*** Public Notice Copy***

03/30/2012 DRAFT Permit OC S

- EPA

- R4008 

## UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Atlanta, Georgia

Permit to Construct and Operate Under the

Outer Continental Shelf Air Regulations

Permit No . OCS

- EPA

- R400 8

In accordance with the provisions of s ection 328 of the Clean Air Act (CAA), 42 U.S.C. § 7627 and the implementing Outer Continental Shelf (OCS) Air Regulations at t itle 40 Code of Federal Regulation s (CFR) part 55, which incorporate by reference the Prevention of Significant Deterioration (PSD) of Air Quality Regulations at 40 CFR § 52.21, and the title V Operating Permit Program at 40 CFR part 71

,

BHP Billiton Petroleum, Inc. 1360 Post Oak Blvd., Suite 150 Houston, Texas 770 56

is hereby authorized to construct and operate air emissions units and to conduct other air pollutant emitting activities at an OCS source at multiple sites within the Gulf of Mexico, DeSoto Canyon lease blocks 499, 543

- 545, 586

- 592, 631

- 640, 676

- 685, 721

- 729, 768

- 773, and 815

- 817 . The center of the contiguous lease blocks is located on OCS waters of the Gulf of Mexico e ast of longitude 87.5 o W at

latitude 28.31 o N and longitude 86.96 o W

, approximately 1 2 0 miles from nearest Louisiana shoreline,

139 miles from the nearest Miss issippi shoreline, and 125 miles from the nearest Alabama and Florida

shorelines

.

Upon initial start

- up, this OCS source and support vessels shall be constructed and operated in accordance with the terms and conditions set forth in this permit.

This p ermit shall become effective on : [ insert effective date 3 0 days after the date of the service of notice of the final permit decision under 40 CFR 124.15, unless review of the permit decision is requested in accordance with 40 CFR 124.19; or if no comments requested a change in the draft permit, the permit shall become effective immediately upon issuance].

This permit shall expire two years from the date the OCS source c ommences activity on the identified DeSoto Canyon lease blocks, not to exceed [insert date five years from effective date].

This permit shall not relieve the owner or operator of the responsi bility to comply fully with all applicable provisions of federal and state law.

__________ ______________________ Date Signed Beverly H. Ba nister

Director Air, Pesticides, and Toxics Management Division03/30/2012 BHPB DRAFT Permit OCS

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1 AUTHORITY

The United States Environmental Protection Agency (EPA) issues this permit pursuant to section 328 of the CAA, 42 U.S.C. § 7627, and the implementing OCS Air Regulations at 40 CFR part 55, which incorporate by reference the PSD Regulations at 40 CFR § 52.21 and the title V Operating Permit Program at 40 CFR part 71. This permit is based upon application materials submitted to EPA by

BHP Billiton Petroleum, Inc., (BHPB) dated October 14 , 2010, February 9, 2011, September 30, 2011, October 14, 2011, December 21, 2011, January 18, 2012

, supplemental submittals in the administrative record for this permit action, and upon the technical analysis performed by EPA.

2 APPLICANT

BHP Bi lliton Petroleum, Inc. 1360 Post Oak Blvd., Suite 150 Houston, Texas 77056

3 PROJECT LOCATION

BHP B ’s project is located in the OCS waters of the Gulf of Mexico, DeSoto Canyon area, within lease
blocks 499, 543

- 545, 586

- 592, 631

- 640, 676

- 685, 721

- 729, 768

- 773, and 815

- 817. These contiguous lease blocks are found approximately within latitude 28.15° to 28.50° N and longitude 86.68° to

87.27° W, east of longitude 87.5° W. The center of the lease block area is located at 28.31° N and longitude 86.96° W, ap proximately 120 miles from nearest Louisiana shoreline, 139 miles from the nearest Mississippi shoreline, and 125 miles from the nearest Alabama and Florida shorelines.

4 PROJECT DESCRIPTION

BH P B’s project, known as the Sake Prospect Drilling Project (Sake Project)

, is an oil and natural gas explor ation drilling campaign for a period of up to two years using a mobile offshore drilling unit (MODU) and associated support vessels described in this section. BH P B will use either the Transocean

ultra

- deepwater dri llship C.R. Luigs MODU (Operating Scenario 1) or the Transocean semisubmersible Development Driller 1 MODU (Operating Scenario 2) . Under either o perating s cenario, BHPB will conduct drilling activities in multiple locations within the DeSoto Canyon lease block locations listed in

Section 3 , Project Location, of this permit

. This permit does not authorize the establishment of any permanent production facilities.

Air pollutant emissions generated from the Sake Project include carbon monoxide (CO), nitrogen dioxide (NO 2 ) ; particulate matter (PM) which includes PM with an aerodynamic diameter less than 10 microns (PM 10 ) and with an aerodynamic diameter less than 2.5 microns (PM 2.5 ) ; and sulfur dioxide (SO 2 ) (known as criteria pollutants), as well as other regu lated air pollutants, including oxides of nitrogen (NO X ), volatile organic compounds (VOC), and greenhouse gases (GHGs). VOC and NO X are the measured precursors for the criteria pollutant ozone, and NO X and SO 2 are measured precursors for the criteria poll utant PM 2.5

. Based on emissions estimates and applicable permitting thresholds, both operating scenarios are subject to the PSD and title V programs and have significant emissions of NO X , CO, PM 10 , PM 2.5 , VOC, and GHG s . The project emissions of VOC and NO X are measured precursors for the criteria pollutant ozone and NO X is a measured precursor for PM 2.5

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The C.R. Luigs emission units consists of eight main power plant diesel engines to provide power and propulsion, four crane diesel engines, one emergency diesel generator, and a black start compressor diesel engine. The cementing operations use two cementing unit diesel engines and a portable cementing nitrogen pump diesel engine. The wireline operations are intermittent and use up to four small portable

di esel engines. The four life boats and the one fast rescue craft are powered by diesel engines. In

addition

, there is one mud degassing unit and two dust collectors for mud and cement. There are 29 tanks to store diesel fuel, one tank for hydraulic oil, on e tank for base oil, and two tanks to store Jet A

helifuel. A list of all emission units is in Table 1.

The Development Driller 1 ( DD1 ) emission units consist of eight main power plant generator diesel engines to provide power and propulsion and one emerg ency diesel generator. The cementing operations use two cementing unit diesel engines, a batch mixer diesel engine, and a portable cementing nitrogen pump engine. The wireline operations are intermittent and use up to four small portable diesel engines.

Th e four life boats and the one fast rescue craft are powered by diesel engines. In addition

, there is one mud degassing unit and two dust collectors for mud and cement. There are 21 tanks to store diesel fuel, one base oil tank, and four tanks to store Jet A helifuel. A list of all emission units is in Table 2.

Support vessels operating within 25 miles of either operating scenario will include offshore supply, work boats, and crew boats that run marine diesel engines.

The information provided in Tables 1

- 3 is for description and identification purposes and does not establish operating limits.

Table 1

– C.R Luigs Emissions Units (Operating Scenario 1)

Emissions

Unit ID Engine Description Manufacturer Model Rating a ( h p ) * Mfg

Year

EU

- 001

- 008 Main Power Plant Diesel Engines 1

- 8 MAN B&W 9L32/40

- 47 5,875 1998

EU

- 009 Port Fwd Crane Diesel Engine Caterpillar 3406 305 1998

EU

- 010 Port Aft Crane Diesel Engine Caterpillar 3406 305 1998

EU

- 011 Stb Fwd Crane Diesel Engine Caterpillar 3406 305 1998

EU

- 012 Stb Aft Crane Diesel Engine Caterpillar 3406 305 1998

EU

- 013 Mud and Cement Mixing Dust Collectors Metroplex Products CR400R

- 129 NA

-- EU

- 014 Mud Degassing Operations

-- -- NA

-- EU

- 015 Emergency Generator Diesel Engine Caterpillar D3516A 2,064 1998

EU

- 016

- 17 Cement Units 1

- 2 Diesel Engines Caterpillar 3412 CDITA 860 2001

EU

- 018 Cementing Nitrogen Pump Diesel Engine b Caterpillar or similar 3406 CDITA

or similar 490 2000

EU

- 019 POSU

- CA Primary Wireline Unit Diesel Engine

Hydraulic Generator Combination b Caterpillar or similar C

- 7 DITA or

similar 300 2009

EU

- 020 Wireline Unit Alt #2 Diesel Engine b Caterpillar or similar C

- 7 DITA or

similar 300 2008

EU

- 022 Wireline Unit Power P lant GSU

- W Generator b Various Various 160 Various

EU

- 023 Wireline Unit Hydraulic Diesel Generator DHPS b Various Various 160 Various

EU

- 024 Fast Rescue Craft Diesel Engine Steyr Motors M0144M38 142 2008

EU

- 025

- 028 Lifeboat Diesel Engines 1

- 4 Bukh DV36

- 39 39 1998

EU

- 029

- 050 Various Diesel Fuel Tanks

-- -- NA

-- EU

- 051 Hydraulic Fluid Tank

-- -- NA

-- EU

- 052 Base Oil Tank

-- -- NA

-- EU

- 053

- 059 Cement and Wireline Unit Diesel Fuel Tanks

-- -- NA

-- EU

- 060 Workboat Diesel Engines (See Table 3) Various Various 10,632 Various

EU

- 061 Fast Crew Boat Diesel Engines (See Table 3) Various Various 4,800 Various

EU

- 062

- 089 Support Vessel Tanks Diesel and Lube Oil

-- -- NA

-- EU

- 090

- 091 Helifuel Tanks 1

- 2 Jet A

-- -- NA

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EU

- 092 Black Start Air Compressor Hatz E673L5 6 1998

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

b These units are po r table and brought on the MODU as needed by a third party supplier. The exact engine available for use during the project has not been identified at the time of application. The replacement engine will meet an equivalent or a higher EPA Tier standard.

