopardy. Installing an untested emulsified fuel system designed for heavy fuel oil use on the existing engines increases the potential for mechanical failure and poses a safety risk that is unacceptable for this project. Due to the reasons discussed above, this technology is deemed as technologically infeasible.

Intake Air Humidification/Cooling

– Infeasible

.

Intake Air Humid ification consists of fogging or saturation of the intake air with water. These motors consist of evaporating water into the relatively hot scavenging air, which flows to the engine through the inlet air manifold. Installation of a Humid Air Motor (HAM) is an alternative to water injection currently being investigated by some diesel engine manufacturers.

Reductions in NO X emissions due to water injection can be expected using this technique but the long term effects of using seawater (if used) is not known. Such technology can require additional freshwater production and storage for humidification of the intake air. A hi gh quantity of water need to be evaporated to create enough humid air to achieve the reductions sought, and are comparable with the fuel volumes . This requires heat input and is provided by heat exchange from the hot compressed air after the engine turboc harger. This implies that at low load there may not be sufficient heat
, in which case the HAM system is not used.

I t is also hard to control the humidity adequately u nder varying loads (when it is most difficult to achieve optimum combustion)

. In addi tion, the technology is in development stages for marine applications, and not available for the main propulsion engines operating on the BlackHornet drillship. Therefore, considering the aforementioned reas ons, Intake Air Humidification/ Cooling is not te chnically feasible.

NO X Adsorber

– Infeasible

.

A NO X adsorber is a catalyst technology used to remove NO X in lean exhaust for diesel and gasoline fired engines. NO X adsorbers consist of ceramic monolith containing parallel channels, coated with precious metal catalysts. During lean operation, NO X is stored in the form of nitrates produced by reactions between the NO x and catalyst. At regular intervals, a momentary reducing condition is produced inside the monolith by injecting reductant, causing the nitrates to decompose to nitrogen.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 86 Trinity Consultants This technology has been used primarily for on

- road diesel applications or off

- ro ad applications for smaller engines such as backhoes, graders, and wheel loaders. This technology is still a technology that is in experimental stages of development stages for marine applications.

CSNOx Emissions Abatement System

– Infeasible

.

This tec hnology is currently in the licensing and commercial demonstration phases of development. This system is tested on engines operating at stable loads

. While this technology is commercially available for certain types of marine uses, it has not been demons trated in practice for variable load engines such as main engines on the drillship. Since significant research and development is required to design a working, deployable CSNO x system that is safe to operate on a drillship, this technology is considered t echnically infeasible

. CAM Shaft Replacement/Retooling of Engines

– Infeasible

. Clean Cam Technology Systems (CCTS) offers retrofit cam shaft reengineering kits for some diesel engines. The kits reduce NO X emissions by increasing the volume of the residual exhaust gas that remains in the combustion chamber after the power stroke.

CCTS cam shaft retrofit (Re

- tooling) kits are only available for Detroit Diesel engines. This technology is only suitable for s mall engines since the cams are integral with the camshaft. The cams are mounted on the camshaft individually and can be easily replaced for smaller engines (most likely 2

- stroke engines). However, it has not yet been developed for larger engines (e.g., 4

- stroke). Therefore, it is not technically feasible for the main propulsion engines.

LNC or HC

- SCR

– Infeasible

. This technology is not commercially available for large marine engines of marine applications. Also, LNC systems operate best at consistent high loads, and are not amenable to load shifts. Therefore, it is not techn olog ically feasible for the main engines.

Engine Replacement To Meet Higher Tier Standards (40 CFR Part 89, 94, or 1042)

– Infeasible

. The main diesel engines meet th e IMO Tier 2 standard of 9.7 g/Kw

- hr for engines under Category 3 (i.e., >30 liter/cylinder displacement operating at 720 rpm ). This emission standard is equal to the EPA Tier 2 (40 CFR Part 1042 ) standards for NO X for this category of engine. Currently , there is no comparable engine available that meets lower emission standards without the use of add

- on control technology. Therefore, replacement engines with higher Tier rating is not an option.

Moreover , certification to meet these standards is part of the inherent design of the engine and there is no upgrade available for an existing IMO Tier 2 certified engine to meet more stringent standards which will also require recertification from the engine manufacturer. Considering the aforementioned reason

r eplacing the existing engine to meet a higher Tier standards is not a feasible option.

4

- Way Catalyst Converter

– Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 87 Trinity Consultants 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 ti ming 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 ca n hinder operations. For these reasons this te chnology 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), t he cost effectiveness analysis of SCR installation is estimated to be approximately $1 2
, 000 per ton of NO X reduced, making this option cost pro hibitive. A detailed control cost effectiveness analysis is provided in Appendix E.

Perfo rmance Management S ystem including Turbocharger with Aftercooler and High Fuel Injection Pressure System and Low NO x 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 NO X emission by optimizing the intake valve's closing timing espec ially, 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 mo unted 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 NO X design. Since Anadarko i s proposing to implement this technology, a control cost analysis is not required.

13 Cost analysis presented in Appendix EAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 88 Trinity Consultants Good Combustion and Manufacturer Recommended maintenance practice

– Anadarko is proposing to supplement the good combustion practices outlined by the manufacturer with use of recommended operation and maintenance practices. Since Anadarko is proposing to implement this technology, a control cost analysis is not required.

Step 5

- Select BACT The main engines on the drillship are certified to meet Tier 2 standards of the IMO’s 2008 NO X Technical Code (Regulation 13). In other words, at engine speeds of 720 rpm, these engines are designed to meet NO X emission limits of 9.7 g/kW

- hr. Anadarko proposes compliance with NSPS IIII, IMO Tier 2 standards, LNE Design, Turbocharger with Aftercooler & High Injection Pressure, Optimized Supercharger with Miller Cycle and good combustion and manufacturer recommended maintenance practic es as NO X BACT for the eight main engines

.



### 5.1.2. NO X 

### BACT Analysis for Emergency Generators (DR

- GE

- 01)
The emergency generator is a Cummins QSK60DMGE model engine.



### Step 1

– Identify all Control Technologies

T he control technologies for the main propulsion engines discussed above were considered as the potential control technologies for the emergency generators

.



### Step 2

– Eliminate Technically Infeasible Options

SCR

– Infeasible.

This control option is not technically feasible for use on the emergency generator , which only operates intermittently during short weekly periods. The SCR systems require a longer period of operating time in order to reach a minimum temperature before the system can operate. Hence, it is deemed as technically infeasible.

SNCR

– Infeasible

. 

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

DWI

– Infeasible

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

.

EGR

– Infeasible

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

Derate Engines

– Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 89 Trinity Consultants This control technology is deemed technically infeasible for the same reasons identified in Section 5.1.1

Water

- in

- fuel Emulsions (emulsified diesel)

– Infeasible

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

Intake Air Humidification/Cooling

– Infeasible

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

NO X Adsorber/Scrubber Technology

– Infeasible

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

CAM Shaft Replacement/Retooling of Engines

– Infeasible

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

LNC or HC

- SCR

– 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

Table 5

- 2 . Ranks of Technologies Feasible for Emergency Generators

Technology Efficiency Rank Low NO X Engine and Turbocharger with Aftercooler and High I njection P ressure 30% N/A

Good Combustion and Manufacturer Recommended Maintenance Practices Baseline N/A

All feasible technologies for the emergency engines are listed in Table 5

- 2. Control technologies are ranked by efficiency in a descending order.

Step 4

– Evaluate Most Effective Controls and Document ResultsAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 90 Trinity Consultants The emergency engines on the drill ship are certified at construction to meet Tier 2 standards of th e IMO’s 2008 NO X Technical Code (Regulation 13).

The emergency generator only operates intermittently for short periods (2 hours per day and 100 hours per year) and it is primarily designed to handle during emergency situation. The emergency generator is certified to meet IMO Tier 2 standards and is the cleanest available engines in this category of engines. Since, the remaining identified technologies are proposed as BACT, a cost analysis is not required.

Step 5

- Select BACT

Anadarko proposes compliance with IMO Tier 2 standards, Turbocharger with Aftercooler and High Injection Pressure, and good combustion and manufacturer recommended maintenance practices as NO X BACT for the emergency generator.



### 5.1.3. NO X 

### BACT Analysis for Emergency Air Compressor Engine (DR

- AC

- 01)
The air compressor diesel engine is a 52 HP HATZ 2 M41 model engine.



### Step 1

– Identify all Control Technologies EPA's RBLC search was used to obtain potential control technologies for 

### NO X from smaller diesel engines (< 500 HP) 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 NO X from smaller engines. 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 NO X from smaller diesel engi nes are listed below.

DWI EGR Derate Engines Water

- in

- fuel Emulsions Intake Air Humidification/Cooling NO X Adsorber/Scrubber Technology Replacement of Older Engines with Newer Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042) CAM Sha ft Replacement/ Retooling of Engines LNC or HC

- SCR LNE design including (Turbocharger with After cooler and High Pressure Fuel Injection ) 4

- Way Catalyst Converter ITR Good Combustion and Manufacturer Recommended Maintenance Practices



### Step 2

– Eliminate Tec hnically Infeasible Options

DWI

– Infeasible.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 91 Trinity Consultants This technology is not suitable for emergency air compressor engine which only operate intermittently during short weekl y periods of engine operation since these engines do not operate under steady state conditions for a long time. In addition, as described in the Section 5.1.1, a significant quantity of fresh water is necessary for this NO X reduction technology. This control technology is deemed technically infeasible for the reasons discussed above and the reasons identified in Section 5.1.1.

EGR

– Infeasible.

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

Derate Engines

– Infeasible.

The primary concern associated with derating the emerge ncy air compressor engine is that derating engines would reduce available power, which is a safety concern during emergency situations where the engines are required to perform at full load. This control technology is deemed technically infeasible for thi s reasons and the reasons identified in Section 5.1.1.

Water

- in

- fuel Emulsions (emulsified diesel)

– Infeasible

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

Intake Air Humidification/Cooli ng

– Infeasible

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

NO X Adsorber/Scrubber Technology

– Infeasible

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

CAM Shaft Replacement/ Retooling of Engines

– Infeasible

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

LNC or HC

- SCR

– Infeasible

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

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

– Infeasible

. Incorporation of this control technology will involve redesigning the engines, making this technology to be most feasibly installed when the engine is manufactured. Requiring this technology would essentially mean having to replace the existing air compressor engine with another air compressor engine that have this technology already installed. This technology is intrinsic to the engine design and retrofitting the air compressor diesel engines is not an option.

4

- Way Catalyst Converter

– Infeasib le

. This control technology is deemed technically infeasible for the same reasons identified in Section 5.1.1.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 92 Trinity Consultants ITR

– Infeasible.

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

Step 3

– Rank Re maining 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 had previously obtained an initial cost estimate of $12,600 for replacing a similar air c ompressor engines compliant with 40 CFR 89 Tier 3 standards.

