***DRAFT for Public Notice***

Statoil OCS-EPA-R4012-M1 08/14/14

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-R4012-M1

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

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

(CFR) part 55, which incorporate by reference the 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.

Statoil Gulf Services, LLC

2103 CityWest Boulevard, Suite 800

Houston, Texas 77042

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

emitting activities at an OCS source at multiple sites within the Gulf of Mexico, within the areas defined 

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

the project location, this OCS source and associated support vessels shall be constructed and operated in 

accordance with the terms and conditions set forth in this permit.

This permit originally became effective on November 27, 2013.

This permit was modifiedModifications to this permit shall become effective on [INSERT DATE],

August 14, 2014. unless review of the permit decision is requested in accordance with 40 CFR § 124.19

or 40 CFR § 71.11(l).

This permit shall expire on: November 27, 2018.

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

applicable provisions of federal and state law.

__________ ______________________

Date Signed Beverly H. Banister

Director

Air, Pesticides, and Toxics

Management Division
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Statoil OCS-EPA-R4012-M1 08/14/14

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 the 

EPA by Statoil Gulf Services, LLC (Statoil) dated September 5, 2012, December 7, 2012, January 28, 

2013, and June 27, 2013, and, as revised, March 27, 2014; all supplemental submittals and information

included in the administrative record for this permit action; and upon the technical analysis performed 

by the EPA.

2 APPLICANT

Statoil Gulf Services, LLC

2103 CityWest Boulevard, Suite 800

Houston, Texas 77042

3 PROJECT LOCATION

Statoil’s project is located in the OCS waters of the Gulf of Mexico. The Transocean Discoverer

Americas will operate in the DeSoto Canyon area lease blocks 143, 187, 188, 230, 231, 625, 669, 670, 

671, 715, 716, 759, 760, and 804. The Maersk Developer will operate in the same DeSoto Canyon area 

or in any eastern Gulf of Mexico area located further from the Breton Wilderness Class I area, east of 

longitude 87.5, west of the Military Mission Line (86°41’ west longitude), outside of the current 

Congressional moratoria area as specified by the Gulf of Mexico Energy Security Act of 2006, and not

within 75 nautical miles of the state seaward boundary of Florida. 

The northwest corner of lease block 143, the closest point within the specified lease blocks to any state’s 

shoreline, is located on OCS waters of the Gulf of Mexico east of longitude 87.5 o W at latitude 28.85o N 

and longitude 86.42 o W. 

4 PROJECT DESCRIPTION

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

Americas (Operating Scenario 2) deepwater drilling vessel and its associated support vessels to perform 

exploratory drilling activities for approximately 180 days per year at multiple locations listed in Section 

3 above. Drilling operations are expected to occur for approximately five to ten years. This permit does 

not authorize the construction or establishment of any permanent production facilities.

Air pollutant emissions generated from the project include nitrogen dioxide (NO2), carbon monoxide 

(CO), particulate matter (PM), particulate matter with an aerodynamic diameter less than or equal to 2.5 

microns (PM2.5), particulate matter with an aerodynamic diameter less than or equal to 10 microns 

(PM10), and sulfur dioxide (SO2) (known as criteria pollutants), as well as other regulated air pollutants

including volatile organic compounds (VOC), oxides of nitrogen (NOX), and greenhouse gases (GHG). 

VOC and NOX are the measured precursors for the criteria pollutant ozone, and NOX and SO2 are 

measured precursors for PM2.5. 
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Statoil OCS-EPA-R4012-M1 08/14/14

GHG emissions for this project were calculated based on Global Warming Potential (GWP) factors from 

the GHG Reporting Rule at 40 CFR Part 98, Subpart A, Table A-1. The following GWP factors in 

Table A-1 as of the date of the original permit remain applicable to the unmodified terms of the permit 

(i.e, emissions related to the Transocean Discoverer Americas operating under Operating Scenario 2):

GHG Pollutant GWP Factor

CO2 1

CH4 21

N2O 310

SF6 23,900

GWP factors currently in 40 CFR Part 98, Subpart A, Table A-1 and applicable to the modified permit 

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

GHG Pollutant GWP Factor

CO2 1

CH4 25

N2O 298

SF6 22,800

Emissions are primarily released from the combustion of diesel fuel in the drilling vessel’s main 

engines, as well as in engines that supply power for drilling equipment and support vessels. Emissions 

are also released from other equipment such as storage tanks, and from activities such as vessel 

maintenance, cementing the wells, and the pumping of heavy lubricating mud. 

Based on emissions estimates and the applicable permitting thresholds, both operating scenarios will 

have significant emissions of NOX, and are considered major sources of NOX with respect to the PSD 

and title V regulations. Therefore, drilling operations conducted under either operating scenario are 

subject to the PSD and title V programs for NOX as the measured pollutant for criteria pollutants NO2

and ozone and as a precursor to PM2.5. Based on stack testing data from October 2013 included in 

Statoil’s permit modification application dated March 27, 2014, drilling under Operating Scenario 1 

using the Developer also has emissions of PM10, PM2.5, and VOC that meet or exceed the respective 

PSD significant emission rates. In addition, either operating scenario will be considered an area source 

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

Based on Statoil’s original permit application dated September 5, 2012, PM2.5 will be emitted at close to 

its significant emission rate in Operating Scenario 2. Therefore, the EPA has also included a condition in 

the draft permit that limits the Discoverer America’s total filterable and condensable PM2.5 emissions.

The Developer (Operating Scenario 1) is a self-powered, dynamically positioned semi-submersible drill 

rig constructed with pontoon structures below the water surface and columns supporting a platform 

above the surface. Rig positioning is achieved using a computer controlled sensor system and the 

vessel’s propellers and thrusters. Therefore, the rig will not require the use of towing or anchoring 

vessels as part of the support fleet.

The rig is equipped with eight main generator engines to provide propulsion and electrical power, two 

cementing unit engines, an emergency generator, four life boats, a fast rescue boat (man overboard 

boat), and storage vessels for fuel and waste oil storage. Electric powered well logging (wireline) units, 

forklifts, and cranes are used on the rig. However, since the electric units do not have combustion 
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Statoil OCS-EPA-R4012-M1 08/14/14

engines, they are not addressed as a separate source of air emissions. Information regarding emissions 

units for the Developer is provided in Table 1 below.

The information provided in Tables 1 and 2 is for description and identification purposes and does not 

establish operating limits. Permit conditions may limit operation to less than rated capacity.

Table 1 – Developer Emissions Units (Operating Scenario 1)

Emissions

Unit ID

Description Manufacturer 

and Model

Displacement 

(L/cylinder)

Rating

(kW)a

Rating

(hp)b

Manufacture 

Date

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

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

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

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

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

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

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

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

EGEN Emergency Generator Engine Caterpillar 3516B 4.9 1902 2551 11/2006

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

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

LB-1 Lifeboat 1 Engine BUKH or similar --- 22 29 8/2007

LB-2 Lifeboat 2 Engine BUKH or similar --- 22 29 8/2007

LB-3 Lifeboat 3 Engine BUKH or similar --- 22 29 8/2007

LB-4 Lifeboat 4 Engine BUKH or similar --- 22 29 8/2007

MOB-1 Fast Rescue Boat Engine Steyr Motors or 

similar

--- 122 163 3/2007

a Kilowatt

b Horsepower

The Discoverer Americas (Operating Scenario 2) is a dynamically positioned drillship. Similar to the 

Developer in Operating Scenario 1, this drillship is equipped with a computer controlled sensor system 

to automatically maintain the vessel's position and heading over a location using its propellers and 

thrusters. The drillship travels under the main generator engines’ power to the next drill site and does not 

require towing or anchoring vessels as part of the support fleet.

