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EPA's Region 6 Office

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

Offshore and Oil & Gas NPDES permits

NetDMR Alert

electronic Notice of Intent (eNOI) system

CDX has a test and a production environment.
TEST Site - get familiar with the new system = https://test.epacdx.net/CDX2

SUBMIT your eNOI here
= https://cdx.epa.gov/

Region 6 eNOI presentation of 10/2012
(pdf 7.15 MB 125 pp)

Region 6 NetDMR presentation 09/2013 (PDF 7.21 MB 221 pp)

NeT Regulated Community User Guide (PDF 4MB/92 pp)

REMINDERS regarding eReporting for the OCS General Permit (as of November 7, 2013):

    1. Be sure you utilize the correct eNOI form (the Change eNOI form if you had an existing NPDES permit number (GMG290xxx) prior to October 2012; the New eNOI form if you are a new OCS operator after October 2012).  Using the wrong form will result in the eNOI being incorrect and will delay coverage until the eNOI can be corrected.  In addition, EPA is finding that operators using a New eNOI form when they were an existing operator prior to October 2012 is resulting in duplicate permit numbers being assigned to the same operator; operators can only have one permit number for a single operator name.  Again, existing operators with permit numbers assigned prior to October 2012 must use the Change eNOI form.
    2. Be sure to double-check your entries on the eNOI, eNOT, and NetDMR forms before hitting the Send and/or Submit buttons.  Multiple errors are occurring in large part due to forms not being correctly completed, so please double-check your entries before submitting the form.
    3. Operator name changes and address changes must be submitted, via a paper letter (signed and certified by the corporate officer) to Ms. Sharon Angove (6EN-WC), 1445 Ross Avenue, Suite 1200, Dallas, TX 75202-2733.  Please ensure the name of the operator, and their assigned NPDES permit number are affixed to the document.

    This is the Water Enforcement Offshore and Oil & Gas NPDES discharge web page. Mr. Robert Houston is the Regional Coordinator; his phone number is (214) 665-8565. Additional enforcement officer: Mr. Anthony Loston (phone number (214) 665-3109). Ms. Sharon Angove is the Offshore Specialist; she handles general permit applications and processing of Discharge Monitoring Reports. Her phone number is (214) 665-6472. If you have non-enforcement permitting questions, please contact Mr. Isaac Chen, the permit writer, at (214) 665-7364.

    This office works closely with the Department of Interior's Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE). BOEMRE inspectors perform most of the NPDES offshore platform compliance inspections for EPA. Additionally, the US Coast Guard Marine Safety Office conducts inspections. We also work closely with the Offshore Operators Committee, which is a trade organization representing the offshore operators.

    The EPA Region 6 NPDES OCS General Permit No. GMG290000 was reissued with an effective date of October 1, 2012, expiring at midnight of September 30, 2017 [77 Fed. Reg. No. 196, p. 61605]. (Permit Language Link)

    • If you had permit coverage under the previous permit (e.g., you applied for coverage before it expired on September 30, 2007, and were assigned permitted feature(s) (PF)), then you do not have to reapply for permit coverage. You will retain your previous permit number and PF's unless EPA notifies you otherwise.
    • If you applied for permit coverage after the September 30, 2007, expiration date and utilized the previous permits NOI form, then you will need to resubmit a Notice of Intent application to be covered under this general permit, using the NOI form reflecting the reissued permit.
    • Note that your monitoring periods will remain the same as you had under the previous permit.

    EPA Region 6:  DMR Refresh Schedule for Offshore Operators:

    • Twice a month:  15th & the last day of the month. (They must run over the weekend.)
    • DMR Refreshes will ensure NetDMRs will be in Net for all eNOIs submitted that held coverage during a given calendar quarter.
    • EXCEPTION: DMR Refresh will not be run during the month when quarterly DMRs are due (that is:  January, April, July, & October)

    NOTE:  Final DMRs, where a Notice of Termination (eNOT) has been filed – the permit authorizes a final NetDMR to be submitted either with the eNOT or at the time of quarterly NetDMR submission.  If you choose to submit the final NetDMR at the same time of the eNOT, please be sure to plan submission of the final NetDMR according to the monthly DMR Refresh Schedule noted above.  Otherwise, if the NetDMR has been prepared and is awaiting signature and DMR Refresh runs, then you will have to go back in and re-save each final NetDMR.

