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STATEWIDE ACCOMPLISHMENTS

 

Hall & Associates has coordinated statewide regulatory modification efforts and has developed and submitted comments on proposed and existing water quality standards and permitting procedures on behalf of municipalities, industries, and municipal/ industrial coalitions in states throughout the country.  In every case, our efforts have led to major changes in the applicable water quality criteria and/or the implementation of innovative approaches to toxics permitting. In some instances, the passage of state legislation or the formation of governor-sponsored advisory committees that have recommended adoption of a majority of the issues we have addressed has achieved these results.  Click on a state to see a representative list of our accomplishments.

 

 

STATE

PROJECT / ACCOMPLISHMENT

Alaska:

  • Petition for rulemaking triggered EPA proposal to withdraw federally adopted human health arsenic criteria on a statewide basis.

 

California:

  • Proper averaging periods for ammonia and toxics approved in two regions.
  • Obtained approval of site-specific criteria for ammonia, cadmium, copper, and lead.
  • Obtained approval of innovative mixing zone approach which considers toxicological characteristics of  pollutant.
  • Developed proper reasonable potential analyses to avoid multiple worst-case assumptions in permit development.
  • Agreement reached to use fish tissue data to assess need for mercury limits.

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Colorado:

  • Obtained state approval for site-specific sludge application program recognizing low potential for exposure from selenium.

 

Connecticut:

  • Copper criteria corrected to be less restrictive for municipal discharges on a statewide basis.
  • Obtained approval for mass limitations approach to allow appropriate metals limitations for individual facilities.

 

Delaware:

  • Use of innovative wasteload allocation techniques allowed.
  • Expanded procedures for site-specific water quality standards approved.
  • Less restrictive mixing zones permitted.

 

Delaware River Basin Commission:

  • Obtained approval of less restrictive mixing zone policies.
  • Obtained approval of site-specific approaches for permit calculations.
  • Updated lead and arsenic criteria.
  • Clarification of reasonable potential procedures for including limitations in permits.

 

Florida:

  • Obtained state approval of innovative flow-based permitting for WET limitations.
  • Approval of a permit compliance provision exception for toxicity from a federally approved pesticide.
  • Obtained approval of site-specific mixing zones.

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Georgia:

  • Approval of site-specific standards for copper and zinc.
  • Statewide revision of criteria to measure only the toxic form of metals.
  • Agreement on innovative approach to chronic WET implementation.
  • Approval of innovative pretreatment limitations analyses to reduce industrial discharge requirements using inter-plant pollutant trading.
  • Approval of Section 303(d) TMDL de-listing.

 

Iowa:

  • Approval of revised standards and permit calculations for ammonia on a statewide basis.
  • Prepared regulatory update on numerous water quality issues that trigger numerous state program revisions.

 

Kansas:

  • Initiated statewide update to permits program.
  • Obtained statewide revision to ammonia toxicity, mixing zone, and design flow provisions used to calculate NPDES limitations.

 

Kentucky:

  • Filed petition to recognize variability issue regarding biomonitoring procedures that led to statewide modification of  permit provisions.

 

Louisiana:

  • Obtained EPA's concurrence on use of fish tissue measurements to address mercury bio-accumulation concerns.

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Maine:

  • Obtained state re-evaluation of aluminum criteria.

 

Maryland:

  • Obtained EPA/state approval of site-specific approach to evaluate iron-related toxicity.

 

Massachusetts:

  • Statewide revision of metals criteria to the bioavailable form.

 

Minnesota:

  • Stayed the implementation of ammonia requirements pending the outcome of EPA's review of the national criteria.
  • Prepared evaluation leading to statewide revision of water quality-based permitting program.
  • Agreement reached on the use of stream/plant flow correlations for permit derivation.
  • Agreement reached to revise copper and silver criteria  implementation.
  • Innovative approach to avoid chlorine non-compliance due to short-term exceedances.
  • Obtained approval of innovative flow-based permit requirements for ammonia.

 

Missouri:

  • Obtained first approval for high rate diffuser to the Mississippi River authorizing elevated ammonia discharge.

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New Hampshire:

  • NPDES permit calculation procedures modified to authorize flow correlation and use of drought and treatment plant flows to establish water quality-based limits.

 

New Jersey

  • Across-the-board update of NPDES permitting processes (all aspects).
  • Deletion of flow limitations
  • Correction of permit averaging periods.

 

New Mexico:

  • Establishment of less stringent ammonia criteria statewide.
  • Provided for application of metals criteria under a dissolved protocol.
  • Authorized use of probabilistic modeling methodologies.

 

North Carolina:
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  • Secured adoption of innovative point/non-point pollutant credits trading program for nitrogen.
  • Obtained first state approval for removal credits program.

 

North Dakota:

  • Obtained statewide update to ammonia criteria and design flows.

 

Oklahoma:

  • Implemented program to prevent interference due to major industrial user.

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Oregon:

  • Averaging periods on the dissolved oxygen standard revised to reflect the latest EPA science.
  • Chronic criteria revised from daily minimum to 30 day averages.

 

Pennsylvania:

  • Revision of the metals criteria to allow dissolved, bioavailable approach.
  • Withdrawal of silver chronic criteria.
  • Agreement on the use of fish tissue data to modify mercury human health criteria.
  • Modification of acute criteria application in mixing zones.
  • Corrected averaging period approach on acute standards.
  • Approval of innovative WER procedures for deriving copper limitations.

 

Tennessee:

  • Initiated program to clarify proper application of federal bypass regulation and allow authorization of blending to manage peak wet weather flows.

 

Utah:

  • Approved use of  probabilistic modeling and site-specific ammonia standards.

 

Virginia:

  • Obtained approval of use of dissolved metals approach.
  • Secured first state approval of probabilistic modeling.

 

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