Response to Comments OCS

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- R4019 and

- R4 0 20 BlackHawk BlackHornet UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4

Final Determination and Response to Comments for Outer Continental Shelf Air Permit s OCS

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- R4019 and OCS

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- R4020

Anadarko Petroleum Corporation

On November 14, 2014, the Region 4 office of the United States Environmental Protection Agency (EPA) requested public comment on two draft Outer Continental Shelf (OCS) air permits for Anadarko Petroleum Corporation (Anadarko), 1201 Lake Robbins Drive, The Woodlands, Texas 77380. The permits will reg ulate air pollutant emissions from exploratory drilling operation s within the Eastern Gulf of Mexico of the OCS . The proposed project associated with permit OCS

- EPA

- R4019 will mobilize the exploratory drillship Diamond BlackHawk and the proposed project as sociated with permit OCS

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- R 4020 will mobilize the exploratory drillship Diamond BlackHornet . The proposed projects are for exploratory drilling and well completion and maintenance activities only and do not include the establishment of any permanent pro duction platforms.

The EPA prepared two draft permits for public comment, as well as a preliminary determination/statement of basis for each draft permit that explains the permit conditions. The draft permit conditions and preliminary determination docume nts are the same for both projects; they simply reference different drilling rigs. The preliminary determination s and the draft permit s are available on the EPA Region 4’s website at: http://www.epa.gov/region4/air/permits/ocspermits/ocspermits.html and regulations.gov (docket #EPA

- R04

- OAR

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- 0728 ). The permit s incorporate applicable requirements from the federal Prevention of Significant Deterioration preconstruction and ti tle V operating permit programs, New Source Performance Standards (NSPS), and National Emission Standards for Hazardous Air Pollutants (NESHAP), as required by the OCS Air Quality Regulations at 40 Code of Federal Regulations (CFR) part 55.

During the pub lic comment period, which commenced on November 14, 2014, and ended on December 15, 2014, the EPA only received comments from Anadarko. The EPA did not receive a request for a public hearing and did not hold a public hearing because it has determined that there was not a significant degree of public interest in the permit . The Response to Comments document summarizes the comments received, provides the EPA’s response, and summarizes the changes made to the permit. A copy of the comments is in the administrative record for the BlackHawk and BlackHornet permits and available at the website listed above.

In addition, the EPA has clarified the Project Description section of the permit. The EPA removed t he reference to “facilities on the sea floor” in the description of the well maintenance activities in the Project Description section. The EPA removed the reference to “facilities on the sea floor” in the description of the well maintenance activities in the Project Description section because there are no facilities on the sea floor associated with the permitted well maintenance activities.

After consideration of the expressed view of all interested persons, the pertinent federal statutes and regulations, and additional material relevant to the application and contained in the administrative record, the EPA has made a final determination in a ccordance with title 40 CFR part 55 to issue two air permit s to Anadarko for their proposed exploratory drilling operation. The final permit s do not differ significantly from the draft permit s offered for public comment.

The final permit s , the EPA’s resp onse to the public comments, and additional supporting information are available at http://www.epa.gov/region4/air/permits/ocspermits/ocspermits.html . Copies of the final permit s and the EPA’s responses to the public comments are available for inspection during normal business hours at the EPAResponse to Comments OCS

- EPA

- R4019 and

- R4 0 20 BlackHawk BlackHornet Region 4 Office (please contact the EPA in advance for available viewing times) and are also available upon request

. To request the se documents or check available viewing times, please contact Ms. Rosa Yarbrough at: R4OCSpermits@epa.gov ; (404) 562

- 9643; or EPA Region 4, APTMD; ATTN: Ms. Rosa Yarbrough, 61 Forsyth Street, SW; Atlanta, GA 3030 3.

Any person who filed comments on the draft permits may petition the Environmental Appeals Board (EAB) by January 30, 2015 , to review any condition of the final permit. Others may petition for review only with respect to any changes from the draft to th e final permit decision or other grounds that were not reasonably foreseeable during the public comment period on the draft permit. The petition must be filed with the Clerk of the EAB no later than January 30, 2015 and contain the information required by 40 CFR §§ 71.11(l) and 124.19

. Please see 40 CFR § 124.19, 40 CFR § 71.11 (l) , and the EAB’s website at http://www.epa.gov/eab/ for more information regarding the procedure for appeals to the EAB . Please also visit the EAB website for filing addresses and electronic filing information.
Please bring this announcement to the attention of all persons who you know would be interested in the
matter.Response to Comments OCS

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- R4019 and

- R4 0 20 BlackHawk BlackHornet

Summary of Comments Received from Anadarko Petroleum Corporation on Draft Outer Continental Shelf Air Permit s OCS

- EPA

- R4019 and OCS

- EPA

- R4020 Followed by EPA Responses:

Comme nt 1: Section 5.23 Transfer of Ownership (page 16)

- Anadarko commented that this condition is not applicable in the offshore context, because it does not reflect the ownership of the permit and the drillship for projects on the OCS . Anadarko requested the language of this c ondition change, as reflected by the strikethrough and bold

, to the following:

In the event of any changes in control or ownership of the OCS source, t T his permit shall be binding on all subsequent owners and operators if the permittee elects to transfer the permit. If transferred, the 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 in accordance with Condition 5.16.7.

Response: The EPA concurs that this comment does not reflect the mob ile nature and ownership of OCS drilling vessels. The EPA has revised the condition to reference the requirements of 40 CFR 71.7(d) for amending a permit to reflect changes in ownership or operation al control

.

