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Produced Water White Paper 26 4.2.1 Calculation of Effluent Limits Numerical effluent limits present the primary mechanism for controlling discharges of pollutants to receiving waters. The EPA has grouped pollutants into three categories under the NPDES program: conventional pollutants (five-day biochemical oxygen demand, total suspended solids, pH, fecal coliform, and oil and grease), toxic or priority pollutants (including metals and manmade organic compounds), and nonconventional (including ammonia, nitrogen, phosphorus, chemical oxygen demand, and whole effluent toxicity). The effluent limits describe the pollutants subject to monitoring as well as the appropriate quantity or concentration of pollutants. Permit writers derive effluent limits from the applicable technology-based effluent limitation guidelines (ELGs) and water quality-based standards. The more stringent of the two will be written into the permit. 4.2.1.1 Effluent Limitation Guidelines (ELGs) ELGs are national technology-based minimum discharge requirements. These standards are developed by EPA on an industry-by-industry basis and represent the greatest pollutant reductions that are economically achievable for an industry sector or portion of the industry (e.g., offshore oil and gas platforms). The selection of ELGs involves consideration of technologies that have already been demonstrated in industrial applications, costs and economic impacts, and non-water quality environmental impacts. ELGs are applied uniformly to every facility within the industrial sector, regardless of the location of the facility or the condition of the water body receiving the discharge. Existing facilities must meet a level of performance known as best available technology economically achievable (BAT) for toxic and nonconventional pollutants. The EPA has defined the BAT as the performance associated with the best control and treatment measures that have been, or are capable of being, achieved. While the EPA must still consider the cost of attainability in the context of BAT, it is not required to balance the implementation cost against the pollution reduction benefit. (For conventional pollutants only, BAT is replaced by best conventional pollutant control technology [BCT].) New facilities must meet new source performance standards (NSPS). NSPS reflect the most stringent limits based on performance of the state-of-the- art technologies. The EPA has developed ELGs for most major industrial categories. For the oil and gas industry, EPA developed separate ELGs for onshore activities in 1979, offshore activities in 1993, and coastal activities in 1996. The terms onshore, offshore, and coastal may be illustrated by drawing an imaginary line that runs along the coast of a country. The line crosses the mouth of rivers, bays, and inlets. Any facility to the ocean side of the line is an offshore facility. Any facility to the land side of the line and located on land is classified as an onshore facility. Any facility in or on the water or in wetlands on the land side of the line is a coastal facility. For example, a facility located in a marsh or inside a river mouth or bay is a coastal facility. The EPA has codified the ELGs in the Code of Federal Regulations (CFR) at 40 CFR Part 435 — oil and gas extraction point source category.PDF Image | Produced Water from Production of Crude Oil
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