The emergency air compressor only operates intermittently for short periods (0.5 hours per day and 100 hours per year) and it is primarily designed to operate during emergency situation. The emergency air compressor is certified to meet EPA Tier 2 standards. Given the minimal operations of this equipment resulting in low emissions (i.e., <0.1 tons per year) , Anadarko believes that replacement of existing air compressor engine with the cleanest available engine is cost prohibitive; hence a detailed cost analysis is not warranted.

Step 5

- Select BACT Anadarko proposes 40 CFR 89, EPA Tier 2 standards and good combustion and manufacturer recommended maintenance practices as BACT for the emergency air compressor engine.



### 5.1.4. NO X 

### 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:



### T hird 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 NO X 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, theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 93 Trinity Consultants same options identified for the drillship main propulsion engines and eme rgency 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 operate intermittently. These third party engines are brought onboard as required to perform specific operations and then sent back to the shore base once required task is completed. These engines do not permanently reside on the drillship.

The SCR systems require a longer period of operating time under steady state conditions in order to reach a minimum temperature before the system can operate. Hence, this control technology is deemed technically infeasible for the reasons discussed above and the reasons identified in Section 5.1.1.

SNCR

– Infeasible

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

DWI

– Infeasible.

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

EGR

– Infeasible.

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

Derate Engines

– Infeasible

. An engine can be derated by restricting its operation to lower levels of power than normal for the given application resulting in the decrease in available power

. Since these engines are brought onboard to perform specific operations, these a re selected based on the power requirements for a specific task. Hence, derating these engines could significantly impact the operations . Hence, it is deemed as technologically infeasible.

Water

- in

- fuel Emulsions (emulsified diesel)

– Infeasible

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

Intake Air Humidification/Cooling

– Infeasible

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

NO X Adsorber/Scrubber Technology

– Infeasible

. This control technology is deemed technically infeasible for the same reasons identified in Section 5.1.1.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 94 Trinity Consultants Replacement of Older Engines with Newer Engines

– Infeasible

.

The cleanest available engine for each category was found to be EPA Tier 3 or Tier 4 certified. However, upon further investigation, the vendors noted that EPA Tier 3 and Tier 4 certified engines constitute a small percentage (i.e., approximately less tha n 20%) of the total inventory for each category.
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 b e 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 de emed 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 NO X 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.



### 5.1.5. NO X 

### BACT Analysis for Third Party Well Evaluation Engines (DR

- TP

- 12Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 95 Trinity Consultants



### through DR

- TP

- 16)

Step 1

– Identify all Control Technologies

EPA's RBLC search was used to obtain potential control t echnologies for NO X from smaller diesel eng in es (< 500 hp) 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 wa s conducted to obtain potential control technologies for NO X from smaller engines. 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 pot ential control technologies for NO X from smaller diesel engines are listed below.

DWI EGR Derate Engines H/E process (w ater

- in

- fuel Homogenization and Emulsification) Intake Air Humidification/Cooling NO X Adsorber/Scrubber Technology Replacement of Older Engines with Newer Engines CAM Shaft Replacement/ Re

- tooling of Engines LNC or HC

- SCR LNE design including Turbocharger, After coolers , and H igh Pressure Fuel I njection 4

- Way Catalyst Converter Good Combustion and Manufacturer Recommended Maintenance Practices ITR



### Step 2

– Eliminate Technically Infeasible Options

DWI

– Infeasible.

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

EGR

– Infeasible.

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

Derate Engines

– Infeasible

. An engine can be derated by restricting its operation to lower levels of power than normal for the given application resulting in the decrease in available power

. Since these engines are brought onboard to perform specific operations, these are selected based on the power requirements for a specific task. Hence, derating these engines could significantly impact the op erations . Hence, it is deemed as technologically infeasible.

H/E process

– Infeasible

. Diesel and water emulsions were offered as a means of lowering the NO X output from the engines. These emulsion systems have been shown to reduce NO X by 15

- 20% in engines running heavy fuel oilAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 96 Trinity Consultants (HFO). Running an engine on fuel

- water emulsions makes it theoretically possible to reduce NO X emissions by up to 50%. 14

This technology would require derating of the engines, and emulsified diesel in marine vessels can cau se fuel tank corrosion issues. Additionally, emulsified fuel systems were designed for and installed on slow

- speed engines burning heavy fuel oil.

These engines are designed and will be burning medium density fuel (diesel). Several significant enginee ring hurdles must be overcome in order to install a diesel/water emulsion system. Hence, this technology is considered as technologically infeasible.

Intake Air Humidification/Cooling

– Infeasible

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

NO X Adsorber/Scrubber Technology

– Infeasible

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

Replacement of Older Engines with Newer Engines

– Infeasible

. The five third party well evaluation diesel engines are pre

- 1998 engines and hence no engine certification is available. During one of the well evaluation activities these five diesel engines will be used to send information to a logging unit powered by third party engines. Since all of these engines are used to power different equipment that is performing a single operation they are all leased from the same third party vendor to avoid compatib ility issues. The third party vendor Anadarko proposes to leases these engines from has no EPA Tier certified well evaluation engines in their fleet. Therefore, this is not considered a viable BACT option.

LNC or HC

- SCR

– Infeasible

. This technology is not typically not suitable for smaller portable engines such as well evaluation engines. Also, LNC systems operate best at consistent high loads, and are not amenable to long periods of engine idle or load shifts.

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

4

- Way Catalyst Converter

– Infeasible

. This control technology is deemed techni cally 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.

14 Based on Non

- Road Diesel Emission Reduction Study”.www.ecy.wa.gov/programs/air/PDFS/NonroadDieselStudy.pdfAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 97 Trinity Consultants 

### Step 3

– Rank Remaining Control Technologies by Control Effe ctiveness

Table 5

- 4

. Ranks of Technologies Feasible for Diesel Fired Engines

Technology Efficiency Rank CAM Shaft Replacement/ Retooling of Engines various 1

Good Combustion and Manufacturer Recommended Maintenance Practices Baseline N/A

All feasible technologies for the diesel fired engines are listed in Table 5

- 4 . Control technologies are ranked by efficiency in a descending order.



### Step 4

– Evaluate Most Effective Controls and Document Results

Clean Cam Technology Systems (CCTS) offers retrofit cam shaft reengineering kits for some diesel engines. The kits reduce NO X emissions by increasing the volume of the residual exhaust gas that remains in the combustion chamber after the power stroke.

CCTS cam shaft retrofit (r etooling) kits are available for Detroit Diesel engines (model series 71 or 92.) The “well evaluation ” engines proposed in this application are Detroit Diesel engines (model series 71) and hence this technology considered feasible.
The proposed operating time for these engines is 125 hrs/year per engine. Given the engine’s minimal operating time, the resulting emissions are minimal. For example, NO X emissions per engine are approximately 0.3 tpy per engine. Therefore, Anadarko believes that detailed cost infeasibility is not warranted. Given the minimal operations of this equipment resulting in low emissions, Anadarko believes that CAM Shaft Replacement/ Retooling of the engines will be cost prohibitive.



### Step 5

- Select BACT Anadarko proposes good combustion practices and manufacturer recommended operating and maintenance practices as NO X BACT for th e third party well evaluation engines

.



### 5.1.6. NO X 

### BACT Analysis for Pumps on the Stimulation Vessel (SV

- PE

- 01 through

SV

- PE

- 08)

The proposed Stimulation Vessel will have eight 2,250 HP pumps

. The pumps described in this application are not certified for EPA Ti er rating due to their manufacturing/model year.



### Step 1

– Identify all Control Technologies

Similar to the drillship main propulsion engines, the pumps on the stimulation vessel also are large (>500 HP) diesel engines and the NO X control options are expected to be same as the main propulsion engine s . Therefore, the same options identified for the main propulsion engines are considered as the potential control technologies for the pumps on the stimulation vessel



### .Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 98 Trinity Consultants Step 2

– Eliminat e Technically Infeasible Options

SCR

– Infeasible.

This control option is not technically feasible for use on the pumps , which only operate for short periods during the specific well completion scenario. SCR systems require a longer period of operating time in order to reach a minimum temperature before the system can operate. Installation of each SCR will require significant structural changes to support the SCRs and urea storage tanks.

Hence, this control technology is deemed technically infeasible for the reasons discussed above and the reasons identified in Section 5.1.1. SNCR

– Infeasible

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

DWI

– Infeasible.

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

EGR

– Infeasible.

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

Derate Engines

– Infeasible

. Derating the eng ine will reduce the available power and may n ot meet the power requirements. S ince the pumps are expected to be operated at peak power, this control technology is deemed technologically infeasible.

Water

- in

- fuel Emulsions (emulsified diesel)

– Infeasible

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

Intake Air Humidification/Cooling

– Infeasible

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

NO X Adsorber/Scrubber Technology

– Infeasible

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

CAM Shaft Replacement/ Retooling of Engines

– Infeasible

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

LNC or HC

- SCR

– Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 99 Trinity Consultants This control technology is deemed technically infeasible for the same reasons identified in Section 5.1.1.

LNE Design with Turbocharger, After cooler and High Pressure Fuel Injection System

– Infeasible

. Incorporation of this control technology will involve redesigning the engines, making this technology to be most feasibly installed when the engine is manufactured. Requiring this technology would essentially mean having to replace the existing pumps with other pumps that have this technology already installed. This technology is intrinsic to the engine design and retrofitting the pumps is not an option. Therefore, this is not considered a v iable BACT option.

Replacement of Older Engines with Newer Engines

– Infeasible

. The certification to meet these standards is part of the inherent design of the engine and there is no upgrade available for an existing engine to meet EPA Tier 2 or higher standards. In order for these
pumps to meet EPA Tier 2 (Part 89) standards or higher, the engines would have to be replaced with

newer engines. Since these pumps are already installed on a Stimulation Vessel, replacing the existing pumps with the newer p umps will require significant engineering redesign and possible recertification of the Stimulation Vessel. Moreover, these pumps will operate for a limited time (i.e., approximately 201 hours per year.) Hence, replacement of these pumps with the newer pu mps is not considered a viable BACT option. Regardless, Anadarko performed a cost analysis to assess cost feasibility of this option.

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

Table 5

- 5 . Ranks of Technologies Feasible for Pumps on Stimulation Vessel

Technology Efficiency Rank Replacement of old engines with new engines varies 1

Good Combustion and Manufacturer Recommended Maintenance Practices Baseline N/A

All feasible technologies for the miscellaneous well completion engines are listed in Table 5

- 5 . Control technologies are ranked by efficiency in a descending order.



### Step 4

– Evaluate Most Effective Controls and Document ResultsAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 100 Trinity Consultants Replacement of old engines with new engines

– 40 CFR 89 Tier 2 compliant engine was identified as the cleanest available engine in the stimulation vessel pump engine category ( SV

- PE

- 01 through SV

- PE

08) Anadarko performed the cost effectiveness analysis for replacing the exis ting engines with the newer engines meeting the EPA 40 CFR 89 tier 2 standards. The cost effectiveness for the engine replacement was estimated to be $75,788 per ton of NO X reduced, making this option cost prohibitive. A detailed control cost effectiveness analysis is provided in Appendix E.

