90% of produced water that has gone through separation/treatment at the
production facility is transferred to a separate facility to be reinjected (57%) or for
disposal (36%) (EPA-HQ-OPA-2007-0584-0015). There are sufficient amounts of
oil recovered at the disposal facilities for states to define this type of oil in their
regulations and to impose a severance tax at rates similar to the rates imposed
on primary crude. EPA should not create additional confusion by not recognizing
standards held by States and a 30 year EPA history.
Anonymous public comment
This is comment on Rule
Oil Pollution Prevention: Non-Transportation Related Onshore Facilities; Spill Prevention, Control, and Countermeasure Rule - Final Amendments
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