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 proposed operations are planned to be 

conducted using the Discoverer Spirit drillship and associated 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, 2013 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 response 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 units 

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 application 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 been 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 1998

DR-GE-02 Main Propulsion Electrical Generator Engine #1B 1998

DR-GE-03 Main Propulsion Electrical Generator Engine #1C 1998

DR-GE-04 Main Propulsion Electrical Generator Engine #1D 1998

DR-GE-05 Main Propulsion Electrical Generator Engine #2A 1998

DR-GE-06 Main Propulsion Electrical Generator Engine #2B 1998

Emergency Engines 

DR-GE-07 Emergency Generator 1998

DR-GE-08 ROV Emergency Generator 2004

DR-AC-01 Emergency Air Compressor Diesel Engine #1 1997

DR-AC-02 Emergency Air Compressor Diesel Engine #2 1997

Escape Capsule Engines 

DR-EC-01 Escape Capsule Diesel Engine #1 1997

DR-EC-02 Escape Capsule Diesel Engine #2 1997

DR-EC-03 Escape Capsule Diesel Engine #3 1997

DR-EC-04 Escape Capsule Diesel Engine #4 1997

DR-EC-05 Escape Capsule Diesel Engine #5 1997

DR-EC-06 Escape Capsule Diesel Engine #6 1997

DR-FR-01 Fast Rescue Craft 1997

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 analyses 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 topdown 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. Anadarko 

contacted the stimulation vessel pump vendor. The vendor identified 40 CFR 89 Tier 2 compliant 

engines as the cleanest available engines in the stimulation vessel pump engine category (SV-PE-01 

through SV-PE-08). A detailed control cost effectiveness analysis for replacing the SV-PE-01 through SVPE-08 with the pumps complying with 40 CFR 89 Tier 2 standards was performed and provided in 

Appendix E-2 of the submitted application. The cost for the engine replacement was estimated to be 

$75,788 per ton of NOX 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 

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

The third 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 obtaining 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 NOX, CO, PM/PM10/PM2.5 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 because 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 Forney 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 operating 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 NOX

emissions are less than 3.0 tons per year (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 requested 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 2 standards are the cleanest available engines in this 
Ms. Fortin, EPA Region 4

Page 4

category of engines. 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. Given the 

minimal operations of this equipment resulting in low emissions, Anadarko believes that replacement of 

existing emergency engine with the cleanest available engine is cost prohibitive.

b. The NOX, CO, PM/PM10/PM2.5 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 application, 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 infeasible 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-01 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, 

NOX 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 requested 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 available engines in this 

category of equipment. Anadarko obtained an initial cost estimate of $12,600 for replacing the DR-AC01 and $10,900 for replacing the DR-AC-02 with similar air compressor engines compliant with 40 CFR 

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

submittal. Given the minimal operations of this equipment resulting in low emissions, Anadarko 

believes that replacement of existing emergency engine with the cleanest available engine is cost 

prohibitive.

4. The application has identified Painting Operations as source of PM/PM10/PM2.5 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 practices 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 transfer 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 

from 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/PM10/PM2.5 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, the paint could be applied with air assisted paint gun, airless paint gun, and by 

use of roller or brush. The transfer efficiency of each paint 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 email 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 multiangle items due to paint volume and precision requirements. An 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 painting method on 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 found this painting technique unsuitable due to following reasons:

• Marine coatings are designed to perform at certain thicknesses. The proper film thickness 

for these materials to perform as designated by the product data sheet is approximately 5 

mils thick. The only way to achieve these film thicknesses in a single application is to 

spray the coating. A single application with a roller will generate approximately 1.5 mils 

in thickness per application. A surface would have to be painted 3 to 4 times per coat to 

achieve the manufactures’ requirements for coating performance.

• To achieve good film continuity most of the marine coatings are designed to be sprayed. 

The atomization of the coating promotes a good flow of the material and creates a tight 

surface that has low moisture permeation which is essential for creating a barrier system 

and makes them work.

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

with several areas where a brush or roller could not reach and hence, the material must be 

sprayed.

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

operations. 
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 greatly 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 have 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 used 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 detailed. 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 boom supports the flare system and 

associated piping. These booms will be leased from a third party vendor with a King Post Assembly for a 

guyed installation or Cantilever assembly for a more permanent, self-supporting installation.. The 

drillship has permanent 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 flares. If pilot gas is required then Anadarko proposes to use portable canisters of 

propane or butane. There is no separate pilot line available on the drillship. 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 operated 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. Anadarko 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 welding operations 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 than 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 additional impact assessment or further emission 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. Hence, 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 scenario 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, listed 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 all 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-GE06) 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 the ROV Electric Generator Diesel engine #4 (SB-GE-04) on the work boat 

and painting 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 

completion 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

Stimulation Vessel 

Engines hours - - - - 24 504 - -

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

Supply Boats hours 16 3,328 - - - - 16 3,328

Painting (paint + 

thinner) gals 34 - 34 - 34 - 34 -
Ms. Fortin, EPA Region 4

Page 9

Table 4. Well Completion Scenario – PM Emissions 

Table 5. Well Completion Scenario – PM10 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 – PM2.5 Emissions 

Table 7. Well Completion Scenario – NOX 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 – SO2 Emissions 

Table 9. Well Completion Scenario – H2SO4 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 Boats 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 

SO2 and H2SO4 only. If this column is based on 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 represent 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 main 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 6,610 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 237,245 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 calculated. 

