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Offshore and Oil & Gas NPDES permits
Welcome to the EPA Region 6 Water Enforcement Branch Offshore platform and Oil & Gas NPDES discharge web page. Mr. Robert Houston is the Regional Coordinator and Enforcement Officer and his phone is (214)665-8565. Ms. Sharon Haggard is the Specialist and she handles permit applications and processing of Discharge Monitoring Reports. Her phone number is (214)665-6472. If you have non-enforcement permitting questions, please contact Mr. Brian Muller at (214)665-7167.
EPA Region 6 also has an Onshore Oil and Gas NPDES discharge program for Region 6.
EPA Region 6 works closely with the Department of Interior's Minerals Management Service (MMS). MMS inspectors perform most of the NPDES offshore platform compliance inspections for EPA. Additionally, the US Coast Guard Marine Safety Office conducts inspections. EPA Region 6 works closely with the Offshore Operators Committee, which is a trade organization representing the offshore operators.
The EPA Region 6 NPDES OCS General Permit No. GMG290000 was reissued with an effective date of October 1, 2007, expiring at midnight of September 30, 2012 [72 Fed. Reg. No. 109, p. 31575]. (Permit Language Link)
- If you had permit coverage under the previous permit (e.g., you applied for coverage before it expired on September 30, 2007, and were assigned and outfall), then you do not have to reapply for permit coverage. You will retain your previous permit number and outfalls unless EPA notifies you otherwise.
- If you applied for permit coverage after the September 30, 2007, expiration date and utilizing the previous permits NOI form, then you will need to resubmit a Notice of Intent application to be covered under this general permit, using the NOI form reflecting the reissued permit.
- Note that your monitoring periods will remain the same as you had under the previous permit.
EPA has completed fitting out a new ship in 2005 for use in federal waters under EPA jurisdiction. This ship has many functions and will support everything from research and development to enforcement inspections. The ship is named "Bold". EPA plans to periodically use this ship in the Gulf of Mexico to perform NPDES inspections and collect on-site samples of produced water discharges from offshore oil and gas operations. The vessels specifications can be found at www.nvr.navy.mil/nvrships/details/AGOS12.htm. The following are some pictures of the Bold (click on different pictures for an enlarged version).
During the period inbetween expiration of the 1998 permit and reissuance of the 2004 NPDES OCS general permit, the regulated communited could not apply for new coverage under the expired permit. EPA made available to these new facilities an Administrative Compliance Order. This Order automatically expired upon the effective date, November 6, 2004, of the new NPDES OCS general permit.
Discharge Monitoring Reports (DMRs):
Operators desiring to use the new OOC DMR form reflecting the 2007 reissued permit must submit a written request (signed and certified in accordance with Part II.D.10. of the permit), with their NPDES permit number affixed, to the following address:
U.S. Environmental Protection Agency
NPDES Compliance Section
Attn: Ms. Sharon Haggard (6EN-WC)
1445 Ross Ave., Suite 1200
Dallas, TX 75202-2733
DMR Reporting: Cross-over from one permit to the reissued permit
Operators who hold a "01/28/08", "04/28/08", and "07/28/08" DMR submission deadline, please be aware that you will have to report under the previous permit DMR form as well as the new permit DMR form. This is because one portion on your monitoring cycle feel within the previous permit's effective/expiration dates; and the other portion fell within the reissued permit's effective/expiration dates. (Those operators holding a "10/28/08" submission deadline will not be affected). The monitoring cycle of the DMR form must reflect that operator's assigned monitoring period. However, the comnment field is used to record the split period of time being reflected on that DMR. Please see the table below for specifics:
Monitoring cycles for the cross-over period of the previous permit to the reissued permit are as follows for all but the "10/28/08" operators, who are not affected:
For "01/28/08" operators DMR Monitoring Period Previous permit DMR "From 01/01/07 to 12/31/07" Comment field: "From 01/01/07 to 09/30/07" Reissued permit DMR "From 01/01/07 to 12/31/07" Comment field: "From 10/01/07 to 12/31/07" For "04/28/08" operators DMR Monitoring Period Previous permit DMR "From 04/01/07 to 03/31/08" Comment field: "From 04/01/07 to 09/30/07" Reissued permit DMR "From 04/01/07 to 03/31/08" Comment field: "From 10/01/07 to 03/31/08" For "07/28/08" operators DMR Monitoring Period Previous permit DMR "From 07/01/07 to 06/30/08" Comment field: "From 07/01/07 to 09/30/07" Reissued permit DMR "From 07/01/07 to 06/30/08" Comment field: "From 10/01/07 to 06/30/08"
Storm Water Discharges from inactive platforms: If you have structures in the Gulf of Mexico that are not covered by the NPDES OCS general permit that are "industrial" in nature (40 CFR 122.26(b)(14)) and they have storm water discharges from deck drainage, etc., then these facilities may be required to have an NPDES permit. If you have coverage under the NPDES OCS general permit, this permit covers those discharges. If you terminate the NPDES OCS general permit (e.g., you stop production and shut in the well) and still have storm water discharges from an industrial activity, you will need to seek alternative NPDES coverage. Oil & gas exploration and production facilities are SIC code 1381 found at 40 CFR 122.26(b)(14)(iii). Oil & Gas exploration and production facilities are exempted from needing an NPDES permit if they have not had a reportable quantity discharge (e.g., a sheen) or caused a water quality violation (see 40 CFR 122.26(c)(1)(iii)). You can find more information at the EPA Region 6 storm water enforcement web page.
