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Home My WebLink AboutDWQ-2024-000480Official 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 BASISWATERLEAF RESOURCES NEW PERMIT: DISCHARGE UPDES PERMIT NUMBER: UT0026280 MINOR INDUSTRIAL FACILITY CONTACTSPerson Name:Tom WilsonPosition:President, Chief Development OfficerPerson Name:Tom Bence, PE, DLEPosition:Project ManagerPhone Number:(248) 497-2883Email: thomas.bence@lilacsolutions.comFacility Name:Waterleaf Great Salt Lake Lithium ProjectMailing and Facility Address:9350 South 150 East, Suite 710Sandy, Utah 84070Telephone:(248) 497-2883 Actual Address:Western Slope Promontory Mountains Unincorporated Box Elder Co. DESCRIPTION OF FACILITY Waterleaf Resources intends to extract lithium from Gunnison Bay, GSL. The master plan will have a Demonstration Plant,Commercial Plant phase 1 and phase 2. The Demonstration Plant is a temporary facility,which will be demobilized after initial testingis completed, and is anticipated to last 9 months. The demonstration plant will operate to validate the ion-exchange technology I(Lilac's IX design basis) and optimize process conditions specific to Gunnison Bay brine and demonstrate stable conditions over anextended operating period. The product (Lithium Carbonate Extract) will be shipped off-site and evaluated for potentialcommercial-scale operations. The Commercial Plant will be designed and constructed with new locations for the intake and outfall,based on the information gathered from the Demonstration Plant and have significantly larger flow rates. DISCHARGE DESCRIPTION OF DISCHARGE FACILITY is a total reuse facility. FACILITY maintains a UPDES permit in the event that a discharge from their facility is necessary. FACILITY has been reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis. FACILITY discharged for 3 days in 2005 during a previous permit cycle. There have been no violations or discharges since 2005.Outfall Number(s)Location of Discharge Outfall(s)001Discharge to the Great Salt Lake, Gunnison BayLocated at latitude 41 26' 44.16" and longitude 112 41' 36.04". RECEIVING WATERS AND STREAM CLASSIFICATION If a discharge were to occur, it would be pumpedinto an irrigation ditch, which is a Class XX according to Utah Administrative Code (UAC) R317-2-13: Class 5 -- The Great Salt Lake. Class 5B Gunnison Bay Geographical Boundary -- All open waters at or below approximately 4,208-foot elevation north of the Union Pacific Causeway and west of the Promontory Mountains, 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. TOTAL MAXIUM DAILY LOAD (TMDL) REQUIREMENTS There are no TMDL requirements for this discharge location. BASIS FOR EFFLUENT LIMITATIONS No numeric water quality standards have been established for the Great Salt Lake with the exception of Selenium in Gilbert Bay. Since this facility does not discharge to Gilbert Bay, the Selenium standards do not apply to this discharge. Federal effluent limitation guidelines (ELG’s) for lithium mining are found in 40 CFR 436 Subpart U Lithium Subcategory.However, at the present time, no federal regulations have been promulgated for this subcategory and the federal regulations are silent with regards to ELGs and lithium mining. Therefore, we are forced to look for allied ELGs that might be applied to this discharge and apply them using best professional judgement. Regulations contained in 40 CFR 436 Subpart L (Mineral, Mining and Processing Point Source Category - Subpart L - Saline from Brine lake Subcategory) are applicable to discharges from facilities that conduct salt evaporation, washing and mineral return activities on saline lakes. The primary salts extracted from the Great Salt Lake are Sodium Chloride, Potassium Chloride and Sulfate of Potash. Since lithium is an alkali salt and has similar chemical qualities to sodium, potassium and other alkali salts mined from the Great Salt Lake it seems reasonable to use this ELG in lieu of 40 CFR 436 Subpart U until regulations are promulgate for this subpart. 40 CFR 436 Subpart L instructs that there should be no discharge of process waste water pollutants into navigable waters, and that this shall be applied on a net basis if the source of the permittees water supply is the same body of water into which the discharge is made. Therefore, 40 CFR 436 Subpart L will apply to Outfall 001 for the activities related to lithium extraction. Dissolved oxygen and pH limits are based on best professional judgement and are derived from current Utah Secondary Treatment Standards, UAC R317-1-3.2. The oil and grease is based on best professional judgment (BPJ). Attached is a Wasteload Analysis for this discharge into Gunnison Bay. It has been determined that this discharge will not cause a violation of water quality standards. An Antidegradation Level II review is required since this is a new discharge. 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 was conducted following DWQ’s September 10, 2015 Reasonable Potential Analysis Guidance (RP Guidance). To complete a robust RP analysis, more than 10 data points per parameter are needed. Since this was a new permit there were not 10 data points, therefore, sufficient data is not available to perform a RP analysis. For this permit cycle, Waterleaf will be required to permit, at a minimum, monthly metal sampling. If additional sampling is performed, it shall be reported to DWQ. Less than 10 data points may affect the RP outcomes which may require additional monitoring in the future. After at least 10 samples have been collected, the facility can request RP be run to evaluate the facilities reasonable potential to discharge these pollutants.DISCHARGE LIMITATIONSThe facility has the following discharge limitations and self-monitoring limitations. There shall be no discharge of process wastewater pollutants into navigable waters.The limitations specified in paragraph (a) of this section shall be applied on a net basis if the source of the applicant's water