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HomeMy WebLinkAboutDWQ-2024-006021Official 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 MCWANE DUCTILE – UTAH, A DIVISION OF MCWANE, INC. RENEWAL PERMIT: DISCHARGE UPDES PERMIT NUMBER: UT0000612 MINORINDUSTRIAL FACILITY CONTACTSOwner Name:McWane, Inc.Contact:Jared EllisonPosition: Vice President and General ManagerPhone Number:801-373-6910Person Name:Christy Seiger WebsterPosition:Environmental ManagerPhone Number:801-201-2585Person Name:David ReesePosition:Environmental SpecialistPhone Number:801-623-4232Facility Name:McWane Ductile - UtahMailing Address:P.O. Box 1219Provo, Utah 84603 Telephone:(801) 373-6910 Fax:(801) 377-0338Actual Address:2550 South Industrial Parkway, in Provo DESCRIPTION OF FACILITYMcWane, Inc. owns and operates a ductile iron foundry in Provo Utah known as McWane Ductile - Utah (MDU); there is a landfill also located on site for disposal of non-hazardous solid waste from the facility. The MDU operations are located at 2550 South Industrial Parkway, in Provo, Utah at latitude 4011'54" N and longitude 11138'00"W. MDU Standard Industrial Classification (SIC) code is 3321 for cast iron foundries. MDU produces cement lined ductile iron pipes used in the drinking water industry as well as ductile iron utility poles.Scrap iron is melted in a cupola furnace, poured into molding machines, cooled, then the pipe are cement-coatedand poles sent for further processing. MDU uses non-contact cooling water for the furnace and moldingprocesses. Wastewater generated from hydrostatic testing of the pipe, during the process of cement-lining, andother miscellaneous contact water is contained on-siteMonitoring of copper, lead, and zinc was eliminated during a previous permit cycle based on data demonstrating that these metal concentrations were below the corresponding waste load analysis. To confirm that monitoring is still not required (and at Division of Water Quality’s request), MDU provided recent representative samples of effluent from Outfall 001, all of which exhibited concentrations below detection for these metals.When Reilly Industries did not renew its authorization to discharge to the Ironton Canal, the thermal load calculations were revised to reflect conditions. The thermal loading was, therefore, recalculated reflecting existing UPDES permit contributions and resulting in a revision to MDU authorized load allocation. MDU collects groundwater for their use from springs in a reservoir on site that is referred to as the million-gallon reservoir. The water flows over a weir and out of the reservoir to the Ironton Canal through the outfall structure. They take water from the reservoir and/or directly from the Ironton for use in the facility. They can blend both sources of water to manage the incoming temperature to prevent a system failure as a result of temperature shock from Ironton water during the winter. The process cooling water from the plant is also discharged to the reservoir. MDU has been replacing casting equipment and other systems at the facility. In order to properly operate the new systems, they added closed loop, non-contact cooling water systems, and cooling towers to maintain the system temperature for the equipment. The water for the towers is drawn from the culinary water supply. MDU completed a Level II anti-degradation review (ADR) in anticipation of the system changes. The ADR addressed the changes in TDS and TRC loading. The determination from the ADR is that the investments in the cooling towers and improvements with the discharge will not negatively impact the designated uses of the Ironton Canal and later Provo Bay. TDS, and TRC limits were added to the permit at that time. The TRC effluent limit is below the minimum quantification level (MQL) of the most common and practical EPA approved TRC methods. The Division has determined the current acceptable MQL to be 0.06 mg/L and the method detection limit (MDL) to be 0.02 mg/L when using the DPD colorimetric Method #4500 – CL G. Measured values greater than or equal to the MQL of 0.06 mg/l will be considered violations of the permit, and values less than the MQL of 0.06 mg/l will be considered to be in compliance with the permit. For purposes of calculating averages and reporting on the Discharge Monitoring Report form, the following will apply: 1) Analytical values less than 0.02 mg/L shall be considered zero; and 2) Analytical values less than 0.06 mg/L and equal to or greater than 0.02 mg/L will be recorded as measured. SUMMARY OF CHANGES FROM PREVIOUS PERMIT Total