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Home My WebLink AboutDWQ-2024-006506Official 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 GREEN RIVER WASTEWATER TREATMENT FACILITY RENEWAL PERMIT: DISCHARGE& REUSE UPDES PERMIT NUMBER: UT0025771 MINOR MUNICIPAL FACILITY CONTACTSOperator Name:City of Green RiverPerson:Travis BaconPosition: MayorPhone Number:(435) 564-3448Person Name:Bryan MeadowsPosition:Public Works DirectorPhone Number:(435) 491-0723Permittee Name:City of Green RiverFacility Name:Green River Wastewater Treatment PlantMailing and Facility Address:Green River City OfficesPO Box 620Green River, Utah 84525Telephone:(435) 564-3448 Actual Address:1285 South Sillimans Lane DESCRIPTION OF FACILITY The Green RiverWastewater Treatment Plant(GRWTP) is located at 1285 South Sillimans Lane, Green River, Utah and serves the City of Green Riverwith the outfall located at latitude3858' 50" and longitude 1109' 8". The design capacity is 0.56 million gallons per day (MGD), population of approximately 1,000, Daily average operating flow is approximately 0.199 MGD. The original facility was built to be a total containment system comprised of facultative lagoons, winter storage, and land application. However, the modifications needed to land apply wastewater, and use it for irrigation of crops was never installed. Up until 1996 the GRWTP has not needed to discharge water from this system, but because of growth in the late nineties, the GRWTP was issued a Utah Pollutant Discharge Elimination System (UPDES) permit and discharged to waters of the State. After a series of upgrades were made to stop infiltration and inflow (I and I), the City no longer needed to discharge and let the permit lapse. However, due to some failures of some of the upgrades for I and I prevention, and recent precipitation in the area, the City reapplied for a discharge permit. Some of the upgrades in the larte 1990’s besides the upgrades to reduce I and I, included a discharge outlet and a Biolac system (difused air). This system helped with evaporation and introducing oxygen into the lagoons to help with odors problems. The facility has a grinder (at the fourth and final lift station), one primary cell, two secondary cells and a winter storage pond. The total surface area of the lagoons in 30 acres. SUMMARY OF CHANGES FROM PREVIOUS PERMIT FACILITY has improved treatment and changed some of the process on site. Most notably they have added a UV Disinfection System and added a Solar Dryer for biosolids treatment. The UV system was added after the chlorination system. The chlorination system is still operational as a backup, and will be maintained but is not required as long as the UV system is operating. The facility will produce Type I reuse water and the renewal permit will include provision covering the Type I reuse of the effluent. The total residual chlorine limit (TRC) is based on the acute TRC water quality standard at end-of-pipe, and is retained from the previous permit. This effluent limit is below the minimum quantification level (ML) of the most common and practical EPA approved TRC methods. The Division has determined the current acceptable ML to be .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 ML of .06 mg/l will be considered violations of the permit, and values less than the ML of .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 .06 mg/L and equal to or greater than .02 mg/L will be recorded as measured. TBPEL Rule Water Quality adopted UAC R317-1-3.3, Technology-Based Phosphorus Effluent Limit (TBPEL) Rule in 2014. No TBPEL will be instituted for discharging treatment lagoons. Instead, each discharging lagoon will be 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 will be established and referred to as phosphorus loading cap. Once the lagoon's phosphorus loading cap has been reached, the owner of the facility will have five years to construct treatment processes or implement treatment alternatives to prevent the total phosphorus loading cap from being exceeded. The load cap shall become effective July 1, 2018. 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, E, 1, a. Influent for total phosphorus (as P) and total Kjeldahl nitrogen (as N) concentrations; R317-1-3.3, E, 1, b. Effluent for total phosphorus and orthophosphate (as P), ammonia, nitrate-nitrite and total Kjeldahl nitrogen (an N); In R317-1-3.3, E, 3 the rule states that all monitoring shall be based on 24-hour composite samples by use of an automatic sampler or a minimum of four grab samples collected a minimum of two hours apart. DISCHARGE DESCRIPTION OF DISCHARGE GRWTP currently treats domestic wastewater from the City of Green River. The discharge is through a 12” concrete pipe, directly into the Green River. GRWTP has been self-monitoriing results on Discharge Monitoring Reports (DMRs) on a monthly basis, and has only discharged XXXX times since the beginning of the current permit. GRWTP land applies a portion of the water on their property. GRWTP’s land application reuse is currently covered under permit No. UTOP002## General Permit for Land Disposal of Treated Wastewater under coverage No. UTOP00207. is a total reuse facility. FACILITY maintains a UPDES permit in the