DWQ-2025-002567

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
CARGILL SALT
PERMIT NO. UT0000639
MINORINDUSTRIAL
FACILITY CONTACTS
Responsible Official:Justin Hipple, General Manager
Morton Salt, Inc.
1794 West Solar Road
Grantsville, Utah 84029
Telephone: [phone]
Email: [e-mail]
Facility ContactRachel Hahn,FSQR Manager
Morton Salt, Inc.
1794 West Solar Road
Grantsville, Utah 84029
Telephone: [phone]
Email: [e-mail]
DESCRIPTION OF FACILITY
Morton Salt Division of Morton International, Inc. (Morton) Grantsville facility precipitates, harvests, washes, dries, sizes, packages, and ships salt. Water from the Great Salt Lake
is utilized during several steps of Morton’s production process.
Precipitation: Lake water is pumped into solar evaporation basins. Once a sufficient quantity of salt has precipitated it is mechanically harvested. Concentrated brine (bitterns)
is produced during this step.
Washing: Once harvested, the salt is washed with salt water from the Great Salt Lake and this water is discharged back to the lake.
Packaging: Morton produces salt blocks to which micronutrients such as cobalt, cadmium, and chromium are added. In order to prevent these micronutrients from being added to the lake,
Morton has installed a bag house and dust collection system.
One production well on the property, known as Timpie Springs (3-5% salt concentration), is used for fire control. Drinking water is hauled from Grantsville, and wastewater is disposed
of in a septic tank/leaching field.
SUMMARY OF CHANGES FROM PREVIOUS PERMITThere have been no changes from the previous permit.
DISCHARGE
The facility utilizes one discharge point, designated as outfall # 001. All water used at Morton is returned to the lake via outfall # 001.Outfall NumberLocation of Discharge Outfall001Return
of bitterns to the Great Salt Lake. Outfall located at a latitude of 40°42'31.9"N and a longitude 112°28'40.9"W
RECEIVING WATERS AND STREAM CLASSIFICATION
The discharge is to Great Salt Lake. The receiving water the effluent discharges to is classified as 5E Transitional Waters and then to 5A (Gilbert Bay, Great Salt Lake) according to
Utah Administrative Code (UAC) R317-2-6.5.a. Both the Transitional Waters and Gilbert Bay are protected for waterfowl, shore birds, and other water-oriented wildlife including their
necessary food chain. The Transitional Waters are also protected for infrequent primary and secondary contact recreation. Gilbert Bay is protected for frequent primary and secondary
contact recreation.
Class 5A Gilbert Bay
Geographical Boundary -- All open waters at or below approximately 4,208-foot elevation south of the Union Pacific Causeway, excluding all of the Farmington Bay south of the Antelope
Island Causeway and salt evaporation ponds.
Beneficial Uses -- Protected for frequent primary and secondary contact recreation, waterfowl, shore birds and other water-oriented wildlife including their necessary food chain.
Class 5E Transitional Waters along the Shoreline of the Great Salt Lake Geographical Boundary –
Geographical Boundary -- All waters below approximately 4,208-foot elevation to the current lake elevation of the open water of the Great Salt Lake receiving their source water from
naturally occurring springs and streams, impounded wetlands, or facilities requiring a UPDES permit. The geographical areas of these transitional waters change corresponding to the fluctuation
of open water elevation.
Beneficial Uses -- Protected for infrequent primary and secondary contact recreation, waterfowl, shore birds and other water-oriented wildlife including their necessary food chain.
TOTAL MAXIMUM DAILY LOAD (TMDL) REQUIREMENTS
There are no TMDL considerations.
BASIS FOR EFFLUENT LIMITATIONS
Effluent limits are based on the more restrictive of protecting the uses (Level I antidegradation review UAC R313-2-3.5) or categorical limits for the specific industry and process.
Effluent limits to protect the uses, called water quality-based effluent limits, are based on numeric criteria (UAC R317-2-14) and the Narrative Standards (UAC R317-2-7). No numeric
criteria have been established for the Transitional Waters. No numeric water criteria have been established for Gilbert Bay with the exception of selenium.
No water quality-based effluent limits are required because the discharge does not have reasonable potential to cause or contribute to an exceedance of a water quality standard. This
conclusion is based on previous monitoring and the fact that the contents of the bitterns came from the lake and nothing is added.
Morton's effluent is subject to the Code of Federal Regulations (CFR) Title 40, 436.120 (Subpart L - Salines from Brine Lakes Subcategory) and 40 CFR 415.160 (Subpart P - Sodium Chloride
Production Subcategory) categorical effluent limits. These regulations pertain to the production of sodium chloride via solar evaporation and establish effluent limits and standards.
Under the regulations, no process wastewater pollutants may be discharged into navigable waters; however, unused bitterns may be returned to the body of water from which the process
brine solution was originally withdrawn. In 40 CFR 436, the “no discharge of process waste water pollutants into navigable waters” shall be applied on a net basis if the discharge complies
with 125.28 of that chapter. In 40 CFR 415.160, bitterns can be returned to the body of water from which the process brine solution was originally withdrawn provided no additional pollutants

