## Environmental solutions de livered uncommonly well 

# Anadarko Petroleum Corporation

BlackHornet PSD/Title V Permit Application Operations in the Eastern Gulf of Mexico
Revision 1

Prepared	By:

TRINITY CONSULTANTS

301	Main	Street,	Suite	900 Baton	Rouge,	LA	70816 (225)	292‐2661

September	2013

Project No. 131901.0020Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants i 

## TABLE OF CONTENTS

1. INTRODUCTION 7 1.1.	Location	of	the	Proposed	Project	.........................

............................................................... .........................................................	7 1.2.	Air	Permitting	and	Summary	o f	Regulatory	Requirements	....

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

............................................................... ......................................................	11

1.3.1. Emission Sources

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

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



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

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

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

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



### 3. EMISSIONS CALCULATIONS 21 3.1.	‘Equivalency’	Determination	..............................

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

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

............................................................... ............................................................... ..................	22

3.3.1. Main Engines (DR

‐ ME

‐ 01 through DR

‐ ME

‐ 08)

.............................................................................................................. 22

3.3.2. Emergency Generator (DR

‐ GE

‐ 01)

............................................................................................................................... ....... 24

3.3.3. Emergency Air Compressor (DR

‐ AC

‐ 01)

........................................................................................................................... 25

3.3.4. Life Boat Engines (DR

‐ LB

‐ 01 through DR

‐ LB

‐ 06)

........................................................................................................ 26

3.3.5. Fast Rescue Craft (DR

‐ FR

‐ 01)

............................................................................................................................... ................. 27

3.3.6. Mud degassing Vent (DR

‐ VG

‐ 01)

............................................................................................................................... ........... 28

3.3.7. Dust Collectors (DR

‐ DC

‐ 01 through DR

‐ DC

‐ 03)

............................................................................................................ 29

3.3.8. Storage Vessels (DR

‐ FT

‐ 01 through DR

‐ FT

‐ 18)

............................................................................................................. 30

3.3.9. Drillship Fugitive Emissions (DR

‐ FE

‐ 01)

.......................................................................................................................... 30

3.3.10. Painting Operations (DR

‐ PO

‐ 01)

............................................................................................................................... ........ 30

3.3.11. Welding Operations (DR

‐ WO

‐ 01)

............................................................................................................................... ....... 31

3.3.12. Third Party Engines (DR

‐ TP

‐ 01 through DR

‐ TP

‐ 21)

................................................................................................ 32

3.3.13. Flowback Boiler (DR

‐ TP

‐ 22)

............................................................................................................................... ................ 33

3.3.14. Boom Flare (DR

‐ TP

‐ 23)

............................................................................................................................... .......................... 34

3.3.15. Well Completion Condensate Tanks (DR

‐ TP

‐ 24 through DR

‐ TP

‐ 26)

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

............................................................... ............................................................... .........	35 Supply Boats (HOS Coral) Combustion Sources

......................................................................................................................... 36

3.4.1. Marine Propulsion Engines 1 and 2 (SB

‐ ME

‐ 01 and SB

‐ ME

‐ 02)

............................................................................ 36

3.4.2. Marine Thruster Engines (SB

‐ TE

‐ 01 through SB

‐ TE

‐ 03)

.......................................................................................... 37

3.4.3. Electrical Generator Engines (SB

‐ GE

‐ 01 and SB

‐ GE

‐ 02)

........................................................................................... 38

3.4.4. Emergency Electrical Generator Engine (SB

‐ GE

‐ 03)

.................................................................................................. 39

3.4.5. ROV Electrical Generator Engine (SB

‐ GE

‐ 04)................................................................................................................. 40

3.4.6. Well Evaluation Third Party Engine (SB

‐ TP

‐ 01 and SB

‐ TP

‐ 02)

............................................................................. 41

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

‐ TP

‐ 03)

........................................................................ 42

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

‐ TP

‐ 04)

........................................................................ 43

3.4.9. Third Party Well Evaluation Engines (SB

‐ TP

‐ 05 through SB

‐ TP

‐ 09)

.................................................................. 44

Anchor Handling Boat (Kirt Chouest) Combustion Sources

................................................................................................. 45

3.4.10. Marine Propulsion Engines (AB

‐ ME

‐ 01 and AB

‐ ME

‐ 02)

......................................................................................... 45

3.4.11. Thruster Engines (AB

‐ TE

‐ 01 through AB

‐ TE

‐ 03)

...................................................................................................... 46

3.4.12. Service Generator Engines (AB

‐ GE

‐ 01 through AB

‐ GE

‐ 05)

................................................................................... 47

3.4.13. Emergency Generator Engine (AB

‐ GE

‐ 06)

.................................................................................................................... 47Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants ii 3.4.14. Winch Hydraulic Engines (AB

‐ GE

‐ 07 and AB

‐ GE

‐ 08)

.............................................................................................. 48

3.4.15. Supply Boat Storage Tanks

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

............................................................................................................................... ............................ 49

3.4.16. Tug Boat Main Engines (TB

‐ ME

‐ 01 to TB

‐ ME

‐ 03) and Generator Engines (TB

‐ GE

‐ 01 to TB

‐ GE

‐ 02) 49 Barge Combustion Sources

............................................................................................................................... .................................. 51

3.4.17. Barge Electrical Generators (BG

‐ LP

‐ 01thru BG

‐ LP

‐ 03)

.......................................................................................... 51

Stimulation Vessel Combustion Sources

............................................................................................................................... ......... 52

3.4.18. Stimulation Vessel Main Engines (SV

‐ ME

‐ 01 and SV

‐ ME

‐ 02)

............................................................................... 52

3.4.19. Bow Thruster Engine (SV

‐ BT

‐ 01)

............................................................................................................................... ....... 54

3.4.20. Bow Drop

‐ Down Engine (SV

‐ DD

‐ 01)

............................................................................................................................... 54

3.4.21. Stern Thruster Engines (SV

‐ ST

‐ 01)

............................................................................................................................... ... 55

3.4.22. Representative Pump Engines (SV

‐ PE

‐ 01 through SV

‐ PE

‐ 08)

.............................................................................. 56

3.4.23. Stimulation Vessel Generators (SV

‐ GE

‐ 01 and SV

‐ GE

‐ 02)

...................................................................................... 57

3.4.24. Stimulation Vessel Generators (SV

‐ GE

‐ 03 and SV

‐ GE

‐ 04)

...................................................................................... 58

Well Evaluation Vessel Combustion Sources

............................................................................................................................... 59

3.4.25. Well Evaluation Vessel Main Engines (WE

‐ ME

‐ 01and WE

‐ ME

‐ 02)

................................................................... 59

3.4.26. Well Evaluation Vessel Auxiliary Engines (WE

‐ AE

‐ 01 and WE

‐ AE

‐ 02)

............................................................ 61

3.4.27. Well Evaluation Vessel Emergency Generator #1 (WE

‐ GE

‐ 01)

........................................................................... 61

3.4.28. Well Evaluation Vessel Emergency Generator #2 (WE

‐ GE

‐ 02)

........................................................................... 62

3.4.29. Well Evaluation Vessel Emergency Generator #3 (WE

‐ GE

‐ 03)

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



### 4. REGULATORY APPLICABILITY ANALYSIS 65

4.1.	Outer	Continental	Shelf	Ai r	Regulations	(40	CFR	55)	......

............................................................... .................................	65 4.2.	Prevention	of	Significant	De terioration	(PSD)	Regulations

............................................................... ............................	67

4.3.	New	Source	Performan ce	Standards	(NSPS)	..................

............................................................... ......................................	68

4.3.1. 40 CFR Subpart A

– General Provisions

............................................................................................................................. 68

4.3.2. 40 CFR Subpart K ‐ Standards of Performance for Storage Vessels for Petroleum Liquids

......................... 68

4.3.3. 40 CFR 60 Subpart Ka

– Standards of Performance for Storage Vessels for Petroleum Liquids

.............. 69

4.3.4. 40 CFR 60 Subpart Kb ‐ Standards of Performance for Volatile Liquid Storage Vessels

.............................. 69

4.3.5. 40 CFR 60 Subpart IIII

– Stationary Compression Ignition Internal Combustion

.......................................... 71

4.3.5.1. Drillship Main Engines (DR

‐ ME

‐ 01 through DR

‐ ME

‐ 08)

....................................................................................... 72

4.3.5.2. Drillship Emergency Generator (DR

‐ GE

‐ 01)

............................................................................................................... 73

4.3.5.3. Drillship Emergency Air Compressor (DR

‐ AC

‐ 01)

..................................................................................................... 74

4.3.5.4. Drillship Temporary Third Party Well Evaluation Engines (DR

‐ TP

‐ 12 through DR

‐ TP

‐ 16)

................. 74

4.3.5.5. Stimulation Vessel Pumps (SV

‐ PE

‐ 01 through SV

‐ PE

‐ 08)

..................................................................................... 74

4.3.6. 40 CFR 60 Subpart JJJJ

– Stationary Spark Ignition Internal Combustion

......................................................... 75

4.3.7. 40 CFR 60 Subpart Dc

– Standards of Performance for Small Industrial

– Commercial

– Institutional

Steam Generating Units

............................................................................................................................... ........................................ 75

4.4.	National	Emission	Standards	F or	Hazardous	Air	Pollutants	( NESHAP	‐	40	CFR	Part	61)	...............................	75

4.4.1. 40 CFR 61 Subpart A ‐ General Provisions

........................................................................................................................ 76

4.5.	National	Emission	Standards	F or	Hazardous	Air	Pollutants	( NESHAP	–	40	CFR	Part	63)	..............................	76

4.5.1. 40 CFR 63 Subpart A

– General Provisions

...................................................................................................................... 76

4.5.2. 40 CFR 63 Subpart ZZZZ

– Stationary Reciprocating Internal Combustion Engines

.................................... 76

4.5.3. 40 CFR 63 Subpart HHHHHH

– Paint Stripping and Miscellaneous Surface Coating Operations at Area

Sources

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

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

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



### 5. BACT ANALYSIS 79

5.1.	NO X BACT	Analysis	................................................

............................................................... ...........................................................	81Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants iii 5.1.1. NO X BACT Analysis for the Drillship Main Engines (DR

‐ ME

‐ 01 to DR

‐ ME

‐ 08)

................................................ 81

5.1.2. NO X BACT Analysis for Emergency Generators (DR

‐ GE

‐ 01)

..................................................................................... 88

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

‐ AC

‐ 01)

............................................................ 90

5.1.4. NO X BACT Analysis for Third Party Engines (DR

‐ TP

‐ 01 through DR

‐ TP

‐ 11 and DR

‐ TP

‐ 17 though DR

‐ TP

‐ 21)

............................................................................................................................... ........................................................................... 92

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

‐ TP

‐ 12 through DR

‐ TP

‐ 16)

................. 94

5.1.6. NO X BACT Analysis for Pumps on the Stimulation Vessel (SV

‐ PE

‐ 01 through SV

‐ PE

‐ 08)

........................... 97

5.1.7. NO X BACT Analysis for Flowback Boiler (DR

‐ TP

‐ 22)

................................................................................................ 100

5.1.8. NO X BACT Analysis for Boom Flare (DR

‐ TP

‐ 23)

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

............................................................... ........................................................	103

5.2.1. CO and VOC BACT Analysis for Drillship Main Propulsion Electrical Generator Engines (DR

‐ ME

‐ 01 through DR

‐ ME

‐ 08)

............................................................................................................................... ............................................. 103

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

‐ GE

‐ 01)

................................................ 105

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

‐ AC

‐ 01)

................................................................. 107

5.2.4. CO and VOC BACT Analysis for Drillship Third Party Engines (DR

‐ TP

‐ 01 through DR

‐ TP

‐ 11 and DR

‐ TP

‐ 17 though DR

‐ TP

‐ 21)

............................................................................................................................... .......................................... 108

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

‐ TP

‐ 12 through DR

‐ TP

‐ 16)

............................................................................................................................... ....................................................................................... 110

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

‐ PE

‐ 01 thru SV

‐ PE

‐ 08)

............................................................................................................................... ....................................................................................... 111

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

‐ TP

‐ 22)

............................................................................... 112

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

‐ TP

‐ 23)

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

............................................................... ................................	115

5.3.1. PM/PM 10 /PM 2.5 BACT Analysis for the Drillship Main Propulsion Electrical Generator Engines (DR

‐ ME

‐ 01 to DR

‐ ME

‐ 08)

............................................................................................................................... .................................................... 115

5.3.2. PM/PM 10 /PM 2.5 BACT Analysis for Drillship Emergency Generator (DR

‐ GE

‐ 01)

......................................... 118

5.3.3. PM/PM 10 /PM 2.5 BACT Analysis for the Air Compressor Engine (DR

‐ AC

‐ 01)

.................................................. 119

5.3.4. PM/PM 10 /PM 2.5 BACT Analysis for Drillship Third Party Engines (DR

‐ TP

‐ 01 through DR

‐ TP

‐ 11 and DR

‐ TP

‐ 17 though DR

‐ TP

‐ 21)

............................................................................................................................... ................................... 120

5.3.5. PM/PM 10 /PM 2.5 BACT Analysis for Third Party Well Evaluation Engines (DR

‐ TP

‐ 12 through DR

‐ TP

‐ 16)

............................................................................................................................... ....................................................................................... 121

5.3.6. PM/PM 10 /PM 2.5 BACT Analysis for Representative Pump Engines on the Stimulation Vessel (SV

‐ PE

‐ 01

thru SV

‐ PE

‐ 08)

............................................................................................................................... ....................................................... 123

5.3.7. PM/PM 10 /PM 2.5 BACT Analysis for Flowback Boiler (DR

‐ TP

‐ 22)

....................................................................... 124

5.3.8. PM/PM 10 /PM 2.5 BACT Analysis for Boom Flare (DR

‐ TP

‐ 23)

................................................................................. 125

5.3.9. PM/PM 10 /PM 2.5 BACT Analysis for Cement and Mud Mixing Operations (DR

‐ DC

‐ 01 thru DR

‐ DC

‐ 03)

............................................................................................................................... ....................................................................................... 126

5.3.10. PM/PM 10 /PM 2.5 BACT Analysis for Painting Operations (DR

‐ PO

‐ 01)

............................................................. 126

5.3.11. PM/PM 10 /PM 2.5 BACT Analysis for Welding Operations (DR

‐ WO

‐ 01)

........................................................... 128 5.4.	VOC	BACT	Analysis	for	St orage	Tanks	And	Paints	...........

............................................................... .................................	130

5.4.1. VOC BACT Analysis for Storage Tanks (DR

‐ DT

‐ 01 thru DR

‐ DT

‐ 09 and DR

‐ FT

‐ 01 thru DR

‐ FT

‐ 03)

..... 130

5.4.2. VOC BACT Analysis for Mud Degassing Operations (DR

‐ VG

‐ 01)

......................................................................... 131

5.4.3. VOC BACT Analysis for Painting Operations (DR

‐ PO

‐ 01)

....................................................................................... 132 5.5.	Greenhouse	Gas	(GHG)	BACT	Analysis	.......................

............................................................... ...........................................	132

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

............................................................ 133

5.5.2. GHG BACT Analysis for Mud Degassing Operations (DR

‐ VG

‐ 01)

......................................................................... 135

5.5.3. GHG BACT Analysis for Flowback Boiler (DR

‐ TP

‐ 22)

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

5.5.4. GHG BACT Analysis for Boom Flare (DR

‐ TP

‐ 23)

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



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

### APPENDIX A

– PLOT PLAN

APPENDIX B

– EMISSION CALCULATIONS

APPENDIX C

– LIST OF INSIGNIFICANT ACTIVITIES

APPENDIX D

– AIR DISPERSION MODELING ANALYSIS

APPENDIX E

– BACT ANALYSIS SUPPORTING DOCUMENTATION

APPENDIX F

– ENVIRONMENTAL IMPACT ASSESSMENT

APPENDIX G ‐ 1

– SPECIFICATION SHEETS: DRILLSHIP

APPENDIX G

‐ 2

– SPECIFICATION SHEETS: THIRD PARTY EPA TIER II CERTIFIED ENGINES

APPENDIX G

‐ 3

– SPECIFICATION SHEETS: NON

‐ EPA TIERED WELL EVALUATION ENGINES

APPENDIX G

‐ 4

– TANKS 4.09 OUTPUT FOR DRILLSHIP TANKS

APPENDIX G

‐ 5

– SPECIFICATION SHEETS: DUST COLLECTORS

APPENDIX G

‐ 6

– SPECIFICATION SHEETS: MSDS ‐ PAINTS/BASE/THINNER

APPENDIX G

‐ 7

– TANKS 4.09 OUTPUT FOR SUPPLY BOAT TANKS

APPENDIX G

‐ 8

– DRILLSHIP MAIN ENGINE MANUFACTURER MAINTENANCE

APPENDIX G

‐ 9

– THIRD PARTY FLOWBACK BOILER

APPENDIX G

‐ 10

– SPECIFICATION SHEETS: SUPPLY BOAT

APPENDIX G

‐ 11

– ANCHOR HANDLING BOAT

APPENDIX G

‐ 12

– SPECIFICATION SHEETS: TUG

APPENDIX G

‐ 13

– SPECIFICATION SHEETS

– BARGE

APPENDIX G

‐ 14

– TANKS 4.09 OUTPUT FOR CONDENSATE TANKS

APPENDIX G

‐ 15

– SPECIFICATION SHEETS

– STIMULATION VESSEL

APPENDIX G

‐ 16

– SPECIFICATION SHEETS

– WELL EVALUATION VESSEL

APPENDIX G

‐ 17

– TANKS 4.09 OUTPUT FOR ANCHOR BOAT TANKS

APPENDIX G

‐ 18

– MSDS OF ULTRA LOW SULFUR DIESELAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants v 

## LIST OF TABLES

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

Table	1‐2.		Project	Potential‐to‐Emit	(PTE)	of	Project	 9

Table	1‐3.		Summary	of	Emission	Units	on	the	Drillship	 11

Table	1‐4.		Summary	of	Temporary Third	Party	Emission	Sources	o n	the	Drillship	 13

Table	1‐5.		Summary	of	Emission	Units	on	the	Supply	Boats	 13

Table	1‐6.		Summary	of	Emission	Units	on	the	Anchor	Handling	Bo ats	 15

Table	1‐7.		Summary	of	Emission	Units	on	the	Stimulation	Vessel 16

Table	1‐8.		Summary	of	Emission	Units	on	the	Tug	Boats	and	Barg es	 16

Table	1‐9.		Summary	of	Emission	Units	on	the	Well	Evaluation	Ve ssel	 17

Table	4‐1.		NSPS	Subpart	Kb	Applic ability	Determination	for	Fue l	Storage	Tanks	 69

Table	4‐2.	Applicable	Engines Subject	to	Subpart	IIII	 72

Table	4‐3.	Emergency	Generato r	Offset	Requirements	 73

Table	4‐4.	Emergency	Genera tor	Residual	Emissions	 74

Table	5‐1.	Ranks	of	Technologie s	Feasible	for	Main	Engines	 87

Table	5‐2.	Ranks	of	Technologies Feasible	for	Emergency	Generat ors	 89

Table	5‐3.	Ranks	of	Technologies Feasible	for	Emergency	Air	Com pressor	Engine	 92

Table	5‐4.	Ranks	of	Technologies Feasible	for	Diesel	Fired	Engi nes	 97

Table	5‐5.	Ranks	of	Technologies Feasible	for	Pumps	on	Stimulat ion	Vessel	 99

Table	5‐6.	Proposed	NO X BACT	Emission	Limits	 102

Table	5‐7.	Ranks	of	Technologies Feasible	for	Main	Diesel	Engin es	 105

Table	5‐8.	Ranks	of	Technologies Feasible	for	Emergency	Engine 106

Table	5‐9.	Ranks	of	Technologies Feasible	for	Emergency	Air	Com pressor	Engine	 108

Table	5‐10.	Ranks	of	Technologies Feasible	for	the	Third	Party Engines	 109

Table	5‐11.	Ranks	of	Technologies Feasible	for	Pumps	on	Stimula tion	Vessel	 112Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants vi Table	5‐12.	Proposed	CO	&	VO C	BACT	Emission	Limits	 113

Table	5‐13.	Ranks	of	Technologies Feasible	for	Main	Diesel	Engi nes	 117

Table	5‐14.	Ranks	of	Technologies Feasible	for	the	Emergency	Di esel	Engine	 118

Table	5‐15.	Ranks	of	Technologies Feasible	for	the	Emergency	Di esel	Engine	 120

Table	5‐16.	Ranks	of	Technologies Feasible	for	the	Third	Party Engines	 121

Table	5‐17.	Ranks	of	Technologies Feasible	for	the	Pumps	on	Sti mulation	Vessel	 124

Table	5‐18.		Paint	Application and	Transfer	Efficiencies	 127

Table	5‐19.	Ranks	of	Technologies Feasible	for	the	Welding	Oper ations	 128

Table	5‐20.	Proposed	PM/PM 10 /PM 2.5 BACT	Emission	Limits	 129

Table	5‐21.	Proposed	VOC BACT	Emission	Limits	 132

Table	5‐22.	Proposed	CO 2 e	BACT	Emission	Limits	 138Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants 7 

## 1. INTRODUCTION

Anadarko	is	proposing	to	conduct exploratory	drilling,	completi on,	and	associated	maintenance activities	(the	proposed	project )	on	the	Outer	Continental	Shel f	(OCS)	of	the	Eastern	Gulf	of	Mexico (EGOM).		The	proposed	project	ac tivity	will	consist	of	three	ph ases	–	(1)	the	drilling	phase,	(2)	the well	completion	phase,	and	(3)	production	well	maintenance	(rem edial	well‐work)	phase.		The proposed	project	will	be	conduct ed	over	a	period	of	five	years, with	the	proposed	operation	of approximately	200	days	per	year. As	specified	in	the	applicat ion,	Anadarko	requested	operating limit	in	terms	of	fuel	consumptio n	in	lieu	of	operating	time	re striction.		With	the	submittal	of application,	Anadarko	is	applying	for	a	pre‐construction	permit and	a	Title	V	operating	permit.



### 1.1. LOCATION OF THE PROPOSED PROJECT

The	proposed	project	is	planned to	be	conducted	within	a	set	of lease	blocks	available	for exploratory	drilling	using	a	dyn amically	positioned	Diamond	Off shore	Drilling, Inc.	(Diamond) BlackHornet	drillship	and	associ ated	support	vessels	in	the	EGO M,	east	of	the	87.5 degree	longitude. The	available	lease	blocks	(i.e .,	the	“wedge”)	i n	the	EGOM	are identified	by	a	boun dary	line	within the	map	presented	in	Figure	1‐1. Within	the	wedge,	there	are	b oth	active	lease	b locks	(currently leased	or	available	for	lease)	a nd	lease	blocks	that	could	pote ntially	be	available	for	lease	by	the Bureau	of	Ocean	Energy	Management (BOEM)	in	the	future.		The	ar ea	within	the	boundary	line identified	as	the	“wedge”	as	sho wn	in	Figure	1‐1,	is	bounded	by the	following	limits:

1. The	87.5	longitude	line	to	the	wes t	(Environmental	Protection	A gency	Jurisdiction);

2. The	86.88	longitude	line	to	the	e ast	(Military	Mission	Line);

3. The	limit	of	100	miles	to	the	shore	in	the	BOEM	Central	Plannin g	area;	and

4. The	limit	of	125	miles	to	the	shore	in	the	BOEM	Eastern	Plannin g	area

Anadarko	has	identified	all	leas e	blocks	currentl y	available	fo r	the	proposed	pro ject	in	the	EGOM within	the	“wedge”	and	has	determ ined	which	of	these	lease	bloc ks	are	closest	to	Cla ss	I	areas	in	the vicinity	of	300	kilometers	(i.e .,	Breton	National	Wildlife	Refu ge	[Breton	NWR],	St.	Marks	National Wildlife	Refuge	[St.	Marks	NWR], and	Bradwell	Bay	Wilderness	Ar ea).		Also,	the	distance	between these	blocks	and	the	boundary	se parating	inner	OCS	and	outer	OC S	is	provided	in	the	Table	1‐1 below.		Table	1‐1	also	presents	t he	direction	and	approximate	d istance	to	the	Class	I	area	and	the corresponding	Federal	Land	Manag ers	(FLM)	for	each	Class	I	area .		A	map	showing	the	location	of

worst‐case	lease	blocks	relative to	the	nearest	C lass	I	areas	a nd	surrounding	onshore	areas	is provided	in	Figure	1‐1.

Table 1

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

Desoto Canyon

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

From The

OCS Boundary (km)

141 Breton	NWR NW	 167 U.S.	Fish	&	Wildlife 95

149 St.	Marks	NWR NE	 285 U.S.	Fish	&	Wildlife 101

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

### 1.2. AIR PERMITTING AND SUMMARY OF REGULATORY REQUIREMENTS

The	drillship	used	for	the	propo sed	project	activities	will	qua lify	as	an	OCS	source,	as	defined	in	40

CFR	55.2	as	follows:

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

This	definition	shall	include vessels	only	when	they	are: (1) Permanently or temporarily attached to the seabed and erected thereon and used for the purpose of exploring, developing or producing resources therefrom, within the meaning of section 4(a)(1) of

OCSLA (43 U.S.C. §1331 et seq. ); or (2) Physically attached to an OCS facility, in which case only the stationary sources aspects of the

vessels will be regulated.”

Therefore,	when	Anadarko	will	be	c onducting	the	proposed	projec t,	it	will	be	considered	an	OCS source	and	will	be	subject	to the	requirements	of	40	CFR	55.		I n	addition,	when	a	s upport	vessel	is attached	to	an	OCS	source,	the	s tationary	source	aspects	of	tha t	support	vessel	will	also	be	regulated

as	an	OCS	source.

Per	40	CFR	55.3(a),	all	OCS	sour ces	located	in	the	EGOM	are	reg ulated	by	the	OCS Air	Regulations

codified	under	40	CFR	55.		As	th e	regulatory	auth ority	over	the EGOM	has	not	been	delegated through	the	requirements	of	40 CFR	55.11(j),	the	proposed	OCS	s ource	falls	under	the	regulatory jurisdiction	of	the	United	State s	Environmental	Protection	Agen cy	(U.S.	EPA)	and	U.S.	EPA	Region	4 will	issue	the	applicab le	permits	and	imple ment	and	enforce	the requirements	of 40	CFR	55.		As	the proposed	project	activ ities	will	be	carried	out	beyond	25	miles of	the	nearest State’s	seaward boundary,	it	will	be	outside	of the	corresponding	state	and	loc al	regulatory	authority.

As	an	OCS	source	subject	to	the requirements	of	40	CFR	55,	the proposed	source	will	need	to	comply with	40	CFR	55.13(d)	which	specifi es	that	the	PSD	program	(codi fied	under	40	CFR	52.21),	applies to	OCS	sources	located	beyond	25	miles	of	States’	seaward	bound aries.		The	PSD	program	is	a	pre‐ construction	permitting	program	t hat	regulates	em issions	from	“ major”	sources	of	regulated	air pollutants.		Further,	as	specif ied	in	40	CFR	55.2,	the	emission s	from	vessels	servicing	or	associated

with	an	OCS	source	sha ll	be	considered	direc t	emissions	from	su ch	a	source	while	at	the	source,	and

while	en	route	to	or	f rom	the	source	when	within	25	miles	of	th e	source,	and	shall be	included	in	the “potential	to	emit”	(PTE)	for	an OCS	source,	when	considered	fo r	complying	with	t he	requirements

of	40	CFR	55.13.

An	OCS	source	is	considered	PSD	m ajor	if	PTE	of	any	PSD‐regulat ed	pollutant	exceed	the	major source	threshold	of	250	tons	per year	(tpy).		The	PSD	program	r egulates	the	emissions	of	all	criteria pollutants	and	several	non‐crit eria	pollutants	such	as	total	re duced	sulfur	compounds,	sulfuric	acid mist,	and	fluorides	(not	inc luding	hydrogen	fluoride).

The	proposed	potential	to	emit	( PTE)	of	criteria	pollutants	and HAPs	for	the	proj ect	are	summarized in	Table	1‐2.		The	proposed	proj ect	will	be	subj ect	to	requirem ents	of	the	PSD	pr ogram	since	it	is classified	as	a	major	source.		A s	shown	in	Table	1‐2,	total	par ticulate	matter	(PM),	particulate	matter with	an	aerodynamic	diamet er	less	than	10	microns	(PM 10 ),	particulate	matter with	an	aerodynamic diameter	less	than	2.5	microns	(PM 2.5 ),	nitrogen	oxides	(NO X ),	carbon	monoxide	(CO),	volatileAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants 9 organic	compounds	(VOC),	and	green house	gases	(GHG)	exceed	thei r	respective	Signif icant	Emission Rates	(SER).			Hence,	the	Best	Av ailable	Control	Technology	(BA CT)	review	for	all	air	emission sources	with	emissions	of	these	p ollutants	has	been	conducted	a nd	is	included	in	this	permit application.

Table 1

‐ 2. Project Potential

‐ to

‐ Emit (PTE) of Project

Pollutant Project Potential

to Emit Tons/year Significant

Emission Rate (SER) Tons/year Exceeds

SER?

NO X 1,363 40 Yes

CO 540 100 Yes

PM	 35 25 Yes

PM 10 32 15 Yes

PM 2.5 32 10 Yes

SO 2 1 40	 No

VOC 121 40 Yes

Pb 0.02 0.6	 No

H 2 SO 4 0.03 7	 No

GHG 111,108 75,000 Yes

In	accordance	with	40	CFR	52.21(i )(3),	the	requirements	under	4 0	CFR	52.21(k),	(m),	and	(o)	do	not apply	to	a	major	stationary	source	or	major	modification	with	r espect	to	a	particular	pollutant,	if	the allowable	emissions	of	that	pollutant	from	the	source,	or	the	n et	increase	of	that	p ollutant	from	the modification	would	not	impact	a	Class	I	area,	would	not	impact an	area	where	an	applicable increment	is	known	to	be	violated,	and	when	the	source	would	be temporary	(i.e.,	less	than	two	(2) years	of	operation).

The	proposed	project	does	not	m eet	these	criteria	and	does	not qualify	for	an	exemption	from	40 CFR	52.21(k),	(m),	and	(o)	as	expl ained	in	Section	4.2	of	this permit	application	report.		Therefore, Class	II	area	modeling	analysis	and	additional	impact	analyses are	included	in	this	permit application.

Based	on	the	locations	of	the	pr oposed	operations	and	analysis of	project	emissions,	air	quality modeling	analyses	of	the	impacts on	federally	protected	Class	I areas	and	Class	II	areas	have	been performed	to	demonstrate	complia nce	with	PSD	Class	I	area	and	C lass	II	area	Increment	standards and	air	quality	related	values	(AQRV)	thresholds. 1 Accordingly,	a	Class	I	area	and	Class	II	area modeling	analysis	and	report	has been	prepared	and	is	included in	Appendix	D	of	this	permit application	report.

1 Anadarko’s EGOM Exploratory Project lease blocks are located wi thin 300 kilometers of three federally protected Class I areas in the Southern United States.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/ Title V Permit Application Trinity Consultants 10 Figure 1

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

### 1.3. DESCRIPTION OF EMISSION SOURCES

The	proposed	project	will	be	con ducted	using	the	Diamond	BlackH ornet	drillship	and	associated support	vessels.		The	support	ve ssels	include	a	combination	of supply	boats	(i.e.,	work	boats	and/or crew	boats),	an	anchor	handling	boat,	tug	boats,	barges,	stimul ation	vessels,	and	well evaluation	vessels. The	anchor	handling	boat	will	not	be	used	to	set	anchors	while on	site.		Hence,	it	was	treated	as	a	Supply Boat	in	this	application.		Supply	boats	will	be	used	to	transpo rt	personnel	and	supplies	to	the	drillship, as	required	for	conducting	the	pr oject	activities.		The	tug	boa ts,	barges,	stimulatio n	vessels,	and	well

evaluation	vessels	will	be	utili zed	under	various	operating	sce nario	as	described	in	Section	3	of	this application.

The	different	support	vessels	wil l	be	used	interchangeably	depe nding	on	availability, and	therefore	it	is not	known	which	specific	support vessel	will	be	available	durin g	the	proposed	project	operations.		To accommodate	this	uncertainty,	Ana darko	selected	the	highest	emi tting	vessels	in	each	category	of	the support	vessels	to	develop	Potent ial	to	Emit	(PTE)	calculations .				Similarly,	Anadarko	will	utilize	various third	party	equipment	(e.g.,	int ernal	combustion	engines,	flowb ack	boiler,	boom	flare,	and	condensate storage	tanks,)	on	the	drillship and/or	support	vessels	during various	operating	scenarios	as	described in	Section	3	of	this	application.		The	exact	specifications	of third	party	equipment	to be	utilized	over	the duration	of	the	proposed	project are	currently	unknown	to	Anada rko.

Air	pollutant	emission s	generated	from	the	project	include	the criteria	pollutants	of	NO X ,	CO,	PM,	PM 10 , PM 2.5 ,	SO 2 ,	VOC,	and	GHGs.		These	emissions	are	primarily	released	from	t he	combustion	of	diesel	fuel	in

the	internal	combustio n	engines	and	a	boiler,	storage	tanks,	an d	miscellaneous	activities.



### 1.3.1. Emission Sources

The	emission	sources	o n	the	BlackHornet	drillship	primarily	con sist	of	internal	com bustion	engines, storage	tanks,	mud	degasser,	dus t	collectors,	diesel	fuel	lines ,	welding,	and	painting.		The	emission sources	on	the	support	vessels	p rimarily	consist	of	internal	co mbustion	engines,	storage	tanks,	and

diesel	fuel	lines.		Several	third party	temporary emission	sour ces	(e.g.,	internal	c ombustion	engines, flowback	boiler,	boom	flare,	and	c ondensate	storage	tanks)	will be	utilized	on	the drillship	and/or support	vessels	per	project	requi rements.	Tables	1‐3	through	1‐ 9	present	a	summary of	the	emission units	proposed	for	this	project.

Table 1

‐ 3. Summary of Emission Units on the Drillship

EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents

DR‐ME‐01

to

DR‐ME‐06 Main	Propulsion	Electrical Generator	Engines	or	Main Engines (#1	to	#6)	 6 HYUNDAI‐HiMSEN, 9H32/40	 6,035	 HP Ultra	Low

Sulfur

Diesel (ULSD)

DR‐ME‐07

DR‐ME‐08 Main	Propulsion	Electrical Generator	Engines	or	Main Engines	 2 HYUNDAI‐HiMSEN, 18H32/40V	 12,069	 HP	 ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 12 Trinity Consultants EPN Emission Unit Description # of

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

DR‐GE‐01	 Emergency	Generator	 1 Cummins

QSK60DMGE 2,547	 HP	 ULSD

DR‐LB‐01

to

DR‐LB‐06 Life	Boat	Engines (#1	TO	#6)	 6	 SIYANG	485‐J	 41	 HP	 ULSD
DR‐AC‐01	 Emergency	Air	Compressor	 1	 HATZ	2M41	 39	 HP	 ULSD

DR‐FR‐01	 Fast	Rescue	Craft	 1	 SABB‐L4	Turbo	 55	 HP	 ULSD

DR‐FT‐01 No.	1	Fuel	Oil	Storage	Tank (Port)	 1 ‐‐ 657

M 3 ULSD

DR‐FT‐02 No.	1	Fuel	Oil	Storage	Tank (Starboard)	 1 ‐‐ 657 M 3

ULSD

DR‐FT‐03 No.	2	Fuel	Oil	Storage	Tank (Port)	 1 ‐‐ 1485 M 3

ULSD

DR‐FT‐04 No.	2	Fuel	Oil	Storage	Tank (Starboard)	 1 ‐‐ 1485 M 3

ULSD

DR‐FT‐05 No.	3	Fuel	Oil	Storage	Tank (Port)	 1 ‐‐ 1439 M 3

ULSD

DR‐FT‐06 No.	3	Fuel	Oil	Storage	Tank (Starboard)	 1 ‐‐ 1439 M 3

ULSD

DR‐FT‐07 No.	1	Fuel	Oil	Settling	Tank (Starboard)	 1 ‐‐ 71 M 3

ULSD

DR‐FT‐08 No.	2	Fuel	Oil	Settling	Tank (Port)	 1 ‐‐ 71 M 3

ULSD

DR‐FT‐09 No.	1	Fuel	Oil	Servicing Tank	(#1	E/R)	 1 ‐‐ 31 M 3

ULSD

DR‐FT‐10 No.	2	Fuel	Oil	Servicing Tank	(#1	E/R)	 1 ‐‐ 31 M 3

ULSD

DR‐FT‐11 No.	1	Fuel	Oil	Servicing Tank	(#2	E/R)	 1 ‐‐ 31 M 3

ULSD

DR‐FT‐12 No.	2	Fuel	Oil	Servicing Tank	(#2	E/R)	 1 ‐‐ 31 M 3

ULSD

DR‐FT‐13 No.	1	Fuel	Oil	Servicing Tank	(#3	E/R)	 1 ‐‐ 35 M 3

ULSD

DR‐FT‐14 No.	2	Fuel	Oil	Servicing Tank	(#3	E/R)	 1 ‐‐ 35 M 3

ULSD

DR‐FT‐15	 Fuel	Oil	Over	Tank	 1	 ‐‐ 46	 M 3 ULSD

DR‐FT‐16	 Fuel	Oil	Leak	Tank	 1	 ‐‐ 23	 M 3 ULSD

DR‐FT‐17 DR‐FT‐18	 Helicopter	Fuel	Tanks	 2 ‐‐ 2,900	 Liter	 Jet	Fuel

DR‐DC‐01

DR‐DC‐02

DR‐DC‐03	 Dust	Collector	 3 ‐‐

26 M 3 /

Min	 ‐‐Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 13 Trinity Consultants EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents DR‐VG‐01	 Mud	Degasser	Vent	 1 ‐‐ ‐‐ ‐‐	 ‐‐ DR‐FE‐01	 Drillship	Fugitive	Emissions ‐‐	 ‐‐	 ‐‐	 ‐‐	 ‐‐
DR‐PO‐01	 Painting	Operations	 ‐‐	 various	 ‐‐	 ‐‐	 ‐‐ DR‐WO‐01	 Welding	Operations	 ‐‐	 various	 ‐‐	 ‐‐	 ‐‐

Table 1

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

EPN Emission Unit Description # of

units Model Rating or Capacity Fuel Type or
Content

s
DR‐TP‐01

and DR‐TP‐02	 Third	Party	Engines		 2 Various	‐	EPA	Tier

II	Certified	 ≤	860	 HP	 ULSD

DR‐TP‐03	to

DR‐TP‐11	 Third	Party	Engines		 9 Various	‐	EPA	Tier

II	Certified	 ≤	300	 HP	 ULSD

DR‐TP‐12	to

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

DR‐TP‐17	to

DR‐TP‐21	 Third	Party	Engines	 5 Various	‐	EPA	Tier

II	Certified	 ≤	126	 HP	 ULSD

DR‐TP‐22 Flowback	Boiler 1	 various	 8 MMBTU /Hr	 ULSD

DR‐TP‐23 Boom	Flare 1	 various	 60 MMSCF/ Day Natural

gas
DR‐TP‐24

DR‐TP‐25

DR‐TP‐26 Well	Completion

Condensate	Tanks (#1	to	#3)	 3	 ‐‐	 21,000 Gallons Condens

ate

Table 1

‐ 5. Summary of Emission Units on the Supply Boats

EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents

SB‐ME‐01

SB‐ME‐02 Marine	Propulsion	Engines (#1	and	#2)	 2 Caterpillar	3516C DITA	or	equivalent	 3,004	 HP	 ULSD

SB‐TE‐01

SB‐TE‐02

SB‐TE‐03 Marine	Thruster	Engines (#1	to	#3)	 3 Caterpillar	3508C DITA	or	equivalent	 1,100	 HP	 ULSD

SB‐GE‐01

SB‐GE‐02 Electrical	Generator		Engine (#1	and	#2)	 2 Caterpillar	C32	DITA or	equivalent	 1,047	 HP	 ULSD

SB‐GE‐03 Emergency	Electrical

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

SB‐GE‐04	 ROV	Electrical	Genera tor		 1	 various	 475	 HP	 ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 14 Trinity Consultants EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents

SB‐DT‐01 Vessel's	Diesel	Fuel	Storage
Tanks	#1	Port	 1	 ‐‐	 38,020	 Gallons	 ULSD

SB‐DT‐02 Vessel's	Diesel	Fuel	Storage
Tanks	#1	Starboard	 1	 ‐‐	 38,020	 Gallons	 ULSD

SB‐DT‐03 Vessel's	Diesel	Fuel	Storage
Tank	#2	Port	 1	 ‐‐	 38,424	 Gallons	 ULSD

SB‐DT‐04 Vessel's	Diesel	Fuel	Storage
Tank	#2	Starboard	 1	 ‐‐	 38,424	 Gallons	 ULSD

SB‐DT‐05 Vessel's	Diesel	Fuel	Storage
Tank	#3	Port	 1	 ‐‐	 42,398	 Gallons	 ULSD

SB‐DT‐06 Vessel's	Diesel	Fuel	Storage
Tank	#3	Starboard	 1	 ‐‐	 42,398	 Gallons	 ULSD

SB‐DT‐07 Vessel's	Diesel	Fuel	Storage
Tank	#4	Port	 1	 ‐‐	 42,346	 Gallons	 ULSD

SB‐DT‐08 Vessel's	Diesel	Fuel	Storage
Tank	#4	Starboard	 1	 ‐‐	 42,346	 Gallons	 ULSD

SB‐DT‐09 Vessel's	Diesel	Fuel	Storage
Tank	#5	Port	 1	 ‐‐	 6,572	 Gallons	 ULSD

SB‐DT‐10 Vessel's	Diesel	Fuel	Storage
Tank	#5	Starboard	 1	 ‐‐	 7,340	 Gallons	 ULSD

SB‐DT‐11 Vessel's	Diesel	Fuel	Storage Day	Tank	#1	Port	 1	 ‐‐	 6,027	 Gallons	 ULSD

SB‐DT‐12 Vessel's	Diesel	Fuel	Storage Day	Tank	#1	Starboard	 1	 ‐‐	 9,149	 Gallons	 ULSD

SB‐DT‐13 Vessel's	Diesel	Fuel	Stern Thruster	Day	Tank	 1	 ‐‐	 1,496	 Gallons	 ULSD

SB‐DT‐14 Vessel's	Diesel	Fuel Overflow	Port	Storage	Tank	 1	 ‐‐	 4,401	 Gallons	 ULSD

SB‐DT‐15 Vessel's	Diesel	Fuel Overflow	Standby	Storage
Tank	 1	 ‐‐	 4,401	 Gallons	 ULSD

SB‐FE‐01 Work	Boat	Fugitive

Emissions	 ‐‐	 ‐‐	 ‐‐	 ‐‐ ‐‐

SB‐TP‐01

SB‐TP‐02 Well	Evaluation	Third	Party Engine	(#6	and	#7)	 2 Caterpillar	3406C	or equivalent	 360	 HP	 ULSD

SB‐TP‐03 Well	Evaluation	Third	Party Crane	Motor	Engine	#1	 1 John	Deere	PE	4045D or	equivalent	 62	 HP	 ULSD

SB‐TP‐04 Well	Evaluation	Third	Party Crane	Motor	Engine	#2	 1 Cummins	B	5.9‐C	or equivalent	 130	 HP	 ULSD

SB‐TP‐05

to	SB‐TP‐

09 Third	Party	Well	Evaluation Engines	 5	 Detroit	Diesel	 ≤	140	 HP	 ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 15 Trinity Consultants Table 1

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

EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents

AB‐ME‐01

AB‐ME‐02 Marine	Propulsion	Engine (#1	and	#2)	 2 Caterpillar	Model
3616	 7,570	 HP	 ULSD

AB‐TE‐01

AB‐TE‐02

AB‐TE‐03 Thruster	Engines (#1	to	#3)	 3 Caterpillar	Model
3512B‐HD	 1,674	 HP	 ULSD

AB‐GE‐01

AB‐GE‐02

AB‐GE‐03 Service	Generator	Engines (#1	to	#3)	 3 Caterpillar	Model

3412C	 716	 HP	 ULSD

AB‐GE‐04

AB‐GE‐05 Service	Generator	Engines

Crane	Dedicated

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

AB‐GE‐06 Emergency	Generator Engine	 1 Caterpillar	Model

3406C	 307	 HP	 ULSD

AB‐GE‐07

AB‐GE‐08 Winch	Hydraulic	Engines (#7	and	#8)	 2	 Caterpillar	Model	C32	 1,300	 HP	 ULSD

AB‐DT‐01 Port	Side	Double	Bottom
Diesel	Fuel	Tank	#1	 1	 ‐‐	 12,842	 Gallons	 ULSD

AB‐DT‐02 Starboard	Side	Double
Bottom	Diesel	Fuel	Tank		#1	 1	 ‐‐	 12,852	 Gallons	 ULSD

AB‐DT‐03 Center	Double	Bottom
Diesel	Fuel	Tank	#1	 1	 ‐‐	 15,706	 Gallons	 ULSD

AB‐DT‐04 Port	Side	Double	Bottom
Diesel	Fuel	Tank	#2	 1	 ‐‐	 31,483	 Gallons	 ULSD

AB‐DT‐05 Starboard	Side	Double
Bottom	Diesel	Fuel	Tank	#2	 1	 ‐‐	 31,483	 Gallons	 ULSD

AB‐DT‐06 Port	Wing	Diesel	Fuel	Tank
#1	 1	 ‐‐	 16,321	 Gallons	 ULSD

AB‐DT‐07 Starboard	Wing	Diesel	Fuel
Tank		#1	 1	 ‐‐	 16,321	 Gallons	 ULSD

AB‐DT‐08 Port	Side	Double	Bottom
Diesel	Fuel	Tank	#3	 1	 ‐‐	 27,788	 Gallons	 ULSD

AB‐DT‐09 Starboard	Side	Double
Bottom	Diesel	Fuel	Tank	#3	 1	 ‐‐	 27,788	 Gallons	 ULSD

AB‐DT‐10 Port	Wing	Diesel	Fuel	Tank
#2	 1	 ‐‐	 53,328	 Gallons	 ULSD

AB‐DT‐11 Starboard	Side	Double
Bottom	Diesel	Fuel	Tank	#4	 1	 ‐‐	 55,097	 Gallons	 ULSD

AB‐DT‐12 Starboard	Wing	Diesel	Fuel
Tank	#2	 1	 ‐‐	 38,974	 Gallons	 ULSD

AB‐DT‐13

AB‐DT‐14 Port	Side	Double	Bottom
Diesel	Fuel	Tank	#4	and	#5	 1	 ‐‐	 28,138	 Gallons	 ULSD
AB‐DT‐15	 Port	Service	Diesel	Tank	 1	 ‐‐	 13,497	 Gallons	 ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 16 Trinity Consultants EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents

AB‐DT‐16 Starboard	Service	Diesel
Tank	 1	 ‐‐	 13,497	 Gallons	 ULSD AB‐DT‐17	 Port	Diesel	Settling	Tank	 1	 ‐‐	 13,724	 Gallons	 ULSD

AB‐DT‐18 Starboard	Diesel	Settling
Tank	 1	 ‐‐	 13,724	 Gallons	 ULSD

AB‐DT‐19	 Diesel		Overflow	Ta nk	 1	 ‐‐	 3,694	 Gallons	 ULSD

AB‐FE‐01 Anchor	Handling	Boat Fugitive	Emissions	 ‐‐	 ‐‐	 ‐‐	 ‐‐	 ‐‐

Table 1

‐ 7. Summary of Emission Units on the Stimulation Vessel

EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents

SV‐ME‐01

SV‐ME‐02 Stimulation	Vessel		Main Propulsion	Engines (#1	and	#2)	 2	 various	 3,634	 HP	 ULSD SV‐BT‐01	 Bow	Thruster	Engine	 1	 various	 1,675	 HP	 ULSD
SV‐DD‐01	 Bow	Drop‐Down	Engine	 1	 various	 1,200	 HP	 ULSD SV‐ST‐01	 Stern	Thruster	Engine	 1	 various	 1,675	 HP	 ULSD

SV‐PE‐01 through

SV‐PE‐08 Representative Pump	Engines

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

SV‐GE‐01 SV‐GE‐02	 Generators	(#1	and	#2)	 2	 various	 1,220	 HP	 ULSD

SV‐GE‐03 SV‐GE‐04	 Generators	(#3	and	#4)	 2	 various	 805	 HP	 ULSD

Table 1

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

EPN Emission Unit Description # of

units Model Rating or Capacity Fuel Type

or
Contents

TB‐ME‐01

TB‐ME‐02

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

TB‐GE‐01

TB‐GE‐02 Tug	Generator	Engine (#1	and	#2)	 1	 various	 174	 HP	 ULSD

BG‐LP‐01

BG‐LP‐02

BG‐LP‐03 Barge	Electrical	Generators (#1	to	#3)	 3	 various	 456	 HP	 ULSDAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 17 Trinity Consultants Table 1

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

EPN Emission Unit Description # of

units Model Rating or Capacity Fuel
Type or
Contents

WE‐ME‐01

WE‐ME‐02 Well	Evaluation	Vessel	Main Engines	(#1	and	#2)	 2	 various	 2,250	 HP	 ULSD

WE‐AE‐01

WE‐AE‐02 Well	Evaluation	Vessel	Axillary Engines	(#1	and	#2)	 2	 various	 1,468	 HP	 ULSD
WE‐GE‐01	 Emergency	Generator	#1	 1	 various	 272	 HP	 ULSD WE_GE‐02	 Emergency	Generator	#2	 1	 various	 212	 HP	 ULSD WE‐GE‐03	 Generator	Engine	#3	 1	 various	 200	 HP	 ULSD



### 1.4. CONTENTS OF THE APPLICATION ADDENDUM

This	 permit	 application	 is	 being	 submitted	 in	 accordance	 with	 4 0	 CFR	 55.6(a)(1)	 and	 satisfies	 all applicable	requirements	of	40	CF R	52.21.		This	application	incl udes	the	following:

Section	2	Process	Description:	c ontains	a	brief	description	of drilling	and	completion	days;

Section	3	Emission	Calculations: contains	the	di scussion	of	emi ssion	calculation	methodology	for	all additional	sources	and	operations	in	this	application; Section	4	Regulatory	Applicabilit y	Analysis:	contains	the	air	r egulatory	applicability	analysis	for	all

emission	sources	related	to	the proposed	drilling	operations; Section	5	BACT	Analysis:	contain s	the	BACT	review	for	all	emiss ion	sources	in	this	application;

Section	6	Part	71	forms:	conta ins	the	Part	71	forms;	and AppendicesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 18 Trinity Consultants 

## 2. PROCESS DESCRIPTION

This	section	describes	the	proce ss	involved	in	conducting	the	e xploratory	drilling,	we ll	completion,	and production	well	maintenance	opera tions,	and	associated	source	o f	air	emissions	as represented	in	this permit	application.



