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Offshore OCS General Permit DMRs
Warning: This permit has expired!
Please refer to the reissued 2007 Offshore Permit DMR web page.
Offshore Discharge Monitoring Reports INSTRUCTIONS FOR COMPLETING UPDATED:
February 5, 2005 |
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There are 7 pages of Discharge Monitoring Reports (DMRs) for the OCS Offshore General Permit. The following are the forms in Adobe Acrobat PDF file format:
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The DMRs, for each lease block, are assigned monitoring periods by EPA. There are four monitoring periods. Your monitoring report period, along with your permit number and outfall numbers, will be provided to you when EPA sends a response to your Notice of Intent (NOI) application form confirmation letter. If you previously were covered under the 1998 OCS general permit, your monitoring period will remain the same, except for toxicity. In this new permit, all DMR's have the same reporting period for each permittee, unless you are notified otherwise by EPA. This means most permittees will have a monitoring period that overlaps two permits and you will only have to submit that one DMR for that period. You will not have to submit a final DMR for the 1998 permit and a 2004 DMR for the new permit. The last monitoring period requiring DMR reporting under the 1998 permit is the monitoring period ending September 30, 2004.
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Under the previous permit, the Toxicity DMR's were from July through June of each year for everyone, and that practice has changed with the new permit to simplify reporting so that all DMRs are on a single reporting period for each permittee.
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The DMR, for each lease block, will summarize discharge monitoring for all facilities (platform, drilling ship, or semi-submersible) operated within that lease block during the reporting period. That is, a single DMR report will be submitted for an individual lease area/block. The "single DMR" will consist of 1 page for produced water toxicity requirements and 4 pages for all other reporting requirements (5 pages altogether). Where applicable to an operator, non-aqueous (synthetic) based drilling fluids (a.k.a. SBM) will be reported on a separate DMR which will be 2 pages in length.
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If no discharge occurs within the lease block which is applicable to any individual parameter listed below, the Permittee may indicate "N/D" on the DMR for that parameter. If monitoring is not required for any individual parameter listed below, the Permittee may indicate "N/R" on the DMR for that parameter. Whether reporting "N/D" or "N/R", please do not report anything in the "No EX", "Frequency of Analysis", or "Sample Type" columns.
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If a Notice of Termination (NOT) was submitted for a lease area/block, the Operator must still report that property to the EPA for any period of time the property was held within the monitoring period and up through when EPA received the NOT. The monitoring period on the DMR form is not to be altered. Use the comment field to explain the duration being reported based on the NOT (and date of NOT). Following is an example of a property in which an NOT was submitted. The example lists all DMRs that will be required for that property following its termination. The operator in the example has a DMR submission date of April 28, 20yy.
Part I.A.3. of the permit requires operators to submit their final DMR with teh NOT. As a reminder, operators must submit an original (pen &ink signature) and one legible "copy" of the DMR with their NOT (the same requirement as when asn operator submits their annual DMRs).
The following is an example of a property in which an NOT was submitted. The example lists all DMRs that will be required for that property following its termination. The operator in the example has a DMR submission date of April 28, 20yy.
Mustang Island 51, Outfalls 070A and 070T - Notice of Termination dated September 5, 2005; received by EPA on September 10, 2005. DMRs will be required for these monitoring periods:
Outfall From To Due 070A 04/01/05 03/31/06 04/28/06 070S 04/01/05 03/31/06 04/28/06* 070T 04/01/05 03/31/06 04/28/06
*SBM, if applicable.
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The Permittee must complete all empty blanks in the DMR, unless: 1) a N/D or N/R is being reported for an individual parameter; or, 2) there has been absolutely no activity or no discharge within the lease block for the entire reporting period.
In the case of the latter, EPA Region 6 will accept a listing of lease blocks with no discharge or no activity, in lieu of submitting actual DMRs for these lease blocks. Each page of the listing must provide the following information (in accordance with Part II.D.4 of the permit):
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NPDES general permit number assigned. For example, GMG290078; not GMG290000.
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Area/block description (i.e., Mustang Island 24)
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Outfall number (see Discharge Number on the form). It will be either xxxA, xxxB, xxxC, xxxT, xxxY or xxxZ. The xxxT, xxxY and xxxZ represent the produced water toxicity requirements for an individual lease area; this DMR has only 1 page. NOTE: The xxxT has a corresponding xxxA outfall; the xxxY has a corresponding xxxB outfall; and, the xxxZ has a corresponding xxxC outfall. The xxxA, xxxB and xxxC represent all other reporting requirements for the lease area/block number, except SBM. (For example: Mustang Island 24, Outfalls 001A & 001T.)
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SBM DMRs, if applicable, will have an outfall number of xxxS, xxxR or xxxW (i.e., 001S, 001R, or 001W).
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The operator's assigned monitoring end date (03/30/yy, 06/30/yy, 09/30/yy, or 12/31/yy).
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And, each page of the listing must be signed and certified in accordance with Part II.D.4. and Part II.D.10 of the permit. The entire certification statement (not just portions of it) must be included. The signature is that of the designated responsible official, in accordance with Part II.D.10.a. The signature is to be an original pen&ink; not a photocopy, carbon, or stamped signature.
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Do not use compressed print when preparing the listing. As with the DMR forms, please use font size 10-point/12 characters per inch or larger.
Previous 1998 Permit Schedule | Previous 1998 Permit Toxicity Schedule | 2004 Permit Reporting Schedule for all DMRs |
Jan 1-Dec 31 | Jul 1-Jun 30 | Jan 1-Dec 31 |
Apr 1-Mar 31 | Jul 1-Jun 30 | Apr 1-Mar 31 |
Jul 1-Jun 30 | Jul 1-Jun 30 | Jul 1-Jun 30 |
Oct 1-Sep 30 | Jul 1-Jun 30 | Oct 1-Sep 30 |
TOXICITY DMRs: Under the 1998 permit, permittees should have submitted toxicity DMR's for the monitoring period ending July 31, 2004. If permittees have taken toxicity samples within a year of your 2004 permit DMR monitoring due date, but prior to the effective date of the 2004 permit (November 6, 2004), they may include those sample results in the first DMR monitoring period. For example, if your monitoring period is January 1st to Dececember 31st, and permittees took their sample in June 2004, then they may include those samples in their DMR monitoring period ending December 31, 2004, even though the sample was taken before the permit took effect on November 6, 2004. For this example, this means that if you took a sample in June 2004, you do not have to resample in November or December 2004 for the monitoring period ending December 31, 2004.
