On July 10, 2017, the PESA Environmental Policy Committee submitted comments to the Environmental Protection Agency Region 6 on the draft National Pollutant Discharge Elimination System (NPDES) General Permit for the western portion of the Outer Continental Shelf of the Gulf of Mexico. The NPDES general permit sets limits, monitoring requirements, and other mandates on discharges from exploration, development, and production facilities in federal waters.
The EPA’s proposed permit contains several new requirements related to well treatment, completion and workover fluids. PESA’s comments provided significant technical input into the impacts of the NPDES general permit; key issues addressed included:
- Recommendations to maintain existing permit language regarding priority pollutants
- Operator assessments on well treatment, well completion and workover fluids
- Approaches to water toxicity evaluations
- New reference samples and calibration for crude oil contamination in Synthetic Based Drilling Fluids (SBDF)
The Environmental Policy Committee will continue to steward this issue as EPA Region 6 moves forward with finalizing the draft permit.
If you have any questions, please contact PESA Senior Director of Public Policy, Jean Gould.