Suspended Solids (TSS), Utah Secondary Treatment Standards In August 2020, DWQ amended the secondary treatment requirements found in Utah Administrative Code (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 TSS do not automatically apply to industrial facilities, unless otherwise required by their EPA effluent limitation guidelines (ELG). The North American Industry Classification System (NAICS) Code for the MDU plant is 331511: Iron Foundries, which applies to is Part 464Metal Molding and Casting Point Source Category. This category does not have any ELG for non-contact cooling water discharges. As a result, the limits for TSS will be removed from the permit. R316(b) In 2014, the EPA finalized rulemaking in association 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 the impacts of water intakes on threatened and endangered species. Under these regulations, if a Permittee meets the minimum requirements, they must evaluate the intake structure and the source water to determine if any listed threatened or endangered species might be impacted by the intake of water. Then they must implement one of the Applicable Best Technology Available for Minimizing Adverse Environmental Impact (BTA) standards, and reduce or eliminate the impingement and/or the entrainment of those species. While evaluating the facility and cooling water intake structure (CWIS) it was determined that the actual intake flow is not above the minimum of 2 MGD required for the requirements to be applicable to MDU. The DWQ has determined that they do not meet the applicability requirements of Subpart J, according to Part 125.91 (a)(2). The DWQ has also determined that MDU should establish intake flow monitoring in such a way that they can demonstrate in the future that the actual intake flow is below the 2 MDG minimum requirement. This will be addressed through a compliance schedule (CS) in the permit. The CS will require the submission of Annual Reports to document the progress being made toward intake monitoring. The first report will be due January 28th, 2025 and should include a report on the current state of the intake flow monitoring and what changes MDU will need to complete in order to monitor and report the intake flows. Every January 28th until the permit is renewed a follow up report will be due. The follow-up reports should include an update on the progress of the intake monitoring system and a summary of any monitoring that has been completed. By the time the January 28, 2028 report is submitted, MDU should have completed all work to establish intake flow monitoring should just be reporting a summary of flows that are measured. While the CS is in place, the flow measurement of the intake water will be reported in the annual reports. Any violation of the CS is a violation of the permit. DISCHARGE DESCRIPTION OF DISCHARGE MDU has been reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis. A summary of 3 years of data is included at the end of the Fact Sheet and there were no discharge violations. MDU’ authorized discharges of process water are generated from the non-contact cooling of the cupola and casting machines, i.e., the “cooling water,” which is discharged into an on-site holding pond. The cooling water is mixed in the holding pond with water from the Boardman spring, and discharges from the pond to the Ironton Canal are permitted as Outfall 001. The cooling water is conditioned to prevent corrosion in the system. They currently use a product known as Inhibitor ISI 8220. The dosing concentrations of the additive were not to exceed 5.0 parts per million (ppm) in the plant effluent discharge to the Ironton Canal, and there has been no evidence of any impact from the use.DWQ staff examined the product’s chemical properties and environmental data. The resultant concentration of product in the Ironton Canal was determined to have minimal ecological impact. While using the corrosion inhibitor, DWQ requested that MDU increase the effluent pH monitoring frequency for pH levels to weekly this change has been carried over and incorporated into the new permit. If the concentration of the additive exceeds 5.0 ppm in the discharge during any 24-hour period, this approval will be void. MDU will take measures to prevent over-application of the inhibitor. If applicable, MDU could be subject to enforcement for any violation of the Narrative Water Quality standards or other regulations pertaining to this or other discharge of pollutants to the receiving water. The permittee is liable for any adverse water quality impacts from use of