environmental site assessments, engineering permits regulations, environment waste water, Huff and Huff

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Regulation Development

H&H was a major participant in the development of the risk based corrective action regulations in Illinois, on behalf of eight industrial clients. Review of proposed regulations and participation in the hearings, through testimony and questioning, provided a clear perspective of the risk assessment program in Illinois.

Rule Changes/Adjusted Standards
Pretreatment and User Charge Programs
Effluent and Water Quality Standards
Toxic Pollutant Surveys
Use Attainability Analysis (UAA) Process

James Huff currently serves on the Illinois Nutrient Standards Committee. This committee is developing water quality standards for phosphorus and total nitrogen, a process that is expected to be completed by 2008. Stream use designations in Illinois will be a critical component in the nutrient standards development.

Huff & Huff is currently actively involved in the Use Attainability Analysis process for the Chicago Area waterways. This UAA has significant economic and environmental implications. Our firm has provided testimony on behalf of two industrial dischargers, reviewed and commented on reports, and assisted in development of alternative regulations.

Experience in evaluating the cost-effectiveness of regulatory alternatives has provided Huff & Huff, Inc. (H&H) with a unique perspective on developing optimal regulations. This expertise has been used to assist both industrial plants and municipalities in developing site specific effluent standards for submittal to the appropriate regulatory authorities.

The firm was retained by seven municipalities and a refinery impacted by proposed ammonia water quality in Illinois. Analysis of the data and testimony before the Pollution Control Board were required in this proceedings. H&H was also retained by a consortium of municipal dischargers to the Fox River to manage a year long intensive stream sampling program on the Fox River. This study was used in the ammonia water quality proceedings as well as negotiating future NPDES permit limits.

H&H has offered expert testimony upon economic factors of site specific rule changes and variances as well as environmental assessments for municipal and industrial sources. These assessments were used to determine appropriate numeric effluent limitations. The firm has been involved in numerous site specific regulatory requests from municipal dischargers, two oil refineries, and a combination inorganic chemical plant/POTW. Stream sampling, both biological (fish, benthic, and mussels) and chemical, has been conducted as part of most of these projects.

H&H has been involved with development of sewer connection fee structure equitable to both existing and future users for a large municipal area and preparation of the user rate structure and ordinance for an Illinois municipality.

H&H has developed the pretreatment program for a municipality in terms of the ordinance as well as developing discharge limits for industrial sources within the municipality. This ordinance has been updated twice to reflect the "503" sludge regulations and other federal mandates.