The Discoverer Americas’ equipment includes six main engines that power electrical equipment and 

serve as propulsion generators, an emergency generator, two emergency air compressors, two forklifts, 

six life boats, a fast rescue boat (man overboard boat), and storage vessels for fuel and waste oil. The 

ship is also equipped with electric-powered wireline units, cementing units, and cranes. However, since 

these units do not have combustion engines, they are not addressed as separate sources of air emissions.

Information regarding emissions units for the Discoverer Americas of Operating Scenario 2 is provided 

in Table 2 below.

Table 2 – Discoverer Americas Emissions Units (Operating Scenario 2)

Emissions

Unit ID

Description Manufacturer and 

Model

Displacement 

(L/cylinder)

Rating

(kW)a

Rating

(hp)b

Manufacture 

Date

GEN-1 Main Generator Engine 

1

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

GEN-2 Main Generator Engine 

2

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

GEN-3 Main Generator Engine 

3

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

GEN-4 Main Generator Engine STX MAN 14V32/40 32.2 7000 9387 3/2008
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Statoil OCS-EPA-R4012-M1 08/14/14

Emissions

Unit ID

Description Manufacturer and 

Model

Displacement 

(L/cylinder)

Rating

(kW)a

Rating

(hp)b

Manufacture 

Date

4

GEN-5 Main Generator Engine 

5

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

GEN-6 Main Generator Engine 

6

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

EGEN Emergency Generator 

Engine

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

ACOMP-1 Emergency Air 

Compressor Engine 1

Duetz F3L912 0.9 37 50 1/2007

ACOMP-2 Emergency Air 

Compressor Engine 2

Duetz F4L912 0.9 51 68 1/2007

FORK-1 Forklift Engine 1 Mitsubishi 

8MVKL.0AAD or 

similar

3.3 (engine 

total)

37 50 2008

FORK-2 Forklift Engine 2 Mitsubishi 

8MVKL.0AAD

or similar

3.3 (engine 

total)

37 50 2008

LB-1 Lifeboat 1 Engine BUKH or similar --- 27 36 9/2006

LB-2 Lifeboat 2 Engine BUKH or similar --- 27 36 9/2006

LB-3 Lifeboat 3 Engine BUKH or similar --- 27 36 8/2006

LB-4 Lifeboat 4 Engine BUKH or similar --- 27 36 9/2006

LB-5 Lifeboat 5 Engine BUKHor similar --- 27 36 9/2006

LB-6 Lifeboat 6 Engine BUKH or similar --- 27 36 9/2006

MOB-1 Fast Rescue Boat Engine Steyr Motors or 

similar

--- 158 212 9/2006

HTR Cargo Hold Heater --- --- --- --- Post 1989

a Kilowatt

b Horsepower

The drillships are supported by various vessels operating within 25 miles. Support vessels include crew 

boats and offshore support vessels (OSVs) that bring crew, supplies, and materials to the ship as needed

during exploratory drilling activities. A representative vessel for each support vessel category, the crew 

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

emissions from the support fleet. 

5 GENERAL CONDITIONS

5.1 Compliance

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

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

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

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

apply to the OCS source and permittee.

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

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

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

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

with the conditions of this permit.

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

5.2 Permit Shield

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

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

alter or affect the following:

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

Administrator under that section;

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

prior to or at the time of permit issuance; or

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

[40 CFR § 71.6(f)(1)]

5.3 Other Credible Evidence

For the purpose of submitting compliance certifications in accordance with Condition 5.21 of this 

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

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

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

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

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

5.4 Construction and Operation

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

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

in 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
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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.

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

[40 CFR § 71.6(a)(2)]

5.7.3 Expiration of this permit terminates the permittee’s right to operate unless a timely and 

complete permit renewal application has been submitted at least six (6) months, but not 

more than 18 months, prior to the date of expiration of this permit. If the permittee 

submits a timely and complete renewal application, and the EPA does not take final 

action on the renewal application before the end of the term of this permit, the 

permittee’s failure to have a permit is not a violation of 40 CFR part 71 until the 

permitting authority takes final action on the renewal application. Such protection will 

cease to apply if, subsequent to the EPA’s determination that the renewal application is 

complete, the permittee fails to submit by the deadline specified in writing by the EPA 

any additional information identified as being needed to process the application.

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

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

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

action on the renewal application before the end of the term of this permit, then all the 

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

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

application.

[40 CFR §§ 71.7(c)(3) and 71.7(b)]

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

initial permit issuance, including those for public participation and affected State 

review.
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Statoil OCS-EPA-R4012-M1 08/14/14

[40 CFR §71.7(c)(1)(i)]

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

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

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

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

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

other information required by the application form.

[40 CFR §§ 71.5(a)(2) and 71.5(c)(5)]

5.8 Property Rights

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

[40 CFR §71.6(a)(6)(iv)]

5.9 Inspections

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

presentation of credentials or other documents as may be required by law and at reasonable times, access 

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:

 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;

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

required under this permit; and

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

assure compliance with this permit or EPA rules.

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

[40 CFR §§ 71.6(c)(2) and 55.8]

5.10 Emergency 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:

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

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

 During the period of the emergency the permittee took all reasonable steps to minimize levels 

of emissions that exceeded the emissions standards, or other requirements in this permit; and

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

the time when emission limitations were exceeded due to the emergency. This notice must 
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Statoil OCS-EPA-R4012-M1 08/14/14

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

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

concerning prompt notification of deviations.

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

5.11 Burden of Proof for Emergencies

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

has the burden of proof.

[40 CFR § 71.6(g)(4)]

5.12 Emergency Defined

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

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

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

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

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

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

[40 CFR § 71.6(g)(1)]

5.13 Certification Requirement

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

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

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

complete.

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

5.14 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 the 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 the EPA may be used by the EPA as evidence in any 

enforcement case involving the permitted source arising under federal statutes, EPA rules, or rules 

enforceable by the EPA.
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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.

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

at 2103 CityWest Boulevard, Suite 800, Houston, Texas 77042, all records required by 

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

required by the permit, copies of all reports required by this permit, and records of all 

data used to complete the application for this permit. These materials shall be retained 

at least five years from the date of the sample, measurement, report, or application 

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

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

Support information includes all 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:

 Date and time of sampling or measurements;

 Emission unit or other place as defined in this permit;

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

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

 Date(s) the analyses were performed;

 Results of such analyses; and

 Analytical techniques or methods used.

[40 CFR § 71.6(a)(3)(ii)(A)]

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

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

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

or in any report to the EPA, such facts or information shall be corrected promptly.

