### ***Draft for Public Notice***

Note: permit terms for OCS

- EPA

- R4019 are the same as for OCS

- EPA

- R4020

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 

## 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

- R4019

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 Preve ntion of Significant Deterioration of Air Quality (PSD) regulations at 40 CFR § 52.21 and the title V Operating Permit Program regulations at 40 CFR part 71,

Anadarko Petroleum Corporation 1201 Lake Robbins Drive The Woodlands, Texas 77380

is hereby auth orized to construct and operate air emissions units and to conduct other air pollutant emitting activities at an OCS source at multiple sites within the Eastern Gulf of Mexico. The drilling area is that area of the OCS located east of longitude 87.5, west of the Military Mission Line (86°41’ west longitude), at least 100 miles from the Louisiana shoreline, and at least 125 miles from the Florida shoreline.

Upon commencing activities in the area identified as the project location, this OCS source and

suppo rt vessels shall be constructed and operated in accordance with the terms and conditions set forth in this permit.

This permit is 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 and 71.11(i) ; or if no comments requested a change in the draft permit, the permit shall become effective immediately upon issuance], unless review of the permit decision is requested in accordance with 40 CFR 124.19 or 40 CFR 71.11(l)

.
This pe rmit shall expire on : [insert date 5 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 Division2

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 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 implementi ng 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 regulations at 40 CFR part 71. This permit is based upon application materials submitted to EPA by Anada rko Petroleum Corporation (Anadarko) dated September 5, 2013 ; supplemental submittals dated on September 18, 2013, November 26, 2013, December 5, 2013, F ebruary 11, 2014, July 15, 2014, September 2, 2014 and September 10, 2014 , in the administrative record for this permit action ; and upon the technical analysis performed by EPA.

2 APPLICANT

Anadarko Petroleum Corporation 1201 Lake Robbins Drive The Woodlands, Texas 77380

3 PROJECT LOCATION

Anadarko’s project is located on the OCS in the Eastern Gulf of Mexico. The drilling sites are located east of longitude 87.5 ° , west of the Military Mission Line (86°41’ west longitude), at least 100 miles from the Louisiana shoreline, and at least 125 miles from the Florida shoreline.

4 PROJECT DE SCRIPTION

The proposed project will mobilize the BlackHawk drillship owned by Diamond Offsh ore Drilling Inc. and associated support vessels. The support vessel s may include a combination of supply boats

, anchor handling boat s , tug boat s , barge s , stimulation vessels and well evaluation vessel s. The proposed project will consist of three phases : the drilling phase, the well completion phase, and the production well maintenance phase. Anadarko will conduct drilling activities at multiple locations wi thin the Eastern Gulf of Mexico area described in Section 3, Project Location, of this permit. Emissions from production well maintenance activities related to facilities on the sea floor are subject to regulation by this permit. This permit does not autho rize the establishment of any permanent non

- subsea production platforms

.
Air pollutant emissions generated from the project include carbon monoxide (CO), oxides of nitrogen (NO x ), particulate matter (PM), particulate matter with an aerodynamic diameter le ss than 2.5 microns (PM 2.5 ), particulate matter with an aerodynamic diameter less than 10 microns (PM 10 ), sulfur dioxide (SO 2 )

, and volatile organic compounds (VOC) (known as criteria pollutants ), as well as other regulated air pollutants

, including greenh ouse gases (GHGs)

. VOC and NO x are the measured precursors for the criteria pollutant ozone, and NO x and SO 2 are measured precursors for PM 2.5 . Based on emissions estimates and applicable permitting thresholds

, the project is subject to the PSD and title V programs and has significant emissions of3

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 NO X , CO, PM, PM 10 , PM 2.5 , VOC, and GHGs. In addition, the BlackHawk is an area source of hazardous air pollutants pursuant to 40 CFR 63 subpart ZZZZ.

The BlackHawk emission units are identified in Table 1 . Additional units on the stimulation vessel that will be used for OCS activities are listed in Table 2 . Table 3 lists the representative support vessels

.
Support vessels operating within 25 miles of the OCS source may include a combination of supply boat s, anchor handling boats, tug boats, barges, stimulation vessels

, and well evaluation vessels that run marine diesel engines.

The information provided in Tables 1 through 3 is for description and identification purposes and does not establish operating l imits.

Table 1

– BlackHawk Emissions Units

Emissions Unit
ID Description Make & Model Rating a Manufacture Year
DR

- ME

- 01

– 06 Main propulsion generator #1

through #6 Hyundai

- HiMsen
9H32/40V 6,035 hp * 2012

DR

- ME

- 07

– 08 Main propulsion generator #7 and

#8 Hyundai

- HiMsen
18H32/40V 12,069 hp 2012

DR

- GE

- 01 Emergency Generator Cummins QSK60DMGE 2,547 hp 2011

DR

- LB

- 01

– 06 Life boat engine #1 through #6 Siyang 485

- J 41 hp

DR

- AC

- 01 Emergency air compressor engine

#1 Hatz 2M41 39 hp 2011

DR

- FR

- 01 Fast rescue craft engine #1 SAAB

- L4 Turbo 55 hp

DR

- VG

- 01

– 02 Mud degass er #1 and #2 Burgess Magna

Vac

– Model 1500 -

DR

- VG

- 03

– 04 Mud degass er # 3 and #4 Hampco

DR

- DC

- 01

– 03 Dust collectors #1 through #3 National Oilwell

Varco

– DP46 26 M 3 /Min

DR

- DC

- 04 Dust Collector #4 Vortex Ventures V

V

- ST

- A

- 20 850

- 1,000

CFM

DR

- FE

- 01 Drillship Fugitive Emissions

- - DR

- PO

- 01 Painting operations

- - DR

- WO

- 01 Welding operations

- - DR

- FT

- 01

– 16

, and

- 19 Various diesel fuel tanks

- -

DR

- FT

- 17

– 18 Various helicopter fuel tanks

- - Third Party Engines b

DR

- TP

- 01

– 02 Third party engine #1 and #2 Various

- Tier II
Certified ≤860 hp Varies

DR

- TP

- 03

– 11 Third party engine #3 through #11 Various

- Tier II
Certified ≤ 300 hp Varies4

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 DR

- TP

- 12

– 16 Third party well evaluation engine

#1 through #5 Detroit Diesel or equivalent ≤ 140 hp Varies

DR

- TP

- 17

– 21 Third party engine #12 through #16 Various

- Tier II
Certified ≤ 126 hp Varies

DR

- TP

- 22 Flowback boiler Various 8 MMBtu/hr Varies

DR

- TP

- 23 Boom flare Various 60 MMScf/day Varies

DR

- TP

- 24

– 26 Condensate tanks

- 21,000 gallons Varies

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

b These units are portable and brought on the drillship as needed by a third party supplier. The specific engine used will meet an equivalent or a higher EPA Tier standard.

* Horsepower

Table 2

– Well Completion Stimulation Vessel Emission Units a

Emissions
Unit ID Description Make & Model Rating b (hp) *

SV

- PE

- 01

– 08 Stimulation vessel pump engines Caterpillar 3512 DITA (or equivalent) 2,250

a The specific stimulation vessel use d during the drilling project may vary based on availability. The engine and vessel used during the project will be an equivalent or a higher EPA Tier standard.

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

* Horsepower

Table 3

– Support Vessels

Vessel Description Representative Vessel a Supply Boat HOS Coral Anchor Handling Boat Kirt Chouest Well Completion Vessels Tug, Barge, Stimulation Vessel, Well Evaluation Vessel

a Specific supply boats

, anchor handling boats, and well completion vessels available for use during the project had not been identified at the time of application. The representative vessel is the wo rst

- case vessel in the potential vessel fleet and used to calculate potential emissions.

