DWQ-2024-000754

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 AND STATEMENT OF BASIS
PACIFICORP - GADSBY PLANT RENEWAL PERMIT: DISCHARGE
RENEWAL PERMIT: DISCHARGE
UPDES PERMIT NUMBER: UT0000116
MINOR INDUSTRIAL
FACILITY CONTACTSBrian Wheeler Environmental AnalystPerson Name:Bill KennickPosition:Plant ManagerPhone Number:[phone]Person Name:Joe BetensonPosition:Environmental AnalystPhone
Number:[phone]Facility Name:PacifiCorp Gadsby Power PlantMailing and Facility Address:1359 West North Temple Salt Lake City, Utah 84116 Telephone:[phone]
Actual Address:1359 West North Temple
DESCRIPTION OF FACILITY
The Gadsby Plant is a steam electric power generating facility consisting of six generation units rated at 66 megawatts (MW), 75 MW, and 100 MW and three 40 MW Combustion Turbines (CT)
yielding a capacity of 361 MW. A CO2 injection system is used at Outfall 004 to control elevated pH readings that may result from biological growth in the settling ponds. The plant
is currently configured for operating all units on natural gas and has a Standard Industrial Classification (SIC) code 4911, for electric power generation. The design flow of this facility
is 3.7 million gallons per day (MGD). A flow diagram of the system is appended in Attachment 1. Based on information obtained from facility representatives, there is no once through
cooling water used in this facility (when used, cooling water is recirculated through the cooling tower, until blowdown is required) and there is no discharge of metal cleaning wastes
or chemical metal cleaning wastes.
The Gadsby Plant currently consists of two discharge points, Outfalls 004 and 007. Outfall 004 discharges waste water from treatment ponds into the Salt Lake Abatement Canal and Outfall
007 discharges back wash water from the intake screen to the Jordan River. The intake screen (Outfall 007) on the Jordan River is backwashed with an average flow of 170 gallons per
minute using Jordan River water for one hour, once per week. The purpose is to clear the screen of river debris. Because Outfall 007 discharges only minimal amounts of Jordan River
rinse water from intake screen back washing, monitoring and reporting requirements have not been included in this renewal UPDES permit.
The Gadsby Plant utilizes water from either the Jordan River, or Salt Lake City culinary water. Jordan River water is treated before use in the plant processes. This water is used
for a variety of processes and becomes part of the facility waste water. The waste water is directed to the treatment ponds and includes water from cooling tower blow down (three sets
of cooling towers), boiler blow down, yard drains, storm water, excess treated raw water and reverse osmosis reject. All other waste water streams are disposed of in the sanitary sewer
system. There are no metal cleaning wastes of any kind discharged. The plant drains and combustion turbine drains pass through an oil water separator before discharge to the waste
water ponds which discharge from Outfall 004.
Prior to the 2012 renewal permit, Gadsby plant personnel requested a waiver from the Federal requirement in 40 CFR 423.12(b)(8)and 423.13(d)(2), which imposes a time limitation on chlorine
discharged from their cooling units to 2-hours per day, and not from more than one unit at a time. The cooling tower components are negatively affected by short periods of high doses
of chlorine (shock treatment). PacifiCorp believes that the Gadsby Plant units would be better conditioned and avoid significant corrosive activity with continuous low doses of chlorine
instead of the periodic shock treatment, as is the case with other PacifiCorp Plants.
The citation in 40 CFR 423 allows for the discretion of the permitting authority to determine the applicability of this requirement because of “…factors relating to the equipment or
facilities involved, the process applied, or other such factors related to such discharger are fundamentally different from the factors considered in the establishment of the guidelines.”
Because all of the wastewater is sent to settling/wastewater ponds before being discharged, the effect on the receiving waters should be negligible as the mass load of chlorine through
continuous low doses is not significantly different from the high dose treatment at two-hour intervals. The Division of Water Quality reviewed the waiver request and agreed to modify
the permit accordingly. This chlorine modification will again be continued under this renewal permit because there have been no changes in the system and the Gadsby Plant is in compliance
with their permit chlorine limitations (no violations over the last five years).
In the 2012 renewal the use of calcium hypochlorite for the control of algae in the settling ponds was requested and approved, and the use of sodium hypochlorite to control algae in
the settling ponds was previously approved by Division of Water Quality. As a result, beginning in the 2013 renewal, both sodium and calcium hypochlorite can be used for control of
algae in the settling ponds. They are both used in tablet form, similarly to how they would be in a swimming pool.
In the previous permits a total residual chlorine effluent limit was included as taken from once through cooling water discharge requirements in 40 CFR 423.13. As indicated above, once-through
cooling water is not presently discharged. For this reason and because the Abatement Canal has no water quality standard for total residual chlorine, the total chlorine residual limits
included in the previous permits were dropped from the 2012 permit renewal at Outfall 004. For a similar reason, total iron was dropped from the permit. Based on 40CFR 423.12 total
iron is required to be limited in the discharge of metal cleaning wastes. Since no metal cleaning wastes are being discharged and there is no water quality standard for iron in the
Abatement Canal, total iron was dropped from the permit at Outfall 004.
The settling ponds are included in pictures appended to this fact sheet statement of basis (FSSOB) along with a diagram showing the process water flow at the Gadsby Plant.
Based on 40 CFR 423.23 total chromium and total zinc effluent limits are included in the renewal permit because, when necessary, there would be cooling tower blowdown. The following
parameters will be sampled only at the cooling tower blowdown before mixing with any other waste streams: the 126 priority pollutants, total chromium and total zinc. The following parameters
will be sampled at Outfall 004: TSS, oil and grease, pH, and flowfree available chlorine.
SUMMARY OF CHANGES FROM PREVIOUS PERMIT
WLA Model
A new model is used by Water Quality to develop a waste load allocation (WLA) for dischargers to Waters of the State.
RP
During the permit cycle, Water Quality has worked to improve our reasonable potential analysis (RP) for parameters to have limits included by using an EPA provided model. The results
of the RP Analysis are included in Attachment 4 of the FSSOB
Total Suspended Solids, Utah Secondary Treatment Standards
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. As a result of that change Utah secondary treatment standards for Biological Oxygen Demand, and Total Suspended Solids (TSS) do not automatically
apply to industrial facilities, unless otherwise required by their effluent limitation guidelines.
The Gadsby Plant is listed as electric power generating facility (SIC 4911 – Electric Services) and wastewater discharges from those facilities are regulated under 40 CFR Part 423 -
Steam Electric Power Generating Point Source Category. This category includes and effluent limit guideline (ELG) under best practicable control technology currently available (BPT) for

