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What are TBELs? WBELs? How are TBELs enforced?

What are the different degrees of TBELs and what effects do each of the different degrees have on a specific industry? In Rybachek v. EPA did the EPA err in their application of different TBELs to pollutants (suspended/settleable) and processes (recirculation/settling pond)? The court gave the EPA a large amount of ___________. In Atlantic State v. Kodak what effect does Section 402(k) have on citizen suits under the CWA? Does this shield provision prevent all citizens from contesting water pollution from a factory such as Kodak?

What is the difference between NPDES and SPDES permits?

What are they? What are performance standards? For who? What is the purpose of TBELs? How are they enforced? In what type of document?

How are WQBELs similar to TBELs? What waters do WQBELs apply to? How do WQBELs differ from TBELs?

Think back to the CAA. How is the categorization of effluent v. heavily contaminated similar to provisions in the CAA?

BPT
Best Practicable Control Technology

BAT
Best Available Technology Economically

Achievable

BCT
Best Conventional Pollution Control Technology

BADT
Best Available Demonstrated Control Technology

BMP
Best Management Practices

What is a variance? Who can apply for a variance?


Non-Conventional Non-Toxics Conventional Pollutants

Why did the court conclude that placer mines were subject to CWA regulations? Did the EPA err in its determination that settling ponds are the BPT? Did the EPA err in its determination that recirculation of process wastewater is the BAT ? How should suspended solids be controlled? BCT or BAT? Should settleable solids be classified as a conventional or nonconventional pollutant?

What is the issue? Why did Atlantic Legal Foundation take Kodak to court? Section 402(k) Shield Provision

The EPA admitted there is a regulatory gap in the CWA. What did they mean?

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