event that a discharge from their facility is necessary. ENTITY has been reporting self-monitoring results on Discharge Monitoring Reports on a monthly basis. FACILITY discharged for 3 days in 2005 during a previous permit cycle. There have been no violations or discharges since 2005.OutfallDescription of Discharge Point 001 Located at latitude3858' 50" and longitude 1109' 8". The discharge flows directly into the Green River.OutfallDescription of Reuse Water Discharge Point 001R Located at latitude 4035'40" and longitude 11219'40". The discharge is through a pipe to ponds on the Overlake Golf Course. The water is then used to irrigate the golf course. It is also available at the plant for use in dust control activities in Permittee. RECEIVING WATERS AND STREAM CLASSIFICATION If a discharge were to occur, it would be pumpedinto the Green River, which is a Class 1C, 2A, 3B and 4according to UAC R317-2-13: Class 1C -- Protected for domestic purposes with prior treatment by treatment processes as required by the Utah Division of Drinking Water Class 2A -- Protected for frequent primary contact recreation where there is a high likelihood of ingestion of water or a high degree of bodily contact with the water. Examples include, but are not limited to, swimming, rafting, kayaking, diving, and water skiing. 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 MAXIMUM DAILY LOAD (TMDL) REQUIREMENTS According to the Utah’s 2016 303(d) Water Quality Assessment Report dated December 7, 2016, the receiving water for the discharge, Kanab Creek and tributaries from the confluence with Fourmile Hollow near the White Cliffs to Reservoir Canyon (UT15010003-003_00) was listed as impaired for Selenium, Boron and Total Dissolved Solids (TDS). No TMDL has been completed for this watershed at this time. As a result, effluent limits will be placed in the permit. These limits will be at the Water Quality Standard for boron and selenium. The TDS limit will be set by the site-specific standard. WATER RIGHTS STATE ENGINEER APPROVAL The State engineer approved the Permittee’s Water Rights on DATE. This approval is attached to the Reuse Project Plan for this facility, which is available upon request. 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. The oil and grease is based on best professional judgment (BPJ). 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: Total dissolved solids (TDS) limitations are based upon Utah Water Quality Standards for concentration values and the Colorado River Basin Salinity Control Forum (CRBSCF) for mass loading values when applicable as authorized in UAC R317-2-4. CRBSCF has established a policy for the reasonable increase of salinity for municipal discharges to any portion of the Colorado River stream system that has an impact on the lower main stem. The CRBSCF Policy entitled “NPDES Permit Program Policy for Implementation of Colorado River Salinity Standards” (Policy), with the most current version dated October 2020, states that the incremental increase in salinity shall be 400 mg/L or less, which is considered to be a reasonable incremental increase above the flow weighted average salinity of the intake water supply. Reuse effluent limitations for BOD5, turbidity, E. coli, total residual chlorine (TRC), and pH are based on the Water Quality Limits set forth in R317-3-11.4-C for Type I reuse and R317-3-11.5-C for Type II reuse. 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 A quantitative RP analysis was performed on(metal)to determine if there was reasonable potential for the discharge to exceed the applicable water quality standards. Based on the RP analysis, the following parameters exceeded the most stringent chronic water quality standard or were determined to have a reasonable potential to exceed the standard:(list metals).In addition, the RP analysis for (metals) indicates increase monitoring is required. A copy of the RP analysis is included at the end of this Fact Sheet. The permit limitations are Parameter Effluent Limitations *a Maximum Monthly Avg Maximum Weekly Avg Yearly Average Daily Minimum Daily Maximum Total Flow (X.X) (X.X) -- -- (X.X) BOD5, mg/L BOD5 Min. % Removal (X.X) 85 (X.X) -- -- -- -- -- -- -- CBOD5, mg/L Summer (Jul-Sep) Fall (Oct-Dec) Winter (Jan-Mar) Spring (Apr-Jun) BOD5 Min. % Removal (X.X) (X.X) (X.X) (X.X) 85 (X.X) (X.X) (X.X) (X.X) (X.X) -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- TSS, mg/L TSS Min. % Removal 25 85 35 -- -- -- -- -- -- -- Dissolved Oxygen, mg/L -- -- -- (X.X) -- Total Ammonia (as N), mg/L Summer (Jul-Sep) Fall (Oct-Dec) Winter (Jan-Mar) Spring (Apr-Jun) (X.X) (X.X) (X.X) (X.X) (X.X) (X.X) (X.X) (X.X) -- -- -- -- -- -- -- -- (X.X) (X.X) (X.X) (X.X) TRC, mg/L (X.X) (X.X) -- -- (X.X) E. coli, No./100mL 126 157 -- -- -- Total Phosphorus, mg/L (Final) *k, *l, *i (X.X) (X.X) (1/X.X) -- (X.X) WET, Acute Biomonitoring -- -- -- -- LC50>100% effluent (from WLA) WET, Chronic Biomonitoring -- -- -- -- IC25>XX% effluent (from WLA) Oil & Grease, mg/L -- -- -- -- 10.0 pH, Standard Units -- -- -- 6.5 9 TDS, mg/L *j The permit limitations for Outfall (00XR) (Reuse) are: ParameterOutfall 001R Effluent Limitations *a, *p, *q Max Monthly Average Max Weekly Median Max Daily Average Minimum