*** Public Notice Copy***

03/30/2012 DRAFT Permit OCS-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-R4008

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

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

(CFR) part 55, which incorporate by reference the Prevention of Significant Deterioration (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 77056

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 east of longitude 87.5 o W at 

latitude 28.31o N and longitude 86.96 o W, approximately 120 miles from nearest Louisiana shoreline, 

139 miles from the nearest Mississippi 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 permit shall become effective on: [insert effective date 30 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 commences 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 responsibility to comply fully with all 

applicable provisions of federal and state law.

__________ ______________________

Date Signed Beverly H. Banister

Director

Air, Pesticides, and Toxics

Management Division
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 2

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 Billiton Petroleum, Inc.

1360 Post Oak Blvd., Suite 150

Houston, Texas 77056

3 PROJECT LOCATION

BHPB’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, approximately 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

BHPB’s project, known as the Sake Prospect Drilling Project (Sake Project), is an oil and natural gas 

exploration 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. BHPB will use either the Transocean 

ultra-deepwater drillship C.R. Luigs MODU (Operating Scenario 1) or the Transocean semisubmersible 

Development Driller 1 MODU (Operating Scenario 2). Under either operating scenario, 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 (NO2); particulate matter (PM) which includes PM with an aerodynamic diameter less than 10

microns (PM10) and with an aerodynamic diameter less than 2.5 microns (PM2.5); and sulfur dioxide 

(SO2) (known as criteria pollutants), as well as other regulated air pollutants, including oxides of 

nitrogen (NOX), volatile organic compounds (VOC), and greenhouse gases (GHGs). VOC and NOX are 

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

the criteria pollutant PM2.5. 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 NOX, 

CO, PM10, PM2.5, VOC, and GHGs. The project emissions of VOC and NOX are measured precursors 

for the criteria pollutant ozone and NOX is a measured precursor for PM2.5.
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 3

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 

diesel 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, one 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 emergency 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. 

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 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 Ratinga

(hp)

*

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 Engineb Caterpillar or 

similar

3406 CDITA

or similar 490 2000

EU-019 POSU-CA Primary Wireline Unit Diesel Engine 

Hydraulic Generator Combinationb

Caterpillar or 

similar

C-7 DITA or 

similar 300 2009

EU-020 Wireline Unit Alt #2 Diesel Engineb Caterpillar or 

similar

C-7 DITA or 

similar 300 2008

EU-022 Wireline Unit Power Plant GSU-W Generatorb Various Various 160 Various 

EU-023 Wireline Unit Hydraulic Diesel Generator DHPSb 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 --
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 4

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 portable 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. 

*

Horsepower

Table 2 – DD1 Emissions Units (Operating Scenario 2)

Emissions

Unit ID Engine Description Manufacturer Model Ratinga

(hp)

*

Mfg 

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 Engineb Caterpillar or 

similar

3406 or 

similar

490 2000

EU-015 Cement Batch Mixer 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 Plant 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 2005

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

b

These units are portable 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.

*

Horsepower

Table 3 – Support Vessels

Vessel Description Representative Vessela 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 

representative vessel is the worst case vessel in the potential vessel fleet and used to calculate potential emissions. 
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 5

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 

conditions 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 applicable requirements 

prior to or at the time of permit issuance; or

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

[40 CFR § 71.6(f)(1)]

5.3 Other Credible Evidence

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

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

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

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

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

[CAA §§ 113(a) and (e)(1), 40 CFR §§ 60.11(g) and 61.12]
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 6

5.4 Construction and Operation

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

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

accordance with the data, specifications, drawings, exhibits, and assumptions included 

with the application and supporting materials submitted by the permittee, which resulted 

in this permit (application materials). This permit is valid only for the specific processes 

and operations applied for and indicated in the application materials. Any unauthorized 

deviation from the application materials, or from any term or condition of this permit 

may constitute grounds for revocation or enforcement action by EPA. 

5.4.2 The permittee shall properly operate and maintain the OCS source and support vessels, 

including all systems of treatment and control (and related appurtenances) that are 

installed and used by the permittee to achieve compliance with the terms and conditions 

of this permit. This provision includes the operation of backup or auxiliary facilities or 

similar systems when necessary to minimize or prevent emissions in achieving 

compliance with the terms and conditions of the permit.

