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

Note: permit terms for OCS-EPA-R4019 are the same a s for OCS-EPA-R4020

.

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 

## 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-R4020

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 ref erence the Prevention of Significant Deterioration of Air Quality (PSD) regulations at 4 0 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 authorized to construct and operate air e missions units and to conduct other air pollutant emitting activities at an OCS source at m ultiple sites within the Eastern Gulf of Mexico. The drilling area is that area of the OCS l ocated east of longitude 87.5, west of the Military Mission Line (86°41’ west longitude), at l east 100 miles from the Louisiana shoreline,
and at least 125 miles from the Florida shoreline.

Upon commencing activities in the area identified a s the project location, this OCS source and support vessels shall be constructed and operated i n accordance with the terms and conditions set forth in this permit.

This permit is effective on: January 31 , 2015[insert effective date: 30 days after the dat e of the service of notice of the final permit decision unde r 40 CFR 124.15 and 71.11(i); or if no comments requested a change in the draft permit, th e 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 permit shall expire on: February 1 , 2020.[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 BlackHornet OCS-EPA-R4020 12/31/2014 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 implement ing OCS Air Regulations at 40 CFR part 55, which incorporate by reference the PSD regulati ons 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 Anadarko Petroleum Co rporation (Anadarko) dated September 5, 2013; supplemental submittals dated on September 18 , 2013, November 26, 2013, December 5, 2013, February 11, 2014, July 15, 2014, September 2 , 2014 and September 10, 2014, in the administrative record for this permit action; and u pon 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 Eas tern Gulf of Mexico. The drilling sites are located east of longitude 87.5°, west of the Milita ry Mission Line (86°41’ west longitude), at least 100 miles from the Louisiana shoreline, and a t least 125 miles from the Florida shoreline.

4 PROJECT DESCRIPTION

The proposed project will mobilize the BlackHornet drillship owned by Diamond Offshore Drilling Inc. and associated support vessels. The s upport vessels may include a combination of supply boats, anchor handling boats, tug boats, bar ges, stimulation vessels and well evaluation vessels. The proposed project will consist of three phases: the drilling phase, the well completion phase, and the production well maintenance phase. A nadarko will conduct drilling activities at multiple locations within the Eastern Gulf of Mexic o area described in Section 3, Project Location, of this permit. Emissions from production well maintenance activiti es related to facilities on the sea floor are subject to regulati on by this permit. This permit does not authorize the establishment of any permanent non-subsea produ ction 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 less 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 c riteria pollutants), as well as other regulated air polluta nts, including greenhouse gases (GHGs). VOC
and NO x are the measured precursors for the criteria pollu tant ozone, and NO x and SO 2 are3

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 measured precursors for PM 2.5 . Based on emissions estimates and applicable permi tting thresholds, the project is subject to the PSD and t itle V programs and has significant emissions of
NO X , CO, PM, PM 10 , PM 2.5 , VOC, and GHGs. In addition, the BlackHornet is an area source of hazardous air pollutants pursuant to 40 CFR 63 subp art ZZZZ.
The BlackHornet emission units are identified in Table 1. Additiona l units on the stimulation
vessel that will be used for OCS activities are lis ted in Table 2. Table 3 lists the representative support vessels.

Support vessels operating within 25 miles of the OC S source may include a combination of supply boats, anchor handling boats, tug boats, bar ges, stimulation vessels, and well evaluation vessels that run marine diesel engines.

The information provided in Tables 1 through 3 is f or description and identification purposes and does not establish operating limits.

Table 1 – BlackHornet 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 hpDR-VG-01 – 02 Mud degasser#1 and #2 Burgess MagnaVac – Model 1500 -

DR-VG-03 – 04 Mud degasser#3 and #4 Hampco DR-DC-01 – 03 Dust collectors #1 through #3 Nation al 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 Va rious-Tier II

Certified ≤ 300 hp Varies4

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 Va rious-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 drillsh ip as needed by a third party supplier. The specifi c engine used will meet an equivalent or a higher EPA Tier standard.

* Horsepower

Table 2 – Well Completion Stimulation Vessel Emissi on Units a

Emissions

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

SV-PE-01 – 08 Stimulation vessel pump engines Cater pillar 3512 DITA (or equivalent) 2,250

a The specific stimulation vessel used during the dri lling project may vary based on availability. The e ngine and vessel used during the project will be an equivalent or a higher EPA T ier 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 Ves sel, Well Evaluation Vessel

a Specific supply boats, anchor handling boats, and w ell completion vessels available for use during the project had not been identified at the time of application. The represen tative vessel is the worst-case vessel in the poten tial vessel fleet and used to calculate potential emissions.

5 GENERAL CONDITIONS

5.1 Compliance

5.1.1 The permittee shall comply with all requirements of 40 CFR part 71, 40 CFR § 52.21, 40 CFR part 55 and this permit. Failure to d o so shall be considered a violation of section 111(e) of the CAA. All enforce ment provisions of the CAA, including, but not limited to, the provisions of se ctions 113, 114, 120, 303 and 304 of the CAA, shall apply to the OCS source and p ermittee

. [40 CFR §§ 55.8, 55.9(a) and (b)]5

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.1.2 The permittee must comply with all conditions of th is permit. All terms and conditions of this permit are enforceable by EPA an d citizens under the CAA. Any permit noncompliance constitutes a violation of the CAA and is grounds for enforcement action; for permit termination, revocat ion and reissuance, or modification; or for denial of a permit renewal app lication.

[40 CFR §§ 55.8, 71.6(a)(6)(i)]

5.1.3 It shall not be a defense for a permittee in an enf orcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

[40 CFR § 71.6(a)(6)(ii)]

5.2 Permit Shield

Compliance with the terms and conditions of this pe rmit shall be deemed compliance with the applicable requirements that are included and are s pecifically 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 that section;

5.2.2 The liability of an owner or operator of a source f or any violation of applicable requirements prior to or at the time of permit issu ance; or

5.2.3 The ability of EPA to obtain information from a sou rce pursuant to CAA section
114.

[40 CFR § 71.6(f)(1)]

5.3 Other Credible Evidence

For the purpose of submitting compliance certificat ions in accordance with Condition 5.20 of this permit, or establishing whether or not a perso n 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 whethe r a source would have been in compliance with applicable requirements if the appropriate per formance or compliance test or procedure had been performed.