    EPA has completed fitting out a new ship in 2005 for use in federal waters under EPA jurisdiction. This ship has many functions and will support everything from research and development to enforcement inspections. The ship is named "Bold". EPA plans to periodically use this ship in the Gulf of Mexico to perform NPDES inspections and collect on-site samples of produced water discharges from offshore oil and gas operations. The vessels specifications can be found at www.nvr.navy.mil/nvrships/details/AGOS12.htmExit EPA Disclaimer. The following are some pictures of the Bold (click on different pictures for an enlarged version).


    Discharge Monitoring Reports (DMRs):

    Operators desiring to use the new OOC DMR form reflecting the 2007 reissued permit must submit a written request (signed and certified in accordance with Part II.D.10. of the permit), with their NPDES permit number affixed, to the following address:

    U.S. Environmental Protection Agency
    NPDES Compliance Section
    Attn: Ms. Sharon Angove (6EN-WC)
    1445 Ross Ave., Suite 1200
    Dallas, TX 75202-2733

    2007 Permit Discharge Monitoring Report instructions for Offshore permittees.

    DMR Reporting: Cross-over from one permit to the reissued permit

    Operators who held a "01/28/08", "04/28/08", and "07/28/08" DMR submission deadline, were required to report under the previous permit DMR form as well as the reissued permit DMR form. This was because one portion on the monitoring cycle fell within the previous permit's effective/expiration dates; the other portion fell within the reissued permit's effective/expiration dates. (Those operators holding a "10/28/08" submission deadline were not affected). The monitoring cycle of the DMR form had to reflect that operator's assigned monitoring period; the comnment field was used to record the split period of time being reflected on that DMR. Please see the table below for specifics:

    Monitoring cycles for the cross-over period of the previous permit to the reissued permit are as follows for all but the "10/28/08" operators, who were not affected:

    For "01/28/08" operators DMR Monitoring Period >
      Previous permit DMR "From 01/01/07 to 12/31/07"
        Comment field: "From 01/01/07 to 09/30/07"
      Reissued permit DMR "From 01/01/07 to 12/31/07"
        Comment field: "From 10/01/07 to 12/31/07"
    For "04/28/08" operators DMR Monitoring Period>
      Previous permit DMR "From 04/01/07 to 03/31/08"
        Comment field: "From 04/01/07 to 09/30/07"
      Reissued permit DMR "From 04/01/07 to 03/31/08"
        Comment field: "From 10/01/07 to 03/31/08"
    >For "07/28/08" operators DMR Monitoring Period
      Previous permit DMR "From 07/01/07 to 06/30/08"
        Comment field: "From 07/01/07 to 09/30/07"
      Reissued permit DMR "From 07/01/07 to 06/30/08"
        Comment field: "From 10/01/07 to 06/30/08"


    Storm Water Discharges from inactive platforms: If you have structures in the Gulf of Mexico that are not covered by the NPDES OCS general permit that are "industrial" in nature (40 CFR 122.26(b)(14)) and they have storm water discharges from deck drainage, etc., then these facilities may be required to have an NPDES permit. If you have coverage under the NPDES OCS general permit, this permit covers those discharges. If you terminate the NPDES OCS general permit (e.g., you stop production and shut in the well) and still have storm water discharges from an industrial activity, you will need to seek alternative NPDES coverage. Oil & gas exploration and production facilities are SIC code 1381 found at 40 CFR 122.26(b)(14)(iii). Oil & Gas exploration and production facilities are exempted from needing an NPDES permit if they have not had a reportable quantity discharge (e.g., a sheen) or caused a water quality violation (see 40 CFR 122.26(c)(1)(iii)). You can find more information at the EPA Region 6 storm water enforcement web page.

    Coast Guard and EPA Enforcement of Spills: Both the EPA and the Coast Guard enforce provisions in the Clean Water Act and there are some overlapping jurisdictions in the Gulf of Mexico. EPA performs Section 309 (33 USC 1319) enforcement assuring compliance with NPDES permits and for unpermitted discharges of pollutants to waters of the U.S. The Coast Guard performs Section 311 (33 USC 1321) enforcement of oil spills (Section 311 is also known as the Oil Pollution Act). Section 311(b)(11) says "Civil penalties shall not be assessed under both this section and section 309 for the same discharge." If you have an oil spill, then you could face an enforcement action under either 309 or 311, but not both. The defendent must raise this defense if enforcement has already commenced under either section.