treatment chemicals pursuant to the Narrative Standard. If the inhibitor use needs to be adjusted or changed during the new permit cycle, the changes will follow the same process as they did for the current product, and approval will be granted or denied in writing.MDU currently operates a closed system for all other process water generated from its operations. This process water, referred to as “basement water,” originates underneath the pipe mold casting machines in a basement or cellar to cool “over-iron” during production. This water is circulated through on-site holding ponds (distinct from the holding pond associated with the UPDES discharge of the noncontact cooling and spring water) and reintroduced to the basement. There are no outfalls associated with “basement water.” MDU is currently working with the Division of Water Quality to evaluate alternative process water management systems that may include active treatment and discharge to a publicly owned treatment works (POTW) or to receiving water. These projects, along with potential permit changes associated with other possible operational changes, could result in permit modifications or additions during this permit term.OutfallDescription of Discharge Point 001 Located at latitude 4011'59" and longitude 11137'52".The discharge flows into Ironton Canal thence into the Utah Lake. The Ironton Canal is classified 2B, 3C and 4 at this location according to Utah Administrative Code (UAC) R317-2-13. RECEIVING WATERS AND STREAM CLASSIFICATION If a discharge were to occur, it would be pumped into an irrigation ditch, which is a Class 2B, 3C, and 4 according to UAC R317-2-13: Class 2B -- Protected for infrequent primary contact recreation. Also protected for secondary contact recreation where there is a low likelihood of ingestion of water or a low degree of bodily contact with the water. Examples include, but are not limited to, wading, hunting, and fishing. Class 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 MAXIMUM 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, “Tributary to Spring Creek (Utah County) which receives the Springville City WWTP effluent from confluence with Spring Creek to headwaters (Assessment Unit Spring Creek-Springville, AU ID: UT16020202-042_00)” was listed as “Fully Supporting”. Utah Lake (Assessment Unit Utah Lake-Lower Provo River, AU ID: UT-L-16020201-004_01) was listed as “Not Supporting” for E. coli, eutrophication, harmful algal blooms, total dissolved solids, total phosphorus, and PCBs in fish tissue on the 2022 303(d) list of impaired waterbodies. Furthermore, Provo Bay (Assessment Unit Utah Lake-Lower Provo River, AU ID: UT-L-16020201-004_02) was listed as “Not Supporting” for eutrophication, harmful algal blooms, total phosphorus, pH, total ammonia, and PCBs in fish tissue on the 2022 303(d) list of impaired waterbodies. The Utah Lake Water Quality Study is ongoing with the objective to develop numeric nutrient criteria for Utah Lake and Provo Bay. BASIS FOR EFFLUENT LIMITATIONS Limitations on pH are based on current Utah Secondary Treatment Standards, UAC R317-1-3.2. Based on Best Professional Judgment (BPJ), oil and grease shall not be monitored unless sheen on the effluent is visible. If an oil and grease sample is taken, it shall not exceed 10 mg/L as a daily maximum. Limitation on TDS and TRC are Water Quality Based Effluent Limits (WQBEL) developed in the WLA. DWQ has evaluated the temperature of the noncontact cooling water discharge from Outfall 001. Utah water quality standards for the receiving waters, i.e., UAC R317-2-14, Table 2.14.2, limit temperature to the maximum in the stream of 27oC and no more than a 4oC temperature change. The permittee will monitor Temperature (Teff, oF) and flow (Qeff, MGD) and will calculate the thermal discharge according to the following equations:Summer FallSpringWinter Based on effluent monitoring data and the existing facility, the permittee is expected to be able to comply with these limitations. The Wasteload Analysis indicates that these limitations should be sufficiently protective of water quality, in order to meet State standards in the receiving waters. Attached is a Wasteload Analysis for this discharge into the Ironton 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. 