Monitoring and Permitting of Offshore Oil and Gas Platform Effluents: An Update of Cooperation and Compliance

Abstract

The Pacific Outer Continental Shelf (OCS) Region of the Minerals Management Service (MMS) and the United States Environmental Protection Agency (EPA) Region 9 have worked cooperatively to perform National Pollutant Discharge Elimination System (NPDES)-related inspections and to collect compliance samples of selected waste streams since 1989. Since 1996, MMS has also worked closely with EPA and other stakeholders to help develop a new General NPDES permit that will cover all of the oil and gas exploration, development, and production operations in the OCS region of southern California. This new permit will require a more stringent level of compliance and replace the existing, out-dated southern California OCS permits. This paper provides a brief discussion of the water quality offshore southern California and a description of the discharges commonly associated with offshore oil and gas facilities. It describes the relationship between the EPA and MMS which includes administering the monitoring program, devising the yearly workplan, and developing the new NPDES permit. This paper will also provide an update of the continuing compliance data collection effort. The 1997 California and the World Oceans Conference featured a presentation describing the status of the data collection effort and the beginning stages of the permit development process. The latter includes an evaluation of the potential for a discharge to cause, or have the reasonable potential to cause or contribute to, exceedences of federal water quality criteria or state standards (regulations in 40 CFR Part 122.44(d)). The objective of the sampling effort since 1998 has been to collect additional data to determine whether any of the constituents potentially existing in produced water exceed the federal criteria or state objectives. This part of the permitting process will eventually allow EPA to direct the operators to focus self-monitoring efforts on those components of the produced water effluent that have the greatest reasonable potential to exceed water quality criteria. Additional sampling and analyses of produced water components not required by the current General NPDES permit include red abalone toxicity tests, sulfides, ammonia, and volatile organic compounds. The offshore inspections and sample collections are undertaken by MMS on behalf of EPA and are based on a Memorandum of Agreement (MOA) initially signed by both agencies in 1989. This MOA takes advantage of MMS's expertise in water quality-related issues and daily presence on the OCS oil and gas platforms offshore southern California. Since 1990, MMS has made nearly 150 visits to offshore oil and gas platforms in this cooperative effort. MMS has used these data to evaluate environmental impacts of offshore oil and gas platforms. MMS has developed an Excel© spreadsheet that includes drilling discharge information and produced water chemical components, as well as the results from the toxicity analyses. These data are important in working with local agencies to address environmental concerns, as well as National Environmental Policy Act requirements. To further facilitate examination of statistical trends, export to a database such as Access can be performed. This information can be used for NEPA analyses and to answer questions from the public and other agencies concerning discharge characteristics and impacts on water quality.