Re: Comments on Study of Oil and Gas Extraction Wastewater Management Under the Clean Water Act, No. EPA‐821‐R19‐001

July 1, 2019
Andrew Grinberg

July 1, 2019

Mr. Jesse Pritts

U.S. Environmental Protection Agency Office of Water (4303T)

1200 Pennsylvania Avenue, N.W. Washington, DC 20460
Submitted via email to: oil-and-gas-study@epa.gov and pritts.jesse@epa.gov

Dear Mr. Pritts:

On behalf of our members and supporters, Clean Water Action/Clean Water Fund appreciates the opportunity to provide input to US EPA on the Study of Oil and Gas Extraction Wastewater Management Under the Clean Water Act (Draft), No. EPA‐821‐R19‐ 001 (hereinafter referred to as the “Draft Study”).

The Draft Study, insofar as it addresses the question of whether or not EPA should make regulatory changes to allow for greater discharges of produced water, indicates the need to increase protections, rather than changing regulations or undertaking non-regulatory activities that would facilitate additional discharge. The Draft Study itself does not fully explore this question but is rather a summary of limited stakeholder outreach conducted by the agency. It is not a pre-rulemaking review, does not evaluate the best available science, and does not comprehensively examine current discharges and possible impacts on water quality and quantity, nor human or environmental health. Although EPA has asked the public how it could facilitate greater discharge under the Clean Water Act, existing evidence supports more restriction on produced water discharge to surface waters, not less. EPA has documented impacts from produced water in both its study of Centralized Waste Treatment facilities, and the study of Hydraulic Fracturing and Drinking Water. Furthermore, a growing body of independent research and state regulatory proceedings4 indicate water quality problems can arise from produced water discharge that should compel EPA and states to adopt additional, more stringent protections that would likely lead to LESS surface discharge, not more.

Read the full comment letter here.

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