[40 CFR §§ 71.5(b) and 55.8]

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

submitted to:

Chief

Air & EPCRA Enforcement Branch

Air, Pesticides and Toxics Management Division

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303
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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

Kelly Fortin fortin.kelly@epa.gov 404-562-9117

Lori Shepherd lorinda.shepherd@epa.gov 404-562-8435

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

the EPA may request in writing to determine whether cause exists for modifying, 

revoking, and reissuing, or terminating the permit, or to determine compliance with the 

permit. Upon request, the permittee shall also furnish to the EPA copies of records that 

are required to be kept pursuant to the terms of the permit, 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 the EPA reports of any required monitoring for each six 

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

except that the first reporting period shall begin on the effective date of this permit and 

end on either June 30 or December 31, whichever occurs first. All reports shall be 

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

reporting period. All instances of deviations from permit 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 the EPA, by telephone or facsimile, deviations 

from permit conditions, including those attributable to upset conditions as defined in 

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

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

Telephone: (404) 562-9194 

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:
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Statoil OCS-EPA-R4012-M1 08/14/14

 For emissions of a hazardous air pollutant or a toxic air pollutant 

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

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

24 hours of the occurrence; 

 For emissions of any regulated pollutant excluding those referenced in the 

preceding bullet, that continue for more than two (2) hours in excess of 

permit requirements, the report must be made within 48 hours of the 

occurrence; or

 For all other deviations from permit requirements, 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 the EPA, certified consistent with Condition 5.13 of this 

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

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

permittee must report in writing the following information:

 OCS Source (Facility) Name;

 OCS Air Permit Number;

 Company Name;

 Date/Time when the deviation was discovered;

 Date/Time when the event began (24-hour clock);

 Date/Time when the event ended (24-hour clock);

 Duration of the event: (hours: minutes) or days (total number of hours, minutes or 

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

 If the deviation was intermittent or continuous;

 Brief description of what happened and the cause, including information regarding 

the operating conditions during the deviation;

 Identification of the emission unit(s) or source(s) involved in the event using the same 

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

 Identification of each emission limit potentially exceeded during the event and the 

level of exceedance, if applicable;

 Whether the deviation was unavoidable;

 Describe corrective action taken and action taken to prevent future recurrence; 

 If not corrected, the anticipated time the deviation is expected to continue and steps 

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

 Certification: Based on information and belief formed after reasonable inquiry, certify 

that the statements and information reported are true, accurate, and complete.

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

which the 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:
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Statoil OCS-EPA-R4012-M1 08/14/14

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

 A situation where process or emissions control device parameter values indicate that 

an emission limitation or standard has not been met; 

 A situation in which observations or data collected demonstrate noncompliance with 

an emission limitation or standard or any work practice or operating condition 

required by the permit (including indicators of compliance revealed through 

parameter monitoring); and

 A situation in which any testing, monitoring, recordkeeping or reporting required by 

this permit is not performed or not performed as required.

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

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

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

5.18 Off Permit Changes

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

requirements are met:

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

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

term or condition; and

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

I of the Clean Air Act.

5.18.1 The permittee shall provide contemporaneous written notice to the EPA of each change

under this provision, except for changes that qualify as insignificant activities under 40 

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

 A description of each change;

 Date of the change;

 Any change in emissions;

 List of pollutants emitted; and 

 Any applicable requirements that would apply as a result of the change.

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

provision.

5.18.3 The permittee 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 within this permitted facility without applying for a permit revision, provided the changes do not 
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Statoil OCS-EPA-R4012-M1 08/14/14

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.

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 

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 Combined Operating Scenarios

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

such as a 12-month rolling average, any applicable condition of this permit, including but not limited to 

emission limits, fuel consumption limits, operating limits, and fee calculations, shall be prorated based 

on the duration of the operation of each vessel during the compliance period. In no case does this 

condition allow for the simultaneous operation of more than one drilling vessel concurrently within the 

lease blocks specified in Section 3 under the terms of this permit.

[40 CFR § 55.6]

5.21 Annual Compliance Certification

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

including emission limitations, standards, or work 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 

effective date of 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:

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

 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; 

 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

 A summary 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 
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reporting period based on recorded data, such as actual fuel usage and actual hours of 

operation.

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

5.22 Compliance Schedule

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

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

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

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

5.23 Safe Shutdown

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

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

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

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

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

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

initiation of the shutdown process will not preclude well procedures necessary to ensure safety.

[40 CFR § 55.9(c)]

5.24 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. 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)]

5.25 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)]

5.26 General Testing Requirements

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

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

requirements in Conditions 5.26.2 through 5.26.10 whenever conducting a performance 

test required by this permit unless specifically stated otherwise in this permit.
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5.26.2 The permittee shall provide the EPA at least 30 days prior notice of any performance 

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

have an observer present. If after the 30- days notice for an initially scheduled 

performance test, there is a delay in conducting the scheduled performance test, the 

permittee shall notify the EPA as soon as possible of any delay in the original test date, 

either by providing at least seven (7) days prior notice of the rescheduled date of the 

performance test, or by arranging a rescheduled date with the EPA by mutual 

agreement.

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

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

 Purpose and scope of testing; 

 Source description, including a description of the operating scenarios and mode of 

operation during testing and including fuel sampling and analysis procedures; 

 Schedule/dates of testing; 

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

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

 Sampling and analysis procedures, specifically requesting approval for any proposed 

alternatives to the reference test methods, and addressing minimum test length (e.g., 

one hour, eight (8) hours, 24 hours, etc.) and minimum sample volume; 

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

 Analysis procedures and laboratory identification; 

 Quality assurance plan; 

 Calibration procedures and frequency; 

 Sample recovery and field documentation; 

 Chain of custody procedures; 

 Quality assurance/quality control project flow chart; 

 Data processing and reporting; 

 Description of data handling and quality control procedures; and

 Report content and timing.

5.26.4 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.

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

the following information:

 All data which is required to be monitored during the test in the emission unit 

sections of this permit; and

 All continuous monitoring system data that is required to be routinely monitored in 

the emission unit sections of this permit for the emission unit being tested.

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

consist of at least three (3) valid test runs conducted under normal operating conditions.
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5.26.7 If the reference test method yields measured pollutant concentration values at an 

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

correct the measured pollutant concentration to the oxygen concentration specified in 

the emission standard by using the following equation:

PCX = PCm x (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.

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

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

Appendix A).

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

emission test required by this permit along with items required to be recorded in 

Condition 5.26.5 above.

5.26.10Source 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)]

5.27 Fee Payment

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

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

5.27.11; 

 An updated fee calculation worksheet form and a photocopy of each fee payment 

check (or other confirmation of actual fee paid), as specified in Conditions 5.27.4 

through 5.27.8; and

 An annual emissions report of actual emissions, as specified in Condition 5.27.6, for 

the preceding calendar year.

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

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

order of the U.S. Environmental Protection Agency.

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

addresses listed below.