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 There are currently no effluent parameters that are associated with this type of discharge that are not already being monitored, and have effluent limits associated with them. Based on this, we did not have any parameters to conduct RP on. The permit limitations are Parameter Effluent Limitations 1 Maximum Monthly Avg Maximum Weekly Avg Yearly Average Daily Minimum Daily Maximum Total Flow, MGD 3.5 - - - - TRC, mg/L 0.013 0.023 - - - Oil & Grease, mg/L - - - - 10.0 pH, Standard Units - - - 6.5 9 TDS, mg/L - - - - 1200 Thermal, F Summer, Teff/(Qeff-0.165) Fall, Teff/(Qeff-0.182) Winter, Teff/(Qeff--0.193) Spring, Teff/(Qeff-0.173) - - - - - - - - - - - - - - - - 98.47 89.855 85.204 93.699 See Definitions in Part VI of the permit. 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 Requirements 1 Parameter Frequency Sample Type Units Total Flow Weekly Recorder MGD TRC, mg/L, 2, 3 Weekly Grab mg/L TDS, mg/L, Monthly Grab mg/L Oil & Grease 4 When Sheen Observed Grab mg/L pH Weekly Grab SU Temperature Weekly Composite mg/L See Definitions in Part VI of the permit. Analytical results less than 0.06 mg/l will not be considered out of compliance with the permit. For purposes of calculating averages and reporting on the Discharge Monitoring Report form, the following will apply: 1)Analytical values less than 0.02 mg/L shall be considered zero; and 2)Analytical values less than 0.06 mg/L and equal to or greater than 0.02 mg/L will be recorded as measured TRC is to be sampled when Chlorine has been used. If no Chlorine has been used, a NODI Code of 9 should be used. Oil & Grease is to be sampled when sheen is present or visible. If no sheen is present or visible, a NODI Code of 9 should be used. 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 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. 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 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 Provo City. 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.MDU 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. COOLING WATER INTAKE STRUCTURE MDUproduces cement lined ductile iron pipes used in the drinking water industry as well as ductile iron utility poles. Scrap iron is melted in a cupola furnace, poured into molding machines, cooled, then cement-coated. MDUuses non-contact cooling water for the furnace and molding processes. Wastewater generated from hydrostatic testing of the pipe, during the process of cement-lining, and other miscellaneous contact water is contained in on-site lagoons. MDU collects groundwater for their use from springs in a reservoir on site that is referred to as the Million-Gallon Reservoir. The water flows over a weir and out of the reservoir to the Ironton Canal through the outfall structure. MDU also draws water from the Ironton Canal for use in the cooling water system. They blend both sources of water to manage the incoming temperature to prevent a system failure as a result of temperature shock from Ironton water during the winter, and to increase the cooling ability during the summer. The non-contact cooling water from the plant is discharged to the Million-Gallon Reservoir. Water drawn from the Ironton is screened and then mixes in the pipes with water from the Million-Gallon Reservoir and is sent to the plant. There is one MDU CWIS, as defined at 40 CFR 125.83, subject to the requirements of 40 CFR 122.21(r). The CWIS consists of two 12‐inch diameter circular intakes (east intake and west intake), approximately 4.0 feet apart, that merge then flow to a 20‐inch pipe containing water flowing from the “million‐gallon reservoir” to the MDU facility. There are accessible valves which can be used to close the intakes. The entire CWISis encapsulated by a screen (0.5” to 1.0” mesh) fully extending to the canal bed and above the canal water level, even at high water levels. Inside of the encapsulating screen, each intake has two separate screens of 40” by 19” with 0.5” to 1.0” mesh which fully block the intake. The center of each intake is approximately 2.0 feet below the top of the screen. The east intake is at 40°11’58.45”North Latitude and 111°37’55.69” West longitude. The west intake is at 40°11’58.47” North Latitude and 111°37’55.74” West Longitude. The CWIS operates during facility production hours. Generally, this is 10 hours per day. The facility operates year‐round, but there were 189 production days in 2023. Both intake points operate simultaneously. Intakes are fully screened, with flow adjusted by operating each intake’s valve. Source Waterbody Description Summary The Ironton Canal is a man‐made water diversion from Spring Creek and a tributary of Utah Lake. It is approximately 23 feet wide and four feet deep at the intake structure location. The intake structure pulls water by gravity alone through dual