[40 CFR § 52.21(r)(1)]

5.5 Compliance and Other Requirements

This permit does not relieve the permittee of the responsibility to comply fully with applicable 

provisions of any other requirements under federal law.

[40 CFR § 55.6(a)(4)(iii)]

5.6 Notification to Owners, Operators and Contractors

The permittee must notify all other owners or operators, contractors, and the subsequent owners or 

operators associated with emissions from the OCS source and support vessels of the terms and 

conditions of this permit.

[40 CFR § 55.6(a)(4)(iv)]

5.7 Expiration of Approval to Construct and Permit Renewal

5.7.1 This approval to construct shall become invalid if: construction is not commenced within 

18 months after the effective date of this permit, construction is discontinued for a period 

of 18 months or more, or construction is not completed within a reasonable time. EPA 

may extend the 18-month period upon a satisfactory showing that an extension is 

justified.

[40 CFR § 52.21(r)(2)]

5.7.2 The permittee’s authority to construct and operate shall expire two years from the date 

the OCS Source commences activity on the DeSoto Canyon lease blocks specified 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-EPA-R4008 7

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 timely 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 action on the renewal 

application before the end of the term of this permit, the permittee’s failure to have a 

permit is not a violation of 40 CFR part 71 until the permitting authority takes final action 

on the renewal application. Such protection will cease to apply if, subsequent to 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 condition 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 renewal, 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 granted pursuant to 

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

application.

[40 CFR §§ 71.7(c)(3) and 71.7(b)]

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

permit issuance, including those for public participation and affected State review.

[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, and other 

information required by the application form.

[40 CFR §§ 71.5(a)(2) and 71.5(c)(5)]

5.8 Property Rights

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

[40 CFR §71.6(a)(6)(iv)]

5.9 Inspections

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

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

to the premises where the permitted activity is located or conducted or where any records are required to 

be kept under the terms and conditions of this permit to:
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 8

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, support 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 provision contained in any applicable requirement, the permittee 

may seek to establish that noncompliance with a technology-based emission limitation under this permit 

was due to an emergency. An emergency constitutes an affirmative defense to an action brought for 

noncompliance with such technology-based emissions limitation. The permittee shall demonstrate the 

affirmative defense of emergency through properly signed, contemporaneous operating logs, or other 

relevant evidence that:

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

The permitted facility was at the time being properly operated; 

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

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

The permittee submitted notice of the emergency to 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 unforeseeable events beyond 

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

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

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

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

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

[40 CFR § 71.6(g)(1)]
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 9

5.13 Certification Requirement

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

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

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

complete.

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

5.14 Permit Actions

This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a 

request by the permittee for a permit modification, revocation and reissuance, or termination, or of a 

notification of planned changes or anticipated noncompliance does not stay any permit condition.

[40 CFR § 71.6(a)(6)(iii)]

5.15 Reopening for Cause

The permit shall be reopened by EPA and the permit revised prior to expiration under any of the 

circumstances described in 40 CFR § 71.7(f).

[40 CFR § 71.7(f)]

5.16 Recordkeeping Requirements

In accepting this permit, the permittee understands and agrees that all information relating to this 

permitted source which is submitted to 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 records required by this permit.

5.16.3 During enforcement actions, the retention period for all records will be extended 

automatically unless 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.

[40 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 

or measurement;
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 10

The date(s) the analyses were performed;

The person who performed the sampling or measurements; and

The analytical techniques or methods used.

[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 Division

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 request in writing to determine whether cause exists for modifying, revoking, and 

reissuing, or terminating the permit, or to determine compliance with the permit. Upon 

request, the permittee shall also furnish to 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-EPA-R4008 11

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 promptly 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. The 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:

5.16.10.1Any definition of prompt or a specific time frame for reporting deviations 

provided in an underlying applicable requirement as identified in this permit.

5.16.10.2Where the underlying applicable requirement fails to address the time frame for 

reporting deviations, 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 requirements, the report must be made within 

24 hours of the occurrence; 

For emissions of any regulated pollutant excluding those referenced in the 

preceding bullet, that continue for more than 2 hours in excess of permit 

requirements, the report must be made within 48 hours of the occurrence; or

For all other deviations from permit requirements, the report shall be 

submitted with the semi-annual monitoring report required in Condition 

5.17.1.

