Polluter List’s Language May Not Clear the Air
The List of Significant Noncompliant Industrial Users is hardly what one would call gripping reading.
After a few introductory paragraphs, The List simply records the names of the companies involved, their addresses, a permit number and letter indicating the type of offense that landed them on The List in the first place.
The letters A through H correspond to eight categories of violations. Category G, for example, is described as “Failure to accurately report noncompliance.”
But category B offers this tongue-twister: “Technical Review Criteria (TRC) violations, defined here as those in which 33% or more of all the measurements for each pollutant parameter taken during a six-month period equal or exceed the product of the daily maximum limit or the average limit multiplied by the applicable TRC (TRC-1.4 for BOD, TSS, fats, oil, and grease, and 1.2 for all other pollutants except pH).”
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