[UDFCD-support] Letter to EPA regarding CD ELG Final Rule

[Ken MacKenzie]

Forwarding this as it may eventually affect most of us, depending on how it
plays out. -Ken MacKenzie, UDFCD


This is a letter from the Small Business Administration to the EPA. To
summarize:

-EPA set a standard based on "passive treatment" as the model technology,
yet almost exclusively relied on data from modified advanced treatment
systems (ATSs) in establishing the standard, and EPA's cost estimates are
therefore too low by approximately a factor of ten because of this error;

-EPA failed to obtain background information on the Sea-Tac airport project
to properly characterize the pretreatment systems at this site, resulting in
EPA counting data from these systems at least five times more than
justified;

-EPA promulgated a 280 NTU standard without providing the public with an
opportunity to review the data or methodology upon which it was based. We
have subsequently uncovered a series of technical errors that, at a minimum,
should cause EPA to reconsider the standard and raise the limitation to more
than 500 NTU;

-EPA set the limit using data from advanced treatment systems rather than
passive treatment systems. Although the technology basis for the ELG was
passive treatment systems If EPA excluded the advanced treatment systems
(ATSs) from consideration, the standard would be in the neighborhood of 800
NTU,

-EPA errors include misinterpretation of vendor data, and the use of a
technology that is not the basis of the rule.


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