*** DRAFT for Public Notice***

Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 4 

Atlanta, Georgia 

Permit to Construct and Operate Under the 

Outer Continental Shelf Air Regulations

Permit No. OCS-EPA-R4015

In accordance with the provisions of section 328 of the Clean Air Act (CAA), 42 U.S.C. § 7627 and the 

implementing Outer Continental Shelf (OCS) Air Regulations at title 40 Code of Federal Regulations 

(CFR) part 55, which incorporate by reference the Prevention of Significant Deterioration of Air Quality 

(PSD) regulations at 40 CFR § 52.21 and the title V Operating Permit Program regulations at 40 CFR 

part 71,

Anadarko Petroleum Corporation

1201 Lake Robbins Drive

The Woodlands, Texas 77380

is hereby authorized to construct and operate air emissions units and to conduct other air pollutant 

emitting activities at an OCS source at multiple sites within the Eastern Gulf of Mexico. The drilling 

area is located on the OCS east of longitude 87.5, west of the Military Mission Line (86°41’ west 

longitude), at least 100 miles from the Louisiana shoreline, and at least 125 miles from the Florida 

shoreline. 

Upon commencing activities in the area identified as the project location, this OCS source and support 

vessels shall be constructed and operated in accordance with the terms and conditions set forth in this 

permit.

This permit is effective on: [insert effective date: 30 days after the date of the service of notice of the 

final permit decision under 40 CFR 124.15; or if no comments requested a change in the draft permit,

the permit shall become effective immediately upon issuance], unless review of the permit decision is 

requested in accordance with 40 CFR 124.19.

This permit shall expire two years from the date that the OCS source commences activity under this 

permit, not to exceed [INSERT DATE].

This permit shall not relieve the owner or operator of the responsibility to comply fully with all 

applicable provisions of federal and state law.

__________ ______________________

Date Signed Beverly H. Banister

Director

Air, Pesticides, and Toxics

Management Division
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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1 AUTHORITY

The United States Environmental Protection Agency (EPA) issues this permit pursuant to section 328 of 

the CAA, 42 U.S.C. § 7627, and the implementing OCS Air Regulations at 40 CFR part 55, which 

incorporate by reference the PSD regulations at 40 CFR § 52.21 and the title V Operating Permit 

Program regulations at 40 CFR part 71. This permit is based upon application materials submitted to 

EPA by Anadarko Petroleum Corporation (Anadarko) dated December 26, 2012, March 27, 2013, April 

26, 2013, May 3, 2013, and July 2, 2013; supplemental submittals and information in the administrative 

record for this permit action; and upon the technical analysis performed by EPA.

2 APPLICANT

Anadarko Petroleum Corporation

1201 Lake Robbins Drive

The Woodlands, Texas 77380

3 PROJECT LOCATION

Anadarko’s project is located on the OCS in the Eastern Gulf of Mexico. The drilling sites are located 

east of longitude 87.5, west of the Military Mission Line (86°41’ west longitude), at least 100 miles 

from the Louisiana shoreline, and at least 125 miles from the Florida shoreline.

4 PROJECT DESCRIPTION

The proposed project will mobilize the Transocean Discoverer Spirit, up to two support vessels to 

transport personnel and supplies, and up to three support vessels for well completion. The proposed 

project will consist of three phases: the drilling phase, the well completion phase, and the production 

well maintenance phase. The operation will last no more than two years, and operate no more than 208 

calendar days per year. Anadarko will conduct drilling activities at multiple locations within the Eastern 

Gulf of Mexico area described in Section 3, Project Location, of this permit. This permit does not 

authorize the establishment of any permanent production facilities.

Air pollutant emissions generated from the project include carbon monoxide (CO), oxides of nitrogen 

(NOx), particulate matter (PM), particulate matter with an aerodynamic diameter less than 2.5 microns 

(PM2.5), particulate matter with an aerodynamic diameter less than 10 microns (PM10), sulfur dioxide 

(SO2) and volatile organic compounds (VOC) (known as criteria pollutants), as well as other regulated 

air pollutants, including greenhouse gases. VOC and NOx are the measured precursors for the criteria 

pollutant ozone, and NOx and SO2 are measured precursors for PM2.5. Based on emissions estimates and 

applicable permitting thresholds, the project is subject to the PSD and title V programs and has 

significant emissions of NOX, CO, PM, PM10, PM2.5, and VOC. In addition, the Discoverer Spirit is an 

area source of hazardous air pollutants pursuant to 40 CFR 63 subpart ZZZZ.

The Discover Spirit emission units can be found in Table 1. Additional units on the stimulation vessel 

that will be used for OCS activities are shown in Table 2. Table 3 lists the representative support vessels.
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Support vessels operating within 25 miles of the OCS source will include supply boats (work or crew 

boat), an anchor handling boat, and support vessels used during well completion activities that run 

marine diesel engines.

The information provided in Tables 1 through 3 is for description and identification purposes and does 

not establish operating limits.

Table 1 – Discoverer Spirit Emissions Units

Emissions 

Unit ID

Description Make & Model Ratinga(hp) Manufacture 

Year

DR-GE-01 -

04

Main propulsion generator #1-

#4

Wärtsilä 18V32 LNE 9,910 hp* 1998

DR-GE-05 -

06

Main propulsion generator #5-

#6

Wärtsilä 12V32 LNE 6,610 hp 1998

DR-GE-07 Emergency diesel engine Wärtsilä 6R32LNE 3,300 hp 1998

DR-GE-08 Remotely operated vehicle 

(ROV) emergency generator

Cummins QSM11-G2NR3 (or 

equivalent)

427 hp 2004

DR-EC-01 -

04

Escape capsule diesel engines Lister Petter L4 (or equivalent) 39 hp 1997

DR-EC-05 -

06

Escape capsule diesel engines Lister Petter L3 (or equivalent) 29 hp 1997

DR-FR-01 Fast rescue craft engine Steyr M16 TCAM-MO236 K42(or 

equivalent)

230 hp 2000

DR-AC-01 Air compressor diesel engine 

#1

Sperre M-HL2/140 (or equivalent) 18 hp 1997

DR-AC-02 Air compressor diesel engine

#2

Sperre M-HL2/140 (or equivalent) 15 hp 1997

DR-FL-01 Diesel powered forklift engine Caterpillar DP30K (or equivalent) 30 hp

DR-VG-01 Mud degassing vent - -

DR-DC-01 Dust collectors #1 ASPA Engineering #9-1400 1400 cfm

DR-DC-02 Dust collectors #2 ASPA Engineering #16-2400 2400 cfm

DR-DC-03 Dust collector #3 Tenkay 6D Mark IV 4000 cfm

DR-PO-01 Painting operations - -

DR-WO-01 Welding operations

DR-DT-01 -

09

Various diesel fuel tanks - -

DR-FT-01 -03 Various helicopter fuel tanks - -

DR-FE-01 Fugitive Emissions - -

Third Party Enginesb

DR-WL-01 -

02

Wireline engines #1 & #2 Cummins C8.3 (or equivalent) 275hp

DR-EL-01 -

02

Electric line engines #1 & #2 Caterpillar 3126B (or equivalent) 300 hp

DR-CU-01 -

02

Casing unit engines #1 & #2 Deutz F6L914 (or equivalent) 124 hp

DR-WB-01 Water blasting engines Deutz BF 6 M 2012C (or equivalent) 208 hp

DR-VS-01 -

05

Well evaluation engines #1-

#5

Detroit 4-71 (or equivalent) 140 hp

Well Completion - Third Party Sources on the Drillshipb

DR-WC-01 Tubing running unit engine Deutz F6L914 (or equivalent) 92 hp
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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DR-WC-02 Fluid filtration pump engine Deutz BF 4 M 2012 (or equivalent) 100 hp

DR-WC-03 Eline powerpack engine John Deere 6068H (or equivalent) 225 hp

DR-WC-04 Slickline powerpack engine FPT N45 MST (or equivalent) 126 hp

DR-WC-05 Flowback boiler “Sigma Fired” SF-200SE (or 

equivalent)

8 MMBtu/hr

DR-WC-06 Boom flare - -

DR-WC-07 CT powerpack engine Detroit Diesel 6063KH74 (or 

equivalent)

600 hp

DR-WC-08 CT pump engine Caterpillar C27 ACERT (or 

equivalent)

860 hp

DR-WC-09 -

10

Wireline engines #3 & #4 Cummins C8.3 (or equivalent) 275 hp

WC-CT-01 -

03

Condensate tanks - -

a

Permit conditions may limit operation to less than rated capacity.

b These units are portable and brought on the drillship as needed by a third party supplier. The specific engine available for use during the 

project had not been identified at the time of application. The specific engine used will meet an equivalent or a higher EPA Tier standard.

* Horsepower

Table 2 – Well Completion Stimulation Vessel Emission Unitsa

Emissions 

Unit ID

Description Make & Model Ratingb

(hp)*

SV-PE-01 -

08

Stimulation vessel pump engines Caterpillar 3512 DITA (or equivalent) 2,250 hp

a The specific stimulation vessel available for use during the drilling project had not been identified at the time of application. The engine 

and vessel used during the project will be an equivalent or a higher EPA Tier standard.

b Permit conditions may limit operation to less than rated capacity.

* Horsepower

Table 3 – Support Vessels

Vessel Description Representative Vessela

Supply Boat HOS Coral

Anchor Handling Boat Kirt Chouest

Well Completion Vessels Tug, Barge, Stimulation Vessel

a Specific crew, supply, and work boats available for use during the drilling project had not been identified at the time of application. The 

representative vessel is the worst-case vessel in the potential vessel fleet and used to calculate potential emissions.

5 GENERAL CONDITIONS

5.1 Compliance

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

40 CFR part 55 and this permit. Failure to do so shall be considered a violation of section 

111(e) of the CAA. All enforcement provisions of the CAA, including, but not limited to, 

the provisions of sections 113, 114, 120, 303 and 304 of the CAA, shall apply to the OCS 

source and permittee.

[40 CFR § 55.8, 55.9(a) and (b)]
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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5.1.2 The permittee must comply with all conditions of this permit. All terms and conditions of 

this permit are enforceable by EPA and citizens under the CAA. Any permit 

noncompliance constitutes a violation of the CAA and is grounds for enforcement action; 

for permit termination, revocation and reissuance, or modification; or for denial of a 

permit renewal application.

[40 CFR § 55.8, 71.6(a)(6)(i)]

5.1.3 It shall not be a defense for a permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of this permit.

[40 CFR § 71.6(a)(6)(ii)]

5.2 Permit Shield

Compliance with the terms and conditions of this permit shall be deemed compliance with the applicable 

requirements that are included and are specifically identified in this permit. Nothing in this permit shall 

alter or affect the following:

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

Administrator under that section;

5.2.2 The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance; or

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

[40 CFR § 71.6(f)(1)]

5.3 Other Credible Evidence

For the purpose of submitting compliance certifications in accordance with Condition 5.20 of this

permit, or establishing whether or not a person has violated or is in violation of any requirement of this 

permit, nothing shall preclude the use, including the exclusive use, of any credible evidence or 

information relevant to whether a source would have been in compliance with applicable requirements if 

the appropriate performance or compliance test or procedure had been performed.