[40 CFR § 71.6(a)(3)(iii)(B)]
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 12

5.16.11 Within 10 working days of the occurrence 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 Condition 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 deviation was intermittent or continuous;

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

the operating conditions during the deviation;

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

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

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

level of exceedance, if applicable;

Whether the deviation was unavoidable;

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

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

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

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

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

[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 

situation lasting more than 24 hours, each 24-hour period is considered a separate 

deviation. Included in the meaning of deviation are any of the following:

A situation where emissions exceed an emission limitation or standard; 

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

an emission limitation or standard has not been met; 

A situation in which observations or data collected demonstrate noncompliance with 

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

required by the permit (including indicators of compliance revealed through 

parameter monitoring); and

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

this permit is not performed or not performed as required.

[40 CFR § 71.6(a)(3)(iii)(C)]
03/30/2012 BHPB DRAFT Permit OCS-EPA-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 changes 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 facility 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 changes does not include changes that 

would violate applicable requirements or changes that would contravene federally enforceable permit 

terms and conditions that are monitoring (including test methods), recordkeeping, reporting, or 

compliance certification requirements.

[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-EPA-R4008 14

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 prorated 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 Certification

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 this 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 

compliance status with each term and condition during the certification period. Such methods 

and other means shall include, at a minimum, the methods and means required in this permit. 

If necessary, the permittee also shall identify any other material information that must be 

included in the certification to comply with section 113(c)(2) of the CAA, which prohibits 

knowingly making a false certification or omitting material information; 

The status of compliance with each term and condition of the permit for the period covered 

by the certification, including whether compliance during the period was continuous or 

intermittent. The certification shall be based on the method or means designated above. The 

certification shall identify each deviation and take it into account in the compliance 

certification; and

A summary of NOX, CO, PM/PM10/PM2.5, SO2, VOC, GHG and HAP emissions in tons per 

year emitted by each emissions unit regulated under this permit during the duration of the 

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

operation.

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

5.21 Compliance Schedule

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

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

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

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

5.22 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 United States Coast Guard, the permittee, 

and the operator to assure that the shutdown will proceed in a safe manner. No shutdown action will 
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 15

occur until after EPA’s consultation with these agencies, but in no case will initiation of the shutdown be 

delayed by 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 Conditions 5.26.2 through 5.26.10 whenever conducting a performance test required 

by this permit unless specifically stated 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 specified 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 possible of any delay in the original test date, either by providing at least 7 days 

prior notice of the rescheduled date of the performance test, or by arranging a 

rescheduled date 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 and compliance with the reference test methods; 
03/30/2012 BHPB DRAFT Permit OCS-EPA-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/quality 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 within 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 For the duration of each test run (unless otherwise specified), the permittee shall record 

the following information:

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

sections of this permit; and

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

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

5.25.6 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:

PCX = PCm x (21-X)

 (21-Y)

Where:

PCX = Pollutant concentration at X percent;

PCm = Pollutant concentration as measured;

X = the oxygen concentration specified in the standard; and

Y = the measured average volumetric oxygen concentration.

5.25.8 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-EPA-R4008 17

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 confirmation of actual fee paid), as specified in Conditions 5.27.4 

through 5.27.8; and

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

the preceding calendar year.

[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 payment and a completed fee filing form to either of the 

addresses listed below.

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

U.S. Environmental Protection Agency

FOIA and Miscellaneous Payments

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-EPA-R4008 18

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 specified in Condition 5.27.1, to:

Chief

Air Permits Section

Air, Pesticides and Toxics Management Division

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303

[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 combusted 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 cannot 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 emissions of each regulated pollutant (for fee 

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

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

included in the fee calculation; and

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

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

[40 CFR §§ 71.9(c)(5)(i) through (iii)]
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 19

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

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

official and shall be submitted each year to 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 shall retain in accordance with the provisions of Conditions 5.16.4 and 

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

Records shall be retained for five years following the year in which the emissions data is 

submitted.

[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 payment 

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 SPECIFIC 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 construction 

or operation and the probable duration of operation at that location; and
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 20

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), 52.21 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 summing 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 as part of the Annual Compliance 

Certification in accordance with Condition 5.21.

[40 CFR § 55.8]

6.4 Source-wide SO2 Emission Limit

The permittee shall not combust any diesel fuel with a sulfur content 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 from 

the fuel supplier (the certification must indicate the sulfur content was determined by an 

approved EPA method), or the permittee shall obtain representative fuel samples using 

one of the methods in 40 CFR 80.330 and shall determine the sulfur content of the fuel 

using one of the methods in 40 CFR 80.580.