Step 5

- Select BACT

Anadarko proposes good combustion and manufacturer recommended operating and maintenance practices as BACT for t he pumps on the stimulation vessel.



### 5.1.7. NO X 

### BACT Analysis for Flowback Boiler (DR

- TP

- 22)

The proposed flowback boiler is a small 8 MMBtu/hr diesel fired combustion source. EPA's RBLC search was used to obtain potential control technologies for NO X from boiler s 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 NO X from boilers. The most recent 10

- year pe riod 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 are listed below.

Flue Gas Recirculation (FGR) Low NO X Burners Good Combustion an d Manufacturer Recommended Maintenance Practices



### Step 2

– Eliminate Technically Infeasible Option

FGR

– Infeasible

. The proposed flowback boiler does not have an FGR and retrofitting FGR on an existing unit will require significant design change. The FGR technology is best suited for new units as retrofitting FGR on the proposed boiler would require extensive modifications, such as installation of ductwork, recirculation fans, air foils for mixing re

- circulated flue gas and combustion air, and controls fo r variable load operation. Also, there is a possibility of flame instability observed at high FGR rates leading to safety concerns. Hence, this control technology is considered as technologically infeasible.

Low NO X Burners

– Infeasible

. This technology is considered technically infeasible because the proposed boiler was not constructed with low

- NO X burners. Low

- NO X burners produce longer flames, and therefore are potentially inappropriate for retrofit on smaller furnaces. Additionally, low

- NO X burners operate in a lower

temperature, fuel

- lean zone, which could result in increases of CO and VOC emissions from the boiler.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness Since good combustion 

### and manufacturer recommended operating and maintenance practices areAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 101 Trinity Consultants the only feasible option, no ranking is required.



### Step 4

– Evaluate Most Effective Controls and Document Results
The manufacturer recommended good combustion operating and maintenance req uirements are considered as the most effective controls

.


### Step 5

- Select BACT Anadarko proposes good combustion and manufacturer recommended operating and maintenance practices as the NO X BACT for the proposed flowback boiler.



### 5.1.8. NO X 

### BACT Analysis for Boom Fl are (DR

- TP

- 23)

Step 1

– Identify all Control Technologies EPA's RBLC search was used to obtain potential control technologies for NO X 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 NO X 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 NO X from flares are listed below.

Comply with 40 CFR 60.18 Good Com bustion and Manufacturer Recommended Maintenance Practices



### 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

Si nce 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 manufacturer recommended good combustion operating practices and maintenance requirements as the BACT for the boom flare.

A summary of the proposed NO X BACT emission limitation for each source associated with the projec t is provided below in Table 5

- 6

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 102 Trinity Consultants Table 5

- 6

. Proposed NO X BACT Emission Limits

Emission Unit BACT Emission Limit BACT Basis BACT Control Technologies

Drillship Main Engines (DR

- ME

- 01 thru DR

- ME

- 06) 9.7 g/kW

- hr IMO Performance Test Data EPA 40 CFR 1042 Tier 2

Standards, NSPS IIII, IMO Tier 2 standards, LNE Design, Performance Management System including Turbocharger with Aftercooler and H igh 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 2 Standard 40 CFR 89 EPA Tier 2 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 practicesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 103 Trinity Consultants 

### 5.2. CO AND VOC BACT A N ALYSIS

The BACT assessment for CO and VOC was performed for the same sources described in Section 5.1.



### 5.2.1. CO and VOC BACT Analysis for Drillship Main Propulsion Electrical Generator

Eng ines (DR

- ME

- 01 through DR

- ME

- 08)

The main propulsion engines are used to power the thrusters that hold the ship on location, as well as power the drilling equipment and other operational needs of the ship. The main propulsion engines operate at variable l oads based on drilling and operational power demand, and extensive “reserve” power is required to adjust for loop currents and subsea soil densities. Hence, CO emissions are not emitted from these engines at a steady state. These factors are important co nsiderations in the BACT analysis for these engines.



### Step 1

– Identify all Control Technologies The first step in the EPA top

- down, five

- step analysis is to identify all available control technologies that are potentially suitable for the affected sources. EPA's RBLC search was used to obtain potential control technologies for CO and VOC from main propulsion engines at offshore sources. The most recent 10

- year period was used to identify applicable control technologies. The results of the RBLC search are included in Appendix E . However, it should be noted that the control technologies evaluated in the “topdown” analysis for main diesel engines were not limited to the controls listed in the RBLC database. The permits recently proposed/issued by U.S. EPA Region 4 and Region 10 (and corresponding permit applications) for similar OCS sources in Gulf of Mexico have also been reviewed in addition to surveying available literature to identify potential control technologies . The search results for potential con trol technologies for CO and VOC from the main diesel engines are listed below.

DOC CDPF 4

- Way Catalyst Converter with Exhaust Gas Recirculation System Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042 ) LNE Design with Turbocharger with Aftercooler and High Fuel Pressure Injection Good combustion practices ITR Positive Crankcase Ventilation System (for VOCs only)



### Step 2

– Eliminate Technically Infeasible Option

DOC

– Infeasible

. DOCs contain precious metals impre gnated onto a high geometric surface area carrier and are placed in the exhaust stream of the engine to reduce emissions of PM, Total Hydrocarbons (THC), and CO. The DOC works by oxidizing CO, gaseous hydrocarbons and liquid hydrocarbon particles (unburne d fuel and oil) in the exhaust gas to CO 2 and H 2 O. The reduction of PM, THC, and CO varies depending on theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 104 Trinity Consultants catalyst formulations in the DOC. DOCs have been verified to reduce emissions of CO and THC by as much as 90 percent. 15

Due to the large load vari ations typical of these exploratory drilling operations, the main propulsion engines are not able to sustain constant steady state loads/exhaust temperatures for sufficient time periods that are necessary for high catalyst performance, resulting in limited control. Use of DOCs would also lead to some pressure drop across exhaust flow resulting in back pressure on the engine that could cause plugging of the engine, thus posing safety concerns for the types of offshore operations proposed. Several non

- combu stible 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 in the DOC. This technology has not been designed, engineered, or tested on a commercially availabl e scale for safe operation on the large scale engines found on the BlackHornet drillship.

CDPF

– Infeasible

. The catalyst in the CDPF filter could potentially reduce emissions of CO and THC by 90 percent but requires sufficient exhaust temperatures to fac ilitate regeneration by the catalyst. 16

CDPFs add back pressure on the engines that could cause plugging of the engine, thus posing safety concerns for the types of offshore operations proposed. The pressure drop will also cause a reduction in fuel economy. Due to load variations, the main die sel engines cannot typically sustain the high exhaust temperatures necessary for optimal regeneration of the catalyst. This technology has not been designed, engineered, or tested on a commercially available scale for safe operation on the large scale eng ines found on the BlackHornet drillship.

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

– Infeasible

. The main diesel engines meet the IMO Tier 2 standard for engines under Category 3 (i.e., >30 liter/cylinder displacement operating at 720 rpm ). IMO does not have an emission standard for CO. However, comparable EPA Standard (i.e., EPA Tier 2) does have emission standards for CO and VOC. Since certification is an engine manufacturer process, it is not possibl e for these engines to obtain an EPA Tier certificate at this point regardless whether these engines meet EPA Tier standards. Hence, these engines will need to be replaced with engines with EPA Tier 2 certification

. The replacement of engine will essenti ally require redesign and recertification process. Hence, this is not a viable BACT option.

4

- Way Catalyst Converter

– Infeasible

. The main propulsion electrical 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 m ay be present in engine lube oils, such as phosphorous, lead and heavy metals, may collect over time and damage the catalyst.

ITR

– Infeasible

.

15 Based on Sections 4.3, Alternative Control Techniques Document: Stationary Diesel Engines (Final Report) , Prepared For: Energy Strategies Group U.S. Environmental Protection Agency (EPA) Office of Air Quality Planning and Standards, March 5, 2010.
16 I bidAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 105 Trinity Consultants Changing ignition timing is not an alternative for these engines due to the intrinsic engine design. Altera tions of the injection timing can impact value performance. Additionally, use of this technology can reduce engine power and combustion stability that can hinder operations. For these reasons this technology is infeasible

.

Positive Crankcase Ventilatio n System (for VOCs only)

– Infeasible

. Installation of a Positive Crankcase Ventilation system involves changes to the design of the engines, making this technology to be most feasibly installed when the drillship is designed. This technology is intrinsi c to the engine design. Furthermore, engine manufacturers have strict restrictions on installing upgrades to avoid violating warranty. Retrofitting the engine with this system will require significant redesign of the drillship including a possibility of recertification. Requiring this technology would essentially mean having to replace the existing engines with other en gines that have this technology already installed.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

- 7 . Ranks of Technologies Feasible for Main Diesel Engines

Technology Efficiency Rank LNE Design with Turbocharger with Aftercooler and High Fuel Pressure Injection ~ 30% 2

Good Combustion Practices Baseline N/A

All feasible technologies for the main diesel engines are listed in Table 5

- 7 . Control technologies are ranked by ef

ficiency in a descending order.



### Step 4

– Evaluate Most Effective Controls and Document Results Since Anadarko is proposing to implement all feasible control technologies , a control cost analysis is not required.

Step 5

- Select BACT

Anadarko proposes LNE desi gn including Turbo charger with Aftercooler and High F uel Injection Pressure along with good combustion and manufacturer recommended operation and maintenance practices

.



### 5.2.2. CO and VOC BACT Analysis for Drillship Emergency Generator (DR

- GE

- 01)

Step 1

– Identify all Control Technologies

Similar to the above addressed main propulsion electrical ge nerator engines, the emergency generator is also a large (>500 HP) diesel engine, and the CO control options are expected to be same as the main diesel engine. Therefore, the same options identified for the main diesel engines are considered as the potent ial control technologies for the 

### emergency generator.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 106 Trinity Consultants 

### 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.

CDPF

– Infeasible

.

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

4

- Way Catalyst Converter

– Infeasible

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

ITR

– Infeasible

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

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

- 8 . Ranks of Technologies F easible for Emergency Engine

Technology Efficiency Rank Replacement of Engine to meet higher EPA Tier standards varies 1

LNE Design 30% N/A Good Combustion Practices Baseline N/A

All feasible technologies for the emergency generator are listed in Table 5

- 8 . Control technologies are ranked by ef

ficiency in a descending order.



### Step 4

– Evaluate Most Effective Controls and Document Results Engines complying with 40 CFR 89 Tier 2 standards are the cleanest available engines in this category of engines. There is no add on technology due to which IMO Tier 2 eng ines could be classified as EPA Tier 2 engines. The only possible option is to replace the existing engine with EPA Tier 2 certified engine and this option will require significant redesigning and possible recertification.