An example calculation for NOX and PM is provided below.

NOX emissions = 9,885.24 kw * 12.7 gram/kw-hr * 24 hr/day * 208 day/year * 1.10231 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

proposing 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 Main 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 2010) 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 assessment as provided in 40 CFR 52.21(i)(3). The following 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 requirement 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 where 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 contacted 

the regulatory agencies of Louisiana, Mississippi, Alabama, and Florida to confirm that there are no 

areas along the EGOM state-seaward boundary with known violations of PSD increments. Therefore, 

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

Increments. Refer to Appendix D of this submittal for correspondence with the state agencies.

Project Drilling and Support Vessels –The following comments are associated with the project emission 

sources used 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 estimated 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: Refer to the response in Item #7. The representative emissions reflect the worstcase 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 

should 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 the Q/d in accordance with the Federal 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 emissions calculated using maximum daily emissions (i.e., 

annualized emissions = max daily emissions in pounds per day * 365 days per year.)

An example calculation for NOX is provided below.

Annualized NOX 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 PM10 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 PM10 from the drilling operating scenario as 23.03 tons 

per year. Please clarify this discrepancy and provide the correct PTE for PM10.

Anadarko Response: 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 PM10 value is 23.03 tons per year as listed in 

Table 1 of Appendix A in the submitted application. The corrected “Table 1-2-Project Potential to Emit

(tons/year)” is attached in Appendix E of this submittal.

2. The NOX, CO, PM/PM10/PM2.5 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 part of BACT control for NOX, CO, PM/PM10/PM2.5 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 NOX control options identified for the main drillship engines are 

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

same options identified for the drillship main diesel engines are considered as the potential 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) CO2e emissions from your project. The EPA anticipates 

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 (CO2e) 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 (CO2e) emissions and reevaluate the GHG (CO2e)

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

APPENDIX A: EMAIL COMMUNICATION RECORD BETWEEN ANADARKO 

AND VENDOR REGARDING EMERGENCY GENERATOR COST
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 PM
Thanks,

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 COMMUNICATION RECORD BETWEEN ANADARKO 

AND VENDOR REGARDING EMERGENCY COMPRESSORS COST
Offer

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

1140 BLOOMFIELD AVENUE - SUITE 107

WEST CALDWELL Page : 1

Phone

NEW JERSEY 07006-7126

UNITED STATES

Offer. date : 14. March 2013

Our ref : HN

Re. : Anadarko Petroleum Corp

Diesel driven air compressors

Payment : To be agreed upon

Validity : 90 days

Del. week : See below

Hull/Vessel:

Your ref. : Chris Bergmann

Fax : 0019735755850

Rev. date : 14. March 2013

: 0019735755775

Description Qty Amount

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

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

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

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.

Delivery conditions: According to "General conditions for supply of plant and machinery for export",

formula ECE 188 together with addendum of 1980 and the below mentioned deviations.

Warranty: 12 months from the date the equipment is put into service, however limited to 18 months

from the time the equipment is ready for dispatch from our works. Possible repaired or replaced

components will be shipped FCA Aalesund. Should possible guarantee-repairs require effectuation by us

on your site, travelling and cost of living expenses 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

Fax +47 70 16 11 10 www.sperre.com

NORWAY

6057 ELLINGSØY

Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: DNBANOKK
Offer

HN-Q130615/13

Page : 2

Item No. Qty Description

Emergency Air Compressor

ELD905 1 HL2/90 aircooled compressor

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:

7203 1 Motor Lister TR2 01

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

-

1374-40 1 Coupling flange, diesel ø40

169 1 Baseplate HL2/77-105 D

Delivered loose:

4606S1 1 Vibration damper A2, set

4597 1 Flex.tube 1" x 800 mm

4738 1 Exhaust tube w/flange

1941 1 Water separator V23-1

4491 1 Non return valve KV35 complete

Spareparts, consisting of:

3036 1 Valve compl. suction/delivery

3037 1 Valve compl. suction/delivery

3489 2 Scraper ring HL-LL2/90

3531 2 Oil scraper ring LL2/90

3528 1 Oil scraper ring HL2/77-105

3501 1 Compr.ring HL2/77-105

IBAN: NO84 5353 0500 590

Bank (Norway): 5353 0500 590

NO 961 479 142 VAT

Fax +47 70 16 11 10 www.sperre.com

NORWAY

6057 ELLINGSØY

Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: DNBANOKK
Offer

HN-Q130615/13

Page : 3

Item No. Qty Description

3487 2 Compr ring Stp. HL2/77-105

PW77D 1 Seaworthy packing

G02-0051 1 General arrangement drawing

D02-0051 1 Installation diagram 77-90-105

Emergency Air Compressor

ELD105 1 HL2/105 aircooled compressor

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:

