Implementing Numerical Phosphorus Limits, 2014 PEERS Conference

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Large paper mills discharge phosphorus at a rate that is equal to, or exceeds, the contributions from large municipal wastewater treatment plants. In Wisconsin, the development of statewide numeric water quality criteria for phosphorus has put mills into the spotlight and forced them to evaluate expensive, capital intensive upgrades to achieve compliance with new restrictions. A coalition of large dischargers has sought relief in the form of a legislative variance that would be the first of its kind. This paper overviews the options available to mills in Wisconsin, highlights the challenges they’re facing, and previews this legislative variance. In addition, it flags issues for mills to be on the lookout for in other states seeking to develop similar numeric criteria for phosphorus. This paper is meant to accompany a presentation in which these ideas are discussed in further depth.