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

5.4 Construction and Operation
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5.4.1 As approved and conditioned by this permit, all construction and operation, including 

equipment operations and maintenance of the OCS source and support vessels shall be in 

accordance with the data, specifications, drawings, exhibits, and assumptions included 

with the application and supporting materials submitted by the permittee, which resulted 

in this permit (application materials). This permit is valid only for the specific processes 

and operations applied for and indicated in the application materials. Any unauthorized 

deviation from the application materials, or from any term or condition of this permit 

may constitute grounds for revocation or enforcement action by EPA. 

5.4.2 The permittee shall properly operate and maintain the OCS source and support vessels, 

including all systems of treatment and control (and related appurtenances) that are 

installed and used by the permittee to achieve compliance with the terms and conditions 

of this permit. This provision includes the operation of backup or auxiliary facilities or 

similar systems when necessary to minimize or prevent emissions in achieving 

compliance with the terms and conditions of the permit.

[40 CFR § 52.21(r)(1)]

5.5 Compliance and Other Requirements

This permit does not relieve the permittee of the responsibility to comply fully with applicable 

provisions of any other requirements under federal law.

[40 CFR § 55.6(a)(4)(iii)]

5.6 Notification to Owners, Operators and Contractors

The permittee must notify all other owners or operators, contractors, and the subsequent owners or 

operators associated with emissions from the OCS source and support vessels of the terms and 

conditions of this permit prior to operation of any subject emissions unit

[40 CFR § 55.6(a)(4)(iv)]

5.7 Expiration of Approval to Construct and Permit Renewal

5.7.1 This approval to construct shall become invalid if: construction is not commenced within 

18 months after the effective date of this permit, construction is discontinued for a period 

of 18 months or more, or construction is not completed within a reasonable time. The 

EPA may extend the 18-month period upon a satisfactory showing that an extension is 

justified. For the purposes of this permit, periods greater than 18 months between drilling 

campaigns are not considered to be a discontinuation of construction.

[40 CFR § 52.21(r)(2)]

5.7.2 The permittee’s authority to construct and operate shall expire two years from the date 

the OCS Source commences activity in the lease block area of the Gulf of Mexico

specified in Section 3.0, Project Location. The EPA may extend the two years upon a 

satisfactory showing that the extension is justified, and under the condition that project 

emissions do not exceed those specified in this permit. 

[40 CFR § 52.21(i)(3)]
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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5.7.3 If the permittee’s authority to construct and operate has not expired pursuant to Condition 

5.7.2 or the approval to construct has not become invalid pursuant to Condition 5.7.1, 

then the permit expires on the date printed on page one of this permit. Expiration of this 

permit terminates the permittee’s right to operate unless a timely and complete permit 

renewal application has been submitted at least six (6) months, but not more than 18 

months, prior to the date of expiration of this permit. If the permittee submits a timely 

and complete renewal application, and EPA does not take final action on the renewal 

application before the end of the term of this permit, the permittee’s failure to have a 

permit is not a violation of 40 CFR part 71 until the permitting authority takes final 

action on the renewal application. Such protection will cease to apply if, subsequent to 

EPA’s determination that the renewal application is complete, the permittee fails to 

submit by the deadline specified in writing by EPA any additional information identified 

as being needed to process the application. This condition does not supersede the 

limitation on the permittee’s authority to construct and operate set forth in Condition 

5.7.2.

[40 CFR §§ 71.5(a)(1)(iii), 71.7(b), and 71.7(c)(1)(ii)]

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

with 40 CFR sections §§ 71.5(a)(1)(iii) and 71.5(a)(2), but EPA does not take final action 

on the renewal application before the expiration of this permit, then all the terms and 

conditions of this permit, including any permit shield granted pursuant to 

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

application.

[40 CFR §§ 71.7(c)(3) and 71.7(b)]

5.7.5 Renewal of this permit is subject to the same procedural requirements that apply to initial 

permit issuance, including those for public participation and affected State review.

[40 CFR §71.7(c)(1)(i)]

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

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

and off-permit changes that occurred during the permit term and were not incorporated 

into the permit during the permit term, any applicable requirements that were 

promulgated and not incorporated into the permit during the permit term, and other 

information required by the application form.

[40 CFR §§ 71.5(a)(2) and 71.5(c)(5)]

5.8 Property Rights

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

[40 CFR §71.6(a)(6)(iv)]

5.9 Inspections

The permittee, by accepting this permit, specifically agrees to allow authorized EPA personnel, upon 

presentation of credentials or other documents as may be required by law and at reasonable times, access 
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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to the premises where the permitted activity is located or conducted or where any records are required to 

be kept under the terms and conditions of this permit to:

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

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

monitoring data, or compliance or noncompliance with the permit;

5.9.2 Inspect the OCS source, support vessels, equipment, practices, or operation regulated or 

required under this permit; and

5.9.3 Sample or monitor any substances or parameters at any location reasonably necessary to 

assure compliance with this permit or EPA rules.

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

[40 CFR §§ 71.6(c)(2) and 55.8]

5.10 Emergency Provisions

In addition to any emergency or upset provision contained in any applicable requirement, the permittee 

may seek to establish that noncompliance with a technology-based emission limitation under this permit 

was due to an emergency. An emergency constitutes an affirmative defense to an action brought for 

noncompliance with such technology-based emissions limitation. The permittee shall demonstrate the 

affirmative defense of emergency through properly signed, contemporaneous operating logs, or other 

relevant evidence that:

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

emergency; 

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

5.10.3 During the period of the emergency, the permittee took all reasonable steps to minimize 

levels of emissions that exceeded the emissions standards, or other requirements in this 

permit; and

5.10.4 The permittee submitted notice of the emergency to EPA within two (2) working days of 

the time when emission limitations were exceeded due to the emergency. This notice 

must contain a description of the emergency, any steps taken to mitigate emissions, and 

corrective actions taken. This notice fulfills the requirements of Condition 5.17.2 of this 

permit concerning prompt notification of deviations.

[40 CFR §§ 71.6(g)(2), 71.6(g)(3), and 71.6(g)(5)]

5.11 Burden of Proof for Emergencies

In any enforcement proceeding, the permittee attempting to establish the occurrence of an emergency 

has the burden of proof. 

[40 CFR § 71.6(g)(4)]
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5.12 Emergency Defined

An “emergency” means any situation arising from sudden and reasonably unforeseeable events beyond 

the control of the source, including acts of God, which situation requires immediate corrective action to 

restore normal operation, and that causes the source to exceed a technology-based emission limitation 

under the permit due to unavoidable increases in emissions attributable to the emergency. An emergency 

shall not include noncompliance to the extent caused by improperly designed equipment, lack of 

preventive maintenance, careless or improper operation, or operator error.

[40 CFR § 71.6(g)(1)]

5.13 Certification Requirement

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

truth, accuracy, and completeness. Such certifications shall state that based on information and belief 

formed after reasonable inquiry, the statements and information in the document are true, accurate, and 

complete.

[40 CFR §§ 71.5(d), 71.6(c)(1), and 71.9(h)(2)]

5.14 Permit Actions

This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a 

request by the permittee for a permit modification, revocation and reissuance, or termination, or of a 

notification of planned changes or anticipated noncompliance does not stay any permit condition.

[40 CFR § 71.6(a)(6)(iii)]

5.15 Reopening for Cause

The permit shall be reopened by EPA and the permit revised prior to expiration under any of the 

circumstances described in 40 CFR § 71.7(f).

[40 CFR § 71.7(f)]

5.16 Recordkeeping Requirements

In accepting this permit, the permittee understands and agrees that all information relating to this 

permitted source which is submitted to EPA may be used by EPA as evidence in any enforcement case 

involving the permitted source arising under federal statutes, EPA rules, or rules enforceable by EPA.

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

5.16.2 The permittee shall furnish all records required by this permit.

5.16.3 During enforcement actions, the retention period for all records required by this permit 

will be extended automatically until the permittee receives written notice from EPA that 

the permittee no longer needs to retain these records.

 
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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5.16.4 The permittee shall hold at the corporate offices of Anadarko Petroleum Corporation,

1201 Lake Robbins Drive, The Woodlands, Texas 77380, all records required by the 

permit including, but not limited to, monitoring data and support information required by 

the permit, and records of all data used to complete the application for this permit. These 

materials shall be retained at least five years from the date of the sample, measurement,

or report unless otherwise specified. Records of all data used to complete the permit 

application must be kept for five years from the date of the application, unless otherwise 

specified. Support information includes all calibration and maintenance records and all 

original strip-chart recordings for continuous monitoring instrumentation and copies of 

all reports required by the permit.

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

5.16.5 Records of monitoring information shall include:

5.16.5.1 the date and time of sampling or measurements;

5.16.5.2 the emission unit or other place as defined in this permit, and time of sampling 

or measurements; 

5.16.5.3 the operating conditions as existing at the time of sample or measurement;

5.16.5.4 the results of such analyses;

5.16.5.5 the date(s) the analyses were performed;

5.16.5.6 the name of the person who performed the sampling or measurements; and

5.16.5.7 the analytical techniques or methods used.

[40 CFR § 71.6(a)(3)(ii)(A)]

5.16.6 When requested by EPA, the permittee shall furnish any information required by law 

which is needed to determine compliance with the permit. If the permittee becomes aware 

that relevant facts were not submitted or were incorrect in the permit application or in any 

report to EPA, the permittee shall, upon becoming aware of such facts or corrected 

information, promptly submit such facts or corrected information to EPA.

[40 CFR §§ 71.5(b) and 55.8]

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

submitted to:

Chief

Air & EPCRA Enforcement Branch

Air, Pesticides and Toxics Management Division

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303

In addition, electronic copies of the above-referenced notifications and communications 

shall be submitted to the following individuals at their corresponding email address:

Name Email Phone

David Lloyd lloyd.david@epa.gov 404-562-9216

Jason Dressler dressler.jason@epa.gov 404-562-9208
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Kelly Fortin fortin.kelly@epa.gov 404-562-9117

Eva Land land.eva@epa.gov 404-562-9103

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

may request in writing to determine whether cause exists for modifying, revoking, and 

reissuing, or terminating the permit, or to determine compliance with the permit. Upon 

request, the permittee shall also furnish to EPA copies of records that are required to be 

kept pursuant to the terms of the permit, including information claimed to be confidential. 

Information claimed to be confidential must be accompanied by a claim of confidentiality 

according to the provisions of 40 CFR part 2, subpart B.

[40 CFR §§ 71.6(a)(6)(v),71.5(a)(3) and 55.8]

5.17 General Reporting Requirements

5.17.1 The permittee shall submit to EPA reports of any required monitoring for each six month 

reporting period from July 1 to December 31 and from January 1 to June 30, except that 

the first reporting period shall begin when the OCS source commences activity subject to 

this permit and end on either June 30 or December 31, whichever occurs first. All reports 

shall be submitted to EPA and shall be postmarked by the 30th day following the end of 

the reporting period. All instances of deviations from permit requirements must be clearly 

identified in such reports. All required reports must be certified by a responsible official 

consistent with Condition 5.13.

