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EPA's Region 6 Office

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

2007 Permit Offshore Discharge Monitoring Reports

2007 Permit
Offshore Discharge Monitoring Reports

INSTRUCTIONS FOR COMPLETING
DISCHARGE MONITORING REPORTS (DMRs)
UNDER OFFSHORE GENERAL PERMIT GMG290000
(72 FR 109, p. 31575, June 7, 2007, effective October 1, 2007)

Updated: July 21, 2011

http://www.epa.gov/region6/offshore

EPA's Clean Water Act NPDES Discharge Monitoring Report forms

Table of Contents/Chapters

I. Reminders/General Information - Important, please read!

II. Mobile Offshore Drilling Units (MODU)

III. Cross-over DMR submission requirements:

  • Previous permit (69 "FR 169, p. 60150, October 7, 2004, effective November 6, 2004)
  • Current permit (72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007)

IV. Notice of Terminations/Final DMRs

V. Transfer Agreements/Final DMRs

VI. No Discharge/No Activity List

VII. DMR Form

  • OOC Facsimile DMR Form
  • EPA Preprinted DMR Form
  • NetDMR

VIII. Parameter Descriptions/Limitations/Reporting Requirements

IX. Common Errors to Avoid

X. Acronyms

XI. Outfall and Permitted Feature (PF) Types (past and present)

XII. EPA Region 6 Contacts

Appendix

A. Frequency of Analysis Table

B. Sample Type Table


Chapter I
Reminders/General Information

1. NOTE: These DMR Completion Instructions are to be followed:

  • At the time of an operator and/or MODU’s annual submission deadline.
  • When final DMRs are being submitted with a Notice of Termination (NOT).
  • When final DMRs are being submitted with a Transfer Agreement (TA).
  • When corrected and/or revised DMRs are being submitted.
  • When submitting a No Discharge/No Activity List (whether at the annual submission, with a NOT or TA, or a corrected List).

2. Permitted Features Descriptions

There are 10 pages of DMRs for the current OCS General Permit (72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007). The following are the pages for each PF type (i.e., Cooling Water Intake), as they appear on EPA’s offshore web site, in Adobe Acrobat PDF file format:

Cooling Water Intake: PF ending K

DMR 1 (Page 1of 1)

Synthetic Based Muds (SBM): PF ending S

DMR 2 (Page 1 of 2)
DMR 3 (Page 2 of 2)

Produced Water Toxicity: PF ending T

DMR 4 (Page 1 of 3)
DMR 5 (Page 2 of 3)
DMR 6 (Page 3 of 3)

All other reporting requirements: PF ending A

DMR 7 (Page 1of 4)
DMR 8 (Page 2 of 4)
DMR 9 (Page 3 of 4)
DMR 10 (Page 4 of 4)

3. Permit Number

Operators and/or Mobile Offshore Drilling Units (MODUs) are assigned a specific National Pollutant Discharge Elimination System (NPDES) permit number under the umbrella of the master general permit number, GMG290000 (i.e., GMG290700). Therefore, no operator or MODU will have the master number, GMG290000.

Operators and/or MODUs will retain their assigned NPDES permit number regardless of any operator/MODU name changes, and regardless of how many lease areas/blocks they acquire and/or subsequently terminate coverage.

Operators and/or MODU’s are reminded they must include their assigned NPDES permit number on all their applications, reports, and documents (including cover letters) submitted to the EPA.

4. Monitoring Periods

Operators and/or MODUs are assigned an annual monitoring period by the EPA. This monitoring period remains for the life of that operator and/or MODU under the OCS General Permit, regardless of the permit’s reissuance. That is, it continues from one OCS General Permit to the next until such time as that operator or MODU submits a Notice of Termination to terminate their permit number, as well as any outstanding lease area/block coverage.

Operators and/or MODUS will also retain their assigned monitoring period even if they submit documentation of an operator/MODU name change.

Operators and/or MODUs are also reminded that their assigned monitoring period must appear on each page of their DMRs as is, regardless of how long they held a particular lease area/block. Alterations of the assigned monitoring period on the form are not permitted. The comment field is to be used to explain periods of time being reported that are less than their assigned monitoring period.

5. DMR submission dates

Based on the large number of permitted operators and/or MODUs in the Western portion of the Gulf of Mexico, EPA Region 6 (Dallas) split the operators into four (4) separate monitoring period/submission groups. The primary purpose
of splitting the operators is to allow for staggered submission of reports required by the permit in order to prevent an overwhelming amount of reports arriving at the EPA at the same time.

The four (4) monitoring periods/submission groups are as follows:

  Monitoring Period DMR
From 01/01/yy To 12/31/yy
From 04/01/yy To 03/31/yy
From 07/01/yy To 06/30/yy
From 10/01/yy To 09/30/yy
Submission Date
01/28/yy
04/28/yy
07/28/yy
10/28/yy

NOTE: Extension of an assigned submission date can only be granted via a permit modification. Because such modifications are very costly and time consuming, they have historically not been granted. Therefore, operators and/or MODUs need to comply with their assigned submission date.

6. Multiple structures within the same lease area/block

In accordance with Part II.D.4. of the permit, the DMR for each lease area/block will summarize monitoring for all facilities (platform, drilling ship, or semi-submersible) operated within that lease block during the reporting period. That is, operators/MODUs will not be given separate PF's for each specific structure within that block. Instead, they must consolidate their reporting for all structures within that block and report the worse case scenario on the DMR.

7. What is to be submitted to EPA

Operators and/or MODUs must submit DMRs and/or No Discharge/No Activity Lists (Lists) as follows:

Original (with pen&ink signature)
"Copy" (legible)

This applies to DMRs and Lists being submitted at an operator or MODU’s annual submission deadline, or with Notice of Terminations and/or Transfer Agreements.

8. EPA Region 6 Mailing Address

All documents, reports, applications, etc., should be submitted to the Region 6 physical address as follows:

U.S. Environmental Protection Agency
Water Enforcement Branch
ATTN: Ms. Sharon Haggard (6EN-WC)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733

9. Signature Authority/Certification Statement

Part II.D.10 of the Permit and 40 CFR 122.22

In accordance with Part II.D.10. of the permit and 40 CFR 122.22, all applications, reports, or information submitted shall be signed and certified. These references outline who is and who is not authorized to sign these reports.

• Signature Delegation

Where signature authority has or is being delegated, the conditions set forth in Part II.D.10.b. of the permit and 40 CFR 122.22(b) must be met. And, as a reminder, the delegation must be submitted to EPA, in writing, signed and certified. [Please be sure the letter of signature authority also contains the operators name and their assigned NPDES permit number, plus any other specifics (i.e., a change of contact or mailing address).]

Signatures "on behalf of"

Section 301 of the Clean Water Act provides the definition of "person." For example, an operator is a legal "person." Where there is a parent company with wholly-owned subsidiaries, the parent company cannot sign documents "on behalf of" their wholly-owned subsidiary. Each operator is a separate legal person and must sign and submit their own documentation and reports.

In addition, the regulations also outline that one person within a corporation cannot sign the name of another, or sign on behalf of the other. The authorized official must sign for themself, or prepare and submit a written document to EPA outline signature delegation.

