HomeMy WebLinkAboutDWQ-2024-000139Official 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 AND STATEMENT OF BASIS
SALT LAKE CROSSING
PERMIT: DISCHARGE
UPDES PERMIT NUMBER: UT0026255
MINOR INDUSTRIAL
FACILITY CONTACTSPermittee:Salt Lake CrossingContact:Sean O’ConnorPosition: Construction ManagerPhone Number:(970)-623-1026Project Name:Salt Lake CrossingMailing and Facility Address:205
North 400 West, Suite 300Salt Lake City, UT 84103Telephone:(970)-623-1026
Physical Location:470 West 200 NorthSalt Lake City, UT 84103
DESCRIPTION OF FACILITY
Currently the site is under construction for a multi-unit residential apartment complex with asub-grade parking structure. Due to interaction with groundwater the parking strcuture will
require groundwater dewatering during and afterconstruction.
SUMMARY OF CHANGES FROM PREVIOUS PERMITThis facility previously had a Treated Groundwater and Surface Water General Permit with the UPDES permit number of UTG790096. Giventhe total flow
from the facility, the length of time of the project (in excess of 1 year), and the nature of the water being discharged (Total Dissolved Solids in excess of what the General Permit
allows), the facility is being transitioned to an individual permit.
DISCHARGE
DESCRIPTION OF DISCHARGE
The facility has been required to report self-monitoring results on Discharge Monitoring Reports on a monthly basis since the permit was obtained in November of 2022. Outfall NumberLocation
of Discharge Outfall 001001Located at latitude 40 48 ' 21.0996" N and longitude 111 55’ 39.108" W. Groundwater discharge to the Salt Lake City Stormwater System that drainto the
Northwest Canal.
RECEIVING WATERS AND STREAM CLASSIFICATION
If a discharge were to occur, it would be pumped into adrainage ditch and then to the Northwest Drain,which is Class 2B, 3E, and 5Daccording to UAC R317-2-13.
Class 2B -- Protected for infrequent primary contact recreation. Also protected for secondary contact recreation where there is a low likelihood of ingestion of water or a low degree
of bodily contact with the water. Examples include, but are not limited to, wading, hunting, and fishing.
Class 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
The majority of the limitations in this permit are based primarily upon the limitations found in the General Permit for Treated Groundwater and Surface WaterPermit Number UTG790000,
with a few exceptions. As mentioned above, this facility applied for and was issued coverage under the Treated Groundwater and Surface Water General Permit. However, it was found that
due to several factors, primarily the length of the project, and the projected flow rates of all outfalls when summed in excess of 1 MGD, the facility was not eligible for that permit.
It is, therefore, being transitioned to an individual permit. The effluent limits for the following pollutantsare basedon the General Permit for treated ground water; lead, benzene,
BTEX, MTBE, naphthalene, Total Toxic Organics (TTO), Individual Toxic Organics, Total Petroleum Hydrocarbon (TPH) GRO, TPH-DRO, and Toxic Metals.
Several of the individual constituents of petroleum fuels will also be included in the permit effluent limitations. Benzene, toluene, ethylbenzene, and naphthalene are included because
they are the components of gasoline that have been identified as toxic pollutants in the Clean Water Act. Xylene is included because it is one of the contaminants of concern to be regulated
under the Safe Drinking Water Act of 1986. EPA has developed a model NPDES permit for discharges resulting from the cleanup of gasoline released from USTs. The model permit provides
effluent limitations for surface water discharges from corrective actions at gasoline UST sites. The limits are based on the characterization of constituents commonly found in gasoline.
The permit was developed to assist permitting authorities by recommending specific effluent limitations, standard conditions, and special conditions for inclusion in all NPDES permits
for discharges from these sites. Of the aromatics known to be present in gasoline and diesel fuels, the ones that are listed as hazardous substances and/or priority toxics include naphthalene.
Naphthalene has been present in detectable concentration in the effluent of greater than 10% of historic projects. Naphthalene’s effluent limitation is based on BPJ and is the same as
in the previous permit. Benzene, for which the EPA Office of Drinking Water has issued a health advisory, is a known human carcinogen. The EPA has set the Maximum Contaminant Level
(MCL) for benzene in drinking water at 0.005 mg/L. In addition, EPA’s model permit recommends an effluent limitation of 0.005 mg/L. The effluent limit for Benzene in this renewal permit
is the same as in the previous permit. The aggregate BTEX parameter’s effluent limitation will be set equal to EPA’s model permit at 0.1 mg/L and is the same as in the previous permit.
MTBE is included as a pollutant of concern with the effluent limitation based on BPJ and is the same as in the previous permit.
