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In 2010, the USEPA published a draft total maximum daily load (TMDL) to address nonattainment of dissolved oxygen (DO) criteria in the Savannah Harbor. The draft TMDL calls for severe (75-90%) reductions in point source discharges of biological oxygen demand. Rather than assigning wasteload
allocation (WLAs) to individual dischargers, USEPA and state regulators provided dischargers with the unusual opportunity to determine among themselves how to best distribute the WLA. It was hoped that this discharger-led process would lead to a solution that is more equitable and acceptable
than one imposed by regulatory agencies. The combined discharger group retained Malcolm Pirnie ARCADIS in the summer of 2010 to facilitate the year-long WLA distribution process. The combined discharger group was highly diverse, with a membership that included large pulp and paper mills,
publically-owned treatment plants of varying sizes, and other industries. Natural dichotomies within the group included municipal versus industrial interests, Georgia versus South Carolina interests, and small versus large discharger interests. The group devised a strategy that relied on moving
from agreement on general equity principals, then to potential WLA distribution scenarios, and finally to one preferred WLA scenario. Major equity issues that the group identified included: •Every discharger should contribute to the solution. •More impacting facilities should
do more. •Past achievements should be rewarded. •There should be equity between the states of Georgia and South Carolina. •Economic hardship should be considered. The discharger group ultimately chose a solution whereby load reductions were made proportional to each
facility's impact on DO under baseline loading conditions. However, load reduction “caps” and technology-based concentration “floors” were also used to help ensure that no discharger received unattainable limits. The chosen solution represents a 396,281 lb/day
reduction in ultimate oxygen demand loading from existing permitted conditions, and a 72 percent total load reduction, and would make approximately 98 percent of the progress needed to eliminate the excess DO deficit in the Savannah Harbor.
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