April 30, 2012 D. Nichols/ERO 

Fact Sheet for NPDES Permit WA002106-7

Quincy Industrial Wastewater Treatment Facility 

Purpose of this fact sheet 

This fact sheet explains and documents the decisions the Department of Ecology (Ecology) made 

in drafting the proposed National Pollutant Discharge Elimination System (NPDES) Permit for 

the City of Quincy’s Industrial Wastewater Treatment Facility. 

This fact sheet complies with Section 173-220-060 of the Washington Administrative Code 

(WAC), which requires Ecology to prepare a draft permit and accompanying fact sheet for public 

evaluation before issuing an NPDES permit. 

Ecology makes the draft permit and fact sheet available for public review and comment at least 

thirty (30) days before issuing the final permit. Copies of the fact sheet and draft permit are 

available for public review and comment from January 6, 2012 until February 6, 2012. For 

more details on preparing and filing comments about these documents, please see Appendix A - 

Public Involvement Information. 

The City and Environmental Management Corporation (Operator) reviewed the draft fact sheet 

for factual accuracy. Ecology corrected any errors or omissions regarding the facility’s location, 

history, discharges, or receiving water prior to publishing this draft fact sheet for public notice. 

After the public comment period closes, Ecology will summarize substantive comments and 

provide responses to them. Ecology will include the summary and responses to comments in this 

fact sheet as Appendix E - Response to Comments, and publish it when issuing the final 

NPDES permit. Ecology will not revise the fact sheet in response to comments, but the full 

document will become part of the legal history contained in the facility’s permit file. Ecology 

will annotate those fact sheet sections that Ecology changed as a result of responding to 

comments received from the Permittee during the public review period. The original fact sheet 

wording will not be changed in response to comments received during the public review period. 

Summary 

The City of Quincy owns an industrial wastewater treatment facility that treats process 

wastewater from a potato and vegetable processor and discharges to a U.S Bureau of 

Reclamation irrigation wasteway year around. No sanitary wastewater is discharged to the 

facility or irrigation wasteway. Environmental Management Corporation (EMC) operates the 

facility as per a service agreement. The City and EMC are Co-Permittees. 

Water-quality based seasonal effluent limits for Biochemical Oxygen Demand (BOD5), fecal 

coliform bacteria, chlorine, dissolved oxygen and temperature remain unchanged from the permit 

issued in 2006. Ecology included water quality-based limits for ammonia in this permit based on 

the wasteload allocation from a TMDL. The 2006 performance-based limits for total suspended 

solids were updated based on the past five years of discharge data. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 2 of 62 

April 30, 2012 D. Nichols/ERO 

The proposed permit requires the submittal of a discharge management plan that describes where 

the City of Quincy plans to discharge the final effluent after September 2015 when the contract 

with the U.S. Bureau of Reclamation expires and the point of discharge is eliminated. The 

proposed permit also requires the City of Quincy to submit an updated engineering report that 

describes the changes needed to re-route the discharge to another location and a new permit 

application for the authorization to discharge the wastewater to a new location. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 3 of 62 

April 30, 2012 D. Nichols/ERO 

Table of Contents 

I. Introduction ............................................................................................................ 6

II. Background Information ....................................................................................... 7

A. Facility description................................................................................................ 8

History ................................................................................................................................ 9

Wastewater Treatment processes ........................................................................................ 9

Solid wastes ...................................................................................................................... 11

Pretreatment Delegation.................................................................................................... 11

B. Description of the receiving water ..................................................................... 12

C. Wastewater characterization ............................................................................. 13

D. Summary of compliance with previous permit Issued .................................... 14

III. Proposed Permit Limits ........................................................................................ 15

A. Design criteria ..................................................................................................... 15

B. Technology-based effluent limits ....................................................................... 16

C. Surface water quality-based effluent limits ...................................................... 18

Numerical criteria for the protection of aquatic life and recreation .................................. 18

Numerical criteria for the protection of human health ...................................................... 18

Narrative criteria ............................................................................................................... 18

Antidegradation ................................................................................................................ 19

Mixing zones..................................................................................................................... 19

D. Designated uses and surface water quality criteria ......................................... 23

E. Water quality impairments ................................................................................ 24

F. Evaluation of surface water quality-based effluent limits for numeric criteria

............................................................................................................................... 26

G. Human health ...................................................................................................... 30

H. Whole effluent toxicity ........................................................................................ 30

I. Brine Water Discharge ....................................................................................... 30

J. Comparison of effluent limits with the previous permit issued on October 13, 

2006....................................................................................................................... 31

IV. Monitoring Requirements .................................................................................... 33

A. Lab accreditation ................................................................................................ 33

B. Effluent limits which are near detection or quantitation levels ...................... 33

V. Other Permit Conditions ...................................................................................... 34

A. Reporting and record keeping ........................................................................... 34

B. Spill plan .............................................................................................................. 34
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 4 of 62 

April 30, 2012 D. Nichols/ERO 

C. Solid waste control plan ..................................................................................... 34

D. Operation and maintenance manual ................................................................. 34

E. Leak Detection ..................................................................................................... 35

F. Plan for Stopping the Discharge to U.S. Bureau of Reclamation Wasteway 

DW237, W645W, and W645 .............................................................................. 35

G. Application for Permit Renewal ....................................................................... 35

H. Engineering Report – Update ........................................................................... 36

Plans and Specifications ................................................................................................... 36

I. General conditions .............................................................................................. 36

VI. Permit Issuance Procedures ................................................................................ 36

A. Permit modifications ........................................................................................... 36

B. Proposed permit Issuance .................................................................................. 36

VII. REFERENCES FOR TEXT AND APPENDICES ............................................ 37

Appendix A - Public Involvement Information .......................................................................... 38

Appendix B - Your Right to Appeal ............................................................................................. 39

Appendix C - Glossary ................................................................................................................. 40

Appendix D - Technical Calculations ......................................................................................... 45

Appendix E - Response to Comments.......................................................................................... 46

Appendix F - Graphs, Figures, Tables ........................................................................................ 60

Table 1: General Facility Information ........................................................................................... 7

Table 2: Wasteway DW237 Water Quality Data ......................................................................... 13

Table 3: Wastewater Characterization ......................................................................................... 14

Table 4: Design Criteria for the Primary Treatment Plant ........................................................... 16

Table 5: Design Flow Standards for the SBRs ............................................................................ 16

Table 6: Performance-based limits for TSS ................................................................................. 17

Table 7: Aquatic Life Uses and Associated Criteria .................................................................... 23

Table 8: Recreational Uses and Associated Criteria .................................................................... 24

Table 9: Seasonal Dilution Factors .............................................................................................. 26

Table 10: TMDL BOD Loading .................................................................................................. 27

Table 11: TMDL Ammonia Loading ........................................................................................... 27
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 5 of 62 

April 30, 2012 D. Nichols/ERO 

Table 12: Comparison of Previous and Proposed Effluent Limits - Summer Season (April - 

October) ........................................................................................................................................ 31

Table 13: Comparison of Previous and Proposed Effluent Limits - Winter Season (November - 

March) ........................................................................................................................................... 32

Figure 1: Facility Location Map .................................................................................................... 8

Figure 2: Aerial photograph of primary facility ............................................................................ 9

Figure 3: Aerial photograph of SBRs and sludge storage lagoons .............................................. 10

Figure 4: Final Discharge Location Map ..................................................................................... 11

Figure 5: Columbia Basin Irrigation Project ................................................................................ 12

Figure 6: Frenchman Hills Wasteway and Potholes Reservoir ................................................... 25

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 6 of 62 

April 30, 2012 D. Nichols/ERO 

I. Introduction 

The Federal Clean Water Act (FCWA, 1972, and later amendments in 1977, 1981, and 1987) 

established water quality goals for the navigable (surface) waters of the United States. One 

mechanism for achieving the goals of the Clean Water Act is the National Pollutant Discharge 

Elimination System (NPDES), administered by the federal Environmental Protection Agency 

(EPA). The EPA authorized the state of Washington to manage the NPDES permit program in 

our state. Our state legislature accepted the delegation and assigned the power and duty for 

conducting NPDES permitting and enforcement to Ecology. The Legislature defined Ecology's 

authority and obligations for the wastewater discharge permit program in 90.48 RCW (Revised 

Code of Washington). 

The following regulations apply to municipal NPDES permits: 

• Procedures Ecology follows for issuing NPDES permits (chapter 173-220 WAC) 

• Water quality criteria for surface waters (chapter 173-201A WAC) 

• Water quality criteria for ground waters (chapter 173-200 WAC) 

• Whole effluent toxicity testing and limits (chapter 173-205 WAC) 

• Sediment management standards (chapter 173-204 WAC)

• Submission of plans and reports for construction of wastewater facilities (chapter 173-240 

WAC) 

These rules require any industrial facility owner/operator to obtain an NPDES permit before 

discharging wastewater to State waters. They also help define the basis for limits on each 

discharge and for performance requirements imposed by the permit. 

Under the NPDES permit program and in response to a complete and accepted permit 

application, Ecology must prepare a draft permit and accompanying fact sheet, and make them 

available for public review before final issuance. Ecology must also publish an announcement 

(public notice) telling people where they can read the draft permit, and where to send their 

comments, during a period of thirty days (WAC 173-220-050). (See Appendix A - Public 

Involvement Information for more detail about the public notice and comment procedures). 

After the public comment period ends, Ecology may make changes to the draft NPDES permit in 

response to comment(s). Ecology will summarize the responses to comments and any changes to 

the permit in Appendix E. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 7 of 62 

April 30, 2012 D. Nichols/ERO 

II. Background Information 

Table 1: General Facility Information 

Facility Information

Applicant: City of Quincy Environmental Management 

Corporation 

Facility Name and Address P.O. Box 338 

Quincy, WA 98848 

P.O. Box 1249 

Quincy, WA 98848 

Contact at Facility N/A Jay Favor 

509.787.2423 

Responsible Official Tim Snead 

City Administrator 

P.O. Box 338, 

Quincy, WA 

509.787.3523 

Randy Jones 

Regional Dir of Op’s, EMC 

1001 Boardwalk Springs Place 

Suite 100 

O’Fallon, MO 63368 

636.561.9400 

Industry Type City owned, privately operated treatment facility that 

receives process wastewater from a potato and vegetable 

processor 

Type of Treatment Primary settling, anaerobic digestion, sequencing batch 

reactors, disinfection, summer season cooling, and reaeration. 

SIC Codes 2037 

Facility Location (NAD83/WGS84 reference 

datum) 

Primary treatment facility: 

Latitude: 47.234183 

Longitude: 119.87395 

SBR treatment facility: 

Latitude: 47.2162 

Longitude: 119.8525

Discharge Waterbody Name and Location 

(NAD83/WGS84 reference datum) 

U.S. Bureau of Reclamation wasteway DW237 

(Columbia Basin Irrigation Project) 

Latitude: 47.200883 

Longitude: -119.88945 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 8 of 62 

April 30, 2012 D. Nichols/ERO 

Permit Status 

Renewal Date of Previous Permit October 13, 2011 

Application for Permit Renewal Submittal Date May 5, 2011 

Date of Ecology Acceptance of Application September 22, 2011 

Inspection Status

Date of Last Non-sampling Inspection Date October 26, 2010 

Figure 1: Facility Location Map 

A. Facility description 

The City’s industrial wastewater facility receives process wastewater from a year around 

potato processor and a seasonal vegetable processor. The two separate waste streams 

discharge to the primary treatment facility that consists of screening, clarifiers and solids 

dewatering. The primary treated water is pumped to the secondary treatment system that is 

comprised of two sequencing batch reactors; SBR’s. The SBR effluent is pumped to a final 

treatment site that consists of disinfection, cooling (summer season), and re-aeration. 

City of Quincy 

West Canal 

Industrial wastewater treatment 

facility; primary treatment 

Industrial wastewater treatment 

facility; SBR secondary treatment 

Indus. w/w; final effluent discharge to 

DW237 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 9 of 62 

April 30, 2012 D. Nichols/ERO 

The City discharges the final effluent to a U.S. Bureau of Reclamation wasteway; DW237. 

Immediately after discharge and mixing, the wasteway flows beneath the W. Canal and 

becomes W645W, which later becomes W645 that discharges to the Potholes Reservoir. The 

entire receiving water system is part of the federal Columbia Basin Irrigation Project that 

began in the mid-1950s. 

History 

The City of Quincy is located in central Washington (Grant Co.) and within the federal 

Columbia Basin Irrigation Project that supplies irrigation water from the Columbia River to 

approximately 500,000 acres of production agriculture. The City has owned and operated an 

industrial wastewater treatment system since the 1960’s. The current system is designed to 

treat the process wastewater from a potato and vegetable processor; ConAgra Foods and 

Quincy Foods, respectively. ConAgra operates year around (average flow of 1.63 mgd) and 

Quincy Foods (average flow of 0.66 mgd) operates during the vegetable harvest season. 

Ecology permits both facilities under a state waste discharge permit that authorizes the 

discharges to the City’s industrial system. No sanitary wastes are discharged into the 

industrial wastewater system. 

In August 2009, Environmental Management Corporation took over operations of the City’s 

entire wastewater system (industrial and sanitary) from Earth Tech, Inc. Ecology reviewed 

the EMC/City service agreement as required by Chapter 70.150.040(9) RCW and determined 

it was consistent with Chapter 90.48 RCW. 