* H orsepower

Table 2

– DD1 Emissions Units (Operating Scenario 2)

Emissions

Unit ID Engine Description Manufacturer Model Rating a ( h p ) * M fg

Year

EU

- 001

- 008 Main Power Plant Diesel Engines 1

- 8 Caterpillar 3612 DITA 5,096 2002

EU

- 009 Mud and Cement Mixing Dust Collectors Hydralift Procon

EU

- 010 Mud Degassing Operations NA NA NA

-- EU

- 011 Emergency Generator Diesel Engine Caterpillar 3516 2,229 2002

EU

- 012

- 013 Cement Unit 1

- 2 Diesel Engine Caterpillar 3412 860 2001

EU

- 014 Cementing Nitrogen Pump Diesel Engine b Caterpillar or similar 3406 or

similar 490 2000

EU

- 015 Cement Batch Mixe r Diesel Engine Caterpillar 3126 250 2004

EU

- 016 POSU

- CA Primary Wireline Unit Diesel Engine

Hydraulic Generator Combination b Caterpillar or similar C

- 7 DITA or

similar 300 2009

EU

- 017 Wireline Unit Alt #2 Diesel Engine b Caterpillar or similar C

- 7 DITA or

similar 300 2008

EU

- 019 Wireline Unit Power P lant GSU

- W Generator b Various Various 160 Various

EU

- 020 Wireline Unit Hydraulic Diesel Generator DHPS b Various Various 160 Various

EU

- 021 Fast Rescue Craft Diesel Engine Steyr Motors M0144M38 142 2008

EU

- 022

- 025 Lifeboat Diesel Engines 1

- 4 Steyr Motors M0144M38 110 2002

EU

- 026

- 032 Various Diesel Fuel Tanks

-- -- NA 2002

EU

- 033 Base Oil Tank

-- -- NA 2002

EU

- 034

- 047 Various Diesel Fuel Tanks

-- -- NA

-- EU

- 048 Workboat Diesel Engines (See Table 3) Various Various 10,632 Various

EU

- 049 Fast Crew Boat Diesel Engines (See Table 3) Various Various 4,800 Various

EU

- 050

- 077 Support Vessel Tanks Diesel and Lube Oil

-- -- NA

-- EU

- 078

- 081 Helifuel Tanks 1

- 4 Jet A Sure Tank LTD ST

- 1430 NA 200 5

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

b These units are po r table and brought on the MODU as needed by a third party supplier. The exact engine available for use during the project has not been identified at the time of application. The replacement engine will be equivalent or a higher EPA Tier standard.

* Horsepo wer

Table 3

– Support Vessels Vessel Description Representative Vessel a Operating Scenario

Crew Boats Allie or similar Operating Scenario 1 and 2 Offshore Supply/Work Boats Fast Skipper or similar Operating Scenario 1 and 2

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

r epresentative vessel is the wor st case vessel in the potential vessel fleet and used to calculate potential emission s

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5 GENERAL CONDITIONS

5.1 Compliance

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

40 CFR part 55 and this permit. Failure to do so shall be considered a violation of section 111(e) of the CAA. All enforcement provisions of the CAA, including, but not limited to, the provisions of sections 113, 114, 120, 303 and 304 of the CAA, shall apply to the OCS source and permittee

. [40 CFR § 55.8, 55.9(a) and (b)]

5.1.2 The permittee must comply with all conditions of this permit. All terms and conditions of this permit are enforceable by EPA and citizens under the CAA. Any permit noncompliance constitutes a violation of the CAA and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.

[40 CFR § 55.8, 71.6(a)(6)(i)]

5.1.3 It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the

c onditions of this permit.

[40 CFR § 71.6(a)(6)(ii)]

5.2 Permit Shield

Compliance with the terms and conditions of this permit shall be deemed in compliance with the applicable requirements that are included and are specifically identified in this permit. Nothing in this permit shall alter or affect the following:

The provisions of CAA section 303 (emergency orders), including the authority of the Administrator under that section; The liability of an owner or operator of a source for any violation of appli cable requirements prior to or at the time of permit issuance; or The ability of EPA to obtain information from a source pursuant to CAA section 114.

[40 CFR § 71.6(f)(1)]

5.3 Other Credible Evidence

For the purpose of submitting compliance certifications in accordance with Condition 5.21 of this permit, or establishing whether or not a person has violated or is in violation of any requirement of this permit, nothing shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

[CAA §§ 113(a) and (e)(1), 40 CFR §§ 60.11(g) and 61.12]03/30/2012 BHPB DRAFT Permit OCS

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5.4 Construction and Operation

5.4.1 As approved and conditioned by this permit, all construction and operation, including equipment operations and maintenance of the OCS source and support vessels shall be in accordance with the data, specifications, drawings, exhibits, and assumptions inc luded with the application and supporting materials submitted by the permittee, which resulted in this permit (application materials). This permit is valid only for the specific processes and operations applied for and indicated in the application material s. Any unauthorized deviation from the application materials, or from any term or condition of this permit may constitute grounds for revocation or enforcement action by EPA.

5.4.2 The permittee shall properly operate and maintain the OCS source and support ve ssels, including all systems of treatment and control (and related appurtenances) that are installed and used by the permittee to achieve compliance with the terms and conditions of this permit. This provision includes the operation of backup or auxiliary facilities or similar systems when necessary to minimize or prevent emissions in achieving compliance with the terms and conditions of the permit.

[ 40 CFR § 52.21(r)(1)]

5.5 Compliance and Other Requirements

This permit does not relieve the permittee of the r esponsibility to comply fully with applicable provisions of any other requirements under federal law.

[40 CFR § 55.6(a)(4)(iii)]

5.6 Notification to Owners, Operators and Contractors

The permittee must notify all other owners or operators, contractors, and th e subsequent owners or operators associated with emissions from the OCS source and support vessels of the terms and conditions of this permit.

[40 CFR § 55.6(a)(4)(iv)]

5.7 Expiration of Approval to Construct and Permit Renewal

5.7.1 This approval to construct shall become invalid if: construction is not commenced within 18 months after the effective date of this permit, construction is discontinued for a period of 18 months or more, or construction is not completed within a reasonable time. EPA may extend the 1 8

- month period upon a satisfactory showing that an extension is justified.

[40 CFR § 52.21(r)(2)]

5.7.2 The permit tee’s authority to construct and operate shall expire two years from the date the OCS Source commences activity on the DeSoto Canyon lease blocks s pecified in Section 3.0, Project Location

. The EPA may extend the two years upon a satisfactory showing that the extension is justified, and under the condition that project emissions do not exceed those specified in this permit.

[40 CFR § 52.21 ( i)(3 )]03/30/2012 BHPB DRAFT Permit OCS

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5.7.3 If the permittee’s authority to construct and operate has not expired pursuant to condition 5.7.2, then the permit expires on [insert date five years from effective date]. Expiration of this permit terminates the permittee’s right to operate unless a timel y and complete permit renewal application has been submitted at least 6 months, but not more than 18 months, prior to the date of expiration of this permit. If the permittee submits a timely and complete renewal application, and EPA does not take final act ion on the renewal application before the end of the term of this permit, the permittee’s failure to have a permit is not a violation of 40 CFR part 71 until the permitting authority takes final action on the renewal application. Such protection will cease to apply if, subsequent to EPA’s determination that the renewal application is complete, the permittee fails to submit by the deadline specified in writing by EPA any additional information identified as being needed to process the application. This condi tion does not supersede the limitation on the permittee’s authority to construct and operate set forth in condition 5.7.2.

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

5.7.4 If the permittee submits a timely and complete permit application for renewa l, consistent with 40 CFR sections 71.5(a)(1)(iii) and 71.5(a)(2), but EPA does not take final action on the renewal application before the end of the term of this permit, then all the terms and conditions of this permit, including any permit shield grante d pursuant to

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

[40 CFR §§ 71.7(c)(3) and 71.7(b)]

5.7.5 Renewal of this permit is subject to the same procedural requirements that apply to initial permit issuance, including those for public participation and affected State review.

[40 CFR part 71.7(c)(1)(i)]

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

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

and off

- permit changes that occurred during the permit term and were not incorporated into the permit during the permit term, any applicable requirements that were promulgated and not incorporated into the permit during the permit term, a nd other information required by the application form.

[40 CFR §§ 71.5(a)(2) and 71.5(c)(5)]

5.8 Property Rights

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

[40 CFR §71.6(a)(6)(iv)]

5.9 Inspections

The permittee, by accepting this permit, specifically agrees to allow authorized EPA personnel, upon presentation of credentials or other documents as may be required by law and at reasonable times, access to the premises where the permitted activity is located or conducted or where any records are required to be kept under the terms and conditions of this permit to:03/30/2012 BHPB DRAFT Permit OCS

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5.9.1 Have access to and copy any records that must be kept under conditions of the permit, including but not limited to, information relating to the OCS source, sup port vessels, monitoring data, or compliance or noncompliance with the permit;

5.9.2 Inspect the OCS source, support vessels, equipment, practices, or operation regulated or required under this permit; and

5.9.3 Sample or monitor any substances or parameters at any location reasonably necessary to assure compliance with this permit or EPA rules.

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

[40 CFR § § 71.6(c)(2) and 55.8 ]

5.10 Emergency Provisions

In addition to any emergency or upset provi sion contained in any applicable requirement, the permittee may seek to establish that noncompliance with a technology

- based emission limitation under this permit was due to an emergency. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology

- based emissions limitation. The permittee shall demonstrate the affirmative defense of emergency through properly signed, contemporaneous operating logs, or other

relevant evidence that:

An emergency occurred and th at the permittee can identify the cause(s) of the emergency; The permitted facility was at the time being properly operated; During the period of the emergency the permittee took all reasonable steps to minimize levels

of emissions that exceeded the emissions standards, or other requirements in this permit; and The permittee submitted notice of the emergency to EPA within 2 working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This notice fulfills the requirements of Condition 5.17.2 of this permit, concerning prompt notification of deviations.

[40 CFR §§ 71.6(g)(2), (3) and (5)]

5.11 Burden of Proof for Emergencies

In any enforcement proceeding, the permittee attempting to establish the occurrence of an emergency has the burden of proof. [40 CFR § 71.6(g)(4)]

5.12 Emergency Defined

An “emergency” means any situation arising from sudden and reasonably un foreseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology

- based emission limitation under the permit due t o unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error.