screens and is therefore believed to not significantly influence water in the canal further than approximately two feet distant. MDU can partially raise the level of the canal in the facility vicinity by partially blocking a culvert further downstream on our property. MDU uses the culvert to maintain water levels within range of the intake screens. Screens may be removed for cleaning or repair but are only to be removed during non‐operational hours when inflow is minimal. These measures do not affect water quality for the aquatic species. Critical Species MDU obtained an official threatened and endangered species list from USFWS in February 2024. It is included with this package. There are no aquatic threatened, endangered, or fragile species that are likely to occur on MDU property. The nearest species of concern, the June Sucker (Chasmistesliorus) fish, has designated critical habitat along the primary shoreline of Utah Lake. Although no known formal field studies have occurred to document the biological community in the vicinity of the cooling water intake structure, no June Sucker fish have been observed in recent years. An estimated 90% of observed fish are adult non‐native common carp (Cyprinus carpio) and the balance are species including but not limited to white bass, largemouth bass, and channel catfish. In the vicinity of the CWIS, the common carp are top and bottom detritus feeders while other species appear to largely migrate through. According to the Utah Division of Wildlife Resources, “carp spawn during the spring and summer, usually in shallow water. Large numbers of eggs (large females can produce well over 1 million eggs) are released into the water and hatch in one to two weeks.” Amphibians and reptiles are only very rarely observed here, likely due to facility activities. Thus, the carp are the species most susceptible to impingement and entrainment. The Ironton Canal‐ Lower has a No Evidence of Impairment listing in the Utah Department of Environmental Quality Final 2022 Integrated Report: 305(b) and 303(d). The results of the search are included in Attachment<5>of the FSSOB. This search, the Species List, the Permit Application, and PAR’s were submitted to the USFW, Utah Field Office for review. No comments or concerns were returned to DWQ. No entrainment studies have been conducted for the MDU facility to include in the permit application. Cooling Water System Data It is estimated that, year‐round, canal water withdrawals are approximately five times that of metered city water usage used as supplemental process water. This amounted to approximately 104 million gallons in 2023, or 198 gallons per minute (gpm). However, higher proportions of canal water are used in summer because canal intake water is cool relative to reservoir and city water, which assists in the cooling process. The maximum canal water use month for 2023 is believed to have been May, when approximately 15,867,071 gallons were withdrawn. When limited to production hours for May 2023, this equals 1,202 gpm. If rounded up to 1,300 gallons per minute, this equals 1.87 million gallons per day (mgd). Engineering diagrams, intake maximum flow calculations, data of 2023 plant water use from the Ironton Canal and a water flow diagram are attached. MDU has taken active measures to minimize impingement and entrainment. First, the entire cooling water intake structure is encapsulated by a screen (0.5” to 1.0” mesh) fully extending to the canal bed and above the canal water level, even at high water levels. Inside of this screen, each intake has two separate screens of 39.5” by 20” with 0.5” to 1.0” mesh which fully block that intake. The facility can partially raise the level of the canal in the facility vicinity by partially blocking a culvert further downstream on our property. MDU uses this culvert to maintain water levels within range of the intake structure screens. Screens may be removed for cleaning or repair. Specific Entrainment Requirements Impingement and Entrainment As detailed in the previous section (Cooling Water System Data), data supports the assertion that the facility does not meet the criteria set forth in 40 CFR 125.91(a)(2) of the intake structure having a design intake flow of greater than 2 MGD. Therefore, the facility does not believe itself to be subject to the requirements of 40 CFR 125.94 and 40 CFR 122.21(r)(6). Nevertheless, the facility believes it has a de minimis rate of impingement as described at 40 CFR 125.94(c)(11). The DWQ has reviewed the information submitted with the permittee’s application. The