DWQ-2025-004504

Official Draft Public Notice Version Month Day, year
The findings, determinations, and assertions contained in this document are not final and subject to change following the public comment period.
FACT SHEET
CASTLE VALLEY SPECIAL SERVICE DISTRICT
FERRON LAGOONS
RENEWAL PERMIT: DISCHARGE
UPDES PERMIT NUMBER: UT0020052
MINOR MUNICIPAL
FACILITY CONTACTSOperator Name:Castle Valley Special Service DistrictContact:Jacob Sharp, P.E. Position: District ManagerPhone Number:[phone]Permittee Name:Castle Valley Special
Service DistrictFacility Name:Ferron LagoonsMailing Address:Castle Valley Special Service District
P.O. Box 877
20 South 100 East,
Castle Dale, Utah 84513Telephone:[phone]Actual Address:~5 miles east along 500 South Street off Hwy 10 in Emery County
DESCRIPTION OF FACILITY
The City of Ferron and the Castle Valley Special Service District (CVSSD) constructed a new lagoonsystem in 2005 to handle domestic sewage for the City of Ferron. The Ferron Lagoons
system is locatedapproximately 2.25 miles east of the City of Ferron off Highway 10 in Emery County, Utah. The FerronLagoons consists of four cells totaling 33 acres in area with a chlorination
pond for disinfection and alsoprovides for the addition of a future cell if needed. To date there has been no discharge from this facilityand none are anticipated for at least the next
five years. The Ferron Lagoons have a design flow of 0.5million gallons per day (MGD) with a single discharge point of Outfall 001, which is located at northlatitude of 39° 04’ 43.75”
and west longitude of 111° 03’ 42.61”.
For the renewal in 2018, a new model was used by Water Quality to develop a waste load allocation (WLA)for dischargers to Waters of the State. Also, there has been more data gathered
on the receiving stream anddischarge since the permit was first issued. This resulted in changes to the possible water quality basedeffluent limits (WQBEL) from the WLA. As a result
of the new WLA, the ammonia limits have increasedand the total residual chlorine(TRC) has decreased. The increase in the acute ammonia limits is due to the pH used to calculate thecriteria.
In the previous permit, due to a lack of data in the receiving water, the maximum pH for eachseason was used. For this permit, with the additional data for the receiving water, the 80th
percentile of thepH for each season was used per standard procedure. There is no proposed change in operation of the FerronLagoons, and there has not been a discharge from the Ferron
Lagoon system to establish the loadingconditions.
TBPEL Rule
Water Quality adopted UAC R317-1-3.3, Technology-Based Phosphorus Effluent Limit (TBPEL) Rule onDecember 16, 2014. No TBPEL will be instituted for discharging treatment lagoons. Instead,
eachdischarging lagoon was evaluated to determine the current annual average total phosphorus load measuredin pounds per year based on monthly average flow rates and concentrations.
Absent field data to determinethese loads, and in case of intermittent discharging lagoons, the phosphorus load cap will be estimated bythe Director
A cap of 125% of the current annual total phosphorus load is to be established and is referred to as the phosphorus loading cap. It is the intent of UAC R317-3.3.B to provide capacity
for growth within the facility’s service area by setting the loading cap at 125 percent of the current annual total phosphorus load. The phosphorus loading cap went into effect July
1, 2018. A discharge from the Ferron Lagoons has not occurred during the time frame that the loading cap would be developed. As a result, no cap could beimplemented. To address this,
when a discharge does become consistent and data can be obtained, the loading cap will be calculated and implemented. Currently, there is no estimate on when this might happen. Once
the lagoon's phosphorus loading cap has been reached, the owner of the facility will have five years to construct treatment processes or implement treatment alternatives to prevent the
total phosphorus loading cap from being exceeded.
SUMMARY OF CHANGES FROM PREVIOUS PERMIT
Monitoring Frequency Changes
Division of Water Quality (DWQ) updated theMonitoring Frequency Guidance Document used in determining the minimum monitoring frequency for Permit Compliance. Due to this, some monitoring
frequency was changed to match the guidance. Specifically, Flow monitoring has been changed to Monthly and a Grab sample. Previously the flow monitoring was continuous, and by a recorder.
The flow monitoring at the lagoons has been by a Siemens OCM III, which is manual read, and has never had a data recorder attached. This change will make the requirements of the permit
consistent with our guidance and the capabilities of the lagoons.