[40 C FR § 71.6(g)(1)]03/30/2012 BHPB DRAFT Permit OCS

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5.13 Certification Requirement

Any document required to be submitted under this permit shall be certified by a responsible official as to truth, accuracy and completeness. Such certifications shall state that based on information and belief

fo rmed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

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

5.14 Permit Actions

This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

[40 CFR § 71.6(a)(6)(iii)]

5.15 Reopening for Cause

The permit shall be reopened by EPA and the permit revised prior to expiration under any of the circumstances described in 40 CFR § 71.7(f).

[40 CFR § 71.7(f)]

5.16 Recordkeeping Requirements

In accepting this permit, the permittee underst ands and agrees that all information relating to this permitted source which is submitted to EPA may be used by EPA as evidence in any enforcement case involving the permitted source arising under federal statutes, EPA rules, or rules enforceable by EPA.

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

5.16.2 The permittee shall furnish all r ecords required by this permit.

5.16.3 During enforcement actions, the retention period for all records will be extended automatically unles s otherwise stipulated by EPA.

5.16.4 The permittee shall hold at the corporate offices of BHP Billiton Petroleum, Inc., located at 1360 Post Oak Blvd., Suite 150, Houston, Texas 77056, records of all monitoring information required by the permit, copies of all reports required by this permit, and records of all data used to complete the application for this permit. These materials shall be retained at least five years from the date of the sample, measurement, report, or application unless otherwise specified.

[4 0 CFR § § 71.6(a)(3)(ii)(B) and 55.8 ]

5.16.5 Records of monitoring information shall include:

The date, emission unit or other place as defined in this permit, and time of sampling

or measurements; The results of such analyses and operating conditions as existing at the time of sample

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[40 CFR § 71.6(a)(3)(ii)(A)]

5.16.6 When requested by EPA, the permittee shall furnish any information required by law which is needed to determine compliance with the permit. If the permittee becomes aware that relevant facts were not submitted or were incorrect in the permit application or in any report to EPA, such facts or information shall be corrected promptly.

[40 CFR § § 71.5(b) and 55.8 ]

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

submitted to:

Chief

Air & EPCRA Enforcement Branch Air, Pesticides and Toxics Management Di vision U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303

In addition, electronic copies of the above

- referenced notifications and communications shall be submitted to the following individuals at their corresponding email address:

Name Email Phone David Lloyd lloyd.david@epa.gov 404

- 562

- 9216

Jason Dressler dressler.jason@epa.gov 404

- 562

- 9208 Gregg Worley worley.gregg@epa.gov 404

- 562

- 9141

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

may r equest in writing to determine whether cause exists for modifying, revoking, and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee shall also furnish to EPA copies of records that are required to be kept pursuant to the terms of the permit, including information claimed to be confidential. Information claimed to be confidential must be accompanied by a claim of confidentiality according to the provisions of 40 CFR part 2, subpart B.

[40 CFR §§ 71.6 (a)(6)(v), 71.5(a)(3) and 55.8 ]03/30/2012 BHPB DRAFT Permit OCS

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General Reporting Requirements

5.16.8 The permittee shall submit to EPA reports of any required monitoring for each six month reporting period from July 1 to December 31 and from January 1 to June 30, except that

the first reporting period shall begin on the effective date of this permit and end on either June 30 or December 31, whichever occurs first. All reports shall be submitted to EPA and shall be postmarked by the 30th day following the end of the reporting period. All instances of deviations from permit requirements must be clearly identified in such reports. All required reports must be certified by a responsible official consistent with

Condition 5.13.

[40 CFR § § 71.6(a)(3)(iii)(A) and 55.8 ]

5.16.9 The permittee shall prom ptly report to EPA, by telephone or facsimile, deviations from permit conditions, including those attributable to upset conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventive

measures taken. Th e report shall be made using the following numbers:

Telephone: (404) 562

- 9194 Facsimile: (404) 562

- 9019 Attn: Air Permits Part 71 Deviation Report

[40 CFR § 71.6(a)(3)(iii)(B)]

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

5.16.10.1 Any definition of prompt or a specific time frame for reporting deviations provided in an underlying applicable requirement as identified in this permit.

5.16.10.2 Where the underlying applicable requirement fails to address the time frame for reporting d eviations, reports of deviations will be submitted based on the following schedule:

For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit re quirements, the report must be made within

24 hours of the occurrence; For emissions of any regulated pollutant excluding those referenced in the preceding bullet, that continue for more than 2 hours in excess of permit requirements, the report must be ma de within 48 hours of the occurrence; or For all other deviations from permit requirements, the report shall be

submitted with the semi

- annual monitoring report required in Condition

5.17.1.

[40 CFR § 71.6(a)(3)(iii)(B)]03/30/2012 BHPB DRAFT Permit OCS

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5.16.11 Within 10 working days of the occu rrence of a deviation as provided in Condition 5.17.3.2 above, the permittee shall also submit a written notice, which shall include a narrative description of the deviation and updated information as listed below to EPA,

certified consistent with Conditio n 5.13 of this permit. When reporting excess emissions or permit deviations, the permittee must report in writing the following information:

OCS Source (Facility) Name;
OCS Air Permit Number; Company Name;
Date/Time when the deviation was discovered;

Date /Time when the event began (24

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

- hour clock); Duration of the event: (hours: minutes) or days (total number of hours, minutes or days, if intermittent then include only the duration of the deviation);

If the de viation was intermittent or continuous; Brief description of what happened and the cause, including information regarding the operating conditions during the deviation; Identification of the emission unit(s) or source(s) involved in the event using the same identification number(s) and name(s) as in the permit; Identification of each emission limit potentially exceeded during the event and the level of exceedance, if applicable;
Whether the deviation was unavoidable;

Describe corrective action taken and action taken to prevent future recurrence; If not corrected, the anticipated time the deviation is expected to continue and steps being taken to reduce, eliminate, and prevent recurrence of the deviation; and

Certification: Based on information and belief formed after reasonable inquiry, certify that the statements and information reported are true, accurate, and complete.

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

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

which the permittee fails to meet a permit term or condition. A deviation is not always a violation. A deviation can be determined by observation or through review of data obtained from any testing, monitoring, or recordkeeping required by this permit. For a

si tuation lasting more than 24 hours, each 24

- hour period is considered a separate deviation. Included in the meaning of deviation are any of the following:

A situation where emissions exceed an emission limitation or standard; A situation where process or emissions control device parameter values indicate that an emission limitation or standard has not been met; A situation in which observations or data collected demonstrate noncompliance with an emission limitation or standard or any work practice or ope rating condition required by the permit (including indicators of compliance revealed through parameter monitoring); and A situation in which any testing, monitoring, recordkeeping or reporting required by this permit is not performed or not performed as re quired.

[40 CFR § 71.6(a)(3)(iii)(C)]03/30/2012 BHPB DRAFT Permit OCS

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- R4008 13

5.16.13 If requested by EPA, the permittee shall provide a more detailed written report as requested to follow up on an excess emissions/deviation report.

[40 CFR § 71.6(a)(3)(iii)(B)]

5.17 Off Permit Changes

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

Each change is not addressed or prohibited by this permit; Each change shall meet all applicable requirements and shall not violate any existing permit term or condition; Changes under this provision may not include changes subject to any requirement under any provision of title I of the Clean Air Act; The permittee shall provide contemporaneous written notice to EPA of each change, except

for cha nges that qualify as insignificant activities under 40 CFR § 71.5(c)(11). The written notice shall describe each change, the date of the change, any change in emissions, pollutants emitted and any applicable requirements that would apply as a result of the change; The permit shield in Condition 5.2 does not apply to changes made under this provision; and The permittee shall keep a record describing all changes that result in emissions of any regulated air pollutant subject to any applicable requirement not otherwise regulated under this permit, and the emissions resulting from those changes.

[40 CFR §71.6(a)(12)]

5.18 Operational Flexibility

The permittee is allowed to make a limited class of changes under section 502(b)(10) of the CAA within this permitted faci lity without applying for a permit revision, provided the changes do not exceed the emissions allowable under this permit (whether expressed therein as a rate of emissions or in terms of total emissions) and are not title I modifications. This class of cha nges does not include changes that would violate applicable requirements or changes that would contravene federally enforceable permit terms and conditions that are monitoring (including test methods), recordkeeping, reporting, or compliance certification requirements.

[40 CFR § 71.2 and 71.6(a)(13)(i)]

5.18.1 The permittee is required to send a notice to EPA at least 7 days in advance of any change made under this provision. The notice must describe the change, when it will occur and any change in emissions, and identify any permit terms or conditions made inapplicable as a result of the change. The permittee shall attach each notice to its copy this permit.

[40 CFR § 71.6(a)(13)(i)(A)]

5.18.2 Any permit shield provided under 40 CFR § 71.6(f) and Condition 5.2 of this permit does not apply to changes made under this provision.

[40 CFR § 71.6(a)(13)(i)(B)]03/30/2012 BHPB DRAFT Permit OCS

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5.19 Combined Operating Scenarios

In the event that more than one MODU is constructed or operated during any compliance period, such as

a 12

- month rolling average, any applicable condition of this permit, including but not limited to emission limits, fuel consumption limits, operating limits, and fee calculations, shall be p rorated based on the duration of the operation of each MODU during the compliance period. In no case does this condition allow for the simultaneous operation of more than one MODU under the terms of this permit.

[40 CFR § 55.6]

5.20 Annual Compliance Certifica tion

The permittee shall submit to EPA a certification of compliance with permit terms and conditions, including emission limitations, standards, or work practices, postmarked by February 28 of each year and covering the previous calendar year except that the first certification shall cover the period from the effective date of this permit through December 31. The compliance certification shall be certified as to truth, accuracy and completeness by a responsible official consistent with Condition 5.13 of t his permit. The certification shall include the following:

The identification of each permit term or condition that is the basis of the certification; The identification of the method(s) or other means used by the permittee for determining the complianc e status with each term and condition during the certification period. Such methods and other means shall include, at a minimum, the methods and means required in this permit. If necessary, the permittee also shall identify any other material information t hat must be included in the certification to comply with section 113(c)(2) of the CAA, which prohibits knowingly making a false certification or omitting material information; The status of compliance with each term and condition of the permit for the per iod covered by the certification, including whether compliance during the period was continuous or intermittent. The certification shall be based on the method or means designated above. The certification shall identify each deviation and take it into acco unt in the compliance certification; and A summary of NO X , CO, PM/PM 10 /PM 2.5 , SO 2 , VOC, GHG and HAP emissions in tons per year emitted by each emissions unit regulated under this permit during the duration of the reporting period based on recorded data, su ch as actual fuel usage and actual hours of operation.

