Fact Sheet For

NPDES Permit No. OHW000004 Ohio EPA Permit No. 5IGW0004

Ohio Environmental Protection Agency

Fact Sheet For

National Pollutant Discharge Elimination System (NPDES)

General Permit for Discharges from Water Treatment Plants

I. Background

The Federal Water Pollution Control Act [also referred to as the Clean Water Act (CWA)], the Ohio Water Pollution Control Act and the Ohio Revised Code (ORC Chapter 6111) provide that discharge of pollutants to waters of the state from any point source is unlawful, unless the discharge is in compliance with an effective NPDES permit.

The purpose of issuing NPDES permits to water treatment plant operators is to ensure that any wastewater discharges from these systems are in compliance with all applicable state and federal water pollution control laws.

Wastewaters are generated while producing potable water in water treatment plants. During normal operations, the common types of wastewaters from water plants and the processes that generate them are (a) clarifier sludge blowdown and particulate filter backwash from plain purification and lime-soda softening process, (b) iron filter backwash wastewater from iron and manganese removal process, and (c) wastewater containing dissolved solids from sodium cycle ion-exchange processes and reverse osmosis processes. During times when harmful algal blooms (HABs) enter the plant above threshold values, plant operators change operations in ways that increase discharge volumes or cause pollutants to be discharged that would not normally be discharged.

Ohio EPA has elected to renew the existing statewide general permit authorizing the discharge of wastewater from water treatment systems to waters of the State. Dischargers which meet the eligibility requirements may apply for coverage under this NPDES general permit instead of seeking coverage under an individual NPDES permit. The eligibility requirements of the permit (Part I of the general permit) define which discharges can be covered.

Discharge limitations are listed in Part V of this fact sheet. Draft changes to the permit are described in Part VI.

Discharge limitations and Best Management Practices are listed in Part VII of this fact sheet. The general permit is intended to cover any eligible water treatment system discharge that was designed to meet these limits and that would consequently have a minimal impact on the environment.

II. Antidegradation

Because this permit does not authorize new discharges of pollutants to waters of the State, this permit is not applicable to the Antidegradation Rule in Ohio Administrative Code (OAC) 3745-1-05. Regardless of the water treatment system, these facilities are expected to discharge total suspended solids (TSS) and

1 total residual chlorine to surface waters of the state. Depending on the processes in the water treatment system, the discharge is expected to contain significant quantities of halomethanes, total recoverable copper, suspended iron, suspended manganese, total dissolved solids, algal toxins, and/or organic carbon.

III. Description of General Permit Coverage and Type of Discharge

The permit covers discharges from three water treatment system processes to waters of the State. These three processes include:  Plain Purification Processes;  Lime-Soda Softening Processes; and  Iron/Manganese Removal Processes.

Discharges from these types of plants can meet all applicable NPDES requirements through treatment technology limits, or broadly set water quality limitations. See Attachment A for the definitions of these processes.

For these three processes, HAB-related water treatment plant discharges are also covered under this permit. HAB-related water treatment plant discharges are generated to minimize concentration of HAB toxins in the drinking water supply. For example, plant operators often increase filter backwash discharge to prevent toxins from being recycled to the head of the plant and potentially into the water system. This operational change causes increased volumes of discharge to receiving waters and can add pollutants such as algal toxins (i.e. microcystin) and organic carbon that the plant does not normally discharge as authorized under the existing permit.

Discharges from Ion Exchange Processes and Reverse Osmosis Processes require individual permits because site-specific water quality-based limitations for total dissolved solids, and possibly other related pollutant parameters, will be needed. Individual NPDES permits may be obtained by submitting individual permit applications (Form 1, Form 2D or 2E, and an Antidegradation Addendum) available through Ohio EPA’s eBusiness Center (https://ebiz.epa.ohio.gov/login.html) or Ohio EPA’s website (http://www.epa.ohio.gov/dsw/permits/npdesform.aspx) .

