ENV-04-201 Negotiating Higher NPDES Permit Limits– Optimizing Technology and Water Quality based Effluent Limit Calculations for Petroleum Refining

Description:

Facility compliance can be improved by planning for permit renewal and using strategic approaches when developing the permit renewal application. Given an understanding of the methodology, data, and assumptions used in development of effluent limitations, the application can be developed to provide the most favorable presentation of data and facilitate development of the highest possible limits allowed under the regulation. This paper provides an overview of strategic approaches that can be employed to optimize effluent limitations for petroleum refineries.