DWQ-2025-005086

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
EMERY COUNTY COAL RESOURCES, INC. - LILA CANYON MINE
UTAH POLLUTANT DISCHARGE ELIMINATION SYSTEM (UPDES)
RENEWAL PERMIT: DISCHARGE
UPDES PERMIT NUMBER: UT0026018
MINOR INDUSTRIAL FACILITY
FACILITY CONTACTSPerson Name:Angelo KonakisPosition:Superintendent & SignatoryPerson Name:Jesse CandelariaPosition:Environmental Permitting TechPhone Number:[phone]Permittee Name:Emery
County Coal Resources, Inc.Facility Name:Lila Canyon Mine Facility Location:23415 N. Lia Canyon RoadGreen River, UTMailing Address:PO Box 910East Carbon, UT 84520
DESCRIPTION OF FACILITY
The Emery County Coal Resources, Inc. - Lila Canyon Mine facility (facility) is an inactive underground coal mining facility located in Lila Canyon, in Emery County, Utah, with permitted
discharges to ephemeral tributaries within the Price River watershed. The facility currently has a total of three permitted outfalls and maintains this UPDES Permit primarily for its
minewater and sedimentation pond discharges via Outfalls 002 & 003, respectively, but also for any domestic wastewater treated effluent discharges from its sanitary sewage and grey water
system, which was newly constructed as part of the initial UPDES Permit issuance in 2015, but has yet to become operational and discharge via Outfall 001.
The facility has been inactive since September 2022 due to an underground fire that ceased operations, including the mine water discharges. The facility desires continuation of this
Permit for any potential discharges over the next five years as appropriate.
SUMMARY OF CHANGES FROM PREVIOUS PERMITTemperature monitoring has been added for all discharging Outfalls as discussed further in the Total Maximum Daily Load section of this Fact SheetThe
Interim Flow limit for mine water discharges via Outfall 002 has expired, which was included in the previous 2023 Permit modification. The season ammonia limits for Outfall 001 have
been updated to reflect the current WLA as discussed further in the Basis For Effluent Limitations section of this Fact Sheet.
DISCHARGE INFORMATION
DESCRIPTION OF DISCHARGE
The facility has been reporting self-monitoring results via Discharge Monitoring Reports (DMRs) on a monthly basis as required. A summary of the past five years of effluent discharge
data has been included as an attachment to this Fact Sheet. The discharge Permit Outfalls remain unchanged as follows:
OutfallDescription of Discharge Point001Located at latitude 3925' 26" north and longitude 110 20' 55" west. Discharge is from a sanitary wastewater package plant to an unnamed ditch
to Lila Canyon Wash. 002Located at latitude 39° 25' 27" north and longitude 110° 20' 28" west. Mine water discharge southeast of sedimentation pond to Grassy Wash. 003Located at latitude
39° 25' 37" north and longitude 110° 21' 1" west. Sedimentation pond discharge to Grassy Wash.
RECEIVING WATERS AND STREAM CLASSIFICATION
Both Lila Canyon Wash and Grassy Wash are tributaries to the Price River, which is approximately ten miles downstream of the facility. Per Utah Administrative Code (UAC) R317-2-13.1b,
the beneficial uses for the Price River and tributaries, from confluence with the Green River to the confluence with Soldier Creek are classified as follows:
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 Utah’s Final 2024 Integrated Report on Water Quality dated April 30, 2024 (UDWQ, 2024), the receiving water for Outfalls
001 through 003 effluent discharge is, “Price River and tributaries from confluence with Green River to confluence with Soldier Creek, (AU name: Price River-4, AU ID: UT14060007-014_00)”,
are listed as “Fully Supporting”. The Price River and tributaries from confluence with the Green River to confluence with Soldier Creek has a site-specific standard for TDS of 3,000
mg/l, which has been incorporated in the Permit.No additional monitoring requirements or parameters of concern have been included in this Permit as a result of any TMDL requirements,
however, temperature monitoring of all effluent discharges has been added in the Permit to support any future water quality analyses or TMDL studies.
BASIS FOR EFFLUENT LIMITATIONS
In accordance with regulations promulgated in the Code of Federal Regulations (C.F.R.), specifically in 40 C.F.R. § Part 122.44, and in UAC R317-8-4.2, effluent limitations are derived
from technology-based effluent limitations guidelines,Utah Secondary Treatment Standards as found in UAC R317-1-3.2, and/or Utah Water Quality Standards found in UAC R317-2 as applicable.