Coast Guard and EPA Enforcement of Spills: Both the EPA and the Coast Guard enforce provisions in the Clean Water Act and there are some overlapping jurisdictions in the Gulf of Mexico. EPA performs Section 309 (33 USC 1319) enforcement assuring compliance with NPDES permits and for unpermitted discharges of pollutants to waters of the U.S. The Coast Guard performs Section 311 (33 USC 1321) enforcement of oil spills (Section 311 is also known as the Oil Pollution Act). Section 311(b)(11) says "Civil penalties shall not be assessed under both this section and section 309 for the same discharge." If you have an oil spill, then you could face an enforcement action under either 309 or 311, but not both. The defendent must raise this defense if enforcement has already commenced under either section.
Mail to the Agency: Please note that EPA Region 6 has changed mail handling procedures. Suspicious mail will have to go through additional screening and may not be delivered timely. Please make sure your mail is properly addressed, including a complete and accurate return address, to assure your mail is delivered in a timely fashion. Make sure that certfied mail has a return address on the letter in addition to the return address on the green card.
The final NPDES General Permit [Adobe Acrobat PDF file format] for New and Existing Sources and New Discharges in the Offshore Subcategory of the Oil and Gas Extraction Category for the Western Portion of the Outer Continental Shelf (OCS) of the Gulf of Mexico (GMG290000) and Notice of a Proposed Modification to that permit was published at 72 Fed. Reg. No. 109, p. 31575, published June 7, 2007, effective October 1, 2007.
OCS Application and Termination forms:
2004 Permit Discharge Monitoring Report instructions for Offshore permittees.
2007 Permit Discharge Monitoring Report instructions for Offshore permittees.
Final NPDES General Permit for New and Existing Sources and New Dischargers in the Offshore Subcategory of the Oil and Gas Extraction Category for the Western Portion of the Outer Continental Shelf of the Gulf of Mexico (GMG290000) as published at 63 Fed. Reg. No. 211, p. 58722, November 2, 1998.
Environmental Assesment of Final Effluent Limitations Guidelines and Standards for Synthetic-Based Drilling Fluids and other Non-Squeous Drilling Fluids in the Oil and Gas Extraction Point Source Category: www.epa.gov/ost/guide/sbf/
EPA's Office of Wetlands, Oceans & Watersheds is our headquarters office in Washington DC that developes polices and guidelines on discharges from offshore platforms.
Final NPDES General Permit for Discharges from the Oil and Gas Extraction Point Source Category to Coastal Waters in Texas (TXG330000) This final permit was published in the Federal Register on July 7, 2007 (72 Fed. Reg. No. 109, p. 31579). Federal Register Notice. Application: Notice of Intent.
Final NPDES General Permit for Discharges from the Oil and Gas Extraction Point Source Category to Coastal Waters in Texas (TXG330000) This final permit was published in the Federal Register on November 15, 2001 (66 Fed. Reg. No. 22, p. 57457-57465). Response to Comments.