5 GENE RAL 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

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 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 be en 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 compliance with the

a pplicable requirements that are included and are specifically identified in this permit. Nothing in this permit shall alter or affect the following:

5.2.1 The provisions of CAA section 303 (emergency orders), including the authority of the Administrator under t hat section;

5.2.2 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

5.2.3 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 5.20 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 performe d.
[CAA §§ 113(a) and (e)(1), 40 CFR §§ 60.11(g) and 61.12]6

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 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 sha ll 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 t he 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

an d 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 prior to operation of an y subject emissions unit

. [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. The EPA may extend the 18

- month period upon a satisfactory showing that an extension is justified. For the purposes of this permit, periods greater than 18 months between drilling campaigns are not considered to be a discontinuation of construction.
[40 CFR § 52.21(r)(2)]7

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 5.7.2 This permit shall expire on the expiration date on page one of this permit.

[40 CFR § 52.21(i)(3)]

5.7.3 Expiration of this permit terminates the permittee’s right to operate unless a timely and complete permit renewal application has been submitted at least six (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 t he 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 deter mination 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 expiration 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 re main 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 participatio n and affected State review.
[40 CFR §71.7(c)(1)(i)]

5.7.6 An 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 applicat ion 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)]8

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 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:

5.9.1 Have access to and copy any records that must be kept under the conditions of the permit, including but not limited to, information relating to the OCS source, support vessels, monitoring data, or complian ce 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 co mpliance with this permit or EPA rules.

Reasonable times 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 requirem ent, 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

- b ased emissions limitation. The permittee shall demonstrate the affirmative defense of emergency through properly signed, contemporaneous operating logs, or other relevant evidence that:

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

emergency;

5.10.2 The permitted facility was at the time being properly operated;

5.10.3 During the period of the emergency, the permittee took all reasonable steps to minimize levels of emi ssions that exceeded the emissions standards, or other requirements in this permit; and

5.10.4 The permittee submitted notice of the emergency to EPA within two (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.9

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 [40 CFR §§ 71.6(g)(2), 71.6(g)(3), and 71.6(g)(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 si tuation 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

bas ed 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)]

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 may be used by EPA as evidence in any enforcement case involving the permitted source arising under federal statutes, EPA rules, or rules en forceable by EPA.10

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 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 required by this permit will be extended automatically until the permittee receives written notice from EPA that the permittee no longer needs to retain these records.

5.16.4 The permittee shall hold at the corporate offices of Anadarko Petroleum Corporation, 1201 Lake Robbins D rive, The Woodlands, Texas 77380, all records required by the permit including, but not limited to, monitoring data and support information required by the permit, and records of all data used to complete the application for this permit. These materials sh all be retained for at least five years from the date of the sample, measurement, or report unless otherwise specified. Records of all data used to complete the permit application must be kept for five years from the date of the application, unless otherwi se specified. Support information includes all calibration and maintenance records and all original strip

chart recordings for continuous monitoring instrumentation and copies of all reports required by the permit.
[40 CFR §§ 71.6(a)(3)(ii)(B) and 55.8]

5.16.5 Records of monitoring information shall include:

5.16.5.1 the date and time of sampling or measurements; 5.16.5.2 the emission unit or other place as defined in this permit; 5.16.5.3 the operating conditions as existing at the time of sample or

measurement; 5.16.5.4 the results of such samples or measurements ; 5.16.5.5 the name of the person who performed the sampling or measurements;

and 5.16.5.6 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 whi ch 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, the permittee shall, upon becoming aware of such facts or corre cted information, promptly submit such facts or corrected information to EPA

. [40 CFR §§ 71.5(b) and 55.8]11

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 5.16.7 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, the permittee shall submit electronic copies of the above

- referenced notifications and communications to the following individuals at their

co rresponding email address:

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

- 562

- 9216 Jason Dressler dressler.jason@epa.gov 404

- 562

- 9208 Kelly Fortin fortin.kelly@epa.gov 404

- 562

- 9117 Eva Land land.eva@epa.gov 404

- 562

- 9103

5.16.8 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, t he 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 confidenti ality 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]

5.17 General Reporting Requirements

5.17.1 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 when the OCS source commences activity subject to this permit and end on either June 30 or December 31, whichever occurs first. All reports shall be submitte d 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

co nsistent with Condition 5.13.

5.17.2 The permittee shall promptly report to EPA, by telephone or facsimile, deviations from permit conditions, the probable cause of such deviations, and any corrective actions or preventive measures taken. The report shall be made using the following numbers:12

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014

Telephone: (404) 562

- 9194 Facsimile: (404) 562

- 9019 Attn: Air Permits Part 71 Deviation Report

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

5.17.3.1 Any definition of prompt or a specific t ime frame for reporting

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

5.17.3.2 Where the underlying applicable requirement fails to address the time

frame for reporting deviations, reports of deviations will be submitted based on the following schedule:

5.17.3.2.1 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;

5.17.3.2.2 for emissions of any regulated pollutant excluding those

referenced in Condition 5.17.3.2.1, that continue for more than two (2) hours in excess of permit requirements, the report must be made within 48 hours of the occurrence; or

5.17.3.2.3 for all other deviations from permit requirements, the report

shall be submitted with the semi

- annual monitoring report required in Condition 5.17.1.

5.17.4 Within 10 working days of the occurrence of a deviation that requires 24

- hr or 48

- hr notification 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.

5.17.5 When reporting excess emissions or permit deviations, including those that are required to be submitted for the first time with the semi

- annual monitoring report, the permittee must report in writing the following information:13

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014

5.17.5.1 OCS Source (Facility) Name; 5.17.5.2 OCS A ir Permit Number; 5.17.5.3 company Name; 5.17.5.4 date/time when the deviation was discovered; 5.17.5.5 date/time when the event began (24

- hour clock); 5.17.5.6 date/time when the event ended (24

- hour clock); 5.17.5.7 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); 5.17.5.8 if the deviation was intermittent or continuous; 5.17.5.9 brief description of what happened and the cause, including

information regarding the operating conditions during the deviation; 5.17.5.10 ident ification 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; 5.17.5.11 identification of each emission limit potentially exceeded during the

event and the level of exceedance, if applicabl e; 5.17.5.12 whether the deviation was unavoidable; 5.17.5.13 describe corrective action taken and action taken to prevent future

recurrence; 5.17.5.14 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 5.17.5.15 certification: Based on information and belief formed after reasonable

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

5.17.6 For the purposes of Conditions 5.17.1 through 5.17.7, d eviation 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 recordkeep ing 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:

5.17.6.1 a situation where emissions exceed an emission limitation or st andard; 5.17.6.2 a situation where process or emissions control device parameter values

indicate that an emission limitation or standard has not been met; 5.17.6.3 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 5.17.6.4 a situation in which any testing, monitoring, recordkeeping or

reporting required by this permit is not performed or not performed as required.14

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 5.17.7 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 §§ 55.8, 71.6(a)(3)(i)(B), and 71.6(a)(3)(iii)]

5.18 Off Pe rmit Changes

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

5.18.1 Each change is not addressed or prohibited by this permit. 5.18.2 Each change shall meet all applicable requirements and shall not violate any existing permit term or condition. 5.18.3 Each change may not include changes subject to any requirement under any provision of title I of the Clean Air Act. 5.18.4 The permittee shall provide contemporaneous written notice to EPA of each change

un der the provision, except for changes that qualify as insignificant activities under 40 CFR § 71.5(c)(11). The written notice shall include the following:

5.18.4.1 a description of each change; 5.18.4.2 date of the change; 5.18.4.3 any change in emissions; 5.18.4.4 list of pollutants emitt ed; and 5.18.4.5 any applicable requirements that would apply as a result of the change.