supply is the same body of water into which the discharge is made.Effective immediately and lasting the duration of this permit, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: Parameter Effluent Limitations *a Maximum Monthly Avg Annual Load Monthly Load Daily Minimum Daily Maximum Total Flow *b Phase 1 Phase 2 Phase 3 0.06 0.?? ?.?? -- -- -- 0.12 0.?? ?.?? Dissolved Oxygen, mg/L -- -- -- 5.0 -- Oil & Grease, mg/L -- -- -- -- 10.0 pH, Standard Units -- -- -- 6.5 9 Total Lithium, mg/L *d Report -- -- -- Report Total Arsenic mg/L *d, *e -- *f *g -- -- Total Cadmium mg/L *d, *e -- *f *g -- -- Total Chromium *d, *e -- *f *g -- -- Total Copper mg/L *d, *e -- *f *g -- -- Total Lead mg/L *d, *e -- *f *g -- -- Total Molybdenum mg/L *d, *e -- *f *g -- -- Total Nickel mg/L *d, *e -- *f *g -- -- Total Selenium mg/L *d, *e -- *f *g -- -- Total Silver mg/L *d, *e -- *f *g -- -- Total Zinc mg/L *d, *e -- *f *g -- -- Total Cyanide mg/L *d, *e -- *f *g -- -- Total Mercury mg/L *d, *e -- *f *g -- -- SELF-MONITORING AND REPORTING REQUIREMENTSThe following are the self-monitoring requirements for the permit. The 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. Self-Monitoring and Reporting Requirements *a Parameter Frequency Sample Type Units Total Flow *b, *c Continuous Recorder MGD pH Weekly Grab SU DO Weekly Grab mg/L Oil & Grease *h When Sheen Observed Grab mg/L Total Lithium Monthly Composite mg/L Total Arsenic Monthly Composite mg/L, kg/day Total Cadmium Monthly Composite mg/L, kg/day Total Chromium Monthly Composite mg/L, kg/day Total Copper Monthly Composite mg/L, kg/day Total Lead Monthly Composite mg/L, kg/day Total Molybdenum Monthly Composite mg/L, kg/day Total Nickel Monthly Composite mg/L, kg/day Total Selenium Monthly Composite mg/L, kg/day Total Silver Monthly Composite mg/L, kg/day Total Zinc Monthly Composite mg/L, kg/day Total Cyanide Monthly Composite mg/L, kg/day Total Arsenic Yearly Composite kg/year Total Cadmium Yearly Composite kg/year Total Chromium Yearly Composite kg/year Total Copper Yearly Composite kg/year Total Lead Yearly Composite kg/year Total Molybdenum Yearly Composite kg/year Total Nickel Yearly Composite kg/year Total Selenium Yearly Composite kg/year Total Silver Yearly Composite kg/year Total Zinc Yearly Composite kg/year Total Cyanide Yearly Composite kg/year*aSee Definitions, Part VIII, for 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.*dIn addition to monitoring the final discharge, influent samples shall be taken and analyzed for this constituent at the same frequency as required for this constituent in the discharge. *eThe minimum detection limit (MDL) of the test method used for analysis must be below this limit in mg/L. If a test method is not available the Permittee must submit documentation to the Director regarding the method that will be used. Total Arsenic 0.180 mg/L, Total Cadmium 0.0052 mg/L, Total Chromium 0.0166 mg/L, Total Copper 0.067 mg/L, Total Lead 0.0465 mg/L, Total Molybdenum NA, Total Nickel 0.376 mg/L, Total Selenium 0.0079 mg/L, Total Silver 0.0899 mg/L, Total Zinc 0.675 mg/L, Total Cyanide 0.0093 mg/L, Total Mercury 0.000022 mg/L.*fThe average annual load for this parameter in the final discharge shall not exceed +/- 10% of the load in the intake water as reported in kg/year. *gThe average monthly load for this parameter in the final discharge shall not exceed +/- 10% of the load in the intake water as reported in kg/day. *hOil & Grease sampled when sheen is present or visible. If no sheen is present or visible, report NA. BIOSOLIDS The facility is a minor industrial facility that uses an ion exchange process for mineral mining of lithium salt. It does not produce biosolids. For this reason, there are not requirements or conditions related to biosolids in the permit. 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. 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. 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 Waterleaf does not discharge to a POTW. Nor does Waterleaf expect to haul wastewater to a POTW. Although Waterleaf does not anticipate discharging to a POTW, any wastewater discharged to a 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 CWA, the permittee shall comply with all applicable Federal Pretreatment Regulations promulgated at 40 CFR Part 403, the State Pretreatment Requirements at UAC R317-8-8, and any specific local discharge limitations developed by the Publicly Owned Treatment Works (POTW) accepting the wastewaters. In addition, in accordance with 40 CFR Part 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 the permittee discharges any substance into a POTW which if otherwise disposed of would be considered a hazardous waste under 40 CFR Part 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 anlimited amount of effluent, in which toxicity is neither an existing concern, nor likely to be present. Additionally, the intake water and discharge are expected to be so saline that no freshwater or marine species approved for Whole Effluent Toxicity testing would be expected survived. This outcome would not give valid WET tests results. Also the facility will only be allowed to discharge wastewater pollutants that are present in the intake water. Therefore, based on these considerations, and the absence of receiving 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, Pretreatment, Storm Water, TMDL/Watershed Suzan Tahir, 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 in the (NEWSPAPER OF RECORD FOR AREA).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). 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: (801) 536-4383Fax:(801) 536-4301E-mail:jenrobinson@utah.govF:\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:(801) 536-4383 Fax:(801) 536-4301E-Mail:jenrobinson@utah.gov 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 tables below. 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 table below. 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