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Mass Based Local Limits Allocations

Utility water-cycle model for copper control (from 2008 in Durango). Summary:Pretreatment programs can have greater leverage in the control of copper into and out of the POTW by considering a system wide approach.The pollutant contributions across the utility water cycle may provide various key co

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Mass Based Local Limits Allocations

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    1. Mass Based Local Limits Allocations USEPA Region VIII Conference May 2010 Presenter: Ridge Dorsey Pretreatment Supervisor City of Boulder, Colorado 303-413-7361 dorseyr@bouldercolorado.gov

    2. Utility water-cycle model for copper control (from 2008 in Durango) Summary: Pretreatment programs can have greater leverage in the control of copper into and out of the POTW by considering a system wide approach. The pollutant contributions across the utility water cycle may provide various key control points.

    3. Copper Influences on POTW Effluent Compliance (from 2008 in Durango)

    4. “Adoption of mass-loadings: This is probably the preferred method, but is done much less frequently for SIUs. Most POTWs find that uniform allocation is easiest to manage.” EPA Region VIII Local Limits Strategy - 2003

    5. Presentation Format General Local Limits Information EPA Guidance Manuals Local Influences on Limits Development Development of Mass Limits Industrial User Allocations SIU Permits, Limits, and Reporting Evaluating SIU Compliance Observed Benefits of Mass Limitations

    6. Local Limits General Information Influent Scan Pollutants of Concern SIU, Commercial, Domestic, Septage Data POTW Removal Efficiencies Limiting Criteria (NPDES Permit, WQ Stds., Sludge Criteria) MAHL (Max. Allowable Headworks Loading) MAIL (Max. Allowable Industrial Loading) Local Limit Adoption – Concentration, Mass, Instantaneous, Daily, Monthly

    7. EPA Guidance 1987 – Guidance Manual on the Development and Implementation of Local Discharge Limitations ….. 1991 – Supplemental Manual On the Development and Implementation of Local …Residential and Commercial Toxic Pollutant Loadings … 2003 – Technically-Based Local Limits Development Strategy –( Region 8 ) 2004 – Local Limits Development Guidance

    8. How Good is the EPA Guidance? Excellent? Good? Fair? Okay? Not too Good?

    9. Local Influences POTW Design (may influence removal efficiencies) Limiting Criteria (WQ Stds, Biosolids Stds, NPDES) SIU Characteristics (Heavy Industrial vs. other) Community Growth (always important)

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