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as it is EPA's responsibility to independently determine appropri- 

 ate environmental limitations, it is also EPA's responsibility to 

 insure that NPDES permits for offshore oil and gas facilities are 

 issued without unnecessary delays and in coordination with other 

 Federal agencies having responsibilities on the OCS. 



Thus, EPA is committed to an OCS permitting policy and process 

 which: (1) insures that NPDES permit limitations are established 

 which will provide adequate protection of the marine environment; 

 (2) Develops necessary permit limitation at the earliest possible 

 stage in the OCS lease sale process. I will describe that a little bit 

 later. To the extent possible, we are moving to achieve this by 

 gathering and evaluting our information in cooperation with other 

 Federal agencies as part of the development of environmental 

 impact statements prepared prior to the OCS lease sales; (3) Estab- 

 lishes in the rulemaking process appropriate permit limitations, 

 such as new source performance standards and ocean discharge 

 guidelines; and (4) Promotes the issuance of the less resource- 

 intensive NPDES general permits and I will describe the general 

 permit process later. 



EPA's statutory authority to regulate discharges into marine 

 waters from offshore oil and gas exploration and production oper- 

 ations is derived from the Outer Continental Shelf Lands Act, and 

 its 1978 amendments, which you are familiar with, and from the 

 Federal Water Pollution Control Act, now known as the Clean 

 ^Vater Act 



Section 402 of the Clean Water Act established the NPDES 

 permit program to regulate the discharge of pollutants from point 

 sources into waters of the United States including the territorial 

 seas, continguous zone, and the oceans. Section 301 of the Clean 

 Water Act prohibits the discharge of any pollutant without an 

 NPDES permit or in violation of the terms and conditions of an 

 NPDES permit. 



The Clean Water Act authorizes EPA or, if a State NPDES 

 permit program has been approved, an approved State to issue 

 NPDES permits. However, EPA issues permits to all point sources, 

 such as mobile drilling rigs and production platforms, discharging 

 into the ocean waters beyond the 3 mile territorial limit, regardless 

 of whether the adjoining coastal State has an approved NPDES 

 permit program. 



The Outer Continental Shelf Lands Act, Public Law 95-372, ex- 

 tends Federal laws such as the Clean Water Act, to the seabed, 

 subsoil, and fixed structures, such as artificial island drilling rigs, 

 located on the Outer Continental Shelf. Thus, NPDES permits are 

 required for all discharge from offshore oil and gas facilities in 

 OCS lease sale areas. 



I would like to describe now our NPDES permit process. The 

 NPDES permit process begins when the owner or operator of a 

 pollution source files a standard application form for an NPDES 

 permit. If sufficient information is not available to develop a draft 

 permit, the State or EPA may request the applicant to submit 

 additional information such as bioassay and bioaccumulation test 

 data. Upon receipt of adequate information and after assessment of 

 the guidelines applicability to this source and other matters, a 

 draft permit is prepared and a public notice of the draft permit. 



