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### Fact Sheet for NPDES Permit WA002106-7 Quincy Industrial Wastewater Treatment Facility

Purpose of this fact sheet This fact sheet explains and documents the decision s the Department of Ecology (Ecology) made in drafting the proposed National Pollutant Dischar ge Elimination System (NPDES) Permit for the City of Quincy’s Industrial Wastewater Treatmen t Facility. This fact sheet complies with Section 173-220-060 o f the Washington Administrative Code (WAC), which requires Ecology to prepare a draft pe rmit and accompanying fact sheet for public evaluation before issuing an NPDES permit. Ecology makes the draft permit and fact sheet avail able 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 pu blishing this draft fact sheet for public notice. After the public comment period closes, Ecology wil l summarize substantive comments and provide responses to them. Ecology will include th e 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 she et in response to comments, but the full document will become part of the legal history cont ained in the facility’s permit file. Ecology will annotate those fact sheet sections that Ecolog y changed as a result of responding to comments received from the Permittee during the pub lic 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 tr eatment facility that treats process wastewater from a potato and vegetable processor an d discharges to a U.S Bureau of Reclamation irrigation wasteway year around. No san itary wastewater is discharged to the facility or irrigation wasteway. Environmental Mana gement Corporation (EMC) operates the facility as per a service agreement. The City and E MC are Co-Permittees. Water-quality based seasonal effluent limits for Bi ochemical Oxygen Demand (BOD 5 ), fecal coliform bacteria, chlorine, dissolved oxygen and t emperature remain unchanged from the permit issued in 2006. Ecology included water quality-base d limits for ammonia in this permit based on the wasteload allocation from a TMDL. The 2006 per formance-based limits for total suspended solids were updated based on the past five years of discharge data.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO The proposed permit requires the submittal of a dis charge management plan that describes where the City of Quincy plans to discharge the final eff luent 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 discha rge 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

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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 li fe and recreation ................................. . 18 Numerical criteria for the protection of human heal th ................................................ ...... 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 per mit issued on October 13, 2006...............................................

................................................... ..................... 31
IV. Monitoring Requirements ...........................

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

................................................... ............ 33
B. Effluent limits which are near detection or quantit ation levels ...................... 33
V. Other Permit Conditions ...........................

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

................................................... .. 34
B. Spill plan ........................................

................................................... ................... 34Fact Sheet for NPDES Permit WA002106-7

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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 R eclamation 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 ...................

................................................... ..................... 27Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Table 12: Comparison of Previous and Proposed Effl uent Limits - Summer Season (April - October) ..........................................

................................................... ........................................... 31 Table 13: Comparison of Previous and Proposed Effl uent 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 sto rage lagoons ...................................... ........ 10 Figure 4: Final Discharge Location Map ...........

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

................................................... ....................... 12 Figure 6: Frenchman Hills Wasteway and Potholes Re servoir ........................................... ........ 25Fact Sheet for NPDES Permit WA002106-7

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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 Wate r Act is the National Pollutant Discharge Elimination System (NPDES), administered by the fed eral 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 dele gation and assigned the power and duty for conducting NPDES permitting and enforcement to Ecol ogy. The Legislature defined Ecology's authority and obligations for the wastewater discha rge permit program in 90.48 RCW (Revised Code of Washington). The following regulations apply to municipal NPDES permits:

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

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

• Water quality criteria for ground waters (chapter 1 73-200 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/o perator 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 an d 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 173-2 20-050). (See Appendix A - Public Involvement Information for more detail about the public notice and commen t procedures). After the public comment period ends, Ecology may m ake 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

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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 treatm ent facility that receives process wastewater from a potato and veget able processor
Type of Treatment Primary settling, anaerobic diges tion, 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: -119.88945Fact Sheet for NPDES Permit WA002106-7

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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 co nsists 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, cooli ng (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 DW237Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO The City discharges the final effluent to a U.S. Bu reau of Reclamation wasteway; DW237. Immediately after discharge and mixing, the wastewa y flows beneath the W. Canal and becomes W645W, which later becomes W645 that discha rges to the Potholes Reservoir. The entire receiving water system is part of the federa l 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 irr igation water from the Columbia River to approximately 500,000 acres of production agricultu re. The City has owned and operated an industrial wastewater treatment system since the 19 60’s. The current system is designed to treat the process wastewater from a potato and vege table processor; ConAgra Foods and Quincy Foods, respectively. ConAgra operates year a round (average flow of 1.63 mgd) and Quincy Foods (average flow of 0.66 mgd) operates du ring 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 sani tary wastes are discharged into the industrial wastewater system. In August 2009, Environmental Management Corporatio n 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 Chapt er 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 m ain approximately one mile to the secondary treatment site; SBR. Figure 2: Aerial photograph of primary facilityFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Secondary treatment facility : The wastewater from the primary facility is dire cted to one of two earthen walled and geomembrane-lined sequencing batch reactor basins; Figure 2. Each reactor basin discharges to a geomembrane- lined, e arthen walled flow equalization basin. Wastewater from the basin is pumped to the above gr ound disinfection contact chamber where sodium hypochlorite is added. The contact tim e is 20 minutes at the design flow (5 cfs).
Wastewater from the chlorine contact basin flows th rough 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 e ffect. Wastewater from the cooling tower is dechlorinated using sodium bisulfite and then pu mped to a fine pore diffused aeration basin to increase the dissolved oxygen to meet perm it 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 la goon #5. The discharge from the re-aeration basin gravity fl ows approximately one mile in a 24 inch pipe prior to discharge to the Bureau of Reclamatio n’s DW237 wasteway; Figure 3. Immediately after discharge the DW237 crosses the W est Canal via a siphon and emerges as the W645W wasteway. The wasteway is part of the Bur eau’s irrigation return flow collection system that discharges to the Potholes Reservoir. W ater from the reservoir is re-distributed to the southern portion of the irrigation project area

.