### 2.1. EXPLORATORY DRILLING DESCRIPTION

The	Diamond	BlackHornet	drillshi p	is	a	dynamically‐positioned	d rillship	that	is	desi gned	for	operation in	the	deep	water	(i.e.,	10,000	feet of	water	or	below.)		As	a dynamically‐positione d	drillship,	the BlackHornet	maintains	its	positi on	over	the	desired	location	by using	computer‐controlled	thruster propellers	rather	than	anchors and	is	not	required	to	be	attach ed	to	the	seabed	in	or der	to	establish	or maintain	its	position	like	a	tra ditional	moored	semi‐submersibl e	drillship.

The	dynamically	positioned	drills hip	transits	to	a	particular	d rilling	location	and	performs	a	bottom survey	with	a	remotely	operated	ve hicle	(ROV)	to	mark	the	spud‐ in	location.		The	well	is	then	spudded to	initiate	drilling	operations	at	the	site.		To	accomplish	thi s,	a	short	length	of	pipe	called	the	jet	pipe	is run	to	the	seabed	floor	using	a	s maller	multi‐purpose	pipe	call ed	the	drill	pipe.		The drill	pipe	is	run through	the	jet	pipe, terminating	with	a	drill	bit	at	the	end. The	drill	bit	is	spaced	so	that	it	extends	just outside	the	jet	pipe	a	few	inches.

Seawater	is	pumped	through	the	b it	as	the	jet	pipe	is	lowered	i nto	the	seabed	until	approximately	12 feet	of	the	end	of	the	jet	pipe remains	above	the	seabed	floor. The	drill	pipe	is	then released	from	the	jet pipe	so	that	the	drill	bit	can	b e	used	to	drill	the	exploration well.		Seawater	or	dri lling	fluid	(mud)	is pumped	down	the	drill	pipe	out	t he	bit	to	clean	the	hole	as	the drill	bit	is	rotated with	weight	put	down

on	the	formation.		Once	the	dril l	bit	has	drille d	to	a	designat ed	depth,	the	drill	bit is	retrieved	back	to surface,	leaving	the	jet	pipe	an d	a	section	of	hole	drilled	bel ow	the	jet	pipe.		Another	pipe	called	the surface	casing	is	then	run	throu gh	the	jet	pipe	and	into	the	op en‐hole	section.		Ce ment	is	then	pumped around	the	outside	of	the	casing to	cement	it	in	place.		Once	s urface	casing	has	been set,	the	blow	out preventer	(BOP)	is	run.

The	BOP	is	run	on	pipe	called	th e	drilling	riser	which	is	conne cted	to	the	wellbore	at the	seabed	floor. This	arrangement	allows	a	closed	loop	system	in	which	fluids	pu mped	through	the	drill bit	return	to	the drillship	for	reuse.		The	BOP	als o	serves	as	a	safety	device	pr otecting	against	a	well	blowout.		The	drill and	casing	process	is	then	repea ted	to	progress	the	well	to	the well	objective	depth.		Casings	are	run	at designed	intervals	according	to	t he	subsurface	data	used	to	des ign	the	well.		Each	time	a	casing	is	run, the	next	section's	casing	will	b e	smaller	in	order	to	fit	insid e	the	casing	that	has just	been	cemented.

Once	the	well	objective	depth	in the	potential	reservoir	is	ach ieved,	an	evaluation	program	is	carried out.		This	typically	involves	ru nning	a	series	of	wire	line	too ls	to	measure	variou s	properties	of	the formation.		Depending	upon	the	e valuation	results,	the	well	wil l	either	be	sidetracked	to	another objective,	abandoned,	or	a	casin g	set.		Once	the	exploratory	wo rk	scope	is	completed,	the	well	is	plugged with	cement	and/or	mechanical	t ools.		The	BOP	is	retrieved	alon g	with	the	riser	and	an	ROV	bottom survey	is	performed.		This	will	c omplete	the	expl oratory	drilli ng	activity	for	one	location.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 19 Trinity Consultants During	the	exploratory	drilling, several	diesel	fired	internal combustion	engines	are	used	to	provide power	for	several	activities.		T he	main	engines	on	the	drillshi p	are	utilized	to	mainta in	a	position	of	the drillship	as	well	as	to	supply	power	to	the	drilling	activity. Some	of	these	engines	are	fixed	on	the drillship	(such	as	main	engines, emergency	generators,	and	air compressors	etc.)	and	remaining	engines are	brought	onboard	as	required	( i.e.,	third	part y	engines	such as	wire	line	engines ,	casing	units	and electric	line	engines	etc.).			T hese	engines	emit	criteria	poll utants,	GHGs,	as	well	as	hazardous	air pollutants	(HAPs)	due	to	combusti on	of	diesel	fuel.		Several	di esel	fuel	storage	tank s	are	located	on	the drillship	and	these	tanks	emit	V OCs	due	to	variation	in	ambient temperature	(also	known	as	‘breathing losses’)	and	during	fuel	loading activity	(also	known	as	‘worki ng	losses’).		These	storage	tanks	are equipped	with	pumps,	flanges,	co nnectors,	and/or	other	miscella neous	devices	(also	known	as	fugitive components	of	air	emi ssions)	for	transferri ng	the	fuel	from	one location	to	other. The	support	vessels also	operate	several	diesel	fired internal	combustion	engines	a nd	fuel	storage	tanks contributing	to	air pollution.		Other	miscellaneous	air	pollution	sources	during	th e	drilling	activity	include	painting operations,	mud	degassing,	and	ce ment	and	mud	mixing	operations .		Air	emissions	from these	activities are	described	in	details	in	Section	3	of	this	application.



### 2.2. WELL COMPLETION

Once	a	well	has	been	drilled	and	evaluated,	a	decision	must	be made	whether	to	com plete	the	well	or plug	it.		If	the	well	is	to	be	c ompleted,	a	well	head	which	ser ves	as	the	pressure‐c ontaining	equipment
will	be	installed	subs ea	where	casing	strin gs	are	suspended	and the	BOP	or	subsea	tree	is	connected.

Production	casing	is	run	down	th e	hole	and	cemented.		Once	the casing	is	in	place,	holes	are	perforated through	the	casing,	cement,	and into	the	reservoir.		These	hole s	are	made	to	facilita te	material	transfer between	the	reservoir	and	the	pro duction	casing. Tubing	along with	the	packer	is	run	into	the	casing.		A plug	is	set	above	the	perforatio ns	as	a	barrier	between	the	pro duction	casing	and	the	tubing.

For	a	gas	well,	a	gravel	pack	completion	assembly	is	typically installed	to	reduce	th e	inflow	of	sand	from

the	formation.		The	formation	is perforated	through	the	well	ca sing	to	allow	the	expected	natural	gas

into	the	well	and	then to	the	surface.		Dur ing	the	well	complet ion	phase,	a	sub‐sea	well	head	is	installed on	the	sea	floor	and	the	product ion	tubing,	with	down‐hole	cont rol	valve,	and	packer	is	lowered	into	the finished	well	(inside	the final	casing	string).

Thereafter,	a	production	packer and	a	tubing	are	installed.		Pr oduction	packers	are	placed	above	the production	zone.		The	packer	is olates	the	annulus	between	the	t ubing	and	the	inner	casing	and	the	foot of	the	well.		It	provides	a	sea l	to	stop	reservoir	fluids	from flowing	up	the	full	length	of	the	casing	and damaging	it.		Production	tubing	plays	the	role	of	the	main	cond uit	for	transporting hydrocarbons	from the	reservoir	to	surface	(or	inje ction	material	the	other	way). It	runs	from	the	tubing	hanger	at	the	top of	the	wellhead	down	to	a	point	generally	just	above	the	top	of the	production	zone.		Tubing	hanger	sits on	top	of	the	wellhead	and	serves as	the	main	support	for	the	p roduction	tubing.

A	surface‐controlled	sub‐surface safety	valve	(SCSSV)	is	instal led	in	the	production	tubing	and	is	held	in the	open	position	by	a	high‐pres sure	hydraulic	line	from	surfac e	contained	in	a	control	line	that	is

attached	to	the	down‐hole	contro l	valve's	hydraulic	chamber	and terminated	at	surface	to	a	hydraulic actuator.		The	high	pressure	is needed	to	overcome	the	producti on	pressure	in	the	tubing	upstream	of

the	choke	on	the	tree.		The	SCSSV acts	as	a	safety	device	in	th e	event	of	the	wellhea d/tree/tubing	failure. During	temporary	unloading/flowb ack	phase,	through	portable	wel l	testing	equipmen t	on	a	drillship,Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 20 Trinity Consultants the	hydrocarbons	flow	up	the	tub ing	and	are	processed	through	s urface	well	test	e quipment.		The hydrocarbons	are	separated	and	th e	gas	flared	and	the	liquids	a re	directed	to	the	barge	or	to	the	tanks. After	flowback	is	completed	and the	well	is	clea ned	up,	the	wel l	is	secured	until	flow	lines	are	installed to	the	production	facility.

During	the	well	completion,	sev eral	diesel	fired	internal	combu stion	engines	are	us ed	to	provide	power

for	different	activities.		The	d rillship	main	engines	supply	po wer	along	with	various	third	party equipment	to	perform different	activities. This	phase	could	re quire	use	of	supply	boats,	tug	boats, barges,	stimulation	vessel,	or	we ll	evaluation	vessel	to	suppor t	the	various	ac tivities.		The	different	well completion	scenario	and	associat ed	sources	of	ai r	emissions	are described	in	the	Section	3.



### 2.3. PRODUCTION DESCRIPTION (WELL MAINTENANCE)

After	completion	activities,	the well	is	brought	on	production, and	the	oil	and	gas	is	flowed	back	to	the production	facility	for	processi ng	and	then	sent	to	shore	via	t he	sales	pipeline.	D ownhole	equipment

failure	or	reservoir‐related	issu es	(i.e.,	remedial	well‐work/m aintenance)	may require	drillship intervention	to	repai r	and	restore	production	to	the	well.

The	drillship,	the	support	vesse ls,	and/or	the	stimulation	vess el	will	conduct	reme dial	well‐work	if needed	after	the	well	is	put	in production.		The	air	pollution sources	during	the	w ell	maintenance	are similar	to	that	of	the	drilling and	the	well	com pletion	phases. Emissions	associated	with	well maintenance	phase	are	lower	comp ared	to	that	of	drilling	and	we ll	completion	phases	and	therefore,

emissions	associated	with	the	we ll	maintenance	activities	are	n ot	separately	estimated	in	this application.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 21 Trinity Consultants 

## 3. EMISSIONS CALCULATIONS

This	section	presents	a	summary	o f	the	emissions	calculation	me thodologies,	emission	factors,	and operating	parameter	assumptions for	estimating	emissions	from	t he	sources	of	air	pollution	on	the drillship,	the	supply	boats,	the stimulation	vessel,	the	well	e valuation	vessel,	and	miscellaneous

activities.		The	detailed	emissi ons	calculations	are	included	i n	Appendix	B	of	this	application.



### 3.1. ‘EQUIVALENCY’ DETERMINATION

As	mentioned	previously,	Anadar ko	will	operate	various	emission units	for	which	exact	specifications are	not	available	at	this	time	due	to	scheduling	and	other	cont ractual	agreements	tha t	will	be	completed in	the	future.		Therefore,	Anadark o	has	proposed	the	worst	case emission	units	for	each	category	of	air pollution	sources	to	develop	the PTE	while	maintaining	sufficie nt	operational	flexibility	to	provide Anadarko	the	ability	to	utilize	various,	‘equivalent’	operation al	equipment.		Also,	A nadarko	proposes	the demonstration	of	‘equivalency’	b ased	on	the	following	factors:

Equal	or	lower	mass	emi ssions	for	each	crit eria,	toxic,	and	oth er	regulated	air	pollu tants	on	a	short‐ term	(e.g.,	lbs/day)	and	a	long‐term	(e.g.,	ton/year)	basis; Compliance	with	applicable	reg ulations	(e.g.,	40	CFR	60,	40	CFR 63); Compliance	with	applicable	cert ifications	(e.g.,	EPA	Tier	2,	IM O	Tier	2);	and Compliance	with	applicable	BAC T	requirements	identified	for	rep resentative	equipment.

A	list	of	equipment	for	which	An adarko	is	requesting	above‐ment ioned	flexibility	is	provided	below.

Third	party	engines	(DR‐ TP‐01	through	DR‐TP‐21) Supply	boats	and	all	associated	air	pollution	sources	(all	EPNs starting	with SB	and	AB)

Stimulation	vessel	and	all	associ ated	air	pollution	sources	(al l	EPNs	starting	with	SV)

Well	evaluation	vessel	and	all	a ssociated	air	pollution	sources (all	EPNs	starting	with	WE) Tug	boats,	barges	and	all	associ ated	air	pollution	sources	(all EPNs	starting	with	TB	and	BG) Other	miscellaneous	sources	(suc h	as	painting,	welding,	etc.)	a s	described	in	this	application.



### 3.2. OPERATING SCENARIOS

Various	operating	scenarios	can	o ccur	during	the	drilling,	well completion,	and	maintenance	phases. The	proposed	project	can	be	broa dly	classified	in	to	six	operat ing	scenario.		The	goal	of	this	classification is	to	represent	the	worst‐case	hou rly,	24‐hour,	and	annual	air emissions	for	calculating	Potential	to	Emit (PTE).		The	following scenarios	were	derived	for	estimating	the PTE.

Worst‐case	gas	well	flowback	scenario; Worst‐case	oil	well	flowback	scenario;

Worst‐case	stimulation	ves sel	operations	scenario; Well	completion	third	party	equ ipment	operations	scenario; Well	evaluation	vessel	op erations	scenario;	and Worst‐case	drilling	scenario.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 22 Trinity Consultants The	proposed	emissions	sources	du ring	each	scenario	and	associa ted	operating	parameters	are provided	in	Appendix	B.		The	afo rementioned	operation	scenarios will	not	happen	concurrently.		Only

one	out	of	these	scenarios	OR	an y	‘equivalent’	combination	will be	conducted	an d	the	resulting

emissions	from	activities	involv ed	in	the	scenario	will	not	exc eed	the	worst‐case	em issions	among	the six	scenarios.		The	drillship	and	supply	boats	will	also	be	ope rating	on	an	as	required	basis.		The operation	of	the	aforem entioned	scenarios	w ill	typically	involv e	the	following	sources as	listed	below.

The	remainder	of	this	se ction	discusses	the short	term	and	long term	emission	calculation methodologies	for	each	equipment ,	assumptions,	proposed	operati ng	parameters,	and the	derivation	of the	fuel	based	emission	factors,	if	applicable.		Appendix	B	pro vides	a	summary	of	em issions	for	each operating	scenario	for	each	c riteria	pollutant,	GHGs,	H 2 SO 4 ,	and	HAPs.



### 3.3. DRILLSHIP

The	emission	calculation	methodologies	for	the	air	pollution	so urces	on	the	BlackHornet	drillship	are

discussed	below.



### 3.3.1. Main Engines (DR-ME-01 through DR-ME-08)

The	drillship	consists	of	eight main	engines.		Six	of	the	eight engines	are	identical	HYUNDAI‐HiMSEN, 9H32/40V	6,035	HP	diesel‐fired	eng ines.		The	other	two	engines are	HYUNDAI‐HiMSEN,	18H32/40V 12,069	HP	diesel‐fired	engines.		The specification	sheets	for	t hese	engines	are	provided	in	Appendix	G‐1.

Emission Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	each	of	the	eight engines	are	summarized	below.

AP

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

‐ fuel Engines –CO,	VOC,

and	HAP	emissions	esti mates	for	the	eight main	engines	are	base d	on	AP‐42,	Section	3.4 emission	factors	(Table	3.4‐1, Table	3.4‐2,	and	Table	3.4‐3). Non‐methane	VOC emission	factor
has	been	taken	as	91%	o f	the	total	organic compounds	(TOC)	emis sion	factor.

NSPS Subpart IIII ‐ Standards of Performance for Stationary Compression Ignition Internal

Combustion Engines –	Particulate	Matter	and	NO X Emission	estimates	f or	the	eight	main engines	are	based	on	the	emission standards	specified	in	40	CFR 60.4204(c)	for	non‐emergency stationary	CI	engines	with	a	dis placement	of	greater	than	or	eq ual	to	30	liters	per	cylinder	and installed	after	January	1,	2 012	and	before	Ja nuary	1,	2016	wher e	maximum	engine	speed	is greater	than	130	rpm but	less	than	2,000	rpm.		Furthermore,	bas ed	on	AP‐42	guidance,	all	of	the particulate	matter	is	assumed	to be	less	than	1	μm.		Therefore, it	is	assumed	PM 2.5 =	PM 10 =	PM.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA’s	guidance	documen t: 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	us ed	as	a surrogate	for	distillate	oil‐fired engines	due	to	unavailabilit y	of	emission	factors.

EPA Regulations

– CO 2 ,	CH 4, and	N 2 O	emission	factors	are	obtain ed	from	40	CFR	98	Subpart	C, Table	C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	andAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 23 Trinity Consultants Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel fuel	assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized to	SO 2 and	2	percent	of	sulfur	in	the fuel	is	oxidized	to	sulfuric	acid	(H 2 SO 4 )	mist	based	on	Section	4.1.1 of	Draft	Regulatory	Impact Analysis:	Control	of	Emissions	fr om	Nonroad	Diesel	Engines,	EPA 420‐R‐03‐008,	April	2003. Emissions	of	Hydrogen	sulfide	(H 2 S),	total	reduced	sulfur	(TRS), and	reduced	sulfur	compounds resulting	from	sulfur	content in	the	fuel	are	negligible.

Fuel Based Emission Factor Derivation :

Since	the	main	engines	operate	in	a	group,	the	PTE	is	calculate d	for	the	group	of	mai n	engines	based	on the	maximum	power	req uirements	for	all	opera ting	scenario.		Bas ed	on	the	specifications	sheet provided,	all	of	these	engines	h ave	a	break	specific	fuel	consu mption	(BSFC)	of	179	g/kW‐hr.		Since	the main	engines	are	the	highest	emi tters	of	a	pollutant	on	a	lbs	o f	pollutant/cubic	met er	of	fuel	consumed among	the	variou s	engines	on	the	drillsh ip,	the	fuel limits	est ablished	on	the	fuel	b ased	emission	factors for	the	main	engines	represent	t he	worst	case	emission	scenario .		Hence,	Anadarko	is	proposing drillship‐wide	fuel	limit	derive d	using	the	main engine	fuel	ba sed	emission	factors	(i. e.,	lbs	of	pollutant per	cubic	meter	of	fue l.)			These	fuel	bas ed	emission	factor	ca lculation	is	presented	in	Appendix	B.

Proposed Operating Limits :

Anadarko	proposes	a	drillship‐wide	fuel	cap	of	123	cubic	meters /day	for	all	the	diesel	combustion sources	located	on	the	drillship.		This	fuel	cap	is	the	highest fuel	usage	of	all	the	six	scenarios.		The	daily fuel	cap	is	derived	based	on	t he	maximum	daily power	requiremen t	of	576,000	KW.

Also,	Anadarko	proposes	to	use 18,438	cubic	meters/year	fuel	fo r	all	the	diesel	c ombustion	sources located	on	the	drillship.		The	annual	fuel	limit	is	calculated based	on	approximately	200	days	of operation	and	the	power	requi rement	of	86,400,000	KW.		However, Anadarko	proposes	the	annual	fuel limit	in	lieu	of	annual	operating	time	limit.		In	case	Anadarko does	not	consume	the	proposed	annual	fuel in	200	days,	Anadarko	proposes	to	maintain	the	flexibility	of	o perating	more	than	200	days	as	long	as total	fuel	consumption is	within	the	proposed	limit.		The	maxim um	hourly,	daily,	an d	annual	emissions from	the	main	engines	are	calcul ated	based	on	the	derived	fuel based	emission	factor	as	described

below:

Maximum Hourly Emissions

– The	maximum	hourly	emissions	for the	main	engines	are	calculate d

based	on	the	fuel	based	emission factor	and	max imum	fuel	requir ement	of	5.1	cubic meter	of	fuel.

Maximum Daily Emissions

– The	maximum	daily	emissions	for the	main	engines	are	based	on	t he	fuel

based	emission	factor	and	maximu m	fuel	requirement	of	123	cubic meter	of	fuel.

Annual Emissions –	The	annual	emissions for	the	main	engines are	based	on	the	fu el	based	emission factor	and	maximum	fuel	requirem ent	of	18,438	cubic	meter	of	fu el.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 24 Trinity Consultants 

### 3.3.2. Emergency Generator (DR-GE-01)

The	drillship	includes	one	2,547 HP	Cummins	QSK60 DMGE	diesel‐fi red	emergency	generator.		Air emissions	are	generate d	as	a	result	of	combustion	of	diesel	fue l	in	the	engine.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	the	engine	are

summarized	below.

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

AP

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

‐ fuel Engines –PM	VOC,

and	HAP	emissions	esti mates	for	the	emergen cy	generator	is	base d	on	AP‐42,	Section	3.4 emission	factors	(Table	3.4‐1, Table	3.4‐2,	and	Table	3.4‐3). Non‐methane	VOC emission	factor has	been	taken	as	91%	of	the	TOC	emission	factor.		All	of	the	p articulate	matter	is	assumed	to	be less	than	1	μm.		Theref ore,	it	is	assumed	PM 2.5 =	PM 10 =	PM.

Manufacturer Specification –	The	CO	emissions	fact ors	are	obtained	from	the	manufacturer’s specification	sheet.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐ 98‐006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillat e	oil‐fired	gas	turbines	was	used	as a	surrogate	for	distillate	oil‐fi red	engines	due	to	lack	of	emi ssion	factors.

EPA Regulations

– CO 2 ,	CH 4 ,	and	N 2 O	emission	factors	are	obtain ed	from	40	CFR	98	Subpart	C, Table	C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.

Mass Balance

– Anadarko	is	proposing	the	use	of ULSD	fuel	for	all	diesel	combu stion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel fuel	assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized to	SO 2 and	2	percent	of	sulfur	in	the

fuel	is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	Dr aft	Regulatory	Impact	Analysi s:	Control

of	Emissions	from	Nonroad	Die sel	Engines,	EPA420‐R‐03‐008,	Apri l	2003.		Emissions	of	H 2 S, TRS,	and	reduced	sulfur	compound s	resulting	from	sulfur	content in	the	fuel	are	negligible.

The	maximum	hourly,	daily,	and	annual	emissions	from	the	emerge ncy	generator	are	calculated	as

described	below:

Maximum Hourly Emissions

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

Maximum Daily Emissions

– The	maximum	daily	emissions	for the	emergency	gen erator	based	o n	2 hrs/day	operation.

Annual Emissions –	The	annual	emission s	for	the	emergency	generator	calculated	b ased	on	annual operation	of	100	hours

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

Since	this	emission	unit	will	be a	part	of	drillship‐wide	fuel consumption	limit,	no	separate	fuel	limit	is required	to	demonstrate	compliance .		Anadarko	will	maintain	ade quate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.3.3. Emergency Air Compressor (DR-AC-01)

The	drillship	consists	of	one	39 HP	HATZ	2M41	diesel‐fired	emer gency	air	compresso r,	which	is	EPA Tier	2	certified.		The	specificati on	sheet	is	provided	in	Appen dix	G‐1.		Emissions	a re	generated	as	a

result	of	combustion	of	die sel	fuel	in	th e	engine.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	each	of	the emergency	air	compressor	en gine	is	summarized	below.

40 CFR 89 Control Of Emissions From New And In

‐ Use Nonroad Compression

‐ Ignition Engines –Particulate	matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions estimates	for	the third	party	engines	are	based	on 40	CFR	89	Tier	2	exhaust	emiss ion	standards.		NO X emission
factors	are	assumed	to	b e	equal	to	the	NMHC	+	NO X emission	factor.		Based	on	footnote	b	of	AP‐ 42	Chapter	3,	Table	3.3‐1,	all	PM	i s	assumed	to	be	<	1	μm.		The refore,	it	is	assumed	PM 2.5 =	PM 10 =	PM.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –	VOC	and	HAP	Emissions	are

based	on	AP‐42	Section	3.3	emi ssion	factors	(Table	3.3‐2.)		An average	BSFC	of	7,000	Btu/HP‐hr has	been	used	to	convert	emission	factors	from	lb/MMBtu	to	lb/H P‐hr.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐ 98‐006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillat e	oil‐fired	gas	turbines	was	used	as a	surrogate	for	distillate	oil‐fi red	engines	due	to	lack	of	emi ssion	factors.

EPA Regulations

– CO 2 ,	CH 4 ,	and	N 2 O	emission	factors	are	obtain ed	from	40	CFR	98	Subpart	C, Table	C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.

Mass Balance

– Anadarko	is	proposing	the	use	of ULSD	fuel	for	all	diesel	combu stion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel fuel	assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized to	SO 2 and	2	percent	of	sulfur	in	the

fuel	is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of Draft	Regulatory	Impact	Analysi s:	Control

of	Emissions	from	Nonroad	Die sel	Engines,	EPA420‐R‐03‐008,	Apri l	2003.		Emissions	of	H 2 S, TRS,	and	reduced	sulfur	compound s	resulting	from	sulfur	content in	the	fuel	are	negligible.

The	maximum	hourly,	daily,	and	annual	emissions	from	the	emerge ncy	air	compressor	are	calculated	as

described	below:Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 26 Trinity Consultants Maximum Hourly Emissions

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

Maximum Daily Emissions

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

Annual Emissions –	The	annual	emissions for	the	air	compressor	calculated	based on	100 hours	of	operation

.

Proposed Operating Limits :

Since	this	emission	unit	will	be a	part	of	drillship‐wide	fuel consumption	limit,	no	separate	fuel	limit	is required	to	demonstrate	compliance .		Anadarko	will	maintain	ade quate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.3.4. Life Boat Engines (DR-LB-01 through DR-LB-06)

The	drillship	consists	of	six	SI YANG	485‐J	41	HP,	diesel‐fired life	boat	engines.		The	specification	sheet	is provided	in	Appendix	G‐1.		The	l ife	boats	will	be	operated	duri ng	emergency	situations,	drills	and periodically	operated	for	mainte nance	checks.		Emissions	are	ge nerated	as	a	result of	combustion	of

diesel	fuel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	the	engines	are

summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –	Particulate	matter	(PM,	PM 10 , and	PM 2.5 ),	NO X ,	VOC,	CO,	and	HAP	emissions	est imates	for	the	diesel‐fired	lif e	boat	engines	are based	on	AP‐42,	Section	3.3	emissi on	factors.		Based	on	AP‐42	g uidance,	all	of	the	particulate

matter	is	assumed	to	be	less	th an	1	μm.		Therefore,	it	is	assum ed	PM 2.5 =	PM 10 =	PM.			All	of	the

TOC	is	assumed	to	be	VOC.		TOC	emission	factor	has	been	calcula ted	as	the	sum	of	exhaust	and

crankcase	emission	fac tors.		An	average	BSFC	of	7,000	Btu/HP‐hr has	been	used	to	convert

emission	factors	from lb/MMBtu	to	lb/HP‐hr.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐ 98‐006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillat e	oil‐fired	gas	turbines	was	used	as a	surrogate	for	distillate	oil‐fi red	engines	due	to	lack	of	emi ssion	factors.

EPA Regulations

– CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	from	40	CFR	98	Subpart	C, Table	C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.

Mass Balance

– Anadarko	is	proposing	the	use	of ULSD	fuel	for	all	diesel	combu stion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel fuel	assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized to	SO 2 and	2	percent	of	sulfur	in	the fuel	is	oxidized	to	sulfuric	acid	(H 2 SO 4 )	mist	based	on	Section	4.1.1 of	Draft	Regulatory	ImpactAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 27 Trinity Consultants Analysis:	Control	of	Emissions	fr om	Nonroad	Diesel	Engines,	EPA 420‐R‐03‐008,	April	2003. Emissions	of	Hydrogen	sulfide	(H 2 S),	total	reduced	sulfur	(TRS), and	reduced	sulfur	compounds resulting	from	sulfur	content in	the	fuel	are	negligible.

The	maximum	hourly,	daily,	and	a nnual	emissions	from	the	life	b oat	engines	are	calc ulated	as	described

below:

Maximum Hourly Emissions

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

Maximum Daily Emissions

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

Annual Emissions –	The	annual	emissions	for	the	li fe	boats	are	calculated	based on	100	hours of	annual	operation	per	engine

.

Proposed Operating Limits :

Since	these	emission	units	will	be	a	part	of	drillship‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	annual	operation	limits.



### 3.3.5. Fast Rescue Craft (DR-FR-01)

The	drillship	consists	of	one	EP A	Marine	Tier	2 fast	rescue	cra ft	with	55	HP	power	rating	and	SABB‐L4 Turbo	engine.		The	specification sheet	for	the	representative	e ngine	is	provided	in	Appendix	G‐1. Emissions	are	generate d	as	a	result	of	combustion	of	diesel	fue l	used	in	the	engine.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 the	 engine	 are

summarized	below.

40 CFR 94 Control of Emissions From Marine Compression

‐ Ignition –Particulate	matter	(PM,

PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estimates	for the	fast	rescue	craft	are	base d	on	40	CFR	94

Marine	Tier	2	exhaust	em ission	standards.		NO X emission	factors	are	assumed	to	be	equal	to	the

NMHC	+	NO X emission	factor.		Based	on	footnote	b	of	AP‐42	Chapter	3,	Tabl e	3.3‐1,	all	PM	is assumed	to	be	<	1	μm.		T herefore,	it	is	assumed	PM 2.5 =	PM 10 =	PM

.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –	VOC	and	HAP	Emissions	are	based

on	AP‐42	Section	3.3	emission	fa ctors	(Table	3.3‐2.)		An	averag e	BSFC	of	7,000	Btu/HP‐hr	has	been used	to	convert	emission	factors	from	lb/MMBtu	to	lb/HP‐hr.

EPA Regulations

– CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 28 Trinity Consultants 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

Mass Balance –	Anadarko	proposed	the	use	of ULSD	fuel	for	all	diesel	combus tion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel and	assuming	that	98	percent	of	sulfur	in	the	fuel	will	be	conv erted	to	SO 2 and	2	percent	of	the

sulfur	in	the	fuel	wil l	be	converted	to	H 2 SO 4 based	on	U.S.	EPA	guidance	document.

The	maximum	hourly,	daily,	and	a nnual	emissions	from	the	main	e ngines	are	calculated	as	described

below:

Maximum Hourly Emissions

– The	maximum	hourly	emissions	fo r	the	fast	rescue	craft	are calculated	based	on	one	hour	operation.

Maximum Daily Emissions

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

Annual Emissions –	The	annual	emissions for	the	fast	rescue craft	are	calculated based	on	100 hours	per	year operation.

Proposed Operating Limits :

Since	this	emission	unit	will	be a	part	of	drillship‐wide	fuel consumption	limit,	no	separate	fuel	limit	is required	to	demonstrate	compliance .		Anadarko	will	maintain	ade quate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.3.6. Mud degassing Vent (DR-VG-01)

Drilling	mud	is	used	in	the	drilling	process	to	cool	and	lubric ate	the	drill	bit.		Whe n	the	drilling	mud returns	to	the	surface,	it	may	co ntain	entrained	hydrocarbons	f rom	the	well.		On	rea ching	the	surface, off‐gassing	occurs,	leading	to	VO C	emissions.		Al so	during	this process,	Anadarko	may	emit	trace

amounts	of	H 2 S	during	non‐routine	conditions that	could	be	encountered	while drilling.		At	this	juncture, Anadarko	cannot	reasonably	quantify	the	H 2 S	amount	emitted	or	a nticipate	how	much	H 2 S,	if	any,	will be	encountered	during	this	operati on	as	this	would	only	occur	d uring	non‐routine,	upset	conditions.		As such,	H 2 S	emitted	during	mud	degassing	o peration	would	be	considered	an upset	condition	which	is	not required	to	be	permitted	under	PS D	(40	CFR	52.21)	and	Title	V	( 40	CFR	71)	regulations.

Emissions Factors ‐	The	emission	factor	sources	used	in	the	development	of	emiss ions	estimates	for	the mud	degassing	operations are	summarized	below.

MMS Guidance Document –	Emission	factors	for	total	hydrocarbon	(THC)	emissions	durin g degassing	for	synthetic‐based	muds,	and	the	volume	percent	comp osition	of	the	THC	emissions were	obtained	based	on	a	study commissioned	by	the	formers	Mine ral	Management	Services (MMS)	that	is	currentl y	the	Bureau	of	Ocean Energy	Management	( BOEM).		Specifically,	theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 29 Trinity Consultants emission	factors	and	volume	%	sp eciation	were	obtained	from	Yea r	2005	Gulfwide	Emission Inventory	Study,	conducted	by	th e	Eastern	Research	Group,	Inc. 2



### Operating Parameters ‐ The	maximum	hourly,	daily	and average	annual	emissions	 from	the mud	degassing	operations	are	calc ulated	based	on	the	following operating	parameters.

Maximum Hourly/Daily Emissions –	Based	on	the	expected	thr oughputs	of	synthetic‐based muds	for	the	proposed	operations and	based	on	the	emission	fact ors	provided	in	the	guidance document	referenced	above,	a	wei ghted	average	THC	(lb/day)	emis sion	factor	has	been developed.		Also,	the	volume	%	co mposition	obtained	from	the	MM S	guidance	document	have been	converted	to	weight	%	based on	molecular	weights	of	the	co mponents.

As	shown	in	Appendix	B,	maximum hourly	speciated	emissions	are calculated	based	on	the weighted	average	THC	emission	fac tor	and	weight	%	of	the	specia ted	components,	using	24 hours	of	operation	per	day.		Maxim um	hourly	VOC	em issions	are	o btained	as	the	sum	of	all speciated	hourly	emissions	ex cept	methane	and	ethane.

Annual Emissions –	Annual	emissions	fo r	the	mud	degassing operation	have	been	e stimated similar	to	the	maximum	hourly	em issions.		Annual	emissions	are calculated	using	pound	per	day

emission	factors	and	a	worst‐c ase	4,800	hours	of	operation	per year.



### 3.3.7. Dust Collectors (DR-DC-01 through DR-DC-03)

Mud	and	cement	mixing	operation s	on	the	drillship	are	controlle d	by	three	National	O ilwell	Varco	dust collectors.		The	specifi cation	sheet	for	these	dust	collectors is	provided	in	Appendix	G‐1.

Emissions Factors ‐	The	emission	factor	sources	used	in	the	development	of	emiss ions	estimates	for	the

dust	collectors	are summarized	below.

AP

‐ 42, Section 11.12. Concrete Batching –	Particulate	matter	(PM,	PM 10 ,	and	PM 2.5 )	emissions estimates	for	the	cement	mixing operations	are	based	on	the	con trolled	emission	factor	provided	in	AP‐ 42,	Section	11.12	Concrete	Batchi ng	emission	factors	(Table	11. 12‐2).

Operating Parameters –	The	maximum	hourly,	daily	and annual	emissions	from	the	dust collectors	are

calculated	based	on	the	foll owing	operating	parameters.

Maximum Hourly Emissions –	Maximum	hourly	emi ssions	are	estimated	ba sed	on	150	tons/hr of maximum	process	rate.

Maximum Daily Emissions –	Maximum	daily	emissions	are	estimated	based	on	150	tons/hr	o f maximum	process	rate	and 24	hrs/day	operation.

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

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

### 3.3.8. Storage Vessels (DR-FT-01 through DR-FT-18)

The	drillship	includes	follo wing	fuel	storage	tanks:

Diesel	fuel	storage	vessels (16)	–	various	capacities Helicopter	fuel	storage	tan ks	(2)	–	2,900	gallons	each

Emissions	from	all	storage	vessels	on	the	Drillship	have	been	e stimated	using	EPA’s	TANKS	4.0.9d (TANKS)	program.		Default	TANKS	p roperties	for	distillate	fuel oil	No.	2	were	used	to model	the	contents of	the	diesel	tanks.		Default	spe ciation	profile	and	physical	a nd	chemical	properties for	Jet	Naphtha	(JP‐ 4)	in	TANKS	4.09d	program	are	used to	model	the	contents	of	the helicopter	fuel	storage	tanks.		Refer Appendix	G‐4	for	Tanks	program	output.

The	maximum	diesel	fue l	usage	for	the	Dri llship	is	123	cubic	me ters/day.		To	represent	conservative scenario,	a	throughput	equal	to twice	the	fuel	usage	restrictio n.		It	was	assumed	that	all	fuel	will	be loaded	into	the	largest	tank	DR‐DT‐04	to	calculate	the	maximum total	tank	VOC	emissions	(tpy)	on	the drillship.

Maximum	hourly	emissions	was	calculated	using	EPA	TANKS	4.09d	p rogram	for	the	month	of	June,	since June	results	in	the	high est	daily	emissions.



### 3.3.9. Drillship Fugitive Emissions (DR-FE-01)

The	fugitive	emissions	on	the	dri llship	occur	from	the	diesel	f uel	lines	and	associated	components.

Emissions	from	the	lines	are	bas ed	on	an	estimated	number	of	co mponents	and	heavy	oil	emission

factors	from	Table	2‐4	of	the	EP A	Protocol	for	E quipment	Leak	E mission	Estimates.		Since	the	exact

component	counts	were not	available,	compo nent	count	were	conse rvatively	estimated	using engineering	judgments	and	based	o n	the	component	counts	for	the other	drillship	cu rrently	leased	by

Anadarko.

Operating Parameters –	The	maximum	hourly,	daily	and	annual	fugitive	emissions	are calculated based	on	the	following	o perating	parameters.

Maximum Hourly Emissions –	Maximum	hourly	emissions	a re	estimated	based	on	one	hour operation.

Maximum Daily Emissions –	Maximum	daily	emissions	are	estimated	based	on	24	hrs/day operation.

Annual Emissions –	Maximum	annual	emissions	are estimated	based	on	4,800	hrs/ye ar	operation.



### 3.3.10. Painting Operations (DR-PO-01)

As	part	of	maintenance	activity, painting	happens	on	the	BlackH ornet	drillship.	PM/PM 10 /PM 2.5 ,	VOC,

and	HAP	emissions	are calculated	based	on	th e	average	thinner	u sage,	average	primer	usage,	30%	air assisted	spray	transfer	efficien cy	and	paint/primer	usage	of	ma ximum	40	gal/day	and	thinner	usage	ofAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 31 Trinity Consultants maximum	10	gal/day.		Total	emissi ons	are	estimated	based	on	the sum	of	worst‐case	primer	and thinner	components. Anadarko	proposes	to	maintain	the	flexibility	of	using	the	afor ementioned	air	assisted	or	an	airless spray	gun	with	a	50%	spray	trans fer	efficiency	(i.e.,	more	effi cient	in	transferring	the	material.) The	PTE	of	PM/PM 10 /PM 2.5 ,	VOC,	and	HAP	were	estimated	for air	assisted	spray	gun	operat ions	to represent	the	worst	case	scenario .		The	specification	sheet	for the	airless	and	air assisted	spray	guns along	with	the	MSDS sheets	for	the	paints ,	primers	and	thinners are	provided	in	Appendix	G‐6.		Refer	to Appendix	B	for	assumptions,	material	usage	limits,	and	detailed calculations.

Proposed Operating Limits :

Anadarko	proposes	annual	limit s	of	5,200	gallons	and	1,300	gall ons	for	paints	(i.e.,	any	combination	of paints,	base,	primer	etc.)	and	th inner,	respectively.		Anadarko will	maintain	adequat e	records	to	comply with	proposed	daily	and	a nnual	operation	limits.



### 3.3.11. Welding Operations (DR-WO-01)

Anadarko	proposes	to	carry	out	welding	operations	as	part	of	th e	maintenance	activities	on	the drillship.		The	proposed	welding activity	will	use	80	lbs	of	we lding	rods	per	day,	and	200	days	per	year.

