HomeMy WebLinkAboutDWQ-2024-000522Official 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
SPRINGDALE WASTEWATER LAGOONS
RENEWAL PERMIT: DISCHARGE
UPDES PERMIT NUMBER: UT0025224
MINOR MUNICIPAL
FACILITY CONTACTSOperator Name:Town of SpringdalePerson Name:Barbara BrunoPosition: MayorPerson Name:Rick WixomPosition:City ManagerPerson Name:Robert TottemPosition:Public Works SuperintendentPhone
Number:(435) 243-3686Facility Name:Springdale Wastewater LagoonsMailing and Facility Address:Springdale City OfficesPO Box 187118 Lion BlvdSpringdale, Utah 84767Telephone:(435) 772-6907
Actual Address:3300 North 1200 West
DESCRIPTION OF FACILITY
The Springdale Wastewater Lagoons (Facility) are located in Springdale, Washington County, Utah and serves the towns of Springdale and Rockville, as well as Zion National Park with the
outfall located at latitude 37°09'45'' and longitude 113°04'17''. The design capacity is .29 MGD, population equivalent of 4,500, and influent organic loadings of 765 lbs. of BOD5 and
900 lbs. TSS. Present flow averages.25 MGD.
The facility has a grinder, two aerated primary cells and one secondary cell for sedimentation and clarification. The effluent is treated with ultraviolet (UV) light for disinfection.
The total surface area of the lagoons is 19.38 acres and has a capacity of 52 million gallons. Due to compliance issues the Facility is upgrading its headworks to include a powered screen
to remove non-volatile solids from entering the lagoon system. A sand filtration system is also being constructed to help further reduce the level of total suspended solids (TSS). An
updated compliance schedule for the completion of the abovementioned upgrades is included in the permit.
SUMMARY OF CHANGES FROM PREVIOUS PERMIT
Ammonia sampling was changed to 2X monthly as a composite sample to fulfill permit requirements and total phosphorus effluent limits are based on UAC R 317-1-3.3, Technology-Based Phosphorus
Effluent Limits (TBPEL) Rule. Oil and grease was added to be consistent with other permits.
Springdale has requested an extension of the compliance milestone schedule for Lagoon upgrades and total suspended solids (TSS) and biochemical oxygen demand (BOD5) compliance. This
request has been update in this permit renewal as stipulated below:Lagoon UpgradeDateMilestoneNovember 1, 2024Construction Completed and Approved by DWQDecember 1, 2024Final Effluent
Limitations in EffectTSSDateTSS Max. Monthly AverageTSS Max. Weekly AverageTSS Min. % RemovalPermit Issue – November 30, 202470 mg/L70 mg/LNo limitationDecember 1, 202445 mg/L65 mg/L85%BODDateBOD
Max. Monthly AverageBOD Max. Weekly AverageBOD Min. % RemovalPermit Issue – November 30, 202470 mg/L70 mg/LNo limitationDecember 1, 202445 mg/L65 mg/L85%
DISCHARGE
DESCRIPTION OF DISCHARGE
The wastewater treatment plant has one discharge point, known as outfall 001. The discharge flowsthrough an eight-inch green PVC pipe discharging directly to the Virgin River. The average
flow over approximately the last five yearsis 0.268 MGD.
Springdale has been reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis. There have been violations of TSS since the permit modification in October
2022.Effluent monitoring and compliance data information is available for public review at www.echo.epa.gov by searching for permit number UT0025224.OutfallDescription of Discharge
Point 001 Located atlatitude3709' 45" and longitude 11304' 17". An 8-inch green PVC pipe discharges directly to the Virgin River.
RECEIVING WATERS AND STREAM CLASSIFICATION
The Virgin River is classified as a Class 1C, 2B, 3C and 4according to Utah Administrative Code (UAC) R317-2-13:
Class 1C -- Protected for domestic purposes with prior treatment by treatment processes as required by the Utah Division of Drinking Water
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 MAXIUM DAILY LOAD (TMDL) REQUIREMENTS
According to the Utah’s Final 2022 Integrated Report on Water Quality dated December 9, 2022, the receiving water for the discharge, “Virgin River and tributaries from North Creek confluence
to North Fork Virgin River (Assessment Unit UT15010008-012_00)” was listed as “No Evidence of Impairment”. Furthermore, downstream Assessment Unit (UT15010008-011_00) “Virgin River and
tributaries from Quail Creek Diversion to North Creek confluence” was listed as “Fully Supporting”.
BASIS FOR EFFLUENT LIMITATIONS
Effluent limitations on total suspended solids (TSS), biochemical oxygen demand (BOD5), E. coli, pH and percent removal for BOD5 and TSS are based on current Utah Secondary Treatment
Standards, UAC R317-1-3.2. The oil and grease is based on best professional judgment (BPJ). Effluent limitations for flow and dissolved oxygen (DO) are based on the wasteload analysis
(WLA).