The emergency generator only o perates intermittently for short periods (2 hours per day and 100 hours per year) and it is primarily designed to handle during emergency situation. Given the small emissions and trivial emission reduction benefit, Anadarko believes a comprehensive cost a ssessment is not warranted.



### Step 5

- Select BACTAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 107 Trinity Consultants Anadarko proposes LNE design along with good combustion and manufacturer recommended maintenance practices as BACT for the drillship emergency generator

.



### 5.2.3. CO and VOC BACT Analysis for Air Compressor Engine (DR

- AC

- 01)
The air compressor engine is a HATZ 2M41 engine with 39 HP rating.



### Step 1

– Identify all Control Technologies EPA's RBLC search was used to obtain potenti al control technologies for CO and VOC f rom smaller emergency diesel engines (< 500 HP) 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 and VOC from smaller engines. 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 and VOC from smaller diesel engines are listed below.

DOC CDPF 4

- Way Catalyst Converter ITR Replacement of Engine to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042 ) LNE Design with Turbocharger and High Pressure Fuel Injection Good combustion practices (Manufacturer recommended operations and maintenance) Positive Crankcase Ventilation System (for VOCs only)



### 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.

CDPF

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

4

- Way Catalyst Converter

– Infeasible

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

ITR

– Infeasible

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

LNE Design with Turbocharger and High Pressure Fuel Injection

– Infeasible

. Incorporation of this control technology will involve rede signing the engines, making this technology to be most feasibly installed when the engine is installed . Requiring this technology would essentially mean having to replace the existing compressor engine with other air compressor diesel engines that have this technology already installed. This technology is intrinsic to the engine design and retrofitting the air compressor diesel engines is not an option.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 108 Trinity Consultants 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 F easible 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 ef ficiency 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 categor y of equipment. Anadarko previously obtained an initial cost estimate of $12,600 for replacing a similar engine with air compressor engines compliant with 40 CFR 89 Tier 3 standards. Given the minimal operations of this equipment resulting in low emissions, Anadarko believes that replacement of existing air compressor engine with the cleanest avail able engine is co st prohibitive and a detailed cost analysis is not warranted.

Step 5

- Select BACT Anadarko proposes 40 CFR 94 EPA Tier 2 standards and good combustion and manufacturer recommended maintenance practices as CO and VOC BACT for the emergency air compressor.



### 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 an d 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 optio ns identified for the drillship main diesel engines are considered as the potential control technologies for the third party engines on the drillship.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 109 Trinity Consultants 

### Step 2

– Eliminate Technically Infeasible Options

DOC

– Infeasible. This control technology is deemed te chnically infeasible for the same reasons identified in Section 5.2.1.

CDPF

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

4

- Way Catalyst Converter

– Infeasible

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

ITR

– Infeasible

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

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

– Infeasible

. The cleanest available engine was found to be EPA Tier III or Tier IV certified. However, upon further investigation, the vendors noted that EPA Tier III and Tier IV certified engines constit ute a small percentage (i.e., approximately less than 20%) of the total inventory.
Due to constantly changing schedules during the proposed operations, the availability of these third party engines changes on short notice. Hence, it is difficult to deter mine which specific engine would be brought onboard on any given day. Since availability of the EPA Tier III and Tier IV engines is limited, there is no guarantee that these engines will be available when Anadarko would need them. Restricting these third party engines to EPA Tier III or Tier IV certified engines will significantly impact the operations. Hence, this option is not a viable BACT option.

Positive Crankcase Ventilation System (for VOCs only)

– Infeasible

. This control technology is deemed technically infeasible since it is an intrinsic part of engine design and restricting the temporary third party engines to be equipped with this technology could have significant operational impact as described above.

Step 3

– Rank Remaining Control Techn ologies by Control Effectiveness

Table 5

- 10 . Ranks of Technologies Feasible for the Third Party Engines

Technology Efficiency Rank LNE design 30% 1 Good Combustion Practices Baseline N/A

All feasible technologies for the third party engines are listed in Table 5

- 1 0 . Control technologies are ranked by efficiency in a descending order.

Step 4

– Evaluate Most Effective Controls and Document Results

Anadarko proposes 40 CFR 89 EPA Tier 2 standards, the highest ranked among the feasible options, as BACT for CO control from the third party engines. Therefore control cost analysis is not required.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 110 Trinity Consultants Step 5

- Select BACT

Anadarko proposes 40 CFR 89 EPA Tier 2 standards and LNE Design along with good combustion practices as CO BACT for the third party engines. Anadarko proposes good combustion practices as VOC BACT. As indicated previously, the third party engines and the horsepower ratings shown in this application are for representation purposes on ly. However, a well completion engine brought onto the drillship will at least be certified to 40 CFR 89 EPA Tier 2 or higher standards, with equivalent or lower emissions than the engine represented.



### 5.2.5. CO and VOC BACT Analysis for Third Party Well Evaluati on Engines (DR

- TP

12 through DR

- TP

- 16)

Step 1

– Identify all Control Technologies The third party well evaluation engines on the drillship are four 140 HP diesel engines , and the CO 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 t hird 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.

CDPF

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

4

- Way Catalyst Converter

– Infeasible

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

ITR

– Infeasible

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

LNE Design

– Infeasible

. Incorporation of this control technology will involve redesigning the engines, making this technology to be most feasibly installed when the engine is manufactured. Requiring this technology would essentially mean having to replace the existing well evalu ation compressor diesel engines with other air compressor diesel engines that have this technology already installed. This technology is intrinsic to the engine design and retrofitting the air compressor diesel engines is not an option.

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

– Infeasible

. The five third party well evaluation diesel engines are pre

- 1998 engines and hence no engine certification is available. During one of the well evaluation activities these five diesel engines will be used to send information to a logging unit powered by third party engines. Since all of these engines are used to power different equipment that is performing a single operation they are all leased from the same third party ven dor to avoid compatibility issues. The third party vendor Anadarko leases theseAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 111 Trinity Consultants engines from currently has no EPA Tier certified well evaluation engines in their fleet. Therefore, this is not considered a viable BACT option.

Positive Crankcase Ventilat ion System (for VOCs only)

– Infeasible

. This control technology is deemed technically infeasible for the same reasons identified in Section 5.2.4.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Good combustion practices (manufac turer recommended operation and maintenance) are the only feasible option. Therefore, ranking is not required.

Step 4

– Evaluate Most Effective Controls and Document Results

Good combustion practices are the only feasible option. Therefore, ranking is not required.

Step 5

- Select BACT

Anadarko proposes good combustion and manufacturer recommended operation and maintenance practices as CO and VOC BACT for the third party well evaluation diesel engines.



### 5.2.6. CO and VOC BACT Analysis for Representative Stimulation Vessel Pumps (SV

PE

- 01 thru SV

- PE

- 08)
The proposed Stimulation Vessel will have eight 2,250 HP pump engines

.
Step 1

– Identify all Control Technologies

Similar to the main propulsion electrical generator engines, the pump engines on the stimulation vessel also are large (>500 HP) diesel engines and the CO and VOC control options are expected to be same as the main diesel engine. Therefore, the same options identified for the main diesel engines are consi dered as the potential control technologies for the pumps on the stimulation vessel.



### 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.

CDPF

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

4

- Way Catalyst Converter

– Infeasible

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

I TR

– 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 112 Trinity Consultants LNE Design

– Infeasible

. Incorporation of this control technology will involve redesigning the engines, making this technology to be most feasibly installed when the engine is manufactured. Requiring this technology would essentially mean having to replace the pumps with another engine that has this technology already installed. This technology is intrins ic to the engine design and retrofitting the pumps is not an option.

Positive Crankcase Ventilation System (for VOCs only)

– Infeasible

. This control technology is deemed technically infeasible for the same reasons identified in Sections 5.2.4 and 5.1.6.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

- 11

. Ranks of Technologies Feasible for Pumps on Stimulation Vessel

Technology Efficiency Rank Replacement of engines to meet higher EPA tier standards. varies 1

Good Combustion Practices N/A N/A

All feasible technologies for the miscellaneous well completion engines are listed in Table 5

- 1 1 . Control technologies are ranked by efficiency in a descending order.



### Step 4

– E valuate Most Effective Controls and Document Results Replacement of engines to meet higher EPA tier standards

– 40 CFR 89 Tier 2 compliant engine was identified as the cleanest available engine in the stimulation vessel pump engine category ( SV

- PE

- 01 through SV

- PE

- 08)

. Anadarko previously performed the cost effectiveness analysis for replacing the existing engines with the newer engines meeting the EPA 40 CFR 89 tier 2 standards. However, 40 CFR 89 Tier 2 emission factor results in higher emissions than the existing engine, for which emissions were calculated using AP

- 42 factor. Therefore, it is not possible to perform a representati ve cost effectiveness analysis.

Step 5

- Select BACT Anadarko prop oses good combustion practices and manufacturer recommended operation and maintenance practices as BACT for the pumps on the stimulation vessel.



### 5.2.7. CO and VOC BACT Analysis for Flowback Boiler (DR

- TP

- 22)

The proposed flowback boiler is a small 8 MMBtu/hr dies el fired combustion source. An RBLC search for potential control options for CO from a small boiler (<10 MMBtu/hr) did not produce any results. Also, a review of the permits recently proposed/issued by U.S. EPA Region 4 and Region 10 for similar OCS sour ces did not result in any potential control technologies. Therefore, Anadarko proposes good combustion practices (manufacturer recommended operation and maintenance) as BACT for the flowback boiler.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 113 Trinity Consultants 

### 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 s imilar 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 resu lts 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

- 1 2

.

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

- 08) 2.49 g/kW

- hr

– CO 0.43 g/kW

- hr

- VOC AP

- 42, Chapter 3, Table 3.4

- 1 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 P ractices Emergency Air Compressor Engine (DR

- AC

- 01) -- 40 CFR 89 EPA Tier 2 Standard EPA Tier 2 StandardAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 114 Trinity Consultants Emission Unit BACT Emission Limit BACT Basis BACT Control Technologies 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 Vess el 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 Practi cesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 115 Trinity Consultants 

### 5.3. PM/PM 10 

### /PM 2.5 

### BACT ANALYSIS

The emission sources of PM/PM 10 /PM 2.5 on the drillship that are used for the proposed drilling operation are as listed below:

Eight main propulsion electrical generator engines ( DR

- ME

- 01 to DR

- ME

- 08 ) Emergency generator (DR

- GE

- 01) Emergency A ir compressor (DR

- AC

- 01) Third party engines: 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 well evaluation engines ≤140 HP (DR

- TP

- 12

- DR

- TP

- 16 and SB

- TP

- 05 to SB

- TP

- 09) Third party engines ≤126 HP (DR

- TP

- 16 to DR

- TP

- 21) One flow back boiler (DR

- TP

- 22 ) One boom flare (DR

- TP

- 23 ) Painting Operation (DR

- PO

- 01) Welding Operation (DR

- WO

- 01) Stimulation Vessel

– 8 pumps (SV

- PE

- 01 thru SV

- PE

- 08)



### 5.3.1. PM/PM 10 

### /PM 2.5 

### BAC T Analysis for the Drillship Main Propulsion Electrical

Generator Engines (DR

- ME

- 01 to DR

- ME

- 08)
The main propulsion electrical generator engines are used to power the thrusters that hold the ship on location, as well as power the drilling equipment and ot her operational needs of the ship. The main propulsion engines operate at variable loads based on drilling and operational power demand, and extensive “reserve” power is required to adjust for loop currents and subsea soil densities. Hence, PM/PM 10 /PM 2.5 emissions are not emitted from these engines at a steady state. These factors are important considerations in the BACT analysis for these engines.



