AbstractIn July of 1977, Texas Instruments, located in Attleboro, Massachusetts was issued a five‐year National Pollutant Discharge Elimination System (NPDES) permit to discharge a treated industrial waste effluent in compliance with the Clean Water Act (CWA). The company had just completed the installation of a modern waste treatment facility employing metal hydroxide precipitation. At the time, this system was considered the Best Available Technology (BAT), and it was based on such process chemistry criteria that the original permit limits were generated.In 1982, however, when Texas Instruments submitted a renewal application for its NPDES discharge permit, water quality criteria were used in place of BAT to determine the permit limits. Since it had been shown that BAT was insufficient to achieve water qualities in receiving streams equal to their designated uses, the EPA, in compliance with Section 301 (b)(1)(c) of the CWA, began imposing much more stringent limits to attain the necessary water quality standards. Furthermore, the Massachusetts Water Quality Standards, 314 CMR 4.00, required that all waters must be free of toxic substances in amounts or combinations that would impair the most sensitive water uses. Therefore, the draft NPDES permit issued to Texas Instruments in January of 1984 reflected the stringent water quality guidelines. Due to the limited dilution water available in the company's receiving stream, the proposed limits were impossible to meet with any existing technology.Texas Instruments then faced a difficult decision on whether to attempt to relieve the tight proposed limits through aquatic toxicity testing, or whether to re‐direct the effluent to another receiving stream (i.e. Publically Owned Treatment Works (POTW)), or in the worst case, whether to shut‐down its large Attleboro based manufacturing facility employing over 5000 people and relocate to another area. In the final analysis and after much deliberation, TI chose to maintain its Attleboro facility and enter into a long and relatively unexplored avenue of aquatic toxicity testing to raise its permit limits to achievable levels. It was realized early on, that, even if TI succeeded in raising the limits, the existing waste treatment facility would probably require more modifications.As one of the first industries in the New England region to negotiate an NPDES permit based on the new water quality criteria, this article explores the protocol and method by which a new permit was established at Texas Instruments.
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