DWQ-2024-005781 (4)

2023 Triennial Review of
Utah’s Water Quality
Standards
Table of contents
Summary.............................................................................................................................................. 3
Response to comments...................................................................................................................... 4
Aquatic life criteria - Ammonia ......................................................................................................... 4
Comment (USEPA): ................................................................................................................... 4
Response: .................................................................................................................................. 4
Comment (Richards): ................................................................................................................. 5
Response: .................................................................................................................................. 5
Aquatic life criteria - Selenium ......................................................................................................... 6
Comment (USEPA): ................................................................................................................... 6
Response: .................................................................................................................................. 6
Comment (Simmons): ................................................................................................................ 7
Response: .................................................................................................................................. 7
Great Salt Lake, Farmington and Bear River Bays Aquatic Life Criteria .......................................... 7
Comment (USEPA): ................................................................................................................... 7
Response: .................................................................................................................................. 8
Comment (Richards): ................................................................................................................. 8
Response: .................................................................................................................................. 9
Aquatic life criteria - iron .................................................................................................................. 9
Comment (USEPA): ................................................................................................................... 9
Response: .................................................................................................................................. 9
Human health criteria - MCL based criteria ................................................................................... 10
Comment (USEPA): ................................................................................................................. 10
Response: ................................................................................................................................ 10

Human health criteria - methylmercury .......................................................................................... 11
Comment (USEPA): ................................................................................................................. 11
Response: ................................................................................................................................ 11
Comment (Simmons): .............................................................................................................. 11
Response: ................................................................................................................................ 11
Recreational use criteria - microcystins and cylindrospermopsin .................................................. 12
Comment (USEPA): ................................................................................................................. 12
Response: ................................................................................................................................ 13
Numeric nutrient criteria for lakes and reservoirs .......................................................................... 13
Comment: ................................................................................................................................. 13
Response: ................................................................................................................................ 13
Colorado River salinity standards .................................................................................................. 13
Comment (USEPA): ................................................................................................................. 13
Response: ................................................................................................................................ 14
Wetland water quality standards .................................................................................................... 14
Comment (USEPA): ................................................................................................................. 14
Response: ................................................................................................................................ 14
Provo River Watershed and Heber Valley Aquifer ......................................................................... 15
Comment (Simmons): .............................................................................................................. 15
Response: ................................................................................................................................ 16
Comment (Franco): .................................................................................................................. 16
Response: ................................................................................................................................ 17
Appendices ........................................................................................................................................ 17

Summary
To meet obligations under the Clean Water Act, the Utah Division of Water Quality (DWQ) is required
to review Utah’s Water Quality Standards in Utah Administrative Code R317-2 at least once every three
years.
For the 2023 Triennial Review, DWQ performed a comprehensive review of all of Utah’s water quality
policies and criteria, including a comparison of the state’s water quality standards to nationally
recommended standards to identify and prioritize needed additions and updates. DWQ also sought
input through a collaborative engagement process with stakeholder; partner state and federal agencies;
and the public to identify any recommended changes to Utah’s water quality standards. DWQ’s 2023
Triennial Review identifies short-term goals for water quality standards changes expected before the
2026 Triennial Review; interim goals to support future water quality standards changes; and long-term
priorities.
DWQ opened the 2023 Triennial Review comment period via public notice (Appendix 1) on October 30,
2023, soliciting comments on Utah’s water quality standards and recommended changes. The notice
was posted on Utah’s public notice webpage, DWQ’s webpage, and published in local newspapers.
Comments were also solicited through outreach to Utah’s Water Quality Board, DWQ’s Water Quality
Standards Workgroup, and postcards sent to municipalities throughout the state (Appendix 2).
Comments were accepted until close of business on December 15, 2023. A public hearing was held on
December 14, 2023, hosted at the Multi Agency State Office Building in Salt Lake City with virtual
access provided.
DWQ received four sets of written comments (appendix 3). No comments were received during the
public hearing (appendix 4). DWQ has evaluated and responded to all comments and updated the
water quality standards prioritization table (appendix 5).
DWQ has reviewed all criteria recommendations. Though the review identifies and prioritizes future
standards changes, no new or updated standards are proposed for immediate adoption as part of the
2023 Triennial Review. No new data or information were identified that would require revisions
to currently designated beneficial uses or existing site-specific standards. No new information
regarding Tribal reserved rights was asserted that would require updates to water quality standards.
The Environmental Protection Agency has published new criteria for nutrients in lakes and
reservoirs since DWQ’s 2020 Triennial Review. State adoption of these criteria will require
substantial technical and administrative work including data collection, statistical analysis, and
public and stakeholder outreach. As part of the 2023 Triennial Review, DWQ has prioritized initial
technical work to support future adoption of these or other defensible criteria, but is not currently
proposing them for adoption.
These materials have been reviewed by Utah’s Water Quality Standards Workgroup and
presented to the Utah Water Quality Board.

Response to comments
Aquatic life criteria - Ammonia
Comment (USEPA):
We acknowledge and support the Division recommending Utah update its existing ammonia criteria by
considering EPA’s 2013 ammonia criteria recommendations, and a potential adjustment based on the
presence/absence of certain species sensitive to ammonia exposure. It is our understanding that a
survey to evaluate the historic and expected occurrence of freshwater mussels and sensitive snails in
state waterbodies will be completed beforehand. Information obtained from this study will be needed
for any potential adjustments to the 2013 recommended ammonia criteria. As you know, recalculation
of the national ammonia criteria recommendations based on the ammonia toxicity of species
occurrence in Utah waters is only possible where it is documented that more sensitive species are not
currently occurring and not expected to be able to return to those waters. For example, UDWQ would
need to provide a rationale when developing site-specific ammonia criteria based on the absence of
certain unionid mussels and suitable habitat (including suitable hosts such as salmonids) in all affected
segments pursuant to EPA recommendations (see: Aquatic Life Ambient Water Quality Criteria for
Ammonia – Freshwater, 2013). We understand that UDWQ will discuss the results of the freshwater
mussels and snails study, and any other supporting documentation with the WQS Workgroup prior to
proposing revisions to Utah’s existing ammonia criteria. The EPA is available to provide additional
technical support to aid in the adoption and implementation of the 2013 recommended ammonia
criteria.
Response:
Thank you for supporting DWQ’s prioritization of updated ammonia criteria to protect aquatic life in Utah
and for providing additional information regarding criteria recalculation procedures. Utah and Colorado
water quality agencies partnered to conduct an historical survey of mussels and snails in our respective
states (Final Report). Utah is not within the distributional ranges of the unionid mussel species used in
the derivation of national recommended ammonia criteria. However, other unionid species do occur in
Utah. DWQ’s current plan for recalculation is to generate state-wide ammonia criteria that are protective
of Utah taxa, including unionids, by substituting toxicity data available for Utah unionid species for those
in the national recommendations, then recalculating the criteria, assuming the presence of Utah-
specific unionid taxa state-wide. DWQ is currently finalizing draft implementation guidance for ammonia
criteria. As suggested in the comment, all work related to adopting updated ammonia criteria will be
discussed with Utah’s Water Quality Standards Workgroup, and adoption of proposed criteria will follow
appropriate rulemaking procedures including review by Utah’s Water Quality Board, a public comment
period, and request for EPA approval.

DWQ does not anticipate expanding or altering existing site-specific, unionid-absent, ammonia criteria
as part of adopting the 2013 recommendations state-wide. Any recalculation of the ammonia criteria
will follow appropriate procedures for documenting resident and representative taxa.
Comment (Richards):
Utah Division of Water Quality (UDWQ) developed ammonia criteria and regulations based on EPA’s
outdated 2013 criteria. As UDWQ states, these ammonia criteria values were based on toxicity test
results using sensitive mussels from SE USA, not the two mussel taxa that occur in Utah (Table 1).
These stringent UDWQ ammonia criteria resulted in many wastewater treatment facilities contracting
mollusk experts to survey for presence/absence of mussels over large areas of Utah at substantial
monetary cost and time expenditure. Criteria also raised concerns and contributed to upgrade planning
of facilities to meet ammonia criteria, increasing monetary and time expenditures. UDWQ then
conducted recalculation of ammonia criteria based on toxicity tests conducted on mussel taxa that
occur in Utah, specifically Anodonta californiensis/nutalliana (Table 1) (CVCWA 2020). The CVCWA
(2020) toxicity test showed that A. californiensis/nutalliana was much less sensitive to ammonia than
mussel taxa from SE USA and values used by EPA 2013 and UTDWQ (Table 1) and that A.
californiensis/nutalliana was 164% less sensitive to ammonia than another Anodonta sp. within the
same genus.
EPA bases its Recalculation Procedure on “The underlying premise …. that taxonomy has value in
predicting sensitivity” (USEPA 2013a). EPA also based its entire Aquatic life ambient water quality
criteria for ammonia – freshwater 2013 document on this premise (USEPA 2013b). By 2017, UDWQ
was well aware that taxonomy was not often consistent with phylogeny, and that neither were good
predictors of sensitivity to toxicants, including ammonia (e.g., Richards 2016) and in a final report
UDWQ (2017) stated that: “First, taxonomic relationships may not be consistent with phylogenetic
relationships, and both are frequently modified based on new genetic or other information.” “Third, and
perhaps most importantly, phylogenetic similarity may not predict toxicological similarity (Blomberg et
al. 2003; Losos 2008). The probability of toxicological similarity is presumably greatest when taxa are
identical at the species or genus level due to shared life-history, morphological, or physiological traits
(USEPA 2013a, b). However, traits related to toxicological susceptibility may evolve at rates not
reflected in overall phylogenetic (or taxonomic) similarity.” As the CVCWA (2020) report illustrates, EPA
recalculation procedures are highly complex and subject to potentially erroneous and unrepresentative
values. For example, if a species occurs in a water body and has not been tested for a toxicant then
values from a surrogate species that has been tested are used, in some instances even if that surrogate
species is far removed taxonomically and phylogenetically. This is contrary to what UDWQ has
knowledge of (see preceding paragraphs). Application of unrealistic recalculated criteria values by
UDWQ can subsequently elicit costly wastewater facility upgrades and increased consulting costs.
Response:
Utah’s current state-wide ammonia criteria are based on EPA’s 1999 recommended criteria. In 2013,