    Mail to the Agency: Please note that EPA Region 6 has changed mail handling procedures. Suspicious mail will have to go through additional screening and may not be delivered timely. Please make sure your mail is properly addressed, including a complete and accurate return address, to assure your mail is delivered in a timely fashion. Make sure that certfied mail has a return address on the letter in addition to the return address on the green card.

    Oil and Gas Permits, Forms, Documents (mostly in Adobe Acrobat PDF file format) and links:

    The final NPDES General Permit [Adobe Acrobat PDF file format] for New and Existing Sources and New Discharges in the Offshore Subcategory of the Oil and Gas Extraction Category for the Western Portion of the Outer Continental Shelf (OCS) of the Gulf of Mexico (GMG290000) and Notice of a Proposed Modification to that permit was published at 72 Fed. Reg. No. 109, p. 31575, published June 7, 2007, effective October 1, 2007. 

    2004 Permit Discharge Monitoring Report instructions for Offshore permittees.

    2007 Permit Discharge Monitoring Report instructions for Offshore permittees.

    Economic Analysis of Proposed Effluent Limitations Guidelines and Standards for Synthetic-Based Drilling Fluids and Other Non-Aqueous Drilling Fluids in the Oil and Gas Extraction Point Source Category.

    Environmental Assesment of Final Effluent Limitations Guidelines and Standards for Synthetic-Based Drilling Fluids and other Non-Squeous Drilling Fluids in the Oil and Gas Extraction Point Source Category: www.epa.gov/ost/guide/sbf/

    EPA's Office of Wetlands, Oceans & Watersheds is our headquarters office in Washington DC that developes polices and guidelines on discharges from offshore platforms.

    Marine Pollution Control Programs

    Final NPDES General Permit for Discharges from the Oil and Gas Extraction Point Source Category to Coastal Waters in Texas (TXG330000) This final permit was published in the Federal Register on July 7, 2007 (72 Fed. Reg. No. 109, p. 31579). Federal Register Notice. Application: Notice of Intent.

    Final NPDES General Permit for Discharges from the Oil and Gas Extraction Point Source Category to Coastal Waters in Texas (TXG330000) This final permit was published in the Federal Register on November 15, 2001 (66 Fed. Reg. No. 22, p. 57457-57465). Response to Comments.

    Common Compliance Issues:

    Non-compliance Reporting: Part II.D.7. of the OCS Permit (GMG290000), as well as in the Standard Conditions section of most NPDES permits, requires the permittee to report any non-compliance which may endanger health or the environment within 24 hours. The 24 Hour report may be either on telephone to (214)665-6593 or by E-mail to r6genpermit@epa.gov. Additionally, the oral/e-mail report is required to be followed up by a written report within 5 days of the time the permittee becomes aware of the situation. This written report shall be certified [40 CFR 122.22(d)] and signed by an authorized official [40 CFR 122.22(a)], and include your specific permit number (e.g. GMG29#### and not just GMG290000) and information regarding the non-compliance, its duration, any environmental impacts, and any remediation actions taken.

    Questions and Answer document developed with the Offshore Operators Committee for the Feb. 16th permit modifications.

    Authorized Signatories:

    40 CFR 122.22(d), as well as Part II.D.10. of the OCS permit, states that "All applications [NOIs, Transfer Agreements, Mergers, etc.], reports [Discharge Monitoring Reports, Non-compliance Reports, etc.], or information [address/contact name updates], NOT's, submitted to the Director shall be signed and certified. Many operators fail to have their documents properly signed and certifed by an authorized official of their company. The following is the certification that must accompany these documents:
    "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 gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those person 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."

    An example letter of Delegation of Signatory Authority for the Offshore Outer Continental Shelf General Permit (GMG29####) has been prepared for use by those permittees.

