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Fwd: EPA Region 8 Comments on DRAFT Exploration and Production Waste Rules
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JaLynn Knudsen <jknudsen@utah.gov>Mon, May 6, 2024 at 7:44 AM
To: Deq submit <dwmrcsubmit@utah.gov>
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---------- Forwarded message ---------
From: Hubner, Tara <Hubner.Tara@epa.gov>
Date: Friday, May 3, 2024 at 4:27:28 PM UTC-6
Subject: EPA Region 8 Comments on DRAFT Exploration and Production Waste Rules
To: Utah Division of Waste Management and Radiation Control <dwmrcpublic@utah.gov>
Cc: Hensley, Amy (she/her/hers) <Hensley.Amy@epa.gov>, Newland, Jesse (he/him/his) <Newland.Jesse@epa.gov>,
Maxwell, Annette <Maxwell.Annette@epa.gov>, Ruhs, Alison <Ruhs.Alison@epa.gov>, Saldenha, Jasmine
<Saldenha.Jasmine@epa.gov>, Beierle, Rob <Beierle.Rob@epa.gov>
EPA Region 8 Comments on DRAFT Exploration and Production Waste Rules
May 3, 2024
EPA Region 8 RCRA Program provides the following information for consideration while Utah DEQ finalizes the draft
Exploration and Production (E&P) Waste Rules, including concerns with some current oil and gas waste management
practices.
EPA Region 8 RCRA Enforcement and Program have performed inspections and site visits and taken enforcement action
under Section 7003(a) of RCRA at several oil and gas waste management facilities in Utah. During inspections, site visits,
and in the findings of imminent and substantial endangerment enforcement orders, EPA identified many problems at oil
and gas waste management facilities, which include:
Landfills containing free liquids and oily waste
Open-top storage tanks containing oil or oily waste
Surface impoundments of produced fluids covered with oil or oily sheens
Lack of netting or other preventative measures to keep wildlife out of the liquid and oily waste units mentioned
above
Whole bird carcasses and remains of bird carcasses within or near waste units
Landfarms of concerning depth
Upwelling of oil and free liquids from closed waste units
Mixing non-E&P waste that was a listed or characteristic hazardous waste in units designed to manage E&P waste
exempt from regulation under RCRA Subtitle C
Tara Hubner, PG | Environmental Scientist
Hazardous Waste - RCRA Branch
U.S. EPA Region 8 | Land, Chemicals and Redevelopment Division (LCRD)
1595 Wynkoop St (Mailcode 8LCR-RC) | Denver, CO 80202
5/6/24, 1:00 PM State of Utah Mail - Fwd: EPA Region 8 Comments on DRAFT Exploration and Production Waste Rules
https://mail.google.com/mail/b/AEoRXRR7iQeljWFqWDk5PQsnGV0n1MeTkhofqHSHCUMdDOupaVZD/u/0/?ik=adf9d5e615&view=pt&search=all&per…1/2
T: 303-312-6597
Hubner.tara@epa.gov
5/6/24, 1:00 PM State of Utah Mail - Fwd: EPA Region 8 Comments on DRAFT Exploration and Production Waste Rules
https://mail.google.com/mail/b/AEoRXRR7iQeljWFqWDk5PQsnGV0n1MeTkhofqHSHCUMdDOupaVZD/u/0/?ik=adf9d5e615&view=pt&search=all&per…2/2