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Joint Trade Comments on NPDES General Permit

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Joint Trade Comments on NPDES General Permit July 10, 2017 Submitted via www.regulations.gov Water Division US Environmental Protection Agency, Region 6 1445 Ross Avenue, Suite 1200 Mail Code: 6EN Dallas, TX 75202-2733 RE: Joint Trades Comments Notice of Proposed NPDES General Permit Permit for New and Existing Sources and New Dischargers in the Offshore Subcategory of the Oil and Gas Extraction Category for the Western Portion of the Outer Continental Shelf in the Gulf of Mexico (GMG290000) Docket ID No. EPA-R06-OW-2017-0217 The Offshore Operators Committee (OOC), the American Petroleum Institute (API), and the National Ocean Industries Association (NOIA), hereinafter referred to as “the Joint Trades,” appreciate the opportunity to provide detailed comments on the above-captioned NPDES General Permit. Comments submitted on behalf of the Joint Trades are submitted without prejudice to any member’s right to have or express different or opposing views. It is from this perspective that these comments have been developed. The Joint Trades API is a national trade association representing more than 625 member companies involved in all aspects of the oil and natural gas industry. API’s members include producers, refiners, suppliers, pipeline operators, marine transporters, and service and supply companies that support all segments of the industry. API and its members are dedicated to meeting environmental requirements, while economically and safely developing and supplying energy resources for consumers. API is a longstanding supporter of offshore exploration and development and the process laid out in the Outer Continental Shelf Lands Act (“OCSLA”) as a means of balancing and rationalizing responsible oil and gas activities and the associated energy security and economic benefits with the protection of the environment. NOIA is the only national trade association representing all segments of the offshore industry with an interest in the exploration and production of both traditional and renewable energy resources on the U.S. Outer Continental Shelf (OCS). The NOIA membership comprises more than 325 companies engaged in a variety of business activities, including production, drilling, engineering, marine and air transport, offshore construction, equipment manufacturing and supply, telecommunications, finance and insurance, and renewable energy. OOC is an organization of 41 producing companies and 53 service providers to the industry who conduct essentially all oil and gas exploration and production activities in the Gulf of Mexico (GOM) OCS. 2 Founded in 1948, the OOC is a technical advocate for the oil and gas industry regarding the regulation of offshore exploration, development and producing operations in the GOM. Comments The Joint Trades’ detailed technical comments are included in the attachment. The Joint Trades believe the information included in the attached comments is important and critical to providing a final permit that is protective of water quality in the GOM, as well as a practical permit that allows the continued development of our nation’s energy resources. The attached comments are structured to include suggested edits to the proposed permit language and justification for the suggested change. Cooling Water Intake Structure Entrainment Monitoring One concern that the Joint Trades would like to highlight is the continued requirements for cooling water intake structure entrainment monitoring (see Comment 37 in the attachment for more details). The Joint Trades strongly object to the continued requirement to conduct ongoing entrainment monitoring. The Joint Trades request the removal of entrainment monitoring/sampling requirement and the addition of language requiring permittees to submit a SEAMAP data report annually. 40 CFR 125.137.a.3 provides the Director the flexibility to reduce the frequency of monitoring following 24 months of bimonthly monitoring provided that “seasonal variations in species and the numbers of individuals that are impinged or entrained” can be detected. The report on the 24 month industry entrainment study (1) documents that many important Gulf of Mexico species were not detected at all in the regions where new facilities are expected to be installed so that entrainment impacts on these species will be zero; (2) provided documentation on the seasonal dependence of species and number of eggs and larvae available for entrainment, and (3) concludes that anticipated entrainment will have an insignificant impact on fisheries in any season; the Joint Trades believes that the intent of 40 CFR 125.137 has effectively been met and that the requirement for ongoing entrainment monitoring can be removed. Our request is based on the results of the results