Total Toxic Organics chemicals are the primary sources of concern at cleanup sites. However, many of the toxic organics may be found in contaminated ground and surface water. They
are often used as solvents or as oil additives to extend the useful life of oils. Although there are variations of toxicity among the toxic organic pollutants, a number are known carcinogens
and many pose significant environmental hazards. Since there are potential adverse effects associated with these organics, they must also be addressed. The control of toxic organics
will be achieved in this permit by setting an effluent limit for total toxic organics (TTO). TTO is defined as the sum of the concentrations of the specific toxic organic compounds
(listed in Table B of the NOI) found in the wastewater discharge. All permittees are required to do an initial screening for all of the priority toxics prior to NOI submittal (see Table
B of the NOI for a full list of the TTOs). From then on, only those organics that were detected in concentrations equal to or greater than 0.25 times (or, 25%) the numeric criteria in
R317-2-14, in the initial influent screening are required to be analyzed for during discharge. The maximum daily effluent limitation for TTO is 2.0 mg/L and is the same as in the previous
permit. This is similar to the EPA pretreatment standards for TTO in several industries in which toxic organics are a concern, such as the “Electroplating and Metal Finishing” and the
“Electrical and Electronic Components” categories. Organics generally have a higher solubility in hydrocarbons than in water and are therefore present in highest concentrations in the
oily waste stream of the wastewater. Since the treatment systems employed in these cleanup projects are designed to remove the waste oil, they should sufficiently reduce organic chemicals
as well. For receiving waters which do not have designated use Class 1C Drinking Water, Total Petroleum Hydrocarbon (TPH) analyses may be substituted for the TTO analyses upon approval
from the Director. It is the permittee’s responsibility to petition the Director. The Director may then approve, partially approve, or deny the request based on all available information.
If approval is given, the modification will take place without a public notice.
In August 2020, the Utah Division of Water Quality amended the secondary treatment requirements found in UAC R317-1-3. That rule change made the secondary treatment standards applicable
only to Publicly Owned Treatment Works (POTW). As a result of that change, Utah secondary treatment standards for Biological Oxygen Demand (BOD) and Total Suspended Solids (TSS) do not
automatically apply to industrial facilities, unless otherwise required by their effluent limitation guidelines. Since this facility is not classified as a POTW, and there are no controlling
effluent limitation guidelines (ELG) for this activity, neither Utah secondary treatment standards nor ELG limits for BOD and TSS apply at this time. However, the daily TSS limit of
70 mg/L will remain to align the permit with the Treated Groundwater and Surface Water General Permit (UTG790000) and based on Best Professional Judgement (BPJ). The oil and grease
are based on best professional judgment (BPJ). Flow is based on reported values.
The absence of discharge limitations for Total dissolved solids (TDS) are based upon the use classification for the receiving waters and the lack of effluent limitation guidelines for
the facility. Both the Northwest Drain and the Oil Drain Canal are listed as 2B, 3E. There are no agricultural uses (Class 4) for either of these waters. Since only Class 4 waters have
limits for TDS, no TDS limitations will be included in this individual permit. However, this permit will require monitoring and reporting of TDS.
Based upon the limitations set forth in the permit, it has been determined that this discharge will not cause a violation of water quality standards. An Antidegradation Level II review
wascompleted as part of this permitting process.
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 not conducted
following DWQ’s September 10, 2015 Reasonable Potential Analysis Guidance (RP Guidance) because there is inadequate data for use in RP. As a result, monitoring for metals will be included
in this permit. The additional monitoring will help establish a record of the presence or absence of each pollutant. Monitoring for metals will be required at a monthly frequency. See
below for details.
The permit limitations are:
Parameter
Effluent Limitations *a
Maximum Monthly Avg
Maximum Weekly Avg
Daily Minimum
Daily Maximum
Total Flow, MGD *b *c *d
0.012
--
--
0.024
TSS, mg/L
--
--
--
70
pH, Standard Units
--
--
6.5
9
Oil & Grease, mg/L *e
--
--
--
10
Total Recoverable Lead, µg/L *f
--
--
--
5.0
Benzene, µg/L
--
--
--
5.0
BTEX, mg/L *g
--
--
--
0.1
MTBE, mg/L
--
--
--
0.2
Naphthalene, mg/L
--
--
--
0.7
Total Toxic Organics (TTO) *h
--
--
--
2.0
Individual Toxic Organics
--
----
*g
Total Petroleum Hydrocarbon (TPH) GRO, mg/L *i
--
--
--
1.0
TPH-DRO, mg/L *i
--
--
--
1.0
Toxic Metals, µg/L *j
--
--
--
Report
Total Dissolved Solids (TDS), mg/L
--
--
--
Report
SELF-MONITORING AND REPORTING REQUIREMENTSThe permit will require 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 must be submitted using NetDMR unless the permittee has successfully petitioned for an exception.
Lab sheets for metals and toxic organics must be attached to the DMRs.