5.17.2 The permittee shall promptly report to EPA, by telephone or facsimile, deviations from 

permit conditions, the probable cause of such deviations, and any corrective actions or 

preventive measures taken. The report shall be made using the following numbers:

Telephone: (404) 562-9194 

Facsimile: (404) 562-9019 

Attn: Air Permits Part 71 Deviation Report

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

5.17.3.1 Any definition of prompt or a specific time frame for reporting deviations 

provided in an underlying applicable requirement as identified in this permit.

5.17.3.2 Where the underlying applicable requirement fails to address the time frame 

for reporting deviations, reports of deviations will be submitted based on the 

following schedule:

5.17.3.2.1 for emissions of a hazardous air pollutant or a toxic air pollutant 

(as identified in the applicable regulation) that continue for more 

than an hour in excess of permit requirements, the report must be 

made within 24 hours of the occurrence; 

5.17.3.2.2 for emissions of any regulated pollutant excluding those referenced 

in Condition 5.17.3.2.1, that continue for more than two (2) hours 

in excess of permit requirements, the report must be made within 

48 hours of the occurrence; or
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5.17.3.2.3 for all other deviations from permit requirements, the report shall 

be submitted with the semi-annual monitoring report required in 

Condition 5.17.1.

5.17.4 Within 10 working days of the occurrence of a deviation that requires 24-hr or 48-hr 

notification as provided in Condition 5.17.3.2 above, the permittee shall also submit a 

written notice, which shall include a narrative description of the deviation and updated 

information as listed below to EPA, certified consistent with Condition 5.13 of this 

permit.

5.17.5 When reporting excess emissions or permit deviations, including those that are required 

to be submitted for the first time with the semi-annual monitoring report, the permittee 

must report in writing the following information:

5.17.5.1 OCS Source (Facility) Name;

5.17.5.2 OCS Air Permit Number;

5.17.5.3 company Name;

5.17.5.4 date/time when the deviation was discovered;

5.17.5.5 date/time when the event began (24-hour clock);

5.17.5.6 date/time when the event ended (24-hour clock);

5.17.5.7 duration of the event: (hours: minutes) or days (total number of hours, minutes 

or days, if intermittent then include only the duration of the deviation);

5.17.5.8 if the deviation was intermittent or continuous;

5.17.5.9 brief description of what happened and the cause, including information 

regarding the operating conditions during the deviation;

5.17.5.10 identification of the emission unit(s) or source(s) involved in the event using 

the same identification number(s) and name(s) as in the permit;

5.17.5.11 identification of each emission limit potentially exceeded during the event and 

the level of exceedance, if applicable;

5.17.5.12 whether the deviation was unavoidable;

5.17.5.13 describe corrective action taken and action taken to prevent future recurrence; 

5.17.5.14 if not corrected, the anticipated time the deviation is expected to continue and 

steps being taken to reduce, eliminate, and prevent recurrence of the deviation; 

and

5.17.5.15 certification: Based on information and belief formed after reasonable inquiry, 

certify that the statements and information reported are true, accurate, and 

complete.

5.17.6 For the purposes of Conditions 5.17.1 through 5.17.7, deviation means any situation in 

which the permittee fails to meet a permit term or condition. A deviation is not always a 

violation. A deviation can be determined by observation or through review of data 

obtained from any testing, monitoring, or recordkeeping required by this permit. For a 

situation lasting more than 24 hours, each 24-hour period is considered a separate

deviation. Included in the meaning of deviation are any of the following:
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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5.17.6.1 a situation where emissions exceed an emission limitation or standard; 

5.17.6.2 a situation where process or emissions control device parameter values 

indicate that an emission limitation or standard has not been met; 

5.17.6.3 a situation in which observations or data collected demonstrate 

noncompliance with an emission limitation or standard or any work practice 

or operating condition required by the permit (including indicators of 

compliance revealed through parameter monitoring); and

5.17.6.4 a situation in which any testing, monitoring, recordkeeping or reporting 

required by this permit is not performed or not performed as required.

5.17.7 If requested by EPA, the permittee shall provide a more detailed written report as 

requested to follow up on an excess emissions/deviation report.

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

5.18 Off Permit Changes

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

requirements are met:

5.18.1 Each change is not addressed or prohibited by this permit.

5.18.2 Each change shall meet all applicable requirements and shall not violate any existing 

permit term or condition.

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

title I of the Clean Air Act.

5.18.4 The permittee shall provide contemporaneous written notice to EPA of each change under 

the provision, except for changes that qualify as insignificant activities under 40 CFR § 

71.5(c)(11). The written notice shall include the following:

5.18.4.1 a description of each change;

5.18.4.2 date of the change;

5.18.4.3 any change in emissions; 

5.18.4.4 list of pollutants emitted; and 

5.18.4.5 any applicable requirements that would apply as a result of the change.

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

5.18.6 The permittee shall keep a record describing all changes that result in emissions of any 

regulated air pollutant subject to any applicable requirement not otherwise regulated under 

this permit, and the emissions resulting from those changes.

[40 CFR §71.6(a)(12)]

5.19 Operational Flexibility

The permittee is allowed to make a limited class of changes under section 502(b)(10) of the Clean Air 

Act (CAA) within this permitted facility without applying for a permit revision, provided the changes do 

not exceed the emissions allowable under this permit (whether expressed therein as a rate of emissions 

or in terms of total emissions) and are not title I modifications. This class of changes does not include 

changes that would violate applicable requirements or changes that would contravene federally 

enforceable permit terms and conditions that are monitoring (including test methods), recordkeeping, 

reporting, or compliance certification requirements.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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5.19.1 The permittee is required to send a notice to EPA at least 7 days in advance of any 

change made under this provision. The notice must describe the change, when it will 

occur and any change in emissions, and identify any permit terms or conditions made 

inapplicable as a result of the change. The permittee shall attach each notice to its copy of 

this permit.

5.19.2 Any permit shield provided under Condition 5.2 does not apply to changes made under 

this provision.

[40 CFR §§ 71.2 and 71.6(a)(13)(i)]

5.20 Annual Compliance Certification

The permittee shall submit to EPA a certification of compliance with permit terms and conditions, 

including emission limitations, standards, or work practices, postmarked by February 28 of each year 

and covering the previous calendar year except that the first certification shall cover the period from the 

date the OCS commences activities subject to this permit through December 31. The compliance 

certification shall be certified as to truth, accuracy and completeness by a responsible official consistent 

with Condition 5.13 of this permit.

The certification shall include the following:

5.20.1 The identification of each permit term or condition that is the basis of the certification; 

5.20.2 The identification of the method(s) or other means used by the permittee for determining 

the compliance status with each term and condition during the certification period. Such 

methods and other means shall include, at a minimum, the methods and means required 

in this permit. If necessary, the permittee also shall identify any other material 

information that must be included in the certification to comply with section 113(c)(2) of 

the CAA, which prohibits knowingly making a false certification or omitting material 

information; 

5.20.3 The status of compliance with each term and condition of the permit for the period 

covered by the certification, including whether compliance during the period was 

continuous or intermittent. The certification shall be based on the method or means 

designated above. The certification shall identify each deviation and take it into account 

in the compliance certification; and

5.20.4 A report of NOX, CO, PM/PM10/PM2.5, SO2, VOC, GHG and HAP emissions in tons per 

year emitted by each emissions unit regulated under this permit during the duration of the 

reporting period based on recorded data, including actual fuel usage and actual hours of 

operation. The report shall include the emission factors used for each unit and a 

description of the reproducible methodology used to calculate the emissions for the 

reporting period.

[40 CFR §§71.6(c)(5), 55.6(a)(4) and 55.8]
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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5.21 Compliance Schedule

For applicable requirements with which the source is in compliance, the permittee will continue to 

comply with such requirements. For applicable requirements that will become effective during the

permit term, the permittee shall meet such requirements on a timely basis.

[40 CFR §§ 71.6(c)(3) and 71.5(c)(8)(iii)(A) and (B)]

5.22 Safe Shutdown

As provided in 40 CFR § 55.9(c), if this OCS source is ordered to cease operation of any piece of 

equipment due to enforcement action taken by EPA, the shutdown will be coordinated by EPA with the 

DOI Bureau of Safety and Environmental Enforcement, the United States Coast Guard, the permittee, 

and the operator to assure that the shutdown will proceed in a safe manner. No shutdown action will 

occur until after EPA’s consultation with these entities, but in no case will initiation of the shutdown be 

delayed by more than 24 hours after EPA consults with these agencies. The initiation of the shutdown 

process will not preclude well procedures necessary to ensure safety.

[40 CFR § 55.9(c)]

5.23 Transfer of Ownership

In the event of any changes in control or ownership of the OCS source, this permit shall be binding on 

all subsequent owners and operators. The permittee shall notify the succeeding owner and operator of 

the existence of this permit and its conditions by letter, a copy of which shall be forwarded to EPA 

Region 4.

[40 CFR § 55.6(a)(4)(iv)]

5.24 Severability

The provisions of this permit are severable, and, in the event of any challenge to any portion of this 

permit or if any provision of the permit is held invalid, the remainder of this permit shall remain valid 

and in force.

[40 CFR §71.6(a)(5)]

5.25 General Testing Requirements

5.25.1 In addition to the specific testing requirements contained in the emission unit sections of 

this permit, the permittee shall comply with the generally applicable testing requirements 

in Conditions 5.25.2 through 5.25.10 whenever conducting a performance test required 

by this permit unless specifically stated otherwise in this permit.

5.25.2 The permittee shall provide EPA at least 30 days prior notice of any performance test, 

except as otherwise specified in this permit, to afford EPA the opportunity to have an 

observer present. If after 30 days notice for an initially scheduled performance test, there 

is a delay in conducting the scheduled performance test, the permittee shall notify EPA as 

soon as possible of any delay in the original test date, either by providing at least seven 

(7) days prior notice of the rescheduled date of the performance test, or by arranging a 

rescheduled date with EPA by mutual agreement.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

16

5.25.3 The permittee shall submit to EPA a source test plan 30 days prior to any required 

testing. The source test plan shall include and address the following elements:

5.25.3.1 purpose and scope of testing; 

5.25.3.2 source description, including a description of the operating scenarios and 

mode of operation during testing and including fuel sampling and analysis 

procedures; 

5.25.3.3 schedule/dates of testing; 

5.25.3.4 process data to be collected during the test and reported with the results, 

including source-specific data identified in the emission unit sections of this 

permit; 

5.25.3.5 sampling and analysis procedures, specifically requesting approval for any 

proposed alternatives to the reference test methods, and addressing minimum 

test length (e.g., one hour, eight (8) hours, 24 hours, etc.) and minimum 

sample volume; 

5.25.3.6 sampling location description and compliance with the reference test methods; 

5.25.3.7 analysis procedures and laboratory identification; 

5.25.3.8 quality assurance plan; 

5.25.3.9 calibration procedures and frequency; 

5.25.3.10 sample recovery and field documentation; 

5.25.3.11 chain of custody procedures; 

5.25.3.12 quality assurance/quality control project flow chart; 

5.25.3.13 data processing and reporting; 

5.25.3.14 description of data handling and quality control procedures; and

5.25.3.15 report content and timing.

