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Utah Division of Water Quality
Statement of Basis
ADDENDUM
Wasteload Analysis and Antidegradation Level I Review
Date: May 19, 2025
Prepared by: Suzan Tahir
Standards and Technical Services
Facility: Ferron Wastewater Treatment Facility Castle Valley Special Service
District
UPDES No. UT0020052
Receiving water: Ferron Creek (2B, 3C, 4)
This addendum summarizes the wasteload analysis that was performed to determine water quality
based effluent limits (WQBEL) for this discharge. Wasteload analyses are performed to determine
point source effluent limitations necessary to maintain designated beneficial uses by evaluating
projected effects of discharge concentrations on in-stream water quality. The wasteload analysis
also takes into account downstream designated uses (UAC R317-2-8). Projected concentrations
are compared to numeric water quality standards to determine acceptability. The numeric criteria
in this wasteload analysis may be modified by narrative criteria and other conditions determined
by staff of the Division of Water Quality.
Discharge
Outfall 001: Ferron Creek
The maximum daily design discharge is 0.5 MGD and the maximum monthly design discharge is
0.5 MGD for the facility.
Receiving Water
The receiving water for Outfall 001 is Ferron Creek, which is tributary to the San Rafael River,
which drains to the Colorado River.
Per UAC R317-2-13.1(b), the designated beneficial uses for Ferron Creek and tributaries, from
confluence with San Rafael River to Millsite Reservoir are 2B, 3C and 4.
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.
Utah Division of Water Quality
Wasteload Analysis
Ferron Wastewater Treatment Plant
UPDES No. UT0020052
Page 2 of 4
Class 4 - Protected for agricultural uses including irrigation of crops and stock watering.
Critical Flow
Typically, the critical flow for the wasteload analysis is considered the lowest stream flow for
seven consecutive days with a ten year return frequency (7Q10). Due to a limited of flow records
for Ferron Creek for the period 2015-2025, the 20th percentile of flow measurements at 4930798
Ferron Ck ab New Ferron Lagoons 001 was used to calculate annual critical low flow in the
receiving water (Table 1).
Table 1: Annual critical low flow for Ferron Creek above
New Ferron lagoon outfall
Season Count Flow (cfs)
Annual 8 1.88
Receiving water quality
Receiving water quality data were obtained from monitoring sites 4930820 Ferron Creek above
Ferron Lagoons 001 at U10 Crossing and 4930798 Ferron Creek above New Ferron Lagoons
001. The average seasonal value was calculated for each constituent with available data in the
receiving water. Effluent parameters were characterized using data from monitoring site 4930796
Ferron Lagoons New 001.
Mixing Zone
The maximum allowable mixing zone is 15 minutes of travel time for acute conditions, not to
exceed 50% of stream width, and 2,500 feet for chronic conditions, per UAC R317-2-5. Water
quality standards must be met at the end of the mixing zone.
The actual length of the mixing zone was not determined; however, it was presumed to remain
within the maximum allowable mixing zone dimensions. Acute limits were calculated using 50%
of the seasonal critical low flow.
Parameters of Concern
The potential parameters of concern identified for the discharge/receiving water were total
suspended solids (TSS), dissolved oxygen (DO), BOD5, total phosphorus (TP), total nitrogen (TN),
total ammonia (TAN), E. coli, pH, and total residual chlorine (TRC) as determined in consultation
with the UPDES Permit Writer.
Utah Division of Water Quality
Wasteload Analysis
Ferron Wastewater Treatment Plant
UPDES No. UT0020052
Page 3 of 4
TMDL
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.
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 Total Maximum Daily Load (TMDL) Price River, San
Rafael River, and Muddy Creek TMDLs for Total Dissolved Solids, West Colorado Watershed
Management Unit, Utah (MFG Inc. 2004).
WET Limits
The percent of effluent in the receiving water in a fully mixed condition, and acute and chronic
dilution in a not fully mixed condition are calculated in the WLA in order to generate WET limits.
The LC50 (lethal concentration, 50%) percent effluent for acute toxicity and the IC25 (inhibition
concentration, 25%) percent effluent for chronic toxicity, as determined by the WET test, needs to
be below the WET limits, as determined by the WLA. The WET limit for LC50 is typically 100%
effluent and does not need to be determined by the WLA.
Table 2: WET Limits for IC25
Season Percent
Effluent
Annual 29%
Effluent Limits
Effluent limits were determined using a mass balance mixing analysis (UDWQ 2012). The mass
balance analysis is summarized in Appendix A.