The following table and paragraph shows an example of how to report lease areas/blocks with No Discharge/No Activity utilizing the option of reporting via a listing verses the DMR form. As a reminder, only entire lease area/blocks can be on this listing. If any portion of the property had discharge, you must use the DMR form. NOTE: This example has been updated from previous versions of these DMR completion instructions. Be sure to note the changes.
Oil & Gas Company ABC123, GMG29xxxx
Listing of Lease Areas/Blocks with
No Discharge/No Activity
For the monitoring periods ending, as specified
by the MVDT* dates below
Lease Area/Block # | Produced Water Outfall & mvdt=mm/dd/yy | SBM** (if applicable) Outfall & mvdt=mm/dd/yy | All Other Monitoring Requirements Outfall & mvdt=mm/dd/yy |
Mustang Island 24 | 001T | 001S | 001A |
Ewing Bank 985 | 010T | 010S | 010A |
Garden Banks 75 | 045Y | 045R | 045B |
Eugene Island 70 | 079Y | 079R | 079B |
South Timbalier 25 | 100Z | 100W | 100C |
Grand Isle 15 | 175Z | 175W | 175C |
"I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
//signature//
________________________
Printed name of Authorized Official***
Title
Operator Name
*The monitoring end date (MVDT) for SBM, produced water toxicity, and All Other Reporting Requirements is that monitoring period assigned to the operator [e.g., ending 03/31/yy (due 04/28/yy); ending 06/30/yy (due 07/28/yy); ending 09/30/yy (due 10/28/yy); and ending 12/31/yy (due 01/28/yy)]. Note: be sure to record only the monitoring end date in each column, not the DMR due date.
** SBM represents non-aqueous (synthetic) based drilling fluids [or synthetic based muds (SBM) for short].
***Authorized Official is defined in Part II.D.10. of the permit and 40 CFR 122.22. Someone of lesser authority may be designated by an Authorized Official if a delegation letter is submitted to EPA Region 6.
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Operators must return the original and one carbon (or legible photocopy of the original) of the DMR to the following address.
If the DMR package is a standard envelope or small box, mail them to:
Ms. Sharon Haggard (6EN-WC)
U.S. Environmental Protection Agency
Compliance Assurance and Enforcement Division
P.O. Box 50625
Dallas, TX 75250-0625
If the DMR package is a heavy envelope/large box, please mail to:
Ms. Sharon Haggard (6EN-WC)
U.S. Environmental Protection Agency
Compliance Assurance and Enforcement Division
1445 Ross Avenue
Dallas, TX 75202-2733
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Offshore Operators Committee (OOC) DMR Form:
The OOC has created a Microsoft Excel version of the DMR to reflect the reissued permit of 2004. Operators who had authorization to use the OOC DMR form under the previous 1998 permit will have to resubmit an authorization request under the current permit.
Operators should submit a written request to EPA (at the address noted above) approximately 90 days prior to their DMR submission date for authorization to use the forms. EPA will review the request, then send a letter of authorization to that operator. Approximately 30 days prior to an operator's DMR submission date, EPA will send the operator a listing of properties that must be reported and the monitoring periods to be inserted on the DMR form.
To ensure an operator does not have their authorization revoked, please refer to Section V of these instructions for "Tips and Hints for Using OOC DMR Forms".
Operators can access the OOC form from the OOC or from the EPA Region 6 Offshore web page (www.epa.gov/region6/offshore).
EPA Online-DMR form: Operators who elect to use this form should submit a letter or e-mail to Ms. Sharon Haggard (6EN-WC) or haggard.sharon@epa.gov at least 90 days prior to usage. Approximately 30 days prior to an operator's DMR submission date, EPA will send the operator a listing of properites that must be reported and the monitoring periods to be inserted in the DMR form.
II. PERMIT LIMITATIONS
A description of the information to be reported on the DMR is as follows:
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PRODUCED WATER
- Produced Water, Toxicity (7-Day Minimum) - Mysidopsis bahia (Storet code TLP3E) and Menidia Beryllina (TLP6B): If the lowest NOEC value for survival is less than the critical effluent dilution, enter a "1"; otherwise, enter a "0"
- Produced Water, Toxicity (Monthly Avg. Minimum) - Mysidopsis bahia (Storet code TLP3E) and Menidia Beryllina (TLP6B): If the lowest NOEC value for survival is less than the critical effluent dilution, enter a "1"; otherwise, enter a "0".
- Produced Water, Survival (7-Day Minimum) - Mysidopsis bahia (Storet code TOP3E) and Menidia Beryllina (TOP6B): Report the NOEC value for survival.
- Produced Water, Survival (Monthly Avg. Minimum) - Mysidopsis bahia (Storet code TOP3E) and Menidia Beryllina (TOP6B): Report the NOEC value for survival.
- Produced Water, Growth (7-Day Minimum) - Mysidopsis bahia (Storet code TPP3E) and Menidia Beryllina (TPP6B): Report the NOEC value for growth.
- Produced Water, Growth (Monthly Avg. Minimum) - Mysidopsis bahia (Storet code TPP3E) and Menidia Beryllina (TPP6B): Report the NOEC value for growth.
- Produced Water, Whole Effluent Toxicity (7-Day Minimum) (Storet code 22414): Report the lowest Whole Effluent Lethality value for either species.
- Produced Water, Whole Effluent Toxicity (Monthly Ave. Minimum) (Storet code 22414): Report the lowest Whole Effluent Lethality value for either species.
- Produced Water, Oil & Grease (Monthly Avg) (Storet code 82599): Enter the highest monthly average measurement (mg/L) for any particular month during the reporting period.
