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EPA's Region 6 Office

Serving: Arkansas, Louisiana, New Mexico, Oklahoma, Texas, and 66 Tribal Nations

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
DISCHARGE MONITORING REPORTS
UNDER OFFSHORE GENERAL PERMIT GMG290000
[69 FR 169, p. 60150, Oct. 7, 2004]

UPDATED: February 5, 2005
This is a supplement to the Region 6 DMR Instruction Manual.

EPA's Clean Water Act NPDES Discharge Monitoring Report forms

I. GENERAL COMMENTS AND INSTRUCTIONS
  • 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:
    • DMR 1 - ###A
    • DMR 2 - ###A
    • DMR 3 - ###A
    • DMR 4 - ###A
    • DMR 5 - ###S
    • DMR 6 - ###S
    • DMR 7 - ###T

    • The Offshore Operators Committee (OOC) has prepared some DMRs that EPA has reviewed and approved as of January 20, 2005. They are in Microsoft Excel format. If you use these forms, please submit a signed and certified letter to Ms. Haggard requesting to use of these forms.
      • DMRs
      • SBM DMRs
  • 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.
  • 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.
  • 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 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.

  • 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.

  • 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.
  • 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):

    • NPDES general permit number assigned. For example, GMG290078; not GMG290000.
    • Area/block description (i.e., Mustang Island 24)
    • 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.)
    • SBM DMRs, if applicable, will have an outfall number of xxxS, xxxR or xxxW (i.e., 001S, 001R, or 001W).
    • The operator's assigned monitoring end date (03/30/yy, 06/30/yy, 09/30/yy, or 12/31/yy).
    • 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 signatureis to be an original pen&ink; not a photocopy, carbon, or stamped signature.
    • 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.
  • All lease blocks which have an NPDES discharge must comply with the DMR submittal requirements specified in Part II.D.4 of the permit.

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.

  • 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

  • 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 shouldsubmit 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/region6/6en/w/offshore/home.htm).

    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:
  1. 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.

  2. 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.

  3. 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.
  4. 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.

  5. 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.

  6. 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.

  7. 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.

  8. 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.
    • 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".

  9. 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.

  10. 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).

    • 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 supplier’s 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.

    • 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.

    • 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.

  11. SEABED SURVEYS (Storet codes 51121, 51122 & 51123) - (See Part I.B.2.3. of the permit)

    • 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.

    • There are three entries on the DMR form for reporting:

      • 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.
      • 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".
      • 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".

III. OTHER REQUIREMENTS

  • 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".
  • Frequency of Analysis – Enter the maximum frequency of sampling or observation performed for each parameter during the reporting period.
  • 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.

  • 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.
  • Decimals/Commas: Please be careful when reporting sample measurement data where decimals or commas are used. Make sure commas and decimals are clearly distinguishable.
  • 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".
  • 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.
  • "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.
  • 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.
  • 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"?
  • 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).
  • "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.
  • 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".
  • 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.
  • 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.
  • 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.
  • 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.
  • "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.
  • 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.
    • Name and address of the operator
    • NPDES permit number assigned (i.e., GMG290078; not GMG290000)
    • Lease area/block number
    • Outfall number
    • Certification statement, in its entirety
    • Signature of the responsible corporate official (pen & ink)

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.

  1. Incorrect monitoring periods
  2. Incorrect outfall numbers (see "Discharge Number" on the form).
    1. Operators are not consistently ensuring the outfall number recorded on their DMR is what EPA had assigned to that lease area/block being reported.
    2. 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).
    3. 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".
  3. 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".
  4. 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.).
  5. 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".
  6. Failure to sign all pages of the DMR form.
  7. Failure to submit DMRs for all properties held (for any period of time) within the monitoring period.
  8. 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

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