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

5.21 Compliance Schedule

For applicable requirements with which the source is in compliance, the permittee will continue to comply with such requirements. For appl icable requirements that will become effective during the permit term, the permittee shall meet such requirements on a timely basis.

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

5.22 Safe Shutdown

As provided in 40 CFR § 55.9(c), if this OCS source is ordered to cease operation of any piece of equipment due to enforcement action taken by EPA, the shutdown will be coordinated by EPA with the

DOI Bureau of Safety and Environmental Enforcement , the Uni ted States Coast Guard, the permittee, and the operator to assure that the shutdown will proceed in a safe manner. No shutdown action will03/30/2012 BHPB DRAFT Permit OCS

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- R4008 15

occur until after EPA’s consultation with these agencies, but in no case will initiation of the shutdown be delayed b y more than 24 hours after EPA consults with these agencies. The initiation of the shutdown process will not preclude well procedures necessary to ensure safety.

[40 CFR § 55.9(c)]

5.23 Transfer of Ownership

In the event of any changes in control or ownership of the OCS source, this permit shall be binding on all subsequent owners and operators. Permittee shall notify the succeeding owner and operator of the existence of this permit and its conditions by letter, a copy of which shall be forwarded to EPA Region 4.

[40 CFR § 55.6(a)(4)(iv)]

5.24 Severability

The provisions of this permit are severable, and, in the event of any challenge to any portion of this permit or if any provision of the permit is held invalid, the remainder of this permit shall remain valid

and in force

. [40 CFR §71.6(a)(5)]

5.25 General Testing Requirements

5.25.1 In addition to the specific testing requirements contained in the emission unit sections of this permit, the permittee shall comply with the generally applicable testing requirements

in Condition s 5.26.2 through 5.26.10 whenever conducting a performance test required by this permit unless specifically s tated otherwise in this permit.

5.25.2 The permittee shall provide EPA at least 30 days prior notice of any performance test, except as otherwise specifi ed in this permit, to afford EPA the opportunity to have an observer present. If after 30 days notice for an initially scheduled performance test, there is a delay in conducting the scheduled performance test, the permittee shall notify EPA as

soon as poss ible of any delay in the original test date, either by providing at least 7 d ays prior notice of the rescheduled date of the performance test, or by arranging a

rescheduled dat e with EPA by mutual agreement.

5.25.3 The permittee shall submit to EPA a source test plan 30 days prior to any required testing. The source test plan shall include and address the following elements:

Purpose and scope of testing; Source description, including a description of the operating scenarios and mode of operation during testing and including fuel sampling and analysis procedures; Schedule/dates of testing; Process data to be collected during the test and reported with the results, including

source

- specific data identified in the emission unit sections of this permit; Sampling and analysis procedures, specifically requesting approval for any proposed alternatives to the reference test methods, and addressing minimum test length ( e.g. , one hour, 8 hours, 24 hours, etc.) and minimum sample volume; Sampling location description an d compliance with the reference test methods;03/30/2012 BHPB DRAFT Permit OCS

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- R4008 16 Analysis procedures and laboratory identification; Quality assurance plan; Calibration procedures and frequency; Sample recovery and field documentation; Chain of custody procedures; Quality assurance/qua lity control project flow chart; Data processing and reporting; Description of data handling and quality control procedures; and Report content and timing.

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

or withi n 2 hours prior to the start of a source test. Any operating adjustments made during a source test, that are a result of consultation during the tests with source testing personnel, equipment vendors, or consultants, may render the source test invalid.

5.25.5 Fo r the duration of each test run (unless otherwise specified), the permittee shall record the following information:

All data which is required to be monitored during the test in the emission unit sections of this permit; and All continuous monitoring system data that is required to be routinely monitored in the emission unit sections of this permit for the emission unit being tested.

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

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

5.25.7 If the reference test method yields measured pollutant concentration values at an oxygen concentration other than specified in the emission standard, the permittee shall correct the measured pollutant concentration to the oxygen concentration specified in the emission standard by using the following equation:

PC X = PC

m x (21

- X)

(21

- Y)

Where:

PC X = Pollutant concentration at X percent;

PC

m = Pollutant concentration as measured; X = the oxygen c oncentration specified in the standard; and Y = the measured average volumetric oxygen concentration.

5.25.8 Facilities for performing and observing the emission testing shall be provided that meet the requirements of 40 CFR § 60.8(e) and Reference Method 1 (40 CFR § 60, Appendix A).

5.25.9 Emission test reports shall be submitted to EPA within 45 days of completing any emission test required by this permit along with items required to be recorded in

Condition 5.26.5 above.03/30/2012 BHPB DRAFT Permit OCS

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5.25.10 Source test emission data shall be reported as the arithmetic average of all valid test runs and in the terms of any applicable emission limit, unless otherwise specified in the emission unit sections of this permit.

[40 CFR §§ 71.6(a)(3) and 71.6(c)(1)]

5.26 Fee Payment

5.26.1 No later than April 1 of the subsequent year, the permittee shall submit the following to

EPA:

Full payment of the annual permit fee, as specified in Conditions 5.27.2 through 5.27.11; An updated fee calculation worksheet form and a photocopy of each fee payment check (or other conf

irmation of actual fee paid), as specified in Condit ions 5.27.4 through 5.27.8; and An annual emissions report of actual emissions, as specified in Condition 5.27.6, for the preceding calendar year.

[40 CFR §§ 71.9(a) and (h)]

5.26.2 The fee payment shall be in United States currency and shall be paid by money order, bank draft, certified check, corporate check, or electronic funds transfer payable to the order of the U.S. Environmental Protection Agency.

[40 CFR § 71.9(k)(1)]

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

addresses listed below.

If sent by Regular Mail through U.S. Postal Service (USPS)

, send to:

U.S. Environmental Protection Agency FOIA and Miscellaneous Payments

Cincinnati Finance Center

PO Box 979078 St. Louis, MO 63197

- 9000

If sent by Express Delivery (or when a physical address is required)

, send to:

U.S. Bank

Government Lockbox 979078 US EPA FOIA & Misc. Payments

1005 Convention Plaza

Mail Station SL

- MO

- C2GL St. Louis, MO 63101

Contact: Natalie Pearson (314

- 418

- 4087)

[40 CFR § 71.9(k)(2)]03/30/2012 BHPB DRAFT Permit OCS

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5.26.4 The permittee shall send an updated fee calculation worksheet form and a photocopy of each fee payment check (or other confirmation of actual fee paid), submitted annually by the date spe cified in Condition 5.27.1, to:

Chief

Air Permits Section Air, Pesticides and Toxics Management Division U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303

[40 CFR § 71.9(h)(1)]

5.26.5 The annual emissions fee shall be calculated by multiplying the total tons of actual emissions of all “regulated pollutants (for fee calculation),” emitted from the source by the presumptive emission fee (in dollars/ton) in effect at the time of calculation. The presumptive emission fee is revised each calendar year and is available from EPA prior to the start of each calendar year. [40 CFR § 71.9(c)(1)]

5.26.5.1 “Actual emissions” means the actual rate of emissions in tons per year (TPY) of any “regulated pollutant (for fee calculation),” as defined in 40 CFR § 71.2, emitted from a part 71 source over the preceding calendar year. Actual emissions shall be calculated using each emissions unit’s actual operating hours, production rates, in

- place control equipment, and types of materials processed, stored, or comb usted during the preceding calendar year.

[40 CFR § 71.9(c)(6)]

5.26.5.2 Actual emissions shall be computed using methods required by the permit for determining compliance, such as monitoring or source testing data.

[40 CFR § 71.9(h)(3)]

5.26.5.3 If actual emissions canno t be determined using the compliance methods in the permit, the permittee shall use other federally recognized procedures.

[40 CFR § 71.9(e)(2)]

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

fees:

The amount of actual emissi ons of each regulated pollutant (for fee calculation) that the source emits in excess of 4,000 tons per year; Actual emissions of any regulated pollutant (for fee calculation) already

inclu ded in the fee calculation; and The insignificant quantities of actual emissions not required to be listed or calculated in a permit application pursuant to 40 CFR § 71.5(c)(11).

[40 CFR §§ 71.9(c)(5)(i) through (iii)]03/30/2012 BHPB DRAFT Permit OCS

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5.26.6 The permittee shall submit an annual emissions report of its actual emissions for the preceding calen dar year. The annual emissions report shall be certified by a responsible official and shall be submitted each year to EPA by the date specified in Condition 5.27.1. The annual emissions report shall be submitted to EPA at the address listed in

Condition 5 .27.3 of this permit.

[40 CFR §§ 71.9(h)(1) and (2)]

5.26.7 Fee calculation worksheets shall be certified as to truth, accuracy, and completeness by a responsible official in accordance with Condition 5.13 of this permit.

[40 CFR § 71.9(h)(2)]

5.26.8 The permittee sha ll retain in accordance with the provisions of Conditions 5.16.4 and 5.16.5 of this permit, all worksheets and other materials used to determine fee payments. Records shall be retained for five years following the year in which the emissions data is

submit ted.

[40 CFR § 71.9(i)]

5.26.9 Failure of the permittee to pay fees in a timely manner shall subject the permittee to assessment of penalties and interest.

[40 CFR § 71.9(l)]

5.26.10 The permittee, when notified by EPA of additional amounts due, shall remit full paymen t within 30 days of receipt of an invoice from EPA.

[40 CFR § 71.9(j)(2)]

5.26.11 If the permittee thinks an EPA assessed fee is in error and wishes to challenge such fee, the permittee shall provide a written explanation of the alleged error to EPA along with full payment of the EPA assessed fee.