of the recently completed Gulf of Mexico Cooling Water Intake Structure Entrainment Monitoring Study and reinforced by the quarterly entrainment monitoring reports by individual operators. Industry believes that these results warrant removal of the entrainment monitoring/sampling because (a) the study showed that no meaningful impacts from entrainment are expected; (b) no meaningful impact was found, therefore, the seasonality of the impact is a moot point; (c) the SEAMAP database provides a continually-updated source of information that is functionally equivalent to permit-required monitoring for the purpose of estimating entrainment impacts. The Gulf of Mexico Cooling Water Intake Structure Entrainment Monitoring Study was conducted for the purposes of informing policy and permit requirements with sound science. The conclusions of the study are clear – there are no meaningful impacts. Yet, the science presented in the study is not being utilized to inform changes to permit requirements. Regulatory Reform Initiatives In addition to the detailed, technical comments included with this letter, the Joint Trades also plan to engage EPA Headquarters in discussions regarding the impact of the recent Presidential Executive Orders 13771, Reducing Regulation and Controlling Regulatory Cost, and 13795, Implementing an America-First Offshore Energy Strategy, on the renewal of NPDES Permit GMG290000. As presented in the attached detailed comments, the Joint Trades offer several positions that question the necessity of changes proposed 3 in the draft permit. The proposed changes, taken in their entirety, do not appear to be in keeping with the intent of E.O. 13771 and E.O. 13795. Therefore, it is our intent to engage EPA on the need for the proposed changes, whether the proposed changes provide any benefits for water quality of the Gulf of Mexico, and if the proposed changes comply with the Executive Orders. Also, the Joints Trades, through OOC, will be contacting EPA Region 6 staff, after the comment period closes, to request a meeting to review the attached technical comments, and answer any clarifying questions the agency may have regarding the information provided here. The Joint Trades appreciate EPA’s efforts regarding the draft permit, and look forward to working with the agency on the important issues included in our comments as the permit is finalized. If you have any questions or require additional information, please contact Mr. Greg Southworth at [email protected], or Mr. James Durbin at [email protected]. Sincerely, Greg Southworth Associate Director Offshore Operators Committee Amy Emmert Senior Policy Advisor American Petroleum Institute Tim Charters Senior Director National Ocean Industries Association 4 cc (via email): Environmental Protection Agency: Scott Pruitt, Administrator Samuel Coleman, Regional Administrator, Region 6 Bill Honker, Water Division, Region 6 Scott Wilson, Energy Coordinator, Industrial Branch/Water Permits Division Stacey Dwyer, Associate Director, NPDES Permits & TMDL Branch, Region 6 Brent Larsen, Permits & Technical Section, Region 6 Isaac Chen, Permits & Technical Section, Region 6 Mitty Mohon, NPDES Enforcement Officer, Region 6 Sharon Angove, NPDES Enforcement, Region 6 Bureau of Safety and Environmental Enforcement: Scott Angelle, Director Lars Herbst, Gulf of Mexico Regional Director TJ Broussard, Gulf of Mexico Regional Environmental Officer Bureau of Ocean Energy Management: Walter Cruickshank, Acting Director Michael Celata, Gulf of Mexico Regional Director Gregory Kozlowski, Gulf of Mexico Deputy Regional Supervisor, Office of Environment Draft NPDES General Permit for New and Existing Sources and New Dischargers in the Offshore Subcategory of the Oil and Gas Extraction Point Source Category for the Western Portion of the Outer Continental Shelf of the Gulf of Mexico (GMG290000) GMG290000 May 11, 2017 Draft Renewal Permit, Docket # EPA-R06-OW-2017-0217 – The Joint Trades Comments General Note – all permit text is shown in quotations. All suggested revisions to the proposed permit text are shown in red and strikethroughs within OOC’s comments. Comment Permit Type/Category Current or Revised Permit Language /Clarifications/Issue Rationale No. Section Ref. 1 Notice of Intent Part I.A.2 “A Notice of Intent (NOI) must be filed 24-hour in advance to cover specific discharges prior to commencement of specified discharges.” The Joint Trades request that the 24-hour requirement of this condition be removed. In certain situations, it is not always feasible for a permittee to file a Notice of Intent (NOI) 24- hours in advance to cover a discharge. Due to potentially sudden and unforeseen changes in operational priority, weather conditions, asset availability/functionality, an operator will not always know about commencement of discharging 24-hours
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