- Produced Water, Oil & Grease (Daily Max) (Storet code 82599): Enter the highest daily average measurement (mg/L) recorded during the reporting period.
- Produced Water, Flow (Storet code 82600): Enter the highest monthly average flow rate (barrels per day) recorded in any particular month during the reporting period.
- Produced Water, Free Oil (Storet code 79834): Enter the highest number of days in which sheens
were observed in any particular month during the
reporting period.
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DRILLING FLUIDS
- Drilling Fluids, End of Well Toxicity (Storet code 04311) Enter the lowest daily average 96-hour LC-50 recorded during the reporting period.
- Drilling Fluids, Toxicity (Monthly Avg) (Storet code 04312) Enter the lowest monthly average 96-hour LC-50 recorded for any particular month during the reporting period.
- Drilling Fluids, Toxicity (Daily Min) (Storet code 04312) Enter the lowest daily average 96-hour LC-50 recorded during the reporting period.
- Drilling Fluids, Free Oil (Storet code 82589) Enter the highest number of days in which sheens were observed in any particular month during the reporting period.
- Drilling Fluids, Discharge Rate (Storet code 82592) Enter the maximum drilling fluid discharge rate (barrels per hour) recorded during the reporting period.
- Cadmium in Barite (Storet code 78244) Enter the highest concentration of cadmium in milligrams per kilogram of barite (dry weight) for stock barite added to discharged drilling fluids.
- Mercury in Barite (Storet code 78245) Enter the highest concentration of mercury
in milligrams per kilogram of barite (dry weight)
for stock barite added to discharged drilling
fluids.
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WELL FLUIDS
- Well Fluids, Oil & Grease (Monthly Avg) (Storet code 04379) Enter the highest monthly average measurement (mg/L) for any particular month during the reporting period.
- Well Fluids, Oil & Grease (Daily Max) (Storet code 04379) Enter the highest daily average measurement (mg/L) recorded during the reporting period.
- Well Fluids, Free Oil (Storet code 82603) Enter the highest number of days in which
sheens were observed in any particular month during
the reporting period.
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DRILL CUTTINGS
- Drill Cuttings, Free Oil (Storet code 82595) Enter the highest number of days in which
sheens were observed in any particular month during
the reporting period.
- Drill Cuttings, Free Oil (Storet code 82595) Enter the highest number of days in which
sheens were observed in any particular month during
the reporting period.
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DECK DRAINAGE
- Deck Drainage, Free Oil (Storet code 82597) Enter the highest number of days in which
sheens were observed in any particular month during
the reporting period.
- Deck Drainage, Free Oil (Storet code 82597) Enter the highest number of days in which
sheens were observed in any particular month during
the reporting period.
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SANITARY WASTE
- Sanitary Waste, Residual Chlorine (Storet code 82605) For facilities continuously manned by 10 or more persons, enter the lowest measurement (mg/L) recorded during the reporting period, unless the facility properly operates and maintains a Marine Sanitation Device (MSD) that complies with pollution control standards and regulations under section 312 of the Act. The MSD shall be tested yearly for proper operation and test results maintained for three years at the facility. If the facility properly operates an MSD, then report "N/R" on the DMR.
- Sanitary Waste, Solids (Storet code 82607) For all facilities, enter the highest number of days in which solids
were observed in any particular month during the
reporting period, unless the facility properly operates and maintains a MSD that complies with pollution control standards and regulations under section 312 of the Act. The MSD shall be tested yearly for proper operation and test results maintained for three years at the facility. If the facility properly operates an MSD, then report "N/R" on the DMR.
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DOMESTIC WASTE
- Domestic Waste, Solids (Storet code 82608) Enter the highest number of days in which
solids were observed in any particular month during
the reporting period.
- Domestic Waste, Solids (Storet code 82608) Enter the highest number of days in which
solids were observed in any particular month during
the reporting period.
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MISCELLANEOUS DISCHARGES
- Miscellaneous, Free Oil (Storet code 04239) Enter the highest number of days in which sheens were observed in any particular month during the reporting period.
- Miscellaneous Discharges, Flow (Storet code 74076) Enter the estimated number of barrels per day of chemically treated discharges.
- Miscellaneous Discharges, Toxicity (48-Hour
Min):
- For Mysidopsis Bahia (Storet code TEM3E)
and Menidia (Storet code TEM6B): The lowest NOEC value determined during the 48-Hour test
period is the "48-Hr. NOEC value." Enter the number "1" if any daily average 48-Hr. NOEC value recorded during the reporting period is less than the allowable critical dilution as determined by Table 2 of the permit; otherwise, enter the number "0". - For Mysidopsis Bahia (Storet code TOM3E) and Menidia (Storet code TOM6B): Report the lowest NOEC value.
- For Mysidopsis Bahia (Storet code TEM3E)
and Menidia (Storet code TEM6B): The lowest NOEC value determined during the 48-Hour test
- Miscellaneous Discharges, Toxicity (48-Hour
Monthly Avg Min):
- For Mysidopsis Bahia (Storet code TEM3E)
and Menidia (Storet code TEM6B): The lowest NOEC value determined during the 48-Hour test
period is the "48-Hr. NOEC value."
Enter the number "1" if the average
of all 48-Hr. NOEC values for any particular
month during the reporting period is less than
the allowable critical dilution as determined
by Table 2 of the permit; otherwise, enter the
number "0".
- For Mysidopsis Bahia (Storet code TEM3E)
and Menidia (Storet code TEM6B): The lowest NOEC value determined during the 48-Hour test
period is the "48-Hr. NOEC value."
Enter the number "1" if the average
of all 48-Hr. NOEC values for any particular
month during the reporting period is less than
the allowable critical dilution as determined
by Table 2 of the permit; otherwise, enter the
number "0".
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STOCK LIMITS FOR DRILL CUTTINGS GENERATED USING NON-AQUEOUS BASED DRILLING FLUIDS - "STOCK BASE FLUID" on the DMR. (See Part I.B.2.1. of the permit)
- Polynuclear Aromatic Hydrocarbons (PAH) (Storet
code 51114) Enter the maximum ratio
of grams of PAH per gram of base fluid. Measurement
frequency is once-per-year and the maximum ratio
is 0.00001. Sample type: PAH content of Oil by
High Performance Liquid Chromatography with Ultraviolet
Detector, EPA Method 1654 (see 40 CFR 435.11(u)).