Maximum Turbidity, NTU *p -- -- 2 -- 5 TRC, mg/L *m, *q -- -- -- 1 -- BOD5, mg/L 10 -- -- -- -- E. coli, No/100mL *o -- ND*q -- -- 9 pH, Standard Units -- -- -- 6.0 9.0 Parameter Type II Reuse Outfall 001R Effluent Limitations *a Max Monthly Average Max Weekly Median Max Daily Average Minimum Maximum BOD5 25 -- -- -- -- TSS 25 35 -- - -- E. coli, No/100mL *o -- 126 -- -- 500 pH, Standard Units -- -- -- 6.0 9.0 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 *a Parameter Frequency Sample Type Units Total Flow *b, *c Continuous/What? Recorder MGD BOD5, Influent *d Effluent How Often? How Often? Composite Composite mg/L mg/L CBOD5, Influent *d Effluent How Often? How Often? Composite Composite mg/L mg/L TSS, Influent *d Effluent How Often? How Often? Composite Composite mg/L mg/L E. coli How Often? Grab No./100mL pH How Often? Grab SU Total Ammonia (as N) How Often? Composite mg/L DO How Often? Grab mg/L WET – Biomonitoring *h Ceriodaphnia - Acute Ceriodaphnia - Chronic Fathead Minnows - Acute Fathead Minnows - Chronic How Often? 1st & 3rd Quarter 2nd & 4th Quarter 2nd & 4th Quarter 1st & 3rd Quarter Composite Composite Composite Composite Pass/Fail Pass/Fail Pass/Fail Pass/Fail TRC, mg/L, *e, *g How Often? Grab mg/L Oil & Grease *f When Sheen Observed Grab mg/L Orthophosphate (as P), *k Effluent Monthly/ How Often? Composite mg/L Total Phosphorus (as P), *l, *k Influent Effluent Monthly/ How Often? Monthly/ How Often? Composite Composite mg/L mg/L Total Kjeldahl Nitrogen TKN (as N), *k, *l Influent Effluent Monthly/ How Often? Monthly/ How Often? Composite Composite mg/L mg/L Nitrate, NO3 *k, *l Monthly/ How Often? Composite mg/L Nitrite, NO2 *k, *l Monthly/ How Often? Composite mg/L TDS, mg/L *j Monthly/ How Often? Composite mg/L Temperature, mg/L *l, Monthly/ How Often? Composite mg/L Metals, Influent *h Effluent Quarterly/ How Often? Quarterly/ How Often? Composite Composite mg/L mg/L Organic Toxics Quarterly/ How Often? Grab mg/L The following is a summary of the Type I reuse self-monitoring and reporting requirements. Reuse Outfall 001R Self-Monitoring and Reporting Requirements *a *n Parameter Frequency Sample Type Units Total Flow, *b, *c Continuous Recorder MGD Turbidity Continuous Recorder mg/L TRC *m, *q Daily Recorder mg/L BOD5 Weekly Composite mg/L E. coli Daily Grab No./100mL pH Daily Grab SU **Cell Depth** Monthly Measure Feet **Free Board ** Monthly Measure Feet **Remove if lagoon discharges routinely** Type II Reuse Outfall 001R Self-Monitoring and Reporting Requirements *a *n Parameter Frequency Sample Type Units Total Flow, *b, *c Continuous Recorder MGD BOD5 Weekly Composite mg/L TSS Daily Composite mg/L E. coli Daily Grab No./100mL pH Daily/ Continuous Grab/Recorder SU **Cell Depth** Monthly Measure Feet **Free Board ** Monthly Measure Feet **Remove if lagoon discharges routinely***aSee Definitions, Part VIII, for definition of terms.*bFlow measurements of influent/effluent volume shall be made in such a manner that the permittee can affirmatively demonstrate that representative values are being obtained.*cIf the rate of discharge is controlled, the rate and duration of discharge shall be reported.*dIn addition to monitoring the final discharge, influent samples shall be taken and analyzed for this constituent at the same frequency as required for this constituent in the discharge.*eAnalytical 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.*fOil & Grease sampled when sheen is present or visible. If no sheen is present or visible, report NA. *gTotal residual chlorine monitoring frequency is (How Often?) times a week. The chlorine disinfection is a backup system to the ultra violet system and therefore should not be needed unless the ultra violet system has a failure and is by passed. The TRC limits are low enough to require analysis in the onsite lab which is open only 6 days a week. Frequency reduction will remove a requirement that the lab be opened for a 7th day. In case of a bypass on any day the lab is closed, (Permittee) will bring in lab personnel to open the lab for TRC analysis *hTheacute Ceriodaphnia will be tested during the 1stand 3rdquarters and the acute fathead minnows will be tested during the 2ndand 4thquarters. The chronic Ceriodaphnia will be tested during the 2ndand 4thquarters, and the chronic fathead minnows will be tested during the 1stand 3rdquarters. *iMetals results were reviewed for the last 36 months. Only selenium appeared to be close to the limits suggested in the Wasteload. After further review, and confirmation by a round of sampling in late November, early December of 2004, it was shown that the reporting limit for selenium for the onsite lab is above the suggested limits, and when samples are analyzed off site in a lab with lower reporting limits, selenium levels are under the reporting limit for the lab. No limits are required at this time.NOTE: If discharge is in the Colorado River Basin, put the appropriate total dissolved solids (TDS) language in the SOB, and the permit (see below). *jThe effluent shall not exceed the culinary source water intake by more than 400 mg/L of TDS (*******or the permittee could request 1 ton/day salt loading, or 366 tons/year*******).