EPA provided updated ammonia criteria that supersede the 1999 criteria recommendations. Utah has
previously adopted a site-specific recalculation of EPA’s 2013 recommended ammonia criteria for
certain sections of the Jordan River, but has not adopted the 2013 recommendations state-wide. The
update to ammonia criteria proposed in the 2023 Triennial Review is to incorporate the 2013
recommended criteria state-wide, recalculating the national recommendations based on available
toxicity data for resident taxa in Utah. Thank you for providing additional information regarding ammonia
toxicity to mussels and taxonomic considerations for potential criteria recalculations. All work related to
adopting updated ammonia criteria will be discussed with Utah’s Water Quality Standards Workgroup.
Adoption of proposed criteria will follow appropriate rulemaking procedures including review by Utah’s
Water Quality Board, a public comment period, and request for EPA approval.
Aquatic life criteria - Selenium
Comment (USEPA):
The Water Quality Unit supports UDWQ’s recommendation to consider adopting the 2016 selenium
criterion. The updated criterion reflects the latest scientific knowledge, which indicates that selenium
toxicity to aquatic life is primarily based on organisms consuming selenium-contaminated food rather
than exposure only to selenium dissolved in water. The final criterion is expressed both in terms of fish
tissue concentration (egg/ovary, whole body, or muscle) and water concentration (lentic, lotic). (See
Table 1 below.) It is our understanding that UDWQ is considering a recalculation of the 2016 selenium
criterion based on the presence/ absence of certain selenium-sensitive aquatic species occurring in
Utah waters. We also understand that UDWQ plans to discuss the results of any supporting
documentation with the WQS Workgroup prior to proposing revisions to Utah’s existing selenium
criteria. We recommend review of the criterion document, the Technical Support for Adopting and
Implementing EPA’s 2016 Selenium Criterion in Water Quality Standards, and EPA’s Revised Deletion
Process for the Site-Specific Recalculation Procedure for Aquatic Life Criteria. The EPA suggests Utah
review these documents, with the 2016 criteria, and develop a statewide plan to adopt and implement
the updated selenium criterion before recommending any revisions to the Board. EPA guidance also
recommends that states wishing to develop site-specific selenium fish tissue criterion elements based
on the revised deletion process should engage their EPA Regional office early in the process to ensure
the development of sound scientific analyses. The EPA is available to provide additional technical
support to aid in the adoption and implementation of the 2016 recommended selenium criterion.
Response:
Thank you for supporting DWQ’s prioritization of updated selenium criteria to protect aquatic life in Utah
and for providing additional information regarding the recommended criteria and criteria recalculation
procedures. DWQ is currently updating draft technical support documents for selenium criteria to clearly
identify and provide appropriate evidence for determinations of presence or absence of taxa used to
recalculate the recommended criteria. Any recalculation of the selenium criteria will follow appropriate

procedures for documenting resident and representative taxa; and taxa deletions. As suggested in the
comment, all work related to adopting updated selenium criteria will be discussed with Utah’s Water
Quality Standards Workgroup. Adoption of proposed criteria will follow appropriate rulemaking
procedures including review by Utah’s Water Quality Board, a public comment period, and request for
EPA approval.
Comment (Simmons):
The proposed changes for selenium are particularly problematic if they weaken rather than strengthen
oversight and rapid detection of water contamination by these chemicals through using a less sensitive
assay method. For example, weakening oversight by using tissue analysis rather than column analysis
seems to be the explicit goal for selenium as stated in the report. This is unfortunate and should not be
done. Instead, I recommend having both column testing and tissue testing. In any event, the most
sensitive method of detecting contamination should always be used, not the least sensitive. With regard
to the Provo River Shed and this rare aquifer, such an approach is essential.
Response:
EPA provided updated recommended aquatic life criteria for selenium in 2016. DWQ has reviewed
these recommendations and determined that Utah should update selenium criteria to ensure that Utah’s
criteria appropriately reflect nationally recommended criteria and the best available science. Updating
these criteria will enhance DWQ’s ability to protect aquatic life.
The updated recommended selenium criterion reflects the latest scientific knowledge indicating that
selenium toxicity to aquatic life primarily occurs due to ingestion of contaminated food. The final criteria
are expressed in terms of both fish tissue and water concentrations. Utah’s existing selenium criteria
for domestic source and agricultural use classifications will be unaffected by updated aquatic life
criteria, and routine water quality monitoring will still include water column selenium analysis.
All work related to adopting updated selenium criteria will be discussed with Utah’s Water Quality
Standards Workgroup. Adoption of updated criteria will follow all required rulemaking procedures
including review by Utah’s Water Quality Board, a public comment period, and request for EPA
approval.
Great Salt Lake, Farmington and Bear River Bays Aquatic
Life Criteria
Comment (USEPA):
We support UDWQ’s recommendation to pilot adoption of aluminum, ammonia, copper and selenium
criteria protecting aquatic life in Farmington and Bear River Bays. UDWQ has made significant strides

in strengthening CWA programs as they apply to Great Salt Lake (GSL) through stakeholder
coordination, scientific studies and monitoring, and improved implementation in programs such as
discharge permits. We applaud UDWQ’s substantial efforts invested into these program areas and their
long-term benefits to protect GSL’s unique habitats. The EPA provides a variety of support to UDWQ’s
ongoing efforts including metals toxicity studies under hypersaline conditions, fisheries and other
biological population studies throughout the varied GSL habitats, and continued water quality
monitoring. The unique ecology, chemistry, and hydrologic modifications of GSL have traditionally been
thought to preclude application of state-wide criteria to GSL. Although this likely remains true for the
hypersaline portions of GSL, the products from these recent studies have improved our understanding
of the similarities and differences in the aquatic life using the different bays, especially those with less
saline waters. We support continued dedicated efforts to develop water quality criteria applicable to
portions of GSL. We recommend that Utah continue this work so that soon the existing uses in GSL
can be fully protected under 40 C.F.R. § 131.10(i) and 131.11. The EPA is available to provide
additional technical support to aid in the adoption and implementation of these criteria.
Response:
Thank you for supporting DWQ’s efforts to develop and adopt numeric criteria for aquatic life in
Farmington and Bear River Bays of Great Salt Lake and for offering continued technical support. DWQ
looks forward to continued collaboration with EPA in working towards numeric criteria in Great Salt
Lake.
Comment (Richards):
The additional biological surveys that UDWQ has for Farmington Bay (FB) and Bear River Bay (BRB)
have macroinvertebrate data that only taxonomically identify to genus level or subfamily level but no
species level taxonomy (Armstrong and Wurtsbaugh 2019). This level of taxonomy will have the same
effects on recalculation as did for ammonia, i.e., toxicity criteria not representative of the taxa that occur
in FB and BRB (see Item 1). The same problem will result if the macroinvertebrate species that UDWQ
has in its database for FB or BRB have not been tested for the four toxicants listed in Table 2. Criteria
values from surrogate species that have been tested will need to be used, in some instances even if
those surrogate species are far removed taxonomically and phylogenetically. After reviewing the taxa
list for FB and BRB, I assume there will be a substantial number of taxa that have not been evaluated
for these toxicants. Again, this is contrary to what UDWQ has knowledge of (see preceding
paragraphs). Application of unrealistic recalculated criteria values by UDWQ for FB and BRB can
subsequently elicit costly wastewater facility upgrades and increased consulting costs.
Recommendation
Given the likely inaccuracies in recalculation procedures that I have outlined in this letter, I recommend
that UDWQ carefully evaluates any recalculation given these concerns. UDWQ should generate error
rates (e.g., confidence intervals) for recalculation if species found in FB and BRB are not same as those
that have toxicity values but do not occur in these ecosystems using appropriate resampling (e.g.,

bootstrap, jackknife) or other statistical methods. In addition, recent research suggests that species
traits including three major trait categories, external exposure, intrinsic sensitivity, and population
sustainability may be more useful for ecotoxicological evaluations (Liang et al. 2024, Rubach et. al.
2011). Unrealistically low criteria values based on EPA recalculation procedure could have large
economic costs, particularly for wastewater treatment facilities; unrealistically high criteria values could
result in under protection of our cherished water bodies in Utah, including Farmington Bay and Bear
River Bay.
Response:
Thank you for providing information and recommendations regarding the species deletion and criterion
recalculation procedures. This work is not yet completed, so particular species that may be deleted and
the effects on criteria are currently unknown. All work related to recalculating criteria for Farmington
and Bear River Bays will be discussed with DWQ’s Water Quality Standards Workgroup, and subject
to review from Utah’s Water Quality Board, a public comment period, and EPA approval. These
recommendations will be considered as this work proceeds through that process.
Aquatic life criteria - iron
Comment (USEPA):
The EPA continues to recommend that Utah review its existing iron criterion for consistency with EPA’s
CWA § 304(a) criteria recommendations. Utah’s aquatic life criterion for iron is currently expressed as
dissolved when EPA’s recommendation is 1,000 µg/L total recoverable iron. It is important to express
the criterion as total recoverable given the toxicity of iron hydroxide and ferric oxide (iron precipitates
or floc) to benthic organisms and the reduction of suitable spawning habitat due to excessive iron floc.
We are not aware of any data or analyses to support that 1,000 µg/L as dissolved iron is protective of
aquatic life. Therefore, we suggest that Utah revise the existing iron criterion to total recoverable to
account for the toxicity that results from precipitated iron.
Response:
DWQ is aware that precipitated iron can adversely affect aquatic life, especially benthic organisms, and
will continue to internally evaluate the potential need for changes to iron criteria. However, DWQ has
not prioritized iron criteria for updates at this time because we have concluded that Utah’s current iron
criteria and implementation procedures are protective of aquatic life uses. Permit effluent limits are
based on 1,000 µg/L total recoverable iron because no dissolved-to-total recoverable concentration
translator is specified. Utah also routinely assesses water quality using benthic macroinvertebrates.
Benthic macroinvertebrates are expected to be sensitive to any adverse effects from iron flocculation.
Locations where the existing criteria aren’t sufficiently protective can be identified by the biological
assessments and addressed through the total maximum daily load program.