5.18.5 The permit shield in Condition 5.2 does not apply to changes made under this provision.

5.18.6 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)]

5.19 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 o f 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 (includin g test methods), recordkeeping, reporting, or compliance certification requirements.15

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 5.19.1 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 oc cur 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 of this permit. 5.19.2 Any permit shield provided under Condition 5.2 does not apply to ch anges made under this provision.
[40 CFR §§ 71.2 and 71.6(a)(13)(i)]

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 pract ices, postmarked by February 28 of each year and covering the previous calendar year except that the first certification shall cover the period from the date the OCS commences activities subject to this permit through December 31. The compliance certificat ion 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:

5.20.1 The identification of each permit term or condition that is the basis o f the certification;

5.20.2 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 req uired 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;

5.20.3 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

m ethod or means designated above. The certification shall identify each deviation and take it into account in the compliance certification; and

5.20.4 A report of NO X , CO, PM/PM 10 /PM 2.5 , SO 2 , VOC, GHG

, and HAP emissions in tons per year emitted by each emissions unit regulated under this permit during the duration of the reporting period based on recorded data, including actual fuel usage and actual hours of operation. The report shall include the emiss ion factors used for each unit and a description of the reproducible methodology used to calculate the emissions for the reporting period.

[40 CFR §§71.6(c)(5), 55.6(a)(4) and 55.8]16

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 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)(i ii)(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 Env ironmental 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 occur until after EPA’s consultation with these entities, but in no case will initiati on 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 c hanges in control or ownership of the OCS source, this permit shall be binding on all subsequent owners and operators. The permittee shall notify the succeeding owner and operator of the existence of this permit and its conditions by letter, a copy of whic h shall be forwarded to EPA Region 4 in accordance with Condition 5.16.7

. [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 permi t 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 5.25.2 through 5.25.10 whenever conducting a performance test required by this permit unless specifically stated otherwise in this permit.17

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 5.25.2 The permittee shall provide EPA at lea st 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 th e 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 seven (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:

5.25.3.1 purpose and scope of testing; 5.25.3.2 source description, incl uding a description of the operating scenarios

and mode of operation during testing and including fuel sampling and analysis procedures; 5.25.3.3 schedule/dates of testing; 5.25.3.4 process data to be collected during the test and reported with the

results, including sour ce

- specific data identified in the emission unit sections of this permit; 5.25.3.5 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, e ight (8) hours, 24 hours, etc.) and minimum sample volume; 5.25.3.6 sampling location description and compliance with the reference test

methods; 5.25.3.7 analysis procedures and laboratory identification; 5.25.3.8 quality assurance plan; 5.25.3.9 calibration procedures and frequency; 5.25.3.10 s ample recovery and field documentation; 5.25.3.11 chain of custody procedures; 5.25.3.12 quality assurance/quality control project flow chart; 5.25.3.13 data processing and reporting; 5.25.3.14 description of data handling and quality control procedures; and 5.25.3.15 report content and timing.

5.25.4 Only regular operating staff may adjust the processes or emission control devices during or within two (2) hours prior to the start of a source test. Any operating adjustments made during a source test that do not result in representative testing conditions 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:18

Anadarko BlackHawk OCS

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- R4019 11/14/2014

5.25.5.1 all data which is required to be monitored during the test per the

applicable condition of this permit that is requiring a test; and

5.25.5.2 all continuous monitoring system data that is required to be routinely

monitored in the applicable condition of this permit for the emission unit being tested.

5.25.6 Each source test shall follow the reference test methods specifie d by this permit and consist of at least three (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 sta ndard, the permittee shall correct the measured pollutant concentration to the oxygen concentration specified in the emission standard by using the following equation:

PC X = PC m · (21

- X)

(21

- Y)

Where: PC X = Pollutant concentration at X percent; PC m = 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. The report shall include the information required to be recorded pursuant to Condition 5.25.5 above.

5.25.10 Source test emission data shall be reported as the arithmetic average of all valid

test runs in the units of any applicable emission limit, unless otherwise specified in the emis sion unit sections of this permit. The permittee shall also submit the raw test data, which may be submitted in electronic format.
[40 CFR §§ 71.6(a)(3) and 71.6(c)(1)]

5.26 Fee Payment

5.26.1 No later than April 1 of each year, the permittee shall submit the followi ng to EPA:19

Anadarko BlackHawk OCS

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- R4019 11/14/2014

5.26.1.1 Full payment of the annual permit fee, as specified in Conditions

5.26.2 through 5.26.11;

5.26.1.2 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 5.26.4 through 5.26.8; and

5.26.1.3 An annual emissions report of actual emissions, as specified in

Condition 5.26.6, for the preceding calendar year.

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

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 M ail 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), s end 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)

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 5.26.1, to:

Chief Air Permits Section Air, Pesticides and Toxics Management Division U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 3030320

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 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.

5.26.5.1 “Actual emissions” means the actual rate of emissions in tons per year

(TPY) of any “regulated polluta nt (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, a nd types of materials processed, stored, or combusted during the preceding calendar year.

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.

5.26.5.3 If actual emissions c annot be determined using the compliance

methods in the permit, the permittee shall use other federally recognized procedures.

5.26.5.4 The permittee shall exclude the following emissions from the

calculation of fees:

5.26.5.4.1 the amount of actual emissions of each “ regulated pollutant

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

5.26.5.4.2 actual emissions of any “ regulated pollutant (for fee

calculation) ” already included in the fee calculation; and

5.26.5.4.3 the insignificant quantities of actual emis sions not required

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

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 cer tified by a responsible official and shall be submitted each year to EPA by the date specified in Condition 5.26.1. The annual emissions report shall be submitted to EPA at the address listed in Condition 5.26.4 of this permit.

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.21

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- R4019 11/14/2014 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 worksh eets 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.

5.26.9 Failure of the permittee to pay fees in a timely manner shall subject the permittee

to assessmen t of penalties and interest.

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.

5.26.11 If the permittee believes that 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]

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 latitude/longitude and Universal Transverse Mercator grid system formats;

6.1.2 The proposed date that the drillship will enter the lease block and commence construction or operation and the probable duration of operation at that location; and

6.1.3 The certification of maintenance an d no physical changes required by Condition
6. 5 .1. 2 (if applicable); and

6.1.4 N ot less than 24 hours prior to commencing construction or operation, of any changes to the information provided by the permittee in Condition 6.1.
[40 CFR §§ 71.6(a)(6)(v), 52.21 an d 55.8]

6.2 Reserved.22

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014 6.3 Global Warming Potential (GWP)

For the purposes of showing compliance with any GHG emission limit in this permit, the GWP factors listed in 40 CFR Part 98 Subpart A, Table A

- 1 as of the date of this permit shall be used. The current GWP factors are listed below:

GHG Pollutant GWP Factor

CO 2 1

CH 4 25

N 2 O 298

SF 6 2 2,800 [40 CFR § 98 Subpart A]

6.4 Source

- wide SO 2 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 the BlackHawk or on any support vessel.

6.4.1 The permittee shall obtain a certification of sulfur content from the fuel supplier for all diesel fuel used on the BlackHawk , and used in all equipment and vessels used during well completion (the certification must indicate the sulfur content was determined by an approved E PA method ), o r the permittee shall obtain representative fuel samples using one of the methods in 40 CFR 80.330 and shall determine the sulfur content 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 BlackHawk for activities covered by this

permit, the permittee shall determine and record the sulfur content of the diesel fuel on the BlackHawk and the support vessels using the procedures in Condition 6.4.1.23

Anadarko BlackHawk OCS

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- R4019 11/14/2014

6.4.2.2 Thereafter, the permi ttee shall determine and record the sulfur content

of the diesel fuel on the BlackHawk and the support vessels using the procedures in Condition 6.4.1 upon receiving each fuel shipment

.

