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printech, February, 2001
RE: Ammonia


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From:Steven Noble (Snoble@pmai.org)
Date:Wed, 21 Feb 2001 09:21:30 -0500


A key issue is how they set their ammonia limit. Many POTWs are truly maxed out on being able to treat nitrogen related compounds and that is why they limit the discharge. Some POTWs (due to staffing and budgetary issues) really have not properly calculated their actual headworks loadings of Ammonia and simply set a number that reflects their treatment plant discharge limit (NPDES permit limit) with no consideration for reductions by the biological actions of the treatment plant. Also we have run into POTWs that really do not have a discharge limit for the treatment plant but have established a pretreatment limit for people in their system. A couple key questions that you can ask are as follows: How was the ammonia limit established? Via headworks analysis? What is the percent removal by the treatment plant? How is the commercial/industrial loading portion of the Ammonia allocated? a little to all dischargers or apportioned to those industries that actually discharge ammonia from their processes? Can we pay a surcharge for the excess ammonia that we discharge rather than installing pretreatment equipment. We have been through similar situations for effluent from photo processors. We have found that most POTWs (especially pretreatment folks) are willing to chat about the situation. Also, it is always key to POTWs and negotiations that your client is doing as much as they can to reduce their discharges. Showing that they have a pollution prevention programs in place may buy your client some flexibility in the discharge limits. Just some things to ponder. Steve Noble



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