STATEMENT OF BASIS/TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

DESCRIPTION OF APPLICATION 

Applicant: Cooper Natural Resources Inc.; Texas Pollutant Discharge Elimination System 

(TPDES) Permit No. WQooo3642ooo (TX0112038) 

Regulated Activity: Industrial Wastewater Permit 

Type of Application: Major Amendment with Renewal 

Request: 

Authority: 

Major Amendment with Renewal to reduce certain sampling frequencies at all 

three outfalls 

Federal Clean Water Act §402; Texas Water Code §26.027; 30 Texas 

Administrative Code (TAC) Chapter 305, Subchapters C-F, Chapters 307 and 

319; Commission policies; and Environmental Protection Agency (EPA) 

guidelines 

EXECUTIVE DIRECTOR RECOMMENDATION 

The Executive Director has made a preliminary decision that this permit, if issued, meets all statutory 

and regulatory requirements. The draft permit includes an expiration date of December 1, 2019, 

following the requirements of 30 TAC § 305.71, Basin Permitting. 

REASON FOR PROJECT PROPOSED 

The applicant has applied to the Texas Commission on Environmental Quality (TCEQ) for an 

amendment of its existing permit. The proposed amendment would reduce certain sampling 

frequencies from once per week to once per year at all three outfalls. 

PROJECT DESCRIPTION AND LOCATION 

The applicant currently operates the Cedar Lake Plant, a facility that produces sodium sulfate fi:om 

naturally occuring brine deposits. The facility pumps brine from sediments beneath Cedar Lake, 

extracts the sodium sulfate from the brine, and returns the spent brine to Cedar Lake. The facility uses 

a simple recovery process that is based on the phase chemistry of salts in solution to preferentially 

extract the sodium sulfate from the brine. No reagents or reactive chemical processes are used. 

The brine is pumped from a series of 54 production wells, approximately 30 of which are in use at any 

given time. The wells are approximately 100 feet deep, are located throughout the lake, and are 

accessed along roads that extend into the lake. The wells draw brine from the salty groundwater, 

which receives recharge from Cedar Lake. Portions of the access roads along the west shore of Cedar 

Lake form two salt-evaporator areas, each of which is connected to Cedar Lake via culverts. 

Brine withdrawn from the production wells is first piped to a brine storage tank, then routed to the 

Chilling Plant. At the Chilling Plant, the field brine flows through chillers, where an ammonia coolant 

reduces the temperature of the brine to cause precipitation of Glauber's Salt, the hydrated form of 

sodium sulfate. The spent brine is cold, so it is used to cool the incoming field brine before being 

returned to Cedar Lake, thus enhancing plant efficiency. The Glauber's Salt is melted in its own waters 

of hydration at the Swenson Evaporator Crystallizer (SEC) and subjected to further evaporation, 

resulting in precipitation of anhydrous sodium sulfate. Steam condensate generated during the 

evaporation process is used throughout the plant for many useful purposes, including salt 

reclamation. The sodium sulfate is further de-watered by centrifuges in the Drying Plant and then sent 
STATEMENT OF BASIS/ TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooo3642000 

through a rotary dryer to remove any remaining moisture. The final product, anhydrous sodium 

sulfate, is either bagged at the plant for bulk truck or rail car shipment or transported by truck to a 

loading facility in Seagraves, Texas, where it is loaded into bulk rail cars for shipment to customers. 

Any waste sodium sulfate generated during the production process is collected and placed in the Salt 

Reclamation Pond (SRP), which is in the southwestern corner ofthe southern salt-evaporator area. 

This salt is reprocessed by spraying it with water, pumping the resulting sodium sulfate solution to a 

brine storage tank, and then processing the solution in the same manner that field brine is processed. 

The water that is sprayed over the salt pile is a mix of fresh water and steam condensate. 

Wastewater from the facility is discharged via three different outfalls, as described below. 

Outfall 001 - Spent brine, plant floor wash water, condensate from evaporation processes, and 

storm water flow through an oil/water separator prior to discharge via Outfall 001. 