Total Dissolved Solids (TDS)
The TDS limits are being changed to be more consistent with the guidance and other UPDES Permits subject to Colorado River Basin Salinity Control Forum (CRBSCF) requirements. The loading
limit was indicated as 1 ton/day as a maximum, but the requirement is that over the year the average should not be greater than 1 ton/day. Also, the annual loading cap of 366 tons is
being added to the permit as a limit.
DISCHARGE
DESCRIPTION OF DISCHARGE
Ferron Lagoons has been reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis. Ferron Lagoons have not discharged since they were first completed and permitted.OutfallDescription
of Discharge Point
001 Located at latitude 3904'43.75" and longitude 11113'42.61"from the final cell through a sand filter to the Ferron Creek.RECEIVING WATERS AND STREAM CLASSIFICATION
If a discharge were to occur, it would be to Ferron Creek, which is a Class 2B, 3C, 4 according to UAC R317-2-13:
Class 2B -- Protected for infrequent primary contact recreation. Also protected for secondary contact recreation where there is a low likelihood of ingestion of water or a low degree
of bodily contact with the water. Examples include, but are not limited to, wading, hunting, and fishing.
Class 3C -- Protected for nongame fish and other aquatic life, including the necessary aquatic organisms in their food chain.
Class 4 -- Protected for agricultural uses including irrigation of crops and stock watering.
TOTAL MAXIMUM DAILY LOAD (TMDL) REQUIREMENTS According to the 303(d) list in Utah’s 2024 Integrated Report, the receiving water body for the discharge, Ferron Creek Lower (Ferron Creek
and tributaries from confluence with San Rafael River to Millsite Reservoir, UT14060009-012_00 supports all designated uses.
SITE SPECIFIC TOTAL DISSOLVED SOLIDS CRITERION
Per UAC R317-2-14, Ferron Creek has a site-specific criterion for TDS concentration of 3,500 mg/L that is based upon the EPA approved TMDL “Price River, San Rafael River, and Muddy Creek
TMDLs for Total Dissolved Solids, West Colorado Watershed Management Unit, Utah” (MFG Inc. 2004).

BASIS FOR EFFLUENT LIMITATIONS
Limitations on total suspended solids (TSS), biochemical oxygen demand (BOD5), E. coli, pH and percent removal for BOD5 and TSS are based on current Utah Secondary Treatment Standards,
UAC R317-1-3.2. The alternative effluent limits and percent removal requirements for TSS and BOD5 were previously requested by CVSSD and subsequently granted by the Utah Water Quality
Board in 2001 and remains unchanged. Ammonia as Nitrogen (NH3-N), total residual chlorine (TRC), and dissolved oxygen (DO),are water quality based, and were derived by the waste load
analysis attached to this fact sheet statement ofbasis. Flow limitations were developed from information included in the permit application.
The TDS concentration limit of 3500 mg/L is based upon the approved TMDL study for the San Rafael River watershed (which includes Cottonwood Creek), in which a site-specific criterion
was developed for TDS and can be found in Table A-12 of the document entitled, “Price River, San Rafael River, and Muddy Creek TMDLs for Total Dissolved Solids, West Colorado Watershed
Management Unit, Utah” (MFG Inc., 2004).
The TDS mass loading limitations are based upon the Colorado River Basin Salinity Control Forum (CRBSCF) Policy for mass loading values when applicable as authorized in UAC R317-2-4.
CRBSCF has established a Policy for the reasonable increase of salinity for municipal discharges to any portion of the Colorado River stream system that has an impact on the lower main
stem. The CRBSCF Policy entitled “NPDES Permit Program Policy for Implementation of Colorado River Salinity Standards” (Policy), with the most current version dated October 2023, states
that the incremental increase in salinity shall be 400 mg/L or less, which is considered to be a reasonable incremental increase above the flow weighted average salinity of the intake
water supply, unless a demonstration is made and upon request for an alternative requirement. The permittee previously requested an alternative salt loading (TDS) of 1 ton/day average,
or 366 tons/year in lieu of the requirement that the effluent not exceeding the culinary source water intake by more than 400 mg/L of TDS, which is in allowable under CRBSCF Policy and
is consistent with other similar permits in Utah.