*kThese reflect changes required with the adoption of UAC R317-1-3.3, Technology-based Phosphorus Effluent Limits rule.Total Phosphorus Compliance Schedule:DateMilestoneDecember 31, 2019Complete monitoring only sampling for Total PhosphorusJanuary 1, 2020Comply with Final Total Phosphorus Effluent Limit *l(Pollutant or Pollutants) are being sampled in support of the work being done for the TMDL currently underway for the (Water Body). The Pollutants Of Concern (POC) will be monitored and reported (on a monthly basis by the facility on Discharge Monitoring Report, but will not have a limit associated with them /or at the end of each Calendar year of sampling for these POC’s), (Permittee) will report the results of all sampling done for the POC. If (Permittee) decides to sample more frequently for these POC’s, the additional data will be welcome. *m The facility is required to disinfect to destroy, inactivate or remove pathogenic microorganisms by chemical, physical or biological means. Disinfection may be accomplished by chlorination, ozonation, or other chemical disinfectants, UV radiation. Or other approved processes. Chlorine residual is recommended but no longer required. Sampling not required if chlorination is not being used. The total residual chlorine shall be measured continuously and shall at no time be less than 1.0 mg/l after 30 minutes contact time at peak flow. If an alternative disinfection process is used, it must be demonstrated to the satisfaction of the Director that the alternative process is comparable to that achieved by chlorination with a 1 mg/l residual after 30 minutes contact time. If the effectiveness cannot be related to chlorination, then the effectiveness of the alternative disinfection process must be demonstrated by testing for pathogen destruction as determined by the Director. A 1 mg/l total chlorine residual is recommended after disinfection and before the treated effluent goes into the distribution system. *n Reuse monitoring results obtained during the previous month for reuse discharges shall be summarized for each month and reported on NetDMR.*o(For Type I only.) The weekly median E. coli concentration shall be non-detect*p(For Type I resue only.) An alternative disposal option or diversion to storage must be automatically activated if turbidity exceeds the maximum instantaneous limit for more than 5 minutes, or chlorine residual drops below the instantaneous required value for more than 5 minutes, where chlorine disinfection is used. *q(For Type I reuse only.) The total residual chlorine shall be measured continuously and shall at no time be less than 1.0 mg/l after 30 minutes contact time at peak flow. If an alternative disinfection process is used, it must be demonstrated to the satisfaction of the Director that the alternative process is comparable to that achieved by chlorination with a 1 mg/l residual after 30 minutes contact time. If the effectiveness cannot be related to chlorination, then the effectiveness of the alternative disinfection process must be demonstrated by testing for pathogen destruction as determined by the Director. A 1 mg/l total chlorine residual is recommended after disinfection and before the treated effluent goes into the distribution system. Management Practices for Land Application of Treated Effluent: (1)The application of treated effluent to frozen, ice-covered, or snow covered land is prohibited. (2)No person shall apply treated effluent where the slope of the site exceeds 6 percent. (3)The use should not result in a surface water runoff. (4)The use must not result in the creation of an unhealthy or nuisance condition, as determined by the local health department. (5)Any irrigation with treated effluent must be at least 300 feet from a potable well. (6)For Type I reuse, any irrigation must be at least 50 feet from any potable water well. (7)For Type II reuse, any irrigation must be at least 300 feet from any potable water well. (8)For Type II reuse, spray irrigation must be at least 100 feet from areas intended for public access. This distance may be reduced or increased by the Director. (9)Impoundments of treated effluent, if not sealed, must be at least 500 feet from any potable well. (10)Public access to effluent storage and irrigation or disposal sites shall be restricted by a stock-tight fence or other comparable means which shall be posted and controlled to exclude the public (Compliance Schedule for a Particular Parameter if necessary) BIOSOLIDS The State of Utah has adopted the 40 CFR 503 federal regulations for the disposal of sewage sludge (biosolids) by reference. However, since this facility is a lagoon, there is not any regular sludge production. Therefore 40 CFR 503 does not apply at this time. In the future, if the sludge needs to be removed from the lagoons and is disposed in some way, the Division of Water Quality must be contacted prior to the removal of the sludge to ensure that all applicable state and federal regulations are met STORM WATER Separate storm water permits may be required based on the types of activities occurring on site. Permit coverage under the Multi Sector General Permit (MSGP) for Storm Water Discharges from Industrial Activities is required based on the Standard Industrial Classification (SIC) code for the facility and the types of industrial activities occurring. If the facility is not already covered, it has 30 days from when this permit is issued to submit the appropriate Notice of Intent (NOI) for the MSGP or exclusion documentation. 