[40 CFR § 71.9(j)(3)]

6 S PECIFIC CONDITIONS

6.1 Drill Site Notification

At least 10 days prior to entering the drill site, the permittee shall notify EPA in writing in accordance with Condition 5.16.7 of this permit, of the following information:

6.1.1 The location of the proposed drill site, using coordinates in the following formats:

Latitude and longitude; and Universal Transverse Mercator grid system.

6.1.2 The proposed date that the MODU will enter the lease block and commence c onstruction or operation and the probable duration of operation at that location; and03/30/2012 BHPB DRAFT Permit OCS

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6.1.3 Not less than 24 hours prior to commencing construction or operation, of any changes to the information provided by the permittee in Conditions 6.1.1 and 6.1.2.

[40 CFR §§ 71.6(a) (6)(v), 5 2.21 and 55.8 ]

6.2 Drilling Limitations

6.2.1 The permittee shall not operate the C.R. Luigs drillship and the DD1 drilling unit concurrently within the lease blocks specified in section 3 of this permit

.

6.2.2 The total combined hours of operation of the C.R. Luigs and the DD1 MODUs shall not exceed 6,570 hours per year on a rolling 12

- month basis.

6.2.3 Compliance with this operating limit will be assured by maintaining a record of operating

hours and summi ng such hours on a rolling 12

- month basis

. [40 CFR § 55.6(a)]

6.3 Support Vessel Identification

The permittee shall maintain records in accordance with Condition 5.16 of the engine specifications, performance data and emission estimates for any support vessel used in place of the Allie (work boat) or

the Fast Skipper (crew boat). These records shall be submitted a s part of the Annual Compliance

Certification in accordance with Condition 5.21.

[40 CFR § 55

. 8 ]

6.4 Source

- wide SO 2 Emission Limit

The permittee shall not combust any diesel fuel with a sulfur conte nt greater than 15 parts per million (ppm) by weight, as determined by Condition 6. 4 .1, in any diesel fueled emission unit on C.R. Luigs

, DD1 , or any support vessel.

6.4.1 The permittee shall obtain a certification of sulfur content for each shipment of fuel fr om the fuel supplier (the certification must indicate the sulfur content was determined by an approved EPA method ), o r the permittee shall obtain representative fuel samples using

one of the methods in 40 CFR 80.330 and shall determine the sulfur content o f the fuel using one of the methods in 40 CFR 80.580.

6.4.2 Monitoring, Recordkeeping and Reporting

6.4.2.1 Prior to mobilizing the selected MODU for activities covered by this permit, the permittee shall determine and record the sulfur content of the diesel fuel on t he

MODU and the support vessels using the procedures in Condition 6.4.1.

6.4.2.2 Thereafter, the permittee shall determine and record the sulfur content of the diesel fuel on the MODU and the support vessels using the procedures in

Condition 6.4.1 upon receiving each fuel shipment

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6.4.3 The permittee shall provide the results of all fuel sample analyses required by Conditions 6.4.1 and 6.4.2 with the Compliance Certification Report required by Condition 5.21.

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

6.5 C.R. Luigs Emission and Operating Limits

6.5.1 Source Identification: EU

- 001 through

- 008, main power plant engines equipped with positive crankcase ventilation, turbocharger and aftercooler, and high

- pressure fuel injection with aftercooler.

6.5.1.1 The permittee shall not discharge or cause the discharge of emissions into the atmosphere from each engine in excess of:

6.5.1.1.1 NO X BACT Limit: 1 8

. 1 g/kW

- hr (12.1 g/kW

- hr, corrected to 95%

NO) on a rolling 24

- hour average basis.

6.5.1.1.2 CO BACT Limit: 2.42 g/kW

- hr on a rolling 24

- hour average basis.

6.5.1.1.3 VOC BACT Limit: 6.42 x 10 - 4 lb/hp

- hr (0.39 g/kW

- hr) on a rolling

24

- hour average basis.

6.5.1.1.4 PM BACT Limit: 7.00 x 10 - 4 lb/hp

- hr (0.43 g/kW

- hr) on a rolling

24

- hour average basis.

6.5.1.1.5 PM 10 BACT Limit: 4.01 x 10 - 4 lb/hp

- hr (0.24 g/kW

- hr) on a rolling

24

- hour average basis.

6.5.1.1.6 PM 2.5 BACT Limit: 3.89 x 10 - 4 lb/hp

- hr (0.24 g/kW

- hr) on a rolling

24

- hour average basis.

6.5.1.1.7 GHG BACT Limits: 1.16 lb/hp

- hr (705 g/kW

- hr) of CO 2 e on a

rolling 24

- hour average basis and 78,005 tons per year of CO 2 e on a rolling 12

- month basis.

6.5.1.2 BACT Work Practice Standards:

6.5.1.2.1 Use of ultra low sulfur diesel ;

6.5.1.2.2 G ood combustion practices based on the current manufacturer’s

specifications for these engines ; and03/30/2012 BHPB DRAFT Permit OCS

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- R4008 22 6.5.1.2.3 A dditional enhanced work practice standards as detailed in the

application received (by EPA) on October 20, 2010; and application addendums received on February 11, 2011; October 27, 2011; and

December 22, 2011, respectively. The application is provided in the

administrative record and defines a de tailed engine performance management system and the Diesel Engines with Turbochargers (DEWT) monitoring system designed by Transocean. A parametric monitoring system equivalent to DEWT may be used with prior EPA approval.

6.5.1.3 Compliance Demonstration Method f or units EU

- 01 through

- 08: The permittee shall monitor emissions by the use of an EPA

- approved continuous emissions monitoring system, an EPA

- approved stack testing emissions monitoring system, or, with prior written approval by EPA, an alternative parame tric monitoring method pursuant to Condition 6.10.

6.5.1.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.10 and 6.1 6

.

6.5.2 Source Identification: EU

- 009 through

- 012, crane engines equipped with positive

crankcase ventilat ion, turbocharger and aftercooler, and high

- pressure fuel injection with

aftercooler.

6.5.2.1 The permittee shall not discharge or cause the discharge of emissions into the atmosphere from the engines combined in excess of:

6.5.2.1.1 NO X BACT Emission Limit: 82.83 tons per year on a 12

- month

rolling total basis.

6.5.2.1.2 CO BACT Emission Limit: 17.85 tons per year on a 12

- month

rolling total basis.

6.5.2.1.3 VOC BACT Emission Limit: 6.72 tons per year on a 12

- month

rolling total basis.

6.5.2.1.4 PM/PM 10 /PM 2.5 BACT Emission Limit: 5.88 tons per year on a 12

-

month rolling total basis.

6.5.2.1.5 GHG BACT Emission Limit: 3,083 tons per year of CO 2 e on a 12

-

month rolling total basis.

6.5.2.2 BACT Work Practice Standards :

6.5.2.2.1 Use of ultra low sulfur diesel fuel

, and

6.5.2.2.2 G ood combustion practices based on the current manufacturer’s

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- R4008 23 6.5.2.3 Operating Limit: These units shall be operated no more than 4,380 hours per

year each on a 12

- month rolling total basis.

6.5.2.4 Compliance with this operating limit will be assured by maintaining a record of hours of operation and summing such hours on a rolling 12

- month basis.

6.5.2.5 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.5.2.6 Any subsequent replacement of these units must be co mpliant with

40 CFR part 60, subpart IIII.

6.5.3 Source Identification: EU

- 013, mud and cement mixing, equipped with dust collectors.

6.5.3.1 PM/PM 10 /PM 2.5 BACT Emission Limit: 1.08 tons per year on a 12

- month rolling total basis.

6.5.3.2 BACT Work Practice Standard: Proper maintenance and operation of the dust

collectors in accordance with manufacturer specifications to ensure a control efficiency of 99.95%.

6.5.3.3 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.1 4 and 6.1 6

.

6.5.4 Source Identification: EU

- 014, mud degassing operations.

6.5.4.1 VOC BACT Emission Limit: 19.39 tons per year on a 12

- month rolling total

basis.

6.5.4.2 GHG BACT Emission Limit: 982.7 tons per year of CO 2 e on a 12

- month rolling

total basis.

6.5.4.3 The permittee shall determine the w ater

- based mud/oil

- based mud ratio to ensure it does not exceed 2:5 at any time based on a 12

- month rolling average.

6.5.4.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.1 5 and 6.1 6

.

6.5.5 Source Identification: EU

- 015, em ergency generator engine, equipped with positive crankcase ventilation, turbocharger and aftercooler, and high

- pressure fuel injection with

aftercooler.

6.5.5.1 NO X BACT Emission Limit: 1.49 tons per year on a 12

- month rolling total

basis.

6.5.5.2 CO BACT Emission Limit : 0.34 ton s per year on a 12

- month rolling total basis.03/30/2012 BHPB DRAFT Permit OCS

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- R4008 24 6.5.5.3 VOC BACT Emission Limit: 0.04 ton s per year on a 12

- month rolling total

basis.

6.5.5.4 PM BACT Emission Limit: 0.04 ton s per year on a 12

- month rolling total basis.

6.5.5.5 PM 10 /PM 2.5 BACT Emission Limit: 0.02 ton s per year on a 12

- month rolling

total basis.

6.5.5.6 GHG BACT Emission Limit: 72.06 tons per year of CO 2 e on a 12

- month rolling

total basis.

6.5.5.7 BACT Work Practice Standards:

6.5.5.7.1 Use of ultra low sulfur diesel fuel

, and

6.5.5.7.2 G ood combustion practices based on the current manufacturer’s

specifications for this engine.

6.5.5.8 Operating Limit: This unit shall be operated no more than 60 hours per year on

a 12

- month rolling total basis.

6.5.5.9 Compliance with this operating limit will be assured by maintaining a record of hours of operat ion and summing such hours on a rolling 12

- month basis.

6.5.5.10 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.5.6 Source Identification: EU

- 092, black start air compressor.

6.5.6.1 BACT Work Practice Standards:

6.5.6.1.1 Use of ultra low sulfur diesel fuel

, and

6.5.6.1.2 G ood combustion practices based on the current manufacturer’s

specifications for this engine.

6.5.6.2 Operating Limit: This unit shall be operated no more than 25 hours per year on

a 12

- month rolling total basis.

6.5.6.3 Compliance with this operating limit will be assured by maintaining a record of hours of operation and summing such hours on a rolling 12

- month basis.