Human health criteria - MCL based criteria
Comment (USEPA):
In 2015, the EPA published final updated ambient water quality criteria for the protection of human
health for 94 chemical pollutants. These updated recommendations reflect the latest scientific
information and EPA policies, including updated body weight, drinking water consumption rate, fish
consumption rate, bioaccumulation factors, health toxicity values, and relative source contributions.
The EPA acknowledges and supports UDWQ’s and the Board’s significant efforts in adopting most of
these updated human health criteria recommendations during the 2018 Utah WQS triennial review. We
note that for some of the parameters in EPA’s new/updated CWA § 304(a) human health criteria
recommendations, Utah has adopted the more stringent Maximum Contaminant Level (MCL)
established by the EPA under the Safe Drinking Water Act. The EPA supports retaining MCLs where
those values are more stringent than the 304(a) criteria recommendations. For a pollutant for which the
EPA has not published a recommended CWA § 304(a) criterion for "water + organisms" and for which
the EPA has promulgated a Maximum Contaminant Level Goal (MCLG), the EPA generally
recommends the MCLG for noncarcinogenic pollutants, or a criterion derived by recalculating the
MCLG at an acceptable cancer risk level. The EPA does not recommend that the MCL be used where
consideration of available treatment technology, costs, or availability of analytical methodologies has
resulted in a MCL that is less protective than a MCLG. The EPA recommends that UDWQ review the
criteria in Table 2.14.6 that are based on a MCL to ensure consistency with the recommendations
above.
Response:
DWQ recently updated over 100 human health criteria in accordance with the EPA’s 2015 updates to
304(a) recommended human health criteria, and has concluded that these criteria are protective
because they assume both direct human consumption of water and fish consumption. Some of the
Class 1C criteria in Utah Admin. Code R317-2-14 Table 2.14.1 are based on the Safe Drinking Water
Act maximum contaminant levels (MCLs). The MCLs are also protective of the Class 1C use because
under the Safe Drinking Water Act, MCLs are at the point of consumption whereas DWQ applies these
criteria to Utah surface waters prior to any treatment. DWQ continues to coordinate with the Utah
Division of Drinking Water to ensure that Utah’s Class 1C surface waters are protected.
Although DWQ concludes that existing criteria are protective of human health, given the potential for
discrepancies between recommended human health criteria, MCLs, MCLGs, and state adopted criteria,
DWQ agrees that additional review of the human health criteria in Utah Admin. Code R317-2 table
2.14.6 in the context of EPA’s 304(a) recommended human health criteria and EPA’s promulgated
MCLs and MCLGs is appropriate. DWQ will conduct an internal review of these criteria to identify any
potential needed changes and consider these updates for future water quality standards update
priorities. As resources permit, DWQ will work with EPA to address specific human health criteria that
do not meet federal requirements.

Human health criteria - methylmercury
Comment (USEPA):
We acknowledge and support the Division recommending Utah adopt the 2001 methylmercury fish
tissue-based criterion for the protection of people eating fish and shellfish. This criterion, 0.3 mg/kg fish
tissue wet weight, was EPA’s first water quality criterion expressed as a fish and shellfish tissue value
rather than as an ambient water column value. In April 2010, the EPA finalized technical guidance on
how to implement the fish tissue-based criterion. As discussed in Chapter 3 of the guidance document,
the EPA recommends working with stakeholders and the public to develop an implementation plan prior
to moving forward with a rulemaking proposal for the Board. The Water Quality Unit recognizes the
logistics and outreach involved in implementing this criterion, and we are available to assist the Division
in this effort.
Response:
Thank you for supporting DWQ’s prioritization of updated methylmercury criteria and for providing
additional information regarding EPA’s recommended criteria and technical guidance. DWQ currently
incorporates EPA’s recommended methylmercury fish consumption criterion of 0.3 mg/kg fish tissue
wet weight into Utah’s edible tissue advisory program for fish and waterfowl to protect public health
from methylmercury exposure. Adding methylmercury criteria to Utah’s water quality standards will
align criteria with the advisory program and enhance DWQ’s ability to protect human health from
methylmercury exposure. All work related to adopting updated methylmercury criteria will be discussed
with Utah’s Water Quality Standards Workgroup, and DWQ appreciates EPA’s engagement and
technical assistance with that group on this issue.
Comment (Simmons):
The proposed changes for methyl mercury are particularly problematic if they weaken rather than
strengthen oversight and rapid detection of water contamination by these chemicals through using a
less sensitive assay method. This is unfortunate and should not be done. Instead,I recommend having
both column testing and tissue testing. In any event, the most sensitive method of detecting
contamination should always be used, not the least sensitive. With regard to the Provo River Shed and
this rare aquifer, such an approach is essential.
Response:
EPA provided national recommended criteria for methylmercury in 2001. DWQ has reviewed these
recommendations and determined that Utah should adopt the recommended methylmercury criteria to
ensure that Utah’s criteria appropriately reflect nationally recommended criteria and the best available

science and information. Adopting this criterion will enhance DWQ’s ability to protect human health.
Methylmercury is the primary toxic and bioaccumulative form of mercury in the environment. EPA’s
nationally recommended methylmercury criteria were developed to protect human health from the
consumption of contaminated fish and shellfish and are therefore based on concentrations in tissues
of fish and shellfish. Methylmercury tissue criteria would be adopted in addition to Utah’s existing
mercury water criteria for domestic source and aquatic life uses.
All work related to adopting the recommended methylmercury criteria will be discussed with Utah’s
Water Quality Standards Workgroup. Adoption of proposed criteria will follow all required rulemaking
procedures including review by Utah’s Water Quality Board, a public comment period, and request for
EPA approval.
Recreational use criteria - microcystins and
cylindrospermopsin
Comment (USEPA):
The Water Quality Unit supports UDWQ’s recommendation to adopt the microcystins and
cylindrospermopsin criteria for the protection of human health. The EPA released national
recommendations for the Human Health Recreational Ambient Water Quality Criteria/Swimming
Advisories for Microcystins and Cylindrospermopsin (AWQC/SA) in May 2019. These AWQC/SA
accurately reflect the latest scientific knowledge on the potential human health effects from recreational
exposure to these two cyanotoxins. (See Table 2 below.) Primary contact recreation is protected in
water bodies at or below the recommended concentrations of microcystins and cylindrospermopsin.
The EPA acknowledges and commends that UDWQ already uses the information provided in these
recommendations since it developed triggers for posting swimming advisories.
As indicated in EPA’s fact sheet, cyanobacteria are naturally occurring photosynthetic bacteria found
in freshwater and marine habitats. Under certain environmental conditions, such as elevated levels of
nutrients, warmer temperatures, still water, and plentiful sunlight, cyanobacteria can rapidly multiply to
form “harmful algal blooms” (HABs). We acknowledge that HAB events appear to be occurring in Utah
at increasing frequency over time, and UDWQ has developed and implemented significant monitoring,
public notification and coordination protocols to address them. These HABs can result in adverse health
effects to humans and animals. Exposure to elevated levels of microcystins can potentially lead to liver
damage, and cylindrospermopsin toxicity can affect the kidneys and liver. EPA’s recommended
magnitude for microcystins and cylindrospermopsin is as follows:
For both cyanotoxins, the recommended duration and frequency depend on their application as a water
quality criterion or a swimming advisory, as described in the criteria document and the fact sheet.
Please note that the EPA also published national drinking water health advisories for these cyanotoxins.
Also, the EPA has published Implementation Guidance, Fact Sheets and FAQs that are available along
with the criteria recommendations document. We support UDWQ’s recommendation that the Board

adopt EPA’s recommended recreational water quality criteria for these cyanotoxins into R317-2 to
improve protection of public health.
Response:
Thank you for supporting DWQ prioritizing adoption of cyanotoxin criteria and for providing additional
information regarding EPA’s recommended criteria and technical guidance. Currently, EPA’s
recommended cyanotoxin criteria, along with other indicators of harmful algal bloom risk to human
health, are incorporated into DWQ’s recreational health advisory program and water quality
assessments. Adopting cyanotoxin criteria into Utah’s water quality standards will align criteria with the
recreational health advisory program and enhance DWQ’s protection of human health from exposure
to cyanotoxins. All work related to adopting updated cyanotoxin criteria will be discussed with Utah’s
Water Quality Standards Workgroup, and DWQ appreciates EPA’s engagement and technical
assistance with that group on this issue.
Numeric nutrient criteria for lakes and reservoirs
Comment (USEPA):
The Water Quality Unit supports the Division’s proposals to continue efforts developing numeric criteria
for nutrients in Utah Lake, and piloting application of EPA’s 2021 Numeric Nutrient Criteria for Lakes
and Reservoirs. We are available to continue assisting the Division in these efforts.
Response:
Thank you for supporting DWQ’s ongoing efforts to develop numeric nutrient criteria for Utah Lake and
in Utah’s lakes and reservoirs. DWQ appreciates EPA’s engagement and technical assistance on these
issues.
Colorado River salinity standards
Comment (USEPA):
We support UDWQ’s recommendation to adopt by reference the updated 2023 Colorado River Salinity
Standards. The Colorado River Basin Salinity Control Forum (Forum) reviews the numeric criteria and
Plan of Implementation for controlling salinity within its seven member states, including Utah, and
publishes its recommendations every three years. The EPA supports adopting by reference the
Forum’s 2023 Colorado River Salinity Standards into R317-2-4.

Response:
Thank you for supporting DWQ’s recommendation to adopt the updated 2023 Colorado River Salinity
Standards.

Wetland water quality standards
Comment (USEPA):
With the assistance of EPA Wetland Program Development Grants (WPDGs), the Utah Department of
Environmental Quality and collaborating colleagues have developed a robust wetlands program that
has produced wetland mapping tools, sampling standard operating procedures (SOPs) specific to
Utah’s wetland types, assessment tools, characterization of the highest attainable condition for
impounded wetlands, and a CWA § 401 certification program. With over one million dollars in WPDGs
(including match) used to specifically address WQS for wetlands, Utah has made significant advances
in developing the policy and scientific foundations for wetland WQS protective of these important
habitats. The EPA is particularly encouraged by these efforts. However, the EPA notes that though
significant policy and scientific advances have occurred, wetlands WQS have not been adopted into
R317-2. The EPA recommends that Utah prioritize making the necessary final steps to draft and adopt
WQS protective of its wetland ecosystems. In 2016, the EPA published an online tool, with interactive
templates to facilitate the development of protective WQS for wetlands. The templates are separated
into the three components: designated uses, criteria, and antidegradation. Customizing all three
components to the needs of the state and its wetland resources will generate a narrative statement that
serves as a wetland-specific WQS that will ensure consistent application of CWA provisions to
wetlands. The EPA recommends that Utah review existing wetland data with the online material and
consider the development and adoption of a narrative criterion that will provide robust protection of its
wetlands and their functions, either as a whole or based on specific wetland types.
Response:
As noted in the comment, DWQ, in cooperation with partner agencies, particularly EPA, has made
substantial progress building the scientific basis for wetland protections in Utah. However, DWQ
believes there is some confusion from EPA regarding water quality standards and protections for
wetlands in Utah. All national wildlife refuges and state waterfowl management areas in Utah have
numeric criteria applied to them through designated uses 2B, 3A, 3B, 3C, or 3D (UAC R317-2-13.11).
These constitute a significant surface area of high value wetlands in Utah. For unclassified wetlands,
discharge permits have presumed default use classifications and numeric criteria of 2B, 3D use classes.
In addition, all waters of the state, including wetlands, have protections under the narrative standard,
401 water quality certifications, and antidegradation policy. Finally, DWQ continues to collaborate with

