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HomeMy WebLinkAboutDWQ-2024-002181Official Draft Public Notice Version March 20, 2024 The findings, determinations, and assertions contained in this document are not final and subject to change following the public comment period. FACT SHEET STATEMENT OF BASIS WEIR MINERALS NA SLC - RUBBER ENGINEERING RENEWAL DISCHARGE PERMIT UPDES PERMIT NUMBER: UT0024767 MINOR INDUSTRIAL FACILITY FACILITY CONTACT INFORMATIONPerson Name, Position:Alvyn Haley, EHS ManagerPerson Name, Position:Ricky Nolan, Signatory and Facility ManagerFacility Full Name:Weir Minerals North America Salt Lake City - RubberEngineeringPermittee Name:Weir Minerals NA SLC - Rubber EngineeringFacility & Mailing Address:3459 South 700 West Salt Lake City, Utah 84119 Telephone:801-574-2189 DESCRIPTION OF FACILITY Weir Minerals NA SLC-Rubber Engineering (WMRE) is a molded rubber products manufacturer located in Salt Lake City, Utah with Standard Industrial Classification Code 3069 for rubber manufacturing. The WMRE manufacturing plant has been in service for over 50 years and processes 11,000-13,700 pounds of rubber products per day, on average. The wastewater discharge from the WMRE facility consists of both contact and non-contact cooling water, which are used to control temperature in the manufacturing of rubber products. WMRE uses municipal culinary water to maintain constant temperatures (usually warmer than ambient to increase the malleable characteristics of rubber) while manufacturing rubber parts. Some rubber parts are heated with the intent to cure, in pressurized autoclaves with steam (contact water) during which some of the steam condenses and is discharged. After the curing process is completed, contact water is used to cool the rubber parts in the autoclave before it is opened. Non-contact water flows through the jackets enveloping processes (warming the rubber) while shaping it in presses, extruders, and mills. About 8,000 gallons per day (gpd) of contact cooling water is used in the autoclaves, which flows to an internal discharge point (Outfall 002), which then flows to the primary WMRE discharge via Outfall 001. The non-contact process water flow is approximately 100,000 gpd and flows directlyto discharge point Outfall 001. This permit will once again authorize the wastewater discharges from WMRE during the next 5 years as appropriate. SUMMARY OF CHANGES FROM PREVIOUS PERMIT There are a few changes in this renewal permit when compared to the previous permit. The first change is regarding the previously included Stormwater provisions, which have been removed as part of a Division of Water Quality (DWQ) programmatic separation of the previously combined UPDES permits. WMRE will now be required to apply for and obtain separate UPDES Industrial Storm Water Permit coverage under the UPDES General Permit No. UTR000000, or an applicable exemption, as described further in the STORMWATER section of this Fact Sheet. The second change is the removal of metals monitoring for lead, zinc and copper, which were previously included in the permit to confirm the presence or absence of these parameters in the WMRE effluent discharge. See the Reasonable Potential Analysis section of this Fact Sheet for more information. The third and final permit change is the removal of effluent limitations derived from Utah Secondary Treatment Standards to reflect a rule change in Utah Administrative Code (UAC) R317-1-3, which clarifies that Secondary Treatment Standards for both total suspended solids (TSS) and biochemical oxygen demand 5-day-test (BOD5) are not applicable for Non-POTW facilities. Publicly Owned Treatment Works (POTWs) are facilities that receive and process domestic waste water. WMRE is an industrial and Non-POTW type facility and therefore, Secondary Treatment Standards do not apply and the BOD5 monitoring is no longer being required in this permit, as further justified in the Reasonable Potential Analysis section of this Fact Sheet. However, the TSS monitoring for monthly and weekly maximum average effluent limitationsremain in unchanged the permit to further address the applicable Federal effluent limit guidelines as appropriate. See the BASIS FOR EFFLUENT LIMITATIONS section of this Fact Sheet for more information. All other permit conditions remain