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Proposed Stringent Limits – Compliance Issues
Challenge Stringent discharge limits for copper and phosphorous are proposed to be included in a Northeast manufacturing facility’s NPDES Permit for cooling water discharges. The copper and phosphorous limits were established based on default...
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Clean Water Act 316(A) Variance Renewal Activities – Compliance Issues
Challenge Cooling water discharges are subject to default federal or state-wide temperature standards. Normally, a facility with cooling water discharges could meet the temperature standards if it can demonstrate that the discharge temperatures...
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Local Limits – Compliance Issues
Challenge A used oil re-refining facility in the Midwest discharges to a municipality that has strict cyanide pre-treatment local limits based on strict NPDES Permit conditions for the municipality. Local limits, which are usually distributed...
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