The New Gulf of Mexico National Pollution Discharge Elimination System Permit: How does it Shape up?

Abstract

Abstract December 2001 marked the introduction of a new modification to the EPA National Pollution Discharge Elimination System (NPDES) Permit for Region 6 (Gulf of Mexico.) The changes related to the permit's coverage of the discharge of synthetic based fluids on cuttings. Regulators in other areas of the world, for example North Sea and Nigeria, have also permitted discharge of synthetic based fluids on cuttings. However, time has seen increasing restriction of discharge rules and has also seen operators forced to go to zero discharge of synthetics base fluids. The permitting of discharge, followed by tightening of regulations, and, sometimes, ultimate moves towards zero discharge by regulators has had a profound impact on usage, development, and availability of synthetic based drilling fluids. This paper lists key events regarding environmental regulations and follows the developments following the introduction of the new NPDES Permit for the Gulf of Mexico from the perspective of a drilling fluid supplier and examines industry reactions to the implementation of the permit. It also seeks to answer two key questions from the supplier's perspective-"How is this rulemaking different from that seen in other areas in the world?" and "Is the next regulatory step for the Gulf of Mexico zero discharge"?