unchanged. DISCHARGE INFORMATION DESCRIPTION OF DISCHARGE WMRE discharges to an on-site storm water collection system via a storm drain inlet on the west side of the plant building near the front street entrance off 700 West, which then connects to the South Salt Lake City storm water collection system. There is a manhole at this discharge location labeled,“Outfall 001” and is considered the primary discharge point for the WMRE facility. A second sampling point (Outfall 002) is an intermediate,internal discharge point (upstream from Outfall 001) located in the interior of the plant near the autoclaves. Outfall NumbersDescription of Discharge Outfalls001Located at latitude 40 41' 48" and longitude 111 54' 40". Discharge is to a storm water inlet structure located in the west parking lot.002Located at latitude 40 41' 46" and longitude 111 54' 36". Discharge is to a floor drain located inside the facility near the autoclaves. RECEIVING WATERS AND STREAM CLASSIFICATION The finaleffluent from WMRE discharges into a South Salt Lake City Storm Drain (Outfall 001), which flows into Mill Creek, which then flows to the Jordan River. Mill Creek from the confluence of the Jordan River to Interstate 15 is classified as 2B, 3C, and 4 according to Utah Administrative Code (UAC) R317-2-13.5: Class 2B --Protected for infrequent primary contact recreation. Also protected for secondary contact recreation where there is a low likelihood of ingestion of water or a low degree of bodily contact with the water. Examples include, but are not limited to, wading, hunting, and fishing. Class 3C --Protected for nongame fish and other aquatic life, including the necessary aquatic organisms in their food chain. Class 4 --Protected for agricultural uses including irrigation of crops and stock watering. TOTAL MAXIMUM DAILY LOAD (TMDL) REQUIREMENTS According to Utah’s 2022 303(d) Water Quality Assessment Report, the receiving water for the discharge, Mill Creek1-SL City (UT16020204-026_00), which extends from the confluence of the Jordan River to Interstate 15 crossing is impaired for a loss of benthic macroinvertebrates community. Additional downstream impairments of the Jordan River include Total Dissolved Solids (TDS), Total Phosphorus, Dissolved Oxygen and E. Coli. Two TMDL studies and analyses are applicable to these waters. The Jordan River Watershed E. coli TMDL addresses elevated E. coli impairments in the Mill Creek1-SLCity, Jordan River-4, Jordan River-3, and Jordan River-2 assessment units. This TMDL was approved in January 2023 (UDWQ, 2023). The second applicable TMDL is the Jordan River Total Maximum Daily Load Water Quality Study - Phase I, which addressed the dissolved oxygen impairment in Jordan River segments Assessment Units UT16020204-001 through 003, was completed in July 2013 (UDWQ, 2013). A TMDL has not yet been completed for the other impaired constituents. PARAMETERS OF CONCERN The parameters of concern (POCs) identified for the WMRE dischargesare TSS, Oil & Grease and pH, as initially determined by Federal effluent limit requirements found in 40 Code of Federal Regulation (CFR) Part 428.62(a). Additional POCs identified by the existing TMDLs and impairment statusof the downstream receiving waters include TDS, Dissolved Oxygenand Total Phosphorus. In addition to the POCs included as identified in the development of this renewal permit, E-coli and benthic macroinvertebrates bioassessment are also listed in the aforementioned TMDL as impairments, but based upon BPJ of the permitting authority have once again not been included in therenewal permit as monitoring requirements. This is primarily because WMRE utilizes municipal culinary water for the cooling processes, in which the presence of E-coli or bacteria colonies is unlikely to exist. BASIS FOR EFFLUENT LIMITATIONSIn accordance with regulations promulgated in 40 CFR Part 122.44 and in UACR317-8-4.2, effluent limitations are derived from technology-based effluent limitation guidelines, Utah Secondary Treatment Standards (UAC R317-1-3.2) or Utah Water Quality Standards (UAC R317-2-14) as applicable. In cases where multiple limits have been developed, those that are more stringent apply. In cases where no limits or multiple limits have been developed, Best Professional Judgment (BPJ) of the permitting authority may be used where applicable. Best