Figure 3: Aerial photograph of SBRs and sludge sto rage lagoonsFact Sheet for NPDES Permit WA002106-7

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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 P olyethylene (HDPE) lined and covered anaerobic digester. The digester will replace the p rimary 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 po nds with leak detection (1.25 MG each) in 2011/12 on land immediately adjacent to the disi nfection/cooling/re-aeration site (Figure 3). The ponds are part of the City’s brine manageme nt 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 t o the SBR system.

Pretreatment Delegation Ecology issued an administrative order to Quincy th at required it to obtain pretreatment delegation authority and begin permit issuance by M ay 2012. Disinfection, cooling, re-aeration site, and Brine Pond site

Lagoon #5 West Canal

Anaerobic Digester site; sludge storage #2Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO B. Description of the receiving water The facility discharges to the U.S. Bureau of Recla mation’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 Pr oject that brings water from the Columbia River to approximately 500,000 acres in central Was hington. Wasteway drains are manmade and are part of the irr igation 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 DischargeFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO EMC submits monthly receiving water data in DMRs. E cology 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; 0.0 2 mg/L
Fecal Coliform (max; geometric mean) 156 /100 mL; 1 2 /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 th e Bureau dated September 21, 1965 that expires in 2015. In a letter dated July 19, 20 10, the Bureau informed the City they do not intend to renew the contract.

C. Wastewater characterization The City/EMC reported the concentration of pollutan ts in the discharge in the permit application and in discharge monitoring reports. T he tabulated data represents the quality of the wastewater effluent discharged to wasteway DW23 7. The wastewater effluent is characterized as follows:Fact Sheet for NPDES Permit WA002106-7

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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 pre sented in the permit application. The units are different from what are in the Fact Sheet boilerpla te: monthly geometric mean; 7-Day geometric

mean. D. Summary of compliance with previous permit Issue d 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 cy cle. 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 du e to problems with the SBR aeration system which the City replaced in 2009.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO The City and EMC submitted a leak detection plan f or the SBRs as required by the permit. The first submittal in 2008 was updated in 2010; EMC, 2 010. The first leak survey was scheduled for February/March 2011. To date, the leak survey of th e 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 treatmen t 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 t he effluent will comply with the Surface Water Quality Standards (chapter 173-201A WAC), Ground Wa ter Standards (chapter 173-200 WAC), Sediment Quality Standards (chapter 1 73-204 WAC), or the National Toxics Rule (40 CFR 131.36). Ecology must apply the most stringent of these limi ts to each parameter of concern. These limits are described below. The limits in this permit reflect information recei ved in the application and from supporting reports (engineering, hydrogeology, etc.). Ecology evaluated the permit application and determined the limits needed to comply with the rul es adopted by the State of Washington. Ecology does not develop effluent limits for all re ported pollutants. Some pollutants are not treatable at the concentrations reported, are not c ontrollable 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 polluta nts not reported in the permit application but may be present in the discharge. The permit does n ot 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 pollutant s, a permitted facility could be violating its permit. A. Design criteria Under WAC 173-220-150 (1)(g), flows and waste loadi ngs must not exceed approved design criteria. Ecology approved design criteria for thi s 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

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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

BOD 5 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 treatmen t 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 S BRs and the 2005 upgrades from the amended engineering reports prepared by Earth Tech (2000; 2 005) 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 mee ting the requirements in the 1965 signed agreement between the City and the Bureau of Reclam ation that allows the crossing of the Bureau’s right of way with an industrial sewerage s ystem and the discharge into the irrigation wasteway.

B. Technology-based effluent limits The design of the industrial wastewater facility wa s based, in part, on the quality and quantity of process wastewater discharged from the potato an d 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 20 05 to meet water quality-based limits for dissolved oxygen, fecal coliforms, and t emperature. Ecology included technologybased limits in the permit for TSS and pH.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO TSS Ecology used daily effluent TSS data (Jan 2007 – Se pt 2011) provided by EMC to update the performance-based limits for TSS; Appendix D. The v alues for ‘Lognormal Transformed Mean’ and ‘Lognormal Transformed Variance’ in the p erformance-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 d ischarge flow of 3.23 MGD. The results of the performance-based analysis provi ded 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 per mit 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 se en 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 lim it values, this action would be considered backsliding (40 CFR122.44(l)(1)) which is not allow ed. Therefore, Ecology will extend the current winter season limits for TSS into the propo sed permit. However, the updated summer season TSS limits are m ore stringent than the current TSS limits. The updated summer season limits reflect the most u p-to-date operational efficiency of the SBRs. Ecology has decided to include the updated TS S performance-based limits in the proposed permit.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Ecology compared the updated summer season TSS limi ts to actual effluent values for Jan 2007 – July 2011; Appendix F, Figs. 3 and 4. Effluent va lues 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 standard s (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 permi ts must include conditions that ensure the discharge will meet the surface water quality s tandards (WAC 173-201A-510). Water quality-based effluent limits may be based on an in dividual 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 li fe and recreation Numerical water quality criteria are listed in the water quality standards for surface waters (chapter 173-201A WAC). They specify the maximum l evels of pollutants allowed in receiving water to protect aquatic life and recreat ion 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 discharg e permit. When surface water quality-based limits are more stringent or potentially more strin gent than technology-based limits, the discharge must meet the water quality-based limits. Numerical criteria for the protection of human heal th The U.S. EPA has published 91 numeric water quality criteria for the protection of human health that are applicable to dischargers in Washin gton State (EPA, 1992). These criteria are designed to protect humans from exposure to polluta nts linked to cancer and other diseases, based on consuming fish and shellfish and drinking contaminated surface waters. The water quality standards also include radionuclide criteri a to protect humans from the effects of radioactive substances.
Narrative criteria Narrative water quality criteria (e.g., WAC 173-201 A-240(1); 2006) limit the toxic, radioactive, or other deleterious material concentr ations 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

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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 o f the surface waters of Washington.

