Greenfield Development and TMDLS: NPDES Permitting of a New Facility Discharging to a Nutrient-Impaired Stream, 2009 TAPPI Engineering, Pulping, Environmental Conference

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State environmental agencies, working in conjunction with the United States Environmental Protection Agency (USEPA), are developing total maximum daily loads (TMDLs) for surface waters listed on State 303(d) lists. Of particular concern to the pulp and paper industry is the development of nutrient TMDLs that can result in National Pollutant Discharge Elimination System (NPDES) permit limitations for nitrogen and phosphorus. In developing nutrient TMDLs, loadings from both point (process wastewater) sources and non-point (storm water) sources are evaluated to assess the current nutrient loading to the stream. Often, TMDLs reference existing numeric water quality standards in establishing target concentrations for nitrogen and phosphorus. When water quality standards are narrative in nature and not numeric, alternative TMDL development methods such as the use of a reference stream or “ecoregion” are employed by state agencies to establish discharge standards. This paper will discuss the basics of TMDL development and will use the NPDES permitting of wastewater discharges from a greenfield facility to a nutrient-impaired stream, Buxahatchee Creek, in Alabama as a case study.