are added to the bitterns during the production of sodium chloride. 40 CFR 415.160 is more stringent and will apply to Morton; i.e., Morton will be allowed to discharge their concentrated
bitterns back to the Great Salt Lake, provided no additional pollutants are added during the production of sodium chloride.
Based on UAC R317-1-3.2C, pH must remain in the range of 6.5 to 9.0 standard units. Because oil and grease sources are present in the processing and shipping areas, the potential exists
for their addition to process water. Thus, oil and grease concentrations will be limited to 10 mg/L (based on best professional judgment [BPJ]).
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. Since the facility is prohibited from discharging process wastewater pollutants into navigable waters and there
are no numeric water quality standards for the Great Salt Lake, the facility has is no reasonable potential to violate state water quality standards.
The permit limitations are
Parameter
Effluent Limitations
30 Day Average
Daily Minimum
Daily Maximum
Flow (MGD)
Report
NA
Report
Oil & Grease, mg/L
NA
NA
10.0
pH, Standard Units
NA
6.5
9.0
NA – Not Applicable
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/ b/ c/
Parameter
Frequency
Sample Type
Units
Total Flow d/ e/
Daily
Measured
MGD
Oil & Grease f/
Monthly
Visual/Grab
mg/L
pH
Monthly
Grab
SU
a/This discharge shall contain only materials originally present in the Great Salt Lake waters or other intake waters. The permittee shall add nothing to the effluent prior to discharging.
b/There shall be no visible sheen or floating solids or visible foam in other than trace amounts.
c/There shall be no discharge of sanitary wastes.
d/Flow measurements shall be made in such a manner that the permittee can affirmatively demonstrate that representative values are being obtained.
e/If the rate of discharge is controlled, the rate and duration of discharge shall be reported.
f/A sample for oil & grease shall be taken if a visual sheen is observed. If a sample is taken because a sheen is observed, it shall not exceed a daily maximum concentration of 10 mg/L.
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, this facility does not receive, generate, treat
or dispose of biosolids. Therefore 40 C.F.R. § 503 shall not apply.
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 may be required based on the Standard Industrial Classification (SIC)

code for the facility and the types of industrial activities occurring. 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. If the facility is not already covered, it has 30 days from when this permit is issued to submit the appropriate Notice of Intent (NOI) for the MSGP or exclusion documentation.
Previously storm water discharge requirements and coverage were combined in this individual permit. These have been separated to provide consistency among permittees, electronic reporting
for storm water discharge monitoring reports, and increase flexibility to changing site conditions.
Permit coverage under the Construction General Storm Water Permit (CGP) is required for any construction at the facility which disturban acre or more, or is part of a common plan of
development or sale thatis an acre or greater. A Notice of Intent (NOI) is required to obtain a construction storm water permit prior to the period of construction.
Information onstorm 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.Morton is a minor industrial facility that discharges bitterns
taken directly from the Great Salt Lake, in which no chemicals or other pollutants are introduced, thus returning any residual materials back to the highly saline Great Salt Lake.
Based upon these facts, the permitting authority’s BPJ, and that the anticipated discharges are of relatively small volumes of effluent when compared to the existing water body of the
Great Salt Lake, there is no reasonable potential for toxicity in Morton’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 byLonnie Shull, Discharge Permit Writer, Biomonitoring, Reasonable
Potential AnalysisDaniel Griffin, BiosolidsJennifer Robinson, PretreatmentJordan Bryant, Storm WaterJames Harris, TMDL/Watershed ProtectionSuzan Tahir, Wasteload Analysis/ADRUtah Division
of Water Quality, [phone]PUBLIC 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 FSSOBDuring 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).
This Page Intentionally Left Blank
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
This Page Intentionally Left Blank
ATTACHMENT 2
Effluent Monitoring Data
This Page Intentionally Left BlankEffluent Monitoring Data.