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

U.S. Environmental Protection Agency

FOIA and Miscellaneous Payments
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Statoil OCS-EPA-R4012-M1 08/14/14

Cincinnati Finance Center

PO Box 979078

St. Louis, MO 63197-9000

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

U.S. Bank

Government Lockbox 979078 

US EPA FOIA & Misc. Payments

1005 Convention Plaza

Mail Station SL-MO-C2GL

St. Louis, MO 63101

Contact: Natalie Pearson

(314-418-4087)

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

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

by the date specified in Condition 5.27.1, to:

Chief

Air Permits Section

Air, Pesticides and Toxics Management Division

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303

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

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

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

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

prior to the start of each calendar year.

5.27.5.1 “Actual emissions” means the actual rate of emissions in tons per year 

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

CFR § 71.2, emitted from a part 71 source over the preceding calendar year. 

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

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

materials processed, stored, or combusted during the preceding calendar 

year.

5.27.5.2 Actual emissions shall be computed using methods required by the permit 

for determining compliance, such as monitoring or source testing data.

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

the permit, the permittee shall use other federally recognized procedures.

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

fees:
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 The amount of actual emissions of each regulated pollutant (for fee 

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

 Actual emissions of any regulated pollutant (for fee calculation) already 

included in the fee calculation; and

 The insignificant quantities of actual emissions not required to be listed or 

calculated in a permit application pursuant to 40 CFR § 71.5(c)(11).

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

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

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

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

in Condition 5.27.3 of this permit.

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

a responsible official in accordance with Condition 5.13 of this permit.

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

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

payments. Records shall be retained for five years following the year in which the 

emissions data is submitted.

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

assessment of penalties and interest.

5.27.10The permittee, when notified by the EPA of additional amounts due, shall remit full 

payment within 30 days of receipt of an invoice from the EPA.

5.27.11If 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 the 

EPA along with full payment of the EPA assessed fee.

[40 CFR § 71.9]
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6 SPECIFIC CONDITIONS

6.1 Drill Site Notification

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

writing, in accordance with Condition 5.16.7 of this permit, of the following 

information:

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

Universal Transverse Mercator grid system formats;

 The proposed date that the drilling vessel will enter the lease block and commence 

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

 The certification of maintenance and no physical changes required by Condition 

6.5.1.1 (if applicable).

; and

6.1.2 Not less than 24 hours prior to commencing construction or operation, the permittee 

shall notify the EPA of any changes to the information provided by the permittee in 

Condition 6.1.1. This notification of changes may be provided to the EPA 

electronically.

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

6.2 Support Vessel Identification

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

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

of the Peyton Candies (offshore support vessel) and/or the Sybil Graham (crew boat). These records, as 

well as engine emission factors and calculated mass emissions in tons per year of regulated pollutant,

shall be submitted as part of the Annual Compliance Certification in accordance with Condition 5.21.

6.2.1 Any offshore support vessel used in place of the Peyton Candies shall meet Condition 

6.20, and shall be selected to have worst case potential emissions less than those of the 

Peyton Candies. 

6.2.2 Any crew boat used in place of the Sybil Graham shall meet Condition 6.21, and shall 

be selected to have worst case potential emissions less than those of the Sybil Graham.

[40 CFR § 55.8]

6.3 Source-wide SO2 Emission Limits

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

(ppm) by weight (0.0015%), as determined by Condition 6.3.1, in any diesel fueled emission unit on the

Developer, the Discoverer Americas, or any support vessel.

6.3.1 The permittee shall obtain a certification of sulfur content for each shipment of fuel 

from the fuel supplier (the certification must indicate the sulfur content was determined 

by an approved EPA method), 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.
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6.3.2 Prior to mobilizing the selected drilling vessel for activities covered by this permit, the 

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

vessel and the support vessels using the procedures in Condition 6.3.1.

6.3.3 Thereafter, the permittee shall determine and record the sulfur content of diesel fuel on 

the drilling vessel and the support vessels using procedures in Condition 6.3.1 upon 

receiving each fuel shipment.

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

Conditions 6.3.2 and 6.3.3 with the Annual Compliance Certification required by 

Condition 5.21.

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

6.4 Discoverer Americas Source-Wide PM2.5 Emission Limits

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

more of total filterable and condensable PM2.5 emissions from all emission units on the

Discoverer Americas, including any support vessels operating within 25 miles and used

in service of the drilling vessel, on a 12-month rolling basis.

6.4.2 Compliance with this operating limit shall be demonstrated by calculating total PM2.5

emissions in TPY from all emission units using monthly fuel consumption, as required 

by Conditions 6.19 (Discoverer Americas), 6.20.2 (OSVs), and 6.21.2 (crew boats), or 

hours of operation and verifiable equipment-specific emissions rates for total filterable 

and condensable PM2.5 emissions determined in accordance with compliance 

demonstration methods set forth in Condition 6.22, or by using the most accurate 

equipment specific emission rate that may be obtained from among those included in 

the application, vendor data, or manufacturer emissions certification, if actual emissions 

rates are not available. The permittee shall calculate total PM2.5 emissions for the 

previous 12-month period on a 12-month rolling basis within 15 days following the end 

of each calendar month. 

6.4.3 The permittee shall submit a written report in compliance with Condition 5.17.1 

including the results of the PM2.5 limit calculations performed in accordance with 

Condition 6.4.2 for each 12-month period completed in the report. 

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

6.5 General Stack Test Requirements 

6.5.1 Within 90 days of the start of the first campaign that the subject drilling vessel operates 

under this permit, the eight main engines (GEN-1 through GEN-8) of the Developer or 

the six main engines of the Discoverer Americas (GEN-1 through GEN-6) shall have 

been stack tested under the requirements of Condition 6.5 and Condition 5.26 within 

the previous 12 month period. 
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Statoil OCS-EPA-R4012-M1 08/14/14

6.5.1.1 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 5.26 and Conditions 6.5.2 through 6.5.6. 

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

Condition 6.5.1.1, the certification shall be included with the drill site 

notification required pursuant to Condition 6.1. Maintenance records shall 

be kept in accordance with the recordkeeping requirements set forth in 

Condition 5.16

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

EPA approved source test plan set forth in Condition 5.26. 

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

of operations.

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

VOC, and visible emissions at a reference O2 or CO2 concentration.

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

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

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

 Electrical power produced (in kW-hr). 

6.5.6 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 6.5 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)]

6.6 Developer Main Generator Engines (GEN-1 through GEN-8) Emission and Operating 

Limits

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

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

rolling 24-hour average basis:

6.6.1.1 NOX BACT Emission Limit: 12.0 g/kW-hr.

6.6.1.2 VOC BACT Emission Limit:

6.6.1.2.1 2.15 g/kW-hr for engine loads < 55%, or

6.6.1.2.2 1.73 g/kW-hr for engines loads ≥ 55%.
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6.6.1.3 PM10 BACT Emission Limit: 

6.6.1.3.1 0.50 g/kW-hr for engine loads < 55%; or

6.6.1.3.2 0.26 g/kW-hr for engines loads ≥ 55%.

6.6.1.4 PM2.5 BACT Emission Limit: 

6.6.1.4.1 0.49 g/kW-hr for engine loads < 55%; or

6.6.1.4.2 0.26 g/kW-hr for engines loads ≥ 55%.

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

atmosphere in excess of the following from the eight main generator engines combined 

on a rolling 12-month total basis.