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

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

• Ensure that all human activities likely to contribu te 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) f or surface waters of the State. Tier I ensures existing and designated uses are mai ntained and protected and applies to all waters and all sources of pollutions. Tier II ensu res that waters of a higher quality than the criteria assigned are not degraded unless such lowe ring of water quality is necessary and in the overriding public interest. Tier II applies on ly to a specific list of polluting activities. Tier III prevents the degradation of waters formall y 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 de gradation 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. Withi n mixing zones the pollutant concentrations may exceed water quality numeric sta ndards, so long as the discharge doesn’t interfere with designated uses of the receiving wat er 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 standa rds. 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 t he end-of-pipe discharge could harm water quality, plants, or fish.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO The State’s water quality standards allow Ecology t o authorize mixing zones for the facility’s permitted wastewater discharges only if those disch arges already receive all known, available, and reasonable methods of prevention, co ntrol, and treatment (AKART). Mixing zones typically require compliance with water quali ty criteria within a specified distance from the point of discharge and must not use more t han 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 mix ing within the mixing zone. Through modeling Ecology determines the potential for viola ting the water quality standards at the edge of the mixing zone and derives any necessary e ffluent limits. Steady-state models are the most frequently used tools for conducting mixin g 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 “reasona ble 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 di lution factor of 10 means the effluent is 10% and the receiving water is 90% of the total vol ume of water at the boundary of the mixing zone. Ecology uses dilution factors with th e water quality criteria to calculate reasonable potentials and effluent limits. Water q uality 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 an y of these mixing zones may not exceed the numerical criteria for that zone. Each aquatic life acute criterion is based on the assumption that organism s 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 organism s are not exposed to that concentration for more than four consecutiv e days and more often than once in three years. The two types of human health-based water quality c riteria distinguish between those pollutants linked to non-cancer effects (non-carcin ogenic) and those linked to cancer effects (carcinogenic). The human health-based water quali ty 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 wa ter.

• A one-in-one-million cancer risk for carcinogenic c hemicals. This permit authorizes a small acute mixing zone, s urrounded 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

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April 30, 2012 D. Nichols/ERO 1. Ecology must specify both the allowed size and loca tion 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 d ischarge. 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 exis ting 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 affecti ng dilution include the depth of water, the density stratification in the water column, the cur rents, and the rate of discharge. Density stratification affects how far up in the water colu mn a freshwater plume may rise. Density stratification is determined by the salinit y and temperature of the receiving water. Temperatures are warmer in the surface waters in su mmer. Therefore, density stratification is generally greatest during the sum mer 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 t he effluent stops rising, the rate of mixing is much more gradual. Water depth can affec t dilution when a plume might rise to the surface when there is little or no stratific ation. Ecology’s Permit Writer’s Manual describes additional guidance on criteria/design co nditions 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 mi xing zone would not:

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

• Substantially interfere with the existing or charac teristic 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 tox icity tests with numerous organisms and set the criteria to generally protect the speci es tested and to fully protect all commercially and recreationally important species.
EPA sets acute criteria for toxic chemicals assumin g organisms are exposed to the pollutant at the criteria concentration for one hou r. They set chronic standards assuming organisms are exposed to the pollutant at the crite ria concentration for four days.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Dilution modeling under critical conditions general ly shows that both acute and chronic criteria concentrations are reached within minutes of discharge. The discharge plume does not impact drifting and no n-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 with in 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 plu me rises in the water column. Ecology has additionally determined that the efflue nt 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 migra tion. Ecology evaluates the cumulative toxicity of an eff luent by testing the discharge with whole effluent toxicity (WET) testing. The results of WET testing submitted with the permi t application showed no acute or chronic toxicity for samples collected in September /October 2010 and January 2011. Based on this information, Ecology concluded that t he discharge does not have a reasonable potential to cause the loss of sensitive or important habitat, substantially interfere with existing or characteristic uses, res ult 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 p ortion 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 th e receiving water volume at lower depths in the mixing zone is not mixed with dischar ge. Similarly, because the discharge may stop rising at some depth due to density strati fication, 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 d ilution occurs as the plume rises and moves with the current. Ecology minimizes the size of mixing zones by requi ring 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 comple tely mixed with the receiving water in a shorter time. Ecology also minimizes the size of t he mixing zone (in the form of the dilution factor) using design criteria with a low p robability of occurrence. For example, Ecology uses the expected 95th percentile pollutant concentration, the 90th percentile background concentration, the centerline dilution f actor, and the lowest flow occurring once in every ten years to perform the reasonable p otential analysis. Because of the above reasons, Ecology has effective ly 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 maxi mum size restriction.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO 7. Acute mixing zone.

• The discharge/receiving water mixture must comply w ith acute criteria as near to the point of discharge as practicably attainable

. Ecology determined the acute criteria will be met a t 10% of the volume fraction of the chronic mixing zone.

• The pollutant concentration, duration, and frequenc y 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 cau se damage to the ecosystem. As described above, the toxicity of any pollutant d epends upon the exposure, the pollutant concentration, and the time the organism is exposed to that concentration. Authorizing a limited acute mixing zone for this di scharge assures that it will not create a barrier to migration. The effluent from t his 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 (b elow the rising effluent).

