An Overview of the Changes Made to the Current Region 6 GMG290000 Permit

Oral Presentation

Prepared by J. Griffith
Environmental Enterprises USA, Inc., 58485 Pearl Acres Road, Suite D, Slidell, LA, 70461, United States


Contact Information: jgriffith@eeusa.com; 985-646-2787


ABSTRACT

The Clean Water Act prohibits the discharge of pollutants to waters of the United States without National Pollutant Discharge Elimination System (NPDES) permits. The current NPDES Region 6 GMG290000 permit became effective on October 1, 2017 and will expire on September 30, 2022. Some significant changes were made to the new permit including NOIs and the eNOI/eNOT system. Other changes to the permit include a revised definition of composite oil and grease samples to include a minimum of 4 grabs after a sheen event, the monitoring approach used for intake velocity through cooling water intake structures, and the allowance of Operators to submit SEAMAP data instead of entrainment monitoring. The frequency of produced water toxicity testing was not altered, however, an Industry-Wide Study on the toxicity of well treatment, completion, and workover fluids is offered as an option to operators in order to comply with the requirement to provide a Characteristic Assessment Report of all well fluids discharged directly overboard. This Characteristic Assessment includes toxicity testing of each fluid, each well.