Wastewater Treatment processes 

Primary facility: Process wastewater from both processors is piped separately to the primary 

treatment facility which is comprised of screening and a clarifier for each stream. Solids from 

the clarifiers are dewatered using centrifuges, and are trucked off-site for cattle feed. The 

clarifier effluent is pumped via an 18 inch force main approximately one mile to the 

secondary treatment site; SBR. 

Figure 2: Aerial photograph of primary facility 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 10 of 62 

April 30, 2012 D. Nichols/ERO 

Secondary treatment facility: The wastewater from the primary facility is directed to one of 

two earthen walled and geomembrane-lined sequencing batch reactor basins; Figure 2. Each 

reactor basin discharges to a geomembrane- lined, earthen walled flow equalization basin. 

Wastewater from the basin is pumped to the above ground disinfection contact chamber 

where sodium hypochlorite is added. The contact time is 20 minutes at the design flow (5 

cfs). 

Wastewater from the chlorine contact basin flows through a three-cell, fan forced-air cooling 

tower for temperature control. This system operates only during the summer months (AprilOctober) when temperature discharge limits are in effect. Wastewater from the cooling tower 

is dechlorinated using sodium bisulfite and then pumped to a fine pore diffused aeration 

basin to increase the dissolved oxygen to meet permit discharge limits. 

The cooling tower includes a temperature monitoring probe at the end of the tower that 

measures the temperature of the wastewater exiting the tower. If the temperature exceeds the 

permit limit, the water automatically diverts to lagoon #5. 

The discharge from the re-aeration basin gravity flows approximately one mile in a 24 inch 

pipe prior to discharge to the Bureau of Reclamation’s DW237 wasteway; Figure 3. 

Immediately after discharge the DW237 crosses the West Canal via a siphon and emerges as 

the W645W wasteway. The wasteway is part of the Bureau’s irrigation return flow collection 

system that discharges to the Potholes Reservoir. Water from the reservoir is re-distributed to 

the southern portion of the irrigation project area. 

Figure 3: Aerial photograph of SBRs and sludge storage lagoons 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 11 of 62 

April 30, 2012 D. Nichols/ERO 

Figure 4: Final Discharge Location Map 

Anaerobic Digestion 

Beginning in January 2011, Quincy dewatered sludge lagoon #2 (Figure 3) to allow the 

construction of a 22 million gallon, High Density Polyethylene (HDPE) lined and covered 

anaerobic digester. The digester will replace the primary treatment facility (Figure 1) and 

help equalize the hydraulic and organic loading to the SBRs. The City plans to begin 

operation of the digester by the end of 2011. 

Brine Ponds

Quincy plans to construct two double lined brine ponds with leak detection (1.25 MG each) 

in 2011/12 on land immediately adjacent to the disinfection/cooling/re-aeration site (Figure 

3). The ponds are part of the City’s brine management system that will receive brine 

regeneration water from a demineralization facility that will provide cooling water to 

privately owned data servers in Quincy. 

Solid wastes 

Waste sludge from the SBRs discharges to the onsite unlined storage lagoons; Figure 2. 

Liquid decanted from the lagoons is directed back to the SBR system. 

Pretreatment Delegation 

Ecology issued an administrative order to Quincy that required it to obtain pretreatment 

delegation authority and begin permit issuance by May 2012. 

Disinfection, cooling, re-aeration 

site, and Brine Pond site 

Lagoon #5 

West Canal 

Anaerobic Digester site; 

sludge storage #2 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 12 of 62 

April 30, 2012 D. Nichols/ERO 

B. Description of the receiving water 

The facility discharges to the U.S. Bureau of Reclamation’s irrigation return drain DW237, 

that changes to wasteway W645W and W645 (Figure 1). Wasteway W645 discharges into 

the Frenchman Hills Wasteway that discharges to the Potholes Reservoir. The entire system 

is part of the federal Columbia Basin Irrigation Project that brings water from the Columbia 

River to approximately 500,000 acres in central Washington. 

Wasteway drains are manmade and are part of the irrigation project that receive excess water 

from irrigated lands (sprinkler and rill irrigation) and field underdrain systems. There is 

essentially no riparian vegetation associated with wasteways. 

Figure 5: Columbia Basin Irrigation Project 

Potholes Reservoir 

Irrigation Project 

Columbia River 

Point of Discharge 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 13 of 62 

April 30, 2012 D. Nichols/ERO 

EMC submits monthly receiving water data in DMRs. Ecology summarized the data for Jan 

2001 – July 2011. The data is based on grab samples once/month. 

Table 2: Wasteway DW237 Water Quality Data 

Parameter Value 

Temperature (highest annual 1-DADMax) 84 °F 

Temperature (highest annual 7-DADMax) 84 °F 

pH (Maximum / Minimum) 11 / 6.6 standard units 

Dissolved Oxygen (average; max; min) 8.4; 12.4; 1.1 mg/L 

Total Ammonia-N (average; max; min) 0.64; 14.5; 0.02 mg/L 

Fecal Coliform (max; geometric mean) 156 /100 mL; 12 /100mL 

Alkalinity (average) 165 mg/L as CaCO3 

BOD (average) 4.9 mg/L 

TKN (average) 1.2 mg/L 

Flow (average; max; min) 11.9; 28.8; 2.2 cfs 

U.S.Bureau of Reclamation Discharge Contract

The discharge of the treated industrial wastewater into the bureau’s wasteway (Figure 3) 

is allowed per an agreement between the City and the Bureau dated September 21, 1965 

that expires in 2015. In a letter dated July 19, 2010, the Bureau informed the City they do 

not intend to renew the contract. 

C. Wastewater characterization 

The City/EMC reported the concentration of pollutants in the discharge in the permit 

application and in discharge monitoring reports. The tabulated data represents the quality of 

the wastewater effluent discharged to wasteway DW237. The wastewater effluent is 

characterized as follows: 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 14 of 62 

April 30, 2012 D. Nichols/ERO 

Table 3: Wastewater Characterization 

Parameter Units # of 

Samples 

Average Value Maximum 

Daily Value 

 BOD mg/L 52 19.6 59 

 Lbs/day 52 230 695 

TSS mg/L 58 39 118 

 Lbs/day 58 514 2039 

Ammonia mg/L 85 1.01 17 

 Lbs/day 85 14 298 

Total Residual Chlorine mg/L 260 0 0 

Temperature (summer) °C 122 20.2 22.5 

 (winter) °C 118 13.8 22.5 

Flow MGD 365 1.48 3.03 

Parameter Units # of 

Samples 

Average Value * Maximum 

Daily Value *

Fecal Coliforms #/ 100 mL 52 6 48 

Parameter Units # of 

Samples 

Minimum Value Maximum 

Value 

pH standard units 233 6.0 8.6 

*

 The units for the fecal coliform values are as presented in the permit application. The units are 

different from what are in the Fact Sheet boilerplate: monthly geometric mean; 7-Day geometric 

mean. 

D. Summary of compliance with previous permit Issued 

Ecology queried the agency’s permit tracking system (PARIS) for violations during the current 

permit cycle; Appendix E, Table 1. The City and EMC generally complied with the terms and 

conditions in the permit over the current permit cycle. All required reports have been submitted. 

All violations of the effluent flow limit (3.23 MGD) occurred in 2007 and were minor 

exceedances. Many of the ammonia violations were due to problems with the SBR aeration 

system which the City replaced in 2009. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 15 of 62 

April 30, 2012 D. Nichols/ERO 

 The City and EMC submitted a leak detection plan for the SBRs as required by the permit. The 

first submittal in 2008 was updated in 2010; EMC, 2010. The first leak survey was scheduled for 

February/March 2011. To date, the leak survey of the SBRs has not been done. 

III. Proposed Permit Limits 

Federal and state regulations require that effluent limits in an NPDES permit must be either 

technology- or water quality-based. 

Technology-based limits are based upon the treatment methods available to treat specific 

pollutants. Technology-based limits are set by the EPA and published as a regulation, or 

Ecology develops the limit on a case-by-case basis (40 CFR 125.3, and chapter 

173-220 WAC). 

Water quality-based limits are calculated so that the effluent will comply with the Surface Water 

Quality Standards (chapter 173-201A WAC), Ground Water Standards (chapter 

173-200 WAC), Sediment Quality Standards (chapter 173-204 WAC), or the National Toxics 

Rule (40 CFR 131.36). 

Ecology must apply the most stringent of these limits to each parameter of concern. These limits 

are described below. 

The limits in this permit reflect information received in the application and from supporting 

reports (engineering, hydrogeology, etc.). Ecology evaluated the permit application and 

determined the limits needed to comply with the rules adopted by the State of Washington. 

Ecology does not develop effluent limits for all reported pollutants. Some pollutants are not 

treatable at the concentrations reported, are not controllable at the source, are not listed in 

regulation, and do not have a reasonable potential to cause a water quality violation. 

Ecology does not usually develop limits for pollutants not reported in the permit application but 

may be present in the discharge. The permit does not authorize discharge of the non-reported 

pollutants. During the five-year permit term, the facility’s effluent discharge conditions may 

change from those conditions reported in the permit application. The facility must notify Ecology 

if significant changes occur in any constituent [40 CFR 122.42(a)]. Until Ecology modifies the 

permit to reflect additional discharge of pollutants, a permitted facility could be violating its 

permit. 

A. Design criteria 

Under WAC 173-220-150 (1)(g), flows and waste loadings must not exceed approved design 

criteria. Ecology approved design criteria for this facility’s treatment plant in the engineering 

report dated 1997 and prepared by Montgomery Watson. The table below includes design 

criteria from the referenced report. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 16 of 62 

April 30, 2012 D. Nichols/ERO 

Table 4: Design Criteria for the Primary Treatment Plant 

Parameter Design Quantity 

Peak monthly flow 4.89 MGD 

Instantaneous peak flow 6.98 MGD 

BOD5 influent loading 74,000 lb/day 

TSS influent loading 66,400 lb/day 

TKN influent loading 4700 lbs/day 

The design influent values for the primary treatment facility were based on flows and 

concentrations in the influent from Lamb-Weston and J.R. Simplot (now Quincy Foods) during a 

12 month period (November 95 – October 96). 

Ecology obtained the design flow criteria for the SBRs and the 2005 upgrades from the amended 

engineering reports prepared by Earth Tech (2000; 2005) and are as follows: 

Table 5: Design Flow Standards for the SBRs 

Parameter Design Quantity 

Maximum daily flow 3.23 MGD 

Maximum month daily flow 4.89 MGD 

The maximum daily flow design value is based on meeting the requirements in the 1965 signed 

agreement between the City and the Bureau of Reclamation that allows the crossing of the 

Bureau’s right of way with an industrial sewerage system and the discharge into the irrigation 

wasteway. 

B. Technology-based effluent limits 

The design of the industrial wastewater facility was based, in part, on the quality and quantity 

of process wastewater discharged from the potato and vegetable processor that discharge to 

the system, and meeting the discharge limits in the permit. Quincy upgraded the SBRs in 

2000 to meet TMDL ammonia limits and upgraded in 2005 to meet water quality-based 

limits for dissolved oxygen, fecal coliforms, and temperature. Ecology included technologybased limits in the permit for TSS and pH. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 17 of 62 

April 30, 2012 D. Nichols/ERO 

TSS

Ecology used daily effluent TSS data (Jan 2007 – Sept 2011) provided by EMC to update the 

performance-based limits for TSS; Appendix D. The values for ‘Lognormal Transformed 

Mean’ and ‘Lognormal Transformed Variance’ in the performance-based calculations were 

determined from the daily TSS data for the summer (April – October) and winter (November 

– March) seasons. The analysis is also based on a discharge flow of 3.23 MGD. 

The results of the performance-based analysis provided the following concentration and load 

limits. 

Table 6: Performance-based limits for TSS 

Proposed TSS Performance-Based Limits 

Summer (April – October) Winter (November – March) 

Maximum Daily limit 114 mg/L; 3071 lbs/day 140 mg/L; 3771 lbs/day 

Average Monthly limit 64 mg/L; 1724 lbs/day 72 mg/L; 1940 lbs/day 

Current TSS Performance-Based Limits 

Summer Winter 

Maximum Daily limit 218 mg/L (7272 lbs/day) 118 mg/L (3936 lbs/day) 

Average Monthly limit 109 mg/L (3636 lbs/day) 59 mg/L (3636 lbs/day) 

The TSS performance-based limits in the current permit are based on daily effluent data for June 

02 – March 2006 (n = 196). The SBRs went online in February 2002, therefore the data base 

includes startup values. From Table 6 it can be seen that the updated winter season TSS limits 

(Jan 07 – Sept 11) are less stringent (i.e., lower concentration and load values) than the values in 

the current permit. If Ecology used the updated limit values, this action would be considered 

backsliding (40 CFR122.44(l)(1)) which is not allowed. Therefore, Ecology will extend the 

current winter season limits for TSS into the proposed permit. 

However, the updated summer season TSS limits are more stringent than the current TSS limits. 

The updated summer season limits reflect the most up-to-date operational efficiency of the 

SBRs. Ecology has decided to include the updated TSS performance-based limits in the proposed 

permit. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 18 of 62 

April 30, 2012 D. Nichols/ERO 

Ecology compared the updated summer season TSS limits to actual effluent values for Jan 2007 

– July 2011; Appendix F, Figs. 3 and 4. Effluent values were generally less than their respective 

limits. Compliance with the limits was best in 2010 and 2011 after replacement of the SBR 

aeration system. 