the Utah Department of Natural Resources in developing appropriate wetland health assessment
methods.
However, applying numeric criteria to wetlands presents substantial challenges, because wetlands
naturally and routinely fall outside of the ranges of parameters that were developed conventionally for
lakes and rivers, such as temperature, dissolved oxygen, and pH. We request that EPA provide clear
recommendations to states regarding wetland-specific numeric criteria. We would appreciate knowing
how other states have developed and replaced conventional numeric criteria with appropriate and
protective wetland criteria and how those have been applied to permits and assessments.
DWQ’s last application for Wetland Program Development Grant funding, which included steps
necessary for adopting wetland-specific water quality criteria by completing a Use Attainability Analysis,
a necessary process to justify criteria replacement, was rejected by EPA. Subsequently, that program
was allocated to another Utah state agency. This has significantly impacted DWQ’s ability to move
forward with wetland-specific standards.
Provo River Watershed and Heber Valley Aquifer
Comment (Simmons):
I write to address some concerns I have with the State’s Triennial Water assessment plans. I have
particular concerns about the Provo River Watershed and, specifically, the pristine and rare Class 1a
aquifer that underlies Heber Valley. The health of the aquifer depends on the health of the surface
waters that feed and overlay it. I am very concerned about the ever increasing pressures put not just
on water usage, but on water treatment and cleanliness. Heber Valley, home of this critical class 1a
aquifer with an unconsolidated, porous, top is particularly sensitive to damage as recognized by
Wasatch County’s environmental studies.
The following are key water quality concerns:
The Heber Valley North Fields Class IA pristine aquifer is a key resource serving drinking water to
residents of the Heber Valley.
Protection of the aquifer water quality is critical. Polluted aquifers are very hard to restore.
Water quality of the Heber Valley drinking water aquifer is linked to the water quality of surface waters
including the Provo River.
The portion of the Heber Valley Groundwater Classification Map which includes the north end of North
Fields is reproduced in Figure 1. The Class 1A Aquifer is shown mapped with green shading on Figure
1. There are several wells in the area which rely on the excellent water quality of the aquifer. The red
dots on Figure 1 show wells inventoried in 1991. The subsoils in the area are very cobbly and have
high permeability but low ability to absorb and treat pollutants.

Please assure that changes in Water Quality standards will continue to protect the pristine water quality
of the Heber Valley North Fields.
Response:
Thank you for identifying your concerns regarding groundwater protections and DWQ’s proposed
updates to water quality standards for methylmercury and selenium. The Triennial Review is specifically
limited to Utah Administrative Code R317-2 which designates uses and water quality standards for
surface waters in Utah. Groundwater rules are contained in R317-6. Comments regarding groundwater
have been referred to DWQ’s Groundwater Section Manager. Surface waters in this area are protected
as 1C domestic source waters.
Comment (Franco):
As Mayor of Heber City I'm definitely concerned and committed about maintaining our City's water
supply from the Class IA aquifer beneath the Heber Valley floor in Wasatch County. I'm sending these
public comments to show our City's actions to recognize and protect the unique geology for our Class
IA aquifer and water supply based on existing Utah Administrative Code R317 Standards.
Three years ago I advocated for our City to adopt MS4 Stormwater Standards before being required
by the State because the amount of density we were approving then would lead to that state
requirement. Our City then took two years to develop the MS4 stormwater management standards at
great expense in order to protect the aquifer drinking source and not adversely affect contiguous
wetlands to the City, especially within the North Fields. The North Fields, their many wetlands, and
most of Heber Valley are also part of that contiguous, unprotected Class IA aquifer per Utah
Administrative Code R317 standards.
Now our City requires MS4 stormwater infrastructure in all of our developments even though we are
not required to by the State. I believe that Wasatch County also requires strict stormwater requirements
for these same purposes.
Please understand that Heber City's commitment to protecting this unprotected aquifer cannot be
understated with this expensive, proactive stormwater management program.
We collaborated extensively with the Valley's Irrigation Companies, CUP, Wasatch County, the Utah
River Mitigation and Conservation Commission, the Provo River Water Users Association, etc., in
developing this proactive MS4 stormwater management plan.
Our City also contributed money to a new wetlands mapping survey for the North Fields and Provo
River Corridor with the Utah Geological Survey (UGS) in 2022. This completed survey showed
increased amounts of wetlands and riparian areas which are now documented for applicable
protections.
Our City also increased its Sensitive Lands protection with a new ordinance in 2023 allowing buffers
and greater protections in addition to the MS4 Stormwater management standards.
In all of these proactive steps, we relied on the current R317 Utah Administrative Code standards and
would only want to maintain or improve those standards; not diminish them in any way. Please
understand Heber City's commitment to ensure and maintain state and local standards for water quality
given the high rate of growth within our area. Our State must maintain the highest standards in Utah
Administrative Code R317 to protect our natural resources and their quality, especially water, given the
impacts of continuing growth. This is the only way to have sustainable, responsible growth within our
State.
Response:
Thank you for identifying your concerns regarding stormwater requirements, groundwater protections,
and maintaining appropriate water quality standards for Utah. DWQ appreciates Heber City’s proactive
efforts to protect water quality. The Triennial Review is specifically limited to Utah Administrative Code
R317-2 which designates uses and water quality standards for surface waters in Utah. Stormwater and
groundwater rules are contained in R317-8 and R317-6. Comments regarding stormwater and
groundwater have been referred to the managers of those programs.
The goal of the triennial review is to identify and prioritize water quality standards updates necessary
to protect the beneficial uses of Utah’s surface waters. DWQ strives to ensure that water quality
standards are up to date and appropriately reflect nationally recommended criteria, state-specific water
quality issues, and the best available science and information. Thank you for highlighting the ongoing
need to meet these goals.
Appendices
Appendix 1. 2023 Triennial Review public notice
Appendix 2. 2023 Triennial Review postcard
Appendix 3. Written comments received
Appendix 4. Public hearing summary
Appendix 5. 2023 Triennial Review water quality standards priority list
Appendix 6. EPA submittal letter
Appendix 7. EPA response
Appendix1.2023 TriennialReview Public
Notice
195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144870 • Salt Lake City, UT 84114-4870 Telephone [phone] • Fax [phone] TDD [phone] www.deq.utah.gov Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality
Kimberly D. ShelleyExecutive Director
DIVISION OF WATER QUALITYJohn K. Mackey, P.E.Director
SPENCER J. COX Governor
DEIDRE HENDERSONLieutenant Governor
October 30, 2023
DIVISION OF WATER QUALITY UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY PUBLIC NOTICE OF 2023 WATER QUALITY STANDARDS TRIENNIAL REVIEW
PURPOSE OF PUBLIC NOTICE The purpose of this notice is to declare a public comment period to solicit public and stakeholder comments on Utah’s water quality standards and revisions to be considered for the 2023 triennial
review.
BACKGROUND To meet obligations under the Clean Water Act, the Division of Water Quality (DWQ) is required to review Utah’s Water Quality Standards in Utah Administrative Code R317-2
(adminrules.utah.gov/public/rule/R317-2/Current%20Rules) at least once every three years. As
part of this review, DWQ is soliciting input from the public and interested parties regarding standards topics to be considered during the review including any specific recommended changes to Utah’s Standards of Quality for Waters of the State. When appropriate, the rationale and any supporting information should be included with the recommendations.
The DWQ will discuss the comments with the Utah Water Quality Standards Workgroup, inform the Utah Water Quality Board at a regularly scheduled meeting, and issue comment responses. More information, including a list of revisions currently being considered is available at deq.utah.gov/water-quality/triennial-review-water-quality.
PUBLIC COMMENTS Public comments are invited any time prior to the deadline of the close of business on December 15, 2023. Written comments can be submitted by email to: Jake Vander Laan at [e-mail], or by mail to: Jake Vander Laan, Utah Division of Water Quality, P.O. Box
144870, Salt Lake City, Utah 84114-4870.
Page 2

PUBLIC HEARING A public hearing to receive comments will be held on December 14, 2023, 6:00-7:00 PM, in the Red Rocks Conference Room 3132 on the 3rd floor at the Multi Agency State Office Building,
195 North 1950 West, Salt Lake City, UT with virtual access available at meeting link https://utah-
gov.zoom.us/j/87582829743?pwd=WVdlWUtZdjc0UzBOblJ1RERqMXpMdz09
DWQ-2023-125039
Appendix 2.2023 Triennial Review Postcard
FIRST-CLASS MAILUS POSTAGEPAIDSLC, UTPERMIT NO. 4621
Division of Water QualityDEPARTMENT of ENVIRONMENTAL QUALITY
P.O. Box 144870
Salt Lake City, Utah
84114-4870
Return Service Requested
Notice of Public Comment Period
for Utah Administrative Code R317-2: Standards of Quality for Waters of the State
The Utah Division of Water Quality (DWQ) is conducting the 2023 Triennial Review of Utah’s Water Quality Standards.
DWQ is asking for comments from the public and stakeholders about recommended changes to Utah Administrative Code R317-2 Standards of Quality for Waters of the State.
To submit comments and find more info including supporting documents, visit
Individuals with special needs (including auxiliary communicating aids and services) should contact the DEQ
Oce of Human Resources at [phone] or T.D.D. [phone].
Questions? Contact Jake Vander Laan, [e-mail]
Dec. 14, 2023, 6-7 PMRed Rocks Conference Room 31323rd floor Multi Agency State Oce Building195 North 1950 West, Salt Lake City, UT
bit.ly/40kuRuR (case-sensitive)
Written comments accepted until 6pm Dec. 15, 2023
WaterQuality.utah.gov
PUBLIC HEARING
REMOTE OPTION
Appendix 3.2023 Triennial Review Comments
Received
Ref: 8WD-CWQ
Jake Vander Laan
Utah Division of Water Quality
[e-mail]
Subject: EPA’s Priorities for Utah’s 2023 Triennial Review of Water Quality Standards
Dear Mr. Vander Laan:
Thank you for notifying the U.S. Environmental Protection Agency (EPA) Region 8 Water Quality Unit of
the State of Utah’s upcoming triennial review of its water quality standards (WQS). This letter provides
the EPA’s comments in response to the Utah Division of Water Quality’s (UDWQ or Division) public
notice1 requesting scoping-level comments for the triennial review of Utah Administrative Code R317-
2, Standards of Quality for Waters of the State. Our comments address the information and supporting
materials included in the public notice and currently posted on the UDWQ website.2 Public comments
are being solicited from October 30 through December 15, 2023, and a public hearing will be held
December 14, 2023 at 6:00PM. It is EPA’s understanding that UDWQ will summarize and discuss all
comments received with the Utah Water Quality Standards Workgroup (Workgroup) before updating
the Utah Water Quality Board (Board) with proposed WQS revisions from the 2023 triennial review.
EPA’s Role
Consistent with the Clean Water Act (CWA) and the EPA’s WQS Regulation at 40 C.F.R. § 131.21, new
or revised WQS do not become applicable for CWA purposes until approved by the EPA. Pursuant to
CWA § 303(c) requirements, states and authorized tribes must submit such WQS changes to EPA for
review, and EPA must approve or disapprove the revisions. The EPA has a duty to promptly promulgate
federal WQS where necessary to remedy a disapproved WQS, and in any case where the Administrator
determines that an EPA promulgation action is necessary to meet the requirements of the CWA. The
EPA Region 8 strives to work closely with states and authorized tribes throughout each WQS review,
development, and revision process so that new and revised WQS can be approved.
The EPA acknowledges UDWQ’s and the Board’s significant ongoing work revising Utah’s WQS and
standard operating procedures to meet the requirements of the WQS Regulation (40 C.F.R. Part 131)
and CWA. Our comments below are designed to identify opportunities for UDWQ and the Board to
1 See DIVISION OF WATER QUALITY, UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY, PUBLIC NOTICE OF 2023 Water
Quality Standards Triennial Review, October 30, 2023, and supporting materials.
2 https://deq.utah.gov/water-quality/triennial-review-water-quality.