7203 1 Motor Lister TR2 01

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

-

1374-40 1 Coupling flange, diesel ø40

169 1 Baseplate HL2/77-105 D

Delivered loose:

4738 1 Exhaust tube w/flange

4606S1 1 Vibration damper A2, set

4597 1 Flex.tube 1" x 800 mm

1941 1 Water separator V23-1

4491 1 Non return valve KV35 complete

IBAN: NO84 5353 0500 590

Bank (Norway): 5353 0500 590

NO 961 479 142 VAT

Fax +47 70 16 11 10 www.sperre.com

NORWAY

6057 ELLINGSØY

Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: DNBANOKK
Offer

HN-Q130615/13

Page : 4

Item No. Qty Description

Spareparts, consisting of:

3036 1 Valve compl. suction/delivery

3037 1 Valve compl. suction/delivery

3490 2 Scraper ring HL2-LL2/105

3535 2 Oil sc. ring LL2/105 HV2/240

3528 1 Oil scraper ring HL2/77-105

3501 1 Compr.ring HL2/77-105

3487 2 Compr ring Stp. HL2/77-105

PW77D 1 Seaworthy packing

G02-0051 1 General arrangement drawing

D02-0051 1 Installation diagram 77-90-105

Painting: SPERRE STANDARD

IBAN: NO84 5353 0500 590

Bank (Norway): 5353 0500 590

NO 961 479 142 VAT

Fax +47 70 16 11 10 www.sperre.com

NORWAY

6057 ELLINGSØY

Sperre Industri AS Tel. +47 70 16 11 00 industri@sperre.com DnB Bank, BIC: DNBANOKK

APPENDIX C: EMAIL COMMUNICATION RECORD BETWEEN TRINITY AND 

VENDOR REGARDING TRANSFER 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 PM
To: 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 COMMUNICATION RECORD BETWEEN TRINITY AND 

STATE AGENCIES
Dhesikan, 

I don't know of any increment violations along the Gulf Coast 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@deq.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 Mississippi 

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 applicable 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_Ferguson@deq.state.ms.us 

To: DVenkatesan@TrinityConsultants.com 

Cc: Jerry_Beasley@deq.state.ms.us 

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file://C:\Users\dvenkatesan\AppData\Local\Temp\notes193AC4\~web8778.htm 3/8/2013
Dheskian - 

I agree with Bruce. I am not aware of any increment violations 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 Mississippi 

Dhesikan, 

Fw: Question regarding an area where an applicable 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. 

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file://C:\Users\dvenkatesan\AppData\Local\Temp\notes193AC4\~web2954.htm 3/8/2013
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. Most written communications to or from state officials regarding state 

business are public records available to the public and media upon request. Your e-mail communication may therefore be subject to

public disclosure.

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

RE: Question regarding an area where an applicable 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 <DVenkatesan@TrinityConsultants.com> 

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file://C:\Users\dvenkatesan\AppData\Local\Temp\notes193AC4\~web0595.htm 3/8/2013
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 applicable 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" <Melody.Lovin@dep.state.fl.us> 

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

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

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file://C:\Users\dvenkatesan\AppData\Local\Temp\notes193AC4\~web0086.htm 3/8/2013
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 applicable 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' <DVenkatesan@TrinityConsultants.com> 

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

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file://C:\Users\dvenkatesan\AppData\Local\Temp\notes193AC4\~web7859.htm 3/8/2013
52.21(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 

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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 question 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 there 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 Louisiana

Page 4 of 6

file://C:\Users\dvenkatesan\AppData\Local\Temp\notes193AC4\~web7859.htm 3/8/2013
5 Attachments 

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

your 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 applicable air quality increment is known to be 

violated along the state seaward 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" <LBB@adem.state.al.us> 

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

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

History: This message has been replied to. 

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file://C:\Users\dvenkatesan\AppData\Local\Temp\notes193AC4\~web5878.htm 3/8/2013
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?

NOX	 1,162.03	 250	 Yes 40	 Yes

CO	 362.52	 250	 Yes 100	 Yes

PM	 35.37	 250	 No	 25	 Yes

PM10	 33.60	23.03 250	 No	 15	 Yes

PM2.5	 22.42	 250	 No	 10	 Yes

SO2	 0.75	 250	 No	 40	 No	

VOC	 56.33	 250	 No	 40	 Yes

Pb	 0.01	 100	 No	 0.6	 No	

H2SO4	 0.02	 NA	 NA	 7	 No	

GHG	 73,406	 100,000	 No	 75,000	 No	
APPENDIX F: CORRECTED TUBING UNIT ENGINE (DR-WC-01) EMISSIONS
Engine 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

Maximum 

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-hr 0.06 1.44 0.02

PM10

40 CFR 89.112, 

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

PM2.5

40 CFR 89.112, 

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

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

SO2 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-hr 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

H2SO4 Fuel S Content [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 SO2 and 2 percent of sulfur in the fuel is oxidized to H2SO4 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