IV. Procedures for Participation in the Formulation of Final Determinations

The draft action shall be issued as a final action unless the Director revises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the Administrator of the U.S. Environmental Protection Agency.

Within thirty days of the date of the Public Notice, any person may request or petition for a public meeting for presentation of evidence, statements or opinions. The purpose of the public meeting is to obtain additional evidence. Statements concerning the issues raised by the party requesting the meeting are invited. Evidence may be presented by the applicant, the state, or other parties, and following presentation of such evidence, other interested persons may present testimony of facts or statements of opinion.

Requests for public meetings shall be in writing and shall state the action of the Director objected to, the questions to be considered, and the reasons the action is contested. Such requests should be addressed to:

DSW Permits Processing Unit Ohio Environmental Protection Agency P.O. Box 1049 Columbus, Ohio 43216-1049

Interested persons are invited to submit written comments upon the discharge permit. Comments should be submitted in person or by mail no later than 30 days after the date of this Public Notice. Deliver or mail all comments to:

Ohio Environmental Protection Agency Attention: Division of Surface Water Permits and Compliance Section P.O. Box 1049 Columbus, Ohio 43216-1049

The OEPA permit number and Public Notice numbers should appear on each page of any submitted comments. All comments received no later than 30 days after the date of the Public Notice will be considered.

Citizens may conduct file reviews regarding specific companies or sites. Appointments are necessary to conduct file reviews, because requests to review files have increased dramatically in recent years. The first 250 pages copied are free. For requests to copy more than 250 pages, there is a five-cent charge for each page copied. Payment is required by check or money order, made payable to Treasurer State of Ohio.

For additional information about this fact sheet or the draft permit, contact Phoebe Low, (614) 644-2134, [email protected].

V. Description of Application Process

Notice of Intent (NOI) – Each facility seeking coverage under this general permit must submit a NOI form. Individuals with an existing discharge who intend to obtain coverage for wastewater discharges under this general permit shall submit an NOI form within 45 days of the effective date of this permit.

An applicant will not be covered under the general permit until they receive written notification from the Director of Ohio EPA that a discharge is authorized under the general permit. Dischargers who fail to obtain coverage under the general permit and are not otherwise covered by a NPDES permit are in violation of Ohio Revised Code (ORC) 6111.

Federal regulations found in 40 CFR 122.21(a) exclude persons covered by general permits from requirements to submit an application for an individual permit.

NOI requirements are intended to establish a mechanism that can be used to establish a clear accounting of the number of permittees covered by the general permit, the identities, locations, mailing addresses, and nature of discharge. The NOI application form and instructions for completing the form are available on the following internet website by clicking on "Applying for Coverage": http://www.epa.ohio.gov/dsw/permits/gpfact.aspx

Completed NOI application shall be submitted through the Ohio EPA eBusiness Center Division of Surface Water NPDES Permit Application STREAMS service in the link below. https://ebiz.epa.ohio.gov/login.html

For facilities that discharge water treatment plant wastewater through a municipal separate storm sewer system (MS4) shall also submit a signed copy of the NOI to the operator of the MS4. More details are included in Part II.D of this general permit.

Application Fee – All applicants must submit the $200 fee for NOI processing. Payment can be electronically submitted through the agency eBusiness Center ePay service. Instructions on submitting fee payments via the ePay service can be found in the link below. http://epa.ohio.gov/portals/35/edmr/doc/ePAYwalkthrough.pdf

VI. Eligibility Determining Factors

A. Except for discharges identified in paragraph B, this permit may cover discharges of wastewater from water treatment plants to waters of the State.

