Gulf of Mexico OCS Operators: New permits, and the changes you need to know.
As an OCS Operator, having the latest NPDES permits is only part of the job. Another responsibility is to remain up-to-date on any changes in order to perform properly under your NPDES permit regulations.
With a new NPDES permit in effect as of October 1, 2017, are you in compliance with the new procedures?
The sampling frequency, test methods and limits for Oil & Grease in produced water remains unchanged. Operators are not required to report produced water sheens to the National Response Center but must report all sheen events to the EPA.
Well Treatment, Completion and Workover Fluids (TCW)
Well Treatment Operators are now required to choose to either perform a detailed characteristic assessment of Well Treatment, completion and workover fluids, or participate in an Industry-Wide Study Alternative program. It is recommended that operators participate in the Industry-Wide study due to the high cost and complexities of an individual Characteristics Assessment Study. A plan for the Industry-Wide study must be submitted to the EPA for approval by 4/1/2019.
A minor procedural change was put in place for Drilling Fluids under EPA 1655. This will affect Lab Testing.
Discharge Monitoring Reports (DMR’s):
DMR’s shall be submitted quarterly (JAJO) no later than 60 days following the end of the quarterly monitoring period.
To learn more about this NPDES permit or other testing programs, contact Element – Lafayette, your go to for all of your NPDES permit compliance testing services, at 1-800-737-2378. Element is prepared to help you stay permit compliant.
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