[CAA §§ 113(a) and (e)(1), 40 CFR §§ 60.11(g) and 6 1.12]6

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.4 Construction and Operation

5.4.1 As approved and conditioned by this permit, all con struction and operation, including equipment operations and maintenance of t he OCS source and support vessels shall be in accordance with the data, speci fications, drawings, exhibits, and assumptions included with the application and s upporting materials submitted by the permittee, which resulted in this permit (ap plication materials). This permit is valid only for the specific processes and operat ions applied for and indicated in the application materials. Any unauthorized deviati on from the application materials, or from any term or condition of this pe rmit may constitute grounds for revocation or enforcement action by EPA.

5.4.2 The permittee shall properly operate and maintain t he OCS source and support vessels, including all systems of treatment and con trol (and related appurtenances) that are installed and used by the permittee to ach ieve compliance with the terms and conditions of this permit. This provision inclu des the operation of backup or auxiliary facilities or similar systems when necess ary to minimize or prevent emissions in achieving compliance with the terms an d conditions of the permit.

[40 CFR § 52.21(r)(1)]

5.5 Compliance and Other Requirements

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

[40 CFR § 55.6(a)(4)(iii)]

5.6 Notification to Owners, Operators and Contractors

The permittee must notify all other owners or opera tors, 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 any subject emissions unit.

[40 CFR § 55.6(a)(4)(iv)]

5.7 Expiration of Approval to Construct and Permit Rene wal

5.7.1 This approval to construct shall become invalid if: construction is not commenced within 18 months after the effective date of this p ermit, 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 cam paigns are not considered to
be a discontinuation of construction.

[40 CFR § 52.21(r)(2)]7

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 d ate of expiration of this permit. If the permittee submits a timely and compl ete renewal application, and EPA does not take final action on the renewal appli cation before the end of the term of this permit, the permittee’s failure to hav e a permit is not a violation of 40 CFR part 71 until the permitting authority takes fi nal action on the renewal application. Such protection will cease to apply if , subsequent to EPA’s determination that the renewal application is compl ete, the permittee fails to submit by the deadline specified in writing by EPA any additional information identified as being needed to process the applicati on. This condition does not supersede the limitation on the permittee’s authori ty 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 perm it 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 be fore the expiration of this permit, then all the terms and conditions of this p ermit, including any permit shield granted pursuant to 40 CFR § 71.6(f), shall remain in effect until EPA takes final action on the renewal application.

[40 CFR §§ 71.7(c)(3) and 71.7(b)]

5.7.5 Renewal of this permit is subject to the same proce dural requirements that apply to initial permit issuance, including those for pub lic participation 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 duri ng the permit term and were not incorporated into the permit during the permit term, any applicable requirements that were promulgated and not incorpor ated into the permit during the permit term, and other information required by the application form.

[40 CFR §§ 71.5(a)(2) and 71.5(c)(5)]

5.8 Property Rights

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

[40 CFR §71.6(a)(6)(iv)]8

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.9 Inspections

The permittee, by accepting this permit, specifical ly 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 a ctivity 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 ke pt under the conditions of the permit, including but not limited to, information r elating to the OCS source, support vessels, monitoring data, or compliance or noncompliance with the permit;

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

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

Reasonable times may depend on the nature of the co ncern being investigated.

[40 CFR §§ 71.6(c)(2) and 55.8]

5.10 Emergency Provisions

In addition to any emergency or upset provision con tained in any applicable requirement, the permittee may seek to establish that noncompliance with a technology-based emission limitation under this permit was due to an emergency. An emerg ency constitutes an affirmative defense to an action brought for noncompliance with such techn ology-based emissions limitation. The permittee shall demonstrate the affirmative defense of emergency through properly signed, contemporaneous operating logs, or other relevant e vidence that:

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

emergency;

5.10.2 The permitted facility was at the time being proper ly operated;

5.10.3 During the period of the emergency, the permittee t ook all reasonable steps to
minimize levels of emissions that exceeded the emis sions 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 exc eeded due to the emergency. This notice must contain a description of the emerg ency, any steps taken to mitigate emissions, and corrective actions taken. T his notice fulfills the requirements of Condition 5.17.2 of this permit con cerning prompt notification of
deviations.9

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 [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 attemp ting to establish the occurrence of an emergency has the burden of proof. [40 CFR § 71.6(g)(4)]

5.12 Emergency Defined

An “emergency” means any situation arising from sud den 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 technologybased emission limitation under the permit due to u navoidable increases in emissions attributable to the emergency. An emergency shall not include no ncompliance to the extent caused by improperly designed equipment, lack of preventive m aintenance, 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 pe rmit shall be certified by a responsible official as to truth, accuracy, and completeness. S uch certifications shall state that based on information and belief formed after reasonable inqu iry, 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 m odification, revocation and reissuance, or termination, or of a notification of planned change s 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, EP A rules, or rules enforceable by EPA.10

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 fo r all records required by this permit will be extended automatically until the per mittee receives written notice from EPA that the permittee no longer needs to reta in these records.

5.16.4 The permittee shall hold at the corporate offices o f Anadarko Petroleum Corporation, 1201 Lake Robbins Drive, The Woodlands , Texas 77380, all records required by the permit including, but not limited t o, monitoring data and support information required by the permit, and records of all data used to complete the application for this permit. These materials shall 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 app lication must be kept for five years from the date of the application, unless othe rwise specified. Support
information includes all calibration and maintenanc e records and all original stripchart recordings for continuous monitoring instrume ntation 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 o r 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 which is needed to determine compliance with th e permit. If the permittee
becomes aware that relevant facts were not submitte d or were incorrect in the permit application or in any report to EPA, the per mittee shall, upon becoming aware of such facts or corrected information, promp tly submit such facts or
corrected information to EPA.