B. The following wastewater discharges associated with the production of potable water supplies (water treatment plants) are not eligible for coverage under this permit:

1. Wastewater discharges associated with ion exchange or reverse osmosis processes.1 This includes wastewater from plants using combined treatment of ion exchange and iron and manganese removal processes;

2. Discharges of suspended solids (excluding suspended solids from water treatment additives) to the Ohio River that may result in more than a five (5) percent 30-day net increase (excluding solids from additives) over the amount of suspended solids in the Ohio River intake;

3. Any discharge that has been previously authorized by an individual NPDES permit with a final effluent limitation or parameter that is not listed in the applicable table contained in Part III of this general permit with the exception of a loading limit, if any;

4. Wastewater discharges associated with water treatment plants during the process of producing potable water supplies that is mixed with another wastestream from the plant prior to reaching the receiving stream;

5. Wastewater discharges associated with water treatment plants during the process of producing potable water supplies that the Director has determined to be contributing to a violation of a water quality standard (WQS), as determined by OAC 3745-1;

6. Wastewater discharges associated with water treatment plants that are discharged to combined or sanitary sewers;

1 Discharges from these processes require individual permits because site-specific water quality-based effluent limitations will be needed for total dissolved solids and possibly other related pollutants.

7. Wastewater discharges associated with water treatment plants that treat concentrated arsenic streams which exceed the maximum contaminant level listed in OAC 3745-81-11(B)2 ;

8. Discharges to waters applicable to the seasonal salmonid habitat (SSH) use designation under OAC 3745-1-08 thru 32;

9. New point source discharges of wastewater associated with water treatment plants during the process of producing potable water supplies to waters of the state. New point sources are those sources that were constructed and discharging after July 1, 1993, and do not have an existing NPDES permit for the discharge of wastewater from water treatment plants;

10. Wastewater discharges that are not treated prior to discharge;

11. Wastewater discharges that take place within 500 yards of a surface water intake; and

12. HAB-related discharges from plants and/or operations which meet any of the criteria of Paragraph B of this section.

Discharges not eligible for coverage under this permit, or those seeking individual permit conditions for HAB-related discharges, may still obtain an individual NPDES permit by submitting individual permit applications (Form 1, Form 2D or 2E, and an Antidegradation Addendum) available through Ohio EPA’s eBusiness Center (https://ebiz.epa.ohio.gov/login.html) or Ohio EPA’s website (http://www.epa.ohio.gov/dsw/permits/npdesform.aspx) .

If discharging to a POTW with an approved pretreatment program which follows federal regulations and has been approved by Ohio EPA, the permittee shall obtain authorization from the POTW prior to discharge. If discharging to a POTW without an approved pretreatment program, the permittee shall submit an Indirect Discharge Permit Application to Ohio EPA preferably six months prior to the estimated date of initial discharge. The website below contains a list called “NPDES Permits of Approved Programs” and a page for “Forms for Indirect Discharge”. http://www.epa.ohio.gov/dsw/pretreatment/index.aspx .

VII. Effluent Limitations and Monitoring Requirements

Treatment-technology based limits The main pollutant common to all of the wastestreams covered by this general permit is TSS. All of the water treatment processes and associated wastewater processes are designed to remove suspended material from potable water and wastewater. Wastewater treatment plants at these facilities typically have clarifiers or equivalent settling technologies that can meet TSS limits that are roughly equivalent to secondary treatment levels. Except for Plain Purification Process wastewaters discharging to the Ohio River (Outfall 001), the current permit contains TSS limits of 30 mg/L (monthly average) and 45 mg/L (daily maximum) as the performance standard associated with secondary treatment levels.

During the Plain Purification Process, a plant’s discharge to the Ohio River may result in a slight increase in the amount of solids removed from the river. Water treatment plants that may result in more

2 As of September 2016, the maximum contaminant level for arsenic is 10 µg/L.

5 than five (5) percent net increase (measured over a 30-day period) in the amount of solids discharged to the river will not be covered by this general permit. See Attachment B for an example calculation of the solids net increase. For those existing plants, coverage by individual permits will continue.

Iron and manganese removal processes also have specific treatment standards of 1,000 µg/L (monthly average) and 2,000 µg/L (daily maximum) each for suspended iron and suspended manganese. These limits are representative of treatment standards applicable to all metals treatable by precipitation. The purpose of these limits is to ensure that metals are well treated and that nuisance concentrations are not discharged to receiving waters.