The water quality standard for chronic ammonia toxicity is dependent on temperature and pH, and
the water quality standard for acute ammonia toxicity is dependent on pH. The seasonal average
temperature and pH of Ferron Creek from the previous wasteload analysis were used to determine
the chronic criteria, and the seasonal 80th percentile pH was used to determine the acute criteria.
The water quality standards for ammonia are summarized in Appendix A.
The limits for total residual chlorine were determined assuming a decay rate of 20 /day (at 20 ºC)
and a travel time in the outlet ditch of 10 minutes (1,000 linear feet at 0.02 ft/ft slope) prior to
discharge to Ferron Creek. The analysis for TRC is summarized in Appendix C.
Due to the lack of discharge since 2005, the effects of TP, TN, DO and BOD5 in the effluent on
the DO in the downstream receiving waters was not assessed. It is presumed that previous permit
limits for these constituents, if applicable, would be sufficiently protective of the receiving water.
Utah Division of Water Quality
Wasteload Analysis
Ferron Wastewater Treatment Plant
UPDES No. UT0020052
Page 4 of 4
Model and supporting documentation are available for review upon request.
Antidegradation Level I Review
The objective of the Level I ADR is to ensure the protection of existing uses, defined as the
beneficial uses attained in the receiving water on or after November 28, 1975. No evidence is
known that the existing uses deviate from the designated beneficial uses for the receiving water.
Therefore, the beneficial uses will be protected if the discharge remains below the WQBELs
presented in this wasteload.
Antidegradation Review II
A Level II Antidegradation Review (ADR) is not required for this discharge since the pollutant
concentration and load is not increasing under this permit renewal.
Documents:
WLA Document: ferron_potw_wla_2025.docx
Wasteload Analysis: ferron_potw_wla_2025.xlsm
References:
Utah Division of Water Quality. 2024. Final 2024 Integrated Report on Water Quality
Utah Division of Water Quality. 2021. Utah Wasteload Analysis Procedures Version 2.0.
MFG Inc. 2004. Price River, San Rafael River, and Muddy Creek TMDLs for Total Dissolved Solids, West Colorado
Watershed Management Unit, Utah. Utah Division of Water Quality.
Utah Division of Water Quality
WASTELOAD ANALYSIS [WLA]Date:5/19/2025
Appendix A: Mass Balance Mixing Analysis for Conservative Constituents
Discharging Facility:Ferron Lagoons
UPDES No:UT-0020052
Permit Flow [MGD]:0.50 Annual Max. Daily
0.50 Annual Max. Monthly
Receiving Water:Ferron Creek
Stream Classification:2B, 3C, 4
Stream Flows [cfs]:1.9 All Seasons Critical Low Flow 20th %
Fully Mixed:NO
Acute River Width:50%
Chronic River Width:100%
Modeling Information
A simple mixing analysis was used to determine the effluent limits.
All model numerical inputs, intermediate calculations, outputs and graphs are available for
discussion, inspection and copy at the Division of Water Quality.
Effluent Limitations
Current State water quality standards are required to be met under a variety of conditions including
in-stream flows targeted to the 7-day, 10-year low flow (R317-2-9).
Other conditions used in the modeling effort reflect the environmental conditions expected
at low stream flows.
Effluent Limitations for Protection of Recreation (Class 2B Waters)
Physical
Parameter Maximum Concentration
pH Minimum 6.5
pH Maximum 9.0
Turbidity Increase (NTU)10.0
Bacteriological
E. coli (30 Day Geometric Mean)206 (#/100 mL)
E. coli (Maximum)668 (#/100 mL)
Page A-1
Utah Division of Water Quality
