DWQ-2025-004717

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
BIG WEST OIL
MODIFIED PERMIT: DISCHARGE
UPDES PERMIT NUMBER: UT0026174
MINOR INDUSTRIAL
FACILITY CONTACTSPerson Name: Alec KlinghofferPosition: President, VP Refinery ManagerPhone Number: [phone] Email [e-mail] Person Name: FaitheSchwartzengraberPosition:
President, Environmental ManagerPhone Number: [phone]Email [e-mail] Name: Eric SimdornPosition: President, Environmental EngineerPhone Number:
[phone]Email [e-mail] Permittee Name:Big West Oil LLCFacility Name:Big West OilMailing and Facility Address:333 West Center Street North Salt Lake, Utah 84054Telephone:(801)
296-7716Actual Address:333 West Center Street, North Salt Lake
DESCRIPTION OF FACILITY
Big West Oil LLC operates an oil refinery in North Salt Lake, Utah. Until recently, Big West obtained all process and fire suppression water from the local municipality (North Salt Lake)
and discharged all process water to the local sewer district (South Davis Sewer District). The refinery has added a groundwater extraction and reverse osmosis (RO) treatment system to
serve the refinery’s process water needs. Process water for the facility from the new extraction and RO treatment system is supplemented with culinary water from the North Salt Lake
as needed. Additionally, as a result of new fire regulations, Big West has added a new process using the treated groundwater to deluge existing propane tanks at the facility in the event
of a fire.
This permit and the discharge that is authorizes through Outfall 001 are for the single pass engine cooling water and wastewater from the RO process (filtrate) only. No other process
water or wastewater are permitted for discharge through Outfall 001.
This permit and discharge are for the new fire suppression process at the refinery, single pass engine cooling water and wastewater from the RO process (filtrate). The propane tanks
and discharge are located in the South East and West portion of the property respectively. The source for water is a groundwater well. Water is pumped up to the surface and sent to the
reverse osmosis (RO) treatment system. The RO filtrate goes to Outfall 001 and the permeate is sent to utility water system which is supplemented by culinary water from the city system
when needed.
Plant utility water is used as makeup water for onsite cooling tower blowdown, process makeup water, and in the fire suppression system. A portion of the utility water from the RO system
is directed to a larger reservoir onsite. Water in the reservoir is used in in the fire suppression system. When the fire water (FW) pumps are activated during a fire, they take water
from the tank and pump it into the fire suppression system. A portion of this flow is circulated back through the engines as cooling water which will then be discharged through Outfall
001. If there is no fire, but the engines are being tested to ensure their operation, or if they are being operated due to engine maintenance, the fire suppression water is piped back
to the reservoir onsite.
The FW pumps are tested for 30 minutes weekly. The test consists of running the engine FW pumps in a recirculating setting. They take water from the treated water tank and pump it back
to the tank. A small portion of the water is sent through the motors as cooling water. This cooling water is then discharged at Outfall 001. When the tests are conducted, the FW pumps
are run one at a time, and the pumped water recirculates to the onsite storage tank. During a fire emergency at the refinery, the pumps would be run concurrently.
The groundwater well is housed in the same building as all the FW pumps. This will reduce the risk of any leaks or spills of engine fluid from being discharged to the surface water,
or carried away during a precipitation event. Located next to the pump building are the reservoir tank (west side), and the RO system building (east side). Floor drains in the buildings
are directed to the discharge to the local sewer district.
The RO system has two RO Units that will reject up to 40 gpm. There are currently 5 FW pumps. One pump (P-995) is older, the other four are recently installed and identical.
Pump Flow Rates
Pump
Flow, gpm
at 60 °F
at 80 °F
at 100 °F
Max
RO Pad (2 @ 40 gpm)
80
80
80
80
Firewater Pump (P-995)
40
42
44
80
Firewater Pumps
24.8
26.4
28
unspecified
The discharge of process wastewater and sanitary waste through Outfall 001 is prohibited. Big West discharges all sanitary waste and process wastewater to the local sewer district (South
Davis Sewer District) and has been permitted to do this through the district Pretreatment Program.
The chronic flow level for the system is 80 gpm (0.178 cfs) or 0.12 million gallons per day (MGD) which will be a monthly average flow limit.