TSS. The ELG’sincluded are a daily maximum of 100 mg/L and a monthly average of 30 mg/L. The previous Utah Secondary Standards Limit for TSS will be removed from the permit and the EGL
TSS limits will be included in the permit.
The updated TSS Effluent Limits will be;
Parameter
Effluent Limitations
Maximum Monthly Avg
Maximum Weekly Avg
Yearly
Average
Daily Minimum
Daily Maximum
TSS, mg/L
30
-
-
-
100
TBPEL Rule
Water Quality adopted UAC R317-1-3.3, Technology-Based Phosphorus Effluent Limit (TBPEL) Rule in 2014. The TBPEL rule as it relates to "non-lagoon" wastewater treatment plants establishes
new regulations for the discharge of phosphorus to surface waters and is self-implementing. The TBPEL rule includes the following requirements for non-lagoon wastewater treatment plants:
The TBPEL requires that all non-lagoon wastewater treatment works discharging wastewater to surface waters of the state shall provide treatment processes which will produce effluent
less than or equal to an annual mean of 1.0 mg/L for total phosphorus. This TBPEL shall be achieved by January 1, 2020.
The TBPEL discharging treatment works are required to implement, at a minimum, monthly monitoring of the following beginning July 1, 2015:
R317-1-3.3, D, 1 Influent for total phosphorus (as P) and total Kjeldahl nitrogen (as N) concentrations;
R317-1-3.3, D, 2. Effluent for total phosphorus and orthophosphate (as P), ammonia, nitrate-nitrite and total Kjeldahl nitrogen (an N);
In R317-1-3.3, D, 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.
On November 3, 2015 Water Quality granted a variance to this rule after determining the facility does not meet the definition of treatment works as defined in UAC R317-1-1.29.
R316(b)
In 2014, the EPA finalized rulemaking in connection with Section 316(b) of the Code of Federal Regulations. This section of the Clean Water Act required the EPA to issue regulations
on the design and use of intake structures in order to minimize impacts of water intakes on threatened and endangered species. The Gadsby Plant is now subject to the section R316 (b).