C. Surface water quality-based effluent limits 

The Washington State surface water quality standards (chapter 173-201A WAC) are 

designed to be protective of existing water quality and preserve the beneficial uses of 

Washington's surface waters. Waste discharge permits must include conditions that ensure 

the discharge will meet the surface water quality standards (WAC 173-201A-510). Water 

quality-based effluent limits may be based on an individual waste load allocation or on a 

waste load allocation developed during a basin wide total maximum daily load study 

(TMDL). 

Numerical criteria for the protection of aquatic life and recreation 

Numerical water quality criteria are listed in the water quality standards for surface waters 

(chapter 173-201A WAC). They specify the maximum levels of pollutants allowed in 

receiving water to protect aquatic life and recreation in and on the water. Ecology uses 

numerical criteria along with chemical and physical data for the wastewater and receiving 

water to derive the effluent limits in the discharge permit. When surface water quality-based 

limits are more stringent or potentially more stringent than technology-based limits, the 

discharge must meet the water quality-based limits.

Numerical criteria for the protection of human health 

The U.S. EPA has published 91 numeric water quality criteria for the protection of human 

health that are applicable to dischargers in Washington State (EPA, 1992). These criteria are 

designed to protect humans from exposure to pollutants linked to cancer and other diseases, 

based on consuming fish and shellfish and drinking contaminated surface waters. The water 

quality standards also include radionuclide criteria to protect humans from the effects of 

radioactive substances. 

Narrative criteria 

Narrative water quality criteria (e.g., WAC 173-201A-240(1); 2006) limit the toxic, 

radioactive, or other deleterious material concentrations that the facility may discharge to 

levels below those which have the potential to: 

• Adversely affect designated water uses. 

• Cause acute or chronic toxicity to biota. 

• Impair aesthetic values. 

• Adversely affect human health. 

Narrative criteria protect the specific designated uses of all fresh waters 

(WAC 173-201A-200, 2006) and of all marine waters (WAC 173-201A-210, 2006) in the 

state of Washington. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 19 of 62 

April 30, 2012 D. Nichols/ERO 

Antidegradation 

Description--The purpose of Washington's Antidegradation Policy 

(WAC 173-201A-300-330; 2006) is to: 

• Restore and maintain the highest possible quality of the surface waters of Washington. 

• Describe situations under which water quality may be lowered from its current condition. 

• Apply to human activities that are likely to have an impact on the water quality of surface 

water. 

• Ensure that all human activities likely to contribute to a lowering of water quality, at a 

minimum, apply all known, available, and reasonable methods of prevention, control, and 

treatment (AKART). 

• Apply three tiers of protection (described below) for surface waters of the State. 

Tier I ensures existing and designated uses are maintained and protected and applies to all 

waters and all sources of pollutions. Tier II ensures that waters of a higher quality than the 

criteria assigned are not degraded unless such lowering of water quality is necessary and in 

the overriding public interest. Tier II applies only to a specific list of polluting activities. 

Tier III prevents the degradation of waters formally listed as "outstanding resource waters," 

and applies to all sources of pollution. 

A facility must prepare a Tier II analysis when all three of the following conditions are met: 

• The facility is planning a new or expanded action. 

• Ecology regulates or authorizes the action. 

• The action has the potential to cause measurable degradation to existing water quality at 

the edge of a chronic mixing zone. 

Facility Specific Requirements--This facility must meet Tier I requirements. 

• Dischargers must maintain and protect existing and designated uses. Ecology must not 

allow any degradation that will interfere with, or become injurious to, existing or 

designated uses, except as provided for in chapter 173-201A WAC. 

Mixing zones 

A mixing zone is the defined area in the receiving water surrounding the discharge port(s), 

where wastewater mixes with receiving water. Within mixing zones the pollutant 

concentrations may exceed water quality numeric standards, so long as the discharge doesn’t 

interfere with designated uses of the receiving water body (for example, recreation, water 

supply, and aquatic life and wildlife habitat, etc.) The pollutant concentrations outside of the 

mixing zones must meet water quality numeric standards. 

State and federal rules allow mixing zones because the concentrations and effects of most 

pollutants diminish rapidly after discharge, due to dilution. Ecology defines mixing zone 

sizes to limit the amount of time any exposure to the end-of-pipe discharge could harm water 

quality, plants, or fish. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 20 of 62 

April 30, 2012 D. Nichols/ERO 

The State’s water quality standards allow Ecology to authorize mixing zones for the facility’s 

permitted wastewater discharges only if those discharges already receive all known, 

available, and reasonable methods of prevention, control, and treatment (AKART). Mixing 

zones typically require compliance with water quality criteria within a specified distance 

from the point of discharge and must not use more than 25% of the available width of the 

water body for dilution [WAC 173-201A-400 (7)(a)(ii-iii)]. 

Ecology uses modeling to estimate the amount of mixing within the mixing zone. Through 

modeling Ecology determines the potential for violating the water quality standards at the 

edge of the mixing zone and derives any necessary effluent limits. Steady-state models are 

the most frequently used tools for conducting mixing zone analyses. Ecology chooses values 

for each effluent and for receiving water variables that correspond to the time period when 

the most critical condition is likely to occur (see Ecology’s Permit Writer’s Manual). Each 

critical condition parameter, by itself, has a low probability of occurrence and the resulting 

dilution factor is conservative. The term “reasonable worst-case” applies to these values. 

The mixing zone analysis produces a numerical value called a dilution factor (DF). A 

dilution factor represents the amount of mixing of effluent and receiving water that occurs at 

the boundary of the mixing zone. For example, a dilution factor of 10 means the effluent is 

10% and the receiving water is 90% of the total volume of water at the boundary of the 

mixing zone. Ecology uses dilution factors with the water quality criteria to calculate 

reasonable potentials and effluent limits. Water quality standards include both aquatic 

life-based criteria and human health-based criteria. The former are applied at both the acute 

and chronic mixing zone boundaries; the latter are applied only at the chronic boundary. The 

concentration of pollutants at the boundaries of any of these mixing zones may not exceed 

the numerical criteria for that zone. 

Each aquatic life acute criterion is based on the assumption that organisms are not exposed to 

that concentration for more than one hour and more often than one exposure in three years. 

Each aquatic life chronic criterion is based on the assumption that organisms are not exposed 

to that concentration for more than four consecutive days and more often than once in three 

years. 

The two types of human health-based water quality criteria distinguish between those 

pollutants linked to non-cancer effects (non-carcinogenic) and those linked to cancer effects 

(carcinogenic). The human health-based water quality criteria incorporate several exposure 

and risk assumptions. These assumptions include: 

• A 70-year lifetime of daily exposures. 

• An ingestion rate for fish or shellfish measured in kg/day. 

• An ingestion rate of two liters/day for drinking water. 

• A one-in-one-million cancer risk for carcinogenic chemicals. 

This permit authorizes a small acute mixing zone, surrounded by a chronic mixing zone 

around the point of discharge (WAC 173-201A-400). The water quality standards impose 

certain conditions before allowing the discharger a mixing zone: 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 21 of 62 

April 30, 2012 D. Nichols/ERO 

1. Ecology must specify both the allowed size and location in a permit. 

The proposed permit specifies the size and location of the allowed mixing zone (as 

specified below). 

2. The facility must fully apply “all known, available, and reasonable methods of 

prevention, control and treatment” (AKART) to its discharge. 

Ecology has determined that the treatment provided by the City and EMC meets the 

requirements of AKART (see “Technology-based Limits”). 

3. Ecology must consider critical discharge conditions. 

Surface water quality-based limits are derived for the water body’s critical condition (the 

receiving water and waste discharge condition with the highest potential for adverse 

impact on the aquatic biota, human health, and existing or designated waterbody uses). 

The critical discharge condition is often pollutant-specific or waterbody-specific. 

Critical discharge conditions are those conditions that result in reduced dilution or 

increased effect of the pollutant. Factors affecting dilution include the depth of water, the 

density stratification in the water column, the currents, and the rate of discharge. Density 

stratification affects how far up in the water column a freshwater plume may rise. 

Density stratification is determined by the salinity and temperature of the receiving water. 

Temperatures are warmer in the surface waters in summer. Therefore, density 

stratification is generally greatest during the summer months. The rate of mixing is 

greatest when an effluent is rising. The effluent stops rising when the mixed effluent is 

the same density as the surrounding water. After the effluent stops rising, the rate of 

mixing is much more gradual. Water depth can affect dilution when a plume might rise 

to the surface when there is little or no stratification. Ecology’s Permit Writer’s Manual 

describes additional guidance on criteria/design conditions for determining dilution 

factors. The manual can be obtained from Ecology’s website at: 

http://www.ecy.wa.gov/biblio/92109.html. 

4. Supporting information must clearly indicate the mixing zone would not: 

• Have a reasonable potential to cause the loss of sensitive or important habitat. 

• Substantially interfere with the existing or characteristic uses. 

• Result in damage to the ecosystem. 

• Adversely affect public health. 

Ecology established Washington State water quality criteria for toxic chemicals using 

EPA criteria. EPA developed the criteria using toxicity tests with numerous organisms 

and set the criteria to generally protect the species tested and to fully protect all 

commercially and recreationally important species. 

EPA sets acute criteria for toxic chemicals assuming organisms are exposed to the 

pollutant at the criteria concentration for one hour. They set chronic standards assuming 

organisms are exposed to the pollutant at the criteria concentration for four days. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 22 of 62 

April 30, 2012 D. Nichols/ERO 

Dilution modeling under critical conditions generally shows that both acute and chronic 

criteria concentrations are reached within minutes of discharge. 

The discharge plume does not impact drifting and non-strong swimming organisms 

because they cannot stay in the plume close to the outfall long enough to be affected. 

Strong swimming fish could maintain a position within the plume, but they can also 

avoid the discharge by swimming away. Mixing zones generally do not affect benthic 

organisms (bottom dwellers) because the buoyant plume rises in the water column. 

Ecology has additionally determined that the effluent will not exceed 33 degrees C for 

more than two seconds after discharge; and that the temperature of the water will not 

create lethal conditions or blockages to fish migration. 

Ecology evaluates the cumulative toxicity of an effluent by testing the discharge with 

whole effluent toxicity (WET) testing. 

The results of WET testing submitted with the permit application showed no acute or 

chronic toxicity for samples collected in September/October 2010 and January 2011. 

Based on this information, Ecology concluded that the discharge does not have a 

reasonable potential to cause the loss of sensitive or important habitat, substantially 

interfere with existing or characteristic uses, result in damage to the ecosystem, or 

adversely affect public health if the permit limits are met. 

5. The size of the mixing zone and the concentrations of the pollutants must be 

minimized. 

At any given time, the effluent plume uses only a portion of the acute and chronic mixing 

zone, which minimizes the volume of water involved in mixing. The plume mixes as it 

rises through the water column therefore much of the receiving water volume at lower 

depths in the mixing zone is not mixed with discharge. Similarly, because the discharge 

may stop rising at some depth due to density stratification, waters above that depth will 

not mix with the discharge. Ecology determined it is impractical to specify in the permit 

the actual, much more limited volume in which the dilution occurs as the plume rises and 

moves with the current. 

Ecology minimizes the size of mixing zones by requiring dischargers to install diffusers 

when they are appropriate to the discharge and the specific receiving waterbody. When a 

diffuser is installed, the discharge is more completely mixed with the receiving water in a 

shorter time. Ecology also minimizes the size of the mixing zone (in the form of the 

dilution factor) using design criteria with a low probability of occurrence. For example, 

Ecology uses the expected 95th percentile pollutant concentration, the 90th percentile 

background concentration, the centerline dilution factor, and the lowest flow occurring 

once in every ten years to perform the reasonable potential analysis. 

Because of the above reasons, Ecology has effectively minimized the size of the mixing 

zone authorized in the proposed permit. 

6. Maximum size of mixing zone. 

The authorized mixing zone does not exceed the maximum size restriction. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 23 of 62 

April 30, 2012 D. Nichols/ERO 

7. Acute mixing zone. 

• The discharge/receiving water mixture must comply with acute criteria as near 

to the point of discharge as practicably attainable. 

Ecology determined the acute criteria will be met at 10% of the volume fraction of 

the chronic mixing zone. 

• The pollutant concentration, duration, and frequency of exposure to the 

discharge will not create a barrier to migration or translocation of indigenous 

organisms to a degree that has the potential to cause damage to the ecosystem. 

As described above, the toxicity of any pollutant depends upon the exposure, the 

pollutant concentration, and the time the organism is exposed to that concentration. 

Authorizing a limited acute mixing zone for this discharge assures that it will not 

create a barrier to migration. The effluent from this discharge will rise as it enters the 

receiving water, assuring that the rising effluent will not cause translocation of 

indigenous organisms near the point of discharge (below the rising effluent). 

• Comply with size restrictions. 

The mixing zone authorized for this discharge complies with the size restrictions 

published in chapter 173-201A WAC. 

8. Overlap of Mixing Zones. 

This mixing zone does not overlap another mixing zone. 

D. Designated uses and surface water quality criteria 

Applicable designated uses and surface water quality criteria are defined in chapter 

173-201A WAC. In addition, the U.S. EPA set human health criteria for toxic pollutants 

(EPA 1992). The table included below summarizes the criteria applicable to this facility’s 

discharge. 