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 the 

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.
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 21

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), and 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 NOX BACT Limit: 18.1 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 10-4lb/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 10-4lb/hp-hr (0.43 g/kW-hr) on a rolling 

24-hour average basis.

6.5.1.1.5 PM10 BACT Limit: 4.01 x 10-4lb/hp-hr (0.24 g/kW-hr) on a rolling 

24-hour average basis.

6.5.1.1.6 PM2.5 BACT Limit: 3.89 x 10-4lb/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 CO2e on a 

rolling 24-hour average basis and 78,005 tons per year of CO2e 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 Good combustion practices based on the current manufacturer’s 

specifications for these engines; and
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 22

6.5.1.2.3 Additional 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 detailed 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 for 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 parametric 

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 6.16.

6.5.2 Source Identification: EU-009 through -012, crane engines equipped with positive 

crankcase ventilation, 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 NOX 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/PM10/PM2.5 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 CO2e 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 Good combustion practices based on the current manufacturer’s 

specifications for these engines.
03/30/2012 BHPB DRAFT Permit OCS-EPA-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 6.16.

6.5.2.6 Any subsequent replacement of these units must be compliant 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/PM10/PM2.5 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 6.14 and 6.16.

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 CO2e on a 12-month rolling 

total basis.

6.5.4.3 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.

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

Conditions 6.15 and 6.16.

6.5.5 Source Identification: EU-015, emergency generator engine, equipped with positive 

crankcase ventilation, turbocharger and aftercooler, and high-pressure fuel injection with 

aftercooler.

6.5.5.1 NOX 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 tons per year on a 12-month rolling total basis.
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 24

6.5.5.3 VOC BACT Emission Limit: 0.04 tons per year on a 12-month rolling total 

basis.

6.5.5.4 PM BACT Emission Limit: 0.04 tons per year on a 12-month rolling total basis.

6.5.5.5 PM10/PM2.5 BACT Emission Limit: 0.02 tons per year on a 12-month rolling 

total basis.

6.5.5.6 GHG BACT Emission Limit: 72.06 tons per year of CO2e 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 Good 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 operation 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 6.16.

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 Good 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 6.16.
03/30/2012 BHPB DRAFT Permit OCS-EPA-R4008 25

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 NOX 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 tons per year on a 12-month 

rolling total basis.

6.5.7.1.4 PM BACT Emission Limit: 0.38 tons per year on a 12-month rolling 

total basis.

6.5.7.1.5 PM10 BACT Emission Limit: 0.23 tons per year on a 12-month 

rolling total basis.

6.5.7.1.6 PM2.5 BACT Emission Limit: 0.22 tons per year on a 12-month 

rolling total basis.

6.5.7.1.7 GHG BACT Emission Limit: 628.9 tons per year of CO2e 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) Nonroad engine for EU-018;

6.5.7.2.2 Use of ultra low sulfur diesel fuel; and

6.5.7.2.3 Good combustion practices based on the current manufacturer’s 

specifications for these engines.

6.5.7.3 Operating Limit: Units 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 these operating limits 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 6.16.

6.5.8 Source Identification: 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 aftercooler.

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 NOX 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/PM10/PM2.5 BACT Emission Limit: 0.60 tons per year on a 12-

month rolling total basis.

6.5.8.1.5 GHG BACT Emission Limit: 536.6 tons per year of CO2e 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 Good 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-022 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 these operating limits 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 6.16.

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 Good combustion practices based on the current manufacturer’s 

specifications for this engine.

6.5.9.2 Operating Limit: This 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 6.16.

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 Good 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 record 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 6.16.
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 tons per year on a 12-month 

rolling total basis.

6.5.11.2 BACT Work Practice Standard: Use of good maintenance practices.

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

Conditions 6.12 and 6.16.

[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 emissions into the 

atmosphere from each engine in excess of:

6.6.1.1.1 NOX 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 10-4lb/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 10-4lb/hp-hr (0.43 g/kW-hr) on a rolling 

24-hour average basis.

6.6.1.1.5 PM10 BACT Limit: 4.01 x 10-4lb/hp-hr (0.24 g/kW-hr) on a rolling 

24-hour average basis.

6.6.1.1.6 PM2.5 BACT Limit: 3.89 x 10-4lb/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 CO2e on a rolling 

24-hour average basis and 79,921 tons per year of CO2e 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, and
03/30/2012 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 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 detailed 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.