5.25.4 Only regular operating staff may adjust the processes or emission control devices during 

or within two (2) hours prior to the start of a source test. Any operating adjustments made 

during a source test that do not result in representative testing conditions may render the 

source test invalid.

5.25.5 For the duration of each test run (unless otherwise specified), the permittee shall record 

the following information:

5.25.5.1 all data which is required to be monitored during the test per the applicable 

condition of this permit that is requiring a test; and

5.25.5.2 all continuous monitoring system data that is required to be routinely 

monitored in the applicable condition of this permit for the emission unit 

being tested.

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

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

5.25.7 If the reference test method yields measured pollutant concentration values at an oxygen 

concentration other than specified in the emission standard, the permittee shall correct the 

measured pollutant concentration to the oxygen concentration specified in the emission 

standard by using the following equation:
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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PCX = PCm · (21-X)

 (21-Y)

Where:

PCX = Pollutant concentration at X percent;

PCm = Pollutant concentration as measured;

X = the oxygen concentration specified in the standard; and

Y = the measured average volumetric oxygen concentration.

5.25.8 Facilities for performing and observing the emission testing shall be provided that meet 

the requirements of 40 CFR § 60.8(e) and Reference Method 1 (40 CFR § 60, 

Appendix A).

5.25.9 Emission test reports shall be submitted to EPA within 45 days of completing any 

emission test required by this permit. The report shall include the information required to 

be recorded pursuant to Condition 5.25.5 above.

5.25.10 Source test emission data shall be reported as the arithmetic average of all valid test runs 

and in the terms of any applicable emission limit, unless otherwise specified in the 

emission unit sections of this permit.

[40 CFR §§ 71.6(a)(3) and 71.6(c)(1)]

5.26 Fee Payment

5.26.1 No later than April 1 of each year, the permittee shall submit the following to EPA:

5.26.1.1 Full payment of the annual permit fee, as specified in Conditions 5.26.2 

through 5.26.11; 

5.26.1.2 An updated fee calculation worksheet form and a photocopy of each fee 

payment check (or other confirmation of actual fee paid), as specified in 

Conditions 5.26.4 through 5.26.8; and

5.26.1.3 An annual emissions report of actual emissions, as specified in Condition 

5.26.6, for the preceding calendar year.

5.26.2 The fee payment shall be in United States currency and shall be paid by money order, 

bank draft, certified check, corporate check, or electronic funds transfer payable to the 

order of the U.S. Environmental Protection Agency.

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

addresses listed below.

If sent by Regular Mail through U.S. Postal Service (USPS), send to:

U.S. Environmental Protection Agency

FOIA and Miscellaneous Payments

Cincinnati Finance Center
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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PO Box 979078

St. Louis, MO 63197-9000

If sent by Express Delivery (or when a physical address is required), send to:

U.S. Bank

Government Lockbox 979078 

US EPA FOIA & Misc. Payments

1005 Convention Plaza

Mail Station SL-MO-C2GL

St. Louis, MO 63101

Contact: Natalie Pearson

(314-418-4087)

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

each fee payment check (or other confirmation of actual fee paid), submitted annually by 

the date specified in Condition 5.26.1, to:

Chief

Air Permits Section

Air, Pesticides and Toxics Management Division

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303

5.26.5 The annual emissions fee shall be calculated by multiplying the total tons of actual 

emissions of all “regulated pollutants (for fee calculation),” emitted from the source by 

the presumptive emission fee (in dollars/ton) in effect at the time of calculation. The 

presumptive emission fee is revised each calendar year and is available from EPA prior to 

the start of each calendar year.

5.26.5.1 “Actual emissions” means the actual rate of emissions in tons per year (TPY) 

of any “regulated pollutant (for fee calculation),” as defined in 40 CFR § 71.2, 

emitted from a part 71 source over the preceding calendar year. Actual 

emissions shall be calculated using each emissions unit’s actual operating 

hours, production rates, in-place control equipment, and types of materials 

processed, stored, or combusted during the preceding calendar year.

5.26.5.2 Actual emissions shall be computed using methods required by the permit for 

determining compliance, such as monitoring or source testing data.

5.26.5.3 If actual emissions cannot be determined using the compliance methods in the 

permit, the permittee shall use other federally recognized procedures.

5.26.5.4 The permittee shall exclude the following emissions from the calculation of 

fees:
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

19

5.26.5.4.1 the amount of actual emissions of each regulated pollutant (for fee 

calculation) that the source emits in excess of 4,000 tons per year; 

5.26.5.4.2 actual emissions of any regulated pollutant (for fee calculation) 

already included in the fee calculation; and

5.26.5.4.3 the insignificant quantities of actual emissions not required to be 

listed or calculated in a permit application pursuant to 40 CFR § 

71.5(c)(11).

5.26.6 The permittee shall submit an annual emissions report of its actual emissions for the 

preceding calendar year. The annual emissions report shall be certified by a responsible 

official and shall be submitted each year to EPA by the date specified in Condition 

5.26.1. The annual emissions report shall be submitted to EPA at the address listed in 

Condition 5.26.4 of this permit.

5.26.7 Fee calculation worksheets shall be certified as to truth, accuracy, and completeness by a 

responsible official in accordance with Condition 5.13 of this permit.

5.26.8 The permittee shall retain, in accordance with the provisions of Conditions 5.16.4 and 

5.16.5 of this permit, all worksheets and other materials used to determine fee payments. 

Records shall be retained for five years following the year in which the emissions data is 

submitted.

5.26.9 Failure of the permittee to pay fees in a timely manner shall subject the permittee to 

assessment of penalties and interest.

5.26.10 The permittee, when notified by EPA of additional amounts due, shall remit full payment 

within 30 days of receipt of an invoice from EPA.

5.26.11 If the permittee believes that an EPA-assessed fee is in error and wishes to challenge such 

fee, the permittee shall provide a written explanation of the alleged error to EPA along 

with full payment of the EPA assessed fee.

[40 CFR § 71.9]

6 SPECIFIC CONDITIONS

6.1 Drill Site Notification

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

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

6.1.1 the location of the proposed drill site, using coordinates in latitude/longitude and 

Universal Transverse Mercator grid system formats;
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

20

6.1.2 the proposed date that the drillship will enter the lease block and commence construction 

or operation and the probable duration of operation at that location; and

6.1.3 the certification of maintenance and no physical changes required by Condition 6.6.1.1 (if 

applicable); and

6.1.4 not less than 24 hours prior to commencing construction or operation, of any changes to 

the information provided by the permittee in Conditions 6.1.

[40 CFR §§ 71.6(a)(6)(v), 52.21 and 55.8]

6.2 Drilling Limitations

6.2.1 The total combined hours for drilling and well completion by the Discoverer Spirit shall 

not exceed 4,992 hours per year on a rolling 12-month basis.

6.2.2 The permittee shall maintain a record of operating hours and sum such hours on a rolling 

12-month basis.

6.2.3 A report providing the rolling 12-month totals shall be submitted with the annual 

compliance certification in accordance with Condition 5.20.

[40 CFR § 55.6(a)]

6.3 Support Vessel Identification

6.3.1 The permittee shall maintain records, in accordance with Condition 5.16, of the engine 

specifications and number of hours each engine is operated within 25 miles of the 

Discover Spirit for any support vessel used in place of the HOS Coral (supply boat), the 

Kirt Chouest (anchor handling boat), or any vessel used during well completion.

6.3.2 These records, as well as a table of engine emission factors used and calculated mass 

emissions in tons per year of each regulated pollutant, shall be submitted as part of the 

Annual Compliance Certification in accordance with Condition 5.20.

[40 CFR § 55.8]

6.4 Source-wide SO2 Emission Limit

The permittee shall not combust any diesel fuel with a sulfur content greater than 15 parts per million 

(ppm) by weight, as determined by Condition 6.4.1, in any diesel fueled emission unit on the Discoverer 

Spirit or on any support vessel.

6.4.1 The permittee shall obtain a certification of sulfur content from the fuel supplier for all 

diesel fuel used on the Discoverer Spirit, and all equipment and vessels used during well 

completion (the certification must indicate the sulfur content was determined by an 

approved EPA method), or the permittee shall obtain representative fuel samples using 

one of the methods in 40 CFR 80.330 and shall determine the sulfur content of the fuel 

using one of the methods in 40 CFR 80.580.

6.4.2 Monitoring, Recordkeeping and Reporting
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.4.2.1 Prior to mobilizing the Discoverer Spirit for activities covered by this permit, 

the permittee shall determine and record the sulfur content of the diesel fuel 

on the Discoverer Spirit and the support vessels using the procedures in 

Condition 6.4.1.

6.4.2.2 Thereafter, the permittee shall determine and record the sulfur content of the 

diesel fuel on the Discoverer Spirit and the support vessels using the 

procedures in Condition 6.4.1 upon receiving each fuel shipment.

6.4.3 The permittee shall provide the records required by Condition 6.4.2 and the 

certification(s) of sulfur content or results of all fuel sample analyses required by 

Conditions 6.4.1 and 6.4.2 with the Annual Compliance Certification required by 

Condition 5.20.

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

6.5 Source-wide Greenhouse Gas Emissions Limits 

6.5.1 The permittee shall not discharge or cause the discharge into the atmosphere in excess of 

the following limit for the total emissions from all permitted units on the Discoverer 

Spirit drilling vessel and support vessels:

6.5.1.1 CO2e: 74,571 tons per year on a 12-month rolling total.

6.5.2 The permittee shall calculate and maintain a record of monthly fuel consumption as 

required by Conditions 6.7.20, 6.8.2, 6.9.2, 6.10.2, and 6.11, and determine emissions 

from all diesel units by multiplying fuel usage by the respective pollutant-specific 

emissions rates from the most up-to-date emission factors or from the emission 

certificates for each unit, and determine emissions from all non-diesel units by 

multiplying total hours of operation for each non-diesel unit by the pollutant-specific 

emissions rates presented in the application.

6.5.3 The permittee shall provide the records required by Condition 6.5.2 and a summary table 

of CO2e tons per year on a 12-month rolling total basis with the Annual Compliance 

Certification required by Condition 5.20.

6.5.4 Global Warming Potential (GWP)

For the purposes of showing compliance with any GHG emission limit in this permit, the 

GWP factors listed in 40 CFR Part 98 Subpart A, Table A-1 as of the date of this permit 

shall be used. The current GWP factors are listed below:

GHG Pollutant GWP Factor

CO2 1

CH4 21

N2O 310

SF6 23,900
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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[40 CFR § 98 Subpart A]

6.6 General Stack Test Requirements 

6.6.1 Within 90 days of the start of drilling that the drilling vessel operates under this permit, the 

six main engines (DR-GE-01 through DR-GE-06) of the Discoverer Spirit shall have been 

stack tested under the requirements of Condition 6.6 and Condition 5.25 within the 

previous 12-month period. 