6.4.3 The permittee shall provide the records required by Condition 6.4.2 a nd the certification(s) of sulfur content or results of all fuel sample analyses required by Conditions 6.4.1 and 6.4.2 with the Annual Compliance Certification required by Condition 5.20.
[40 CFR §§ 52.21, 71.6(a)(3) and (c)(1), and 55.8]

6.5 General Stack T est Requirements

6.5.1 Within 12 months prior and no more than 3 months after the start of drilling under this permit, the eight mai n engines (DR

- ME

- 01 through DR

- ME

- 08 ) of the BlackHawk shall have been stack tested under the requirements Condition 5.25.

6.5.1.1 If, after the initial stack tests, the drilling vessel discontinues drilling

under the permit for more than 12 months, the permittee shall certify that a continuous maintenance program has been conducted and that no physical changes that could impact emissions have occurred since the latest stack test, or the permittee shall conduct a new stack test prior to restarting drilling operations in accordance with the general stack testing requirements set forth in Condition 5.25 and Conditions
6. 5 .2 through 6. 5 .6.

6.5.1.2 If a continuous maintenance program is selected from the options in

Condition 6. 5 .1.1 , the certification shall be included with the drill site notification required pursuant to Condition 6.1. Maintenance records shall be kept in accordance with the recordk eeping requirements set forth in Condition 5.16

6.5.2 Each stack test shall be conducted according to an EPA

- approved source test plan set forth in Condition 5.25.

6.5.3 Each stack test shall be conducted at three different loads spanning the expected range of operations.

6.5.4 At a minimum, each stack test shall test for emissions of CO, CO 2 , NO X , PM 2.5 /
PM 10 , VOC, and visible emissions.

6.5.5 During each test run, the permittee shall monitor and record the electrical power produce d (in kW

- hr).24

Anadarko BlackHawk OCS

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- R4019 11/14/2014 6.5.6 For each engine, each lo ad, and each pollutant (CO, CO 2 , NO X , PM, PM 2.5 , PM 10 , VOC), the permittee shall determine emission rates in g/kW

- hr or lb/hr . Pollutant test data obtained in accordance with Condition 6

. 5 or fuel usage monitoring data may be used to calculate CO 2 and PM.
[40 CFR §§ 52.21 and 71.6(a)(1), (a)(3) and (c)(1)]

6.6 BlackHawk Emission and Operating Limits

6.6.1 Source Identification: DR

- ME

- 01 through

- 08 ( main propulsion generator engines )

.

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 NO X BACT Limit DR

- ME

- 01 through DR

- ME

- 08

Operating at 50% Load and Above: 10. 57 g/kw

- hr on a rolling 24

- hour average basis.

6.6.1.1.2 NO X BACT Limit DR

- ME

- 01 through D R

- ME

- 06

Operating Below 50% L oad: 57.3 lb/hr on a rolling 24

- hour average basis.

6.6.1.1.3 NO X BACT Limit DR

- MR

- 07 and DR

- ME

- 08 Operating

Below 50% L oad : 103.5 lb/hr on a rolling 24

- hour average basis.

6.6.1.1.4 CO Limit DR

- ME

- 01 through DR

- ME

- 08 Operating at

50% Load and Above : 2.8 g/kw

- hr on a rolling 24

- hour average basis

.

6.6.1.1.5 CO BACT Limit D R

- ME

- 01 through DR

- ME

- 06 Operating

Below 50% Load : 16.6 lb/hr on a rolling 24

- hour average basis.

6.6.1.1.6 CO BACT Limit D R

- ME

- 07 through DR

- ME

- 08 Operating

Below 50% Load : 23 .3 lb/hr on a rolling 24

- hour average basis

.

6.6.1.1.7 VOC BACT Limit D R

- ME

- 01 through DR

- ME

- 08

Operating at 50% Load and Above : 0.8 g/kw

- hr on a rolling 24

- hour average basis.25

Anadarko BlackHawk OCS

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- R4019 11/14/2014 6.6.1.1.8 VOC BACT Limit D R

- ME

- 01 through DR

- ME

- 06

Operating Below 50% L oad : 4.6 lb/hr on a rolling 24

- hour average basis.

6.6.1.1.9 VOC BACT Limit DR

- MR

- 07 and DR

- ME

- 08 Operating

Below 50% L oad : 6.2 lb/hr on a rolling 24

- hour average basis.

6.6.1.1.10 PM / PM 10 / PM 2.5 BACT Limit D R

- ME

- 01 through DR

- ME

08 Operating at 50 % Load and Above : 0.4 0 g/kW

- hr on a rolling 24

- hour average basis.

6.6.1.1.11 PM / PM 10 / PM 2.5 BACT Limit DR

- ME

- 01 through DR

- ME

06 Operating Below 50% L oad : 2.0 lb/hr on a rolling 24

- hour average basis.

6.6.1.1.12 PM /PM 10 /PM 2.5 BACT Limit DR

- ME

- 07 through DR

- ME

08 Operating Below 50% Load: 4.0 lb /hr on a rolling 24

- hour average basis.

6.6.1.1.13 GHG BACT Limit D R

- ME

- 01 through DR

- ME

- 08

Operating at 50% Load and Above: 856 g /kw

- hr on a rolling 24

- hour average basis.

6.6.1.1.14 GHG BACT Limit DR

- ME

- 01 through DR

- ME

- 06

Operating Below 50% L oad : 4

, 700 lb/hr on a rolling 24

- hour average basis.

6.6.1.1.15 GHG BACT Limit DR

- MR

- 07 and DR

- ME

- 08 Operating

Be low 50% L oad : 8

, 299 lb/hr on a rolling 24

- hour average basis.

6.6.1.2 The permittee shall use the following BACT work practice standards :

6.6.1.2.1 main propulsion generator engines with LNE design

,

including: turbocharger, aftercooler, and high injection

pressure;

6.6.1.2.2 diesel fuel with sulfur content less than or equal to 15 ppm

by weight;

6.6.1.2.3 engines certified to IMO Tier II (or higher tier

classification) ;26

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- R4019 11/14/2014 6.6.1.2.4 good combustion practices based on the most recent

manufacturer’s specifications issued for th ese engine s at the time that the engine s are operating under this permit; and

6.6.1.2.5 a parametric emissions monitoring system (PEMS ) as

defined in the permit application received by EPA and found in the administrative record to be used in conjunction with an enhanced monitoring, maintenance

, and load management system

.

6.6.1.2.6 A PEMS equivalent to the one identified in the application

may be used with prior written EPA approval.

6.6.1.2.7 The permittee will develop and implement an enhanced

monitoring

, maintenance and load management protocol that will ensure good combustion practices and manage load levels to ensure combustion efficiency.

6.6.1.2.8 The permittee shall submit the enhanced monitoring

,

maintenance

, and load management system protocol wit h the annual compliance report as required in Condition 5.20.

6.6.1.3 Monitoring and Recordkeeping:

6.6.1.3.1 The permittee shall monitor and record NO X , CO, and CO 2

emissions from the main generator diesel units specified in Condition 6.6.1 by using the parametric emissions monitoring system (PEMS) provided in Anadarko’s application or a parametric monitoring system equivalent to PEMS with EPA approval. The permittee may use a parametric monitoring system equivalent to PEMS only upon prior written approval by EPA.