• Comply with size restrictions. The mixing zone authorized for this discharge compl ies with the size restrictions published in chapter 173-201A WAC.
8. Overlap of Mixing Zones. This mixing zone does not overlap another mixing zo ne. D. Designated uses and surface water quality criter ia Applicable designated uses and surface water qualit y 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 th e criteria applicable to this facility’s discharge. Washington updated the surface water criteria in 20 06 (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, theref ore 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

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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 ge ometric 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) obta ined 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 desig nations are somewhat equivalent to the Class A designation of surface water in the older version o f 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 i mpaired 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 Potho les Reservoir that are further downstream in the system are listed.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Figure 6: Frenchman Hills Wasteway and Potholes Re servoir

Both waterbodies are listed as a category 5 which m eans the waters are impaired by a pollutant and needs a TMDL. The listed parameters for each ar e: 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 d ischarge and the wasteway and reservoir is large and the influence of the discharge on these w ater bodies is most likely neglible. In October 1998, EPA approved a seasonal TMDL for t he receiving water (DW237 and W645) for BOD, ammonia nitrogen, and fecal coliforms. Sea sonal limits were determined in recognition that flows in the receiving water varies with the i rrigation season. Ecology determined the TMDL values for BOD and ammo nia (Pelletier, 1994) using the QUAL2E model developed by EPA. Calibration and veri fications were done using data from a receiving water study (CH 2 M 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 equate s to the following uses: water supply (domestic, industrial, agricultural); stock waterin g; fish migration; fish rearing, spawning and harvesting; wildlife habitat; primary contact recre ation; 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 al l uses. Quincy Industrial discharge Potholes Reservoir

Frenchman Hills WastewayFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO F. Evaluation of surface water quality-based efflue nt limits for numeric criteria Pollutants in an effluent may affect the aquatic en vironment 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 pollu tant 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 c alculating surface water quality-based effluent limits varies with the point at which the pollutant has its maximum effect. With technology-based controls (AKART), predicted p ollutant concentrations in the discharge exceed water quality criteria. Ecology t herefore authorizes a mixing zone in accordance with the geometric configuration, flow r estriction, and other restrictions imposed on mixing zones by chapter 173-201A WAC. A mixing zone is authorized for each season in acco rdance 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 dow nstream from the effluent’s entry into drain DW237; 25% of the stream flow shall be a llowed to meet chronic criteria and 2.5% of the flow shall be allowed to meet acute cri teria. Ecology determined the seasonal dilution factors fo r the receiving water (Pelletier, 1994) based on chemical and flow data measured during a r eceiving water study (CH 2 M 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 disc harge 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--BOD 5 and Ammonia Effects-- Natural decomposition of organic material in wastewater effluent impacts dissolved o xygen in the receiving water at distances far outside of the regulated mixing zone.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO The 5-day Biochemical Oxygen Demand (BOD 5 ) of an effluent sample indicates the amount of biodegradable material in the wastewater and est imates the magnitude of oxygen consumption the wastewater will generate in the rec eiving water. The amount of ammoniabased nitrogen in the wastewater also provides an i ndication of oxygen demand in the receiving water. Ecology modeled the impact of BOD 5 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 modelin g, Ecology determined that this dissolved oxygen concentration would protect the beneficial u ses 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 Pelleti er were updated by Ecology during the preparation of the 1996 discharge permit to ref lect 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 becau se of the high buffering capacity of marine water.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Fecal Coliform - Under critical conditions, modeling predicted no vi olation of the water quality criterion for fecal coliform; Pelletier, 19 94. Therefore, the proposed permit retains the current daily maximum limit of 50/100 mL, which Eco logy 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 whe never 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 fr om 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 chl orine 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 173-20 1A-200-210 and 600- 612) include multiple elements:

• Annual summer maximum threshold criteria (June 15 t o 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 d etermine reasonable potential and derive permit limits.

• Annual summer maximum and supplementary spawning/re aring criteria Each water body has an annual maximum temperature c riterion [WAC 173-201A200(1)(c), 210(1)(c), and Table 602]. These thresh old criteria (e.g., 12, 16, 17.5, 20°C) protect specific categories of aquatic life by cont rolling 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 speci fic date-windows. The threshold criteria apply at the edge of the chr onic mixing zone. Criteria for most fresh waters are expressed as the highest 7-Day ave rage of daily maximum temperature (7-DADMax). The 7-DADMax temperature is the arithm etic average of seven consecutive measures of daily maximum temperatures. Criteria for marine waters and some fresh waters are expressed as the highest 1-Da y annual maximum temperature (1- DMax).

• Incremental warming criteriaFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO The water quality standards limit the amount of war ming 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 m ixing 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 i s being exceeded due to natural conditions, all human sources, considered cumulativ ely, must not warm the water more than 0.3°C above the naturally warm condition. When Ecology has not yet completed a TMDL, our poli cy allows each point source to warm water at the edge of the chronic mixing zone b y 0.3°C. This is true regardless of the background temperature and even if doing so wou ld cause the temperature at the edge of a standard mixing zone to exceed the numeric thr eshold criteria. Allowing a 0.3°C warming for each point source is reasonable and pro tective 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 cu mulative allowance (0.075°C or less) for all human sources combined.

• Protections for temperature acute effects Instantaneous lethality to passing fish: The upper 99 th 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: Measurab le (0.3°C) increases in temperature at the edge of a chronic mixing zone are not allowed w hen the receiving water temperature exceeds either a 1DMax of 23°C or a 7DADMax of 22°C

. Lethality to incubating fish: Human actions must n ot cause a measurable (0.3°C) warming above 17.5°C at locations where eggs are in cubating. The 2005 upgrade of the treatment facility included the construction of a cooling tower to reduce the temperature of the effluent during the s ummer months. Ecology determined a reasonable potential to exceed the water quality cr iteria 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 co oling tower was based on meeting an effluent temperature of 22.5 ° C during the summer. Ecology determined this temper ature limit based on meeting the Class AA water quality a t 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

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April 30, 2012 D. Nichols/ERO The current water quality standards require that an y surface water that does not have defined designated uses, such as DW237 and W645W, must be p rotected for, “Salmonid spawning rearing, and migration; primary contact recreation; domestic, industrial, and agricultural water supply; stock watering; wildlife habitat; har vesting; commerce and navigation; boating; and aesthetic values” . In addition, because the wa steways ultimately discharge to the Potholes Reservoir, the permit must also protect “c ore summer salmonid habitat; and extraordinary primary contact recreation” because t he 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 w asteway 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 requi re 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 num eric 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 (4 0 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 chem icals of concern based on existing effluent data or knowledge of discharges to their s ystem. Ecology will reevaluate this discharge for impacts to human health at the next p ermit reissuance. H. Whole effluent toxicity The water quality standards for surface waters forb id discharge of effluent that has the potential to cause toxic effects in the receiving w aters. Many toxic pollutants cannot be measured by commonly available detection methods. However, laboratory tests can measure toxicity directly by exposing living organisms to t he wastewater and measuring their responses. These tests measure the aggregate toxic ity of the whole effluent, so this approach is called whole effluent toxicity (WET) testing. S ome 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 Januar y 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 a re 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-aerati on site (Figure 2).Fact Sheet for NPDES Permit WA002106-7

