Each state developed implementation strategies for the GLI water quality criteria and antidegradation standards, but without a clear map, both dischargers and regulators found themselves in unfamiliar territory in developing discharge limits and operational conditions.
As water use and discharge regulations in the Great Lakes continue to be at the forefront of science and policymaking, Ramboll maintains an active presence on water issues with many industrial clients in the region.
Solving the Compliance Puzzle
With 20 years of continual collaboration, Ramboll has provided one steel company with a broad spectrum of services to address the myriad issues associated with water usage at the largest integrated steel mill in North America. Highlights of recent support include:
- Source investigation, technology evaluation, analytical support, and regulatory strategic planning to address compliance with part-per-trillion mercury discharge limits
- Development of pollution minimization plans for mercury
- Derivation of site-specific cyanide criteria based on the presence of adult salmon
- Routine aquatic toxicity texting; specialized toxicity reduction studies
- Fish kill incident investigations
- Technology review and biological impact evaluations for water withdrawal structures (intakes)
- Determining baseline stormwater quality and statistically developing benchmarks for improvement
- Multiple design upgrades and operations support for the coke oven wastewater treatment plant
- Preparation of permit applications including development of water quality-based effluent limits and technology-based effluent limits
- Review and comment on draft regulations, including interface with regulators.
The combination of activities (regulatory deciphering, engineering and operational assessments, and studies to understand risks) allowed this integrated iron and steel mill to appropriately invest in actions that resulted in environmental benefit and compliance with discharge limits.
Ramboll scientists and engineers had participated in the development of this far-reaching and precedent setting rule at the federal level and, in some states, the adoption of the rule into state programs. Combined with the depth of Ramboll’s experience with iron and steel wastewater management, the in-sight gleaned during rulemaking allowed for a comprehensive yet clear direction on compliance options. Ramboll remains actively engaged in federal and state rulemaking including cooling water intake structure rule (316(b) rule), iron and steel technology-based effluent limits (BPT/BCT/BAT), and adoption of new analytical methods.