Total phosphorus effluent limits are based on UAC R 317-1-3.3, TBPEL Rule. No TBPEL will be instituted for discharging treatment lagoons. Instead each discharging lagoon was evaluated
to determine the current annual average total phosphorus load measured in pounds per year based on monthly average flow rates and concentrations. Absent field data to determine these
loads and in case of intermittent discharging lagoons, the phosphorus load cap will be estimated by the Director.
The TBPEL discharging treatment works are required to implement, at a minimum, monthly monitoring of the following beginning July 1, 2018:
R317-1-3.3, E, 1, a.Influent for total phosphorus (as P) and total Kjeldahl nitrogen (as N) concentrations;
R317-1-3.3, E, 1, b. Effluent for total phosphorus and orthophosphate (as P), ammonia, nitrate-nitrite and total Kjeldahl nitrogen (an N);
In R317-1-3.3, E, 3 the rule states that all monitoring shall be based on 24-hour composite samples by use of an automatic sampler or a minimum of four grab samples collected a minimum
of two hours apart.
A cap of 125% of the current annual total phosphorus load has been established and is referred to as phosphorus loading cap. It is the intent of UACR317-3.3.B to provide capacity for
growth within your facility’s service area by setting the loading cap at 125 percent of your current annual total phosphorus load. Springdale’s current annual total phosphorus load was
calculated based on the data reported on your monthly discharge monitoring reports.
The permit was modified to include the new phosphorus loading cap. Springdale’s phosphorus loading cap is 3,490 lbs/year.
The phosphorus annual loading cap is defined as
"Annual Loading Cap” is the highest allowable phosphorus loading discharged over a calendar year, calculated as the sum of all the monthly loading discharges measured during a calendar
year divided by the number of monthly discharges measured during that year.
The reported monthly loading is calculated as shown here;The annual total phosphorus loading
Once the lagoon's phosphorus loading cap has been reached, the owner of the facility will have five years to construct treatment processes or implement treatment alternatives to prevent
the total phosphorus loading cap from being exceeded.
Total dissolved solids (TDS) limitations are based upon Utah Water Quality Standards for concentration values and the Colorado River Basin Salinity Control Forum (CRBSCF) for mass loading
values when applicable as authorized in UAC R317-2-4. CRBSCF has established a policy for the reasonable increase of salinity for municipal discharges to any portion of the Colorado
River stream system that has an impact on the lower main stem. The CRBSCF Policy entitled “NPDES Permit Program Policy for Implementation of Colorado River Salinity Standards” (Policy),
with the most current version dated October 2020, states that the incremental increase in salinity shall be 400 mg/L or less, which is considered to be a reasonable incremental increase
above the flow weighted average salinity of the intake water supply.
Attached is a Wasteload Analysis for this discharge into the unnamed irrigation ditch. It has been determined that this discharge will not cause a violation of water quality standards.
An Antidegradation Level II review is not required since the Level I review shows that water quality impacts are minimal. The permittee is expected to be able to comply with these limitations.
Reasonable Potential Analysis
Since January 1, 2016, DWQ has conducted reasonable potential analysis (RP) on all new and renewal applications received after that date. RP for this permit renewal was conducted following
DWQ’s September 10, 2015Reasonable Potential Analysis Guidance (RP Guidance).There are four outcomes defined in the RP Guidance: Outcome A, B, C, or D. These Outcomes provide a framework
for what routine monitoring or effluent limitations are required.
Springdale has not monitored for metals in the past. As a result, there is no data to evaluate in a RP analysis. Springdale does not have an approved pretreatment program, does not have
any industrial users contributing pollutants, and has a discharge that is less than 1 MGD and is therefore not required to sample metals according to the UPDES Pretreatment Guidance
for Sampling POTWs. Therefore there is a low probability of RP for metals to cause a violation of a WQBEL or subsequent downstream water quality standard for the Virgin River as a result
of discharge.
The permit limitations are:
Parameter
Table 1: Effluent Limitations at Outfall 001(a)
Maximum Monthly Avg
Maximum Weekly Avg
Yearly
Average
Daily Minimum
Daily Maximum
Total Flow
.29
--
--
--
--
BOD5, mg/L
BOD5 Min. % Removal
45
85
65
--
--
--
--
--
--
--
TSS, mg/L
TSS Min. % Removal
45
85
65
--
--
--
--
--
--
--
Dissolved Oxygen, mg/L
--
--
--
4.0
--
E. coli, No./100mL
126
157
--
--
--
Total Phosphorus, lbs/year
--
--
3,490
--
--
pH, Standard Units
--
--
--
6.5
9
TDS, mg/L
<400 Increase
--
--
--
--
SELF-MONITORING AND REPORTING REQUIREMENTSThe following self-monitoring requirements are the same for Outfall 001 as in the previous 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. Lab sheets for biomonitoring must be attached to the biomonitoring DMR. Lab sheets for metals
and toxic organics must be attached to the DMRs.