See Parts I.B.2.c.1. and I.D.10. of the permit.
- Sediment Toxicity (Storet code 51115) Enter the maximum ratio of the C16-C18
internal olefin (or C12-C14 or C8 ester reference
fluid) LC50 to stock base fluid LC50 sediment
toxicity test with Leptocheirus plumulosus of base fluid. The monitoring frequency is once-per-year
on each base fluid blend using ASTM method E1367-99
(see Part I.D.8. of the permit). The ratio of
the 10-day LC50 of C16-C18 internal olefin divided
by the 10-day LC50 of the base fluid shall not
exceed 1.0. See Part I.B.2.c.1. of the permit.
- Biodegradation Rate (Storet code 51116) Enter the maximum ratio of the cumulative
gas production (ml) of C16-C18 internal olefin
or C12-C14 or C8 ester reference fluid divided
by the cumulative gas production (mL) of stock
base fluid, both at 275 days. This ratio shall
not exceed 1.0 and monitoring shall be performed
once-per-year on each base fluid blend. See Parts
I.D.9. and I.B.2.c.1. of the permit.
Exception: Until February 1, 2003, a blend of different non-aqueous base fluids may be considered compliant with the biodegradation rate limit if the weighted average of the base fluids' biodegradation rate is greater than that of the C16-C18 internal olefin standard tested concurrently. If you are blending different non-aqueous based fluids, add a remark in the "Comments and Explanation of Violations" section at the bottom of the DMR noting the base fluids were blended.
- Polynuclear Aromatic Hydrocarbons (PAH) (Storet
code 51114) Enter the maximum ratio
of grams of PAH per gram of base fluid. Measurement
frequency is once-per-year and the maximum ratio
is 0.00001. Sample type: PAH content of Oil by
High Performance Liquid Chromatography with Ultraviolet
Detector, EPA Method 1654 (see 40 CFR 435.11(u)).
See Parts I.B.2.c.1. and I.D.10. of the permit.
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DISCHARGE LIMITS FOR CUTTINGS GENERATED USING NON-AQUEOUS (SYNTHETIC) BASED DRILLING FLUIDS - "DISC. DRILL CUTTING" on the DMR. (See Part I.B.2.2.of the permit)
- Sediment Toxicity (Storet code 51117) Enter the ratios of the 4-day LC50 of C16-C18
internal olefin reference drilling fluid divided
by the 4-day LC50 of the drilling fluids removed
from cuttings at the solids control equipment.
The ratios shall not exceed 1.0 for each monitoring
period or it will be a violation. Monitoring shall
be performed at least once-per-month on drilling
fluids which meet the stock limitations for C16-C18
internal olefin. The final monthly sample shall
be collected at the end of drilling with non-aqueous
based drilling fluids. For drilling fluids which
meet stock limitations for C12-C14 ester or C8
ester, monitoring shall be performed at least
once-per-well at the end of drilling with non-aqueous
based drilling fluids. (See Appendix A of the
permit.) The reference drilling fluid shall be
formulated from C16-C18 internal olefin and meet
the criteria listed in Table 1 of 40 CFR Part
435, Subpart A, Appendix 8. A uniform emulsifier
package shall be used for all formulations of
reference drilling fluids.
- There will be two entries on the DMR form
for reporting.
- The first entry will be denoted "P"
and will be the monthly maximum ratio
for stock limitations for C16-C18 internal
olefin. Put "N/R" in the field
if it's not required; do not leave it
blank.
- The second entry will be denoted "R"
and will be the once-per-well at the end
of drilling maximum ratio for all stock
(C16-C18 internal olefin, C12-C14 ester
or C8 ester).
- The first entry will be denoted "P"
and will be the monthly maximum ratio
for stock limitations for C16-C18 internal
olefin. Put "N/R" in the field
if it's not required; do not leave it
blank.
- There will be two entries on the DMR form
for reporting.
- Formation Oil (Storet code 51118)
Monitoring for the presence of formation oil shall
be performed once prior to drilling using the
gas chromatography/mass spectrometry (GC/MS) test
method specified in Part I.D.11. of the permit.
Alternatively, the permittee may provide certification,
as documented by the supplier(s), that the drilling
fluid being used on the well will meet the "no
discharge" limit for formation oil. Also,
monitoring shall be performed once-per-week during
drilling using the Reverse Phase Extraction (RPE)
test method specified in Part I.D.12. of the permit.
- There will be two entries on the DMR form
for reporting.
- The first entry will be denoted "S"
and will be the initial sample prior to
drilling using the GC/MS. Report a "0"
if the sample passes (no formation oil
in sample) or a "1" if it fails
(formation oil found in sample). The pass/fail
is to be reported whether it is certified
by you based on your data or on the suppliers
data. Either way you must maintain certification
in your records.
- The second entry will be denoted "T"
and will be the maximum weekly sample
using the RPE test method (or the GC/MS) and shall be
reported as "0" if the sample passes
(no formation oil in sample) or "1"
if it fails (formation oil found in sample).
The permit requires you to
perform the weekly RPE test; and, it may
be substituted with the GC/MS test.
- The first entry will be denoted "S"
and will be the initial sample prior to
drilling using the GC/MS. Report a "0"
if the sample passes (no formation oil
in sample) or a "1" if it fails
(formation oil found in sample). The pass/fail
is to be reported whether it is certified
by you based on your data or on the suppliers
data. Either way you must maintain certification
in your records.
- There will be two entries on the DMR form
for reporting.