6.6.1.1 If, after the initial stack tests, the drilling vessel discontinues drilling under the 

permit for more than 12 months, the permittee shall certify that a continuous 

maintenance program has been conducted and that no physical changes that could 

impact emissions have occurred since the latest stack test, or the permittee shall 

conduct a new stack test prior to restarting drilling operations in accordance with 

the general stack testing requirements set forth in Condition 5.25 and Conditions 

6.6.2 through 6.6.6. 

6.6.1.2 If a continuous maintenance program is selected from the options in Condition 

6.6.1.1, the certification shall be included with the drill site notification required 

pursuant to Condition 6.1. Maintenance records shall be kept in accordance with 

the recordkeeping requirements set forth in Condition 5.16

6.6.2 Each stack test shall be conducted by using stack testing data collected according to an 

EPA-approved source test plan set forth in Condition 5.25. 

6.6.3 Each stack test shall be conducted at three different loads spanning the expected range of 

operations.

6.6.4 At a minimum, each stack test run shall test for emissions of CO, CO2, NOX, PM2.5, PM10, 

VOC, and visible emissions.

6.6.5 During each test run, the permittee shall monitor and record the following information:

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

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

6.6.5.3 Electrical power produced (in kW-hr). 

6.6.6 For each engine, each load, and each pollutant (CO, CO2, NOX, PM, PM2.5, PM10, VOC), 

the permittee shall determine emission rates in g/kW-hr. Pollutant test data obtained in 

accordance with Condition 6.6 or fuel usage monitoring data may be used to calculate CO2

and PM.

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

6.7 Discoverer Spirit Emission and Operating Limits

6.7.1 Source Identification: DR-GE-01 through -06, main propulsion generator engines.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

23

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

atmosphere from each engine in excess of:

6.7.1.1.1 NOX BACT Limit: 12.7 g/kW-hr on a rolling 24-hour average 

basis.

6.7.1.1.2 CO BACT Limit: 0.8 g/kW-hr on a rolling 24-hour average basis.

6.7.1.1.3 VOC BACT Limit: 0.08 lb/MMBtu (0.13 g/kW-hr) on a rolling 

24-hour average basis.

6.7.1.1.4 PM BACT Limit: 0.1 lb/MMBtu (0.15 g/kW-hr) on a rolling 24-

hour average basis.

6.7.1.1.5 PM10/ PM2.5 BACT Limit: 0.06 lb/MMBtu (0.09 g/kW-hr) on a 

rolling 24-hour average basis.

6.7.1.2 The permittee shall use the following BACT work practice standards:

6.7.1.2.1 main propulsion generator engines with turbocharger, aftercooler, 

and high injection pressure;

6.7.1.2.2 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight;

6.7.1.2.3 engines certified to IMO Tier I (40 CFR § 94.8) (or better); 

6.7.1.2.4 good combustion practices based on the most recent 

manufacturer’s specifications issued for these engines at the time 

that the engines are operating under this permit; and

6.7.1.2.5 a Power Management System (PMS) and NOx concentration 

maintenance system as defined in the permit application received 

(by EPA) and found in the administrative record. The permittee 

will develop and implement an enhanced monitoring protocol and 

NOx concentration maintenance system, which at a minimum shall 

include the following:

6.7.1.2.5.1 indicator ranges that will trigger an alarm if the NOx

concentration reaches a specified threshold, at which time 

the operator will investigate the cause of the emission 

increase and determine corrective action; 

6.7.1.2.5.2 development and implementation of the enhanced 

maintenance protocol to ensure good combustion 

practices; 

6.7.1.2.5.3 enhanced load management of the engines to maintain 

load levels to ensure combustion efficiency.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.1.2.6 The permittee shall monitor and record the following parameters 

from the PMS once every 30 seconds for 30 minutes twice a day:

 Charge Air Pressure (kPa) after air cooler

 Charge Air Temperature (Celsius) after air cooler

 Turbocharger RPM A&B (RPM)

 Engine Air Inlet Pressure (kPa)

 Engine Air Inlet Temperature (Celsius)

 Engine Air Inlet Relative Humidity (g/kG)

 Generator Load (kW)

 NOx and CO (ppm); and CO2 (%) Emission 

Concentration 

6.7.1.2.7 A PMS equivalent to the one identified in the application may be 

used with prior written EPA approval.

6.7.1.2.8 The permittee shall submit the enhanced monitoring and NOx

concentration maintenance protocol with the annual compliance 

report as defined in Condition 5.20.

6.7.1.3 Monitoring and Recordkeeping:

6.7.1.3.1 The permittee shall monitor and record NOX, CO, VOC, and 

PM/PM10/PM2.5 emissions (at a determined reference O2 or CO2

concentration) from the main engines by the use of an EPAapproved parametric monitoring method as described in Condition 

6.7.1.3.1.1; or an EPA-approved continuous emissions monitoring 

system described in Condition 6.7.1.3.1.2; or, with prior written 

approval by EPA, a stack testing emissions monitoring system as 

described in Condition 6.7.1.3.1.3; or, with prior written approval 

of EPA, a combination of these methods. 

6.7.1.3.1.1 Parametric Monitoring

6.7.1.3.1.1.1 The permittee shall properly monitor and record 

emissions of one or more of the subject regulated air 

pollutants (NOX, CO, VOC, and PM/PM10/PM2.5)

emissions from the main generator diesel units 

specified in Condition 6.7.1 by using a parametric 

monitoring system such as the Power Management

System (PMS) monitoring system or a parametric 

monitoring system equivalent to PMS. The permittee 

may use a parametric monitoring system equivalent to 

PMS only upon prior written approval by EPA.

6.7.1.3.1.1.2 The permittee shall monitor and record the following 

parameters once every 30 seconds for 30 minutes 

twice a day:

 Charge Air Pressure (kPa) after air cooler
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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 Charge Air Temperature (Celsius) after air 

cooler

 Turbocharger RPM A& B (RPM)

 Engine Air Inlet Pressure (kPa)

 Engine Air Inlet Temperature (Celsius)

 Engine Air Inlet Relative Humidity (g/kg)

 Generator Load (kW)

 NOx, CO, and SO2 (ppm); and CO2 (%) 

Emission Concentration 

6.7.1.3.1.1.3 The permittee shall record the date and time of the 

most recent NOx analyzer calibration, the calibration 

results from the NOx analyzer, and the calibration 

method used. 

6.7.1.3.1.2 Continuous Emissions Monitoring 

6.7.1.3.1.2.1 The permittee shall install, calibrate, maintain, and 

operate a continuous emissions monitoring system 

(CEMS) in accordance with a plan submitted by the 

permittee to the EPA and subsequently approved by 

the EPA to monitor and record emissions from the 

main generator engines specified in Condition 6.7.1.

6.7.1.3.1.2.2 The permittee shall obtain stack gas volumetric flow 

rates using a calibrated flow monitor that records data 

on a continuous basis.

6.7.1.3.1.2.3 The permittee shall monitor and record engine 

electric power output in kW-hr that corresponds to 

emissions readings taken by the CEMS.

6.7.1.3.1.2.4 The quality assurance plan used by the permittee for 

the certification and operation of the continuous 

emissions monitoring system shall be included with 

the plan described in Condition 6.7.1.3.1.2.1.

6.7.1.3.1.3 Stack Testing Emissions Monitoring

6.7.1.3.1.3.1 The permittee shall properly monitor and record 

emissions from diesel engines specified in Condition

6.7.1 by collecting stack testing data within 12 

months preceding the commencement of operation or 

within 3 months following the commencement of 

operation according to an EPA approved protocol and 

in accordance with Conditions 5.25 and 6.7.1.3.1.3.2

through 6.7.1.3.1.3.6. Data collected prior to issuance 

of this permit may be used with written EPA 

approval. After three annual/periodic stack tests of 

the same drilling vessel, stack test frequency may be 

reduced upon written approval by the EPA.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.1.3.1.3.2 Each stack test shall be conducted at three different 

loads spanning the expected range of operations.

6.7.1.3.1.3.3 During each test run, the permittee shall monitor and 

record the following information: 

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

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

and 

 Electrical power produced (in kW-hr). 

6.7.1.3.1.3.4 The permittee shall prepare a graph of engine load 

versus emission rates expressed in g/kW-hr for each 

engine. Plot the engine load as the independent (or x) 

variable and the pollutant emission rates as the 

dependent (or y) variable for each load point tested. 

Construct the graph by drawing straight-line segments 

between each load point. Draw a horizontal line to the 

y-axis from the minimum load point tested.

6.7.1.3.1.3.5 The permittee shall use the load information with the 

graph of engine load versus emission rates to 

determine the emission rate in g/kW-hr for each 

engine load recorded. Linear interpolation shall be 

used to determine the emission rate when the actual 

load falls between two tested load points, the 

permittee shall use linear interpolation between the 

two load points to determine the emission rate. When 

the engine load exceeds the maximum load measured 

during the stack testing, the g/kW-hr emission rate 

obtained for the highest load point tested during the 

most recent stack test may be used. When records of 

engine load are not available, the highest g/kW-hr 

emission rate calculated for all the load points tested 

during the most recent stack test may be substituted. 

The average emission rate for each hour of operation 

from all individual emission rate results recorded 

during the hour will then be calculated.

6.7.1.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.1 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17. 

6.7.2 Source Identification: DR-GE-07, emergency engine.

6.7.2.1 The permittee shall use the following BACT work practice standards:

6.7.2.1.1 an emergency diesel engine with turbocharger, aftercooler, and 

high injection pressure;
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.2.1.2 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight, and

6.7.2.1.3 good combustion practices based on the most recent 

manufacturer’s specifications issued for this engine at the time that 

the engine is operating under this permit.

6.7.2.2 Operating Limit: This unit shall be operated no more than 100 hours per year 

of non-emergency, planned operation time on a 12-month rolling total basis.

6.7.2.3 The permittee shall maintain a record of hours of operation and sum such 

hours on a rolling 12-month basis. Hours of operation shall be recorded 

monthly from a non-resettable hour meter or, if such a meter is not available, 

by monitoring and maintaining a contemporaneous record of the following 

information:

6.7.2.3.1 unit ID;

6.7.2.3.2 date/time engine started;

6.7.2.3.3 date/time engine shut down;

6.7.2.3.4 name of person operating equipment (printed); and

6.7.2.3.5 signature of person operating equipment.

6.7.2.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.2 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17. 

6.7.3 Source Identification: DR-GE-08, remotely operated vehicle emergency generator.

6.7.3.1 The permittee shall use the following BACT work practice standards:

6.7.3.1.1 a remotely operated vehicle emergency generator with 

turbocharger, aftercooler, and high injection pressure;

6.7.3.1.2 an engine certified to EPA Tier 2 nonroad engine (40 CFR § 89) 

(or better);

6.7.3.1.3 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight, and

6.7.3.1.4 good combustion practices based on the most recent 

manufacturer’s specifications issued for this engine at the time that 

the engine is operating under this permit.