Emissions Factors –	Anadarko	proposes	to	use	seve ral	different	types	of	welding rods.		The	welding rods	resulting	in	maximum	emissi ons	are	included in	the	emissio n	calculations	in	Appendix	B. Anadarko	proposes	to	maintain	a	flexibility	to	utilize	any	othe r	welding	rod	as	lon g	as	the	resulting emissions	are	less	than	the	p roposed	maximum	emissions.

AP

‐ 42, Section 12.19 Electric Arc Welding

– PM 10 and	HAPs	emissions	esti mates	for	the	proposed welding	activity	are	based	on	A P‐42,	Section	12.19	emission	fac tors	(Table	12.19‐1).		PM	and	PM 2.5 emissions	are	assume d	to	be	same	as	PM 10

.

Operating Parameters –	The	project	emissions	from	the	welding	operations	are	calcul ated	based	on	the following	operating	parameters.

Maximum Hourly Emissions

– Maximum	hourly	emissions	for the	welding	operations	are

calculated	based	on	3.33	lbs	of welding	rod	usage	per	hour.

Maximum Daily Emissions

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

Annual Emissions

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

Proposed Operating Limits :

Anadarko	proposes	annual	weldi ng	rod	usage	limit	of	16,000	lbs. Anadarko	will	maintain	adequate records	to	comply	with	proposed	d aily	and	annual	operation	limi ts.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 32 Trinity Consultants 

### 3.3.12. Third Party Engines (DR-TP-01 through DR-TP-21)

Various	 third	 party	 engines	 are required	 during	 the	 drilling	 an d	 well	 completion	 operations.	 	 These engines	 are	 EPA	 Tier	 2	 certified	 engines	 (except	DR‐TP‐12	 and	D R‐TP‐16)	and	 can	 be	grouped	in	 the following	categories: Third	Party	Engines	≤	860	H P	(DR‐TP‐01	and	DR‐TP‐02) Third	Party	Engines	≤	300	HP (DR‐TP‐03	through	DR‐TP‐11) Third	Party	Engines	≤	140	HP (DR‐TP‐12	through	DR‐TP‐16) Third	Party	Engines	≤	126	HP (DR‐TP‐17	through	DR‐TP‐21)

Note	that	the	third	party	engine s	shown	in	this application	are for	representation	purposes	only,	and Anadarko	may	replace	these	engin es	with	equivalent	engines	as	s pecified	in	Section 3.1	with	equal	or lesser	emissions.		The	specificat ion	sheets	for	the	equivalent engines	are	provided	in	Appendix	G‐2	and Appendix	G‐3.		Emissions	from	third	party	engines	will	be	a	res ult	of	combustion	of	diesel	fuel.

Emissions Factors –	The	sources	of	emission	factors	used	to	estimate	emissions	f or	each	of	these	engines

are	summarized	below.

40 CFR 89 Control Of Emissions From New And In

‐ Use Nonroad Compression

‐ Ignition Engines –	Except	for	engines	DR‐TP‐12	th rough	DR‐TP‐16,	Particulate	mat ter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X , and	CO	emissions	estima tes	for	the	third	pa rty	engines	are	base d	on	40	CFR	89	T ier	2	exhaust
emission	standards.		NO X emission	factors	are	assumed	to	be	equal	to	the	NMHC	+	NO X emission
factor.		Based	on	footnote	b	o f	AP‐42	Chapter	3,	Table	3.3‐1,	a ll	PM	is	assumed	to	be	<	1	μm. Therefore,	it	is	assumed	PM 2.5 =	PM 10 =	PM.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –	VOC	and	HAP	emissions	are	based
on	emission	factors	from	AP‐42 Chapter	3.3,	Table	3.3‐2:	Specia ted	Organic	Compound	Emission
Factors	for	Uncontrolled	Diesel Engines.		An	average	BFSC	of	7, 000	Btu/HP‐hr	was	used	to	convert from	lb/MMBtu	to	lb/HP‐hr	to	calc ulate	emissions. Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X , and	CO	emissions	estima tes	for	the	third	pa rty	engines	DR‐TP‐12 through	DR‐TP‐16	are	based	on AP‐42,	Chapter	3,	Tabl e	3.3.1,	Emission	Factors	for	Uncontrolle d	Gasoline	and	Die sel	Industrial Engines.

EPA Regulations

– CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

Mass Balance

– Anadarko	is	proposing	the	use	of ULSD	fuel	for	all	diesel	combu stion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is oxidized	to	sulfuric	acid	(H 2 SO 4 )	mist	based	on	Section	4.1.1	of Draft	Regulatory	Impact	Analys is:
Control	of	Emissions	from	Nonro ad	Diesel	Engines,	EPA420‐R‐03‐0 08,	April	2003.		Emissions	ofAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 33 Trinity Consultants Hydrogen	sulfide	(H 2 S),	total	reduced	sulfur	(TRS),	a nd	reduced	sulfur	compounds	re sulting	from

sulfur	content	in	the fuel	are	negligible.

The	maximum	hourly,	daily,	and	annual	emissions	from	the	third party	engines	are	calculated	based	on

the	derived	fuel	bas ed	emission	factor	as	described	below:

Maximum Hourly Emissions

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

Maximum Daily Emissions

– The	maximum	daily	emi ssions	are	calculated	based	on	24	hours/da y operation	per	engine.

Maximum Daily Emissions –	The	maximum	annual emissions	are	calculated	based	on	4,800 hours/year	operation	per	engine.

Proposed Operating Limits :

Since	this	emission	unit	will	be a	part	of	drillship‐wide	fuel consumption	limit,	no	separate	fuel	limit	is required	to	demonstrate	compliance .		Anadarko	will	maintain	ade quate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.3.13. Flowback Boiler (DR-TP-22)

A	"SIGMA	FIRED"	SF‐200SE,	8	MMBtu /hr	flowback	boiler	or	equival ent	will	be	used	for	certain	well completion	operations.		A	copy	of the	specification	sheet	is	pr ovided	in	Appendix	G‐9.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 this	 boiler	 are

summarized	below.

AP

‐ 42, Section 1.3 Fuel Oil Combustion ‐ The	sources	of	emission	f actors	used	to	estimate

emissions	for	this	b oiler	are	cited	from AP‐42,	Section	1.3.		F uel	Oil	Combustion	and	emission Factors	for	No.2	fuel	oil	was	used.	PM,	SO 2 ,	NO X ,	and	CO	emissions	are	ba sed	on	emission	factors from	AP‐42	Chapter	1.3,	Tables 1.3‐1	Criteria	Pollutant	Emissio ns	Factors	for	Fuel	Oil Combustion	and	1.3‐2,	Condensabl e	Particulate	Ma tter	Emission	F actors	for	Oil	Combustion. Total	particulate	emi ssions	are	the	sum	of	f ilterable	and	total condensable	particulate	emissions.

All	PM	is	assumed	to	be	<	1 um,	therefore,	i t	is	assumed	PM 2.5 =	PM 10 =	PM.		VOC	emission	factors

are	obtained	from	AP‐42	Sectio n	1.3,	Table	1.3‐3	Emission	Facto rs	for	Total	Organic	compounds

from	Uncontrolled	Fuel	Oil	Combu stion.	All	non‐methane	TOC	is	a ssumed	to	convert	to	VOC.		HAP

Emission	Factors	are	obtained	fro m	AP‐42	Section	1.3,	Table	1.3 ‐9	Emission	Factors	for	Speciated Organic	Compounds	from	Fuel	Oil Combustion,	and	Table	1.3‐10	Em ission	Factors	for	Trace

Elements	from	Dist illate	Fuel	oil	Combustion	Sources.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtain ed	from	40	CFR	98	Subpart	C, Table	C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 34 Trinity Consultants Operating Parameters –	The	maximum	hourly,	daily	and	annual	emissions	from	the	boil er	are	calculated based	on	the	following	operating	parameters.

Maximum Hourly Emissions –	Maximum	hourly	emi ssions	for	the boiler	are	calculated	based on related	emission	factors	and	8	MM Btu/hr	of	rated	heat	input.

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

Annual Emissions

– The	annual	emissions	from	the	boi ler	are	calculated	based	on	11 52 MMBtu/year.

Proposed Operating Limits :

Anadarko	proposes	annual	heat	in put	limit	of	1152	MMBtu.		Anada rko	will	maintain	adequate records	to	comply	with	proposed	d aily	and	annual	operation	limi ts.



### 3.3.14. Boom Flare (DR-TP-23)

A	gas	fired	Boom	Flare	capable	of processing	60	MMScf/day	could be	used	during	the	well	completion operation.			Since	the exact	equipment	spec ifications	are	not	k nown,	a	typical	VOC	red uction	efficiency	of 98%	is	assumed.		Emissions	are	generated	as	a	result	of	combust ion	process.

Emissions Factors –	The	sources	of	emission	factors	used	to	estimate	emissions	f or	the	representative

flare	are	summa rized	below.

AP

‐ 42, Section 13.5 Industrial Flares ‐ NO X ,	CO,	and	VOC	emission	factors	are	based	on	AP	42 Section	13.5,	Table	13.5‐1	Emission	Factors	for	Flare	Operation s.	Total	hydrocarbon	are

assumed	to	be	VOC.

AP

‐ 42, Section 1.4, Natural Gas Combustion ‐ SO 2 and	Particulate	Matter	(PM,	PM 10 ,	and

PM 2.5 )	emission	factors	are	obtaine d	from	AP‐42	Section	1.4,	Table	1 .4‐2 Emission Factors For

Criteria Pollutants And Greenhouse Gases From Natural Gas Combustion .		Total	particulate

emission	is	the	sum	of filterable	and	total condensable	particu late	emissions.		All	PM	is	assumed to	be	<	1	um,	therefo re,	it	is	assumed	PM 2.5 =	PM 10 =	PM.		Each	individual	HAP	emission	factor (except	total	POM	emission	facto r)	is	based	on	AP‐42	Section	1. 4,	Table	1.4‐4 Emission Factors for Metals from Natural Gas Combustion. Per	footnote b and c of	AP‐42	Section	1.4,	Table	1.4‐3

Emission Factors for Speciated Organic Compounds from Natural Gas Combustion ,	all	individual species	of	POM	have	been	conserv atively	added	and	represented	a s	HAP.		The	emission	factor

for	POM	is	calculated	as	the	sum	of	the	emission	factors	for	al l	the	individual	species	of	POM.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	from	40	CFR	98	Subpart	C, Table	C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 35 Trinity Consultants Operating Parameters –	The	maximum	hourly,	daily	and	annual	emissions	from	the	repr esentative	flare

are	calculated	based	on	the	fo llowing	operating	parameters.

Maximum Hourly Emissions –	Maximum	hourly	emissions	fo r	the	representa tive	flare	are calculated	based	on	a	proc ess	rate	of	2.5	MMscf/hr.

Maximum Daily Emissions –	Maximum	daily	emissions	for	this	representative	flare	are	ca lculated based	on	a	gas	process	rate	of	60	MMscf/day.

Annual Emissions

– The	annual	emissions	from	the	rep resentative	flare	are	calculat ed	based	on	a
gas	process	rate	o f	360	MMscf/year.

Proposed Operating Limit –Anadarko	proposes	to	demonstrat e	compliance	with	a	maximum	fir ing rate	of	60	MMScf/day or	360	MMScf/year. Anadarko	proposes	to	maintain the	flexibility	of	flaring	at a	higher	flow	rate	as	long	as	the y	stay	at	or	below	the	mass	em ission	limits	as	established	in Appendix	B.



### 3.3.15. Well Completion Condensate Tank s (DR-TP-24 through DR-TP-26)

There	are	three	condensate	tanks in	the	well	completion	operati on

Emissions	from	three	co ndensate	tanks	in	th e	well	completion	ha ve	been	estimated	using	EPA’s	TANKS 4.0.9d	(TANKS)	program.		Default	TAN KS	properties	for	Gasoline RVP	13	were	used	to	model	the

contents	of	the	condensate	tanks .	To	represent	conservative	sce nario,	a	throughput	equal	to	twice	the fuel	usage	was	used.	The	TANKS	o utput	files	are	presented	in	Ap pendix	B.

The	maximum	hourly	emi ssions	were	calculated using	EPA	TANKS	4. 09d	program	for	the	month	of	June, since	June	results	in the	highest	daily	em issions.		They	could be	used	during	every	c ompletion	so	I	don’t think	I’d	say	this.	I’ d	double	the	capacity	as	throughput	to	be safe.



### 3.4. SUPPORT VESSELS

As	discussed	under	Section	2	of the	application,	the	associated support	vessels	proposed	for	this	project will	include	a	combination	of	supply	boats	(work	boat	and	crew boat),	well	evaluati on	vessels,	well stimulation	vessels,	tug	boats	and	barges,	and	an	anchor	handli ng	boat.		These	vessels	will	be	used	for transport	of	fuel	and	equipment	as	well	as	performing	various	o perations.		Except	for	barges,	Anadarko is	proposing	fuel	consumption	limit	for	each	category	of	suppor t	vessel	as	described	below.

Emissions	from	support	vessels	w hile	the	support	vessels	are	at the	drillship,	and	w hile	enroute	to	or from	the	drillship	when	within	25	miles	of	the	drillship.		For purposes	of	the	air permit	application, representative	emissions	from	the support	vessels	potentially	a vailable	to	support	operations	of	the BlackHornet	drillship	have	been quantified.		Based	on	review	of all	available	supply	boats,	the	HOS	Coral supply	boat	was	found	to	be	the	w orst	case	supply	boat	for	emis sion	estimations.		If	anchor	handling boat	is	utilized	as	a	supply	boat	then	it	will	be	subject	to	sa me	short	term	and	long	term	emission	limits

established	for	the	HOS	Coral.		A nadarko	proposes to	maintain	t he	flexibility	of	utilizing	any	supply	boat as	long	as	it	meets	th e	criteria	of	equival ency	specified	in	Se ction	2.1.		While	complying	with	massAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 36 Trinity Consultants emissions	to	demonstra te	equivalency,	Anadarko	proposes	to	use equal	or	lower	emissi on	for	the	entire supply	boat	and	not	on	equipment	by	equipment	basis.



### Supply Boats (HOS Coral) Combustion Sources

3.4.1. Marine Propulsion Engines 1 and 2 (SB-ME-01 and SB-ME-02)

HOS	Coral	supply	boat	consists of	two	3,004	HP	(2,240kW)	Caterp illar	3516C	DITA	diesel‐fired	marine propulsion	engines.		Emissions	a re	generated	as	a	result	of	com bustion	of	diesel	fuel from	the	engines. The	specification	sheets	for	thes e	engines	are	provided	in	Appe ndix	G‐10.

Emissions Factors –	The	sources	of	emission	 factors	used	to	estimate	emissions	 f or	these	engines	are

summarized	below.

AP

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

‐ fuel Engines –	VOC	and

HAP	emissions	estimate s	for	the	engines	a re	based	on	AP‐42,	Sec tion	3.4	emission	factors.		Non

methane	VOC	emission	f actor	has	been	taken as	91%	of	TOC	emissi on	factor.		A	calculated	heat	rate of	19.16	MMBtu/hr	was	used	to	co nvert	from	lb/MMBtu	to	lb/hr	to calculate	emissions.

40 CFR 94 Control of Emissions From Marine Compression

‐ Ignition ‐	Particulate	matter	(PM,

PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estimates	for the	main	propuls ion	engines	ar e	based	on	40
CFR	94	Marine	Tier	2	exhaus t	emission	standards.	NO X emission	factors	are	assumed	to	be	equal	to
the	NMHC	+	NO X emission	factor.		Emission	factor	of	PM 2.5 and	PM 10 are	calculated	based	on	ratio	of PM/PM 2.5 and	PM/PM 10 which	are	obtained	from	AP‐42 Chapter	3,	Table	3.4‐2.	Total	pa rticulate
emission	factor	used	i n	the	ratio	has	been	t aken	as	the	sum	of filterable	and	conden sable	particulate

emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

Fuel Based Emission Factor Derivation :Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 37 Trinity Consultants Based	on	the	specifications	sheet s	for	each	engine,	the	BSFC	wa s	used	to	convert	the	above	mentioned emission	factors	to	lbs	of	pollutant/bbl	of	fuel	consumed	for	a ll	permanent	diesel	com bustion	sources	on the	supply	boat	as	show n	in	Appendix	B.		Hence,	Anadarko	is	pro posing	supply	boat ‐wide	fuel	limit, derived	using	the	fuel	based	emi ssion	factors,	to	establish	ope rating	limits	and	PTE	calculations	for supply	boats.

Proposed Operating Limits :

Anadarko	proposes	a	supply	boat ‐wide	fuel	limit	of	200	bbl/day and	40,000	bbl/year	based	on	the historical	fuel	consumption	recor ds	for	comparable	supply	boats .			Note	that	certain operating	situation require	more	than	one	s upply	boats	simultan eously	within	25	nau tical	miles	from	the	drillship.		In	that case,	the	proposed	fuel	limit	wi ll	serve	as	a	combined	fuel	lim it	for	all	supply	boats.			For	example,	if	two supply	boats	provide	support	to	t he	drillship	operations	during the	same	day	simultaneously	then	total fuel	consumption	on	both	the	su pply	boats	will	not	exceed	200	b bl/day	and	both	the	supply	boats	will meet	“equivalency”	crit eria	specified	above.

The	maximum	hourly,	daily,	and	a nnual	emissions	from	the	main	e ngines	are	calculated	based	on	the

derived	fuel	based	emission	f actor	as	described	below:

Maximum Hourly Emissions

– The	maximum	hourly	emissions	for the	main	engines	are	calculate d

based	on	the	fuel	based	emission factor	and	max imum	fuel	requir ement	of	8	bbl	of	fuel.

Maximum Daily Emissions

– The	maximum	daily	emissions	for the	main	engines	are	based	on	t he	fuel

based	emission	factor	and	maximu m	fuel	requiremen t	of	200	bbl/d ay	of	fuel.

Annual Emissions –	The	annual	emissions for	the	main	engines are	based	on	the	fu el	based	emission factor	and	maximum	fuel	requirem ent	of	40,000	bbl/year	of	fuel.



### 3.4.2. Marine Thruster Engines (SB-TE-01 through SB-TE-03)

HOS	Coral	supply	boat	include s	three	1,100	HP	(820 kW)	Caterpil lar	3508C	DITA	diesel‐fired	marine thruster	engines.		Emi ssions	are	generated as	a	result	of	combu stion	of	diesel	fuel from	the	engine.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 this	 engine	 are

summarized	below.

AP

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

‐ fuel Engines –	VOC	and

HAP	emissions	estimate s	for	the	engines	a re	based	on	AP‐42,	Sec tion	3.4	emission	factors.		Non

methane	VOC	emission	f actor	has	been	taken as	91%	of	TOC	emissi on	factor.		A	calculated	heat	rate of	7.01	MMBtu/hr	was	used	to	conv ert	from	lb/MMBtu	to	lb/hr	to calculate	emissions.

40 CFR 94 Control of Emissions From Marine Compression

‐ Ignition Engines ‐	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estimates	for thruster	engines are	based	on 40
CFR	94	Marine	Tier	2	exhaus t	emission	standards.		NO X emission	factors	are	assumed	to	be	equal	to
the	THC	+	NO X emission	factor.	Emission	factor	of	PM 2.5 and	PM 10 are	calculated	based	on	ratio	of PM/PM 2.5 and	PM/PM 10 which	are	obtained	from	AP‐ 42	Chapter	3,	Table	3.4‐2.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 38 Trinity Consultants EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

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

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.3. Electrical Generator Engine s (SB-GE-01 and SB-GE-02)

HOS	Coral	supply	boat	consists of	two	1,047	HP	(781	kW)	Caterpi llar	C32	DITA	diesel‐fired	electrical generator	engines.		Emissions	are generated	as	a	result	of	comb ustion	of	diesel	fuel.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 this	 engine	 are

summarized	below.

AP

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

‐ fuel Engines –	VOC	and

HAP	emissions	estimate s	for	the	engines	a re	based	on	AP‐42,	Sec tion	3.4	emission	factors.		Non

methane	VOC	emission	f actor	has	been	taken as	91%	of	TOC	emissi on	factor.		A	calculated	heat	rate of	6.56	MMBtu/hr	was	used	to	conv ert	from	lb/MMBtu	to	lb/hr	to calculate	emissions.

40 CFR 94 Control of Emissions From Marine Compression

‐ Ignition Engines ‐	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estimates	for electric	generator	engines	are
based	on	40	CFR	94	Marine	Tier	2 exhaust	emission	standards.		N O X emission	factors	are	assumed	to be	equal	to	the	THC	+	NO X emission	factor.		Emission	factor	of	PM 2.5 and	PM 10 are	calculated	based on	ratio	of	PM/PM 2.5 and	PM/PM 10 which	are	obtained	from	AP‐ 42	Chapter	3,	Table	3.4‐2.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 39 Trinity Consultants 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

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

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	annual	operation	limits.



### 3.4.4. Emergency Electrical Generator Engine (SB-GE-03)

HOS	Coral	supply	boat	consists	of	one	253	HP	(189	kW)	Caterpill ar	C9	DITA	diesel‐fired,	emergency electrical	generator	engine.		Emi ssions	from	the	emergency	gene rator	engine	will	be	a	result	of

combustion	of	diesel	fuel.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 the	 engine	 are

summarized	below.

40 CFR 94 Control Of Emissions From Marine Compression

‐ Ignition Engines ‐	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estimates	fo r	the	two	representative	Main Engines	(SV‐ME‐01	and	SV‐ME‐02)		a re	based	on	40	CFR	94	Marine Tier	2	exhaus t	emission
standards.	NO X emission	factors	are	assumed	to	be	equal	to	the	NMHC	+	NO X emission	factor.		PM 10 and	PM 2.5 emission	factors	are	obtained	by	applying	the	ratio	of	PM/PM 10 and	PM/PM 2.5 from	AP‐42 Chapter	3,	Table	3.4‐1 and	Table	3.4‐2	on	EPA Tier	2	PM	emissio n	factor.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –	VOC	and	HAP	Emissions	are	based

on	AP‐42	Section	3.3	emission	fa ctors	(Table	3.3‐2.)		An	averag e	BSFC	of	7,000	Btu/HP‐hr	has	been used	to	convert	emission	factors	from	lb/MMBtu	to	lb/HP‐hr.

EPA Regulations

– CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 40 Trinity Consultants (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

Mass Balance –	Anadarko	proposed	the	use	of ULSD	fuel	for	all	diesel	combus tion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel and	assuming	that	98	percent	of	sulfur	in	the	fuel	will	be	conv erted	to	SO 2 and	2	percent	of	the

sulfur	in	the	fuel	wil l	be	converted	to	H 2 SO 4 based	on	U.S.	EPA	guidance	document.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	1	hour,	and	100 hours	of	operation	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	annual	operation	limits.



### 3.4.5. ROV Electrical Generator Engine (SB-GE-04)

HOS	Coral	supply	boat	includes one	475	HP	(354	kW)	diesel‐fired ,	ROV	electrical	g enerator	engine.
Emissions	from	the	ROV electric	generator	engine	will	be	a	resu lt	of	combustion	of	diesel	fuel	in	the engine.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 this	 engine	 are

summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –VOC	and	HAP	emi ssions	estimates for	the	ROV	electric	generator	e ngine	are	based	on	AP‐42,	Secti on	3.3	emission	factors.		An	average BFSC	of	7,000	Btu/HP‐hr	was	used to	convert	from	lb/MMBtu	to	lb /HP‐hr	to	calculate	emissions.

40 CFR 89 Control Of Emissions From New And In

‐ Use Nonroad Compression

‐ Ignition Engines ‐	Particulate	matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estima tes	for	the	electric generator	engine	are	based	on	4 0	CFR	89	Tier	2	ex haust	emission standards.	NO X emission	factors are	assumed	to	be	equal	to	the	NMHC	+	NO X emission	factor.		Based	on	footnote	b	of	AP‐42	Chapter 3,	Table	3.3‐1,	all	P M	is	assumed	to	be	< 1	μm.		Therefore,	it is	assumed	PM 2.5 =	PM 10 =	PM.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 41 Trinity Consultants EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	annual	operation	limits.



### 3.4.6. Well Evaluation Third Party En gine (SB-TP-01 and SB-TP-02)

Two	temporary	third	pa rty	Well	Evaluation	Electrical	Generator Engines,	Caterpillar	3406C	or equivalent	‐	360	HP,	could	be	bro ught	on	the	support	vessels	fo r	well	evaluation	activities.		These engines	will	be	temporarily	brou ght	onboard	and	operated	on	the supply	boat	as	req uired.		Emissions from	the	electric	generator	engi nes	will	be	a	result	of	combust ion	of	diesel	fuel.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 this	 engine	 are

summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	fo r	the	electric	genera tor	engines	are	base d	on	AP‐42,	Section	3.3	emission factors.		An	average	BFSC	of	7,000 Btu/HP‐hr	was	used	to	conver t	from	lb/MMBtu	to	lb/HP‐hr	to
calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 42 Trinity Consultants Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	annual	operation	limits.



### 3.4.7. Well Evaluation Third Party Cran e Motor Engine #1 (SB-TP-03)

One	Well	Evaluation	Crane	motor Engine	#1,	John	Deere	PE	4045D or	equivalent	‐	62	HP,	could	be brought	on	the	support	vessels	f or	well	evaluation	activities. Emissions	from	the	cra ne	motor	engine	#1

will	be	a	result	of	combu stion	of	diesel	fuel.

Emissions Factors –	 The	 sources	 of	 emission	 factors	 used	 to	 estimate	 emissions	 f or	 this	 engine	 are

summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	fo r	the	Crane	motor	en gine	are	based	on	AP‐ 42,	Section	3.3	emission	factors. An	average	BFSC	of	7,000	Btu/HP‐hr was	used	to	convert	from	lb/ MMBtu	to	lb/HP‐hr	to	calculate

emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 43 Trinity Consultants The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.8. Well Evaluation Third Party Cran e Motor Engine #2 (SB-TP-04)

One	Well	Evaluation	Crane	motor Engine	#2,	Cummins	B	5.9‐C	or	e quivalent	‐	130	HP,	could	be	brought on	the	support	vessels	for	well evaluation	activities.		Emissio ns	from	the	crane	moto r	engine	#2	will	be	a

result	of	combustion	of	diesel	fuel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	this	engine	are

summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	fo r	the	crane	motor	engi ne	#2	are	based	on AP‐42,	Section	3.3	emission	factors. An	average	BFSC	of	7,000	Btu/HP‐hr was	used	to	convert	from	lb/ MMBtu	to	lb/HP‐hr	to	calculate

emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation,	respectively.

Proposed Operating Limits :Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 44 Trinity Consultants Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.9. Third Party Well Evaluation Engi nes (SB-TP-05 through SB-TP-09)

Five	well	evaluation	third	par ty	engines	are	required	for	well evaluation	activities.

Note	that	the	third	party	engine s	shown	in	this application	are for	representation	purposes	only,	and Anadarko	may	replace	these	engin es	with	equivalent	engines	as	s pecified	in	Section 3.1	with	equal	or lesser	emissions.		The	specificat ion	sheets	for	the	equivalent engines	are	provided	in	Appendix	G‐10. Emissions	from	third	party	engin es	will	be	a	result	of	combusti on	of	diesel	fuel.

Emissions Factors –	The	sources	of	emission	factors	used	to	estimate	emissions	f or	each	of	these	engines

are	summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –	VOC	and	HAP	emissions	are	based
on	emission	factors	from	AP‐42 Chapter	3.3,	Table	3.3‐2:	Specia ted	Organic	Compound	Emission
Factors	for	Uncontrolled	Diesel Engines.		An	average	BFSC	of	7, 000	Btu/HP‐hr	was	used	to	convert from	lb/MMBtu	to	lb/HP‐hr	to	calc ulate	emissions. Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X , and	CO	emissions	are	based	on AP‐42,	Chapter	3,	Table	3.3.1,	Em ission	Factors	for	Uncontrolled
Gasoline	and	Diesel	Industrial Engines.	.		Based	on	footnote	b of	AP‐42	Chapter	3,	Table	3.3‐1,	all	PM is	assumed	to	be	<	1	μm.		T herefore,	it	is	assumed	PM 2.5 =	PM 10 =	PM.

EPA Regulations

– CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1	(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

Mass Balance

– Anadarko	is	proposing	the	use	of ULSD	fuel	for	all	diesel	combu stion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is oxidized	to	sulfuric	acid	(H 2 SO 4 )	mist	based	on	Section	4.1.1	of Draft	Regulatory	Impact	Analys is:
Control	of	Emissions	from	Nonro ad	Diesel	Engines,	EPA420‐R‐03‐0 08,	April	2003.		Emissions	of Hydrogen	sulfide	(H 2 S),	total	reduced	sulfur	(TRS),	a nd	reduced	sulfur	compounds	re sulting	from

sulfur	content	in	the fuel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation,	respectively.

Proposed Operating Limits :Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 45 Trinity Consultants Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



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

The	Kirt	Chouest	is	the	worst	ca se	anchor	handling	boat	which	w ill	be	used	as	a	supply	boat	when required	to	perform	specific	op erations.		The	fuel	consumption and	emissions	from	t his	boat	will	be counted	against	the	su pply	boat	fuel	limits.		The	emission	esti mation	procedures	for	several	diesel engines	on	the	anchor	handling boat	are	described	below.



### 3.4.10. Marine Propulsion Engines (AB-ME-01 and AB-ME-02)

The	Kirt	Chouest	includes	two 7,570	HP	(5,650	kW)	Caterpillar	3 616	diesel‐fired	marine	propulsion engines.	Emissions	are	generated	as	a	result	of	combustion	of	d iesel	fuel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	these	engines	are

summarized	below.

AP

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

‐ fuel Engines –Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC,	and	HAP	emissions	esti mates	for	the	en gines	are	base d on	AP‐42,	Section	3.4	emission	fa ctors.	Non	methane	VOC	emissio n	factor	has	been	taken	as	91%	of TOC	emission	factor.	Total	particulate	emissions	have	been	take n	as	the	sum	of	filterable	and condensable	particulate	emission s.	An	average	BSFC	of	7,000	Btu /HP‐hr	has	been	used	to	convert
emission	factors	from lb/MMBtu	to	lb/HP‐hr.

EPA Guidance Documents

– Lead	emission	factor	has	been	obtained	from	EPA	guidance	docume nt: Locating and Estimating Air Emissions from Sources of Lead and Lead Compounds ,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.	Emissi on	factor	for	distillate	oi l‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil	fired engines	due	to	lack	of	emiss ion	factors.

Mass Balance –	Anadarko	is	proposing	the	use of	ULSD	fuel	for	all	diesel	com bustion	sources. Therefore,	SO 2 emissions	have	been	calculated	based	on	a	maximum	sulfur	conte nt	of	15	ppm	in diesel	fuel	assuming	t hat	98	percent	of	sul fur	in	the	fuel	is	o xidized	to	SO 2 and	2	percent	of	sulfur	in
the	fuel	is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of Draft Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines ,	EPA420‐R‐03‐008,	April	2003.	Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation	respectively.

Proposed Operating Limits :Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 46 Trinity Consultants Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.11. Thruster Engines (AB-TE-01 through AB-TE-03)

The	Kirt	Chouest	includes	th ree	1,674	HP	(1,249	kW)	Caterpillar 3512B‐HD	diesel‐fired	thruster engines.	Emissions	are	generated	as	a	result	of	combustion	of	d iesel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	these	engines	are

summarized	below.

AP

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

‐ fuel Engines –Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC,	and	HAP	emissions	esti mates	for	the	en gines	are	base d on	AP‐42,	Section	3.4	emission	fa ctors.	Non	methane	VOC	emissio n	factor	has	been	taken	as	91%	of TOC	emission	factor.	Total	particulate	emissions	have	been	take n	as	the	sum	of	filterable	and condensable	particulate	emission s.	An	average	BSFC	of	7,000	Btu /HP‐hr	has	been	used	to	convert
emission	factors	from lb/MMBtu	to	lb/HP‐hr.

EPA Guidance Documents

– Lead	emission	factor	has	been	obtained	from	EPA	guidance	docume nt: Locating and Estimating Air Emissions from Sources of Lead and Lead Compounds ,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.	Emissi on	factor	for	distillate	oi l‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil	fired engines	due	to	lack	of	emiss ion	factors.

Mass Balance –	Anadarko	is	proposing	the	use of	ULSD	fuel	for	all	diesel	com bustion	sources. Therefore,	SO 2 emissions	have	been	calculated	based	on	a	maximum	sulfur	conte nt	of	15	ppm	in diesel	fuel	assuming	t hat	98	percent	of	sul fur	in	the	fuel	is	o xidized	to	SO 2 and	2	percent	of	sulfur	in
the	fuel	is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of Draft Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines ,	EPA420‐R‐03‐008,	April	2003.	Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 47 Trinity Consultants 

### 3.4.12. Service Generator Engines (A B-GE-01 through AB-GE-05)

The	Kirt	Chouest	inc ludes	of	three	716	HP	( 534	kW)	Caterpillar 3412C	diesel‐fired	service	generator engines	and	two	1,300	HP	(968	kW )	Caterpillar	3508B	crane	dedic ated	diesel‐fired	service	generator engines.	Emissions	are	generated	as	a	result	of	combustion	of	d iesel	fuel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	these	engines	are

summarized	below.

AP

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

‐ fuel Engines –Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC,	and	HAP	emissions	esti mates	for	the	ge nerator	engine s are	based	on	AP‐42,	Section	3.4	e mission	factors.	Non	methane	V OC	emission	factor	has	been	taken as	91%	of	TOC	emission	factor.	Total	particulate	emissions	have been	taken	as	the sum	of	filterable and	condensable	particulate	em issions.	An	average	BSFC	of	7,000 Btu/HP‐hr	has	been	used	to convert	emission	factors	from	lb/MMBtu	to	lb/HP‐hr.

EPA Guidance Documents

– Lead	emission	factor	has	been	obtained	from	EPA	guidance	docume nt: Locating and Estimating Air Emissions from Sources of Lead and Lead Compounds ,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.	Emissi on	factor	for	distillate	oi l‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil	fired engines	due	to	lack	of	emiss ion	factors.

Mass Balance –	Anadarko	is	proposing	the	use of	ULSD	fuel	for	all	diesel	com bustion	sources. Therefore,	SO 2 emissions	have	been	calculated	based	on	a	maximum	sulfur	conte nt	of	15	ppm	in diesel	fuel	assuming	t hat	98	percent	of	sul fur	in	the	fuel	is	o xidized	to	SO 2 and	2	percent	of	sulfur	in
the	fuel	is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of Draft Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines ,	EPA420‐R‐03‐008,	April	2003.	Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel limit	is	required	to	demonstrate compliance.		Anadarko	will	mai ntain	adequate	records	to	comply with	proposed	daily	and annual	operation	limits.



### 3.4.13. Emergency Generator Engine (AB-GE-06)

The	Kirt	Chouest	includes	on e	307	HP	(229	kW)	Caterpillar	3406C diesel‐fired,	emergency	generator engine.	The	emergency	generator	en gine	will	be	operated	during emergencies,	and	periodically operated	for	maintenance	checks. Emissions	from	the	emergency	g enerator	engine	wil l	be	a	result	of
combustion	of	diesel	fuel.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 48 Trinity Consultants Emissions Factors

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

AP

‐ 42, Section 3.3

. Gasoline and Diesel Industrial Engines –	Particulate	(PM,	PM10,	PM2.5), VOC,	CO,	NO X ,	and	HAP	emissions	es timates	for	the	emerg ency	generator	engin e	are	based	on AP‐42,	Section	3.3	emission	factors.		Based	on	AP‐42	guidance, all	of	the	particulate	matter	is assumed	to	be	less	than	1	μm.		All	of	the	TOC	is	assumed	to	be VOC.		TOC	emission	factor	has
been	calculated	as	the	sum	of	ex haust	and	crankcase	emission	fa ctors.

EPA Guidance Documents

– Lead	emission	factor	has	been	obtained	from	EPA	guidance
document: Locating and Estimating Air Emissions from Sources of Lead and Lead Compounds ,	EPA 454/R‐98‐006,	May	1998,	Section 5.2.2.	Emission	factor	for	dist illate	oil‐fired	gas	turbines	was used	as	a	surrogate	for	distillate oil	fired	engines	due	to	lac k	of	emission	factors.

Mass Balance –	Anadarko	is	proposing	the	use of	ULSD	fuel	for	all	diesel	com bustion	sources. Therefore,	SO 2 emissions	have	been	calculated	based	on	a	maximum	sulfur	conte nt	of	15	ppm	in diesel	fuel	assuming	t hat	98	percent	of	sul fur	in	the	fuel	is	o xidized	to	SO 2 and	2	percent	of
sulfur	in	the	fuel is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of Draft Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines ,	EPA420‐R‐03‐008,	April	2003.
Emissions	of	H 2 S,	TRS,	and	reduced	sulfur	compou nds	resulting	from	sulfur	cont ent	in	the	fuel are	negligible.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	from	40	CFR	98	Subpart	C, Table	C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	one	hour,	and 100	hours	of	operation	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.14. Winch Hydraulic Engines (AB-GE-07 and AB-GE-08)

The	Kirt	Chouest includes	two	1,300	HP	(969	kW)	Ca terpillar	C32	diesel‐fired	hyd raulic	engines. Emissions	are	generate d	as	a	result	of	combustion	of	diesel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	these	engines	are

summarized	below.

AP

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

‐ fuel Engines

– Particulate	matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC,	and	HAP	emissi ons	estimates	for	the engines	are	based	on	AP‐42,	Sect ion	3.4	emission	factors.	Non	m ethane	VOC	emission	factor	has been	taken	as	91%	of	TOC	emission	factor.	Total	particulate	emi ssions	have	been	taken	as	the
sum	of	filterable	and condensable	particulat e	emissions.	An	ave rage	BSFC	of	7,000	Btu/HP‐hrAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 49 Trinity Consultants has	been	used	to	convert	emission	factors	from	lb/MMBtu	to	lb/H P‐hr.

EPA Guidance Documents

– Lead	emission	factor	has	been	obtained	from	EPA	guidance
document: Locating and Estimating Air Emissions from Sources of Lead and Lead Compounds ,	EPA 454/R‐98‐006,	May	1998,	Section 5.2.2.	Emission	factor	for	dist illate	oil‐fired	gas	turbines	was used	as	a	surrogate	for	distillate oil	fired	engines	due	to	lac k	of	emission	factors.

Mass Balance –	Anadarko	is	proposing	the	use of	ULSD	fuel	for	all	diesel	com bustion	sources. Therefore,	SO 2 emissions	have	been	calculated	based	on	a	maximum	sulfur	conte nt	of	15	ppm	in diesel	fuel	assuming	t hat	98	percent	of	sul fur	in	the	fuel	is	o xidized	to	SO 2 and	2	percent	of
sulfur	in	the	fuel is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of Draft Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines ,	EPA420‐R‐03‐008,	April	2003.
Emissions	of	H 2 S,	TRS,	and	reduced	sulfur	compou nds	resulting	from	sulfur	cont ent	in	the	fuel are	negligible.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	from	40	CFR	98	Subpart	C, Table	C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.

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

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	supply	boat‐wide	fue l	consumption	limit,	no	separate	fuel	limit is	required	to	demonstrate	compli ance.		Anadarko	will	maintain adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.15. Supply Boat Storage Tanks

The	supply	boat	(HOS	Coral)	inclu des	15	diesel	fuel	storage	ves sels	and	the	anchor handling	boat	(Kirt Chouest)	includes	19	diesel	fuel storage	vessels.		Emissions	fr om	all	storage	vessels	on	the	support vessels	have	been	estimated	using EPA’s	TANKS	4.0.9d	program. Default	TANKS	properties	for	distillate

fuel	oil	No.	2	were	used	to	model the	contents	of	the	diesel	ta nks.		The	tank	emissions	calculations (including	the	EPA	TANKS	4.09d	r uns)	are	included	in	Appendix	G ‐7	of	this	application.



### Tug Boat Combustion Sources

3.4.16. Tug Boat Main Engines (TB-ME-01 to TB-ME-03) and Generator Engines (TBGE-01 to TB-GE-02)

The	Tug	Boat	includes	Main	Engin es	(TB‐ME‐01	through	TB‐ME‐03) and	Generator	Engines	(TB‐GE‐01 and	TB‐GE‐02)	or	equivalent	engi nes	for	this	operation.		The	Ma in	Engines	and	Generator	Engines	as presented	in	this	application have	2,200	HP	(1,641	KW)	rating	a nd	174	HP	(130	KW)	rating, respectively.		Emissions	are	gene rated	as	a	result	of	combustio n	of	diesel	fuel.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 50 Trinity Consultants Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f rom	Main	Engines (TB‐ME‐01	through	TB‐ME‐03)	and Generators	(TB‐GE‐01	and	TB‐GE‐ 02)	are	summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –	Particulate	matter	(PM,	PM 10 ,	and

PM 2.5 ),	NO X ,	CO,	VOC	and	HAPs	estimates	for the	representative	Generators (TB‐GE‐01	and	TB‐GE‐ 02)	are	based	on	AP‐42,	Section	3.3	emission	factors.		Based	on AP‐42	guidance,	all	of	the	particulate matter	is	assumed	to	be	less	than	1	μm.		All	of	the	TOC	is	assu med	to	be	VOC.		TOC	emission	factor

has	been	calculated	as	the	sum	o f	exhaust	and	crankcase	emissio n	factors.	An	average	BSFC	of	7,000 Btu/HP‐hr	was	used	to	convert	fro m	lb/MMBtu	to	lb/HP‐hr	to	calc ulate	emissions.

AP

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

‐ fuel Engines –	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	CO,	VOC	and	HAPs		emissions	es timates	for	the	representative Main Engines	(TB‐ME‐01	through	TB‐ME‐ 03)	are	based	on	AP‐42,	Section 3.4	emission	factors	(Table	3.4‐ 1,		Table	3.4‐2	and	table	3.4‐3) .		Non	methane	VOC	emission	fac tor	has	been	tak en	as	91%	of	the total	organic	compounds	(TOC)	em ission	factor.	Emission	factor of	PM 2.5 and	PM 10 are	calculated based	on	ratio	of	PM/PM 2.5 and	PM/PM 10 which	are	obtained	from	AP ‐42	Chapter	3,	Table	3.4‐2. Total	particulate	emission	facto r	used	in	the	ratio	has	been	ta ken	as	the	sum	of	filterable	and condensable	particulate	emissi ons.	PM	<	3um	are	taken	as	PM 2.5 .	An	average	brake‐specific	fuel consumption	(BSFC)	of	7,000	Btu/ HP‐hr	was	used	to	convert	from lb/MMBtu	to	lb/HP‐hr.

IMO Tier 2 –	NO X emissions	estimates	fo r	the	representative	Main	Engines	(TB‐ME ‐01	through	TB‐ ME‐03)	are	based	on	IMO Tier	2	emission	fac tors	for	an	engine	s peed	of	1,800	rpm.

EPA Guidance Documents –	Lead	emission	factor	for	Main	Engines	(TB‐ME‐01	through	TB‐M E‐03) and	Generators	(TB‐GE‐01	and	TB‐GE‐02)	is	obtained	from	EPA	gui dance	document:	Locating	and Estimating	Air	Emissions	from	Sources	of	Lead	and	Lead	Compound s,	EPA	454/R‐98‐006,	May	1998,

Section	5.2.2.		Emission	factor	fo r	distillate	oil‐fired	gas	tu rbines	was	used	as	a	surrogate	for distillate	oil‐fired	engines	due	to	lack	of	emission	factors.

EPA Regulations

– CO 2 ,	CH 4 and	N 2 O	emission	factors	for	Main	Engines	(TB‐ME‐01	through	TB‐ME‐ 03)	and	Generators	(TB‐GE‐01	and	TB‐GE‐02)	are	obtained	from	40 CFR	98	Subpart	C,	Table	C‐ 1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is oxidized	to	sulfuric	acid	(H 2 SO 4 )	mist	based	on	Section	4.1.1	of Draft	Regulatory	Impact	Analys is:
Control	of	Emissions	from	Nonro ad	Diesel	Engines,	EPA420‐R‐03‐0 08,	April	2003.		Emissions	of Hydrogen	sulfide	(H 2 S),	total	reduced	sulfur	(TRS),	a nd	reduced	sulfur	compounds	re sulting	from

sulfur	content	in	the fuel	are	negligible.

Fuel Based Emission Factor Derivation :

Based	on	the	specifications	sheet s	for	each	engine,	the	BSFC	wa s	used	to	convert	the	above	mentioned emission	factors	to	lbs	of	pollutant/bbl	of	fuel	consumed	as	sh own	in	the	Appendix	B.		Hence,	AnadarkoAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 51 Trinity Consultants is	proposing	tug	boat‐wide	fuel	limit,	based	on	the	fuel	based emission	factors,	to	e stablish	operating limits	and	PTE	calculations	for	tug	boats.

Proposed Operating Limits :

Anadarko	proposes	a	tug	boat‐wide	fuel	cap	of	125	bbl/day	and	2 5,000	bbl/year	based	on	the	historical fuel	consumption	records	f or	comparable	tug	boats.

The	maximum	hourly,	daily,	and	a nnual	emissions	from	the	main	e ngines	are	calculated	based	on	the

derived	fuel	based	emission	f actor	as	described	below:

Maximum Hourly Emissions

– The	maximum	hourly	emissions	for the	main	engines	are	calculate d

based	on	the	fuel	based	emission factor	and	max imum	fuel	requir ement	of	5.1 bbl	of	fuel.

