ANADARKO PETROLEUM CORPORATION 1201 LAKE ROBBINS DRIVE, THE WOODLANDS, TEXAS 77380 P.O. BOX 1330 HOUSTON, TEXAS 77251

- 1330 U.S.A. PH. (832)636

- 1000



### March 27 , 2013

Ms. Kelly Fortin U.S. EPA Region 4 61 Forsyth Street, S.W.
Atlanta, GA 30303

- 8960

**RE: Anadarko Petroleum Corporation**  **OCS Air Permit Application for Drilling, Exploration,**

**and Maintenance Activities in the Eastern Gulf of Mexico**

**EPA’s Incompleteness Determination Letter Dated February 27, 2013** 

Dear Ms. Fortin :

On December 26, 2012, Anadarko Petroleum Corporation (Anadarko ) submitted an application for a
construction and operating permit for conducting exploratory drilling and maintenance activity on the
Outer Continental Shelf (OCS) of the Gulf of Mexico. The prop osed operations are pl anned to be
conducted using the Discoverer Spirit drillship and assoc iated support vessels in various lease blocks in

the Eastern Gulf of Mexico (EGOM) , east of the 87.5 degree longitude as described in the submitted
application

.

Anadarko representatives met with EPA Region 4 staff on February 7, 2013 and also had a follow up conference call on February 19, 2013 to discuss the submitted application. Anadarko received a letter

from Ms. Kelly Fortin of EPA Region 4 on February 27, 2 013 providing comments regarding various

sections of the submitted PSD/Title V major source permit application

. EPA Region 4 specified additional information is necessary in order to deem the application complete

. This letter is being submitted in respo nse to comments provided by EPA Region 4

. This letter includes EPA Region 4 comments and Anadarko’s response to those comments.

**Regulatory Applicability**

1. Section 4 of the application contains the Regulatory Applicability Analysis for all emissions unit s
onboard the Discoverer Spirit , and emission units onboard the support vessels that will contribute to the stationary sources aspects of the vessel while attached to the OCS source. The applicability of the New Source Performance Standards (NSPS) and the National Emission Standards for Hazardous Air Pollutants (NESHAPS) is dependent on the model year of the

emission sources. The application does not provide the model year of all emission sources subject to regulatory applicability analysis. The applicat ion should provide the model year of all regulated emission sources in order to support the analysis. For the third party emission sources, the model years and compliance certificates will be required to confirm compliance once the specific engines have b een determined.

### Ms. Fortin, EPA Region 4
Page 2

**Anadarko Response** : The model years for all non

- third party NSPS and NESHAP subject engines are

listed in the table below. For the third party emission sources, the model years and compliance certificates will be submitted to EPA Region 4 once the specific engines have been determined.

**Table 1. Model Years for Applicable Engines Subject to NSPS and NESHAP** 

**EPN Description**  **Model/ Manufacturing Year**  **Drillship**

Power Plant Engines Maximum Operating Emissions

DR

- GE

- 01 Main Propulsion Electrical Generator Engine #1A 199 8

DR

- GE

- 02 Main Propulsion Electrical Generator Engine #1B 199 8

DR

- GE

- 03 Main Propulsion Electrical Generator Engine #1C 199 8

DR

- GE

- 04 Main Propulsion Electrical Generator Engine #1D 199 8

DR

- GE

- 05 Main Propulsion Electrical Generator Engine #2A 199 8

DR

- GE

- 06 Main Propulsion Electrical Generator Engine #2B 199 8 Emergency Engines

DR

- GE

- 07 Emergency Generator 199 8

DR

- GE

- 08 ROV Emergency Generator 2004

DR

- AC

- 01 Emergency Air Compressor Diesel Engine #1 199 7

DR

- AC

- 02 Emergency Air Compressor Diesel Engine #2 199 7 Escape Capsule Engines

DR

- EC

- 01 Escape Capsule Diesel Engine #1 199 7

DR

- EC

- 02 Escape Capsule Diesel Engine #2 199 7

DR

- EC

- 03 Escape Capsule Diesel Engine #3 199 7

DR

- EC

- 04 Escape Capsule Diesel Engine #4 199 7

DR

- EC

- 05 Escape Capsule Diesel Engine #5 199 7

DR

- EC

- 06 Escape Capsule Diesel Engine #6 199 7

DR

- FR

- 01 Fast Rescue Craft 199 7 Forklift Engine

DR

- FL

- 01 Diesel Powered Forklift Engine 2000

Other

DR

- WB

- 01 Water Blasting Engine 2005



### Best Available Control Technology Analysis (BACT)

2. The BACT analy s es for diesel engines in section 5 of the application identified Replacement of

Older Engines with Newer Engines and EPA Tier 2 Standards as available control technologies. The Replacement of Older Engines with Newer Engines should identify the cleanest engines that

### Ms. Fortin, EPA Region 4
Page 3

are currently available; this may be EPA Tier 2, EPA Tier 3 compliant engines, or another cleaner
engine. The BACT analyses for the diesel engines, (specifically DR

- GE

- 07, DR

- GE

- 08, DR

- AC

- 01,

DR

- AC

- 02, third party engines, and SV

- PE

- 01 through SV

- PE

- 08), should identify what the cleanest engines are for each applicable unit, and the use of cleanest available engine in the top

down BACT analyses.

**Anadarko Response** : During the phone call between Anadarko representatives and EPA Region 4 (Ms. Katy Forney and Ms. Eva Land) on February 19, 2013, EPA requested clarification about due diligence performed by Anadarko regarding the cleanest available stimulation vessel pump engines. A nadarko

contacted the stimulation vessel pump vendor . The vendor identified 40 CFR 89 Tier 2 compliant engines as the cleanest available engine s in the stimulation vessel pump engine category ( SV

- PE

- 01 through SV

- PE

- 08). A detailed control cost effective ness analysis for replacing the SV

- PE

- 01 through SV

PE

- 08 with the pumps complying with 40 CFR 89 T ier 2 standards was performed and provided in Appendix E

- 2 of the submitted application. The cost for the engine replacement was estima ted to be $75,788 per ton of NO X 

### reduced, making this option cost prohibitive.

Refer to responses to comments #3a and #3b for DR

- GE

- 07, DR

- AC

- 01, and DR

- AC

- 02 BACT comments. Anadarko is currently obtaining more information about the water blasting engine DR

- GE

- 08 BACT

comm ent and a detailed response is provided at a later date after necessary information is received.

The t hird party engines do not permanently reside on the drillship. These engines will be leased and brought onboard when they are needed for use. BACT for the third Party Engines (DR

- Wl

- 01,

DR

- WL

- 02, DR

- EL

- 01, DR

- EL

- 02, DR

- CU

- 01, DR

- CU

- 02, DR

- WC

- 01 through DR

- WC

- 04, DR

- WC

- 07, and

DR

- WC

- 08) has been qualitatively determined as compliance with 40 CFR 89 Tier 2 Standard and LNE design. Anadarko is currently ob taining more information regarding this comment and a detailed response is provided at a later date after necessary information is obtained.



### 3. The following comments are in reference to the economic feasibility of the engines

referenced below:

a. The NO X 

### , CO, PM/PM 10 

### /PM 2.5 

### and VOC BACT analyses for the Emergency Diesel Engines are provided in Section 5.1.2, 5.2.2, 5.3.2, 5.5.2 of the application, respectively. Step 2 eliminated Replacement of Older Engines with Newer Engines as feasible control technology bec ause this would be cost prohibitive. However, the application does not contain a cost analysis for replacing the existing Emergency Diesel Generator with a newer engine. For this control technology to be considered economically infeasible, the application should provide a cost analysis in Step 4 of the BACT analyses to determine if replacing the emergency diesel engines with new cleaner engines is cost prohibitive.

**Anadarko Response :**  During the phone call between Anadarko and EPA Region 4 (Ms. Katy Forne y and Ms. Eva Land) on February 19, 2013, Anadarko indicated that DR

- GE

- 07 is an IMO Tier 1 certified

emergency generator and it only operates intermittently during emergency situations in addition to maintenance and testing periods. The proposed operatin g time for this engine is 1 hr/day and 100 hrs/yr. Given the engine’s minimal operating time, emissions are minimal. For example, the NO X 

### emissions are less than 3.0 tons per year ( tpy ) . Therefore, Anadarko believed detailed cost infeasibility

is not wa rranted. EPA agreed that a comprehensive cost infeasibility analysis is not required for this equipment; however, EPA requested Anadarko to provide a cost of replacement of this engine with the cleanest available engine in that category

. Accordingly, Ana darko contacted the engine vendor and found that engines complying with 40 CFR 89 Tier 2 standards are the cleanest available engines in this

### Ms. Fortin, EPA Region 4
Page 4

category of e ngines . Anadarko obtained an initial cost estimate of 825,000 Euro for replacing the
existing emergency generator (DR

- GE

- 07) with engine compliant with 40 CFR 89 Tier 2 standards. An email communication with the vendor is provided in the Appendix A of this submittal . G iven the minimal operations of this equipment resulting in lo w emissions , Anada rko believes that replacement of existing emergency engine with the cleanest available engine is cost prohibitive.

b. The NO X 

### , CO, PM/PM 10 

### /PM 2.5 

### and VOC BACT analyses for the Air Compressor Engines are provided in Section 5.1.3, 5.2.3, 5.3.3, 5.5.3 of the ap plication, respectively. Step 1 of the

BACT identified Replacement of the Older Engines with Newer Engines as a technically feasible control technology. In step 2 of the BACT analyses, this option eliminates the control technology as technically infeasib le because it would be extremely cost prohibitive. For this technology to be considered economically infeasible, the application should provide a cost analysis in Step 4 of the BACT analyses to determine if replacing the air compressor engines with Tier 2 compliant engines is cost prohibitive.