The acute flow for the system is expected to occur when the system is undergoing a full load test of the pumps. This would be the base RO system flow plus the cooling water from all
five pumps. The acute flow should be 227.6 gpm (0.3277 cfs) or 0.33 MGD which would be a maximum daily flow.
TBPEL considerations.
This facility does not introduce phosphorus or phosphorus containing products into the waste stream. There will be no annual limit for phosphorus in the permit. There will still be monitoring
related to the TBPEL rules, but this monitoring will only be on the effluent, and may be reduced or eliminated in the future.
Anti-degradation Review
Since this is a modification of the discharge, the permittee conducted a level II antidegradation review (L2ADR) and submitted it with the application. The L2ADR was conducted using
a preliminary WLA supplied by Division of water Quality (DWQ). The facility will be treating high quality groundwater and discharging the treatment process waste water, and discharging
the treated product. The result is that they do not have the expected potential to reduce the assimilative capacity of, and should not negatively impact the receiving water. The L2ADR
(and application) is included in Attachment 3 of this FSSOB.
SUMMARY OF CHANGES FROM PREVIOUS PERMIT
During the first 6 months of discharge, BWO had to calculate the effluent flow based on pump rates and time. This resulted in an overestimate of the effluent flow (average monthly),
and they exceeded the average flow limit for the permit. They finally received their flow meter and installed it in December 2023.
At this point the evaluated the flow for several months to see if they could determine a correction factor for the calculated flow, to adjust it to better match the measured flow. When
this was done they were able to show that the calculated flows were higher than would have been measured using the meter, and that no flow limitations were exceeded during the first
six months. Shortly after this, they did exceed the average monthly effluent limit (April 2024).
Upon review, BWO determined they would need to request a modification of the permit to increase the limits and avoid further violations. They also were working on determining if they
would need additional treatment units to supply more water for fire suppression and other onsite processes.
The effluent limit modification is to allow for the system growth and a safety factor in case They have missed anything in their estimates. The new flows will be
Parameter
Effluent Limitations *a
Maximum Monthly Avg
Maximum Weekly Avg
Yearly
Average
Daily Minimum
Daily Maximum
Total Flow, MGD
0.33
-
-
-
0.55
The other item modified is that BWO will be moving the outfall, and sampling location, 700 ft South to the property line, and directly into the receiving stream. This will allow room
for more units in the area. This change has little to no impact on the effluent limits.
DISCHARGE
DESCRIPTION OF DISCHARGE
Big West Oil has been discharging and reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis since May 2023. A summary of the monitoring data has been included
in Attachment 1 below. There are several flow violations and one oil and grease violation. None of the violations have resulted in enforcement actions by DWQ. OutfallDescription of Discharge
Point
001 Located at latitude 4050'05” and longitude 11155'31". The discharge is by will be through a pipe to the Salt Lake Sewage Canal and on to the Northwest Drain Canal.RECEIVING WATERS
AND STREAM CLASSIFICATION
The discharges will be to the Salt Lake Sewage Canal, which is a Class 2B, 3E, AND 5D according to Utah Administrative Code (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 3E -- Severely habitat-limited waters. Narrative standards will be applied to protect these waters for aquatic wildlife.
Class 5D Farmington Bay
Geographical Boundary -- All open waters at or below approximately 4,208-foot elevation east of Antelope Island and south of the Antelope Island Causeway, excluding salt evaporation
ponds.
Beneficial Uses -- 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
Limitations on pH are based on current Utah Secondary Treatment Standards, UAC R317-1-3.2. The oil and grease limits are based on best professional judgment (BPJ). Attached is a Wasteload
Analysis for this discharge into the receiving water. It has been determined that this discharge will not cause a violation of water quality standards. An Antidegradation Level II review
was conducted and shows the 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
There is only a 2-year history of discharging at this time, and that is not enough data to base the RP on. It will be conducted when the permit is renewed. 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
0.33
-
-
-
0.55
Oil & Grease, mg/L
-
-
-
-
10.0
pH, Standard Units
-
-
-
6.5
9
See Definitions, Part VIII, for definition of terms.
SELF-MONITORING AND REPORTING REQUIREMENTSThe following self-monitoring requirements are the same as in the previous permit. 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 *a
Parameter
Frequency
Sample Type
Units
Total Flow 2
Continuous
Recorder
MGD
pH
Weekly
Grab
SU
DO
Weekly
Grab
mg/L
Oil & Grease
Monthly
Grab
mg/L
TDS, mg/L
Monthly
Composite
mg/L
TSS, mg/L
Monthly
Composite
mg/L