### Step 1

– Identify all Control Technologies The first step in the EPA top

- down, five

- step analysis is to identify all available control technologies that are potentially suitable for the affected sources. EPA's RBLC search was used to obtain potential control technologies for PM/PM 10 /PM 2.5 from main diesel engines at offshore sources. The most recent 10

- yea r period was used to identify applicable control technologies. The results of the RBLC search are included in Appendix E. However, it should be noted that the control technologies evaluated in the “top

- down” analysis for main propulsion engines were not limited to the controls listed in the RBLC database. The permits recently proposed/issued by U.S. EPA Region 4 and Region 10 (and corresponding permit applications) for similar OCS sources in Gulf of Mexico have also been reviewed in addition to surveying available literature to identify potential control technologies . The search results for potential control technologies for PM/PM 10 /PM 2.5 from the main diesel engines are listed below.

Baghouse Use of Ultra Low Sulfur Diesel (ULSD) Fuel/ Low Ash Fuel DOC CDPFAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 116 Trinity Consultants Positive Crankcase Ventilation (PCV) 4

- Way Catalyst Converter Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042) Good combustion (Manufacturer recommended operation and maintenance ) practices LNE design including Turbo char ger with Aftercooler and High Fuel Injection Pressure Fuel Injection Timing Retard



### Step 2

– Eliminate Technically Infeasible Option Baghouse

– Infeasible

. Baghouses are considered to be technically infeasible for all engines, as use of a baghouse would lead to a high pressure drop across exhaust flow resulting in excessive back pressure on the engine that could cause plugging of the engine, thus posing safety concerns for the types of offshore operations proposed. The pressure drop will also caus e a reduction in fuel economy. To avoid an unacceptable pressure drop across the baghouse, the use of a large fabric area would be required which in turn would require a significant amount of space on a vessel. 17 Required space would include the size of t he baghouse itself as well as the removal system for the collected material. Installation of a baghouse would require significant space reassignment on a drillship , which is unavailable, and therefore may require recertification of the vessel itself.

DOC

– Infeasible

. Due to the large load variations typical of these exploratory drilling operations, the main propulsion engines are not able to sustain constant steady state loads/exhaust temperatures for sufficient time periods that are necessary for high catalyst performance, resulting in limited control. Use of DOCs would also lead to some pressure drop across exhaust flow resulting in back pressure on the engine that could cause plugging of the engine, thus posing safety concerns for the types of offshore operations proposed. Several non

- combustible chemical elements that may be present in engine lube oils, such as ph osphorous, lead and heavy metals, may collect over time and damage the catalyst in the DOC. This technology has not been designed, engineered, or tested on a commercially available scale for safe operation on the large scale engines found on the BlackHorn et drillship.

CDPF

– Infeasible

. The catalyst in the CDPF filter reduces emissions of PM/PM 10 /PM 2.5 and THC by 90 percent but requires sufficient exhaust temperatures to facilitate regeneration by the catalyst. 18

CDPFs add back pressure on the engines that could cause plugging of the engine, thus posing safety concerns for the types of offshore operations proposed. The pressure drop will also cause a reduction in fuel economy. Due to load variations, the main pro pulsion engines onboard the BlackHornet drillship cannot typically sustain the high exhaust temperatures necessary for optimal regeneration of the catalyst. This technology has not been designed, engineered or tested on a commercially available scale for safe operation on the large scale engines found on the BlackHornet drillship.

17 Based on Air Pollution Control Technology Fact Sheet for Fabric Filter, U.S. EPA, EPA

- 452/F

- 03

- 025.
18 Based on Alternative Control Techniques Document: Stationary Diesel Engines (Final Report), Prepared For: Energy Strategies Group U.S. Environmental Protection Agency (EPA) Office of Air Quality P lanning and Standards, March, 2010.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 117 Trinity Consultants Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042)

– Not Applicable

.

The main propulsion electrical generator engines will comply with PM st andards specified in NSPS IIII, which is the most stringent PM emission standard for this category of engines. Hence, there is no requirement to identify a different engine.

4

- Way Catalyst Converter

– Infeasible

.

The main propulsion 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 m ay be present in engine lube oils, such as phosphorous, lead and heavy metals, may collect over time and damage the catalyst.

Fuel Injection T iming R etard

– Infeasible

. Changing ignition timing is not an alternative for these engines due to the intrin sic engine design. Alterations of the injection timing can impact value performance. Additionally, use of this technology can reduce engine power and combustion stability that can hinder operations. For these reasons this technology is infeasible

.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

- 13 . Ranks of Technologies Feasible for Main Diesel Engines

Technology Efficiency Rank LNE design including Turbo char ger with Aftercooler and High Fuel Injection Pressure 30% 1

Use of ULSD varies 2 Good Combustion Practices Baseline N/A

All feasible technologies for the main propulsion engines are listed in Table 5

- 13 above . Control technologies are ranked by efficiency in a descending order.

Step 4

– Evaluate Most Effective Controls and Document Results

Since Anadarko is proposing to implement a ll feasible technologies , no cost feasibility is required.

Step 5

- Select BACT

Anadarko proposes compliance with NSPS IIII, LNE design including Turbocharger with Aftercooler and High Fuel Injection Pressure, and ULSD usage along with good combustion and manufacturer recommended operation and maintenance practices as PM/PM 10 /PM 2.5 BACT for all main propulsion electrical generator engines.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 118 Trinity Consultants 

### 5.3.2. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Drillship Emergency Generator (DR

- GE

- 01)
Step 1

– Identify all Control Technologies

Similar to the main propulsion engines, the emergency generator is also a large (>500 HP) diesel engine, and the PM/PM 10 /PM 2.5 control options are expec ted to be same as the main propulsion engines. Therefore, the same options identified for the main diesel engines are considered as the potential control technologies for the emergency generator



### 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 i dentified 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.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

- 14 . Ranks of Technologies Feasible for the Emergency Diesel Engine

Technology Efficiency Rank Replacement of Engines to meet higher EPA Tier standards Varies 1

LNE design including Turbo char ger and High Fuel Injection Pressure N/A 2

ULSD N/A 3 Good Combustion Practices Baseline N/A

All feasible technologies for the emergency generator engine are listed in Table 5

- 1 4 . 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 2 standards are the cleanest available engines in this category of engines. There is no add on technology due to which IMO Tier 2 engines could be classified as EPA Tier 2 engines. The only possible option is to replace the existing engine with EPA Tier 2 certified engine and this option will require significant redesigning and possible recertification.

The emergency generator only operates intermittently for short periods (2 hours per day and 100 hours per year) and it is primarily designed to handle during emergency situation. Given the small emissions and trivial emission r eduction benefit, Anadarko believes a comprehensive cost assessment is not warranted.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 119 Trinity Consultants Step 5

- Select BACT Anadarko proposes LNE design and ULSD usage along with good combustion and manufacturer recommended maintenance practices as PM/PM 10 /PM 2.5 BACT for the drillship emergency generator

.



### 5.3.3. PM/PM 10 

### /PM 2.5 

### BACT Analysis for the Air Compressor Engine (DR

- AC

- 01)
The air compressor diesel engine is a HATZ 2M41, 38.5 HP engine.



### Step 1

– Identify all Control Technologies

EPA's RBLC search was used to obtain potential control technologies for PM/PM 10 /PM 2.5 from smaller emergency diesel engines (< 500 HP) 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 cond ucted to obtain potential control technologies for PM/PM 10 /PM 2.5 from smaller engines. 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 PM/PM 10 /PM 2.5 from smaller diesel engines are listed below.

DOC CDPF 4

- Way Catalyst Converter Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042) LNE design including Turbocharger and High Pressure Fuel Injection USLD Fuel Good combustion practices (manufacturer recommended operation and maintenance)



### Step 2

– Eliminate Technically Infeasible Options

DOC

– Infeasible. This control technology is deemed techni cally 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.

LNE Design

– Infeasible

. Incorporation of this control technology will involve redesigning the engines, making this technology to be most feasibly installed wh en the engine is manufactured. Requiring this technology would essentially mean having to replace the existing air compressor diesel engines with other air compressor diesel engines that have this technology already installed. This technology is intrinsi c to the engine design and retrofitting the air compressor diesel engines is not an option.

Step 3

– Rank Remaining Control Technologies by Control EffectivenessAnadarko 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 previously obtained an initial cost estim ate of $12,600 for replacing a similar air compressor with an air compressor engines comp liant with 40 CFR 89 Tier 3 standards. An email communication with the vendor is provided in the Appendix B of this submittal. Given the minimal operations of this equipment resulting in low emissions, Anadarko believes that replacement of existing emerg ency engine with the cleanest available engine is cost prohibitive.

Step 5

- Select BACT

Anadarko proposes compliance with EPA Tier 2 standards, use of ULSD fuel along with good combustion and manufacturer recommended operation and maintenance practices as PM/PM 10 /PM 2.5 BACT.



### 5.3.4. PM/PM 10 

### /PM 2.5 

### 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/PM 10 /PM 2.5 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 opti ons 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.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 121 Trinity Consultants Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042 )

– Infeasible

. The cleanest available engine was found to be EPA Tier III or Tier IV certified. However, upon further investigation, the vendors noted that EPA Tier III and Tier IV certified engines constitute a small percentage (i.e., approximately less than 20%) of th e total inventory.
Due to constantly changing schedules during the proposed operations, the availability of these third party engines changes on short notice. Hence, it is difficult to determine which specific engine would be brought onboard on any given day. Since availability of the EPA Tier III and Tier IV engines is limited, there is no guarantee that these engines will be available when Anadarko would need them. Restricting these third party engines to EPA Tier III or Tier IV certified engines will significantly impact the operations. Hence, this option is not a viable BACT option

. Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

- 16 . Ranks of Technologies Feasible for the Third Party Engines

Technology Efficiency Rank LNE design 30% 1 Good Combustion Practices (Manufacturer Recommended operation and maintenance procedures). Baseline N/A

All feasible technologies for the third party engines are listed in Table 5

- 1 6 . Control technologies are ranked by efficiency in a descending order.