- Base Fluids Retained on Cuttings (Storet
code 51120) Monitoring shall be performed
at least once-per-day when generating new cuttings,
except when meeting the conditions of the Best
Management Practices (BMP) described below. Operators
conducting fast drilling (i.e. greater than 500
linear feet advancement of the drill bit per day
using non-aqueous fluids) shall collect and analyze
one set of drill cuttings sample per 500 linear
feet drilled, with a maximum of three sets per
day. Operators shall collect a single discrete
drill cuttings sample for each point of discharge
to the ocean. The weighted average of the results
of all discharge points for each sampling interval
will be used to determine compliance (see Part
I.D.13. of the permit).
- Drill fluids which meet stock limitations
for C16-C18 internal olefin: the end-of-well
maximum weighted mass ratio averaged over
all well sections drilled using non-aqueous
fluids shall not exceed 6.9 grams non-aqueous
based fluids per 100 grams of wet drill cuttings.
- Drill fluids which meet stock limitations
for C12-C14 ester or C8 ester: the end-of-well
maximum weighted mass ratio averaged over
all well sections drilled using non-aqueous
fluids shall not exceed 9.4 grams non-aqueous
base fluids per 100 grams of wet drill cuttings.
- Drill fluids which meet stock limitations
for C16-C18 internal olefin: the end-of-well
maximum weighted mass ratio averaged over
all well sections drilled using non-aqueous
fluids shall not exceed 6.9 grams non-aqueous
based fluids per 100 grams of wet drill cuttings.
- There are three entries on the DMR form for
reporting:
- The first entry s denoted "U"
and is the daily average for drilling fluids
which meet stock limitations for C16-C18 internal
olefin, end-of-well maximum weighted mass
ratio averaged over all well sections drilled
using non-aqueous fluids per 100 grams of
wet drill cuttings.
- The second entry is denoted "V"
and is the daily maximum for drill fluids
which meet stock limitations for C12-C14 ester
or C8 ester, end-of-well maximum weighted
mass ratio averaged over all well sections
drilled using non-aqueous fluids per 100 grams
of wet drill cuttings.
- The third entry is denoted "W"
is to be reported as "0" for "yes"
if you are meeting all the conditions of the
BMPs or it is to be reported "1" for "no"
if you are not meeting all the conditions
of the BMPs, or "N/R" if you are not using a BMP.
- The first entry s denoted "U"
and is the daily average for drilling fluids
which meet stock limitations for C16-C18 internal
olefin, end-of-well maximum weighted mass
ratio averaged over all well sections drilled
using non-aqueous fluids per 100 grams of
wet drill cuttings.
- Sediment Toxicity (Storet code 51117) Enter the ratios of the 4-day LC50 of C16-C18
internal olefin reference drilling fluid divided
by the 4-day LC50 of the drilling fluids removed
from cuttings at the solids control equipment.
The ratios shall not exceed 1.0 for each monitoring
period or it will be a violation. Monitoring shall
be performed at least once-per-month on drilling
fluids which meet the stock limitations for C16-C18
internal olefin. The final monthly sample shall
be collected at the end of drilling with non-aqueous
based drilling fluids. For drilling fluids which
meet stock limitations for C12-C14 ester or C8
ester, monitoring shall be performed at least
once-per-well at the end of drilling with non-aqueous
based drilling fluids. (See Appendix A of the
permit.) The reference drilling fluid shall be
formulated from C16-C18 internal olefin and meet
the criteria listed in Table 1 of 40 CFR Part
435, Subpart A, Appendix 8. A uniform emulsifier
package shall be used for all formulations of
reference drilling fluids.
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SEABED SURVEYS (Storet codes 51121, 51122 & 51123) - (See Part I.B.2.3. of the permit)
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Operators who discharge drill cuttings which are generated using non-aqueous drilling fluids shall conduct seabed surveys at each location where such a discharge occurs. Results of the seafloor surveys shall be submitted to EPA, Region 6 with the DMR no later than two (2) years after completion of drilling operations at the site. Monitoring shall be conducted twice at each site where drill cuttings generated using non-aqueous drilling fluids are discharged. The first survey is required to commence within two (2) weeks after completion of drill operations. A second survey shall be accomplished one (1) year after commencement of the first survey. Alternatively, operators required to conduct seafloor surveys under the permit may submit a plan for an equivalent industry-wide seafloor monitoring study to EPA Region 6 for approval.
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There are three entries on the DMR form for reporting:
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The first entry is to report whether the permittee is participating in the industry-wide seafloor monitoring study for EPA Region 6. If the permittee is a participant and EPA Region 6 has approved the industry-wide seafloor report, then report "0" for "yes". If not, report "1" for "no". The monitoring frequency is once-per-well.
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The second entry is to report if the first survey commenced within two (2) weeks after completion of drilling operations. Enter a "0" for "yes" if you commenced the first survey within two (2) weeks after completion of drilling operations or else enter a "1" for "no" if you did not commence the first survey within two (2) weeks after completion of drilling operations. If you are a participant in the industry-wide seafloor monitoring study and EPA Region 6 has approved the industry-wide study, then report "N/R" for "not required".
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The third entry is to report if the second survey was accomplished within one (1) year after commencement of the first survey. Enter a "0" for "yes" if you accomplished the second survey within one (1) year after commencement of the first survey or else enter a "1" for "no" if you did not accomplish the second survey within one (1) year after commencement of the first survey. If you are a participant in the industry-wide seafloor monitoring study and EPA Region 6 has approved the industry-wide study, then report "N/R" for "not required".
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III. OTHER REQUIREMENTS
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Number of Exceedances (No Ex) Enter the total number of exceedances of sample measurements during the monitoring period that exceed maximum (and/or minimum or 7-day average as appropriate) permit requirement for each parameter. If none, enter "0".
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Frequency of Analysis Enter the maximum frequency of sampling or observation performed for each parameter during the reporting period.
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Sample Type Enter the actual sample taken, regardless of the permit requirement.
For any questions about DMR completion or reporting, please call Mr. Robert Houston, Enforcement Officer (6EN-WM) at (214) 665-8565 or e-mail him at houston.robert@epa.gov.
For any questions regarding lease block coverage, please call Ms. Sharon Haggard, Offshore Specialist (6EN-WC) at (214) 665-6472 or e-mail her at haggard.sharon@epa.gov.
