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HomeMy WebLinkAboutDWQ-2024-000914Official 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 GRANTSVILLE CITY WATER RECLAMATION FACILITY RENEWAL PERMIT: DISCHARGE UPDES PERMIT NUMBER: UT0021130 MAJOR MUNICIPAL FACILITY CONTACTSOperator Name:Grantsville City CorporationContact:James Waltz Position: Public Works DirectorPhone Number:(435) 884-3411Person Name:Marcus SeatPosition:Field Operations Lead Phone Number:(435) 884-3411Permittee Name:Grantsville City CorporationFacility Name:Grantsville City Water Reclamation FacilityMailing and Facility Address:Grantsville City Public Works 336 West Main Street Grantsville, UT 84029Telephone:City Hall- (435) 884-3411 Actual Address:630 North Race Street DESCRIPTION OF FACILITY The Grantsville City Lagoons (Grantsville) were constructed in 1972. The lagoons service the city of Grantsville with a service population of approximately 5000. The average design flow capacity in 2009 was 0.76 MGD, population equivalent of 6323 through the year 2015, and influent organic loadings of 170mg/L or 1,075lbs/day each for BOD5 and TSS. The peak design flow was 1.9 MGD. The facility consists of a headwork’s control building containing control equipment as well as a Rotomat rag compactor, headwork’s structure with two influent channels and one bar screen followed by a 15-inch Palmer Bowlus flume and Drexel Brook ultrasonic flow meter. The facility is equipped with a diesel-powered generator that will operate as a backup power source. Grantsville City’s Lagoons consist of 8 lagoons, 1 primary, 1 secondary, 2 tertiary and 4 empty lagoons to allow for overflow. Their lagoons included aerators. The primary lagoon has eight (8) aerators. The secondary lagoon has five (5) aerators and the first tertiary cell has three (3) aerators. The cells are contained on 102.2 acres. Following the lagoon cells is the disinfection building. The disinfection building contains the influent and effluent flow recorders, and an ultraviolet (UV) light channel. The UV channel is 21 feet long, 20 inches wide and contains two banks of UV lights in series, with 40 lights per bank. The building also houses the facility laboratory. Following the disinfection building is an effluent 15-inch Palmer Bowlus flume and Drexel Brook flow sensor. The facility’s discharge location at Outfall 001 is located at latitude 40o37'15" and longitude 112o26'50" and STORET number 496024. Grantsville improved and changed some of the treatment process on site. Most notably they have improved the primary cell. They now use an Advanced Treatment Lagoon Activated Sludge system utilizing a Decant BioBalanced Reactor technology to manage biosolids (ATLAS™ - DBBR). The process was described in the Anti-Degradation Review Facility Management Plan as, “The basic ATLAS framework uses conventional low-rate activated sludge process with process oxygen requirements provided by fine bubble aeration and system biomass controlled by a decant operation. The ATLAS-DBBR system is comprised of integrated hardware equipment design specifically to meet the treatment objectives of the plant. The key determinate technologies include in-basin aeration equipment (floating air laterals and diffusers), blowers, decant piping and valves and integrated process control logic.” The result of the process change is that the facility