Professional Judgment or BPJ, refers to a discretionary, best professional decision made by the permit writer based upon precedent, prevailing regulatory standards or other relevant information. Permit limits can also be derived from a Wasteload Analysis (WLA), which incorporates Secondary Treatment Standards, Water Quality Standards (WQS), including any applicable TMDL impairments as appropriate, Antidegradation Reviews (ADR) and designated uses into a water quality model that projects the effects of discharge concentrations on receiving water quality. Effluent limitations are those that the model demonstrates are sufficient to meet State water quality standards in the receiving waters. During this UPDES permit development, the WLA and ADR processes were completed as appropriate. An ADR Level I review was performed and concluded that an ADR Level II review was not required this time since there are no proposed increases in effluent flow or concentrations from the existing permit limitations. The WLA indicates that the effluent limitations will be sufficiently protective of water quality, in order to meet State water quality standards in the receiving waters. The WLA and ADR are attached as an addendum to this Fact Sheet.The following list is the basis of the effluent limitations for the permit parameters: Limitations on TSS concentrations for Outfall 001 were previously based on Utah Secondary Treatment Standards and remain unchanged in this permit based upon BPJ of the permitting authority. As previously mentioned,Secondary Treatment Standards no longer apply, butthe Federal effluent limit guidelinerequirement for TSS still applies for the WMRE wastewater discharges and therefore, the TSS monthly and weekly maximum average effluent concentration limitations for Outfall 001will remain in the permit as appropriate. The pH limitations for Outfall 001 are based upon Utah WQS found in UAC R317-2-14. The limitation on dissolved oxygen for Outfall 001 is also based upon Utah WQS, and more specifically based upon the current WLA, and which remains unchanged from the previous permit. The Oil and Grease concentration limit for Outfall 001 is the same as in the previous permit and is based on BPJ of the permitting authority to be consistent with other industrial facilities statewide. The TDS concentration limitation for Outfall 001 remains unchanged and is based upon the Utah WQS found in UAC R317-2-14 and in further support of the aforementioned TMDLs to be protective of any downstream agricultural beneficial uses of the receiving waters as designated. Limitations at Outfall 002 are based on applicable technology-based standards for “Medium-Sized General Molded, Extruded, and Fabricated Rubber Plants Subcategory” found in 40 CFR 428.62(a) (40 CFR). These categorical standards are mass loading limits based onproduction rates.A medium-sized rubber plant processes between 8,200 lbs/day and 23,000 lbs/day of raw materials. WMRE consistently operates at 11,000-13,700 lbs/day and is therefore, considered medium-sized for calculating effluent loading limitations for both TSS and Oil & Grease as appropriate.The daily and monthly maximum effluent loading limits were calculated using the lb/1,000-lb values from 40 CFR and multiplied by the 13,700 lbs/day maximum production rate (see Outfall 002 Effluent Limitations table). Effluent flow limitations were not included in this renewal permit once again because the parameters for Outfall 001 are based on water quality standards where the concentrations are not exclusively dependent on flow, or in the case of Outfall 002, have mass loading limitations derived from production based categorical standards. However, effluent flow from each outfall will continue to be measured and reported for monitoring purposes. The permittee is expected to be able to continue complying with the permit effluent limitations. Reasonable Potential Analysis Since January 1, 2016, DWQ has conducted reasonable potential analysis (RP) on all new and renewal applications received after that date. RP for this permit renewal was conducted following DWQ’s September 10, 2015 Reasonable Potential Analysis Guidance (RP Guidance).There are four outcomes defined in the RP Guidance: Outcome A, B, C, or D. These Outcomes provide a frame work for what routine monitoring or effluent