6.6.1.3.1.1 The permittee shall monitor and record the

following parameters once an hour:

 Generator Load in kW e and kW m ; and

 NO x , CO, and O 2 (ppm)

.

6.6.1.3.1.2 The permittee shall determine the stack flow rate

using the method in Conditions 6.6.1.3.2.3 and 6.6.1.3.2.4

.27

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- R4019 11/14/2014 6.6.1.3.1.3 The permittee shall record the date and time of the

most recent parametric monitoring system calibration, the calibration results from the parametric emissions monitoring system, and the calibration method used.

6.6.1.3.1.4 The permittee shall determine the average emission

rate of the monitored air pollutant and express in the units of the applicable emissions limit (g/kW

- hr or lb/hr ) for each engine from the emission rat e results in each rolling 24

- hour average basis period.

6.6.1.3.1.5 For any unrecorded NO x , CO, or CO 2 concentration

data of the PEMS :

6.6.1.3.1.5.1 the permittee shall substitute the previously

monitored concent ration for the same engine load , or

6.6.1.3.1.5.2 when NO x , CO, or CO 2 concentration data is

unrecorded, or the monitor is not performing to manufacturer specifications, for more than 48

- continuous hours, the permittee may submit a written request to the EPA asking the EPA to authorize the permittee to use stack test data in accordance with Condition 5.25, 6.5, and 6.6.1.3.2.1 through 6.6.3.2.5 for NO X , CO, and /or CO 2 emissions. If the permittee elects to make such a request, the permittee shall make the request within 72

- hours of the beginning of the collection period of con cern. The permittee may use stack test data onl y upon EPA’s written approval. The use of stack test data relieves the permittee of the obligation to comply with Condition 6.6.1.3.1.5.1 for the missing data replaced by the stack test data

.

6.6.1.3.2 The permittee sha ll monitor and record VOC and

PM/PM 10 /PM 2.5 emissions from diesel engines specified in Condition 6.6.1 by collecting stack testing data according to an EPA approved protocol and in accordance with Conditions 5.25

, 6.5

, and 6.6.1.3.2.1 through 6.6.1.3.2 .5.28

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- R4019 11/14/2014 6.6.1.3.2.1 Each stack test shall be conducted at three different

loads spanning the expected range of operations.

6.6.1.3.2.2 During each test run, the permittee shall monitor

and record the e lectrical power produced (in kW

hr).

6.6.1.3.2.3 The permittee shall prepare a graph of engine load

versus emission rates expressed in the units of the applicable emissions limit, such as g/kW

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

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

- axis from the minimum load point tested.

6.6.1.3.2.4 The permittee shall use the load information with

the graph of engine load versus emission rates to determine the emission rate for each engine load recorded. Linear interpolation shall be used to determine the emission rate when the actual load falls between two tested load poi nts, the permittee shall use linear interpolation between the two load points to determine the emission rate. When the engine load exceeds the maximum load measured during the stack testing, the g/kW

- hr emission rate obtained for the highest load point tes ted during the most recent stack test may be used. When records of engine load are not available, the highest g/kW

hr emission rate calculated for all the load points tested during the most recent stack test may be substituted. The average emission rate fo r each hour of operation from all individual emission rate results recorded during the hour will then be calculated

.

6.6.1.3.2.5 The permittee shall determine the average emission

rate for each unit from the hourly emission rate results on a rolling 24

- hour average ba sis

.

6.6.1.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.1 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.29

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- R4019 11/14/2014 6.6.2 Source Identification: DR

- GE

- 01 ( eme rgency generator engine )

.

6.6.2.1 The permittee shall use the following BACT work practice standards:

6.6.2.1.1 an emergency diesel engine with LNE design

, including:

turbocharger, aftercooler, and high injection pressure;

6.6.2.1.2 diesel fuel with sulfur content less than or equal to 15 ppm

by weight, and

6.6.2.1.3 an engine certified to IMO Tier II ( or higher tier

classification ); and

6.6.2.1.4 good combustion practices based the most recent

manufacturer’s specifications issued for this engine at the time that the engine is operating under this permit

.

6.6.2.2 Operating Limit: This unit shall be operated no more than 100 hours

per year of non

- emergency, planned operation time on a 12

- month rolling total basis.

6.6.2.3 The permittee shall maintain a record of hours of operation and sum

such hours on a rolling 12

- month basis. Hours of operation shall be recorded monthly from a non

- resettable hour meter or, if such a meter is not available, by monitoring and maintaining a contemporaneous record of the following information:

6.6.2.3.1 unit ID; 6.6.2.3.2 engine tier certification; 6.6.2.3.3 date/time engine started; 6.6.2.3.4 date/time engine shut down; 6.6.2.3.5 name of person operating equipment (printed); and 6.6.2.3.6 signature of person operating equ ipment.

6.6.2.1 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.2 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.3 Source Identification: DR

- AC

- 01 ( emergency air compressor engine )

.

6.6.3.1 The permittee shall use the following BACT work practice standards:30

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- R4019 11/14/2014 6.6.3.1.1 an engine certified to EPA Tier 3 Nonroad (40 CFR §

1039 ) ( or higher tier classification ) ;

6.6.3.1.2 diesel fuel with sulfur content less than or equal to 15 ppm

by weight, and

6.6.3.1.3 good combustion practices based on the most recent

manufacturer’s specifications issued for this engine at the time that the engine is operating under this permit

.

6.6.3.2 Operating Limit: This unit shall be operated no more than 100 hours

per ye ar on a 12

- month rolling total basis.

6.6.3.3 The permittee shall maintain a record of hours of operation and sum

such hours on a rolling 12

- month basis. Hours of operation shall be recorded monthly from a non

- resettable hour meter or, if such a meter is not ava ilable, by monitoring and maintaining a contemporaneous record of the following information:

6.6.3.3.1 unit ID; 6.6.3.3.2 engine tier certification; 6.6.3.3.3 date/time engine started; 6.6.3.3.4 date/time engine shut down; 6.6.3.3.5 name of person operating equipment (printed); and 6.6.3.3.6 signature of person operating equipment.

6.6.3.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.3 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.4 Source Identification : DR

- LB

- 01 through DR

- LB

- 06 ( life boat emergency engines )

.

6.6.4.1 The permittee shall use the following work practice standards:

6.6.4.1.1 diesel fuel with sulfur content less than or equal to 15 ppm

by weight ; and

6.6.4.1.2 good combustion practices based on the most recent

manufacturer’s specifications issued for th ese engine s at the time that the engine s are operating under this permit

.

6.6.4.2 Operating Limit: These units shall be operated no more than 100 hours

per year each on a 12

- month rolling total basis.31

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6.6.4.3 T he permittee shall maintain a record of hours of operation for each

engine and a record of the sum of such hours for each engine on a rolling 12

- month basis. Hours of operation shall be recorded monthly from a non

- resettable hour meter or, if such a meter is not available, by monitoring and maintaining a contemporaneous record of the following information:

6.6.4.3.1 unit ID; 6.6.4.3.2 date/time engine started; 6.6.4.3.3 date/time engine shut down; 6.6.4.3.4 name of person operating equipment (printed); and 6.6.4.3.5 signature of person operating equipment

.

6.6.4.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.4 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.5 Source Identification: DR

- FR

- 01 ( fast re scue craft engine )

.

6.6.5.1 The permittee shall use the following work practice standards:

6.6.5.1.1 diesel fuel with sulfur content less than or equal to 15 ppm

by weight ; and

6.6.5.1.2 good combustion practices based on the most recent

manufacturer’s specifications issued for this engine at the time that the engine is operating under this permit

.