Certification Statement Language

In addition, Part II.D.10.(d) and 40 CFR 122.22(d) provide the only legal and acceptable language of the certification statement (the statement is the same in both reference citations). Operators are cautioned not to use any other statement than as found in these reference citations. And, the full language (not a partial wording) of the statement must appear on the document or report.

Operators who have been authorized to use the OOC’s facsimile DMR must ensure that as they print the form for completion and submission that their printer does not cause portions of the form to fail to print. For example, EPA continues to receive DMRs where only a portion of the certification statement prints, or the entire statement fails to print. Submission of these deficient DMRs is a violation of Part II.D.10. of the permit. So, operators are advised to carefully review their reports prior to submission to ensure they are not only accurate and true, but are also complete.

10. OOC DMR Facsimile Form

The Offshore Operator’s Committee (OOC) submitted a facsimile of EPA’s preprinted DMR form for EPA Region 6 approval. That form has been approved and can be found on the EPA Region 6 offshore web site, as follows:

www.epa.gov/region6/6en/w/offshore/home.htm

Please be aware that although EPA approved the form itself, operators must individually submit a written request seeking authorization to use it. [This policy is consistent with all NPDES permits the EPA tracks and regulates.]

NOTE: Any OOC DMR authorization an operator gained for a previous OCS General Permit expired with that particular general permit. Prior authorizations do not carry forward to a new OCS General Permit/OOC Facsimile DMR form. [Retroactive authorization can be granted for a previous permit where an operator is attempting to fulfill final DMR requirements for that permit and the EPA’s preprinted DMR form is no longer available.]

When authorization has been granted to the operator, please be sure to use the most current version of the form as found on the web site (all previous versions will be obsolete). And of further note, please be sure to follow, very carefully, the instructions for usage of the OOC DMR facsimile form (as found under Chapter VI of these Instructions) to avoid having your authorization terminated.

11. Abbreviations

Abbreviations on the NOI form, the NOT form, the TA form, the DMR form, or a No Discharge/No Activity List will not be accepted.

Operators are to spell out the name of the lease area/block.

12. No Discharge Block

This block on the DMR form is to be checked only if all reporting requirements for that PF are no discharge.

Operators cannot, for example, check the No Discharge block on Page 1 of 4 for PF 0001A when sample measurement data is being reported on pages 2 of 4, 3 of 4, and 4 of 4.

13. Individual Parameters that are: No Discharge, No Activity, or Not Required

Where a specific parameter has no discharge, no activity, or is not required, then the operator can record in the sample measurement block for that parameter, "N/D" (no discharge), "N/A" (not applicable), and/or "N/R" (not required), respectively. Operators are to provide a brief explanation of any N/A and N/R in the comment field (i.e., MSD for Sanitary Waste).

14. NO EX, Frequency of Analysis, and Sample Type Columns

When an operator is reporting a particular parameter as "N/A" (not applicable), "N/D" (no discharge), or "N/R" (not required), then the last three columns on the DMR form (NO EX, Frequency of Analysis, and Sample Type) are to remain blank.

However, wherever sample measurement data is being reported, operators must complete these three columns. Please refer to the information below on how to report information in these three columns.

1. No Ex column: 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 a "0."

2. Frequency of Analysis: Enter the maximum frequency of sampling or observation performed for each parameter during the reporting period, regardless of the permit requirement. Operators can report values greater than what the permit requires, but values less than what the permit requires will be considered a violation, unless otherwise stated by the EPA. The latter is pending any documentation submitted by the operator and EPA’s review and consideration of such documentation. Please use the Table in Appendix A for a listing of how to report Frequency of Analysis.

3. Sample Type: Enter the actual sample taken, regardless of the permit requirement. Again, operators can report values greater than what the permit requires, but values less than what the permit requires will be considered a violation, unless otherwise stated by the EPA. The latter is pending any documentation submitted by the operator and EPA’s review and consideration of such documentation. Please use the Table in Appendix B for a listing of how to report Sample Types.

15. Comment Field

Please refer to the preprinted comments on the DMR form, as provided by the EPA, to assist in completing the DMR form.

Additional comments by the operator should be briefly stated followed by a supplemental document providing further details (i.e., a non-compliance report).

16.Operator name, mailing address, contact information, signature authority

It is the responsibility of the operator to keep EPA current on the name of the operator (often times it changes, for various reasons), the corporate mailing address, any special DMR mailing address, as well as contact information.

EPA relies on the latest information provided. When information is no longer current, this can result in an operator not being able to receive required documentation back from the EPA, such as a letter of coverage for specific lease areas/blocks or information relative to an operators DMR submission (for example, a listing of lease areas/blocks to be reported along with their PF assignment).

It is also the responsibility of the operator to keep EPA current on all authorized signature authorities. EPA pays very close attention to who is signing the reports submitted and will take appropriate enforcement action where signatures are not authorized in accordance with Part II.D.10. of the permit and 40 CFR 122.22.

Any documentation submitted to bring EPA’s records current is considered a legal document (it is affecting legal changes to official records) and must be signed and certified in accordance with the reference citations noted above.

17.NetDMR

OCS Operators need to be aware that the future of the OCS General Permit will require only electronic submission of the DMR; paper DMRs will no longer be accepted under the reissued permit. Therefore, operators need to take the required training, which will not only outline how to complete the DMRs, but also what is required to have access to submitting e-DMRs (i.e., signature authority, subscriber agreement, operators who utilize the service of a consulting firm, ect.). Operators will be required to have completed the NetDMR training and have at least one successful transmission of test data prior to getting approval for NetDMR. And, operators are encouraged to take this training as soon as possibile in order to be prepared for this upcoming requirement to submit DMRs electronically. To register for NetDMR training, send an email to netdmr@epa.gov. To learn more, including if you have any questions, please visit www.epa.gov/netdmr.

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Chapter II
Mobile Offshore Drilling Units (MODUs)

Mobile Offshore Drilling Units (MODU’s) who must gain their own coverage for either 1) Sandblasting/Maintenance Waste, or, 2) for Sandblasting/Maintenance Waste and Cooling Water Intake, based on their contractual agreement with the operator of a lease area/block, will need to submit a Notice of Intent (NOI) for National Pollutant Discharge Elimination System (NPDES) coverage under the OCS General Permit. The EPA Region 6 offshore website has a suggested NOI form for the OCS General Permit that the MODU can use to apply for coverage. [Please refer to the OCS General Permit (72 FR 109, p. 31575, June 7, 2007, effective October 1, 2007) as well as some general information below for specifics on how to complete a NOI application.]

OCS General Permit Coverage

Based on the understanding that MODU’s can be on a given lease area/block anywhere from a few days to a week or even a month or more, coverage will be granted according to the name of the MODU rather than the name of the lease area/block, the latter of which is the process EPA follows when granting NPDES coverage to lease operators.

Furthermore, PF assignment will also be contingent on what the MODU requests in their NOI application. If the MODU indicates that only Sandblasting/Maintenance Waste PF assignment is required, then EPA will only assign a general PF (i.e., 0001A). [Note: the general PF is also known as “All Other Reporting Requirements”.] However, if the MODU indicates that both Sandblasting/Maintenance Waste and Cooling Water Intake PF assignments are required, then EPA will assign a general PF as well as a PF for Cooling Water Intake (i.e., 0001A for Sandblasting/Maintenance Waste and 0001K for Cooling Water Intake).