Flow
pH
O & G
TRC
E. coli
BOD5
TSS
Month
Ave
Max
Min
Max
Max
Max
Acute
Chronic
Ave
Max
Ave
Max
Jan-13
18.8
20.2
7.5
7.7
1.7
1.2
10
6
5
6
7
8
Feb-13
21.3
22.9
7.6
7.7
1.7
1.1
13
8
7
9

7
7
Mar-13
24.3
28.6
7.5
7.7
1.7
1.1
11
9
17
21
7
9
Apr-13
20.2
21.2
7.5
7.7
1.7
1.2
20
12
19
21
7
8
May-13
21.4
25.5
7.4
7.6
1.7
1.3
9
7
18
21
10
11
Jun-13
20.5
22.1
7.5
7.7
1.4
1
12
7
18
21
11
14
Jul-13
20.2
22.3
7.4
7.7
1.4

1.3
10
8
10
11
14
16
Aug-13
19.6
20.8
7.5
7.6
1.4
1.2
13
7
8
10
8
9
Sep-13
20
21.8
7.6
7.8
1.4
1.1
78
15
11
12
8
9
Oct-13
17.9
19
7.5
7.7
1.7
0.9
11
8
9
11
8
8
Nov-13
17.2
18.1
7.5
7.7
1.7
0.9
10
8
9
10
8
10
Dec-13

17.2
20.4
7.2
7.6
1.4
1.2
10
12
9
10
10
18
Jan-14
17.5
19.9
7.3
7.5
1.4
0.8
29
6
7
8
8
9
Feb-14
20.3
22.6
7.4
7.6
1.4
1
43
19
8
10
8
8
Mar-14
20.8
27.4
7.4
7.7
1.7
1
30
10
7
8
9
10
Apr-14
19.1
21.2
7.4
7.6
1.4
1.5
8
6

8
9
9
10
May-14
20.2
22.7
7.4
7.5
1.4
1.3
9
6
7
9
8
10
Jun-14
20.6
23
7.5
7.6
1.4
1
16
8
8
10
8
9
Jul-14
20.5
22.3
7.5
7.8
1.4
1.5
10
7
9
10
12
13
Aug-14
21
21.9
7.6
7.7
1.2
1.3
17
14
8
9
9
10
Sep-14
20.2
23.2
7.5

7.7
1.4
1.1
12
8
7
8
8
13
Oct-14
18.2
20.9
7.5
7.6
1.4
1.1
7
5
6
8
9
10
Nov-14
16.6
17.7
7.4
7.6
1.4
1.7
8
6
7
9
14
23
Dec-14
16.9
19.3
7.4
8.9
1.4
1.2
34
8
6
10
11
23
Jan-15
18.1
19.8
7.5
7.6
1.4
0.9
10
6
7
8
10

11
Feb-15
17.8
18.7
7.3
7.5
1.4
1
7
6
5
6
9
10
Mar-15
17.6
18.6
7.3
7.5
1.4
1.3
5
5
5
6
7
8
Apr-15
18.1
22.3
7.2
7.6
1.4
1
7
6
7
8
11
11
May-15
22.5
31.9
7.5
7.6
2
1.1
10
6
7
9
13
16
Jun-15
20.2
22.5
7.5
7.6
1.6
1.3

