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Keys to Appropriate NPDES Permitting of Low Effluent Nutrient Discharges

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Wastewater utilities and regulators both face challenges in setting and meeting low nutrient effluent NPDES discharge limits. Both also benefit from an improved understanding of the practical capabilities of advanced wastewater treatment technology. A new Water Environment Research Foundation (WERF) report published in September 2010, Nutrient Management: Regulatory Approaches to Protect Water Quality, Volume 1 Review of Existing Practices provides a state-of-the art discussion of key nutrient management issues that confront point source wastewater dischargers nationwide, including discharge permitting issues. Work is currently underway on a companion document to provide guidelines for improvement low nutrient discharge permitting and present model discharge permits for reference. In this paper, low nutrient discharge permitting issues are discussed and key issues are identified. Impractical permit structures that result in the potential for noncompliance without being linked to additional levels of water quality protection are also discussed.
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Keywords: Clean Water Act; NPDES permit; Nutrients; TMDL; effluent limits; nitrogen; numeric nutrient standards; nutrient criteria; nutrient removal; phosphorus; total maximum daily load; trading; variance; water quality

Document Type: Research Article

Publication date: 2011-01-01

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