2

further align Utah’s WQS with the EPA WQS Regulation, the EPA’s recommended water quality criteria
and policies, and make other program improvements.
Water Quality Criteria
The Water Quality Unit reviewed R317-2-14 and identified criteria with new or updated EPA CWA §
304(a) water quality criteria recommendations.3 We recognize the Division proposal to adopt some of
these new and updated criteria recommendations. We support the Division’s consideration of these
EPA national recommendations to better protect Utah surface waters with criteria that more
accurately predict and prevent impacts to aquatic ecosystems and people.

Aquatic Life Criteria

Ammonia – We acknowledge and support the Division recommending Utah update its existing
ammonia criteria by considering EPA’s 2013 ammonia criteria recommendations, and a potential
adjustment based on the presence/absence of certain species sensitive to ammonia exposure. It is our
understanding that a survey to evaluate the historic and expected occurrence of freshwater mussels
and sensitive snails in state waterbodies will be completed beforehand. Information obtained from this
study will be needed for any potential adjustments to the 2013 recommended ammonia criteria. As
you know, recalculation of the national ammonia criteria recommendations based on the ammonia
toxicity of species occurrence in Utah waters is only possible where it is documented that more
sensitive species are not currently occurring and not expected to be able to return to those waters. For
example, UDWQ would need to provide a rationale when developing site-specific ammonia criteria
based on the absence of certain unionid mussels and suitable habitat (including suitable hosts such as
salmonids) in all affected segments pursuant to EPA recommendations (see: Aquatic Life Ambient
Water Quality Criteria for Ammonia – Freshwater, 2013).4 We understand that UDWQ will discuss the
results of the freshwater mussels and snails study, and any other supporting documentation with the
WQS Workgroup prior to proposing revisions to Utah’s existing ammonia criteria. The EPA is available
to provide additional technical support to aid in the adoption and implementation of the 2013
recommended ammonia criteria.

Selenium – The Water Quality Unit supports UDWQ’s recommendation to consider adopting the 2016
selenium criterion.5 The updated criterion reflects the latest scientific knowledge, which indicates that
selenium toxicity to aquatic life is primarily based on organisms consuming selenium-contaminated
food rather than exposure only to selenium dissolved in water. The final criterion is expressed both in
terms of fish tissue concentration (egg/ovary, whole body, or muscle) and water concentration (lentic,
lotic). (See Table 1 below.)

It is our understanding that UDWQ is considering a recalculation of the 2016 selenium criterion based
on the presence/ absence of certain selenium-sensitive aquatic species occurring in Utah waters. We
also understand that UDWQ plans to discuss the results of any supporting documentation with the
WQS Workgroup prior to proposing revisions to Utah’s existing selenium criteria. We recommend
review of the criterion document,5 the Technical Support for Adopting and Implementing EPA’s 2016

3 https://www.epa.gov/wqc/national-recommended-water-quality-criteria.
4 EPA 822-R-18-002, April 2013. See also Appendix N. Site Specific Criteria for Ammonia.
5 https://www.epa.gov/wqc/aquatic-life-criterion-selenium.
3
Selenium Criterion in Water Quality Standards,6 and EPA’s Revised Deletion Process for the Site-Specific
Recalculation Procedure for Aquatic Life Criteria.7 The EPA suggests Utah review these documents, with
the 2016 criteria, and develop a statewide plan to adopt and implement the updated selenium
criterion before recommending any revisions to the Board. EPA guidance also recommends that states
wishing to develop site-specific selenium fish tissue criterion elements based on the revised deletion
process should engage their EPA Regional office early in the process to ensure the development of
sound scientific analyses. The EPA is available to provide additional technical support to aid in the
adoption and implementation of the 2016 recommended selenium criterion.
Table 1. Aquatic Life Ambient Water Quality Criterion for Selenium in Freshwater 2016.
Chronic Selenium Short-term
Egg-Ovary¹
[mg/kg dw]
Whole Body¹
[mg/kg dw]
Muscle¹
[mg/kg dw]
Water Lentic¹
[ug/L]
Water Lotic¹
[ug/L]
Water¹
[ug/L]
15.1 8.5 11.3 1.5
(30 day)
3.1
(30 day)
Intermittent
exposure
equation
¹A note on hierarchy of table: when fish egg/ovary concentrations are measured, the values supersede any whole-body,
muscle or water column elements except in certain situations. Whole body or muscle measurements supersede any water
column element when both fish tissue and water concentrations are measured, except in certain situations. Water column
values are derived from the egg & ovary concentrations via bioaccumulation modeling. Water column values are the
applicable criterion element in the absence of fish tissue measurements, such as waters where fish have been extirpated or
where physical habitat and/or flow regime cannot sustain fish populations, or in waters with new discharges of selenium
where steady state has not been achieved between water and fish tissue at the site.
Great Salt Lake, Farmington and Bear River Bays Aquatic Life Criteria - We support UDWQ’s
recommendation to pilot adoption of aluminum, ammonia, copper and selenium criteria protecting
aquatic life in Farmington and Bear River Bays. UDWQ has made significant strides in strengthening
CWA programs as they apply to Great Salt Lake (GSL) through stakeholder coordination, scientific
studies and monitoring, and improved implementation in programs such as discharge permits. We
applaud UDWQ’s substantial efforts invested into these program areas and their long-term benefits to
protect GSL’s unique habitats. The EPA provides a variety of support to UDWQ’s ongoing efforts
including metals toxicity studies under hypersaline conditions, fisheries and other biological population
studies throughout the varied GSL habitats, and continued water quality monitoring. The unique
ecology, chemistry, and hydrologic modifications of GSL have traditionally been thought to preclude
application of state-wide criteria to GSL. Although this likely remains true for the hypersaline portions
of GSL, the products from these recent studies have improved our understanding of the similarities and
differences in the aquatic life using the different bays, especially those with less saline waters. We
support continued dedicated efforts to develop water quality criteria applicable to portions of GSL. We
recommend that Utah continue this work so that soon the existing uses in GSL can be fully protected
under 40 C.F.R. § 131.10(i) and 131.11. The EPA is available to provide additional technical support to
aid in the adoption and implementation of these criteria.
6 https://www.epa.gov/system/files/documents/2021-10/selenium-adopting-tsd-draft-2021.
7 Revised Deletion Process for the Site-Specific Recalculation Procedure for Aquatic Life Criteria. EPA 823-R-13-001.
https://www.epa.gov/sites/production/files/2015-08/documents/revised_deletion_process_for_the_sitespecific_
recalculation_procedure_for_aquatic_life_criteria.

4

Iron - The EPA continues to recommend that Utah review its existing iron criterion for consistency with
EPA’s CWA § 304(a) criteria recommendations. Utah’s aquatic life criterion for iron is currently
expressed as dissolved when EPA’s recommendation is 1,000 µg/L total recoverable iron. It is
important to express the criterion as total recoverable given the toxicity of iron hydroxide and ferric
oxide (iron precipitates or floc) to benthic organisms and the reduction of suitable spawning habitat
due to excessive iron floc.8 We are not aware of any data or analyses to support that 1,000 µg/L as
dissolved iron is protective of aquatic life. Therefore, we suggest that Utah revise the existing iron
criterion to total recoverable to account for the toxicity that results from precipitated iron.

Human Health Criteria

In 2015, the EPA published final updated ambient water quality criteria for the protection of human
health for 94 chemical pollutants. These updated recommendations reflect the latest scientific
information and EPA policies, including updated body weight, drinking water consumption rate, fish
consumption rate, bioaccumulation factors, health toxicity values, and relative source contributions.9
The EPA acknowledges and supports UDWQ’s and the Board’s significant efforts in adopting most of
these updated human health criteria recommendations during the 2018 Utah WQS triennial review.

We note that for some of the parameters in EPA’s new/updated CWA § 304(a) human health criteria
recommendations, Utah has adopted the more stringent Maximum Contaminant Level (MCL)
established by the EPA under the Safe Drinking Water Act. The EPA supports retaining MCLs where
those values are more stringent than the 304(a) criteria recommendations. For a pollutant for which
the EPA has not published a recommended CWA § 304(a) criterion for "water + organisms" and for
which the EPA has promulgated a Maximum Contaminant Level Goal (MCLG), the EPA generally
recommends the MCLG for noncarcinogenic pollutants, or a criterion derived by recalculating the
MCLG at an acceptable cancer risk level. The EPA does not recommend that the MCL be used where
consideration of available treatment technology, costs, or availability of analytical methodologies has
resulted in a MCL that is less protective than a MCLG.10 The EPA recommends that UDWQ review the
criteria in Table 2.14.6 that are based on a MCL to ensure consistency with the recommendations
above.

