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Blog_SeptemberThis month’s blog is a continuation of my previous blog on detailed re-evaluation of local limits.

Re-evaluation of local limits must be carried out periodically to ensure protective limits and operation and POTWs may wish to review local limits when preparing their annual Pretreatment Program Reports. However, a detailed re-evaluation is necessary when there is a change in operating conditions, environmental criteria, data or assumptions used to establish local limits or if POTW violates its NPDES permit limitations but all the regulated IUs have been maintaining compliance which needs evaluation on adequacy of local limits to protect treatment works, workers and environment.

Detailed re-evaluation is a four step process:

  1. Assess Current Conditions to determine whether MAHLs should be re-calculated, MAILs reallocated or additional local limits should be developed. Also determine which pollutants need to be further evaluated and for which criteria. Please note that if only re-allocation of existing MAHLs is needed, skip to step 4.
  2. Collect and Analyze Data to determine whether existing data is sufficient based on the pollutants and criteria identified in Step 1. If not, develop and implement site specific sampling plan, then analyze the data collected.  
  3. Recalculate existing or determine MAHLs for new pollutants of concern (POC) if the results of the analyses conducted in steps 1 and 2 warrant.
  4. Implement the local limits if MAHL for POCs should be reallocated among the sources of pollutants which involves following:



  • Allocating or reallocating MAHLs.
  • Public Participation.
  • Approval of revised local limits considered either non-substantial or substantial modification as defined in 40 CFR 403.18(b).
  • Adoption of local limits and revisions to the Sewer Use Ordinance (SUO).
  • Revisions of control mechanism or Industrial User (IU) permits.


In my next blog, I will be talking on addressing concerns about collection systems.

Please contact me if you have any questions.

Shri Vani Sripada is a Project Engineer at Smith Management Group. Shri Vani can be reached at shrivani@smithmanage.com

Source: EPA’s Local Limits Development Guidance, July 2004.

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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 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.

SMG 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.


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.