6.7.3.2 Operating Limit: This unit shall be operated no more than 100 hours per year 

of non-emergency, planned operation time combined on a 12-month rolling 

total basis.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.3.3 The permittee shall maintain a record of hours of operation and sum such 

hours on a rolling 12-month basis. Hours of operation shall be recorded 

monthly from a non-resettable hour meter or, if such a meter is not available, 

by monitoring and maintaining a contemporaneous record of the following 

information:

6.7.3.3.1 unit ID;

6.7.3.3.2 date/time engine started;

6.7.3.3.3 date/time engine shut down;

6.7.3.3.4 name of person operating equipment (printed); and

6.7.3.3.5 signature of person operating equipment.

6.7.3.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.3 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17. 

6.7.4 Source Identification: DR-AC-01 and DR-AC-02, air compressor engines.

6.7.4.1 The permittee shall use the following BACT work practice standards:

6.7.4.1.1 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight, and

6.7.4.1.2 good combustion practices based on the most recent 

manufacturer’s specifications issued for these engines at the time 

that the engines are operating under this permit.

6.7.4.2 Operating Limit: These units shall be operated no more than 104 hours per 

year each on a 12-month rolling total basis.

6.7.4.3 The permittee shall maintain a record of hours of operation for each engine 

and a record of the sum of such hours for each engine on a rolling 12-month 

basis. Hours of operation shall be recorded monthly from a non-resettable 

hour meter or, if such a meter is not available, by monitoring and maintaining

a contemporaneous record of the following information:

6.7.4.3.1 unit ID;

6.7.4.3.2 date/time engine started;

6.7.4.3.3 date/time engine shut down;

6.7.4.3.4 name of person operating equipment (printed); and

6.7.4.3.5 signature of person operating equipment.

6.7.4.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.4 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17. 

6.7.5 Source Identification: DR-FL-01, diesel powered forklift engine.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.5.1 The permittee shall use the following work practice standards:

6.7.5.1.1 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight, and

6.7.5.1.2 good combustion practices based on the most recent 

manufacturer’s specifications issued for this engine at the time that 

the engine is operating under this permit.

6.7.5.2 Operating Limit: This unit shall be operated no more than 4,992 hours per 

year on a 12-month rolling total basis.

6.7.5.3 The permittee shall maintain a record of hours of operation and sum such 

hours on a rolling 12-month basis. Hours of operation shall be recorded 

monthly from a non-resettable hour meter or, if such a meter is not available, 

by monitoring and maintaining a contemporaneous record of the following 

information:

6.7.5.3.1 unit ID;

6.7.5.3.2 date/time engine started;

6.7.5.3.3 date/time engine shut down;

6.7.5.3.4 name of person operating equipment (printed); and

6.7.5.3.5 signature of person operating equipment.

6.7.5.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.5 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17. 

6.7.6 Source Identification: DR-FR-01, fast rescue craft engine with turbocharger, aftercooler 

and high injection pressure.

6.7.6.1 The permittee shall use the following work practice standards:

6.7.6.1.1 a remotely operated vehicle emergency generator with 

turbocharger, aftercooler, and high injection pressure;

6.7.6.1.2 an engine certified to EPA Tier 2 nonroad engine (40 CFR § 89)

(or better);

6.7.6.1.3 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight, and

6.7.6.1.4 good combustion practices based on the most recent 

manufacturer’s specifications issued for this engine at the time that 

the engine is operating under this permit.

6.7.6.2 Operating Limit: This unit shall be operated no more than 100 hours per year 

on a 12-month rolling total basis.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.6.3 The permittee shall maintain a record of hours of operation and sum such 

hours on a rolling 12-month basis. Hours of operation shall be recorded 

monthly from a non-resettable hour meter or, if such a meter is not available, 

by monitoring and maintaining a contemporaneous record of the following 

information:

6.7.6.3.1 unit ID;

6.7.6.3.2 date/time engine started;

6.7.6.3.3 date/time engine shut down;

6.7.6.3.4 name of person operating equipment (printed); and

6.7.6.3.5 signature of person operating equipment.

6.7.6.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.6 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17.

6.7.7 Source Identification: DR-EC-01 through DR-EC-06, escape capsule engines.

6.7.7.1 The permittee shall use the following work practice standards:

6.7.7.1.1 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight, and

6.7.7.1.2 good combustion practices based on the most recent 

manufacturer’s specifications issued for these engines at the time 

that the engines are operating under this permit.

6.7.7.2 Operating Limit: These units shall be operated no more than 100 hours per 

year total each of non-emergency, planned operation time on a 12-month 

rolling total basis.

6.7.7.3 The permittee shall maintain a record of hours of operation for each engine 

and a record of the sum of such hours for each engine on a rolling 12-month 

basis. Hours of operation shall be recorded monthly from a non-resettable 

hour meter or, if such a meter is not available, by monitoring and maintaining

a contemporaneous record of the following information:

6.7.7.3.1 unit ID;

6.7.7.3.2 date/time engine started;

6.7.7.3.3 date/time engine shut down;

6.7.7.3.4 name of person operating equipment (printed); and

6.7.7.3.5 signature of person operating equipment.

6.7.7.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.7 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17. 
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.8 Source Identification: DR-DC-01 and DR-DC-02, mud and cement mixing, equipped 

with dust collectors.

6.7.8.1 The permittee shall use the following BACT work practice standard: proper 

maintenance and operation of the dust collectors in accordance with current 

manufacturer specifications.

6.7.8.2 The permittee shall ensure that the dust collector bin is not over capacity, and 

report any times where there is a high-level alarm, at which time the operator 

will investigate the cause and take corrective actions. For each high alarm 

event, the permittee shall record the following:

6.7.8.2.1 unit ID;

6.7.8.2.2 date/time of alarm;

6.7.8.2.3 corrective action taken, if any;

6.7.8.2.4 name of person operating equipment (printed); and

6.7.8.2.5 signature of person operating equipment.

6.7.8.1 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.8 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17.

6.7.9 Source Identification: DR-DC-03, mud and cement mixing, equipped with dust collector.

6.7.9.1 The permittee shall use the following BACT work practice standard: proper 

maintenance and operation of the dust collector in accordance with current 

manufacturer specifications including maintaining a constant minimum air 

supply pressure reading (at the cyclone-filter pressure regulator gauge) 

between 90 and 105 psi, for the volume based upon 0.9 SCFM per pulse.

6.7.9.2 The permittee shall perform a daily visual check of air supply pressure 

reading, and record the following:

6.7.9.2.1 unit ID;

6.7.9.2.2 date/time visual inspection;

6.7.9.2.3 air pressure at time of reading;

6.7.9.2.4 name of person operating equipment (printed); and

6.7.9.2.5 signature of person operating equipment.

6.7.9.3 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.9 shall be submitted to EPA by the permittee in accordance with the 

reporting specifications detailed in Condition 5.17. 

6.7.10 Source Identification: DR-VG-01, mud degassing operations.

6.7.10.1 VOC BACT Emission Limit: 5.57 tons per year on a 12-month rolling total 

basis.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

32

6.7.10.2 The permittee shall use the following BACT work practice standard: proper 

maintenance and operation of the mud degassing operations units in 

accordance with current manufacturer specifications.

6.7.10.3 The permittee shall monitor and record the daily throughput of the synthetic 

based mud.

6.7.10.1 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.10 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.11 Source Identification: DR-WL-01 and DR-WL-02, wireline engines; DR-EL-01 and DREL-02, electric line engines; DR-CU-01 and DR-CU-02, casing unit engines; DR-WC01, tubing running engine; DR-WC-02, fluid filtration pump engine; DR-WC-03, eline 

powerpack engine; DR-WC-04, slickline powerpack engine; DR-WC-07, CT powerpack 

engine; DR-WC-08, CT pump engine; and DR-WC-09 and DR-WC-10, wireline unit 

engines #3 and #4.

6.7.11.1 The permittee shall use the following BACT work practice standards:

6.7.11.1.1 engines with turbocharger, aftercooler, and high injection pressure;

6.7.11.1.2 engines certified to EPA Tier 2 nonroad engine (40 CFR § 89) (or 

better);

6.7.11.1.3 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight; and

6.7.11.1.4 good combustion practices based on the most recent 

manufacturer’s specifications issued for these engines at the time 

that the engines are operating under this permit.

6.7.11.2 Operating Limit for DR-WL-01 and DR-WL-02, wireline engines; DR-EL-01 

and DR-EL-02, electric line engines; DR-CU-01 and DR-CU-02, casing unit 

engines: These units shall be operated no more than 4,992 hours per year each

on a 12-month rolling total basis.

6.7.11.3 Operating Limit for DR-WC-01, tubing running engine: This unit shall be 

operated no more than 684 hours per year on a 12-month rolling total basis.

6.7.11.4 Operating Limit for DR-WC-02, fluid filtration pump engine: This unit shall 

be operated no more than 1,008 hours per year on a 12-month rolling total 

basis.

6.7.11.5 Operating Limit for DR-WC-03, eline powerpack engine; DR-WC-07, CT 

powerpack engine; DR-WC-08, CT pump engine: These units shall be 

operated no more than 720 hours per year combined on a 12-month rolling 

total basis.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.11.6 Operating Limit for DR-WC-04, slickline powerpack engine; DR-WC-09 and 

DR-WC-10, wireline unit engines #3 and #4: These units shall be operated no 

more than 1,440 hours per year combined on a 12-month rolling total basis.

6.7.11.7 The permittee shall maintain a record of hours of operation for each engine 

and a record of the sum such hours for each engine on a rolling 12-month 

basis. Hours of operation shall be recorded monthly from a non-resettable 

hour meter or, if such a meter is not available, by monitoring and maintaining

a contemporaneous record of the following information:

6.7.11.7.1 unit ID;

6.7.11.7.2 engine tier certification;

6.7.11.7.3 date/time engine started;

6.7.11.7.4 date/time engine shut down;

6.7.11.7.5 name of person operating equipment (printed); and

6.7.11.7.6 signature of person operating equipment.

6.7.11.8 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.11 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.12 Source Identification: DR-WB-01, water blasting engine.

6.7.12.1 The permittee shall use the following BACT work practice standards:

6.7.12.1.1 a water blasting engine with turbocharger, aftercooler, and high 

injection pressure;

6.7.12.1.2 engine certified to EPA Tier 3 nonroad engine (40 CFR § 89) (or 

better);

6.7.12.1.3 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight; and

6.7.12.1.4 good combustion practices based on the most recent 

manufacturer’s specifications issued for this engine at the time that 

the engine is operating under this permit .

6.7.12.2 Operating Limit: This unit shall be operated no more than 2,496 hours per 

year on a 12-month rolling total basis.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.12.3 The permittee shall maintain a record of hours of operation and sum such 

hours on a rolling 12-month basis. Hours of operation shall be recorded 

monthly from a non-resettable hour meter or, if such a meter is not available, 

by monitoring and maintaining a contemporaneous record of the following 

information:

6.7.12.3.1 unit ID;

6.7.12.3.2 engine tier certification;

6.7.12.3.3 date/time engine started;

6.7.12.3.4 date/time engine shut down;

6.7.12.3.5 name of person operating equipment (printed); and

6.7.12.3.6 signature of person operating equipment.

6.7.12.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.12 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.13 Source Identification: DR-VS-01 through DR-VS-05, well evaluation engines.