Methylmercury – We acknowledge and support the Division recommending Utah adopt the 200111
methylmercury fish tissue-based criterion for the protection of people eating fish and shellfish. This
criterion, 0.3 mg/kg fish tissue wet weight, was EPA’s first water quality criterion expressed as a fish
and shellfish tissue value rather than as an ambient water column value. In April 2010, the EPA
finalized technical guidance on how to implement the fish tissue-based criterion.12 As discussed in
Chapter 3 of the guidance document, the EPA recommends working with stakeholders and the public

8 U.S. EPA. Quality Criteria for Water. July, 1976.
9 https://www.epa.gov/wqc/human-health-criteria-development-documents.
10 See 65 Fed. Reg. 66444, 66450-66451 (November 3, 2000) available at https://www.gpo.gov/fdsys/pkg/FR-2000-11-
03/pdf/00-27924.pdf.
11 66 Fed. Reg. 1344, 1355, (January 8, 2001).
12 http://www.epa.gov/waterscience/criteria/methylmercury/.
5
to develop an implementation plan prior to moving forward with a rulemaking proposal for the Board.
The Water Quality Unit recognizes the logistics and outreach involved in implementing this criterion,
and we are available to assist the Division in this effort.
Recreational Ambient Water Quality Criteria for Microcystins and Cylindrospermopsin - The Water
Quality Unit supports UDWQ’s recommendation to adopt the microcystins and cylindrospermopsin
criteria for the protection of human health. The EPA released national recommendations for the
Human Health Recreational Ambient Water Quality Criteria/Swimming Advisories for Microcystins and
Cylindrospermopsin (AWQC/SA) in May 2019.13 These AWQC/SA accurately reflect the latest scientific
knowledge on the potential human health effects from recreational exposure to these two
cyanotoxins. (See Table 2 below.) Primary contact recreation is protected in water bodies at or below the
recommended concentrations of microcystins and cylindrospermopsin. The EPA acknowledges and
commends that UDWQ already uses the information provided in these recommendations since it
developed triggers for posting swimming advisories.
As indicated in EPA’s fact sheet,14 cyanobacteria are naturally occurring photosynthetic bacteria found
in freshwater and marine habitats. Under certain environmental conditions, such as elevated levels of
nutrients, warmer temperatures, still water, and plentiful sunlight, cyanobacteria can rapidly multiply
to form “harmful algal blooms” (HABs). We acknowledge that HAB events appear to be occurring in
Utah at increasing frequency over time, and UDWQ has developed and implemented significant
monitoring, public notification and coordination protocols to address them. These HABs can result in
adverse health effects to humans and animals. Exposure to elevated levels of microcystins can
potentially lead to liver damage, and cylindrospermopsin toxicity can affect the kidneys and liver. EPA’s
recommended magnitude for microcystins and cylindrospermopsin is as follows:
Table 2. EPA Recommended AWQC/SA for Microcystins and Cylindrospermopsin.
Recommended magnitude for cyanotoxins
Microcystins Cylindrospermopsin
8 ug/L 15 ug/L
For both cyanotoxins, the recommended duration and frequency depend on their application as a
water quality criterion or a swimming advisory, as described in the criteria document and the fact
sheet. Please note that the EPA also published national drinking water health advisories for these
cyanotoxins. Also, the EPA has published Implementation Guidance, Fact Sheets and FAQs that are
available along with the criteria recommendations document.15 We support UDWQ’s recommendation
that the Board adopt EPA’s recommended recreational water quality criteria for these cyanotoxins into
R317-2 to improve protection of public health.
The Water Quality Unit also supports the Division’s proposals to continue efforts developing numeric
criteria for nutrients in Utah Lake, and piloting application of EPA’s 2021 Numeric Nutrient Criteria for
Lakes and Reservoirs. We are available to continue assisting the Division in these efforts.
13 See https://www.epa.gov/sites/production/files/2019-05/documents/hh-rec-criteria-habs-document-2019.pdf.
14 See https://www.epa.gov/sites/production/files/2019-05/documents/hh-rec-criteria-habs-factsheet-2019.pdf.
15 https://www.epa.gov/wqc/recreational-water-quality-criteria-and-methods#rec3.

6

Colorado River Salinity Standards

We support UDWQ’s recommendation to adopt by reference the updated 2023 Colorado River Salinity
Standards. The Colorado River Basin Salinity Control Forum (Forum) reviews the numeric criteria and
Plan of Implementation for controlling salinity within its seven member states, including Utah, and
publishes its recommendations every three years. The EPA supports adopting by reference the Forum’s
2023 Colorado River Salinity Standards into R317-2-4.

Wetland Water Quality Standards

With the assistance of EPA Wetland Program Development Grants (WPDGs), the Utah Department of
Environmental Quality and collaborating colleagues have developed a robust wetlands program that
has produced wetland mapping tools, sampling standard operating procedures (SOPs) specific to
Utah’s wetland types, assessment tools, characterization of the highest attainable condition for
impounded wetlands, and a CWA § 401 certification program.16 With over one million dollars in
WPDGs (including match) used to specifically address WQS for wetlands, Utah has made significant
advances in developing the policy and scientific foundations for wetland WQS protective of these
important habitats. The EPA is particularly encouraged by these efforts. However, the EPA notes that
though significant policy and scientific advances have occurred, wetlands WQS have not been adopted
into R317-2. The EPA recommends that Utah prioritize making the necessary final steps to draft and
adopt WQS protective of its wetland ecosystems.

In 2016, the EPA published an online tool, with interactive templates to facilitate the development of
protective WQS for wetlands.17 The templates are separated into the three components: designated
uses, criteria, and antidegradation. Customizing all three components to the needs of the state and its
wetland resources will generate a narrative statement that serves as a wetland-specific WQS that will
ensure consistent application of CWA provisions to wetlands. The EPA recommends that Utah review
existing wetland data with the online material and consider the development and adoption of a
narrative criterion that will provide robust protection of its wetlands and their functions, either as a
whole or based on specific wetland types.

Conclusion

We thank UDWQ and the Board for the opportunity to comment on the substance of the WQS triennial
review, and hope our comments are helpful in developing and refining the scope of the triennial
revisions. We acknowledge and commend ongoing efforts by UDWQ and the Board to maintain and
improve water quality in Utah. The EPA appreciates UDWQ’s and the Board’s efforts to ensure that
Utah’s rulemaking complies with the EPA’s WQS Regulation at 40 C.F.R. Part 131. Please note that the
Water Quality Unit’s comments are preliminary in nature and should not be interpreted as final EPA

16 https://deq.utah.gov/water-quality/wetlands-program/wetlands-program. 17 https://www.epa.gov/wqs-tech/templates-developing-wetland-water-quality-standards
7
decisions under CWA § 303(c). If there are questions concerning our comments, please contact George
Parrish (at 303-312-7027 or via email at [e-mail]).
Sincerely,
Andrew Todd
Supervisor, Water Quality Section
2/7/24, 12:31 PM Comment for Triennial Water Quality Studies- Please Accept - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#label/2023+Triennial+Review+Comment/FMfcgzGwJJWwHglVWPMMDsTtVtvmpHhM 1/1
<[e-mail]>
to me
Heidi Franco
Hello Division of Water Quality and Mr. Vander Laan;
As Mayor of Heber City I'm definitely concerned and commied about maintaining our City's water supply from the Class IA aquifer beneath the Heber Valley floor in
Wasatch County. I'm sending these public comments to show our City's acons to recognize and protect the unique geology for our Class IA aquifer and water supply
based on exisng Utah Administrave Code R317 Standards.
Three years ago I advocated for our City to adopt MS4 Stormwater Standards before being required by the State because the amount of density we were approving then
would lead to that state requirement. Our City then took two years to develop the MS4 stormwater management standards at great expense in order to protect the
aquifer drinking source and not adversely affect conguous wetlands to the City, especially within the North Fields. The North Fields, their many wetlands, and most of
Heber Valley are also part of that conguous, unprotected Class IA aquifer per Utah Administrave Code R317 standards.
Now our City requires MS4 stormwater infrastructure in all of our developments even though we are not required to by the State. I believe that Wasatch County also
requires strict stormwater requirements for these same purposes.
Please understand that Heber City's commitment to protecng this unprotected aquifer cannot be understated with this expensive, proacve stormwater management
program.
We collaborated extensively with the Valley's Irrigaon Companies, CUP, Wasatch County, the Utah River Migaon and Conservaon Commission, the Provo River
Water Users Associaon, etc., in developing this proacve MS4 stormwater management plan.
Our City also contributed money to a new wetlands mapping survey for the North Fields and Provo River Corridor with the Utah Geological Survey (UGS) in 2022. This
completed survey showed increased amounts of wetlands and riparian areas which are now documented for applicable protecons.
Our City also increased its Sensive Lands protecon with a new ordinance in 2023 allowing buffers and greater protecons in addion to the MS4 Stormwater
management standards.
In all of these proacve steps, we relied on the current R317 Utah Administrave Code standards and would only want to maintain or improve those standards; not
diminish them in any way.
Please understand Heber City's commitment to ensure and maintain state and local standards for water quality given the high rate of growth within our area. Our State
must maintain the highest standards in Utah Administrave Code R317 to protect our natural resources and their quality, especially water, given the impacts of
connuing growth. This is the only way to have sustainable, responsible growth within our State.
Thank you for accepng my public comments,
Heidi Franco