Outfall 002 -Decanted brine water, washdown water from the pump house floor, condensate, 

non -contact cooling water from the booster pump, and stormwater from the SRP are discharged 

via Outfall 002 into the southern salt-evaporator area, which is part of Cedar Lake. The outfall is 

located at the decant tower of the SRP. Recovered sodium sulfate (from truck loading and other 

site activities) is routed to the SRP, where fresh water and steam condensate from the SEC is 

sprayed over the salt to bring it back into solution so it can be pumped to the brine storage tank 

and processed as field brine. 

Outfall 003 Brine water, condensate, tank washdown water, overflow from the evaporation pond 

(which includes condensate, cooling tower blowdown, and stormwater), and stormwater are 

discharged via Outfall 003. 

According to the permit application, domestic wastewater is routed to on-site septic tanks. 

The plant site is located adjacent to Cedar Lake, approximately 8 miles east of the intersection of 

Farm-to-Market Road 1066 and Farm-to-Market Road 303, southeast ofthe Town of Loop in Gaines 

County, Texas. 

Discharge Routes 

The effluent is discharged via Outfall 001 to a ditch; thence to Seco Draw; thence to Cedar Lake; via 

Outfall 002 to the Salt Reclamation Pond; thence to Cedar Lake; and via Outfall 003 via culverts to 

Coyote Draw; thence to Cedar Lake in Segment No. 1400 of the Colorado River. The unclassified 

receiving waters have minimal aquatic life use for the ditch, Seco Draw, Coyote Draw, and Cedar Lake. 

The effluent limits in the draft permit will maintain and protect the existing instream uses. All 

determinations are preliminary and subject to additional review and revisions. 

Antidegradation Review 

In accordance with 30 TAC § 307.5 and the TCEQ implementation procedures (June 2010) for the 

Texas Surface Water Quality Standards, an antidegradation review of the receiving waters was 

performed. A Tier 1 antidegradation review has preliminarily determined that existing water quality 

uses will not be impaired by this permit action. Numerical and narrative criteria to protect existing 

uses will be maintained. A Tier 2 review is not required since no exceptional, high, or intermediate 

aquatic life use water bodies have been identified in the discharge route. Existing uses will be 

maintained and protected. The preliminary determination can be reexamined and may be modified if 

new information is received. 

Endangered Species Review 

The discharge from this permit is not expected to have an effect on any federal endangered or 

threatened aquatic or aquatic-dependent species or proposed species or their critical habitat. This 

Page 2 
STATEMENT OF BASIS /TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooo3642000 

determination is based on the United States Fish and Wildlife Service's (USFWS's) biological opinion 

on the State of Texas authorization ofthe TPDES (September 14, 1998, and October 21, 1998 update). 

To make this determination for TPDES permits, TCEQ and the EPA only considered aquatic or 

aquatic-dependent species occurring in watersheds of critical concern or high priority as listed in 

Appendix A of the USFWS biological opinion. The determination is subject to reevaluation due to 

subsequent updates or amendments to the biological opinion. The permit does not require EPA review 

with respect to the presence of endangered or threatened species. 

Impaired Water Bodies 

None of the water bodies in the discharge routes are currently listed on the State's inventory of 

impaired and threatened waters (the 2012 Clean Water Act Section 303(d) list). 

SUMMARY OF EFFLUENT DATA 

The following is a quantitative description of the discharge described in the Monthly Effluent Report 

data for the period October 2009 through September 2014. The "Average of Daily Avg" values 

presented in the following table are the average of all daily average values for the reporting period for 

each parameter. The "Maximum of Daily Max" values presented in the following table are the 

individual maximum values for the reporting period for each parameter. Flows are expressed in million 

gallons per day (MGD). pH values are expressed in standard units (SU). 