6.5.6.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

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6.5.7 Source Identification: EU

- 016 through

- 018, cementing engines and cementing nitrogen pump engine, equipped with closed crankcase ventilation, turbocharger (without aftercooler), and high

- pressure fuel injection with aftercooler.

6.5.7.1 The permittee shall not discharge or cause the discharge of emissions into the atmosphere from the engines combined in excess of:

6.5.7.1.1 NO X BACT Emission Limit: 8.69 tons per year on a 12

- month

rolling total basis.

6.5.7.1.2 CO BACT Emission Limit: 3.30 tons per year on a 12

- month rolling

total basis.

6.5.7.1.3 VOC BACT Emission Limit: 0.38 ton s per year on a 12

- month

rolling total basis.

6.5.7.1.4 PM BACT Emission Limit: 0.38 ton s per year on a 12

- month rolling

total basis.

6.5.7.1.5 PM 10 BACT Emission Limit: 0.23 ton s per year on a 12

- month

roll ing total basis.

6.5.7.1.6 PM 2.5 BACT Emission Limit: 0.22 ton s per year on a 12

- month

rolling total basis.

6.5.7.1.7 GHG BACT Emission Limit: 628.9 tons per year of CO 2 e on a 12

-

month rolling total basis.

6.5.7.2 BACT Work Practice Standards:

6.5.7.2.1 Use of certified EPA Tier 1 (or better) Marine engines for EU

- 016

and

- 017 and Tier 1 (or better) Non r oad engine for EU

- 018 ;

6.5.7.2.2 Use of ultra low sulfur diesel fuel ; and

6.5.7.2.3 G ood combustion practices based on the current manufacturer’s

specifications for these engines.

6.5.7.3 Operating Limit: Un its EU

- 016 and

- 017 shall be operated no more than 600 hours per year each on a 12

- month rolling total basis.

6.5.7.4 Operating Limit: Unit EU

- 018 shall be operated no more than 100 hours per year on a 12

- month rolling total basis.

6.5.7.5 Compliance with th ese operating limit s will be assured by maintaining a record

of hours of operation and summing such hours on a rolling 12

- month basis.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 26 6.5.7.6 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.5.8 Source Identificat ion: EU

- 019,

- 020,

- 022, and

- 023; wireline unit engines (including primary, alternative #2, and power plant generator, and hydraulic generator), equipped with turbocharger and aftercooler (EU

- 019 and

- 020 only), and high

- pressure fuel injection with after cooler.

6.5.8.1 The permittee shall not discharge or cause the discharge of emissions into the atmosphere from the engines combined in excess of:

6.5.8.1.1 NO X BACT Emission Limit: 8.92 tons per year on a 12

- month

rolling total basis.

6.5.8.1.2 CO BACT Emission Limit: 2.90 tons per year on a 12

- month rolling

total basis.

6.5.8.1.3 VOC BACT Emission Limit: 1.17 tons per year on a 12

- month

rolling total basis.

6.5.8.1.4 PM/PM 10 /PM 2.5 BACT Emission Limit: 0.60 ton s per year on a 12

-

month rolling total basis.

6.5.8.1.5 GHG BACT Emission Limit: 536.6 tons per y ear of CO 2 e on a 12

-

month rolling total basis.

6.5.8.2 BACT Work Practice Standards:

6.5.8.2.1 Use of certified EPA Tier 2 Nonroad (or better) engines for EU

- 022

and

- 023 and Tier 3 Nonroad (or better) engines for EU

- 019 and

- 020 ;

6.5.8.2.2 Use of ultra low sulfur diesel fuel ; and

6.5.8.2.3 G ood combustion practices based on the current manufacturer’s

specifications for these engines.

6.5.8.3 Operating Limit: Units EU

- 019 and

- 020 shall be operated no more than 750 hours per year each on a 12

- month rolling total basis.

6.5.8.4 Operating Limit: Unit EU

- 02 2 shall be operated no more than 1700 hours per year on a 12

- month rolling total basis.

6.5.8.5 Operating Limit: Unit EU

- 023 shall be operated no more than 1300 hours per year on a 12

- month rolling total basis.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 27 6.5.8.6 Compliance with th ese operating limit s will be assured by maintaining a record

of hours of operation and summing such hours on a rolling 12

- month basis.

6.5.8.7 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.5.9 Source Identification: EU

- 024, fast rescue craft engine, equipped with turbocharger (without aftercooler).

6.5.9.1 Work Practice Standards:

6.5.9.1.1 Use of ultra low sulfur diesel fuel

, and

6.5.9.1.2 G ood combustion practices based on the current manufacturer’s

specifications for this engine.

6.5.9.2 Operating Limit: Thi s unit shall be operated no more than 25 hours per year on

a 12

- month rolling total basis.

6.5.9.3 Compliance with this operating limit will be assured by maintaining a record of hours of operation and summing such hours on a rolling 12

- month basis.

6.5.9.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.5.10 Source Identification: EU

- 025 through

- 028, life boat engines.

6.5.10.1 Work Practice Standards:

6.5.10.1.1 Use of ultra low sulfur diesel fuel

, and

6.5.10.1.2 G ood combustion practices based on the current manufacturer’s

specifications for these engines.

6.5.10.2 Operating Limit: These units shall be operated no more than 25 hours per year

each on a 12

- month rolling total basis.

6.5.10.3 Compliance with this operating limit will be assured by maintaining a r ecord of hours of operation and summing such hours on a rolling 12

- month basis.

6.5.10.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 28

6.5.11 Source Identification: EU

- 029 through

- 059 and EU

- 090 through

- 091, storage tanks.

6.5.11.1 The permittee shall not discharge or cause the discharge of emissions into the atmosphere from the storage tanks combined in excess of:

6.5.11.1.1 VOC BACT Emission Limit: 0.57 ton s per year on a 12

- month

rolling total basis.

6.5.11.2 BACT Work Practice Stan dard: Use of good maintenance practices.

6.5.11.3 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.12 and 6.1 6

.

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

6.6 DD1 Emission and Operating Limits

6.6.1 Source Identification: EU

- 001 through

- 008, main power plant engines equipped with positive crankcase ventilation, turbocharger and aftercooler, and high

- pressure fuel injection with aftercooler.

6.6.1.1 The permittee shall not discharge or cause the discharge of emissi ons into the atmosphere from each engine in excess of:

6.6.1.1.1 NO X BACT Limit: 12.1 g/kW

- hr ( 8.10 g/kW

- hr, corrected to 95%

NO) on a rolling 24

- hour average basis.

6.6.1.1.2 CO BACT Limit: 1.98 g/kW

- hr on a rolling 24

- hour average basis.

6.6.1.1.3 VOC BACT Limit: 6.42 x 10 - 4 lb/hp

- hr (0.39 g/kW

- hr) on a rolling

24

- hour average basis.

6.6.1.1.4 PM BACT Limit: 7.00 x 10 - 4 lb/hp

- hr (0.43 g/kW

- hr) on a rolling

24

- hour average basis.

6.6.1.1.5 PM 10 BACT Limit: 4.01 x 10 - 4 lb/hp

- hr (0.24 g/kW

- hr) on a rolling

24

- hour average basis.

6.6.1.1.6 PM 2.5 BACT Limit: 3.89 x 10 - 4 lb/hp

- hr (0.24 g/kW

- hr) on a rolling

24

- hour average basis.

6.6.1.1.7 GHG BACT Limit: 1.16 lb/hp

- hr (705 g/kW

- hr) of CO 2 e on a rolling

24

- hour average basis and 79,921 tons per year of CO 2 e on a rolling

12

- month basis.

6.6.1.2 BACT Work Practice Standards:

6.6.1.2.1 Use of ultra low sulfur diesel

, and03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 29 6.6.1.2.2 Good combustion practices based on the current manufacturer’s

specifications for these engines, and additional enhanced work practice standards as detailed in the applicati on received (by EPA) on October 20, 2010; and application addendums received on February 11, 2011; October 27, 2011; and December 22, 2011, respectively. The application is provided in the administrative record and defines a detailed engine performance management system and the Diesel Engines with Tur bochargers (DEWT) monitoring system designed by Transocean. A parametric monitoring system equivalent to DEWT may be used with prior EPA approval.

6.6.1.3 Compliance Demonstration Method for units EU

- 01 through

- 08: Pursuant to Condition 6.10, t he permittee shall monitor NO X emissions by the use of an

EPA

- approved continuous emissions monitoring system, an EPA

- approved stack testing emissions monitoring system, or, with prior written approval by EPA, an alternative parametric monitoring method.

6.6.1.4 Monitoring, record keeping and reporting shall be conducted in accordance with

Conditions 6.10 and 6.1 6

.

6.6.2 Source Identification: EU

- 009, mud and cement mixing, equipped with dust collectors.

6.6.2.1 PM/PM 10 /PM 2.5 BACT Emission Limit: 1.08 tons per year on a 12

- month rolling total b asis.

6.6.2.2 BACT Work Practice Standard: Proper maintenance and operation of the dust collectors to ensure a control efficiency of 99.95%.

6.6.2.3 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.1 4 and 6.1 6

.

6.6.3 Source Identification: EU

- 010, mud degassing operations.

6.6.3.1 VOC BACT Emission Limit: 19.39 tons per year on a 12

- month rolling total

basis.

6.6.3.2 GHG BACT Emission Limit: 982.7 tons per year of CO 2 e on a 12

- month rolling

total basis.

6.6.3.3 The permittee shall determine the water

- based mud/oil

- based mud ratio to ensure it does not exceed 2:5 at any time based on a 12

- month rolling average.

6.6.3.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.1 5 and 6.1 6

.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 30

6.6.4 Source Identification: EU

- 011, emergency generator engine, equipped with positive crankcase ventilation, turbocharger and aftercooler, and high

- pressure fuel injection with

aftercooler.

6.6.4.1 NO X BACT Emission Limit: 1.60 tons per year on a 12

- month rolling total

basis.

6.6.4.2 CO BACT Emission Lim it: 0.37 ton s per year on a 12

- month rolling total basis.

6.6.4.3 VOC BACT Emission Limit: 0.04 ton s per year on a 12

- month rolling total

basis.