Maximum Daily Emissions

– The	maximum	daily	emissions	for the	main	engines	are	based	on	t he	fuel

based	emission	factor	and	maximu m	fuel	requiremen t	of	125	bbl/d ay	of	fuel.

Annual Emissions –	The	annual	emissions for	the	main	engines are	based	on	the	fu el	based	emission factor	and	maximum	fuel	requirem ent	of	25,000	bbl/year	of	fuel.



### Barge Combustion Sources

3.4.17. Barge Electrical Generators (BG-LP-01thru BG-LP-03)

The	Barge	electrical	generator	e ngines	represented	in	this	appl ication	include	three	456	HP	electrical generator	engines.		Emissions	are generated	as	a	result	of	comb ustion	of	diesel	fuel	in	the	engines.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	representative engines	are	summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	fo r	the	electrical	gen erator	engines	are	ba sed	on	AP‐42,	Section	3.3	emission factors.		An	average	BFSC	of	7,000 Btu/HP‐hr	was	used	to	conver t	from	lb/MMBtu	to	lb/HP‐hr	to
calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuelAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 52 Trinity Consultants assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

Proposed Operating Limits :

The	maximum	hourly,	daily,	and	a nnual	emissions	from	the	barge electrical	generator	engines	are

calculated	based	on	the	hours	of operation	as	described	below:

Maximum Hourly Emissions

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

Maximum Daily Emissions

– The	maximum	daily	emissions	for the	barge	electr ical	generator engines	operations	are	calculated based	on	24	hours	operation	p er	engine.

Annual Emissions

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



### Stimulation Vessel Combustion Sources

The	representative	Stimulation	V essel	Engines	inc ludes	Main	Pro pulsion	Engines	(SV‐ME‐01	and	SV‐ME‐ 02),	representative	Thrusters	(SV ‐BT‐01	through	SV‐ST‐01),	repr esentative	Drop‐down	Engines	(SV‐ DD‐01)	representative	Pump	Engin es	(SV‐PE‐01	through	SV‐PE‐08), and	representative	Generator Engines	(SV‐GE‐01	through	SV‐GE‐ 04)	as	presented	in	this	applic ation.		Emissions	are	generated	as	a

result	of	combustion	of	diesel	fuel.



### 3.4.18. Stimulation Vessel Main Engines (SV-ME-01 and SV-ME-02)

The	Stimulation	Vessel	includes two	3,634	HP	(2,710	kW)	Caterpi llar	C280‐8	main	eng ines.		Emissions are	generated	as	a	result	of	com bustion	of	diesel	fuel	in	the	e ngines.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	representative stimulation	vessel	main	eng ines	are	summarized	below.

40 CFR 94 Control Of Emissions From Marine Compression

‐ Ignition Engines ‐	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estimates	fo r	the	two	representative	Main Engines	(SV‐ME‐01	and	SV‐ME‐02)		a re	based	on	40	CFR	94	Marine Tier	2	exhaus t	emission
standards.	NO X emission	factors	are	assumed	to	be	equal	to	the	NMHC	+	NO X emission	factor.		PM 10 and	PM 2.5 emission	factors	are	obtained	by	applying	the	ratio	of	PM/PM 10 and	PM/PM 2.5 from	AP‐42 Chapter	3,	Table	3.4‐1 and	Table	3.4‐2	on	EPA Tier	2	PM	emissio n	factor.

AP

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

‐ fuel Engines –	VOC	and

HAP	emissions	estimate s	for	the	two	main	e ngines	are	based	on	A P‐42,	Section	3.4	Table	3.4‐1	and

Table	3.4‐3.		All	of	the	TOC	is	a ssumed	to	be	VOC.		TOC	emissio n	factor	has	been	calculated	as	the

sum	of	exhaust	and	crankcase	emission	factors.	Per	footnote	f	o f	AP‐42	Chapter	3,	Table	3.4‐1,	non‐Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 53 Trinity Consultants methane	VOC	emission	f actor	has	been	taken as	91%	of	TOC	emissi on	factor.		An	average	BSFC	of 7,000	Btu/HP‐hr	was	used	to	convert from	lb/MMBtu	to	lb/HP‐hr	t o	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

Fuel Based Emission Factor Derivation :

Based	on	the	specifications	sheet s	for	each	engine,	the	BSFC	wa s	used	to	convert	the	above	mentioned emission	factors	to	lbs	of	pollutant/bbl	of	fuel	consumed	as	sh own	in	the	Appendix	B.		Hence,	Anadarko is	proposing	stimulation	vessel‐wide	fuel	limit,	based	on	the	f uel	based	emission	fac tors,	to	establish operating	limits	and	PTE	calculations	for	stimulation	vessel.

Proposed Operating Limits :

Anadarko	proposes	a	stimulation vessel‐wide	fuel	cap	of	225	bbl /day	and	4725	bbl/yea r	based	on	the historical	fuel	consumption	recor ds	for	comparable	vessel	and	e xpected	operating	time	for	this	vessel.

The	maximum	hourly,	daily,	and	annual	emissions	from	the	stimul ation	vessel	are	calculated	based	on

the	derived	fuel	bas ed	emission	factor	as	described	below:

Maximum Hourly Emissions

– The	maximum	hourly	emissions	for the	main	engines	are	calculate d

based	on	the	fuel	based	emission factor	and	max imum	fuel	requir ement	of	9.37 bbl	of	fuel.

Maximum Daily Emissions

– The	maximum	daily	emissions	for the	main	engines	are	based	on	t he	fuel

based	emission	factor	and	maximu m	fuel	requiremen t	of	225	bbl/d ay	of	fuel.

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

### 3.4.19. Bow Thruster Engine (SV-BT-01)

The	Stimulation	Vessel	includes one	1,675	HP	(1,249	kW)	bow	thr uster	engine.		Emissi ons	are	generated

as	a	result	of	combustion	of	d iesel	fuel	in	the	engines.

Emissions Factors –	 The	 sources	 of	 emission	 facto rs	 used	 to	 estimate	 emissions	 f or	 representative
Stimulation	Vessel	Bow	Thruster Engine	are	summarized	below.

AP

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

‐ fuel Engines –	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC	and	HAP	em issions	estimates	fo r	thruster	engine	are based	on	AP‐42,	Section	3.4	Tabl e	3.4‐1	through	Table	3.4‐4.	PM <	3um	is	taken	as	PM 2.5 .		Total particulate	emission	is	the	sum of	filterable	an d	condensable	p articulate	emissions.	Per	footnote	f	of AP‐42	Chapter	3,	Table	3.4‐1,	non‐ methane	VOC	emission	factor	h as	been	taken	as	91%	of	TOC emission	factor.		An	average	BSF C	of	7,000	Btu/HP‐hr	was	used	t o	convert	from	lb/MMBtu	to	lb/HP‐

hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and	504 hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a part	of	stimulation	vessel‐w ide	fuel	consumption	lim it,	no	separate	fuel limit	is	required	to	demonstrate compliance.		Anadarko	will	mai ntain	adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.20. Bow Drop-Down Engine (SV-DD-01)

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

a	result	of	combustion	of	die sel	fuel	in	th e	engines.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 55 Trinity Consultants Emissions Factors –	 The	 sources	 of	 emission	 facto rs	 used	 to	 estimate	 emissions	 f or	 representative Stimulation	Vessel	Bow	Drop‐Dow n	Engine	are	summarized	below.

AP

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

‐ fuel Engines –	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC	and	HAP	em issions	estimates	fo r	the	bow	drop‐down engine	are	based	on	AP‐42,	Secti on	3.4	Table	3.4‐1	through	Tabl e	3.4‐4.	PM	<	3um	is	taken	as	PM 2.5

. Total	particulate	emi ssion	is	the	sum	of	fil terable	and	condens able	particulate	emissions.	Per footnote	f	of	AP‐42	Chapter	3,	Ta ble	3.4‐1,	non‐methane	VOC	emi ssion	factor	has	been	taken	as	91%

of	TOC	emission	factor.		An	avera ge	BSFC	of	7,000	Btu/HP‐hr	was used	to	convert	from	lb/MMBtu	to lb/HP‐hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and	504 hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a part	of	stimulation	vessel‐w ide	fuel	consumption	lim it,	no	separate	fuel limit	is	required	to	demonstrate compliance.		Anadarko	will	mai ntain	adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.21. Stern Thruster En gines (SV-ST-01)

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

Emissions Factors –	 The	 sources	 of	 emission	 facto rs	 used	 to	 estimate	 emissions	 f or	 representative
Stimulation	Vessel	Stern	Thrust er	Engine	are	summ arized	below.

AP

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

‐ fuel Engines –	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC	and	HAP	em issions	estimates	fo r	thruster	engine	areAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 56 Trinity Consultants based	on	AP‐42,	Section	3.4	Tabl e	3.4‐1	through	Table	3.4‐4.	PM <	3um	is	taken	as	PM 2.5 .		Total particulate	emission	is	the	sum of	filterable	an d	condensable	p articulate	emissions.	Per	footnote	f	of AP‐42	Chapter	3,	Table	3.4‐1,	non‐ methane	VOC	emission	factor	h as	been	taken	as	91%	of	TOC emission	factor.		An	average	BSF C	of	7,000	Btu/HP‐hr	was	used	t o	convert	from	lb/MMBtu	to	lb/HP‐

hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and	504 hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a part	of	stimulation	vessel‐w ide	fuel	consumption	lim it,	no	separate	fuel limit	is	required	to	demonstrate compliance.		Anadarko	will	mai ntain	adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.22. Representative Pump Engines (SV-PE-01 through SV-PE-08)

The	Stimulation	Vessel	includes eight	2,250	HP	(1,678	kW)	pump engines.		Emissions	a re	generated	as	a

result	of	combustion	of	diesel	fuel.

Emissions Factors –	The	sources	of	emission	 factors	used	 to	estimate	emissions	 f or	 these	pumps	are

summarized	below.

AP

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

‐ fuel Engines –	Particulate matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	CO,	VOC	and	HAP	emi ssions	estimates	for the	pump	engines	are based	on	AP‐42,	Section	3.4	Tabl e	3.4‐1	through	Table	3.4‐4.	PM <	3um	is	taken	as	PM 2.5 .		Total particulate	emission	is	the	sum of	filterable	an d	condensable	p articulate	emissions.	Per	footnote	f	of AP‐42	Chapter	3,	Table	3.4‐1,	non‐ methane	VOC	emission	factor	h as	been	taken	as	91%	of	TOC emission	factor.		An	average	BSF C	of	7,000	Btu/HP‐hr	was	used	t o	convert	from	lb/MMBtu	to	lb/HP‐

hr	to	calculate	emissions.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 57 Trinity Consultants EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	10	hours,	and	504 hours	of	operation,	respectively. Anadarko	proposes	to	maintai n	flexibility	of	op erating	fewer	pumps for	longer	duration	than	specifie d	above	as	long	as	total	daily and	annual	operations	are	within	the proposed	daily	and	annual	opera ting	limits,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a part	of	stimulation	vessel‐w ide	fuel	consumption	lim it,	no	separate	fuel limit	is	required	to	demonstrate compliance.		Anadarko	will	mai ntain	adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.23. Stimulation Vessel Generators (SV-GE-01 and SV-GE-02)

The	Stimulation	Vessel	incl udes	two	1,220	HP	(910	kW) generator	engines.		Emi ssions	are	generated	as

a	result	of	combustio n	of	diesel	fuel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	the	generator	engines

are	summarized	below.

40 CFR 89 Control Of Emissions From New And In

‐ Use Nonroad Compression

‐ Ignition Engines ‐	Particulate	matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions	estimate s	for	the	Generators	are

based	on	40	CFR	89	Tier	2	exha ust	emission	standards.	NO X emission	factors	are	assumed	to	be equal	to	the	NMHC	+	NO X emission	factor.		PM 10 and	PM 2.5 emission	factors	are	obtained	by	applying the	ratio	of	PM/PM 10 and	PM/PM 2.5 from	AP‐42	Chapter	3,	Table	3.4‐1 and	Table	3.4‐2	on	EPA	Tier	2

PM	emission	factor.

AP

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

‐ fuel Engines –	VOC	and

HAP	emissions	estimate s	for	the	generator	en gines	are	based	on AP‐42,	Section	3.4	Table	3.4‐1	and

Table	3.4‐3.		All	of	the	TOC	is	a ssumed	to	be	VOC.		TOC	emissio n	factor	has	been	calculated	as	theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 58 Trinity Consultants sum	of	exhaust	and	crankcase	emission	factors.	Per	footnote	f	o f	AP‐42	Chapter	3,	Table	3.4‐1,	non‐

methane	VOC	emission	f actor	has	been	taken as	91%	of	TOC	emissi on	factor.		An	average	BSFC	of 7,000	Btu/HP‐hr	was	used	to	convert from	lb/MMBtu	to	lb/HP‐hr	t o	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and	504 hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a part	of	stimulation	vessel‐w ide	fuel	consumption	lim it,	no	separate	fuel limit	is	required	to	demonstrate compliance.		Anadarko	will	mai ntain	adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### 3.4.24. Stimulation Vessel Generators (SV-GE-03 and SV-GE-04)

The	Stimulation	Vessel	includes	t wo	805	HP	(600	kW)	Caterpillar C18	ATAAC	engines.		Emissions	are generated	as	a	result	of	c ombustion	of	diesel	fuel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	the	generator	engines

are	summarized	below.

40 CFR 89 Control Of Emissions From New And In

‐ Use Nonroad Compression

‐ Ignition Engines ‐	Particulate	matter	(PM,	PM 10 ,	and	PM 2.5 ),	NO X ,	and	CO	emissions estimates	for	the generator	engines	are	based	on	4 0	CFR	89	Tier	2	ex haust	emissio n	standards.	NO X emission
factors	are	assumed	to	b e	equal	to	the	NMHC	+	NO X emission	factor.		PM 10 and	PM 2.5 emission factors	are	obtained	by	applying	the	ratio	of	PM/PM 10 and	PM/PM 2.5 from	AP‐42	Chapter	3,

Table	3.4‐1	and	Table	3.4‐2	on	E PA	Tier	2	PM	emission	factor.

AP

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

‐ fuel Engines –	VOC	and

HAP	emissions	estimate s	for	the	Generators Baker	Hughes	engines are	based	on	AP‐42,	SectionAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 59 Trinity Consultants 3.4	Table	3.4‐1	and	Table	3.4‐3.		A ll	of	the	TOC	is	assumed	to be	VOC.		TOC	emission	factor	has

been	calculated	as	the	sum	of	ex haust	and	crankcase	emission	fa ctors.	Per	footnote	f	of	AP‐42 Chapter	3,	Table	3.4‐1,	non‐metha ne	VOC	emission	factor	has	bee n	taken	as	91%	of	TOC emission	factor.		An	average	BSF C	of	7,000	Btu/HP‐hr	was	used	t o	convert	from	lb/MMBtu	to lb/HP‐hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐ 98‐006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillat e	oil‐fired	gas	turbines	was	used	as a	surrogate	for	distillate	oil‐fi red	engines	due	to	lack	of	emi ssion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	from	40	CFR	98	Subpart	C, Table	C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and Table	C‐2	(Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for

CO 2 e	has	been	calculated using	the	GWPs	obtaine d	from	40	CFR	98	Su bpart	A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel fuel	assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized to	SO 2 and	2	percent	of	sulfur	in	the

fuel	is	oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of Draft	Regulatory	Impact	Analysi s:	Control

of	Emissions	from	Nonroad	Die sel	Engines,	EPA420‐R‐03‐008,	Apri l	2003.		Emissions	of	H 2 S, TRS,	and	reduced	sulfur	compound s	resulting	from	sulfur	content in	the	fuel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and	504 hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a part	of	stimulation	vessel‐w ide	fuel	consumption	lim it,	no	separate	fuel limit	is	required	to	demonstrate compliance.		Anadarko	will	mai ntain	adequate	records	to	comply	with proposed	daily	and	ann ual	operation	limits.



### Well Evaluation Vessel Combustion Sources

The	Well	Evaluation	Vessel	will	c onsist	of	Main	Engines	(WE‐ME‐ 01	and	WE‐ME‐02),	Auxiliary	Engines (WE‐AE‐01	and	WE‐AE‐02),	and	E mergency	Generators	(WE‐GE‐01,	WE ‐GE‐02,	and	WE‐GE‐03).

Emissions	from	each	ai r	pollution	source	a re	estimated	using	th e	methodology	as	shown	below.



### 3.4.25. Well Evaluation Vessel Main En gines (WE-ME-01and WE-ME-02)

The	Well	Evaluation	Vessel	Main	E ngines	represented	in	this	app lication	consist	of	two	2,250	HP engines.		Emissions	are generated	as	a	result	of	combustion	of diesel	fuel	in	the	engines.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	representative	well evaluation	vessel	main	eng ines	are	summari zed	below.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 60 Trinity Consultants AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	for	the	well evaluation	main	engines	are	ba sed	on	AP‐42,	Section	3.3	emission factors.		An	average	BFSC	of	7,000 Btu/HP‐hr	was	used	to	conver t	from	lb/MMBtu	to	lb/HP‐hr	to
calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

Fuel Based Emission Factor Derivation :

Based	on	the	specifications	sheet s	for	each	engine,	the	BSFC	wa s	used	to	convert	the	above	mentioned emission	factors	to	lbs	of	pollutant/bbl	of	fuel	consumed	as	sh own	in	Appendix	B.		The	fuel	consumption resulting	in	highest	em issions	for	the	pres ented	well	evaluatio n	vessel	engines	is 194	g/kW‐hr	as	shown in	Appendix	B.		Based	on	a	conservative	estimate,	Anadarko	prop oses	well	evaluation	vessel‐wide	fuel limit	of	144	bbls/day.

Proposed Operating Limits :

Anadarko	proposes	a	well	evaluation	vessel‐wide	fuel	cap	of	144 bbl/day	and	28,800	bbl/year	based	on the	engineering	estimates	and	exp ected	operating	time	for	this vessel.

The	maximum	hourly,	daily,	and	annual	emissions	from	the	stimul ation	vessel	are	calculated	based	on

the	derived	fuel	bas ed	emission	factor	as	described	below:

Maximum Hourly Emissions

– The	maximum	hourly	emissions	for the	main	engines	are	calculate d

based	on	the	fuel	based	emission factor	and	max imum	fuel	requir ement	of	6	bbl	of	fuel.

Maximum Daily Emissions

– The	maximum	daily	emissions	for the	main	engines	are	based	on	t he	fuel

based	emission	factor	and	maximu m	fuel	requiremen t	of	144	bbl/d ay	of	fuel.

Annual Emissions –	The	annual	emissions for	the	main	engines are	based	on	the	fu el	based	emission factor	and	maximum	fuel	requirem ent	of	28,800	bbl/year	of	fuel.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 61 Trinity Consultants 

### 3.4.26. Well Evaluation Vessel Auxiliary Engines (WE-AE-01 and WE-AE-02)

The	Well	Evaluation	Vessel	Auxili ary	Engines	represented	in	thi s	application	consist	of	two	1,468	HP engines.		Emissions	are generated	as	a	result	of	combustion	of diesel	fuel	in	the	engines.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	representative	well evaluation	vessel	auxiliary	en gines	are	summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	for	the	well evaluation	auxiliary	engines	a re	based	on	AP‐42,	Section	3.3 emission	factors.		An	average	BFS C	of	7,000	Btu/HP‐hr	was	used to	convert	from	lb/MMBtu	to lb/HP‐hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	the	well	evaluation vessel‐wide	fuel	consumption	limit,	no separate	fuel	limit	is	required	t o	demonstrate	compliance.		Ana darko	will	maintain	adequate	records	to comply	with	proposed	daily	a nd	annual	operation	limits.



### 3.4.27. Well Evaluation Vessel Emerge ncy Generator #1 (WE-GE-01)

The	Well	Evaluation	Vessel	Emerg ency	Generator	represented	in	t his	application	consist	of	one	272	HP engine.		Emissions	are	generated	as	a	result	of	combustion	of	d iesel	fuel	in	the	engine.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	representative	well evaluation	emergency	genera tor	are	summarized	below.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 62 Trinity Consultants AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	for	the	well evaluation	emergency	generator #1	are	based	on	AP‐42,	Section	3.4 emission	factors.		An	average	BFS C	of	7,000	Btu/HP‐hr	was	used to	convert	from	lb/MMBtu	to lb/HP‐hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	the	well	evaluation vessel‐wide	fuel	consumption	limit,	no separate	fuel	limit	is	required	t o	demonstrate	compliance.		Ana darko	will	maintain	adequate	records	to comply	with	proposed	daily	a nd	annual	operation	limits.



### 3.4.28. Well Evaluation Vessel Emerge ncy Generator #2 (WE-GE-02)

The	Well	Evaluation	Vessel	Emerg ency	Generator	#2	represented	i n	this	application	consist	of	one	212 HP	engine.		Emissions	are	generate d	as	a	result	of	combustion	o f	diesel	fuel	in	the	engine.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	representative	well evaluation	emergency	generato r	#2	are	summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	for	the	well evaluation	emergency	generator #2	are	based	on	AP‐42,	Section	3.4 emission	factors.		An	average	BFS C	of	7,000	Btu/HP‐hr	was	used to	convert	from	lb/MMBtu	to lb/HP‐hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 63 Trinity Consultants EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuel assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	the	well	evaluation vessel‐wide	fuel	consumption	limit,	no separate	fuel	limit	is	required	t o	demonstrate	compliance.		Ana darko	will	maintain	adequate	records	to comply	with	proposed	daily	a nd	annual	operation	limits.



### 3.4.29. Well Evaluation Vessel Emerge ncy Generator #3 (WE-GE-03)

The	Well	Evaluation	Vessel	Emerg ency	Generator	#3	represented	i n	this	application	consist	of	one	200 HP	engine.		Emissions	are	generate d	as	a	result	of	combustion	o f	diesel	fuel.

Emissions Factors –	The	sources	of	emission	facto rs	used	to	estimate	emissions	f or	representative	well evaluation	emergency	generato r	#3	are	summarized	below.

AP

‐ 42, Section 3.3. Gasoline and Diesel Industrial Engines –PM,	NO X ,	CO,	VOC	and	HAP
emissions	estimates	for	the	well evaluation	emergency	generator #3	are	based	on	AP‐42,	Section	3.4 emission	factors.		An	average	BFS C	of	7,000	Btu/HP‐hr	was	used to	convert	from	lb/MMBtu	to lb/HP‐hr	to	calculate	emissions.

EPA Guidance Documents –	Lead	emission	factor	is	obtained	from	EPA	guidance	document: Locating	and	Estimating	Air	Emissions	from	Sources	of	Lead	and Lead	Compounds,	EPA	454/R‐98‐ 006,	May	1998,	Section	5.2.2.		Emissi on	factor	for	distillate	o il‐fired	gas	turbines	was	used	as	a surrogate	for	distillate	oil‐fired engines	due	to	lack	of	emiss ion	factors.

EPA Regulations –	CO 2 ,	CH 4 and	N 2 O	emission	factors	are	obtained	f rom	40	CFR	98	Subpart	C,	Table C‐1(Default	CO 2 Emission	Factors	and	High	Heat	Values	for	Various	Types	of	Fue l)	and	Table	C‐2 (Default	CH 4 and	N 2 O	Emission	Factors	for	Various	Types	of	Fuel).		Emission	factor for	CO 2 e	has been	calculated	using	the	GWPs	o btained	from	40	CFR	98	Subpart A.

Mass Balance –	Anadarko	is	proposing	the	use	of	ULSD	fuel	for	all	diesel	co mbustion	sources. Therefore,	SO 2 emissions	are	calculated	based	on	a	maximum	sulfur	content	of 15	ppm	in	diesel	fuelAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 64 Trinity Consultants assuming	that	98	percent	of	sulfur	in	the	fuel	is	oxidized	to	S O 2 and	2	percent	of	sulfur	in	the	fuel	is

oxidized	to	H 2 SO 4 mist	based	on	Section	4.1.1	of	D raft	Regulatory	Impact	Analysi s:	Control	of

Emissions	from	Nonroad	Diesel Engines,	EPA420‐R‐03‐008,	April	2 003.		Emissions	of	H 2 S,	TRS,	and reduced	sulfur	compounds	resulting from	sulfur	content	in	the	f uel	are	negligible.

The	maximum	hourly,	da ily,	and	annual	emi ssions	were	calculated based	on	one	hour,	24	hours,	and 4,800	hours	of	operation,	respectively.

Proposed Operating Limits :

Since	this	emission	unit	will	be	a	part	of	the	well	evaluation vessel‐wide	fuel	consumption	limit,	no separate	fuel	limit	is	required	t o	demonstrate	compliance.		Ana darko	will	maintain	adequate	records to	comply	with	proposed	daily and	annual	operation	limits.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 65 Trinity Consultants 

## 4. REGULATORY APPLICABILITY ANALYSIS

To	assist	U.S.	EPA	Region	4	in	dr afting	the	pre‐construction	pe rmit	for	the	proposed project,	this	section of	the	application	provides	a	rev iew	of	pertinent	federal	air	q uality	regulations	that potentially	apply	to

the	emission	sources	associated	w ith	the	proposed	project.		As the	proposed	project	will	be	carried	out beyond	25	miles	of	the	nearest	St ates’	seaward	boundary,	it	wil l	be	outside	of	the corresponding	state and	local	regulatory	jurisdiction s	and	will	not	be	subject	to	a ny	state	or	local	regulations.



### 4.1. OUTER CONTINENTAL SHELF AI R REGULATIONS (40 CFR 55)

The	BlackHornet	drillship	used	f or	the	proposed	exploratory	dri lling	operations	will	qualify	as	an	OCS source,	as	defined	in	40	CFR	P art	55.2.		An	OCS	source	is	defin ed	in	40	CFR	55.2	as	follows:

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

and (3) Is located on the OCS or in or on waters above the OCS.

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

will be regulated.”

Therefore,	when	the	BlackHornet	dr illship	is	conducting	the	pro posed	project,	it	wi ll	be	considered	an OCS	source	and	shall	be	subject to	the	requirements	of	40	CFR	5 5.		In	addition,	when	an	associated vessel	is	physically	attached	to an	OCS	source,	the	stationary source	aspects	of	the vessel	will	also	be regulated	as	an	OCS	source.

The	main	engines	on	the	support	v essels	are	solely	used	for	pro pulsion	purposes	and/or	for	maintaining the	position	of	the respective	vessel.		The	generators	on	the	s upport	vessels	and	the barge	are	not	used for	OCS	activity;	rather,	they	a re	used	only	for	non‐process	an cillary	activities	su ch	as	operating	HVAC System,	maintaining	the	GPS	posi tion	and	other	such	similar	fun ctions.	The	ROV	electr ic	generator	diesel engine	on	the	Supply	Boat	is	not operated	while	physically	conn ected	to	the	drillship.	Therefore,	these engines	do	not	meet	the	definitio n	of	stationary	aspects	of	the se	vessels.

As	specified	in	Section	1	of	t his	application,	per	40	CFR	55.3( a),	all	OCS	sources	located	in	the	EGOM	are regulated	by	the	OCS Air	Regulations	codi fied	under	40	CFR	55. As	the	regulatory authority	over	the EGOM	has	not	been	delegated	throu gh	the	requirements	of	40	CFR 55.11(j),	the	proposed	OCS	source falls	under	the	regulatory	jurisd iction	of	the	U.S.	EPA	and	U.S .	EPA	Region	4	will	i ssue	the	applicable permits	and	implement and	enforce	the	requi rements	of	40	CFR	55

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 66 Trinity Consultants As	specified	at	40	CFR	55.13,	OCS sources	subject	to	the	requir ements	of	40	CFR	55	must	comply	with the	following	federal	req uirements,	as	applicable:

40	CFR	52.21	‐	Prevention	of	Sign ificant	Deterioration	(PSD);

40	CFR	Part	60	‐	New	Source	Per formance	Standards	(NSPS);

40	CFR	Part	61	‐	National	Emission	Standards	for	Hazardous	Air Pollutants	(NESHAP),	which represent	pollutant‐specific	stan dards	established	pursuant	to Section	112	of	th e	Clean	Air	Act (CAA)	for	those	pollutants	for	wh ich	a	standard	is	prescribed	u nder	40	CFR	61;

40	CFR	Part	63	‐	Maximu m	Achievable	Control	Technology	(MACT), which	represent	standards established	pursuant	to	Section 112	of	the	CAA	to regulate	spec ific	categories	of	stationary	sources that	emit	(or	have	the	potential to	emit)	one	or	more	HAPs;	and 40	CFR	Part	71	‐	Federal	Ope rating	Permits	Program.

Based	on	the	definition	of	the	O CS	source,	support	vessels	are subject	to	applicable	regulatory requirements	when	they are	physically	attached	to	the	OCS	sourc e,	in	which	case	onl y	the	stationary source	aspects	of	the	vesse ls	will	be	regulated.

Therefore,	detailed	regulatory	a pplicability	determinations	in this	section	are	only	needed	for	the following	emission	units	on	th e	BlackHornet	drillship:

Eight	Main	Engines	(DR‐ME‐01	to	DR‐ME‐08) One	Emergency	Generator	(DR‐GE‐01) One	Emergency	Air	Compressor	(DR‐AC‐01) Three	Well	Completion	Condensate Tanks	(DR‐TP‐24	to	DR‐TP‐26) Five	Third	Party	Well	Evaluation Engines	(DR‐TP‐12	to	DR‐TP‐16) One	Flowback	Boiler	(DR‐TP‐22) One	Boom	Flare	(DR‐TP‐23) Fuel	Storage	tanks	(several	EPNs) Painting	(DR‐PO‐01) Welding	(DR‐WO‐01)

Under	certain	operating	scenarios ,	the	following	sources	of	air pollution	will	cons titute	stationary source	aspects	of	the	vessels	w hen	the	support	vessels	are	phys ically	attached	to	the	OCS	source:

Fuel	Storage	Tanks	on	the	supply boats	and	the	anchor	handling boat	(several	EPNs) Eight	pumps	on	the	stimulation	v essel	(SV‐PE‐01	through	SV‐PE‐0 8)

The	Life	Boats	(DR‐LB‐01	and	DR‐ LB‐06)	and	the	Fast	Rescue	Craf t	(DR‐FR‐01)	are	included	in	the	PTE calculations	and	air	dispersion modeling	as	specified	in	40	CFR part	55	and	these	sour ces	are	subject	to operating	limits,	monitoring,	rec ordkeeping	and	reporting	requi rements	to	ensure	they will	not	exceed the	potential	emissions	assumed in	the	application	and	impact	r eview.			Per	40	CFR	55.2,	the	support vessels	operating	within	25	miles of	the	OCS	source	are	not	sub ject	to	BACT	requirem ents	unless	they

are	attached	to	the	OC S.		If	attached,	only	the	stationary	sour ce	aspects	of	the	vessel	are	regulated.

These	units	do	not	hav e	any	stationary	sourc e	aspects	with	resp ect	to	air	pollutant emissions,	as	they

are	used	for	man	overboard	and	e mergency	escape	scenarios	only. Hence,	these	units are	not	subject	to NSPS	and	MACT	regulations.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 67 Trinity Consultants Additionally,	details	(e.g.,	mode l	year,	exact	po wer	rating	etc .)	of	the	Temporary	Th ird	Party	Emission Sources	(DR‐TP‐01	through	DR‐TP‐ 11	and	DR‐TP‐17	through	DR‐TP‐2 1)	were	not	available	at	the	time of	this	application	since	these engines	are	brou ght	onboard	as required.		Therefore,	regulatory determinations	for	these	engines will	be	made	before	selecting the	engines.		A	detai led	overview	of	the applicability	of	each	federal	ai r	quality	regulation	is	provide d	in	the	following	sections.



### 4.2. PREVENTION OF SIGNIFICANT DET ERIORATION (PSD) REGULATIONS

As	an	OCS	source	subject	to	the requirements	of	40	CFR	55,	the proposed	project	wil l	need	to	comply with	40	CFR	55.13(d)	which	specifi es	that	the	PSD	program	(codi fied	under	40	CFR	52.21),	applies	to OCS	sources	located	beyond	25	mi les	of	State’s	seaward	boundari es.		The	requirements	of	the	PSD program	apply	to	the	constructio n	of	any	new	major	stationary	s ource	or	any	project	at	an	existing major	stationary	source	in	an	a rea	designated	as	attainment	or unclassifiable	under	Sections 107(d)(1)(A)(ii)	or	(iii)	of	the CAA.		The	pollutants	regulated by	the	PSD	program include	all	criteria pollutants	and	several	non‐crit eria	pollutants	such	as	total	re duced	sulfur	compounds,	sulfuric	acid	mist, and	fluorides	(not	includi ng	hydrogen	fluoride).

An	OCS	source	is	considered	a	PSD major	source	if	the	potential emission	of	any	PSD‐regulated	pollutant exceeds	the	major	source	thres hold	of	250	tons	per	year	(tpy). For	a	PSD	regulated	pollutant	emitted from	a	new	PSD	major	source	whos e	source‐wide	potential	emissio ns	exceed	the	respective	Significant Emission	Rates	(SERs)	defined	in	40	CFR	52.21(b)(23)(i),	PSD	re view	is	required.

On	May	13,	2010,	the	U.S.	EPA	issu ed	the	final	“Prevention	of	S ignificant	Deterioration	and	Title	V Greenhouse	Gas	Tailoring	Rule”	sp ecifying	that	as	of	January	2, 2011,	all	new	industri al	sources	that	are major	sources	for	any	new	source review	(NSR)	regulated	polluta nts	other	than	GHGs,	and	will	emit	or have	the	potential	t o	emit	75,000	tons	per	year	or	more	of	tota l	GHGs,	on	a	CO 2 e	basis	will	need	to

determine	the	Best	Available	Con trol	Technology	for	their	GHG	e missions. 3

To	determine	the	applicability of	PSD	permitting	requirements	a nd	the	pollutants	to	which	these requirements	would	apply,	the	emi ssions	estimates	from	the	prop osed	EGOM	Exploratory	Project	were compared	to	the	respective	PSD	ma jor	source	threshold	and	SER. As	required	by	40	CFR	55.13,	the source‐wide	potential	emissions were	calculated	b y	including	th e	emissions	from	s ources	associated with	the	proposed	exploratory	dr illing	operation s	along	with	th e	associated	support	vessels	while	at	the source,	and	while	enro ute	to	or	from	the	s ource	when	within	25 miles	of	the	source.		Table	1‐2	lists	the source‐wide	potential	emission	r ates	of	each	regulated	air	poll utant	for	the	EGOM	Exploratory	Prospect against	the	resp ective	PSD	SER.

As	shown	in	Table	1‐2, the	proposed	OCS	source	qualifies	as	a	m ajor	source	under	the	PSD	program because	potential	annual	emissions	of	NO X and	CO	are	each	greater	tha n	the	250	tpy	major	source threshold.		Additionally,	PSD review	is	required	for	PM,	PM 10 ,	PM 2.5 ,	NO X ,	GHGs,	and	VOCs	since emissions	of	these	pollutants	ex ceed	their	respective	PSD	SERs.

40	CFR	52.21(k)	requires	that	Anad arko	demonstrate	that	for	all regulated	air	pollutants	that	would	be

emitted	at	or	in	excess	of	the	S ER	would	not	cause	or	contribut e	to	a	violation	of	any	NAAQS	or	cause	or contribute	to	a	violation	of	any	applicable	PSD	increments.		Th erefore,	for	pollutants	subject	to	PSD

3 CO 2 equivalent encompasses a list of six greenhouse gases, including carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbo ns, and sulfur hexafluoride.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 68 Trinity Consultants review,	the	following requirements	of	the PSD	regulations	appli cable	to	the	EGOM	Ex ploratory	Project are	addressed	in	this	application:

A	determination	of	BACT	for	each applicable	emission	unit	as	de tailed	in	Section	5	of	this	report. Air	dispersion	modeling	analysis	as	detailed	in	Appendix	D	of	t his	report

The	air	dispersion	modeling	anal ysis	is	performed	for	Class	I	a nd	Class	II	areas	to address	following requirements	in	th is	regulation:

An	analysis	of	the	source’s	impact	on	total	air	quality	to	ensu re	compliance	with	the	NAAQS	and the	applicable	maximum	allowable increase	over	the	baseline	con centration	in	any	area,	per	40 CFR	52.21(k); Ambient	air	qualit y	analysis	per	40	CFR	52.21(m);	and An	analysis	of	source	related	gro wth	impacts	as	well	as	an	anal ysis	of	the	impairment	to	soils, vegetation,	and visibility	per	40	CFR	52.21(o).



### 4.3. NEW SOURCE PERFORMANCE STANDARDS (NSPS)

NSPS	require	new,	modified,	or	rec onstructed	sources	in	applica ble	source	categories	to	control

emissions	to	the	level achievable	by	the	best	demonstrated	tech nology	as	specified	in	the	applicable provisions.		A	regulatory	applic ability	determination	and	a	sum mary	of	potentially	applicable	NSPS subparts	for	the	equipment	associ ated	with	the	proposed	EGOM	Ex ploratory	Projec t	operations	are provided	in	the	foll owing	subsections.



### 4.3.1. 40 CFR Subpart A – General Provisions

All	affected	sources	subject	to	an	NSPS	are	also	subject	to	the general	provisions	of	NSPS	Subpart	A	unless specifically	 excluded	 by	 the	 source‐specific	 NSPS.	 	 NSPS	 Subpar t	 A	 requires	 the	 following	 of	 facilities subject	to	a	source‐specific	NSPS:

Initial	construction/recon struction	notification Initial	startup	notification

Performance	tests

Performance	test	date initial	notification General	monitoring	requirements General	recordkeeping	requirements Semiannual	monitoring	system	a nd/or	excess	emission	reports

General	control	device	and	w ork	practice	requirements

Source‐specific	NSPS	provisions can	supersede	NSPS	Subpart	A	as noted	in	the	relev ant	NSPS	Subpart.



### 4.3.2. 40 CFR Subpart K- Standards of Perf ormance for Storage Vessels for Petroleum Liquids

NSPS	Subpart	K,	Standards	of	Perf ormance	of	Storage	Vessels	for Petroleum	Liquids	for	which
Construction,	Reconstruction,	or Modification	Commenced	After	J une	11,	1973,	and	Prior	to	May	19,Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 69 Trinity Consultants 1978,	provides	standards	of	perfor mance	for	storage	vessels	for petroleum	liquids	with	a	storage capacity	greater	than	or	equal to	40,000	gallons	but	less	than 65,000	gallons	for	which	the	construction

or	modification	is	commenced	a fter	March	8,	1974	and	prior	to	M ay	19,	1978.			Requirements	of	this Subpart	also	apply	to	storage	ve ssels	with	a	capacity	greater	t han	65,000	gallons	for	which	construction

or	modification	commenced	aft er	June	11,	1973	and	prior	to	May 19,	1978.

All	storage	tanks	represented	in	t his	application	are	exempt	fr om	NSPS	subpart	K	si nce	all	of	them	were

constructed	after	1978.



### 4.3.3. 40 CFR 60 Subpart Ka – Standards of Performance for Storage Vessels for Petroleum Liquids

NSPS	Subpart	Ka,	Standards	of	Performance	of	Storage	Vessels	fo r	Petroleum	Liquids	for	which
Construction,	Reconstruction,	or Modification	Commenced	After	M ay	18,	1978,	and	Prior	to	July	23, 1984,	provides	standards	of	perfor mance	for	storage	vessels	for petroleum	liquids	with	a	storage capacity	greater	than	or	equal to	40,000	gallons	for	which	cons truction	is	commenced	after	May	18, 1978	and	prior	to	July	23,	1984. 4

All	storage	tanks	represented	in	t his	application	are	exempt	fr om	NSPS	subpart	Ka	since	all	of	them

were	constructed	after	1984.



### 4.3.4. 40 CFR 60 Subpart Kb- Standards of Performance for Volatile Liquid Storage Vessels

NSPS	Subpart	Kb, Standards of Performance of Volatile Organic Liquid Storage Vessels (Including

Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced After July 23, 1984 ,	provides	standards	of	performa nce	for	storage	vessels	storing petroleum	liquids	with a	capacity	of	greater than	or	equal	to	75	m 3 (19,812	gallons)	for	which	cons truction,	reconstruction,	or modification	is	commenced	after	July	23,	1984. 5

All	bulk	fuel	storage	tanks	in	t his	project	were constructed	af ter	1984	and	hence	are	potentially	subject to	NSPS	Subpart	Kb.		However,	p er	40	CFR	60.110(b)	these	tanks are	exempt	from	th e	requirements	of NSPS	Subpart	Kb.		Table	4‐1	list s	all	tanks	in	this	project	tha t	were	constructed	af ter	1984	and	includes the	non‐applicability	determinat ion	for	each	tan k	with	NSPS	Sub part	Kb.

