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Produced Water White Paper 33 migratory pathways); the existence of special aquatic sites such as marine sanctuaries and refuges, parks, national and historic monuments, national seashores, wilderness areas, and coral reefs; the potential impacts on human health through direct and indirect pathways; existing or potential recreational and commercial fishing; and numeric water quality criteria for specific pollutants. NPDES permits for facilities discharging into marine waters are required to include limits that prevent unreasonable degradation of the marine environment. In certain cases, that may mean a discharge prohibition. If insufficient information is available to conduct the degradation assessment, the EPA will determine whether the discharge will cause irreparable harm to the marine environment and whether reasonable alternatives to onsite disposal exist. When assessing the potential for irreparable harm, the EPA determines whether the facility is likely to cause permanent and significant harm to the environment on the basis of additional information collected during a monitoring period. If the potential for irreparable harm is low, the EPA may allow a monitoring program to demonstrate that the discharge will not cause unreasonable degradation. If the data gathered through monitoring indicate that continued discharge may cause unreasonable degradation, the discharge must be halted or additional permit limitations must be established. President Clinton’s Executive Order (E.O.) 13158, issued on May 26, 2000, states that the EPA “shall expeditiously propose new science-based regulations, as necessary, to ensure appropriate levels of protection for the marine environment.” In the wake of the E.O., the EPA developed a proposal that would have made the ocean discharge regulations more stringent. However, in early 2001, the EPA withdrew the proposal. 4.2.4 Other NPDES Permit Conditions Facilities are responsible for taking the steps necessary to demonstrate compliance with NPDES permit limits. Permits instruct each facility operator regarding the frequency for collecting wastewater samples, the location for sample collection, the pollutants to be analyzed, and the laboratory procedures to be used in conducting the analyses. Detailed records of these “self-monitoring” activities must be retained by the facility for at least three years. Furthermore, each facility is required to submit the results of these analyses to the regulators on a periodic basis. For most facilities, the reporting frequency is monthly or quarterly, but in no case may it be less than once per year. NPDES permits may also require operational or environmental effects monitoring. This includes the preparation of best management practices plans or spill prevention plans. Inspectors from the EPA visit the offshore platforms occasionally to monitor their discharges and make sure that all operations are in compliance with permit requirements. Failure to meet the permit limits can result in fines or loss of the permit. 4.3 Injection of Produced Water The Safe Drinking Water Act of 1974 (Part C, Sections 1421-1426) gave the EPA the authority for Underground Injection Control (UIC) regulation. The UIC program isPDF Image | Produced Water from Production of Crude Oil
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