has greatly improved the effluent quality and increased capacity. Grantsville requested the design capacity (discharge flow limit) of the facility be adjusted to match and submitted the Anti-Degradation Review and supporting reports for the changes. This Document (DWQ-2014-007999) was included in the attachments to the Fact Sheet Statement of Basis (FSSOB) for the renewal in 2014. It will not be attached to this, or future FSSOBs for Public Comment, but is available from DWQ. Water Quality reviewed the receiving waters and generated a report (DWQ-2014-009708). The review confirmed the status of the receiving water bodies as 3D. A Waste Load Analyses (DWQ-2014-009709) was developed, resulting in some limit changes for the 2014 renewal permit.These documents were included in the attachments to the Fact Sheet Statement of Basis (FSSOB) for the renewal in 2014 but will not be attached to this, or future FSSOBs for Public Comment. They are available from DWQ. In the 2014 renewal a mass loading limit for ammonia during the months of July, August and September was added to the permit, as well as a minimum limit for dissolved oxygen. The mass loading limit is calculated as shown here; Monitoring for metal and total toxic organics was also added to the permit during this renewal. Water Quality adopted UAC R317-1-3.3, Technology-Based Phosphorus Effluent Limit (TBPEL) Rule on December 16, 2014. No TBPEL will be instituted for discharging treatment lagoons. Instead, each discharging lagoonwas 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. A cap of 125% of the current annual total phosphorus load has been established andis 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. Grantsville’s current annual total phosphorus load was calculated based on the data reported on your monthly discharge monitoring reports. Grantsville’s phosphorus loading cap is 2839 lbs/year and went into effect July 1, 2018. SUMMARY OF CHANGES FROM PREVIOUS PERMIT On July 1, 2018 and annual phosphorus loading cap of 2839 lbs/year was added to the permit. Grantsville has been reporting the loading on an annual basis. They have exceeded the loading cap in 2022 and 2023. They have started the process of updating their facilities management plan and determining what improvements will be required to return to compliance with the limit and rule. Annual Total Phosphorus Loading Year Limit 2839lb/yr Violation 2019 2298 No 2020 1633 No 2021 2725 No 2022 3897 Yes 2023 7351 Yes The WLA developed more restrictive water quality based effluent limits (WQBEL) for ammonia. These limits will be added to the permit. The changes are listed in the table below. Effluent Concentration and Mass loading Limits Previous Limit New Limits Total Ammonia (as N) Average (mg/L) Maximum (mg/L) Loading Cap (lbs/Month) Average (mg/L) Maximum (mg/L) Loading Cap (lbs/Month) Summer (Jul-Sep) Fall (Oct-Dec) Winter (Jan-Mar) Spring (Apr-Jun) - 2.5 2.9 1.7 3.2 3.2 3.2 3.2 412.8 - - - - 2.2 2.3 1.5 2.3 2.3 2.3 2.3 337.8 - - - The changes required to comply with the phosphorus loading cap, and lower ammonia limits will take time. They may require construction of a completely new treatment facility, which may change the status of plant from being a lagoon to a mechanical plant, and change the phosphorus limit for a loading cap to annual average concentration limit of 1 mg/L. Compliance