Orthophosphate (as P)
Monthly
Composite3
mg/L
Total Phosphorus (as P)
Monthly
Composite3
mg/L
Temperature,
Weekly
Composite
°C
Metals4
Annually
Composite/Grab
mg/L
Organic Toxics
Once
Grab
mg/L
See Definitions, Part VIII, for definition of terms.
If the rate of discharge is controlled, the rate and duration of discharge shall be reported.
In R317-1-3.3, D, 3 the rule states that all monitoring (TBPEL related) shall be based on 24-hour composite samples by use of an automatic sampler or a minimum of four grab samples collected
a minimum of two hours apart.
See Metals Monitoring Table below for list of metals to monitor for.
Metals Monitoring TableParameterSample Type
Total ArsenicCompositeTotal CadmiumTotal ChromiumTotal CopperTotal LeadTotal MolybdenumTotal NickelTotal SeleniumTotal SilverTotal ZincTotal CyanideComposite/GrabTotal MercuryGrab
PERMIT DURATIONIt is recommended that this modified permit be effective for the remainder of the current permit, expiring April 30, 2028.Drafted and Reviewed byDaniel Griffin, Discharge
Permit Writer, Reasonable Potential AnalysisSusan 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)
This Page Intentionally Left Blank
ATTACHMENT 1
Effluent Monitoring Data
This Page Intentionally Left BlankEffluent Monitoring Data.
Month
Value
Value
Value
Value
Value
Value
Value
Value
Value
Value
Parameter
Flow
TDS
TSS
O & G
DO
Temp
Ortho P
Tot P
pH

Unit
MGD
mg/L
mg/L
mg/L
mg/L
deg C
mg/L
mg/L
SU
Stat
Chronic
Max
Chronic
Chronic
Max
Chronic
Chronic
Chronic
Chronic
Max - Min
Limit
0.12
0.33

10

9 - 6.5
May-23
0.144
0.22
5150
7

2.8
24.8
0.14
1
7
Jun-23
0.146
0.187
4660
10

3.9
24.7
0.13
1
7
Jul-23
0.157
0.185
2340
5

2.9
26.9
0.1
0.3
7
Aug-23
0.149
0.186
3880
6
5
3.2
25
0.08
0.5
7
Sep-23
0.148
0.163
6020
13
5
3.1
24.6
0.15
1
7
Oct-23
0.145
0.169
5980
15
5
4.2
23
0.12
0.6
7
Nov-23
0.102
0.148
5920
4
5
5.5
20.2
0.16
1.3
7
Dec-23
0.094
0.127
4590
8
5
3.6
20.4
0.08
0.3
7

Jan-24
0.111
0.123
4770
4
5
4.8
20.3
0.09
0.5
7
Feb-24
0.117
0.202
880
4
5
5.2
20.3
0.02
0.02
7
Mar-24
0.126
0.211
3900
7
5
3.9
21.8
0.06
0.3
7
Apr-24
0.083
0.221
464
4
5
3.9
21.2
0.01
0.02
7
May-24
0.025
0.079
872
4
5
3
22.5
0.02
0.01
7
Jun-24
0.015
0.05
844
4

5
3.7
26.1
0.02
0.02
7
Jul-24
0.015
0.066
960
23
32
3.9
26.6
0.02
0.02
7
Aug-24
0.041
0.144
4960
7
5
4
28.2
0.1
4.4
7
Sep-24
0.113
0.169
5710
4
5
4.2
22.8
0.11
0.3
7
Oct-24
0.117
0.143
7020
6
5
4.4
21.9
0.2
0.4
7
Nov-24
0.11
0.168
8740
18

4.1
21.3
0.14
0.6

7
Dec-24
0.082
0.13
6860
10

0.9
20
0.11
0.6
7
Jan-25
0.069
0.122
1900
5

18.7
0.04
0.1
7
Feb-25
0.071
0.145
7860
26

18.8
0.14
0.7
7
Mar-25
0.098
0.163
7590
10

2.9
20.6
0.12
1
7
Apr-25
0.127
0.269
9100
19

3.7
21.8
0.13
0.3
7
Parameter
2024
2025
Arsenic

0.0174
0.0008
Cadmium
ND
0.0002
Chromium
0.001
0.0037
Copper
0.0017
0.0367
Cyanide
ND
0.005
Lead
ND
0.0005
Mercury
ND
0.00015
Molybdenum
0.0014
0.0007
Nickel
0.0009
0.001
Selenium
0.0009
0.002
Silver
ND
0.0005
Zinc
ND
0.01
This Page Intentionally Left Blank
ATTACHMENT 2
Wasteload Analysis
This Page Intentionally Left Blank
ATTACHMENT 3
Level 2 Antidegradation Review
This Page Intentionally Left Blank
ATTACHMENT 4
Reasonable Potential Analysis
This Page Intentionally Left Blank
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.
This is a relatively new discharger that has been discharging for 2 year, therefore there is not enough data to run the RP against.