Washington updated the surface water criteria in 2006 (WAC 173-201A) and are now based 

on aquatic life and recreational use. The receiving water wasteway drains are not specifically 

listed in the standards for designated uses, therefore they must be protected for: 

Table 7: Aquatic Life Uses and Associated Criteria

Salmonid Spawning, Rearing, and Migration 

Temperature Criteria – Highest 7-DAD MAX 17.5°C (63.5°F) 

Dissolved Oxygen Criteria – Lowest 1-Day 

Minimum 

8.0 mg/L 

Turbidity Criteria • 5 NTU over background when the background 

is 50 NTU or less; or 

• A 10 percent increase in turbidity when the 

background turbidity is more than 50 NTU. 

Total Dissolved Gas Criteria Total dissolved gas must not exceed 110 percent 

of saturation at any point of sample collection. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 24 of 62 

April 30, 2012 D. Nichols/ERO 

Salmonid Spawning, Rearing, and Migration 

pH Criteria The pH must measure within the range of 6.5 to 

8.5 with a human-caused variation within the 

above range of less than 0.5 units. 

• The recreational uses for this receiving water are identified below. 

Table 8: Recreational Uses and Associated Criteria

Recreational Use Criteria 

Primary Contact 

Recreation 

Fecal coliform organism levels must not exceed a geometric mean value of 100 

colonies /100 mL, with not more than 10 percent of all samples (or any single 

sample when less than ten sample points exist) obtained for calculating the 

geometric mean value exceeding 200 colonies /100 mL. 

• The water supply uses are domestic, agricultural, industrial, and stock watering. 

• The miscellaneous freshwater uses are wildlife habitat, harvesting, commerce and 

navigation, boating, and aesthetics. 

The current aquatic life and recreational use designations are somewhat equivalent to the Class A 

designation of surface water in the older version of the water quality standards. The TMDL was 

based on meeting the Class AA criteria. 

E. Water quality impairments 

Ecology reviewed the most current 303(d) list for impaired waters (2008 Water Quality 

Assessments) and found none of the wasteway drains that directly receive wastewater from the 

industrial facility are listed as impaired waters. 

However, the Frenchman Hills Wasteway and the Potholes Reservoir that are further 

downstream in the system are listed. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 25 of 62 

April 30, 2012 D. Nichols/ERO 

Figure 6: Frenchman Hills Wasteway and Potholes Reservoir 

Both waterbodies are listed as a category 5 which means the waters are impaired by a pollutant 

and needs a TMDL. The listed parameters for each are: 

Frenchman Hills Wasteway: temperature and pH 

Potholes Reservoir: dieldrin, 2,3,7,8-TCDD, 4-4’

-DDE, and PCB 

As seen in Figure 6, the travel distance from the discharge and the wasteway and reservoir is 

large and the influence of the discharge on these water bodies is most likely neglible. 

In October 1998, EPA approved a seasonal TMDL for the receiving water (DW237 and W645) 

for BOD, ammonia nitrogen, and fecal coliforms. Seasonal limits were determined in recognition 

that flows in the receiving water varies with the irrigation season. 

Ecology determined the TMDL values for BOD and ammonia (Pelletier, 1994) using the 

QUAL2E model developed by EPA. Calibration and verifications were done using data from a 

receiving water study (CH2M Hill, 1992). 

Quincy upgraded the SBR system in 2000 to meet the TMDL-based ammonia discharge limits, 

and upgraded in 2005 to meet the TMDL-based limits for dissolved oxygen, fecal coliforms, and 

temperature. 

Ecology based the TMDL and the water quality-based limits on now defunct receiving water 

Class AA (Extraordinary) criteria, which now equates to the following uses: water supply 

(domestic, industrial, agricultural); stock watering; fish migration; fish rearing, spawning and 

harvesting; wildlife habitat; primary contact recreation; sport fishing; boating and aesthetic 

enjoyment; commerce and navigation. Water quality of this class must markedly and uniformly 

exceed the requirements for all or substantially all uses. 

Quincy Industrial discharge Potholes Reservoir 

Frenchman Hills Wasteway 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 26 of 62 

April 30, 2012 D. Nichols/ERO 

F. Evaluation of surface water quality-based effluent limits for numeric criteria 

Pollutants in an effluent may affect the aquatic environment near the point of discharge 

(near-field) or at a considerable distance from the point of discharge (far-field). Toxic 

pollutants, for example, are near-field pollutants; their adverse effects diminish rapidly with 

mixing in the receiving water. Conversely, a pollutant such as biological oxygen demand 

(BOD) is a far-field pollutant whose adverse effect occurs away from the discharge even 

after dilution has occurred. Thus, the method of calculating surface water quality-based 

effluent limits varies with the point at which the pollutant has its maximum effect. 

With technology-based controls (AKART), predicted pollutant concentrations in the 

discharge exceed water quality criteria. Ecology therefore authorizes a mixing zone in 

accordance with the geometric configuration, flow restriction, and other restrictions imposed 

on mixing zones by chapter 173-201A WAC. 

A mixing zone is authorized for each season in accordance with the geometric configuration, 

flow restriction, and other restrictions for mixing zones in Chapter 173-201A WAC and is 

defined as follows: 

The mixing zone must not extend more than 300ft downstream from the effluent’s entry 

into drain DW237; 25% of the stream flow shall be allowed to meet chronic criteria and 

2.5% of the flow shall be allowed to meet acute criteria. 

Ecology determined the seasonal dilution factors for the receiving water (Pelletier, 1994) 

based on chemical and flow data measured during a receiving water study (CH2M Hill, 

1992). 

Table 9: Seasonal Dilution Factors 

 Acute Chronic 

Aquatic Life 

 Ammonia (summer) 1.1 2.1 

 Ammonia (winter) 1.0 1.1 

Ecology summarized the effluent maximum and minimum pH values (Jan 07 – Sept 11) and 

compared the values to the water-quality based discharge limits; Appendix F, Fig 1 and 2. 

With few exceptions, the effluent complied with the pH limits for the summer and winter 

season. 

Dissolved Oxygen--BOD5 and Ammonia Effects--Natural decomposition of organic 

material in wastewater effluent impacts dissolved oxygen in the receiving water at distances 

far outside of the regulated mixing zone. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 27 of 62 

April 30, 2012 D. Nichols/ERO 

 The 5-day Biochemical Oxygen Demand (BOD5) of an effluent sample indicates the amount 

of biodegradable material in the wastewater and estimates the magnitude of oxygen 

consumption the wastewater will generate in the receiving water. The amount of ammoniabased nitrogen in the wastewater also provides an indication of oxygen demand in the 

receiving water.

Ecology modeled the impact of BOD5 and ammonia on the receiving water using critical 

condition s; Pelletier, 1994. 

TMDL BOD: 

Ecology determined values to protect the receiving water for a dissolved oxygen 

concentration of 8 mg/L. At the time of the modeling, Ecology determined that this dissolved 

oxygen concentration would protect the beneficial uses of the receiving stream. Load values 

were based on an effluent flow of 4 MGD. 

Table 10: TMDL BOD Loading 

Monthly Average Daily Maximum

Winter (Nov-March) 65 mg/L; 2168 lbs/day 130 mg/L; 4337 mg/L 

Summer (Apr-Oct) 51.1 mg/L; 1705 lbs/day 95.2 mg/L; 3176 lbs/day 

TMDL Ammonia: 

The ammonia values originally determined by Pelletier were updated by Ecology during 

the preparation of the 1996 discharge permit to reflect new EPA criteria. The updated 

values were made part of the TMDL. 

Table 11: TMDL Ammonia Loading 

Monthly Average Daily Maximum

Winter (Nov-March) 1.45 mg/L; 48.2 lbs/day 2.90 mg/L; 96.7 mg/L 

Summer (Apr-Oct) 1.19 mg/L; 39.8 lbs/day 2.39 mg/L; 79.8 lbs/day 

The proposed permit includes the current discharge limits for BOD and ammonia that 

Ecology based on the TMDL values. 

pH - Compliance with the technology-based limits of 6.0 to 9.0 will assure compliance with 

the water quality standards of surface waters because of the high buffering capacity of marine 

water. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 28 of 62 

April 30, 2012 D. Nichols/ERO 

Fecal Coliform - Under critical conditions, modeling predicted no violation of the water 

quality criterion for fecal coliform; Pelletier, 1994. Therefore, the proposed permit retains the 

current daily maximum limit of 50/100 mL, which Ecology based on Class AA receiving 

water standards in the older version of the surface water quality standards. 

Toxic Pollutants - Federal regulations (40 CFR 122.44) require Ecology to place limits in 

NPDES permits on toxic chemicals in an effluent whenever there is a reasonable potential for 

those chemicals to exceed the surface water quality criteria. Ecology does not exempt 

facilities with technology-based effluent limits from meeting the surface water quality 

standards. 

With the exception of ammonia and chlorine, Ecology has no information to show or suggest 

the presence of toxic pollutants in the effluent. 

The 2005 upgrade included the construction of a chlorine disinfection basin and an injection 

system to add sodium bisulfite in the cooling tower effluent for de-chlorination to meet water 

quality-based criteria: acute = 19 ug/L; chronic = 11 ug/L. The proposed permit retains these 

limits. 

Temperature - The current state temperature standards (WAC 173-201A-200-210 and 600-

612) include multiple elements: 

• Annual summer maximum threshold criteria (June 15 to September 15) 

• Supplemental spawning and rearing season criteria (September 15 to June 15) 

• Incremental warming restrictions 

• Protections against acute effects 

Ecology evaluates each criterion independently to determine reasonable potential and derive 

permit limits. 

• Annual summer maximum and supplementary spawning/rearing criteria 

Each water body has an annual maximum temperature criterion [WAC 173-201A200(1)(c), 210(1)(c), and Table 602]. These threshold criteria (e.g., 12, 16, 17.5, 20°C) 

protect specific categories of aquatic life by controlling the effect of human actions on 

summer temperatures. 

Some waters have an additional threshold criterion to protect the spawning and 

incubation of salmonids (9°C for char and 13°C for salmon and trout) [WAC 173-201A602, Table 602]. These criteria apply during specific date-windows. 

The threshold criteria apply at the edge of the chronic mixing zone. Criteria for most 

fresh waters are expressed as the highest 7-Day average of daily maximum temperature 

(7-DADMax). The 7-DADMax temperature is the arithmetic average of seven 

consecutive measures of daily maximum temperatures. Criteria for marine waters and 

some fresh waters are expressed as the highest 1-Day annual maximum temperature (1-

DMax). 

• Incremental warming criteria 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 29 of 62 

April 30, 2012 D. Nichols/ERO 

The water quality standards limit the amount of warming human sources can cause under 

specific situations [WAC 173-201A-200(1)(c)(i)-(ii), 210(1)(c)(i)-(ii)]. The incremental 

warming criteria apply at the edge of the chronic mixing zone. 

At locations and times when background temperatures are cooler than the assigned 

threshold criterion, point sources are permitted to warm the water by only a defined 

increment. These increments are permitted only to the extent doing so does not cause 

temperatures to exceed either the annual maximum or supplemental spawning criteria. 

At locations and times when a threshold criterion is being exceeded due to natural 

conditions, all human sources, considered cumulatively, must not warm the water more 

than 0.3°C above the naturally warm condition. 

When Ecology has not yet completed a TMDL, our policy allows each point source to 

warm water at the edge of the chronic mixing zone by 0.3°C. This is true regardless of 

the background temperature and even if doing so would cause the temperature at the edge 

of a standard mixing zone to exceed the numeric threshold criteria. Allowing a 0.3°C 

warming for each point source is reasonable and protective where the dilution factor is 

based on 25% or less of the critical flow. This is because the fully mixed effect on 

temperature will only be a fraction of the 0.3°C cumulative allowance (0.075°C or less) 

for all human sources combined. 

• Protections for temperature acute effects 

Instantaneous lethality to passing fish: The upper 99th percentile daily maximum effluent 

temperature must not exceed 33°C, unless a dilution analysis indicates ambient 

temperatures will not exceed 33°C two seconds after discharge. 

General lethality and migration blockage: Measurable (0.3°C) increases in temperature at 

the edge of a chronic mixing zone are not allowed when the receiving water temperature 

exceeds either a 1DMax of 23°C or a 7DADMax of 22°C. 

Lethality to incubating fish: Human actions must not cause a measurable (0.3°C) 

warming above 17.5°C at locations where eggs are incubating. 

The 2005 upgrade of the treatment facility included the construction of a cooling tower to 

reduce the temperature of the effluent during the summer months. Ecology determined a 

reasonable potential to exceed the water quality criteria for a Class AA waterbody during the 

development of the 2001 discharge permit. Ecology used effluent data for 1997-2000 to 

conduct reasonable potential. The design of the cooling tower was based on meeting an 

effluent temperature of 22.5°C during the summer. Ecology determined this temperature 

limit based on meeting the Class AA water quality at the mixing zone boundary. The 

proposed permit retains this limit. 

Wasteway TMDL 

EPA approved the TMDL to irrigation drain DW237 and W645W on October 7, 1998 for 

BOD, ammonia-nitrogen, and fecal coliforms. Ecology based the 1998 TMDL, in part, on 

surface water standards that it changed in 2006. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 30 of 62 

April 30, 2012 D. Nichols/ERO 

The current water quality standards require that any surface water that does not have defined 

designated uses, such as DW237 and W645W, must be protected for, “Salmonid spawning 

rearing, and migration; primary contact recreation; domestic, industrial, and agricultural 

water supply; stock watering; wildlife habitat; harvesting; commerce and navigation; boating; 

and aesthetic values” . In addition, because the wasteways ultimately discharge to the 

Potholes Reservoir, the permit must also protect “core summer salmonid habitat; and 

extraordinary primary contact recreation” because the reservoir has a detention time greater 

than 15 days; (WAC 173-201A-600). 