In cases where multiple limits have been developed, those that are more stringent apply. In cases where no limits or multiple limits have been developed, Best Professional Judgment
(BPJ) of the permitting authority may be used where applicable. “Best Professional Judgment” refers to a discretionary, best professional decision made by the permit writer based upon
precedent, prevailing regulatory standards or other relevant information.
Permit limits can also be derived from a WLA, which incorporates Utah Water Quality Standards, including TMDL impairments as appropriate, Antidegradation Reviews (ADR) and designated
uses into a water quality model that projects the effects of discharge concentrations on receiving water quality. Effluent limitations are those that the model demonstrates are sufficient
to meet Utah Water Quality Standards in the receiving waters. During this UPDES renewal permit development, a WLA and ADR were completed. An ADR Level I review was performed and concluded
that an ADR Level II review was not required this time since there are no proposed increases in flow or concentrations from the previous Permit. The WLA indicates that the effluent limitations
will be sufficiently protective of water quality in order to meet Utah Water Quality Standards in the receiving waters. The WLA and ADR information are included as an attachment to
this Fact Sheet.
The following list is the basis for the effluent limitations for all Outfalls unless stated otherwise;
The daily minimum and maximum limitations for pH are derived from Utah Secondary Treatment Standards (for Outfall 001) and from Utah Water Quality Standards (for Outfalls 002 & 003)
as cited above.
Regarding effluent limitations for E. coli, biochemical oxygen demand (BOD5), and total suspended solids (TSS); the 30-day and 7-day averages, along with BOD5 and TSS percent removal
requirements, are all derived from the Utah Secondary Treatment Standards as applicable to Outfall 001 and remain unchanged from the previous Permit.
The seasonal limits for ammonia as nitrogen (NH3-N) for Outfall 001 are derived from the current WLA and are similar in concentrations to the previous Permit & WLA.
The dissolved oxygen (DO) minimum limitations remain unchanged and are based uponUtah Water Quality Standards (found in UAC R317-2 Table 2.14.2) as well as the WLA.
Since the facility discharge meets the EPA definition of “alkaline mine drainage,” the permittee is subject to the technology based effluent limitations in 40 C.F.R.§ Part 434.45. Applicable
technology-based limits included in the permit are as follows for Outfalls 002 and 003 as appropriate:

TSS daily maximum limit of 70 mg/L.
For discharges composed of surface water or mine water commingled with surface water, 40 C.F.R. § Part 434.63 allows alternate effluent limits to be applied when discharges result from
specific runoff events, detailed below and in the Permit. The facility has the burden of proof that the described runoff event occurred as described in the Permit. This applies at surface
water runoff pond outfalls only (Outfall 003).
For runoff events (rainfall or snowmelt) less than or equal to a 10-year 24-hour precipitation event, settleable solids may be substituted for TSS and shall be limited to 0.5 milliliters
per liter (ml/L). All other effluent limitations must be achieved concurrently, as described in the permit.
For runoff events (rainfall or snowmelt) greater than a 10-year 24-hour precipitation event, the pH limitations may supersede the otherwise applicable Permit effluent limitations.
Total dissolved solids (TDS) are limited by both mass loading and concentration requirements and remain unchanged from the previous Permit as described below:
Since discharges from the facility would eventually reach the Colorado River, TDS mass loading is limited according to policies established by the Colorado River Basin Salinity Control
Forum (Forum), as authorized in UAC R317-2-4 to further control salinity in the Utah portion of the Colorado River Basin. On February 28, 1977 the Forum produced the “Policy For Implementation
of Colorado River Salinity Standards Through the NPDES Permit Program” (Policy), with the most current subsequent triennial revision dated October 2023. Based on Forum Policy, provisions
have previously been approved by DWQ for salinity-offset projects to account for any TDS loading in excess of the 1 ton/day requirement as a sum of all outfalls at the facility. Salinity-offset
provisions remain included in the Permit to account for all excess TDS loading above the 1 ton/day requirement. If the concentration of TDS at any Outfall is less than or equal to 500
mg/L as a thirty-day average, then no loading limit applies for that Outfall. These provisions and requirements, as described further in both the Permit and in a latter section of this
Fact Sheet, have been included in the Permit as appropriate.