Heidi Franco
Mayor, Heber City
435-671-8244
[e-mail]
Transparency & Accountability to Citizens
2/7/24, 12:32 PM Comment on Triennial Water quality studies. - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#label/2023+Triennial+Review+Comment/FMfcgzGwJJTfMmqDDJjhwZnVgsnsvxfq 1/2
Dear Mr. Vander.
I write to address some concerns I have with the State’s Triennial Water assessment plans. I have particular
concerns about the Provo River Watershed and, specifically, the pristine and rare Class 1a aquifer that underlies
Heber Valley. The health of the aquifer depends on the health of the surface waters that feed and overlay it.
I am very concerned about the ever increasing pressures put not just on water usage, but on water treatment and
cleanliness. Heber Valley, home of this critical class 1a aquifer with an unconsolidated, porous, top is particularly
sensitive to damage as recognized by Wasatch County’s environmental studies.
The following are key water quality concerns:The Heber Valley North Fields Class IA prisne aquifer is a key resource serving drinking water to residents of theHeber Valley. Protecon of the aquifer water quality is crical. Polluted aquifers are very hard to restore.
Water quality of the Heber Valley drinking water aquifer is linked to the water quality of surface waters includingthe Provo River.
The poron of the Heber Valley Groundwater Classificaon Map which includes the north end of North Fields isreproduced in Figure 1. The Class 1A Aquifer is shown mapped with green shading on Figure 1. There are severalwells in the area which rely on the excellent water quality of the aquifer. The red dots on Figure 1 show wellsinventoried in 1991. The subsoils in the area are very cobbly and have high permeability but low ability to absorband treat pollutants.
Figure 1 - Poron of Ground Water Classificaon Map for Heber Valley
Please assure that changes in Water Quality standards will connue to protect the prisne water quality of the
Heber Valley North Fields.
The proposed changes for methyl mercury and selenium are parcularly problemac if they weaken rather thanstrengthen oversight and rapid detecon of water contaminaon by these chemicals through using a less sensiveassay method. For example, weakening oversight by using ssue analysis rather than column analysis seems to bethe explicit goal for selenium as stated in the report. This is unfortunate and should not be done. Instead,Irecommend having both column tesng and ssue tesng. In any event, the most sensive method of detecng
2/7/24, 12:32 PM Comment on Triennial Water quality studies. - [e-mail] - State of Utah Mail
https://mail.google.com/mail/u/0/?tab=rm&ogbl#label/2023+Triennial+Review+Comment/FMfcgzGwJJTfMmqDDJjhwZnVgsnsvxfq 2/2
contaminaon should always be used, not the least sensive. With regard to the Provo River Shed and this rare
aquifer, such an approach is essenal.
Thank you very much for this opportunity to respond on this important subject.
Sincerely,
Daniel L. Simmons, Ph.D.

OreoHelix Ecological “Dedicated to Evalua4ng and Protec4ng the World’s Ecological Health, Integrity, and Well Being…. One Snail
at a Time”

Date: November 29, 2023

To: Utah Division Water Quality
P. O. Box 144870,
Salt Lake City, UT
Attn: Jake Vander Laan

From: David C. Richards, Ph.D.
OreoHelix Ecological, Vineyard UT 84059
Phone: [phone]
Email: [e-mail]

Regarding: DWQ 2023 Triennial Review
Water Quality Standards Priorities
Public Comment

Comments:

Item 1. EPA 2013 Ammonia Criteria

Utah Division of Water Quality (UDWQ) developed ammonia criteria and regulations based on EPA’s
outdated 2013 criteria. As UDWQ states, these ammonia criteria values were based on toxicity test results
using sensitive mussels from SE USA, not the two mussel taxa that occur in Utah (Table 1). These
stringent UDWQ ammonia criteria resulted in many wastewater treatment facilities contracting mollusk
experts to survey for presence/absence of mussels over large areas of Utah at substantial monetary cost
and time expenditure. Criteria also raised concerns and contributed to upgrade planning of facilities to
meet ammonia criteria, increasing monetary and time expenditures.

UDWQ then conducted recalculation of ammonia criteria based on toxicity tests conducted on mussel
taxa that occur in Utah, specifically Anodonta californiensis/nutalliana (Table 1) (CVCWA 2020). The
CVCWA (2020) toxicity test showed that A. californiensis/nutalliana was much less sensitive to ammonia
than mussel taxa from SE USA and values used by EPA 2013 and UTDWQ (Table 1) and that A.
californiensis/nutalliana was 164% less sensitive to ammonia than another Anodonta sp. within the same
genus.

Table 1. UDWQ Triennial Review 2023. EPA 2013 Ammonia Criteria.
EPA 2013
Ammonia
Criteria
The 2013 EPA criteria are more stringent than Utah's
current criteria if unionid mussels are present. Utah has 2
unionid species, but toxicity tests weren't available for
these specific species when EPA updated the criteria.
Testing was recently conducted for these 2 species in
California. Recalculating the 2013 EPA criteria using the
California toxicity data results in unionids- present
criteria for Utah that are similar to Utah's existing criteria.
Update implementation guidance,
request cost analysis from
affected facilities, propose criteria
to the Water Quality Board, adopt
and submit for EPA approval.

OreoHelix Ecological “Dedicated to Evalua4ng and Protec4ng the World’s Ecological Health, Integrity, and Well Being…. One Snail
at a Time”
EPA bases its Recalculation Procedure on “The underlying premise …. that taxonomy1 has value in
predicting sensitivity” (USEPA 2013a). EPA also based its entire Aquatic life ambient water quality
criteria for ammonia – freshwater 2013 document on this premise (USEPA 2013b).
By 2017, UDWQ was well aware that taxonomy was not often consistent with phylogeny, and that neither
were good predictors of sensitivity to toxicants, including ammonia (e.g., Richards 2016) and in a final
report UDWQ (2017) stated that:
“First, taxonomic relationships may not be consistent with phylogenetic relationships, and
both are frequently modified based on new genetic or other information.”
“Third, and perhaps most importantly, phylogenetic similarity may not predict toxicological
similarity (Blomberg et al. 2003; Losos 2008). The probability of toxicological similarity is
presumably greatest when taxa are identical at the species or genus level due to shared life-history,
morphological, or physiological traits (USEPA 2013a, b). However, traits related to toxicological
susceptibility may evolve at rates not reflected in overall phylogenetic (or taxonomic) similarity.”
As the CVCWA (2020) report illustrates, EPA recalculation procedures are highly complex and subject to
potentially erroneous and unrepresentative values. For example, if a species occurs in a water body and
has not been tested for a toxicant then values from a surrogate species that has been tested are used, in
some instances even if that surrogate species is far removed taxonomically and phylogenetically. This is
contrary to what UDWQ has knowledge of (see preceding paragraphs). Application of unrealistic
recalculated criteria values by UDWQ can subsequently elicit costly wastewater facility upgrades and
increased consulting costs.
Item 2. Great Salt Lake: Farmington and Bear River Bays
The additional biological surveys that UDWQ has for Farmington Bay (FB) and Bear River Bay (BRB)
have macroinvertebrate data that only taxonomically identify to genus level or subfamily level but no
species level taxonomy (Armstrong and Wurtsbaugh 2019). This level of taxonomy will have the same
effects on recalculation as did for ammonia, i.e., toxicity criteria not representative of the taxa that occur
in FB and BRB (see Item 1). The same problem will result if the macroinvertebrate species that UDWQ
has in its database for FB or BRB have not been tested for the four toxicants listed in Table 2. Criteria
values from surrogate species that have been tested will need to be used, in some instances even if those
surrogate species are far removed taxonomically and phylogenetically. After reviewing the taxa list for FB
and BRB, I assume there will be a substantial number of taxa that have not been evaluated for these
toxicants. Again, this is contrary to what UDWQ has knowledge of (see preceding paragraphs).
Application of unrealistic recalculated criteria values by UDWQ for FB and BRB can subsequently elicit
costly wastewater facility upgrades and increased consulting costs.
Table 2. UDWQ Triennial Review 2023. Great Salt Lake: Farmington and Bear River Bays.
Great Salt Lake:
Farmington and
Bear River Bays
Additional biological surveys have been conducted in Farmington
and Bear River Bays of Great Salt Lake (GSL), filling data gaps
identified in the GSL Aquatic Life Use survey. Recently updated
Update the GSL
Strategy. Pilot the
species deletion
1 EPA slightly confuses taxonomy with phylogeny. Taxonomy is typically defined as the science or technique of classification,
whereas phylogeny is typically defined as the development or evolution of a particular group of organisms.
OreoHelix Ecological “Dedicated to Evalua4ng and Protec4ng the World’s Ecological Health, Integrity, and Well Being…. One Snail
at a Time”

recommended criteria for aluminum, ammonia, selenium, and
copper provide appropriate species toxicity information for a
recalculation procedure. Combined, these factors provide a
potential pathway for adopting recalculated criteria for Farmington
and Bear River Bays.
procedure for 4
criteria.

Recommendation
Given the likely inaccuracies in recalculation procedures that I have outlined in this letter, I recommend
that UDWQ carefully evaluates any recalculation given these concerns. UDWQ should generate error
rates (e.g., confidence intervals) for recalculation if species found in FB and BRB are not same as those
that have toxicity values but do not occur in these ecosystems using appropriate resampling (e.g.,
bootstrap, jackknife) or other statistical methods. In addition, recent research suggests that species traits
including three major trait categories, external exposure, intrinsic sensitivity, and population sustainability
may be more useful for ecotoxicological evaluations (Liang et al. 2024, Rubach et. al. 2011).
Unrealistically low criteria values based on EPA recalculation procedure could have large economic costs,
particularly for wastewater treatment facilities; unrealistically high criteria values could result in under
protection of our cherished water bodies in Utah, including Farmington Bay and Bear River Bay.

Literature Cited

Armstrong, T. and W. A. Wurstbaugh. 2019. Impacts of Eutrophication on Benthic Invertebrates & Fish
Prey of Birds in Farmington and Bear River Bays of Great Salt Lake. Final Report to the Utah
Division of Forestry, Fire & State Lands.

CVCWA (Central Valley Clean Water Association). 2020. Phase IIc Freshwater Mussel Collaborative
Study for Wastewater Treatment Plants: Ammonia Criteria Recalculation Final Report. Pacific
EcoRisk etc.

Liang, R. et. al. 2024. Spatial variation in the sensitivity of freshwater macroinvertebrate assemblages to
chemical stressors. Water Research. 248, 120854.

Richards, D. C. 2016. Does Phylogeny Predict Sensitivity to Ammonia in Freshwater Animals using
USEPA Ammonia Criteria Data? Technical Memo. OreoHelix Consulting, Moab, UT. Prepared
for: Jordan River/Farmington Bay Water Quality Council. Salt Lake City, UT. 34 pages.

Rubach, M.N. et.al. 2011. A framework for traits-based assessment in ecotoxicology. Integrated
Environmental Assessment and Management. 7(2):172-86.

Utah DWQ. 2017. Utah and Colorado Water Surveys for Mussels and Snails. Final Report.

