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Produced Water White Paper 29 discharge following treatment with reverse osmosis, and injection (EPA 2001). EPA has not yet issued its final guidance for this topic. 4.2.1.3 Water Quality-Based Limits The Clean Water Act prohibits the discharge of toxic substances in toxic quantities. This goal is accomplished through water quality-based effluent limits designed to ensure that ambient receiving water concentrations are low enough to maintain the designated use of the waters (e.g., fishing). 4.2.1.4 Calculation of Effluent Limits ELGs serve as a foundation for the effluent limits included in a permit, but the ELGs are based on the performance of a technology and do not address the site-specific environmental effects of discharges. In certain instances, the technology-based controls may not be strict enough to ensure that the aquatic environment will be protected against toxic quantities of substances. In these cases, the permit writer must include additional, more stringent water quality-based effluent limits in NPDES permits. These water quality-based limits may be numeric (the EPA has published numeric water quality criteria for more than 100 pollutants that can be used to calculate water quality-based limits) or narrative (e.g., “no toxic substances in toxic quantities”). The process for establishing the limits takes into account the designated use of the water body, the variability of the pollutant in the effluent, species sensitivity (for toxicity), and, where appropriate, dilution in the receiving water (including discharge conditions and water column properties). 4.2.2 Regional General Permits Four of the EPA’s regional offices have issued permits to facilities discharging into ocean waters beyond the three-mile limit of the territorial seas and may also issue permits to facilities in the territorial sea if the adjoining state does not have an approved NPDES program. Regional NPDES permits impose additional operational, monitoring, testing, and reporting requirements. The following describes the five most important general permits for oil and gas exploration, development, and production operations issued for the Eastern Gulf of Mexico (Region 4), Western Gulf of Mexico (Region 6), California (Region 9), and North Slope and Cook Inlet, Alaska (Region 10) (Veil 2001a). 4.2.2.1 Region 4 — Eastern Gulf of Mexico General Permit GMG280000 applies to operators of lease blocks located in the Outer Continental Shelf (OCS) federal waters seaward of 200 meters in the Eastern Planning Area and seaward of the outer boundary of the territorial seas in the Central Planning Area with existing or new source discharges originating from oil and gas exploration or development and production operations. The general permit includes the following additional requirements related to produced water discharges:PDF Image | Produced Water from Production of Crude Oil
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