Comme nt 2: Section 6.6 BlackHawk Emissions and Operating Limits (page 24)

- Anadarko requested that the emission limits in Condition 6.6.1.1.9 through 6.6.1.1.12 for the main engines be changed consistent with previously requested BACT limits

. Response: Condition 6.6.1.1.9 of the draft permit sets the VOC BACT limit for DR

- ME

- 07 and DR

ME

- 08 at 6.2 lb/hr . Anadarko proposed a limit of 9.16 lb/hr in comments on the draft permit and in Anadarko’s August 2014 addendum submittal. As stated in EPA’s preliminary determination

, the EPA used the stack test data in Appendix B of the Emissions Test Report received by the EPA on July 15, 2014 , to set the VOC BACT emission limit for DR

- ME

- 07 and DR

- ME

- 08 in the draft permit

. T he draft permit limit of 6.2 lb/hr was determined based on the se stack test results and the 95% confidence interval of the highest emitt ing engine operating at 50% load

. Anadarko calculated their proposed limit of 9.16 lb/hr by interpolating the stack test data from the smaller engines, DR

- ME

- 01 through DR

- ME

- 06 , measured at 30% and 60% load

.

The EPA concurs that the stack test results for the Hyundai

- HiMsen ( HHI ) engines on the BlackHawk drillship represent a small data set upon which to base the emission limitation. However, EPA does not find the applicant’s methodology of usi ng interpolated data from the smaller engines to be more reliable than actual emissions data from the larger engines operating at the permitted 50% load. Hence, EPA has retain ed the emission limit proposed in the draft permit

. Revisions to the permitted limits may be necessary as additional operating data becomes available.

Anadarko proposed PM/PM 10 /PM 2.5 BACT e mission limits for DR

- ME

- 01 through DR

- ME

- 08 in their comments for Conditions 6.6.1.1.10 through 6.6.1.1.12 . The limits requested in Anadarko ’s comments on the draft permit correspond to Anadarko’s July 18, 2014 submittal, which was subsequently updated in Anadarko’s August 2014 submittal

. A summary of the July 18, 2014 and the August 2014 limits appears on page 2 of the August 2014 addendum su bmittal. T he EPA relied on the PM/PM 10 /PM 2.5Response to Comments OCS

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- R4 0 20 BlackHawk BlackHornet

BACT emission limits for DR

- ME

- 01 through DR

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- 08 proposed in the revised August 2014 submittal, as well as our independent analysis

, to establish the PM/PM 10 /PM 2.5 BACT emission limits for these engines in the permits. Anadarko did not provide any new information to substantiate a change in the se permit limits to reflect those in Anadarko’s July 18, 2014 submittal, and therefore

, the EPA retain ed the limits as proposed in the draft permit.

Comment 3: Section 6.6.1.3 Monitoring and Recordkeeping (page 26)

- The condition requires the permittee to monitor and record NO x , CO, and O 2 emissions in ppm. Anadarko commented that the monitoring system will record O 2 emissions i n percentage as opposed to ppm, an d requested the condition change to reflect this

. Response: The requested change is consistent with the application and the assumptions used in the EPA’s review. The EPA changed the units for O 2 as requested to reflect the actual monitoring parameters.

Comment 4: Section 6.6.7 Source Identification: DR

- V G

- 01 through DR

- VG

- 04 (page 32)

- Anadarko requested that greenhouse gas (GHG) limit be updated from the limit proposed in the September 2013 application to the limit submi tted as part of the February 11, 201 4 technical memorandum based on EPA’s revised global warming potentials

. Response: The EPA has included the requested change in the final permit and updated the GHG limit to reflect the most recent GHG submittal from February 11, 2014

.

Comment 5 : Section 6.7.1 (page 39 )

- This condition limits the fuel for all support vessels. Anadarko requested that the daily and annual fuel limits increase from the worst

- case emissions for the supply boat to the total worst

- case emissions for all support vessels.
Response: The requested change is consistent with the application and the assumptions used in the EPA’s review. This condition limits the support vessels based on the modeling analysis. However, the corresponding fuel limit used in the modeling procedure include d only the supply and the anchor handling boat. Therefore, Condition 6.7.1 has been modified to on ly apply to the supply and anchor handling boats. In addition, the EPA included specific fuel or hourly limits for the stimulation vessel, the tug, the barge, and the well evaluation vessel, to more accurately reflect the emissions that were modeled and th e emission estimates used in the application. These additional operating limits are based on the information presented in Anadarko’s August 2014 submittal.

Comment 6: Section 6.11 (page 43)

- This condition includes an inaccurat e engine reference for the well evaluation engines , DR

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- 12 through DR

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- 16 . An a darko has proposed that the description DR

T P

- 16 through DR

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- 21 change to accurately refle ct the well evaluation units, DR

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- 12 through DR

TP

- 16.

Response: The EPA corrected th is inadvertent error as requested

.Response to Comments OCS

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- R4019 and

- R4 0 20 BlackHawk BlackHornet

Comment 7: Preliminary Determination and Statement of Basis Section 4.5.1 (page 13)

- Anadarko requested removing language justifying the EPA’s de cision f or granting Anadarko an exemption under 40 CFR part 55.
Response: T he EPA typically does not re

- issue the preliminary determination document with the final permit nor change our justifications for permit terms that will not be revised . The EPA has determined that, based on currently available data, no emissions offsets will be required. I f , however, the EPA determines that the facility emissions were misrepresented in the permit application, or for other reasons of material error, the EPA has the authority to open and revise the permit for cause.