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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 Effl uent 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, Commen t #1 from the Bureau of Reclamation for changes to this table)Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Table 13: Comparison of Previous and Proposed Effl uent 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, Commen t #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 disc harge treated wastewater from its industrial wastewater treatment facility to the bureau’s waste way 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 c oncentration of the discharge shall not exceed 15 mg/l.Fact Sheet for NPDES Permit WA002106-7

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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 li mit required in the Bureau/city agreement. Ecology will reissue the permit based on its approval of the City’s treatment facil ity providing AKART (all known available and reasonable methods o f treatment) as required by RCW 90.48. That AKART is protective of water quality and the p ermit’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 i n General Condition G6 of the permit. A second condition of the agreement is the limitati on 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 indu strial wastewater facility. The industrial wastewater facility has been upgraded (flow equaliz ation basin) not to exceed the 3.23 MGD limit. In recognition of the difference in the bas is 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, Comm ent #1 from the Bureau of Reclamation for the addition of this language to th e fact sheet.)



### IV. Monitoring Requirements Ecology requires monitoring, recording, and reporti ng (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 laborat ory 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, CO D, nitrate, nitrite, pH, total residual chlorine, TSS, fecal and total coliforms. B. Effluent limits which are near detection or quan titation levels The water quality-based effluent concentration limi ts for total residual chlorine are near the limits of current analytical methods to detect or a ccurately quantify. The method detection level (MDL) is the minimum concentration of a pollu tant that a laboratory can measure and report with a 99 percent confidence that its concen tration 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 lev el of error. Estimated concentrations are the values between the MDL and the QL. Ecology req uires permitted facilities to report estimated concentrations.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO When reporting maximum daily effluent concentration s, Ecology requires the facility to report “less than X” where X is the required detect ion level if the measured effluent concentration falls below the detection level. Whe n calculating average monthly concentrations, the facility must use all the efflu ent concentrations measured below the quantitation level but above the method detection l evel.



### 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 rec ord keeping) B. Spill plan This facility stores sodium hypochlorite (12.5%) an d 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 ident ified any other chemicals or materials stored on site that have the potential to cause wat er pollution if accidentally released. Ecology can require a facility to develop best mana gement plans to prevent this accidental release [Section 402(a)(1) of the Federal Water Pol lution 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 diges ter in late 2011, it will discontinue use of the primary treatment facility (clarifiers and s ludge vacuum filter). Thereafter, the facility will generate solid wastes from the digester and SB R’s. The proposed permit requires an update to the O&M manual that includes the new dige ster 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 stat e and federal regulations [40 CFR 122.41(e) and WAC 173-220-150 (1)(g)]. The facilit y has prepared and submitted an operation and maintenance manual (City of Quincy, 2 005) 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 complianc e with the terms and limits in the permit. The proposed permit will require the manual to be u pdated to include:
1. The O&M of the anaerobic digester including the man agement of solid wastes.
2. Management of solid wastes from the SBRs.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO 3. Any specific handling requirements of the brine wat er and disposal requirements brine residue after evaporation. E. Leak Detection
SBRs EMC submitted the most recent leak detection plan f or the SBRs in 2010 in a one page document that includes the complete draining of eac h basin, a visual inspection followed by an electronic leak detection survey. The facility h as not completed the first inspection/survey scheduled for February/March 2011. Ecology understands the difficulty in taking the SB Rs 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 wit h 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 out puts; 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 i n the biogas is due to leakage. EMC defined a significant loss as greater than 0.25 inc hes over the five days, or 5000 gallons per day. The plan identifies a list of actions to compl ete if/when this occurs. An experienced vendor installed the single 60-mil l iner and completed an electronic leak survey following installation. The structure includ es 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 o f Reclamation Wasteway DW237, W645W, and W645 As described previously, the City/EMC must terminat e the discharge of treated process wastewater from the industrial treatment facility t o 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 associ ated 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 discharg e of treated and disinfected wastewater to the U.S. Bureau of Reclamation wasteway until Oc tober 1, 2015. The City/EMC must submit an application for the discharge of the wast ewater after October 2015. To allow Ecology sufficient time to reissue the per mit, 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

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April 30, 2012 D. Nichols/ERO H. Engineering Report – Update The termination of the discharge of process wastewa ter to the bureau’s wasteway in 2015 will most likely require changes to the infra-struc ture of the treatment system. The proposed permit requires the City/EMC to submit an updated e ngineering 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 per mit. Plans and Specifications The City and EMC will be required to submit for rev iew and approval plans and specifications for the removal of the industrial wa stewater discharge to the bureau’s wasteway. I. General conditions Ecology bases the standardized General Conditions o n state and federal law and regulations. They are included in all individual industrial NPDE S 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 se diment quality standards, or with water quality standards for ground waters, after obtainin g 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 require ments for Ecology to authorize a wastewater discharge. The permit includes limits an d 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

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### 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 Trea tment Facility 2005 Process Upgrades Operations & Maintenance Manual, Final. December
Earth Tech.
2005. Amendment to Engineering, 2005 Process Upgrades, Qu incy, Washington Industrial Wastewater Treatment Facility . February.
2000. Amendment to City of Quincy Industrial Wastewater T reatment Facility Engineering Report / Facility Plan Water Quality Ba sed Effluent Limitations . October. Environmental Management Corporation.
2011. Quincy Industrial Facility – Revised Lagoon #2 Line r 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, Decemb er 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 Faci lity Engineering Report, Facilities Plan, Water Quality-Based Effluent Limit ations Compliance, October. Pelletier, Greg.
1994. BOD Loading from Quincy Industrial Wastewater Treat ment 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

