The PESA Health, Safety, and Environment Committee recently submitted comments to the Environmental Protection Agency on a draft permit governing activities in the Gulf of Mexico offshore the states of Mississippi, Alabama, and Florida.
The National Pollutant Discharge Elimination System (NPDES) general permit sets limits, monitoring requirements, and other mandates on discharges from exploration, development, and production facilities in federal waters of the Gulf.
The EPA’s proposed permit contains a number of new requirements related to well treatment, completion and workover fluids. PESA’s comments provided significant technical input into the impacts of EPA’s draft language, covering issues related to confidential business information to specific details of testing requirements.
EPA will review these comments as it develops the final permit. The term of that permit is expected to be no longer than five years.