6.6.5.2 Operating Limit: This unit shall be operated no more than 100 hours

per year on a 12

- month rolling total basis.

6.6.5.3 The permitte e shall maintain a record of hours of operation and sum

such hours on a rolling 12

- month basis. Hours of operation shall be recorded monthly from a non

- resettable hour meter or, if such a meter is not available, by monitoring and maintaining a contemporane ous record of the following information:

6.6.5.3.1 unit ID; 6.6.5.3.2 date/time engine started; 6.6.5.3.3 date/time engine shut down; 6.6.5.3.4 name of person operating equipment (printed); and 6.6.5.3.5 signature of person operating equipment.32

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6.6.5.4 All information required to be collected, recorded, or maint ained

pursuant to Condition 6.6.5 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.6 Source Identific ation: DR

- DC

- 01 through DR

- DC

- 04 ( mud and cement mixing, equipped with dust collectors )

.

6.6.6.1 The permittee shall use the following BACT work practice standard :

proper maintenance and operation of the dust collectors in accordance with the most recent manufacturer ’s specifications at the time that the se dust collectors are operating under this permit

.

6.6.6.2 The permittee shall ensure that the dust collector bin for each dust

collector is not over capacity, and report any times where there is a high

- level alarm, at which time the operator will investigate the cause and take correc tive actions. For each high alarm event, the permittee shall record the following:

6.6.6.2.1 unit ID; 6.6.6.2.2 date/time of alarm; 6.6.6.2.3 corrective action taken, if any; 6.6.6.2.4 name of person operating equipment (printed); and 6.6.6.2.5 signature of person operating equipment.

6.6.6.3 All information req uired to be collected, recorded, or maintained

pursuant to Condition 6.6.6 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.7 Source Identification: DR

- VG

- 01 through DR

- VG

- 0 4 ( mud degasser s )

.

6.6.7.1 The permittee shall not discharge or cause the discharge of emissions

into the atmosphere from the mud degassers in excess of:

6.6.7.1.1 V OC BACT Limit: 5.36 tons per year combined on a 12

-

month rolling total basis.

6.6.7.1.2 GHG BACT Limit: 271 tons per year CO 2 e combined on a

12

- month rolling total basis.

6.6.7.2 The permittee shall use the following BACT work practice standard :

proper maintenance and operation of the mud degassing operations units in accordance with the most recent manufacturer ’s specifications at the time that these degassers are operating under this permit

.33

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6.6.7.3 The permittee shall monitor and record the daily throughput of the

synthetic based mud through each degassing unit

.

6.6.7.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.7 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.8 Source Identification: DR

- TP

- 01 through DR

- TP

- 11 and DR

- TP

- 17 through DR

TP

- 21 ( third

- party engine s)

.

6.6.8.1 The permittee shall use the following BACT work practice standards:

6.6.8.1.1 engines to certified EPA Tier 2 Nonroad (40 CFR § 89) ( or

higher tier classification ) ;

6.6.8.1.2 diesel fuel with sulfur content less than or equal to 15 ppm

by weight; and

6.6.8.1.3 good combustion practices based on the most recent

manufacturer’s specifications issued for th ese engine s at the time that the se engine s are operating under this permit

.

6.6.8.2 Operating Limit: DR

- TP

- 01 and DR

- TP

- 02 shal l be operated no more

than 4,800 hours per year each on a 12

- month rolling t otal basi s , and each engine ’s horsepower rating shall be less than or equal to 860

.

6.6.8.3 Operating Limit: DR

- TP

- 03 through DR

- TP

- 1 1 shall be operated no

more than the following 4,800 hours per year each on a 12

- month rolling total basis , and each engine’s horsepower rating shall be less than or equal to 300

.

6.6.8.4 Operating Limit: DR

- TP

- 17 through DR

- TP

- 21 shall be operated no

more than the following 4,800 hours per year each on a 12

- month rolling total basis , and each engine’s horsepower rating shall be less than or equal to 126

.

6.6.8.5 The permittee shall maintain a record of hours of operation for each

engine and a record of the sum of such hours for each engine on a rolling 12

- month basis. Hours of operation shall be recorded monthly from a non

- resettable hour m eter or, if such a meter is not available, by monitoring and maintaining a contemporaneous record of the following information:34

Anadarko BlackHawk OCS

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- R4019 11/14/2014 6.6.8.5.1 unit ID; 6.6.8.5.2 engine tier certification; 6.6.8.5.3 date/time engine started; 6.6.8.5.4 date/time engine shut down; 6.6.8.5.5 name of person operating equipment (printed); and 6.6.8.5.6 signature of person operating equipment.

6.6.8.6 The permittee shall provide the following information for each engine

used:

6.6.8.6.1 e ngine tier certificate ; and

6.6.8.6.2 e ngine description including make, model year, and

horsepower rating.

6.6.8.7 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.8 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.9 Source Identification: DR

- TP

- 12 through DR

- TP

- 16 ( third

- party well evaluation engines rated at less than or equal to 140 hp )

.

6.6.9.1 The permittee shall use the following BACT work practice standards:

6.6.9.1.1 diesel fuel with sulfur content less than or equal to 15 ppm

by weight; and

6.6.9.1.2 good combustion practices based on the most recent

manufacturer’s specifications issued for th ese engine s at the time that the se engine s are operating under this permit

.

6.6.9.2 Operating Limit: DR

- TP

- 12 through DR

- TP

- 16 shall be operated no

more than 125 hours per year each on a 12

- month rolling total basis and each engine’s horsepower rating shall be less than or equal to 140

.

6.6.9.3 The permittee shall maintain a record of hours of operation and sum

such hours on a rolling 12

- month basis.

6.6.9.4 The permittee shall maintain a record of hours of operation f or each engine and a record of the sum of such hours for each engine on a rolling 12

- month basis. Hours of operation shall be recorded monthly from a non

- resettable hour meter or, if such a meter is not available, by monitoring and maintaining a contempora neous record of the following information:35

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- R4019 11/14/2014 6.6.9.4.1 unit ID; 6.6.9.4.2 date/time engine started; 6.6.9.4.3 date/time engine shut down; 6.6.9.4.4 name of person operating equipment (printed); and 6.6.9.4.5 signature of person operating equipment.

6.6.9.5 For each engine used, the permittee shall record an engine description

including make, model year, and horsepower rating.

6.6.9.6 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.9 shall be submitted to EPA by the permittee in accordance with the reporting specifications detaile d in Condition 5.17.

6.6.10 Source Identification: DR

- TP

- 22 ( third party flowback boiler )

.

6.6.10.1 The permittee shall use the following BACT work practice standards:

6.6.10.1.1 diesel fuel with sulfur content less than or equal to 15 ppm

by weight; and

6.6.10.1.2 good combustion practices based on the most recent

manufacturer’s specifications issued for this boiler at the time that the boiler is operating under this permit

.

6.6.10.2 Operating Limit: This unit shal l be operated no more than 144 hours

per year on a 12

- month rolling total basis.

6.6.10.3 The permittee shall maintain a record of hours of operation and sum

such hours on a rolling 12

- month basis. Hours of operation shall be recorded monthly by monitoring and maintaining a contemporaneous record of the following informati on:

6.6.10.3.1 unit ID and description ; 6.6.10.3.2 unit rating; 6.6.10.3.3 date/time boiler started; 6.6.10.3.4 date/time boiler shut down; 6.6.10.3.5 name of person operating equipment (printed); and 6.6.10.3.6 signature of person operating equipment.

6.6.10.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.10 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.36

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- R4019 11/14/2014 6.6.11 Source Identification: DR

- TP

- 23 ( boom flare )

.