Attached is a Wasteload Analysis for this discharge into Ferron Creek. It has been determined that this discharge will not cause a violation of water quality standards. An Antidegradation
Level II review is not required since the Level I review shows that water quality impacts are minimal. The permittee is expected to be able to comply with these limitations.
Reasonable Potential Analysis
Since January 1, 2016, DWQ has conducted reasonable potential analysis (RP) on all new and renewal applications received after that date. RP for this permit renewal was conducted following
DWQ’s September 10, 2015 Reasonable Potential Analysis Guidance (RP Guidance). There are four outcomes defined in the RP Guidance: Outcome A, B, C, or D. These Outcomes provide a frame
work for what routine monitoring or effluent limitations are required
A qualitative RP check was performed on the pollutants of concern to determine if there was enough data to perform a reasonable potential analysis on the outfall. The Ferron Lagoons
did not discharge during the term of the expiring permit and as a result no monitoring results were submitted. This results in no changes to the monitoring requirements in the permit.
A copy of the RP analysis is included at the end of this Fact Sheet.
The permit limitations are:
Parameter
Effluent Limitations 1
Maximum Monthly Avg
Maximum Weekly Avg
Yearly
Average
Daily Minimum
Daily Maximum
Total Flow, MGD
0.5
-
-
-
-
BOD5, mg/L
BOD5 Min. % Removal
45
65
65
-
-
-
-
-
-
-
TSS, mg/L
TSS Min. % Removal
45
65
65
-
-
-
-

-
-
-
Dissolved Oxygen, mg/L
-
-
-
5.0
-
Total Ammonia (as N), mg/L
Summer (Jul-Sep)
Fall (Oct-Dec)
Winter (Jan-Mar)
Spring (Apr-Jun)
4.6
8.9
11.3
3.9
-
-
-
-
-
-
-
-
-
-
-
-
14.5
14.0
14.2
6.1
TDS, mg/L
-
-
-
-
3500
TRC, mg/L2
-
-
-
-
0.033
E. coli, No./100mL
126
157
-
-
-
pH, Standard Units
-
-
-
6.5
9
Mass Loading Limits
Parameter

Annual Avg. Daily
Maximum Monthly Avg
Annual Max
TDS, Ton/Day3
Tons/Year
1
-
Report
-
-
366
-
-
-
-
See Definitions, Part VIII, for definition of terms.
Analytical results less than 0.06 mg/l will not be considered out of compliance with the permit. For purposes of calculating averages and reporting on the Discharge Monitoring Report
form, the following will apply:
Analytical values less than 0.02 mg/L shall be considered zero; and
Analytical values less than 0.06 mg/L and equal to or greater than 0.02 mg/L will be recorded as measured.
The salt loading (TDS) limit is 1 ton/day, or 366 tons/year in lieu of the requirement that the effluent not exceeding the culinary source water intake by more than 400 mg/L of TDS.
SELF-MONITORING AND REPORTING REQUIREMENTSThe following self-monitoring requirements have been modified to be consistent with the updated Monitoring and Sampling Frequency Guidance Document,
as described above. The permit requires reports to be submitted monthly and annually, as applicable, on Discharge Monitoring Report (DMR) forms due 28 days after the end of the monitoring
period. Effective January 1, 2017, monitoring results shall be submitted using NetDMR unless the permittee has successfully petitioned for an exception. Lab sheets for biomonitoring,
metals and toxic organics shall be attached to the DMRs.
Self-Monitoring and Reporting Requirements 1
Parameter
Frequency
Sample Type
Units
Total Flow 4, 5
Monthly
Grab
MGD
BOD5, Influent 6
Effluent
Monthly
Monthly
Composite
Composite
mg/L
mg/L
TSS, Influent6
Effluent
Monthly
Monthly
Composite
Composite
mg/L
mg/L
E. coli
Monthly
Grab
No./100mL
pH
Monthly
Grab
SU
Total Ammonia (as N)
Monthly

Composite
mg/L
DO
Monthly
Grab
mg/L
TRC, mg/L, 7
Monthly
Grab
mg/L
TDS, mg/L
Monthly
Composite
mg/L
TDS, Average Daily Ton
Annually8
Composite
mg/L
TDS, Total Tons
Annually8
Composite
mg/L
Orthophosphate (as P),
Effluent
Monthly
Composite
mg/L
Total Phosphorus (as P),
Influent
Effluent
Monthly
Monthly
Composite
Composite
mg/L
mg/L
Total Kjeldahl Nitrogen
TKN (as N),
Influent
Effluent
Monthly
Monthly
Composite
Composite
mg/L
mg/L
Nitrate, NO3
Monthly
Composite
mg/L
Nitrite, NO2
Monthly
Composite
mg/L
See Definitions, Part VIII, for definition of terms.