**Anadarko Response :**  During the phone call between Anadarko and EPA Region 4 (Ms. Katy Forney and Ms. Eva Land) on February 19, 2013, Anadarko indicated that DR

- AC

- 0 1 and DR

- AC

- 02 are emergency air compressors and they only operate intermittently during emergency situations in addition to maintenance and testing periods. The proposed operating time for this engine is 0.5 hr/day and 100 hr/year . Given the engine’s minimal operating time, the resulting emissions are minimal. For example,

NO X 

### emissions are less than 0.03 tpy. Therefore, Anadarko believed detailed cost infeasibility is not warranted. EPA agreed that a comprehensive cost infeasibility analysis is not required for this equipment; however, EPA requ ested Anadarko to provide a cost of replacement of this engine with the cleanest available engine in that category. Accordingly, Anadarko contacted the engine vendor and found that engines complying with 40 CFR 89 Tier 3 standards are the cleanest availab le engines in this category of equipment. Anadarko obtained an initial cost estimate of $12,600 for replacing the DR

- AC

01 and $10,900 for replacing the DR

- AC

- 02 with similar air compressor engines compliant with 40 CFR

89 Tier 3 standards. An email comm unication with the vendor is provided in the Appendix B of this

submittal . G iven the minimal operations of this equipment resulting in lo w emissions , Anadarko believes that replacement of existing emergency engine with the cleanest available engine is cost prohibitive.

4. The application has identified Painting Operations as source of PM/PM 10 

### /PM 2.5 

### and VOC emissions and included BACT analyses for both these pollutants in sections 5.3.13 and 5.5.14, respectively. These analyses propose best management pra ctices as BACT for both those pollutants, which includes down spraying of paint and use of shroud or barrier around the area being painted. However, the description of the emission source, on page 31 of the application, explains that the airless spray tra nsfer efficiency also affects emissions. The application states that the potential

- to

- emit (PTE) calculations were done assuming 50 % transfer efficiency, but Anadarko is proposing to use a 30% transfer efficiency, which would result in higher emissions

fr om the painting operation. The vendor information provided in the application does not contain the transfer efficiency expected from the proposed airless sprayer. Please provide documentation for the transfer efficiency of the proposed model sprayer and provide revised PM/PM 10 

### /PM 2.5 

### and VOC BACT analyses consistent with the top down approach to evaluate the

various transfer efficiencies.

**Anadarko Response** : Per phone call between Anadarko representatives and EPA Region 4 (Ms. Katy Forney and Ms. Eva Land ) on February 19, 2013, this response is focused on two areas: the paint application method and the VOC content of the paint.

### Ms. Fortin, EPA Region 4
Page 5

**Type of painting** 

In marine environments , t he paint could be applied with air assisted paint gun, airless paint gun, and by use of roller or brush. The transfer efficiency of each paint application method is provided in the Table

below. An email communication with the vendor regarding transfer efficiency for Airless spray gun is provided in the Appendix C of this submittal

.

**Table 2. Paint Application and Transfer Efficiencies**

**Paint Application Method Transfer Efficiency**  **Information Source**
Air assisted spray gun 30% Coating Operations Instructions for Emission

Calculation Spreadsheet

- Minnesota Pollution Control Agency
Airless spray gun 50%

- 80% Phone and e mail communications with the equipment vendor

Roller

- N/A

The paint application method is generally dictated by the characteristics of work areas. An airless spray gun would be used to paint large deck areas or bulkheads since greater volume of paint and fine control is not required. An air assisted spray gun would be required to paint piping, brackets, and other multi

angle items due to paint volume and precision requirements

. A n airless gun requires a great deal of pressure to atomize the material for spray. Due to this pressure, a volume of material that comes out of the gun is increased making this method as a preferred paint ing method o n flat surfaces or tank applications . However, while utilizing this method for painting multi

- angle items

, a lot of the paint material is lost creating overspray and waste. A conventional air assisted gun provides a solution to this

overspray issue due to its operational mechanism. Therefore, use of air assisted spray gun is preferred

for painting small or multi

- angle items

.

Anadarko also considered the possibility of using roller or brush application for the proposed
operations. However, Anadarko fou nd this painting technique unsuitable due to following reasons:

• Marine coatings are designed to perform at certain thicknesses. The proper film thickness
for these materials to perform as designated by the product data sheet is approximately 5
mils thick. The only way to achieve these film thicknesses in a single application is to
spray the coating. A single application with a roller will generate approximately 1.5 mils
in thickness per application. A surface would have to be painted 3 to 4 times per coat to

achieve the manufactures ’ requirements for coating performance.

• T o achieve good film continuity most of the marine coatings are designed to be sprayed.
The atomization of the coating promotes a good flow of the material and creates a t ight
surface that has low moisture permeation which is essential for creating a barrier system

and makes them work.

• Throughout the drilling and well completion operations , painting crew will be dealing

with several areas where a brush or roller c ould not r each and hence, th e material must be
sprayed.

Hence, Anadarko is proposing a combination of air assisted and airless gun for the proposed painting
operations.

### Ms. Fortin, EPA Region 4
Page 6

**VOC Contents of the proposed paints**

The proposed coatings were selected based on following criteria: regulatory requirements, long term performance, waste reduction, and efficiency of application. All of the proposed paint materials are compliant with EPA the marine coatings requirements as specified in EPA 453/R

- 94

- 032

. 1 

### The VOC contents of a coating great ly influence the prospective application area (e.g., flat or metallic) as well as method of application (e.g

. , spray or roller)

. The low VOC paints ha ve a tendency to be very thick making them difficult to be applied to smaller areas

. It takes a great deal of pressure to atomize the low
VOC coatings and this could potentially result in a lot of waste when coating smaller areas

. The low VOC paints work better for the larger surface areas such as hull sections in immersion areas and tank

internals. Anadarko proposed paints could be use d without sacrificing operational requirements.

**Source Description**

5. The boom flare (DR

- WC

- 06) will be used during well completion activities; however the application lacks a detailed description of the boom flare. It is not clear if this flare has a pilot, nor are the situations in which the flare will be used clearly deta iled. Please provide a further description of the flare set

- up and its planned use.

**Anadarko Response :**  The primary purpose of the boom is to locate the flame far enough away from the drillship to reduce heat radiation and protect rig personnel

. The boo m support s the flare system and associated piping

. These booms will be lease d from a third party vendor with a King Post Assembly for a

gu yed installation or Cantilever assembly for a more permanent, self

- supporting installation.. The drillship has perman ent piping assembly to be connected to the boom. This piping assembly supplies
the burner with air, water, oil, and /or pilot line

. The pilot gas assistance is not necessary for certain types of boom f lares. If pilot gas is required then Anadarko propose s to use portable canisters of

propane or butane. There is no separate pilot line available on the dr illship. The drillship only provides housing and structural support to the boom flare assembly. A schematic diagram of the boom is provided in the Figure 1 below.

The flaring operation will be conducted primarily during the well completion operations

. Hence, pilot gas (if necessary) will not be utilized continuously. The pilot gas will be opera ted only during active flowback operations. The boom flare will not be operated during drilling.

If pilot gas is used, overall contribution of the pilot gas is expected to be very minimal (<0.1%) compared
to the gas processed through the boom flare. Ana darko believes emission calculations provided in the
permit application adequately cover the emissions from the pilot gas combustion if pilot gas is used
during flaring operations.

1 Alternate Control Techniques: Surface Coating Operations at Shipbuilding and Ship Repair Facilities, April

1994 . Available online at: http://www.epa.gov/glo/SIPToolkit/ctg_act/199404_voc_epa453_r

- 94

- 032_coating_shipbuilding_repair .pdf

### Ms. Fortin, EPA Region 4
Page 7

**Figure 1. Typical Boom Flare** 

6. Please confirm that there are no welding activities that will generate emissions on the OCS

source. If welding activities do occur, the emissions should be accounted for in the emission calculations and in any other applicable sections in the application.

**Anadarko Response :**  The w elding operati ons will be performed as a part of maintenance activities

. Anadarko is currently working on gathering necessary information for emission calculations, BACT analysis and other regulatory applicability analysis for inclusion of welding operations.