Flow 

Average of Maximum of 

Outfall Frequency Daily Avg, MGD Daily Max, MGD 

001 Continuous 1.259 1.575 

002 Intermittent No discharge reported 

003 Intermittent 0.148 1.305 

Effluent Characteristics 

Outfall Parameter 

001 Total Dissolved Solids (TDS) 

Specific Gravity 

Chloride 

Sulfate as S04 

Oil and Grease 

pH 

002 _T;::cD=S-;--,;-----;:---:c-------

Specific Gravity 

Average of 

Daily Avg, mg/L 

179,697 

1.141 (*1) 

25,508 

N/A 

6.0 SU, min 

Maximum of 

Daily Max, mg/L 

282,800 

1.210 (*1) 

166,000 

435,001 

22.8 

8.8SU 

Chloride 

Sulfate as S04 

No discharge reported 

Oil and Grease 

H 

003 TDS 150,115 326,000 

Specific Gravity 1.117 (*1) 1.212 (*1) 

Chloride 66,857 211,000 

Sulfate as S04 40,717 178,000 

OilandGrease N/A 11.6 

pH 6.1 SU, min 8.8SU 

("*1) This parameter has no units; it is dimensionless. 

Page3 
STATEMENT OF BASIS j TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooo3642000 

The facility reported a single violation of its effluent limits (daily maximum oil and grease at Outfall 

001) during the period reviewed. No changes were made to the draft permit based on this single 

violation. 

DRAFT PERMIT CONDITIONS 

The draft permit authorizes the discharge of treated process wastewater (plant floor wash water and 

evaporation condensate), spent brine, and stormwater at a daily average flow not to exceed 2.0 MGD via 

Outfall 001; decanted brine water, floor washdown water, condensate, non-contact cooling water, and 

stormwater on an intermittent and flow-variable basis via Outfall 002; and brine water, condensate, 

tank wash down water, stormwater, and overflow from the evaporation pond on an intermittent and 

flow-variable basis via Outfall 003. 

Effluent limitations are established in the draft permit as follows: 

Outfall Pollutant Daily Average, mg/L Daily Maximum, mg/L 

001 Flow 2.oMGD 2.5MGD 

TDS Report Report 

Specific Gravity Report (''1) Report (*1) 

Chloride Report Report 

Sulfate Report Report 

Oil and Grease N/A 20 

pH 6.0 SU,min g.oSU 

002 Flow Report, MGD Report, MGD 

TDS Report Report 

Specific Gravity Report ('*1) Report (*1) 

Chloride Report Report 

Sulfate Report Report 

Oil and Grease N/A 20 

pH 6.0 SU, min g.o SU 

003 Flow Report,MGD Report, MGD 

TDS Report Report 

Specific Gravity Report (*1) Report (*1) 

Chloride Report Report 

Sulfate Report Report 

Oil and Grease N/A 20 

pH 6.0 SU, min g.oSU 

(''1) This parameter has no units; it is dimensionless. 

Technology-Based Effluent Limitations 

Regulations promulgated in Title 40 of the Code of Federal Regulations ( 40 CFR) require technologybased limitations to be placed in wastewater discharge permits based on effluent limitations 

guidelines (ELGs), where applicable, or on best professional judgment (BPJ) in the absence of 

guidelines. ELGs in 40 CFR Part 436 - Mineral Mining and Processing, Subpart L- Salines from 

Brine Lakes, have been previously applied to the withdrawal of brine from Cedar Lake and subsequent 

processing of sodium sulfate. According to regulations in 40 CFR § 436.122(a) for best practicable 

control technology currently available (BPT): "there shall be no discharge of process waste water 

pollutants into navigable waters." Historically, the ELGs in 40 CFR § 436.122(b), which apply the 

limitations in 40 CFR § 436.122(a) [no discharge] on a net basis when "the source ofthe applicant's 

water supply is the same body of water into which the discharge is made," were used to establish 

Page4 
STATEMENT OF BASIS/ TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooo3642000 

Other Requirement No.3 in the original permit (issued July 5, 1994). Other Requirement No.3 

prohibits any net increase of TDS, chloride, and sulfate in the combined discharges from Outfalls 001, 

002, and 003 and specifies that sulfate must be used as the indicator parameter. 