Schedule to be added Grantsville has been reporting effluent monitoring results for beryllium, antimony, phenols, and thallium since 1999. The results forberyllium, phenols, and thallium have been below the MRL (no detect). There have not been any WQBEL for beryllium, antimony, and thallium, and there is no indication that Grantsville would have any industrial contributors that would elevate those pollutants of concern in the effluent. If the RP model was run on these parameters the result would be “Outcome B: No limitation or routine monitoring requirements are in the permit”. As a result of this the reporting for beryllium, antimony, phenols, and thallium will be removed from the DMR’s. DISCHARGE DESCRIPTION OF DISCHARGE Grantsville has been reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis. OutfallDescription of Discharge Point 001 Located at latitude 4037'15" and longitude 11226'50". The discharge is located north of the disinfection building, in the NW ¼ section 29, T2S R5W, via a constructed ditch that travels approximately 150 yards to the North, before entering Blue Lakes. RECEIVING WATERS AND STREAM CLASSIFICATION When a discharge does occur, it is pumped into a drainage ditch, thence to Blue Lakes, thence to an irrigation ditch, which are a Class 2B, 3D 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 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. Class 4 -- Protected for agricultural uses including irrigation of crops and stock watering. TOTAL MAXIMUM DAILY LOAD (TMDL) REQUIREMENTS According to DWQ’s 2022 Integrated Report and 303(d) Assessment, North Willow Creek (North Willow Creek and tributaries, Tooele County, UT16020304-003_00) needs more data for any future assessments. BASIS FOR EFFLUENT LIMITATIONS 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. 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. The permit limitations are: Reasonable Potential Analysis Since January 1, 2016, DWQ has conducted reasonable potential analysis (RP) on all new and renewal applications received after that date. RP for this permit renewal was conducted following DWQ’s September 10, 2015 Reasonable Potential Analysis Guidance (RP Guidance).There are four outcomes defined in the RP Guidance: Outcome A, B, C, or D. These Outcomes provide a frame work for what routine monitoring or effluent limitations are required A quantitative RPscreening was conducted on cyanide and mercury. Further review of these metals resulted in a determination that the monitoring requirements from the previous permit will be retained for this renewal. A copy of the RP analysis is included at the end of this Fact Sheet. The permit limitations are Parameter Effluent Limitations1 Maximum Monthly Avg Maximum Weekly Avg Yearly Average Daily Minimum Daily Maximum Total Flow, MGD 1.5 - - - - BOD5, mg/L BOD5 Min. % Removal 25 85 35 - - - - - - TSS, mg/L TSS Min. % Removal 25 85 35 - - - - - - - Dissolved Oxygen, mg/L - - - 3 - E. coli, No./100mL 126 158 - - - pH, Standard Units - - - 6.5 9 Definitions, Part VIII, for definition of terms. Effluent Concentration and Mass Loading Limits1 Parameter Maximum Monthly Avg (mg/L) Maximum Weekly Avg (mg/L) Loading cap (lbs./Year) Loading cap (lbs./Month) Daily Maximum (mg/L) Interim Limits 2 Total Ammonia (as N) Summer (Jul-Sep) Fall (Oct-Dec) Winter (Jan-Mar) Spring (Apr-Jun) - 2.5 2.9 1.7 - - - - - - - - 412.8 - - - 3.2 3.2 3.2 3.2 Total Phosphorous - - 2,839 - - Final Limits 3 Total Ammonia (as N) Summer (Jul-Sep) Fall (Oct-Dec) Winter (Jan-Mar) Spring (Apr-Jun) - 2.2 2.3 1.5 - - - - - - - - 337.8 - - - 2.3 2.3 2.3 2.3 Total Phosphorous - - 2,839 - - Definitions, Part VIII, for definition of terms. Interim limits are in effect until <<Date>>. Final limits go into effect on<<Date>>. SELF-MONITORING AND REPORTING REQUIREMENTSThe following self-monitoring requirements are the same 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. Self-Monitoring and Reporting Requirements1 Parameter Frequency Sample Type Units Total Flow4, 5 Continuous Recorder MGD BOD5, Influent 6 Effluent Weekly Weekly Composite Composite mg/L mg/L TSS, Influent4 Effluent Weekly Weekly Composite Composite mg/L mg/L E. coli Weekly Grab No./100mL pH Weekly Grab SU Total Ammonia (as N) Weekly Grab mg/L DO Weekly Grab mg/L Metals7, Influent Effluent 2 X Yearly 2 X Yearly Composite/Grab Composite/Grab mg/L mg/L Organic Toxics8, Influent Effluent Odd Calendar Years Odd Calendar Years Grab Grab mg/L TBPEL Rule Monitoring9 Total Ammonia (as N) Monthly Composite mg/L Orthophosphate, (as P) Effluent Monthly Composite mg/L Phosphorus, Total Influent Effluent Monthly Monthly Composite Composite mg/L mg/L Total Kjeldahl Nitrogen, TKN (as N) Influent Effluent Monthly Monthly Composite Composite mg/L mg/L Nitrate, NO3 Monthly Composite mg/L Nitrite, NO2 Monthly Composite mg/L 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 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. Testing for metals listed in the table below. The testing is conducted to support future RP analysis.Grantsville will be required to have the effluent analyzed for mercury using a method that is sensitive enough to demonstrate a presence or absence of mercury in the effluent, such as EPA Method 245.7 or 1631. A list of the organics to be tested can be found in 40CFR122 appendix D table II. These reflect changes required with the adoption of UCA R317-1-3.3, Technology-based Phosphorus Effluent Limits rule.Metals to be Monitored for RPTotal ArsenicTotal CadmiumTotal ChromiumTotal CopperTotal CyanideTotal LeadTotal MercuryTotal MolybdenumTotal NickelTotal SeleniumTotal SilverTotal Zinc 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 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 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 Reviewed byDaniel Griffin, Discharge Permit Writer, Reasonable Potential AnalysisJennifer Robinson, PretreatmentLonnie Shull, BiomonitoringSuzan 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 theDivision of Water Quality Public NoticeWebpage.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.During 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 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 BOD5 TSS DO Ammonia E. coli pH   MGD mg/L % Removal mg/L % Removal mg/L mg/L lb/mo #/100mL SU   Average Max Min Max Averag Max Acute Chronic Min Max Jan-21 0 0 Feb-21 0.43 0.69 4.8 97 3.5 98 4.5 0.7 -- -- 0.7 -- 0.5 0.5 7.6 8.4 Mar-21 0.25 0.51 11.7 93 11.3 96 7.8 0.1 -- -- 0.1 -- 0.0667 0.0667 8.9 9.0 Apr-21 0.08 0.39 5 98 5 98 4.3 0.5 0.5 -- -- -- 0.5 0.5 8.9 8.9 May-21 0 0 Jun-21 0 0 Jul-21 0 0 Aug-21 0 0 Sep-21 0 0 Oct-21 0 0 Nov-21 0.75 0.94 3 99 2 99 4.0 0.8 -- 0.44 -- -- 1 1 7.2 7.5 Dec-21 0.66 1.01 2.8 97 1 99 4.5 1 -- 