Step 4

– Evaluate Most Effective Controls and Document Results

Anadarko proposes compliance with 40 CFR 89 E PA Tier 2 standards, the highest ranked among the feasible options, as BACT for the third party diesel engines. Therefore control cost analysis is not required.

Step 5

- Select BACT

Anadarko proposes 40 CFR 89 EPA Tier 2 standards and LNE design along with good combustion and manufacturer recommended operation and maintenance practices as PM/PM 10 /PM 2.5 BACT for the third party engines. As indicated previously, the third party engines and the horsepower ratings shown in this application are for re presentation purposes only. However, a well completion engine brought onto the drillship will at least be certified to 40 CFR 89 EPA Tier 2 or higher standards, with equivalent or lower emissions than the engine represented.



### 5.3.5. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Third Party Well Evaluation Engines (DR

- TP

12 through DR

- TP

- 16)Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 122 Trinity Consultants 

### Step 1

– Identify all Control Technologies

The third party well evaluation engines on the drillship are four 140 HP diesel engines, and the PM/PM 10 /PM 2.5 control options identified fo r the drillship main propulsion 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

– In feasible.

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

– Infeasible

. The five third party well evaluation diesel engines are pre

- 1998 engines and hence no engine certification is available. During one of the well evaluation activities t hese five diesel engines will be used to send information to a logging unit powered by third party engines. Since all of these engines are used to power different equipment that is performing a single operation they are all leased from the same third part y vendor to avoid compatibility issues. The third party vendor Anadarko leases these engines from currently has no EPA Tier certified well evaluation engines in the fleet. Therefore, this is not considered a viable BACT option.

LNE Design

– Infeasible

. Incorporation of this control technology will involve redesigning the engines, making this technology to be most feasibly installed when the engine is manufactured. Requiring this technology would essentially mean having to replace the existing well ev aluation compressor diesel engines with other air compressor diesel engines that have this technology already installed. This technology is intrinsic to the engine design and retrofitting the air compressor diesel engines is not an option.



### Step 3

– Rank R emaining Control Technologies by Control Effectiveness ULSD fuel usage is the only feasible option followed by good combustion practices (manufacturer recommended operation and maintenance practices) . Therefore, ranking is not required

.



### Step 4

– Evaluate Most Effective Controls and Document Results ULSD fuel usage is the only feasible option. Therefore, ranking is not required

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 123 Trinity Consultants 

### Step 5

- Select BACT Anadarko proposes ULSD fuel usage along with good combustion and manufacturer recommended operation and main tenance practices as PM/PM 10 /PM 2.5 BACT for the third party well evaluation engines

.



### 5.3.6. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Representative Pump Engines on the

Stimulation Vessel (SV

- PE

- 01 thru SV

- PE

- 08)
The proposed Stimulation Vessel will have eight 2,250 HP pump engines.

Step 1

– Identify all Control Technologies

Similar to the main propulsion electrical generator engines, the pump engines on the stimulation vessel also are large (>500 HP) diesel engines and the PM/PM 10 

### /PM 2.5 

### control options are expected to be same as the main diesel engine. Therefore, the same options identified for the main diesel engines are considered as the potential co ntrol technologies for the pump engines on the stimulation vessel.

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 reason s identified in Section 5.3.1.

PCV

– 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.

LNE Design

– Infeasible

. Incorporation of this control technology will involve redesigning the pumps making this technology to be most feasibly installed when the engine is manufactured. Requiring this technology would essentially mean having to replace the existing pumps with another engine that has this technology already installed. This technology is intrinsic to the engine design and retrofitting the pumps is not an option.

Step 3

– Rank Remaining Control Technologies by Control EffectivenessAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 124 Trinity Consultants

Table 5

- 17 . Ranks of Technologies Feasible for the Pumps on Stimulation Vessel
Technology Efficiency Rank Replacement of Engines to meet higher EPA Tier standards varies 1

ULSD Fuel N/A 2 Good Combustion Practices (Manufacturer recommended operation and maintenance practices) N/A N/A

All feasible technologies for the representative pump engines are listed in Table 5

- 1 7 . Control technologies are ranked by efficiency in a descending order.

Step 4

– Evaluate Most Effective Controls and Document Results

Replacement of Engines to meet higher EPA Tier standards

– 40 CFR 89 Tier 2 compliant engine was identified as the cleanest available engine in the stimulation vessel pump engine category ( SV

- PE

- 01 through SV

- PE

- 08)

. Anadarko previously performed the cost effectiveness analysis for replacing the existing engines with the newer engines meeting the EPA 40 CFR 89 tier 2 standards. As shown in Section 5.1.6, this option was concluded as cost prohibitive.

Step 5

- Select BACT

Anadarko pro poses use of ULSD along with good combustion and manufacturer recommended operation and maintenance practices as BACT for the pump engines on the stimulation vessel.



### 5.3.7. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Flowback Boiler (DR

- TP

- 22)

Step 1

– Identify all Control T echnologies

The proposed flowback boiler is a small 8 MMBtu/hr diesel fired combustion source. EPA's RBLC search was used to obtain potential control technologies for PM/PM 10 /PM 2.5 from boilers and review of the permits recently proposed/issued by U.S. E PA Region 4 and Region 10 (and corresponding permit applications) for similar OCS sources was conducted to obtain potential control technologies for PM/PM 10 /PM 2.5 from boilers. The most recent 10

- year period was used to identify applicable control technol ogies. The results of the RBLC search are included in Appendix E. The search results for potential control technologies for PM/PM 10 /PM 2.5 from the main diesel engines are listed below.



### Low Sulfur Fuel (ULSD) Good Combustion Practices (Manufacturer Recommended Operation and Maintenance Practices).



### Step 2

– Eliminate Technically Infeasible Option

ULSD

– Feasible

.

Good Combustion Practices

– Feasible

.
Step 3

– Rank Remaining Control Technologies by Control EffectivenessAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 125 Trinity Consultants 

### 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 ULSD fuel usage and good combustion and manufacturer recommended operation and maintenance practices as the BACT for the boiler.



### 5.3.8. PM/PM 10 

### /PM 2.5 

### 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 PM/PM 10 

### /PM 2.5 

### 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 PM/PM 10 

### /PM 2.5 

### 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 PM/PM 10 

### /PM 2.5 

### from flares are listed below.

Comply with 40 CFR 60.18 Good Combustion Practices (Manufacturer Recommended Operation and Maintenance Practices).



### Step 2

– Eliminate Technically Infeasible Option

Comply wit h 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 and

m anufacturer recommended operation and maintenance practices as the BACT for the boom flare.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 126 Trinity Consultants 

### 5.3.9. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Cement and Mud Mixing Operations (DR

- DC

01 thru DR

- DC

- 03)
Step 1

– Identify all Control Technologies

A RBLC search for potential control options for PM/PM 10 /PM 2.5 from cement and mud mixing operations did not produce any results. Also, a review of the permits recently proposed/issued by U.S. EPA Region 4 and Region 10 for similar OCS sources was performed. The search results for p otential control technologies for PM/PM 10 /PM 2.5 from flares are listed below.

Dust Collectors



### Step 2

– Eliminate Technically Infeasible Option

Dust Collectors

– Feasible



### .
Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since dust collectors is the only control option identified, no ranking is required

Step 4

– Evaluate Most Effective Controls and Document Results

Since dust collectors are the only control option identified , a cost analysis is not required.

Step 5

- Select BACT

Anadarko proposes dust collectors with proper maintenance and operations as PM/PM 10 /PM 2.5 BACT for the cement and mud mixing operations.



### 5.3.10. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Painting Operations (DR

- PO

- 01)

An RBLC search for potential control options for VO C from painting operations on a drillship did not produce any results. Also, a review of the permits recently proposed/issued by U.S. EPA Region 4 and Region 10 for similar OCS sources did not result in any potential control technologies . Therefore, Anada rko evaluated various transfer efficiencies related to painting operations.

In marine environments , the paint could be applied with air assisted paint gun, airless paint gun, and by use of roller or brush. The transfer efficiency of each paint applicatio n method is provided in the Table below.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 127 Trinity Consultants Table 5

- 18

. Paint Application and Transfer Efficiencies

Paint Application Method Transfer Efficiency Information Source Air assisted spray gun 30% Coating Operations Instructions for Emission Calculation Spreadsheet

- Minnesota Pollution Control Agency Airless spray gun 50%

- 80% Phone and email communications with the equipment vendor Roller

- N/A

The paint application method is generally dicta ted by the characteristics of work areas. An airless spray gun would be used to paint large deck areas or bulkheads since greater volume of paint and fine control is not required. An air assisted spray gun would be required to paint piping, brackets, and other multi

angle items due to paint volume and precision requirements

. A n airless gun requires a great deal of pressure to atomize the material for spray. Due to this pressure, a volume of material that comes out of the gun is increased making this met hod as a preferred painting method o n flat surfaces or tank applications . However, while utilizing this method for painting multi

- angle items
, a lot of the paint material is lost creating overspray and waste. A conventional air assisted gun provides a so lution to this overspray issue due to its operational mechanism. Therefore, use of air assisted spray gun is preferred for painting small or multi

- angle items

. Anadarko also considered the possibility of using roller or brush application for the proposed operations. However, Anadarko found this painting technique unsuitable due to following reasons:

 Marine coatings are designed to perform at certain thicknesses. The proper film thickness for these materials to perform as designated by the product data sheet is approximately 5 mils thick. The only way to achieve these film thicknesses in a single application is to spray the coating. A single application with a roller will generate approximately 1.5 mils in thickness per application. A surface would have to be painted 3 to 4 times per coat to achieve the manufactures’ requirements for coating performance.

 To achieve good film continuity most of the marine coatings are designed to be sprayed. The atomization of the coating promotes a go od flow of the material and creates a tight surface that has low moisture permeation which is essential for creating a barrier system and makes them work.

 Throughout the drilling and well completion operations, painting crew will be dealing with several ar eas where a brush or roller could not reach and hence, the material must be sprayed.

Hence, Anadarko is proposing a combination of air assisted and airless gun for the proposed painting operations. Anadarko proposes best management practices as BACT for t he painting operations. The best management practices will include down spraying of paint and use of a containment system such as a shroud or a barrier around the section of the ship being painted to prevent the airborne paint from drifting into the atmos phere.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 128 Trinity Consultants 

### 5.3.11. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Welding Operations (DR

- WO

- 01)

Step 1

– Identify all Control Technologies A RBLC search for potential control options for PM/PM 10 /PM 2.5 from welding operations did not produce many results. Also, a review of the perm its recently proposed/issued by U.S. EPA Region 4 and Region 10 for similar OCS sources was performed. The results of the RBLC search are included in Appendix E. However , it should be noted that the control technologies evaluated in the “top

- down” analys is for these operations were not limited to the controls listed in the RBLC database. The search results for potential control technologies for PM/PM 10 /PM 2.5 from flares are listed below.