The agreement between the City and the Bureau that allows the treated wastewater from the 

industrial treatment system to discharge into the wasteway system expires in September 

2015. Ecology has decided not to update the current TMDL, but to instead extend the TMDL 

and water quality-based discharge limits, and require the City to submit to Ecology a plan to 

remove the industrial wastewater from the wasteways by 2015. 

G. Human health 

Washington’s water quality standards include 91 numeric human health-based criteria that 

Ecology must consider when writing NPDES permits. These criteria were established in 

1992 by the U.S. EPA in its National Toxics Rule (40 CFR 131.36). The National Toxics 

Rule allows states to use mixing zones to evaluate whether discharges comply with human 

health criteria. 

Ecology determined the applicant's discharge (1) is unlikely to contain chemicals regulated to 

protect human health, and (2) does not contain chemicals of concern based on existing 

effluent data or knowledge of discharges to their system. Ecology will reevaluate this 

discharge for impacts to human health at the next permit reissuance. 

H. Whole effluent toxicity 

The water quality standards for surface waters forbid discharge of effluent that has the 

potential to cause toxic effects in the receiving waters. Many toxic pollutants cannot be 

measured by commonly available detection methods. However, laboratory tests can measure 

toxicity directly by exposing living organisms to the wastewater and measuring their 

responses. These tests measure the aggregate toxicity of the whole effluent, so this approach 

is called whole effluent toxicity (WET) testing. Some WET tests measure acute toxicity and 

other WET tests measure chronic toxicity. 

Test results submitted by the City/EMC for the most recent WET sampling events 

(April/May 2008, September/October 2010, and January 2011) showed no acute or chronic 

toxicity at 100% effluent. Based on these results, Ecology determined that toxic effects 

caused by unidentified pollutants in the effluent are unlikely. Therefore, this permit does not 

require WET testing is allowed by WAC 173-205-030 (5)(b). 

I. Brine Water Discharge 

Ecology recently modified the permit (October 2011) to allow the discharge of reverse 

osmosis (RO) and ion exchange brine reject water to one of two double lined evaporation 

ponds built near the disinfection/cooling/re-aeration site (Figure 2). 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 31 of 62 

April 30, 2012 D. Nichols/ERO 

Both ponds were designed to be non-discharging. The proposed permit continues to authorize 

the discharge of RO/ion exchange brine reject water. 

J. Comparison of effluent limits with the previous permit issued on October 13, 

2006 

Table 12: Comparison of Previous and Proposed Effluent Limits - Summer Season (April - 

October) 

Previous Effluent Limits: 

Outfall # 001 

Proposed Effluent Limits: 

Outfall # 001 

Parameter Basis of 

Limit 

Average 

Monthly 

Maximum 

Daily 

Average 

Monthly 

Maximum 

Daily 

Flow Design 4.89 MGD 3.23 MGD 4.89 MGD 3.23 MGD 

Biochemical Oxygen 

Demand (5-day) TMDL 

51.1 mg/L; 

1705 

lbs/day 

95.2 mg/L; 

3176 

lbs/day 

Same Same 

Total Suspended 

Solids 

Performance 

based 

109 mg/L; 

3636 

lbs/day 

218 mg/L; 

7272 

lbs/day 

64 mg/L; 

1724 

lbs/day 

114 mg/L; 

3071 lbs/day 

Total Ammonia 

Nitrogen TMDL 1.19 mg/L; 39.8 lbs/day 

2.39 mg/L; 

79.8 lbs/day Same Same 

Dissolved Oxygen TMDL Shall be not less than 8.0 

mg/L or saturation a 

Same 

Temperature TMDL ****** 22.5°C ******* Same 

Residual Chlorine Water qualitybased 8 ug/L 20 ug/L Same Same 

Parameter Basis of 

Limit

Monthly 

Geometric 

Mean 

Limit

Maximum 

Daily

Monthly 

Geometric 

Mean 

Limit

Maximum 

Daily

Fecal Coliform 

Bacteria TMDL ******* 50/ 100 mL ****** Same 

 

Parameter Basis of 

Limit

Daily 

Minimum 

Daily 

Maximum 

Daily 

Minimum 

Daily 

Maximum 

pH Technology 6.0 9.0 Same Same 

(NOTE: See Appendix E, Response to Comments, Comment #1 from the Bureau of 

Reclamation for changes to this table) 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 32 of 62 

April 30, 2012 D. Nichols/ERO 

Table 13: Comparison of Previous and Proposed Effluent Limits - Winter Season (November - 

March) 

Previous Effluent Limits: 

Outfall # 001 

Proposed Effluent Limits: 

Outfall # 001 

Parameter Basis of 

Limit 

Average 

Monthly 

Maximum 

Daily 

Average 

Monthly 

Maximum 

Daily 

Flow Design 4.89 MGD 3.23 MGD 4.89 MGD 3.23 MGD 

Biochemical Oxygen 

Demand (5-day) TMDL 

65 mg/L; 

2168 

lbs/day 

130 mg/L; 

4337 

lbs/day 

Same Same 

Total Suspended 

Solids 

Performance 

based 

59 mg/L; 

3636 

lbs/day 

118 mg/L; 

3936 

lbs/day 

Same Same 

Total Ammonia 

Nitrogen TMDL 1.45 mg/L; 48.2 lbs/day 

2.90 mg/L; 

96.7 lbs/day Same Same 

Dissolved Oxygen TMDL Shall be not less than 8.0 

mg/L or saturation a

 

Same 

Temperature TMDL ****** ****** Same Same 

Residual Chlorine Water qualitybased 8 ug/L 20 ug/L Same Same 

Parameter Basis of 

Limit

Monthly 

Geometric 

Mean 

Limit

Maximum 

Daily

Monthly 

Geometric 

Mean 

Limit

Maximum 

Daily

Fecal Coliform 

Bacteria TMDL ******* 50/ 100 mL ****** Same 

 

Parameter Basis of 

Limit

Daily 

Minimum 

Daily 

Maximum 

Daily 

Minimum 

Daily 

Maximum 

pH Technology 6.0 9.0 Same Same 

(NOTE: See Appendix E, Response to Comments, Comment #1 from the Bureau of 

Reclamation for changes to this table) 

Bureau of Reclamation Contract 

The City of Quincy entered into a 50-year agreement with the Bureau of Reclamation on 

September 21, 1965 that authorized the city to discharge treated wastewater from its industrial 

wastewater treatment facility to the bureau’s wasteway system. The Bureau has informed the city 

the agreement will not be extended when it expires in 2015. 

One of the conditions of the agreement is the BOD concentration of the discharge shall not 

exceed 15 mg/l. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 33 of 62 

April 30, 2012 D. Nichols/ERO 

The BOD limits in the proposed permit are based on meeting the EPA approved TMDL 

requirements for dissolved oxygen and exceed the limit required in the Bureau/city agreement. 

Ecology will reissue the permit based on its approval of the City’s treatment facility providing 

AKART (all known available and reasonable methods of treatment) as required by RCW 90.48. 

That AKART is protective of water quality and the permit’s effluent limits are based on the EPA 

approved TMDL for the wasteway. The permit does not authorize the City of Quincy to violate 

any terms or conditions of any contract agreement. Reference to the City’s responsibilities to 

comply with other laws and statutes is also given in General Condition G6 of the permit. 

A second condition of the agreement is the limitation of flow to 3.23 MGD. The maximum daily 

flow limit in Section S1 (3.23 MGD) is based on the agreement and the average monthly flow 

limit (4.89 MGD) is based on the design of the industrial wastewater facility. The industrial 

wastewater facility has been upgraded (flow equalization basin) not to exceed the 3.23 MGD 

limit. In recognition of the difference in the basis for the two flow values, Section S1 will show 

the 3.23 MGD limit and Section S7 (Facility Loading) will show the design value of 4.89 MGD. 

(Note: Please see Response to Comments section, Comment #1 from the Bureau of 

Reclamation for the addition of this language to the fact sheet.) 

IV. Monitoring Requirements 

Ecology requires monitoring, recording, and reporting (WAC 173-220-210 and 40 CFR 122.41) 

to verify that the treatment process is functioning correctly and that the discharge complies with 

the permit’s effluent limits. 

The monitoring schedule is detailed in the proposed permit under Special Condition S.2. 

Specified monitoring frequencies take into account the quantity and variability of the discharge, 

the treatment method, past compliance, significance of pollutants, and cost of monitoring. 

A. Lab accreditation 

Ecology requires that facilities must use a laboratory registered or accredited under the 

provisions of chapter 173-50 WAC, Accreditation of Environmental Laboratories, to prepare 

all monitoring data (with the exception of certain parameters). Ecology accredited the 

laboratory at this facility for: ammonia-N, BOD, COD, nitrate, nitrite, pH, total residual 

chlorine, TSS, fecal and total coliforms. 

B. Effluent limits which are near detection or quantitation levels 

The water quality-based effluent concentration limits for total residual chlorine are near the 

limits of current analytical methods to detect or accurately quantify. The method detection 

level (MDL) is the minimum concentration of a pollutant that a laboratory can measure and 

report with a 99 percent confidence that its concentration is greater than zero (as determined 

by a specific laboratory method). The quantitation level is the level at which a laboratory can 

reliably report concentrations with a specified level of error. Estimated concentrations are 

the values between the MDL and the QL. Ecology requires permitted facilities to report 

estimated concentrations. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 34 of 62 

April 30, 2012 D. Nichols/ERO 

When reporting maximum daily effluent concentrations, Ecology requires the facility to 

report “less than X” where X is the required detection level if the measured effluent 

concentration falls below the detection level. When calculating average monthly 

concentrations, the facility must use all the effluent concentrations measured below the 

quantitation level but above the method detection level. 

V. Other Permit Conditions 

A. Reporting and record keeping 

Ecology based Special Condition S3 on its authority to specify any appropriate reporting and 

record keeping requirements to prevent and control waste discharges (WAC 173-220-210). 

(NOTE: Please see ‘Response to Comments’ section, Comment 7 for changes made to the 

language in permit Section S3 for reporting and record keeping) 

B. Spill plan 

This facility stores sodium hypochlorite (12.5%) and sodium bisulfite (38%) in above ground 

tanks at the disinfection/cooling/reaeration site; Figure 3. Both tanks are surrounded by 

containment structures. The facility has not identified any other chemicals or materials 

stored on site that have the potential to cause water pollution if accidentally released. 

Ecology can require a facility to develop best management plans to prevent this accidental 

release [Section 402(a)(1) of the Federal Water Pollution Control Act (FWPCA) and RCW 

90.48.080]. 

The proposed permit does not require the submittal of a spill plan. 

C. Solid waste control plan 

When Quincy begins operation of the anaerobic digester in late 2011, it will discontinue use 

of the primary treatment facility (clarifiers and sludge vacuum filter). Thereafter, the facility 

will generate solid wastes from the digester and SBR’s. The proposed permit requires an 

update to the O&M manual that includes the new digester and a solid waste plan for the 

solids from the SBRs and the digester. The facility will update the O&M manual in lieu of 

preparing a solid waste plan. 

D. Operation and maintenance manual 

Ecology requires industries to take all reasonable steps to properly operate and maintain their 

wastewater treatment system in accordance with state and federal regulations [40 CFR 

122.41(e) and WAC 173-220-150 (1)(g)]. The facility has prepared and submitted an 

operation and maintenance manual (City of Quincy, 2005) as required by state regulation for 

the construction of wastewater treatment facilities (WAC 173-240-150). It has submitted 

updates to Ecology in 2007 and 2009. Implementation of the procedures in the operation and 

maintenance manual ensures the facility’s compliance with the terms and limits in the permit. 

The proposed permit will require the manual to be updated to include: 

1. The O&M of the anaerobic digester including the management of solid wastes. 

2. Management of solid wastes from the SBRs. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 35 of 62 

April 30, 2012 D. Nichols/ERO 

3. Any specific handling requirements of the brine water and disposal requirements 

brine residue after evaporation. 

E. Leak Detection 

SBRs

EMC submitted the most recent leak detection plan for the SBRs in 2010 in a one page 

document that includes the complete draining of each basin, a visual inspection followed by 

an electronic leak detection survey. The facility has not completed the first inspection/survey 

scheduled for February/March 2011. 

Ecology understands the difficulty in taking the SBRs off line for an extended period of time 

because the survey must coincide with reduced flows from the two processors. The proposed 

permit requires the City/EMC to provide Ecology with a schedule for completion of the first 

inspection/survey to be conducted in 2012. 

Anaerobic Digester

EMC submitted a leak detection plan (2011) for the digester (a/k/a biogas facility) based on a 

comparison of the known inputs versus the known outputs; i.e., water balance. It plans to 

conduct the test over a five day period when it can isolate the digester from the waste stream. 

Any volume lost and not accounted for by moisture in the biogas is due to leakage. EMC 

defined a significant loss as greater than 0.25 inches over the five days, or 5000 gallons per 

day. The plan identifies a list of actions to complete if/when this occurs. 