Reporting Requirement

Part II.D.4. of the permit requires the annual submission of Discharge Monitoring Reports (DMRs) providing monitoring results for all facilities within each lease block for which the MODU has permit coverage.

With over 300 permitted operators and MODU’s in the Western portion of the Gulf of Mexico, EPA Region 6 established four (4) different monitoring periods, with corresponding DMR submission dates for ease and volume of reports being submitted at a given time. Based on the initial NOI application, EPA will assign the MODU to one of those four different monitoring periods. [Please refer to Chapter I of these Instructions for a breakout of the four groups and their corresponding DMR submission deadline.]

DMR Submission

Approximately one (1) month prior to the MODU’s assigned submission, EPA will send an updated list of PF's to be reported. MODU’s, along with operators, have the option to use the Offshore Operators Committee (OOC) facsimile DMR form. However, operators and MODU’s must request authorization prior to actual usage. Please refer to Chapter VII for details regarding the OOC’s form, including the process for requesting authorization prior to actual usage.

NOTE: EPA will no longer send preprinted DMR forms. Operators and MODU's must utilize, the OOC facsimilie DMR (with approval from EPA) or NetDMR.

Reporting information on the DMR

Please refer to Chapter VIII of these Instructions for specifics on how to report the parameters on each designated PF type, that being the “General PF ” (also known as “All other reporting”) and the “Cooling Water Intake”.

Note: The requirements to track sandblasting/maintenance have been embedded within the “general PF” for all operators. Therefore, not all the parameters listed in that “general PF” apply to the MODU. The two parameters that do apply to the MODU are:

Storet Code Parameter Description / Response Required
85866 Maintenance Waste, Do You Have a BMP
  Response is to be a "0" for yes, or a "1" for no.
85867 Maintenance Waste, Are You Using a BMP?
  Responose is to be a "0" for yes, or a "1" for no.

Although only the two parameters above apply to the MODU, the MODU is still required to respond to the other parameters so noted on the “General PF ” DMR. Specifically, where a parameter does not apply to the MODU, the MODU must insert “N/R” (for not required) in the sample measurement field for that parameter.

DMR Supplemental Requirement

At their scheduled DMR submission deadline a MODU must also include a supplemental sheet providing the following:

  • A list of all lease areas/blocks visited within the monitoring period.
  • The dates visited.
  • The operator of record for that lease area/block (i.e., ABC Oil & Gas Company).

The supplemental sheet must also include:

  • The name of the MODU.
  • The specific NPDES permit number assigned to the MODU (i.e., GMG290800, not GMG290000 or GMG 290800 or 290800, or even the NPDES permit number of the operator of record).
  • Monitoring period assigned to the MODU.
  • PF assigned.
  • The certification statement, as found in Part II.D.10. of the permit.
  • The signature and title of an authorized individual, in accordance with Part II.D.10. of the permit.
  • The date the document was signed.

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Chapter III
Submission Requirements for the Previous OCS General Permit
(69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004)

Operators who have a DMR submission deadline of "01/28/08," "04/28/08," and "07/28/08" will have to submit DMRs for both the previous OCS General Permit, as well as the current OCS General Permit at the time of their submission dates noted here. This is due to the fact of the overlapping expiration and effective dates of the previous and current permit, respectively.

Note: The "10/28/08" group is not affected as the permit was reissued on the first date of their monitoring period. This reporting group will only need to submit DMRs for the current OCS General Permit on "10/28/08."

Both the EPA and the OOC will retain, for a reasonable period of time, the earlier version of the OOC’s facsimile DMR form to assist these three operator groups in fulfilling their "cross-over" reporting requirements of the two permits. Again, operators must seek authorization to use these forms prior to usage.

Of particular note in preparing these "cross-over" DMRs: The monitoring period on both sets of DMRs will remain the same. And, it must be that assigned to the operator. The Comment Field at the bottom of the DMR form is to be used to show the split of time being reported. See below for the specifics of these three groups:

01/28/08 Operators

Previous OCS General Permit:

1. Monitoring period to be recorded at the top of the DMR (written in YY/MM/DD format as it appears on the DMR):

"From 07/01/01 To 07/12/31"

2. Statement in Comment Field:

"Reporting is for the period of 01/01/07 ending 09/30/07, under the OCS General Permit 69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004."

Current OCS General Permit:

1. Monitoring period to be recorded at the top of the DMR (written in YY/MM/DD format as it appears on the DMR):

"From 07/01/01 To 07/12/31"

2. Statement in Comment Field:

"Reporting is for the period of 10/01/07 ending 12/31/07, under the OCS General Permit 72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007."

04/28/08 Operators

Previous OCS General Permit:

1. Monitoring period to be recorded at the top of the DMR (written in YY/MM/DD format as it appears on the DMR):

"From 07/04/01 To 08/03/31"

2. Statement in Comment Field:

"Reporting is for the period of 04/01/07 ending 09/30/07, under the OCS General Permit 69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004."

Current OCS General Permit:

1. Monitoring period to be recorded at the top of the DMR (written in YY/MM/DD format as it appears on the DMR):

"From 07/04/01 To 08/03/31"

2. Statement in Comment Field:

"Reporting is for the period of 10/01/07 ending 03/31/08, under the OCS General Permit 72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007."

07/28/08 Operators

Previous OCS General Permit:

1. Monitoring period to be recorded at the top of the DMR (written in YY/MM/DD format as it appears on the DMR):

"From 07/07/01 To 08/06/30"

2. Statement in Comment Field:

"Reporting is for the period of 07/01/07 ending 09/30/07, under the OCS General Permit 69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004."

Current OCS General Permit:

1. Monitoring period to be recorded at the top of the DMR (written in YY/MM/DD format as it appears on the DMR):

"From 07/07/01 To 08/06/30"

2. Statement in Comment Field:

"Reporting is for the period of 10/01/07 ending 06/30/08, under the OCS General Permit 72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007."

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Chapter IV
Notice of Termination (NOT)/Final DMRs

1. In accordance with Part I.A.3. of the permit, operators are to submit a Notice of Termination (NOT) within 60 days of termination of lease ownership for lease blocks assigned to the operator by the Department of Interior or within 60 days of termination of operations in the case of temporary operations (i.e., hydrostatic testing).

2. Part I.A.3. of the permit also allows the operator the "option" of submitting their final DMR with that NOT. A few things the operator needs to be aware of regarding final DMRs:

• EPA bases the effective date of termination on when it receives the NOT.

• Final DMRs will be required for all monitoring periods within which the operator held the lease, including up through when EPA received the NOT. For example:

Operator ABC has a monitoring period of "From 01/01/08 To 12/31/08." Operator ABC submits a NOT dated 12/31/08 for Mustang Island 51 but EPA does not receive it until January 7, 2009. DMRs for Mustang Island 51 will be required for the period: "From 01/01/08 To 12/31/08" as well as final DMRs for the period "From 01/01/09 To 12/31/09." This is because the NOT was received within a new monitoring period.

• Submission requirements for DMRs provided with a NOT are the same as if it were being submitted at the operators normal annual submission date. Specifically, the operator must provide an original (with pen&ink signature) plus one legible "copy" of the DMR. This includes No Discharge/No Activity Lists which are an "in lieu of" DMR.

