DWQ-2024-000553

M E M O R A N D U M
TO:Lonnie Shull III, UPDES Permit Writer
FROM:Suzan Tahir, Waste Load Analyst
Jacob Vanderlaan, Standards Coordinator
DATE:January 26, 2024
SUBJECT:Preliminary Wasteload and Antidegradation Review for Waterleaf Resources
Great Salt Lake Lithium Project
UPDES Permit UT0026280
RECEIVING WATERS AND STREAM CLASSIFICATION
At current and anticipated Lake elevations for the duration of the temporary demonstration plant, the discharge is to the Transitional Waters of Great Salt Lake (GSL) and then to Gunnison
Bay, Great Salt Lake. According to the Utah Administrative Code (UAC) R317-2-13, and the interim permitting program for GSL discharges (Interim permitting program for GSL discharges),where
effluent pollutant concentrations are screened against Class 3D aquatic life numeric criteria, the beneficial uses are:
Class 3D: Protected for waterfowl, shore birds and other water-oriented wildlife not included in Classes 3A, 3B, or 3C, including the necessary aquatic organisms in their food chain.
Class 5E: Transitional Waters of Great Salt Lake. Protected for infrequent primary and secondary contact recreation, waterfowl, shore birds and other water-oriented wildlife including
their necessary food chain
Class 5B: Gunnison Bay of the Great Salt Lake. Protected for infrequent primary and secondary contact recreation, waterfowl, shore birds and other water-oriented wildlife including
their necessary food chain.
BASIS FOR EFFLUENT LIMITATIONS
Water quality-based effluent limits are usually based on maintaining numeric water quality criteria as determined by a Waste Load Analysis. This approach cannot fully be implemented
for the proposed new discharge, Waterleaf Resources, as there is only one numeric water quality criterion for the GSL (selenium).
As a result, a preliminary wasteload was conducted in accordance with the interim permitting program for GSL discharges (Interim permitting program for GSL discharges) where effluent
pollutant concentrations were screened against Class 3D aquatic life numeric criteria (Interim permitting program for GSL discharges, Step 2) to ensure protection of the uses in accordance
with the Narrative Standards. No dilution was assumed for this proposed new discharge.
The hardness of the receiving water and effluent were greater than 40,000 mg CaCO3/L, therefore the dissolved metals water quality criteria were adjusted for hardness up to 400 mg/l
CaCO3 as shown in R317-2-14 (UAC R317-2).
PARAMETERS OF CONCERN (POCs)
At its current status, H.B. 513, requires the characterization of the physical, chemical, biological, thermal, and other pertinent properties of the discharge; at a minimum: pH, total
alkalinity, total dissolved solids (TDS), total suspended solids (TSS), sulfate, nitrate, nitrite, carbonate, bicarbonate, chloride, hydroxide, chemical oxygen demand (COD), biological
oxygen demand (BOD5), silica, zinc, magnesium, sodium, calcium, potassium, boron, bromine, aluminum, iron, silicon, temperatures ranges expected in effluent and density range of effluent
to be discharged.New dischargers also shall disclose the quantity of any foreign materials that would be discharged to the GSL on an annual basis.
MIXING ZONE
The Division of Water Quality will not grant a mixing zone, based on the assumption that the effluent from Waterleaf Resources may not always reach the open waters of GSL.
ANTIDEGRADATION LEVEL II REVIEW
An Antidegradation Level II review is required because the facility is a new discharge and there is uncertainty if this discharge will cause changes in water quality.
SCREENING FOR CLASS 3D AQUATIC LIFE NUMERIC CRITERIA
Waterleaf Resources shall monitor and screen pollutant concentration levels against the following water quality based effluent limits; Water Quality Based Effluent Limits ParameterAquatic
Life, 3BAquatic Life, 3DUnitpH6.5-9.06.5-9.0Turbidity Increase, NTU1015NTUMaximum Temperature27N/AoCMaximum Temperature change4N/AoCDissolved Oxygen 30 Day Average5.55.0(mg/L)7 Day Average6.0/4.0*NA(mg/L)Minimum5.0/3.0*3.0(mg/L)Ammonia,
Varies Acute12.7812.78(mg/L)Chronic1.971.97(mg/L)Total Residual Chlorine Acute0.0190.019(mg/L)Chronic0.0110.011(mg/L)*First number in column is for when early life stages are present,
second number is for when allother life stages present.Dissolved Metals (Based on Hardness = 400 mg CaCO3/L)ParameterAquatic Life, 3BAquatic Life, 3DUnitAluminum Acute (1 Hour Average)750750ug/LChronic
(30 Day Average)8787ug/LArsenic Acute (1 Hour Average)340340ug/LChronic (30 Day Average)150150ug/LCadmium Acute (1 Hour Average)1.81.8ug/LChronic (30 Day Average)0.720.72ug/LChromium
(VI)Acute (1 Hour Average)1616ug/LChronic (30 Day Average)1111ug/LChromium (III)Acute (1 Hour Average)570570ug/LChronic (30 Day Average)7474ug/LCopperAcute (1 Hour Average)1313ug/LChronic
(30 Day Average)99ug/L
FURTHER EVALUATION
The source of the effluent data and parameters was the permit application. Pollutants that required further evaluation are discussed in the following section. Ammonia
Ammonia criteria are more stringent when early life stages of fish may be present. Early life stages of fish are not considered for this preliminary wasteload because of the lack of
specific data regarding the potential fish species present in the immediate receiving waters.
Consistent with Utah Wasteload Allocation procedures, acute limits were based on the maximum observed pH and temperature of the effluent [note: ammonia limits are very sensitive to
pH and to a lesser extent temperature]. Chronic limits are based on the average pH and temperature of the effluent. The acute and chronic effluent ammonia concentrations reported in
the wasteload are 12.78 and 1.9 mg/L, respectively. Effluent temperature will be added as a monitoring requirement.
Selenium
Based on the permit application, the maximum potential effluent concentration is <0.050 mg/L, which exceeds the criterion 0.0184 mg/L. Selenium is concluded to not have reasonable potential
because the presence of fish in the immediate receiving waters is uncertain.
Total Residual Chlorine
Total residual chlorine is challenging to measure accurately and the available analytical methods have insufficient sensitivity. If the proposed discharge contains a total residual chlorine
(>0.20 mg/L) it may interfere with WET testing. A monitoring requirement for total residual chlorine can be added as a monitoring requirement.
In the future, additional parameters may become apparent as a result of reasonable potential analysis, technology-based standards, or other factors as determined by the UPDES Permit
Writer.
WHOLE EFFLUENT TOXICITY (WET) TESTING
The permittee is a minor industrial facility that will be discharging ana limited amount of effluent, in which toxicity is neither an existing concern, nor likely to be present. Additionally,

the intake water and discharge are expected to be so saline that no freshwater or marine species approved for Whole Effluent Toxicity testing would be expected survived. This outcome
would not give valid WET tests results. AlsoAlso, the facility will only be allowed to discharge wastewater pollutants that are present in the intake water. Therefore, based on these
considerations, and the absence of receiving water quality monitoring data, there is no reasonable potential for toxicity in the permittee’s discharge (per State of Utah Permitting and
Enforcement Guidance Document for WET Control). As such, there will be no numerical WET limitations or WET monitoring requirements in this permit. However, the permit will contain
a toxicity limitation re-opener provision that allows for modification of the permit should additional information indicate the presence of toxicity in the discharge.