Table 4

‐ 1. NSPS Subpart Kb Applicability Determination for Fuel Storage Tanks

4 40 CFR 60.110a(a)

5 40 CFR 60.110b(a)Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 70 Trinity Consultants

Tank ID Description Capacity
of the
Tank (m 3 ) NSPS Subpart Kb

Non

‐ applicability

Determination

DR‐FT‐01	 No.	1	Fuel	Oil Storage	Tank	(Port) 657

Per	40	CFR	60.110b(b), NSPS	Subpart	Kb	does	not apply	to	storage	tanks	with a	capacity	greater	than	or equal	to	151	m3	storing	a

liquid	with	a	maximum true	vapor	pressure	less than	3.5	kPa	(0.5	psia).
These	tanks	store	diesel fuel	which	has	a	vapor pressure	lesser	than	or equal	to	0.012	psi	at	78	 ̊F

based	on	Tank	4.0.9d

program. DR‐FT‐02	 No.	1	Fuel	Oil	S torage	Tank	(Starboard) 657

DR‐FT‐03	 No.	2	Fuel	Oil Storage	Tank	(Port) 1485

DR‐FT‐04	 No.	2	Fuel	Oil	S torage	Tank	(Starboard) 1485

DR‐FT‐05	 No.	3	Fuel	Oil Storage	Tank	(Port) 1439

DR‐FT‐06	 No.	3	Fuel	Oil	Sto rage	Tank	(Starboard)	 1439

SB‐DT‐05	 Vessel's	Diesel	Fue l	Storage	Tank	#3	Port	 161

SB‐DT‐06	 Vessel's	Diesel	Fue l	Storage	Tank	#3	Starboard 161

SB‐DT‐07	 Vessel's	Diesel	Fue l	Storage	Tank	#4	Port	 160
SB‐DT‐08	 Vessel's	Diesel	Fuel	Storage	Tank	#4	Starboard	 160
AB‐DT‐12	 Starboard	Wing	Diesel	Fuel	Tank	#2 148

AB‐DT‐13	 Port	Side	Double	Bott om	Diesel	Fuel	Tank	#4	 107

AB‐DT‐14	 Starboard	Sid e	Double	Bottom	Diesel	Fuel	Tank	#5	 107
AB‐DT‐10	 Port	Wing	Diesel	Fuel	Tank	#2 202

AB‐DT‐11	 Starboard	Sid e	Double	Bottom	Diesel	Fuel	Tank	#4	 209 DR‐FT‐09	 No.	1	Fuel	Oil	Servicing	Tank	(#1	E/R)	 31

Per	40	CFR	60.110b	(a), NSPS	Subpart	Kb	does	not apply	to	storage	tanks	with

capacity	less	than	75	m3. DR‐FT‐10	 No.	2	Fuel	Oil	Servicing	Tank	(#1	E/R)	 31 DR‐FT‐11	 No.	1	Fuel	Oil	Servicing	Tank	(#2	E/R)	 31 DR‐FT‐12	 No.	2	Fuel	Oil	Servicing	Tank	(#2	E/R)	 31 DR‐FT‐13	 No.	1	Fuel	Oil	Servicing	Tank	(#3	E/R)	 35 DR‐FT‐14	 No.	2	Fuel	Oil	Servicing	Tank	(#3	E/R)	 35

DR‐FT‐15	 Fuel	Oil	Over	Tank	 46

DR‐FT‐16	 Fuel	Oil	Leak	Tank	 23
DR‐FT‐17	 Helicopter	Fuel	Tank	1 2.9 DR‐FT‐18	 Helicopter	Fuel	Tank	2	 2.9

Per	40	CFR	60.110b(a), NSPS	Subpart	Kb	does	not apply	to	storage	tanks	with

capacity	less	than	75	m3. SB‐DT‐09	 Vessel's	Diesel	Fuel Storage	Tank	#5	Port	 24.88
SB‐DT‐10	 Vessel's	Diesel	Fuel	Storage	Tank	#5	Starboard	 27.79

SB‐DT‐11	 Vessel's	Diesel	Fue l	Storage	Day	Tank	#1	Port 22.81
SB‐DT‐12	 Vessel's	Diesel	Fuel	Storage	Day	Tank	#1	Starboard	 34. 63
SB‐DT‐13	 Vessel's	Diesel	Fuel	Stern	Thruster	Day	Tank	 5.66

SB‐DT‐14	 Vessel's	Diesel	Fuel	Overflow	Port	Storage	Tank 16.66

SB‐DT‐15	 Vessel's	Diesel	Fuel Overflow	Standby	Storage	Tank 16.66

AB‐DT‐01	 Port	Side	Double	Bott om	Diesel	Fuel	Tank	#1		 48.63

AB‐DT‐02	 Starboard	Sid e	Double	Bottom	Diesel	Fuel	Tank	#1	 48.66

AB‐DT‐03	 Center	Double	Bottom	Diesel	Fuel	Tank	#1 59.45
AB‐DT‐06	 Port	Wing	Diesel	Fuel	Tank	#1	 61.78
AB‐DT‐07	 Starboard	Wing	Diesel	Fuel	Tank	#1	 61.78

AB‐DT‐15	 Port	Service	Diesel	Tank 51.09

AB‐DT‐16	 Starboard	Service	Diesel	Tank	 51.09
AB‐DT‐17	 Port	Diesel	Settling	Tank	 51.95Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 71 Trinity Consultants AB‐DT‐18	 Starboard	Diesel	Settling	Tank 51.95

AB‐DT‐19	 Diesel	Fuel	Overflow	Tank 13.98
DR‐FT‐07	 No.	1	Fuel	Oil	Settling	Tank	(Starboard) 71	 Per	40	CFR	60.110b(b), NSPS	Subpart	Kb	does	not apply	to	storage	tanks	with a	capacity	greater	than	or

equal	to	75	m 3 but	less
than	151	m 3 storing	a liquid	with	a	maximum true	vapor	pressure	of	less

than	15	kPa	(2.2	psia).
These	tanks	store	diesel fuel	which	has	a	vapor pressure	lesser	than	or

equal	to	0.012	psi	at
78	 ̊F	based	on	Tank	4.0.9d

program. DR‐FT‐08	 No.	2	Fuel	Oil	S ettling	Tank	(Port)	 71

SB‐DT‐01	 Vessel's	Diesel	F uel	Storage	Tank	#1	Port 143.92
SB‐DT‐02	 Vessel's	Diesel	Fuel	Storage	Tank	#1	Starboard	 143.92

SB‐DT‐03	 Vessel's	Diesel	F uel	Storage	Tank	#2	Port 145.46

SB‐DT‐04	 Vessel's	Diesel	Fuel	Storage	Tank	#2	Starboard	 145.46

AB‐DT‐04	 Port	Side	Double	Bo ttom	Diesel	Fuel	Tank	#2 119.18

AB‐DT‐05	 Starboard	S ide	Double	Bottom	Diesel	Fuel	Tank	#2 119.18

AB‐DT‐08	 Port	Side	Double	Bo ttom	Diesel	Fuel	Tank	#3 105.19

AB‐DT‐09	 Starboard	S ide	Double	Bottom	Diesel	Fuel	Tank	#3 105.19

Well Completion Tanks

DR‐TP‐24	 Well	Completion	Condensate	Tank	1 80 Per	40	CFR	60.110(d)(4),
condensate	tanks	are

exempt	from	the requirements	of	NSPS Subpart	Kb	since	the	tank
volume	is	less	than

1,589.87m3,	and condensate	is	stored	prior to	custody	transfer. DR‐TP‐25	 Well	Completion	Condensate	Tank	2 80

DR‐TP‐26	 Well	Completion	Condensate	Tank	3	 80



### 4.3.5. 40 CFR 60 Subpart IIII – Stationary Comp ression Ignition Internal Combustion

NSPS	Subpart	IIII,	Standards	of	P erformance	for	Stationary	Comp ression	Ignition	Internal	Combustion Engines,	provides	standards	for manufacturers,	ow ners,	and	oper ators	of	stationary	compression ignition	(CI)	internal	combustio n	engines	(ICE).		This	subpart provides	standards	for	owners	and operators	of	stationary	CI	ICE	th at	commence	construction	after July	11,	2005	where the	stationary	IC engines	are:

Manufactured	after	April	1,	2006	a nd	are	not	fire	pump	engines [40	CFR	60.4200(a)(2)(i)];	or

Manufactured	as	a	certified	Nati onal	Fire	Protection	Associatio n	(NFPA)	fire	pump	engine	after July	1,	2006	[40	CFR	60.4200(a)(2)(ii)].Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 72 Trinity Consultants Table 4

‐ 2. Applicable Engines Subject to Subpart IIII

EPN Description Manufacturing

Year Engine Rating (HP) Displacement Per Cylinder

Drillship

Main Engines

DR‐ME‐01 Main	Propulsion	Electrical Generator	Engine	#1	 2012 6,035 32.2

DR‐ME‐02 Main	Propulsion	Electrical Generator	Engine	#2	 2012 6,035 32.2

DR‐ME‐03 Main	Propulsion	Electrical Generator	Engine	#3	 2012 6,035 32.2

DR‐ME‐04 Main	Propulsion	Electrical Generator	Engine	#4	 2012 6,035 32.2

DR‐ME‐05 Main	Propulsion	Electrical Generator	Engine	#5	 2012 6,035 32.2

DR‐ME‐06 Main	Propulsion	Electrical Generator	Engine	#6	 2012 6,035 32.2

DR‐ME‐07 Main	Propulsion	Electrical Generator	Engine	#7 2012 12,069 32.2

DR‐ME‐08 Main	Propulsion	Electrical Generator	Engine	#8 2012 12,069 32.2

Emergency Engines

DR‐GE‐01	 Emergency	Generator April	2012	 2,547	 3.8
DR‐AC‐01	 Emergency	Air	Compressor September	2011	 38.5	 0.9



### 4.3.5.1. 

### Drillship Main Engines (D R-ME-01 through DR-ME-08)

Per	40	CFR	60.4200(a)(2)(i),	the	ei ght	main	engines	on	the	dril lship	are	subject	to	this	regulation because	they	were	manufactured	a fter	April	1,	2 006.		These	engi nes	are	required	to	comply	with	the following	requirements:



### NO X and	PM	emission	standards	for	o wners	and	operators	as	outlined in	40	CFR	60.4204(c)

Use	of	fuels	that	meet	a	maximum per‐gallon	sulfur	content	of	1 ,000	ppm	[40	CFR	60.4207(d)]. Operation	and	maintenan ce	requirements	as	sp ecified	in	40	CFR	6 0.4211(a). Initial	and	annual	performance	tests	for	NO X and	PM,	as	well	as	continuous	operating	parameter monitoring	per	40	CFR	60.4211(d),	and	40	CFR	60.4213. Notification	and	recordkeeping requirements	as	specified	in	40 CFR	60.4214.

Anadarko	will	comply	with	the	NO X emission	standard	of	9.69	g/kw‐hr and	will	comply	with	the	PM emission	standard	of	0.15	g/kw‐hr .		Anadarko	will	demonstrate	c ompliance	with	these	standards	during the	initial	performanc e	test	as	required	and will	comply	with	n otification	and	recordkeeping requirements.		Furthermore,	Anada rko	will	comply	with	the	fuel sulfur	content	requirement	by	using ULSD,	which	has	a	maximum	of	15	ppm	sulfur	content.		Anadarko	i s	proposing	to	ins tall	an	emission monitoring	system	to	comply	with	the	requirements	of	40	CFR	60. 4211(d),	and	40	CFR	60.4213.		The

details	of	the	emission	monitorin g	system	will	be	submitted	as they	become	available.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 73 Trinity Consultants



### 4.3.5.2. 

### Drillship Emergency Generator (DR-GE-01)

The	drillship	emergency	generato r	is	a	2011	model	year	with	a	d isplacement	of	less than	10	liters	per cylinder	CI	engine.		Per	requiremen ts	of	NSPS	IIII	for	this	cat egory	of	engine,	this engine	must	comply with	emission	limitations	for	new	nonroad	CI	engines	as	specifi ed	in	40	CFR	89.112	and	40	CFR	89.113, for	all	pollutants.

Currently,	this	engine is	not	certified	as	per	requirements	spe cified	in	the	40	CFR	89.112.		However,	this engine	is	compliant	wi th	IMO	Tier	II	standard,	which	is	more	co mmonly	applicable	standards	for	a	non U.S.	flagged	vessels	such	as	the BlackHornet.		Since	certificat ion	is	an	engine	manuf acturer	process,	it	is not	possible	for	these engines	to	obtain	an EPA	Tier	certificat e.		The	IMO	Tier	II	standard	only	limits
emissions	of	NO X and	the	NO X emission	standard	for	this	engin e	is	less	conservative	than	th e	EPA	Tier	2 standard	for	this	engine.		Hence this	engine	currently	does	not comply	with	the	EPA	Tier	2	standards.

Since	an	EPA	Tier	2	c ertified	engine	is	the only	compliance	opt ion	available	to	meet the	requirements	of 40	CFR	60	Subpart	IIII	for	this	c ategory	of	engines,	a	new	engi ne	would	have	to	b e	purchased	and installed	by	the	operator	to	rep lace	the	existing	engine	to	com ply	with	NSPS	IIII.

Pursuant	to	40	CFR	§	55.7,	the	EP A	may	grant	an	exemption	from a	part	55	requi rement,	if	the Administrator	or	the	delegated	a gency	finds	that	compliance	is technically	infeasible	or	will	cause	an
unreasonable	threat	to	h ealth	and	safety.		Since	the	existing	e mergency	generator	was	sized	to	meet	the drillship’s	stringent	space	and weight	distribution	requirement s	in	the	vessel’s	design	phase,	any replacement	engine	would	have	to meet	similar	physical	characte ristics	and	restricti ons	dictated	by	the vessel’s	design.		It	is	very	diffi cult,	if	not	impossible,	to	f ind	a	replacement	EPA	Ti er	2	certified	engine meeting	the	constraint s	discussed	above.		Moreover,	such	a	repl acement	will	require	significant redesign	and	recertificati on	of	the	drillship.

As	shown	in	Table	4‐3	and	Table	4‐4	below,	the	emergency	engine ’s	emission	levels	for	NO X and	PM	are higher	than	that	of	the	EPA	Tier 2	emissions	standards.		Given the	minimal	operation s	of	this	equipment resulting	in	low	emissi ons,	Anadarko	believes	that	replacement of	the	existing	emergency	engine	with an	EPA	Tier	2	certified	engine	i s	cost	prohibitive	and	therefor e,	requests	an	exemption	from	the requirements	of	40	CFR	Subpart IIII	for	the	emergency	generator engine.

Table 4

‐ 3. Emergency Generator Offset Requirements

Pollutant PTE Emissions (g/KW

‐ hr) EPA Tier 2 Standard (g

‐ KW

‐ hr) Emission
Offsets Required

NO X 7.85	 6.4	*	 Yes

CO	 0.38	 3.5	 No

PM	 0.43	 0.2	 Yes

Notes: 1) Vendor	supplied	CO	emissions	da ta	are	less	than	Tier	2	emission standards	for	CO. 2) Vendor	data	unavailable	for	PM	em issions,	therefore	Anadarko	pr oposed	PTE
calculations	for	PM	are	based	on	AP‐42	factor. *The	factor	represents	emission	limit	for	NOx	+	NMHCAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 74 Trinity Consultants Table 4

‐ 4. Emergency Generator Residual Emissions

Pollutant PTE Emissions (tpy) EPA Tier 2 (tpy) Residual

Emissions (tpy)

NOx	+	NMHC 1.64 1.34 +0.30

CO 0.08 0.73	 ‐‐

PM 0.089 0.042 +0.047



### 4.3.5.3. 

### Drillship Emergency Air Compressor (DR-AC-01)

Since	the	emergency	air	compre ssor	engine	is	a	post	2007	non‐fi re	pump	emergency	CI engine	less	than 50	HP	with	a	displacement	of	le ss	than	10	L	per	cylinder,	this engine	must	comply	with	emission

limitations	for	new	nonroad	CI	e ngines	as	specified	in	40	CFR	8 9.112	and	40	CFR	89.113.		Table	1	of	40 CFR	89.112(a)	requires	the	engine	to comply	with	the	following EPA	Tier	2	exhaust	em ission	standards:



### NO X –	7.5	g/kw‐hr CO	–	5.5	g/kw‐hr PM	–	0.6	g/kw‐hr

Additionally,	the	emergency	air	c ompressor	must	comply	with	the following	exhaust	opacity	limits specified	in	40	CFR	89.113(a):

20%	during	acceleration	mode 15%	during	the	lugging	mode 50%	during	the	peaks	in	acce leration	or	lugging	modes

Since	the	emergency	air	compresso r	is	an	EPA	Tier	2	certified	e ngine	compliance with	the	above

mentioned	emission	standard	is	d emonstrated.		In addition,	the emergency	air	compressor	must	comply with	the	diesel	fuel	requirement s	for	nonroad	diesel	under	40	C FR	80.510(b)	for	15	ppm	sulfur	content,

a	minimum	cetane	index	of	40	or	a	maximum	aromatic	content	of	3 5	volume	percent.		Anadarko	will comply	with	the	specified	fuel requirements	by	using	ULSD	for	a ll	diesel	combustion	sources.



### 4.3.5.4. 

### Drillship Temporary Third Party We ll Evaluation Engines (DR-TP-12 through DR-TP-16)

Per	40	CFR	60.4200(a)(2)(i),	above mentioned	CI	engines	are	not subject	to	this	regulation	because	the engines	were	not	manufactured	a fter	April	1,	2006.		Also,	these engines	were	not	constructed,	modified,

or	reconstructed	a fter	July	11,	2005.



### 4.3.5.5. 

### Stimulation Vessel Pumps (SV-PE-01 through SV-PE-08)

The	only	sources	utilized	for	th e	well	completion	activity	whic h	are	potentially	subject	to	NSPS	subpart IIII	are	eight	pumps	(SV‐PE‐01	thru SV‐PE‐08)	on	the	Stimulatio n	VesselAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 75 Trinity Consultants Per	40	CFR	60.4200(a)(2)(i),	all	th e	engines	above	are	not	subj ect	to	this	regulation because	the	engines were	not	manufactured	after	Apri l	1,	2006.		Also,	these	engines were	not	constructed,	modified,	or reconstructed	after	July	11,	2005.

With	regard	to	the	pumps	on	the stimulation	vessel,	they	are	“r epresentative”	pumps	only	(i.e.,	available at	the	time	of	this	report	prepar ation),	and	Anadarko	may	repla ce	these	engines	with substitute	engines with	equal	or	lesser	emissions. Therefore,	in cases	where	the substitute	engines	a re	subject	to	40	CFR 60	Subpart	IIII,	Anadarko	will	comply	with	all	applicable	requi rements.



### 4.3.6. 40 CFR 60 Subpart JJJJ – Stationary Sp ark Ignition Internal Combustion

NSPS	Subpart	JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

, provides	standards	for	manufac turers,	owners,	and	operators	of stationary	spark	ignition	(SI)	ICE.		For emergency	engines	with	a	maximum power	greater	th an	25	HP,	this subpart	provides	standards	for owners	and	operators	of	stationa ry	SI	ICE	that	commence	constru ction	after	June	12,	2006,	where	the stationary	SI	ICE	are	manufact ured	on	or	after	July	1,	2009	[40 CFR	60.4230(a)(4)(iv)].		This	subpart	is also	applicable	to	owners	and	op erators	of	stationary	SI	ICE	th at	modify	or	reconstruct	their	stationary SI	ICE	after	June	12,	2006	[40	CFR	60.4230(a)(5)].

There	are	no	stationary	SI	engines proposed	for	this	project. Therefore,	NSPS	Subpar t	JJJJ	does	not	apply to	any	source	included	in	this	permit	application.



### 4.3.7. 40 CFR 60 Subpart Dc – Standards of Performance for Small Industrial – Commercial – Institutional Steam Generating Units

A	typical	flowback	boiler	("SIGM A	FIRED"	SF‐200SE	or	equivalent )	will	be	used	for	the	well	completion activity.		Based	on	the	firing	capacity,	it	could	be	potentiall y	subject	to	40	CFR	60	Subpart	Dc.

Per	40	CFR	60.40c(a),	owners	and	o perators	of	each	steam	genera ting	unit	for	which	construction, modification,	or	reconstructio n	is	commenced	after	June	9,	1989 and	that	has	a	maximum	design	heat input	capacity	of	29	megawatts	( MW)	(100	million	British	therma l	units	per	hour	(MMB tu/hr))	or	less, but	greater	than	or	eq ual	to	2.9	MW	(10	MMBtu/hr)	should	comply to	standards	in	the	subpart.

The	maximum	design	heat	input	ca pacity	of	the	proposed	flowback boiler	is	8	MMBtu/hr	which	is	less than	10	MMBtu/hr.		Therefore,	NSP S	Subpart	Dc	does	not	apply	to this	equipment.



### 4.4. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP - 40 CFR PART 61)

Per	40	CFR	55.13(e),	40	CFR	Part 61	together	with	any	other	pro visions	promulga ted	pursuant	to

section	112	of	the	Clean	Air	Act shall	apply	to	OCS	sources	if rationally	related	to the	attainment	and

maintenance	of	federal	or	state	a mbient	air	quality	standards	o r	the	requirements	of	pa rt	C	of	title	I	of the	Clean	Air	Act	(PSD).Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 76 Trinity Consultants 

### 4.4.1. 40 CFR 61 Subpart A- General Provisions

40	CFR	61	Subpart	A	provides	the general	provisions	to	which	ea ch	source	subject to	another	Part	61 subpart	must	comply	unless	specif ically	excluded	by	the	applica ble	subpart.		These	p rovisions	include initial	notification	and	performa nce	testing,	recordkeeping,	an d	monitoring	requirements	for	all	other subparts	as	applicable.		Part 61	applies	to	owners	or	operators of	any	stationary	source	for	which	a pollutant‐specific	standard	is prescribed	under	this	part.		The re	are	no	subparts	un der	the	40	CFR	Part 61	that	applies	to	the	explorato ry	drilling	operations	proposed in	this	application.



### 4.5. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP – 40 CFR PART 63)

NESHAP	apply	to	major	sources	of HAP	or	specifically	designated area	sources	of	HAP.		A	HAP	major source	is	defined	as	having	pote ntial	emissions	in	excess	of	10 tons	per	year	for	any	individual	HAP and/or	25	tons	per	year	for	total HAPs.		The	proposed	project	r esults	in	an	area	source	of	HAP,	because potential	HAP	emissions	are	less than	the	major	source	threshol ds.		Potentially	applicable	NESHAP subparts	are	discussed	below.



### 4.5.1. 40 CFR 63 Subpart A – General Provisions

All	affected	sources	are	subject to	the	general	provisions	of	P art	63	NESHAP	Subpart	A	unless specifically	excluded	by	the	sou rce‐specific	NESHAP.		These	pro visions	include	initial	notification	and performance	testing,	recordkeepin g,	reporting,	monitoring,	and control	device	and	work	practice

standards	for	all	other	su bparts	as	applicable.



### 4.5.2. 40 CFR 63 Subpart ZZZZ – Stationary Reciprocatin g Internal Combustion Engines

NESHAPs	Subpart	ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines ,	provides	national	emission limitations	and	operating

limitations	for	HAPs	emitted	from stationary	reciprocating	inte rnal	combustion engines	(RICE) located	at	major	sources	and	area sources	of	HAP	emissions.		An adarko's	proposed	exploratory drilling	operations	will	be	an	a rea	source	for	HAPs	and	therefo re	this	Subpart	wou ld	be	potentially applicable.

Per	CFR	63.6590(a)(1)(iii),	stationa ry	RICE	located	at	an	area source	of	HAP	emissions	would	be defined	as	an	existing	source	un der	the	requirements	of	this	Su bpart	if	the	construction	or reconstruction	of	the	stationary RICE	is	commenced	before	June 12,	2006.		The	third	party	well evaluation	engines	(DR‐TP‐12	through	DR‐TP‐16)	qualify	as	exist ing	non‐emergency	stationary	RICE under	40	CFR	63,	Subpart	ZZZZ.			The se	engines	wil l	be	subject to	the	following	requirements:

Operate	and	maintain	the	stationa ry	RICE	and	after‐treatment	co ntrol	device	(if	any) according	to	the	manufacturer's emission‐related	written	instru ctions	or	develop	own maintenance	plan	which	provides to	the	extent	practicable	for	t he	maintenance	and operation	of	the	engine	in	a	mann er	consistent	with	good	air	po llution	control	practice for	minimizing	emission s	[40	CFR	63.6625(e)]. Minimize	the	engine's	time	spent at	idle	during	startup	and	min imize	the	engine'sAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 77 Trinity Consultants startup	time	to	a	period	needed	f or	appropriate	and	safe	loadin g	of	the	engine,	not	to exceed	30	minutes,	after	which	ti me	the	non‐startup	emission	st andards	apply	[40 CFR	63.6625(h)]. Comply	with	the	recordkeeping requirements	of	40	CFR	63.6655(e)

. Comply	with	the	management	pract ices	applicable	requirements	in Table	2d	of	this Subpart:

 change	oil	and	filter	every	1,000 hours	of	operation	or	annuall y,	whichever comes	first;

 inspect	air	cleaner every	1,000	hours	of	operation	or	annually, whichever comes	first,	and	replace	as	needed;	and

 inspect	all	flexible	hoses	and	b elts	every	500	hours	of	operati on	or	annually, whichever	comes	first,	a nd	replace	as	needed. Per	40	CFR	63.6660,	records	of	mana gement	practices	discussed	a bove	need	to	be	kept in	readily	accessible	hard	or	elec tronic	form	for	at	least	5	ye ars	following	the	date	of each	maintenance	activity.		At	a minimum,	the	most	recent	2	yea rs	of	data	shall	be

retained	on	site	and the	remaining	3	years of	data	may	be	retai ned	off	site.

The	following	engines on	the	Drillship	quali fy	as	new	stationar y	RICE	under	this	reg ulation	because	the engines	were	constructe d	after	June	12,	2006.

Drillship	Main	engines	(DR‐ME‐01	through	DR‐GE‐08) Drillship	Emergency	G enerator	(DR‐GE‐01) Drillship	Emergency	Air	Compressor	(DR‐AC‐01)

Pursuant	to	§	63.6590(c)(1)	of	this subpart,	a	new	CI	RICE	loca ted	at	an	area	sourc e	must	comply	with 40	CFR	part	60,	subpart	IIII,	an d	no	further	requirements	apply for	such	engines	under	40	CFR	part	63. Therefore,	the	engines	will	comp ly	with	40	CFR	part	60,	subpart IIII,	and	will	not	b e	subject	to	any further	requirements	u nder	this	subpart.



### 4.5.3. 40 CFR 63 Subpart HHHHHH – Paint Stri pping and Miscellaneous Surface Coating Operations at Area Sources

NESHAPs	Subpart	HHHHHH	provides	n ational	emission	limitations	a nd	operating	limitations	for	HAPs emitted	from	paint	stripping	and miscellaneous	surface	coating operations	performed	at	area	sources	of

HAP	emissions.

Anadarko's	proposed	exploratory drilling	operations	will	be	an area	source	for	HAPs	and	therefore	this Subpart	would	be	potentially	appl icable.		The	spray	painting	op eration	performed	on	the drillship	is	part of	the	routine	maintenance	to	pr otect	the	vessel	from	the	harsh environment	so	th at	the	drillship functions	in	its	intended	capaci ty.		Therefore,	this	activity	m eets	the	definition	of	“f acility	maintenance” provided	in	40	CFR	63.11180.		Pursuant	to	40	CFR	63.11170(a)(3) ,	spray	painting	operations	on	the drillship	are	not	subject	to	the requirements	of this	regulatio n.



### 4.6. FEDERAL OPERATING PERMITS PROGRAM (40 CFR PART 71)

The	Federal	Operating	Permits	Pro gram	(40	CFR	71)	sets	forth	th e	comprehensive	Fed eral	air	quality operating	permits	permitting	progr am	consistent	with	the	requir ements	of	Title	V	of	the	Clean	Air	ActAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 78 Trinity Consultants and	defines	the	requi rements	and	the	corresponding	standards	an d	procedures	by	which	the

Administrator	will	issu e	operating	permits. 6 Using	the	procedures	of	40	CF R	71,	the	Admini strator	will issue	permits	to	any	source	whic h	is	an	OCS	source	that	is	loca ted	beyond	25	miles	of	States'	seaward boundaries,	as	defined	under	40	CFR	55.2. 7

A	major	source	is	defined	under 40	CFR	71	as,	“A	major	stationa ry	source	of	air	pollu tants	or	any	group of	stationary	sources	as	defined	in	section	302	of	the	CAA,	tha t	directly	emits,	or	ha s	the	potential	to emit,	100	tpy	or	more	of	any	air	pollutant.” 8 Per	this	definition,	the	propo sed	project	is	a	major	source under	40	CFR	71	and	shall	obtain	a	Title	V	Operating	Permit.

All	major	sources	under	this	sub part	shall	be	subject	to	the	ge neral	monitoring, recordkeeping,	and reporting	requirements	as	provid ed	under	40	CFR	71,	unless	othe rwise	specified.		In addition,	each	Part 71	source	is	required	to	submit	a n	annual	report	containing	the actual	emissions for	the	preceding calendar	year,	a	fee	calculations work	sheet,	and	a	full	paymen t	of	the	annual	fee	as	required	under	40 CFR	71.9(h).		Anadarko	will	compl y	with	the	requirement	to	subm it	annual	emission	report	and	pay such	annual	fees	as	required.



### 4.7. ENGANGERED SPECIES ACT

Under	Section	7	of	the	Endangere d	Species	Act	(ESA),	16	U.S.C. §	1536,	EPA	has	a	responsibility	to ensure	that	any	action	authorized or	permitted	by	EPA	is	not	li kely	to	jeopardize	the	continued existence	of	any	federally‐liste d	endangered	or	threatened	spec ies	or	result	in	the	destruction	or adverse	modification	of	such	spe cies’	designated	critical	habit at.		If	EPA’s	action	(i. e.,	permit	issuance) may	affect	a	federally‐listed	sp ecies	or	critical	habitat,	Sect ion	7	of	the	ESA	sets	up	a	procedure	for

consultation	between	EPA	and	U.S .	Fish	and	Wildlife	Service	(US FWS)	and/or	the	National	Oceanic	and Atmospheric	Administration’s	Nat ional	Marine	Fisheries	Service (NMFS).

BOEM	issued	an	environmental	assessment	 (EA)	 for	 the	 Central	an d	Western	 Planning	Areas	in	 2012 (Post	Macondo	Oil	Spill).		Currently,	BOEM	is	preparing	a	draft for	 the	Eastern	Planning	Area	which	is expected	to	be	completed	by	th e	end	of	2013.		Per	a	discussion between	Trinity	and	t he	National	Oceanic and	 Atmospheric	 Administration	 (NOAA) 9 ,	 no	 new	 protected	 species	 have	 been	 listed	 in	 the	 Gulf	 of Mexico	 since	 the	 2007	 biological	 opinion;	 hence,	 no	 further	 act ion	 is	 required	 from	 Anadarko	 to demonstrate	compliance

6 40	CFR	71.1(a)

7 40	CFR	71.4(d)(1)

8 40	CFR	71.2

9 Per phone email communication with Mr. Rahul Pendse and Mr. Adam Brame on 08/06/2013Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 79 Trinity Consultants 

## 5. BACT ANALYSIS

As	required	by	40	CFR	§52,	Best	Av ailable	Control	Technology	(B ACT)	must	be	applied	to	reduce	or

eliminate	air	emission s	from	a	new	or	modified	facility.		PSD	B ACT	is	defined	40	CFR	§52.21(b)(12)	as:

“An emissions limitation (including a visible emission standard) based on the maximum degree of reduction for each pollutant subject to regulation under Act which would be emitted from any proposed major stationary source or major modification which the Administrator, on a case

‐ by

‐ case basis, taking into

account energy, environmental, and economic impacts and other costs, determines is achievable for such

source or modification through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of

such pollutant. In no event shall application of best available control technology result in emissions of any pollutant, which would exceed the emissions allowed by any applicable standard under 40 CFR parts 60

and 61. If the Administrator determines that technological or economic limitations on the application of

measurement methodology to a particular emissions unit would make the imposition of an emissions

standard infeasible, a design, equipment, work practice, operational standard, or combination thereof, may be prescribed instead to satisfy the requirement for the application of best available control technology.

Such standard shall, to the degree possible, set forth the emissions reduction achievable by implementation of such design, equipment, work practice or operation, and shall provide for compliance by means which

achieve equivalent results.”

EPA	has	developed	a	“top‐down”	p rocess	that	can	be	used	to	ensu re	that	a	BACT	analysis	satisfies	the applicable	legal	criteria.		Presen ted	below	are	the	five	basic steps	of	a	top‐down	BACT	review	as identified	by	the	EPA. 10

STEP 1

– IDENTIFY ALL CONTROL TECHNOLOGIES Step	1	of	the	top‐down	approach requires	that	all	available	con trol	options	that	are	potentially applicable	to	the	proposed	sourc e	are	identified.		It	is	the	ap plicant’s	responsibility to	identify	available control	options	by	consulting	the	EPA’s	Reasonably	Available	Co ntrol	Technology	(RACT)/BACT/Least Achievable	Emission	Rate	(LAER)	clearinghouse	(RBLC),	along	wit h	other	reliable	sources.		Viable control	options	are	those	techno logies	that	have	a	practical	po tential	for	application	to	the	emissions unit	and	the	regulated	pollutant	under	evaluation.

STEP 2

– ELIMINATE TECHNICALLY INFEASIBLE OPTIONS Step	2	of	the	top‐down	approach	allows	for	the	elimination	of	c ontrol	options	tha t	are	technically infeasible.		Also,	each	technolo gy	should	be	“demonstrated”	(pr eviously	installed	and	operated successfully	on	a	similar	facility );	or	if	undemonstrated,	then the	applicant	must	d etermine	whether	the technology	is	both	“available”	a nd	“applicable.”		Technologies identified	in	Step	1	that	are	neither demonstrated	nor	found	to	be	both	available	and	applicable	are eliminated	under	Step	2.

STEP 3

– RANK REMAINING CONTROL TECHNOLOGIES Step	3	of	the	top‐down	approach requires	ranking of	the	remaini ng	control	technol ogies	based	on

control	effectiveness.		If	there is	only	one	remaining	option	o r	if	all	of	the	remaini ng	technologies	could achieve	equivalent	control	effici encies,	ranking	based	on	contr ol	efficiency	is	not	required.

10 U.S.	EPA. Draft New Source Review Workshop Manual ,	Chapter	B.	Research	Triangle	Park,	North	Carolina,	October	19 90.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 80 Trinity Consultants STEP 4

– EVALUATE MOST EFFECTIVE CONTROLS Step	4	of	the	top‐down	approach	allows	for	the	elimination	of	c ontrol	options	based	on	collateral impacts.		In	descending	order,	the	applicant	should	evaluate	an d	compare	the	collateral	impacts	of	each control	option.		The	permitting	a uthority	(EPA)	has	discretion on	weighting	each area	of	collateral impact.		This	step	validates	the	suitability	of	the	top	control option	identified	or	provides	a	clear justification	as	to	why	the	top option	should	not	be	selected	a s	BACT.		Costs	of	installing	and	operating control	technologies	are	estimate d	and	annualized	following	the methodologies	outlined	in	the	U.S.

EPA’s OAQPS Control Cost Manual (CCM). 11

STEP 5

– SELECT BACT Step	5	of	the	top‐down	approach requires	selection	of	BACT	for the	emissions	unit	and	the	regulated pollutant	under	evaluation.		The	m ost	effective	control	alterna tive	not	eliminated	in	Step	4	is	selected	as BACT	with	a	corresponding	emission limit	established.		The	sele ction	of	BACT	in	the	fifth	step	involves

an	evaluation	of	emission	rates	a chievable	with	the	selected	co ntrol	technology.		BACT	is	an	emissions limit	unless	technological	or	economic	limitations	of	the	measu rement	methodology	would	make	the imposition	of	an	emissi ons	standard	infeasible,	in	which	case	a work	practice	or	operating	standard	can be	imposed.		Selected	BACT	can	b e	no	less	string ent	than	an	app licable	NSPS,	MACT,	or	RACT.

The	emissions	of	NO X ,	CO,	PM,	PM 10 ,	PM 2.5 ,	VOC,	and	GHG	exceed	the	appl icable	SERs.		Therefore	PSD

BACT	must	be	determined	for	each emission	unit	at	the	facility that	emits	NO X ,	CO,	PM,	PM 10 ,	PM 2.5 ,	VOC or	GHG	when	conducting	the	proposed	operations.

The	emission	sources	o n	the	drillship	subjec t	to	BACT	analysis are	as	listed	below:

Eight	main	engines	(DR‐ME‐01	to	DR‐ME‐08) One		emergency	generator	(DR‐GE‐01) One	emergency	air	compressor		engine	(DR‐AC‐01) Third	party	engines: Third	party	EPA	Tier	II	certifie d	engines	≤860	HP	(DR‐TP‐01	and Dr‐TP‐02) Third	party	EPA	Tier	II	certifie d	engines	≤300	HP	(DR‐TP‐03	to DR‐TP‐11) Third	party	well	evaluation	engi nes	≤140	HP	(DR‐TP‐12	to	DR‐TP‐ 16	and SB‐TP‐05	to	SB‐TP‐09) Third	party	EPA	Tier	II	certifie d	engines	≤126	HP	(DR‐TP‐17	to DR‐TP‐21) One	flowback	boiler	(DR‐TP‐22) One	boom	flare	(DR‐TP‐23) Fuel	storage	tanks	(several	EPNs) Painting	(DR‐PO‐01) Welding	(DR‐WO‐01)

Under	certain	operating	scenarios ,	the	following	sources	of	air pollution	will	cons titute	stationary source	aspects	of	the	vessels	w hen	the	support	vessels	are	phys ically	attached	to	the	OCS	source;	hence, BACT	analysis	is	performed	for	these	sources.

Fuel	Storage	Tanks	on	the	supply boats	and	the	anchor	handling boat	(several	EPNs)

11 Office	 of	 Air	 Quality	 Planning	 and	 Standards	 (OAQPS), EPA Air Pollution Control Cost Manual ,	 Sixth	 Edition,	 EPA	 452‐02‐001 (http://www.epa.gov/ttn/catc/pr oducts.html#cccinfo),	Daniel	C. Mussatti	&	William	M.	Vatavuk,	January	2002.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 81 Trinity Consultants Eight	pump	engines	on	the	Stim ulation	Vessel	(SV‐PE‐01	thru	SV‐ PE‐08)

The	life	boats	(DR‐LB‐01	and	DR‐LB‐06)	and	the	fast	rescue	boat (DR‐FR‐01)	are	included	in	the	PTE calculations	and	air	dispersion modeling	as	specified	in	40	CFR part	55	and	these	sour ces	are	subject	to operating	limits,	monitoring,	rec ordkeeping	and	reporting	requi rements	to	ensure	they will	not	exceed the	potential	emissions	assumed in	the	application	and	impact	r eview.			Per	40	CFR	§	55.2,	the	support vessels	operating	within	25	miles of	the	OCS	source	are	not	sub ject	to	BACT	requirem ents	unless	they

are	attached	to	the	OC S.		If	attached,	only	the	stationary	sour ce	aspects	of	the	vessel	are	regulated.

These	units	do	not	hav e	any	stationary	sourc e	aspects	with	resp ect	to	BACT	subject	pollutant	emissions, as	they	are	used	for	man	overboa rd	and	emergency	escape	scenari os	only.



### 5.1. NO X 

### BACT ANALYSIS

The	emission	s ources	of	NO X on	the	drillship	subject	to	BACT	analysis	are	as	listed	below:

Eight	main	engines	(DR‐ME‐01	to	DR‐ME‐08) One		emergency	generator	(DR‐GE‐01) One	emergency	air	compressor		engine	(DR‐AC‐01) Third	party	engines:

 Third	party	EPA	Tier	II	certifie d	engines	≤860	HP	(DR‐TP‐01	and Dr‐TP‐02)

 Third	party	EPA	Tier	II	certifie d	engines	≤300	HP	(DR‐TP‐03	to DR‐TP‐11)

 Third	party	well	evaluation	engi nes	≤140	HP	(DR‐TP‐12	to	DR‐TP‐ 16	and SB‐TP‐05	to	SB‐TP‐09)

 Third	party	EPA	Tier	II	certifie d	engines	≤126	HP	(DR‐TP‐17	to DR‐TP‐21) One	flowback	boiler	(DR‐TP‐22) One	boom	flare	(DR‐TP‐23) Eight	pump	engines	on	the	Stim ulation	Vessel	(SV‐PE‐01	thru	SV‐ PE‐08)



### 5.1.1. NO X 

### BACT Analysis for the Drillship Ma in Engines (DR-ME-01 to DR-ME-08)

Deepwater	drilling	wit h	a	dynamically	posit ioned	drillship	pres ents	a	unique	set	of	challenges	in managing	power	while	conducting	work.	The	drillship	is	designed to	operate	in	deep	water	in	highly variable	operational	and	environ mental	conditions.		The	need	fo r	power	redundanc y	to	manage	the operating	risks	affects	the	power use	levels,	which	in	turn	aff ects	the	air	emissions.

The	main	propulsion	en gines	are	used	to	po wer	the	thrusters	tha t	hold	the	ship	on	location,	as	well	as power	the	drilling	equipment	a nd	other	operational	needs	of	the ship.		The	main	propulsion	engines operate	at	variable	loads	based	o n	drilling	and	operational	pow er	demand,	and	extensive	“reserve” power	is	required	to	adjust	for loop	currents	and	storms	which can	cause	large	vari ations	in	thruster power	used.		Hence,	NO X emissions	are	not	emi tted	from	these	engines	at	a	steady	state .		These	factors are	important	considerations	in	t he	BACT	analysis	for	these	eng ines.



### Step 1

– Identify all Control Technologies

The	first	step	in	the EPA	top‐down,	five‐ste p	analysis	is	to	id entify	all	available	control	technologies	that are	potentially	suitable	for	the affected	sources.		EPA's	RBLC search	was	used	to	obtain	potential	controlAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 82 Trinity Consultants technologies	for	NO X from	main	propulsion	engines	at	offshore	sources.		The	most	re cent	10‐year	period was	used	to	identify	applicable	c ontrol	technologies.		The	resu lts	of	the	RBLC	search	are	included	in Appendix	E.		However,	it	should	b e	noted	that	the	control	techn ologies	evaluated in	the	“topdown” analysis	for	main	engi nes	were	not	limited to	the	controls	list ed	in	the	RBLC	dat abase.		The	permits recently	proposed/issued	by	U.S.	E PA	Region	4	and	Region	10	(an d	corresponding	permit	applications)

for	similar	OCS	sources	in	Gulf of	Mexico	have	a lso	been	review ed	in	addition	to	su rveying	available literature	to	identify	potential control	technologies.		The	sea rch	results	for	potential	control technologies	for	NO X from	the	main	engin es	are	listed	below.

1. Selective	Catalytic	Reduction	(SCR)

2. Selective	Non‐Catalytic	Reduction	(SNCR)

3. Direct	Water	Injection	(DWI)

4. Exhaust	Gas	Recirculation	(EGR)

5. Derate	Engines

6. Water‐in‐fuel	Emulsions

7. Intake	Air	Humidification/Cooling

8. NO X Adsorber

9. CSNO x Emissions	Abat ement	System

10. Replacement	of	Engines	to	meet	h igher	EPA	Tier	st andards	(40	CF R	part	89,	94,	or	1042)

11. CAM	Shaft	Replacement/ Retooling	of	Engines

12. Lean	De‐NO X Catalyst	(LNC)	or	Hydrocarbon	SCR	(HC‐SCR)

13. Low	NO X Engine	(LNE)	design

14. Performance	management system	including	Tu rbocharger	with	After cooler	and	High	Fuel Injection	Pressure	System

15. 4‐Way	Catalyst	Converter

16. Good	Combustion	and	Manufacturer Recommended	Maintenance	Practi ces

17. Ignition	Timing	Retard	(ITR)



### Step 2

– Eliminate Technically Infeasible Option

SCR – Infeasible.

SCR	is	a	post‐combustion	NO X control	technology.		In	SCR,	ammonia	(NH 3 )	or	urea	diluted	with	air	or steam	is	injected	into	the	flue gas	upstream	of	a	catalytic	rea ctor.		The	catalyst	bed	operates	at temperatures	between	600	and	800 °F,	depending	on	the	catalyst. On	the	catalyst	surface,	the	NH 3 reacts	with	NO X to	form	molecular	n itrogen	and	water.

The	primary	variable	affecting	NO X reduction	is	temperature	of	the gas	stream.		If	operating	belo w	the optimum	temperature	range,	the	c atalyst	activity	is	reduced	all owing	unreacted	NH 3 to	slip	through.		If operating	above	the	optim um	temperature	range,	NH 3 is	oxidized,	form ing	additional	NO X and	the catalyst	may	suffer	thermal	stress	damage.

The	highly	variable	power	use	in herent	to	operations	on	a	dynam ically	positioned	drillship	creates

circumstances	that	are	unfavorabl e	for	the	SCR	process.		The	po wer	load	variability	requires	a corresponding	high	level	of	pow er	redundancy	to	ensure	reliable station	keeping.		This	redundancy	can

result	in	lower	level s	of	power	capacity	u sed	over	extended	per iods	(e.g.	during	strong	loop	currents	orAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 83 Trinity Consultants winter	storms).		When	the	engine s	are	run	at	low er	capacity,	th e	engine	exhaust	tem peratures	can	drop

to	levels	that	reduc e	the	effectiveness	of	SCR	technology.

Urea	slip	rates	can	occur	that	d o	not	allow	the	catalytic	reduc tion	of	NO X to	the	predicted	levels.		The volume	of	urea	required	for	optim al	SCR	performance	is	substant ial;	approximately	20	to	25	g	of	urea solution/KW‐hr	engine	output.		H ence,	additional	tanks	would	be added	onboard	for	urea	storage.		Since these	additional	storage	tanks	w ere	not	a	part	of	initial	drill ship	design,	addition	of	these	tanks	will require	considerable	redesign	to	e nsure	load	balancing	and	othe r	critical	criteria are	complied	with. Moreover,	since	limited	space	is available	for	critical	drillin g	equipment,	tubulars	and	consumables,	the handling	and	storage	of	urea	onb oard	presents	difficult	operati onal	challenges.

Although	SCR	technology	has	been utilized	at	onshore	sources,	i t	has	not	been	successfully	proven	as	a viable	control	technology	for	so urces	such	as	main	engines	on	t he	drillship.		This	technology	has	been proven	successful	for	steady	st ate	load	conditions.		However,	d ue	to	nature	of	operations,	main	engines on	the	drillship	have	frequent	load	variations,	which	could	sig nificantly	impact	emission	control efficiency	of	SCR	technology.

While	the	accommodation	of	SCRs	is	less	difficult	in	the	design stage	of	a	drillship,	post	design	addition of	SCRs	would	require	significan t	space	reassignment	and	will	i mpact	deck	load	capacity	and	stability (i.e.,	center	of	gravity)	of	the currently	designed	drillship. However	for	completeness,	Anadarko	is including	the	cost	analysis	for SCR	installation	below	which	re affirms	the	cost	pro hibitive	nature	of installing	an	SCR.

SNCR – Infeasible

.

This	technology	is	technically	i nfeasible	to	operate	on	the	mai n	engines	of	the	BlackHornet	drillship.

This	method	of	NO X reduction	introduces	new	compou nds	(most	commonly	ammonia	or	u rea)	to	the

diesel	exhaust	whi ch	break	down	NO X molecules	into	nitrogen	and	oxygen,	much	like	an	SCR.		SNCR systems	can	realize	NO X reductions	of	60%,	but	only	a t	temperatures	g reater	than	1,700 °F.		At	lower temperatures,	the	reaction	proc eeds	too	slowly,	resulting	in	un used	ammonia	emitting	from	the	stack. Because	this	temperature	is	well above	the	exhaust	gas	temperat ure	range	of	the	main	engines,	this option	was	not	deemed	to	be	techn ically	feasible	for	this	appli cation.

In	addition,	this	technology	is	a lso	infeasible	for	the	reasons provided	for	SCR	above,	pertaining	to	urea storage	requirements	and	significa nt	structural	changes	that	wi ll	impact	deck	load	capa city	and	stability. 

### Due	to	the	reasons	discussed	above,	this	technology	is	deemed	a s	technologically	infeasible.

DWI – Infeasible

.

This	control	technology	involves reduction	in	combustion	temper ature	by	mixing	st eam	or	water	with

the	air	flow.		Steam	o r	water	acts	as	a	heat sink	to	reduce	pea k	temperatures,	thereby	reducing	the

formation	of	NO X .		NO X reductions	of	25‐35	p ercent	can	be	achieve d	with	water	injecti on. 12 

### This technology is in development stages for marine applic ations and cannot be used reliably at low loads (30- 50%) or variable loads.

12

Based on Memorandum from Tanya Parise, Alpha-Gamma Technologies, Inc. to Sims Roy, EPA OAQPS ESD Combustion Group, titled NOx Control Technologies for Stationary Diesel ICE

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 84 Trinity Consultants 

### Also, fresh water is necessary for this NO X 

### reduction technology. Introducing salt water into the engines

could result in serious deterioration due to corrosion and fouling. For this reason, implementing this strategy would require either production of fresh wa ter through the use of desalination or distillation system or the storage of fresh water on board. Theref ore, either pure water storage tanks would need to

be constructed or the alternative of installing a desalination or distillation unit would incur additional

costs for the unit. Both altern atives would also require additiona l space and would potentially require

recertification of the vessel.

Another	concern	with	the	use	of	w ater	in	the	combustion	process is	the	effect	on	PM/PM 10 /PM 2.5 emissions.