6.6.11.1 The permittee shall use the following BACT work practice sta ndards:

6.6.11.1.1 m aintain compliance with 40 CFR 60.18;

6.6.11.1.2 good combustion practices ; and

6.6.11.1.3 proper flare maintenance

.

6.6.11.2 Operating Limit: This unit will have a throughput of no more than 360

MMscf per year on a 12

- month rolling total basis.

6.6.11.3 The permittee shall monito r and maintain a record of the following:

6.6.11.3.1 date/duration of each flaring episode; 6.6.11.3.2 type of fuel burned; and 6.6.11.3.3 amount of gas flared in MMscf and the sum of such MMscf

on a rolling 12

- month basis.

6.6.11.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.11 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.12 Source Identification: DR

- PO

- 01 ( painting operations )

.

6.6.12.1 The permittee shall use the following BA CT work practice standards:

6.6.12.1.1 best management practices

, includ ing but are not limited to:

down spraying of paint

, use of a containment system such as a shroud or a barrier around the section of the ship being painted whenever practical to prevent the airbor ne particulate matter from drifting into the atmosphere, and proper storage of coatings and thinners in non

- leaking containers; and

6.6.12.1.2 use of an airless spray gun with transfer efficiency of 50%

or greater; where it is not practical to use an airless spray

g un, the permittee may use an air assisted spray gun with a transfer efficiency of 30% or greater.

6.6.12.2 Operating Limits: The permittee will use no more than 1 ,300 and

5,200 gallons per calendar year of thinner and primer, respectively

.37

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6.6.12.3 The permittee shall monitor and record the types and amounts (in

gallons) of coatings and thinners used in a calendar year . Also, the permittee shall keep material safety data sheet ( MSDS ) information on file for all coatings and thinners used on the drill ship

.

6.6.12.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.12 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.13 Source Identification: DR

- WO

- 01 ( welding operations )

.

6.6.13.1 The permittee shall use the following BACT work practice standard:

follow current manufacturer’s recommendations for all equipment used in welding operations at the time that that welding occurs under this permit , including but not li mited to, recommendations regarding voltage levels.

6.6.13.2 The permittee shall maintain an accurate account of the quantity (in

pounds) and type of welding rods used annually. This information may be obtained from delivery manifests or records maintained during use.

6.6.13.3 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.13 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.14 Source Identific ation: DR

- FT

- 01 t hrough DR

- FT

- 19 ( diesel and helicopter fuel storage tanks ) and DR

- TP

- 24 through DR

- TP

- 26 ( condensate tanks ).

6.6.14.1 The permittee shall not discharge or cause the discharge of emissions

into the atmosphere from the storage tanks combined in excess of:

6.6.14.1.1 VOC BACT Emission Lim it for DR

- FT

- 01 through DR

FT

- 19 : 0.69 tons per year on a 12

- month rolling total basis.

6.6.14.2 The permittee shall not discharge or cause the discharge of emissions

into the atmosphere from the condensate tanks combined in excess of:

6.6.14.2.1 VOC BACT Emissi on Limit for DR

- TP

- 24 through DR

TP

- 26: 9.65 tons per year on a 12

- month rolling total basis.38

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6.6.14.3 The permittee shall use the following BACT work practice standard:

use of good maintenance practices.

6.6.14.4 The permittee shall use EPA’s TANKS 4.0.9d program to calculate

emissions

.

6.6.14.5 The permittee shall monitor and maintain the following information:

6.6.14.5.1 unit ID; and

6.6.14.5.2 the dimensions, fuel type or condensate stored, and

capacities of units DR

- FT

- 01 through DR

- FT

- 19 and DR

TP

- 24 through DR

- TP

- 26.

6.6.14.6 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.14 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

6.6.15 Source Identification: DR

- FE

- 01 ( drillship fugitive emissions ).

6.6.15.1 The permittee shall use the following BACT work practice standard:

good maintena nce practices to minimize fugitive emissions

, including but not limited to

, minimizing the release of emissions from valves, pump seals, and connectors from the fuel and mud pu mping systems

.

6.6.15.2 Compliance will be assured by performing a daily check to ensure that

there are no leaks. Upon detection of a leak, the permittee shall maintain and record the following information:

6.6.15.2.1 date/duration of leak detection from valves , pump seals,

a nd connectors ; 6.6.15.2.2 type of component; 6.6.15.2.3 method of detection; 6.6.15.2.4 corrective action taken; 6.6.15.2.5 date of component reinspection; 6.6.15.2.6 name of person inspecting equipment (printed); and 6.6.15.2.7 signature of person inspecting equipment.

6.6.15.3 All information required to be collected, recorde d, or maintained

pursuant to Condition 6.6.15 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.39

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- R4019 11/14/2014 6.6.16 Fuel Use Limit.

6.6.16.1 Operating Limit: The Bl a ckHawk shall not use more than 112 cubic

meters per day of diesel fuel, not to exceed 18,438 cubic meters of diesel fuel on a rolling 12

- month total basis

.

6.6.16.2 The permittee shall maintain a record of fuel consumption for the

duration of the project on a rolling 12

- month basis

.

6.6.16.3 The permittee shall monitor and maintain a record of the following

information:

6.6.16.3.1 initial cubic meters of diesel fuel on the OCS source at the

beginning of the project; 6.6.16.3.2 date of each diesel fuel delivery; 6.6.16.3.3 cubic meters of diesel fuel in each delivery; 6.6.16.3.4 name of person record ing delivery (printed); 6.6.16.3.5 signature of recorder; and 6.6.16.3.6 final cubic meters of diesel fuel on the OCS source at the

end of the project.

6.6.16.4 All information required to be collected, recorded, or maintained

pursuant to Condition 6.6.16 shall be submitted to EPA by th e permittee in accordance with the reporting specifications detailed in Condition 5.17.

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

6.7 Support Vessel Operating Limits

6.7.1 Any combination of supply boat ( HOS Coral or substitute )

, anchor handling bo at ( Kirt Chouest or substitute), Tug, Barge, or Well Evaluation Vessel (with equivalent or lower potential emissions to the vessels used in the application ) shall not use more than :

6.7.1.1 200 barrels of diesel fuel per day when within 25 miles of the drilling

vessel.

6.7.1.2 4 0,00 0 barrels of diesel fuel per year when within 25 miles of the

drilling vessel.

6.7.2 T he support vessels shall not combust any diesel fuel with sulfur content greater than 15 ppm by weight.

6.7.3 The permittee shall monitor and maintain a contemporaneous record of the following information:40

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6.7.3.1 name of vessel; 6.7.3.2 units onboard the vessel, with short description and applicable ratings

of each unit; 6.7.3.3 date/time entering the 25 nautical mile radius; 6.7.3.4 date/time exiting the 25 nau tical mile radius; 6.7.3.5 sulfur content of all fuel used in any engine as specified in Condition

6.4; 6.7.3.6 barrels of diesel fuel on the vessel entering the 25 nautical mile radius; 6.7.3.7 barrels of diesel fuel on the vessel exiting the 25 nautical mile radius;

and 6.7.3.8 barrel s of diesel fuel loaded on to the vessel for each 24

- hour period

within the 25 nautical mile radius.

6.7.4 All information required to be collected, recorded, or main tained pursuant to Condition 6.7 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

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

6.8 Stimulation Vessel Emission Limits

6.8.1 Source Identification: SV

- PE

- 01 through SV

- PE

- 08 ( stimulation vessel pump engines )

.

6.8.1.1 The permittee shall use the followin g BACT work practice standards:

6.8.1.1.1 diesel fuel with sulfur content less than or equal to 15 ppm

by weigh; and

6.8.1.1.2 good combustion practices based on the most recent

manufacturer’s specifications issued for this engine at the time that the engine is operating under this permit

.