6.6.4.4 PM BACT Emission Limit: 0.05 ton s per year on a 12

- month rolling total basis.

6.6.4.5 PM 10 /PM 2.5 BACT Emission Limit: 0.03 ton s per year on a 12

- month rolling

total basis.

6.6.4.6 GHG BACT Emission Limit: 77.84 tons per year of CO 2 e on a 12

- month rolling

total basis.

6.6.4.7 BACT Work Practice Standards:

6.6.4.7.1 Use of ultra low sulfur diesel fuel

, and

6.6.4.7.2 G ood combustion practices based on the current manufacturer’s

specifications for this engine.

6.6.4.8 Operating Limit: This unit shall be operated no more than 60 hours per year on

a 12

- month rolling total basis.

6.6.4.9 Compliance with this operating limit will be assured by maintaini ng a record of hours of operation and summing such hours on a rolling 12

- month basis.

6.6.4.10 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.6.5 Source Identification: EU

- 012 through

- 015, cementing engines, c ementing nitrogen pump engine, and cement batch mixer engine, equipped with closed crankcase ventilation, turbocharger (without aftercooler), and high

- pressure fuel injection with

aftercooler.

6.6.5.1 The permittee shall not discharge or cause the discharge of em issions into the atmosphere from the engines combined in excess of:

6.6.5.1.1 NO X BACT Emission Limit: 9.50 tons per year on a 12

- month

rolling total basis.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 31 6.6.5.1.2 CO BACT Emission Limit: 3.73 tons per year on a 12

- month rolling

total basis.

6.6.5.1.3 VOC BACT Emission Limit: 0.5 2 ton per year on a 12

- month

rolling total basis.

6.6.5.1.4 PM BACT Emission Limit: 0.41 ton per year on a 12

- month rolling

total basis.

6.6.5.1.5 PM 10 BACT Emission Limit: 0.25 ton per year on a 12

- month

rolling total basis.

6.6.5.1.6 PM 2.5 BACT Emission Limit: 0.25 ton per year on a 12

- month

rolling total basis.

6.6.5.1.7 GHG BACT Emission Limit: 715.5 tons per year of CO 2 e on a 12

-

month rolling total basis.

6.6.5.2 BACT Work Practice Standards:

6.6.5.2.1 Use of certified EPA Tier 1 Marine engines for EU

- 012 and

- 013,

Tier 1 Non r oad ( or better) for EU

- 014, and Tier 2 Non r oad engine

for EU

- 015;

6.6.5.2.2 Use of ultra low sulfur diesel fuel; and

6.6.5.2.3 G ood combustion practices based on the current manufacturer’s

specifications for these engines.

6.6.5.3 Operating Limit: Units EU

- 012 and

- 013 shall be operated no more than 600 hours per year each on a 12

- month rolling total basis.

6.6.5.4 Operating Limit: Unit EU

- 014 shall be operated no more than 100 hours per year on a 12

- month rolling total basis.

6.6.5.5 Operating Limit: Unit EU

- 015 shall be operat ed no more than 100 hours per year on a 12

- month rolling total basis.

6.6.5.6 Compliance with th ese operating limit s will be assured by maintaining a record

of hours of operation and summing such hours on a rolling 12

- month basis.

6.6.5.7 Monitoring, recordkeeping and r eporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 32

6.6.6 Source Identification: EU

- 016,

- 017,

- 019, and

- 020; wireline unit engines (including primary, alternative #2, and power plant generator, and hydraulic generator), equipped

with turbocharger and aftercooler (EU

- 016 and

- 017 only), and high

- pressure fuel injection with aftercooler.

6.6.6.1 The permittee shall not discharge or cause the discharge of emissions into the atmosphere from the engines combined in excess of:

6.6.6.1.1 NO X BACT Emission Limit: 8.92 tons per year on a 12

- month

rolling total basis.

6.6.6.1.2 CO BACT Emission Limit: 2.90 tons per year on a 12

- month rolling

total basis.

6.6.6.1.3 VOC BACT Emission Limit: 1.17 tons per year on a 12

- month

rolling total basis.

6.6.6.1.4 PM/PM 10 /PM 2.5 BACT E mission Limit: 0.60 ton s per year on a 12

-

month rolling total basis.

6.6.6.1.5 GHG BACT Emission Limit: 536.6 tons per year of CO 2 e on a 12

-

month rolling total basis.

6.6.6.2 BACT Work Practice Standards:

6.6.6.2.1 Use of certified EPA Tier 2 Non r oad (or better) engines for EU

- 019

and

- 020 and Tier 3 Non r oad (or better) engines for EU

- 016 and

- 017 ;

6.6.6.2.2 Use of ultra low sulfur diesel fuel ; and

6.6.6.2.3 G ood combustion practices based on the current manufacturer’s

specifications for these engines.

6.6.6.3 Operating Limit: Units EU

- 016 and

- 017 shall be operated no more than 750 hours per year each on a 12

- month rolling total basis.

6.6.6.4 Operating Limit: Unit EU

- 019 shall be operated no more than 1700 hours per year on a 12

- month rolling total basis.

6.6.6.5 Operating Limit: Unit EU

- 020 shall be operated no more than 1300 hours per year on a 12

- month rolling total basis.

6.6.6.6 Compliance with th ese operating limit s will be assured by maintaining a record

of hours of operation and summing such hours on a rolling 12

- month basi s.

6.6.6.7 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 33

6.6.7 Source Identification: EU

- 021, fast rescue craft engine, equipped with turbocharger (without aftercooler).

6.6.7.1 Work Practice Standards:

6.6.7.1.1 Use of ultra low sulfur diesel fuel

, and

6.6.7.1.2 G ood combustion practices based on the current manufacturer’s

specifications for this engine.

6.6.7.2 Operating Limit: This unit shall be operated no more than 25 hours per year on

a 12

- month rolling total basis.

6.6.7.3 Compliance with th es e operating limit s will be assured by maintaining a record

of hours of operation and summing such hours on a rolling 12

- month basis.

6.6.7.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.6.8 Source Identifica tion: EU

- 022 through

- 025, life boat engines.

6.6.8.1 Work Practice Standards:

6.6.8.1.1 Use of ultra low sulfur diesel fuel

, and

6.6.8.1.2 G ood combustion practices based on the current manufacturer’s

specifications for these engines.

6.6.8.2 Operating Limit: These units shall be operated no more than 25 hours per year

each on a 12

- month rolling total basis.

6.6.8.3 Compliance with th ese operating limit s will be assured by maintaining a record

of hours of operation and summing such hours on a rolling 12

- month basis.

6.6.8.4 Monitoring, recordkeeping and reporting shall be conducted in accordance with

Conditions 6.11 and 6.1 6

.

6.6.9 Source Identification: EU

- 026 through

- 047 and EU

- 078 through

- 081, storage tanks.

6.6.9.1 The permittee shall not discharge or cause the dis charge of emissions into the atmosphere from the storage tanks combined in excess of:

6.6.9.1.1 VOC BACT Emission Limit: 0.44 ton s per year on a 12

- month

rolling total basis.

6.6.9.2 BACT Work Practice Standard: Use of good maintenance practices.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 34 6.6.9.3 Monitoring, recordkeepin g and reporting shall be conducted in accordance with

Conditions 6.12 and 6.1 6

.

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

6.7 Work Boat Operating Limits

6.7.1 The vessel Allie or substitute work boats (with eq uivalent or lower potential emissions), used in any combination with 25 nautical miles of the C.R. Luigs or DD1 , shall not

exceed a combined total of 7,500 operating hours per year on a rolling 12

- month total

basis.

6.7.2 Utilized work boats shall not combust any diesel fuel with sulfur content greater than

15 ppm by weight.

6.7.3 Compliance with this operating limit will be demonstrated through the monitoring, recordkeeping and reporting conditions as set forth in Conditions 6.13 and 6.1 6

.

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

6.8 Crew Boat Operating Limits

6.8.1 The vessel Fast Skipper or substitute crew boats (with equivalent or lower potential emissions), used in any combination within 25 nautical miles of the C.R. Luigs or DD1

, shall not exceed a combined tota l of 800 operating hours per year on a rolling 12

- month

total basis.

6.8.2 Utilized crew boats shall not combust any diesel fuel with sulfur content greater than

15 ppm by weight.

6.8.3 Compliance with this operating limit will be demonstrated through the monitoring

, recordkeeping and reporting conditions as set forth in Conditions 6.13 and 6.1 6

.

[40 CFR §§ 52.21, 55.2, 55.6(a)(4)

, 55.8 and 71.6(a)(1), (a)(3) and (c)(1)]

6.9 Monitoring and Recordkeeping Requirements for Main Generator Diesel Engines

6.9.1 Compliance demonstration method for the main generator diesel units EU

- 001 through

- 008 on the C.R. Luigs and EU

- 001 through

- 008 on the DD1 : In accordance with Conditions 6.5.1.10 and 6.6.1.10, the permittee shall monitor NO X , CO, VOC, CO 2 , and

PM/PM 10 /P M 2.5 emissions from the main engines by the use of an EPA

- approved parametric monitoring method as described in Condition 6. 9 .1.1 , or an EPA

- approved continuous emissions monitoring system described in Condition 6. 9.1.2

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

Condition 6. 9 .1.3 , or with prior written approval of EPA, a combination of these

methods

.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 35 6.9.1.1 Parametric Monitoring

6.9.1.1.1 The permittee shall properly monitor NO X , CO, VOC, CO 2 , and

PM/PM 10 /PM 2.5 em issions from the main generator diesel units specified in Condition 6. 9 .1 by using a parametric monitoring system such as the Transocean Diesel Engines with Turbochargers (DEWT) monitoring system or an equivalent system upon prior written approval by EPA.

6.9.1.1.2 The permittee shall monitor and record the following parameters

once every 30 seconds for 30 minutes twice a day:

Charge Air Pressure (bar) before and after air cooler; Charge Air Temperature (Celsius) before and after air cooler; Turbocharger RPM A&B (R PM); Exhaust Air Temperature (Celsius); Engine Air Inlet Pressure (mbar); Engine Air Inlet Temperature (Celsius); Engine Air Inlet Relative Humidity (%);
Generator Load (kW); and

NO X , CO, SO 2 , CO 2 , O 2 Emission Concentration (ppm).