6.6.2.1 NOX BACT Emission Limit: 416.15 TPY.

6.6.2.2 VOC BACT Emission Limit: 66.12 TPY.

6.6.2.3 PM10 BACT Emission Limit: 12.81 TPY.

6.6.2.4 PM2.5 BACT Emission Limit: 12.43 TPY.

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

6.6.3.1 Main generator engines with low NOX tuning design, including 

turbocharger, aftercooler, open crankcase ventilation system, and high 

injection pressure fuel system;

6.6.3.2 Good combustion practices based on the most recent manufacturer’s 

specifications for these engines issued at the time that the engines are 

operating under this permit;

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

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

and

6.6.3.5 Additional enhanced work practice standards including, but not limited to, 

specialized personnel training, having an equipment maintenance specialist 

available at all times during drilling activities, conducting weekly engine 

inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to engine-specific maintenance manuals.
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Statoil OCS-EPA-R4012-M1 08/14/14

6.6.4 Monitoring and Recordkeeping: The permittee shall monitor NOX, VOC, PM10, and 

PM2.5 emissions at a determined reference O2 or CO2 concentration by the use of an 

EPA-approved continuous emissions monitoring system, an EPA-approved parametric 

monitoring method, or with prior written approval by the EPA, an EPA approved stack 

testing emissions monitoring method or an alternative parametric monitoring method,

pursuant to Condition 6.22.

6.6.5 Reporting: All information required to be collected, recorded, or maintained pursuant to 

Conditions 6.6 and 6.22 shall be submitted to EPA by the permittee in accordance with 

the reporting specifications detailed in Conditions 5.17.

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

6.7 Developer Emergency Generator Engine (EGEN) Standards & Limits

6.7.1 The permittee shall use the following BACT Work Practice Standards: 

6.7.1.1 An emergency generator engine with low NOX engine design, including 

turbocharger, aftercooler, open crankcase ventilation system, and electronic 

fuel injection;

6.7.1.2 Good combustion practices based on the most recent manufacturer’s 

specifications for this engine issued at the time that the engine is operating 

under this permit;

6.7.1.3 Diesel fuel with sulfur content less than or equal to 15 ppm by weight ultralow sulfur diesel; 

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

6.7.1.5 Additional enhanced work practice standards including, but not limited to, 

specialized personnel training, having an equipment maintenance specialist 

available at all times during drilling activities, conducting weekly engine 

inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to engine-specific maintenance manuals.

6.7.2 Operating Limit: This engine shall be operated no more than 39 hours per year of nonemergency, planned operation time on a rolling 12-month average basis.

6.7.3 Monitoring, Recordkeeping, and Reporting:

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

hours on a rolling 12-month basis in accordance with Condition 6.23. 

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

to Conditions 6.7 and 6.23 shall be submitted to EPA by the permittee in 

accordance with the reporting specifications detailed in Condition 5.17.

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

6.8 Developer Cementing Unit Engines (CMU-1 and CMU-2) Standards & Limits
25

Statoil OCS-EPA-R4012-M1 08/14/14

6.8.1 The permittee shall use the BACT work practice standards: 

6.8.1.1 Cementing unit engines with low NOX engine design, including 

turbocharger, aftercooler, open crankcase ventilation system, and electronic 

fuel injection;

6.8.1.2 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;

6.8.1.3 Diesel fuel with sulfur content less than or equal to 15 ppm by weight ultralow sulfur diesel;

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

and

6.8.1.5 Additional enhanced work practice standards including, but not limited to, 

specialized personnel training, having an equipment maintenance specialist 

available at all times during drilling activities, conducting weekly engine 

inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to engine-specific maintenance manuals.

6.8.2 Operating Limit: These engines shall be operated no more than a combined total of 300 

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

6.8.3 Monitoring, Recordkeeping, and Reporting:

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

hours on a rolling 12-month basis in accordance with Condition 6.23.

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

to Conditions 6.8 and 6.23 shall be submitted to EPA by the permittee in 

accordance with the reporting specifications detailed in Condition 5.17.

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

6.9 Developer Life Boat Engines (LB-1 through LB-4) and Fast Rescue Boat Engine (MOB) 

Standards and Operating Limits

6.9.1 Operating Limit: These engines shall be operated no more than 12 hours for each unit 

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

6.9.2 The permittee shall use good combustion practices based on the most recent 

manufacturer’s specifications issued for these engines at the time that the engines are 

operating under this permit.

6.9.3 Monitoring, Recordkeeping, and Reporting:

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

hours on a rolling 12-month basis in accordance with Condition 6.23.
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6.9.3.2 All information required to be collected, recorded, or maintained pursuant 

to Condition 6.9 and 6.23 shall be submitted to EPA by the permittee in 

accordance with the reporting specifications detailed in Condition 5.17.

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

6.10 Developer Non-engine Related Standards and Operating Limits

6.10.1 Source Identification: Cement and Barite Transfer Activities (CEMENT-BARITE)

6.10.1.1 As a BACT work practice standard, the permittee shall use proper 

maintenance and operation of the enclosed pneumatic conveyance dust 

collector system based on the most recent manufacturer’s specifications for 

the system issued at the time that project activities are conducted under this 

permit.

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

6.10.1.3 The permittee shall perform a daily visual check of the dust collector 

system and maintain a record of daily inspections and system maintenance.

6.10.2 Source Identification: Welding Activities (WELD)

6.10.2.1 As a BACT work practice standard, the permittee shall use best 

management practices including, but not limited to, following the most 

recent manufacturer’s specifications for all equipment used in welding 

operations issued at the time that project activities are conducted under this 

permit.

6.10.2.2 The permittee shall maintain an accurate record of the types and quantity 

(in pounds) of welding rods used on a rolling 12-month basis for the 

purpose of calculating actual emissions pursuant to Condition 5.21.

6.10.3 Source Identification: Painting Activities (PAINT)
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6.10.3.1 As BACT work practice standards, the permittee shall use best management 

practices that include, but are not limited to, the following:

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

6.10.3.1.2 Use of paint rollers instead of sprayers where practical;

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

minimum transfer efficiency of 65%, operated within the 

manufacturer’s recommended pressure range, and following the 

most recent manufacturer’s specifications issued at the time that 

coating operations are conducted under this permit; 

6.10.3.1.4 Down spraying of paint where possible;

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

around the section of the drillship being painted whenever 

practical to reduce airborne particulate matter; 

6.10.3.1.6 Proper storage of coatings and thinners in appropriately labeled, 

non-leaking containers; and

6.10.3.1.7 The permittee shall maintain and record the types and amounts 

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

6.10.3.1.8 Maintenance of MSDS information for all paints and thinners 

used while conducting painting activities under this permit.

6.10.3.2 The permittee shall record the following:

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

on a rolling 12-month basis;

6.10.3.2.2 Method of application (sprayed or rolled); and

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

6.10.4 Source Identification: Mud Degassing (MUD)

6.10.4.1 As a BACT work practice standard, the permittee shall use proper 

maintenance and operation of the mud degassing operations units in 

accordance with the most recent manufacturer’s specifications for all 

equipment used in mud handling operations issued at the time that project 

activities are conducted under this permit.