0.475 -- -- 63 20 7.3 7.9 Jan-22 0.34 0.76 3.3 98 2 99 4.1 1.5 -- -- 1.4 -- 5.5 5.5 7.6 7.7 Feb-22 0.41 0.74 4.9 97 2.5 99 4.3 1 -- -- 1.0 -- 1.25 1.25 7.4 7.7 Mar-22 0.36 0.81 4.5 98 2 99 5.2 0.8 -- -- 0.6 -- 0.5 0.5 7.8 8.1 Apr-22 0.23 0.61 2.5 98 2 99 4.4 1.1 1.1 -- -- -- 1 0.75 7.9 7.9 May-22 0 0 Jun-22 0 0 Jul-22 0 0 Aug-22 0 0 Sep-22 0 0 Oct-22 0.35 0.93 3.8 97 5 98 4.5 1.3 -- 1.095 -- -- 0.5 0.5 7.7 8.2 Nov-22 0.76 0.87 3.5 97 8.0 97 4.1 2.75 -- 1.756 -- -- 0.875 4 7.2 7.7 Dec-22 0.36 0.78 2.5 97 2 99 5.0 2.07 -- 1.975 -- -- 3.5 3.5 7.9 8.1 Jan-23 0.83 0.96 5.6 97 7.8 96 10.4 1.33 -- -- 0.9 -- 0.5 0.5 8.1 8.6 Feb-23 0.87 0.94 16 94 11 98 17.8 0.32 -- -- 0.2 -- 0.625 0.625 8.5 8.7 Mar-23 0.71 0.89 9.8 96 8.2 95 11.4 0.31 -- -- 0.1 -- 0.5 0.5 8.4 8.8 Apr-23 0.73 0.76 7.3 96 7.8 95 8.0 0.6 0.433 -- -- -- 0.5 0.5 8.2 8.7 May-23 0.64 0.80 7.6 97 4.3 96 5.0 4.62 3.5 -- -- -- 0.5 0.5 7.3 8.5 Jun-23 0 0 Jul-23 0 0 Aug-23 0.16 0.63 2.5 98 2 98 5.2 2.68 -- -- -- 111.55 0.5 0.5 8.2 8.2 Sep-23 0.19 0.45 5.5 97 4 97 5.8 2.92 -- -- -- 84.01 0.5 0.5 7.8 7.9 Oct-23 0.31 0.56 3.4 99 2 99 5.3 1.89 -- 1.605 -- -- 0.5 0.5 7.6 8.0 Nov-23 0.60 0.70 2.5 99 2.4 98 6.7 0.97 -- 0.588 -- -- 0.5 0.5 7.5 7.7 Dec-23 0.72 0.89 2.5 99 2 99 6.5 1.84 -- 1.03 -- -- 2 1 7.2 7.6 Flow NH3 + NH2 Ortho P TKN Total P Flow NH3 + NH2 Ortho P TKN Total P MGD mg/L mg/L mg/L mg/L MGD mg/L mg/L mg/L mg/L Jan-21 0 Jul-22 0 Feb-21 0.43 20.3 3.5 0.5 5.1 Aug-22 0 Mar-21 0.25 18.2 4 1.1 4.7 Sep-22 0 Apr-21 0.08 7.6 2.7 1.7 3.4 Oct-22 0.35 0.1 6.5 4.2 7.1 May-21 0 Nov-22 0.76 3.81 5.7 3.8 6.25 Jun-21 0 Dec-22 0.36 8.4 4.8 1.8 5 Jul-21 0 Jan-23 0.83 11.6 4.5 0.5 4.5 Aug-21 0 Feb-23 0.87 8.74 4.1 1.3 5 Sep-21 0 Mar-23 0.71 9.77 3.8 11.3 4.54 Oct-21 0 Apr-23 0.73 3.66 3.5 1.7 4.55 Nov-21 0.75 11.3 4.1 0.5 5.3 May-23 0.64 1 5.7 3.5 7.075 Dec-21 0.66 14 3.7 0.5 5 Jun-23 0 Jan-22 0.34 20.8 4.2 0.5 4.4 Jul-23 0 Feb-22 0.41 20 4.4 0.5 4.4 Aug-23 0.16 0.65 3.5 3.3 4.7 Mar-22 0.36 17.1 4.4 0.5 4.8 Sep-23 0.19 0.6 3.5 2 5.45 Apr-22 0.23 1.8 5.6 1.6 6.1 Oct-23 0.31 0.41 4.6 2.9 5.725 May-22 0 Nov-23 0.60 2.08 4.5 1.5 5.888 Jun-22 0 Dec-23 0.72 0.94 3.8 1 4.825 Metals Monitoring, mg/L Ag As Cd CN Cr Cu Hg Mo Ni Pb Se Zn Jun-19 0.00025 0.0015 0.0001 0.001 0.0005 0.0047 0.0001 0.0009 0.0037 0.00025 0.0012 0.02 Dec-19 0.00025 0.0017 0.0001 0.001 0.0032 0.0001 0.0011 0.0024 0.00025 0.0006 0.02 Jun-20 0.00025 0.0011 0.0001 0.001 0.0005 0.0046 0.0001 0.0006 0.0012 0.00025 0.00025 0.05 Dec-20 0.00025 0.0016 0.0001 0.001 0.00025 0.0017 0.0001 0.0012 0.0013 0.00025 0.00025 0.02 Jun-21 0.00025 0.0009 0.0001 0.001 0.00025 0.0036 0.0001 0.0007 0.0008 0.00025 0.00025 0.04 Dec-21 0.00025 0.0014 0.0001 0.003 0.00025 0.0017 0.0001 0.001 0.001 0.00025 0.0005 0.02 Jun-22 0.00025 0.0011 0.0001 0.001 0.00025 0.0032 0.0001 0.0008 0.0009 0.00025 0.00025 0.04 Dec-22 0.00025 0.0011 0.0001 0.001 0.00025 0.002 0.0003 0.0007 0.001 0.00025 0.0005 0.005 Jun-23 0.00025 0.0017 0.0001 0.001 0.0005 0.0022 0.000075 0.0008 0.0022 0.00025 0.001 0.01 Dec-23 0.00025 0.0009 0.0001 0.001 0.0005 0.0005 0.000075 0.0006 0.0006 0.00025 0.0005 0.005 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.