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 disturban acre or more, or is part of a common plan of development or sale thatis an acre or greater. A Notice of Intent (NOI) is required to obtain a construction storm water permit prior to the period of construction. Information onstorm water permit requirements can be found at http://stormwater.utah.gov PRETREATMENT REQUIREMENTS 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 WriterDaniel Griffin, BiosolidsJennifer Robinson, PretreatmentLonnie Shull, BiomonitoringCarl Adams, Storm WaterAmy Dickey, TMDL/Watershed Ken Hoffman, Reasonable Potential AnalysisNick von Stackelberg, Wasteload AnalysisUtah Division of Water Quality, (801) 536-4300PUBLIC NOTICEBegan: Month Day, YearEnded: Month Day, YearComments will be received at: 195 North 1950 West PO Box 144870 Salt Lake City, UT 84114-4870The Public Noticed of the draft permit was published in the (NEWSPAPER OF RECORD FOR AREA).During the public comment period provided under R317-8-6.5, any interested person may submit written comments on the draft permit and may request a public hearing, if no hearing has already been scheduled. A request for a public hearing shall be in writing and shall state the nature of the issues proposed to be raised in the hearing. All comments will be considered in making the final decision and shall be answered as provided in R317-8-6.12.ADDENDUM TO FSSOBDuring finalization of the Permit certain dates, spelling edits and minor language corrections were completed. Due to the nature of these changes they were not considered Major and the permit is not required to be re Public Noticed.Responsiveness Summary(Explain any comments received and response sent. Actual letters can be referenced, but not required to be included). This Page Intentionally Left Blank ATTACHMENT 1 Industrial Waste Survey This Page Intentionally Left BlankIndustrial Pretreatment Wastewater SurveyDo you periodically experience any of the following treatment works problems:foam, floaties or unusual colorsplugged collection lines caused by grease, sand, flour, etc.discharging excessive suspended solids, even in the wintersmells unusually badwaste treatment facility doesn’t seem to be treating the waste rightPerhaps the solution to a problem like one of these may lie in investigating the types and amounts of wastewater entering the sewer system from industrial users.An industrial user (IU) is defined as a non-domestic user discharging to the waste treatment facility which meets any of the following criteria: 1.has a lot of process wastewater (5% of the flow at the waste treatment facility or more than 25,000 gallons per work day.)Examples:Food processor, dairy, slaughterhouse, industrial laundry.2.is subject to Federal Categorical Pretreatment Standards;Examples:metal plating, cleaning or coating of metals, blueing of metals, aluminum extruding, circuit board manufacturing, tanning animal skins, pesticide formulating or packaging, and pharmaceutical manufacturing or packaging,3.is a concern to the POTW.Examples:septage hauler, restaurant and food service, car wash, hospital, photo lab, carpet cleaner, commercial laundry.All users of the water treatment facility are prohibited from making the following types of discharges:1.A discharge which creates a fire or explosion hazard in the collection system.2.A discharge which creates toxic gases, vapor or fumes in the collection system.3.A discharge of solids or thick liquids which creates flow obstructions in the collection system.4.An acidic discharge (low pH) which causes corrosive damage to the collection system.5.Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will cause problems in the collection system or at the waste treatment facility.6.Waste haulers are prohibited from discharging without permission. (No midnight dumping!)When the solution to a sewer system problem may be found by investigating the types and amounts of wastewater entering the sewer system discharged from IUs, it’s appropriate to conduct an Industrial Waste Survey.An Industrial Waste Survey consists of:Step 1: Identify Industrial UsersMake a list of all the commercial and industrial sewer connections.Sources for the list:business license, building permits, water and wastewater billing, Chamber of Commerce, newspaper, telephone book, yellow pages.Split the list into two groups:domestic wastewater only--no further information neededeveryone else (IUs)Step 2: Preliminary InspectionGo visit each IU identified on the “everybody else” list. Fill out the Preliminary Inspection Form during the site visit.Step 3: Informing the StatePlease fax or send a copy of the Preliminary inspection form (both sides) to:Jennifer RobinsonDivision of Water Quality288 North 1460 WestP.O. Box 144870Salt Lake City, UT 84114-4870Phone: (801) 536-4383Fax:(801) 536-4301E-mail:jenrobinson@utah.govF:\WP\Pretreatment\Forms\IWS.doc PRELIMINARY INSPECTION FORM INSPECTION DATE / / Name of Business Person