6.10.4.2 The permittee shall monitor and record the type of mud used and 

throughput for each type on a rolling 12-month basis. 

6.10.5 Source Identification: Fugitive Emissions (FUG)
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6.10.5.1 As a BACT work practice standard, the permittee shall use good 

maintenance practices to minimize fugitive emissions from valves, pump 

seals, and flanges, including a daily visual inspection and prompt repair of 

leaking components.

6.10.5.2 The permittee shall visually inspect components daily and maintain the 

following information:

 Date of inspection;

 Type of component; 

 Method of leak detection used;

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

 Corrective action taken;

 Date of corrective action;

 Date of component re-inspection;

 Name of person inspecting equipment (printed); and

 Signature of person inspecting equipment.

6.10.6 Source Identification: Storage Tank Emissions (FO CMV ST, FO MOB ST, FO SER 

ST 1 and 2, FO SET ST 3 and 4, FO ST 1 through 4, FO LB ST 1 through 4, FO EGEN 

ST, AV ST 1 through 3, WO ST 1 and 2)

6.10.6.1 As a BACT work practice standard, the permittee shall use good 

maintenance practices in accordance with the most recent manufacturer’s 

specifications for all storage tanks on the drilling vessel at the time that 

project activities are conducted under this permit.

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

4 and FO SER ST 1 and 2.

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

emissions for annual reporting.

6.10.6.4 The permittee shall maintain the following information:

 Storage tank ID; 

 Tank dimensions;

 Fuel type stored; and 

 Capacity of each storage tank.

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

6.11 Developer Fuel Consumption Limits

6.11.1 The drill rig is limited to an annual consumption of 2,459,150 gallons of diesel fuel on 

a rolling 12-month total basis. 
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Statoil OCS-EPA-R4012-M1 08/14/14

6.11.2 In the event that Developer and Discoverer Americas are operated sequentially during 

any rolling 12-month basis, the fuel consumption limits in Conditions 6.11.1 and 6.19.1 

shall be prorated based on daily vessel usage. The permittee shall not operate 

Developer and Discoverer Americas concurrently within the lease blocks specified in 

section 3 of this permit.

6.11.3 Compliance with this operating limit will be demonstrated by calculating and 

maintaining a record of monthly fuel consumption based on information obtained 

pursuant to Condition 6.11.4 for the duration of the drilling campaign to obtain the 

annual fuel usage.

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

information: 

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

 Date of each diesel fuel delivery;

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

 Name of person recording delivery (printed);

 Signature of recorder; and

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

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

6.12 Discoverer Americas Main Generator Engines (GEN-1 through GEN-6) NOX Emission 

Limits 

6.12.1 NOX BACT Emission Limit: The permittee shall not discharge or cause the discharge 

of emissions into the atmosphere in excess of 12.7 g/kW-hr for each of the main 

generator engines on a rolling 24-hour average basis.

6.12.2 NOX BACT Work Practice Standards: 

6.12.2.1 The permittee shall use main generator engines with low NOX engine 

design, including turbocharger, aftercooler, and high injection pressure. 

6.12.2.2 The permittee shall use good combustion practices based on the 

manufacturer’s current specifications for these engines. 

6.12.2.3 The permittee shall use additional enhanced work practice standards as 

detailed in Section 5.3.1.16 of the September 2012 application (provided in 

the administrative record). These practices shall include, but are not limited 

to, specialized personnel training, having an equipment maintenance 

specialist available at all times during drilling activities, conducting weekly 

engine inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to engine-specific maintenance manuals.
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6.12.2.4 The permittee shall use an engine performance management and monitoring 

system that employs parametric or continuous emissions monitoring, such 

as described in Condition 6.22, to establish indicator ranges for 

maintenance evaluation and repair.

6.12.3 Compliance Demonstration Method: The permittee shall monitor NOX emissions by the 

use of an EPA-approved continuous emissions monitoring system, an EPA-approved 

parametric monitoring method, or, with prior written approval by the EPA, an EPA 

approved stack testing emissions monitoring method, or, an alternative parametric 

monitoring method, pursuant to Condition 6.22.

6.12.4 Monitoring and recordkeeping shall be conducted in accordance with Condition 6.22.

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

6.13 Discoverer Americas Emergency Generator Engine (EGEN) NOX Standards & Limits

6.13.1 NOX BACT Work Practice Standards: 

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

engine design, including turbocharger, aftercooler, and high injection 

pressure.

6.13.1.2 The permittee shall use good combustion practices based on the 

manufacturer’s current specifications for this engine.

6.13.1.3 The permittee shall use additional enhanced work practice standards as 

detailed in Section 5.3.1.16 of the September 2012 application (provided in 

the administrative record). These practices shall include, but are not limited 

to, specialized personnel training, having an equipment maintenance 

specialist available at all times during drilling activities, conducting weekly 

engine inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to engine-specific maintenance manuals.

6.13.2 Operating Limit: This engine shall be operated no more than 41 hours per year of nonemergency, planned operation time on a rolling 12-month average basis.

6.13.2.1 Compliance Demonstration Method: Compliance with the operating limit 

set forth in Condition 6.13.2 will be assured by maintaining a record of total 

monthly operating hours, identifying and describing any periods of 

emergency use.

6.13.2.2 Monitoring and recordkeeping shall be conducted in accordance with 

Condition 6.23.

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

6.14 Discoverer Americas Forklift Engines (FORK-1 and FORK-2) NOX Standards & Limits

6.14.1 NOX BACT Work Practice Standards: 
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Statoil OCS-EPA-R4012-M1 08/14/14

6.14.1.1 The permittee shall use forklift engines with EPA rated interim Tier 4 or 

better engines.

6.14.1.2 The permittee shall use good combustion practices based on the 

manufacturer’s current specifications for these engines.

6.14.1.3 The permittee shall use additional enhanced work practice standards as 

detailed in Section 5.3.1.16 of the September 2012 application (provided in 

the administrative record). These practices shall include, but are not limited 

to, specialized personnel training, having an equipment maintenance 

specialist available at all times during drilling activities, conducting weekly 

engine inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to engine-specific maintenance manuals.

6.14.2 Operating Limit: These engines shall be operated no more than 237 hours per year for 

each engine on a rolling 12-month average basis.

6.14.2.1 Compliance Demonstration Method: Compliance with the operating limit 

set forth in Condition 6.14.2 will be assured by maintaining a record of total 

monthly operating hours.

6.14.2.2 Monitoring and recordkeeping shall be conducted in accordance with 

Condition 6.23.

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

6.15 Discoverer Americas Emergency Air Compressor Engines (ACOMP-1 and ACOMP-2) NOX 

Standards & Limits

6.15.1 NOX BACT Emission Limit: The permittee shall not discharge or cause the discharge 

of emissions into the atmosphere in excess of a combined 0.01 tons of NOX per year on 

a rolling 12-month total basis.

6.15.2 NOX BACT Work Practice Standards: 

6.15.2.1 The permittee shall use emergency air compressor engines with low NOX

engine design, including turbocharger and aftercooler.

6.15.2.2 The permittee shall use good combustion practices based on the 

manufacturer’s current specifications for these engines.