**Emission Calculations**

7. The emission calculation description in section three, and throughout the application, states that the associated support vessels (i.e., supply and anchor handling boats) and equipment (e.g., engines) are unknown so a representative supply boat ( HOS Coral ), handling boat ( Kirk

Chouest ), and third party equipment were used to develop representative emissions. This language is also used to describe the third party engines on the drillship. The EPA recommends
using worst

- case rather tha n representative emissions in the analysis for the support vessel emission units to allow the use of any available support vessel or equipment without the possible need for an additiona l impact assessment or further e m ission limitations.

**Anadarko Response** : Per discussions during a meeting on February 7, 2013, Anadarko concurs that all “representative” air emissions sources described in the application represent the “worst

- case” air emission sources in their respective category. For example, HOS Coral was identified as the worst case supply boat since its PTE of all air pollutants is higher than that of other supply boats in the fleet Anadarko assessed. Therefore, in reality

, HOS Coral is the worst case supply boat from an air emission
perspective. H ence
, an additional impact assessment or further emission limitations are not required while selecting another supply boat among the assessed fleet

.

8. It is unclear how the total worst

- case well completion emissions were calculated. Each well completion scena rio will use both the emission units listed in Table 1 on page 4 of Appendix B and emission units on the drillship and support vessels. For example, each of the four well completion scenarios will use the Main Engines, listed as DR

- ME

- 01 through DR

- ME

- 06, (it is assumed that these engines are the same as the drillship engines listed in the first part of the
emission calculations, DR

- GE

- 01 through DR

- GE

- 06). Yet, this results in a discontinuity. The total emissions from each well completion scenario, list ed at the bottom of Table 1 on page 4, do not result from a summation of the emission units listed on this page. The application indicates that additional units will be used during a given well completion scenario, but the information provided does not clearly show how many hours these emissions units will operate. Please provide an additional chart that provides al l emission units and calculations for the worst

- case well completion scenarios, so that the total emission equal the emissions for each unit presented.

### Ms. Fortin, EPA Region 4
Page 8

**Anadarko Response** : Anadarko confirms that the same main engines (i.e., DR

- GE

- 01 through DR

- GE

06) on the drillship will be used during the well completion activities. However, the requested fuel restriction (i.e., 200 bbl/day) during well completion scenario is lower than that of drilling scenario. Also note that, operation of t he ROV Electric Generator Diesel engine #4 (SB

- GE

- 04) on the work boat and p ainting operations (DR

- PO

- 01) on the drillship will not be occurring at the same time during well completion activities. Hence, in order to represent the worst

- case emissions in each of the well completio n scenarios, the highest emissions amongst these two operations are included in the maximum daily and annual emissions.

**Table 3**

**. Well Completion Scenario** 

**– Emission Source Summary** 

**Air Emission Sources Unit**  **Scenario 1 Scenario 2**  **Scenario 3 Scenario 4** 

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

per day per year per day per year per day per year per day per year

Tubing Running Pumps hours

- - - - - - 24 684

Fluid Filtration Pack hours

- - - - - - 24 1,008

E

- Line Power Pack hours

- - - - - - 24 720

CT Power Pack hours

- - - - - - 24 720

CT Pump hours

- - - - - - 24 720

Tug bbls

- - 340 7,140

- - - -
Barge hours

- - 24 504

- - - -

Flowback Boiler MMbtu 192 1,152 192 1,152

- - - -

Boom Flare MMscf 60 360 40 160

- - - -

Slickline Power Pack hours

- - - - - - 24 1,440

Stimulatio n Vessel

Engines hours

- - - - 24 504

- - Drillship Main Engines bbls 200 41,600 200 41,600 200 41,600 200 41,600

Su pply Boats hours 16 3,328

- - - - 16 3,328

Painting (paint +

thinner) gals 34

- 34

- 34

- 34

-

### Ms. Fortin, EPA Region 4
Page 9

**T able**  **4**

**. Well Completion Scenario** 

**– PM Emissions** 

**Table 5. Well Completion Scenario** 

**– PM**  **10** 

### Emissions **Air Emission Sources Scenario 1**  **Scenario 2 Scenario 3**  **Scenario 4**

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 1.44 0.02

Fluid Filtration Pack

- - - - - - 1.19 0.02

E

- Line Power Pack

- - - - - - 1.78 0.03

CT Power Pack

- - - - - - 4.73 0.07

CT Pump

- - - - - - 6.79 0.1

Tug

- - 295.68 3.10

- - - - Barge

- - 28.51 0.30

- - - -

Flowback Boiler 4.40 0.01 4.40 0.01

- - - -

Boom Flare 446.88 1.34 297.93 0.90

- - - -

Slickline Power Pack

- - - - - - 0.99 0.03

Stimulation Vessel Engines

- - - - 212.92 4.09

- - Drillship Main Engines 113.07 11.78 113.07 11.78 113.07 11.78 113.07 11.78

Supply Boats 58.99 6.35

- - - - 58.99 6.35

Painting (paint + thinner) 1.86

- 1.86 0.1 1.86 0.1 1.86

-

**Total Emissions 625.20**  **19.48 741.45**  **16.19 327.84**  **15.97 190.83**  **18.4**

**Air Emission Sources Scenario 1**  **Scenario 2 Scenario 3**  **Scenario 4**

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 1.44 0.02

Fluid Filtration Pack

- - - - - - 1.19 0.02

E

- Line Power Pack

- - - - - - 1.78 0.03

CT Power Pack

- - - - - - 4.73 0.07

CT Pump

- - - - - - 3.89 0.06

Tug

- - 169.42 1.78

- - - - Barge

- - 28.51 0.30

- - - -

Flowback Boiler 4.40 0.01 4.40 0.01

- - - -

Boom Flare 446.88 1.34 297.93 0.90

- - - -

Slickline Power Pack

- - - - - - 0.99 0.03

Stimulation Vessel

Engines

- - - - 122.00 2.34

- - Drillship Main Engines 64.79 6.75 64.79 6.75 64.79 6.75 64.79 6.75

Supply Boats 48.31 5.24

- - - - 48.31 5.24

Painting (paint +

thinner) 1.86

- 1.86 0.1 1.86 0.1 1.86

-

**Total Emissions 566.24**  **13.34 566.91**  **9.83 188.65**  **9.19 128.98**  **12.21**

### Ms. Fortin, EPA Region 4
Page 10

**Table 6. Well Completion Scenario** 

**– PM**  **2.5** 

### Emissions

**Table 7. Well Completion Scenario** 

**– NO**  **X** 

### Emissions **Air Emission Sources Scenario 1**  **Scenario 2 Scenario 3**  **Scenario 4**

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 1.44 0.02

Fluid Filtration Pack

- - - - - - 1.19 0.02

E

- Line Power Pack

- - - - - - 1.78 0.03

CT Power Pack

- - - - - - 4.73 0.07

CT Pump

- - - - - - 3.77 0.06

Tug

- - 164.40 1.73

- - - - Barge

- - 28.51 0.30

- - - -

Flowback Boiler 4.40 0.01 4.40 0.01

- - - -

Boom Flare 446.88 1.34 297.93 0.90

- - - -

Slickline Power Pack

- - - - - - 0.99 0.03

Stimulation Vessel Engines

- - - - 118.38 2.27

- - Drillship Main Engines 62.87 6.55 62.87 6.55 62.87 6.55 62.87 6.55

Supply Boats 46.85 5.08

- - - - 46.85 5.08

Painting (paint + thinner) 1.86

- 1.86 0.1 1.86 0.1 1.86

-

**Total Emissions 562.86**  **12.98 559.96**  **9.58 183.11**  **8.92 125.48**  **11.86**

**Air Emission Sources**  **Scenario 1 Scenario 2**  **Scenario 3 Scenario 4** 

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 26.98 0.38

Fluid Filtration Pack

- - - - - - 26.16 0.55

E

- Line Power Pack

- - - - - - 58.67 0.88

CT Power Pack

- - - - - - 151.51 2.27

CT Pump

- - - - - - 217.17 3.26

Tug

- - 5451.13 57.24

- - - - Barge

- - 401.76 4.22

- - - -

Flowback Boiler 32.03 0.10 32.03 0.10

- - - -

Boom Flare 4078.37 12.24 2718.91 8.16

- - - -

Slickline Power Pack

- - - - - - 32.83 0.98

Stimulation Vessel

Engines

- - - - 6621.61 133.03

- - Drillship Main Engines 4080.29 425.12 4080.29 425.12 4080.29 425.12 4080.29 425.12

Supply Boats 2191.42 227.90

- - - - 2191.42 227.90

Painting (paint +

thinner)