For TDS concentration limitations, a site-specificstandard of 3,000 mg/L, which was developed by DWQ for the Price River and tributaries from confluence with Green River to the confluence
with Soldier Creek, remains unchanged in the Permit. Based on this site-specific standard, the Lila Mine can discharge up to, but not exceed, an effluent concentration of 3,000 mg/L
TDS for Outfalls 002 and 003. Outfall 001 previously had a TDS concentration limit of 1,500 mg/L, because the water supplied to the bathhouse is treated by reverse osmosis and meets
drinking water standards making it unlikely that the TDS in the effluent will ever exceed 1,500 mg/L. Therefore, the TDS limitation for Outfall 001 shall remain 1,500 mg/L as a daily
maximum value. This is based upon BPJ of the permitting authority to comply with EPA’s anti-backsliding policy.
The total iron limitation for Outfalls 002 & 003 are based upon the Utah Water Quality Standard of 1.0 mg/L for dissolved iron (as found in UAC R317-2 Table 2.14.2) and the WLA limitation
of 1.0 mg/L for total recoverable iron. Total recoverable iron is a more stringent limit than dissolved iron since the dissolved component is a part of the total recoverable component.
This is consistent with other similar type permits in Utah and remains unchanged from the previous Permit.
Oil and Grease concentrations are limited to 10 mg/L based upon BPJ of the permitting authority to be consistent with other similartype permitsin Utah and remains unchanged from the
previous Permit.
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
An RP analysis was performed on all metals parameters from the facility mine water discharge data via Outfalls 002. Initial screening values that were submitted through both the monthly
DMRs, as well as the permit renewal application information, showed that a closer look may be needed for several of the metals parameters. Therefore, a qualitative RP analysis was conducted
for all metals parameters discharged via Outfall 002, which resulted in the total metal parameters for cadmium, lead, mercury and selenium as having potential to exceed the applicable
Acute and/or Chronic WQS due to the elevated laboratory reporting limits. All other total metals parameters were below the applicable WQS, except for total iron, which already has a
water quality based effluent limit as appropriate.
Upon closer look of the metals parameter data points, including any potential outliers that were above the laboratory method detection limits (MDLs), as well as each of the metals parameter
MDLs themselves, it does not appear that sufficiently sensitive test methods, MDLs and their reporting limits are being consistently utilized for all metals parameters. Specifically,
for the same total metals in question: cadmium, lead, mercury and selenium. All of which would require more sensitive testing/reporting methods and/or lower MDLs in order to better evaluate
RP for each of the respective Acute and/or Chronic WQS. As such, RP for these metals could not be adequately determined with the existing data points and current MDLs and/or laboratory
reporting limits. Therefore, more data points are needed utilizing the most sensitive laboratory MDLs and reporting limits to determine if RP actually exists for the total cadmium, lead,
mercury and/or selenium parameters to exceed either the Acute WQS and/or the Chronic WQS.
Based upon this RP evaluation, the final RP outcome was not to include any additional metal effluent limits at this time, however, monitoring for all the total metals parameters will
remain in place utilizing sufficiently sensitive laboratory test methods, MDLs and reporting limits as detailed in the permit. This will provide a better data set to be re-evaluated
for RP during the next permit cycle as appropriate. Once re-evaluated, the permit can be re-opened and modified as necessary to include any additional permit limitations as required.

The RP analysis of the effluent discharge data for all of the listed parameters resulted in no additional Acute or Chronic limits being required at this time, which equates to RP Outcome
C: No neweffluent limitation. Routine monitoring requirements maintained as they are in the permit,but with utilizing sufficiently sensitive laboratory test methods, MDLs and reporting
limits as appropriate.The complete RP analysis is included as an attachment to this Fact Sheet.
The permit limitations are
<INSERT FINAL TABLE>
SELF-MONITORING AND REPORTING REQUIREMENTSThe following self-monitoring requirements are the same as in the previous Permit with the addition of temperature monitoring as mentioned previously.