With this application, the permittee submitted an "Approved Jurisdictional Determination Form" 

completed by the U.S. Army Corps of Engineers on April2, 2010. According to this determination 

form, Cedar Lake is "an intrastate, non-navigable isolated water (salt playa lake) and is not subject to 

Section 404 jurisdiction under 33 CFR 328.3(a)(3)." The prohibition on discharging in 40 CFR § 

436.122(a) and the application ofthat prohibition on a net basis in 40 CFR § 436.122(b) therefore do 

not apply; however, the permittee did not request removal of Other Requirement No.3 from the 

permit. 

The review performed during the original permit action determined that TDS, chloride, and sulfate 

were appropriate indicator parameters for the wastewater being discharged, and monitoring and 

reporting requirements for these parameters were included in the original permit. Monitoring and 

reporting requirements for specific gravity were also included in the original permit in order to 

determine whether a correlation could be established with TDS concentration, but it is unclear 

whether such an analysis was ever performed. Monitoring and reporting requirements for TDS, 

chloride, sulfate, and specific gravity are therefore carried forward in the draft permit based on EPA 

anti-backsliding requirements at 40 CFR §122-44(1). The permittee did request that the monitoring 

frequencies for TDS, chloride, sulfate, and specific gravity be reduced from once per week to once per 

year. The requested frequency is consistent with the existing monitoring and reporting frequency for 

oil and grease, and the requested changes have been made. The oil and grease and pH limits, which 

were originally established based on BPJ, are continued in the draft permit based on EPA antibacksliding requirements at 40 CFR §122-44(1). 

Water Quality-Based Effluent Limitations 

Calculations of water quality-based effluent limitations for the protection of aquatic life are presented 

in Appendix A. Aquatic life criteria established in Table 1 of 30 TAC Chapter 307 are incorporated into 

the calculations, as are recommendations in the Water Quality Assessment Team memorandum dated 

January 6, 2015. TCEQ practice for determining significant potential is to compare the reported 

analytical data from the facility against percentages of the calculated daily average water qualitybased effluent limitation. Permit limitations are required when analytical data reported in the 

application exceeds 85 percent of the calculated daily average water quality-based effluent limitation. 

Monitoring and reporting is required when analytical data reported in the application exceeds 70 

percent of the calculated daily average water quality-based effluent limitation. 

Effluent data was submitted with the application for Outfalls 001 and 003; there was no discharge via 

Outfall 002 during the previous permit term. Other Requirement No.9 has been added to the draft 

permit requiring submittal of effluent testing for Outfall 002 within 90 days of a discharge. Effluent 

data for total aluminum at Outfall 003 and hexavalent chromium, total selenium, and total silver at 

both Outfalls 001 and 003 exhibited a wide range of non-detect levels (5 - 500 11g/L) that were all 

greater than the required minimum analytical levels (MALs) in the permit application. Given the 

extremely high TDS concentrations in the effluent, it appears likely that effluent test results were 

affected by matrix interference and that achievement of the TCEQ MALs for these parameters may not 

be possible. For this reason, Other Requirement No. 11 was added to require a study to establish 

effluent-specific MALs for these pollutants. The study is to be completed and submitted to the TCEQ 

within one year of the date of permit issuance and with the next permit application. 

TDS, Chloride, and Sulfate Screening 

Cedar Lake, which receives the discharges from this facility, does not have criteria established for 

TDS, chloride, or sulfate in 30 TAC Chapter 307; therefore, no screening was performed. 

Pages 
pH Screening 

STATEMENT OF BASIS/ TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooo3642000 

The existing permit includes limits on pH of 6.0 - 9.0 SU at Outfalls 001, 002, and 003, which 

discharge into unclassified water bodies. Consistent with the procedures for pH screening that were 

submitted to EPA with a letter dated May 28, 2014, and approved by EPA in a letter dated June 2, 

2014, requiring these discharges to unclassified water bodies to meet pH limits of 6.0 - 9.0 standard 

units reasonably ensures instream compliance with Texas Surface Water Quality Standards pH 

criteria. 