- - - - - - - -

**Total Emissions 10,382.11**  **665.36 12,684.12**  **494.83 10,701.91**  **558.16 6,785.03**  **661.36**

### Ms. Fortin, EPA Region 4
Page 11

**Table 8** 

**. Well Completion Scenario** 

**– SO**  **2** 

### Emissions

**Table 9** 

**. Well Completion Scenario** 

**– H**  **2** 

### SO **4** 

### Emissions **Air Emission Sources Scenario 1**  **Scenario 2 Scenario 3**  **Scenario 4**

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 2.48E

- 02 3.53E

- 04

Fluid Filtration Pack

- - - - - - 2.70E

- 02 5.68E

- 04

E

- Line Power Pack

- - - - - - 6.06E

- 02 9.08E

- 04

CT Power Pack

- - - - - - 1.62E

- 01 2.42E

- 03

CT Pump

- - - - - - 2.31E

- 01 3.47E

- 03

Tug

- - 4.74 0.05

- - - - Barge

- - 1.45E

- 01 1.53E

- 03

- - - -

Flowback Boiler 2.84E

- 01 8.53E

- 04 2.84E

- 01 8.53E

- 04

- - - -

Boom Flare 35.38 0.11 23.52 0.07

- - - -

Slickline Power Pack

- - - - - - 3.39E

- 02 1.02E

- 03

Stimulation Vessel Engines

- - - - 3.90 7.07E

- 02

- - Drillship Main Engines 1.81 0.19 1.81 0.19 1.81 0.19 1.81 0.19

Supply Boats 2.04 0.21

- - - - 2.04 0.21

Painting (paint + thinner)

- - - - - - - -

**Total Emissions 39.42**  **0.51 30.50**  **0.31 5.72**  **0.26 4.40**  **0.41**

**Air Emission Sources**  **Scenario 1 Scenario 2**  **Scenario 3 Scenario 4** 

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 7.74E

- 04 1.10E

- 05

Fluid Filtration Pack

- - - - - - 8.44E

- 04 1.77E

- 05

E

- Line Power Pack

- - - - - - 1.89E

- 03 2.84E

- 05

CT Power Pack

- - - - - - 5.05E

- 03 7.57E

- 05

CT Pump

- - - - - - 7.23E

- 03 1.08E

- 04

Tug

- - 0.15 1.55E

- 03

- - - - Barge

- - 4.54E

- 03 4.77E

- 05

- - - -

Flowback Boiler 0 0 0 0

- - - -

Boom Flare 0 0 0 0

- - - -

Slickline Power Pack

- - - - - - 1.06E

- 03 3.18E

- 05

Stimulation Vessel

Engines

- - - - 0.12 2.21E

- 03

- - Drillship Main Engines 5.66E

- 02 5.90E

- 03 5.66E

- 02 5.90E

- 03 5.66E

- 02 5.90E

- 03 5.66E

- 02 5.90E

- 03

Supply Boat s 6.39E

- 02 6.65E

- 03

- - - - 6.39E

- 02 6.65E

- 03

Painting (paint +

thinner)

- - - - - - - -

**Total Emissions 0.12**  **0.01 0.21**  **0.01 0.18**  **0.01 0.14**  **0.01**

### Ms. Fortin, EPA Region 4
Page 12

**Table 10** 

**. Well Completion Scenario** 

**– CO Emissions** 

**Table 11** 

**. Well Completion Scenario** 

**– VOC**  **Emissions Air Emission Sources**  **Scenario 1 Scenario 2**  **Scenario 3 Scenario 4** 

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 17.99 0.26

Fluid Filtration Pack

- - - - - - 19.82 0.42

E

- Line Power Pack

- - - - - - 31.11 0.47

CT Power Pack

- - - - - - 82.86 1.24

CT Pump

- - - - - - 118.76 1.78

Tug

- - 2323.20 24.39

- - - - Barge

- - 86.57 0.91

- - - -

Flowback Boiler 6.67 0.02 6.67 0.02

- - - -

Boom Flare 22191.12 66.57 14794.08 44.38

- - - -

Slickline Power Pack

- - - - - - 17.41 0.52

Stimulation Vessel Engines

- - - - 2057.90 36.16

- - Drillship Main Engines 257.03 26.78 257.03 26.78 257.03 26.78 257.03 26.78

Supply Boats 1517.1 157.78

- - - - 1517.1 157.78

Painting (paint + thinner) 0

- 0 0 0 0 0

-

**Total Emissions 23,971.92**  **251.15 17,467.55**  **96.48 2,314.92**  **62.94 2,062.07**  **189.24**

**Air Emission Sources Scenario 1**  **Scenario 2 Scenario 3**  **Scenario 4**

Gas Well Completion Oil Well Completion Stimulation Vessel Third Party Equipment

lb/day tpy lb/day tpy lb/day tpy lb/day tpy

Tubing Running Pumps

- - - - - - 5.55 0.08

Fluid Filtration Pack

- - - - - - 6.05 0.13

E

- Line Power Pack

- - - - - - 13.58 0.20

CT Power Pack

- - - - - - 36.17 0.54

CT Pump

- - - - - - 13.24 0.20

Tug

- - 270.99 2.85

- - - - Barge

- - 32.55 0.34

- - - -

Flowback Boiler 2.67E

- 01 8.01E

- 04 2.67E

- 01 8.01E

- 04

- - - -

Boom Flare 8396.64 25.19 5597.76 16.79

- - - -

Slickline Power Pack

- - - - - - 7.61 0.23

Stimulation Vessel

Engines

- - - - 223.33 4.04

- - Drillship Main Engines 92.61 9.65 92.61 9.65 92.61 9.65 92.61 9.65

Supply Boats 117.51 12.23

- - - - 117.51 12.23

Painting (paint +

thinner) 142.30

- 142.30 7.40 142.30 7.40 142.30

- Well Completion Tanks 66.60 9.26 66.60 9.26 66.60 9.26

- -

**Total Emissions 8,815.92**  **56.33 6,203.07**  **46.29 524.83**  **30.35 434.60**  **23.26**

### Ms. Fortin, EPA Region 4
Page 13

9. From Table 1 and Table 3 of Appendix B it is unclear how the emissions for the Main Propulsion Generator Engines (DR

- GE

- 01 through DR

- GE

- 06) were calculated. The detailed emission

calculations for DR

- GE

- 01 through DR

- GE

- 06 are provided in this section. However, in Table 1 underneath the rows for the Main Propulsion Generator Engines there is a row titled, “Main
Engines Worst

- Case Operating Emissions (Maximum 325 bbls/day of fuel used for all main engines).” The application does not provide information how the numbers in this row were calculated. Page one of the emission calculations presents a mass balance based on fuel usage for

SO 2 

### and H 2 

### SO 4 

### only. If this column is based o n fuel usage, there are no conversion provided for the additional pollutants listed in the table. Moreover the detailed calculations for this row are not provided. Please provide additional explanation, assumptions and/or calculations for the

row titled “ Main Engines Worst

- Case Operating Emissions (Maximum 325 bbls/day of fuel used for all main engines).”

**Anadarko Response** : The 325 bbls/day represents the annual average fuel consumption for the main engines on the drillship. Similarly, 425 bbls/day rep resent maximum fuel consumption for the main engine on the drillship. There is a typographical error in the row titled “Main Engines Worst

- Case Operating Emissions (Maximum 325 bbls/day of fuel used for all main engines).” It should be revised to:

“Main Engines Average Annual Operating Emissions ( Average 325 bbls/day of fuel used for 208 days/year for all main engines).”

Anadarko used the following approach in estimating the emissions and corresponding fuel limitation for the maximum daily and annual average fuel consumption. The fuel consumption at 50% operating load

for each Wartsila main engine ( DR

- GE

- 01 through DR

- GE

- 06) is 192 g/kW

- hr. The 50% operating load is typical operating load for main engines of the drillship operations at OCS

. Each mai n propulsion electric generator engines #1 through #4 (DR

- GE

- 01 through DR

- GE

- 04) rated 9,910 HP respectively,

could consume 126 bbls/day of fuel at 50% operating load. Similarly, main propulsion electric generator engines #5 and #6 (DR

- GE

- 05 and DR

- GE

- 06)

, rated 6,6 10 HP each

, could consume 84 bbls/day of fuel at 50% operating load. The emissions in the row referenced in EPA comments were calculated based on an average fuel consumption of 325 bbls /day which would result in the generation

of 237,2 45 kw / day ( 322,511 HP/day ) from a combination of main engines. Using emission factors provided in Appendix B of the submitted application and expected power generation of approximately 9,885.24 kw/hr (13,437.96 HP/hr)

, emissions of each pollutant were cal culated.

An example calculation for NO X 

### and PM is provided below.

NO X 

### emissions = 9

, 885.24 kw * 12.7 gram /kw

- hr * 24 hr / day * 208 day/ year * 1.1023 1 E

- 6 tons/gram = 690.83 tons/year

PM emissions = 13,437.96 HP * 5,708 Btu/HP

- hr * 0.1 lb/MMBtu * 24 hr/day * 208 day/year * 10 E

- 6 MMBtu/Btu * 0005 tons/lb = 19.14 tons/year

Same emission calculation methodology is used to estimate maximum daily emissions. Anadarko is

prop osing a fuel limitation based on the historical fuel requirements for the main propulsion electric
generator engines on the drillship while operating at locations outside of the EGOM. Anadarko proposes to retain the flexibility of using any combination of the six main engines on the drillship as long as they meet the fuel and emissions limitations as represented in the submitted application (i.e., 325 bbls/day of average daily fuel used for all main engines)

.