The permit requires reports to be submitted monthly and quarterly, as applicable, on 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 reportsfor biomonitoring, metals and toxic organics shall be attached to
the DMRs when applicable.<INSERT FINAL TABLE>
BIOSOLIDS
The State of Utah has adopted the 40 C.F.R. § Part 503 federal regulations for the disposal of sewage sludge (biosolids) by reference. The sanitary treatment system at the Lila Canyon
Mine facility is a small package plant, knownas an Orenco system. Sewage will be sent from the bath house to a septic tank (approx. 18,000 gallons capacity)where most of the solids will
be retained and the liquid pumped to the Orenco System. Solids will haveto be disposed of as required by the 503 requirements. The Lila Canyon Mine plans to have the septictank pumped
out when needed and the solids disposed of as septage at a local treatment plant for proper disposal. In the future, if the solids waste needs to be removed from the facility and disposed
in some other way, DWQ must be contacted prior to the removal of the solids waste to ensure that all applicable state and federal regulations are met.
STORM WATER

Separate storm water permits may be required based on the types of activities occurring on site. Permit coverage under the Multi Sector General Permit (MSGP) for Storm Water Discharges
from Industrial Activities is required based on the Standard Industrial Classification (SIC) code for the facility and the types of industrial activities occurring for which the facility
has previously obtained separate MSGP coverage as appropriate.
Permit coverage under the Construction General Storm Water Permit (CGP) is required for any construction at the facility which disturb an acre or more, or is part of a common plan of
development or sale that is an acre or greater, and which is not part of active mining activities. A Notice of Intent (NOI) is required to obtain a construction storm water permit prior
to the period of construction.
Information on storm water permit requirements can be found at http://stormwater.utah.gov.
PRETREATMENT REQUIREMENTS
The facility does not discharge process wastewater to a Publicly Owned Treatment Works (POTW). However, any wastewater discharged to a sanitary sewer or POTW is 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.
In addition, in accordance with 40 C.F.R. § 403.12(p)(1), the permittee must notify the POTW, the EPA Regional Waste Management Director, the DWQ Director and the State hazardous waste
authorities in writing if the facility discharges any substance into a POTW that if otherwise disposed of would be considered a hazardous waste under 40 C.F.R. § 261. This notification
must include the name of the hazardous waste, the EPA hazardous waste number, and the type of discharge (continuous or batch).
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 not classified as a major facility or a significant minor facility and any discharges to date from the Mine are either from intercepted ground water,or from storm water,
in which toxicity has previously not been identified as an existing or a potential concern. Discharges are to ephemeral drainages and do not normally reach the downstream waters of
the Price River. Outfall 001 discharges are from a sanitary waste package plant that will receive only domestic wastes from a bath house associated with Lila Canyon Mine. Outfall 003
discharges are from a sedimentation pond that collects surface water runoff from the active mining area. Outfalls 001 & 003 have not discharged to date and will likely only discharge
intermittently if at all in the near future. Regarding Outfall 002 and upon request from DWQ during the development of the previous permit, the permittee performed a chronic biomonitoring
whole effluent toxicity (WET) test on the mine water from Outfall 002, using the appropriate test species and methods, which resulted in no toxicity.
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 byJeff Studenka, Discharge Permit WriterDaniel Griffin, BiosolidsJennifer
Robinson, PretreatmentLonnie Shull, BiomonitoringJordan Bryant, Storm WaterAmy Dickey, TMDL/Watershed ProtectionChris Shope, Wasteload Analysis/ADRUtah Division of Water Quality(801)
536-4300PUBLIC NOTICE INFORMATION (to be updated after)Began: Month Day, YearEnded: Month Day, YearComments 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(If applicable,
explain any comments received and response sent. Actual letters can be referenced, but not required to be included).
DWQ-2025-00
This Page Intentionally Left Blank
ATTACHMENT 1
Effluent Monitoring Data Summary
(DWQ-2025-00004162)
This Page Intentionally Left Blank
ATTACHMENT 2
Wasteload Analysis Information
(DWQ-2025-004557 & DWQ-2025-004558)
This Page Intentionally Left Blank
ATTACHMENT 3
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.