Under these regulations the Permittee (Gadsby) is required to determine if any listed species might be impacted by the intake of water. They then analyze the effects of the intake on
the species and report on it to the US Fish and Wildlife Service who will review the analysis, and if there is an impact, they will consult with the Permittee and give a biological opinion
on the project.
The regulations also contain Permit Application Requirements (PARs) that must be submitted prior to renewing the permit. This has already been completed by Gadsby. The PARs were received
along with the renewal application on November 9, 2022. A copy of which is included in Attachment 4 of the FSSOB.
Title 40 Part 423 list several other restrictions on the discharge. These are:
There shall be no discharge of metal cleaning wastes or chemical metal cleaning wastes.
There shall be no visible sheen or floating solids or visible foam in other than trace amounts.
There shall be no discharge of sanitary wastes.
There shall be not discharge of polychlorinated biphenyl compounds such as those that were commonly used in transformer fluids
These prohibitions are included in the permit, and have noted on the DMR as a “Yes” or “No” indication. These indications will be removed as part of the DMR following the renewal. If
one of these is to happen at the facility during the coverage period of this Permit, it will be reported as a violation following the requirements of Part V, H and I of the Permit.
DISCHARGE
DESCRIPTION OF DISCHARGE
Outfall 004 discharges to the Salt Lake Abatement Canal which is a tributary to the City Drain, which is a tributary to the Salt Lake Sewage Canal which leads to the final destination
of the Farmington Bay Water Fowl Management Area. The Farmington Bay Water Fowl Management Area is several miles downstream of the discharge at PacifiCorp Gadsby and undergoes significant
dilution; therefore, use of these receiving water classifications is very conservative and protective of the water fowl management area. Outfall 007is for the backwashing of the influent
screens along the Jordan River.
The Gadsby Plant has been reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis. The last five years of data is included as Attachment 3 of the FSSOB.OutfallDescription
of Discharge Point
004Located at latitude 40 76' 89" and longitude 111 93' 05". Continuous discharge from the treatment ponds to the Salt Lake Abatement Canal.
007 Located at latitude 40 76' 87" and longitude 111 76' 64". East side of property along the Jordan River back flushing Jordan River rinse water from the intake screens.
RECEIVING WATERS AND STREAM CLASSIFICATION
Outfall 004 eventually goes to the Farmington Bay Water Fowl Management Area. The Farmington Bay Water Fowl Management Area is classified as 2B, 3C, and 3D according to Utah Administrative
Code (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 3C -- Protected for nongame fish and other aquatic life, including the necessary aquatic organisms in their food chain.

