Technical Evaluation of The Best Available Technology Economically Achievable (BAT) Effluent Limitations Guidelines for The Petroleum Refining Point Category
"OBJECTIVES AND SCOPE OF THIS STUDY The objectives of this study were to: (1) Evaluate the technical basis of the proposed BAT guidelines (Ref. 1@2)@ and (2) Develop alternative methodologies@ as necessary. Specific aspects of the topic addressed in this report include: (1) Flow Modeling (2) Flow Reduction Technology (3) Variability Factors (4) Long-Term Achievable 4AAP Phenolics Concentration Other aspects of the guidelines have been addressed in separate documents and are excluded from this report. The ""cost-reasonableness"" test applied by EPA to the proposed BCT limitations is the subject of a separate report (Ref. 13). The ""economic achievability"" of the proposed BAT Effluent Limitations Guidelines is not considered. The question of whether any additional controls are required by the Clean Water Act in view of the very low quantities of pollutants currently being discharged by the petroleum refining industry is not addressed. Finally@ the existence of variables that might greatly affect the mass discharge of pollutants but have""little correlation with wastewater flow rate could not be established with the available EPA data base@ since it provides information primarily related to wastewater flow."