Document bBjy8R6erVZ5yJJb972mR5XKg
REGION 6
DALLAS, TX 75270
June 21, 2024
Mr. Blair Spencer Cantium, LLC 111 Park Place Drive, Suite 100 Covington, LA 70433 blair.spencer@cantium.com
RE: Clean Water Act, Section 308 Information Request Oil Platform Inspection and Sampling NPDES ID: GMG290615
Dear Mr. Spencer:
Pursuant to Section 308 of the Clean Water Act (CWA), 33 U.S.C. Section 1318 et seq., the United States Environmental Protection Agency (EPA) has the authority to request information pertinent to carrying out its responsibilities under the CWA. Accordingly, this Information Request is hereby served on you and Cantium, LLC.
Compliance with the provisions of this letter is mandatory. Please provide the information requested below and copies of the requested documents within 30 days of receipt of this letter. The response must be signed by a duly authorized official of Cantium, LLC. The information will be considered in the evaluation of the extent of your compliance with the Clean Water Act, federal regulations, and the Gulf of Mexico Offshore Oil & Gas NPDES General Permit (GMG290000), ("General Permit").
EPA is currently conducting an inspection of Respondent's oil platform D, M, L Facilities and is interested in information concerning compliance with the General Permit, Effluent Limitations and Monitoring Requirements.
Failure to respond fully and truthfully to the Information Request, or to adequately justify such failure to respond, will be considered a violation of Section 309 of the CWA, as amended by the Water Quality Act of 1987, which can result in enforcement action by the EPA. Section 309 of the CWA permits the EPA to seek the imposition of civil and criminal penalties for failure to submit information requested under Section 308 of the CWA, including issuance of an Administrative Penalty Order or referral to the United States Department of Justice for judicial action with monetary fines. Please be further advised that providing false, misleading, or fraudulent statements or representations, may subject you to criminal penalties under Section 309 of the CWA.
Cantium, LLC NPDES ID GMG290615 Page No. 3
This Information Request is not subject to the approval requirements of the Paperwork Reduction Act, of 1980, as amended, 44 U.S.C. Section 3501, et. seq., as described in 5 CFR Part 1320.3(c).
You are hereby requested to provide the following information regarding Cantium, LLC, Platform D, M, L Facilities and compliance with Effluent Limitations and Monitoring Requirements.
1. The full legal name and contact information for the owner and operator of the PLATFORM (e.g., company name). Provide the appropriate contact information for each person who consulted in or contributed to the preparation of the answers to this Request. Include affiliation, a telephone number, a mailing address, and an email address to reach this individual (e.g., company representative).
2. Produced Water Monitoring: Oil and Grease.
Pursuant to Part I.B.4, Produced Water discharges must meet effluent limitations specified in the General Permit and in accordance with method 1664.
During the current EPA Inspection, please collect a sample for oil and grease monitoring. EPA inspectors should witness the sampling.
Within 30 days of receipt of this letter, analyze the sample in the manner prescribed by the Permit and submit the results to EPA. Provide date, time, and sampler names for the reading. Provide data quality assurance information, if available, and documentation establishing chain of custody.
In some instances, information requested by the EPA may be considered confidential business information (CBI) by the provider of that information. Should any of the information requested by the EPA as part of this request for information be considered CBI material by Cantium, LLC, you must assert that claim as part of your reply. The final determination regarding this material will be made by the EPA per the regulations found in 40 CFR Part 2.204.
At this time, the EPA is requesting that the information requested be submitted electronically. Please email your response to garcia.mitty@epa.gov. If you are unable to submit the information electronically, please mail it to the following address:
Ms. Mitty Garcia Water Enforcement Branch (ECDWE) U.S. EPA Region 6 garcia.mitty@epa.gov
Cantium, LLC NPDES ID GMG290615 Page No. 3
If you need additional time to respond to this request or if you have any questions relating to this Information Request, please contact Ms. Mitty Garcia at 214-665-6497.
Sincerely,
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Digitally signed by
CHERYL SEAGER Date: 2024.06.21
10:33:32 -05'00'
Cheryl T. Seager, Director
Enforcement and
Compliance Assurance Division