6.9.1.2 Continuous Emissions Mon itoring

6.9.1.2.1 The permittee shall properly install, maintain in good working order,

and operate a continuous emissions monitoring system to monitor

emissions from the main generator diesel units specified in

Condition 6. 9 .1.

6.9.1.2.2 The permittee shall obtain stack g as volumetric flow rates using a

calibrated flow monitor that records data on a continuous basis.

6.9.1.2.3 The permittee shall monitor and record energy usage in kW

- hr.

6.9.1.2.4 The permittee shall install, calibrate and maintain the continuous

emissions monitoring system with a plan approved by EPA.

6.9.1.2.5 The quality assurance plan used by the permittee for the certification

and operation of the continuous emissions monitoring system shall be made available to EPA upon request.

6.9.1.2.6 The permittee shall demonstrate compliance based on a 24

- hour

period.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 36 6.9.1.3 Stack Testing Emissions Monitoring

6.9.1.3.1 The permittee shall properly monitor NO X , CO, VOC, CO 2 , and

PM/PM 10 /PM 2.5 emissions from diesel units specified in Condition

6. 9 .1 by using stack testing data collected according to an EPA approved protocol and in accordance with Condition s 5.26 and

6.9 .1.3 .1.1 to 6.9.1.3 .1.4, to prepare a graph of engine load versus emission rates expressed in grams per kilowatt

- hour (g/kW

- hr) for each engine. Plot the engine load as the independent (or x) variable and the pollutant emission rates as the dependent (or y) variable for each load point tested. Construct the graph by drawing straight

- line segments between each load point. Draw a horizontal line to the y

axis from the minimum load point tested.

6.9.1.3.1.1 W ithin 90 days of the start of the drilling campaign, the

main generator diesel units of the MODU that will be in operation under this permit, EU

- 001 through

- 008 on the C.R. Luigs or EU

- 001 through

- 008 on the DD1, shall be stack tested under the requireme nts of this section. Data collected prior to issuance of this permit may be used with EPA approval

.

6.9.1.3.1.2 Each stack test shall be conducted at three different

loads within the expected range of operations.

6.9.1.3.1.3 At a minimum, each stack test run shall test for

emissi ons of CO, NO X , PM 2.5 , PM 10 , VOC, CO 2, and

visible emissions.

6.9.1.3.1.4 During each test run, the permittee shall monitor and

record the following information:

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

Electrica l power produced (in kW

- hr).

6.9.1.3.2 Use the load information recorded per Condition 6.9 .1.3 .1 ., along

with the graph of engine load versus emission rates to determine the emission rate in g/kW

- hr for each engine load recorded. Linear interpolation shall be used to determine the emission rate when the actual load falls between two tested load points When the engine load exceeds the maximum load measured during the stack testing, report the g/kW

- hr emission rate obtained for the highest load point tested during th e most recent stack test. Calculate the average emission rate for each hour of operation from all the individual emission rate results recorded during the hour.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 37 6.9.1.3.3 When records of engine load are not available, substitute the highest

g/kW

- hr emission rate ca lculated for all the load points tested during

the most recent stack test.

6.9.1.3.4 Determine the average emission rate (g/kW

- hr) for each unit from

the hourly emission rate results in each rolling 24

- hour period.

[40 CFR §§ 52.21

, and 71.6(a)(1), (a)(3) and (c)(1)]

6.10 Monitoring and Recordkeeping Requirements for Emergency Generators and Small Onboard Engines

Compliance demonstration method for the emergency generator diesel units (EU

- 015 on

C. R. Luigs and EU

- 011 on DD1 ) and the smal l on

- board diesel engines (EU

- 009 through

- 012,

- 016,

- 0 17,

- 019 through

- 028, and

- 092 on C.R

. Luigs and EU

- 012 through

- 017 and

- 019 through

- 025 on DD1 ): In accordance with Conditions 6.5.2, 6.5.5 through 6.5.9, and 6.6.4 through 6.6.8, the permittee sh all monitor and maintain a contemporaneous record of the following information:

Unit ID; Date/time engine started; Date/time engine shut down; Name of person operating equipment (printed); and Signature of person operating equipment.

[40 CFR §§ 52.21

, 55.8, and 71.6(a)(1), (a)(3) and (c)(1)]

6.11 Monitoring and Recordkeeping Requirements for Storage Tanks

6.11.1 Compliance with applicable operating limits in Conditions 6.5.10 and 6.6.9 will be assured by using EPA’s TANKS 4.0.9d program.

6.11.2 The permittee shall monit or and maintain the following information:

Unit ID; and The dimensions and capacities of units EU

- 029 through

- 059 and EU

- 090 through

- 091 on C.R. Luigs and EU

- 026 through

- 047 and EU

- 078 through

- 081 on DD1

. These records shall be kept for the life of the unit.

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

6.12 Monitoring and Recordkeeping Requirements for Support Vessel Engines

6.12.1 Compliance demonstration method for the support vessels for both C.R. Luigs and DD1

, in accordance with Conditions 6. 7 through 6.8, the permittee shall monitor and maintain a contemporaneous record of the following information:

6.12.1.1 Compliance with this operating limit will be assured by maintaining a record of operating time and diesel fuel use within the 25

- nautical mile r adius of the C.R. Luigs or DD1 and during standby time at the C.R. Luigs or DD1

.03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 38 6.12.1.2 The permittee shall show compliance by determining and recording the sulfur content upon receiving each fuel shipment as specified in Condition 6.4.

6.12.2 Monitoring and Recordkee ping Requirements: The permittee shall monitor and maintain a contemporaneous record with the following information:

Date/time entering the 25 nautical mile radius; Date/time exiting the 25 nautical mile radius; Sulfur content of all fuel used in any engine as specified in Condition 6.4; Gallons of diesel fuel on the support vessel entering the 25 nautical mile radius; and Gallons of diesel fuel on the support vessel exiting the 25 nautical mile radius. Gallons of diesel fuel loaded on to the support v essel within the 25 nautical mile

radius.

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

6.13 Monitoring and Recordkeeping Requirements for Mud and Cement Mixing Operations

6.13.1 Compliance with Conditions 6.5.3.1 and 6.5.3.2 ( for EU

- 013 ) will be assured by maintaining a constant minimum air supply pressure reading (at the cyclone

- filter pressure regulator gauge) of 65 psig. The permittee shall monitor and record this reading at least daily to ensure a pressure drop of no more than 4 psig when the system pulses.

6.13.2 Compliance with Conditions 6.6.2.1 and 6.6.2.2 (for EU

- 009) will be assured by complying with manufacturer specifications including maintaining the minimum air supply pressure reading specified by the manufacture.

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

6.14 Monitoring and Recordkeeping Requirements for Mud Degassing Operations

Compliance with Conditions 6.5.4.1, 6.5.4.2, 6.6.3.1, and 6.6.3.2 (for EU

- 014 and

EU

- 010, respectively) will be assured by monitoring an d recording the daily throughput

of both water

- based and oil

- based mud.

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

6.15 Reporting Requirements

The permittee shall submit the information required in Conditions 6.2, 6.4

, and 6. 9 through 6.1 4 in

accorda nce with reporting specifications detailed in Condition 5.17.

[40 CFR § 71.6(a)(3)(iii) and 55.8 ]

6.16 New Source Performance Standards and National Emission Standard for Hazardous Air Pollutants (HAP) Requirements

6.16.1 Wireline engines EU

- 019 and

- 020 on C.R. Luigs and wireline engines EU

- 016 and

- 017

on DD1 are subject to 40 CFR part 60, subpart IIII based on their per cylinder displacement and model year. The permittee shall demonstrate compliance with the applicable requirements through the following:03/30/2012 BHPB DRAFT Permit OCS

- EPA

- R4008 39 6.16.1.1 The permittee shall maintain documentation in accordance with Condition 5.16 that engines specified in Condition 6.15.1 were installed and configured according to manufacturer’s specifications

.

6.16.1.2 The permittee shall maintain records in accordance with Condi tion 5.16 of manufacturer data indicating compliance with EPA Tier 2 or Tier 3 standards.

6.16.1.3 The permittee shall operate and maintain the engines according to the manufacturer's written instructions or procedures developed by the permittee that are approved in writing by the engine manufacturer. The permittee shall only change those settings that are approved by the manufacturer. The permittee shall maintain records of the manufacturer’s written instructions for operation and maintenance of the engine or th e procedures the permittee developed that are approved in writing by the manufacturer in accordance with Condition 5.16

.

6.16.1.4 The permitted engines shall not combust any diesel fuel that does not meet the requirements of Condition 6.4. [40 CFR § 60 subpart III I and 55.8 ]

6.16.2 Based on engine model years and engine use (summarized in Table s 1 and 2 of

Section 4 ), all diesel engines on C.R. Luigs and DD1 (with the exception of: EU

- 019,

- 020,

- 024 through

- 028,

- 060, and

- 061 on C.R. Luigs and EU

- 016,

- 017,

- 021 through

- 025,

- 048, and

- 049 on DD1 ) are subject to and shall comply with the applicable requirements of 40 CFR part 63, subpart ZZZZ.

6.16.2.1 Existing stationary engines located at an area source of HAP emissions must comply with the requirements in Table 2d and the operating limitations in Table 1b and Table 2b in subpart ZZZZ no later than May 3, 2013 in accordance with the compliance schedule requirem ents of Condition 5.22.

6.16.2.2 Compliance with the numerical emission limitations established in subpart

ZZZZ is based on the results of testing the average of three 1

- hour runs using the testing requirements and procedures in 40 CFR § 63.6620.

6.16.2.3 Compliance with Condition 6.15.2 shall be determined based upon recordkeeping required by the Annual Compliance Certificati on set forth in

Condition 5.21.

[40 CFR part 63, subpart ZZZZ and 55.8 ]

6.16.3 The permittee shall submit to EPA prior notification of any upgrades to or replacements of diesel units specified in Tables 1 and 2 of Section 4 in addition to a reevaluation of the applicability of pertinent NESHAP and NSPS regulations for the modified diesel unit.

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