8
6
6
6
9
10
Jul-15
19.7
21.8
7.5
7.7
1.4
1.5
12
9
5
6
11
11
Aug-15
20.7
22.6
7.5
7.7
1.4
1.1
9
5
5
6
7
13
Sep-15
20.1
23.5
7.6
7.7
1.4
1.1
7
5
5
6
8
10
Oct-15
18.1
20.3
7.5
7.6
1.4
1
12
8
5
6
11
13
Nov-15
16.9

18.3
7.1
7.6
1.4
1.3
11
8
4
6
6
7
Dec-15
18.1
21.6
7.4
7.6
2.63
0.9
8
5
7
8
8
8WET Results
Month
WET Test
Pass / Fail
Mar-13
48Hr Acute Ceriodaphnia
Pass
Mar-13
96Hr Acute Pimephales Promelas
NA
Jun-13
48Hr Acute Ceriodaphnia
NA
Jun-13
96Hr Acute Pimephales Promelas
Pass
Sep-13
48Hr Acute Ceriodaphnia
Pass
Sep-13
96Hr Acute Pimephales Promelas
NA
Dec-13
48Hr Acute Ceriodaphnia
NA
Dec-13
96Hr Acute Pimephales Promelas
Pass
Mar-14
48Hr Acute Ceriodaphnia
Pass
Mar-14
96Hr Acute Pimephales Promelas
NA
Jun-14
48Hr Acute Ceriodaphnia
Pass

Jun-14
96Hr Acute Pimephales Promelas
NA
Sep-14
48Hr Acute Ceriodaphnia
Pass
Sep-14
96Hr Acute Pimephales Promelas
NA
Dec-14
48Hr Acute Ceriodaphnia
NA
Dec-14
96Hr Acute Pimephales Promelas
Pass
Mar-15
48Hr Acute Ceriodaphnia
Pass
Mar-15
96Hr Acute Pimephales Promelas
NA
Jun-15
48Hr Acute Ceriodaphnia
NA
Jun-15
96Hr Acute Pimephales Promelas
Pass
Sep-15
48Hr Acute Ceriodaphnia
Pass
Sep-15
96Hr Acute Pimephales Promelas
NA
Dec-15
48Hr Acute Ceriodaphnia
NA
Dec-15
96Hr Acute Pimephales Promelas
Pass
ATTACHMENT 3
Wasteload Analysis
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.
(REASONABLE POTENTIAL LANGUAGE )Initial screening for metals values that were submitted through the discharge monitoring reports showed that a closer look at some of the metals is needed.
A copy of the initial screening is included in the “Effluent Metals and RP Screening Results” table in this attachment. The initial screening check for metals showed that the full model
needed to be run on (List Metals).(Outcome A Use as a guide for as many metals as required)
The RP model was run on (metal) using the most recent data back through (Year). This resulted in XXdata points and that there is a Reasonable Potential for an acute limit for (metal).
Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YYdata points (delete is no more data provided).The
EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If
not Outliers found use (This identified no outliers in the data set.))