information indicates that there are no threatened or endangered aquatic species, nor any habitat critical to their survival in the Ironton Canal. MDU has taken measures to minimize impingement and entrainment through the use of two layers of mesh screens and having the ability to maintain canal water levels at a point to ensure the intakes are always submerged. The information also indicates that due to the actual flows being less than the minimum of 2 MGD set int Part 125.91, MDU is not subject to the CWIS Requirements. The DWQ has determinedthat MDU does not meet the criteria in 40 CFR 125.91(a)(2), and is not subject the BTA Impingement and Entrainment Requirements. The DWQ has also determined that the actual intake flow (AIF) through the CWIS should be measured and reportedto confirm the flows are below the minimum. Intake flow monitoring will be added to the permit. Permit Requirements The proposed permit will contain the following language as required by 40 CFR 125.98(b)(1), “Nothing in this permit authorizes take for the purpose of a facility’s compliance with the Endangered Species Act.” The proposed permit requires MDU measure intake flows in such a way as to demonstrate continued compliance with the minimum flow determination. 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, BiomonitoringScott Daley, TMDL/Watershed Suzan Tahir, Wasteload AnalysisUtah Division of Water Quality, (801) 536-4300PUBLIC NOTICEBegan: Month Day, YearEnded: Month Day, YearComments will be received at: 195 North 1950 West PO Box 144870 Salt Lake City, UT 84114-4870The Public Noticed of the draft permit was published in the 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.Responsiveness Summary(Explain any comments received and response sent. Actual letters can be referenced, but not required to be included). This Page Intentionally Left Blank ATTACHMENT 1 Site Map and Flow Diagram This Page Intentionally Left Blank This Page Intentionally Left Blank ATTACHMENT 2 Effluent Monitoring Data This Page Intentionally Left Blank Effluent Monitoring Data  Parameter Flow TSS TDS pH Temp Thermal Units MGD kg/d mg/L SU deg F MBTU/d Ave Max Ave/Max Max Min Max Max Max Limit 729/1021 1200 6.5 9 103.43 99.18 109.56 112.46 Jul-21 0.465 0.52 15.5 864 6.8 7.3 88.3 71.76 Aug-21 0.48 0.48 16.0 944 6.6 7.1 86 72.69 Sep-21 0.45 0.5 15.0 932 6.8 7.4 87.7 73.5 Oct-21 0.424 0.58 11.7 868 7.1 7.5 89.5 68.36 Nov-21 0.505 0.86 28.7 868 7.2 7.6 84.4 72.66 Dec-21 0.311 0.36 10.4 676 7.3 7.4 78.6 54.83 Jan-22 0.873 2.11 29.1 888 7.3 7.8 73.6 94.65 Feb-22 0.954 0.95 31.8 840 7.5 7.5 69.5 68.41 Mar-22 0.925 2.45 30.9 872 7.2 7.8 78.9 100.44 Apr-22 0.407 0.86 20.4 812 7.3 7.9 81.3 72.79 May-22 0.475 0.67 15.9 832 7.4 8.4 86.2 78.78 Jun-22 0.332 0.51 11.1 796 7.2 7.7 92.3 79.02 Jul-22 0.487 0.74 28.5 852 6.9 7.8 93.2 86.88 Aug-22 0.361 0.51 72.3 896 7.4 7.5 98.3 77.6 Sep-22 0.236 0.36 7.9 824 6.9 7.3 92.2 71.75 Oct-22 0.78 1.86 39.0 844 6.6 7.6 85.7 95.19 Nov-22 0.878 1.38 29.3 680 6.9 8.2 78 81.91 Dec-22 0.581 0.86 19.4 928 6.7 7.9 82.1 70.97 Jan-23 0.719 1.27 36.0 1190 7.8 8.1 79.1 85.34 Feb-23 0.368 0.51 12.3 968 7.9 8.3 79.1 59.02 Mar-23 0.677 1.16 33.9 968 7.4 8.2 72.8 76.52 Apr-23 0.674 0.67 22.5 1040 7.3 7.7 74.3 67.91 May-23 0.925 1.38 46.3 952 7.6 7.8 83.5 85.22 Jun-23 1.246 1.49 52.0 1150 7.7 7.9 86.6 94.9 Jul-23 1.036 1.44 34.6 1080 7.4 7.7 86.6 93.21 Aug-23 1.215 1.38 57.5 1040 7.4 7.7 81.5 85.14 Sep-23 1.228 1.38 80.6 980 7.6 7.9 87.6 89.66 Oct-23 1.009 1.44 50.5 1080 7.5 7.7 76.8 85.33 Nov-23 1.268 1.27 42.3 1030 7.7 7.7 79.3 84.97 Dec-23 1.109 1.21 71.6 1000 7.8 8 80.6 85.26 Jan-24 0.922 1.27 30.8 984 7.5 7.8 73.2 79.28 Feb-24 1.426 2.38 47.6 1120 7.7 8 68.5 91.72 Mar-24 1.244 1.67 41.5 964 7.7 7.9 73.8 81.71 Apr-24 1.286 1.32 42.9 960 7.7 7.9 70.3 74.21 May-24 1.394 1.49 46.5 1050 7 7.8 75.7 80.47 Jun-24 1.389 1.79 58.0 1040 7.7 7.9 76.6 83.61 This Page Intentionally Left Blank 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.An initial review of the pollutants of concern for this facility and the corresponding values submitted through the discharge monitoring reports showed that there was no need to examine them more closely. For this discharge, there are no corresponding ELGs limits or pollutants of concern (POCs) that are not already covered by the limits developed in the WLA. This Page Intentionally Left Blank ATTACHMENT 5 Species List_ Utah Ecological Services Field Office (March 2024) This Page Intentionally Left Blank ATTACHMENT 6 Cooling Water Intake Structure Permit Application Requirements This Page Intentionally Left Blank