IV. COMMON REPORTING ERRORS
The following represent common reporting errors found on DMRs (and No Discharge/No Activity Listings) when operators submit them to the EPA. Please ensure that you carefully review your documents before submitting them to the EPA. Errors in reporting delay the process of information and result in operators resubmitting the reports to include corrected data. Errors may also result in potential enforcement actions.
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DMR Copies: Failure to submit the original and/or one legible copy. Two copies are required: the original with pen-&-ink signature; the second a legible copy of the original.
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Decimals/Commas: Please be careful when reporting sample measurement data where decimals or commas are used. Make sure commas and decimals are clearly distinguishable.
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Sample measurement data: Sample measurement data has incorrectly been reported on the DMR as a number with an error range. For example: 65+7 or 138+14. You are to report only one number, without any error ranges. Also, if a parameter is being reported with the value as greater or lesser than, please use the "<" or ">" symbols. Do not report the information as "=31,000", or "-31,000", or "±31,000".
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Signature: Each page of the DMR must be signed. The signature must be pen&ink; not pencil or a photocopy or a carbon copy or a stamped signature.
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"Remarks" or "Comments": If you need to provide remarks or comments on the DMR, please confine them to the bottom of the DMR form. Do not state "remarks (1)" or "see comments" in the sample measurement fields. Use a footnote indicator instead, but be sure it is separated from the sample measurement data.
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Corrections on DMRs: When a correction is necessary, please strike out the incorrect data and insert the correct information legibly; this applies to all carbons being submitted as well. Often times, the corrected data is written over top of the incorrect data; it is difficult to discern which is the correct information. Be sure to initial the change.
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Frequency of Analysis and Sample Type: Attached is a listing of frequency of analysis and sample types available for use in reporting data. If you report a frequency of analysis or sample type not indicated on the listing, please use the bottom of the DMR to explain the information you are reporting. For example: a frequency of analysis has been reported as "20/12" and the permit requirement is "once/month". Since "20/12" is not on the attached listing, please explain what "20/12" means at the bottom of the DMR. Or another example is: a frequency of analysis has been reported as "33" or "8" or "once" and the permit requirement is once/month or daily. What is "33" and what is "8", and what is "once"?
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No Ex, Frequency of Analysis, Sample Type: These blocks are to remain blank if the parameter is being reported as "N/D" (no discharge), "N/R" (not required), or "N/A" (no activity).
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"No Discharge Block" in upper right corner of DMR: This block is to be used only if the entire lease area is being reported as No Discharge. Also, do not use this block if the parameters on an individual page of the DMR happen to be No Discharge. Properties that had no discharge can be reported via a listing, per Part II.D.4. If you choose to submit a listing, do not send the DMR. Also, be sure that if you list a lease area as No Discharge/No Activity, that the corresponding DMR is not also submitted with sample measurement data; this is a conflict of data and the two reports cancel each other. See using a listing method. Section I of this document for an example of how to prepare a No Discharge / No Activity listing.
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Sample measurement data: If a parameter is being reported with the value as greater or lesser than, please use the < > symbols. Do not report the information as "+31,000" or "-31,000".
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QC data: Be sure to review each page of the DMR to ensure all required information has been reported. Often times, a single parameter has been overlooked and the information not reported.This results in a non-reporting violation.
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Conflict of data: Do not report a measurement value in the sample measurement field of a parameter then state "N/D" or "N/A" in the frequency of analysis and sample type fields. "N/D" and "N/A" mean no discharge and no activity which are in conflict with sample measurement data being reported. EPA cannot assume what you are reporting; therefore, the data is considered invalid as one item cancels the other.
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Font size: Do not use compressed print when reporting information to the EPA. Use a font size of 10-point/12 characters per inch or larger. The information on the DMR is read and keyed to EPA's database by a human and must be legible and of a size so as to not cause eye strain.
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Alterations on Preprinted DMRs: Do not alter the preprinted information on the DMR form without express permission from the EPA. For example, a lease area was terminated within the reporting period of "01/01/05 to 12/31/05". The termination date was February 14, 2005. Do not alter the monitoring period of the DMR form to state "From 01/01/05 To 02/14/05". Use the bottom of the DMR or a separate sheet to explain.
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"No Ex" Number of Excursions: This field is to be used to report the number of sample measurements during the monitoring period that exceed a maximum (and/or minimum or 7-day average as appropriate) permit requirement for each parameter. If none, enter "0". If the parameter is no discharge or no activity, then leave it blank.
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Supporting documents: All supporting documents to the DMR (i.e., a listing of No Discharge/No Activity, non-compliance reports, supplemental information, etc.) must contain the following basic elements of information.
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Name and address of the operator
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NPDES permit number assigned (i.e., GMG290078; not GMG290000)
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Lease area/block number
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Outfall number
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Certification statement, in its entirety
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Signature of the responsible corporate official (pen & ink)
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V. Tips and Hints for Using OOC DMR Forms
To ensure the success of the OOC DMR forms, please avoid the following common reporting errors EPA has found, to date, in operator's usage of the OOC DMR forms. Incorrect usage of the forms may result in an operators authorization to use them being revoked.
- Incorrect monitoring periods
- Incorrect outfall numbers (see "Discharge Number" on the form).
- Operators are not consistently ensuring the outfall number recorded on their DMR is what EPA had assigned to that lease area/block being reported.
- Operators are not recording the full outfall number, as assigned by EPA. The outfall number must include the three numeric figures followed by the alpha character, with no spaces between any of the four characters (i.e., 001A; not 10, or 10A, or 10 A).
- NOTE: If you are awaiting an outfall number assignment, please leave this section of the DMR blank and EPA will insert the outfall number. Be sure to note at the bottom of the DMR, "Outfall Number Assignment Pending".
- Reporting the identification of the lease area/block in various locations on the DMR form. The correct location is the upper right corner above the words "No Discharge".
- Failure to report all required elements on the DMR (i.e., sample measurement data for each parameter, Number of Excursions (NO EX), Frequency of Analysis, Sample Type, etc.).
- Checking the "No Discharge" block on the form when sample measurement data is also reported. The "No Discharge" block is only to be used when the entire lease area/block is "No Discharge".