### Ms. Fortin, EPA Region 4
Page 14

10. The emission calculation tables for the M ain Propulsion Electrical Generator Engines notes that the data used for CO emissions factor is based on data from Wartsila LNE engine specifications for operating at 50% load, and “The more conservative factor is chosen between the stack test (December 20 10) and Vendor Provided Data,” footnote 1 found in Appendix B. However, based on a review of Stack Test Report, found in Appendix H, the highest emission rates occurs not at 50% load, but at an approximate load of 20%. Emission limits will be established with emissions presented in the permit application. The application should verify that the main engines will be

able to meet the emissions at all loads.

**Anadarko Response** : Anadarko concurs that the emission limits requested in the permit application is adequate

. The proposed emission rate results in the worst case mass emissions for any combination of emission rate and associated engine load. Although the source test results in Appendix H occasionally show emission factors higher than the proposed emission factor, those higher emission factors are

associated with lower loads. The mass emission limits account for both emission factors as well as engine loads and hence, Anadarko proposed a combination of emission factor (0.8 g/kw

- hr) and engine

load (50%) that results in the worst case mass emissions.

**Modeled Operational Scenarios**

Temporary Source Exemption

– The content of the application assumes the project will qualify as a temporary emission source (i.e., project duration less than 2 years), and therefore will be exempted from the ambient impact asses s ment as provided in 40 CFR 52.21(i)(3). The followin g comments are associated with this exemption.

11. The provided PSD Class I area modeling is not, as indicated in the application, to demonstrate compliance with the PSD Class I increments, NAAQS, and AQRV but to demonstrate compliance with the exemption requ irement of no project impacts to any PSD Class I area.

12. For a source to qualify as a temporary emission source it must meet several requirements, including that the source must demonstrate that its emissions will not impact any Class I area

and no area w here an applicable increment is known to be violated 40 CFR 52.21(i)(3)(i). The application does not address the requirement that the project will have no impacts in any area with known violations of the PSD increments. Please provide a description of the analysis performed and conclusions to address this requirement.

**Anadarko Response** : The proposed project will be conducted in the EGOM. There is no known area with known violations of the PSD increments along the EGOM shoreline. Moreover, Trinity conta cted

the r egulatory a gencies of Louisiana, Mississippi, Alabama, and Florida to confirm that there are no areas along the EGOM state

- seaward boundary with known violation s of PSD i ncrements. Therefore

, Anadarko believes the proposed project will have no i mpact in any area with known violation of PSD

Increments. R efer to Appendix D of this submittal for correspondence with the state agenc ies.

Project Drilling and Support Vessels

– The following comments are associated with the project emission

sources use d in the impact assessment

.

13. Section 2.1 of the Class I Area Air Quality Dispersion Modeling Analysis Report (Appendix D)

indicates worst

- case support vessels emissions were modeled. This section states the hourly, daily, and annual emissions were estimat ed for the worst

- case boats to conservatively account

for the worst

- case emissions from the support vessels potentially available to support

### Ms. Fortin, EPA Region 4
Page 15

operations of the drillship. However, the description provided earlier in the application

describes these sources as representative. Please clarify the assumptions made for "representative emissions."

**Anadarko Response** : R efer to the response in Item # 7. The representative emissions reflect the worst

case emissions from the support vessels.

14. The Q/D analysis indicates emission sources operating intermittently or seasonally were adjusted to account for year round operation. This adjustment does not appear appropriate given the Federal Land Manager's guidance states that the Q value used in this assessment

shou ld be the sum of maximum 24

- hour emissions of all visibility impairing pollutants annualized in tons per year. The adjustment procedure and its appropriateness should be explained.

**Anadarko Response** : Anadarko prepared th e Q/d in accordance with the Fede ral Land Managers (FLM) guidance. The adjustment refers to the maximum daily emissions and converting it to year round emissions. The Q/d analysis as presented in Appendix E of the modeling report in the submitted application is based on the annualized e missions calculated using maximum daily emissions (i.e., annualized emissions = max daily emissions in pounds per day * 365 days per year

. )

An example calculation for NO X 

### is provided below.

Annualized NO X 

### emissions = 12,684.13 lb/day * (1/2000) tons/lb * 365 days/year
= 2314.87 tons per year

**Requests for Clarification**

1. Table 1

- 2 on page 3 of the application lists the project's PTE. The PTE for PM 10 

### is listed at 33.60
tons per year. However, “ Table 1

- Annual Emissions Summary (tons/year)” found on page 4 of Appendix A, lists the total emissions for PM 10 

### from the drilling operating scenario as 23.03 tons per year. Please clarify this discrepancy and provide the correct PTE for PM 10



### .

**Anadarko Res ponse**  : Anadarko concurs with EPA Region 4 and would like to correct the typographical

error in Table 1

- 2 on page 3 of the application. The correct PM 10 

### value is 23

. 03 tons per year as listed in Table 1 of Appendix A in the submitted application. The cor rected “ Table 1

- 2

- Project Potential to Emit (tons/year)” is attached in Appendix E of this submittal

.

2. The NO X 

### , CO, PM/PM 10 

### / PM 2.5 

### and VOC BACT analyses for the drillship third party engines selected LNE design as BACT, sections 5.1.8, 5.2.8, 5.3.8, 5.5.8, respectively. These BACT analyses have ranked LNE design in Step 3; however, Step 1 of the BACT analyses did not identify LNE design as an applicable control technology. Please correct this inconsistency in the application and verify that LNE design is par t of BACT control for NO X 

### , CO, PM/PM 10 

### / PM 2.5 

### and VOC from the third party engines.

**Anadarko Response** : The third party engines on the drillship are a combination of small (<500 hp) and large (>500 hp) diesel engines, and the NO X 

### control options identified for the main drillship engines are assumed to sufficiently account for all the possible control technologies for the third party engines. T he same options identified for the drillship main diesel engines are considered as the pot ential control

### Ms. Fortin, EPA Region 4
Page 16

technologies for the third party engines on the drillship identified in this comment

. Hence , LNE design was included as an applicable control technology for all engines described in this comment

.

**Upcoming Change to Global Warming Potential**

The EPA would like to make you aware of an upcoming change to the Global Warming Potential (GWP) factors in 40 CFR Part 98, Subpart A, Table A

- 1; which were used in calculating the greenhouse gas (GHG) CO 2 

### e emissions from your project. The EPA anticipate s that the GWP factors in Part 98 will be revised this year. It is anticipated that a Federal
Register notice will be published in March of this year and the revisions finalized this fall. Please be aware that if your permit has not been issued by the time the new GWP factors are effective, you will need to revise your GHG (CO 2 

### e) emissions calculations for your project. The EPA will notify you when the proposed revisions to Part 98 have been published.

**Anadarko Response** : Anadarko will revise the GHG (CO 2 

### e) emissions and reevaluate the GHG (CO 2 

### e) regulatory applicability if the new GWP factors are effective prior to issuance of the permit.

## APPENDIX A : EMAIL COMMUNICATI ON RECORD BETWEEN ANADARKO

AND VENDOR REGARDING EME RGENCY GENERATOR COS T

### Anadarko EPA question 3(a) - Email from Vendor about the cost

Rahul Pendse to: Dhesikan Venkatesan 03/04/2013 01:55 PM

History: This message has been forwarded.

Best Regards,

Rahul Pendse

------------------------------------------------------------------------------------------------------------------------------- ------

Rahul Pendse │ Managing Consultant │ rpendse@trinityconsultants.com

Trinity Consultants │ 301 Main Street, Suite 900 │ Baton Rouge, LA 70825

Office: 225-346-4003 │ Fax: 225-346-4032 │ Cell: (714) 454-0518

----- Forwarded by Rahul Pendse/Trinity Consultants on 03/04/2013 02:55 PM -----

From: "Carlson, Sara" <Sara.Carlson@anadarko.com>

To: "Rahul Pendse (rpendse@trinityconsultants.com)" <rpendse@trinityconsultants.com>,

Cc: "Maness, Katie" <Kathryn.Maness@anadarko.com>

Date: 03/04/2013 02:26 PM Subject: FW: Tier 2 engines

Hey Rahul,

Here's the cost for the emergency generator BACT question.

Sara

From: Matts.Andersson@wartsila.com [mailto:Matts.Andersson@wartsila.com]
Sent: Monday, March 04, 2013 8:16 AM
To: Carlson, Sara Cc: Dougie.Robertson@deepwater.com Subject: RE: Tier 2 engines

Good morning Sara, Sorry for not getting back to you sooner.