Whole Effluent Toxicity Testing (Biomonitoring) 

Biomonitoring requirements are not included in the draft permit. 

SUMMARY OF CHANGES FROM APPLICATION 

The following change has been made to the draft permit that makes it more stringent: 

1. Other Requirement No. 11 has been added to require the permittee to conduct a study to 

establish effluent-specific MALs for total aluminum, hexavalent chromium, total selenium, and 

total silver. Effluent testing submitted during the application process for these pollutants 

exhibited a wide range of non-detect levels (5 - 500 f.lg/L). Given the extremely high TDS 

concentrations in the effluent, it appears likely that effluent test results were being affected by 

matrix interference and that achievement of the TCEQ MALs for these parameters may not be 

possible. The study is to be completed and submitted to the TCEQ within one year of the date of 

permit issuance and with the next permit application. 

SUMMARY OF CHANGES FROM EXISTING PERMIT 

The permittee requested the following change in its amendment request that the Executive Director 

(ED) has recommended granting. 

1. Reduce sampling frequencies for TDS, chloride, sulfate, and specific gravity from once per week 

to once per year at all three outfalls. Based on information provided in the application, Cedar 

Lake is not considered to be a navigable water body, and the ELGs in 40 CFR § 436.122 no 

longer apply. The monitoring and reporting requirements for TDS, chloride, sulfate, and specific 

gravity were originally included in the permit based on the ELGs. The permittee has not 

requested that these requirements be removed frotn the permit, but the ED agrees there is no 

reason to require weekly monitoring. The monitoring frequencies for these pollutants have been 

reduced to once per year as requested. 

The following additional changes have been made to the draft permit. 

1. "Salt Cake Reclamation Pond" has been changed to "Salt Reclamation Pond" in the discharge 

route for Outfall 002, consistent with the information provided in the permit application. 

2. Other Requirement No. 1 has been updated with current language used to prohibit discharge of 

domestic wastewater. 

3· Other Requirement No. 3, which deals with the no net increase of TDS, chloride, and sulfate, has 

been revised for clarity and to change the frequency of updating records from monthly to yearly, 

consistent with the change in monitoring and reporting frequencies on pages 2-2b. 

4· Other Requirement No. 5 has been revised to specify that the mixing zone definition applies to 

all three outfalls. 

5· Other Requirement No.6, which deals with the disposal of cooling tower blowdown into an 

evaporation pond, has been revised for clarity. 

Page6 
STATEMENT OF BASIS/ TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooo3642000 

6. Other Requirement No. 8 has been revised to remove the instructions for submitting data for 

pollutants that are monitored twice per year and four times per year because the draft permit 

does not include either of these monitoring frequencies. 

7. Existing Other Requirement No.9, dealing with intensive water quality surveys, has been 

removed because it is no longer applicable. 

8. Existing Other Requirement No. 10 has been removed because it is no longer applicable. 

9. New Other Requirement No. 9 has been added to require effluent sampling for Outfall 002 upon 

discharge. Effluent testing tables have been added as Attachment A. 

10. New Other Requirement No. 10 has been added to specify requirements for any new ponds 

constructed after this permit is issued. 

BASIS FOR DRAFf PERMIT 

The following items were considered in developing the draft permit: 

1. Application received on October 14, 2014, and additional information received on November 12, 

December 1, and December 3, 2014, and on March 13, 2015 

2. Existing permits: TPDES Permit No. WQooo3642000 issued on Apri113, 2010 

3. TCEQ Rules 

4. Texas Surface Water Quality Standards- 30 TAC §§307.1-307.10, effective March 6, 2014, as 

approved by EPA Region 6 

5· Texas Surface Water Quality Standards- 30 TAC §§307.1-307.10, eflective July 22, 2010, as 

approved by EPA Region 6, for portions of the 2014 Standards not approved by EPA Region 6 

6. Texas Surface Water Quality Standards - 30 TAC §§307.1-307.10, effective August 17, 2000, and 

Appendix E, effective February 27, 2002, for portions ofthe 2010 Standards not approved by EPA 