An experienced vendor installed the single 60-mil liner and completed an electronic leak 

survey following installation. The structure includes a 100-mil HDPE cover and it has no 

mechanical moving parts. Based on this Ecology will require a leak test of the digester during 

the fourth year of the permit; 2015. 

F. Plan for Stopping the Discharge to U.S. Bureau of Reclamation Wasteway 

DW237, W645W, and W645 

As described previously, the City/EMC must terminate the discharge of treated process 

wastewater from the industrial treatment facility to wasteway DW237, W645W, and W645 

by September 2015. The proposed permit requires the City/EMC to submit a plan to Ecology 

describing what steps it will be take and an associated timeline to remove the outfall from the 

wasteways. (NOTE: Please see Response to Comments section, Comment #6 for changes) 

G. Application for Permit Renewal 

The proposed permit continues to allow the discharge of treated and disinfected wastewater 

to the U.S. Bureau of Reclamation wasteway until October 1, 2015. The City/EMC must 

submit an application for the discharge of the wastewater after October 2015. 

To allow Ecology sufficient time to reissue the permit, the permit requires the submittal of an 

application six months before the expiration of the permit; March 2015. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 36 of 62 

April 30, 2012 D. Nichols/ERO 

H. Engineering Report – Update 

The termination of the discharge of process wastewater to the bureau’s wasteway in 2015 

will most likely require changes to the infra-structure of the treatment system. The proposed 

permit requires the City/EMC to submit an updated engineering report no later than one year 

before the termination of discharge to the bureau’s wasteway; September 2014. Ecology will 

use this information to prepare a new discharge permit. 

Plans and Specifications 

The City and EMC will be required to submit for review and approval plans and 

specifications for the removal of the industrial wastewater discharge to the bureau’s 

wasteway. 

I. General conditions 

Ecology bases the standardized General Conditions on state and federal law and regulations. 

They are included in all individual industrial NPDES permits issued by Ecology. 

VI. Permit Issuance Procedures 

A. Permit modifications 

Ecology may modify this permit to impose numerical limits, if necessary to comply with 

water quality standards for surface waters, with sediment quality standards, or with water 

quality standards for ground waters, after obtaining new information from sources such as 

inspections, effluent monitoring, outfall studies, and effluent mixing studies. 

Ecology may also modify this permit to comply with new or amended state or federal 

regulations. 

B. Proposed permit Issuance 

This proposed permit includes all statutory requirements for Ecology to authorize a 

wastewater discharge. The permit includes limits and conditions to protect human health and 

aquatic life, and the beneficial uses of waters of the State of Washington. Ecology proposes 

to issue this permit for a term of five (5) years. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 37 of 62 

April 30, 2012 D. Nichols/ERO 

VII. REFERENCES FOR TEXT AND APPENDICES 

CH2M Hill. 

1992. Receiving Water and Effluent Mixing Study. October 

City of Quincy. 

2005. City of Quincy Industrial Secondary Wastewater Treatment Facility 2005 Process 

Upgrades Operations & Maintenance Manual, Final. December 

Earth Tech. 

2005. Amendment to Engineering, 2005 Process Upgrades, Quincy, Washington 

Industrial Wastewater Treatment Facility. February. 

2000. Amendment to City of Quincy Industrial Wastewater Treatment Facility 

Engineering Report / Facility Plan Water Quality Based Effluent Limitations. October. 

Environmental Management Corporation. 

2011. Quincy Industrial Facility – Revised Lagoon #2 Liner Leak Detection Plan 

Submittal. July 

2010. SBR Leak Detection Plan. Email from Travis Kirk, EMC, Quincy. March 

Environmental Protection Agency (EPA) 

1992. National Toxics Rule. Federal Register, V. 57, No. 246, Tuesday, December 22, 

1992. 

1991. Technical Support Document for Water Quality-based Toxics Control. EPA/505/2-

90-001. 

Montgomery Watson. 

1997. City of Quincy Industrial Wastewater Treatment Facility Engineering Report, 

Facilities Plan, Water Quality-Based Effluent Limitations Compliance, October. 

Pelletier, Greg. 

1994. BOD Loading from Quincy Industrial Wastewater Treatment System. January. 

Washington State Department of Ecology. 

November 2010. Permit Writer’s Manual. Publication Number 92-109 

(http://www.ecy.wa.gov/biblio/92109.html) 

Laws and Regulations 

( http://www.ecy.wa.gov/laws-rules/index.html) 

Permit and Wastewater Related Information 

(http://www.ecy.wa.gov/programs/wq/wastewater/index.html) 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 38 of 62 

April 30, 2012 D. Nichols/ERO 

Appendix A - Public Involvement Information 

Ecology proposes to reissue the permit to the City of Quincy and EMC. The permit includes 

wastewater discharge limits and other conditions. This fact sheet describes the facility and 

Ecology’s reasons for requiring permit conditions. 

Ecology placed a Public Notice of Application on September 28 and October 5, 2011 in the 

Columbia Basin Herald to inform the public about the submitted application and to invite 

comment on the reissuance of this permit. 

Ecology will place a Public Notice of Draft Permit on January 6, 2012 in the Columbia Basin 

Herald to inform the public and to invite comment on the proposed draft National Pollutant 

Discharge Elimination System permit and fact sheet.

The notice: 

• Tells where copies of the draft Permit and Fact Sheet are available for public evaluation (a 

local public library, the closest Regional or Field Office, posted on our website). 

• Offers to provide the documents in an alternate format to accommodate special needs. 

• Urges people to submit their comments, in writing, before the end of the Comment Period 

• Tells how to request a public hearing of comments about the proposed NPDES permit. 

• Explains the next step(s) in the permitting process. 

Ecology has published a document entitled Frequently Asked Questions about Effective Public 

Commenting which is available on our website at http://www.ecy.wa.gov/biblio/0307023.html. 

You may obtain further information from Ecology by telephone at (509) 329-3524 or by writing 

to the address listed below. 

Water Quality Permit Coordinator 

Department of Ecology 

Eastern Regional Office 

4601 North Monroe Street 

Spokane, WA 99205-1295

The primary author of this permit and fact sheet is Don Nichols. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 39 of 62 

April 30, 2012 D. Nichols/ERO 

Appendix B - Your Right to Appeal 

You have a right to appeal this permit to the Pollution Control Hearing Board (PCHB) within 30 

days of the date of receipt of the final permit. The appeal process is governed by chapter 43.21B 

RCW and chapter 371-08 WAC. “Date of receipt” is defined in RCW 43.21B.001(2) (see 

glossary). 

To appeal you must do the following within 30 days of the date of receipt of this permit: 

File your appeal and a copy of this permit with the PCHB (see addresses below). Filing means 

actual receipt by the PCHB during regular business hours. 

Serve a copy of your appeal and this permit on Ecology in paper form - by mail or in person. 

(See addresses below.) E-mail is not accepted. 

You must also comply with other applicable requirements in chapter 43.21B RCW and chapter 

371-08 WAC. 

ADDRESS AND LOCATION INFORMATION 

Street Addresses Mailing Addresses

Department of Ecology 

Attn: Appeals Processing Desk 

300 Desmond Drive SE 

Lacey, WA 98503 

Department of Ecology 

Attn: Appeals Processing Desk 

PO Box 47608 

Olympia, WA 98504-7608 

Pollution Control Hearings Board 

1111 Israel RD SW 

STE 301 

Tumwater, WA 98501 

Pollution Control Hearings Board 

PO Box 40903 

Olympia, WA 98504-0903 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 40 of 62 

April 30, 2012 D. Nichols/ERO 

Appendix C - Glossary 

1-DMax or 1-day maximum temperature -- The highest water temperature reached on any 

given day. This measure can be obtained using calibrated maximum/minimum thermometers 

or continuous monitoring probes having sampling intervals of thirty minutes or less. 

7-DADMax or 7-day average of the daily maximum temperatures -- The arithmetic average 

of seven consecutive measures of daily maximum temperatures. The 7-DADMax for any 

individual day is calculated by averaging that day's daily maximum temperature with the 

daily maximum temperatures of the three days prior and the three days after that date. 

Acute toxicity --The lethal effect of a compound on an organism that occurs in a short time 

period, usually 48 to 96 hours. 

AKART -- The acronym for “all known, available, and reasonable methods of prevention, 

control and treatment.” AKART is a technology-based approach to limiting pollutants from 

wastewater discharges, which requires an engineering judgment and an economic judgment. 

AKART must be applied to all wastes and contaminants prior to entry into waters of the state 

in accordance with RCW 90.48.010 and 520, WAC 173-200-030(2)(c)(ii), and WAC 173-

216-110(1)(a). 

Ambient water quality -- The existing environmental condition of the water in a receiving 

water body. 

Ammonia -- Ammonia is produced by the breakdown of nitrogenous materials in wastewater. 

Ammonia is toxic to aquatic organisms, exerts an oxygen demand, and contributes to 

eutrophication. It also increases the amount of chlorine needed to disinfect wastewater. 

Annual average design flow (AADF -- average of the daily flow volumes anticipated to occur 

over a calendar year. 

Average monthly discharge limit -- The average of the measured values obtained over a 

calendar month's time. 

Best management practices (BMPs) -- Schedules of activities, prohibitions of practices, 

maintenance procedures, and other physical, structural and/or managerial practices to prevent 

or reduce the pollution of waters of the state. BMPs include treatment systems, operating 

procedures, and practices to control: plant site runoff, spillage or leaks, sludge or waste 

disposal, or drainage from raw material storage. BMPs may be further categorized as 

operational, source control, erosion and sediment control, and treatment BMPs. 

BOD5 -- Determining the five-day Biochemical Oxygen Demand of an effluent is an indirect 

way of measuring the quantity of organic material present in an effluent that is utilized by 

bacteria. The BOD5 is used in modeling to measure the reduction of dissolved oxygen in 

receiving waters after effluent is discharged. Stress caused by reduced dissolved oxygen 

levels makes organisms less competitive and less able to sustain their species in the aquatic 

environment. Although BOD5 is not a specific compound, it is defined as a conventional 

pollutant under the federal Clean Water Act. 

Bypass -- The intentional diversion of waste streams from any portion of a treatment facility. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 41 of 62 

April 30, 2012 D. Nichols/ERO 

Chlorine -- A chemical used to disinfect wastewaters of pathogens harmful to human health. It is 

also extremely toxic to aquatic life. 

Chronic toxicity -- The effect of a compound on an organism over a relatively long time, often 

1/10 of an organism's lifespan or more. Chronic toxicity can measure survival, reproduction 

or growth rates, or other parameters to measure the toxic effects of a compound or 

combination of compounds. 

Clean water act (CWA) -- The federal Water Pollution Control Act enacted by Public Law 

92-500, as amended by Public Laws 95-217, 95-576, 96-483, 97-117; USC 1251 et seq. 

Composite sample -- A mixture of grab samples collected at the same sampling point at 

different times, formed either by continuous sampling or by mixing discrete samples. May 

be "time-composite" (collected at constant time intervals) or "flow-proportional" (collected 

either as a constant sample volume at time intervals proportional to stream flow, or collected 

by increasing the volume of each aliquot as the flow increased while maintaining a constant 

time interval between the aliquots). 

Continuous monitoring -- Uninterrupted, unless otherwise noted in the permit. 

Critical condition -- The time during which the combination of receiving water and waste 

discharge conditions have the highest potential for causing toxicity in the receiving water 

environment. This situation usually occurs when the flow within a water body is low, thus, 

its ability to dilute effluent is reduced. 

Date of receipt – This is defined in RCW 43.21B.001(2) as five business days after the date of 

mailing; or the date of actual receipt, when the actual receipt date can be proven by a 

preponderance of the evidence. The recipient's sworn affidavit or declaration indicating the 

date of receipt, which is unchallenged by the agency, constitutes sufficient evidence of actual 

receipt. The date of actual receipt, however, may not exceed forty-five days from the date of 

mailing. 

Detection limit -- See Method Detection Level. 

Dilution factor (DF) -- A measure of the amount of mixing of effluent and receiving water that 

occurs at the boundary of the mixing zone. Expressed as the inverse of the percent effluent 

fraction, for example, a dilution factor of 10 means the effluent comprises 10% by volume 

and the receiving water 90%. 

Engineering report -- A document that thoroughly examines the engineering and administrative 

aspects of a particular domestic or industrial wastewater facility. The report must contain the 

appropriate information required in WAC 173-240-060 or 173-240-130. 

Fecal coliform bacteria -- Fecal coliform bacteria are used as indicators of pathogenic bacteria 

in the effluent that are harmful to humans. Pathogenic bacteria in wastewater discharges are 

controlled by disinfecting the wastewater. The presence of high numbers of fecal coliform 

bacteria in a water body can indicate the recent release of untreated wastewater and/or the 

presence of animal feces. 

Grab sample -- A single sample or measurement taken at a specific time or over as short a 

period of time as is feasible. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 42 of 62 

April 30, 2012 D. Nichols/ERO 

Industrial user -- A discharger of wastewater to the sanitary sewer that is not sanitary 

wastewater or is not equivalent to sanitary wastewater in character. 

Industrial wastewater -- Water or liquid-carried waste from industrial or commercial processes, 

as distinct from domestic wastewater. These wastes may result from any process or activity 

of industry, manufacture, trade or business; from the development of any natural resource; or 

from animal operations such as feed lots, poultry houses, or dairies. The term includes 

contaminated storm water and, also, leachate from solid waste facilities. 