• If the NOT is for an operator affected by the split reporting of the previous and current OCS General Permits, and the NOT was submitted within that time frame, then two sets of "final DMRs" will be required. One for the previous OCS General Permit; the other for the current OCS General Permit. See Chapter II of these Instructions for how to record the monitoring period information on each set of DMRs.

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Chapter V
Transfer Agreements (TA)/Final DMRs

A Transfer Agreement (TA) is a legal agreement in which Operator B agrees to accept, all or in part, the transfer of coverage from Operator A for a specific or series of lease areas/blocks.

The TA also serves as a NOT for Operator A if they are transferring all of their coverage. In this instance, Operator A has the option of submitting final DMRs with that TA. And, as with a NOT, termination becomes effective on the date EPA received the TA.

As a reminder, all DMR Completion Instructions are to be followed when submitting DMRs, whether at an operator’s annual submission, with a NOT, or with a TA when the TA is serving as a NOT for Operator A. For example: an original and one legible "copy" are to be provided.

Furthermore, if Operator A is transferring all of their coverage and the TA is dated prior to the end of Operator A’s monitoring period end date, but received by EPA after the start of a new monitoring period for Operator A, then Operator A must submit two DMRs. One for the monitoring period within which the TA (serving as a NOT) was dated, and another for the monitoring period within which EPA received the TA.

NOTE: If Operator A has a "01/28/08," "04/28/08," or a "07/28/08" annual submission deadline for their DMRs and their TA (serving as a NOT) is dated and/or received during their monitoring period overlapping the previous OCS General Permit (69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004) and the reissued OCS General Permit (72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007), then Operator A must submit all DMRs required for both permits (see Chapter II of these Instructions for specifics of how to report). For example:

Operator A has a "04/28/08" annual submission deadline. They submit a TA, serving as a NOT, dated March 28, 2008, but not received by EPA until April 7, 2008, then Operator A must submit 3 sets of DMRs for each lease area/block listed on their TA in which full coverage was transferred to Operator B. NOTE: MVDT below refers to the monitoring end date.

Set 1: For the previous OCS General Permit, MVDT=03/31/08. The Comment Field will reflect: [Reporting is for the period "From 04/01/07 To 09/30/07" under OCS General Permit 69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004.]

Set 2: For the reissued OCS General Permit, MVDT=03/31/08. The Comment Field will reflect: [Reporting is for the period "From 10/01/07 To 03/31/08" under the OCS General Permit 72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007.]

Set 3: For the reissued OCS General Permit, MVDT=03/31/09. This DMR is required due to the fact the TA was received after the start of a new monitoring period, that being "From 04/01/08 To 03/31/09." However, no comment in the Comment Field is required regarding the monitoring period as the overlap of two OCS General Permits does not apply.

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Chapter VI
No Discharge/No Activity List

1. Part II.D.4. of the permit authorizes operators to submit a list of those lease areas/blocks in which the entire lease area/block had no discharge or activity during the monitoring period. The No Discharge/No Activity List (hereafter, List) serves as an "in lieu of" DMR.

2. Only those lease areas/blocks in which the entire lease area had no discharge or activity can appear on the List. Operators cannot split report a lease area/block. For example, under Mustang Island 51 the operator cannot report 0001A via the DMR form with 0001T on the List, regardless if they had no discharge/no activity for produced water toxicity. If there is any discharge or activity, then the lease area/block (with all of its assigned PF's) must be reported via the DMR form.

3. As with the DMR form, operators must submit an original with pen&ink signature and one legible "copy."

4. Again, as with the DMR form, each page of the List must identify/provide:

• The name of the operator.

• The operator’s assigned NPDES permit number [this includes the "GMG" portion of their permit number (i.e., GMG290700 not GMG290000 or GMG 290700 or 290700)]. EPA tracks and monitors many different types of NPDES permits, some with similar names and/or similar permit numbers (in part). These reports must be distinguishable. Therefore, the full permit number is required by Operators on their Lists and not just a portion of the permit number. The alpha characters as well as the numeric characters all make up the permit number. [The emphasis here is provided as this continues to be a common error on some reports received under the OCS General Permit.]

• The operators assigned monitoring period being reported. NOTE: The assigned monitoring period cannot be altered on the List. If a lease area/block was held for less than the full monitoring period assigned to that operator, then the operator can place a footnote in the Comment field stating the range of time they are reporting for that lease area/block.

• The name of the lease area/block (again, it must be spelled out; abbreviations will not be accepted).

• Each PF assignment for a given lease area/block (i.e., Mustang Island 51, PFs 0001A, 0001K, 0001S, and 0001T). NOTE: Where an operator had submitted a Notice of Intent or a Transfer Agreement and their PF assignments were not available at the time of their annual submission, then the operator should state "PNDG" (for "pending") in the PF column followed by a footnote stating, "PF assignment pending EPA’s review of our NOI (or TA) dated mm/dd/yy."

• The signature of an authorized individual.

• The full language of the certification statement as found in Part II.D.10.c. of the permit and at 40 CFR 122.22(d).

5. The List must be prepared using a font size of 10-point/12 characters per inch or larger. These reports are reviewed and processed by EPA manually and must not cause undue eye strain on the part of the reviewer or data entry person. In addition, these reports are public records and must be legible to the requestor of such information under the Freedom of Information Act.

6. NOTE: Operators with a "01/28/08," "04/28/08," and "07/28/08" submission date who are preparing a No Discharge/No Activity List will have to submit two Lists. One representing the previous OCS General Permit (69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004); the other representing the reissued OCS General Permit (72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007). Each List will need to identify which permit the List is representing by providing the Federal Register citation of that permit.

7. See the next page for an example of a No Discharge/No Activity List.

Oil & Gas Company ABC 123, GMG290700
Listing of Lease Areas/Blocks With
No Discharge/No Activity
(Note: PF Stands for Permitted Feature)
For the Monitoring Period: "From 01/01/10 To 12/31/10" (MVDT=12/31/10)
Lease area/block Produced Water Toxicity PF Cooling Water Intake PF (1) SBM PF(1) All Other Reporting Requirements PF
Mustang Island 24 0001T (2) (2) 0001A
Ewing Bank 985 0010T 0010K 0010S 0010A
Garden Banks 75 PNDG(3) (2) (2) PNDG(3)
Eugene Island 70 0079T 0079K 0079S 0079A
Grand Isle 15 0175T 0175K 0175S 0175A
Mississippi Canyon 45 PNDG(4) PNDG(4) PNDG(4) PNDG(4)
(1) PF assignment will only be made if requested by the Operator via their NOI or TA.
(2) PF assignment not requested by the operator.
(3) PF assignment pending (PNDG) EPA’s review of NOI dated 12/31/10.
(4) PF assignment pending (PNDG) EPA’s review of a Transfer Agreement dated 12/01/10.
"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



__________________________
Date

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Chapter VII
Discharge Monitoring Report (DMR)

1. Offshore Operator Committee (OOC) Facsimile DMR Form

• Only those operators who submitted a written (signed and certified) request to use this form will be authorized to use it.

Caution: Authorization to use the form could be terminated if an operator consistently fails to comply with the requirements for usage of the form.

