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 Letter 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 applications 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 comments

no. 1 to 15 except comment no. 11. 

Source Identification

1. The application has identified the main diesel engines (DR-ME-01 through 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 Response: 

The Engine International Air Pollution Prevention (EIAPP) certificates 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 ‘Certificate 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 unit 
Ms. 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 applicant 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 

found 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, the main diesel engines (DR-ME-01 through DR-ME-08) particulate 

matter emissions were calculated using NSPS IIII emission factors and NOx 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 following values in the detailed calculation table are reported as zero: Scenario 

5, NOx 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, NOX 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 NOX 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. The PTE relied on the emission generated from Scenario 5 for NOx 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 PM10, H2SO4 and Lead from 

Scenario 2 emissions. Please clarify what the PTE is for these pollutants.

Anadarko Response:

The 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 PM10, H2SO4 and Lead is provided in Table 1.
Ms. Fortin

Page 3 of 10

Table 1: PM10, H2SO4 and Lead PTE

Pollutant PTE Summary

lb/hr lb/day ton/yr

PM10 2.51E+1 6.02E+2 3.22E+1

Lead 6.71E-3 1.61E-1 1.73E-2

H2SO4 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 to 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 source to meet the stated requirements unless, pursuant to 40 CFR 55.7, 

“the administrator 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 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 infeasible.

Best Available Control Technology (BACT) Analysis
Ms. 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 are 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 evaluation 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 have 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 generated 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 search did not produce any specific results for fugitive components in diesel or distillate 

service. Moreover, the majority of fugitive VOC emissions are expected to occur during the fuel 

loading operations. The fuel loading crew will follow standard operating 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 procedures 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 limited 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 cannot 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 infeasible for 

all BACT subject pollutants.

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 situations for maintenance and readiness testing, resulting emissions are 

minimal (for example, NOx 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 higher 

standards 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 

EcoSilencer®, as an additional control technology for the reduction of particulate matter from 

marine diesel engines. Please update the PM/PM10/PM2.5 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 SO2 in exhaust emissions, 

remove soot particulate, and reduce exhaust noise. As specified in the submitted permit 

application, the proposed project did not trigger BACT analysis for SO2; hence, SO2 emission 
Ms. 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 SO2 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 this 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 research 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. Considering the limited space 

availability on the drillship, it is not possible to accommodate the installation of this control 

technology without significant redesign and 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 operations and are operated 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 technology is considered as technically infeasible for emergency generator, 

emergency air compressor, and other third party engines operated on the drillship. 

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

analysis 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 LATER
Ms. Fortin

Page 7 of 10

Requests 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 operated 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 subject to BACT analysis. 

13. The BACT analysis for the drillship main engines (DR-ME-01 through DR-ME-08) has identified 

control technologies in Step 1 that include Low NOx 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 for the drillship main engines (DR-ME-01 through DRME-08) is developed by Hyundai Heavy Industries (HHI) and it is implemented on HHI engines. 

This system is not available for the emergency generator (DR-GE-01) as the emergency 

generator is manufactured by a different manufacturer (i.e., Cummins.) Hence, the performance 

management system for the drillship main engines is not applicable for the emergency 

generator.

14. Section 5.3 of the application includes the PM/PM10/PM2.5 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. However, 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/PM10/PM2.5 analyses.

Anadarko Response: 

Positive Cranckcase Ventilation (PCV) is an 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/PM10/PM2.5.
Ms. Fortin

Page 8 of 10

Appendix G Specification Sheets

15. This Appendix contains specification sheets for all sources that are associated with this project. 

However, it does not appear to contain specifications for the third party boom flare, (DR-TP23). Please provide a copy of a representative boom flare manufacturer’s specification sheet.

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.)
APPENDIX A: CERTIFICATE OF CONFORMITY FOR EMERGENCY 

GENERATOR AND EMERGENCY AIR COMPRESSOR 
Curve 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 battery 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 exceed 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% overload 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.

 CUMMINS 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 23Aug06

QSK60-D(M) D(M)-6440a

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), MARPOL 73/78 Annex VI, 

Regulation 13 as applicable.

Displacement: 59.9 liter [3673 in.

3] kW [bhp] @ rpm

Bore: 159 mm [6.25 in.] Prime Power Rating: 1900 [2547] @ 1800

Stroke: 190 mm [7.48 in.]

Fuel System: Direct Injection Cummins HPI-PT Aspiration: Turbocharged/Low Temperature Aftercooled

Cylinders: 16 Exhaust: Dry
b*

TINITED STATES ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF TRANSPORTATION AND AIR QUALITY

WASHINGTON. DC 20460

CERTIFICATE OF CONFORMITY

2011 MODEL YEAR
APPENDIX B: FUEL LOADING OPERATING PROCEDURES 
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 Machinery 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 directed 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 control. 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 fuel 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 conference 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 transferred 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 station.

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 throughout 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.