Contacted Address Phone Number Description of Business Principal product or service: Raw Materials used: Production process is: [ ] Batch [ ] Continuous[ ] Both Is production subject to seasonal variation? [ ] yes[ ] no If yes, briefly describe seasonal production cycle. This facility generates the following types of wastes (check all that apply): 1. [ ] Domestic wastes(Restrooms, employee showers, etc.) 2. [ ] Cooling water, non-contact3. [ ] Boiler/Tower blowdown 4. [ ] Cooling water, contact5. [ ] Process 6. [ ] Equipment/Facility washdown7. [ ] Air Pollution Control Unit 8. [ ] Storm water runoff to sewer9. [ ] Other describe Wastes are discharged to (check all that apply): [ ] Sanitary sewer[ ] Storm sewer [ ] Surface water[ ] Ground water [ ] Waste haulers[ ] Evaporation [ ] Other (describe) Name of waste hauler(s), if used Is a grease trap installed?YesNo Is it operational?YesNo Does the business discharge a lot of process wastewater?More than 5% of the flow to the waste treatment facility?YesNoMore than 25,000 gallons per work day?YesNo Does the business do any of the following:[ ] Adhesives[ ] Car Wash[ ] Aluminum Forming[ ] Carpet Cleaner[ ] Battery Manufacturing[ ] Dairy[ ] Copper Forming[ ] Food Processor[ ] Electric & Electronic Components[ ] Hospital[ ] Explosives Manufacturing[ ] Laundries[ ]Foundries[ ] Photo Lab[ ]Inorganic Chemicals Mfg. or Packaging[ ] Restaurant & Food Service[ ] Industrial Porcelain Ceramic Manufacturing[ ] Septage Hauler[ ] Iron & Steel[ ] Slaughter House [ ] Metal Finishing, Coating or Cleaning [ ] Mining [ ] Nonferrous Metals Manufacturing [ ]Organic Chemicals Manufacturing or Packaging [ ] Paint & Ink Manufacturing [ ] Pesticides Formulating or Packaging [ ] Petroleum Refining [ ] Pharmaceuticals Manufacturing or Packaging [ ] Plastics Manufacturing [ ] Rubber Manufacturing [ ] Soaps & Detergents Manufacturing [ ] Steam Electric Generation [ ] Tanning Animal Skins [ ] Textile Mills Are any process changes or expansions planned during the next three years? YesNo If yes, attach a separate sheet to this form describing the nature of planned changes or expansions. Inspector Waste Treatment Facility Please send a copy of the preliminary inspection form (both sides) to: Jennifer Robinson Division of Water Quality P. O. Box 144870 Salt Lake City, Utah 84114-4870 Phone:(801) 536-4383 Fax:(801) 536-4301E-Mail:jenrobinson@utah.gov Industrial User Jurisdiction SIC Codes Categorical Standard Number Total Average Process Flow (gpd) Total Average Facility Flow (gpd) Facility Description 1 2 3 4 5 6 7 8 9 10 11 This Page Intentionally Left Blank ATTACHMENT 2 Effluent Monitoring Data This Page Intentionally Left BlankEffluent Monitoring Data. Flow pH O & G TRC E. coli BOD5 TSS Month Ave Max Min Max Max Max Acute Chronic Ave Max Ave Max Jan-13 18.8 20.2 7.5 7.7 1.7 1.2 10 6 5 6 7 8 Feb-13 21.3 22.9 7.6 7.7 1.7 1.1 13 8 7 9 7 7 Mar-13 24.3 28.6 7.5 7.7 1.7 1.1 11 9 17 21 7 9 Apr-13 20.2 21.2 7.5 7.7 1.7 1.2 20 12 19 21 7 8 May-13 21.4 25.5 7.4 7.6 1.7 1.3 9 7 18 21 10 11 Jun-13 20.5 22.1 7.5 7.7 1.4 1 12 7 18 21 11 14 Jul-13 20.2 22.3 7.4 7.7 1.4 1.3 10 8 10 11 14 16 Aug-13 19.6 20.8 7.5 7.6 1.4 1.2 13 7 8 10 8 9 Sep-13 20 21.8 7.6 7.8 1.4 1.1 78 15 11 12 8 9 Oct-13 17.9 19 7.5 7.7 1.7 0.9 11 8 9 11 8 8 Nov-13 17.2 18.1 7.5 7.7 1.7 0.9 10 8 9 10 8 10 Dec-13 17.2 20.4 7.2 7.6 1.4 1.2 10 12 9 10 10 18 Jan-14 17.5 19.9 7.3 7.5 1.4 0.8 29 6 7 8 8 9 Feb-14 20.3 22.6 7.4 7.6 1.4 1 43 19 8 10 8 8 Mar-14 20.8 27.4 7.4 7.7 1.7 1 30 10 7 8 9 10 Apr-14 19.1 21.2 7.4 7.6 1.4 1.5 8 6 8 9 9 10 May-14 20.2 22.7 7.4 7.5 1.4 1.3 9 6 7 9 8 10 Jun-14 20.6 23 7.5 7.6 1.4 1 16 8 8 10 8 9 Jul-14 20.5 22.3 7.5 7.8 1.4 1.5 10 7 9 10 12 13 Aug-14 21 21.9 7.6 7.7 1.2 1.3 17 14 8 9 9 10 Sep-14 20.2 23.2 7.5 7.7 1.4 1.1 12 8 7 8 8 13 Oct-14 18.2 20.9 7.5 7.6 1.4 1.1 7 5 6 8 9 10 Nov-14 16.6 17.7 7.4 7.6 1.4 1.7 8 6 7 9 14 23 Dec-14 16.9 19.3 7.4 8.9 1.4 1.2 34 8 6 10 11 23 Jan-15 18.1 19.8 7.5 7.6 1.4 0.9 10 6 7 8 10 11 Feb-15 17.8 18.7 7.3 7.5 1.4 1 7 6 5 6 9 10 Mar-15 17.6 18.6 7.3 7.5 1.4 1.3 5 5 5 6 7 8 Apr-15 18.1 22.3 7.2 7.6 1.4 1 7 6 7 8 11 11 May-15 22.5 31.9 7.5 7.6 2 1.1 10 6 7 9 13 16 Jun-15 20.2 22.5 7.5 7.6 1.6 1.3 8 6 6 6 9 10 Jul-15 19.7 21.8 7.5 7.7 1.4 1.5 12 9 5 6 11 11 Aug-15 20.7 22.6 7.5 7.7 1.4 1.1 9 5 5 6 7 13 Sep-15 20.1 23.5 7.6 7.7 1.4 1.1 7 5 5 6 8 10 Oct-15 18.1 20.3 7.5 7.6 1.4 1 12 8 5 6 11 13 Nov-15 16.9 18.3 7.1 7.6 1.4 1.3 11 8 4 6 6 7 Dec-15 18.1 21.6 7.4 7.6 2.63 0.9 8 5 7 8 8 8WET Results Month WET Test Pass / Fail Mar-13 48Hr Acute Ceriodaphnia Pass Mar-13 96Hr Acute PimephalesPromelas NA Jun-13 48Hr Acute Ceriodaphnia NA Jun-13 96Hr Acute PimephalesPromelas Pass Sep-13 48Hr Acute Ceriodaphnia Pass Sep-13 96Hr Acute PimephalesPromelas NA Dec-13 48Hr Acute Ceriodaphnia NA Dec-13 96Hr Acute PimephalesPromelas Pass Mar-14 48Hr Acute Ceriodaphnia Pass Mar-14 96Hr Acute PimephalesPromelas NA Jun-14 48Hr Acute Ceriodaphnia Pass Jun-14 96Hr Acute PimephalesPromelas NA Sep-14 48Hr Acute Ceriodaphnia Pass Sep-14 96Hr Acute PimephalesPromelas NA Dec-14 48Hr Acute Ceriodaphnia NA Dec-14 96Hr Acute PimephalesPromelas Pass Mar-15 48Hr Acute Ceriodaphnia Pass Mar-15 96Hr Acute PimephalesPromelas NA Jun-15 48Hr Acute Ceriodaphnia NA Jun-15 