[40 CFR §§ 71.5(b) and 55.8]11

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.16.7 All notifications, reporting or other communication s 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 i ndividuals at their corresponding email address:

Name Email Phone David Lloyd lloyd.david@epa.gov 404-562-9216 Jason Dressler dressler.jason@epa.gov 404-562-9208 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 reason able time, any information that EPA may request in writing to determine whether cau se exists for modifying, revoking, and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee shall also furnish to EPA copies of records that are required to be kept pursuant to th e terms of the permit, including
information claimed to be confidential. Information claimed to be confidential must be accompanied by a claim of confidentiality a ccording 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 re quired monitoring for each six month reporting period from July 1 to December 31 a nd from January 1 to June 30, except that the first reporting period shall be gin when the OCS source commences activity subject to this permit and end o n either June 30 or December 31, whichever occurs first. All reports shall be su bmitted to EPA and shall be postmarked by the 30th day following the end of the reporting period. All instances of deviations from permit requirements mu st be clearly identified in such reports. All required reports must be certifie d by a responsible official
consistent with Condition 5.13.12

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.17.2 The permittee shall promptly report to EPA, by tele phone or facsimile, deviations from permit conditions, the probable cause of such deviations, and any corrective actions or preventive measures taken. The report sh all be made using the following numbers:

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 time frame f or reporting deviations provided in an underlying applicable req uirement as identified in this permit.

5.17.3.2 Where the underlying applicable requirement fails t o address the time

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

5.17.3.2.1 for emissions of a hazardous air pollutant or a tox ic air

pollutant (as identified in the applicable regulati on) that continue for more than an hour in excess of permit requirements, the report must be made within 24 hou rs 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 f or more than two (2) hours in excess of permit requirements , the report must be made within 48 hours of the occurren ce; 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 devia tion that requires 24-hr or 48- hr notification as provided in Condition 5.17.3.2 a bove, the permittee shall also submit a written notice, which shall include a narr ative description of the deviation and updated information as listed below t o EPA, certified consistent with Condition 5.13 of this permit.

5.17.5 When reporting excess emissions or permit deviation s, including those that are required to be submitted for the first time with th e semi-annual monitoring report, the permittee must report in writing the following information:13

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

5.17.5.1 OCS Source (Facility) Name;
5.17.5.2 OCS Air 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 (to tal 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, i ncluding

information regarding the operating conditions duri ng the deviation;
5.17.5.10 identification of the emission unit(s) or source(s) involved in the event

using the same identification number(s) and name(s) as in the permit;
5.17.5.11 identification of each emission limit potentially e xceeded during the

event and the level of exceedance, if applicable;
5.17.5.12 whether the deviation was unavoidable;
5.17.5.13 describe corrective action taken and action taken t o prevent future

recurrence; 5.17.5.14 if not corrected, the anticipated time the deviatio n 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 form ed after reasonable

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

5.17.6 For the purposes of Conditions 5.17.1 through 5.17. 7, deviation means any situation in which the permittee fails to meet a pe rmit term or condition. A deviation is not always a violation. A deviation ca n be determined by observation or through review of data obtained from any testing , monitoring, or recordkeeping required by this permit. For a situation lasting mo re 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 limi tation or standard;
5.17.6.2 a situation where process or emissions control devi ce parameter values

indicate that an emission limitation or standard ha s not been met;
5.17.6.3 a situation in which observations or data collected demonstrate

noncompliance with an emission limitation or standa rd or any work practice or operating condition required by the per mit (including indicators of compliance revealed through parameter monitoring); and
5.17.6.4 a situation in which any testing, monitoring, recor dkeeping or

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

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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/devia tion report.

[40 CFR §§ 55.8, 71.6(a)(3)(i)(B), and 71.6(a)(3)(i ii)]

5.18 Off Permit Changes

The permittee is allowed to make certain changes wi thout 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 under the provision, except for changes that qualif y as insignificant activities under 40 CFR § 71.5(c)(11). The written notice shall incl ude 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 emitted; and
5.18.4.5 any applicable requirements that would apply as a r esult of the change.

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

5.18.6 The permittee shall keep a record describing all ch anges that result in emissions of any regulated air pollutant subject to any applicab le requirement not otherwise regulated under this permit, and the emissions resu lting 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 (w hether expressed therein as a rate of emissions or in terms of total emissions) and are n ot title I modifications. This class of changes does not include changes that would violate applica ble requirements or changes that would contravene federally enforceable permit terms and c onditions that are monitoring (including test methods), recordkeeping, reporting, or compliance c ertification requirements.15

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.19.1 The permittee is required to send a notice to EPA a t least 7 days in advance of any change made under this provision. The notice must d escribe the change, when it will occur and any change in emissions, and identif y any permit terms or conditions made inapplicable as a result of the cha nge. 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 changes 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 o f compliance with permit terms and conditions, including emission limitations, standar ds, or work practices, postmarked by February 28 of each year and covering the previous calendar year except that the first certification shall cover the period from the date the OCS commences ac tivities subject to this permit through December 31. The compliance certification shall be certified as to truth, accuracy and completeness by a responsible official consistent w ith 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 of 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 an d condition during the certification period. Such methods and other means shall include, at a minimum, the methods and means required in this permit. If n ecessary, the permittee also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of t he CAA, which prohibits knowingly making a false certification or omitting material information;

5.20.3 The status of compliance with each term and conditi on of the permit for the period covered by the certification, including whet her compliance during the period was continuous or intermittent. The certific ation shall be based on the method or means designated above. The certification shall identify each deviation and take it into account in the compliance certific ation; 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 regula ted under this permit during the duration of the reporting period based on recor ded data, including actual fuel usage and actual hours of operation. The report sha ll include the emission factors used for each unit and a description of the reprodu cible 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 BlackHornet OCS-EPA-R4020 12/31/2014 5.21 Compliance Schedule

For applicable requirements with which the source i s in compliance, the permittee will continue to comply with such requirements. For applicable re quirements that will become effective during the permit term, the permittee shall meet such requ irements on a timely basis.

