Practices used by offshore polluters to violate the Federal Clean Water Act

In the offshore oil & gas industry for the past 35 years it has been a common practice to doctor overboard dicharged produced water samples sumbitted to the regulatory agecies for testing of pollutants , oil , grease , chemicals , toxins ,and heavy metals.

Herein lays a personal account of what i have be taught , insturcted , mentored and eye witnessed employees of oil companies and contract companies doing in an effort to DOCTOR UP samples of overboard discharged produced water into the Gulf of Mexico, in intentional crimnal actions and industry wide practice , which has existed for over 35 years and is ongoing today , which violate the NPDES requirements and compliance with the Clean Water Act to prevent pollution of the nations waters.

Requirement : Thru a 24 hour period utilizing the regulatory provided sample jar catch 3 separate samples into the same jar over a 24 hour period from the discharge point before entering the environmental waters "

Practice 1

Using a " non approved clean catch jar " the operator will take a " diluted " sample of the discharged produced water " after " it has entered the envrionmental waters , an unapproved sampling point, testing the sample with a relatively inexpensive testing device to ensure the sample is below the toxic level and then poring the sample into the " official " collection jar, ensuring a " clean " but false water sample which meets regulatory requirement ,and submitting it to the regulatory agency for testing.

Practice 2

Using a " non approved clean catch jar " the operator will take a sample of the discharged produced water from the " approved " sample point , the operator will then test the sample for pollution utilizing approved testing equipment , once excessive pollution is identified in the water sample to be submitted for testing , the operator will then " filter " the test sample and remove contaminats and pollution from the test sample utilizing everyday coffee filters , then retest the sample , and upon verifying that the sample is belows the regulatory requirements , will then pour the " filtered " and " altered " sample into the approved sample jar and submitt for regulatory testing.

Practice 3

Using a " non approved clean catch jar " the operator will take a sample of the discharged produced water from the " approved " sample point, with no regard for any pollution limits the operator will as a " matter of routine and common practice filter and alter " the produced water sample and then submit the sample for testing by regulatory agencies.

Practice 4

The operator will simply provide a sample of " potable water " rather than the produced water and then submit the sample for testing by regulatory agencies

Practice 5

The operator will identify a " clean sample source from a different location or facility " and provide the produced water sample falsifying the facility and location from which the sample was taken and then submit the sample for testing for several other facililties which are required to provide samples for regulatory testing.

For the past 35 years I have worked in the offshore oil and gas industry and have witnessed these criminal acts by industry personnel through out the Gulf of Mexico from offshore waters of Texas , Louisiana , Mississippi and Alabama.

The " filtering and altering " of the discharged produced water to " remove oil , grease , chemicals and toxins " into the Gulf of Mexico waters , is a common every day prectice utillized by the offshore oil and gas industry personnel.

Although denied and discredited by industry executives , the practice exixt , the "code of conduct being what goes on offshore stays offshore" , these inncorrect misguided political statements by industry executives are "ignorant lacking of any true experience" beliefes of individuals who have never truly spent any quantity of time or experience any actual significant "offshore" time on a platform and been able to witness the criminal corruption and practices which exist

The truth the whole truth is , the Gulf of Mexico is being polluted in unprecident and unknown quantities greater than what is known or imagined by federal authorities, corporate executives , scientist , envionmenalit, individuals and industries which depend upon the health of the Gulf of Mexico and our Oceans.

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, Baton Rouge Environmental News Examiner

Randy Comeaux is a native born child of the southern United States, who has chosen his home in the heart of Acadiana, living with his wife and our 4 children. His passion is family, outdoors, horses, camping and travel-which he is trying to incorporate into the unique festivals and vacation areas...

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