Effluent Limitations for Protection of Aquatic Wildlife (Assumed Class 3C Waters)
Temperature (deg C)Maximum
Instantaneous 27.0
Change 4.0
Dissolved Oxygen (mg/L)Minimum Concentration
Instantaneous 3.0
30-day Average 5.0
pH Concentration
Minimum 6.5
Maximum 9.0
Inorganics Chronic Standard (4 Day Average)Acute Standard (1 Hour Average)
Parameter Standard Standard
Phenol (mg/L)0.010
Hydrogen Sulfide (Undissociated) [mg/L]0.002
Ammonia-Total (mg/L)
Chronic (30-day ave)Acute (1-hour ave)
Season Standard Background Limit Standard Background Limit
Summer 2.3 0.030 7.8 9.6 0.030 21.2
Fall 4.4 0.030 15.0 9.2 0.030 20.4
Winter 5.6 0.030 19.1 9.4 0.030 20.8
Spring 2.0 0.030 6.6 4.0 0.030 8.9
Metals-Total Recoverable
Chronic (4-day ave)Acute (1-hour ave)
Parameter Standard1 Background Limit Standard1 Background Limit
Aluminum (µg/L)87.0 21.0 247.4 750.0 21.0 1635.9
Arsenic (µg/L)150.0 2.7 508.0 340.0 2.7 749.9
Cadmium (µg/L)0.6 0.48 1.1 7.7 0.48 16.6
Chromium VI (µg/L)11.0 5.4 24.6 16.0 5.4 28.9
Chromium III (µg/L)230.7 5.4 778.2 1773.3 5.4 3921.7
Copper (µg/L)29.3 6.2 85.4 49.6 6.2 102.4
Cyanide (µg/L)2 5.2 3.5 9.4 22.0 3.5 44.5
Iron (µg/L)1000.0 23.0 2187.3
Lead (µg/L)10.9 1.3 34.4 280.8 1.3 620.6
Mercury (µg/L)2 0.012 0.008 0.022 2.4 0.008 5.3
Nickel (µg/L)168.0 5.8 562.4 1512.9 5.8 3344.4
Selenium (µg/L)4.6 2.1 10.7 18.4 2.1 38.2
Silver (µg/L)34.9 1.1 76.0
Tributylin (µg/L)2 0.072 0.048 0.130 0.46 0.048 0.96
Zinc (µg/L)382.4 24.0 1253.5 379.3 24.0 811.1
1: Based upon a Hardness of 400 mg/l as CaCO3
2: Background concentration assumed 67% of chronic standard
Page A-2
Utah Division of Water Quality
Organics [Pesticides]
Chronic (4-day ave)Acute (1-hour ave)
Parameter Standard Limit Standard Limit
Aldrin (µg/L)1.5 1.5
Chlordane (µg/L)0.0043 0.0043 1.2 1.2
DDT, DDE (µg/L)0.001 0.001 0.55 0.55
Diazinon (µg/L)0.17 0.17 0.17 0.17
Dieldrin (µg/L)0.0056 0.0056 0.24 0.24
Endosulfan, a & b (µg/L)0.056 0.056 0.11 0.11
Endrin (µg/L)0.036 0.036 0.086 0.086
Heptachlor & H. epoxide (µg/L)0.0038 0.0038 0.26 0.26
Lindane (µg/L)0.08 0.08 1.0 1.0
Methoxychlor (µg/L)0.03 0.03
Mirex (µg/L)0.001 0.001
Nonylphenol (µg/L)6.6 6.6 28.0 28.0
Parathion (µg/L)0.0130 0.0130 0.066 0.066
PCB's (µg/L)0.014 0.014
Pentachlorophenol (µg/L)15.0 15.0 19.0 19.0
Toxephene (µg/L)0.0002 0.0002 0.73 0.73
Radiological Maximum Concentration
Parameter Standard
Gross Alpha (pCi/L)15
Effluent Limitation for Protection of Agriculture (Class 4 Waters)
Maximum Concentration
Parameter Standard Background Limit
Total Dissolved Solids (mg/L)3500 3500
Boron (mg/L)0.75 0.8
Arsenic, Dissolved (µg/L)100 100
Cadmium, Dissolved (µg/L)10 10.0
Chromium, Dissolved (µg/L)100 100
Copper, Dissolved (µg/L)200 200
Lead, Dissolved (µg/L)100 100
Selenium, Dissolved (µg/L)50 50
Gross Alpha (pCi/L)15 15.0
Page A-3
Utah Division of Water Quality
WASTELOAD ANALYSIS [WLA]Date:5/19/2025
Appendix C: Total Residual Chlorine
Discharging Facility:Ferron Lagoons
UPDES No:UT-0020052
CHRONIC Decay Rate (/day)
Season
Receiving
Water Standard
Total
Effluent
Mixing
Zone
Boundary
Effluent Limit
Without Decay
Temperature
(°C)
@ 20 deg
C
@ T
deg C
Travel
Time (min)
Decay
Coefficient
Effluent
Limit
Discharge (cfs)Annual 1.9 0.8 2.7
TRC (mg/L)Annual 0.000 0.011 0.038 20.0 20 20.0 10 0.87 0.043
ACUTE Decay Rate (/day)
Season
Receiving
Water Standard
Total
Effluent
Mixing
Zone
Boundary
Effluent Limit
Without Decay
Temperature
(°C)@ 20 °C @ T °C
Travel
Time (min)
Decay
Coefficient
Effluent
Limit
Discharge (cfs)Annual 0.9 0.8 1.7
TRC (mg/L)Annual 0.000 0.019 0.042 20.0 20 20.0 10 0.87 0.048
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