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

5.22 Safe Shutdown

As provided in 40 CFR § 55.9(c), if this OCS source is ordered to cease operation of any piece of equipment due to enforcement action taken by EPA, t he shutdown will be coordinated by EPA with the DOI Bureau of Safety and Environmental Enf orcement, 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 consul tation with these entities, but in no case will initiation of the shutdown be delayed by more than 24 hours after EPA consults with these agencies. The initiation of the shutdown process wi ll not preclude well procedures necessary to ensure safety.

[40 CFR § 55.9(c)]

5.23 Transfer of OwnershipPermit

In the event of any changes in control or ownership of the OCS source, this permit shall be binding on all subsequent owners and operators. The permittee shall notify the succeeding owner and operator of the existence of this permit and it s conditions by letter, a copy of which shall be forwarded to EPA Region 4 in accordance with Condit ion 5.16.7. This permit may be transferred to subsequent owners or operators of the OCS source provided that the applicable permit amendment or modification criteria of 40 CFR § 71.7 are satisfied. A change in ownership or operational control of the OCS source may be treate d as an administrative permit amendment under 40 CFR § 71.7(d) if the EPA determines that n o other change in the permit is necessary and provided that a written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the current and new permittee has been submitted
to EPA.

[40 CFR § 7155

. 76 ( da )( 14 )(iv)]

5.24 Severability

The provisions of this permit are severable, and, i n the event of any challenge to any portion of this permit or if any provision of the permit is he ld invalid, the remainder of this permit shall
remain valid and in force.

[40 CFR §71.6(a)(5)]17

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.25 General Testing Requirements

5.25.1 In addition to the specific testing requirements co ntained 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 spe cifically stated otherwise in this permit.

5.25.2 The permittee shall provide EPA at least 30 days pr ior 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 f or 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 p rior notice of the rescheduled date of the performance test, or by arranging a res cheduled date with EPA by mutual agreement.

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

5.25.3.1 purpose and scope of testing;
5.25.3.2 source description, including 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 re ported with the

results, including source-specific data identified in the emission unit sections of this permit;
5.25.3.5 sampling and analysis procedures, specifically requ esting approval for

any proposed alternatives to the reference test met hods, and addressing minimum test length ( e.g. , one hour, eight (8) hours, 24 hours, etc.) and minimum sample volume;
5.25.3.6 sampling location description and compliance with t he 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;18

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

5.25.3.10 sample recovery and field documentation;
5.25.3.11 chain of custody procedures;
5.25.3.12 quality assurance/quality control project flow char t; 5.25.3.13 data processing and reporting;
5.25.3.14 description of data handling and quality control pr ocedures; and
5.25.3.15 report content and timing.

5.25.4 Only regular operating staff may adjust the process es or emission control devices during or within two (2) hours prior to the start o f a source test. Any operating adjustments made during a source test that do not r esult 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:

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

applicable condition of this permit that is requiri ng a test; and

5.25.5.2 all continuous monitoring system data that is requi red to be routinely

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

5.25.6 Each source test shall follow the reference test me thods specified by this permit and consist of at least three (3) valid test runs c onducted under normal operating
conditions.

5.25.7 If the reference test method yields measured pollut ant concentration values at an oxygen concentration other than specified in the em ission standard, the permittee shall correct the measured pollutant concentration to the oxygen concentration specified in the emission standard by using the fol lowing 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 stand ard; and Y = the measured average volumetric oxygen concentr ation.

5.25.8 Facilities for performing and observing the emissio n testing shall be provided that meet the requirements of 40 CFR § 60.8(e) and Refer ence Method 1 (40 CFR § 60, Appendix A).19

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 5.25.9 Emission test reports shall be submitted to EPA wit hin 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 l imit, unless otherwise specified in the emission unit sections of this permit. The p ermittee 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 s hall submit the following to
EPA:

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 pho tocopy 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, certified check, corporate check , or electronic funds transfer payable to the order of the U.S. Environmental Prot ection Agency.

5.26.3 The permittee shall send fee payment and a complete d fee filing form to either of
the addresses listed below.

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

U.S. Environmental Protection Agency FOIA and Miscellaneous Payments
Cincinnati Finance Center
PO Box 979078 St. Louis, MO 63197-9000

If sent by Express Delivery (or when a physical add ress is required), send to:

U.S. Bank
Government Lockbox 979078 US EPA FOIA & Misc. Payments
1005 Convention Plaza20

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 confi rmation of actual fee paid), submitted annually by the date specified in Conditi on 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 30303

5.26.5 The annual emissions fee shall be calculated by mul tiplying the total tons of actual emissions of all “regulated pollutants (for fee calculation),” emitted from the source by the presumptive emission fee (in doll ars/ton) in effect at the time of calculation. The presumptive emission fee is revise d each calendar year and is available from EPA prior to the start of each calen dar year.

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

(TPY) of any “regulated pollutant (for fee calculat ion),” as defined in 40 CFR § 71.2, emitted from a part 71 source over t he preceding calendar year. Actual emissions shall be calculated using each emissions unit’s actual operating hours, production rates, in-place control equipment, and types of materials processed , stored, or combusted during the preceding calendar year.

5.26.5.2 Actual emissions shall be computed using methods re quired by the

permit for determining compliance, such as monitori ng or source testing data.21

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

5.26.5.3 If actual emissions cannot be determined using the compliance

methods in the permit, the permittee shall use othe r 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 p ollutant

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

5.26.5.4.2 actual emissions of any “regulated pollutant (for f ee calculation)” already included in the fee calculati on; and

5.26.5.4.3 the insignificant quantities of actual emissions no t 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 repo rt of its actual emissions for the preceding calendar year. The annual emissions r eport shall be certified by a responsible official and shall be submitted each ye ar to EPA by the date specified in Condition 5.26.1. The annual emissions report sh all 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 accordanc e with Condition 5.13 of this permit.

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

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

5.26.10 The permittee, when notified by EPA of additional a mounts due, shall remit full payment within 30 days of receipt of an invoice fro m 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 w ritten explanation of the alleged error to EPA along with full payment of the EPA ass essed fee.