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### 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 Se ptember 28 and October 5, 2011 in the Columbia Basin Herald to inform the public about th e 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 o n the proposed draft National Pollutant Discharge Elimination System permit and fact sheet.
The notice:

• Tells where copies of the draft Permit and Fact She et 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 for mat 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 a bout 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

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### Appendix B - Your Right to Appeal You have a right to appeal this permit to the Pollu tion Control Hearing Board (PCHB) within 30 days of the date of receipt of the final permit. T he appeal process is governed by chapter 43.21B RCW and chapter 371-08 WAC. “Date of receipt” is d efined 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 Ecol ogy in paper form - by mail or in person. (See addresses below.) E-mail is not accepted. You must also comply with other applicable requirem ents 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 98504-0903Fact Sheet for NPDES Permit WA002106-7

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### 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 calib rated maximum/minimum thermometers or continuous monitoring probes having sampling int ervals of thirty minutes or less. 7-DADMax or 7-day average of the daily maximum temp eratures -- The arithmetic average of seven consecutive measures of daily maximum temp eratures. 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 th at occurs in a short time period, usually 48 to 96 hours.
AKART -- The acronym for “all known, available, and reas onable methods of prevention, control and treatment.” AKART is a technology-base d approach to limiting pollutants from wastewater discharges, which requires an engineerin g judgment and an economic judgment. AKART must be applied to all wastes and contaminant s prior to entry into waters of the state in accordance with RCW 90.48.010 and 520, WAC 173-2 00-030(2)(c)(ii), and WAC 173- 216-110(1)(a). Ambient water quality -- The existing environmental condition of the wat er in a receiving water body.
Ammonia -- Ammonia is produced by the breakdown of nitroge nous materials in wastewater. Ammonia is toxic to aquatic organisms, exerts an ox ygen demand, and contributes to eutrophication. It also increases the amount of ch lorine needed to disinfect wastewater. Annual average design flow (AADF -- average of the daily flow volumes anticip ated to occur over a calendar year. Average monthly discharge limit -- The average of the measured values obtained ove r a calendar month's time. Best management practices (BMPs) -- Schedules of activities, prohibitions of practices, maintenance procedures, and other physical, structu ral and/or managerial practices to prevent or reduce the pollution of waters of the state. BM Ps include treatment systems, operating procedures, and practices to control: plant site r unoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. B MPs may be further categorized as operational, source control, erosion and sediment c ontrol, and treatment BMPs.
BOD 5 -- Determining the five-day Biochemical Oxygen Dem and of an effluent is an indirect way of measuring the quantity of organic material p resent in an effluent that is utilized by bacteria. The BOD 5 is used in modeling to measure the reduction of di ssolved oxygen in receiving waters after effluent is discharged. Str ess caused by reduced dissolved oxygen levels makes organisms less competitive and less ab le to sustain their species in the aquatic environment. Although BOD 5 is not a specific compound, it is defined as a con ventional 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

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April 30, 2012 D. Nichols/ERO Chlorine -- A chemical used to disinfect wastewaters of pat hogens 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 to xicity 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 e nacted by Public Law 92-500, as amended by Public Laws 95-217, 95-576, 9 6-483, 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 sampli ng or by mixing discrete samples. May be "time-composite" (collected at constant time int ervals) or "flow-proportional" (collected either as a constant sample volume at time interval s proportional to stream flow, or collected by increasing the volume of each aliquot as the flo w increased while maintaining a constant time interval between the aliquots). Continuous monitoring -- Uninterrupted, unless otherwise noted in the pe rmit.
Critical condition -- The time during which the combination of receiv ing water and waste discharge conditions have the highest potential for causing toxicity in the receiving water environment. This situation usually occurs when th e 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 busi ness days after the date of mailing; or the date of actual receipt, when the ac tual receipt date can be proven by a preponderance of the evidence. The recipient's swor n affidavit or declaration indicating the date of receipt, which is unchallenged by the agenc y, constitutes sufficient evidence of actual receipt. The date of actual receipt, however, may n ot 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 a nd receiving water that occurs at the boundary of the mixing zone. Express ed as the inverse of the percent effluent fraction, for example, a dilution factor of 10 mean s the effluent comprises 10% by volume and the receiving water 90%. Engineering report

-- A document that thoroughly examines the enginee ring and administrative aspects of a particular domestic or industrial wast ewater 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. Pathog enic bacteria in wastewater discharges are controlled by disinfecting the wastewater. The pre sence of high numbers of fecal coliform bacteria in a water body can indicate the recent re lease of untreated wastewater and/or the presence of animal feces. Grab sample -- A single sample or measurement taken at a speci fic time or over as short a period of time as is feasible.Fact Sheet for NPDES Permit WA002106-7

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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 wastewa ter in character.
Industrial wastewater -- Water or liquid-carried waste from industrial o r commercial processes, as distinct from domestic wastewater. These wastes may result from any process or activity of industry, manufacture, trade or business; from t he development of any natural resource; or from animal operations such as feed lots, poultry h ouses, or dairies. The term includes contaminated storm water and, also, leachate from s olid waste facilities. Maximum daily discharge limit -- The highest allowable daily discharge of a poll utant measured during a calendar day or any 24-hour perio d 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 occu r 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 d aily average. Maximum week design flow (MWDF ) -- The largest volume of flow anticipated to occu r during a continuous 7-day period, expressed as a da ily average. Method detection level (MDL) -- The minimum concentration of a substance that c an be measured and reported with 99 percent confidence th at 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 wi thin 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 regu lations (chapter 173-201A WAC). National pollutant discharge elimination system (NP DES) -- The NPDES (Section 402 of the Clean Water Act) is the federal wastewater permitti ng system for discharges to navigable waters of the United States. Many states, includin g the state of Washington, have been delegated the authority to issue these permits. NP DES 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 alka linity. 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 aqu atic 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 requireme nt 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