6.7.13.1 The permittee shall use the following BACT work practice standards:

6.7.13.1.1 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight, and

6.7.13.1.2 good combustion practices based on the most recent 

manufacturer’s specifications issued for these engines at the time 

that the engines are operating under this permit.

6.7.13.2 Operating Limit: These units shall be operated no more than 125 hours per 

year each on a 12-month rolling total basis.

6.7.13.3 The permittee shall maintain a record of hours of operation for each engine 

and a record of the sum of such hours for each engine on a rolling 12-month 

basis. Hours of operation shall be recorded monthly from a non-resettable 

hour meter or, if such a meter is not available, by monitoring and maintaining

a contemporaneous record of the following information:

6.7.13.3.1 unit ID;

6.7.13.3.2 engine tier certification;

6.7.13.3.3 date/time engine started;

6.7.13.3.4 date/time engine shut down;

6.7.13.3.5 name of person operating equipment (printed); and

6.7.13.3.6 signature of person operating equipment.

6.7.13.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.13 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.14 Source Identification: DR-WC-05, flowback boiler.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.14.1 The permittee shall use the following BACT work practice standards:

6.7.14.1.1 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight; and

6.7.14.1.2 good combustion practices based on the most recent 

manufacturer’s specifications issued for this boiler at the time that 

the boiler is operating under this permit.

6.7.14.2 Operating Limit: This unit shall be operated no more than 144 hours per year 

combined on a 12-month rolling total basis.

6.7.14.3 The permittee shall maintain a record of hours of operation and sum such 

hours on a rolling 12-month basis. Hours of operation shall be recorded 

monthly from a non-resettable hour meter or, if such a meter is not available, 

by monitoring and maintaining a contemporaneous record of the following 

information:

6.7.14.3.1 unit ID;

6.7.14.3.2 date/time boiler started;

6.7.14.3.3 date/time boiler shut down;

6.7.14.3.4 name of person operating equipment (printed); and

6.7.14.3.5 signature of person operating equipment.

6.7.14.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.14 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.15 Source Identification: DR-WC-06, boom flare.

6.7.15.1 The permittee shall use the following BACT work practice standards:

6.7.15.1.1 maintain compliance with 40 CFR 60.18; and

6.7.15.1.2 use good combustion practices and proper flare maintenance.

6.7.15.2 Operating Limit: Non-emergency flaring shall be limited to no more than 144

hours per year on a 12-month rolling total basis.

6.7.15.3 The permittee shall monitor and maintain a record of the following:

6.7.15.3.1 date/duration of each flaring episode;

6.7.15.3.2 type of fuel burned; and 

6.7.15.3.3 hours of operation and sum such hours on a rolling 12-month basis.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.15.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.15 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17.

6.7.16 Source Identification: DR-PO-01, painting operations.

6.7.16.1 The permittee shall use the following BACT work practice standards:

6.7.16.1.1 best management practices that include, but are not limited to: 

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 

whenever practical to prevent the airborne particulate matter from 

drifting into the atmosphere, and proper storage of coatings (and 

thinners) in non-leaking containers; and

6.7.16.1.2 either an airless spray gun with transfer efficiency of 50% or 

greater, or an air assisted spray gun with transfer efficiency of 30% 

or greater for all coating operations.

6.7.16.2 Operating Limits: The airless spray gun shall be limited to 57 and 24 gallons 

per calendar week of primer and thinner, respectively.

6.7.16.3 Operating Limits: The air assisted spray gun shall be limited to 60 and 25 

gallons per calendar week of primer and thinner, respectively.

6.7.16.4 The permittee shall maintain and record the types and amounts (in gallons) of 

coatings and thinners used on a weekly basis. Also, MSDS information for all

coatings and thinners used must be kept on file.

6.7.16.5 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.16 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.17 Source Identification: DR-WO-01, welding operations.

6.7.17.1 The permittee shall use the following BACT work practice standard: follow

current manufacturer’s recommendations for all equipment used in welding 

operations, including but not limited to, voltage levels. 

6.7.17.2 The permittee shall maintain an accurate account of the quantity (in pounds)

and type of welding rods used during the duration of the project.

6.7.17.3 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.17 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.18 Source Identification: DR-DT-01 through DR-DT-09 and DR-FT-01 through DR-FT-03, 

storage tanks; and WC-CT-01 through WC-CT-03, condensate tanks.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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

atmosphere from the storage tanks combined in excess of:

6.7.18.1.1 VOC BACT Emission Limit for DR-DT-01 through DR-DT-09 

and DR-FT-01 through DR-FT-03: 0.71 tons per year on a 12-

month rolling total basis.

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

atmosphere from the condensate tanks combined in excess of:

6.7.18.1.1 VOC BACT Emission Limit for WC-CT-01 through WC-CT-03: 

9.26 tons per year on a 12-month rolling total basis.

6.7.18.2 The permittee shall use the following BACT work practice 

standard: good maintenance practices.

6.7.18.3 The permittee shall use EPA’s TANKS 4.0.9d program to calculate emissions 

for the semi-annual report.

6.7.18.4 The permittee shall monitor and maintain the following information:

6.7.18.4.1 unit ID; and

6.7.18.4.2 the dimensions, fuel type or condensate stored, and capacities of 

units DR-DT-01 through DR-DT-09, DR-FT-01 through DR-FT03, and WC-CT-01 through WC-CT-03. 

6.7.18.5 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.18 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.19 Source Identification: DR-FE-01, fugitive emissions.

6.7.19.1 The permittee shall use the following BACT work practice standard: good 

maintenance practices to minimize fugitive emissions; including minimizing 

the release of emissions from valves, pump seals, and connectors.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.7.19.2 Compliance will be assured by performing a daily check to ensure that there 

are no leaks. Upon detection of a leak, the permittee shall maintain and record 

the following information:

6.7.19.2.1 date/duration of leak detection from critical components; 

6.7.19.2.2 type of component; 

6.7.19.2.3 method of detection;

6.7.19.2.4 corrective action taken;

6.7.19.2.5 date of component reinspection;

6.7.19.2.6 name of person inspecting equipment (printed); and

6.7.19.2.7 signature of person inspecting equipment.

6.7.19.3 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.19 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

6.7.20 Fuel Use Limit

6.7.20.1 Operating Limit: The OCS source shall not use more than 425 barrels (17,850 

gallons) per day of diesel fuel, not to exceed 67,600 barrels (2,840,336

gallons) of diesel fuel on a 12-month total basis.

6.7.20.2 The permittee shall maintain a record of fuel consumption for the duration of 

the project.

6.7.20.3 The permittee shall monitor and maintain a record of the following 

information:

6.7.20.3.1 initial number of barrels/gallons of diesel fuel on the OCS source

at the beginning of the project;

6.7.20.3.2 date of each diesel fuel delivery;

6.7.20.3.3 number of barrels/gallons of diesel fuel in each delivery;

6.7.20.3.4 name of person recording delivery (printed);

6.7.20.3.5 signature of recorder; and

6.7.20.3.6 final number of barrels/gallons of diesel fuel on the OCS source at 

the end of the project.

6.7.20.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.7.20 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17. 

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

6.8 Stimulation Vessel Emission and Operating Limits

6.8.1 Source Identification: SV-PE-01 through SV-PE-08, stimulation vessel pump engines.

6.8.1.1 The permittee shall use the following BACT work practice standards:

6.8.1.1.1 diesel fuel with sulfur content less than or equal to 15 ppm by 

weight; and
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.8.1.1.2 good combustion practices based on the most recent 

manufacturer’s specifications issued for these engines at the time 

that the engines are operating under this permit.

6.8.1.2 Operating Limit: These units shall be operated no more than 504 hours per 

year each on a 12-month rolling total basis.

6.8.1.3 The permittee shall maintain a record of hours of operation for each engine 

and a record of the sum of such hours for each engine on a rolling 12-month 

basis. Hours of operation shall be recorded monthly from a non-resettable 

hour meter or, if such a meter is not available, by monitoring and maintaining

a contemporaneous record of the following information:

6.8.1.3.1 unit ID;

6.8.1.3.2 unit rating;

6.8.1.3.3 date/time engine started;

6.8.1.3.4 date/time engine shut down;

6.8.1.3.5 name of person operating equipment (printed); and

6.8.1.3.6 signature of person operating equipment.

6.8.1.4 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.8.1 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17. 

6.8.2 Stimulation Vessel Fuel Consumption Limit

6.8.2.1 The stimulation vessel or substitute stimulation vessel (with equivalent or 

lower potential emissions) shall not use more than 21,008 gallons (500 

barrels) of diesel fuel per day when within 25 miles of the drilling vessel.

6.8.2.2 The stimulation vessel or substitute stimulation vessel shall not use any diesel 

fuel with sulfur content greater than 15 ppm by weight.

6.8.2.3 The permittee shall monitor and maintain a contemporaneous record of the 

following information:

6.8.2.3.1 operating time and diesel fuel use within the 25-nautical mile 

radius of the Discoverer Spirit; and

6.8.2.3.2 a record of the sulfur content upon receiving each fuel shipment as 

specified in Condition 6.4.

6.8.2.4 Monitoring and Recordkeeping Requirements: The permittee shall monitor 

and maintain a contemporaneous record of the following information:

6.8.2.4.1 name of vessel;

6.8.2.4.2 units onboard vessel, with short description and applicable ratings 

of each unit;

6.8.2.4.3 date/time entering the 25 nautical mile radius;

6.8.2.4.4 date/time exiting the 25 nautical mile radius;
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

40

6.8.2.4.5 sulfur content of all fuel used in any engine as specified in

Condition 6.4;

6.8.2.4.6 gallons of diesel fuel on the vessel entering the 25 nautical mile 

radius; 

6.8.2.4.7 gallons of diesel fuel on the vessel exiting the 25 nautical mile 

radius; and

6.8.2.4.8 gallons of diesel fuel loaded on to the vessel within the 25 nautical 

mile radius.

6.8.2.5 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.8.2 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17.

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

6.9 Supply Boat Emission and Operating Limits

6.9.1 Source Identification: SB-DT-01 through SB-DT-15, storage tanks.

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

atmosphere from the storage tanks combined in excess of:

6.9.1.1.1 VOC BACT Emission Limit: 0.08 tons per year on a 12-month 

rolling total basis.

6.9.1.2 The permittee shall use the following BACT work practice standard: good 

maintenance practices.

6.9.1.3 The permittee shall use EPA’s TANKS 4.0.9d program to calculate emissions 

for the semi-annual report.

6.9.1.4 The permittee shall monitor and maintain the following information:

6.9.1.4.1 Unit ID; and

6.9.1.4.2 the dimensions, fuel type or condensate stored, and capacities of 

units SB-DT-01 through SB-DT-15..

6.9.1.5 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.9.1 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17.

6.9.2 Supply boat fuel consumption limit

6.9.2.1 The supply boat HOS Coral or substitute supply boat (with equivalent or 

lower potential emissions) shall not use more than 17,098 gallons of diesel 

fuel per day when within 25 miles of the drilling vessel.