Emission Limit/Welding Rod Usage Limit Best Management Practices R outing to Control Device Body Shop



### Step 2

– Eliminate Technically Infeasible Option

Routing to Control Device

– Infeasible The welding process results in negligible fugitive emissions, which cannot feasibly be captured and routed to a control device with any significant control efficiency.

Body Shop

– Infeasible Due to available space constraints on the drillship , performin g the welding operations in a separate body shop with options to route emissions via control device is technically infeasible.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

- 19

. Ranks of Technologies Feasible for the Welding Operations
Technology Efficiency Rank Emission Limit/Welding Rods Usage Limit N/A N/A Best Management Practices N/A N/A

All feasible technologies for the welding operations are listed in Table 5

- 19

. Anadarko is proposing all the feasible options as BACT. Therefore, ranking is not required.



### Step 4

– Evaluate Most Effective Controls and Document Results Since all the identified technologies are being proposed as BACT , a cost analysis is not required.



### S tep 5

- Select BACT

Anadarko proposes emission limitation/welding rods usage limit and best management practices as PM/PM 10 /PM 2.5 BACT for the welding operations.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 129 Trinity Consultants A summary of the proposed PM/PM 10 /PM 2.5 BACT emission limitation for each source associated with the project is provided below in Table 5

- 2 0

.

Table 5

- 20 . Proposed PM/PM 10 /PM 2.5 BACT Emission Limits

Emission Unit BACT Emission Limit BACT Basis BACT Control Technologies Drillship Main Diesel Engines (DR

- ME

- 01 thru DR

- ME

- 06) PM/PM 10 /PM 2.5 – 2.47E

- 04 lb/Hp

- hr (0.15 g/KW

- hr) NSPS IIII Standards NSPS IIII standards,

LNE design including Turbocharger with Aftercooler and High Fuel Pressure Injection , U LSD 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 2 Standard ULSD, EPA Tier 2

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

PracticesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 1 30 Trinity Consultants



### 5.4. VOC BACT ANALYSIS FOR STORAGE TANKS AN D PAINTS

The storage tanks subject to VOC BACT are listed below:



### 5.4.1. VOC BACT Analysis for Storage Tanks (DR

- DT

- 01 thru DR

- DT

- 09 and DR

- FT

01 thru DR

- FT

- 03)

Step 1

– Identify all Control Technologies EPA's RBLC search was used to obtain potential control technologies for VOC from storage tanks 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 conduct ed to obtain potential control technologies for VOC from storage tanks. 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 cont rol technologies for VOC from flares are listed below.

Vapor Recovery Unit (VRU) Thermal Oxidation (TO) Adsorption System Internal or External Floating Roof Tank (IFR/EFR) Submersible Fill Pipe (SFP)

Step 2

– Eliminate Technically Infeasible Option

VRU

– Infeasible

.
A VRU and associated vapor collection system would require a significant amount of space on the drillship . This installation would require significant space reassignment and significant alterations to the drillship that would result in modif ications to the drillship design and recertification of the drillship

.

TO

- Infeasible.

A thermal oxidation system and associated vapor collection system would require a significant amount of space on the drillship . This installation would require signi ficant space reassignment and significant alterations to the drillship that would result in modifications to the drillship design and recertification of the drillship . Furthermore, the auxiliary fuel combustion that would be necessary for an incinerator w ill generate emissions of other pollutants such as NO X and CO that may exceed the small benefit in VOC emission reductions because of the small amount of VOC emissions from the tanks.

Adsorption System

- Infeasible.

Adsorption systems are not as efficient when controlling low concentrations of VOC that are generated from diesel or base oil storage tanks as opposed to the higher VOC concentrations that would be generated from storage of higher vapor pressure materials such as gasoline. Additionally, an adsorptionAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 131 Trinity Consultants system will require a significant amount of space on the drillship . This installation would require significant space reassignment and significant alterations to the drillship that would result in modificatio ns to the drillship design and recertification of the drillship

.
IFR/EFR

- Infeasible.

Internal and external floating roof tanks are typically utilized to control VOC emissions from stored liquids with high vapor pressures. As diesel fuel and base oil a re low vapor pressure liquids, emissions of VOC from the storage tanks are expected to be minimal and the associated VOC emissions decrease associated with installation of a floating roof would be minimal. Additionally, the tanks on the BlackHornet are we ll integrated into the design of the drillship . Retrofitting such storage tanks with a floating roof would require significant space reassignment and significant alterations to the drillship in order to create enough space to complete the installation. T hese alterations would result in modifications to the drillship design and potentially require recertification of the drillship

.

SFP

- Infeasible.

While the accommodation of SFP is not difficult in the design stage of a new tank, equipping an existing tank on a marine vessel is expected to be a difficult hurdle. Installation will require significant space for handling of the equipment and safe acces s for the personnel. Moreover, storage tanks result in a very small amount of VOC emissions. Therefore, installing SFPs will only result in a very small reduction in the VOC emissions, would be cost prohibitive.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness There are not technologies that were identified as feasible.

Step 4

– Evaluate Most Effective Controls and Document Results There are not technologies that were identified as feasible.

Step 5

- Select BACT Anadarko pro poses good maintenance practices as BACT for the storage tanks.



### 5.4.2. VOC BACT Analysis for Mud Degassing Operations (DR

- VG

- 01)

A n RBLC search for potential control options for VOC from mud degassing operations did not produce any results. Also, a review of the permits recently proposed/issued by U.S. EPA Region 4 and Region 10 for similar OCS sources did not result in any potential control technologies. Therefore, Anadarko proposes VOC BACT limit of 5.36 tpy on a 12

- month rolling total basis.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 132 Trinity Consultants 

### 5.4.3. VOC BACT Analysi s for Painting Operations (DR

- PO

- 01)

An RBLC search for potential control options for VO C from painting operations on a drillship did not produce any results. Also, a review of the permits recently proposed/issued by U.S. EPA Region 4 and Region 10 for similar OCS sources did not result in any potential control technologies

. Therefore, Anadarko proposes best management practices as BACT for the painting operations. The best management practices will include down spraying of paint and use of a containment system such as a shroud or a barrier around the section of the ship being painted to prevent the airborne paint from drifting into the atmosphere.

Furthermore, the proposed coatings were selected based on following criteria: regulatory requirements, long term performance, waste reduction, and efficiency of application. All of the proposed paint materials are compliant with EPA the marine coatings requirements as specified in EPA 453/R

- 94

- 032

. 19 The VOC contents of a coating great ly influence the prospective application area (e.g., flat or metallic) as well as method of application (e.g., spray or roller)

. A summary of the proposed VOC BACT emission limitation for each source associated with the project is provided below in Table 5

- 2 1

.

Table 5

- 21 . Proposed VOC BACT Emission Limits

Emission Unit BACT Basis BACT Control Technologies Storage Tanks TANKS 4.09.d Best Management Practices Mud Degassing Operations (DR

- VG

- 01) Minerals Management Service Guidance Best Management

Practices

Painting Operations (DR

- PO

- 01) Paint + Thinner Composition Best Management

Practices



### 5.5. GREENHOUSE GAS (GHG) BACT ANALYSIS

On May 1 3, 2010, the U.S. EPA issued the final “Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule” specifying that as of January 2, 2011, all new industrial sources that are major sources for any NSR regulated pollutants other than GHGs, and will emi t or have the potential to emit 75,000 tons per year or more of total GHGs, on a CO 2 equivalent (CO 2 e) basis will need to determine the Best Available Control Technology for their GHG emissions. 20

19 Alternate Control Techniques: Surface Coating Operations at Shipbuilding and Ship Repair Facilities, April 1994 . Available online at: http://www.epa.gov/glo/SIPToolkit/ctg_act/199404_voc_epa453_r

- 94

- 032_coating_shipbuilding_repair.pdf

20 CO 2 equivalent encompasses a list of s ix Greenhouse Gases, including carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 133 Trinity Consultants 

### 5.5.1. GHG BACT Analysis for the Diesel Fired Internal Combustion E ngines
The majority of Greenhouse Gas emissions from diesel engines are in the form of carbon dioxide (CO 2 ). CO 2 is formed during complete combustion of diesel in the combustion chamber when carbon in the fuel is converted to CO 2 .


### Step 1

– Identify all Control Technologies

The first step in the EPA top

- down, five

- step analysis is to identify all available control technologies that are potentially suitable for the affected sources. The results of the RBLC search did not identify GHG control technologies since GHG emission control is still an emergency area of technology. However, it should be noted the control technology analysis for all internal combustion engines were not limited to the controls listed in the R BLC database. The permits recently proposed/issued by U.S. EPA Region 4 and Region 10 (and corresponding permit applications) for similar OCS sources in Gulf of Mexico have also been reviewed in addition to surveying available literature to identify poten tial control technologies

. T he following technologies were identified as potentially applicable for controlling CO 2 e emissions from the diesel engines:

Carbon Capture Storage (CCS); Alternative/ Biomass Fuel Sources; CSNOx Emissions Abatement System; Goo d Combustion and Manufacturer Recommended Maintenance Practices.



### Step 2

– Eliminate Technically Infeasible Option

CCS

– Infeasible

. Carbon Capture and Storage/ Carbon Sequestration refers to the processes in which CO 2 that would otherwise be emitted into the atmosphere, is captured and stored. This process requires the separation and capture of CO 2 at the point of emissions, transportation of the captured CO 2 to the storage location, and storing the captured CO 2 in de ep underground geologic formations in such a way that it will remain permanently stored. Potential sites for underground storage of CO 2 are mature oil and natural gas reservoirs, deep unmineable coal seams, deep saline formations, oil and gas rich organic shales, and basalt formations 21 . Injection of captured CO 2 into the ocean at great depths has also been proposed as a potential option to isolate CO 2 from the atmosphere for centuries 22

. The diesel fired engines on the BlackHornet Drillship and associated project operations are designed for and rely on air

- fired combustion, a process that exhausts CO 2 diluted with nitrogen, wherein the flue gas contains a relatively small percentage (under 20% by volume) of CO 2 . For effective carbon sequestration, the CO 2 in the exhaust gases must be separated and concentrated. Currently an effective method for recovering CO 2 from combustion exhaust is by using amine absorbers and cryogenic coolers.

21 Carbon Sequestration Atlas of the United States and Canada, U.S. Department of E nergy, Office of Fossil Energy, National Energy Technology Laboratory

. 22 Carbon Dioxide Capture and Storage, Intergovernmental Panel on Climate Change (IPCC), 2005

- Bert Metz, Ogunlade Davidson, Heleen de Coninck, Manuela Loos and Leo Meyer (Eds.), Cambridge University Press, UK.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 134 Trinity Consultants C urrently there are no known mature oil and natural gas reservoirs in re lative proximity of the areas proposed for exploratory drilling that can potentially be considered for geological sequestration. Furthermore, the exhaust from diesel engines is diluted with nitrogen in the air and the CO 2 must be separated prior to transport for storage. This separation has to be achieved using an absorption process that uses the chemical reaction of an aqueous alkaline solvent, usually an amine, with the exhaust gases. This process will require the addi tion of equipment such as absorber columns, stripper columns, condensers, reboilers, heat exchangers, etc. Installation of such equipment would require significant space reassignment on the drillship , which is unavailable.

