INTEGRATED LEGAL, TECHNICAL, ENGINEERING AND ECONOMIC ANALYSIS

• STATE WATER QUALITY STANDARDS / NPDES PROGRAM REFORM:
  Prepared "White Papers" on NPDES and water quality standards issues in 15 states leading to statewide modification of existing rules. Issues addressed included metals, ammonia, mixing zones, mathematical modeling, averaging periods, and permit calculation procedures.
• NATIONAL TOXICS RULE, SLUDGE RULE AND WHOLE EFFLUENT TOXICITY TEST PROCEDURES:
  Participated in court actions which resulted in remands and/or substantial beneficial revisions of rules and issues of national guidance documents, including nationwide revision of heavy metal criteria, sludge incineration monitoring, and selenium requirements.
• EFFLUENT GUIDELINES ANALYSIS:
  Provided comments and technical analysis on Metal Products and Machinery Proposed Rule which caused deferral of Rule pending additional data collection and reconsideration of Benefits Analysis. Obtained deferral of pharmaceutical guideline for Lysine manufacturer.
• WHOLE EFFLUENT TOXICITY GUIDANCE:
  Promoted revisions to national policies and obtained nationwide clarification regarding proper application of whole effluent toxicity requirements.

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