[40 CFR § 71.9]22

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 coor dinates 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 and no physical ch anges required by Condition 6.5.1.2 (if applicable); and

6.1.4 Not less than 24 hours prior to commencing construc tion or operation, of any changes to the information provided by the permitte e in Condition 6.1.

[40 CFR §§ 71.6(a)(6)(v), 52.21 and 55.8]

6.2 Reserved.

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 Su bpart 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 22,800
[40 CFR § 98 Subpart A]

6.4 Source-wide SO 2 Emission Limit

The permittee shall not combust any diesel fuel wit h 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 BlackHornet

or on any support vessel.23

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.4.1 The permittee shall obtain a certification of sulfu r content from the fuel supplier
for all diesel fuel used on the BlackHornet , and used in all equipment and vessels used during well completion (the certification must indicate the sulfur content was determined by an approved EPA method), or the permi ttee shall obtain representative fuel samples using one of the method s 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 BlackHornet for activities covered by this permit, the permittee shall determine and record th e sulfur content of
the diesel fuel on the BlackHornet and the support vessels using the procedures in Condition 6.4.1.

6.4.2.2 Thereafter, the permittee shall determine and recor d the sulfur content

of the diesel fuel on the BlackHornet and the support vessels using the procedures in Condition 6.4.1 upon receiving each f uel shipment.

6.4.3 The permittee shall provide the records required by Condition 6.4.2 and the certification(s) of sulfur content or results of al l fuel sample analyses required by Conditions 6.4.1 and 6.4.2 with the Annual Complian ce Certification required by
Condition 5.20.

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

6.5 General Stack Test Requirements

6.5.1 Within 12 months prior and no more than 3 months af ter the start of drilling under this permit, the eight main engines (DR-ME-01 throu gh DR-ME-08) of the
BlackHornet shall have been stack tested under the requirements Condition 5.25.

6.5.1.1 If, after the initial stack tests, the drilling ves sel discontinues drilling

under the permit for more than 12 months, the permi ttee shall certify that a continuous maintenance program has been cond ucted and that no physical changes that could impact emissions hav e occurred since the latest stack test, or the permittee shall condu ct a new stack test prior to restarting drilling operations in accordan ce with the general stack testing requirements set forth in Condition 5 .25 and Conditions 6.5.2 through 6.5.6.24

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

6.5.1.2 If a continuous maintenance program is selected fro m the options in

Condition 6.5.1.1, the certification shall be inclu ded with the drill site notification required pursuant to Condition 6.1. Ma intenance records shall be kept in accordance with the recordkeeping 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 differe nt loads spanning the expected range of operations.

6.5.4 At a minimum, each stack test shall test for emissi ons 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 a nd record the electrical power produced (in kW-hr).

6.5.6 For each engine, each load, 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 BlackHornet Emission and Operating Limits

6.6.1 Source Identification: DR-ME-01 through -08 (main p ropulsion generator engines).

6.6.1.1 The permittee shall not discharge or cause the disc harge 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 DR-ME-06

Operating Below 50% Load: 57.3 lb/hr on a rolling 2 4-hour average basis.

6.6.1.1.3 NO X BACT Limit DR-MR-07 and DR-ME-08 Operating

Below 50% Load: 103.5 lb/hr on a rolling 24-hour av erage basis.25

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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-hou r average basis.

6.6.1.1.5 CO BACT Limit DR-ME-01 through DR-ME-06 Operating

Below 50% Load: 16.6 lb/hr on a rolling 24-hour ave rage basis.

6.6.1.1.6 CO BACT Limit DR-ME-07 through DR-ME-08 Operating

Below 50% Load: 23.3 lb/hr on a rolling 24-hour ave rage basis.

6.6.1.1.7 VOC BACT Limit DR-ME-01 through DR-ME-08

Operating at 50% Load and Above: 0.8 g/kw-hr on a rolling 24-hour average basis.

6.6.1.1.8 VOC BACT Limit DR-ME-01 through DR-ME-06

Operating Below 50% Load: 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% Load: 6.2 lb/hr on a rolling 24-hour aver age basis.

6.6.1.1.10 PM/PM 10 /PM 2.5 BACT Limit DR-ME-01 through DR-ME08 Operating at 50% Load and Above: 0.40 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-ME06 Operating Below 50% Load: 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-ME08 Operating Below 50% Load: 4.0 lb/hr on a rolling 24- hour average basis.

6.6.1.1.13 GHG BACT Limit DR-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% Load: 4,700 lb/hr on a rolling 24- hour average basis.26

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.6.1.1.15 GHG BACT Limit DR-MR-07 and DR-ME-08 Operating

Below 50% Load: 8,299 lb/hr on a rolling 24-hour av erage basis.

6.6.1.2 The permittee shall use the following BACT work pra ctice standards:

6.6.1.2.1 main propulsion generator engines with LNE design,

including: turbocharger, aftercooler, and high inje ction

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);

6.6.1.2.4 good combustion practices based on the most recent

manufacturer’s specifications issued for these engi nes at the time that the engines 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 a nd
found in the administrative record to be used in co njunction with an enhanced monitoring, maintenance, and load
management system.

6.6.1.2.6 A PEMS equivalent to the one identified in the appl ication

may be used with prior written EPA approval.

6.6.1.2.7 The permittee will develop and implement an enhance d

monitoring, maintenance and load management protoco l that will ensure good combustion practices and mana ge load levels to ensure combustion efficiency.

6.6.1.2.8 The permittee shall submit the enhanced monitoring,

maintenance, and load management system protocol wi th the annual compliance report as required in Conditi on 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 spec ified in Condition 6.6.1 by using the parametric emissions monitoring system (PEMS) provided in Anadarko’s application or a parametric monitoring system equiv alent to PEMS with EPA approval. The permittee may use a27

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 parametric monitoring system equivalent to PEMS onl y 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 (ppm) , CO (ppm) , 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.

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 rate resul ts 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 concentration for the same engine load, or28

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 concern. The permittee may use stack test data only 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 shall 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 ac cording 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.

6.6.1.3.2.1 Each stack test shall be conducted at three differe nt

loads spanning the expected range of operations.