Expiration of Form - Part I: Where an OCS General Permit has expired and an operator had received authorization from EPA to use the OOC’s facsimile DMR form for that permit, then their authorization for usage of that form also expired with that expired permit. In other words, prior OOC DMR facsimile authorizations for previous OCS General Permits do not "roll over" to a reissued OCS General Permit. [ This is the same policy for all NPDES permits the EPA issues and tracks.] Operators will have to seek authorization for any new OOC DMR forms reflective of a reissued OCS General Permit via a signed and certified written request.

Expiration of Form - Part II: Where a permit has expired and the operator had received authorization from the EPA to use the OOC’s facsimile DMR form for that permit, then the operator is still authorized to use the now expired form to fulfill any DMR submission requirements pertaining to that expired permit. [Examples include: 1) An operator who’s monitoring period overlaps two permits (the previous permit and the reissued permit). or 2) The operator must submit a corrected DMR for the previous permit. In both of these examples, the operator is fulfilling reporting requirements for the previous permit. This is not to be confused as a "roll over" authorization.]

• Operators must submit their own written request for authorization to use any new OOC DMR form. Meaning, one operator cannot submit on "behalf of" another operator. For example, a parent company cannot submit "on behalf of" their wholly-owned subsidiary. Or, a consulting firm cannot submit "on behalf of" their client.

• A special note for "01/28/08," "04/28/08," and "07/28/08" operators where reporting for both the previous OCS General Permit and the reissued OCS General Permit will be required and who choose to use the OOC’s facsimile DMR form to meet their submission requirement: Please be sure you are authorized to use the OOC’s facsimile DMR form for both the previous OCS General Permit as well as the reissued OCS General Permit. If you did not have authorization for the previous permit’s OOC facsimile DMR form, then you will need to submit a written request (signed and certified) requesting retroactive authorization to use that form. Retroactive OOC DMR form authorization will only be to fulfill reporting requirements for the previous permit; it does not carry over into a reissued OCS General Permit.

• Operators who elect (and are authorized) to use the OOC’s facsimile DMR form must provide certain items of information that would normally have been provided to them via the EPA’s preprinted DMR form. Specifically, operators must provide:

a. Operator name/address: The name of operator and their address must appear in the upper left corner, on each DMR page, for each PF requirement.

b. NPDES permit number: Operators are to provide in the appropriate block of the form their assigned NPDES permit number, in its entirety (i.e., GMG290700) and not the master permit number of GMG290000. Also, their assigned permit number must be stated on each page of the DMR, for each PF requirement, in the format of, for example, "GMG290700" and not GMG 290700 or GMG-290700 or 290700.

c. Lease area name/block number: Consistent with EPA’s preprinted DMR form, operators are to only state the lease area/block number in the upper right corner of the DMR form, above the No Discharge block, on each DMR page for each reporting/PF requirement. [EPA reviews thousands of sheets of DMR forms and must be able to efficiently and expeditiously locate this information.] In addition, the lease area name is to be spelled out; no abbreviations will be accepted.

d. PF Assignment: Operators are to state the full PF assigned to that lease area/block, on the appropriate DMR form for each specific PF requirement. [For example: Mustang Island 25 was assigned PF numbers 0001T, 0001S, 0001K, and 0001A. The PF 0001T can only be recorded on the produced water toxicity DMR form; it cannot be used for an SBM reporting requirement. EPA continues to receive DMR forms with incorrect PF noted.] Operators are also reminded they must record the full PF and not a partial (i.e., 0010A, not 0010 A or 010 or 10A). NOTE: Where an operator had submitted a Notice of Intent or a Transfer Agreement and their PF assignments were not available at the time of their annual submission, then the operator should leave the PF block blank (see Discharge Number on the form). They are to follow-up by stating in the Comment field, "PF assignment pending EPA’s review of our NOI (or TA) dated mm/dd/yy."P

e. Monitoring Period: Operators are to provide the monitoring period assigned to them, on each page of the DMR form, for each reporting requirement. It must be recorded in "yy/mm/dd" format, consistent with the EPA’s DMR form. [Note: where an operator is reporting on a lease area/block in which coverage was held for less than their assigned monitoring period, then the operator must still record their assigned monitoring period at the top of the DMR form. If the operator so desires, they are to use the Comment Field to explain periods of time less than their monitoring period.]

f. Font size: Operators are to use a font size of 10-point/12 characters per inch or larger. These reports are manually reviewed and entered into EPA’s database (at this time) and must be of a font size not to cause eye strain. EPA reviews thousands of sheets of DMR forms and small print can be very taxing on the eye.

g. No Discharge Block: The No Discharge block in the upper right corner of the form is to be checked only if that PF is no discharge/no activity. Operators cannot check the block for a specific page of an PF and yet report sample measurement data on the other pages of the same PF. Also, for example, if 0001A has sample data but 0001T had no discharge, then the DMRs forms for both PFs must be used. The operator cannot "split report" 0001A on the DMR form and 0001T on the No Discharge/No Activity List. The List can only be used if the entire lease area/block is no discharge/no activity.

2. Operators who have a "01/28/08", "04/28/08", or "07/28/08" DMR submission date:

(NOTE This section was only applicable in the first year following reissuance of the permit.)

• Operators in these submission groups must submit DMRs under both the previous OCS General Permit (69 FR 169, p. 60150, October 7, 2004, effective November 6, 2004) as well as the reissued OCS General Permit (72 FR 109, p. 31575, October 1, 2007, effective October 1, 2007).

• The "10/28/08" operators are not affected. Meaning, they do not have to split their reporting under two separate OCS General Permits because the permit was reissued effective with the start of their monitoring period (10/01/07).

• For those operators who are authorized to use the OOC’s facsimile DMR form, the monitoring period for both sets of DMR forms must state the same monitoring period; this is required. The comment field is to be used to show the distinction of the forms. (See Chapter II for specifics on how to report the monitoring period on the DMRs for both permits.)

• Where an operator did not request authorization to use the OOC’s facsimile DMR form, they will receive two sets of EPA preprinted DMR forms. One representing the previous OCS General Permit; the other representing the reissued OCS General Permit. Both will state the same monitoring period; this is required. There will be a cover letter with each set identifying which permit the form represents. Operators are to refer to Chapter II of these instructions for the information they must provide in the comment field.

3. Preprinted EPA DMR Form Reminders

Do not alter the monitoring period provided on the form. The dates as they appear are the assigned monitoring period for that operator for all of their lease areas/blocks, regardless of when the operator acquired the property. An operator may use the comment field to record periods of time that are less than the full monitoring period.

Do not alter the PF or the lease areas/block information. These PF's were assigned by the EPA for that particular lease area/block. (NOTE: Where an operator is using preprinted EPA DMR forms, and where that particular lease area/block appears on their No Discharge/No Activity List, then the form can be "recycled" to report another lease area/block if the operator does not have a DMR form for that lease area/block. HOWEVER, the operator must be sure to white-out the preprinted PF and lease area/block and record the proper lease area/block and PF information being reported on the recycled form.)

Do not alter the NPDES permit number.

What is to be submitted to EPA. Operators must return the top copy (original) with pen&ink signature, plus one of the carbons. The carbon must be legible.

Corrections. Any corrections on the form must be legible and they must be initialed (this includes the carbon copy).

Commas/decimal points. Operators are to be careful when using pen&ink or the typewriter to complete the preprinted DMR forms where commas and/or decimal points are being used. Errors in punctuation could cause a violation to appear that is not really a violation. [For example: Produced Water Toxicity, Oil & Grease has a daily maximum of 42 mg/L. The operator "rested" their hand while completing the form using a pen and the sample measurement was recorded as "42,000 mg/L" when in reality it was "42.000 mg/L." The comma makes it appear they violated the maximum limit.]