Region 6 

7· Procedures to Implement the Texas Surface Water Quality Standards (IP), Texas Commission 

on Environmental Quality, June 2010, as approved by EPA Region 6 

8. Procedures to Implement the Texas Surface Water Quality Standards, Texas Commission on 

Environmental Quality, January 2003, for portions ofthe 2010 IP not approved by EPA Region 6 

9· Memos from the Water Quality Standards Implementation Team and the Water Quality 

Assessment Team of the Water Quality Assessment Section of the TCEQ 

10. "Guidance Document for Establishing Monitoring Frequencies for Domestic and Industrial 

Wastewater Discharge Permits," TCEQ Document No. 98-oo1.ooo-OWR-WQ, May 1998 

11. EPA Effluent Guidelines: N/A 

12. Consistency with the Coastal Management Plan: N/A 

13. Letter dated May 28, 2014, from L'Oreal W. Stepney, P.E., Deputy Director, Office of Water, 

TCEQ, to Bill Honker, Director, Water Quality Protection Division, EPA (TCEQ proposed 

development strategy for pH evaluation procedures) 

14. Letter dated June 2, 2014, from William K. Honker, P.E., Director, Water Quality Protection 

Division, EPA, to L'Oreal W. Stepney, P.E., Deputy Director, Office of Water, TCEQ (Approval of 

TCEQ proposed development strategy for pH evaluation procedures) 

Page7 
STATEMENT OF BASIS/ TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooos642ooo 

PROCEDURES FOR FINAL DECISION 

When an application is declared administratively complete, the Chief Clerk sends a letter to the 

applicant advising the applicant to publish the Notice of Receipt of Application and Intent to Obtain 

Permit in the newspaper. In addition, the Chief Clerk instructs the applicant to place a copy of the 

application in a public place for reviewing and copying in the county where the facility is or will be 

located. This application will be in a public place throughout the comment period. The Chief Clerk also 

mails this notice to any interested persons and, if required, to landowners identified in the permit 

application. This notice informs the public about the application and provides that an interested person 

may file comments on the application or request a contested case hearing or a public meeting. 

Once a draft permit is completed, it is sent, along with the Executive Director's preliminary decision, as 

contained in the technical summary or fact sheet, to the Chief Clerk. At that time, the Notice of 

Application and Preliminary Decision will be mailed to the same people and published in the same 

newspaper as the prior notice. This notice sets a deadline for maldng public comments. The applicant 

must place a copy of the Executive Director's preliminary decision and draft permit in the public place 

with the application. This notice sets a deadline for public comment. 

Any interested person may request a public meeting on the application until the deadline for filing 

public comments. A public meeting is intended for the taking of public comment and is not a contested 

case proceeding. 

After the public comment deadline, the Executive Director prepares a response to all significant public 

comments on the application or the draft permit raised during the public comment period. The Chief 

Clerk then mails the Executive Director's response to comments and final decision to people who have 

filed comments, requested a contested case hearing, or requested to be on the mailing list. This notice 

provides that if a person is not satisfied with the Executive Director's response and decision, they can 

request a contested case hearing or file a request to reconsider the Executive Director's decision within 

30 days after the notice is mailed. 

The Executive Director will issue the permit unless a written hearing request or request for 

reconsideration is filed within 30 days after the Executive Director's response to comments and final 

decision is mailed. If a hearing request or request for reconsideration is filed, the Executive Director will 

not issue the permit and will forward the application and request to the TCEQ Commissioners for their 

consideration at a scheduled Commission meeting. If a contested case hearing is held, it will be a legal 

proceeding similar to a civil trial in state district court. 

If the Executive Director calls a public meeting or the Commission grants a contested case hearing as 

described above, the Commission will give notice of the date, time, and place of the meeting or hearing. 

If a hearing request or request for reconsideration is made, the Commission will consider all public 

comments in making its decision and shall either adopt the Executive Director's response to comments 

or prepare its own response. 

