ANADARKO PETROLEUM CORPORATION 1201 LAKE ROBBINS DRIVE, THE WOODLANDS, TEXAS 77380 P.O. BOX 1330 HOUSTON, TEXAS 77251

- 1330 U.S.A. PH. (832)636

- 1000

November 26 , 2013

Ms. Kelly Fortin U.S. EPA Region 4 61 Forsyth Street, S.W. Atlanta, GA 30303

- 8960

RE: Anadarko BlackHawk and BlackHornet OCS Air Permit Application for Drilling, Exploration, and Maintenance Activities in the Eastern Gulf of Mexico EPA’s Incompleteness Determination Letter Dated October 31 , 2013 Addendum to Response Lett er Submitted on November 12, 2013

Dear Ms. Fortin :

EPA Region 4 provided Anadarko with incompleteness determination letter on October 31, 2013 requesting more information as well as clarifications. Anadarko representatives met with EPA Region 4
staff on November 5 , 2013 to discuss the submitted application s and comments provided in the incompleteness determination letter

. Anadarko submitted a response letter including comments on the air dispersion modeling (i.e., comments no. 16 to 25) on November 12, 2013. This letter is being submitted as an addendum to the submission on November 12, 2013. This letter addresses comment s no. 1 to 1 5 except comment no. 11

.

Source Identification

1. The application has identified the m ain diesel engines (DR

- ME

- 01 th r o ug h DR

- ME

- 08) and the emergency generator (DR

- GE

- 01) as IMO Tier II certified, and the emergency air compressor engine (DR

- AC

- 01) as EPA Tier 2 certified. Please provide the tier certificates to EPA for these engines when they become available.

Anadarko Resp onse :

The Engine International Air Pollution Prevention ( EIAPP ) certificat es for the main diesel engines (DR

- ME

- 01 through DR

- ME

- 08) are currently not available and will be provided to EPA at a later date after they become available

. The emergency generator (DR

- GE

- 01) certification is attached in Appendix A. The emergency air compressor engine (DR

- AC

- 01) is 2011 Model year
EPA non

- road Tier 3 certified engine

. A copy of ‘C ertificate of Conformity’ is attached in Appendix A

.

Emission Calculations

2. While not prohibited, the use of AP

- 42 emission factors to calculate the projects’ emissions may not result in accurate emission estimates. These factors are averages, often based on limited data, and therefore are not a good representation of the emissions from a defined emissions unitMs. Fortin

Page 2 of 10

used under different operating scenarios. These factors were designed for large scale, area

- wide attainment demonstrations and inventories, and not source specific assessments. EPA recommends that the applican t use AP

- 42 emission factors in the emission calculations as the last resort, or ensure that the estimates are conservative. Stack testing, manufacturer data, or test results from other comparable engines provide more representative factors than those
foun d in AP

- 42. Compliance with the emissions limits in the permit will be based on the best available information, regardless of whether AP

- 42 factors were used in the application.

Anadarko Response :

Anadarko understands that AP

- 42 emission factors are often based on limited data and most of the times result in conservative (i.e., higher) emissions. Anadarko utilized AP

- 42 emission factors when no other representative data such as manufacturer’s test data or test data from other comparable equipment were available. Anadarko understands that the emissions limits in the permit will be based on the best available information.

Anadarko used emission factors specified in the EPA non

- road tier (40 CFR 89 ) and EPA marine

tier ( 40 CFR 94 ) requirements wherever applicable to calculate the criteria pollutants

emissions

. Moreover, regulatory requirements were used as emission factors wherever applicable. For example, t he main diesel engines (DR

- ME

- 01 through DR

- ME

- 08) particulate

matter emissions we re calculated using NSPS IIII emission factors and NO x emissions are calculated using IMO Tier II standards

.



### 3. Appendix B of the application include the detailed calculations for the potential to emit (PTE). The f

ollowing values in the detailed calculation table are reported as zero: Scenario 5, NO
x 

### emissions from the emergency air compressor, and Scenario 2, PM emissions from the Supply Boats. Please confirm these values.