6.15.2.3 The permittee shall use additional enhanced work practice standards as 

detailed in Section 5.3.1.16 of the September 2012 application (provided in 

the administrative record). These practices shall include, but are not limited 

to, specialized personnel training, having an equipment maintenance 

specialist available at all times during drilling activities, conducting weekly 

engine inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to engine-specific maintenance manuals.
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Statoil OCS-EPA-R4012-M1 08/14/14

6.15.3 Operating Limit: These engines shall be operated no more than 3 hours per year for 

each engine of non-emergency, planned operation time on a rolling 12-month average 

basis.

6.15.3.1 Compliance Demonstration Method: Compliance with the operating limit 

set forth in Condition 6.15.3 will be assured by maintaining a record of total 

monthly operating hours, identifying and describing any periods of 

emergency use.

6.15.3.2 Monitoring and recordkeeping shall be conducted in accordance with 

Condition 6.23.

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

6.16 Discoverer Americas Cargo Hold Heater (HTR) Standards & Limits

6.16.1 NOX BACT Work Practice Standards: 

6.16.1.1 The permittee shall use good combustion practices based on the 

manufacturer’s current specifications for this unit.

6.16.1.2 The permittee shall use additional enhanced work practice standards as 

detailed in Section 5.3.1.16 of the September 2012 application (provided in 

the administrative record). These practices shall include, but are not limited 

to, specialized personnel training, having an equipment maintenance 

specialist available at all times during drilling activities, conducting weekly 

inspections, adhering to manufacturer-recommended maintenance 

schedules, and providing access to a unit-specific maintenance manual.

6.16.2 Operating Limit: This unit shall be operated no more than 2 hours per year on a rolling 

12-month average basis.

6.16.2.1 Compliance Demonstration Method: Compliance with the operating limit 

set forth in Condition 6.16.2 will be assured by maintaining a record of total 

monthly operating hours.

6.16.2.2 Monitoring and recordkeeping shall be conducted in accordance with 

Condition 6.23.

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

6.17 Discoverer Americas Life Boat Engines (LB-1 through LB-6) NOX Operating Limits

6.17.1 Operating Limit: These engines shall be operated no more than 12 hours for each unit 

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

6.17.2 Compliance Demonstration Method: Compliance with this operating limit will be 

assured by maintaining a record of total monthly operating hours, identifying and 

describing any periods of emergency use.

6.17.3 Monitoring and recordkeeping shall be conducted in accordance with Condition 6.23.

[40 CFR §§ 52.21 and 71.6(a)(1), 71.6(a)(3) and 71.6(c)(1)]
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Statoil OCS-EPA-R4012-M1 08/14/14

6.18 Discoverer Americas Fast Rescue Boat Engine (MOB) NOX Operating Limits

6.18.1 Operating Limit: This engine shall be operated no more than 12 hours per year of nonemergency, planned operation time on a rolling 12-month total basis.

6.18.2 Compliance Demonstration Method: Compliance with this operating limit will be 

assured by maintaining a record of total monthly operating hours, identifying and 

describing any periods of emergency use.

6.18.3 Monitoring and recordkeeping shall be conducted in accordance with Condition 6.23.

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

6.19 Discoverer Americas Fuel Consumption Limits

6.19.1 The drill rig is limited to an annual consumption of 2,179,983 gallons of diesel fuel on 

a rolling 12-month total basis. 

6.19.2 Compliance with this operating limit will be demonstrated by calculating and 

maintaining a record of monthly fuel consumption based on information obtained 

pursuant to Condition 6.19.3 for the duration of the drilling campaign to obtain the 

annual fuel usage.

6.19.2.1 In the event that Developer and Discoverer Americas are operated 

sequentially during any rolling 12-month basis, the emission limits in 

6.11.1 and 6.19.1 shall be prorated based on daily vessel usage. The 

permittee shall not operate Developer and Discoverer Americas

concurrently within the lease blocks specified in section 3 of this permit.

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

information: 

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

 Date of each diesel fuel delivery;

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

 Name of person recording delivery (printed);

 Signature of recorder; and

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

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

6.20 Offshore Support Vessels Operating Limits

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

exceed a total of 2,570 hours per year on a rolling 12-month total basis when within 25 

miles of the drilling vessel.

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

exceed a total of 621,468 gallons of diesel fuel per year on a rolling 12-month total 

basis when within 25 miles of the drilling vessel.
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Statoil OCS-EPA-R4012-M1 08/14/14

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

combust any diesel fuel with sulfur content greater than 0.0015 percent by weight.

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

recordkeeping conditions as set forth in Condition 6.24.

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

6.21 Crew Boats Operating Limits

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

618 hours per year on a rolling 12-month total basis when within 25 miles of the 

drilling vessel.

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

235,176 gallons of diesel fuel per year on a rolling 12-month total basis when within 25 

miles of the drilling vessel.

6.21.3 Crew boats like the Sybil Graham or any substitute crew boat shall not combust any 

diesel fuel with sulfur content greater than 0.0015 percent by weight.

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

recordkeeping conditions as set forth in Condition 6.24.

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

6.22 Compliance Monitoring and Recordkeeping Requirements for Main Generator Engines

In accordance with Condition 5.16, the permittee shall monitor and record NOX, CO2, CO, VOC, and 

PM/PM10/PM2.5 emissions (at a determined reference O2 concentration) from the main generator diesel 

engines (GEN-1 through GEN-8 on the Developer and GEN-1 through GEN-6 on the Discoverer 

Americas) by the use of an EPA-approved parametric monitoring method as described in Condition 

6.22.1, or an EPA-approved continuous emissions monitoring system described in Condition 6.22.2, or, 

with prior written approval by the EPA, a stack testing emissions monitoring system as described in 

Condition 6.22.3, or a combination of these methods, as necessary for different pollutants or engines.

6.22.1 Parametric Monitoring (Compliance Monitoring Option #1)

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

of the subject regulated air pollutants (NOX, CO2, CO, VOC, and 

PM/PM10/PM2.5) from the main generator diesel engines specified in 

Condition 6.22 by using a parametric monitoring system such as the 

Transocean Diesel Engines with Turbochargers (DEWT) monitoring system 

or its equivalent upon prior written approval by EPA.

6.22.1.2 The permittee shall monitor and record the following parameters once every 

30 seconds for 30 minutes twice a day:

 Charge Air Pressure (kPa) after air cooler;

 Charge Air Temperature (Celsius) after air cooler;

 Turbocharger RPM A&B (RPM);

 Engine Air Inlet Pressure (kPa);
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Statoil OCS-EPA-R4012-M1 08/14/14

 Engine Air Inlet Temperature (Celsius);

 Engine Air Inlet Relative Humidity (%);

 Generator Load (kW); and

 Regulated pollutant Emission Concentrations (ppm) and O2 or CO2 

concentration (%)

6.22.1.3 The permittee shall record the date and time of the most recent NOX

analyzer calibration method used to calibrate and the results.

6.22.1.4 permittee shall determine the average emission rate of the monitored air 

pollutant (g/kW-hr) for each engine from the emission rate results in each 

rolling 24-hour period, and total annual emissions in TPY on a 12-month 

rolling basis.