Final NPDES General Pemrits for Produced Water and Produced Sand Discharges from Oil and Gas Extraction Point Source Category to Coastal Waters in Louisiana (LAG290000) and Texas (TXG290000) [60 Fed. Reg. No. 5, p. 2387, January 9, 1995]
Final NPDES General Permits for the Oil and Gas Extraction Point Source Categroy, Onshore Subcategory - States of Louisiana (LAG320000), New Mexico (NMG320000), Oklahoma (OKG320000), and Texas (TXG320000) [56 Fed. Reg. No. 37, p 7698, February 25, 1991]
Final NPDES General Permits for the Coastal Waters of Louisiana (LAG330000) and Texas (TXG330000) [58 Fed. Reg. No. 181, p. 49126, September 21, 1993]
EPA Region 6 Water Management Division's General Permits web page (contains all general permits including oil/gas and offshore general permits).
Common Compliance Issues:
Non-compliance Reporting: Part II.D.7. of the OCS Permit (GMG290000), as well as in the Standard Conditions section of most NPDES permits, requires the permittee to report any non-compliance which may endanger health or the environment within 24 hours. The 24 Hour report may be either on telephone to (214)665-6593 or by E-mail to r6genpermit@epa.gov. Additionally, the oral/e-mail report is required to be followed up by a written report within 5 days of the time the permittee becomes aware of the situation. This written report shall be certified [40 CFR 122.22(d)] and signed by an authorized official [40 CFR 122.22(a)], and include your specific permit number (e.g. GMG29#### and not just GMG290000) and information regarding the non-compliance, its duration, any environmental impacts, and any remediation actions taken.
Questions and Answer document developed with the Offshore Operators Committee for the Feb. 16th permit modifications.
Authorized Signatories:
40 CFR 122.22(d), as well as Part II.D.10. of the OCS permit, states that "All applications [NOIs, Transfer Agreements, Mergers, etc.], reports [Discharge Monitoring Reports, Non-compliance Reports, etc.], or information [address/contact name updates], NOT's, submitted to the Director shall be signed and certified. Many operators fail to have their documents properly signed and certifed by an authorized official of their company. The following is the certification that must accompany these documents:"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 gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those person 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."An example letter of Delegation of Signatory Authority for the Offshore Outer Continental Shelf General Permit (GMG29####) has been prepared for use by those permittees.
40 CFR 122.22 was revised effective July 1, 2001 to amend the requirements of an authorized person. If you are corresponding with EPA regarding compliance with a permit you already have, you are to use the definition of authorized person in your permit language. Upon modification or reissuance of your NPDES permit, the definition will be updated. If do not have an NPDES permit, you should use the new definition of authorized person.
40 CFR 122.22 (HTML Format) 40 CFR 122.22 (Adobe Acrobat PDF File format)EPA tracks all of your documentation by NPDES permit number (e.g. GMG29####). To assure your correspondence is properly filed, please make reference to your permit number in all correspondence to EPA. Also, be sure and spell out the name of the lease area. While MMS uses abbreviations, there are some duplicates (e.g. MI could be either Matagorda Island or Mustang Island) and spelling the lease area out will eliminate any confusion.
"New Source" means any facility or activity that meets the definition of "new source" under 40 CFR 122.2 and meets the criteria for determination of new sources under 40 CFR 122.29(b) applied consistently with all of the following definitions:
(a) The term "water area" as used in the term "site" in 40 CFR 122.29 and 122.2 shall mean the water area and ocean floor beneath any exploratory, development, or production facility where such facility is conducting its exploratory, development, or production activities.
(b) The term "significant site preparation work" as used in 40 CFR 122.29 shall mean the process of surveying, clearing, or preparing an area of the ocean floor for the purpose of constructing or placing a development or production facility on or over the site.
New Source does not include facilities covered by an existing NPDES permit immediately prior to the effective date of these guidelines pending EPA issuance of a new source NPDES permit.
Also, exploration facilities are not defined as new sources.
The guidelines were issued on March 4, 1993 [58 Fed. Reg. No. 12504], any facility put in place after that date is a new source. It should be noted that the new source definition has little actual meaning in this case since the limits are the same for both existing sources and new sources for the 1998 GMG290000 permit. Effluent guidelines were also published at 61 Fed. Reg. No. 66085, December 16, 1996.