6.6.1.3 Compliance Demonstration Method for units EU-01 through -08: Pursuant to 

Condition 6.10, the permittee shall monitor NOX 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, recordkeeping and reporting shall be conducted in accordance with 

Conditions 6.10 and 6.16.

6.6.2 Source Identification: EU-009, mud and cement mixing, equipped with dust collectors.

6.6.2.1 PM/PM10/PM2.5 BACT Emission Limit: 1.08 tons per year on a 12-month 

rolling total basis.

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 6.14 and 6.16.

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 CO2e 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 6.15 and 6.16.
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 NOX BACT Emission Limit: 1.60 tons per year on a 12-month rolling total 

basis.

6.6.4.2 CO BACT Emission Limit: 0.37 tons per year on a 12-month rolling total basis.

6.6.4.3 VOC BACT Emission Limit: 0.04 tons per year on a 12-month rolling total 

basis.

6.6.4.4 PM BACT Emission Limit: 0.05 tons per year on a 12-month rolling total basis.

6.6.4.5 PM10/PM2.5 BACT Emission Limit: 0.03 tons per year on a 12-month rolling 

total basis.

6.6.4.6 GHG BACT Emission Limit: 77.84 tons per year of CO2e 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 Good 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 maintaining 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 6.16.

6.6.5 Source Identification: EU-012 through -015, cementing engines, cementing 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 emissions into the 

atmosphere from the engines combined in excess of:

6.6.5.1.1 NOX 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: 0.52 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 PM10 BACT Emission Limit: 0.25 ton per year on a 12-month 

rolling total basis.

6.6.5.1.6 PM2.5 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 CO2e 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 Nonroad (or better) for EU-014, and Tier 2 Nonroad engine 

for EU-015;

6.6.5.2.2 Use of ultra low sulfur diesel fuel; and

6.6.5.2.3 Good 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 operated no more than 100 hours per 

year on a 12-month rolling total basis.

6.6.5.6 Compliance with these operating limits 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 reporting shall be conducted in accordance with 

Conditions 6.11 and 6.16.
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 NOX 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/PM10/PM2.5 BACT Emission Limit: 0.60 tons per year on a 12-

month rolling total basis.

6.6.6.1.5 GHG BACT Emission Limit: 536.6 tons per year of CO2e 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 Nonroad (or better) engines for EU-019

and -020 and Tier 3 Nonroad (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 Good 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 these operating limits will be assured by maintaining a record 

of hours of operation and summing such hours on a rolling 12-month basis.

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

Conditions 6.11 and 6.16.
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 Good 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 these operating limits 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 6.16.

6.6.8 Source Identification: 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 Good 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 these operating limits 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 6.16.

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 discharge of emissions into the 

atmosphere from the storage tanks combined in excess of:

6.6.9.1.1 VOC BACT Emission Limit: 0.44 tons 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, recordkeeping and reporting shall be conducted in accordance with 

Conditions 6.12 and 6.16.

[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 equivalent 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 6.16.

[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 total 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 6.16.

[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 NOX, CO, VOC, CO2, and 

PM/PM10/PM2.5 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 NOX, CO, VOC, CO2, and 

PM/PM10/PM2.5 emissions 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 (RPM);

Exhaust Air Temperature (Celsius);

Engine Air Inlet Pressure (mbar);

Engine Air Inlet Temperature (Celsius);

Engine Air Inlet Relative Humidity (%);

Generator Load (kW); and

NOX, CO, SO2, CO2, O2 Emission Concentration (ppm).

6.9.1.2 Continuous Emissions Monitoring

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 gas 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 NOX, CO, VOC, CO2, and 

PM/PM10/PM2.5 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 Conditions 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 yaxis from the minimum load point tested.

6.9.1.3.1.1 Within 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 requirements 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 

emissions of CO, NOX, PM2.5, PM10, VOC, CO2, 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 

Electrical 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 the 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 calculated 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 small on-board diesel engines (EU-009 through -012, 

-016, -017, -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 shall 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 monitor 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 radius 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 Recordkeeping 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 vessel 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 and 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 6.14 in

accordance 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 Condition 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 the 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 IIII and 55.8]

6.16.2 Based on engine model years and engine use (summarized in Tables 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 requirements 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 Certification 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)]