6.22.2 Continuous Emissions Monitoring (Compliance Monitoring Option #2)

6.22.2.1 The permittee shall install, calibrate, maintain, and operate a continuous 

emissions monitoring system with a plan approved by the EPA to monitor 

and record emissions from the main generator engines specified in 

Condition 6.22.

6.22.2.2 The permittee shall obtain stack gas volumetric flow rates using a calibrated 

flow monitor that records data on a continuous basis.

6.22.2.3 The permittee shall monitor and record engine electric power output in kWhr.

6.22.2.4 The quality assurance plan used by the permittee for the certification and 

operation of the continuous emissions monitoring system shall be made 

available to the EPA upon request.

6.22.2.5 The permittee shall determine the average emission rate in g/kW-hr for each 

engine from the hourly emission rate results in each rolling 24-hour period, 

and total annual emissions in TPY on a 12-month rolling basis.

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

6.22.3.1 The permittee shall properly monitor and record emissions from diesel 

engines specified in Condition 6.22 by collecting stack testing data within 

the previous 12 months according to an EPA approved protocol and in 

accordance with Conditions 5.26 and 6.22.3.2 through 6.22.3.7. Data 

collected prior to issuance of this permit may be used with EPA approval. 

After three annual/periodic stack tests of the same drilling vessel, stack test 

frequency may be reduced upon written approval by the EPA.

6.22.3.2 Each stack test shall be conducted at three different loads spanning the 

expected range of operations.
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Statoil OCS-EPA-R4012-M1 08/14/14

6.22.3.3 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. 

6.22.3.4 The permittee shall prepare a graph of engine load versus emission rates 

expressed in g/kW-hr for each engine. Plot the engine load as the 

independent (or x) variable and the pollutant 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.

6.22.3.5 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.

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.

6.22.3.6 The permittee shall determine the average emission rate in g/kW-hr for each 

engine from the hourly emission rate results in each rolling 24-hour period

and total annual emissions in TPY on a 12-month rolling basis.

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

6.23 Compliance Monitoring and Recordkeeping Requirements for Emergency Generators, 

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

Pursuant to Conditions 6.7 through 6.10 and 6.13 through 6.18 and in accordance with Condition 

5.16, the permittee shall monitor and maintain a contemporaneous record of the monthly hours of 

operation of the emergency generator engines (EGEN on both the drill rig Developer and the

drillship Discoverer Americas ), the cargo hold heater on the Discoverer Americas, and the small 

on-board diesel engines (CMU-1 and CMU-2, LB-1 through LB-4, and MOB on the Developer

and FORK-1 and FORK-2, ACOMP-1 and ACOMP-2, LB-1through LB-6 and MOB on the 

Discoverer Americas). 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:

 Unit ID;

 Date/time equipment started;

 Date/time equipment shut down;

 Name of person operating equipment (printed); and
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Statoil OCS-EPA-R4012-M1 08/14/14

 Signature of person operating equipment.

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

6.24 Compliance Monitoring and Recordkeeping Requirements for Support Vessel Engines

In accordance with Condition 5.16, the permittee shall demonstrate compliance with support vessel 

operational limits pursuant to Conditions 6.20 and 6.21 by maintaining a record of support vessel 

operating time and diesel fuel use within a 25 mile radius of the drilling vessel and during standby 

time at the drilling vessel. The permittee shall monitor and maintain a contemporaneous record of 

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

 Date/time entering the 25 mile radius;

 Date/time exiting the 25 mile radius;

 Sulfur content of all fuel used in any engine as specified in Condition 6.3;

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

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

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

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

6.25 Reporting Requirements

All information required to be collected, recorded, or maintained pursuant to Conditions 6.3 

through 6.21 shall be submitted to EPA by the permittee in accordance with the reporting 

specifications detailed in Condition 5.17.

[40 CFR § 71.6(a)(3)(iii) and 55.8]

6.26 New Source Performance Standards and National Emission Standard for Hazardous Air 

Pollutants (HAP) Requirements

6.26.1 The main generator engines, emergency generator engine, and cementing unit engines 

on the Developer drill rig (Units GEN-1 through GEN-8, EGEN, CMU-1, and CMU-2)

and the main generator engines, emergency generator engine, and forklift engines, on 

the Discoverer Americas (GEN-1 through GEN-6, FORK-1, and FORK-2) are subject 

to 40 CFR part 60, subpart IIII based on engine size, per cylinder displacement, and 

model year. The permittee shall demonstrate compliance with the applicable 

requirements through the following:

6.26.1.1 The permittee shall maintain documentation in accordance with Condition 

5.16 that engines specified in Condition 6.26.1 were installed and 

configured according to manufacturer’s specifications.

6.26.1.2 The permittee shall maintain records in accordance with Condition 5.16 of 

manufacturer data indicating compliance with EPA Tier standards, if 

applicable, to the engine. 
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6.26.1.3 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.

6.26.1.4 The permitted engines shall not combust any diesel fuel that does not meet 

the requirements of Condition 6.3.

6.26.2 The emergency generator and emergency air compressor engines on the Discoverer 

Americas (EGEN, ACOMP-1, and ACOMP-2) are subject to 40 CFR part 60, subpart 

IIII based on the per cylinder displacement and model year. The permittee has been 

granted a technical exemption pursuant to 40 CFR § 55.7 from the emission standard 

certification requirement of 40 CFR 60, subpart IIII and must comply with the 

following: 

6.26.2.1 The permittee shall demonstrate compliance with alternate emissions standards as 

specified in Condition 6.15.

6.26.2.2 The permittee shall comply with requirements defined in Conditions 6.26.1.1 

through 6.26.1.4.

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

Section 4), the main generator engines, emergency generator engine, and cementing 

unit engines on the Developer drill rig (Units GEN-1 through GEN-8, EGEN, CMU-1, 

and CMU-2) and the main generator engines, emergency generator engine, forklift 

engines, and emergency air compressor engines on the Discoverer Americas (GEN-1 

through GEN-6, EGEN, FORK-1, FORK-2, ACOMP-1, and ACOMP-2) are subject to 

and shall comply with the applicable requirements of 40 CFR part 63, subpart ZZZZ.

The permittee shall demonstrate compliance with subpart ZZZZ for each engine by 

demonstrating compliance with the applicable requirements of 40 CFR part 60, subpart 

IIII and Conditions 6.26.1 and 6.26.2.]

6.26.4 Compliance with the requirements of Condition 6.26 shall be determined based upon 

recordkeeping required by the Annual Compliance Certification set forth in Condition 

5.21.

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

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

63, subpart ZZZZ, or obtain a technical exemption under 40 CFR § 55.7.

6.26.6 The permittee shall notify EPA prior to use of any new, modified, or reconstructed 

engine intended to be used on the drilling vessel or in replacement of an engine in 

Tables 1 and 2 of Section 4 of this permit, and shall submit to EPA a reevaluation of the 

applicability of pertinent NESHAP and NSPS regulations, as well as copies of the 

manufacturer engine certification to EPA standards.
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[40 CFR §§ 55.7, 55.8, 60 subpart IIII, 63 subpart ZZZZ, 71.6(a)(1), 71.6(a)(3) and 

71.6(c)(1)]