Maximum daily discharge limit -- The highest allowable daily discharge of a pollutant 

measured during a calendar day or any 24-hour period that reasonably represents the calendar 

day for purposes of sampling. The daily discharge is calculated as the average measurement 

of the pollutant over the day. 

Maximum day design flow (MDDF) -- The largest volume of flow anticipated to occur during a 

one-day period, expressed as a daily average. 

Maximum month design flow (MMDF) -- The largest volume of flow anticipated to occur

during a continuous 30-day period, expressed as a daily average. 

Maximum week design flow (MWDF) -- The largest volume of flow anticipated to occur 

during a continuous 7-day period, expressed as a daily average. 

Method detection level (MDL) -- The minimum concentration of a substance that can be 

measured and reported with 99 percent confidence that the pollutant concentration is above 

zero and is determined from analysis of a sample in a given matrix containing the pollutant. 

Mixing zone -- An area that surrounds an effluent discharge within which water quality criteria 

may be exceeded. The permit specifies the area of the authorized mixing zone that Ecology 

defines following procedures outlined in state regulations (chapter 173-201A WAC). 

National pollutant discharge elimination system (NPDES) -- The NPDES (Section 402 of the 

Clean Water Act) is the federal wastewater permitting system for discharges to navigable 

waters of the United States. Many states, including the state of Washington, have been 

delegated the authority to issue these permits. NPDES permits issued by Washington State 

permit writers are joint NPDES/State permits issued under both state and federal laws. 

 pH -- The pH of a liquid measures its acidity or alkalinity. It is the negative logarithm of the 

hydrogen ion concentration. A pH of 7 is defined as neutral and large variations above or 

below this value are considered harmful to most aquatic life. 

Pass-through -- A discharge which exits the POTW into waters of the State in quantities or 

concentrations which, alone or in conjunction with a discharge or discharges from other 

sources, is a cause of a violation of any requirement of the POTW's NPDES permit 

(including an increase in the magnitude or duration of a violation), or which is a cause of a 

violation of State water quality standards. 

Peak hour design flow (PHDF) -- The largest volume of flow anticipated to occur during a 

one- period, expressed as a daily or hourly average. 

Peak instantaneous design flow (PIDF) -- The maximum anticipated instantaneous flow. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 43 of 62 

April 30, 2012 D. Nichols/ERO 

Quantitation level (QL) -- Also known as Minimum Level of Quantitation (ML) – The lowest 

level at which the entire analytical system must give a recognizable signal and acceptable 

calibration point for the analyte. It is equivalent to the concentration of the lowest calibration 

standard, assuming that the lab has used all method-specified sample weights, volumes, and 

cleanup procedures. The QL is calculated by multiplying the MDL by 3.18 and rounding the 

result to the number nearest to (1,2,or 5) x 10n, where n is an integer. (64 FR 30417). 

ALSO GIVEN AS: 

The smallest detectable concentration of analyte greater than the Detection Limit (DL) where 

the accuracy (precision & bias) achieves the objectives of the intended purpose. (Report of 

the Federal Advisory Committee on Detection and Quantitation Approaches and Uses in 

Clean Water Act Programs Submitted to the US Environmental Protection Agency December 

2007). 

Reasonable potential -- A reasonable potential to cause a water quality violation, or loss of 

sensitive and/or important habitat. 

Responsible corporate officer -- A president, secretary, treasurer, or vice-president of the 

corporation in charge of a principal business function, or any other person who performs 

similar policy- or decision-making functions for the corporation, or the manager of one or 

more manufacturing, production, or operating facilities employing more than 250 persons or 

have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 

dollars), if authority to sign documents has been assigned or delegated to the manager in 

accordance with corporate procedures (40 CFR 122.22). 

Slug discharge -- Any discharge of a non-routine, episodic nature, including but not limited to 

an accidental spill or a non-customary batch discharge to the POTW. This may include any 

pollutant released at a flow rate that may cause interference or pass through with the POTW 

or in any way violate the permit conditions or the POTW’s regulations and local limits.

Solid waste -- All putrescible and non-putrescible solid and semisolid wastes including, but not 

limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, demolition and 

construction wastes, abandoned vehicles or parts thereof, contaminated soils and 

contaminated dredged material, and recyclable materials. 

Soluble BOD5 -- Determining the soluble fraction of Biochemical Oxygen Demand of an 

effluent is an indirect way of measuring the quantity of soluble organic material present in an 

effluent that is utilized by bacteria. Although the soluble BOD5 test is not specifically 

described in Standard Methods, filtering the raw sample through at least a 1.2 um filter prior 

to running the standard BOD5 test is sufficient to remove the particulate organic fraction. 

State waters -- Lakes, rivers, ponds, streams, inland waters, underground waters, salt waters, 

and all other surface waters and watercourses within the jurisdiction of the state of 

Washington. 

Stormwater -- That portion of precipitation that does not naturally percolate into the ground or 

evaporate, but flows via overland flow, interflow, pipes, and other features of a storm water 

drainage system into a defined surface water body, or a constructed infiltration facility. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 44 of 62 

April 30, 2012 D. Nichols/ERO 

Technology-based effluent limit -- A permit limit based on the ability of a treatment method to 

reduce the pollutant. 

Total coliform bacteria -- A microbiological test, which detects and enumerates the total 

coliform group of bacteria in water samples. 

Total dissolved solids -- That portion of total solids in water or wastewater that passes through a 

specific filter. 

Total suspended solids (TSS) -- Total suspended solids is the particulate material in an effluent. 

Large quantities of TSS discharged to a receiving water may result in solids accumulation. 

Apart from any toxic effects attributable to substances leached out by water, suspended solids 

may kill fish, shellfish, and other aquatic organisms by causing abrasive injuries and by 

clogging the gills and respiratory passages of various aquatic fauna. Indirectly, suspended 

solids can screen out light and can promote and maintain the development of noxious 

conditions through oxygen depletion. 

Upset -- An exceptional incident in which there is unintentional and temporary noncompliance 

with technology-based permit effluent limits because of factors beyond the reasonable 

control of the Permittee. An upset does not include noncompliance to the extent caused by 

operational error, improperly designed treatment facilities, lack of preventative maintenance, 

or careless or improper operation. 

Water quality-based effluent limit -- A limit imposed on the concentration of an effluent 

parameter to prevent the concentration of that parameter from exceeding its water quality 

criterion after discharge into receiving waters. 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 45 of 62 

April 30, 2012 D. Nichols/ERO 

Appendix D - Technical Calculations 

Several of the Excel® spreadsheet tools used to evaluate a discharger’s ability to meet 

Washington State water quality standards can be found on Ecology’s homepage at 

http://www.ecy.wa.gov/programs/eap/pwspread/pwspread.html. 

Performance-based TSS limits – Summer (April – October) 

PERFORMANCE-BASED EFFLUENT LIMITS

USE EXCEL TO PERFORM THE LOGNORMAL TRANSFORMATION

 AND CALCULATE THE TRANSFORMED MEAN AND VARIANCE 

LOGNORMAL TRANSFORMED MEAN = 3.3924

 'LOGNORMAL TRANSFORMED VARIANCE = 0.3325

 NUMBER OF SAMPLES/MONTH FOR COMPLIANCE MONITORING = 2

 AUTOCORRELATION FACTOR( ne)(USE 0 IF UNKNOWN) = 0

E(X) = 35.1158

V(X) = 486.403

VARn 0.1800

MEANn= 3.4686

VAR(Xn)= 243.201

MAXIMUM DAILY EFFLUENT LIMIT = 113.708

AVERAGE MONTHLY EFFLUENT LIMIT = 64.494

Performance-based TSS limits – Winter (November – March) 

PERFORMANCE-BASED EFFLUENT LIMITS

USE EXCEL TO PERFORM THE LOGNORMAL TRANSFORMATION

 AND CALCULATE THE TRANSFORMED MEAN AND VARIANCE 

LOGNORMAL TRANSFORMED MEAN = 3.3097

 'LOGNORMAL TRANSFORMED VARIANCE = 0.4917

 NUMBER OF SAMPLES/MONTH FOR COMPLIANCE MONITORING = 2

 AUTOCORRELATION FACTOR( ne)(USE 0 IF UNKNOWN) = 0

E(X) = 35.0078

V(X) = 778.415

VARn 0.2758

MEANn= 3.4177

VAR(Xn)= 389.208

MAXIMUM DAILY EFFLUENT LIMIT = 139.880

AVERAGE MONTHLY EFFLUENT LIMIT = 72.354
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 46 of 62 

April 30, 2012 D. Nichols/ERO 

Appendix E - Response to Comments 

Quincy-Columbia Basin Irrigation District Response to Comments on the Draft NPDES Permit 

No. WA-0021067-7 and associated Fact Sheet

A copy of the original comment letter is attached to this fact sheet. 

DRAFT PERMIT COMMENTS

Comment 1: Reporting and Recordkeeping

The District requests that the Reporting and Recordkeeping Requirements section of the draft 

permit be updated to include mailing and email addresses as indicated below: 

Quincy-Columbia Basin Irrigation District 

Water Quality Programs 

PO Box 188 

Quincy, WA 98848 

cgyselinck@qcbid.org

Response to Comment 1

Section S3.A of the permit (Reporting and recordkeeping requirements, Reporting) has the 

district’s mailing address for all monthly discharge monitoring reports. Ecology has edited 

this section of the permit to require the city to begin submitting electronic DMRs by 

September 2012. Until then the city will continue to send paper copies to the District. After 

September, the District can obtain the monthly data by using the following link: 

www.ecy.wa.gov/programs/wq/permits/wwdischargepermits.html. 

Comment 2: Reporting and Recordkeeping

Additionally, the District requests to be included in Section 3(E) of the draft permit and to be 

notified of any violations of the conditions of this permit.

Response to Comment 2

Ecology will add to Section S3.E (Reporting permit violations) the phone number of the 

irrigation district for the Permittee to immediately report failures of the disinfection system 

and collection system overflows. 

Quincy-Columbia Basin Irrigation District: 509.787.3591 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 47 of 62 

April 30, 2012 D. Nichols/ERO 

Comment3: 

A correction should be noted regarding the “receiving Water” and “Water Quality 

Impairments” as described in the permit. Treated water from the Facility discharges into the 

DW237 which flows into the W645W and W645. The W645 discharges into the Frenchman 

Hills Wasteway (FH WW) before being received by the Potholes Reservoir. On the most 

current 303(d) list for impaired waters (2008 Water Quality Assessments) the FH WW is 

listed as a category 5 polluted water for pH and temperature. 

Response to Comment 3

Ecology has added language to the following sections in the Fact Sheet: 

1. Section B (Description of the receiving water) that explains the entire wasteway 

drainage from the receiving water (DW237) to the Potholes Reservoir. 

2. Section E (Water quality impairments) has been edited to show a map of the drainage 

area and the location of the 303(d) listed waterbodies; Frenchman Hills and Potholes 

Reservoir. 

Bureau of Reclamation Response to Comments on the Draft NPDES Permit No. WA-0021067-7

and associated Fact Sheet

A copy of the original comment letter is attached to this fact sheet. 

DRAFT PERMIT COMMENTS

Comment 1: 

The volume of water being discharged by the IWTF into the receiving water DW237 is 

concerning. The contract allows for 5 cfs, or 3.23 MGD, as per the capacity and structural 

integrity of the constructed facility. In the draft permit and fact sheet, the flow set for the 

Maximum Daily allowance is 3.23 MGD; however, Ecology also allows for a monthly average 

of 4.89 MGD. The 3.23 MGD should not be exceeded for any given day to protect the federal 

irrigation facilities from potential injury related with the increased volumes of water, as well as 

to protect public health and safety.

Monthly average limits for the biological oxygen demand (BOD) in the permit and fact sheet are 

set at 51.1 mg/L in the summer and 65 mg/L in the winter, and daily maximum limits are set at 

95.2 mg/l in the summer and 130 mg/L in the winter, while the contract Reclamation has with 

the City allows for a daily maximum of 15 mg/l of BOD in the effluent. 

Response to Comment 1:

Section III.J of the fact sheet will be edited to reflect the following: 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 48 of 62 

April 30, 2012 D. Nichols/ERO 

Ecology is aware of the contract between the city and the bureau regarding the discharge 

limitations for the industrial treated effluent to the wasteway system that are in the agreement. 

With regard to the BOD limit in the agreement, Ecology is reissuing the permit based on its 

approval of the city’s treatment facility providing AKART (all known available and reasonable 

methods of treatment) as required by RCW 90.48, and water quality is being protected by the 

permit’s effluent limits that are based on the EPA approved TMDL for the wasteway. The permit 

does not authorize the City of Quincy to violate any terms or conditions of any agreement or 

contract 

Regarding the Bureau’s flow limit in the agreement, the maximum daily flow limit in Section S1 

(3.23 MGD) is based on the value set in the agreement. The average monthly flow limit in S1 

(4.89 MGD) is based on the influent design loading of the industrial wastewater facility. The 

industrial wastewater facility is and has been operated to not exceed the 3.23 MGD effluent 

limit. The city has installed a flow equalization basin to help insure this value is not exceeded. In 

recognition of the difference in basis for the two flow values, Section S1 will show the 3.23 

MGD limit and Section S7 (Facility Loading) will show the design value of 4.89 MGD. 