Anadarko Response :

In the Appendix B of the application, NO X emissions from the emergency air compressor for
Scenario 5 were reported only up to one digit after the decimal point and hence appeared as
zero. The NO X emissions from the emergency air compressor for Scenario 5 are 0.1 pounds per hour, 0.1 pounds per day, and 0.01 tons per year

.

The annual PM PTE from the Supply Boats for Scenario 2 are 2.81 tons per year.

4. T he PTE relied on the emission generated from Scenario 5 for NO x emissions and Scenario 2 for all other pollutants. However, for the sum of the emissions for the pollutant specific tables do
not match the PTE emissions presented in the summary table for PM 10 , H 2 SO 4 and Lead from Scenario 2 emissions. Please clarify what the PTE is for these pollutants.

Anadarko Response :

T he revised emission calculations (i.e., “Revised Appendix B

– Revision 1” document) provided to Eva Land of EPA Region 4 via email on September 17, 2013 addresses this comment . The PTE
for PM 10 , H 2 SO 4 and Lead is provided in Table 1.Ms. Fortin

Page 3 of 10

Table 1: PM 10 , H 2 SO 4 and Lead PTE

Pollutant PTE Summary

lb/hr lb/day ton/yr

PM 10 2.51E+1 6.02E+2 3.22E+1

Lead 6.71E

- 3 1.61E

- 1 1.73E

- 2

H 2 SO 4 1.15E

- 2 2.75E

- 1 2.98E

- 2

Regulatory Applicability Analysis

5. The application has identified the emergency generator as an IMO Tier II certified engine. In section 4.3.5.2, page 73, of the application:

...the existing emergency generator was sized to meet the drillship’s stringent space and weight distribution requirements in the vessel’s design phase, any replacement engine
would have t o meet similar physical characteristics and restrictions dictated by the vessel’s design. It is very difficult, if not impossible, to find a replacement EPA Tier 2 certified engine meeting the constraints discussed above. Moreover, such a replacement
will require significant redesign and recertification of the drillship.

The EPA requests more information regarding this assessment. The New Source Performance Standards require a s ource to meet the stated requirements unless, pursuant to 40 CFR 55.7,
“the adm inistrator of the delegated agency finds that compliance with the control technology requirement is technically infeasible or will cause an unreasonable threat to health and safety .” Anadarko should verify that there are no replacement engines available.

Anadarko Response :

Anadarko contacted the emergency generator engine manufacturer (i.e., Cummins ) to check the availability of EPA Tier 2 certified engine in their fleet. Cummins has an EPA marine Tier 2 , IMO Tier I equivalent engine available. Due to the engine not being IMO Tier II certified this engine

cannot be installed on the BlackHawk or BlackHornet. The emergency generator currently
installed on the BlackHawk and BlackHornet was manufactured in 2 011, although not available
in 2011 Cummins now has an EPA marine Tier 3 and IMO Tier II certified engine. Replacing the currently installed emergency generator with the EPA marine Tier 3 /IMO Tier II certified engine would require modification to the exhau st system, cooling system and possible recertification of the drillship.

This emergency generator is located below the deck level in a space specifically designed to meet its space requirements. Hence, replacement of this engine and modification to the exhaust and cooling system could not be accomplished while the ship is in transit. Such a replacement
will need to be carried out in a dock. Hence, based on the reasonable inquiry, Anadarko believes that replacement of the proposed IMO Tier II certified emergency generator with EPA marine Tier 2 or higher certified engine could not be accomplished without considerable redesign and possible recertification of the drillship; therefore, such a replacement is technically infeasible.

Best Available Control Technology (BACT) AnalysisMs. Fortin

Page 4 of 10

6. The third party well evaluation engines are neither EPA nor IMO Tier certified. Step 1 of the BACT analysis has identified Replacement of Older Engines with Newer engines. The application states, “Since all of these engines ar e used to power different equipment that is performing a single operation they are all leased from the same third party vendor to avoid compatibility issues. The third party Anadarko proposes to lease these engines from has no EPA Tier certified
well evalu ation engines in their fleet,” page 96. The EPA requests more information regarding this statement. It is unclear if there are other available vendors that would provide the same service for the equipment that is being powered, and whether these vendors h ave compliant tier rated engines. If there are costs associated with switching vendors, the applicant should provide a cost analysis.