Flow measurements of influent/effluent volume shall be made in such a manner that the permittee can affirmatively demonstrate that representative values are being obtained
If the rate of discharge is controlled, the rate and duration of discharge shall be reported
In addition to monitoring the final discharge, influent samples shall be taken and analyzed for this constituent at the same frequency as required for this constituent in the discharge
Total residual chlorine monitoring frequency is Daily, but only if the facility is chlorinating the effluent during monitoring period. If not chlorinating, a no data indicator (NODI)
code of 9 (Conditional Monitoring -Not Required This Period)

For clarification, annual and quarterly monitoring requirements and limits are based on the calendar year.
BIOSOLIDS
The State of Utah has adopted the 40 C.F.R. § 503 federal regulations for the disposal of sewage sludge (biosolids) by reference. However, since this facility is a lagoon, there is
not any regular sludge production. Therefore 40 C.F.R. § 503 shall not apply at this time. In the future, if the sludge needs to be removed from the lagoons and is disposed in some
way, the DWQ must be contacted prior to the removal of the sludge to ensure that all applicable state and federal regulations are met
STORM WATER
MSGP coverage is required for Treatment Works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used in the storage, treatment, recycling,
and reclamation of municipal or domestic sewage, including lands dedicated to the disposal of sewage sludge that are located within the confines of the facility, with a design flow of
1.0 million gallons per day (MGD) or more, or required to have an approved pretreatment program under 40 C.F.R. § Part 403.
Because the design flow is less than 1.0 MGD a storm water UPDES permit is not required. Therefore, storm water permit provisions have not been included with the permit renewal. However,
at any time during the lifetime of this permit it may be re-opened and modified, following proper administrative procedures as per UAC R317-8, to include any applicable storm water provisions
and requirements.
Information on storm water permit requirements can be found at http://stormwater.utah.gov
PRETREATMENT REQUIREMENTS
The permittee has not been designated for pretreatment program development because it does not meet conditions which necessitate a full program. The flow through the plant is less than
five (5) MGD, there are no categorical industries discharging to the treatment facility, industrial discharges comprise less than 1 percent of the flow through the treatment facility,
and there is no indication of pass through or interference with the operation of the treatment facility such as upsets or violations of the POTW's UPDES permit limits.
Although the permittee does not have to develop a State-approved pretreatment program, any wastewater discharges to the sanitary sewer are subject to Federal, State and local regulations.
Pursuant to section 307 of the Clean Water Act, the permittee shall comply with all applicable Federal General Pretreatment Regulations promulgated, found in 40 C.F.R. § 403 and the
State Pretreatment Requirements found in UAC R317-8-8.
An industrial waste survey (IWS) is required of the permittee as stated in Part II of the permit. The IWS is to assess the needs of the permittee regarding pretreatment assistance.
The IWS shall be submitted within sixty (60) days after the issuance of the permit. If an Industrial User begins to discharge or an existing Industrial User changes their discharge
the permittee shall resubmit an IWS no later than sixty days following the introduction or change as stated in Part II of the permit.
It is required that the permittee submit for review any local limits that are developed to the DWQ for review. If local limits are developed it is required that the permittee perform
an annual evaluation of the need to revise or develop technically based local limits for pollutants of concern, to implement the general and specific prohibitions 40 C.F.R. §, Part 403.5(a)
and Part 403.5(b). This evaluation may indicate that present local limits are sufficiently protective, may need to be revised, or should be developed.
BIOMONITORING REQUIREMENTS
A nationwide effort to control toxic discharges where effluent toxicity is an existing or potential concern is regulated in accordance with the Utah Pollutant Discharge Elimination System
Permit and Enforcement Guidance Document for Whole Effluent Toxicity Control (biomonitoring), dated February 2018. Authority to require effluent biomonitoring is provided in Permit
Conditions, UAC R317-8-4.2, Permit Provisions, UAC R317-8-5.3 and Water Quality Standards, UAC R317-2-5 and R317 -2-7.2.