The cost of just the engine (W6R32 tier 2) is about 825,000 Euro. Generator

not included.

Best Regards

Matts G. Andersson

Account Manager
Wartsila North America

Houston Texas
Office: 281 233 6253

Cell: 281 732 3347

Email: matts.andersson@wartsila.com<mailto:matts.andersson@wartsila.com>

From: Carlson, Sara [mailto:Sara.Carlson@anadarko.com]<mailto:[
mailto:Sara.Carlson@anadarko.com]>
Sent: Thursday, February 28, 2013 4:21 PMThanks,

Sara

From: Matts.Andersson@wartsila.com [mailto:Matts.Andersson@wartsila.com]
Sent: Monday, March 04, 2013 2:29 PM
To: Carlson, Sara Subject: RE: Tier 2 engines

Hi Sara,

Correct

Matts

From: Carlson, Sara [mailto:Sara.Carlson@anadarko.com]<mailto:[
mailto:Sara.Carlson@anadarko.com]>
Sent: Monday, March 04, 2013 2:27 PM
To: Andersson, Matts Subject: RE: Tier 2 engines

Thanks Matt! Just to confirm this is the cleanest engine you would have available to replace that?

Thanks,

Sara

From: Matts.Andersson@wartsila.com<mailto:Matts.Andersson@wartsila.com> [
mailto:Matts.Andersson@wartsila.com]<mailto:[
mailto:Matts.Andersson@wartsila.com]>
Sent: Monday, March 04, 2013 8:16 AM
To: Carlson, Sara Cc: Dougie.Robertson@deepwater.com<mailto:Dougie.Robertson@deepwater.com> Subject: RE: Tier 2 engines

Good morning Sara, Sorry for not getting back to you sooner.

The cost of just the engine (W6R32 tier 2) is about 825,000 Euro. Generator

not included.

Best Regards

Matts G. Andersson

Account Manager
Wartsila North America

Houston Texas
Office: 281 233 6253

Cell: 281 732 3347

Email: matts.andersson@wartsila.com<mailto:matts.andersson@wartsila.com>

From: Carlson, Sara [mailto:Sara.Carlson@anadarko.com]<mailto:[
mailto:Sara.Carlson@anadarko.com]>
Sent: Thursday, February 28, 2013 4:21 PM
To: Andersson, Matts Subject: RE: Tier 2 engines

## APPENDIX B : EMAIL COMMUNICATI ON RECORD BETWEEN AN ADARKO

AND VENDOR REGARDING EMERGENCY COMPRESSORS COST

# Offer

HN-Q130615/13 OCEAN POWER AND EQUIPMENT CO. INC.

1140 BLOOMFIELD AVENUE - SUITE 107

1 Page : WEST CALDWELL

Phone NEW JERSEY 07006-7126

UNITED STATES Offer. date : 14. March 2013

Our ref : HN

Anadarko Petroleum Corp Re. : Diesel driven air compressors

To be agreed upon Payment : Validity : 90 days
Del. week : See below

Hull/Vessel : Your ref. : Chris Bergmann

Fax : 0019735755850 Rev. date : 14. March 2013

: 0019735755775

Description Qty Amount

10 900,00 1 Diesel Driven Air Compressor type HL2/90 12 600,00 1 Diesel Driven Air Compressor type HL2/105

Total price EXW Ellingsøy, Incoterms 2010 23 500,00 USD

Classification: TEST

Delivery time: 6-8 weeks Ex.Works from receipt of order subject to availability at ordering date. Prices are fixed for delivery in 2013. For delivery later 0,3 % per month must be added.

According to "General conditions for supply of plan t and machinery for export", Delivery conditions: formula ECE 188 together with addendum of 1980 and the below mentioned deviations.

12 months from the date the equipment is put into s ervice, however limited to 18 months Warranty: from the time the equipment is ready for dispatch f rom our works. Possible repaired or replaced components will be shipped FCA Aalesund. Should pos sible guarantee-repairs require effectuation by us on your site, travelling and cost of living expense s will be charged as extras.

Yours sincerely, Sperre Industri AS

Harald Ness Area Sales Manager We trust you will find our proposal of interest and look forward to hearing from you in due time.

IBAN: NO84 5353 0500 590 Bank (Norway): 5353 0500 590

NO 961 479 142 VAT www.sperre.com +47 70 16 11 10 Fax

NORWAY 6057 ELLINGSØY Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: D NBANOKK

# Offer

HN-Q130615/13

2 Page :

Item No. Qty Description

Emergency Air Compressor HL2/90 aircooled compressor ELD905 1 2-stage, 2-cylinder design. Capacity: 34 m3/h FAD tol. +/-5% Working pressure: 30 barg Speed approx.: 1500 rpm Power requirement: 7,6 kW Heat dissipation: 5817 kCal/h

Built-in accessories:

Air suction filter with silencer Air safety valve HP and LP Air pressure gauge HP

Built-in inter- and aftercooler

Mounted on compressor unit:

Motor Lister TR2 01 7203 1 two cylinder 4-stroke diesel engine Power: 15,4 kw 20.9Bhp 2500 rpm. inclusive following items: - Diesel engine parts mounted on: TR2 NA Silencer Eng Mtd Med duty TR2 FB fuel tank -13,5 l - eng mtd TR2 AA Air clearner- Medium Duty Dry - Diesel engine parts delivered loose: TR2 IE Operator handbook -English TR2 EB starting handle - long grip

- Coupling flange, diesel ø40 1374-40 1 Baseplate HL2/77-105 D 169 1

Delivered loose: Vibration damper A2, set 4606S1 1

Flex.tube 1" x 800 mm 4597 1 Exhaust tube w/flange 4738 1 Water separator V23-1 1941 1 Non return valve KV35 complete 4491 1

Spareparts, consisting of: Valve compl. suction/delivery 3036 1 Valve compl. suction/delivery 3037 1 Scraper ring HL-LL2/90 3489 2 Oil scraper ring LL2/90 3531 2 Oil scraper ring HL2/77-105 3528 1 Compr.ring HL2/77-105 3501 1

IBAN: NO84 5353 0500 590 Bank (Norway): 5353 0500 590

NO 961 479 142 VAT www.sperre.com +47 70 16 11 10 Fax

NORWAY 6057 ELLINGSØY Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: D NBANOKK

# Offer

HN-Q130615/13

3 Page :

Item No. Qty Description

Compr ring Stp. HL2/77-105 3487 2

Seaworthy packing PW77D 1 General arrangement drawing G02-0051 1 Installation diagram 77-90-105 D02-0051 1

Emergency Air Compressor HL2/105 aircooled compressor ELD105 1 2-stage, 2-cylinder design. Capacity: 43 m3/h FAD tol. +/-5% Working pressure: 30 barg Speed approx.: 1500 rpm Power requirement: 9,9 kW Heat dissipation: 7577 kCal/h

Built-in accessories:

Air suction filter with silencer Air safety valve HP and LP Air pressure gauge HP

Built-in inter- and aftercooler

Mounted on compressor:

Motor Lister TR2 01 7203 1 two cylinder 4-stroke diesel engine Power: 15,4 kw 20.9Bhp 2500 rpm. inclusive following items: - Diesel engine parts mounted on: TR2 NA Silencer Eng Mtd Med duty TR2 FB fuel tank -13,5 l - eng mtd TR2 AA Air clearner- Medium Duty Dry - Diesel engine parts delivered loose: TR2 IE Operator handbook -English TR2 EB starting handle - long grip

- Coupling flange, diesel ø40 1374-40 1 Baseplate HL2/77-105 D 169 1

Delivered loose: Exhaust tube w/flange 4738 1 Vibration damper A2, set 4606S1 1

Flex.tube 1" x 800 mm 4597 1 Water separator V23-1 1941 1 Non return valve KV35 complete 4491 1

IBAN: NO84 5353 0500 590 Bank (Norway): 5353 0500 590

NO 961 479 142 VAT www.sperre.com +47 70 16 11 10 Fax

NORWAY 6057 ELLINGSØY Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: D NBANOKK

# Offer

HN-Q130615/13

4 Page :

Item No. Qty Description

Spareparts, consisting of: Valve compl. suction/delivery 3036 1 Valve compl. suction/delivery 3037 1 Scraper ring HL2-LL2/105 3490 2 Oil sc. ring LL2/105 HV2/240 3535 2 Oil scraper ring HL2/77-105 3528 1 Compr.ring HL2/77-105 3501 1 Compr ring Stp. HL2/77-105 3487 2

Seaworthy packing PW77D 1 General arrangement drawing G02-0051 1 Installation diagram 77-90-105 D02-0051 1

SPERRE STANDARD Painting:

IBAN: NO84 5353 0500 590 Bank (Norway): 5353 0500 590

NO 961 479 142 VAT www.sperre.com +47 70 16 11 10 Fax

NORWAY 6057 ELLINGSØY Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: D NBANOKK

## APPENDIX C : EMAIL COMMUNICATI ON RECORD BE TWEEN TRINITY AND

VENDOR REGARDING TRA NSFER EFFICIENCY

### Fw: Binks.com Technical Support Request

Rahul Pendse to: Dhesikan Venkatesan 03/12/2013 01:13 PM

Airless gun control efficiency documentation.

