IPAA, Multi-Association Comments to the Environmental Protection Agency on its Effluent Limitations Guidelines for Unconventional Oil and Gas Pretreatment

IPAA, Multi-Association Comments to the Environmental Protection Agency on its Effluent Limitations Guidelines for Unconventional Oil and Gas Pretreatment

We believe that EPA’s analysis is flawed and fails to realistically undertake its responsibilities under the Clean Water Act (CWA) to create ELGs that meet not only current circumstances but future needs as well. Consequently, we recommend that EPA withdraw the current proposed pretreatment ELG for UOG extraction waste water, that it conduct a thorough review of actual waste water management technologies, that it determine best available technology economically achievable and new source performance standards based on these technologies, and that it then repropose an appropriately revised pretreatment ELG.

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