The	water	in	the	c ylinder	reduces	NO X ,	which	is	formed	at	high	temper atures,	by	reducing	the	tempera ture	in the	cylinder	during	combustion.		However,	PM/PM 10 /PM 2.5 oxidation	is	most	efficient	at	high	temperatures. Therefore,	while	water	injecti on	may	lead	to	reduction	in	NO X emissions,	there	may	be	an	increase	in PM/PM 10 /PM 2.5 emissions.		There	is	also	a	potential	for	engine	damage	to	occ ur	as	a	result	of	the	water contacting	the	combustion	cylinde r	surface	causing	disintegrati on	of	lubricating	oil	film.		Due	to	the	reasons discussed	above,	this	technology is	deemed	as	technologically	i nfeasible.

EGR – Infeasible

.

EGR	works	by	re‐circulating	a	fr action	of	an	engine's	exhaust	g as	back	to	the	engine	cylinders.		In	this technology,	the	amount	of	oxygen in	the	air/fuel mixture	is	red uced	causing	the	engine	to	run	less	lean. This	in	turn	lowers	the	operating temperature	of	the	engine.		B ecause	NO X formation	increases	at	higher temperature,	a	reduction	in	the operating	temperature	will	resu lt	in	a	reduction	in	NO X formation.

Applying	EGR	to	a	diesel	RICE	ca n	reduce	the	power	that	is	gene rated	by	the	engine.		This	is	because	the EGR	system	reduces	the	specific heat	ratio	of	the	combustion	ga ses	in	the	power	stroke,	which	in	turn reduces	the	amount	of	power	or	wor k	that	can	be	extracted	by	th e	piston.		The	red uction	in	power generation	could	lead	to	potential	safety	hazards.

Applying	EGR	may	reduc e	the	amount	of	fuel	t hat	is	completely	c ombusted	thereby	increasing	the PM/PM 10 /PM 2.5 emission	rate.		Due	to	the	reaso ns	discussed	above,	this	techno logy	is	deemed	as technologically	infeas ible.		In	addition, the	technology	is	still	unde r	development	for	marine applications;	hence,	this	techno logy	is	considered	as	technolog ically	infeasible.

Derate Engines – Infeasible

.

An	engine	can	be	derated	by	restr icting	its	operation	to	lower levels	of	power	than	normal	for	the	given application.		Derating	reduces	c ylinder	pressures	and	temperatu res	and	can	lower	NO X formation	rates. Engine	derating	is	accomplished	b y	changing	the	injector	nozzle s	with	smaller	holes	to	atomize	the

smaller	amount	of	fuel used	and	the	turboc harger	nozzle	rings	c an	be	allowed	a	low er	exhaust	gas	spin the	turbocharger	faster,	thus	co mpressing	a	greater	volume	of	a ir	for	a	given	volume	of	gas.

Derating	reduces	the	engine's	operating	temperature,	which	can result	in	higher	CO	and	VOC	emissions. Further	derating	the	engines	wi ll	decrease	the	available	power, which	would	cause	an unreasonable	safety risk.		The	safety	concern	would be	that	the	drillship	must	have adequate	power	to	handle	storms	(e.g.,	winter weather	or	hurricanes)	and	loop currents	that	periodically	occu r	at	the	location.		Due	to	the	reasons discussed	above,	this	technology is	deemed	as	technologically	i nfeasible.

Water

‐ in

‐ fuel Emulsions (emulsified diesel) – Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 85 Trinity Consultants This	technology	would require	derating	of	th e	engines,	and	emul sified	diesel	in	marin e	vessels	can	cause

fuel	tank	corrosion	issues.		Addi tionally,	emulsified	fuel	syst ems	were	designed	for	and	installed	on slow‐speed	engines	burning	heavy fuel	oil.		The	existing	main	e ngines	on	the	BlackHornet	drillship	are designed	and	will	be	burning	medium	density	fuel	(diesel).		Sev eral	significant	engi neering	hurdles	must

be	overcome	in	order	to	install a	diesel/water	em ulsion	system on	board	the	BlackHornet	drillship.

The	primary	hurdle	is the	installation	of	a	mixing	tank.		The	c urrent	design	of	the drillship	does	not include	a	space	for	a	mixing	tank.		The	installation	of	a	new	t ank	would	require	exte nsive	analysis,	pipe fitting	and	modification	to	monit oring	systems	aboard	the	rig. The	tank	may	also	need	to	be	pressurized

to	maintain	the	emulsion	which	w ould	require	the	installation	o f	booster	pumps	an d	the	associated piping,	power	and	moni toring	systems	inheren t	in	such	a	configu ration.		The	pressurized	fuel	would increase	pressure	head	that	alrea dy	exists	in	the	fuel	lines	an d	could	lead	to	excessi ve	fuel	pressure	to the	engines.		Over‐pressurized	fu el	lines	subjected	to	loads	in excess	of	their	design	criteria	would potentially	fail	with	catastrophic	results	such	as	spilled	fuel ,	engine	room	fires	or worse.		Such	a	problem would	place	the	safety of	the	rig,	personne l	and	environment	in jeopardy.		Installing	an	untested emulsified	fuel	system	designed for	heavy	fuel	oil	use	on	the	e xisting	engines	increa ses	the	potential	for mechanical	failure	and	poses	a	safety	risk	that	is	unacceptable for	this	project.		Due	to	the	reasons discussed	above,	this	technology is	deemed	as	technologically	i nfeasible.

Intake Air Humidification/Cooling – Infeasible

.

Intake	Air	Humidification	consis ts	of	fogging	or	saturation	of the	intake	air	with	water.		These	motors consist	of	evaporating	water	into the	relatively	hot	scavenging air,	which	flows	to	the	engine	through	the inlet	air	manifold.		Installation	of	a	Humid	Air	Motor	(HAM)	is an	alternative	to	wat er	injection	currently being	investigated	by	some	d iesel	engine	manufacturers.

Reductions	in	NO X emissions	due	to	water	injection can	be	expected	using	this	te chnique	but	the	long term	effects	of	using	seawater	(i f	used)	is	not	known.		Such	te chnology	can	require additional	freshwater production	and	storage	for	humid ification	of	the	intake	air.		A high	quantity	of	water	need	to	be evaporated	to	create	enough	humi d	air	to	achieve	the	reductions sought,	and	are	comparable	with	the fuel	volumes.		This	requires	heat input	and	is	provided	by	heat exchange	from	the	hot	compressed	air after	the	engine	turbocharger.		T his	implies	that	at	low	load	t here	may	not	be	suffici ent	heat,	in	which case	the	HAM	system	is	not	used.

It	is	also	hard	to	control	the	humidity	adequately	under	varyin g	loads	(when	it	is	most	difficult	to achieve	optimum	combustion).		In addition,	the	technology	is	in development	stages	for	marine applications,	and	not	available for	the	main	propulsion	engines operating	on	the	BlackHornet	drillship. Therefore,	considering	the	aforem entioned	reasons,	Intake	Air	H umidification/Cooling	is	not	technically

feasible.

NO X Adsorber – Infeasible

.

A	NO X adsorber	is	a	catalyst	te chnology	used	to	remove	NO X in	lean	exhaust	for	diesel	and	gasoline	fired engines.		NO X adsorbers	consist	of	ceramic	monolith	containing	parallel	chan nels,	coated	with	precious metal	catalysts.		During	lean	operation,	NO X is	stored	in	the	form	of	nitr ates	produced	by	reactions

between	the	NO
x and	catalyst.		At	regular	intervals,	a	momentary	reducing	cond ition	is	produced	inside the	monolith	by	injecting	reducta nt,	causing	the	nitrates	to	de compose	to	nitrogen.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 86 Trinity Consultants This	technology	has	been	used	pr imarily	for	on‐road	diesel	appl ications	or	off‐road	applications	for smaller	engines	such	a s	backhoes,	graders,	and	wheel	loaders. This	technology	is	still	a	technology	that is	in	experimental	stages	of	dev elopment	stages	for	marine	appl ications.

CSNOx Emissions Abatement System – Infeasible

.

This	technology	is	currently	in	t he	licensing	and commercial	de monstration	phases	of	development. This	system	is	tested	on	engines operating	at	stable	loads.		Wh ile	this	technology	is	commercially available	for	certain	types	of	m arine	uses,	it	has	not	been	dem onstrated	in	practice	for	variable	load engines	such	as	main	engines	on the	drillship.		Since	significa nt	research	and	develo pment	is	required	to design	a	working,	deployable	CSN Ox	system	that	is	safe	to	opera te	on	a	drillship,	this	technology	is considered	technically	infeasible.

CAM Shaft Replacement/Retooling of Engines – Infeasible

.

Clean	Cam	Technology	Systems	(CCT S)	offers	retrofit	cam	shaft	r eengineering	kits	for	some	diesel engines.		The	kits	reduce	NO X emissions	by	increasing	the	volum e	of	the	residual	exhaust	gas that

remains	in	the	combustion	cha mber	after	the power	stroke.

CCTS	cam	shaft	retrofit	(Re‐toolin g)	kits	are	only	available	fo r	Detroit	Diesel	engines .		This	technology	is only	suitable	for	small	engines since	the	cams	are	integral	wit h	the	camshaft.		The	cams	are	mounted	on the	camshaft	individually	and	can be	easily	replaced	for	smalle r	engines	(most	likely 2‐stroke	engines). However,	it	has	not	yet	been	dev eloped	for	larger	engines	(e.g. ,	4‐	stroke).		Therefore, it	is	not	t echnically

feasible	for	the	main propulsion	engines.

LNC or HC

‐ SCR – Infeasible

.

This	technology	is	not	commercia lly	available	for	large	marine engines	of	marine	applications.		Also,	LNC systems	operate	best	at	consiste nt	high	loads,	and	are	not	amen able	to	load	shifts.		Therefore,	it	is	not technologically	feasible	for	the	main	engines.

Engine Replacement To Meet Higher Tier Standards (40 CFR Part 89, 94, or 1042) – Infeasible

.

The	main	diesel	engines	meet	the	IMO	Tier	2	standard	of	9.7	g/K w‐hr		for	engines	under	Category	3	(i.e., >30	liter/cylinder	displacement	o perating	at	720	rpm).		This	em ission	standard	is	equal	to	the	EPA	Tier 2	(40	CFR	Part	1042)	standards	for	NO X for	this	category	of	engine.		C urrently,	there	is	no	comparable engine	available	that	meets	low er	emission	standards	without	th e	use	of	add‐on	control	technology. Therefore,	replacement	engines	w ith	higher	Tier	ra ting	is	not	a n	option.

Moreover,	certification	to	meet	t hese	standards	is	part	of	the inherent	design	of	the engine	and	there	is no	upgrade	available	for	an	exis ting	IMO	Tier	2	certified	engin e	to	meet	more	string ent	standards	which will	also	require	recer tification	from	the engine	manufacturer. Considering	the	aforementioned	reason replacing	the	existing	engine	to meet	a	higher	Ti er	standards	i s	not	a	feasible	option.

4

‐ Way Catalyst Converter – Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 87 Trinity Consultants The	main	diesel	engines	will	not	be	able	to	sustain	constant	st eady	state	loads/exhaust	temperatures	for sufficient	time	period s	that	are	critical	for	high	catalyst	per formance,	resulting	in	inconsistent	emission

control.		Several	non‐combustibl e	chemical	elements	that	may	be present	in	engine	lube	oils,	such	as phosphorous,	lead	and	heavy	meta ls,	may	collect	over	time	and	d amage	the	catalyst.		T herefore,	it	is	not technically	feasible	for	the main	propulsion	engines.

ITR – Infeasible.

Changing	ignition	timing	is	not an	alternative	for	these	engine s	due	to	intrinsic	engine	design.	Alterations of	 the	 injection	 timing	 can	 impact	 value	 and	 turbo	 charger	 perf ormance.	 	 Additionally,	 use	 of	 this technology	can	 reduce	engine	pow er	and	combustion	stability	whi ch	can	hinder	operations.	For	 these reasons	this	technology	is	infeas ible	for	the	main	engines	on	B lackHornet	drillship.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 1. Ranks of Technologies Feasible for Main Engines

Technology Efficiency Rank SCR	with	Urea	Injection	 79% 13 1 Performance	manageme nt	system	including Turbocharger	with	Aft ercooler	and	High	Fuel Injection	Pressure	System ~30%	 2

LNE	design		 Baseline	 3

Good	Combustion	and	Manufacturer

Recommended	Maintenance	Practices Baseline	 N/A

All	feasible	technologies	for	th e	main	propulsion	engines	are	l isted	in	Table	5‐1.		Control	technologies	are ranked	by	efficiency	i n	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document Results

SCR –	Based	on	the	very	conservativ e	cost	assumptions	(i.e.,	low	c ost),	the	cost	effect iveness	analysis	of

SCR	installation	is	estimated to	be	approximately	$12,000	per	t on	of	NO X reduced,	making	this	option cost	prohibitive.		A	detailed	co ntrol	cost	effectiveness	analys is	is	provided	in	Appendix	E.

Performance Management System including Turbocharger with Aftercooler and High Fuel Injection Pressure System and Low NO x Design

– The	main	engines	are	eq uipped	with	a	performance management	system	(als o	called	as	“optimized	supercharger	with miller	cycle	technology”	by	the manufacturer),	which	is useful	to	reduce	the	NO X emission	by	optimizing	the	intake	valve's	closing timing	especially,	result	in	cha nging	the	effective	compression and	expansion	ratio.		In	order	to	apply this	technology,	the	high	pressu re	ratio	turbocharger	is	requir ed	to	increase	the	cha rge	air	pressure	and new	developed	Turbo	charger	with high	pressure	ratio	is	mounted on	the	main	engines.		The	optimized supercharging	with	miller	cycle has	recently	been	designed	to	e nhance	the	load	ma nagement	of	the engines.		Also,	the	main	engines are	equipped	with high	fuel	in jection	pressure	and	low	NO X design. Since	Anadarko	is	proposing	to	implement	this	technology,	a	con trol	cost	analysis	is	not	required.

13

Cost analysis presented in Appendix EAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 88 Trinity Consultants Good Combustion and Manufacturer Recommended maintenance practice

– Anadarko	is	proposing to	supplement	the	good	combustio n	practices	outl ined	by	the	man ufacturer	with	use	of	recommended operation	and	maintenance	practices.		Since	Anadarko	is	proposi ng	to	implement	this	technology,	a control	cost	analysis	is	not	required.

Step 5 ‐ Select BACT

The	main	engines	on	the	drillshi p	are	certified	to	meet	Tier	2 standards	of	the	IMO’s	2008	NO X Technical Code	(Regulation	13).		In	other words,	at	engine	speeds	of	720 rpm,	these	engines	are	designed	to	meet

NO X emission	limits	of	9.7	g/kW‐hr.		Anadarko	proposes	compliance with	NSPS	IIII,	IMO	Tier	2	standards, LNE	 Design,	 Turbocharger	 with	 Aftercooler	 &	 High	 Injection	 Pres sure,	 Optimized	 Supercharger	 with Miller	Cycle	and	good	combustion and	manufacturer	recommended	m aintenance	practices	as	NO X BACT for	the	eight	ma in	engines.



### 5.1.2. NO X 

### BACT Analysis for Emergency Generators (DR-GE-01)

The	emergency	generator is	a	Cummins	QSK60D MGE	model	engine.



### Step 1

– Identify all Control Technologies

The	control	technologies	for	the main	propulsion	engines	discus sed	above	were	considered	as	the potential	control	technologies for	the	emergency	generators.



### Step 2

– Eliminate Technically Infeasible Options

SCR – Infeasible.

This	control	option	is	not	techn ically	feasible	for	use	on	the emergency	generator,	which	only	operates intermittently	during	short	week ly	periods.		The	SCR	systems	re quire	a	longer	period of	operating	time

in	order	to	reach	a	minimum	tem perature	before	the	system	can	o perate.		Hence,	it	is	deemed	as technically	infeasible.

SNCR – Infeasible

.



### This control technology is deemed technologically infeasible for the same reasons identified in Section

5.1.1.

DWI – Infeasible

.



### This control technology is deemed te chnically infeasible for the same reas ons identified in Section 5.1.1.

EGR – Infeasible

.



### This control technology is deemed te chnically infeasible for the same reas ons identified in Section 5.1.1.

Derate Engines – Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 89 Trinity Consultants This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1

Water

‐ in

‐ fuel Emulsions (emulsified diesel) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

Intake Air Humidification/Cooling – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

NO X Adsorber/Scrubber Technology – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

CAM Shaft Replacement/Retooling of Engines – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

LNC or HC

‐ SCR – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

ITR –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 2. Ranks of Technologies Feasible for Emergency Generators

Technology Efficiency Rank

Low	NO X Engine	and	Turbocharger	with Aftercooler	and	High Injection	Pressure 30%	 N/A

Good	Combustion and	Manufacturer

Recommended	Maintenance Practices Baseline	 N/A

All	feasible	technologies	for	th e	emergency	engines	are	listed in	Table	5‐2.		Control	technologies	are ranked	by	efficiency	i n	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document ResultsAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 90 Trinity Consultants The	emergency	engines	on	the	dril l	ship	are	certified	at	constr uction	to	meet	Tier	2	standards	of	the
IMO’s	2008	NO X Technical	Code	(Regulation	13).

The	emergency	generator only	operates	intermittently	for	short periods	(2	hours	per	day	and	100	hours per	year)	and	it	is	primarily	de signed	to	handle	during	emergen cy	situation.		The	emergency	generator
is	certified	to	meet	IMO	Tier	2	st andards	and	is	the	cleanest	a vailable	engines	in	this	category	of	engines. Since,	the	remaining	identified technologies	are	proposed	as	BA CT,	a	cost	analysis	is	not	required.

Step 5 ‐ Select BACT

Anadarko	proposes	compliance	with	IMO	Tier	2	standards,	Turboch arger	with	Afterc ooler	and	High Injection	Pressure,	and	good	com bustion	and	manufacturer	recomm ended	maintenance	practices	as

NO X BACT	for	the	emergency	generator.



### 5.1.3. NO X 

### BACT Analysis for Emergency Air Compressor Engine (DR-AC-01)

The	air	compressor	diesel	engine is	a	52	HP	HATZ	2	M41	model	en gine.



### Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	ob tain	potential	control	technolo gies	for 

### NO X from	smaller	diesel engines	(<	500	HP)	and	review	of the	permits	recently	proposed/ issued	by	U.S.	EPA	Region	4	and Region	10	(and	corresponding	perm it	applications)	for	similar	O CS	sources	was	conducted	to	obtain potential	control	technologies	for	NO X from	smaller	engines.		The	mos t	recent	10‐year	period	was	used to	identify	applicable	control	t echnologies.		The	results	of	th e	RBLC	search	are	incl uded	in	Appendix	E. The	search	results	for	potenti al	control	technologies	for	NO X from	smaller	diesel engines	are	listed

below.

DWI

EGR Derate	Engines
Water‐in‐fuel	Emulsions Intake	Air	Humidification/Cooling

NO X Adsorber/Scrubber	Technology Replacement	of	Older	Engines	wi th	Newer	Engines	to	meet	higher EPA	Tier	standards	(40	CFR part	89,	94,	or	1042) CAM	Shaft	Replacement/ Retooling	of	Engines

LNC	or	HC‐SCR LNE	design	including	(Turbocharg er	with	After	cooler	and	High	P ressure	Fuel	Injection) 4‐Way	Catalyst	Converter

ITR

Good	Combustion	and	Manufacturer Recommended	Maintenance	Practi ces



### Step 2

– Eliminate Technically Infeasible Options

DWI –	Infeasible.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 91 Trinity Consultants This	technology	is	not	suitable for	emergency	air	compressor	en gine	which	only	operate	intermittently during	short	weekly	periods	of	e ngine	operation	since	these	eng ines	do	not	operate	under	steady	state conditions	for	a	long	time.		In	addition,	as	described	in	the	S ection	5.1.1,	a	significan t	quantity	of	fresh water	is	necessary	for	this	NO X reduction	technology.		This	cont rol	technology	is	deemed	techn ically

infeasible	for	the	reasons	discu ssed	above	and	the	reasons	iden tified	in	Section	5.1.1.

EGR –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

Derate Engines – Infeasible.

The	primary	concern	associated	wit h	derating	the	e mergency	air compressor	engine	is	that	derating engines	would	reduce	av ailable	power,	which is	a	safety	concern during	emergency	situations	where	the engines	are	required	to	perform at	full	load.		This	control	tec hnology	is	deemed	technically	infeasible	for

this	reasons	and	the	reasons	i dentified	in	Section	5.1.1.

Water

‐ in

‐ fuel Emulsions (emulsified diesel) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

Intake Air Humidification/Cooling – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

NO X Adsorber/Scrubber Technology – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

CAM Shaft Replacement/ Retooling of Engines – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

LNC or HC

‐ SCR – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

LNE Design with Turbocharger, Aftercooler and High Pressure Fuel Injection System – Infeasible

.

Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	engines,	making this	technology	to be	most	feasibly	installed	when	t he	engine	is	manufactured.		Re quiring	this	technolog y	would	essentially mean	having	to	replace	the	exist ing	air	compressor		engine	with another	air	compre ssor		engine	that have	this	technology	already	installed.		This	technology	is	int rinsic	to	the	engine	d esign	and	retrofitting the	air	compressor	diesel	e ngines	is	not	an	option.

4

‐ Way Catalyst Converter

– Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 92 Trinity Consultants ITR –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 3. Ranks of Technologies Feasible for Emergency Air Compressor Engine

Technology Efficiency Rank Replacement	with	Newer	Engine	 varies	 1

Good	Combustion and	Manufacturer

Recommended	Maintenance Practices Baseline	 N/A

All	feasible	technologies	for	th e	air	compressor	are	listed	in Table	5‐3.		Control	tec hnologies	are	ranked by	efficiency	in	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89 Tier	3	standards	are	the	clean est	available	engines	in	this	category	of equipment.		Anadarko	had	previous ly	obtained	an	initial	cost	es timate	of	$12,600	for	replacing	a	similar air	compressor	engines compliant	with	40	CF R	89	Tier	3	standard s.

The	emergency	air	compressor	only operates	intermittently	for	s hort	periods	(0.5	hours	per	day	and	100 hours	per	year)	and	it	is	primar ily	designed	to	operate	during emergency	situation.		The	emergency	air compressor	is	certified	to	meet	EPA	Tier	2	standards.		Given	th e	minimal	operations of	this	equipment resulting	in	low	emissions	(i.e .,	<0.1	tons	per	year),	Anadarko believes	that	replacement	of	existing	air compressor	engine	with	the	cleane st	available	engine	is	cost	pr ohibitive;	hence	a	detai led	cost	analysis	is
not	warranted.

Step 5 ‐ Select BACT

Anadarko	proposes	40	CFR	89,	EPA	T ier	2	standards	and	good	comb ustion	and	manufacturer recommended	maintenance	practices as	BACT	for	the	emergency	air compressor	engine.



### 5.1.4. NO X 

### BACT Analysis for Third Party Engi nes (DR-TP-01 through DR-TP-11 and DR-TP-17 though DR-TP-21)

The	temporary	EPA	Tier	2	certifie d	third	party	en gines	are	divi ded	in	the	following	engine	categories: 

### Third	party	engines	≤860	HP Third	party	engines	≤300	HP Third	party	engines	≤126	HP

Step 1

– Identify all Control Technologies

The	third	party	engines	on	the	d rillship	are	a	combination	of	s mall	(<500	HP)	and	large	(>500	HP)	diesel engines,	and	the	NO X control	options	identified	for the	drillship	main		engines	are assumed	to sufficiently	account	fo r	all	the	possi ble	control	technologies for	the	third	party	en gines.		Therefore,	theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 93 Trinity Consultants same	options	identified	for	the drillship	main	propulsion	engin es	and	emergency	air	compressor	are considered	as	the	potential	contro l	technologies	for	the	third party	engines	on	the	drillship.



### Step 2

– Eliminate Technically Infeasible Options

SCR –	Infeasible.

This	control	option	is	not	techn ically	feasible	for	use	on	the third	party	diesel	e ngines,	which	only operate	intermittently.		These	t hird	party	engines	are	brought onboard	as	required	to	perform	specific operations	and	then	sent	back	t o	the	shore	base	once	required	t ask	is	completed.		These	engines	do	not permanently	reside	on the	drillship.

The	SCR	systems	requi re	a	longer	period	of operating	time	under steady	state	conditions	in	order	to reach	a	minimum	temperature	befo re	the	system	can	operate.		Hen ce,	this	control	technology	is	deemed technically	infeasible	for	the reasons	discussed	above	and	the reasons	identified	in	Section	5.1.1.

SNCR – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

DWI – Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

EGR – Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

Derate Engines – Infeasible

.

An	engine	can	be	derated	by	restr icting	its	operation	to	lower levels	of	power	than	normal	for	the	given application	resulting	in	the	decr ease	in	available	power.		Sinc e	these	engines	are brought	onboard	to perform	specific	operations,	the se	are	selected	based	on	the	po wer	requirements	for	a	specific	task. Hence,	derating	these	engines	cou ld	significantly	impact	the	op erations.			Hence,	it	is	deemed	as technologically	infeasible.

Water

‐ in

‐ fuel Emulsions (emulsified diesel) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

Intake Air Humidification/Cooling – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

NO X Adsorber/Scrubber Technology – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 94 Trinity Consultants Replacement of Older Engines with Newer Engines – Infeasible

.

The	cleanest	available	engine	fo r	each	category	was	found	to	be EPA	Tier	3	or	Tier	4 certified.		However, upon	further	investigation,	the	v endors	noted	that	EPA	Tier	3	a nd	Tier	4	certified	en gines	constitute	a small	percentage	(i.e.,	approxim ately	less	than	20%)	of	the	tot al	inventory	for	each	category.

Due	to	constantly	changing	sched ules	during	the	proposed	operat ions,	the	availabili ty	of	these	third party	engines	changes on	short	notice.		Hence,	it	is	difficult to	determine	which	spec ific	engine	would	be brought	onboard	on	any	given	day.		Since	availability	of	the	EP A	Tier	3	and	Tier	4	en gines	is	limited, there	is	no	guarantee	that	these	e ngines	will	be	a vailable	when Anadarko	would	need	them.		Restricting these	third	party	engi nes	to	EPA	Tier	3	or	T ier	4	certified	eng ines	will	significantly	impact	the operations.		Hence,	this	control technology	is	deemed	technical ly	infeasible

LNE Design with Turbocharger, Aftercooler and High Pressure Fuel Injection System – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.3.

CAM Shaft Replacement/ Retooling of Engines – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

ITR –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	all	the	remaining	feasible technologies	are	being	propose d	as	BACT,	no	ranking	is	required



### Step 4

– Evaluate Most Effective Controls and Document Results

Since	all	the	remaining	feasible technologies	are	being	propose d	as	BACT,	a	cost	analysis	is	not	required.

Step 5 ‐ Select BACT

Anadarko	proposes	40	CFR	89	EPA Tier	2	standards along	with	goo d	combustion	and	manufacturer recommended	maintenance	practices	as	NO X BACT	for	the	temporary	third party	engines.		As	indicated previously,	the	third	party	engi nes	and	the	hors epower	ratings shown	in	this	application	are	for representation	purposes	only.		Ho wever,	a	third	party	engine	br ought	onto	the	drillshi p	will	at	least	be

certified	to	40	CFR	89	EPA	Tier 2	standards,	with	equivalent	or lower	emissions	than	the	engine represented.



### 5.1.5. NO X 

### BACT Analysis for Third Party We ll Evaluation Engines (DR-TP-12Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 95 Trinity Consultants 

### through DR-TP-16)

Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	ob tain	potential	control	technolo gies	for	NO X from	smaller	diesel engines	(<	500	hp)	and	review	of the	permits	recently	proposed/ issued	by	U.S.	EPA	R egion	4	and	Region 10	(and	corresponding	permit	appl ications)	for	similar	OCS	sour ces	was	conducted	to	obtain	potential control	technologies	for	NO X from	smaller	engines.		The	mos t	recent	10‐year	period	was	used to	identify applicable	control	technologies. The	results	of	the	RBLC	searc h	are	included	in	Appe ndix	E.		The	search results	for	potential	con trol	technologies	for	NO X from	smaller	diesel	eng ines	are	listed	below.

DWI

EGR Derate	Engines H/E	process	(water‐in‐fuel	Homoge nization	and	Emulsification) Intake	Air	Humidification/Cooling

NO X Adsorber/Scrubber	Technology Replacement	of	Older	Engin es	with	Newer	Engines CAM	Shaft	Replacement/	R e‐tooling	of	Engines

LNC	or	HC‐SCR LNE	design	including	Turbochar ger,	Aftercoolers,	and	High	Press ure	Fuel	Injection 4‐Way	Catalyst	Converter

Good	Combustion	and	Manufacturer Recommended	Maintenance	Practi ces
ITR



### Step 2

– Eliminate Technically Infeasible Options

DWI –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

EGR –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

Derate Engines – Infeasible

.

An	engine	can	be	derated	by	restr icting	its	operation	to	lower levels	of	power	than	normal	for	the	given application	resulting	in	the	decr ease	in	available	power.		Sinc e	these	engines	are brought	onboard	to perform	specific	operations,	the se	are	selected	based	on	the	po wer	requirements	for	a	specific	task. Hence,	derating	these	engines	cou ld	significantly	impact	the	op erations.			Hence,	it	is	deemed	as technologically	infeasible.

H/E process – Infeasible

. Diesel	and	water	emul sions	were	offered	as a	means	of	lowering the	NO X output	from	the	engines.
These	emulsion systems	have	been	shown	to	reduce	NO X by	15‐20%	in	engines	r unning	heavy	fuel	oilAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 96 Trinity Consultants (HFO).		Running	an	engine	on	fuel ‐water	emulsions	makes	it	theo retically	possible	to	reduce	NO X emissions	by	up	to	50%. 14

This	technology	would require	derating	of	th e	engines,	and	emul sified	diesel	in	marin e	vessels	can	cause

fuel	tank	corrosion	issues.		Addi tionally,	emulsified	fuel	syst ems	were	designed	for	and	installed	on slow‐speed	engines	bur ning	heavy	fuel	oil.

These	engines	are	designed	and	w ill	be	burning	medium	density	f uel	(diesel).		Several	significant engineering	hurdles	must	be	ov ercome	in	order	to	install	a	dies el/water	emulsion	syst em.		Hence,	this technology	is	considered	as	te chnologically	infeasible.

Intake Air Humidification/Cooling – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

NO X Adsorber/Scrubber Technology – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

Replacement of Older Engines with Newer Engines – Infeasible

.

The	five	third	party	well	evalua tion	diesel	engines	are	pre‐199 8	engines	and	hence	no	engine
certification	is	available.		Dur ing	one	of	the	w ell	evaluation activities	these	five	di esel	engines	will	be
used	to	send	information	to	a	lo gging	unit	powered by	third	par ty	engines.	Since	all of	these	engines	are used	to	power	different equipment	that	is	p erforming	a	single	o peration	they	are	all	leased	from	the same	third	party	vendor	to	avoid compatibility	issues.		The	thi rd	party	vendor	Anadarko	proposes	to leases	these	engines	from	has	no EPA	Tier	certified	well	evalua tion	engines	in	their fleet.		Therefore,	this is	not	considered	a	viable	BACT	option.

LNC or HC

‐ SCR – Infeasible

.

This	technology	is	not	typically not	suitable	fo r	smaller	porta ble	engines	such	as	well evaluation	engines. Also,	LNC	systems	operate	best	at consistent	high loads,	and	ar e	not	amenable	to	long	periods	of	engine
idle	or	load	shifts.

LNE Design with Turbocharger, Aftercooler and High Pressure Fuel Injection System – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.3

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

ITR – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

14 Based on Non-Road Diesel Emission Reduction Study”.www.ecy.wa.gov/progr ams/air/PDFS/NonroadDieselStudy.pdfAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 97 Trinity Consultants 

### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 4. Ranks of Technologies Feasible for Diesel Fired Engines

Technology Efficiency Rank CAM	Shaft	Replacement/ Retooling	of	Engines various	 1

Good	Combustion	and

Manufacturer	Recommended

Maintenance	Practices Baseline	 N/A

All	feasible	technologies	for	th e	diesel	fired	engines	are	list ed	in	Table	5‐4.		Contr ol	technologies	are ranked	by	efficiency	i n	a	descending	order.



### Step 4

– Evaluate Most Effective Controls and Document Results

Clean	Cam	Technology	Systems	(CCTS)	offers	retrofit	cam	shaft	r eengineering	kits	for	some	diesel	engines.
The	kits	reduce	NO X emissions	by	increasing	the	volum e	of	the	residual	exhaust	gas that	remains	in	the
combustion	chamber	aft er	the	power	stroke.

CCTS	cam	shaft	retrofit	(retoolin g)	kits	are	available	for	Detr oit	Diesel	engines	(mo del	series	71	or	92.)
The	“well	evalua tion”	engines	proposed	i n	this	application	are Detroit	Diesel	engines	(model	series	71) and	hence	this	technolog y	considered	feasible.

The	proposed	operating	time	for these	engines	is	125	hrs/year	p er	engine.		Given	the	engine’s	minimal operating	time,	the	resulting	emi ssions	are	minima l.		For	examp le,	NO X emissions	per	engine	are approximately	0.3	tpy per	engine.		Therefo re,	Anadarko	believes that	detailed	cost	in feasibility	is	not warranted.		Given	the	minimal	op erations	of	this equipment	resu lting	in	low	emissions,	Anadarko believes	that	CAM	Shaft	Replacem ent/	Retooling	of	the	engines	w ill	be	cost	prohibitive.



### Step 5 ‐ Select BACT

Anadarko	proposes	good	combustio n	practices	and	manufacturer	re commended	operating	and maintenance	practices	as	NO X BACT	for	the	third	party	we ll	evaluation	engines.



### 5.1.6. NO X 

### BACT Analysis for Pumps on the St imulation Vessel (SV-PE-01 through SV-PE-08)

The	proposed	Stimulation	Vesse l	will	have	eigh t	2,250	HP	pumps. The	pumps	described	in	this application	are	not	certified	fo r	EPA	Tier	rating	due	to	their manufacturing/model	year.



### Step 1

– Identify all Control Technologies

Similar	to	the	drillship	main	propulsion	engines,	the	pumps	on the	stimulation	vesse l	also	are	large (>500	HP)	diesel	engines	and	the	NO X control	options	are	expected	to be	same	as	the	main	propulsion engines.		Therefore,	the	same	opti ons	identified	for	the	main	p ropulsion	engines	a re	considered	as	the potential	control	technologies	f or	the	pumps	on	the	stimulation vessel



### .Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 98 Trinity Consultants Step 2

– Eliminate Technically Infeasible Options

SCR –	Infeasible.

This	control	option	is	not	technically	feasible	for	use	on	the pumps,	which	only	operate	for	short	periods during	the	specific	well	completi on	scenario.		SCR	systems	requ ire	a	longer	period	of	o perating	time	in	order to	reach	a	minimum	temperature	b efore	the	system	can	operate. Installation	of	each	SCR	will	require significant	structural	changes	to	support	the	SCRs	and	urea	sto rage	tanks.

Hence,	this	control	technology	i s	deemed	technically	infeasible for	the	reasons	dis cussed	above	and	the

reasons	identified	in	Section	5.1.1.

SNCR – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

DWI – Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

EGR – Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identified	in	Section	5.1.1.

Derate Engines – Infeasible

.

Derating	the	engine	will	reduce	t he	available	power	and	may	not meet	the	power	requi rements.		Since	the pumps	are	expected	to	be	operate d	at	peak	power,	this	control	t echnology	is	deemed	technologically

infeasible.

Water

‐ in

‐ fuel Emulsions (emulsified diesel) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

Intake Air Humidification/Cooling – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

NO X Adsorber/Scrubber Technology – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

CAM Shaft Replacement/ Retooling of Engines – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

LNC or HC

‐ SCR – Infeasible

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 99 Trinity Consultants This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

LNE Design with Turbocharger, Aftercooler and High Pressure Fuel Injection System – Infeasible

.

Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	engines,	making this	technology	to be	most	feasibly	installed	when	t he	engine	is	manufactured.		Re quiring	this	technolog y	would	essentially mean	having	to	replace	the	exist ing	pumps	with	o ther	pumps	that have	this	technology	already	installed. This	technology	is	intrinsic	to the	engine	design	and	retrofitt ing	the	pumps	is	not	a n	option.		Therefore,

this	is	not	considered	a viable	BACT	option.

Replacement of Older Engines with Newer Engines – Infeasible

.

The	certification	to	meet	these	s tandards	is	part	of	the	inhere nt	design	of	the	engine	and	there	is	no upgrade	available	for	an	existin g	engine	to	meet EPA	Tier	2	or higher	standards.		I n	order	for	these pumps	to	meet	EPA	Tier	2	(Part 89)	standards	or	higher,	the	eng ines	would	have	to be	replaced	with newer	engines.		Since	these	pum ps	are	already	installed	on	a	St imulation	Vessel,	replacing	the	existing pumps	with	the	newer pumps	will	require	si gnificant	engineering redesign	and	possible	recertification

of	the	Stimulation	Vessel.		Moreo ver,	these	pumps	will	operate for	a	limited	time	(i. e.,	approximately	201 hours	per	year.)		Hence,	replaceme nt	of	these	pumps	with	the	ne wer	pumps	is	not	considered	a	viable BACT	option.	Regardless,	Anadark o	performed	a	cost	analysis	to assess	cost	feasibility	of	this	option.

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.1.1.

ITR – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.1.1.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 5. Ranks of Technologies Feasible for Pumps on Stimulation Vessel

Technology Efficiency Rank Replacement	of	old	engines	with new	engines varies	 1

Good	Combustion	and

Manufacturer	Recommended

Maintenance	Practices Baseline	 N/A

All	feasible	technologies	for	th e	miscellaneous	well	completion engines	are	listed	in Table	5‐5.		Control technologies	are	ranked	by	effi ciency	in	a	descending	order.



### Step 4

– Evaluate Most Effective Controls and Document ResultsAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 100 Trinity Consultants Replacement of old engines with new engines

– 40	CFR	89	Tier	2	compliant engine	was	identified	as the	cleanest	available	engine	in the	stimulation	vessel	pump	en gine	category	(SV‐PE‐01	through	SV‐PE‐ 08)	Anadarko	performed	the	cost	e ffectiveness	analysis	for	repl acing	the	existing	engines	with	the newer	engines	meeting the	EPA	40	CFR	89	ti er	2	standards.		The cost	effectiveness	for	the	engine replacement	was	estim ated	to	be	more	than	$30,000	per	ton	of	NO X reduced,	making	this	option	cost prohibitive.		A	detailed	control cost	effectiveness	analysis	is provided	in	Appendix	E.

Step 5 ‐ Select BACT

Anadarko	proposes	good	combustio n	and	manufacturer	recommended operating	and	maintenance practices	as	BACT	for	the	pump s	on	the	stimulation	vessel.



### 5.1.7. NO X 

### BACT Analysis for Flowback Boiler (DR-TP-22)

The	proposed	flowback	boiler	is a	small	8	MMBtu/hr	diesel	fired combustion	source.		EPA's	RBLC	search was	used	to	obtain	potential control	technologies	for	NO X from	boilers	and	rev iew	of	the	permits recently	proposed/issued	by	U.S.	E PA	Region	4	and	Region	10	(an d	corresponding	permit	applications)

for	similar	OCS	sources	was	cond ucted	to	obtain	potential	contr ol	technologies	for	NO X from	boilers. The	most	recent	10‐year	period	was used	to	identify	applicable control	technologies.		The	results	of	the RBLC	search	are	included	in	Appe ndix	E.		The	search	results	for potential	control	tec hnologies	are	listed

below.

Flue	Gas	Recirculation	(FGR)

Low	NO X Burners

Good	Combustion	and	Manufacturer Recommended	Maintenance	Practi ces



### Step 2

– Eliminate Technically Infeasible Option

FGR – Infeasible

.

The	proposed	flowback	boiler	does not	have	an	FGR	and	retrofitt ing	FGR	on	an	existing	unit	will	require significant	design	change.		The	FGR	technology	is	best	suited	f or	new	units	as	retrofitting	FGR	on	the proposed	boiler	would require	extensive	modi fications,	such	as installation	of	duct work,	recirculation fans,	air	foils	for	mi xing	re‐circulated	flu e	gas	and	combustio n	air,	and	controls for	variable	load operation.		Also,	there	is	a	possi bility	of	flame	instability	o bserved	at	high	FGR	rates	leading	to	safety concerns.		Hence,	this	control	t echnology	is	considered	as	tech nologically	infeasible.

Low NO X Burners – Infeasible

.

This	technology	is	considered	tec hnically	infeasible	because	th e	proposed	boiler	wa s	not	constructed

with	low‐NO X burners.		Low‐NO X burners	produce	longer	flames ,	and	therefore	are	potentially inappropriate	for	retrofit	on	s maller	furnaces.		Additionally, low‐NO X burners	operate	in	a	lower‐ temperature,	fuel‐lean	zone,	wh ich	could	result in	increases	of CO	and	VOC	emissions	from	the	boiler.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	good	combustion 

### and	manufacturer	recommended operating	and	maintenance practices	areAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 101 Trinity Consultants the	only	feasible	option ,	no	ranking	is	required.



### Step 4

– Evaluate Most Effective Controls and Document Results

The	manufacturer	recommended	good combustion	operating	and	main tenance	requirements	are
considered	as	the	most	effective	controls.



### Step 5 ‐ Select BACT

Anadarko	proposes	good	combustio n	and	manufacturer	recommended operating	and	maintenance practices	as	the	NO X BACT	for	the	proposed	flowback	boiler.



### 5.1.8. NO X 

### BACT Analysis for Boom Flare (DR-TP-23)

Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	ob tain	potential	control	technolo gies	for	NO X from	flares	and	review	of the	permits	recently	pr oposed/issued	by	U.S.	EPA	Region	4	and	R egion	10	(and	corresponding	permit applications)	for	similar	OCS	so urces	was	conducted	to	obtain	p otential	control	technologies	for	NO X from	flares.		The	most	recent	10‐ year	period	was	used	to	identi fy	applicable	control	technologies.		The

results	of	the	RBLC	search	are	in cluded	in	Appendix	E.		The	sea rch	results	for	potential	control technologies	for	NO X from	flares	are	listed	below.

Comply	with	40	CFR	60.18

Good	Combustion	and	Manufacturer Recommended	Maintenance	Practi ces



### Step 2

– Eliminate Technically Infeasible Option

Comply	with	40	CFR	60.18	– Feasible

.

Good	Combustion	Practices	– Feasible

.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	both	the	identified	techno logies	are	being	proposed	as	BA CT,	no	ranking	is	required



### Step 4

– Evaluate Most Effective Controls and Document Results

Since	both	the	identified	techno logies	are	being	proposed	as	BA CT,	a	cost	analysis	is	not	required.



### Step 5 ‐ Select BACT

Anadarko	proposes	compliance	w ith	the	requiremen ts	of	40	CFR	60 .18	and	manufacturer	recommended good	combustion	operating	practic es	and	maintenance	requirement s	as	the	BACT	for	the	boom	flare.

A	summary	of	the	proposed	NO X BACT	emission	limitation	for	ea ch	source	associated	with	the	p roject	is provided	below	in	Table	5‐6.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 102 Trinity Consultants Table 5

‐ 6. Proposed NO X BACT Emission Limits

Emission Unit BACT

Emission

Limit BACT Basis BACT Control Technologies

Drillship	Main		Engines (DR‐ME‐01	thru	DR‐ME‐06) 9.7 g/kW‐hr IMO
Performance

Test	Data EPA	40	CFR	1042	Tier	2 Standards, NSPS	IIII,	IMO	Tier	2 standards,	LNE	Design, Performance	Management System	including	Turbocharger with	Aftercooler	and	High	Fuel Injection	Pressure,	good
combustion	and	manufacturer
recommended	maintenance practices Drillship	Emergency Generators	(DR‐GE‐01) ‐‐ IMO	Tier	2
Standard IMO	Tier	2	standards, Turbocharger	with	Aftercooler &	High	Injection	Pressure,	good
combustion	and	manufacturer
recommended	maintenance practices Emergency	Air	Compressor Engine	(DR‐AC‐01) ‐‐ 40	CFR	89	EPA
Tier	2	Standard 40	CFR	89	EPA	Tier	2	Standard, good	combustion and
manufacturer	recommended

maintenance practices Third	Party	Engines	(DR‐TP‐01 through	DR‐TP‐11	and	DR‐TP‐ 17	through	DR‐TP‐21) ‐‐ 40	CFR	89	EPA
Tier	2	Standard 40	CFR	89	EPA	Tier	2	Standard, good	combustion	and
manufacturer	recommended maintenance	practices Third	Party	Well	Evaluation Engines	(DR‐TP‐12	through DR‐TP‐16) ‐‐ AP‐42,	Chapter 3,	Table	3.3‐1 Good	combustion and
manufacturer	recommended

maintenance practices Stimulation	Vessel	Pumps	(SV‐ PE‐01	thru	SV‐PE‐08) ‐‐ AP‐42,	Chapter 3,	Table	3.4‐1 Good	combustion and
manufacturer	recommended

maintenance practices Flowback	Boiler	(DR‐TP‐22)	 ‐‐ AP‐42,	Chapter 1,	Table	1.3‐1 Good	combustion and
manufacturer	recommended

maintenance practices Boom	Flare	(DR‐TP‐23)	 ‐‐ AP‐42,	Chapter 13,	Table	13.5‐1 Compliance	with	40	CFR	60.18

and	Good	combustion and
manufacturer	recommended

maintenance practicesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 103 Trinity Consultants 

### 5.2. CO AND VOC BACT ANALYSIS

The	BACT	assessment	for	CO	and	V OC	was	performed	for	the	same	s ources	described	in	Section	5.1.