limitations are required A qualitative RP analysis was performed for the POCs from WMRE discharge data over the past five yearsto determine if there was reasonable potential for the discharge to exceed the applicable water quality standards. The previous permit included the addition of total zinc, total lead and total copper as monitoring requirements for Outfall 001 to address additional potential POCs that were identified as potential impairments in early efforts for Jordan River TMDL study. Initialscreening of the effluent data for thesethree metals, as well as for BOD5,showed that a closer look at any of the parameters is not needed since all of the concentration results were consistently either below the appropriate method detection limits and/or well below the applicable water quality standards. Therefore, no RP currently exists at WMRE for theseparameters and a more quantitative RP analysis using the RP Model was not necessary at this time. Based upon the RP Guidance, no additional effluent limits have been included in this renewal permit and further monitoring requirements for the previously identified potential parameters of concern is neither necessary nor required. This resulted in the following RP outcome; RP Outcome D: No effluent limitation or monitoring requirements are required to be in the permit.A copy of the RP analysis summary is included as an attachment to this Fact Sheet. WMRE should be able to continue complying with the applicable permit limitations as follows: Parameter, Units Outfall 001 Effluent Limitations *a Maximum Monthly Average Maximum Weekly Average Daily Minimum Daily Maximum Total Flow, gpd*b *c Report -- -- Report Temperature, °F -- -- -- Report Dissolved Oxygen, mg/L -- -- 4.5 -- TSS, mg/L 25 35 -- -- TDS, mg/L *d -- -- -- 1200 Oil & Grease, mg/L -- -- -- 10 pH, Standard Units -- -- 6.5 9.0 Total Phosphorus, mg/L *d -- -- -- Report Parameter, Units Outfall 002 Effluent Limitations *a Daily Maximum Maximum Monthly Average Total Flow, gpd*b *c Report Report Oil & Grease, lbs/day 5.75 2.05 TSS, lbs/day 10.96 5.48 SELF-MONITORING AND REPORTING REQUIREMENTS The following self-monitoring requirements are similar to the previous permit, with exception to the changes mentioned previously. The permit will require reports to be submitted monthly, as applicable, on Discharge Monitoring Report (DMR) forms due 28 days after the end of the monitoring period. Effective January 1, 2017, monitoring results must be submitted using NetDMR unless the permittee has successfully petitioned for an exception. WMRE has been reporting self-monitoring results via Net DMR on a monthly basis as required. There have been no effluent violations during the previous 5-year permit cycle.The WMRE effluent discharge data has been summarized and included as an attachment to this Fact Sheet. Outfall 001 Self-Monitoring and Reporting Requirements *a Parameter Frequency Sample Type Units Total Flow *b *c Weekly Measured gpd Temperature Weekly Grab °F Dissolved Oxygen Monthly Grab mg/L TSS Monthly Grab mg/L TDS *d Monthly Grab mg/L Oil & Grease Monthly Grab mg/L pH Monthly Grab SU Total Phosphorous *d Monthly Grab mg/L Outfall 002 Self-Monitoring and Reporting Requirements *a Parameter Frequency Sample Type Units Total Flow *b *c Weekly Measured gpd TSS Monthly Grab mg/L Oil & Grease Monthly Grab mg/L*aSee Definitions, Part VIII, for definition of terms.*bFlow measurements of influent/effluent volume shall be made in such a manner that the permittee can affirmatively demonstrate that representative values are being obtained.*cIf the rate of discharge is controlled, the rate and duration of discharge shall be reported.*dThis parameter has been included to support TMDL study efforts for the Jordan River. Upon successful monitoring during this permit cycle, the permittee may request a reduction in the monitoring frequency. The request shall be in writing to the Director for consideration of the reduction(s)in future permitprovisions. STORM WATER Separate storm water permits may be required based on the types of activities occurring on site. Permit coverage under the Multi Sector General Permit (MSGP) for Storm Water Discharges from Industrial Activities is required based on the Standard Industrial Classification (SIC) code for the facility and the types of industrial activities