and reporting requirements for WQBELs and TBELs that were inadequate to
with the TBELs, because it "does not require an actual measurement
ensure compliance with the 2013 VGP TBELs because the method only
agreed, holding that the 2013 VGP monitoring requirements for TBELs were
selected Regulation D-2 as the 2013 VGP TBELs without adequately
approach taken by the EPA in establishing the TBELs.
water quality standards when TBELs are insufficient.
monitoring and reporting verification methods for TBELs in the 2013 VGP