The permittee is a minor municipal facility that will be discharging an infrequent amount of effluent, in which toxicity is neither an existing concern, nor likely to be present. Based
on these considerations, and the absence of receiving stream 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.
PERMIT DURATIONIt is recommended that this permit be effective for a duration of five (5) years.Drafted and Reviewed byDaniel Griffin, Discharge Permit Writer, Biosolids, Reasonable
Potential AnalysisJennifer Robinson, PretreatmentLonnie Shull, BiomonitoringJordan Bryant, Storm WaterAmy Dickey, TMDL/Watershed ProtectionSuzan Tahir, Wasteload Analysis/ADRUtah Division
of Water Quality, [phone]PUBLIC NOTICE INFORMATION (to be updated after)Began: Month Day, 2025Ended: Month Day, 2025Comments will be received at: 195 North 1950 West PO Box 144870
Salt Lake City, UT 84114-4870The Public Notice of the draft permit was published on State of Utah and/or DWQ’s website for at least 30 days as required.During the public notice and comment
period provided under UAC R317-8-6.5, any interested person may submit written comments on the draft permit and may request a public hearing, if no hearing has already been scheduled.
A request for a public hearing shall be in writing and shall state the nature of the issues proposed to be raised in the hearing. All comments will be considered in making the final
decision and shall be answered as provided in UAC R317-8-6.12.ADDENDUM TO FACT SHEETDuring finalization of the Permit certain dates, spelling edits and minor language corrections were
completed. Due to the nature of these changes, they are considered minorchanges and the permit is not required to be re Public Noticed as provided in UAC R317-8-5.6(3)Responsiveness
Summary(Explain any comments received and response sent. Actual letters can be referenced, but not required to be included).
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ATTACHMENT 1
Industrial Waste Survey
This Page Intentionally Left BlankIndustrial Pretreatment Wastewater SurveyDo you periodically experience any of the following treatment works problems:foam, floaties or unusual colorsplugged
collection lines caused by grease, sand, flour, etc.discharging excessive suspended solids, even in the wintersmells unusually badwaste treatment facility doesn’t seem to be treating
the waste rightPerhaps the solution to a problem like one of these may lie in investigating the types and amounts of wastewater entering the sewer system from industrial users.An industrial
user (IU) is defined as a non-domestic user discharging to the waste treatment facility which meets any of the following criteria: 1.has a lot of process wastewater (5% of the flow
at the waste treatment facility or more than 25,000 gallons per work day.)Examples:Food processor, dairy, slaughterhouse, industrial laundry.2.is subject to Federal Categorical Pretreatment
Standards;Examples:metal plating, cleaning or coating of metals, blueing of metals, aluminum extruding, circuit board manufacturing, tanning animal skins, pesticide formulating or packaging,
and pharmaceutical manufacturing or packaging,3.is a concern to the POTW.Examples:septage hauler, restaurant and food service, car wash, hospital, photo lab, carpet cleaner, commercial
laundry.All users of the water treatment facility are prohibited from making the following types of discharges:1.A discharge which creates a fire or explosion hazard in the collection
system.2.A discharge which creates toxic gases, vapor or fumes in the collection system.3.A discharge of solids or thick liquids which creates flow obstructions in the collection system.4.An
acidic discharge (low pH) which causes corrosive damage to the collection system.5.Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause problems in the collection system or at the waste treatment facility.6.Waste haulers are prohibited from discharging without permission. (No midnight dumping!)When the solution
to a sewer system problem may be found by investigating the types and amounts of wastewater entering the sewer system discharged from IUs, it’s appropriate to conduct an Industrial Waste
Survey.An Industrial Waste Survey consists of:Step 1: Identify Industrial UsersMake a list of all the commercial and industrial sewer connections.Sources for the list:business license,
building permits, water and wastewater billing, Chamber of Commerce, newspaper, telephone book, yellow pages.Split the list into two groups:domestic wastewater only--no further information

neededeveryone else (IUs)Step 2: Preliminary InspectionGo visit each IU identified on the “everybody else” list. Fill out the Preliminary Inspection Form during the site visit.Step
3: Informing the StatePlease fax or send a copy of the Preliminary inspection form (both sides) to:Jennifer RobinsonDivision of Water Quality288 North 1460 WestP.O. Box 144870Salt Lake
City, UT 84114-4870Phone: [phone]Fax:[phone]E-mail:[e-mail]:\WP\Pretreatment\Forms\IWS.doc
PRELIMINARY INSPECTION FORM
INSPECTION DATE / /
Name of Business Person Contacted
Address Phone Number
Description of Business
Principal product or service:
Raw Materials used:
Production process is: [ ] Batch [ ] Continuous[ ] Both
Is production subject to seasonal variation? [ ] yes[ ] no
If yes, briefly describe seasonal production cycle.