Best Regards,

Rahul Pendse

------------------------------------------------------------------------------------------------------------------------------- ------

Rahul Pendse │ Managing Consultant │ rpendse@trinityconsultants.com

Trinity Consultants │ 301 Main Street, Suite 900 │ Baton Rouge, LA 70825

Office: 225-346-4003 │ Fax: 225-346-4032 │ Cell: (714) 454-0518

----- Forwarded by Rahul Pendse/Trinity Consultants on 03/12/2013 02:12 PM -----

From: Rachael Startin/Trinity Consultants

To: Rahul Pendse/Trinity Consultants@TCI

_ Dallas,

Date: 03/12/2013 02:07 PM Subject: Fw: Binks.com Technical Support Request

----- Forwarded by Rachael Startin/Trinity Consultants on 03/12/2013 02:06 PM -----

From: Mark Schmidt Jr <MSchmidtJr@finishingbrands.com>

To: "rstartin@trinityconsultants.com" <rstartin@trinityconsultants.com>

Date: 03/12/2013 02:04 PM Subject: RE: Binks.com Technical Support Request



### Rachael,

Yes I can confirm that 50% transfer efficiency is obtainable using the airless outfit. That percentage can
and will vary depending on the coating being sprayed, production rate, the painter, etc.

Thank you

Mark Schmidt Jr.

Technical Support

195 Internationale Blvd

Glendale Heights, IL 60139

P:630

‐ 237

‐ 5127

F:888

‐ 246

‐ 5732 mschmidtjr@finishingbrands.com

From: rstartin@trinityconsultants.com [ mailto:rstartin@trinityconsultants.com]

Sent: Tuesday, March 12, 2013 1:50 PMTo: Mark Schmidt Jr Subject: Binks.com Technical Support Request Importance: High



### Hi! At 3/12/2013 1:49:58 PM a message has been submitted . Message Content:

First Name*: Rachael

Last Name*: Startin

Email*: rstartin @ trinityconsultants

. com Phone*: 713-552-1371 Comments*: Hello, I spoke to someone in the technical department a few weeks ago to ask about the airless spray transfer efficiency of the 98-972 4B cart mount. Could you please confirm via email that 50% is a reasonable estimate for the airless spray transfer efficiency of this model? Thank you, Rachael Startin Company Name*: Trinity Consultants Address*: 1001 West Loop South City*: Houston

State: Texas Country: United States

Postal Code*: 77027

From Email: rstartin @ trinityconsultants

. com

## APPENDIX D : EMAIL COMMUNICATI ON RECORD BETWEEN TR INITY AND

STATE AGENCIESDhesikan,

I don't know of any increment violations along the Gulf C oast or anywhere else in Mississippi. I am copying Jerry Beasley on this email so that he may confirm. If there were known violations of the increment we would have to address it in our SIP and Jerry handles our SIP submittals.

From: Dhesikan Venkatesan <DVenkatesan@TrinityConsultants.com>

To: Bruce_Ferguson@d eq.state.ms.us,

Date: 02/19/2013 04:36 PM

Subject: Question regarding an area where an applicable increment is known to be violated along the state seaward boundary of Mississipp i

Greetings Bruce,,

I am trying to figure out whom to contact regarding an question I have on area's with known violation of Increment standards along the Mississippi shoreline of Gulf of Mexico. I would like to know if there are any area's along the state seaward or shoreline of Mississippi along the Gulf of Mexico with known violations of PSD increments. I am trying to find out if there are any areas where an applicable increment standard is known to have been violated along the Gulf of Mexico and Mississippi shoreline. I would really appreciate if you can help me with this or direct me to the right person/contact at MDEQ. 

### Re: Question regarding an area where an applicab le increment is known to be violated along the state seaward boundary of Mississippi Bruce_Ferguson

to:
DVenkatesan

02/19/2013 03:46 PM

Cc: Jerry_Beasley

Hide Details From: Bruce_Fergus on@deq.state.ms.us

To: DVenkatesan@TrinityConsultants.com

Cc: Jerry_Beasley@deq.state.ms.us

History: This message has been replied to. 

### Pa g e 1 of 2

3/8/2013 file://C:\User s\dvenkatesan\A pp Data\Local\Tem p \notes193AC4\~web8778.htmDheskian -

I agree with Bruce. I am not aware of any increment violati ons on the Mississippi Gulf Coast or elsewhere in the state.

Jerry Beasley, Ph.D., P.E., BCEE
Chief, Air Quality Management Branch
Mississippi Dept. of Environmental Quality

515 East Amite Street
Jackson, Mississippi 39201
(601) 961-5134

----- Forwarded by Jerry Beasley/Air/OPC/DEQ on 02/20/2013 07:52 AM -----

From: Bruce Ferguson/EPD/OPC/DEQ

To: Dhesikan Venkatesan <DVenkatesan@TrinityConsultants.com>@INETDEQ,

Cc: Jerry Beasley/Air/OPC/DEQ@DEQ

Date: 02/19/2013 04:46 PM

Subject: Re: Question regarding an area where an applicable increment is known to be violated along the state seaward boundary of Missis sippi

Dhesikan, 

### Fw: Question regarding an area where an applicab le increment is known to be violated along the state seaward boundary of Mississippi Jerry_Beasley

to: Bruce_Ferguson, DVenkatesan

02/20/2013 06:59 AM

Hide Details From: Jerry_Beasley@deq.state.ms.us

To: Bruce_Ferguson@deq.state.ms.us, DVenkatesan@TrinityConsultants.com

History: This message has been replied to. 

### Pa g e 1 of 3

3/8/2013 file://C:\User s\dvenkatesan\A pp Data\Local\Tem p \notes193AC4\~web2954.htm

### 5 Attachments

Mr. Venkatesan,

I am not aware of any increment violations in the state.

Regards,

Tom Rogers


# Tom Rogers

Florida Department of Environmental Protection Division of Air Resource Management
2600 Blair Stone Road, MS 5500
Tallahassee, FL 32399-2400 Direct Line:(850) 717-9022 (Receptionist (850) 717-9000) DEP Internal System: 59522
Please note: Florida has a very broad public records law. Mo st written communications to or from state officials regarding st ate business are public records available to the public and media upon reques t. Your e-mail communication may therefore be subject to

p ublic disclosure.

Please take a few minutes to share y our comments on the service y ou received from the department b y

clicking 

### RE: Question regarding an area where an appli cable increment is known to be violated along the state seaward boundary of Florida Rogers, Tom

to:
Dhesikan Venkatesan

02/20/2013 07:18 AM

Hide Details From: "Rogers, Tom" <Tom .Rogers@dep.state.fl.us>

To: Dhesikan Venkatesan <DVenka tesan@TrinityConsultants.com>

History: This message has been replied to.

image001.gi f image002.gi f image003.gi f image004.gi f image005.gi f 

### Pa g e 1 of 2

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### 5 Attachments

Hi Dhesikan,

I spoke with Tom Rogers of DEP, and it sounds like he already responded to your question that no, we do not currently have any known violations of PSD increment along Florida’s Gulf Coast. Please let us know if you have

any more questions.

Thanks!
Melody

Please take a few minutes to share your comments on the service you received from the department by clicking

on this link DEP Customer Survey

. From: Koerner, Jeff

Sent: Wednesday, February 20, 2013 9:58 AM

To: Lovin, Melody Subject: FW: Question regarding an area where an applicable increment is known to be violated along the state 

### RE: Question regarding an area where an appli cable increment is known to be violated along the state seaward boundary of Florida Lovin, Melody

to: DVenkatesan@TrinityConsultants.com

02/20/2013 08:08 AM

Cc: "Koerner, Jeff"

Hide Details From: "Lovin, Melody" <Mel ody.Lovin@dep.state.fl.us>

To: "DVenkatesan@TrinityConsultants.com" <DVenkatesan@Trinit yConsultants.com>

Cc: "Koerner, Jeff" <Jeff. Koerner@dep.state.fl.us>

History: This message has been replied to.

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### 5 Attachments

We are not aware of any area where an increment is known to be violated. The only way to detect an increment

violation is PSD modeling. If the applicant is the one causing the violation, a permit can’t be issued.



# Vivian H. Aucoin

Environmental Scientist Manager

Air Permits Division, Manufacturing Section

P O Box 4313

Baton Rouge, La. 70821

‐ 4313 vivian.aucoin@la.gov

225

‐ 219

‐ 3389

Please Note New Phone Number

From: Dhesikan Venkatesan [ mailto:DVenkatesan@TrinityConsultants.com ] 

### RE: Question regarding an area where an appli cable increment is known to be violated along the state seaward boundary of Louisiana

Vivian Aucoin

to:
'Dhesikan Venkatesan'

02/21/2013 01:31 PM

Cc: Bryan Johnston

Hide Details

From: Vivian Aucoin <Vivian.Aucoin@LA.GOV>

To: 'Dhesikan Venkatesan' <DVenka tesan@TrinityConsultants.com>

Cc: Bryan Johnston <B ryan.Johnston@LA.GOV>

History: This message has been replied to.

