Project Overview
EES Coke Battery, L.L.C. retained NTH to assist with ongoing environmental compliance issues, stormwater and wastewater management, NPDES permit application support, and development of an anti-degradation demonstration for their facility located on Zug Island, Michigan.
Project Scope
EES Coke was requested to submit an individual NPDES permit application for their discharge to the Detroit River, which was previously permitted under a combined discharge with another facility. Although not a new discharge nor a discharge that resulted in an increase in loading, MDEQ required the development of an anti-degradation demonstration.
NTH developed a report that provided a demonstration to EGLE that the potential lowering of water quality was necessary to accommodate important economic and social developments in the area in which the facility is located, and provided an “alternatives analysis” regarding the proposed surface water discharge. The alternatives analysis included the identification of pollution prevention measures; the evaluation of potential reduction in the scale of the project, water recycling/reuse, process changes, or innovative and/or advanced treatment technologies; evaluation of seasonal or controlled discharge options; identification of improved operation or maintenance of existing treatment systems; and determination of available alternative discharge locations.
Additionally, the alternatives analysis identified the relative proximity of the facility to any existing wastewater collection and treatment systems in the area, and provided an explanation as to why the surface water discharge was determined to be the best available option for wastewater disposal. The report also presented a determination of the baseline economic and/or social status in the area; provided a demonstration of the social and economic benefits presented by the facility; and a demonstration in the potential increase in economic or social development resulting from the presence of the facility in the area.
In addition, NTH completed a mixing zone evaluation/waste load allocation based on the concentrations and volume of water discharged from the facility and the concentrations and flow of the surface water, the results of which indicated minimal to no impact from the facility.
Client Benefit
NTH assists in maintaining compliance with stormwater, wastewater, and NPDES projects by evaluating the facility’s regulatory requirements and developing a strategic approach to developing compliance documents and implementing the appropriate monitoring program.