### 5.2.1. CO and VOC BACT Analysis for Drillship Main Propulsion Electrical Generator Engines (DR-ME-01 through DR-ME-08)

The	main	propulsion	en gines	are	used	to	po wer	the	thrusters	tha t	hold	the	ship	on	location,	as	well	as power	the	drilling	equipment	a nd	other	operational	needs	of	the ship.		The	main	propulsion	engines operate	at	variable	loads	based	o n	drilling	and	operational	pow er	demand,	and	extensive	“reserve” power	is	required	to	adjust	for loop	currents	and	subsea	soil	d ensities.		Hence,	CO emissions	are	not emitted	from	these	engines	at	a steady	state.		These	factors	ar e	important	considerations	in	the	BACT analysis	for	these	engines.



### Step 1

– Identify all Control Technologies

The	first	step	in	the EPA	top‐down,	five‐ste p	analysis	is	to	id entify	all	available	control	technologies	that are	potentially	suitable	for	the affected	sources.		EPA's	RBLC search	was	used	to	obtain	potential	control technologies	for	CO	and	VOC	from main	propulsion	engines	at	off shore	sources.		The	most	recent	10‐ year	period	was	used	to	identify applicable	control	technologie s.		The	results	of	th e	RBLC	search	are included	in	Appendix	E.		However,	it	should	be	noted	that	the	c ontrol	technologies evaluated	in	the “topdown”	analysis	for	main	dies el	engines	were	not	limited	to the	controls	listed	in	the	RBLC	database. The	permits	recently	pr oposed/issued	by	U.S.	EPA	Region	4	and	R egion	10	(and	corresponding	permit applications)	for	similar	OCS	so urces	in	Gulf	of	Mexico	have	al so	been	reviewed	in	a ddition	to	surveying available	literature	to	identify potential	control	technologies .		The	search	results	for	potential	control technologies	for	CO	and	VOC	from the	main	diesel	engines	are	li sted	below.

DOC

CDPF 4‐Way	Catalyst	Converter	with	Ex haust	Gas	Recirculation	System Replacement	of	Engines	to	meet	h igher	EPA	Tier	st andards	(40	CF R	part	89,	94,	or	1042) LNE	Design	with	Turbocharger	wi th	Aftercooler	and	High	Fuel	Pre ssure	Injection Good	combustion	practices

ITR

Positive	Crankcase	Ventilati on	System	(for	VOCs	only)



### Step 2

– Eliminate Technically Infeasible Option

DOC – Infeasible

. DOCs	contain	precious	metals	imp regnated	onto	a	high	geometric surface	area	carrier	and	are	placed	in the	exhaust	stream	of	the	engine to	reduce	emissions	of	PM,	Tot al	Hydrocarbons	(THC),	and	CO.		The DOC	works	by	oxidizing	CO,	gaseous	hydrocarbons	and	liquid	hydr ocarbon	particles	(u nburned	fuel	and oil)	in	the	exhaust	gas	to	CO 2 and	H 2 O.		The	reduction	of PM,	THC,	and	CO	varies	depending	on	theAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 104 Trinity Consultants catalyst	formulations	in	the	DOC.		DOCs	have	been	verified	to	r educe	emissions	of	CO	and	THC	by	as much	as	90	percent. 15

Due	to	the	large	load	variations typical	of	these	exploratory	d rilling	operations,	t he	main	propulsion engines	are	not	able	to	sustain constant	steady	state	loads/exh aust	temperatures	for	sufficient	time periods	that	are	necessary	for	hi gh	catalyst	performance,	resul ting	in	limited	control.		Use	of	DOCs

would	also	lead	to	som e	pressure	drop	acro ss	exhaust	flow	resul ting	in	back	pressure on	the	engine	that could	cause	plugging	of	the	engi ne,	thus	posing	safety	concerns for	the	types	of	offshore	operations proposed.		Several	non‐combustibl e	chemical	elements	that	may	b e	present	in	engine lube	oils,	such	as phosphorous,	lead	and	heavy	meta ls,	may	collect	over	time	and	d amage	the	catalyst in	the	DOC.		This technology	has	not	been	designe d,	engineered,	or	tested	on	a	co mmercially	available	scale	for	safe operation	on	the	large scale	engines	found on	the	BlackHornet	d rillship.

CDPF – Infeasible

. The	catalyst	in	the	CDPF	filter could	potentially	reduce	emissi ons	of	CO	and	THC by	90	percent	but requires	sufficient	exhaust	temp eratures	to	facilitate	regenera tion	by	the	catalyst. 16

CDPFs	add	back	pressure	on	the	eng ines	that	could	cause	pluggin g	of	the	engine,	thus	posing	safety concerns	for	the	types	of	offsho re	operations	proposed.		The	pr essure	drop	will	also	cause	a	reduction	in fuel	economy.		Due	to	load	variations,	the	main	diesel	engines cannot	typically	susta in	the	high	exhaust temperatures	necessary	for	optim al	regeneration	o f	the	catalyst .		This	technology	has	not	been	designed, engineered,	or	tested	on	a	comm ercially	available scale	for	saf e	operation	on	the	la rge	scale	engines found	on	the	BlackHornet	drillship.

Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042) – Infeasible

.

The	main	diesel	engines	meet	the IMO	Tier	2	standard	for	engine s	under	Category	3	(i.e.,	>30 liter/cylinder	displacement	op erating	at	720	rpm) .		IMO	does	no t	have	an	emission	standard	for	CO. However,	comparable	EPA	Standard (i.e.,	EPA	Tier	2)	does	have	e mission	standards	for	CO	and	VOC. Since	certification	is	an	engine manufacturer	process,	it	is	no t	possible	for these	engines to	obtain	an EPA	Tier	certificate	at	this	poin t	regardless	whet her	these	eng ines	meet	EPA	Tier	standards. Hence, these	engines	will	need	to	be	rep laced	with	engines	with	EPA	Ti er	2	certification.		The	replacement	of engine	will	essentia lly	require	redesign	and	recertification	pr ocess.		Hence,	this	i s	not	a	viable	BACT option.

4

‐ Way Catalyst Converter – Infeasible

. The	main	propulsion	electrical	e ngines	will	not	be	able	to	sust ain	constant	steady	state	loads/exhaust temperatures	for	sufficient	time periods	that	are	critical	for high	catalyst	perfor mance,	resulting	in

inconsistent	emission	control.		S everal	non‐combustible	chemica l	elements	that	may	be	present	in engine	lube	oils,	such as	phosphorous,	lead and	heavy	metals,	m ay	collect	over	time	and	damage	the catalyst.

ITR – Infeasible

.

15

Based on Sections 4.3, Alternative Control Techniques Document: Stationary Diesel Engines (Final Report) , Prepared For: Energy Strategies Group U.S. Environmental Protection Agency (EPA) Office of Air Quality Planning and Standards, March 5, 2010.

16

IbidAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 105 Trinity Consultants Changing	ignition	timing	is	not an	alternative	for	these	engine s	due	to	the	intrinsic	engine	design. Alterations	of	the	injection	timing	can	impact	value	performanc e.		Additionally,	use	of	this	technology can	reduce	engine	power	and	combus tion	stability	that	can	hinde r	operations.		For these	reasons	this technology	is	infeasible.

Positive Crankcase Ventilation System (for VOCs only) – Infeasible

.

Installation	of	a	Positive	Crank case	Ventilation	system	involve s	changes	to	the	design	of	the	engines, making	this	technology	to	be	mos t	feasibly	installed	when	the	d rillship	is	designed. This	technology	is intrinsic	to	the	engine	design. Furthermore,	engine	manufactur ers	have	strict	restrictions	on	installing upgrades	to	avoid	violating	wa rranty.		Retrofitting	the	engine with	this	system	wil l	require	significant redesign	of	the	drillship	includ ing	a	possibility	of	recertific ation.		Requiring	this	technology	would essentially	mean	having to	replace	the	existing	engines	with	ot her	engines	that	hav e	this	technology already	installed.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 7. Ranks of Technologies Feasible for Main Diesel Engines

Technology Efficiency Rank LNE	Design	with	 Turbocharger	with	Aftercooler and	High	Fuel	Pressure	Injection ~	30%	 2

Good	Combustion	Practices	 Baseline	 N/A

All	feasible	technologies	for	th e	main	diesel	engines	are	liste d	in	Table	5‐7.		Control	technologies	are ranked	by	efficiency	i n	a	descending	order.



### Step 4

– Evaluate Most Effective Controls and Document Results

Since	Anadarko	is	proposing	to	i mplement	all	feasible	control	t echnologies,	a	control cost	analysis	is	not required.

Step 5 ‐ Select BACT

Anadarko	proposes	LNE	design	including	Turbocharger	with	Afterc ooler	and	High	Fuel	Injection Pressure	along	with	good	combust ion	and	manufacturer	recommende d	operation	and	maintenance practices.



### 5.2.2. CO and VOC BACT Analysis for Drills hip Emergency Generator (DR-GE-01)

Step 1

– Identify all Control Technologies

Similar	to	the	above	addressed	ma in	propulsion	electrical	gener ator	engines,	the	emergency	generator is	also	a	large	(>500	H P)	diesel	engine,	an d	the	CO	control	opt ions	are	expected	to be	same	as	the	main diesel	engine.		Therefore,	the	sam e	options	identified	for	the main	diesel	engines	are	considered	as	the potential	control	technologies	for	the 

### emergency	generator.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 106 Trinity Consultants 

### Step 2

– Eliminate Technically Infeasible Options

DOC – Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

CDPF – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

ITR – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

Positive Crankcase Ventilation System (for VOCs only) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 8. Ranks of Technologies Feasible for Emergency Engine

Technology Efficiency Rank Replacement	of	Engine	to	meet	higher	EPA

Tier	standards varies	 1

LNE	Design	 30%	 N/A Good	Combustion	Practices		 Baseline	 N/A

All	feasible	technologies	for	th e	emergency	generator	are	liste d	in	Table	5‐8.		Control	technologies	are ranked	by	efficiency	i n	a	descending	order.



### Step 4

– Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89	Tier	2	standards	are	the	clean est	available	engines in	this	category	of engines.		There	is	no	add	on	techn ology	due	to	which	IMO	Tier	2 engines	could	be	cl assified	as	EPA	Tier 2	engines.		The	only	p ossible	option	is	to	replace	the	existing engine	with	EPA	Tier	2 certified	engine	and this	option	will	require	signific ant	redesigning	and	possible	r ecertification.

The	emergency	generator only	operates	intermittently	for	short periods	(2	hours	per	day	and	100	hours per	year)	and	it	is	primarily	de signed	to	handle	during	emergen cy	situation.		Given	the	small	emissions

and	trivial	emission	reduction	b enefit,	Anadarko	believes	a	com prehensive	cost	assessment	is	not

warranted.



### Step 5 ‐ Select BACTAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 107 Trinity Consultants Anadarko	proposes	LNE	design	along	with	good	combustion	and	man ufacturer	recommended maintenance	practices as	BACT	for	the	dri llship	emergency	gener ator.



### 5.2.3. CO and VOC BACT Analysis for Air Compressor Engine (DR-AC-01)

The	air	compressor	engi ne	is	a	HATZ	2M41	engine	with	39	HP	rati ng.



### Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	ob tain	potential	control	technolo gies	for	CO	and	VOC	from	smaller emergency	diesel	engines	(<	500 HP)	and	review	of	the	permits	r ecently	proposed/issued	by	U.S.	EPA Region	4	and	Region 10	(and	corresponding	permit	applications) for	similar	OCS	sources	was	conducted to	obtain	potential	control	tech nologies	for	CO	and	VOC	from	sm aller	engines.		The most	recent	10‐year period	was	used	to	identify	appl icable	control	technologies.		T he	results	of	the	RBLC search	are	included in	Appendix	E.		The	search	results for	potential	control	techno logies	for	CO	and	VOC from	smaller	diesel engines	are	listed	below.

DOC

CDPF 4‐Way	Catalyst	Converter

ITR Replacement	of	Engine to	meet	higher	EPA	Ti er	standards	(40	CFR part	89,	94,	or	1042) LNE	Design	with	Turb ocharger	and	High	Pre ssure	Fuel	Injection Good	combustion	practices	(Man ufacturer	recommended	operations and	maintenance)

Positive	Crankcase	Ventilati on	System	(for	VOCs	only)



### Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

CDPF –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

4

‐ Way Catalyst Converter – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

ITR – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

LNE Design with Turbocharger and High Pressure Fuel Injection – Infeasible

.

Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	engines,	making this	technology	to be	most	feasibly	installed	when the	engine	is	installed.		Requi ring	this	technology	would	essentially mean	having	to	replace	the	exist ing	compressor	engine	with	othe r	air	compressor	diesel	engines	that have	this	technology	already	installed.		This	technology	is	int rinsic	to	the	engine	d esign	and	retrofitting the	air	compressor	diesel	e ngines	is	not	an	option.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 108 Trinity Consultants Positive Crankcase Ventilation System (for VOCs only) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 9. Ranks of Technologies Feasible for Emergency Air Compressor Engine

Technology Efficiency Rank Replacement	of	Engin e	to	meet	higher	EPA

Tier	standards 1

Good	Combustion	Practices	 Baseline	 N/A

All	feasible	technologies	for	th e	air	compressor	are	listed	in Table	5‐9.		Control	tec hnologies	are	ranked by	efficiency	in	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89	Tier	3	standards	are	the	clean est	available	engines in	this	category	of equipment.		Anadarko	previously	o btained	an	initial	cost	estima te	of	$12,600	for	replacing	a	similar engine	with	air	compre ssor	engines	complian t	with	40	CFR	89	Tie r	3	standards.		Given	the	minimal operations	of	this	equipment	resul ting	in	low	emissions,	Anadar ko	believes	that	replacement	of	existing air	compressor	engine	w ith	the	cleanest	ava ilable	engine	is	cos t	prohibitive	and	a	de tailed	cost	analysis
is	not	warranted.

Step 5 ‐ Select BACT

Anadarko	proposes	40	CFR	94	EPA Tier	2	standards	and	good	combu stion	and	manufacturer recommended	maintenance	practices as	CO	and	VOC	BACT	for	the	em ergency	air	compressor.



### 5.2.4. CO and VOC BACT Analysis for Drills hip Third Party Engines (DR-TP-01 through DR-TP-11 and DR-T P-17 though DR-TP-21)

The	 temporary	 EPA	 Tier	 2	 certifie d	 third	 party	 engines	 include the	 following	 engine	 categories:



### Third	party	engines	≤860	H P		(DR‐TP‐01	and	DR‐TP‐02) Third	party	engines	≤300	HP		(DR‐TP‐03	to	DR‐TP‐11) Third	party	engines	≤126	HP		(DR‐TP‐17	to	DR‐TP‐21)

Step 1

– Identify all Control Technologies

The	third	party	engines	on	the	d rillship	are	a	combination	of	s mall	(<500	HP)	and	large	(>500	HP)	diesel engines,	and	the	CO	and	VOC	cont rol	options	identified	for	the main	propulsion	electrical	generator engines	are	assumed	to	sufficien tly	account	for	all	the	possibl e	control	technologies for	the	third	party engines.		Therefore,	the	same	op tions	identified	for	the	drills hip	main	diesel	engines	are	considered	as the	potential	control	technologi es	for	the	third	party	engines on	the	drillship.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 109 Trinity Consultants 

### Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

CDPF –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

4

‐ Way Catalyst Converter – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

ITR – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042) – Infeasible

.

The	cleanest	available	engine was	found	to	be	EPA	Tier	III	or	T ier	IV	certified.		However,	upon	further investigation,	the	vendors	noted that	EPA	Tier	III	and	Tier	IV certified	engines	constitute	a	small percentage	(i.e.,	approximately less	than	20%)	of	the	total	inv entory.

Due	to	constantly	changing	sched ules	during	the	proposed	operat ions,	the	availabili ty	of	these	third party	engines	changes on	short	notice.		Hence,	it	is	difficult to	determine	which	spec ific	engine	would	be brought	onboard	on	any	given	day.		Since	availability	of	the	EP A	Tier	III	and	Tier	IV engines	is	limited, there	is	no	guarantee	that	these	e ngines	will	be	a vailable	when Anadarko	would	need	them.		Restricting these	third	party	engi nes	to	EPA	Tier	III	o r	Tier	IV	certified engines	will	significantly	impact	the operations.		Hence,	this	option is	not	a	viable	BACT	option.

Positive Crankcase Ventilation System (for VOCs only) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	since it	is	an	intrinsic	part	of	engine	design	and restricting	the	temporary	third	party	engines	to	be	equipped	wi th	this	technology	could	have	significant operational	impact	as	described	above.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 10. Ranks of Technologies Feasible for the Third Party Engines

Technology Efficiency Rank LNE	design	 30%	 1 Good	Combustion	Practices	 Baseline	 N/A

All	 feasible	 technologies	 for	 th e	 third	party	engines	are	liste d	in	Table	5‐10.		Control	 technologies	are ranked	by	efficiency	i n	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document Results

Anadarko	proposes	40	CFR	89	EPA Tier	2	standards,	the	highest	r anked	among	the	feasible	options,	as
BACT	for	CO	control	from	the	thi rd	party	engines.	Therefore	con trol	cost	analysis	is	not	required.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 110 Trinity Consultants Step 5 ‐ Select BACT

Anadarko	proposes	40	CFR	89	EPA Tier	2	standards and	LNE	Design along	with	good	combustion practices	as	CO	BACT	for	the	thi rd	party	engines.		Anadarko	pro poses	good	combustion	practices	as	VOC BACT.		As	indicated	previously, the	third	party engines	and	the horsepower	rating s	shown	in	this application	are	for	representatio n	purposes	only.		However,	a	w ell	completion	engine	brought	onto	the drillship	will	at	least	be	cer tified	to	40	CFR	89	EPA	Tier	2	or higher	standards,	wit h	equivalent	or	lower emissions	than	the	engine	represented.



### 5.2.5. CO and VOC BACT Analysis for Third Pa rty Well Evaluation Engines (DR-TP12 through DR-TP-16)

Step 1

– Identify all Control Technologies

The	third	party	well	e valuation	engines	on the	drillship	are	fo ur	140	HP	diesel	engines,	and	the	CO control	options	identified	for	t he	main	propulsion	electrical	g enerator	engines	are	assumed	to sufficiently	account	fo r	all	the	possi ble	control	technologies for	the	third	party	en gines.		Therefore,	the same	options	identified	for	the drillship	main	diesel	engines	a re	considered	as	the	potential	control technologies	for	the	third	par ty	engines	on	the	drillship.



### Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

CDPF –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

4

‐ Way Catalyst Converter – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

ITR – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

LNE Design – Infeasible

. Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	engines,	making this	technology	to be	most	feasibly	installed	when	t he	engine	is	manufactured.		Re quiring	this	technolog y	would	essentially mean	having	to	replace	the	exist ing	well	evaluation	compressor diesel	engines	with	other	air compressor	diesel	engines	that	ha ve	this	technology	already	ins talled.		This	technology is	intrinsic	to	the engine	design	and	retrofitting	the air	compressor	diesel	engine s	is	not	an	option.

Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042) – Infeasible

. The	five	third	party	well	evalua tion	diesel	engines	are	pre‐199 8	engines	and	hence	no	engine
certification	is	available.		Dur ing	one	of	the	w ell	evaluation activities	these	five	di esel	engines	will	be
used	to	send	information	to	a	lo gging	unit	powered by	third	par ty	engines.	Since	all of	these	engines	are used	to	power	different equipment	that	is	p erforming	a	single	o peration	they	are	all	leased	from	the same	third	party	vendor	to	avoid compatibility	issues.		The	thi rd	party	vendor	Anadarko	leases	theseAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 111 Trinity Consultants engines	from	currently has	no	EPA	Tier	certified	well	evaluatio n	engines	in	their	fleet .		Therefore,	this	is not	considered	a	viable	BACT	option.

Positive Crankcase Ventilation System (for VOCs only) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.4.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Good	combustion	practices	(man ufacturer	recommended	operation	a nd	maintenance)	are	the	only feasible	option.		Therefore, ranking	is	not	required.

Step 4

– Evaluate Most Effective Controls and Document Results

Good	combustion	practices	are	th e	only	feasible option.		Theref ore,	ranking	is	not	required.

Step 5 ‐ Select BACT

Anadarko	proposes	good	combustio n	and	manufacturer	recommended operation	and	maintenance practices	as	CO	and	VOC	BACT	for the	third	party	well	evaluatio n	diesel	engines.



### 5.2.6. CO and VOC BACT Analysis for Represen tative Stimulation Vessel Pumps (SVPE-01 thru SV-PE-08)

The	proposed	Stimulation	Vessel	will	have	eight	2,250	HP	pump	e ngines.

Step 1

– Identify all Control Technologies

Similar	to	the	main	propulsion	e lectrical	generator	engines,	th e	pump	engines	on	the	stimulation	vessel also	are	large	(>500	HP)	diesel	en gines	and	the	CO	and	VOC	cont rol	options	are	expe cted	to	be	same	as the	main	diesel	engine.		Therefor e,	the	same	options	identified for	the	main	diesel	engines	are considered	as	the	potential	contro l	technologies	for	the	pumps on	the	stimulation	vessel.



### Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

CDPF –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.2.1.

4

‐ Way Catalyst Converter – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.

ITR – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.2.1.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 112 Trinity Consultants LNE Design – Infeasible

.

Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	engines,	making this	technology	to be	most	feasibly	installed	when	t he	engine	is	manufactured.		Re quiring	this	technolog y	would	essentially mean	having	to	replace	the	pumps with	another	engine	that	has	t his	technology	already	installed.		This technology	is	intrinsic	to	the	engine	design	and	retrofitting	t he	pumps	is	not	an	option.

Positive Crankcase Ventilation System (for VOCs only) – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Sections	5.2.4

and	5.1.6.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 11. Ranks of Technologies Feasible for Pumps on Stimulation Vessel

Technology Efficiency Rank Replacement	 of	 engines	 to	meet higher	EPA	tier	standards. varies	 1

Good	Combustion	Practices	 N/A	 N/A

All	feasible	technologies	for	th e	miscellaneous	well	completion engines	are	listed	in	Table	5‐11.		Control technologies	are	ranked	by	effi ciency	in	a	descending	order.



### Step 4

– Evaluate Most Effective Controls and Document Results

Replacement of engines to meet higher EPA tier standards

– 40	CFR	89	Tier	2	compliant	engine	was
identified	as	the	cleanest	avail able	engine	in	the	stimulation vessel	pump	engine	category	(SV‐PE‐01 through	SV‐PE‐08).		Anadarko	p reviously	performed	the	cost	effe ctiveness	analysis	for	replacing	the existing	engines	with	the	newer engines	meeting the	EPA	40	CFR 89	tier	2	standards.		However,	40	CFR
89	Tier	2	emission	fac tor	results	in	higher emissions	than	the existing	engine,	for	which	emissions	were calculated	using	AP‐42	factor.		T herefore,	it	is	not	possible	t o	perform	a	representative	cost	effectiveness analysis.

Step 5 ‐ Select BACT

Anadarko	 proposes	 good	 combustion	 practices	 and	 manufacturer	 re commended	 operation	 and maintenance	practices as	BACT	for	the	pumps on	the	stimulation vessel.



### 5.2.7. CO and VOC BACT Analysis for Flowback Boiler (DR-TP-22)

The	proposed	flowback	boiler	is a	small	8	MMBtu/hr	diesel	fired combustion	source.		An	RBLC	search for	potential	control	options	fo r	CO	from	a	small	boiler	(<10	M MBtu/hr)	did	not	produce	any	results. Also,	a	review	of	the	permits	rec ently	proposed/issued	by	U.S. EPA	Region	4	and	Region	10	for	similar OCS	sources	did	not	result	in	any potential	control	technologie s.		Therefore,	Anadarko	proposes	good combustion	practices	(manufactu rer	recommended	operation	and	ma intenance)	as	BACT	for	the

flowback	boiler.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 113 Trinity Consultants 

### 5.2.8. CO and VOC BACT Analysis for Boom Flare (DR-TP-23)

Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	ob tain	potential	control	technolo gies	for	CO	from	flares	and	review	of the	permits	recently	pr oposed/issued	by	U.S.	EPA	Region	4	and	R egion	10	(and	corresponding	permit applications)	for	similar	OCS	so urces	was	conducted	to	obtain	p otential	control	technologies	for	CO	from flares.		The	most	recent	10‐year period	was	used	to	identify	ap plicable	control	technologies.		The	results

of	the	RBLC	search	are	included in	Appendix	E.		The	search	resu lts	for	potential	control	technologies	for

CO	from	flares	are	listed	below.

Comply	with	40	CFR	60.18 Good	Combustion	Practices	(Man ufacturer	recommended	operation	a nd	maintenance)



### Step 2

– Eliminate Technically Infeasible Option

Comply	with	40	CFR	60.18	– Feasible

. Good	Combustion	Practices	– Feasible

.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	both	the	identified	techno logies	are	being	proposed	as	BA CT,	no	ranking	is	required



### Step 4

– Evaluate Most Effective Controls and Document Results

Since	both	the	identified	techno logies	are	being	proposed	as	BA CT,	a	cost	analysis	is	not	required.

Step 5 ‐ Select BACT

Anadarko	proposes	compliance	w ith	the	requiremen ts	of	40	CFR	60 .18	and	good	combustion	practices (manufacturer	recommended	operati on	and	maintenance)	as	the	BAC T	for	the	boom	flare.

A	summary	of	the	proposed	CO	and	VOC	BACT	emission	limitation	f or	each	source	associated	with	the project	is	provided	be low	in	Table	5‐12.

Table 5

‐ 12. Proposed CO & VOC BACT Emission Limits

Emission Unit BACT Emission Limit BACT Basis BACT Control Technologies Drillship	Main	Propulsion Electrical	Engines (DR‐ME‐01	thru	DR‐ME‐08) 2.49	g/kW‐hr	– CO 0.43	g/kW‐hr	‐	VOC AP‐42,	Chapter 3,	Table	3.4‐1 LNE	design	including Turbocharger	with Aftercooler	and	High
Fuel	Pressure Injection,	and	Good
Combustion	Practices Drillship	Emergency	Diesel Engine	(DR‐GE‐01) ‐‐ AP‐42,	Chapter 3,	Table	3.4‐1 LNE	design	and	Good
Combustion	Practices Emergency	Air	Compressor Engine	(DR‐AC‐01) ‐‐ 40	CFR	89 EPA
Tier	2	Standard EPA	Tier	2	StandardAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 114 Trinity Consultants Emission Unit BACT Emission Limit BACT Basis BACT Control Technologies

Good	Combustion

Practices Third	Party	Engines	(DR‐TP‐ 01	through	DR‐TP‐11	and DR‐TP‐17	through	DR‐TP‐21) ‐‐ 40	CFR	89	EPA
Tier	2	Standard (CO) AP‐42,	Chapter 3,	Table	3.4‐1 (VOC) 40	CFR	89	EPA	Tier	2
Standard	and	LNE design

Third	Party	Well	Evaluation Engines	(DR‐TP‐12	through DR‐TP‐16) ‐‐ AP‐42,	Chapter 3,	Table	3.3‐1 Good	Combustion

Practices

Stimulation	Vessel	Pumps (SV‐PE‐01	thru	SV‐PE‐08) ‐‐ AP‐42,	Chapter 3,	Table	3.4‐1 Good	Combustion

Practices Flowback	Boiler	(DR‐TP‐22)	 ‐‐ AP‐42,	Chapter 1,	Table	1.3‐1 Good	Combustion

Practices Boom	Flare	(DR‐TP‐23)	 ‐‐ AP‐42,	Chapter 13,	Table	13.5‐1 Compliance	with	40
CFR	60.18	and	Good
Combustion	PracticesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 115 Trinity Consultants 

### 5.3. PM/PM 10 

### /PM 2.5 

### BACT ANALYSIS

The	emission	sources	of	PM/PM 10 /PM 2.5 on	the	drillship	that	are	used	for	the	proposed	drilling operation	are	as	listed	below:

Eight	main	propulsion	electrical generator	engines	(DR‐ME‐01	to DR‐ME‐08) Emergency	generator	(DR‐GE‐01) Emergency	Air	compressor	(DR‐AC‐01) Third	party	engines: Third	party	engines	≤860	HP (DR‐TP‐01	and	DR‐TP‐02) Third	party	engines	≤300	HP (DR‐TP‐03	to	DR‐TP‐11) Third	party	well	evaluation	en gines	≤140	HP	(DR‐TP‐12‐DR‐TP‐16 and SB‐TP‐05	to	SB‐TP‐09) Third	party	engines	≤126	HP (DR‐TP‐16	to	DR‐TP‐21) One	flow	back	boiler	(DR‐TP‐22) One	boom	flare	(DR‐TP‐23) Painting	Operation	(DR‐PO‐01) Welding	Operation	(DR‐WO‐01) Stimulation	Vessel	–	8	pumps	(SV‐PE‐01	thru	SV‐PE‐08)



### 5.3.1. PM/PM 10 

### /PM 2.5 

### BACT Analysis for the Drillshi p Main Propulsion Electrical Generator Engines (DR-ME-01 to DR-ME-08)

The	main	propulsion	electrical	g enerator	engines	are	used	to	po wer	the	thrusters	tha t	hold	the	ship	on location,	as	well	as	p ower	the	drilling	equ ipment	and	other	ope rational	needs	of	the	ship.		The	main propulsion	engines	operate	at	va riable	loads	based	on	drilling and	operational	power	demand,	and extensive	“reserve”	power	is	req uired	to	adjust	for	loop	curren ts	and	subsea	soil	densities.		Hence, PM/PM 10 /PM 2.5 emissions	are	not	emi tted	from	these	engines at	a	steady	state. These	factors	are important	considerations	in	the	BACT	analysis	for	these	engines

.



### Step 1

– Identify all Control Technologies

The	first	step	in	the EPA	top‐down,	five‐ste p	analysis	is	to	id entify	all	available	control	technologies	that are	potentially	suitable	for	the affected	sources.		EPA's	RBLC search	was	used	to	obtain	potential	control technologies	for	PM/PM 10 /PM 2.5 from	main	diesel	engines	at	offs hore	sources.		The	most	recent 10‐year period	was	used	to	identify	appl icable	control	technologies.		T he	results	of	the	RBLC search	are	included in	Appendix	E.		However,	it	should	be	noted	that	the	control	te chnologies	evaluated in	the	“top‐down” analysis	for	main	propulsion	eng ines	were	not	limited	to	the	co ntrols	listed	in	the	RBLC	database.		The permits	recently	proposed/issued	b y	U.S.	EPA	Region	4	and	Regio n	10	(and	corresponding	permit applications)	for	similar	OCS	so urces	in	Gulf	of	Mexico	have	al so	been	reviewed	in	a ddition	to	surveying available	literature	to	identify potential	control	technologies .		The	search	results	for	potential	control technologies	for	PM/PM 10 /PM 2.5 from	the	main	diesel	eng ines	are	listed	below.

Baghouse

Use	of	Ultra	Low	Sulfur	Diesel (ULSD)	Fuel/	Low	Ash	Fuel

DOC

CDPFAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 116 Trinity Consultants Positive	Crankcase	V entilation	(PCV) 4‐Way	Catalyst	Converter Replacement	of	Engines	to	meet	h igher	EPA	Tier	st andards	(40	CF R	part	89,	94,	or	1042) Good	combustion	(Manufacturer	re commended	operation	and	mainten ance)	practices LNE	design	including	Turbochar ger	with	Aftercool er	and	High	Fue l	Injection	Pressure Fuel	Injection	T iming	Retard



### Step 2

– Eliminate Technically Infeasible Option

Baghouse – Infeasible

.

Baghouses	are	considered	to	be	tec hnically	infeasi ble	for	all	e ngines,	as	use	of	a	baghouse	would	lead	to a	high	pressure	drop	across	exha ust	flow	resulti ng	in	excessive back	pressure	on	th e	engine	that	could cause	plugging	of	the engine,	thus	posing	sa fety	concerns	for	t he	types	of	offshore	operations	proposed. The	pressure	drop	will	also	cause	a	reduction	in	fuel	economy. To	avoid	an	unacceptable	pressure	drop across	the	baghouse,	th e	use	of	a	large	fabric	area	would	be	re quired	which	in	tu rn	would	require	a significant	amount	of	space	on	a	vessel. 17 Required	space	would	include	the size	of	the	baghouse	itself as	well	as	the	removal	system	fo r	the	collected	material.		Inst allation	of	a	bagh ouse	would	require significant	space	reassignment	o n	a	drillship,	which	is	unavail able,	and	theref ore	may	require
recertification	of	the	vessel	itself.

DOC – Infeasible

.

Due	to	the	large	load	variations typical	of	these	exploratory	d rilling	operations,	t he	main	propulsion engines	are	not	able	to	sustain constant	steady	state	loads/exh aust	temperatures	for	sufficient	time periods	that	are	necessary	for	hi gh	catalyst	performance,	resul ting	in	limited	control.		Use	of	DOCs

would	also	lead	to	som e	pressure	drop	acro ss	exhaust	flow	resul ting	in	back	pressure on	the	engine	that could	cause	plugging	of	the	engi ne,	thus	posing	safety	concerns for	the	types	of	offshore	operations proposed.		Several	non‐combustibl e	chemical	elements	that	may	b e	present	in	engine lube	oils,	such	as phosphorous,	lead	and	heavy	meta ls,	may	collect	over	time	and	d amage	the	catalyst in	the	DOC.		This technology	has	not	been	designe d,	engineered,	or	tested	on	a	co mmercially	available	scale	for	safe operation	on	the	large scale	engines	found on	the	BlackHornet	d rillship.

CDPF – Infeasible

.

The	catalyst	in	the	CDPF	fil ter	reduces	emissions	of	PM/PM 10 /PM 2.5 and	THC	by	90	perc ent	but	requires sufficient	exhaust	temperatures	t o	facilitate	reg eneration	by	t he	catalyst. 18

CDPFs	add	back	pressure	on	the	eng ines	that	could	cause	pluggin g	of	the	engine,	thus	posing	safety concerns	for	the	types	of	offsho re	operations	proposed.		The	pr essure	drop	will	also	cause	a	reduction	in fuel	economy.		Due	to	load	varia tions,	the	main	propulsion	engi nes	onboard	the	BlackHornet	drillship cannot	typically	sustain	the	hig h	exhaust	temperatures	necessar y	for	optimal	regeneration	of	the catalyst.		This	technology	has not	been	designed,	engineered	or tested	on	a	commercially	available	scale for	safe	operation	on the	large	scale	engine s	found	on	the	Blac kHornet	drillship.

17

Based on Air Pollution Control Technology Fact Sheet for Fabric Filter, U.S. EPA, EPA-452/F-03-025.

18

Based on Alternative Control Techniques Document: Statio nary Diesel Engines (Final Report), Prepared For: Energy Strategies Group U.S. Environmental Protection Agency (EPA) Office of Air Quality Planning and Standards, March, 2010.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 117 Trinity Consultants Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042) – Not Applicable

.

The	main	propulsion	electrical	g enerator	engines	will	comply	wi th	PM	standards	specified	in	NSPS	IIII, which	is	the	most	stringent	PM	e mission	standard	for	this	categ ory	of	engines.		Hence,	there	is	no requirement	to	identify a	different	engine.

4

‐ Way Catalyst Converter – Infeasible

.

The	main	propulsion	engines	will not	be	able	to	sustain	constan t	steady	state	loads/exhaust temperatures	for	sufficient	time periods	that	are	critical	for high	catalyst	perfor mance,	resulting	in

inconsistent	emission	control.		S everal	non‐combustible	chemica l	elements	that	may	be	present	in engine	lube	oils,	such as	phosphorous,	lead and	heavy	metals,	m ay	collect	over	time	and	damage	the catalyst.

Fuel Injection Timing Retard – Infeasible

.

Changing	ignition	timing	is	not an	alternative	for	these	engine s	due	to	the	intrinsic	engine	design. Alterations	of	the	injection	timing	can	impact	value	performanc e.		Additionally,	use	of	this	technology can	reduce	engine	power	and	combus tion	stability	that	can	hinde r	operations.		For these	reasons	this technology	is	infeasible.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 13. Ranks of Technologies Feasible for Main Diesel Engines

Technology Efficiency Rank LNE	 design	 including	 Turbocharger	 with Aftercooler		and	High	Fuel	Injection	Pressure 30%	 1

Use	of	ULSD	 varies	 2

Good	Combustion	Prac tices		 Baseline	 N/A

All	 feasible	 technologies	 for	 the	 main	 propulsion	 engines	 are	 l isted	 in	 Table	 5‐13	 above.	 	 Control technologies	are	ranked	by	effi ciency	in	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document Results

Since	Anadarko	is	proposing	to	i mplement	all	feasible	technolog ies,	no	cost	feasi bility	is	required.

Step 5 ‐ Select BACT

Anadarko	proposes	compliance	wit h	NSPS	IIII,	LNE	design	includi ng	Turbocharger	with	Aftercooler	and High	Fuel	Injection	Pressure,	and	ULSD	usage	along	with	good	co mbustion	and	manufacturer recommended	operation	and	mai ntenance	practices	as	PM/PM 10 /PM 2.5 BACT	for	all	main	propulsion electrical	generator	engines.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 118 Trinity Consultants 

### 5.3.2. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Drillship Em ergency Generator (DR-GE-01)

Step 1

– Identify all Control Technologies

Similar	to	the	main	propulsion	e ngines,	the	emergency	generator is	also	a	large	(>500	HP)	diesel	engine, and	the	PM/PM 10 /PM 2.5 control	options	are	expected	to be	same	as	the	main	propulsion engines. Therefore,	the	same	options	identi fied	for	the	main	diesel	engi nes	are	considered	as	the	potential control	technologies	for the	emergency	generator



### Step 2

– Eliminate Technically Infeasible Options

DOC – Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

CDPF – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

4

‐ Way Catalyst Converter – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.3.1.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 14. Ranks of Technologies Feasible for the Emergency Diesel Engine

Technology Efficiency Rank Replacement	of	Engines	t o	meet	higher	EPA	Tier

standards Varies	 1

LNE	design	including	Tur bocharger	and	High	Fuel Injection	Pressure N/A	 2

ULSD	 N/A	 3 Good	Combustion	Practices			 Baseline	 N/A

All	feasible	technologies	for	th e	emergency	generator	engine	ar e	listed	in	Table	5‐14.		Control technologies	are	ranked	by	effi ciency	in	a	descending	order.



### Step 4

– Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89	Tier	2	standards	are	the	clean est	available	engines in	this	category	of engines.		There	is	no	add	on	techn ology	due	to	which	IMO	Tier	2 engines	could	be	cl assified	as	EPA	Tier 2	engines.		The	only	p ossible	option	is	to	replace	the	existing engine	with	EPA	Tier	2 certified	engine	and this	option	will	require	signific ant	redesigning	and	possible	r ecertification.

The	emergency	generator only	operates	intermittently	for	short periods	(2	hours	per	day	and	100	hours per	year)	and	it	is	primarily	de signed	to	handle	during	emergen cy	situation.		Given	the	small	emissions

and	trivial	emission	reduction	b enefit,	Anadarko	believes	a	com prehensive	cost	assessment	is	not

warranted.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 119 Trinity Consultants Step 5 ‐ Select BACT Anadarko	proposes	LNE	design	and	ULSD	usage	along	with	good	com bustion	and	manufacturer recommended	maintenance	practices	as	PM/PM 10 /PM 2.5 BACT	for	the	drillship	emergency	generator.



### 5.3.3. PM/PM 10 

### /PM 2.5 

### BACT Analysis for the Air Compressor Engine (DR-AC-01)

The	air	compressor	diesel	engin e	is	a	HATZ	2M41,	38.5	HP	engine

.



### Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	ob tain	potential	control	technolo gies	for	PM/PM 10 /PM 2.5 from	smaller emergency	diesel	engines	(<	500 HP)	and	review	of	the	permits	r ecently	proposed/issued	by	U.S.	EPA Region	4	and	Region 10	(and	corresponding	permit	applications) for	similar	OCS	sources	was	conducted to	obtain	potential	control	technologies	for	PM/PM 10 /PM 2.5 from	smaller	engines. The	most	recent	10‐ year	period	was	used	to	identify applicable	control	technologie s.		The	results	of	th e	RBLC	search	are included	in	Appendix	E.		The	sea rch	results	for	potential	contr ol	technologies	for	PM/PM 10 /PM 2.5 from smaller	diesel	engin es	are	listed	below.

DOC

CDPF 4‐Way	Catalyst	Converter Replacement	of	Engines	to	meet	h igher	EPA	Tier	st andards	(40	CF R	part	89,	94,	or	1042) LNE	design	including	Turbocharg er	and	High	Pressu re	Fuel	Inject ion
USLD	Fuel Good	combustion	practices	(man ufacturer	recommended	operation	a nd	maintenance)



### Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

CDPF –	Infeasible. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

4

‐ Way Catalyst Converter – Infeasible

. This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

LNE Design – Infeasible

. Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	engines,	making this	technology	to be	most	feasibly	installed	when	t he	engine	is	manufactured.		Re quiring	this	technolog y	would	essentially mean	having	to	replace	the	exist ing	air	compressor	diesel	engin es	with	other	air compressor	diesel engines	that	have	this	technol ogy	already	installed.		This	tech nology	is	intrinsic	to	the	engine	design	and retrofitting	the	air	compressor	di esel	engines	is	not	an	option

.

Step 3

– Rank Remaining Control Technologies by Control EffectivenessAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 120 Trinity Consultants Table 5

‐ 15. Ranks of Technologies Feasible for the Emergency Diesel Engine

Technology Efficiency Rank Replacement	of	Engines	t o	meet	higher	EPA	Tier

standards varies	 1

ULSD	 N/A	 N/A Good	Combustion	Practices	 Baseline	 N/A

Step 4

– Evaluate Most Effective Controls and Document Results

Engines	complying	with	40	CFR	89	Tier	3	standards	are	the	clean est	available	engines in	this	category	of equipment.		Anadarko	previously	o btained	an	initial	cost	estima te	of	$12,600	for	repla cing	a	similar	air compressor	with	an	air	compressor engines	compliant	with	40	CFR 89	Tier	3	standards.		Given	the minimal	operations	of	this	equip ment	resulting	in	low	emissions ,	Anadarko	believes	that	replacement	of existing	emergency	engine	with	t he	cleanest	available	engine	is cost	prohibitive.

Step 5 ‐ Select BACT

Anadarko	proposes	compliance	wit h	EPA	Tier	2	standards,	use	of ULSD	fuel	along	with	good	combustion and	manufacturer	recommended	opera tion	and	maintenance	practice s	as	PM/PM 10 /PM 2.5 BACT.



### 5.3.4. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Drillship Third Party Engines (DR-TP-01 through DR-TP-11 and DR-T P-17 though DR-TP-21)

Step 1

– Identify all Control Technologies

The	third	party	engines	on	the	d rillship	are	a	combination	of	s mall	(<500	HP)	and	large	(>500	HP)	diesel engines,	and	the	PM/PM 10 /PM 2.5 control	options	identified	for the	main	drillship	engines	are assumed	to sufficiently	account	fo r	all	the	possi ble	control	technologies for	the	third	party	en gines.		Therefore,	the same	options	identified	for	the drillship	main	diesel	engines	a re	considered	as	the	potential	control technologies	for	the	third	par ty	engines	on	the	drillship.



### Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

CDPF –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 121 Trinity Consultants Replacement of Engines to meet higher EPA Tier standards (40 CFR part 89, 94, or 1042 ) – Infeasible

.

The	cleanest	available	engine was	found	to	be	EPA	Tier	III	or	T ier	IV	certified.		However,	upon	further investigation,	the	vendors	noted that	EPA	Tier	III	and	Tier	IV certified	engines	constitute	a	small percentage	(i.e.,	approximately less	than	20%)	of	the	total	inv entory.

Due	to	constantly	changing	sched ules	during	the	proposed	operat ions,	the	availabili ty	of	these	third party	engines	changes on	short	notice.		Hence,	it	is	difficult to	determine	which	spec ific	engine	would	be brought	onboard	on	any	given	day.		Since	availability	of	the	EP A	Tier	III	and	Tier	IV engines	is	limited, there	is	no	guarantee	that	these	e ngines	will	be	a vailable	when Anadarko	would	need	them.		Restricting these	third	party	engi nes	to	EPA	Tier	III	o r	Tier	IV	certified engines	will	significantly	impact	the operations.		Hence,	this	option is	not	a	viable	BACT	option.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 16. Ranks of Technologies Feasible for the Third Party Engines

Technology Efficiency Rank LNE	design	 30%	 1 Good	Combustion	Practices	(Manufacturer Recommended	operation	and	maintenance procedures). Baseline	 N/A

All	 feasible	 technologies	 for	 th e	 third	party	engines	are	liste d	in	Table	5‐16.		Control	 technologies	are ranked	by	efficiency	i n	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document Results

Anadarko	proposes	compliance	with	40	CFR	89	EPA	Tier	2	standard s,	the	highest	ranked	among	the feasible	options,	as	BACT	for	th e	third	party	diesel	engines. Therefore	control	cost	analysis	is	not required.

Step 5 ‐ Select BACT

Anadarko	proposes	40	CFR	89	EPA Tier	2	standards and	LNE	design along	with	good	combustion	and manufacturer	recommended	operati on	and	maintenance	practices	as PM/PM 10 /PM 2.5 BACT	for	the	third party	engines.		As	indicated	prev iously,	the	third	party	engine s	and	the	horsepower ratings	shown	in this	application	are	for	represen tation	purposes	only.		However ,	a	well	completion	engine	brought	onto the	drillship	will	at	least	be	c ertified	to	40	CFR	89	EPA	Tier 2	or	higher	standards, with	equivalent	or

lower	emissions	than	t he	engine	represented.