Comment 2:

Reclamation would like to reiterate its concerns with the proximity of the brine ponds to the 

West Canal; in the event of a severe leak or breach there could be catastrophic consequences in 

the immediate and downstream areas of the canal. Reclamation also feels the acceptable volume 

of leakage from the brine ponds could impact the groundwater beneath the ponds belonging to 

Reclamation. 

Response to Comment 2:

We appreciate your concern but based on information presented in the engineering report for the 

ponds, the site for the brine ponds is approximately 300ft from the West Canal. This is well 

beyond the right of way for the West Canal. Each pond is double lined with 60-mil HDPE with a 

leak detection geocomposite between the two liners. Any water that is collected between the 

liners gravity flows to a leak detection standpipe at each pond. Section S2.A of the permit 

requires daily measurements for the presence and volume of water in the standpipes, and 4/year 

testing of the collected water. The monitoring provides an indicator of potential issues. In 

addition, both ponds were built below grade so there is no chance of breaching. Additionally, 

both ponds were built according to Ecology’s guidance for storage ponds.

Comment 3:

Reclamation is concerned that no groundwater and soil sampling/monitoring has been included 

in the NPDES Permit requirements. Reclamation believes that groundwater and soil sampling 

should be incorporated into the permit requirements. Samples should be extracted from along the 

perimeter of the ponds in order to monitor how saturated the groundwater and soils are 

becoming, as well as tracking any leaching that may occur as a result of the acceptable leakage. 

The introduction of high concentrations of salts into irrigation water (the groundwater beneath 

the ponds) may impact crop production in the surrounding area and possibly downstream. Other 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 49 of 62 

April 30, 2012 D. Nichols/ERO 

monitoring Reclamation feels is being overlooked for the DW237 Wasteway concerns the 

chemicals being used in the treatment facility for disinfection and dechlorination, as well as a full 

work up for nutrients, not just Total Kjeldahl Nitrogen (TKN). 

Response to Comment 3:

Ecology will not add groundwater and soil sampling/monitoring for the area around the brine 

ponds, and will not require a full workup for nutrients in the effluent. It is Ecology’s position that

the double lined leak detection construction of both brine ponds makes the potential for 

groundwater and soil impacts from the ponds very minimal. The leak detection system 

monitoring can alert EMC of a potential problem with the liner(s) and allow for a timely repair. 

According to the approved plans and specifications for the disinfection system, sodium bisulfite 

is used for dechlorination. The point of injection downstream of the chlorine contact basin is 

dependent on the season; before the re-aeration basin (winter season) and before the cooling 

tower (summer season). The use of sodium bisulfite is a widely accepted method to dechlorinate 

before discharging into a surface water. More information can be read on the subject in EPA’s 

Wastewater Technology Fact Sheet, Dechlorination, September 2000, EPA 832-F-00-022. 

The DW237 wasteway collects surface and subsurface drainage water from fertilized irrigated 

crop lands upstream from the point where the industrial effluent discharges. Ecology is unaware 

of any nutrient related problems in the wasteway downstream of the point of discharge. It is 

Ecology’s understanding that the nutrient load in the wasteways and the resulting plant/weed 

growth is managed by the bureau/irrigation district by routinely using chemicals to keep the 

wasteway system free flowing. The nutrient load contributed from the discharge would be 

managed by the current operations and maintenance of the wasteway. 

Comment 4:

Reclamation is very interested in the spill plan the Data Centers and the City are engineering. If a 

spill or leak from the conveyance system of the brine water were to occur there could be 

devastating effects to both crops and the land. 

Response to Comment 4:

Brine water from the reverse osmosis and demineralization facilities will be truck transported to 

the ponds. Until the brine water is piped to the ponds, Ecology will not require a spill plan. 

Ecology will require an Engineering Report and designs and specifications prior to the 

installation of the pipeline. Ecology will discuss the need for leak detection for the pipeline with 

the facility during review of these documents. 

Comment 5:

On page one of the Fact Sheet, there is mention of the proposed permit requiring the submittal of 

a discharge management plan describing the City’s plan for discharge of wastewater after 

September 2015. Reclamation would like to request a copy of any engineering plans submitted to 

Ecology on behalf of this project, as well as to be kept apprised of the City’s intentions for 

relocating the discharge, due to the number of federal facilities in the region. 

Response to Comment 5:
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 50 of 62 

April 30, 2012 D. Nichols/ERO 

Ecology agrees to edit the requirements in Section S8 of the permit to require that a copy of the 

city’s plan to stop discharging to the wasteway be sent to the Bureau and the Irrigation District. 

Comment 6:

Reclamation has been receiving the monthly discharge monitoring reports (DMR’s) from the 

IWTF, and would like to request that they remain a recipient of the DMR’s until such time that 

there is no longer any discharge entering Reclamation facilities from the IWTF. 

Response to Comment 6:

Ecology is requiring all dischargers to begin using their newly developed electronic data entering 

system, WAWebDMR. Once the data has been entered by the Permittee, it can be viewed and 

downloaded by the public. 

Ecology will edit Section S3 of the permit to add updated permit shell language that requires the 

Permittee to begin using WAWebDMR by September 1, 2012. Until then, paper copies of the 

DMRs shall be sent to the Bureau and Irrigation District. 

The Bureau and Irrigation District can access the WAWebDMR data from Ecology’s main 

permit tracking system (PARIS) at: 

http://www.ecy.wa.gov/programs/wq/permits/wwdischargepermits.html

American Water Contract Services Re: Environmental Management Corp Response to 

Comments on the Draft NPDES Permit No. WA-0021067-7 and associated Fact Sheet

A copy of the original comment letter is attached to this fact sheet. 

DRAFT PERMIT COMMENTS

Comment 1: 

The draft permit identifies a new summer outfall TSS limit for both mg/L and lbs/day. The new 

TSS limit affects both Average Monthly and Maximum Daily parameters. 

EMC objects to the new TSS limits for the following reasons: 

1. The IWTP has not had any improvements or capital upgrades since the last permit cycle 

to address the lower effluent TSS permit requirements. 

2. Based on the Facility Loading Design Monthly Maximum of 66,400 lbs/day and the 

lower permit parameter for daily maximum daily discharge of 3,071 lbs/day. The new 

parameter requires the IWTP to operate at a 95 percent reduction rate. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 51 of 62 

April 30, 2012 D. Nichols/ERO 

3. Algae can grow in the EQ basin after the SBR process during low flow periods typically 

occurring in the summer months. The lower TSS parameter may require capital 

improvement by the city to meet the new discharge limit. 

Accordingly, the draft NPDES permit should be revised to reflect the current permit TSS 

parameters. 

Response to Comment 1:

Ecology will not change the summer season limits for TSS. 

Figure 3 and 4 in the Fact Sheet compares the updated limits to values reported in the DMRs 

during the current permit cycle. The IWTP would have exceeded the updated maximum and 

average summer TSS concentration and load limits once during the last permit cycle. There is 

every indication the IWTP can comply with updated summer limits. 

With regards to algae growth contributing to the TSS concentration in the effluent, Ecology 

suggests the Permittee make note of this in the monthly DMR. A digital picture of algal growth 

or other contributing factors to high TSS can be attached to the WAWebDMR. The following 

formats can be attached to a WAWebDMR: ".xls", ".xlsx", ".doc", ".docx", ".txt", ".gif", ".jpeg", 

".jpg", ".bmp", ".pdf", ".tif" 

Comment 2: Special Condition S1.B, Brine Water Discharge. 

Special condition S1.B needs to be changed to, “..the Permittee is authorized to discharge 

wastewater with a TDS concentration in excess of 500 mg/L from the local industries to the non 

discharging lined brine ponds located on the industrial wastewater treatment site.” 

Response to Comment 2:

Ecology agrees to edit the conditions in Section S1.B of the permit. 

Ecology reviewed the engineering report for the brine ponds. The ponds will manage brine waste 

generated by the demineralization facility located at Microsoft, and “..potentially other brine 

wastes produced by City customers.” In addition, the approved engineering report for the brine 

waste ponds stated a TDS concentration of 35,000 mg/L or 3.5 percent solids. 

The changes made to S1.B are: 

Beginning on the effective date of the permit and lasting through the expiration date, 

brine water from the Microsoft – Columbia Data Center’s ion exchange demineralization 

process/reverse osmosis system, and from brine wastes produced by city customers, not 

to exceed 35,000 mg/L, the Permittee is authorized to be discharged discharge brin water 

from the reverse osmosis/ion exchange system that is located at the Microsoft –

Columbia Data Center to non discharging lined brine ponds located on the industrial 

wastewater facility site. 

Comment 3: Special Condition S8 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 52 of 62 

April 30, 2012 D. Nichols/ERO 

Permittee should be changed from “EMC” to the “City of Quincy”. This requirement would be 

a City of Quincy responsibility as owner of the facility – EMC is the contract operator of the 

IWTP. 

Response to Comment 3:

Ecology will not change the language in Section S8.

The phrase, ‘The Permittee...’ is consistently used throughout the permit and does not 

specifically identify either of the co-permittees. Ecology will leave the issue of the responsible 

party to the language in the service agreement. 

Comment 4: Special Condition S9 

Please remove the reference to EMC from this section. EMC should not be a party to this 

requirement. EMC is the contract operator of the IWTP, not the owner. 

Response to Comment 4:

Based on the response to Comment 3, Ecology will edit the language in S9 to read: “No later 

than September 1, 2013, the Permittee the City and EMC must submit to Ecology.....” 

Comment 5: Special Condition S9.A 

Please remove the reference to EMC from this section. EMC should not be a party to this 

requirement. EMC is the contract operator of the IWTP, not the owner. 

Response to Comment 5:

Based on the response to Comment 3, Ecology will edit the language in S9.A to read: “The 

Permittee The City and EMC must submit to Ecology.....” 

Comment 6: Special Condition G13 

Permittee should be changed from “EMC” to the “City of Quincy”. This requirement would be a 

City of Quincy responsibility as owner of the facility. EMC is the contract operator of the IWTP. 

Response to Comment 6:

Based on the response to Comment 3, the language in G13 will not be changed. 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 53 of 62 

April 30, 2012 D. Nichols/ERO 

•
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 54 of 62 

April 30, 2012 D. Nichols/ERO 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 55 of 62 

April 30, 2012 D. Nichols/ERO 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 56 of 62 

April 30, 2012 D. Nichols/ERO 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 57 of 62 

April 30, 2012 D. Nichols/ERO 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 58 of 62 

April 30, 2012 D. Nichols/ERO 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 59 of 62 

April 30, 2012 D. Nichols/ERO 

 
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 60 of 62 

April 30, 2012 D. Nichols/ERO 

Appendix F - Graphs, Figures, Tables 

Table 1. Permit violations 

Quincy Industrial

Permit Violations (Jan 07 - July 2011)

3/1/2007 Flow Maximum MGD 3.24 - 3.23 Numeric effluent violation

4/1/2007 Flow Maximum MGD 3.55 - 3.23 Numeric effluent violation

6/1/2007 Flow Maximum MGD 3.24 - 3.23 Numeric effluent violation

7/1/2007 Flow Maximum MGD 3.24 - 3.23 Numeric effluent violation

8/1/2007 Flow Maximum MGD 3.24 - 3.23 Numeric effluent violation

12/1/2007 Ammonia, Total Average Milligrams/L (mg/L) 2.92 - 1.45 Numeric effluent violation

12/1/2007 Ammonia, Total Maximum Lbs/Day 121.6 - 96.7 Numeric effluent violation

12/1/2007 Ammonia, Total Average Lbs/Day 51.1 - 48.2 Numeric effluent violation

12/1/2007 Ammonia, Total Maximum Milligrams/L (mg/L) 7.48 - 2.9 Numeric effluent violation

7/1/2009 Ammonia, Total Average Milligrams/L (mg/L) 1.39 - 1.19 Numeric effluent violation

11/1/2010 Ammonia, Total Maximum Lbs/Day 297.8 - 96.7 Numeric effluent violation

11/1/2010 Ammonia, Total Maximum Milligrams/L (mg/L) 17.45 - 2.9 Numeric effluent violation

11/1/2010 Ammonia, Total Average Milligrams/L (mg/L) 1.56 - 1.45 Numeric effluent violation

7/1/2009 Temperature Maximum Degrees C 24.7 - 22.5 Numeric effluent violation

9/1/2009 Temperature Single Sample Degrees F - - - Analysis not Conducted

Fig. 1 Summer season effluent pH compliance 

0

2

4

6

8

10

12

max summer

min summer

max limit

mim limit
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 61 of 62 

April 30, 2012 D. Nichols/ERO 

Fig. 2 Winter season effluent pH compliance 

0

1

2

3

4

5

6

7

8

9

10

max winter

min winter

max limit

min limit

Fig. 3. Actual Effluent TSS vs Updated Limits (mg/L) – Summer season 

 

0

20

40

60

80

100

120

140

Mg/L

Summer Season Performance-based TSS

Actual effluent TSS vs. Updated values

AVG

MAX

AVG LIMIT

MAX LIMIT
Fact Sheet for NPDES Permit WA002106-7 

Quincy Industrial Wastewater Treatment Facility

Page 62 of 62 

April 30, 2012 D. Nichols/ERO 

Fig. 4. Actual Effluent TSS vs Updated Limits (lbs/day) – Summer season 

0

20

40

60

80

100

120

140

Lbs/day

Summer Season Performance-based TSS

Actual effluent TSS vs. Updated values

AVG

MAX

AVG LIMIT

MAX LIMIT