96Hr Acute PimephalesPromelas Pass Sep-15 48Hr Acute Ceriodaphnia Pass Sep-15 96Hr Acute PimephalesPromelas NA Dec-15 48Hr Acute Ceriodaphnia NA Dec-15 96Hr Acute PimephalesPromelas Pass ATTACHMENT 3 Wasteload Analysis This Page Intentionally Left Blank ATTACHMENT 4 Reasonable Potential Analysis This Page Intentionally Left Blank REASONABLE POTENTIAL ANALYSIS Water Quality has worked to improve our reasonable potential analysis (RP) for the inclusion of limits for parameters in the permit by using an EPA provided model. As a result of the model, more parameters may be included in the renewal permit. A Copy of the Reasonable Potential Analysis Guidance (RP Guide) is available at water Quality. There are four outcomes for the RP Analysis. They are; Outcome A:A new effluent limitation will be placed in the permit. Outcome B:No new effluent limitation. Routine monitoring requirements will be placed or increased from what they are in the permit, Outcome C:No new effluent limitation. Routine monitoring requirements maintained as they are in the permit, Outcome D:No limitation or routine monitoring requirements are in the permit. (REASONABLE POTENTIAL LANGUAGE )Initial screening for metals values that were submitted through the discharge monitoring reports showed that a closer look at some of the metals is needed. A copy of the initial screening is included in the “Effluent Metals and RP Screening Results” table in this attachment. The initial screening check for metals showed that the full model needed to be run on (List Metals).(Outcome A Use as a guide for as many metals as required) The RP model was run on (metal) using the most recent data back through (Year). This resulted in XXdata points and that there is a Reasonable Potential for an acute limit for (metal). Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YYdata points (delete is no more data provided).The EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If not Outliers found use (This identified no outliers in the data set.)) The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is (acute and/or chronic)RP at 95% confidence, and there is (acute and/or chronic)RP at 99% Confidence. This result indicates that the inclusion of an effluent limit for (metal) is required at this time.(Outcome A from Reasonable Potential Guide) (Outcome BUse as a guide for as many metals as required The RP model was run on (metal) using the most recent data back through (Year). This resulted in XX data points and that there is a Reasonable Potential for an acute limit for (metal). Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YY data points (delete is no more data provided).The EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If not Outliers found use (This identified no outliers in the data set.)) The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is not(acute and/or chronic)RP at 95% confidence, and there is (acute and/or chronic)RP at 99% Confidence. This result indicates that the inclusion of an effluent limit for (metal) is not required at this time, but routine monitoring requirements will be added or increased in the permit.(Outcome B from Reasonable Potential Guide) (Outcome C Use as a guide for as many metals as required) The RP model was run on (metal) using the most recent data back through (Year). This resulted in XX data points and that there is a Reasonable Potential for an acute limit for (metal). Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YY data points (delete is no more data provided).The EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If not Outliers found use (This identified no outliers in the data set.)) The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is not(acute and/or chronic)RP at 95% confidence, and there is not (acute and/or chronic)RP at 99% Confidence. This result indicates that the inclusion of an effluent limit for (metal) is not required at this time, and that routine monitoring requirements can be added or increased in the permit.(Outcome C from Reasonable Potential Guide) (Outcome D Use as a guide for as many metals as required) The RP model was run on (metal) using the most recent data back through (Year). This resulted in XX data points and that there is a Reasonable Potential for an acute limit for (metal). Reviewing the data showed that there could be at least one outlier in the data, more data was provided; back through (YEAR) for a total of YY data points (delete is no more data provided).The EPA ProUCL model was used to evaluate the data. This produced the same outlier for both XXand YYdata points. This/Theseoutlier(‘s) was(were)from the Date(value). (Include Table if needed)(If not Outliers found use (This identified no outliers in the data set.)) The value(‘s) was (were)excluded from the data set and RP was rerun at both the 95% and 99% confidence levels. The results of the model are that there is not(acute and/or chronic)RP at 95% confidence, and there is not (acute and/or chronic)RP at 99% Confidence. This result indicates that there is no requirement to include an effluent limit for (metal) or routine monitoring in the permit.