6.6.1.3.2.2 During each test run, the permittee shall monitor

and record the electrical power produced (in kWhr).

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/h r for each engine. Plot the engine load as the independent (or x) variable and the pollutant emission rates as the dependent (or y) variable for each load point tested. Construct the graph by drawing straight-line segments between each load point. Draw a horizontal line to the y-axis from th e 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 to29

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 determine the emission rate when the actual load falls between two tested load points, 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 tested during t he most recent stack test may be used. When recordsof engine load are not available, the highest g/kWhr emission rate calculated for all the load points tested during the most recent stack test may be substituted. The average emission rate for each hou r 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 basis.

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

pursuant to Condition 6.6.1 shall be submitted to E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.2 Source Identification: DR-GE-01 (emergency generato r engine).

6.6.2.1 The permittee shall use the following BACT work pra ctice standards:

6.6.2.1.1 an emergency diesel engine with LNE design, includi ng:

turbocharger, aftercooler, and high injection press ure;

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 engin e at the time that the engine is operating under this permit

.

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

per year of non-emergency, planned operation time o n a 12-month rolling total basis.30

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

6.6.2.3 The permittee shall maintain a record of hours of o peration and sum

such hours on a rolling 12-month basis. Hours of op eration shall be recorded monthly from a non-resettable hour meter o r, if such a meter is not available, by monitoring and maintaining a c ontemporaneous 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 equipment.

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

pursuant to Condition 6.6.2 shall be submitted to E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.3 Source Identification: DR-AC-01 (emergency air comp ressor engine).

6.6.3.1 The permittee shall use the following BACT work pra ctice standards:

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 engin e at the time that the engine is operating under this permit

.

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

per year on a 12-month rolling total basis.

6.6.3.3 The permittee shall maintain a record of hours of o peration and sum

such hours on a rolling 12-month basis. Hours of op eration shall be recorded monthly from a non-resettable hour meter o r, if such a meter is not available, by monitoring and maintaining a c ontemporaneous record of the following information:31

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.4 Source Identification: DR-LB-01 through DR-LB-06 (l ife 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 these engi nes at the time that the engines are operating under this permit.

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

per year each on a 12-month rolling total basis.

6.6.4.3 The permittee shall maintain a record of hours of o peration for each

engine and a record of the sum of such hours for ea ch engine on a rolling 12-month basis. Hours of operation shall be recorded monthly from a non-resettable hour meter or, if such a mete r 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 E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.32

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.6.5 Source Identification: DR-FR-01 (fast rescue 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 engin e at the time that the engine is operating under this permit

.

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

per year on a 12-month rolling total basis.

6.6.5.3 The permittee shall maintain a record of hours of o peration and sum

such hours on a rolling 12-month basis. Hours of op eration shall be recorded monthly from a non-resettable hour meter o r, if such a meter is not available, by monitoring and maintaining a c ontemporaneous 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.

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

pursuant to Condition 6.6.5 shall be submitted to E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.6 Source Identification: DR-DC-01 through DR-DC-04 (m ud and cement mixing, equipped with dust collectors).

6.6.6.1 The permittee shall use the following BACT work pra ctice standard:

proper maintenance and operation of the dust collec tors in accordance with the most recent manufacturer’s specifications at the time that these dust collectors are operating under this perm it.33

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

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

collector is not over capacity, and report any time s where there is a high-level alarm, at which time the operator will i nvestigate the cause and take corrective actions. For each high alarm ev ent, 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 required to be collected, recorded, or maintained

pursuant to Condition 6.6.6 shall be submitted to E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.7 Source Identification: DR-VG-01 through DR-VG-04 ( mud degassers).

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

into the atmosphere from the mud degassers in exces s of:

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

-

month rolling total basis.

6.6.7.1.2 GHG BACT Limit: 323271 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 pra ctice standard:

proper maintenance and operation of the mud degassi ng operations
units in accordance with the most recent manufactur er’s specifications at the time that these degassers are operating unde r this permit.

6.6.7.3 The permittee shall monitor and record the daily th roughput 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 E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.8 Source Identification: DR-TP-01 through DR-TP-11 an d DR-TP-17 through DRTP-21 (third-party engines).34

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

6.6.8.1 The permittee shall use the following BACT work pra ctice standards:

6.6.8.1.1 engines to certified EPA Tier 2 Nonroad (40 CFR § 8 9) (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 these engi nes at the time that these engines are operating under thi s permit.

6.6.8.2 Operating Limit: DR-TP-01 and DR-TP-02 shall be ope rated no more

than 4,800 hours per year each on a 12-month rollin g total basis, 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-11 shall be operated no

more than the following 4,800 hours per year each o n a 12-month rolling total basis, and each engine’s horsepower r ating 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 o n a 12-month rolling total basis, and each engine’s horsepower r ating shall be less than or equal to 126.

6.6.8.5 The permittee shall maintain a record of hours of o peration for each

engine and a record of the sum of such hours for ea ch engine on a rolling 12-month basis. Hours of operation shall be recorded monthly from a non-resettable hour meter or, if such a mete r is not available, by monitoring and maintaining a contemporaneous record of the following information:
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.35

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

6.6.8.6 The permittee shall provide the following informati on for each engine

used:

6.6.8.6.1 engine tier certificate; and

6.6.8.6.2 engine 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 E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.9 Source Identification: DR-TP-12 through DR-TP-16 (t hird-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 pra ctice 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 these engi nes at the time that these engines are operating under thi s 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 rol ling total basis and each engine’s horsepower rating shall be less t han or equal to 140.

6.6.9.3 The permittee shall maintain a record of hours of o peration and sum

such hours on a rolling 12-month basis.

6.6.9.4 The permittee shall maintain a record of hours of o peration for each

engine and a record of the sum of such hours for ea ch engine on a rolling 12-month basis. Hours of operation shall be recorded monthly from a non-resettable hour meter or, if such a mete r is not available, by monitoring and maintaining a contemporaneous record of the following information:
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.36

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

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 E PA by the permittee in accordance with the reporting specifications det ailed in Condition
5.17.

