A cornerstone RBI service is National Pollutant Discharge Elimination System (NPDES) permit renewals for our Publicly Owned Treatment Works (POTW) clients. RBI staff prepare reports of waste discharge (ROWD) for renewal of waste discharge requirements (WDRs) /NPDES permits for numerous municipal wastewater dischargers in California. The ROWDs included a facility and discharge characterization, facility performance and compliance evaluation, justifications for modified monitoring and reporting requirements, and requests for consideration in the development of effluent limitations. Dischargers for which RBI has led the preparation of ROWDs include:
Following preparation of the ROWD, RBI also assists clients during the period when Regional Water Board staff are developing the WDRs/NPDES permits by facilitating data reviews and responding to requests for supplemental information. RBI conducts thorough review and prepares detailed comments on the preliminary draft and tentative NPDES permits to identify factual corrections and to assess the appropriateness of effluent limitations, receiving water limitations, and special provision requirements. In addition, RBI staff prepare “infeasibility analyses” needed to justify inclusion of compliance schedules in the NPDES permit or outside order (e.g., time schedule order or cease and desist order) for our clients.