6.8.1.2 Operating Limit: SV

- PE

- 01 through SV

- PE

- 08 shal l be operated no

more than 4,032 hours per year combined on a 12

- month rolling total basis.

6.8.1.3 The permittee shall maintain a record of hours of operation for each

engine and a record of the sum of such hours for each engine on a rolling 12

- month basis. Hours of operation shall be recorded monthly from a non

- resettable hour meter or, if such a meter is not available, by monitoring and maintaining a contemporaneous record of the following information:

6.8.1.3.1 unit ID; 6.8.1.3.2 date/time engine started;41

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- R4019 11/14/2014 6.8.1.3.3 date/time engine shut down; 6.8.1.3.4 name of person operating equipment (printed); and 6.8.1.3.5 signature of person operating equipment.

6.8.2 For each engine used, the permittee shall record an engine description including make, model year, and horsepower rating.

6.8.3 All information required to be collected, recorded, or main tained pursuant to Condition 6.8 shall be submitted to EPA by the permittee in accordance with the reporting specifications detailed in Condition 5.17.

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

6.9 Supply Boat Emission Limits

6.9.1 Source Identification: SB

- DT

- 01 through SB

- DT

- 1 5 ( supply boat storage tanks )

.

6.9.1.1 The permittee shall not discharge or cause the discharge of emissions

into the atmosphere from the storage tanks combined in excess of:

6.9.1.1.1 VOC BACT Emission Limit: 0. 0 11 tons per year on a 12

-

month rolling total basis.

6.9.1.2 The permittee shall use the following BACT work practice standard:

use of good maintenance practices.

6.9.1.3 The permittee shall use EPA’s TANKS 4.0.9d program to calculate

emissions.

6.9.1.4 The permittee shall monitor and maintain the following information:

6.9.1.4.1 Unit ID; and

6.9.1.4.2 The dime nsions, fuel type , and capacities of units SB

- DT

01 through SB

- DT

- 15.

6.9.2 All information required to be collected, recorded, or main tained pursuant to Condition 6.9 shall be submitted to EPA by the permittee in accordance with the reporting specific ations detailed in Condition 5.17.

[40 CFR §§ 52.21, 55.2, 55.6(a)(4), 55.8, and 71.6(a)(1), (a)(3) and (c)(1)]42

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- R4019 11/14/2014 6.10 Anchor Handling Boat Emission Limits

6.10.1 Source Identification: AB

- DT

- 01 through AB

- DT

- 19 ( anchor handling boat diesel storage tanks )

.

6.10.1.1 The per mittee shall not discharge or cause the discharge of emissions

into the atmosphere from the storage tanks combined in excess of:

6.10.1.1.1 VOC BACT Emission Limit: 0.10 tons per year on a 12

-

month rolling total basis.

6.10.1.2 The permittee shall use the following BACT work practice standard:

use of good maintenance practices.

6.10.1.3 The permittee shall use EPA’s TANKS 4.0.9d program to calculate

emissions for the semi

- annual report.

6.10.1.4 The permittee shall monitor and maintain the following information:

6.10.1.4.1 Unit ID; and

6.10.1.4.2 The dim ensions , fuel type , and capacities of units AB

- DT

01 through AB

- DT

- 19.

6.10.2 All information required to be collected, recorded, or main tained pursuant to Condition 6.10 shall be submitted to EPA by the permittee in accordance with the reporting specifications detail ed in Condition 5.17.

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

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

6.11.1 The drillship main engines (DR

- M E

- 01 through DR

- M E

- 08 ) , the emergency air compressor engine (DR

- AC

- 01), and the third party engines (DR

- TP

- 01 through
DR

- TP

- 11 and DR

- TP

- 17 through DR

- TP

- 21) are subject to 40 CFR part 60, subpart IIII based on engine size, per cylinder displacement, and model year. The permittee shall demonstrate compliance with the applicable requirements for these engines through the following:

6.11.1.1 The permittee shall maintain documentation in accordance with

Condition 5.16 that eng ines specified in Condition 6.11 .1 were install ed and configured according to manufacturer’s specifications.43

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6.11.1.2 The permittee shall maintain records in accordance with Condition

5.16 of manufacturer data indicating compliance with EPA Tier standards, if applicable, to the engine.

6.11.1.3 The permittee shall op erate 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

m anufacturer. 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.

6.11.1.4 The permitted engines shall not combust any diesel fuel that does not

meet the requirements of Condition 6.4.

6.11.2 The emergency generator (DR

- GE

- 01) is subject to 40 CFR part 60, subpart IIII based on the per

- cylinder displacement and model year. The permittee has been granted a technical exemption pursuant to 40 CFR § 55.7 from the emission standard certification requirement of 40 CFR 60, subpart IIII and must comply with the following:

6.11.2.1 The permittee shall demonstrate compliance with alternate emiss ions

standards as specified in Conditi on 6.6.2

.

6.11.2.2 The permittee shall comply with requirements defined in Conditions

6.1 1.1.1 through 6.11 .1.4.

6.11.3 Based on engine model years and engine use (summarized in Tables 1 and 2 of Section 4), the drillship main engines, the emergency generator, the emergency air compressor, and the third party engines are subject to and shall comply with the applicable requirements of 40 CFR part 63, subpart ZZZZ. The permittee shall demonstrate compliance with subpart ZZZZ for e ach engine by demonstrating compliance with the applicable requirements of 40 CFR part 60, subpart IIII and Conditions 6. 11.1.1 through 6.11 .1.4

.

6.11.4 Based on engine model years and engine use (summarized in Tables 1 and 2 of Section 4) the well evaluation engines and the stimulation vessel pump engines ( DR

- TP

- 16 through DR

- TP

- 21 and SV

- PE

- 01 through SV

- PE

- 08) are subject to and shall comply with the applicable requirements of 40 CFR part 63, subpart
ZZZZ.44

Anadarko BlackHawk OCS

- EPA

- R4019 11/14/2014

6.11.4.1 Existing stationary engines with a site rating of m ore than 300 hp

located at an area source of HAP emissions on the OCS must comply with the applicable requirements in 40 CFR § 63.6603(c) and Table 2d in subpart ZZZZ in accordance with the compliance schedule requirements of Condition 5.21

.

6.11.4.2 Existing stationary engines with a site rating less than 300 hp located

at an area source of HAP emissions must comply with the applicable requirements in Table 2d in subpart ZZZZ in accordance with the compliance schedule requirements of Condition 5.21

.

6.11.4.3 Complianc e with any applicable numerical emission limitation

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.

6.11.4.4 Compliance with Condition 6. 11 shall be determined based upon

recordkeeping required by Condition 5. 16

. [40 CFR part 63, subpart ZZZZ and 55.8]

6.11.5 Any new, modified, or reconstructed engine shall comply with all applicable NESHAP and NSPS, including but not limited to 40 CFR part 60, subpart IIII and 40 CFR part 63, subpart ZZZZ, or obtain a technical exemption under 40 CFR § 55.7.

6.11.6 The permittee shall notify EPA prior to use of any new, modified, or reconstructed engine intended to be used on the drilling vessel or in replacement of an engine in Tables 1 and 2 of Section 4 of this permit, and shall submit to EPA a reevaluation of the applicability of pertinent NESHAP and NSPS regulations, as well as copies of the manufacturer engine certification to EPA standards.

6.11.7 The permittee shall maintain records in accordance with Condition 5.16 of the manufacturer engine certifications of all diesel units specified in Tables 1 and 2 of Section 4

.

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