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### Pa g e 1 of 6

3/8/2013 file://C:\User s\dvenkatesan\A pp Data\Local\Tem p \notes193AC4\~web7859.htm52.21(i)(3)(i).

Thanks and look forward to your response.

------------------------------------------------------------------------------------------------------------------------------- ------

Dhesikan Venkatesan │ Consultant │ dvenkatesan@trinityconsultants.com
Trinity Consultants │ 301 Main Street Suite 900 │ Baton Rouge, LA 70825

Office: (225) 346-4003 │ Fax: (225) 346-4032

PLEASE NOTE: WE'VE MOVED!

Stay sharp with professional training on timely environmental topics. Register today at www.trinityconsult ants.com/training

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This email is CONFIDENTIAL and intended for the use of the addressee and no one else. If you are not the intended

recipient, please do not read or use this email message and notify the sender of the mistaken transmission.

I don’t know that I can, we require modeling for PSD permits and in order to pass the modeling, which is required to receive

the permit, they have to show that they will not exceed the PSD increment so a PSD permit can’t be in violation of a PSD

increments. I may be not fully understanding what you are asking, but I hope this helps.

From: Dhesikan Venkatesan [ mailto:DVenkatesan@TrinityConsultants.com ]

Sent: Tuesday, February 19, 2013 4:58 PM

To: Yvette Olmos Subject: Question regarding an area where an applicable increment is known to be violated along the state seaward boundary of Louisiana

Greetings Yvette,

I am trying to figure out whom to contact regarding an que stion I have on area's with known violation of Increment standards along the Louisiana shoreline of Gulf of Mexico . I would like to know if th ere are any area's along the state seaward or shoreline of Louisiana along the Gulf of Mexico with known violations of PSD increments. I am From: Yvette Olmos < Yvette.Olmos@LA.GOV >

To: 'Dhesikan Venkatesan' < DVenkatesan@TrinityConsultants.com >

Date: 02/20/2013 06:48 AM

Subject: RE: Question regarding an area where an applicable increment is known to be violated along the state seaward boundary of Louisi ana 

### Pa g e 4 of 6

3/8/2013 file://C:\User s\dvenkatesan\A pp Data\Local\Tem p \notes193AC4\~web7859.htm

### 5 Attachments

Good morning Dhesikan! My name is Leigh Bacon and I am going to try and answer

y our question concerning known violations of the Class II Increments along Alabama’s Gulf Coast. The simple answer is that we are not aware of any outstanding modeled violations of the increments in that area of the State. However, it has been a number of years since a cumulative increment consumption analysis has been performed in that area. I hope that this answers your question. If not, please feel free to contact me. Otherwise, I hope you have a great day!

Leigh

Leigh Barb Bacon
Chief, Meteorological Section
Planning Branch, Air Division

State of AL ‐ DEM

334

‐ 270

‐ 5689 

### FW: Question regarding an area where an applic able air quality incr ement is known to be violated along the state s eaward boundary of Alabama Bacon, Leigh

to: DVenkatesan@TrinityConsultants.com

02/25/2013 07:37 AM

Cc: ADEM Airmail, "Bacon, Leigh"

Hide Details From: "Bacon, Leigh" <L BB@adem.state.al.us>

To: "DVenkatesan@TrinityConsultants.com" <DVenkatesan@Trinit yConsultants.com>

Cc: ADEM Airmail <Airmail@a dem.state.al.us>, "Bacon, Leigh" <LBB@adem.state.al.us>

History: This message has been replied to.

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3/8/2013 file://C:\User s\dvenkatesan\A pp Data\Local\Tem p \notes193AC4\~web5878.htm

## APPENDIX E: CORRECTED PROJECT POTENTIAL TO EMIT

Table 12. Project Potential

‐ to

‐ Emit (PTE) of Project

Pollutant Project Potential

to Emit
Tons/year PSD Major

Source

Threshold
Tons/year Exceeds
Major Source

Threshold? Significant

Emission Rate
(SER)
Tons/year Exceeds

SER?

NO X 1,162.03 250 Yes 40 Yes

CO	 362.52 250 Yes 100 Yes

PM	 35.37 250	 No	 25 Yes

PM 10 33.60 23.03 250	 No	 15 Yes

PM 2.5 22.42 250	 No	 10 Yes

SO 2 0.75 250	 No	 40	 No

VOC	 56.33 250	 No	 40 Yes

Pb	 0.01 100	 No	 0.6	 No

H 2 SO 4 0.02 NA	 NA	 7	 No

GHG	 73,406 100,000	 No	 75,000	 No

## APPENDIX F : CORRECTED TUBING UNIT ENGINE (DR

- WC

- 01) EMISSIONSEngine Rating [1] = 68 kW

92 HP Operating Time [2] = 24 hrs/day [1] 684 hrs/yr Fuel Type [3] = ULSD Operating load [2] = 100%

Maximum

Emissions M ax i mum Daily

Emissions Annual

Emissions

Value Units (lb/hr) (lb/day) (tons/yr)

PM 40 CFR 89.112,
AP-42 [4] 4.00E-01 g/kW-h r 0.06 1.44 0.02

PM 10 40 CFR 89.112,

AP-42 [5] 4.00E-01 g/kW-hr 0.06 1.44 0.02

PM 2.5 40 CFR 89.112,

AP-42 [5] 4.00E-01 g/kW-hr 0.06 1.44 0.02

NO

x 40 CFR 89.112 [4] 7.50E+00 g/kW-hr 1.12 26.98 0.38

SO 2 Fuel S Content [3] 1.12E-05 lb/HP-hr 1.03E-03 2.48E-02 3.53E-04
CO 40 CFR 89.112 [4] 5.00E+00 g/kW-h r 0.75 17.99 0.26
VOC AP-42 [6],[8] 2.51E-03 lb/HP-hr 0.23 5.55 0.08

Pb EPA [7] 2.03E-07 lb/HP-hr 1.87E-05 4.48E-04 6.39E-06

H 2 SO 4 Fuel S Conten t [3] 3.50E-07 lb/HP-hr 3.22E-05 7.74E-04 1.10E-05

[1]

[2]

[3]

[4]

[5]

[6]

[7]

[8] Emission factors are based on AP-42, Chapter 3, Table 3.3-1, Emission Factors for Uncontrolled Gasoline and Diesel
Industrial Engines (October 1996). Emission factors for diesel fuel are used.
Lead emission factor was obtained from EPA guidance document: Locating and Estimating Air Emissions from
Sources of Lead and Lead Compounds, EPA 454/R-98-006, May 1998, Section 5.2.2. Emission factor for distillate
oil-fired gas turbines was used as a surrogate for distillate oil-fired engines due to lack of emission factors. An
average brake-specific fuel consumption (BSFC) of 7,000 Btu/hp-hr was used to convert from lb/MMBtu to lb/hp-hr.

All TOC is assumed to be VOC. TOC emission factor has been calculated as the sum of exhaust and crankcase

emission factors. Representative Tube Running Engine to be used on for well completion activities. Information provided by Mr.
Aaron Wade (Anadarko) on August 8, 2012.

Assumptions: Max operating time of 24 hr/day, 100% Operating Load .

Anadarko is proposing the use of Ultra Low Sulfur Diesel (ULSD) for all diesel combustion sources. Therefore,
emissions have been calculated based on a maximum sulfur content of 15 ppm in diesel fuel assuming that 98 percent

of sulfur in the fuel is oxidized to SO 2 and 2 percent of sulfur in the fuel is oxidized to H 2 SO 4 based on Draft

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

Based on Engine Specification obtained provided by Mr. Aaron Wade (Anadarko) to Mr. Raghu Soule (Trinity) via
email on August 8, 2012. Per provided information, this engine is EPA Tier II certified (Table 1 of Federal
Register/Vol. 63, No. 205, October 23, 1998 and 40 CFR 89.112(a)).
Based on footnote b of AP-42 Chapter 3, Table 3.3-1, Emission Factors for Uncontrolled Gasoline and Diesel
Industrial Engines (October 1996). Per footnote b of Table 3.3-1, all PM is assumed to be < 1 um, therefore,

assumed PM2.5 = PM10 = PM. 

### Anadarko Petroleum Corporation
Well Completion Emission Calculations

DEUTZ F6L914 Tube Running Unit Engine

DR-WC-01

Criteria Pollutants

Pollutant Emission Factor Basis Emission Factor

Anadarko Petroleum Corporation EGOM Exploratory Project - Discoverer Spirit 1 of 1 Discoverer Spirit calculation 03-12-2013 _DV.v2.21, Tbg Running Unit - Criteria

Date Printed - 3/12/2013