Class 3D -- Protected for waterfowl, shore birds and other water-oriented wildlife not included in Classes 3A, 3B, or 3C, including the necessary aquatic organisms in their food chain.
Outfall 007 is to the Jordan River. The Jordan River is classified as 2B, 3B, and 4 according to Utah Administrative Code (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 3B -- Protected for warm water species of game fish and other warm water 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
The receiving stream (Salt Lake Abatement Canaland eventually to Farmington Bay Water Fowl Management Area) for this discharger are not currently listed as impaired According to the
Utah’s 2023 303(d) Water Quality Assessment Report dated March 8, 2022.
BASIS FOR EFFLUENT LIMITATIONSIn accordance with regulations promulgated in 40 Code of Federal Regulations (CFR) Part 122.44 and in UAC R317-8-4.2, effluent limitations are derived from
technology-based effluent limitations guidelines, Utah Secondary Treatment Standards (UAC R317-1-3.2) or Utah Water Quality Standards (UAC R317-2). In cases where multiple limits have
been developed, those that are more stringent apply. In cases where no limits have been developed, Best Professional Judgment (BPJ) may be used where applicable.“Best Professional Judgment”
refers to a discretionary, best professional decision made by the permit writer based upon precedent, prevailing regulatory standards or other relevant information.
Effluent limitations are also derived using a waste load analysis (WLA). The WLA incorporates Secondary Treatment Standards, Water Quality Standards, and designated uses into a water
quality model that projects the effects of discharge concentrations on receiving water quality. Effluent limitations are those that the model demonstrates are sufficient to meet applicable
State water quality standards in the receiving waters. Where applicable, effluent limitations from the WLA were incorporated into the renewal permit (see the attached WLA).
The basis for effluent limitations is as follows:
Considering the processes employed at Gadsby, the following parameters are regulated under the effluent limitations guidelines for the Steam Electric Power Generating Point Source Category,
40 CFR Part 423; total suspended solids (TSS), oil and grease, free available chlorine, pH, polychlorinated biphenyls, total chromium, total zinc and the 126 priority pollutants. However,
free available chlorine will be monitored at Outfall 004 instead of from cooling tower blowdown. This is consistent with the previous permit and is more in line with the operational
aspects of the power plant. Holding the discharge water in the ponds will allow the chlorine to dissipate and monitoring at 004 will directly show the chlorine concentration going to
the receiving waters (Abatement Canal).
The parameters regulated under Utah Administrative Code (UAC) R317-1-3.2, are secondary treatment standards for pH which are more stringent than the categorical requirements (40 CFR
Part 423) for this parameter.
Oil and grease will not be changed from what is in the previous permit. This limit is based on best professional judgment (BPJ) and is more stringent than the categorical requirements
(40 CFR 423) for this parameter and will be applicable at Outfall 004.
Attached is a Wasteload Analysis for this discharge into the Salt Lake Abatement Canal. 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.
The permit limitations are:
Reasonable Potential Analysis
DWQ conducts a reasonable potential analysis (RP) on all new and renewal applications. 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
A quantitative RPscreening was conducted on total chrome and total zinc. Monitoring results for both metals did not indicate a full RP was required.
The permit limitations are
Parameter
Effluent Limitations 1
Maximum Monthly Avg
Maximum Weekly Avg
Yearly
Average
Daily Minimum
Daily Maximum
Total Flow
Report
-
-
-
3.7
TSS, mg/L
30
100
Oil & Grease, mg/L
-
-
-
-
10.0
pH, Standard Units
-

-
-
6.5
9
Cooling Tower Blowdown
Free Available Chlorine, mg/L
0.2
-
-
-
0.5
Chromium, mg/L
0.2
-
-
-
0.2
Zinc, mg/L
0.2
-
-
-
0.2
See Definitions, Part VIII, for definition of terms.
SELF-MONITORING AND REPORTING REQUIREMENTSThe following self-monitoring requirements are modified from the previous permit as described above. 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, and 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.
Self-Monitoring and Reporting Requirements *a
Parameter
Frequency
Sample Type
Units
Total Flow2, 3
Continuous
Recorder
MGD
TSS
Monthly
Composite
mg/L
pH
Monthly
Grab
SU
Free Available Chlorine
Weekly
Grab
mg/L
Oil & Grease4
Monthly
Grab
mg/L
Cooling Tower Blowdown
Free Available Chlorine5
Weekly
Total Chromium5
Monthly
Zinc5
Monthly

