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 standards that protects the receiving waters…

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 would be below the default standards after…

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 equally for all of a…