The Initial RP Screening Table is included below for the metals parameters, as derived from the Permit application information, DMRs and WLA. Note that the full RP analysis model could
not be utilized at this time due to the lack of metals data.RP Initial Screening Table for Lila Canyon Mine Water Outfall 002

2021-2023 Data Summary Results & RP Analysis (ceased discharging in January 2024)
(Outfalls 001 & 003 did not discharge)
Parameter
No. of Samples
MEC*a
mg/L
Water Quality Standard MAC*b
Outcome/Result
Acute mg/L
Chronic mg/L
Total Aluminum
10
0.3
0.75
NA
MEC < MAC *c
Total Arsenic
10
0.1
0.34
0.15
MEC < MAC
Total Cadmium
10
<0.02 *f
0.0074
0.0024
Undetermined *f
Total Chromium
10
<0.02
5.61
0.268
MEC < MAC
Total Copper
10
<0.02
0.0517
0.0305
MEC < MAC
Total Iron
31
2.94
1.00
NA
MEC > MAC
Total Lead
10
<0.02 *f
0.4768
0.0186
MEC < MAC (acute)
Undetermined (chronic)*f
Total Mercury
10
<0.002 *f
0.0024
0.000012
MEC < MAC (acute)
Undetermined (chronic)*f

Total Nickel
10
<0.02
1.52
0.169
MEC < MAC
Total Selenium
10
<0.02 *f
0.0184
0.0046
Undetermined *f
Total Silver
10
<0.02
0.021
NA
MEC < MAC
Total Zinc
10
0.036
0.2787
0.2787
MEC < MAC
Notes/Legend
NA – Not Applicable, no current Water Quality Standard (WQS). WQS Exceedances shown in BOLD.
*a – MEC: Maximum expected effluent concentration as determined from existing data set and sufficiently sensitive method detection limits.
*b – MAC: Maximum allowable concentration from current WQS and/or wasteload analysis.
*c – MEC < (less than) MAC: No Acute or Chronic limit required.
*d – MEC > (greater than) MAC: Acute and/or Chronic limits may be required.
*e – MEC = (equal to) MAC: Acute and/or Chronic limits not required at this time.
*f – Undetermined: Unable to determine the Acute and/or Chronic WQS criteria due to insufficient Laboratory method detection limits (MDLs) and/or reporting limits.Since the inception
of sampling for additional metals in 2021, effluent analyses for these metals parameters has not resulted in a detected concentration above the applicable MDL as reported. Upon further
review, the MDLs for these and other metals parameter analyses are not reflective of adequate and sufficiently sensitive test methodologies and/or reporting limits that are readily available
and expected from commercial laboratories. Therefore, going forward the permitee shall ensure that sufficiently sensitive test methodologies, MDLs and their reporting limits are being
utilized as appropriate for all effluent parameters.
Summary: An RP analysis was performed on all metals parameters from the facility mine water discharge data via Outfalls 002 (see Table above). Initial screening values that were submitted
through both the monthly discharge monitoring reports, as well as the permit renewal application information, showed that a closer look may be needed for several of the metals parameters.
Therefore, a qualitative RP analysis was conducted for all metals parameters discharged via Outfall 002, which resulted in the total metal parameters for cadmium, lead, mercury and selenium
as having potential to exceed the applicable Acute and/or Chronic WQS due to the elevated laboratory reporting limits. All other total metals parameters were below the applicable WQS,
except for total iron, which already has a water quality based effluent limit as appropriate.
Upon closer look of the metals parameter data points, including any potential outliers that were above the laboratory method detection limits (MDLs), as well as each of the metals parameter
MDLs themselves, it does not appear that sufficiently sensitive test methods, MDLs and their reporting limits are being consistently utilized for all metals parameters. Specifically,
for the same total metals in question: cadmium, lead, mercury and selenium. All of which would require more sensitive testing/reporting methods and/or lower MDLs in order to better evaluate
RP for each of the respective Acute and/or Chronic WQS. As such, RP for these metals could not be adequately determined with the existing data points and current MDLs and/or laboratory
reporting limits. Therefore, more data points are needed utilizing the most sensitive laboratory MDLs and reporting limits to determine if RP actually exists for the total cadmium, lead,
mercury and/or selenium parameters to exceed either the Acute WQS and/or the Chronic WQS.
Based upon this RP evaluation, the final RP outcome was not to include any additional metal effluent limits at this time, however, monitoring for all the total metals parameters will
remain in place utilizing sufficiently sensitive laboratory test methods, MDLs and reporting limits as detailed in the permit. This will provide a better data set to be re-evaluated
for RP during the next permit cycle as appropriate. Once re-evaluated, the permit can be re-opened and modified as necessary to include any additional permit limitations as required.

Result: The RP analysis of the effluent discharge data for all of the listed parameters resulted in no additional Acute or Chronic limits being required at this time, which equates to
RP Outcome C: No neweffluent limitation. Routine monitoring requirements maintained as they are in the permit,but with utilizing sufficiently sensitive laboratory test methods, MDLs
and reporting limits as appropriate.