occurring. If the facility is not already covered, it has 30 days from when this permit is issued to submit the appropriate Notice of Intent (NOI) for the MSGP or exclusion documentation. Previously, storm water discharge requirements and permit coverage were combined in this individual permit. These have been separated to provide consistency among permittees, electronic reporting for storm water discharge monitoring reports, and increase flexibility to changing site conditions. Additionally, permit coverage under the Construction General Storm Water Permit (CGP) is required for any construction at the facility which disturb an acre or more, or is part of a common plan of development or sale that is an acre or greater. A Notice of Intent (NOI) is required to obtain a construction storm water permit prior to the period of construction.Information onstorm water permit requirements can be found at http://stormwater.utah.gov. PRETREATMENT REQUIREMENTS WMRE does not discharge process wastewater to a Publicly Owned Treatment Works (POTW). Any process wastewater that WMRE may discharge to a POTW, either as a direct discharge or as a hauled waste, is subject to federal, state, and local pretreatment regulations. Pursuant to section 307 of the Clean Water Act, the Mine shall comply with all applicable federal general pretreatment regulations promulgated, found in 40 CFR 403, the pretreatment requirements found in UAC R317-8-8, and any specific local discharge limitations developed by the POTW accepting the waste. In addition, in accordance with 40 CFR 403.12(p)(1), WMRE must notify the POTW, the EPA Regional Waste Management Director, the DWQ Director and the State hazardous waste authorities in writing if the WMRE discharges any substance into a POTW that if otherwise disposed of would be considered a hazardous waste under 40 CFR 261. This notification must include the name of the hazardous waste, the EPA hazardous waste number, and the type of discharge (continuous or batch). BIOMONITORING REQUIREMENTS A nationwide effort to control toxic discharges where effluent toxicity is an existing or potential concern is regulated in accordance with the Utah Pollutant Discharge Elimination System Permit and Enforcement Guidance Document for Whole Effluent Toxicity Control (biomonitoring), dated February 2018. Authority to require effluent biomonitoring is provided in Permit Conditions, UAC R317-8-4.2, Permit Provisions, UAC R317-8-5.3 and Water Quality Standards, UAC R317-2-5 and R317 -2-7.2. The permittee is a minor industrial facility that dischargescooling water derived from a culinary source, in which toxicity is neither an existing concern, nor likely to be present based upon the absence of toxicity resulting from previous biomonitoring tests of the effluent. The permittee has not changed processes since the previous biomonitoring testing. Based on these considerations, as well as a greater than 20 to 1 dilution ratio of effluent in the receiving water, there is no reasonable potential for toxicity in the permittee’s discharge (per State of Utah Permitting and Enforcement Guidance Document for WET Control). As such, there will be no numerical WET limitations or WET monitoring requirements in this permit. However, the permit will contain a toxicity limitation re-opener provision that allows for modification of the permit should additional information indicate the presence of toxicity in the discharge. PERMIT DURATIONIt is recommended that this permit be effective for a duration of five (5) years.Drafted and Reviewed byJeff Studenka, Discharge Permit WriterJennifer Robinson, PretreatmentLonnie Shull, BiomonitoringJordan Bryant, Storm WaterSandy Wingert, TMDL/Watershed Suzan Tahir, Wasteload Analysis/ADRUtah Division of Water Quality, (801) 536-4300PUBLIC NOTICE INFORMATION (to be updated after)Began: Month Day, YearEnded: Month Day, YearComments will be received at: 195 North 1950 West PO Box 144870 Salt Lake City, UT 84114-4870The Public Notice of the draft permit was published on the DWQ website for at least 30 days as required.During the public comment period provided under R317-8-6.5, any interested person may submit written comments on the draft permit and may request a public hearing, if no hearing has already been scheduled. A request for a public hearing shall be in writing and shall