Organic Toxics5, 6
Annually
See Definitions, Part VIII, for definition of terms.
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 the monthly sampling requirement for oil and grease, a sample for oil and grease shall immediately be taken whenever a sheen is observed in the effluent or there is another
reason to believe oil and grease is present.
Samples shall be taken from cooling tower blowdown only and shall not include dilution from any other effluent streams.
The blowdown from the cooling towers shall contain no detectable amounts of the 126 priority pollutants (Appendix A of 40 CFR Part 423) due to chemicals added for cooling tower maintenance.
Compliance with this requirement may be determined by engineering calculations which demonstrate that the regulated pollutants are not detectable in the cooling tower blowdowns by the
analytical methods in 40 CFR Part 136. These calculations must be based on the cooling tower blowdowns only and shall not include dilution by any other effluent streams. A list of the
certified analytical contents of all biofouling and maintenance formulations (Manufacturer’s certification as to contents and priority pollutants status) shall be submitted along with
the engineering calculations. The engineering calculations shall be updated annually or whenever there is a change in the chemicals used or an increase in the application rate of the
chemicals. If chemical usage, both type and quantity has not changed during the year, a letter certifying to that fact is adequate to demonstrate continued compliance with the requirement.
BIOSOLIDS
The State of Utah has adopted the 40 CFR 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 CFR 503 does 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 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.
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.
Information on storm water permit requirements can be found at http://stormwater.utah.gov
PRETREATMENT REQUIREMENTS
The sanitary wastewater and some of the process wastewater from the facility are discharged to a PubliclyOwned Treatment Works (POTW) which is owned and operated by South Davis Sewer
District. Thepermittee must continue to meet the requirements to discharge into the POTW.
Any process wastewater that the permittee discharges to a POTW, either as a direct discharge or as a hauledwaste, is subject to federal, state, and local pretreatment regulations. Pursuant
to section 307 of the CleanWater Act, the permittee shall comply with all applicable federal general pretreatment regulationspromulgated, found in 40 CFR 403, the pretreatment requirements
found in UAC R317-8-8, and anyspecific local discharge limitations developed by the POTW accepting the waste.
In addition, in accordance with 40 CFR 403.12(p)(1), the permittee must notify the POTW, the EPARegional Waste Management Director, and the State hazardous waste authorities, in writing,
if theydischarge any substance into a POTW which if otherwise disposed of would be considered a hazardouswaste under 40 CFR 261. This notification must include the name of the hazardous
waste, the EPAhazardous waste number, and the type of discharge (continuous or batch).
BIOMONITORING REQUIREMENTSAs part of the nationwide effort to control toxics, biomonitoring requirements are being included in allmajor permits and in minor permits for facilities where
effluent toxicity is an existing or potential concern.Authorization for requiring effluent biomonitoring is provided for in UAC R317-8-4.2 and R317-8-5.3. TheWhole Effluent Toxicity
(WET) Control Guidance Document, February 15, 1991, outlines guidance to beused by Utah Division of Water Quality staff and by permittee’s for implementation of WET controlthrough the
UPDES discharge permit program.Gadsby Power Plant is a minor facility with no reasonable potential for toxicity in the effluent. As a result,biomonitoring of the effluent will not be
required. However, the permit will contain a WET reopenerprovision.
PERMIT DURATIONIt is recommended that this permit be effective for a duration of five (5) years.Drafted and Reviewed byDaniel Griffin, Discharge Permit WriterJennifer Robinson, PretreatmentLonnie
Shull, BiomonitoringChris Shope, Wasteload AnalysisUtah Division of Water Quality, [phone]PUBLIC 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 Division of Water Quality Public Notice 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.
This Page Intentionally Left Blank
ATTACHMENT 1
Site Map and Flow Diagram
This Page Intentionally Left Blank
ATTACHMENT 2
Effluent Monitoring Data
This Page Intentionally Left BlankEffluent Monitoring Data.

Flow
TSS
Free, Available Chlorine
O & G
pH

Chronic
Max
Acute
Chronic
Max
Chronic
Max
Max
Max
Min

MGD
mg/L
mg/L
mg/L
SU

3.7
35
25
100
0.2
0.5
10
9
6.5
Aug-18
0.521
0.806
10.4
0.01
ND
8.51
6.658
Sep-18
0.627
1.036
9.2
0.03
ND
8.24
7.11
Oct-18
0.686
1.169
8.4
0.02
ND
8.16
7.34
Nov-18
0.184
0.643
5.6
0.02
ND
8.11
6.818
Dec-18

0.043
0.229
ND
0.03
ND
8.787
6.512
Jan-19
0.06
0.259
ND
0.32
ND
8.31
6.61
Feb-19
0.048
0.135
4.4
0.14
ND
7.91
6.93
Mar-19
0.104
0.406
ND
0.04
ND
8.05
7.5
Apr-19
0.184
0.753
ND
0.04
ND
8.04
6.78
May-19
0.711
0.983
7.2
0.04
ND
8.34
7.54
Jun-19
0.727
1.863
6.8
0.02
ND
8.31
7.97
Jul-19
1.169
1.522
6
0.03

ND
8.12
7.69
Aug-19
1.268
1.685
18.4
0.03
ND
7.87
7.69
Sep-19
0.772
2.071
ND
0.03
ND
7.98
7.6
Oct-19
0.513
1.153
6.4
0.03
ND
8.02
7.72
Nov-19
0.833
2.075
4
0.04
ND
8.44
7.8
Dec-19
1.256
2.114
16.4
0.04
ND
7.89
7.58
Jan-20
0.686
1.053
5.6
0.04
ND
7.93
7.88
Feb-20
0.609
1.012
3.6
0.06
ND
8.24
7.86
Mar-20