Anadarko Response :

Anadarko proposes to use Schlumberger ’s third party well evaluation engines since only Schlumberger currently offers certain deepwater drilling technology ( i.e. , higher pressure ratings for tools)

. As explained during the meeting with EPA on November 5, 2013, Anadarko is proposing these well evaluation engines to perform ‘check shot’ operations. Since Schlumberger currently does not have EPA Tier certified engines for ‘check shot’ operations, Anadarko requests the use of proposed well evaluation engines.

7. The applicant calculated the fugitive emissions in Section 3.3.9 and Appendix B. However, the application does not include a BACT analysis for this emission source. Please include a BACT analysis for VOC emissions and any GHG emissions the will be generate d from the fugitive

emission sources.

Anadarko Response :

There are no GHG emissions from the fugitive sources. Also, fugitive emissions of VOC will be associated with operations of fugitive components such as valves, flanges, connectors etc. The

RBLC s earch did not produce any specific results for fugitive components in diesel or distillate service. Moreover, the major ity of fugitive VOC emissions are expected to occur during the fuel
l oading operations. The fuel loading crew will follow standard oper ating procedures for fuel loading operations to minimize liquid leaks and fugitive emissions. Also, operators will follow manufacturer recommended maintenance and operating practices for fugitive components.
Since the VOC emissions from fugitive sources are minimal ( less than 0.01 tpy), Anadarko

proposes following standard operating procedures during fuel loading operations and manufacturer recommended maintenance and operating practices for fugitive components as
BACT. A copy of fuel loading operating p rocedures is attached in Appendix B.

8. The application has included a BACT analysis for the third party boom flare. However, this analysis and the source description do not identify the type of boom flare. Please provide information including, but not limit ed to, the flare pressure, tip, length required of the boom.

Anadarko Response :

Anadarko (Ms. Sara Carlson) provided a copy of a representative boom flare’s specification
sheet as well as additional information regarding boom flares via email on November 6, 2013 to Eva Land (EPA Region 4) and Kelly Fortin (EPA Region 4.)Ms. Fortin

Page 5 of 10

The proposed project includes exploratory drilling for which the flare pressure, tip and length of
boom cann ot be determined at this stage. The primary objective of the boom flare is to route the
flame a safe distance from the drillship

.

9. The BACT analyses for the emergency generator (DR

- GE

- 01) does not include Replacement of Engines to meet higher standards. The application should be updated to include this assessment for all pollutants.

Anadarko Response :

Anadarko contacted the emergency generator engine manufacturer (i.e., Cummins) to check the availability of EPA Tier 2 certified engine in their fleet. Cummins has an EPA marine Tier 2 , IMO Tier I equivalent engine available. Due to the engine not being IMO Tier II certified this engine cannot be installed on the BlackHawk or BlackHornet. The emergency generator currently
installed on the BlackHawk and BlackHornet was manufactured in 2011, although not available
in 2011 Cummins now has an EPA marine Tier 3 and IMO Tier II certified engine. Replacing the currently installed emergency generator with the EPA marine Tier 3 /IMO Tier II certified engine
would require modification to the exhaust system, cooling system and possible recertification of the drillship.

This emergency generator is located below the deck level in a space specifically designed to meet its space requirements. Hence, replacement of this engine and modification to the exhaust and cooling system could not be accomplished while the ship is in transit. Such a replacement will need to be carried out in a dock. Hence, based on the reasonable inquiry, Anadarko believes that replacement of the proposed IMO Tier II certified emergency generator with EPA marine Tier 2 or higher certified engine could not be accomplished without considerable redesign and possible recertification of the drillship; therefore, such a replacement is technically in feasible for all BACT subject pollutant s

.

Moreover, from a cost feasibility perspective, cost to dock the drillship is at least $ 495,000 per day. Since the emergency generator is proposed to be operated for no more than 100 hours during non

- emergency s ituations for maintenance and readiness testing, resulting emissions are minimal (for example, NO x emissions are less than 2 tons per year.) Although a detailed cost analysis is not performed, Anadarko believes replacement of the existing engine to meet h igher
standard s will also be cost prohibitive based on the daily docking cost of the drillship and minimal emissions associated with the emergency generator.

