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Project Name: NPDES Permit Compliance
Country: USA
Description: Provided regulatory compliance assistance by reviewing the facility's permit, Toxicity Reduction Evaluation (TRE) Plan, and Individual Control Strategy (ICS) and developed a plan of action for compliance with toxicity and metals limitations. The client is a subsidiary of a large textile manufacturer which has a facility located in VA that discharges wastewater under the authority of a VPDES permit. The permit includes requirements for a Toxicity Reduction Evaluation (TRE), chronic Whole Effluent Toxicity (WET) permit limitation, and an Individual Control Strategy (ICS) for copper and zinc. The client's Engineering and Environmental Department Submitted a TRE Plan to the Virginia State Water Control Board (SWCB) in March 1991. The plan was approved in February 1992. We were retained to review the status of the TRE Plan and ICS implementation. A significant amount of testing had been completed towards the identification of the source(s) of toxicity. During that process, numerous potential candidates had been eliminated. However, toxicity testing indicated that the source(s) of toxicity had not been identified. As a result of the difficulty in identifying the source(s) of toxicity, recommendations were made and the client notified the Virginia Department of Environmental Quality (DEQ) that it planned to investigate treatment methodologies on a parallel path with source identification investigations Authorization to conduct a treatability evaluation of the Surge Tank Outflow (STO) was given. As a part of the evaluation, samples of STO wastewater were submitted for acute aquatic toxicity testing using ceriodaphnia dubia. The toxicity of the STO samples used during the evaluation were considerably less than historical values. It was hypothesized that CT-202 was a source of the toxicity and that the material did not decay from the system as quickly as previously believed. As a result of additional studies that were conducted it was concluded that the elimination of CT-202 had resulted in an effluent that is infrequently toxic. However, the occasional toxicity was a concern. Therefore, in addition, to the elimination of CT-202, recommendations were made that the client take additional steps to reduce the toxicity of the effluent. The client, DEQ personnel, and our team met to review the status of the TRE and ICS. One of the discussion items at the meeting was the sampling location to determine compliance with the effluent limitations. It was agreed that since the permit identified a nearby creek as the receiving stream it would be appropriate to sample the effluent as it discharged to this creek. Sampling at the creek has indicated a reduction in metals concentrations as a result of the overland treatment. Also, an evaluation was conducted of the existing wastewater treatment facilities and recommendations were provided for both short-term and long-term modifications to the waste water treatment facilities.
 

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