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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 gi ve a recognizable signal and acceptable calibration point for the analyte. It is equivalen t 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 multipl ying the MDL by 3.18 and rounding the result to the number nearest to (1,2,or 5) x 10 n , where n is an integer. (64 FR 30417). ALSO GIVEN AS: The smallest detectable concentration of analyte gr eater than the Detection Limit (DL) where the accuracy (precision & bias) achieves the object ives of the intended purpose. (Report of the Federal Advisory Committee on Detection and Qua ntitation Approaches and Uses in Clean Water Act Programs Submitted to the US Enviro nmental 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-pres ident of the corporation in charge of a principal business funct ion, or any other person who performs similar policy- or decision-making functions for th e corporation, or the manager of one or more manufacturing, production, or operating facili ties 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 a ssigned 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 discha rge to the POTW. This may include any pollutant released at a flow rate that may cause in terference 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 s emisolid wastes including, but not limited to, garbage, rubbish, ashes, industrial was tes, swill, sewage sludge, demolition and construction wastes, abandoned vehicles or parts th ereof, contaminated soils and contaminated dredged material, and recyclable mater ials.
Soluble BOD 5 -- Determining the soluble fraction of Biochemical Oxygen Demand of an effluent is an indirect way of measuring the quanti ty of soluble organic material present in an effluent that is utilized by bacteria. Although the soluble BOD 5 test is not specifically described in Standard Methods, filtering the raw sa mple through at least a 1.2 um filter prior to running the standard BOD 5 test is sufficient to remove the particulate organ ic fraction.
State waters -- Lakes, rivers, ponds, streams, inland waters, u nderground waters, salt waters, and all other surface waters and watercourses withi n the jurisdiction of the state of Washington.
Stormwater -- That portion of precipitation that does not natu rally 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

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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 enumer ates the total coliform group of bacteria in water samples.
Total dissolved solids -- That portion of total solids in water or wastewa ter that passes through a specific filter. Total suspended solids (TSS) -- Total suspended solids is the particulate mater ial in an effluent. Large quantities of TSS discharged to a receiving w ater may result in solids accumulation. Apart from any toxic effects attributable to substa nces leached out by water, suspended solids may kill fish, shellfish, and other aquatic organis ms by causing abrasive injuries and by clogging the gills and respiratory passages of vari ous aquatic fauna. Indirectly, suspended solids can screen out light and can promote and mai ntain the development of noxious conditions through oxygen depletion. Upset

-- An exceptional incident in which there is unintenti onal and temporary noncompliance with technology-based permit effluent limits becaus e of factors beyond the reasonable control of the Permittee. An upset does not includ e noncompliance to the extent caused by operational error, improperly designed treatment fa cilities, lack of preventative maintenance, or careless or improper operation. Water quality-based effluent limit -- A limit imposed on the concentration of an effl uent parameter to prevent the concentration of that para meter from exceeding its water quality criterion after discharge into receiving waters.Fact Sheet for NPDES Permit WA002106-7

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### Appendix D - Technical Calculations Several of the Excel® spreadsheet tools used to eva luate a discharger’s ability to meet Washington State water quality standards can be fou nd on Ecology’s homepage at http://www.ecy.wa.gov/programs/eap/pwspread/pwsprea d.html

.

Performance-based TSS limits – Summer (April – Octo ber)

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 MONI TORING = 2

AUTOCORRELATION FACTOR( n e)(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 – M arch)

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 MONI TORING = 2

AUTOCORRELATION FACTOR( n e)(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 = 72.354Fact Sheet for NPDES Permit WA002106-7

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### 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 t o this fact sheet.

DRAFT PERMIT COMMENTS
Comment 1: Reporting and Recordkeeping
The District requests that the Reporting and Record keeping Requirements section of the draft permit be updated to include mailing and email addr esses 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 recordkee ping requirements, Reporting) has the district’s mailing address for all monthly discharg e monitoring reports. Ecology has edited this section of the permit to require the city to b egin submitting electronic DMRs by September 2012. Until then the city will continue t o 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/wwdischargepermi ts.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 thi s 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 immediatel y report failures of the disinfection system and collection system overflows. Quincy-Columbia Basin Irrigation District: 509.787 .3591Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Comment3: A correction should be noted regarding the “receivi ng Water” and “Water Quality Impairments” as described in the permit. Treated wa ter 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 te mperature. Response to Comment 3 Ecology has added language to the following section s 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 Po tholes Reservoir.
2. Section E (Water quality impairments) has been edit ed to show a map of the drainage area and the location of the 303(d) listed waterbod ies; Frenchman Hills and Potholes Reservoir.

Bureau of Reclamation Response to Comments on the D raft NPDES Permit No. WA-0021067-7 and associated Fact Sheet

A copy of the original comment letter is attached t o this fact sheet.

DRAFT PERMIT COMMENTS

Comment 1: The volume of water being discharged by the IWTF in to 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, Ecolo gy also allows for a monthly average of 4.89 MGD. The 3.23 MGD should not be exceeded fo r 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 de mand (BOD) in the permit and fact sheet are set at 51.1 mg/L in the summer and 65 mg/L in the w inter, 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 B OD in the effluent.

Response to Comment 1:
Section III.J of the fact sheet will be edited to r eflect the following:Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Ecology is aware of the contract between the city a nd 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, Ecol ogy 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 an y 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 agreeme nt. 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 oper ated to not exceed the 3.23 MGD effluent limit. The city has installed a flow equalization b asin 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 sh ow the design value of 4.89 MGD.

Comment 2:
Reclamation would like to reiterate its concerns wi th 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. Re clamation also feels the acceptable volume of leakage from the brine ponds could impact the gr oundwater 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 approximatel y 300ft from the West Canal. This is well beyond the right of way for the West Canal. Each po nd 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 vo lume of water in the standpipes, and 4/year testing of the collected water. The monitoring prov ides an indicator of potential issues. In addition, both ponds were built below grade so ther e is no chance of breaching. Additionally, both ponds were built according to Ecology’s guidan ce for storage ponds.