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 cyanide and mercury. A review of the mercury results indicates that there are only 10 samples, all Non-Detects and that the results are at the MRL for EPA Method 245.1 (0.00015 mg/L), which is higher than the WQBEL indicated in the WLA. The RP Model cannot be used confidently to determine the need for a limit with so few values. Establishing a mercury limit at this time would require a compliance schedule which would include an in-depth study of the effluent using a more sensitive analysis method, several years for planning and several more of construction. In other instances where the MRL for mercury has been above the WQBEL the chosen path has been to focus on the improvement of the analysis and then reevaluate during the next renewal. This result indicates that the inclusion of an effluent limit for mercury is not recommended at this time, but routine monitoring requirements will be improved in the permit. (Outcome B from Reasonable Potential Guide) A review of the cyanide data indicated that there are only 10 samples, all are Non-Detects and that the results are at the MRL for Method SM 4500 CN-E (0.002 mg/L). The RP Model cannot be used confidently to determine the need for a limit with so few values. This result indicates that the inclusion of an effluent limit for cyanide is not recommended at this time, and routine monitoring requirements will remain as is in the permit. (Outcome C from Reasonable Potential Guide) The Metals Initial Screening Table and Mercury and Cyanide Summary Table are included below attachment.Metals Monitoring and RP Check Metals RP Screening Metal Ag As Cd CN Cr III Cr VI Cu Units mg/L mg/L mg/L mg/L mg/L mg/L mg/L Max 0.00025 0.0017 0.0001 0.003 0.0005 0.0005 0.0047 WQBEL for Metals Acute 0.021 0.34 0.005 0.022 1.401 0.016 0.0378 Chronic 1 0.15 0.0016 0.0052 0.182 0.011 0.0229 RP Screening Results Acute No No No No No No No Chronic No No No Yes No No No Metals RP Screening Metal Hg Mo Ni Pb Se Zn Units mg/L mg/L mg/L mg/L mg/L mg/L Max 0.00015 0.0012 0.0037 0.00025 0.0012 0.05 WQBEL for Metals Acute 0.0024 1 1.186 0.209 0.0184 0.297 Chronic 0.000012 1 0.132 0.0081 0.0046 0.3 RP Screening Results Acute No No No No No No Chronic Yes No No No No NoCyanide and Mercury Monitoring Results Metals Monitoring, mg/L CN Hg Jun-19 ND ND Dec-19 ND ND Jun-20 ND ND Dec-20 ND ND Jun-21 ND ND Dec-21 ND ND Jun-22 ND ND Dec-22 ND ND Jun-23 ND ND Dec-23 ND ND MRL 0.002 0.00015 Grantsville has been reporting effluent monitoring results for beryllium, antimony, phenols, and thallium since 1999. The results forberyllium, phenols, and thallium have been below the MRL (no detect). There have not been any WQBEL for beryllium, antimony, and thallium, and there is no indication that Grantsville would have any industrial contributors that would elevate those pollutants of concern in the effluent. If the RP model was run on these parameters the result would be “Outcome B: No limitation or routine monitoring requirements are in the permit”. As a result of this the reporting for beryllium, antimony, phenols, and thallium will be removed from the DMR’s. The monitoring results for these parameters are included in a table below. Other Parameters Antimony Beryllium Phenols Thallium Month mg/L mg/L mg/L mg/L Jun-19 0.0006 ND ND ND Dec-19 0.0006 ND ND ND Jun-20 0.0007 ND ND ND Dec-20 0.0007 ND ND ND Jun-21 0.0007 ND ND ND Dec-21 0.0007 ND ND ND Jun-22 0.0007 ND ND ND Dec-22 ND ND ND ND Jun-23 0.0008 ND ND ND Dec-23 ND ND ND ND MRL 0.0005 0.0005 0.05 0.0002 WQBEL Acute -- -- -- -- Chronic -- -- -- --