10. A literature search has identified scrubbers such as, the sea scrubber Marine Exhaust Systems

Ec oSilencer®, as an additional control technology for the reduction of particulate matter from marine diesel engines. Please update the PM/PM 10 /PM 2.5 BACT analyses to address this control technology for all viable engines.

Anadarko Response :

Based on the internet search and a brief phone communication with the vendor, the sea scrubber Marine Exhaust Systems EcoSilencer® is designed to reduce SO 2 in exhaust emissions, remove soot particulate, and reduce exhaust noise . As specified in the submitted perm it application, the proposed project did not trigger BACT analysis for SO 2 ; hence, SO 2 emissionMs. Fortin

Page 6 of 10

reductions by EcoSilencer® are not addressed here. Moreover, Anadarko proposed to use ultra
low sulfur diesel as a fuel which results in minimal SO 2 emissions when combusted.

Based on the internet search

, Marine Exhaust Systems EcoSilencer® has been used for main engines on the passenger ships . These engines operate at steady state conditions for a long period of time

. The literature search does not provide any information about t his control technology been tested or successfully installed and operated on a drillship where the main engines operate under frequent load variations (i.e., non steady state operations.) Hence, it appears that more testing and res earch are required to successfully implement this system on the drillship and be considered as a technically feasible emission control technology for the main engines on the drillships

.

Moreover , this system is skid mounted and requires additional housing to accommodate the
associated cooling, scrubbing, waste water treatment operations

. C onsidering the limited space availability on the drillship, it is not possible to accommodate the installation of this control technology without significant redesign an d possibly recertification of the drillship.

Other engines such as emergency generator and emergency air compressor operate intermittently for maintenance and readiness testing. Similarly, the third party engines are temporarily brought on the drillship to perform specific op erations and are opera ted as required. Based on the internet search, it is not clear whether Marine Exhaust Systems EcoSilencer® could be successfully implemented for engines operating intermittently. Hence,
this control t echnology is consider ed as technically infeasible for emergency generator, emergency air compressor , and other third party en g i nes operated on the drillship.

11. Section 5.5 of the BACT analysis evaluated controls for greenhouse gases (GHGs). The GHG

ana lysis for the diesel fired engines omits an evaluation of energy efficiency. Please address the energy efficiency for these engines in the analysis, as well as, the efficiencies of newer cleaner engines.

Anadarko Response :

TO BE ADDRESSED LATERMs. Fortin

Page 7 of 10

Req uests for Short Clarification

12. The beginning of this section identified all units subject to the BACT analysis, page 80. The identified units listed the supply boat third party engines, SB

- TP

- 05 to SB

- TP

- 09. These engines
are not identified later in the BACT analysis, nor in the Regulatory Applicability Analysis section. Please clarify whether these engines are a part of the OCS source and subject to the BACT analysis.

Anadarko Response :

The supply boat third party well evaluation engines, SB

- TP

- 05 to SB

- TP

- 09

, will be located on the supply boats and be o perated to perform certain well evaluation operations such as ‘check shot’ operations. The well evaluation operations using the third party engines on the supply boat will be performed when the supply boat is within 25 miles from the drillship but not physically connected to the drillship. Hence, these supply boat third party engines do not constitute the stationary source aspect when supply boat is physically connected to the drillship; and are not s ubject to BACT analysis

.

13. The BACT analysis for the dr illship main engines (DR

- ME

- 01 through DR

- ME

- 08) has identified control technologies in Step 1 that include Low NO x Engine (LSE) design as well as performance management system including Turbocharger with Aftercooler and High Injection Pressure System. The BACT analysis for the emergency generator (DR

- GE

- 01) states that the control technologies identified for the drillship main engines are applicable for this engine. However, the BACT analysis did not discuss the performance management system. Please clarify if this control technology is applicable for the emergency generator.

Anadarko Response :

The performance management system f or the drillship main engines (DR

- ME

- 01 through DR

ME

- 08) is developed by Hyundai Heavy Industries (HHI) and it is implemented on HHI engines. This system is not a vaila ble for the emergency generator (DR

- GE

- 01) as the emergency generator is manufactured by a different manufacturer (i.e., Cummins

. ) Hence, the performance

ma nagement system for the drillship main engines is not applicable for the emergency
generator.