Comment 3: Reclamation is concerned that no groundwater and so il sampling/monitoring has been included in the NPDES Permit requirements. Reclamation belie ves 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 sat urated 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 in to irrigation water (the groundwater beneath the ponds) may impact crop production in the surrou nding area and possibly downstream. OtherFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO monitoring Reclamation feels is being overlooked fo r 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 Nitr ogen (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 nutri ents in the effluent. It is Ecology’s position that the double lined leak detection construction of bot h brine ponds makes the potential for groundwater and soil impacts from the ponds very mi nimal. The leak detection system monitoring can alert EMC of a potential problem wit h 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 bas in (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 infor mation 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 indust rial effluent discharges. Ecology is unaware of any nutrient related problems in the wasteway do wnstream of the point of discharge. It is Ecology’s understanding that the nutrient load in t he 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 con tributed from the discharge would be managed by the current operations and maintenance o f the wasteway.
Comment 4 : Reclamation is very interested in the spill plan th e Data Centers and the City are engineering. If a spill or leak from the conveyance system of the bri ne 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 deminerali zation facilities will be truck transported to the ponds. Until the brine water is piped to the po nds, Ecology will not require a spill plan. Ecology will require an Engineering Report and desi gns 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 p lan 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 fede ral facilities in the region. Response to Comment 5:Fact Sheet for NPDES Permit WA002106-7

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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 discharg e 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 Reclamati on 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 b y the Permittee, it can be viewed and downloaded by the public. Ecology will edit Section S3 of the permit to add u pdated permit shell language that requires the Permittee to begin using WAWebDMR by September 1, 2 012. Until then, paper copies of the DMRs shall be sent to the Bureau and Irrigation Dis trict. The Bureau and Irrigation District can access the W AWebDMR data from Ecology’s main permit tracking system (PARIS) at: http://www.ecy.wa.gov/programs/wq/permits/wwdischar gepermits.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 t o this fact sheet.

DRAFT PERMIT COMMENTS

Comment 1: The draft permit identifies a new summer outfall TS S 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 up grades since the last permit cycle to address the lower effluent TSS permit requiremen ts.
2. Based on the Facility Loading Design Monthly Maximu m of 66,400 lbs/day and the lower permit parameter for daily maximum daily disc harge of 3,071 lbs/day. The new parameter requires the IWTP to operate at a 95 perc ent reduction rate.Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO 3. Algae can grow in the EQ basin after the SBR proces s during low flow periods typically occurring in the summer months. The lower TSS param eter may require capital improvement by the city to meet the new discharge l imit. Accordingly, the draft NPDES permit should be revis ed to reflect the current permit TSS parameters. Response to Comment 1: Ecology will not change the summer season limits fo r TSS. Figure 3 and 4 in the Fact Sheet compares the updat ed limits to values reported in the DMRs during the current permit cycle. The IWTP would hav e exceeded the updated maximum and average summer TSS concentration and load limits on ce during the last permit cycle. There is every indication the IWTP can comply with updated s ummer limits. With regards to algae growth contributing to the TS S concentration in the effluent, Ecology suggests the Permittee make note of this in the mon thly DMR. A digital picture of algal growth or other contributing factors to high TSS can be at tached to the WAWebDMR. The following formats can be attached to a WAWebDMR: ".xls", ".xl sx", ".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, “..t he Permittee is authorized to discharge wastewater with a TDS concentration in excess of 50 0 mg/L from the local industries to the non discharging lined brine ponds located on the indust rial 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 bri ne 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, th e 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 l asting through the expiration date, brine water from the Microsoft – Columbia Data Cent er’s ion exchange demineralization process/reverse osmosis system, and from brine wast es 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 i s located at the Microsoft

– Columbia Data Center

to non discharging lined brine ponds located on th e industrial wastewater facility site.

Comment 3: Special Condition S8Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/ERO Permittee should be changed from “EMC” to the “Ci ty of Quincy”. This requirement would be a City of Quincy responsibility as owner of the fac ility – 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 t hroughout 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 sectio n. EMC should not be a party to this requirement. EMC is the contract operator of the IW TP, not the owner. Response to Comment 4: Based on the response to Comment 3, Ecology will ed it 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 sectio n. EMC should not be a party to this requirement. EMC is the contract operator of the IW TP, not the owner. Response to Comment 5: Based on the response to Comment 3, Ecology will ed it the language in S9.A to read: “The Permittee T he 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 facil ity. 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

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April 30, 2012 D. Nichols/ERO •Fact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/EROFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/EROFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/EROFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/EROFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/EROFact Sheet for NPDES Permit WA002106-7

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April 30, 2012 D. Nichols/EROFact Sheet for NPDES Permit WA002106-7

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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 vio lation 4/1/2007 Flow Maximum MGD 3.55 - 3.23 Numeric effluent vio lation 6/1/2007 Flow Maximum MGD 3.24 - 3.23 Numeric effluent vio lation 7/1/2007 Flow Maximum MGD 3.24 - 3.23 Numeric effluent vio lation 8/1/2007 Flow Maximum MGD 3.24 - 3.23 Numeric effluent vio lation

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 Nume ric effluent violation 12/1/2007 Ammonia, Total Average Lbs/Day 51.1 - 48.2 Numer ic 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) 1.3 9 - 1.19 Numeric effluent violation 11/1/2010 Ammonia, Total Maximum Lbs/Day 297.8 - 96.7 Nume ric 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 - - - Analysi s not Conducted

Fig. 1 Summer season effluent pH compliance

0 2 4 6 8 10 12

max summer
min summer
max limit

mim limitFact Sheet for NPDES Permit WA002106-7

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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 LIMITFact Sheet for NPDES Permit WA002106-7

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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