NGWA submitted comments on March 22 to the U.S. Environmental Protection Agency’s proposed regulation to revise the technology-based effluent limitations guidelines and standards for the meat and poultry products point source category comprised of 5055 facilities nationwide.
The Association states that the rule focuses on surface water quality protection and does not adequately address protection of groundwater quality.
Specifically, the proposed rule would enable the use of evaporation ponds to reduce chlorides in brine as a wastewater needing disposal. Ponds would need to be designed and have adjacent monitoring wells or apply other geophysical measurement techniques to ensure that chloride does not enter the subsurface and contaminate groundwater directly or through mobilization from rock of heavy metals including arsenic, radium, and uranium, all of which are regulated by standards for safe drinking water under the Safe Drinking Water Act.
If permitted and used, NGWA writes in its comments that evaporation ponds should be lined based on appropriate design and construction and underlying groundwater monitored through monitoring wells or alternative geophysical techniques. NGWA recommends that the EPA first conduct an assessment of brine as a resource for certain uses and reduce the need for disposal.
Click here to read NGWA’s comments.
Click here to read the EPA’s proposed regulation.