The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is (acute and/or chronic)RP at
95% confidence, and there is (acute and/or chronic)RP at 99% Confidence. This result indicates that the inclusion of an effluent limit for (metal) is required at this time.(Outcome
A from Reasonable Potential Guide)
(Outcome BUse as a guide for as many metals as required
The RP model was run on (metal) using the most recent data back through (Year). This resulted in XX data points and that there is a Reasonable Potential for an acute limit for (metal).
Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YY data points (delete is no more data provided).The
EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If
not Outliers found use (This identified no outliers in the data set.))
The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is not(acute and/or chronic)RP
at 95% confidence, and there is (acute and/or chronic)RP at 99% Confidence. This result indicates that the inclusion of an effluent limit for (metal) is not required at this time, but
routine monitoring requirements will be added or increased in the permit.(Outcome B from Reasonable Potential Guide)
(Outcome C Use as a guide for as many metals as required)
The RP model was run on (metal) using the most recent data back through (Year). This resulted in XX data points and that there is a Reasonable Potential for an acute limit for (metal).
Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YY data points (delete is no more data provided).The
EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If
not Outliers found use (This identified no outliers in the data set.))
The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is not(acute and/or chronic)RP
at 95% confidence, and there is not (acute and/or chronic)RP at 99% Confidence. This result indicates that the inclusion of an effluent limit for (metal) is not required at this time,
and that routine monitoring requirements can be added or increased in the permit.(Outcome C from Reasonable Potential Guide)
(Outcome D Use as a guide for as many metals as required)
The RP model was run on (metal) using the most recent data back through (Year). This resulted in XX data points and that there is a Reasonable Potential for an acute limit for (metal).
Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YY data points (delete is no more data provided).The
EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If
not Outliers found use (This identified no outliers in the data set.))
The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is not(acute and/or chronic)RP
at 95% confidence, and there is not (acute and/or chronic)RP at 99% Confidence. This result indicates that there is no requirement to include an effluent limit for (metal) or routine
monitoring in the permit.(Outcome D from Reasonable Potential Guide)
The RP model was run on Selenium using the most recent data back through 2009. This resulted in 19 data points and that there is a Reasonable Potential for an acute limit for Selenium.
Reviewing the data showed that there could be at least one outlier in the data, more data was provided, back through 2006 for a total of 40 data points, and the EPA ProUCL model was
used to evaluate the data. This produced the same outlier for both 19 and 40 data points. This outlier was from the summer of 2011 (0.007 mg/L).
The value was excluded from the data set and RP was rerun. As a result, no effluent limit for Selenium will be included. (Outcome C from RP Guide)
A Summary of the RP Model inputs and outputs are included in the following tables. Initial screening for metals values that were submitted through the discharge monitoring reports showed
that a closer look at some of the metals is not needed.
(NO REASONABLE POTENTIAL LANGUAGE)Initial screening for metals values that were submitted through the discharge monitoring reports showed that a closer look at some of the metals is
not needed.
(Include as needed)
A Summary of the RP Model inputs and outputs are included in the following table.
The Metals Initial Screening Table and RP Outputs Table are included in this attachment.RP input/output summary
RP Procedure Output
Outfall Number:
XXX
Data Units
mg/L
Parameter
metal
metal
Distribution
(Distribution)
(Distribution)
Reporting Limit
(0.0xx)
(0.0xx)
Significant Figures
x
x
Maximum Reported Effluent Conc.
x.xxx
x.xxx
Coefficient of Variation (CV)
x.xxx

x.xxx
Acute Criterion
x.xxx
x.xxx
Chronic Criterion
x.xxx
x.xxx
Confidence Interval
95
99
95
99

Projected Maximum Effluent Conc. (MEC)
x.xxx
x.xxx
x.xxx
x.xxx

RP Multiplier
X.XX
X.XX
X.XX
X.XX

RP for Acute?
YES/NO
YES/NO
YES/NO
YES/NO

RP for Chronic?
YES/NO
YES/NO
YES/NO
YES/NO

Outcome
(A,B,C,D)
(A,B,C,D)
  Metals Monitoring and RP Check
Effluent
Metal
Cyanide
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Silver
Zinc
Molybdenum
Selenium
Mercury
ARP Val
0.0052
0.34
0.0054
0.016

0.0332
0.262
1.019
0.0183
0.26
1
0.0184
0.0024
CRP Val
0.022
0.15
0.00053
0.011
0.0204
0.0102
0.113
1
0.26
1
0.0046
0.000012
Metals, mg/L
0.0097
0.0096
NR
NR
0.011
0.00025
0.00822
0.00004
0.021
0.00395
0.00083
2.4E-06
0.0092
0.0096
0.000035
0
0.0105
0.000179
0.00822
0.000026
0.0203
0.00395
0.000426
2.4E-06
0.0092
0.0096
0.000035
ND
0.0105
0.000192
0.00822
0.00003
0.0203
0.00395
0.000754
1.3E-06
0.0103
0.0096

0.000041
ND
0.0105
0.000192
0.0159
0.000062
0.0341
ND
0.00106
0.000003
0.0103
0.00803
0.000041
ND
0.0106
0.000244
0.0159
0.000062
0.0341
ND
0.000754
0.000003
0.0119
0.00875
0.000041
ND
0.0121
0.000326
0.0159
0.000062
0.0341
ND
0.000754
4.2E-06
0.0093
0.0095
0
0.000226
0.00569
0
0.00737
0
0.0113
0.00355
0.000356
0
0.0086
0.00972
ND
0.0011
0.0127
0.000374
0.00227
ND
0.0166
0.00468
0.000627
ND
0.0055
0.0126