### 5.3.5. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Third Party We ll Evaluation Engines (DR-TP12 through DR-TP-16)

Step 1

– Identify all Control TechnologiesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 122 Trinity Consultants The	third	party	well	evaluation	e ngines	on	the	drillship	are	fo ur	140	HP	diesel	engines,	and	the PM/PM 10 /PM 2.5 control	options	identified	for	the	drillship	main	propulsion	en gines	are	assumed	to sufficiently	account	for	all	the possible	control	technologies for	the	third	party	engines.		Therefore,	the	same options	identified	for	the	drillship	main	diesel	engines	are	co nsidered	as	the	potential	control	technologies for	the	third	party	engines	on	the	drillship.



### Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

CDPF –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	ident ified	in	Section	5.3.1.

Replacement of Engines to meet higher EPA Tier standards – Infeasible

.

The	five	third	party	well	evalua tion	diesel	engines	are	pre‐199 8	engines	and	hence	no	engine
certification	is	available.		Dur ing	one	of	the	w ell	evaluation activities	these	five	di esel	engines	will	be
used	to	send	information	to	a	lo gging	unit	powered by	third	par ty	engines.		Since	all of	these	engines	are used	to	power	different equipment	that	is	p erforming	a	single	o peration	they	are	all	leased	from	the same	third	party	vendor	to	avoid compatibility	issues.		The	thi rd	party	vendor	Anadarko	leases	these engines	from	currently has	no	EPA	Tier	certified	well	evaluatio n	engines	in	the	fleet .		Therefore,	this	is
not	considered	a	via ble	BACT	option.

LNE Design – Infeasible

.

Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	engines,	making this	technology	to be	most	feasibly	installed	when	t he	engine	is	manufactured.		Re quiring	this	technolog y	would	essentially mean	having	to	replace	the	exist ing	well	evaluation	compressor diesel	engines	with	other	air compressor	diesel	engines	that	ha ve	this	technology	already	ins talled.		This	technology is	intrinsic	to	the engine	design	and	retrofitting	the air	compressor	diesel	engine s	is	not	an	option.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

ULSD	fuel	usage	is	the	only	feas ible	option	followed	by	good	co mbustion	practices	(manufacturer recommended	operation	and	maint enance	practices).		Therefore,	r anking	is	not	required

.



### Step 4

– Evaluate Most Effective Controls and Document Results

ULSD	fuel	usage	is	the	only	feas ible	option.		Therefore,	rankin g	is	not	required

.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 123 Trinity Consultants 

### Step 5 ‐ Select BACT

Anadarko	proposes	ULSD	fuel	usag e	along	with	good	combustion	an d	manufacturer	recommended operation	and	maintenance	practices	as	PM/PM 10 /PM 2.5 BACT	for	the	third	party	well	evaluation engines.



### 5.3.6. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Representative Pump Engines on the Stimulation Vessel (SV-PE-01 thru SV-PE-08)

The	proposed	Stimulation	Vessel	will	have	eight	2,250	HP	pump	e ngines.

Step 1

– Identify all Control Technologies

Similar	to	the	main	propulsion	electrical	generator	engines,	th e	pump	engines	on	the	stimulation vessel	also	are	large	(>500	HP)	diesel	engines	and	the	PM/PM 10 

### /PM 2.5 

### control	options	are	expected

to	be	same	as	the	main diesel	engine.		There fore,	the	same	opti ons	identified	for	the	main	diesel engines	are	considered	as	the	po tential	control	technologies	fo r	the	pump	engines	on	the

stimulation	vessel.

Step 2

– Eliminate Technically Infeasible Options

DOC –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.3.1.

CDPF –	Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.3.1.

PCV

– Infeasible.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.3.1.

4

‐ Way Catalyst Converter – Infeasible

.

This	control	technology	is	deemed technically	infeasible	for	th e	same	reasons	identif ied	in	Section	5.3.1.

LNE Design – Infeasible

.

Incorporation	of	this	control	te chnology	will	involve	redesigni ng	the	pumps	making	this	technology	to be	most	feasibly	installed	when	t he	engine	is	manufactured.		Re quiring	this	technolog y	would	essentially mean	having	to	replace	the	existing	pumps	with	another	engine	t hat	has	this	technology	already installed.		This	technology	is	i ntrinsic	to	the	engine	design	a nd	retrofitting	the	pumps	is	not	an	option.

Step 3

– Rank Remaining Control Technologies by Control EffectivenessAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 124 Trinity Consultants Table 5

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

Technology Efficiency Rank Replacement	 of	 Engines	 to	 meet	 higher

EPA	Tier	standards varies	 1

ULSD	Fuel	 N/A	 2 Good	Combustion	Practices	(Manufacturer recommended	operation	and	maintenance practices) N/A	 N/A

All	 feasible	 technologies	 for	 th e	 representative	 pump	 engines	 a re	 listed	 in	 Table	 5‐17.	 	 Control technologies	are	ranked	by	effi ciency	in	a	descending	order.

Step 4

– Evaluate Most Effective Controls and Document Results

Replacement of Engines to meet higher EPA Tier standards

– 40	CFR	89	Tier	2	compliant	engine	was
identified	as	the	cleanest	avail able	engine	in	the	stimulation vessel	pump	engine	category	(SV‐PE‐01 through	SV‐PE‐08).		Anadarko	p reviously	performed	the	cost	effe ctiveness	analysis	for	replacing	the existing	engines	with	the	newer engines	meeting the	EPA	40	CFR 89	tier	2	standards.		As	shown	in Section	5.1.6,	this	option	was	con cluded	as	cost	prohibitive.

Step 5 ‐ Select BACT

Anadarko	proposes	use	of	ULSD	al ong	with	good	combustion	and	ma nufacturer	recommended	operation and	maintenance	practices	as	BAC T	for	the	pump	engines	on	the	s timulation	vessel.



### 5.3.7. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Flowba ck Boiler (DR-TP-22)

Step 1

– Identify all Control Technologies

The	proposed	flowback	boiler	is a	small	8	MMBtu/hr	diesel	fired combustion	source.		EPA's	RBLC	search was	used	to	obtain	potential	c ontrol	technologies	for	PM/PM 10 /PM 2.5 from	boilers	and review	of	the permits	recently	proposed/issued	b y	U.S.	EPA	Region	4	and	Regio n	10	(and	corresponding	permit applications)	for	similar	OCS	so urces	was	conducted	to	obtain	p otential	control	technologies	for PM/PM 10 /PM 2.5 from	boilers.		The	most	recent 10‐year	period	was	used	to	iden tify	applicable	control technologies.		The	results	of	th e	RBLC	search	are	included	in	A ppendix	E.		The	search	results	for potential	control	technologies	for	PM/PM 10 /PM 2.5 from	the	main	diesel	en gines	are	listed	below.



### Low	Sulfur	Fuel	(ULSD) Good	Combustion	Practices	(Manufacturer	Recommended	Operation	a nd	Maintenance	Practices).



### Step 2

– Eliminate Technically Infeasible Option

ULSD	– Feasible

.

Good	Combustion	Practices	– Feasible

.

Step 3

– Rank Remaining Control Technologies by Control EffectivenessAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 125 Trinity Consultants 

### Since	both	the	identified	technologies	are	being	proposed	as	BA CT,	no	ranking	is	required

Step 4

– Evaluate Most Effective Controls and Document Results

Since	both	the	identified	techno logies	are	being	proposed	as	BA CT,	a	cost	analysis	is	not	required.

Step 5 ‐ Select BACT

Anadarko	proposes	ULSD	 fuel	usag e	and	good	combustion	and	manuf acturer	recommended	operation and	maintenance	practices	as the	BACT	for	the	boiler.



### 5.3.8. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Boom Flare (DR-TP-23)

Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	obt ain	potential	control	technolo gies	for	PM/PM 10 

### /PM 2.5 

### from	flares and	review	of	the	permits	recent ly	proposed/issued	by	U.S.	EPA Region	4	and	Region	10	(and corresponding	permit	applications )	for	similar	OCS	sources	was conducted	to	obtain	potential control	technologies	for	PM/PM 10 

### /PM 2.5 

### from	flares.		The	most	recent	10‐year	period	was	used	to identify	applicable	control	tech nologies.		The	results	of	the	R BLC	search	are	inclu ded	in	Appendix	E. The	search	results	for	potential control	technologies	for	PM/PM 10 

### /PM 2.5 

### from	flares	are	listed

below.

Comply	with	40	CFR	60.18 Good	Combustion	Practices	(Manufacturer	Recommended	Operation	a nd	Maintenance	Practices).



### Step 2

– Eliminate Technically Infeasible Option

Comply	with	40	CFR	60.18	– Feasible

. Good	Combustion	Practices	– Feasible

.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	both	the	identified	technologies	are	being	proposed	as	BA CT,	no	ranking	is	required

Step 4

– Evaluate Most Effective Controls and Document Results

Since	both	the	identified	techno logies	are	being	proposed	as	BA CT,	a	cost	analysis	is	not	required.

Step 5 ‐ Select BACT

Anadarko	 proposes	 compliance	 w ith	 the	 requirements	 of	 40	 CFR	 60 .18	 and	 good	 combustion	 and manufacturer	recommended	operati on	and	maintenance	practices	as the	BACT	for	the	boom	flare.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 126 Trinity Consultants 

### 5.3.9. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Cement and Mud Mixing Operations (DR-DC01 thru DR-DC-03)

Step 1

– Identify all Control Technologies

A	RBLC	search	for	potential control	options	for	PM/PM 10 /PM 2.5 from	cement	and	mud	mixing	operations did	not	produce	any	results.		A lso,	a	review	of the	permits	rec ently	proposed/issued	by	U.S.	EPA	Region 4	and	Region	10	for	similar	OCS sources	was	performed.		The	sea rch	results	for	potential	control technologies	for	PM/PM 10 /PM 2.5 from	flares	are	listed	below.

Dust	Collectors



### Step 2

– Eliminate Technically Infeasible Option

Dust	Collectors	– Feasible



### .

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	dust	collectors	is	the	onl y	control	option	identified,	no ranking	is	required

Step 4

– Evaluate Most Effective Controls and Document Results

Since	dust	collectors	are	the	on ly	control	option	identified,	a cost	analysis	is	not	required.

Step 5 ‐ Select BACT

Anadarko	proposes	dust	collector s	with	proper	maintenance	and	o perations	as	PM/PM 10 /PM 2.5 BACT	for the	cement	and	mud	mixing	operations.



### 5.3.10. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Painting Operations (DR-PO-01)

An	RBLC	search	for	potential	control	options	for	VOC	from	paint ing	operations	on	a	drillship	did	not produce	any	results.		Also,	a review	of	the	permits	recently	pr oposed/issued	by	U.S.	EPA	Region	4	and Region	10	for	similar OCS	sources	did	not result	in	any	potenti al	control	technologies.	Therefore,

Anadarko	evaluated	various	trans fer	efficiencies related	to	pai nting	operations.

In	marine	environments,	the	pain t	could	be	applied	with	air	ass isted	paint	gun,	airless	paint	gun,	and	by

use	of	roller	or	brush.		The	tra nsfer	efficiency	of	each	paint application	method	is	provided	in	the	Table

below.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 127 Trinity Consultants Table 5

‐ 18. Paint Application and Transfer Efficiencies

Paint Application Method Transfer Efficiency Information Source Air	assisted	spray	gun	 30%		 Coat ing	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	chara cteristics	of	work	area s.		An	airless	spray gun	would	be	used	to	paint	large deck	areas	or	bulkheads	since greater	volume	of	pain t	and	fine	control is	not	required.		An	air	assist ed	spray	gun	would	be	required	t o	paint	piping,	bracke ts,	and	other	multi‐ angle	items	due	to	pai nt	volume	and	precis ion	requirements.		An airless	gun	requires	a	great	deal	of pressure	to	atomize	the	material for	spray.		Due	to	this	pressu re,	a	volume	of	material that	comes	out	of the	gun	is	increased	ma king	this	method	as a	preferred	painting method	on	flat	surfaces	or	tank applications.		However,	while	uti lizing	this	method	for	paintin g	multi‐angle	items,	a	lot	of	the	paint material	is	lost	creating	overspr ay	and	waste.		A	conventional air	assisted	gun	provide s	a	solution	to	this overspray	issue	due	to	its	opera tional	mechanism.		Therefore,	u se	of	air	assisted	spr ay	gun	is	preferred for	painting	small	or	multi‐angle	items.

Anadarko	also	considered	the	po ssibility	of	usin g	roller	or	bru sh	application	for	the	proposed operations.		However,	Anadarko	fo und	this	painting	technique	un suitable	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	dat a	sheet	is	approximately	5 mils	thick.		The	only	way	to	ach ieve	these	film	thicknesses	in a	single	application	is	to spray	the	coating.		A	single	application	with	a	roller	will	gen erate	approximately	1.5	mils in	thickness	per	application.		A	surface	would	have	to	be	paint ed	3	to	4	times	per	coat	to achieve	the	manufactures’	requi rements	for	coating	performance.

 To	achieve	good	film	continuity	most	of	the	marine	coatings	are designed	to	be	sprayed. The	atomization	of	the	coating	p romotes	a	good	flow	of	the	mate rial	and	creates	a	tight

surface	that	has	low	m oisture	permeation	whi ch	is	essential	for creating	a	barrier	system

and	makes	them	work.

 Throughout	the	drilling	and	well completion	operations,	paintin g	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	fo r	the	proposed	painting operations.		Anadarko	proposes	be st	management	practices	as	BAC T	for	the	painting	operations.		The best	management	practices	will	i nclude	down	spraying	of	paint	a nd	use	of	a	containment	system	such	as

a	shroud	or	a	barrier	around	the	s ection	of	the	ship	being	pain ted	to	prevent	the	airborne	paint	from drifting	into	the	atmosphere.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 128 Trinity Consultants 

### 5.3.11. PM/PM 10 

### /PM 2.5 

### BACT Analysis for Welding Operations (DR-WO-01)

Step 1

– Identify all Control Technologies

A	RBLC	search	for	potential control	options	for	PM/PM 10 /PM 2.5 from	welding	op erations	did	not produce	many	results.		Also,	a review	of	the	permits	recently	p roposed/issued	by	U. S.	EPA	Region	4	and Region	10	for	similar OCS	sources	was	performed.		The	results	o f	the	RBLC	search	are	included	in Appendix	E.		However,	it	should	b e	noted	that	the	control	techn ologies	evaluated	in	the	“top‐down” analysis	for	these	operations	w ere	not	limited	to	the	controls listed	in	the	RBLC	database.		The	search results	for	potential	contr ol	technologies	for	PM/PM 10 /PM 2.5 from	flares	are	listed	below.

Emission	Limit/Welding	Rod	Usage	Limit Best	Management	Practices Routing	to	Control	Device Body	Shop



### Step 2

– Eliminate Technically Infeasible Option

Routing to Control Device – Infeasible The	welding	process	results	in	n egligible	fugitive	emissions,	w hich	cannot	feasibly	be	captured	and

routed	to	a	control	device	with any	significant	control	efficie ncy.

Body Shop – Infeasible Due	to	available	space	constraints	on	the	drillship,	performing the	welding	operations	in	a	separate body	shop	with	options	to	route emissions	via	co ntrol	device	is technically	infeasible.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Table 5

‐ 19. Ranks of Technologies Feasible for the Welding Operations

Technology Efficiency Rank Emission	Limit/Welding	Ro ds	Usage	Limit	 N/A	 N/A Best	Management	Practices	 N/A	 N/A

All	feasible	technologies	for	th e	welding	operati ons	are	listed in	Table	5‐19.		Anadarko	is	proposing	all the	feasible	options	as	BACT.		T herefore,	ranking is	not	requir ed.



### Step 4

– Evaluate Most Effective Controls and Document Results

Since	all	the	identified	technol ogies	are	being	proposed	as	BAC T,	a	cost	analysis	is	not	required.



### Step 5 ‐ Select BACT

Anadarko	proposes	emission	limit ation/welding	rods	usage	limit and	best	management	practices	as PM/PM 10 /PM 2.5 BACT	for	the	welding	operations.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 129 Trinity Consultants A	summary	of	the	proposed	PM/PM 10 /PM 2.5 BACT	emission	limitation	for	ea ch	source	associated	with	the project	is	provided	be low	in	Table	5‐20.

Table 5

‐ 20. Proposed PM/PM 10 /PM 2.5 BACT Emission Limits

Emission Unit BACT Emission Limit BACT Basis BACT Control Technologies Drillship	Main	Diesel	Engines (DR‐ME‐01	thru	DR‐ME‐06) PM/PM 10 /PM 2.5

– 2.47E‐04	lb/Hp‐hr (0.15	g/KW‐hr) NSPS	IIII
Standards NSPS	IIII	standards, LNE	design	including Turbocharger	with Aftercooler	and	High
Fuel	Pressure Injection,	ULSD	and
Good	Combustion

Practices Drillship	Emergency	Diesel Engine	(DR‐GE‐01) ‐‐ AP‐42,	Chapter	3,
Table	3.4‐1 LNE	design,	ULSD	and
Good	Combustion

Practices Air	Compressor	Diesel	Engine (DR‐AC‐01) ‐‐ 40	CFR	89 EPA
Tier	2	Standard ULSD,	EPA	Tier	2
Standard
Good	Combustion

Practices Third	Party	Engines	(DR‐TP‐01 through	DR‐TP‐11	and	DR‐TP‐17 through	DR‐TP‐21) ‐‐ 40	CFR	89	EPA
Tier	2	Standard 40	CFR	89	EPA	Tier	2
Standard	and	LNE design Third	Party	Well	Evaluation Engines	(DR‐TP‐12	through	DR‐ TP‐16) ‐‐ AP‐42,	Chapter	3,
Table	3.3‐1 Good	Combustion

Practices

Stimulation	Vessel	Pumps	(SV‐ PE‐01	thru	SV‐PE‐08) ‐‐ AP‐42,	Chapter	3,
Table	3.4‐1 Good	Combustion

Practices Flowback	Boiler	(DR‐WC‐05)	 ‐‐ AP‐42,	Chapter	1,
Table	1.3‐1 Good	Combustion

Practices Boom	Flare	(DR‐WC‐06)	 ‐‐ AP‐42,	Chapter	1,
Table	1.4‐2 Compliance	with	40
CFR	60.18	and	Good
Combustion	Practices Cement	and	Mud	Mixing Operations	(DR‐DC‐01	thru DR‐DC‐03) ‐‐ AP‐42,	Chapter	11,
Table	11.12‐2 Dust	Collectors

Painting	Operations	(DR‐PO‐01)	 ‐‐ Paint	Composition	 Best	Managem ent
Practices Welding	Operations	(DR‐WO‐ 01)	 ‐‐ AP‐42,	Chapter	12,
Table	12.19‐1 Best	Management

PracticesAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 130 Trinity Consultants 

### 5.4. VOC BACT ANALYSIS FOR STORAGE TANKS AND PAINTS

The	storage	tanks	subject	to VOC	BACT	are	listed	below:



### 5.4.1. VOC BACT Analysis for Storage Tanks (DR-DT-01 thru DR-DT-09 and DR-FT01 thru DR-FT-03)

Step 1

– Identify all Control Technologies

EPA's	RBLC	search	was	used	to	ob tain	potential	control	technolo gies	for	VOC	from	storage	tanks	and review	of	the	permits	recently	pr oposed/issued	by	U.S.	EPA	Regi on	4	and	Region	10 (and	corresponding permit	applications)	for	similar OCS	sources	was	conducted	to	o btain	potential	control	technologies	for VOC	from	storage	tanks.		The	mos t	recent	10‐year	period	was	use d	to	identify	applicable	control technologies.		The	results	of	th e	RBLC	search	are	included	in	A ppendix	E.		The	search	results	for potential	control	technologies	f or	VOC	from	flares	are	listed	b elow.

Vapor	Recovery	Unit	(VRU) Thermal	Oxidation	(TO) Adsorption	System

Internal	or	External	Float ing	Roof	Tank	(IFR/EFR) Submersible	Fill	Pipe	(SFP)

Step 2

– Eliminate Technically Infeasible Option

VRU

– Infeasible

.

A	VRU	and	associated	vapor	colle ction	system	wou ld	require	a	si gnificant	amount	of	space	on	the drillship.		This	installation	would	require	significant	space	r eassignment	and	signifi cant	alterations	to the	drillship	that	would	result in	modifications	to	the	drillsh ip	design	and	recertification	of	the	drillship.

TO ‐ Infeasible.

A	thermal	oxidation	system	and	a ssociated	vapor	collection	syst em	would	require	a	si gnificant	amount of	space	on	the	drillship.		This installation	would	require	sig nificant	space	reassignment	and	significant alterations	to	the	drillship	tha t	would	result	in	modifications to	the	drillship	design	and	recertification	of the	drillship.		Furthermore,	the	a uxiliary	fuel	combustion	that would	be	necessary	for	an	incinerator	will generate	emissions	of	oth er	pollutants	such	as	NO X and	CO	that	may	exceed	the	small	benefit	in	VOC

emission	reductions	because	of	t he	small	amount	of	VOC	emission s	from	the	tanks.

Adsorption System ‐ Infeasible.

Adsorption	systems	are	not	as	efficient	when	controlling	low	co ncentrations	of	VOC	that	are	generated from	diesel	or	base	oil	storage tanks	as	opposed	to	the	higher VOC	concentrations	that	would	be generated	from	storage	of	higher vapor	pressure	m aterials	such as	gasoline.		Additionally,	an	adsorptionAnadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 131 Trinity Consultants system	will	require	a significant	amount	of	space	on	the	drills hip.		This	installa tion	would	require significant	space	reassignment	a nd	significant	alterations	to	t he	drillship	that	would	result	in modifications	to	the	drillship	design	and	recertification	of	th e	drillship.

IFR/EFR ‐ Infeasible.

Internal	and	external	floating	roof	tanks	are	typically	utilize d	to	control	VOC	emissions	from	stored liquids	with	high	vapor	pressures .		As	diesel	fuel	and	base	oil are	low	vapor	pressu re	liquids,	emissions of	VOC	from	the	storage	tanks	a re	expected	to	be	minimal	and	th e	associated	VOC	emissions	decrease associated	with	installation	of	a	floating	roof	would	be	minima l.		Additionally,	the	tanks	on	the BlackHornet	are	well	integrated	i nto	the	design	of	the	drillshi p.		Retrofitting	such	storage	tanks	with	a floating	roof	would	require	significant	space	reassignment	and significant	alteration s	to	the	drillship	in order	to	create	enough	space	to complete	the	ins tallation.		The se	alterations	would	result	in modifications	to	the	drillship	design	and	potentially	require	r ecertification	of	the	drillship.

SFP ‐ Infeasible.

While	the	accommodation	of	SFP	is not	difficult	in	the	design	s tage	of	a	new	tank,	eq uipping	an	existing tank	on	a	marine	vessel	is	expec ted	to	be	a	difficult	hurdle. Installation	will	require significant	space	for handling	of	the	equipm ent	and	safe	access	fo r	the	personnel.		M oreover,	storage	tanks	result	in	a	very

small	amount	of	VOC emissions.		Therefore, installing	SFPs	will only	result	in	a	very	small	reduction	in

the	VOC emissions,	would	be cost	prohibitive.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

There	are	not	technologies	that were	identified	as	feasible.

Step 4

– Evaluate Most Effective Controls and Document Results

There	are	not	technologies	that were	identified	as	feasible.

Step 5 ‐ Select BACT

Anadarko	proposes	good	maintenan ce	practices	as	BACT	for	the	st orage	tanks.



### 5.4.2. VOC BACT Analysis for Mud Dega ssing Operations (DR-VG-01)

An	RBLC	search	for	potential	control	options	for	VOC	from	mud	d egassing	operations	did	not	produce any	results.		Also,	a	review	of the	permits	recently	proposed/i ssued	by	U.S.	EPA	Region	4	and	Region	10

for	similar	OCS	sources	did	not result	in	any	potential	control technologies.		Th erefore,	Anadarko proposes	VOC	BACT	limit	of	5.36 tpy	on	a	12‐month	rolling	total basis.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Title V Permit Application 132 Trinity Consultants 

### 5.4.3. VOC BACT Analysis for Painti ng Operations (DR-PO-01)

An	RBLC	search	for	potential	control	options	for	VOC	from	paint ing	operations	on	a	drillship	did	not produce	any	results.		Also,	a review	of	the	permits	recently	pr oposed/issued	by	U.S.	EPA	Region	4	and Region	10	for	similar OCS	sources	did	not result	in	any	potenti al	control	technologies.	Therefore, Anadarko	proposes	best	managemen t	practices	as	BACT	for	the	pai nting	operations.		The	best management	practices	w ill	include	down	spraying	of	paint	and	us e	of	a	containment	system	such	as	a
shroud	or	a	barrier	aro und	the	section	of	the	ship	being	painte d	to	prevent	the	airborne	paint	from drifting	into	the	atmosphere.

Furthermore,	the	proposed	coatin gs	were	selected	based	on	follo wing	criteria:	regul atory	requirements, long	term	performance,	waste	reduc tion,	and	efficiency	of	appli cation.		All	of	the	proposed	paint materials	are	compliant	with	EPA the	marine	coatings	requiremen ts	as	specified	in	EPA	453/R‐94‐

032. 19 The	VOC	contents	of	a	coating greatly	influence	the	prospecti ve	application	area	(e.g.,	flat	or metallic)	as	well	as	method	of	a pplication	(e.g.,	spray	or	roll er).

A	summary	of	the	proposed	VOC	BAC T	emission	limitation	for	each source	associated	with	the	project	is provided	below	in	Table	5‐21.

Table 5

‐ 21. Proposed VOC BACT Emission Limits

Emission Unit BACT Basis BACT Control Technologies Storage	Tanks	 TANKS	4.09.d Best	Management

Practices Mud	Degassing	Operations (DR‐VG‐01) Minerals Management
Service	Guidance Best	Management

Practices

Painting	Operations	(DR‐PO‐01) Paint +	Thinner Composition Best	Management

Practices



### 5.5. GREENHOUSE GAS (GHG) BACT ANALYSIS

On	May	13,	2010,	the	U.S.	EPA	issu ed	the	final	“Prevention	of	S ignificant	Deterioration	and	Title	V Greenhouse	Gas	Tailoring	Rule”	sp ecifying	that	as	of	January	2, 2011,	all	new	indust rial	sources	that are	major	sources	for any	NSR	regulated	pol lutants	other	than	G HGs,	and	will	emit	or	have	the potential	to	emit	75,000	tons	per year	or	more	of	total	GHGs,	o n	a	CO 2 equivalent	(CO 2 e)	basis	will

need	to	determine	the	Best	Avail able	Control	Technology	for	the ir	GHG	emissions. 20

19 Alternate	Control	Techniques:	S urface	Coating	Operations	at	Sh ipbuilding	and	Ship	Repair	Facilities,	April
1994.	Available	online	at: http://www.epa.gov/glo/SIPToolkit/ctg_act/199404_voc_epa453_r‐9 4‐ 032_coating_shipbuilding_repair.pdf

20 CO 2 equivalent	encompasses	a	list	o f	six	Greenhouse	Gases,	includi ng	carbon	dioxide,	methane,	nitrous oxide,	hydrofluorocarbons,	perfl uorocarbons,	and	sulfur	hexaflu oride.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Ti tle V Permit Application 133 Trinity Consultants 

### 5.5.1. GHG BACT Analysis for the Diesel Fi red Internal Combustion Engines

The	majority	of	Greenho use	Gas	emissions	fr om	diesel	engines	ar e	in	the	form	of	carbon	dioxide (CO 2 ).		CO 2 is	formed	during	complete	combu stion	of	diesel in	the	combusti on	chamber	when	carbon

in	the	fuel	is	converted	to	CO 2

.



### Step 1

– Identify all Control Technologies

The	first	step	in	the EPA	top‐down,	five‐ste p	analysis	is	to	id entify	all	available	control	technologies that	are	potentially	suitable	for the	affected	sources.		The	re sults	of	the	RBLC	search	did	not	identify GHG	control	technologies	since	GHG	emission	control	is	still	an emergency	area	of	technology. However,	it	should	be noted	the	control	tech nology	analysis	for all	internal	combustion	engines

were	not	limited	to	the	controls listed	in	the	RBLC	database. The	permits	recentl y	proposed/issued by	U.S.	EPA	Region	4	and	Region 10	(and	corresponding	permit	ap plications)	for	si milar	OCS	sources

in	Gulf	of	Mexico	have	also	been reviewed	in	addition	to	survey ing	available	litera ture	to	identify potential	control	technologies. The	following	technologies	wer e	identified	as	potentially	applicable for	controlling	CO 2 e	emissions	from	the	diesel	engines:

Carbon	Capture	Storage	(CCS); Alternative/Biomass	Fuel	Sources;

CSNOx	Emissions	Ab atement	System;

Good	Combustion	and	Manufacturer Recommended	Maintenance	Practi ces.



### Step 2

– Eliminate Technically Infeasible Option

CCS – Infeasible

.

Carbon	Capture	and	Storage/	Car bon	Sequestration	refers	to	the processes	in	which	CO 2 that	would
otherwise	be	emitted	into	the	a tmosphere,	is	captured	and	store d.		This	process	requires	the separation	and	capture	of	CO 2 at	the	point	of	emissions,	tra nsportation	of	the	captured	CO 2 to	the storage	location,	and	st oring	the	captured	CO 2 in	deep	underground	geolog ic	formations	in	such	a way	that	it	will	remain permanently	stored.		Potential	sites	fo r	underground	storage	of	CO 2 are mature	oil	and	natura l	gas	reservoirs,	deep unmineable	coal	sea ms,	deep	saline	fo rmations,	oil	and gas	rich	organic	shales,	and	basalt	formations 21 .		Injection	of	captured	CO 2 into	the	ocean	at	great depths	has	also	been	proposed	as	a	potential	option	to	isolate CO 2 from	the	atmosphere	for

centuries 22

.

The	diesel	fired	engines	on	the BlackHornet	Drillship	and	assoc iated	project	operations	are	designed for	and	rely	on	air‐fired	combust ion,	a	process	that	exhausts	C O 2 diluted	with	nitrogen,	wherein	the flue	gas	contains	a	relatively	sm all	percentage	(under	20%	by	v olume)	of	CO 2 .		For	effective	carbon sequestration,	 the	 CO 2 in	 the	 exhaust	 gases	 must	 be	 separated	 and	 concentrated.	 	 Curr ently	 an effective	 method	 for	 recovering	 CO 2 from	 combustion	 exhaust	 is	 by	 using	 amine	 absorbers	 and cryogenic	coolers.

21 Carbon	Sequestration	Atlas	of	the	United	States	and	Canada,	U.S .	Department	of	Energy,	Office	of	Fossil	Energy,	National	Energ y Technology	Laboratory.

22 Carbon	Dioxide	Capture	and	Storage,	Intergovernmental	Panel	on Climate	Change	(IPCC),	2005	‐	Be rt	Metz,	Ogunlade	Davidson, Heleen	de	Coninck,	Manuela	Loos	and	Leo	Meyer	(Eds.),	Cambridge University	Press,	UK.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Ti tle V Permit Application 134 Trinity Consultants Currently	there	are	no	k nown	mature	oil	and natural	gas	reservo irs	in	relative	proximity	of	the	areas proposed	 for	 exploratory	 drilling that	 can	 potentially	 be	 consi dered	 for	 geological	 sequestration. Furthermore,	the	exhaust	from	di esel	engines	is	diluted	with	ni trogen	in	the	air	and	the	CO 2 must	be separated	 prior	 to	 transport	 for	 storage.	 	 This	 separation	 has to	 be	 achieved	 using	 an	 absorption process	 that	uses	 the	chemical reaction	of	an	aqueous	alkaline solvent,	usually	an	amine,	with	 the exhaust	gases.		This	process	will require	the	addition	of	equip ment	such	as	absorber	columns,	stripper columns,	condensers,	reboilers,	heat	exchangers,	etc.		Installa tion	of	such	equipment	would	require significant	space	reassignment	o n	the	drillship,	which	is	unava ilable.

Before	 deploying	 technologies	 tha t	 will	inject	 captured	 and	 sep arated	 CO 2 into	 the	 ocean	 at	 great depths,	 such	 technologies	 would require	 further	 development	 and field	 testing.	 	 Currently	 such technologies	have	only	been	teste d	in	laboratory	experiments. Furthermore,	putting	CO 2 directly	into the	deep	ocean	means	that	the	ch emical	environment	of	the	deep ocean	would	be	altered	immediately. Given	 only	 rudimentary	 understanding	 of	 deep‐sea	 ecosystems,	 on ly	 a	 limited	 and	 preliminary assessment	of	potential	ecos ystem	effects	can	be	given 23

.

Even	 if	 the	 above	 constraints	 are	 overcome,	 separated	 CO 2 from	 the	 drillship	 would	 have	 to	 be transported	using	pipelines	to	t he	storage	location.		Given	the mobile	nature	of	the	exploratory	drilling operations	 and	 thus	 the	 emission	 u nits,	 it	 will	 be	 infeasible	 t o	 connect	 the	 drillship	 with	 a	 static pipeline	infrastructure	to	transport	CO 2

.

Biomass Fuel Sources ‐ Biodiesel – Infeasible

Biodiesel	is	a	fuel	made	from	pl ant	or	animal	feedstocks,	and	m ay	be	used	in	conventional	diesel engines.	Biodiesel	is	comprised of	specific	chemical	components defined	by	ASTM	as	"mono‐alkyl esters	of	long	chain	fatty	acids	derived	from	vegetable	oils	or animal	fats."	In	the United	States,	most biodiesel	is	made	from	soybean	o il.	However,	canola	oil,	sunflo wer	oil,	recycled	cooking	oils,	palm oil,	animal	fats,	and	other	oils are	also	used	as	feedstocks. Biodiesel	in	its	pu re	form	is	known	as B100,	but	it	can	be	blended	with	c onventional	diesel	fuel.	The most	common	blends	are	B5	(5 percent	biodiesel	and 95	percent	conventional	diesel)	and	B20	( 20	percent	biodiesel	and	80	percent conventional	diesel) 24 .		Because	biodiesel	is	made	using	feedstock	that	contain	carbo n	taken	from the	biosphere,	the	combustion	of	b iodiesel	does	not	add	new	car bon	and	so	does	not	add	to	GHG emissions.		However,	the	product ion	of	biodiesel	may	involve	us e	of	fossil	fuel	based	carbon. The	diesel	fired	engines	onboard the	BlackHornet	Drillship	and associated	project	operations	are	not designed	 to	 burn	 biodiesel	 and	 t here	 could	 be	 potential	 engine performance	 issues	 from	 use	 of biodiesel.		Use	of	biodiesel	may	result	in	degradation	of	some fuel	lines	and	gaskets	(e.g.	those	made from	nitrile	and	natural	rubber).		Biodiesel	use	also	results	i n	reduced	power	and	fuel	efficiency	of engines,	thus	impairing	the	abil ity	to	safely	maintain	the	vess el's	position	and	perform	other	functions related	to	the	proposed	offshore	operations	such	as	drilling,	c ementing,	and	wireline.		Requirements for	 handling	 and	 using	 biodiesel may	 differ	 from	 requirements	 f or	 petroleum‐based	 diesel.	 For example,	 biodiesel	 can	gel	at	lo w	 temperatures	and	may	 require special	 handling	in	 cold	 climates

23 Carbon	Dioxide	Capture	and	Storage,	Intergovernmental	Panel	on Climate	Change	(IPCC),	2005	‐	Be rt	Metz,	Ogunlade	Davidson, Heleen	de	Coninck,	Manuela	Loos	and	Leo	Meyer	(Eds.),	Cambridge University	Press,	UK.

24 Guidance	for	Biodiesel	Producers and	Biodiesel	Blenders/Users, Transportation	and	Regional	Programs	Division	Office	of Transportation	and	Air	Quality,	U.S.	Environmental	Protection	A gency,	EPA420‐B‐07‐0 19,	November	2007.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Ti tle V Permit Application 135 Trinity Consultants during	winter.		There	may	also	be degradation	of	biodiesel	due to	long	storage	 times 25 .		Biodiesel

combustion	also	resul ts	in	increase	in	NO X emissions	and	decrease	in PM,	CO,	and	VOC	emissions 26

.

CSNOx Emission Abatement System – Infeasible

ECOSPEC	Global	Technology	PTE	Lt d	has	patented	the	CSNOx	emissi ons	abatement	system	that	is designed	to	convert	CO 2 in	exhaust	gases	from ship	engines	into	bicarbonates,	using	Ul tra	Low Frequency	(ULF)	wave	electrolys is	treatment	to	increase	the	alk alinity	of	the	seawa ter	injected	into a	scrubber.		Seawater	is	pumped	in to	the	control	system	from	t he	ocean	using	suction	pumps, making	the	system	ideal	for	offs hore	applications.		The	system has	been	tested	onboard	a	100,000‐ tonne	oil	tanker,	at	50%	gas	load	(equivalent	to	approximately 5	MW	engine	output),	yielding	a	CO 2 removal	efficiency	of	77% 27 28

.

The	CSNO X technology	has	been	designed	fo r	and	tested	on	vessels	that	op erate	at	stable	loads continuously.		Such	operations	pr ovide	exhaust	gases	that	are	c onsistent	in	their	composition	and properties	over	long	periods	of time,	thereby	facilitating	effi cient	operation	of	the control	processes. Due	to	the	large	load	variation swing	demanded	by	the	proposed exploratory	drilli ng	operations	on
the	drill	floor	and	oth er	applications,	the diesel	fired	engine s	onboard	the	BlackHornet	drillship	and associated	project	operations	will	not	be	able	sustain	constant steady	state	loads for	sufficient	time periods.		The	CSNO X technology	has	not	been	tested or	proven	effective	for	engines with	these	types

of	load	variations.

Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	all	the	remaining	feasible technologies	are	being	propose d	as	BACT,	no	ranking	is	required

Step 4

– Evaluate Most Effective Controls and Document Results

Anadarko	proposes	all	the	feasible	options,	as	BACT	for	the	die sel	fired	engines.		Therefore,	control cost	analysis	is	not	required.

Step 5 ‐ Select BACT

Anadarko	proposes	good	combustio n	and	manufacturer	recommended maintenance	practices	for	all

diesel	 fired	 internal	 combustion engines	 associated	 with	 this	 p roject	 operation.	 	 Additionally	 all control	 technologies	 that	 aid	 im prove	 the	 combustions	 efficienc ies	 of	 the	 various	 diesel	 engines discussed	in	the	previous	sections	of	the	BACT	are	also	propose d	as	BACT	for	GHGs.



### 5.5.2. GHG BACT Analysis for Mud Dega ssing Operations (DR-VG-01)

A	RBLC	search	for	potential	cont rol	options	for	GHG	from	mud	de gassing	operations	did	not	produce any	results.		Also,	a	review	of the	permits	recently	proposed/i ssued	by	U.S.	EPA	Region	4	and	Region

25 Guidance	for	Biodiesel	Producers and	Biodiesel	Blenders/Users, Transportation	and	Regional	Programs	Division	Office	of Transportation	and	Air	Quality,	U.S.	Environmental	Protection	A gency,	EPA420‐B‐07‐0 19,	November	2007.

26 A	Comprehensive	Analysis	of	Biodiesel	Impacts	on	Exhaust	Emissi ons,	Draft	Technical	Report	Assessment	and	Standards	Division, Office	of	Transportation	and	Air	Quality,	U.S.	Environmental	Pr otection	Agency,	EPA 420‐P‐02‐001,	October	2002.

27 CSNO X Brochure	from	http://www.ecospec.com	,	last	accessed	on	August 28,	2010.

28 Regulatory Impact Analysis: Control of Emissions of Air Pollution from Category 3 Marine Diesel Engines ,	Assessment	and	Standards Division,	Office	of	Transportation	and	Air	Quality,	U.S.	Enviro nmental	Protection	Agency,	December	2009.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Ti tle V Permit Application 136 Trinity Consultants 10	for	similar	OCS	sources	did	no t	result	in	any	potential	cont rol	technologies.		Therefore,	Anadarko proposes	GHG	BACT	limit	of	271.37 tpy	on	a	12‐month	rolling	tot al	basis.



### 5.5.3. GHG BACT Analysis for Flow back Boiler (DR-TP-22)

A	RBLC	search	for	potential	cont rol	options	for	GHG	from	boiler operations	did	not	provide	a specific	control	technology.		A lso,	a	review	of	the	permits	rec ently	proposed/issued	by	U.S.	EPA Region	4	and	Region	10	for	simila r	OCS	sources	di d	not	result	i n	any	potential	control	technologies. Therefore,	Anadarko	proposes	good combustion	practices	along	wi th	manufacturer	recommended operations	and	maintenanc e	practices	as	BACT.



### 5.5.4. GHG BACT Analysis for B oom Flare (DR-TP-23)

Step 1

– Identify all Control Technologies

A	 review	 of	 the	 permits	 recently	 proposed/issued	 by	 U.S.	 	 EPA	 R egion	 4	 and	 Region	 10	 (and corresponding	permit	applications)	for	similar	OCS	sources	was conducted 

### for flaring operations on a MODU did not produce any results. The	most	recent	10‐year	period	was	used	to	identify	applicabl e control	technologies.				The	search	results	for	potential	contr ol	technologies	for	GHG	from	flares	are

listed	below.

Comply	with	40	CFR	60.18

Good	Combustion	and	Manufacturer Recommended	Maintenance	Practi ces Proper	Equipment	Des ign	and	Maintenance

Maintain	Presence	of	Flame at	Flare	Tip	at	all	times Flare	gas	minimization



### Step 2

– Eliminate Technically Infeasible Option

Maintain Presence of Flame at Flare Tip at all times –	Infeasible.

Since	the	boom	flare	is	portable this	option	is	not	feasible.

Flare Gas Minimization –	Infeasible.

Redesigning	 to	meet	 this	 operati on	would	likely	 require	 a	 recon figuration	 of	 piping	 during	 a	well

control	situation	and	is	not	fea sible.		This	would	include	rero uting	gas	that	would	have	been	sent	to the	 flare	 back	 to	 the	 process	 to minimize	 emissions	which	 are	i nfeasible	 during	 off	 shore	 drilling

process.



### Step 3

– Rank Remaining Control Technologies by Control Effectiveness

Since	all	the	remaining	feasible technologies	are	being	propose d	as	BACT,	no	ranking	is	required



### Step 4

– Evaluate Most Effective Controls and Document Results

Since	 all	 the	 remaining feasible	 technologies	 are	 being	 propose d	 as	 BACT,	 a	 cost	 analysis	 is	 not required.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Ti tle V Permit Application 137 Trinity Consultants 

### Step 5 ‐ Select BACT

Anadarko	proposes	manufacturer	recommended	good	combustion	oper ating	practices,	and	proper

maintenance	of	flare	as	the BACT	for	the	boom	flare.

Table	5‐21	below	summarizes	EPA’ s	BACT	determinations	for	the	d iesel	internal	combustion	engines with	respect	GHG	emissions.		The respective	emission	limits	are based	on	AP‐42	and	 the	emission
factors	 for	 CO 2 e	 were	 determined	 using	 the	 globa l	 warming	 potentials	 obtained from	 40	 CFR	 98 Subpart	C.Anadarko Petroleum Corporation | Diamond BlackHornet EGOM PSD/Ti tle V Permit Application 138 Trinity Consultants A	summary	of	the	proposed	GHG	BAC T	emission	limitation	for	each source	associated	with	the	project is	provided	below	in	Table	5‐22.

Table 5

‐ 22. Proposed CO 2 e BACT Emission Limits

Emission Unit BACT Emission

Limit BACT Basis BACT Control Technologies

Drillship	Main		Engines (DR‐ME‐01	thru	DR‐ME‐06) 699	g/KW‐hr

CO 2 e 40	CFR	98 Subpart	C LNE	Design	with Turbocharger	with Aftercooler	&	High	Injection Pressure,	Optimized Supercharger	with	Miller Cycle,
Good	combustion	and
manufacturer
recommended	maintenance practices Drillship	Emergency Generators	(DR‐GE‐01) ‐‐ 40	CFR	98 Subpart	C Turbocharger	with Aftercooler	&	High	Injection Pressure,
Good	combustion	and
manufacturer
recommended	maintenance practices Emergency	Air	Compressor Engine	(DR‐AC‐01) ‐‐ 40	CFR	98 Subpart	C Good	combustion	and
manufacturer
recommended	maintenance practices Third	Party	Engines		 ‐‐ 40	CFR	98 Subpart	C Good	combustion	and
manufacturer
recommended	maintenance practices Stimulation	Vessel	Pumps	(SV‐ PE‐01	thru	SV‐PE‐07) ‐‐ 40	CFR	98 Subpart	C Good	combustion	and
manufacturer
recommended	maintenance practices Flowback	Boiler	(DR‐TP‐22)	 ‐‐ 40	CFR	98 Subpart	C Good	combustion	and
manufacturer
recommended	maintenance practices Boom	Flare	(DR‐TP‐23)	 ‐‐ 40	CFR	98 Subpart	C Good	combustion	and
manufacturer
recommended	maintenance practices Mud	degasser	Vent	(DR‐VG‐01)	 ‐‐ 40	CFR	98 Subpart	C Best	management	practices
and	manufacturer
recommended	maintenance practices