Self-Monitoring and Reporting Requirements
Parameter
Frequency
Sample Type
Units
Total Flow
Continuous
Recorder/ Measured
MGD
pH, Standard Units
2x/Monthly
Grab
mg/L
TSS
Monthly
Grab
mg/L
Total Recoverable Lead
Monthly
Grab
mg/L
Oil & Grease
Monthly
Grab
mg/L
Benzene
2x/Monthly
Grab
mg/L
BTEX
2x/Monthly
Grab
mg/L
MTBE
2x/Monthly
Grab
mg/L
Naphthalene
Monthly
Grab
mg/L
Total Toxic Organics (TTO)
Monthly
Grab
mg/L
Individual Toxic Organics
Monthly
Grab
mg/L
Total Petroleum Hydrocarbon (TPH) GRO
Monthly
Grab
mg/L
TPH-DRO
Monthly
Grab
mg/L
Toxic Metals
Monthly
Grab
mg/L
TDS
Monthly
Grab
mg/L*aSee Definitions, Part VIII, for the definition of terms.*bFlow measurements of influent/effluent volume shall be made in such a manner that the permittee can affirmatively demonstrate
that representative values are being obtained.*cIf the rate of discharge is controlled, the rate and duration of discharge shall be reported.*dThe Maximum monthly Average and Daily Maximum
Flow Rates are the sum of all outfalls.
*eOil & Grease sampled when sheen is present or visible. If no sheen is present or visible, report NA.
*fThe freshwater benchmarks values of some metals are dependent on water hardness. These effluent limits have been calculated using an assumption of 25mg/l CaCO3 hardness.
*gBTEX shall be measured as the sum of benzene, ethylbenzene, toluene, and xylenes.
*hThose toxic organics that were detected in concentrations equal to or greater than 0.25 times (or, 25%) the numeric criteria in R317-2-14, or if no numeric criterial exists in R317-2-14,
0.25 times (or 25%) the drinking water MCL as defined by EPA, in the initial TTO influent screening will be required to be analyzed for during discharge. Toxic organics detected in
concentrations equal to or greater than 0.25 times (or, 25%) the numeric criteria in R317-2-14 or the MCL shall have effluent discharge limitations in as defined in R317-2-14, or, if
no numeric criteria exist in R317-2-14, the MCL as defined by EPA will be the limit. Individual toxic organics required to be monitored and analyzed on a monthly basis, will be specified
in the DWQ section of the NOI upon permit issuance.
*iTPH-GRO and TPH-DRO analyses may be substituted for the TTO analyses upon approval from DWQ. Maximum daily effluent limitations of 1.0 mg/L TPH-GRO and TPH-DRO will be substituted
for the TTO effluent limitation. It is the permittee’s responsibility to petition the Director. Ongoing treatment systems will be required to conduct at least one TTO analysis per permit
cycle. The Director may then approve, partially approve, or deny the request based on all available information. If approval is given, the modification will take place without a public
notice.*jThe toxic metals to be sampled include the following: Total Recoverable Aluminum, Total Arsenic, Total Cadmium, Total Chromium, Total Copper, Total Mercury, Total Nickel, Total
Silver and Total Zinc.
BIOSOLIDS
The State of Utah has adopted the 40 CFR Part 503 federal regulations for the disposal of sewage sludge (biosolids) by reference. However, since this facility is a dewatering project,
there is no sludge production. Therefore 40 CFR Part 503 does not apply at this time.
STORM WATER
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. 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
Any process wastewater that the permittee discharges to a Publicly Owned Treatment Works (POTW), either as a direct discharge or as a hauled waste, is subject to federal, state, and
local pretreatment 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 CFR 403, the pretreatment requirements found in UAC R317-8-8, and any specific local discharge limitations, Pretreatment Standards or Pretreatment Requirements developed by the
POTW accepting the waste or required by 40 CFR 403 or R317-8.
In addition, in accordance with 40 CFR 403.12(p)(1), the permittee must notify the POTW, the EPA Regional Waste Management Director, and the State hazardous waste authorities, in writing,
if they discharge any substance into a POTW which if otherwise disposed of would be considered a hazardous waste under 40 CFR 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 a minor industrial facility that will be discharging an infrequent amount of effluent, in which toxicity is neither an existing concern, nor likely to be present. Additionally,
the receivingwatersare listed as Class 3DE, severely habitat-limited waters. 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 byLonnie Shull, Discharge Permit Writer, BiomonitoringDaniel Griffin,BiosolidsJennifer
Robinson, PretreatmentJeanne Riley, StormwaterBen Holcomb, Wasteload AnalysisUtah Division of Water Quality, (801) 536-4300PUBLIC NOTICEBegan: Month Day, YearEnded: Month Day, YearComments
will be received at: 195 North 1950 West PO Box 144870 Salt Lake City, UT 84114-4870The Public Noticed of the draft permit was published on the DWQ webpage. During the public comment
period provided under 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 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 were not considered Major and the permit is not required to be re Public Noticed.Responsiveness Summary(Explain any comments received and response sent.
Actual letters can be referenced, but not required to be included).
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