- Failure to sign all pages of the DMR form.
- Failure to submit DMRs for all properties held (for any period of time) within the monitoring period.
- Failure to submit two (2) copies of the DMR in accordance with these DMR completion instructions (that is, one with an original pen-&-ink signature; the other a legible "copy" of the original)
Please refer to Section I of this document when reporting those properties that were "No Discharge/No Activity" during the monitoring period. Again, only properties where the entire lease area/block were no discharge can be recorded on this listing.
VI. Acronyms
BMP | Best Management Practices |
CFR | Code of Federal Regulations |
DMR | Discharge Monitoring Report |
MVDT | Monitoring End Date |
NOI | Notice of Intent |
NOT | Notice of Termination |
N/D | No Discharge |
N/A | No Activity |
N/R | Not Required |
OOC | Offshore Operators Committee |
RPE | Reverse Phase Extraction |
SBM | Synthetic Based Muds |
IO | Internal Olefin |
xxxA | Outfall A (i.e., 001A) - All Other Reporting Requirements |
xxxB | Outfall B (i.e., 001B) - All Other Reporting Requirements - only used if more than 999 outfalls |
xxxC | Outfall C (i.e., 001C) - All Other Reporting Requirements - only used if EPA runs out of B outfalls |
xxxR | Outfall R (i.e., 001R) - Synthetic Based Muds - only used if more than 999 outfalls |
xxxW | Outfall W (i.e., 001W) - Synthetic Based Muds - only used if EPA runs out of R outfalls |
xxxS | Outfall S (i.e., 001S) - Synthetic Based Muds |
xxxT | Outfall T (i.e., 001T) - Produced Water Toxicity |
xxxY | Outfall Y (i.e., 001Y) - Produced Water Toxicity - only used if more than 999 outfalls |
xxxZ | Outfall Z (i.e., 001Z) - Produced Water Toxicity - only used if EPA runs out of Y outfalls |
VII. Frequency of Analysis & Sample Type Tables
To assist operators in completing the frequency of analysis and sample type columns on the DMR, please see the following charts which reflect the current EPA descriptin of codes (i.e., "Weekly" would be reflected as "01/07"; "Grab" as "GR").
SAMP | Sample Types Description |
AH | HRDALL |
CA | CALCTD |
CG | CMPGRB |
CN | CONTIN |
CP | COMPOS |
CR | CK REQ |
CS | CORSAM |
CT | CERTIF |
CU | CURVE |
DA | DAILAV |
DS | DISCRT |
ES | ESTIMA |
FI | FLOIND |
GH | 4GR24H |
GM | GRAB10 |
GR | GRAB |
G2 | GRAB-2 |
G3 | GRAB-3 |
G4 | GRAB-4 |
G5 | GRAB-5 |
G6 | GRAB-6 |
G7 | GRAB-7 |
G8 | GRAB-8 |
G9 | GRAB9 |
IM | IMERSN |
IN | INSTAN |
IS | INSITU |
IT | IMRSTB |
MC | MATHCL |
MF | MAGFLO |
MP | MATHCP |
MS | MEASRD |
MT | METER |
NA | NOT AP |
NR | NOTRPT |
OC | OCCURS |
PC | PMPCRV |
PL | PMPLOG |
RC | RCORDR |
RD | RNG-DA |
RF | RCDFLO |
RG | RANG-C |
RP | REPRES |
RT | RCOTOT |
R4 | RNG-4A |
SB | SQBCHR |
SE | SNGLES |
SM | SUMATN |
SR | SGLRDG |
SS | STAT-SH |
ST | STATIC |
S1 | SQBTH1 |
S2 | SQBTH2 |
S3 | SQBTH3 |
TI | TIMEMT |
TM | TOTALZ |
UN | UNKNWN |
VI | VISUAL |
WE | WEIR |
01 | COMP-1 |
02 | COMP-2 |
03 | COMP-3 |
04 | COMP-4 |
05 | COMP-5 |
06 | COMP-6 |
07 | COMP-7 |
08 | COMP-8 |
1H | AVG-1H |
10 | COMP10 |
12 | COMP12 |
16 | COMP16 |
2H | AVG-2H |
20 | COMP20 |
22 | BATCH |
24 | COMP24 |
28 | COMP28 |
3G | 3GR/HR |
4C | 4DA24C |
4H | AVG-4H |
5G | 5GR45M |
72 | COMP72 |
96 | COMP96 |
99 | COMPWK |
Frequency of Analysis | Description | |
N/A | NOT | APPLIC |
N/R | NOT | REPORTD |
N/V | NOT | VALID |
AL/EV | ALL | EVENTS |
AL/RN | ALTRNT | RUN |
BI/WK | BI- | WEEKLY |
CL/OC | CLRNTN | OCCURS |
DL/DS | DLYWHN | DISCHG |
ED/WL | END OF | WELL |
ESTMT | ESTI- | MATE |
EV/2H | EVERY | 2 HRS |
LF/PT | LIFE/ | PERMIT |
MEASD | MEA- | SURED |
MM/WD | MNTHLY | WHNDIS |
N/R | NOT | RPROTD |
REPRT | REPORT | |
WH/DS | WHEN | DISCHG |