state the nature of the issues proposed to be raised in the hearing. All comments will be considered in making the final decision and shall be answered as provided in R317-8-6.12.ADDENDUM TO FSSOBDuring finalization of the Permit certain dates, spelling edits and minor language corrections were completed. Due to the nature of these changes they were not considered Major and the permit is not required to be re Public Noticed.Responsiveness Summary(For any comments received and responses sent. Actual letters can be referenced, but not required to be included). ATTACHMENTS:1.Wasteload Analysis Information2. Effluent Monitoring Data3. Reasonable Potential AnalysisDWQ-2024- This Page Intentionally Left Blank ATTACHMENT 1 Wasteload Analysis Information (DWQ-2024-001771 & DWQ-2024-001772) This Page Intentionally Left Blank ATTACHMENT 2 Effluent Monitoring Data (DWQ-2024-001850) This Page Intentionally Left Blank ATTACHMENT 3 Reasonable Potential Analysis This Page Intentionally Left Blank REASONABLE POTENTIAL ANALYSIS The Division of Water Quality (DWQ) has worked to improve our reasonable potential analysis (RP) for the inclusion of limits for parameters in the permit by using an EPA provided model. As a result of the model, more parameters may be included in the renewal permit. A Copy of the Reasonable Potential Analysis Guidance (RP Guide) is available at DWQ. There are four outcomes for the RP Analysis. They are; Outcome A:A new effluent limitation will be placed in the permit. Outcome B:No new effluent limitation. Routine monitoring requirements will be placed or increased from what they are in the permit, Outcome C:No new effluent limitation. Routine monitoring requirements maintained as they are in the permit, Outcome D:No limitation or routine monitoring requirements are in the permit. Initial screening for effluent metals and other parameter values that were submitted through the discharge monitoring reports showed that a closer look at these parameters is not needed. The initial screening information is included in the “Effluent Metals and RP Screening Results” table below. Note that the full RPanalysis model was not necessary at this time due to the results of the initial screening results. Effluent Metals and RP Screening Results Table Weir Minerals (UT0024767) 2018-2023 Effluent Data Parameters of Concern Outfall No. of Samples MEC* mg/L Water Quality Standard MAC** Outcome/Result Acute mg/L Chronic mg/L Total Lead 001 10 0.0582 4.028 0.739 MEC < MAC*** Total Zinc 001 10 0.0454 7.872 15.36 MEC < MAC*** Total Copper 001 10 0.0119 1.032 1.164 MEC < MAC*** BOD5 001 60 <5 35 25 MEC < MAC*** Notes: *MEC – Maximum expected effluent concentration as determined from existing data set. **MAC – Maximum allowable concentration, UPDES permit effluent limits derived from the current wasteload allocation analysis (WLA) and/or applicable water quality standard. ***MEC < (less than) MAC, no Acute or Chronic limits required. __________________________________________________ Result: From the table above, the RP analysis results of the discharge for all of the listed parameters is: MEC <MAC, therefore no Acute or Chronic limits are required regarding the listed parameters. This equates to RP Outcome D: No effluent limitation or monitoring requirements are required to be in the permit. Summary: A qualitative RP analysis was performed for the above parameters of concern from WMRE discharge data over the past five yearsto determine if there was reasonable potential for the discharge to exceed the applicable water quality standards. Initial screening for the metals and BOD5 values as submitted to DWQ showed that a closer look at any of the parameters is not needed since all of the concentration results were either well below the applicable water quality standardsand/or below the appropriate method detection limits. Therefore, no RP currently exists at WMRE for theseparameters and a more quantitative RP analysis using the RP Model was not necessary at this time. Based upon the RP Guidance, no additional metal effluent limits have been included in this renewal permit and further monitoring requirements for these parameters is neither necessary nor required. This resulted in the following RP outcome; RP Outcome D: No effluent limitation or monitoring requirements are required to be in the permit.