14. Section 5.3 of the application includes the PM/PM 10 /PM 2.5 BACT analysis. Step 1 of the BACT analysis for the main propulsion electric generator engines, Section 5.3.1 has identified Positive Cranckcase Ventilation as an available control technology. How e ver, in the subsequent steps for this BACT analysis and in the BACT analyses for the remaining engines onboard, Positive
Crankcase Ventilation has not been identified or addressed. Please clarify if this control technology is appropriate for the PM/PM 10 /PM 2.5 analyses.

Anadarko Response :

Positive Cranckcase Ventilation (PCV) is a n emission control technology for VOC . The PCV was
addressed as a prospective control technology in the VOC BACT analysis discussions in Section 5.2 of the application . PCV was accidentally listed as a control technology for PM/PM 10 /PM 2.5

.Ms. Fortin

Page 8 of 10

Appendix G Specification Sheets

15. This Appendix contains specification sheets f or all sources that are associated with this project. However, it does not appear to contain specifications for the third party boom flare, (DR

- TP

23). Please provide a copy of a representative boom flare manufacturer’s specification sheet.

Anadarko Respo nse :

Anadarko (Ms. Sara Carlson) provided a copy of a representative boom flare’s specification
sheet as well as additional information regarding boom flares via email on November 6, 2013 to Eva Land (EPA Region 4) and Kelly Fortin (EPA Region 4

. )

## APPENDIX A : CERTIFICATE OF CONFO RMITY FOR EMERGENCY GENERATOR AND EMERGENCY AIR CO MPRESSORCurve Number: Basic Engine Model:

Engine Configuration: CPL Code: Date:

TECHNICAL DATA DEPT. CHIEF ENGINEER Rating Conditions: Ratings are in accordance with ISO 3046 reference conditions; air pressure at 100 kPa (29.61 in Hg), air temperature 25°C (77°F ), and 30% relative humidity. The fuel consumption data is based on No. 2 diesel fuel weight at 0.85 kg/liter (7.1 lb/U.S. gal). Power output curves are based on the engine operating with fuel system, water pump and lubricating oil pump; not included are b attery charging alternator, fan, optional equipment and driven components. Operation at elevated temperatures for sustained operation above 40°C (104°F), derate 2% per 11°C (1% per 10°F). Prime Power Rating is applicable for supplying continual electrical power at varied load. The following are the Prime Rating parameters: * Prime Power is available for an unlimited number of hours per year in a variable load application. Variable load should not e xceed a 70% average of

the Prime Power rating during any operating period of 250 hours. * The total operating time at 100% Prime Power shall not exceed 500 hours per year. * There is a 10% overload capability for a period of 1 hour within a 12 hour period of operation. Total operating time at 10% o verload shall not exceed

25 hours per year. Continuous Power Rating is applicable for supplying continual power at a constant 100% load for an unlimited number of hours per year. There is no overload capability for this rating. C UMM I NS INC.

Columbus, Indiana 47201 Marine Performance Curve

0 50 100 150 200 250 300 350 400 450 500 550

0 300 600 900 1200 1500 1800 2100 2400 D593005MX03 8456 23Aug 0 6 D(M)-6440a QSK60-D(M)



## Engine Performance Data @ 1800 rpm

OUTPUT POWER FUEL CONSUMPTION

% kW bhp kg/
kW·hr lb/ bhp·hr l/hr U.S. gal/hr

10% OVERLOAD CAPACITY

110 2090 2802 0.207 0.341 509.6 134.6

PRIME POWER

100 1900 2547 0.206 0.340 461.4 121.9

75 1425 1910 0.209 0.344 349.5 92.4

50 950 1274 0.219 0.361 245.1 64.8

25 475 637 0.250 0.412 139.9 37.0

CONTINUOUS POWER

100 N/A N/A N/A N/A N/A N/A Engine Speed Overload Capacity Prime Power

rpm kW bhp kW bhp

1800 2090 2802 1900 2547



### Gross Engine Power Output - kW L/hr



## •

• CERTIFIED: This marine diesel engine conforms with the NOx requirements of the International Maritime Organization (IMO), MARPO L 73/78 Annex VI, Regulation 13 as applicable. D i s p la c e m en t : 59

. 9 li t er [ 36 7 3 i n

. 3 ] k W [ b hp] @ rpm Bore: 159 mm [6.25 in.] Prime Power Rating: 1900 [2547] @ 1800 Str oke: 190 mm [7.48 in.] F u el S y s t e m : Di r ect Inj e ction Cummins H P I-PT A s pi r a t i o n : Tur b o c h a r g e d / L ow T e mp e r a tu r e Aft e r c o ol e d C y l i nd e r s : 16 E x ha u st: D r y

# b* TINITED STATES

ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TRANSPORTATION AND AIR QUALITY WASHINGTON.