Signatures. Must be pen&ink. They cannot be "stamped"; carbon; crossed out and re-written as such with a corrected/revised DMR; traced; signed "on behalf of"; one person signing the name of another; or, altered. And, they must be by an individual who meets the definition of an authorized person as found in Part II.D.10. of the permit and 40 CFR 122.22(b).

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Chapter VIII
Parameter Descriptions/Limitations/Reporting Requirements

NOTE: Parameters will be listed: first by PF type (i.e., Cooling Water Intake), then by category (i.e., Drill Cuttings, Drill Fluids), then numerically by storet code (i.e., 04311, 04312, 78244, 78245, etc.) within that PF/category.

• Categories include, but are not limited to: drill cuttings, drilling fluids, deck drainage, etc.

• PF requirements include: cooling water intake, synthetic based muds (SBM), produced water toxicity, and all other reporting requirements.

• Sandblasting/maintenance waste.

• Produced water toxicity.

• Parameters will be in bold/underscore print, followed by their description and reporting requirements.

Cooling Water Intake (PF's ending K)

In accordance with Part I.B.12, "These requirements apply to new facilities for which construction was commenced after July 17, 2006, with a cooling water intake structure having a design intake capacity of greater than 2 million gallons of water per day, of which at least 25% is used for cooling purposes."

1. Cooling Water Intake Velocity

85868 R

New non-fixed facilities. The cooling water intake structure(s) must be designed and constructed so that the maximum through-screen design intake velocity is 0.5 ft/s or less.

85868 S

New fixed facilities that employee sea chests as Intake structures. The cooling water intake structure(s) must be designed and constructed so that the maximum through-screen design intake velocity is 0.5 ft/s or less.

85868 T

New fixed facilities that do not employee sea chests as intake structures. The cooling water intake structure must be designed and constructed so that the maximum through-screen design intake velocity is 0.5 ft/s.

2. Cooling Water Baseline Study

85869

Report "0" (zero) if the study was conducted.
Report "1" (one) if the study was not conducted.

3. Cooling Water Entrainment Monitoring Study

85870

Report "0" (zero) if the study was conducted.
Report "1" (one) if the study was not conducted.

4. Cooling Water Intake Inspection

85871

Report "0" (zero) if the inspection was conducted.
Report "1" (one) if the inspection was not conducted.

Sandblasting/Maintenance Waste

Operators should refer to "All Other Reporting Requirements," PFs ending A, B, or C, of this Chapter. For MODUs, please refer to Chapter II.

Synthetic Based Muds (SBM) (PF's ending S)

1. Stock Base Fluid

51114

Polynuclear Aromatic Hydrocarbons (PAH). The mass ratio is grams of PAH (as phenanthrene) divided by the mass in grams of base fluids shall not exceed 0.00001. Monitoring (frequency) shall be performed at least once-per-year on each fluid blend and the maximum ratio is 0.00001 (see Part I.D.9. of the permit).


51115

Sediment Toxicity. The ratio of the 10-day LC50 of C16-C18 internal olefin or C12-C14 or C8 ester reference fluid divided by the 10-day LC50 sediment toxicity test with Leptocheirus plumulosus of the base fluid shall not exceed 1.0. Monitoring (frequency) shall be performed at least once per year on each fluid blend (see Part I.D.7. and Part I.D.9. of the permit).

51116

Biodegradation Rate. The 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, shall not exceed 1.0. Monitoring (frequency) shall be performed at least once per year on each base fluid blend (see Part I.D.8. and Part I.D.9. of the permit).

NOTE: Stock limitations are designed to ensure that only base fluids meeting limits established by the Effluent Limitations Guidance are added to existing drilling fluids. As long as blends of fluids that are added to a built mud system meet the stock limitations and the original drilling fluid was built using base fluids or blends of fluids that meet the stock limitations, it is acceptable to mix a base fluid with a built whole mud system. It is also acceptable to mix together two built whole mud systems that contain different base fluids so long as they are themselves built with base fluids that are compliant with the stock limitations.

2. Discharge Drill Cuttings, Sediment Toxicity

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. (See Appendix A of the permit and sampling protocol in Part I.D.9.)

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 fluid.

There will be two entries on the DMR form:

51117 P

This is the monthly maximum ratio for stock limitations for a C16-C18 internal olefin. Place "N/R" (not required) in the field if it’s not required; do not leave this field blank.

51117 R

This is once-per-well at the end of drilling maximum ratio for drilling fluids which meet stock limitations for C12-C14 ester or C8 ester.

3. Discharge Drill Cuttings, Formation Oil

No discharge. Monitoring shall be performed on the drilling fluid as follows.

There will be two entries on the DMR form.

51118 S

This is the initial sample prior to drilling using the gas chromatography/mass spectrometry (GC/MS).

• Report "Pass" as a "0" (zero) if the sample passes (no formation oil in sample).

• Report "Fail" as a "1" (one) if the sample fails (formation oil found in samples).

• 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.

• NOTE: The pass/fail is to 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.

51118 T

This is the maximum weekly sample using the Reverse Phase Extraction (RPE) test method (see Part I.D.11 of the permit) or the GC/MS method (see Part I.D.11 of the permit).

• Report "Pass" as a "0" (zero) if the sample passes (no formation oil in sample).

• Report "Fail" as a "1" (one) if the sample fails (formation oil found in sample).

4. Discharge Drill Cuttings, Base Fluids Retained

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.12. of this 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:

51120 U

This 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.

51120 V

This 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 for all well sections drilled using non aqueous fluids per 100 grams of wet drill cuttings.

51120 W

Report "0" (zero) for "yes" if you are meeting all the conditions of the BMPs.

Report "1" (one) for "no" if you are not meeting all conditions of the BMPs.

Report "N/R" (not required) if you are not using a BMP.

Produced Water Toxicity (PF's ending T)

NOTE: Please see the next Section on "All Other Reporting Requirements (PF's ending A,)" for all other produced water toxicity requirements that do not appear in this Section of parameters.

Glossary of Terms/Abbreviations and their Definition Used in this Section

Term/Abbreviation Definition
"0" zero
"1" one
CHR Chronic
COEF Coefficient of Variation
LETH Lethal
LF Low Flow
LOEC Lowest Observed Effect Concentration
NOEC No Observable Effect Concentration
P/F Pass/Fail
STATRE Static Renewal
SUB-LETH Sub lethal
WET Whole Effluent Toxicity*
*(NOTE: Static renewal is a WET test, performed in a lab and in which the effluent dilutions are removed each day. Most WET tests over 24 hours duration are of this type.)

1. Menidia beryllina (Inland Silverside minnow)

TGP6B

P/F STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

"0" (Pass), or

"1" (Fail), if the growth is less than the critical dilution

TLP6B

LF P/F LETH STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

"0" (Pass), or

"1" (Fail), if the survival is less than the critical dilution.

TOP6B

NOEC [appears as NOEL on EPA’s preprinted DMR form] LETHAL STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The NOEC value for survival.

TPP6B

NOEC [appears as NOEL on EPA’s preprinted DMR form] SUB-LETH STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The NOEC value for growth.