(Outcome D from Reasonable Potential Guide) The RP model was run on Selenium using the most recent data back through 2009. This resulted in 19 data points and that there is a Reasonable Potential for an acute limit for Selenium. Reviewing the data showed that there could be at least one outlier in the data, more data was provided, back through 2006 for a total of 40 data points, and the EPA ProUCL model was used to evaluate the data. This produced the same outlier for both 19 and 40 data points. This outlier was from the summer of 2011 (0.007 mg/L). The value was excluded from the data set and RP was rerun. As a result, no effluent limit for Selenium will be included. (Outcome C from RP Guide) A Summary of the RP Model inputs and outputs are included in the tables below. Initial screening for metals values that were submitted through the discharge monitoring reports showed that a closer look at some of the metals is not needed. (NO REASONABLE POTENTIAL LANGUAGE)Initial screening for metals values that were submitted through the discharge monitoring reports showed that a closer look at some of the metals is not needed. (Include as needed) A Summary of the RP Model inputs and outputs are included in the table below. The Metals Initial Screening Table and RP Outputs Table are included in this attachment.RP input/output summary RP Procedure Output Outfall Number: XXX Data Units mg/L Parameter metal metal Distribution (Distribution) (Distribution) Reporting Limit (0.0xx) (0.0xx) Significant Figures x x Maximum Reported Effluent Conc. x.xxx x.xxx Coefficient of Variation (CV) x.xxx x.xxx Acute Criterion x.xxx x.xxx Chronic Criterion x.xxx x.xxx Confidence Interval 95 99 95 99 Projected Maximum Effluent Conc. (MEC) x.xxx x.xxx x.xxx x.xxx RP Multiplier X.XX X.XX X.XX X.XX RP for Acute? YES/NO YES/NO YES/NO YES/NO RP for Chronic? YES/NO YES/NO YES/NO YES/NO Outcome (A,B,C,D) (A,B,C,D) Metals Monitoring and RP Check Effluent Metal Cyanide Arsenic Cadmium Chromium Copper Lead Nickel Silver Zinc Molybdenum Selenium Mercury ARP Val 0.0052 0.34 0.0054 0.016 0.0332 0.262 1.019 0.0183 0.26 1 0.0184 0.0024 CRP Val 0.022 0.15 0.00053 0.011 0.0204 0.0102 0.113 1 0.26 1 0.0046 0.000012 Metals, mg/L 0.0097 0.0096 NR NR 0.011 0.00025 0.00822 0.00004 0.021 0.00395 0.00083 2.4E-06 0.0092 0.0096 0.000035 0 0.0105 0.000179 0.00822 0.000026 0.0203 0.00395 0.000426 2.4E-06 0.0092 0.0096 0.000035 ND 0.0105 0.000192 0.00822 0.00003 0.0203 0.00395 0.000754 1.3E-06 0.0103 0.0096 0.000041 ND 0.0105 0.000192 0.0159 0.000062 0.0341 ND 0.00106 0.000003 0.0103 0.00803 0.000041 ND 0.0106 0.000244 0.0159 0.000062 0.0341 ND 0.000754 0.000003 0.0119 0.00875 0.000041 ND 0.0121 0.000326 0.0159 0.000062 0.0341 ND 0.000754 4.2E-06 0.0093 0.0095 0 0.000226 0.00569 0 0.00737 0 0.0113 0.00355 0.000356 0 0.0086 0.00972 ND 0.0011 0.0127 0.000374 0.00227 ND 0.0166 0.00468 0.000627 ND 0.0055 0.0126 0.000127 0.00108 0.00823 0.000262 0.00203 0.000203 0.0199 0.00453 0.00084 0.000158 0.0093 0.0126 0.000127 0.0011 0.0127 0.000374 0.00737 0.000203 0.0199 0.00468 0.00084 5.3E-06 0.0086 0.0126 0.000127 0.0011 0.0127 0.000374 0.00626 0.000203 0.0199 0.00468 0.00084 ND 0.0084 0.0085 ND ND 0.00818 ND 0.0067 ND 0.0137 0.0037 ND 0.000002 0.0085 0.00567 ND 0.001 0.00805 ND 0.00189 ND 0.0287 0.00313 ND 2.3E-06 0.0101 0.00714 ND 0.000921 0.00818 ND 0.00654 ND 0.0213 0.00301 ND ND ND 0.0089 ND 0.0007 0.0045 ND 0.0054 ND 0.01 0.003 0.0014 ND ND 0.0081 ND ND 0.00395 ND 0.00146 2.62E-05 0.0155 0.00315 0.000364 1.9E-06 0.00426 0.00537 ND ND 0.00578 ND 0.00246 2.93E-05 0.0421 0.00935 0.00036 ND ND 0.489 0.000444 0.00431 0.00206 0.000941 0.000941 6.97E-05 0.0163 0.00272 0.000441 1.41E-05 0.0138 0.00911 ND ND 0.00477 ND 0.00204 3.91E-05 0.0298 0.00339 0.000411 ND 0.00557 0.00704 ND ND 0.00596 ND 0.00166 ND 0.0137 0.00328 0.000301 1.5E-06 ND Value 0 0 0 0 0 0 0 0 0 0 0 0 Max 0.0138 0.489 0.000444 0.00431 0.0127 0.000941 0.0159 0.000203 0.0421 0.00935 0.0014 0.000158 A RP? YES YES No No No No No No No No No No C RP? YES YES YES No YES No No No No No No YES This Page Intentionally Left Blank (Metal)RP Results RP Procedure Output Effluent Data Facility Name: (Facility Name) # # # Permit Number: (permit number) 1 41 81 Outfall Number: 001 2 42 82 Parameter (metal) 3 43 83 Distribution (distribution) 4 44 84 Data Units mg/L 5 45 85 Reporting Limit (x.xxx) 6 46 86 Significant Figures X 7 47 87 Confidence Interval 95 8 48 88 9 49 89 Maximum Reported Effluent Conc. (X.XXX) mg/L 10 50 90 Coefficient of Variation (CV) (X.XXX) 11 51 91 RP Multiplier (X.XXX) 12 52 92 Projected Maximum Effluent Conc. (MEC) (X.XXX) mg/L 13 53 93 14 54 94 Acute Criterion (X.XXX) 0 15 55 95 Chronic Criterion (X.XXX) 0 16 56 96 Human Health Criterion NA 0 17 57 97 18 58 98 RP for Acute? (NO/YES) 19 59 99 RP for Chronic? (NO/YES) 20 60 100 RP for Human Health? N/A 21 61 101 22 62 102 Confidence Interval 99 23 63 103 24 64 104 Maximum Reported Effluent Conc. (X.XXX) 25 65 105 Coefficient of Variation (CV) (X.XXX) 26 66 106 RP Multiplier (X.XXX) 27 67 107 Projected Maximum Effluent Conc. (MEC) (X.XXX) 28 68 108 29 69 109 Acute Criterion (X.XXX) 30 70 110 Chronic Criterion (X.XXX) 31 71 111 Human Health Criterion NA 32 72 112 33 73 113 RP for Acute? (NO/YES) 34 74 114 RP for Chronic? (NO/YES) 35 75 115 RP for Human Health? N/A 36 76 116 37 77 117 38 78 118 39 79 119 40 80 120