The Water Environment Federation (WEF) and the Water Environment Research Foundation (WERF) cooperated in a comprehensive study of nutrient removal plants designed and operated to meet the "Limit of Technology" (LOT) for nutrient removal. LOT has been defined as plants meeting 3 mg/L TN and 0.1 mg/L TP. This effort focuses on maximizing what can be learned from existing full scale plants. In general, there were technologies that can reliably meet these requirements, but the key issue is the "averaging" period. Only some of the technologies can meet the LOT limits on a maximum month basis without significant violations during a permit cycle; alternatively, annual rolling average permits embody much less risk of violations. When seasonal and annual limits are equally protective of the environment as monthly limits, both the regulated and regulatory communities would be better served by reducing the frequency of reporting violations for events that have no environmental consequence.