6.6.10 Source Identification: DR-TP-22 (third party flowba ck boiler).

6.6.10.1 The permittee shall use the following BACT work pra ctice 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 boile r at the time that the boiler is operating under this permit

.

6.6.10.2 Operating Limit: This unit shall be operated no mor e 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 o peration and sum

such hours on a rolling 12-month basis. Hours of op eration shall be recorded monthly by monitoring and maintaining a co ntemporaneous record of the following information:

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 specific ations detailed in
Condition 5.17.

6.6.11 Source Identification: DR-TP-23 (boom flare).

6.6.11.1 The permittee shall use the following BACT work pra ctice standards:

6.6.11.1.1 maintain compliance with 40 CFR 60.18;37

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 o f no more than 360

MMscf per year on a 12-month rolling total basis.

6.6.11.3 The permittee shall monitor and maintain a record o f 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 M Mscf

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 specific ations detailed in
Condition 5.17.

6.6.12 Source Identification: DR-PO-01 (painting operation s).

6.6.12.1 The permittee shall use the following BACT work pra ctice standards:

6.6.12.1.1 best management practices, including but are not li mited 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 airborne particulate matter from drifting into the atmospher e, and proper storage of coatings and thinners in non-leak ing containers; and

6.6.12.1.2 use of an airless spray gun with transfer efficienc y of 50%

or greater; where it is not practical to use an air less spray gun, the permittee may use an air assisted spray gu n with a transfer efficiency of 30% or greater.

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

5,200 gallons per calendar year of thinner and prim er, respectively.38

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

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

gallons) of coatings and thinners used in a calenda r year. Also, the permittee shall keep material safety data sheet (MS DS) information on file for all coatings and thinners used on the dril lship.

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 specific ations 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 pra ctice standard:

follow current manufacturer’s recommendations for a ll equipment used in welding operations at the time that that we lding occurs under this permit, including but not limited to, recommen dations 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. Thi s information may be obtained from delivery manifests or records main tained 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 specific ations detailed in
Condition 5.17.

6.6.14 Source Identification: DR-FT-01 through DR-FT-19 (d iesel and helicopter fuel storage tanks) and DR-TP-24 through DR-TP-26 (conde nsate tanks).

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

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

6.6.14.1.1 VOC BACT Emission Limit for DR-FT-01 through DRFT-19: 0.69 tons per year on a 12-month rolling tot al basis.

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

into the atmosphere from the condensate tanks combi ned in excess of:

6.6.14.2.1 VOC BACT Emission Limit for DR-TP-24 through DRTP-26: 9.65 tons per year on a 12-month rolling tot al basis.39

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014

6.6.14.3 The permittee shall use the following BACT work pra ctice 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 follow ing 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 D RTP-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 specific ations 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 pra ctice standard:

good maintenance practices to minimize fugitive emi ssions, including but not limited to, minimizing the release of emiss ions 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 ch eck to ensure that

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

6.6.15.2.1 date/duration of leak detection from valves, pump s eals,

and 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, recorded, or maintained

pursuant to Condition 6.6.15 shall be submitted to EPA by the permittee in accordance with the reporting specific ations detailed in
Condition 5.17.40

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.6.16 Fuel Use Limit.

6.6.16.1 Operating Limit: The BlackHornet 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 consu mption for the

duration of the project on a rolling 12-month basis

.

6.6.16.3 The permittee shall monitor and maintain a record o f the following

information:

6.6.16.3.1 initial cubic meters of diesel fuel on the OCS sour ce 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 recording 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 the permittee in accordance with the reporting specific ations 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 s ( HOS Coral or substitute) and anchor handling
boat s ( Kirt Chouest

or substitute) , Tug, Barge, or Well Evaluation Vessel (with equivalent or lower potential emissions to the vess els used in the application)
shall not use more than:

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

vessel.

6.7.1.2 40,000 barrels of diesel fuel per year when within 25 miles of the

drilling vessel.

6.7.2 The stimulation vessel or substitute stimulation ve ssel (with equivalent or lower potential emissions to the vessel used in the appli cation) shall not use more than 225 barrels of diesel fuel per day when within 25 m iles of the drilling vessel.41

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.7.3 The tug or substitute tug (with equivalent or lower potential emissions to the vessel used in the application) shall not use more than 125 barrels of diesel fuel per day when within 25 miles of the drilling vessel

.

6.7.4 The well evaluation vessel or substitute well evalu ation vessel (with equivalent or lower potential emissions to the vessel used in the application) shall not use more than 144 barrels of diesel fuel per day when within 25 miles of the drilling vessel.

6.7.5 The barge or any substitute barge (with equivalent or lower potential emissions to the vessel used in the application) shall not opera te more than 4,800 hours per year on a rolling 12-month total basis when within 25 miles of the drilling vessel.

6.7.26.7.6 The supply boat, anchor handling boat, stimulation vess el, tug, well evaluation vessel and barge support vessels shall not combust any diesel fuel with sulfur content greater than 15 ppm by weight.

6.7.36.7.7 The permittee shall monitor and maintain a contempo raneous record of the following information for the supply boats, the anchor handling boats, t he stimulation vessel, the tug and the well evaluation vessel :

6.7.3.16.7.7.1 name of vessel;
6.7.3.26.7.7.2 units onboard the vessel, with short description an d applicable

ratings of each unit;
6.7.3.36.7.7.3 date/time entering the 25 nautical mile radius;
6.7.3.46.7.7.4 date/time exiting the 25 nautical mile radius;
6.7.3.56.7.7.5 sulfur content of all fuel used in any engine as sp ecified in

Condition 6.4;
6.7.3.66.7.7.6 barrels of diesel fuel on the vessel entering the 2 5 nautical mile

radius;
6.7.3.76.7.7.7 barrels of diesel fuel on the vessel exiting the 25 nautical mile

radius; and
6.7.7.8 barrels of diesel fuel loaded on to the vessel for each 24-hour period

within the 25 nautical mile radius.