0.000127
0.00108
0.00823
0.000262
0.00203
0.000203
0.0199
0.00453
0.00084
0.000158
0.0093
0.0126
0.000127
0.0011
0.0127
0.000374
0.00737
0.000203
0.0199
0.00468
0.00084
5.3E-06
0.0086
0.0126
0.000127
0.0011
0.0127
0.000374
0.00626
0.000203
0.0199
0.00468
0.00084
ND
0.0084
0.0085
ND
ND
0.00818
ND
0.0067
ND
0.0137
0.0037
ND
0.000002
0.0085
0.00567
ND
0.001
0.00805
ND
0.00189
ND
0.0287
0.00313
ND
2.3E-06
0.0101
0.00714

ND
0.000921
0.00818
ND
0.00654
ND
0.0213
0.00301
ND
ND
ND
0.0089
ND
0.0007
0.0045
ND
0.0054
ND
0.01
0.003
0.0014
ND
ND
0.0081
ND
ND
0.00395
ND
0.00146
2.62E-05
0.0155
0.00315
0.000364
1.9E-06
0.00426
0.00537
ND
ND
0.00578
ND
0.00246
2.93E-05
0.0421
0.00935
0.00036
ND
ND
0.489
0.000444
0.00431
0.00206
0.000941
0.000941
6.97E-05
0.0163
0.00272
0.000441
1.41E-05
0.0138
0.00911

ND
ND
0.00477
ND
0.00204
3.91E-05
0.0298
0.00339
0.000411
ND
0.00557
0.00704
ND
ND
0.00596
ND
0.00166
ND
0.0137
0.00328
0.000301
1.5E-06
ND Value
0
0
0
0
0
0
0
0
0
0
0
0
Max
0.0138
0.489
0.000444
0.00431
0.0127
0.000941
0.0159
0.000203
0.0421
0.00935
0.0014
0.000158
A RP?
YES
YES
No
No
No
No
No
No
No
No
No

No
C RP?
YES
YES
YES
No
YES
No
No
No
No
No
No
YES
This Page Intentionally Left Blank
(Metal)RP Results
RP Procedure Output

Effluent Data
Facility Name:
(Facility Name)

#

#

#

Permit Number:
(permit number)

1
41
81
Outfall Number:
001

2
42
82
Parameter
(metal)

3
43
83
Distribution
(distribution)
4
44
84
Data Units
mg/L

5
45
85
Reporting Limit
(x.xxx)

6
46
86
Significant Figures
X

7
47
87
Confidence Interval
95

8
48
88

9
49
89
Maximum Reported Effluent Conc.
(X.XXX)
mg/L
10
50
90
Coefficient of Variation (CV)
(X.XXX)

11
51
91
RP Multiplier
(X.XXX)

12
52
92
Projected Maximum Effluent Conc. (MEC)
(X.XXX)
mg/L
13
53
93

14
54
94
Acute Criterion
(X.XXX)
0
15
55
95
Chronic Criterion
(X.XXX)
0
16

56
96
Human Health Criterion
NA
0
17
57
97

18
58
98
RP for Acute?
(NO/YES)

19
59
99
RP for Chronic?
(NO/YES)

20
60
100
RP for Human Health?
N/A

21
61
101
22
62
102
Confidence Interval
99
23
63
103

24
64
104
Maximum Reported Effluent Conc.
(X.XXX)
25
65
105
Coefficient of Variation (CV)
(X.XXX)
26
66
106
RP Multiplier
(X.XXX)
27
67
107
Projected Maximum Effluent Conc. (MEC)
(X.XXX)

28
68
108

29
69
109
Acute Criterion
(X.XXX)

30
70
110
Chronic Criterion
(X.XXX)

31
71
111
Human Health Criterion
NA

32
72
112

33
73
113
RP for Acute?
(NO/YES)

34
74
114
RP for Chronic?
(NO/YES)

35
75
115
RP for Human Health?
N/A

36
76
116

37
77
117

38
78
118

39

79
119

40
80
120