Before deploying technologies that will inject captured and separated CO 2 into the ocean at great depths, such technologies would require further development and field testing. Currently such technologies have only been tested in laboratory experiments. Furthermore, putting CO 2 dire ctly into the deep ocean means that the chemical environment of the deep ocean would be altered immediately. Given only rudimentary understanding of deep

- sea ecosystems, only a limited and preliminary assessment of potential ecosystem effect s can be given 23

. Even if the above constraints are overcome, separated CO 2 from the drillship would have to be transported using pipelines to the storage location. Given the mobile nature of the exploratory drilling operations and thus the emission units, it wil l be i nfeasible to connect the drillship with a static pipeline infrastructure to transport CO 2 .
Biomass Fuel Sources

- Biodiesel

– Infeasible

Biodiesel is a fuel made from plant or animal feedstocks, and may be used in conventional diesel engines. Biodiesel is comprised of specific chemical components defined by ASTM as "mono

- alkyl esters of long chain fatty acids derived from vegetable oils or animal fats." In the United States, most biodiesel is made from soybean oil. However, canola oil, sunflower oil, recyc led cooking oils, palm oil, animal fats, and other oils are also used as feedstocks. Biodiesel in its pure form is known as B100, but it can be blended with conventional diesel fuel. The most common blends are B5 (5 percent biodiesel and 95 percent conven tional diesel) and B20 (20 percent biodiesel and 80 percent conventional diesel) 24

. Because biodiesel is made using feedstock that contain carbon taken from the biosphere, the combustion of biodiesel does not add new carbon and so does not add to GHG emiss ions. However, the production of biodiesel may involve use of fossil fuel based carbon. The diesel fired engines onboard the BlackHornet Drillship and associated project operations are not designed to burn biodiesel and there could be potential engine performance issues from use of biodiesel. Use of biodiesel may result in degradation of some fuel lines and gaskets (e.g. those made from nitrile and natural rubber). Biodiesel use a lso results in reduced power and fuel efficiency of engines, thus impairing the ability to safely maintain the vessel's position and perform other functions related to the proposed offshore operations such as drilling, cementing, and wireline. Requirement s for handling and using biodiesel may differ from requirements for petroleum

- based diesel. For example, biodiesel can gel at low temperatures and may require special handling in cold climates

23 Carb on Dioxide Capture and Storage, Intergovernmental Panel on Climate Change (IPCC), 2005

- Bert Metz, Ogunlade Davidson, Heleen de Coninck, Manuela Loos and Leo Meyer (Eds.), Cambridge University Press, UK.
24 Guidance for Biodiesel Producers and Biodiesel Bl enders/Users, Transportation and Regional Programs Division Office of Transportation and Air Quality, U.S. Environmental Protection Agency, EPA420

- B

- 07

- 019, November 2007.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 135 Trinity Consultants during winter. There may also be degradation of biodiesel due to long storage times 25 . Biodiesel combustion also results in increase in NO X emissions and decrease in PM, C O, and VOC emissions 26

. CSNOx Emission Abatement System

– Infeasible

ECOSPEC Global Technology PTE Ltd has patented the CSNOx emissions abatement system that is designed to convert CO 2 in exhaust gases from ship engines into bicarbonates, using Ultra Low Frequency (ULF) wave electrolysis treatment to increase the alkalinity of the seawater injected into a scrubber. Seawater is pumped in to the cont rol system from the ocean using suction pumps, making the system ideal for offshore applications. The system has been tested onboard a 100,000

- tonne oil tanker, at 50% gas load (equivalent to approximately 5 MW engine output), yielding a CO 2 removal effic iency of 77% 27 28

.

The CSNO X technology has been designed for and tested on vessels that operate at stable loads continuously. Such operations provide exhaust gases that are consistent in their composition and properties over long periods of time, thereby facilitating efficient operation of the control processes. Due to the large load variation swing demanded by the proposed exploratory drilling operations on the drill floor and other applications, the diesel fired engines onboard the BlackHornet drillship and associated project operations will not be able sustain constant steady state loads for sufficient time periods. The CSNO X technology has not been tested or proven effective for engines with these types of load variations.

Step 3

– Rank Remaining Control Techno logies 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 Anadarko proposes all the feasible options, as BACT for the diesel fired engines . Therefore, control cost analysis is not required.

Step 5

- Select BACT

Anadarko proposes good combustion and manufacturer recommended maintenance practices for all diesel fired internal combustion engines associated wi th this project operation. Additionally all control technologies that aid improve the combustions efficiencies of the various diesel engines discussed in the previous sections of the BACT are also proposed as BACT for GHGs.



### 5.5.2. GHG BACT Analysis for Mud Degas sing Operations (DR

- VG

- 01)

A RBLC search for potential control options for GHG from mud degassing operations did not produce any results. Also, a review of the permits recently proposed/issued by U.S. EPA Region 4 and Region

25 Guidance for Biodiesel Producers and Biodiesel Blenders/Users, Transportation and Regional Programs Division Office of Transportation and Air Quality, U.S. Environmental Protection Agency, EPA420

- B

- 07

- 019, November 2007.
26 A Comprehensive Analysis of Biodiesel Impacts on Exhaust Emissions
, Draft Technical Report As sessment and Standard s Division, Office of Transportation and Air Quality, U.S. Environmental Protection Agency
, EPA420

- P

- 02

- 001
, October 2002

. 27 CSNO X Brochure from http://www.ecospec.com , last accessed on August 28, 2010.
28 Regulatory Impact Analysis: Control of Emissions o f Air Pollution from Category 3 Marine Diesel Engines , Assessment and Standards Division, Office of Transportation and Air Quality, U.S. Environmental Protection Agency, December 2009.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 136 Trinity Consultants 10 for similar OCS sources did not result in any potential control technologies. Therefore, Anadarko propos es GHG BACT limit of 271.37 tpy on a 12

- month rolling total basis.



### 5.5.3. GHG BACT Analysis for Flowback Boiler (DR

- TP

- 22)

A RBLC search for potential control options for GHG from boiler operations did not provide a specific control technology . Also, a review of the permits recently proposed/issued by U.S. EPA Region 4 and Region 10 for similar OCS sources did not result in any potential control technologies. Therefore, Anadarko proposes good combustion practices along with manufacturer recommended operations an d maintenance practices as BACT

.



### 5.5.4. GHG BACT Analysis for Boom Flare (DR

- TP

- 23)

Step 1

– Identify all Control Technologies A 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 

### for flaring operations on a MODU did not produce any results. The most recent 10

- year period was used to identify applicable control technologies. The search results for poten tial control technologies for GHG from flares are listed below.

Comply with 40 CFR 60.18 Good Combustion and Manufacturer Recommended Maintenance Practices Proper Equipment Design and Maintenance Maintain Presence of Flame at Flare Tip at all times Flare gas minimization



### Step 2

– Eliminate Technically Infeasible Option

Maintain Presence of Flame at Flare Tip at all times

– Infeasible.

Since the boom flare is portable this option is not feasible.

Flare Gas Minimization

– Infe asible.

Redesigning to meet this operation would likely require a reconfiguration of piping during a well control situation and is not feasible. This would include rerouting gas that would have been sent to the flare back to the process to minimize emiss ions which are infeasible during off shore drilling process.



### 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 Eff ective Controls and Document Results Since all the remaining feasible technologies are being proposed as BACT , a cost analysis is not required.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 137 Trinity Consultants 

### Step 5

- Select BACT

Anadarko proposes manufacturer recommended good combustion operating practices, and proper mainten ance of flare as the BACT for the boom flare.

Table 5

- 21 below summarizes EPA’s BACT determinations for the diesel internal combustion engines with respect GHG emissions. The respective emission limits are based on AP

- 42 and the emission factors for CO 2 e were determined using the global warming poten tials obtained from 40 CFR 98 Subpart C

.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

- 2 2

.

Table 5

- 22 . Proposed CO 2 e BACT Emission Limits

Emission Unit BACT Emission Limit BACT Basis BACT Control Technologies Drillship Main Engines (DR

- ME

- 01 thru DR

- ME

- 06) 699 g/KW

- hr CO 2 e 40 CFR 98

Subpart C 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 pra ctices 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

man ufacturer recommended maintenance practices Mud degasser Vent (DR

- VG

- 01)

-- 40 CFR 98 Subpart C Best management practices

and manufacturer recommended maintenance practicesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 139 Trinity Consultants 

## 6. PART 71 FORMSAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX A

– PLOT PLANAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPEND IX B

– EMISSION CALCULATION SAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX C

– LIST OF INSIGNIFICAN T ACTIVITIESAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX D

– AIR DISPERSION MODEL ING ANALY SISAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX E

– BACT ANALYSIS SUPPOR TING DOCUMENTATIONAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX F

– ENVIRONMENTAL IMPACT ASSESSMENTAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 1

– SPECIFICATION SHEETS : DRILLSHIPAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants



## APPENDIX G

- 2

– SPECIFICATION SHEETS : THIRD PARTY EPA TI ER II CERTIFIED ENGINESAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 3

– SPECIFICATION SHEETS: NON

- EPA TIERED WELL EVALUATION ENGINESAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 4

– TANKS 4.09 OUTPUT FO R DRILLSHIP TANKSAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 5

– SPECIFICATION SHEETS : DUST COLLECTORSAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 6

– SPECIFICATION SHEETS : MSDS

- PAINTS/BASE/THINNERAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 7

– TANKS 4.09 OUTPUT FO R SUPPLY BOAT TANKSAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 8

– DRILLSHIP MAIN ENGIN E MANUFACTURER MAINT ENANCEAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 9

– THIRD PARTY FLOWBACK BOILERAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 10

– SPECIFICATION SHEETS : SUPPLY BOATAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 11

– ANCHOR HANDLING BOATAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 12

– SPECIFICATION SHEETS : TUGAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPE NDIX G

- 13

– SPECIFICATION SHEETS

– BARGEAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 14

– TANKS 4.09 OUTPUT FO R CONDENSATE TANKSAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 15

– SPECIFICATION SHEETS

– STIMULATION VESSELAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 16

– SPECIFICATION SHEETS

– WELL EVALUATION VESS ELAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 17

– TANKS 4.09 OUTPUT FOR ANCHOR BO AT TANKSAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application

Trinity Consultants 

## APPENDIX G

- 18

– MSDS OF ULTRA LOW SU LFUR DIESEL