TQP6B

COEF OF VAR STATRE 7DAY CHR - Report the 7-Day Maximum as follows:

The highest (critical dilution or control) Coefficient of Variation.

TXP6B

7-DAY CHR (LETHAL EFFECTS) - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The LOEC value for survival.

TYP6B

7-DAY CHR (SUB-LETHAL EFFECTS - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The LOEC value for growth.

2. Mysidopsis bahia (Mysid shrimp)

TGP3E

P/F STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

"0" (Pass), or

"1" (Fail), if the NOEC for growth is less than the critical dilution.

TLP3E

LF P/F LETH STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

"0" (Pass), or

"1" (Fail), if the NOEC for survival is less than the critical dilution.

TOP3E

NOEC (appears as NOEL on EPA’s preprinted DMR form) LETHAL STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The NOEC value for survival.

TPP3E

NOEC (appears as NOEL on EPA’s preprinted DMR form) SUB-LETH STATRE 7DAY CHR - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The NOEC value for growth.

TQP3E

COEF OF VAR STATRE 7DAY CHR - Report the 7-Day Maximum as follows:

The highest (critical dilution or control) Coefficient of Variation.

TXP3E

7-DAY CHR (LETHAL EFFECTS) - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The LOEC value for survival.

TYP3E

7-DAY CHR (SUB-LETHAL EFFECT) - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The LOEC value for growth.

3. Whole Effluent Toxicity

22414

WHOLE EFFLUENT TOXICITY - Report the 7-Day Minimum and the Monthly Average Minimum as follows:

The lowest WET value for either species.

All Other Reporting Requirements (PF's ending A)

1. Deck Drainage

82597

Deck Drainage, Free Oil - Enter the highest number of days in which sheens were observed in any particular month during the reporting period.

2. Drill Cuttings

82595

Drill Cuttings, Free Oil - Enter the highest number of days in which sheens were observed in any particular month during the reporting period.

3. Drilling Fluids

04311

Drilling Fluid, End of Well, 96-HR LC50 - Enter the lowest daily average 96-hour LC50 recorded during the reporting period.

04312

Drilling Fluid, Toxicity, Daily Average - Enter the lowest daily average 96-hour LC50 recorded during the reporting period.

04312

Drilling Fluid Toxicity, Monthly Average - Enter the lowest monthly average 96-hour LC50 recorded for any particular month during the reporting period.

78244

Cadmium (CD), In Barite, Dry Weight - Enter the highest concentration of cadmium in milligrams per kilogram of barite (dry weight) for stock barite added to discharged drilling fluids.

78245

Mercury (HG), In Barite, Dry Weight - Enter the highest concentration of mercury in milligrams per kilogram of barite (dry weight) for stock barite added to discharged drilling fluids.

82589

Drilling Fluids, Free Oil - Enter the highest number of days in which sheens were observed in any particular month during the reporting period.

82592

Drilling Fluids, Discharge Rate - Enter the maximum drilling fluid discharge rate (barrels per day) recorded during the reporting period.

4. Domestic Waste

82608

Domestic Waste, Solids - Enter the highest number of days in which solids were observed in any particular month during the reporting period.

5. Miscellaneous Discharges

04239 T

Misc. Free Oil In Western GOM, OCS, Untreated - Enter the highest number of days in which sheens were observed in any particular month during the reporting period.

04239 W

Misc. Free Oil in Western GOM, OCS, Chemically Treated - Enter the highest number of days in which sheens were observed in any particular month during the reporting period.

74076

Flow - Enter the estimated number of barrels per day of chemically treated discharges.

Miscellaneous Discharges - Toxicity

A. Menidia beryllina (Inland Silverside minnow)

TEM6B

LF P/F STATRE 48HR ACU - The lowest NOEC value determined during the 48-hour test period is the "48-HR NOEC value." Enter:

"0" for Pass, or

"1" for Fail, 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.

TOM6B

NOEC (appears as NOEL on EPA’s preprinted DMR form) LETHAL STATRE 48HR ACU - Enter:

The lowest NOEC value.

B. Mysidopsis bahia (Mysid shrimp)

TEM3E

LF P/F STATRE 48HR ACU - The lowest NOEC value determined during the 48-hour test period is the "48-HR NOEC value." Enter:

"0" for Pass, or

"1" for Fail, 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.

TOM3E

NOEC (appears as NOEL on EPA’s preprinted DMR form) LETHAL STATRE 48HR ACU - Enter:

The lowest NOEC value.

6. Produced Water

79834

"Produced Water, Free Oil" - Enter the highest number of days in which sheens were observed in any particular month during the reporting period.

82599

"Produced Water, Oil and Grease, Daily Average" - Enter the highest daily average measurement (mg/l) recorded during the reporting period.

82599

"Produced Water, Oil and Grease, Monthly Average" - Enter the highest monthly average measurement (mg/l) for any particular month during the reporting period.

82600

"Produced Water, Flow" - Enter the highest monthly average flow rate (barrels per day) recorded in any particular month during the reporting period.

7. Sandblasting/Maintenance Waste

85866

Maintenance Waste, Do You Have A BMP? - Record:

"0" (Yes), or
"1" (No)

85867

Maintenance Waste, Are You Using BMP? - Record:

"0" (Yes), or
"1" (No)

If an operator has a MODU under contract to perform the sandblasting/maintenance waste, then the operator should report "N/A" (for not applicable) in the sample measurement fields for the above parameters with a brief explanation in the Comment Field.

8. Sanitary Waste

82605

Sanitary Waste, Residual Chlorine - 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 Devise (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" (not required) on the DMR.

82607

Sanitary Waste, Solids - 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" (not required) on the DMR.

9. Well Fluids

04379

Well Fluids, Oil & Grease, Monthly Average - Enter the highest monthly average measurement (mg/L) for any particular month during the monitoring period.

04379

Well Fluids, Oil and Grease, Daily Average" - Enter the highest daily average measurement (mg/L) recorded during the reporting period.

82603

Well Fluids, Free Oil - Enter the highest number of days in which sheens were observed in any particular month during the reporting period.

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Chapter IX
Common Errors to Avoid

The following represent common reporting errors found on DMRs, as well as No Discharge/No Activity Lists. Operators are reminded to be careful of the following to avoid deficient DMRs that could result in enforcement action.

1. Proofread: Be sure to proofread all documents, reports, or information submitted to ensure it is accurate, complete, and true.

2. Punctuation: Be careful when completing DMRs in regard to punctuation. Specifically, be sure your commas are commas and not decimal points or that a decimal is not, for example, the writer "resting" their pen on the paper. Such punctuation errors could cause the document to appear to be reporting a violation and could be subject to enforcement action by the EPA (EPA cannot assume but go on the face value of what is reported).

3. Error Range: Please do not report sample measurement data in the format of an error range. For example: "65±7" or "138±14." Operators are to report only one number.

4. Greater than or Less than: Operators are to use the "<" and/or ">" symbols to report sample measurement data that is less than or greater than, respectively. Do not report the information as "=31,000", or "-31,000", or " ±31,000."

5. NPDES Permit Number: Operators are to report their assigned NPDES permit number, not the master number of GMG290000. Also, the "GMG" alpha portion of the permit number is to be included with the numeric characters, as both the alpha and numeric characters make up the permit number. For example: "GMG290700;" not "GMG290000" or "GMG 290700" or "GMG-290700" or "290700."

