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Recently issued EPA guidelines for treatment of Airport Deicing Effluent is NOT the only requirement for RIAC to comply with.

1) 1st, they are "guidelines" meaning that EPA and RIDEM have agency discretion over permit stipulation within permits issued as part of the RIPDES program, which is a flow down of the federal EPA NPDES program as required under the federal Clean Water Act (CWA).

2) The CWA requirement prohibits RIAC from discharging without a permit. yet RIDEM as the local regulator and enforcement agency has failed in its regulatory responsibilities by allowing RIAC to discharge pollutants without a valid permit.

3) Notwithstanding the recently issued guidelines for treatment of Airport Deicing Effluent, discharges must be limited to an amount that does not degrade the dissolved oxygen level of the receiving waters below federal standards, so to claim what is proposed merely by percentage collection meets or exceeds federal standards in itself is not necessarily compliant with the Clean Water Act.

From: DEM says airport system to capture deicing fluids exceeds EPA demands

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