This facility generates the following types of wastes (check all that apply):
1. [ ] Domestic wastes(Restrooms, employee showers, etc.)
2. [ ] Cooling water, non-contact3. [ ] Boiler/Tower blowdown
4. [ ] Cooling water, contact5. [ ] Process
6. [ ] Equipment/Facility washdown7. [ ] Air Pollution Control Unit
8. [ ] Storm water runoff to sewer9. [ ] Other describe
Wastes are discharged to (check all that apply):
[ ] Sanitary sewer[ ] Storm sewer
[ ] Surface water[ ] Ground water
[ ] Waste haulers[ ] Evaporation
[ ] Other (describe)
Name of waste hauler(s), if used
Is a grease trap installed?YesNo
Is it operational?YesNo
Does the business discharge a lot of process wastewater?More than 5% of the flow to the waste treatment facility?YesNoMore than 25,000 gallons per work day?YesNo
Does the business do any of the following:[ ] Adhesives[ ] Car Wash[ ] Aluminum Forming[ ] Carpet Cleaner[ ] Battery Manufacturing[ ] Dairy[ ] Copper Forming[ ] Food
Processor[ ] Electric & Electronic Components[ ] Hospital[ ] Explosives Manufacturing[ ] Laundries[ ]Foundries[ ] Photo Lab[ ]Inorganic Chemicals Mfg. or Packaging[ ]
Restaurant & Food Service[ ] Industrial Porcelain Ceramic Manufacturing[ ] Septage Hauler[ ] Iron & Steel[ ] Slaughter House
[ ] Metal Finishing, Coating or Cleaning
[ ] Mining
[ ] Nonferrous Metals Manufacturing
[ ]Organic Chemicals Manufacturing or Packaging
[ ] Paint & Ink Manufacturing
[ ] Pesticides Formulating or Packaging
[ ] Petroleum Refining
[ ] Pharmaceuticals Manufacturing or Packaging
[ ] Plastics Manufacturing
[ ] Rubber Manufacturing
[ ] Soaps & Detergents Manufacturing
[ ] Steam Electric Generation
[ ] Tanning Animal Skins
[ ] Textile Mills
Are any process changes or expansions planned during the next three years? YesNo
If yes, attach a separate sheet to this form describing the nature of planned changes or expansions.
Inspector
Waste Treatment Facility
Please send a copy of the preliminary inspection form (both sides) to:
Jennifer Robinson
Division of Water Quality
P. O. Box 144870
Salt Lake City, Utah 84114-4870
Phone:[phone]
Fax:[phone]E-Mail:[e-mail]
Industrial User
Jurisdiction
SIC Codes
Categorical Standard Number

Total Average Process Flow (gpd)
Total Average Facility Flow (gpd)
Facility Description
1
2
3
4
5
6
7
8
9
10
11
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ATTACHMENT 2
Wasteload Analysis
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ATTACHMENT 3
Reasonable Potential Analysis
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REASONABLE POTENTIAL ANALYSIS
Water Quality has worked to improve our reasonable potential analysis (RP) for the inclusion of limits for parameters in the permit by using an EPA provided model. As a result of the
model, more parameters may be included in the renewal permit. A Copy of the Reasonable Potential Analysis Guidance (RP Guide) is available at water Quality. There are four outcomes
for the RP Analysis. They are;
Outcome A:A new effluent limitation will be placed in the permit.
Outcome B:No new effluent limitation. Routine monitoring requirements will be placed or increased from what they are in the permit,
Outcome C:No new effluent limitation. Routine monitoring requirements maintained as they are in the permit,
Outcome D:No limitation or routine monitoring requirements are in the permit.Ferron is a minor discharger with no known industrial dischargers with a low reasonable potential for toxics
to be in the effluent, therefore they are not required to monitor metals, and RP is not required to be run on their effluent at this time. If and when this changes, metals monitoring
may be added to the permit.