6. Certification Statement: The only legal and acceptable certification statement to appear in reports, documents, and information submitted is found in Part II.D.10. of the permit and at 40 CFR 122.22(d). Any other version is not acceptable.

7. Signature: Only the authorized individual of that operator can sign reports, documents, and information submitted. Part II.D.10 of the permit outlines who is authorized to sign. It also clearly states that if signature authority has been delegated, it must be in writing to the EPA. Parent company’s cannot sign on "behalf of" their wholly-owned subsidiaries. Each is considered a separate "legal person" under Section 301 of the Clean Water Act. Also, signatures on original documentation submitted must be original "pen&ink." They cannot be carbon, "copy", photocopy", altered, or traced/signed over. They also cannot be one person signing the name of another.

8. Abbreviations: Abbreviations of lease areas/blocks on reports and documents submitted (i.e., NOIs, NOTs, TA’s, DMRs, etc.) will not be accepted. Lease area/block names must be spelled out.

9. Corrections: Be sure to mark corrected or revised documents as such at the top of the document. Any corrections or revisions within the document, i.e., DMR, should be done so that the information being revised is clear and legible. And, they should be initialed. "Write-overs" are not acceptable; EPA cannot determine what is being reported when multiple information is laying on top of each other.

10. Conflict of data: Operators are to ensure the information they are reporting does not lend itself to a conflict. For example: reporting "N/A" on the DMR for a particular parameter then over in the Frequency of Analysis column they report "1/week." EPA cannot assume which is the correct information - No Discharge or that a sample was taken. In this instance, because EPA cannot assume what is being reported, a non-reporting violation will be generated with possible enforcement action.

11. Font size: Operators are to use a font size of 10-point/12 characters per inch or larger on all information submitted (i.e., No Discharge/No Activity Lists, DMRs, non-compliance reports, etc.). These documents and reports are manually reviewed and manually keyed into EPA’s database. The font size cannot be so small as to cause eye strain.

12. Preprinted information on the DMR: Operators are not permitted to alter the preprinted information on the DMR form. These forms represent the reporting requirements and permit limitations of the existing OCS General Permit and went through extensive review by EPA and the OOC, with final approval by the EPA. In addition, the information preprinted is also reflective of NOIs and TA’s received and processed.

13. Supporting documentation: All supporting documentation submitted with the DMR (i.e., a non-compliance report) must contain the following basic elements of information:

• Name and address of the operator
• NPDES permit number assigned to that operator
• Lease area/block number (spelled out)
• PF assigned
• Certification statement, as found in Part II.D.10 of the permit and in 40 CFR 122.22(d).
• Signature of the responsible corporate official (the signature must be original pen&ink).

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Chapter X
Acronyms

Acronym Description
BMP Best Management Practices
CFR Code of Federal Regulations
DMR Discharge Monitoring Report
MVDT Monitoring Period End Date
MODU Mobile Offshore Drilling Unit
MSD Marine Sanitation Devise
NOI Notice of Intent
NOT Notice of Termination
TA Transfer Agreement
NPDES National Pollutant Discharge Elimination System
N/D No Discharge
N/A No Activity
N/R Not Required
NCR Non-compliant Report
OOC Offshore Operators Committee
PF Permitting Feature
PNDG Pending
RPE Reverse Phase Extraction
SBM Synthetic Based Muds
IO Interal Olefin
STATRE Static Renewal

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Chapter XI
Outfall and PF Descriptions/Types (Past and Present)

PCS Terminology

Outfall

Description

xxxA

All Other Reporting Requirements (except as noted below).

Outfall ending A (i.e., 001A) for operators who have (historical as well as the present) lease areas/blocks numbering from 001 up through 999.

xxxB

All Other Reporting Requirements (except as noted below).

Outfall ending B (i.e., 001B) for operators who have (historical as well as the present) lease areas/blocks numbering from 1,000 up through 1,999.

xxxC

All Other Reporting Requirements (except as noted below).

Outfall ending C (i.e., 001C) for operators who have (historical as well as the present) lease areas/blocks numbering from 2,000 up through 2,999.

xxxJ

Produced Water Toxicity.

Outfall ending J (i.e., 001J) for produced water toxicity requirements from the OCS General Permit that expired on 11/17/97 (effective from 11/01/98 thru 06/30/99) for operators who had PFs numbering from 1,000 up through 1,999.

xxxP

Produced Water Toxicity.

Outfall ending P (i.e., 001P) for produced water toxicity requirements from the OCS General Permit that expired on 11/17/97 (effective from 11/01/98 thru 06/30/99) for operators who had lease areas/blocks numbering from 001 up through 999.

xxxS

Synthetic Based Muds.

Outfall ending S (i.e., 001S) for operators who have (historical as well as the present) lease areas/blocks numbering from 001 up through 999.

xxxR

Synthetic Based Muds.

Outfall ending R (i.e., 001R) for operators who have (historical as well as the present) lease areas/blocks numbering from 1,000 up through 1,999.

xxxW

Synthetic Based Muds.

Outfall ending W (i.e., 001W) for operators who have (historical as well as the present) lease areas/blocks numbering from 2,000 up through 2,999.

xxxK

Cooling Water Intake.

Outfall ending K (i.e., 001K) for operators who have (historical as well as the present) lease areas/blocks numbering from 001 up through 999.

xxxL

Cooling Water Intake.

Outfall ending L (i.e., 001L) for operators who have (historical as well as the present) lease areas/blocks numbering from 1,000 up through 1,999.

xxxM

Cooling Water Intake.

Outfall ending M (i.e., 001M) for operators who have (historical as well as the present) lease areas/blocks numbering from 2,000 up through 2,999.

xxxT

Produced Water Toxicity.

Outfall ending T (i.e., 001T) for operators who have (historical as well as the present) lease areas/blocks numbering from 001 up through 999.

xxxY

Produced Water Toxicity.

Outfall ending Y (i.e., 001Y) for operators who have (historical as well as the present) lease areas/blocks numbering from 1,000 up through 1,999.

xxxZ

Produced Water Toxicity.

Outfall ending Z (i.e., 001Z) for operators who have (historical as well as the present) lease areas/blocks numbering from 2,000 up through 2,999.


ICIS Terminology
PF

Description

xxxxA

All Other Reporting Requirements

xxxxS

Synthetic Based Muds

xxxxK

Cooling Water Intake

xxxxT

Produced Water Toxicity

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Chapter XII
EPA Region 6 Contacts

For any questions about DMR Completion or reporting, please call:

Mr. Robert Houston
Enforcement Officer (6EN-WM)
Office: 214/665-8565
email: houston.robert@epa.gov

For any questions about NOIs, NOTs, TA’s, DMR forms, please call:

Ms. Sharon Haggard
Environmental Protection/Offshore Specialist (6EN-WC)
Office: 214/665-6472
email: haggard.sharon@epa.gov

For any questions about the permit, or its issuance or reissuance, please call:

Mr. Isaac Chen
Permit Writer (6WQ-PP)
Office: 214/665-7368
email: chen.isaac@epa.gov

24-Hour Hotline:

Email

r6genpermit@epa.gov

214/665-6595

http://www.epa.gov/region6/6en/w/cwareprt.htm

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