0.488
0.733
ND
0.05
ND
8.2
8.12
Apr-20
0.56
0.956
6.4
0.02
ND
8.56
8.05
May-20
0.502
0.695
21.6
0.04
ND
8.53
7.1
Jun-20
0.616
1.267
7.6
0.05
ND
8.47
7.04
Jul-20
0.473
1.056
10
0.05
5.13
8.5
7.48
Aug-20
1.027
1.646
10
0.03
5.9
8.43
8.11
Sep-20
0.716
1.14
22
0.03
5.45
8.02
7.8
Oct-20
0.672
0.991
15.6
0.04

ND
8.42
7.29
Nov-20
0.373
0.86
ND
0.05
5.51
8.32
7.56
Dec-20
0.068
0.315
ND
0.14
6.59
8.44
8.18
Jan-21
0.057
0.232
ND
0.11
=
9
7.77
Feb-21
0.025
0.12
3.2
0.09
ND
8.96
7.89
Mar-21
0.067
0.239
4.4
0.06
ND
8.66
7.54
Apr-21
0.459
2.11
4
0.05
ND
8.3
7.1
May-21
0.538
0.745
8.4
0.02
6.06
8.01
7.77
Jun-21

0.541
0.96
9
0.12
ND
7.97
6.68
Jul-21
0.645
1.548
10.4
0.1
ND
8.52
7.7
Aug-21
0.618
1.57
23.2
0.06
6.68
7.96
7.6
Sep-21
0.595
1.167
24.6
0.1
6.26
8.07
7.71
Oct-21
0.178
0.611
6.4
0.02
ND
8.07
7.24
Nov-21
0.042
0.342
8.8
0.02
ND
8.45
8.02
Dec-21
0.168
0.651
ND
0.08
ND
7.6
6.94
Jan-22
0.117
0.862
9.6
0.02

ND
7.67
7.24
Feb-22
0.136
0.809
8
0.03
ND
8.53
7.21
Mar-22
0.046
0.2
4
0.02
ND
8.22
7.35
Apr-22
0.13
0.566
4
0.02
ND
8.12
7.48
May-22
0.613
1.593
7
0.07
ND
8.32
7.93
Jun-22
0.83
1.936
16
0.05
ND
8.75
8.14
Jul-22
0.885
1.366
12
0.05
ND
8.36
7.86
Aug-22
0.819
1.363
14
0.06
ND
8.31
7.82
Sep-22

0.697
1.432
24
0.1
ND
7.9
7.44
Oct-22
0.583
1.459
8
0.16
=
8.33
7.46
Nov-22
0.328
0.862
12
0.16
ND
7.77
7.63
Dec-22
0.19
0.329
12
0.16
ND
8.33
7.78
Jan-23
0.21
0.333
16
0.05
ND
8.52
8.4
Feb-23
0.31
1.392
5
0.05
ND
8.76
8.02
Mar-23
0.241
0.545
14
0.04
ND
8.45
7.95
Apr-23
0.093
0.329
8
0.05

5
8.37
7.51
May-23
0.155
0.476
9
0.09
ND
8.66
8.09
Jun-23
0.795
1.237
9
0.1
ND
8.75
7.63
MDL/MRL

3
5

Effluent Metals Monitoring
Total Cr
Total Zn
Ave/Max
Ave/Max
mg/L
mg/L
0.2
1
Sep-18
0.0066
0.0885
Dec-18
Mar-19
ND
0.0192
Jun-19
0.00472
0.0787
Sep-19
0.00524
0.0741
Dec-19
0.00806
0.074
Mar-20
Jun-20
0.0184
0.358
Sep-20
0.00671
0.141
Dec-20
0.00364

0.0423
Mar-21
Jun-21
0.0233
0.206
Sep-21
0.0235
0.211
Dec-21
0.00823
0.0758
Mar-22
0.0013
0.003
Jun-22
0.0169
0.06
Sep-22
0.0061
0.06
Dec-22
0.0107
0.19
Mar-23
0.0048
0.06
Jun-23
0.0176
0.11
MDL/MRL
0.002
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.Initial review of the pollutants of concern for this facility and the corresponding values submitted by discharge
monitoring reports showed that there was not a need to look closer at them. For this discharge all the ELGs limits for the POCs are all much lower that the WQBEL developed in the WLA.

ATTACHMENT 5
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ATTACHMENT 6
Cooling Water Intake Structure
Permit Application Requirements
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