For additional information about this application, contact Karen Halligan at (512) 239-4589. 

March 31, 2015 

Karen Halligan Date 

PageS 
STATEMENT OF BASIS/TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

Appendix A 

Calculated Water Quality-Based Effluent Limits 

TEXTOX MENU #1- INTERMITTENT STREAM 

The water quality-based effluent limitations developed below are calculated using: 

Table 1, 2014 Texas Surface Water Quality Standards (30 TAC 307) for Freshwater Aquatic Life 

"Procedures to Implement the Texas Surface Water Quality Standards," TCEQ June 2010 

PERMIT INFORMATION 

Permittee Name: 

TPDES Permit No: 

Outfall No: 

Prepared By: 

Date: 

DISCHARGE INFORMATION 

Intermittent Receiving Waterbody: 

Segment No: 

Cooper Natural Resources Inc. 

WQ0003642000 

001,002,003 

Karen Halligan 

January 30, 2015 

ditch, Seco Draw, Coyote Draw, Cedar Draw 

1400 

TSS (mg/L): 16 (Value from Segment No. 1412) 

pH (Standard Units): 7.6 (Value from Segment No. 1412) 

Hardness (mg/L as CaC03 ): 31D (Value from Segment No. 1412) 

Chloride (mg/L): 1635 (Value from Segment No. 1412) 

Effluent Flow for Aquatic Life (MGD): not needed- results not dependent on flow 

Critical Low Flow [7Q2) (cis): 0 

%Effluent for Acute Aquatic Life: ____:1c"O::.O ____________ _ 

CALCULATE DISSOLVED FRACTION (AND ENTER WATER EFFECT RATIO IF APPLICABLE): 

Partftlon Dissolved Water 

Intercept Slope Coefficient Fraction Effect Ratio 

Stream/River Metal (b) (m) {Kp} {Cd/Ct) {WER) 

Aluminum N/A N/A N/A 1.00 Assumed 1 Assumed 

Arsenic 5.68 -0.73 63240.08 0.50 1 Assumed 

Cadmium 6.60 -1.13 173517.95 0.26 1 Assumed 

Chromium (Total) 6.52 -0.93 251286.07 0.20 1 Assumed 

Chromium (+3) 6.52 -0.93 251286.07 0.20 1 Assumed 

Chromium (+6) N/A N/A N/A 1.00 Assumed 1 Assumed 

Copper 5.02 -0.74 134570.92 0.32 1 Assumed 

Lead 6.45 -0.80 306593.11 0.17 1 Assumed 

Mercury N/A N/A N/A 1.00 Assumed 1 Assumed 

Nickel 5.69 -0.57 100844.36 0.38 1 Assumed 

Selenium N/A N/A N/A 1.00 Assumed 1 Assumed 

Silver 6.38 -1.03 137951.03 0.31 1 Assumed 

Zinc 6.10 -0.70 180765.59 0.26 1 Assumed 

Page9 
STATEMENT OF BASIS/ TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQ0003642000 

AQUATIC LIFE 

CAlCUlATE DAllY AVERAGE AND DAllY MAXIMUM EFFlUENT LIMITATIONS: 

FWAcute Daily Daily 

Criterion Avg. Max. 