6.7.8 The permittee shall monitor and maintain a contempo raneous record with the following information for the barge:

6.7.8.1 name of vessel;
6.7.8.2 units onboard vessel, with short description and ap plicable ratings of

each unit;
6.7.8.3 date/time entering the 25 nautical mile radius;
6.7.8.4 date/time exiting the 25 nautical mile radius; and
6.7.3.86.7.8.5 sulfur content of all fuel used in any engine as sp ecified in

Condition 6.4.42

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.7.46.7.9 All information required to be collected, recorded, or maintained pursuant to Condition 6.7 shall be submitted to EPA by the p ermittee 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 Supply Boat Emission Limits

6.8.1 Source Identification: SB-DT-01 through SB-DT-15 (s upply boat storage tanks).

6.8.1.1 The permittee shall not discharge or cause the disc harge of emissions

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

6.8.1.1.1 VOC BACT Emission Limit: 0.011 tons per year on a 1 2-

month rolling total basis.

6.8.1.2 The permittee shall use the following BACT work pra ctice standard:

use of good maintenance practices.

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

emissions.

6.8.1.4 The permittee shall monitor and maintain the follow ing information:

6.8.1.4.1 Unit ID; and

6.8.1.4.2 The dimensions, fuel type, and capacities of units SB-DT01 through SB-DT-15.

6.8.2 All information required to be collected, recorded, or maintained pursuant to
Condition 6. 89 shall be submitted to EPA by the permittee in acco rdance 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 Anchor Handling Boat Emission Limits

6.9.1 Source Identification: AB-DT-01 through AB-DT-19 (a nchor handling boat diesel storage tanks).

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

into the atmosphere from the storage tanks combined in excess of:43

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.9.1.1.1 VOC BACT Emission Limit: 0.10 tons per year on a 12

-

month rolling total basis.

6.9.1.2 The permittee shall use the following BACT work pra ctice standard:

use of good maintenance practices.

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

emissions for the semi-annual report.

6.9.1.4 The permittee shall monitor and maintain the follow ing information:

6.9.1.4.1 Unit ID; and

6.9.1.4.2 The dimensions, fuel type, and capacities of units AB-DT01 through AB-DT-19.

6.9.2 All information required to be collected, recorded, or maintained pursuant to
Condition 6. 910 shall be submitted to EPA by the permittee in acco rdance 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)]

6.10 Stimulation Vessel Emission and Operating Limits

6.10.1 Source Identification: SV-PE-01 through SV-PE-08 (s timulation vessel pump engines).

6.10.1.1 The permittee shall use the following BACT work pra ctice standards:

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

by weigh; and

6.10.1.1.2 good combustion practices based on the most recent

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

.

6.10.1.2 Operating Limit: SV-PE-01 through SV-PE-08 shall be operated no

more than 4,032 hours per year combined on a 12-mon th rolling total
basis.

6.10.1.3 The permittee shall maintain a record of hours of o peration for each

engine and a record of the sum of such hours for ea ch engine on a rolling 12-month basis. Hours of operation shall be recorded monthly from a non-resettable hour meter or, if such a mete r is not available, by monitoring and maintaining a contemporaneous record of the following information:44

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.10.1.3.1 unit ID;
6.10.1.3.2 date/time engine started;
6.10.1.3.3 date/time engine shut down;
6.10.1.3.4 name of person operating equipment (printed); and
6.10.1.3.5 signature of person operating equipment.

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

.[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 Emiss ion Standard for Hazardous Air Pollutants (HAP) Requirements

6.11.1 The drillship main engines (DR-ME-01 through DR-ME- 08), the emergency air compressor engine (DR-AC-01), and the third party e ngines (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 dis placement, and model year. The permittee shall demonstrate compliance with the app licable requirements for these engines through the following:

6.11.1.1 The permittee shall maintain documentation in accor dance with

Condition 5.16 that engines specified in Condition 6.11.1 were installed and configured according to manufacturer’ s specifications.

6.11.1.2 The permittee shall maintain records in accordance with Condition

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

6.11.1.3 The permittee shall operate and maintain the engine s according to the

manufacturer’s written instructions or procedures d eveloped by the permittee that are approved in writing by the engin e manufacturer. The permittee shall only change those settings that are approved by the manufacturer. The permittee shall maintain records of the manufacturer’s written instructions for operation a nd maintenance of the engine or the procedures the permittee develope d that are approved in writing by the manufacturer in accordance with C ondition 5.16.

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

meet the requirements of Condition 6.4.45

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 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 ye ar. The permittee has been granted a technical exemption pursuant to 40 CFR § 55.7 from the emission standard certification requirement of 40 CFR 60, su bpart IIII and must comply with the following:

6.11.2.1 The permittee shall demonstrate compliance with alt ernate emissions

standards as specified in Condition 6.6.2.

6.11.2.2 The permittee shall comply with requirements define d in Conditions

6.11.1.1 through 6.11.1.4.

6.11.3 Based on engine model years and engine use (summari zed in Tables 1 and 2 of Section 4), the drillship main engines, the emergen cy 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 each e ngine by demonstrating compliance with the applicable requirements of 40 C FR 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 (summari zed in Tables 1 and 2 of Section 4) the well evaluation engines and the stim ulation vessel pump engines (DR-TP-1 26 through DR-TP- 1621 and SV-PE-01 through SV-PE-08) are subject to and shall comply with the applicable requirement s of 40 CFR part 63, subpart
ZZZZ.

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 O CS must comply with the applicable requirements in 40 CFR § 63.660 3(c) and Table 2d in subpart ZZZZ in accordance with the compliance s chedule 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 accorda nce with the compliance schedule requirements of Condition 5.21.

6.11.4.3 Compliance with any applicable numerical emission l imitation

established in subpart ZZZZ is based on the results of testing the average of three 1-hour runs using the testing requ irements 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]46

Anadarko BlackHornet OCS-EPA-R4020 12/31/2014 6.11.5 Any new, modified, or reconstructed engine shall co mply with all applicable NESHAP and NSPS, including but not limited to 40 CF R 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 dri lling 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 pertinen t 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 un its specified in Tables 1 and 2 of
Section 4.

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