6.9.2.2 The supply boat or substitute supply boat shall not combust any diesel fuel 

with sulfur content greater than 15 ppm by weight.
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

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6.9.2.3 The permittee shall monitor and maintain a contemporaneous record of the 

following information:

6.9.2.3.1 operating time and diesel fuel use within the 25-nautical mile 

radius of the Discoverer Spirit; and

6.9.2.3.2 the sulfur content upon receiving each fuel shipment as specified in

Condition 6.4.

6.9.2.4 The permittee shall monitor and maintain a contemporaneous record with the

following information:

6.9.2.4.1 name of vessel;

6.9.2.4.2 units onboard vessel, with short description and applicable ratings 

of each unit;

6.9.2.4.3 date/time entering the 25 nautical mile radius;

6.9.2.4.4 date/time exiting the 25 nautical mile radius;

6.9.2.4.5 sulfur content of all fuel used in any engine as specified in

Condition 6.4;

6.9.2.4.6 gallons of diesel fuel on the vessel entering the 25 nautical mile 

radius; 

6.9.2.4.7 gallons of diesel fuel on the vessel exiting the 25 nautical mile 

radius; and

6.9.2.4.8 gallons of diesel fuel loaded on to the vessel within the 25 nautical 

mile radius.

6.9.2.5 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.9.2 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Condition 5.17..

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

6.10 Anchor Handling Boat Emission and Operating Limits

6.10.1 Source Identification: AB-DT-01 through AB-DT-19 condensate tanks.

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

atmosphere from the condensate tanks combined in excess of:

6.10.1.1.1 VOC BACT Emission Limit: 0.10 tons per year on a 12-month 

rolling total basis.

6.10.1.2 The permittee shall use the following BACT work practice standard: good 

maintenance practices.

6.10.1.3 The permittee shall use EPA’s TANKS 4.0.9d program to calculate emissions 

for the semi-annual report.

6.10.1.4 The permittee shall monitor and maintain the following information:

6.10.1.4.1 Unit ID; and
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6.10.1.4.2 The dimensions, fuel type or condensate stored, and capacities of 

units AB-DT-01 through AB-DT-19.

6.10.1.5 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.10.1 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17.

6.10.2 Anchor handling boat fuel consumption limit

6.10.2.1 The anchor handling boat Kirt Chouest or substitute anchor handling boat 

(with equivalent or lower potential emissions) shall not use more than 7,500 

gallons of diesel fuel per day when within 25 miles of the drilling vessel.

6.10.2.2 The anchor handling boat or substitute anchor handling boat shall not combust 

any diesel fuel with sulfur content greater than 15 ppm by weight.

6.10.2.3 The permittee shall monitor and maintain a contemporaneous record of the 

following information:

6.10.2.3.1 operating time and diesel fuel use within the 25-nautical mile 

radius of the Discoverer Spirit; and

6.10.2.3.2 the sulfur content upon receiving each fuel shipment as specified in 

Condition 6.4.

6.10.2.4 The permittee shall monitor and maintain a contemporaneous record with the 

following information:

6.10.2.4.1 name of vessel;

6.10.2.4.2 units onboard vessel, with short description and applicable ratings 

of each unit;

6.10.2.4.3 date/time entering the 25 nautical mile radius;

6.10.2.4.4 date/time exiting the 25 nautical mile radius;

6.10.2.4.5 sulfur content of all fuel used in any engine as specified in

Condition 6.4;

6.10.2.4.6 gallons of diesel fuel on the vessel entering the 25 nautical mile 

radius; 

6.10.2.4.7 gallons of diesel fuel on the vessel exiting the 25 nautical mile 

radius;

6.10.2.4.8 gallons of diesel fuel loaded on to the vessel within the 25 nautical 

mile radius.

6.10.2.5 All information required to be collected, recorded, or maintained pursuant to 

Condition 6.10.2 shall be submitted to EPA by the permittee in accordance 

with the reporting specifications detailed in Condition 5.17.

[40 CFR §§ 52.21, 55.2, 55.6(a)(4), 55.8 and 71.6(a)(1), (a)(3) and (c)(1)]
Anadarko OCS-EPA-R40015 [Draft 06/19/2014]

43

6.11 Tug Operating Limits

6.11.1 The Tug or substitute Tug (with equivalent or lower potential emissions) shall not use

more than 14,285 gallons (340 barrels) of diesel fuel per day when within 25 miles of the 

drilling vessel.

6.11.2 The tug or substitute tug shall not combust any diesel fuel with sulfur content greater than 

15 ppm by weight.

6.11.3 The permittee shall monitor and maintain a contemporaneous record of the following 

information:

6.11.3.1 operating time and diesel fuel use within the 25-nautical mile radius of the 

Discoverer Spirit.

6.11.3.2 the sulfur content upon receiving each fuel shipment as specified in Condition 

6.4.

6.11.4 The permittee shall monitor and maintain a contemporaneous record with the following 

information:

6.11.4.1 name of vessel;

6.11.4.2 units onboard vessel, with short description and applicable ratings of each 

unit;

6.11.4.3 date/time entering the 25 nautical mile radius;

6.11.4.4 date/time exiting the 25 nautical mile radius;

6.11.4.5 sulfur content of all fuel used in any engine as specified in Condition 6.4;

6.11.4.6 gallons of diesel fuel on the vessel entering the 25 nautical mile radius; 

6.11.4.7 gallons of diesel fuel on the vessel exiting the 25 nautical mile radius;

6.11.4.8 gallons of diesel fuel loaded on to the vessel within the 25 nautical mile 

radius.

6.11.5 All information required to be collected, recorded, or maintained pursuant to Condition 

6.11 shall be submitted to EPA by the permittee in accordance with the reporting 

specifications detailed in Condition 5.17.

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

6.12 Barge Electric Generator Operating Limits

6.12.1 The Barge or any substitute barge (with equivalent or lower potential emissions) shall not 

operate more than 504 hours per year on a rolling 12-month total basis when within 25 

miles of the drilling vessel.

6.12.2 The barge or any substitute barge shall not combust any diesel fuel with sulfur content 

greater than 15 ppm by weight.

6.12.3 The permittee shall monitor and maintain a contemporaneous record of the following 

information:
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44

6.12.3.1 operating time and diesel fuel use within the 25-nautical mile radius of the 

Discoverer Spirit.

6.12.3.2 the sulfur content upon receiving each fuel shipment as specified in Condition 

6.4.

6.12.4 The permittee shall monitor and maintain a contemporaneous record with the following 

information:

6.12.4.1 name of vessel;

6.12.4.2 units onboard vessel, with short description and applicable ratings of each 

unit;

6.12.4.3 date/time entering the 25 nautical mile radius;

6.12.4.4 date/time exiting the 25 nautical mile radius; and

6.12.4.5 sulfur content of all fuel used in any engine as specified in Condition 6.4.

6.12.5 All information required to be collected, recorded, or maintained pursuant to Condition 

6.12 shall be submitted to EPA by the permittee in accordance with the reporting 

specifications detailed in Condition 5.17.

7 New Source Performance Standards and National Emission Standard for Hazardous Air 

Pollutants (HAP) Requirements

7.1.1 The third party engines (DR-WL-01 and DR-WL-02; DR-EL-01 and DR-EL-02; DR-CU01 and DR-CU-02; DR-WC-01 through DR-WC-04; DR-WC-07 through DR-WR-10; and 

DR-WB-01) are subject to 40 CFR part 60, subpart IIII based on engine size, per cylinder 

displacement, and model year. The permittee shall demonstrate compliance with the 

applicable requirements through the following:

7.1.1.1 The permittee shall maintain documentation in accordance with Condition 

5.16 that engines specified in Condition 7.1.1 were installed and configured 

according to manufacturer’s specifications.

7.1.1.2 The permittee shall maintain records in accordance with Condition 5.16 of 

manufacturer data indicating compliance with EPA Tier standards, if 

applicable, to the engine. 

7.1.1.3 The permittee shall operate and maintain the engines according to the 

manufacturer's written instructions or procedures developed by the permittee 

that are approved in writing by the engine manufacturer. The permittee shall 

only change those settings that are approved by the manufacturer. The 

permittee shall maintain records of the manufacturer’s written instructions for 

operation and maintenance of the engine or the procedures the permittee 

developed that are approved in writing by the manufacturer in accordance 

with Condition 5.16.

7.1.1.4 The permitted engines shall not combust any diesel fuel that does not meet the 

requirements of Condition 6.4.
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7.1.2 As identified in the permit application, the third party engines (DR-WL-01 and DR-WL02, DR-EL-01 and DR-EL-02, DR-CU-01 and DR-CU-02, DR-WC-01 through DR-WC04, and DR-WC-07 through DR-WR-10, and DR-WB-01) are subject to and shall 

comply with the applicable requirements of 40 CFR part 63, subpart ZZZZ. The 

permittee shall demonstrate compliance with subpart ZZZZ for each engine by 

demonstrating compliance with the applicable requirements of 40 CFR part 60, subpart 

IIII and Condition 7.1.1.

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

Section 4), the Main Diesel Engines (DR-GE-01 through DR-GE-06), Emergency 

Generator Engines (DR-GE-07), Well Evaluation Engines (DR-VS-01 through DR-VS05), Air Compressor Engines (DR-AC-01 and DR-AC-02), Stimulation Vessel Pump 

Engines (SV-PE-01 through SV-PE-08) are subject to and shall comply with the 

applicable requirements of 40 CFR part 63, subpart ZZZZ.

7.1.3.1 Existing stationary engines located at an area source of HAP emissions on the 

OCS must comply with the applicable requirements in 40 CFR § 63.6603(c)

and Table 2d in subpart ZZZZ in accordance with the compliance schedule 

requirements of Condition 5.21.

7.1.3.2 Compliance with any applicable numerical emission limitation established in 

subpart ZZZZ is based on the results of testing the average of three 1-hour 

runs using the testing requirements and procedures in 40 CFR § 63.6620.

7.1.3.3 Compliance with Condition 7.1.3 shall be determined based upon 

recordkeeping required by the Annual Compliance Certification set forth in 

Condition 5.20.

[40 CFR part 63, subpart ZZZZ and 55.8]

7.1.4 Compliance with the requirements of Condition 7 shall be determined based upon 

recordkeeping required by the Annual Compliance Certification set forth in Condition 5.20.

7.1.5 Any new, modified, or reconstructed engine shall comply with all applicable NESHAP and 

NSPS, including but not limited to 40 CFR part 60, subpart IIII and 40 CFR part 63, 

subpart ZZZZ, or obtain a technical exemption under 40 CFR § 55.7.

7.1.6 The permittee shall notify EPA prior to use of any new, modified, or reconstructed engine 

intended to be used on the drilling vessel or in replacement of an engine in Tables 1 and 2 

of Section 4 of this permit, and shall submit to EPA a reevaluation of the applicability of 

pertinent NESHAP and NSPS regulations, as well as copies of the manufacturer engine 

certification to EPA standards. 

7.1.7 The permittee shall maintain records in accordance with Condition 5.16 of the certifications 

of all diesel units specified in Tables 1 and 2 of Section 4. 

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