Outfall Designations:
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xxxP - produced water toxicity from the previous OCS general permit that expired on 11/19/97 (effective from 11/02/98 thru 06/30/99) for outfalls 001 thru 999
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xxxJ - produced water toxicity from the previous OCS general permit that expired on 11/19/97 (effective from 11/02/98 thru 06/30/99) for outfalls exceeding 999
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xxxT - produced water toxicity (post July 1999) for outfalls 001 thru 999
-
xxxY - produced water toxicity (post July 1999) for outfalls exceeding 999
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xxxS - synthetic based muds for outfalls 001 thru 999
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xxxR - synthetic based muds for outfalls exceeding 999
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xxxA - all other reporting requirements for outfalls 001 thru 999
-
xxxB - all other reporting requirements for outfalls exceeding 999
Column Headings |
|||||||||||
Column Headings | Description | ||||||||||
FNMS | “Operator” name | ||||||||||
NPID | “Operator’s” assigned NPDES permit # | ||||||||||
IACC | “A” means the assigned permit # remains open/active “I” means the assigned permit # has been terminated |
||||||||||
IADT | If a date appears, this is the date the NPDES permit number was terminated. | ||||||||||
DSDG | Outfall number assigned to a lease area/block. This “number” is represented by 3 numeric characters/1 alpha character (i.e., 001A). Alpha character descriptions are as follows:
|
||||||||||
PIPE | Lease area name/block # | ||||||||||
STSU | Date 1st DMR due | ||||||||||
PIAC | “A” means the outfall number remains open/active “I” means the outfall number has been terminated |
||||||||||
PIDT | If a date appears, this is the date the outfall number was terminated (based on the date EPA received the NOT). |
General Permits
Regulatory background and history of the Region 6 Offshore General Permits (circa January 2004)
1998 NPDES Outer Continental Shelf offshore general permit GMG290000 - see above for permit language.
NPDES General Permit for New and Existing Sources in the Offshore Subcategory of the Oil and Gas Extraction Category for the Western Portion of the Outer Continental Shelf of the Gulf of Mexico (GMG290000)
Tentative
Decision by the Regional Administrator concerning Gulf of Mexico Oil and
Gas Development
NPDES General Permit for the Territorial Seas off Texas (TXG260000) - The effective date was November 5, 2005. The permit expires November 4, 2009. The permit was issued August 26, 2005. The date on the cover of the Permit says August 5, 2005, but that was just a routing date.
Final NPDES General Permits for Discharges Resulting from Implementing Corrective Action Plans for Cleanup of Petroleum UST Systems in Texas (TXG830000), Louisiana (LAG830000), Oklahoma (OKG830000) and New Mexico (NMG830000)
Miscellaneous Historical Documents
Department of Interior's Minerals Management Service abbreviations for lease areas (Microsoft Excel format) in the Gulf of Mexico (includes the entire Gulf, and not just EPA Region 6 jurisdiction). Please do not use abbreviations for your communications with EPA. Applications that do not have the full lease area name will not be accepted.
Outer Continental Shelf Coordination Committee from 1981
General Permitting Strategy for OCS Oil & Gas Activities under EPA/MMS MOU - 1985
Offshore Effluent Guidelines published March 4, 1993, 58 Fed. Reg. No. 12504. Please note that exploration facilities are not defined as new sources.
History of the Region 6 OCS NPDES General Permits
Permit No. | Effective Date | Citation | Expiration Date |
TX0085642 | April 3, 1981 | 46 FR 20284 | April 3, 1983 |
re-issue | September 15, 1983 | 48 FR 41494 | June 30, 1984 |
GMG280000 (joint with EPA Region 4) | July 9, 1986 | 51 FR 24897 | July 1, 1991 |
GMG290000 (Region 6 only) | November 19, 1992 | 57 FR 54642 | November 18, 1997 |
modified | December 3, 1993 | 58 FR 63964 | November 18, 1997 |
re-issued, adds GMG390000, New Source | August 9, 1996 | 61 FR 41609 | November 18, 1997 |
re-issued Part 1 | November 2, 1998 | 63 FR 58722 | November 3, 2003 |
re-issued Part 2 (Produced Water) | April 19, 1999 | 64 FR 19156 | November 3, 2003 |
modified (SBM) | December 18, 2001 | 66 FR 65209 | November 3, 2003 |
reissue | November 6, 2004 | 69 FR 60150 | November 5, 2007 |
EPA Region 6 covers the Western portion of the Gulf of Mexico off of the Coasts of Texas and Louisiana. EPA Region 4 covers the Eastern portion of the Gulf of Mexico.