DC 20460

CERTIFICATE

OF CONFORMITY
2011 MODEL YEAR

## APPENDIX B: FUEL LOA DING OPERATING PROCE DURES

## Fuel Oil Bunkering Procedure

Fuel Oil Procedure The Master, OIM, Chief Engineer, and the duty licensed engineer(s) are responsible for operating the fuel equipment during all fuel transfers. For fuel oil system details refer to following drawings, Marine P&I D Fuel Oil (F.O.) System

- Hull (Dwg No. 3U

- 2400

- 102) Marine P&I D Fuel Oil (F.O.) System

- Machinery Space (Dwg No. 3U

- 2400

- 103). The functionality and control logic is also explained in Kongsberg’s Functional Design Document for Auxiliary Mac hinery Systems.

Fuel Oil Bunkering FO will be transferred (bunkered) from a supply vessel via FO transfer hoses connected to the loading station. Each loading station has a FO filling manifold located on a platform just above the main
deck. The FO is d irected into storage tanks by manually & remotely lining up the desired FO transfer
valves. When taking fuel from a supply boat, the following procedure should be used. Refer to the GEMS Manual for particulars regarding spill prevention and pollution con trol. When conducting fuel oil transfers in U.S. waters, ensure that the information required by 33 CFR 155.750 is readily available and/or posted.

1. Before taking on fuel, the Master and Chief Engineer shall be notified, and they shall decide how
much fue l will be taken on board and to which tanks the fuel will be directed to.

2. Prior to the fuelling operation, all fuel storage tank(s) shall be sounded to ensure sufficient capacity is available to store the fuel being taken on board.

3. A pre

- transfer conferenc e shall be held between the drillship’s and supply boat’s personnel to establish transfer procedures and to agree on an emergency shutdown procedure. A single point of contact on each vessel shall be determined prior to the transfer, they will be known as the Person In Charge (PIC). A fuel oil transfer check list must be completed before any fuel is transferred. Fuel oil storage tanks shall not be filled more than 90% of capacity (tanks shall not be pressed).

4. Constant communications with the supply boat shall be maintained by the PIC during the entire bunker operation, using an intrinsically safe radio.

5. No “hot” work shall be performed within 10 m (33 ft) of the tanks vents or loading stations.

6. The duty engineer shall ensure day tanks are filled prior to commencing operations. One watch person will be stationed at the main deck loading station together with a Class “B” fire extinguisher and oil absorbent material; the other will be at the fuel meter/filter station to verify the amounts of fuel being trans ferred and to assist as needed. A motorman or engineer will periodically sound the FO storage tanks to ensure that fuel is going to the proper tank and the level is satisfactory.

7. The tank to receive the fuel shall be lined up to the main deck loading stat ion.

8. Radio contact shall now be established with the supply boat; when the boat’s PIC agrees conditions are acceptable for fuel transfer, the bridge will be informed so that the appropriate notices can be posted and announcements made. Once the necessary arrangements are complete, the fuel oil transfer may begin.

9. Notify the supply boat to begin pumping; maintain a watch and radio contact with the supply boat during the entire fuelling operation.

10. FO sampling will be conducted on a continuous basis throughou t the entire fuelling operation. The FO sampling station is located just below the loading station.

### 11. After the fuelling operation is complete, the main deck loading station’s take

- on line vent shall

be opened and the contents of the fuel hose drained back to the supply boat’s tanks.

12. The system shall be secured by closing all valves. Final fuel oil tank soundings are taken to verify quantity transferred.

13. The fuel oil transfer data shall be noted in the drillship’s log book and oil record book.