    40 CFR 122.22 was revised effective July 1, 2001 to amend the requirements of an authorized person. If you are corresponding with EPA regarding compliance with a permit you already have, you are to use the definition of authorized person in your permit language. Upon modification or reissuance of your NPDES permit, the definition will be updated. If do not have an NPDES permit, you should use the new definition of authorized person.

    EPA tracks all of your documentation by NPDES permit number (e.g. GMG29####). To assure your correspondence is properly filed, please make reference to your permit number in all correspondence to EPA. Also, be sure and spell out the name of the lease area. While BOEMRE uses abbreviations, there are some duplicates (e.g. MI could be either Matagorda Island or Mustang Island) and spelling the lease area out will eliminate any confusion.

    "New Source" means any facility or activity that meets the definition of "new source" under 40 CFR 122.2 and meets the criteria for determination of new sources under 40 CFR 122.29(b) applied consistently with all of the following definitions:

    (a) The term "water area" as used in the term "site" in 40 CFR 122.29 and 122.2 shall mean the water area and ocean floor beneath any exploratory, development, or production facility where such facility is conducting its exploratory, development, or production activities.

    (b) The term "significant site preparation work" as used in 40 CFR 122.29 shall mean the process of surveying, clearing, or preparing an area of the ocean floor for the purpose of constructing or placing a development or production facility on or over the site.

    “New Source” does not include facilities covered by an existing NPDES permit immediately prior to the effective date of these guidelines pending EPA issuance of a new source NPDES permit.

    Also, exploration facilities are not defined as new sources.

    The guidelines were issued on March 4, 1993 [58 Fed. Reg. No. 12504], any facility put in place after that date is a new source. It should be noted that the new source definition has little actual meaning in this case since the limits are the same for both existing sources and new sources for the 1998 GMG290000 permit. Effluent guidelines were also published at 61 Fed. Reg. No. 66085, December 16, 1996.

    Outfall and Permitted Feature (PF) Designations:

      PCS (Outfalls)
    • xxxP - produced water toxicity from the previous OCS general permit that expired on 11/19/97 (effective from 11/02/98 thru 06/30/99) for outfalls 001 thru 999
    • xxxJ - produced water toxicity from the previous OCS general permit that expired on 11/19/97 (effective from 11/02/98 thru 06/30/99) for outfalls exceeding 999
    • xxxT - produced water toxicity (post July 1999) for outfalls 001 thru 999
    • xxxY - produced water toxicity (post July 1999) for outfalls exceeding 999
    • xxxS - synthetic based muds for outfalls 001 thru 999
    • xxxR - synthetic based muds for outfalls exceeding 999
    • xxxA - all other reporting requirements for outfalls 001 thru 999
    • xxxB - all other reporting requirements for outfalls exceeding 999
      ICIS (Permitted Features)
    • xxxxA - General PF
    • xxxxS - SBM PF
    • xxxxK - Cooling Water PF
    • xxxxT - Produced Water Toxicity PF

    History of the Region 6 OCS NPDES General Permits

    Permit No. Effective Date Citation Expiration Date
    TX0085642 April 3, 1981 46 FR 20284 April 3, 1983
    reissue September 15, 1983 48 FR 41494 June 30, 1984
    GMG280000 (joint with EPA Region 4) July 9, 1986 51 FR 24897 July 1, 1991
    GMG290000 (Region 6 only) November 19, 1992 57 FR 54642 November 18, 1997
    modified December 3, 1993 58 FR 63964 November 18, 1997
    reissued adds GMG390000, New Source August 9, 1996 61 FR 41609 November 18, 1997
    reissued Part 1 November 2, 1998 63 FR 58722 November 3, 2003
    reissued Part 2 (Produced Water) April 19, 1999 64 FR 19156 November 3, 2003
    modified (SBM) December 18, 2001 66 FR 65209 November 3, 2003
    reissue November 6, 2004 69 FR 60150 November 5, 2007
    reissue October 1,2007 72 FR 31575 November 12, 2012

    EPA Region 6 covers the Western portion of the Gulf of Mexico off of the Coasts of Texas and Louisiana. EPA Region 4 covers the Eastern portion of the Gulf of Mexico.

    EPA Ship - the Bold - Front EPA Ship - the Bold - Propulsion EPA Ship - The Bold - Top-side EPA Ship - The Bold - Front Port-side EPA Ship - The Bold - Front Port-Side

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