Table 2: Self-Monitoring and Reporting Requirements(a)
Parameter
Frequency
Sample Type
Units
Total Flow(d)(e)
Continuous
Recorder
MGD
BOD5(f),
Influent
Effluent
2 x Monthly
2 x Monthly
Composite
Composite
mg/L
mg/L
TSS(f),
Influent
Effluent
2 x Monthly
2 x Monthly
Composite
Composite
mg/L
mg/L
Dissolved Oxygen
2 x Monthly
Grab
mg/L
E. coli
2 x Monthly
Grab
No./100mL
pH
2 x Monthly
Grab
SU
TDS(c),
Effluent
Source Water
Quarterly
Quarterly
Grab
Grab
mg/L
Temperature(g)
2 x Monthly
Grab
℉
Total Boron(g)
2 x Monthly
Composite
mg/L
Total Ammonia (as N)
2 x Monthly
Composite
mg/L
Oil & Grease(h)
When Sheen Observed
Grab
mg/L
Orthophosphate (as P)(i),
Effluent
Monthly
Composite
mg/L
Total Phosphorus (as P)(i),
Influent
Effluent
Monthly
Monthly
Composite
Composite
mg/L
mg/L
Total Kjeldahl Nitrogen,
TKN (as N)(i)
Influent
Effluent
Monthly
Monthly
Composite
Composite
mg/L
mg/L
Nitrate, NO3(i)
Monthly
Composite
mg/L
Nitrite, NO2(i)
Monthly
Composite
mg/LNotes Tables 1 and 2See Definitions, Part VIII, for definition of terms.Interim limit effective through compliance milestone. See Part I.C.3.The effluent shall not exceed the culinary
source water intake by more than 400 mg/L of TDS or the permittee could request 1 ton/day TDS loading or 366 tons/year.Flow measurements of influent/effluent volume shall be made in
such a manner that the Permittee can affirmatively demonstrate that representative values are being obtained.If the rate of discharge is controlled, the rate and duration of discharge
shall be reported.In addition to monitoring the final discharge, influent samples shall be taken and analyzed for this consituient at the same frequency as required for effluent discharge.
During months where a discharge will not occur, influent samples shall be taken and analyzed at the frequency stipulated in Table 2.Boron and Temperature are being sampled in support
of work being done for the TMDL currently underway for the Virgin River. These pollutants of concern (POC) will be monitored and reported on a monthly basis by the facility on Discharge
Monitoring Report but will not have a limit associated with them. If the Permittee decides to sample more frequently for these POC, the additional data will be welcome.Oil and grease
shall be sampled when sheen is present or visible. If no sheen is present or visible, report NA.These reflect changes required with the adoption of UCA R317-1-3.3, Technology-based Phosphorus
Effluent Limits rule.
BIOSOLIDS
The State of Utah has adopted the 40 CFR 503 federal regulations for the disposal of sewage sludge (biosolids) by reference. However, since this facility is a lagoon, there is not any
regular sludge production. Therefore 40 CFR 503 does not apply at this time. In the future, if the sludge needs to be removed from the lagoons and is disposed in some way, the Division
of Water Quality must be contacted prior to the removal of the sludge 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. 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 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
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 CFR 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 is required to 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 must 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 Division of Water Quality 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 CFR, Part 403.5(a) and Part 403.5(b). This evaluation may indicate that present local limits are sufficiently protective, 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.
The permittee is a minor municipal facility that will be discharging an infrequent amount of effluent, in which toxicity is neither an existing concern, nor likely to be present. Also,
the receiving irrigation ditch is regularly dry; therefore there is not any available data to conclude that the irrigation ditch is impaired. 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 ReviewedbyLindsay Cowles, Discharge Permit WriterDaniel Griffin, BiosolidsJennifer
Robinson, PretreatmentLonnie Shull, BiomonitoringCarl Adams, Storm WaterAmy Dickey, TMDL/Watershed Christopher Shope, PhD, 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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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
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ATTACHMENT 2
Effluent Monitoring Data
This Page Intentionally Left BlankEffluent Monitoring Data
ATTACHMENT 3
Wasteload Analysis
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ATTACHMENT 4
Reasonable Potential Analysis
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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.A quantitative RP was not performed on effluent metals data because there is inadequate data for use in a
RP. Additional monitoring for metals will be included in this permit to support future RP.