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This entry of my blog will talk about evaluating the need for local limits development. A POTW can evaluate their needs in three steps:
1)    I mentioned several factors relating to this topic in my previous blog.  In addition, EPA recommends that POTWs evaluating a pollutant for the first time should assume that local limits are needed when any of the following are true:
•    Average influent loading of a toxic pollutant exceeds 60% of the Maximum Available Headworks Loading  or MAHL  (I will discuss more about this in my future blogs);
•    Maximum daily influent loading of a toxic pollutant exceeds 80% of the MAHL at any time in the 12-month period preceding the analysis;
•    Monthly average influent loading reaches 80% of the average design capacity for BODs, TSS and Ammonia during any one month in the 12-month period preceding the analysis.

Please note that these percentages to trigger local limits development are default assumptions that can vary from plant to plant. The approach used for toxic pollutants is more conservative because most POTWs are not designed to treat toxic pollutants.

2)    By reviewing past permit violations, sludge disposal restrictions, inhibition incidents POTW can identify the pollutants for which it should set or maintain local limits.

3)    Any obvious signs during inspections that local limits are needed or need to be re-evaluated.

These findings are also applicable for the re-evaluation of local limits which helps POTW to conduct an in-depth look at all criteria and assumptions on which local limits are based to determine whether any changes affecting the local limits have occurred. A detailed re-evaluation process will be discussed in my future blogs.

In my next few blogs I will talk more about the Local Limits and its process of development/re-evaluation.

If you have any questions, please contact me at shrivani@smithmanage.com

Source: U.S. EPA Introduction to the National Pretreatment Program, 2011; EPA’s Local Limits Development Guidance, July 2004


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FEATURED PROJECT


PROBLEM

A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.


SMG'S APPROACH

SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.

MG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.


RESULTS

SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.