WH/MM | MEASRD | WHNMON |
01/BA | ONCE/ | BATCH |
01/BD | ONCE | BFRDIS |
01/DD | ONCE/ | DSCHDY |
01/DM | ONCE/ | DSCHMN |
01/DQ | ONCE/ | DSCQTR |
01/DS | ONCE/ | DISCHG |
01/DW | ONCE/ | DSCHWK |
01/EP | ONCE | PMTCYC |
01/EV | ONCE/ | EVENT |
01/HR | ONCE/ | HOUR |
01/HV | ONCE/ | HARVST |
01/OC | ONCE/ | OCURNC |
01/PR | ONCE/ | PMTCYC |
01/RN | ONCE/ | RN EVT |
01/RP | ONCE/ | PRT PD |
01/SH | ONCE/ | SHIFT |
01/SN | ONCE/ | SEASON |
01/WD | ONCE/ | WKDAY |
01/WL | ONCE/ | WELL |
01/YR | ANNUAL | |
01/01 | DAILY | |
01/02 | ONCE/ | 2 DAYS |
01/03 | ONCE/ | 3 DAYS |
01/04 | ONCE | 4 DAYS |
01/05 | ONCE/ | 5 DAYS |
01/06 | ONCE/ | 6 DAYS |
01/07 | WEEKLY | |
01/08 | ONCE/ | 8 DAYS |
01/09 | ONCE/ | 9 DAYS |
01/10 | ONCE/ | 10DAYS |
01/11 | ONCE/ | 11DAYS |
01/12 | ONCE/ | 12DAYS |
01/13 | ONCE/ | 13DAYS |
01/14 | ONCE/ | 2 WKS |
01/2Y | ONCE/ | 2 YRS |
01/21 | ONCE/ | 2 WKS |
01/28 | ONCE/ | 4WKS |
01/3H | ONCE/ | 3 HRS |
01/30 | ONCE/ | MONTH |
01/4M | ONCE | 4 MNTS |
01/4Y | ONCE | 4 YRS |
01/5M | ONCE/ | 5 MNTS |
01/5Y | ONCE/ | 5 YRS |
01/6M | ONCE/ | 6 MNTS |
01/60 | ONCE/ | 2 MNTS |
01/7M | ONCE/ | 7 MNTS |
01/8H | ONCE/ | 8 HRS |
01/90 | QTRLY | |
01/99 | INSTNT | |
02/BA | TWICE/ | BATCH |
02/DA | 2DAYS/ | WEEK |
02/DD | TWICE/ | DRWDOWN |
02/DM | TWICE/ | MONTH |
02/DS | TWICE/ | DISCH |
02/DW | TWICE/ | DSCHWK |
02/HR | TWICE/ | HOUR |
02/RP | TWICE/ | RTP PD |
02/SH | TWICE/ | SHIFT |
02/SN | TWICE/ | SEASON |
02/YR | SEMI- | ANNUAL |
02/01 | TWICE/ | DAY |
02/07 | TWICE/ | WEEK |
02/12 | TWICE/ | 12DAYS |
02/30 | TWICE/ | MONTH |
02/5Y | TWICE/ | 5 YRS |
02/57 | TWICE/ | 5 YRS |
02/90 | TWICE/ | QTR |
02/99 | SEE | PERMIT |
03/BA | THREE/ | BATCH |
03/DS | THREE/ | DISCHG |
03/DW | 3DAYS | WEEK |
03/RP | THREE/ | PRT PD |
03/YR | THREE/ | YEAR |
03/01 | THREE/ | DAY |
03/05 | THREE/ | 5 DAYS |
03/07 | THREE/ | WEEK |
03/08 | THREE/ | 8 DAYS |
03/12 | 3 PER | 12 HRS |
03/30 | THREE/ | MONTH |
03/5Y | THREE/ | 5 YRS |
03/6M | THREE/ | 6 MNTS |
03/90 | THREE/ | QTR |
03/99 | SEE | PERMIT |
04/BA | FOUR/ | BATCH |
04/HR | 4 TMS/ | HOUR |
04/RP | FOUR/ | PRT PD |
04/YR | FOUR/ | YEAR |
04/01 | FOUR/ | DAY |
04/07 | FOUR/ | WEEK |
04/30 | FOUR/ | MONTH |
04/90 | 4 TMS/ | QTR |
04/99 | SEE | PERMIT |
05/BA | FIVE/ | BATCH |
05/DW | 5DAYS/ | WEEK |
05/WK | 5 TMS/ | WEEK |
05/01 | 5 TMS | A DAY |
05/07 | WEEK- | DAYS |
05/08 | FIVE/ | 8 DAYS |
05/30 | 5 TS/ | MONTH |
05/90 | FIE/ | QRTLY |
05/99 | SEE | PERMIT |
06/SH | 6/OPR | SHIFT |
06/01 | SIX/ | DAY |
06/07 | SIX/ | WEEK |
06/30 | 6 TMS/ | MONTH |
06/90 | SIX/ | QRTLY |
06/99 | SEE | PERMIT |
07/WD | WEEKLY | WHNDIS |
07/WK | 7 TMS/ | WEEK |
07/14 | 7 PER | 2 WKS |
07/30 | 7 TMS/ | MONTH |
07/99 | SEE | PERMIT |
08/BA | EIGHT/ | BATCH |
08/01 | EIGHT/ | DAY |
08/30 | EIGHT/ | MONTH |
08/99 | SEE | PERMIT |
09/01 | NINE/ | DAY |
09/30 | NINE/ | MONTH |
09/99 | SEE | PERMIT |
10/30 | TEN/ | MONTH |
10/99 | SEE | PERMIT |
11/30 | 11 PER | MONTH |
12/01 | 12 PER | DAY |
12/30 | 13 PER | MONTH |
13/30 | 13 PER | MONTH |
14/30 | 14 PER | MONTH |
15/30 | 15 PER | MONTH |
16/01 | 16 PER | DAY |
16/30 | 16 PER | MONTH |
17/30 | 17 PER | MONTH |
18/01 | 18 PER | DAY |
18/30 | 18 PER | MONTH |
19/30 | 19 PER | MONTH |
20/30 | 20 PER | MONTH |
21/30 | 21 PER | MONTH |
22/30 | 22 PER | MONTH |
23/30 | 23 PER | MONTH |
24/HR | 24 TMS | HOUR |
24/01 | HOURLY | |
24/30 | 24 PER | MONTH |
25/30 | 25 PER | MONTH |
26/30 | 26 PER | MONTH |
27/30 | 27 PER | MONTH |
28/30 | 28 PER | MONTH |
29/30 | 29 PER | MONTH |
48/01 | EVERY | 1/2 HR |
60/HR | 60 PER | HOUR |
66/66 | WPC | PLAN |
77/77 | CONTIN- | GENT |
88/88 | CLEAN- | ING |
99/99 | CONTIN- | UOUS |