USEPA 2013a. Revised deletion process for the site-specific recalculation procedure for aquatic life
criteria. EPA-823-R-13-001.
USEPA. 2013b. Aquatic life ambient water quality criteria for ammonia-freshwater. EPA 822-R-13-001

Appendix 4.2023 Triennial Review Public
Hearing Summary -Dec 14,2023
A public hearing to accept comments on Utah’s water quality standards and recommended
changes was held at 6:00 PM on December 14,2023,hosted at the Multi Agency State Office
Building in Salt Lake City with virtual access provided.
A member of Utah’s Water Quality Board,Joe Havasi,served as the hearing officer.Mr.
Havasi opened the hearing by providing background information regarding the purpose of
the hearing and the Triennial Review.The hearing was then open for comments for one
hour.George Parrish,EPA Region 8,conrmed receipt of EPA’s written comments and
provided a summary of the comments submitted.EPA’s written comments are available in
Appendix 3 and DWQ has responded to the written comments.Lisa Kirschner asked a
question about publication of the comments received for the 2023 Triennial Review.DWQ
explained that comments and draft responses will be shared and discussed with Utah’s
Water Quality Standards Workgroup and Water Quality Board,and that nal responses will
be published on DWQ’s website in a 2023 Triennial Review Report.Mr.Havasi asked a
question about the Great Salt Lake:Gilbert Bay standards priority.Ben Holcomb explained
that the current goal is to summarize and report on the results of past brine shrimp and
brine y toxicity testing and update DWQ’s Great Salt Lake strategy.
Mr.Havasi closed the meeting at 7:00 PM.DWQ did not receive additional formal comments
during the hearing.A recording of the hearing is available on request.
Appendix 5.2023 Triennial Review Water
Quality Standards Priority List
Standards Issue Background Goal
EPA 2001
Methylmercury
Criteria
The methylmercury fish tissue criteria should be
added to Table 2.14.6.Adding the fish tissue
criterion will primarily affect assessments and
assessment methods need to be updated to
address implementation.Waters with current fish
consumption advisories will likely be identified as
impaired.
Propose revised standards to the
Water Quality Board,adopt and
submit for EPA approval.
EPA 2013
Ammonia Criteria
The 2013 EPA criteria are more stringent than
Utah's current criteria if unionid mussels are
present.Utah has 2 unionid species but toxicity
tests weren't available for these specific species
when EPA updated the criteria.Testing was
recently conducted for these 2 species in
California.Recalculating the 2013 EPA criteria
using the California toxicity data results in
unionids-present criteria for Utah that are similar
to Utah's existing criteria.
Update implementation
guidance,request cost analysis
from affected facilities,propose
criteria to the Water Quality
Board,adopt and submit for EPA
approval.
EPA 2019
Cyanotoxins:
microcystin &
cylindrospermopsin
Recommended criteria should be adopted for
recreational uses in table 2.14.1.The
recommended criteria are consistent with
cyanotoxin concentrations used in recreational
health advisories and WQ assessment methods.
Develop guidance document,
propose revised standards to the
Water Quality Board,adopt and
submit for EPA approval.
EPA 2016
Selenium Criteria
The 2016 EPA criteria is hierarchical with the fish
tissue criteria superseding water column criteria.
The water criteria are more stringent than Utah's
current criteria and selenium is common in Utah
surface and waste waters.More stringent
selenium criteria will impact existing discharge
permits that may require changes to treatment
processes.Idaho recently applied the species
deletion procedure to EPA's criteria resulting in
less stringent criteria.This process may be
appropriate to apply to Utah.
Prepare implementation
guidance that compiles existing
data,includes recommendations
for developing site-specific
translators,and a schedule for
adoption.
2023 Colorado
River Salinity
Standards update
In UAC R317-2-4,Utah WQ standards reference
the WQ standards—numeric criteria and
implementation plans—across seven coordinating
states to reduce salinity in the Colorado Basin.
The latest version of these
criteria and plans were updated
in 2023.Utah will update our
standards to acknowledge the
latest version.
Utah Lake Nutrient
Criteria
The Utah Lake Nutrient criteria are being
developed as part of a multi-year effort with a
steering committee and science panel.
Continue studies to support
development of numeric nutrient
criteria.
Great Salt Lake:
Farmington and
Bear River Bays
Additional biological surveys have been
conducted in Farmington and Bear River Bays of
Great Salt Lake,filling data gaps identified in the
GSL Aquatic Life Use survey.Recently updated
recommended criteria for aluminum,ammonia,
selenium,and copper provide appropriate species
toxicity information for a recalculation procedure.
Combined,these factors provide a potential
pathway for adopting recalculated criteria for
Farmington and Bear River Bays.
Update the Great Salt Lake
Strategy.Pilot the species
deletion procedure for 4 criteria.
Great Salt Lake:
Gilbert Bay
Chronic and acute toxicity tests have been
conducted for brine shrimp and brine flies for
arsenic,copper,lead,and zinc.
Summarize toxicity test results
and determine next steps.
Update the Great Salt Lake
Strategy.
EPA 2021 Lakes &
Reservoirs Nutrient
Criteria
Pilot model application to selected lakes and
reservoirs.Current candidates are Willard Bay
Reservoir,Mantua Reservoir,and Deer Creek
Reservoir.These would help evaluate existing
endpoints,potential point sources,and potential
criteria endpoints.
Perform pilot analyses.
Appendix6.EPAsubmialleer
195 North 1950 West • Salt Lake City, UT Mailing Address: PO Box 144870 • Salt Lake City, UT 84114-4870 Telephone [phone] • Fax [phone] • TDD [phone]
www.deq.utah.gov Printed on 100% recycled paper
State of Utah

Department of Environmental Quality
Kimberly D. Shelley Executive Director
DIVISION OF WATER QUALITY John K. Mackey, P.E. Director
Water Quality Board James Webb, Chair Michelle Kaufusi, Vice Chair Carly Castle Michela Harris Joseph Havasi Trevor Heaton Robert Fehr Jill Jones Kimberly D. Shelley John K. Mackey Executive Secretary
SPENCER J. COX Governor
DEIDRE HENDERSON Lieutenant Governor
July 2nd, 2024
VIA EMAIL READ RECEIPT REQUSTED
KC Becker, Regional Administrator
US Environmental Protection Agency Region VIII 1595 Wynkoop Street Denver, Colorado 8202-1129
Subject: Submittal of Utah’s 2023 Triennial Review of water quality standards
Dear Administrator Becker:
The Utah Division of Water Quality (DWQ) has completed the 2023 Triennial Review of Utah’s
water quality standards. DWQ has performed a comprehensive review of all of Utah’s water quality policies and criteria, including a comparison of the state’s water quality standards to nationally recommended standards, to identify and prioritize needed additions and updates. DWQ also sought input through a collaborative engagement process with stakeholders, state and federal
agencies, and the public to identify any recommended changes to Utah’s water quality standards.
DWQ’s 2023 Triennial Review identifies short-term goals for water quality standards changes expected before the 2026 Triennial Review, interim goals to support future water quality standards changes, and long-term priorities.
DWQ has reviewed all criteria recommendations. Though the review identifies and prioritizes
future standards changes, no new or updated standards are proposed for immediate adoption as
part of the 2023 Triennial Review. No new data or information were identified that would require revisions to currently designated beneficial uses or existing site-specific standards. No new information regarding Tribal reserved rights was asserted that would require updates to water quality standards. The Environmental Protection Agency has published new criteria for nutrients
in lakes and reservoirs since DWQ’s 2020 Triennial Review. State adoption of these criteria will
require substantial technical and administrative work, including data collection, statistical analysis, and public and stakeholder outreach. As part of the 2023 Triennial Review, DWQ has prioritized initial technical work to support future adoption of these or other defensible criteria, but is not currently proposing them for adoption.
Page 2
A report describing the results of Utah’s 2023 Triennial Review is attached. The document
includes a summary of the process and findings from the review, comments received and DWQ’s responses, information regarding DWQ’s public engagement including public notices, postcards, and a public hearing summary, and DWQ’s updated water quality standards priority list.
All materials for the 2023 Triennial Review have been reviewed by Utah’s Water Quality
Standards Workgroup and presented to the Utah Water Quality Board.
If you have any questions or require additional information, please contact Jake Vander Laan at (801)-536-4350 or [e-mail].
Sincerely,
John K. Mackey, P.E.
Director
Utah Division of Water Quality
JV:cl
Enclosures: 2023 Triennial Review Report (DWQ-2024-004393) 2023 Triennial Review Appendices Combined (DWQ-2024-004394)
Cc: Via email George Parrish, EPA R8 Water Quality Standards Unit
DWQ-2024-004396
Appendix 7.EPA Response to 2023 Triennial
Review Submission
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
Jacob Vanderlaan <[e-mail]>
RE: Utah DWQ 2023 Water Quality Standards Triennial Review
Parrish, George <[e-mail]>Thu, Aug 8, 2024 at 11:55 AM
To: John Mackey <[e-mail]>
Cc: Jacob Vanderlaan <[e-mail]>, "[e-mail]" <[e-mail]>, "DeJong, Stephanie"
<[e-mail]>
Dear Mr. Mackey:

This email acknowledges the U.S. Environmental Protection Agency Region 8 (EPA) receipt of your July 2, 2024 email
transmitting a letter of completion of the State of Utah’s triennial review of water quality standards. Your email included
supporting materials documenting the State of Utah’s public notice, hearing and comment opportunity for revisions to
water quality standards, as well as comments received and a response to comments. EPA acknowledges that the Utah
Water Quality Board made no revisions to R317-2 Standards of Quality for Waters of the State as a result of the triennial
review. However, the results of the triennial review were used to update the State’s list of proposed and upcoming water
quality standards revisions (submittal Appendix 5: 2023 Triennial Review Water Quality Standards Priority List).

Thank you for addressing this important requirement for water quality standards review pursuant to 40 C.F.R. 131.20. EPA
looks forward to working closely with you and your staff on future proposed revisions to Utah’s water quality standards.
Please have your staff contact me with any questions or further needs.

George Parrish, Environmental Scientist
U.S. EPA Region 8, Water Quality Section
1595 Wynkoop St., 8WD-CWB-WQ, Denver, CO 80202-1129
[e-mail] / ph. 303-312-7027

From: Cambria Linville <[e-mail]>
Sent: Tuesday, July 2, 2024 11:12 AM
To: Becker, KC <[e-mail]>
Cc: Jacob Vanderlaan <[e-mail]>; Parrish, George <[e-mail]>
Subject: C&E Emails

Hello-

Please review the attached documents in regards to the above referenced 2023 Triennial Review

Certified mail was also sent to the address(es) below:

TRACKING #: 9589071052700688623901
KC Becker, Regional Administrator US Environmental Protection Agency Region VIII 1595 Wynkoop Street Denver,
Colorado 8202-1129

If you have any questions, please contact Jake Vander Laan at (801)-536-4350 or [e-mail].

Thank you,

--
Cambria Linville
Office Specialist | Division of Water Quality
P: [phone]
F: [phone]
waterquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.