Parameter (ug/L} WLAa LTAa (ug/L} (ug/L} 

Aldrin 3.0 3.0 1.72 2.53 5.35 

Aluminum 991 991 568 835 1766 

Arsenic 340 684 392 576 1219 

Cadmium 25.7 97.2 55.7 81.9 173 

Carbaryl 2.0 2.0 1.15 1.68 3.56 

Chlordane 2.4 2.4 1.38 2.02 4.28 

Chlorpyrifos 0.083 0.083 0.048 0.070 0.148 

Chromium (+3) 1439 7226 4140 6086 12876 

Chromium (+6) 15.7 15.7 9.00 13.2 28.0 

Copper 41.2 130 74.5 110 232 

Cyanide (free) 45.8 45.8 26.2 38.6 81.6 

4,4'-DDT 1.1 1.1 0.630 0.927 1.96 

Demeton N/A N/A N/A N/A N/A 

Diazlnon 0.17 0.17 0.097 0.143 0.303 

DicofoJ 59.3 59.3 34.0 49.9 106 

Dieldrin 0.24 0.24 0.138 0.202 0.428 

Diu ron 210 210 120 177 374 

Endosulfan I (alpha) 0.22 0.22 0.126 0.185 0.392 

Endosulfan II (beta) 0.22 0.22 0.126 0.185 0.392 

Endosulfan sulfate 0.22 0.22 0.126 0.185 0.392 

Endrin 0.086 0.086 0.049 0.072 0.153 

Guthion N/A N/A N/A N/A N/A 

Heptachlor 0.52 0.52 0.298 0.438 0.927 

Hexachlorocyclohexane (Lindane) 1.126 1.126 0.645 0.948 2.01 

Lead 216 1275 731 1074 2272 

Malathion N/A N/A N/A N/A N/A 

Mercury 2.4 2.4 1.38 2.02 4.28 

Methoxychlor N/A N/A N/A N/A N/A 

Mirex N/A N/A N/A N/A N/A 

Nickel 1219 3187 1826 2684 5679 

Nonylphenol 28 28 16.0 23.6 49.9 

Parathion (ethyl) 0.065 0.065 0.037 0.055 0.116 

Pentachlorophenol 15.9 15.9 9.14 13.4 28.4 

Phenanthrene 30 30 17.2 25.3 53.5 

Polychlorinated Biphenyls (PCBs) 2.0 2.0 1.15 1.68 3.56 

Selenium 20 20 11.5 16.8 35.6 

Silver 0.8 28.6 16.4 24.1 50.9 

Toxaphene 0.78 0.78 0.447 0.657 1.39 

Trlbutyltin (TBT) 0.13 0.13 0.074 0.110 0.232 

2,4,5 Trichlorophenol 136 136 77.9 115 242 

Zinc 306 1190 682 1002 2120 

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STATEMENT OF BASIS/ TECHNICAL SUMMARY AND 

EXECUTIVE DIRECTOR'S PRELIMINARY DECISION 

TPDES Permit No. WQooo3642000 

CALCULATE 70% AND 85% OF DAILY AVERAGE EFFLUENT LIMITATIONS: 

Aquatic Life 

Parameter 70% 85% 

Aldrin. 1.77 2.15 

Aluminum 584 710 

Arsenic 403 490 

Cadmium 57.3 69.6 

Carbaryl 1.18 1.43 

Chlordane 1.42 1.72 

Chlorpyrifos 0.049 0.059 

Chromium (+3) 4260 5173 

Chromium (+6) 9.26 11.2 

Copper 76.7 93.1 

Cyanide (free) 27.0 32.8 

4,4'-DDT 0.649 0.788 

Demeton N/A N/A 

Diazinon 0.100 0.122 

Dicofol 35.0 42.5 

Dieldrin 0.142 0.172 

Diu ron 124 150 

Endosulfan I (alpha) 0.130 0.158 

Endosulfan II (beta) 0.130 0.158 

Endosulfan sulfate 0.130 0.158 

Endrin 0.051 0.062 

Guthion N/A N/A 

Heptachlor 0.307 0.372 

Hexachlorocyclohexane (Lindane) 0.664 0.806 

Lead 752 913 

Malathion N/A N/A 

Mercury 1.42 1.72 

Methoxychlor N/A N/A 

Mirex N/A N/A 

Nickel 1879 2282 

Nonylphenol 16.5 20.0 

Parathion (ethyl) 0.038 0.047 

Pentachlorophenol 9.40 11.4 

Phenanthrene 17.7 21.5 

Polychlorinated Biphenyls (PCBs) 1.18 1.43 

Selenium 11.8 14.3 

Silver 16.8 20.5 

Toxaphene 0.460 0.558 

Tributyltin (TBT) 0.077 0.093 

2,4,5 Trichlorophenol 80.2 97.4 

Zinc 701 852 

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