Water quality-based limits The permit contains water quality-based limits for chlorine and pH. Chlorine limits for plants discharging to low-flow streams (where the ratio of the receiving stream’s 7Q10 3 to average design discharge flow is less than 1:1) are based on outside-mixing zone maximum (OMZM) criteria applied at the discharge. This limit protects streams with zero critical flow and other small bodies of water. Wasteload allocations for chlorine default to IMZM standards when instream dilution ratios are 1:1 or greater. For lime-soda softening processes, an instream dilution ratio less than 3:1 is considered a low-flow stream and a ratio equal to or greater than 3:1 is considered a high-flow stream. This difference is due to the conditions involved in the pH modeling, as explained in the paragraph below.

The pH limits are generally WQS applied at the end of the pipe. For lime-soda softening processes, it may be difficult to meet maximum pH WQS at the discharge point. The permit provides a maximum pH limit based on a wasteload allocation for receiving waters with sufficient assimilative capacity to accept the higher pH wastewater and still meet WQS after mixing. Ohio EPA’s pH modeling gives a close approximation that shows an instream dilution ratio below 3:1 will result in a pH of 9.0 S.U. in the receiving water. Therefore, a 3:1 instream dilution ratio has been set as the criteria for allowing pH up to 11.0 S.U. Those facilities that fail to have a minimum instream ratio of 3:1 will have to meet pH of 9.0 S.U. at the end of the pipe. See Attachment C for an analysis of the dilution/assimilation needed to meet WQS for pH.

In the absence of water quality criteria for Trihalomethane (THM), monitoring for individual halomethane compounds is required. Individual halomethane compounds include bromodichloromethane (dichlorobromomethane), bromoform (tribromomethane), dibromochloromethane (chlorodibromomethane), chloroform, methyl bromide, methyl chloride (chloromethane), and methylene chloride. These compounds are byproducts from the halogenation of methane, which may be present in surface water intakes. Based on Ohio EPA’s experience with water treatment plants, annual monitoring is recommended because there is a low risk of THM formation in the wastewater. Monitoring for these compounds is recommended for plain purification and lime-soda softening systems because these processes usually use surface water as the water source. Monitoring for these pollutants are not required for iron/manganese removal systems because the water source for this process is groundwater, which does not contain significant amounts of methane and is therefore not likely to produce THM.

HAB-Related Water Treatment Plant Discharges The permit contains monitoring requirements which are triggered during HABs. For the purposes of this permit, the threshold for HABs at the intake (raw water sampling point) shall be equal to Ohio’s Elevated Recreational Health Advisory threshold.4 In response to this HABs, plant operators often change

3 Seven-day, 10-year low flow (7Q10) means the lowest seven-consecutive-day average flow expected to occur once every 10 years. The 7Q10 for a specific streams can be found in the United States Geological Survey StreamStats (version 4.0). 4 The threshold is 20 µg/L according to the “State of Ohio Harmful Algal Bloom Response Strategy for Recreational Waters” (2016) . This threshold level is subject to change.

6 operations, potentially increasing the amount of TSS, chlorine, and algal pollutant indicators (i.e. microcystin) in wastewater. Facilities may also discharge a certain amount of residuals from carbon used to adsorb algal toxins (activated carbon). Monitoring requirements at the effluent are dependent on the microcystin concentrations at the intake.

If an intake sample shows that algal concentrations in the wastewater are less than the threshold, monitoring shall continue at the frequency as instructed in Part III of the permit. However, if any intake sample shows microcystin above the threshold, the permittee is required to sample for pH, TSS, organic carbon, chlorine, and microcystin within 24 hours of receiving the intake results. Regardless of HAB- related discharges, treatment-technology based limits and water quality-based limits still apply.

Monitoring for pH, TSS, and chlorine are required specifically during HAB events to document how a plant’s changes in water treatment operations impact the wastewater discharge. Monitoring for total organic carbon is intended to detect activated carbon residuals which may be discharged due to powdered activated carbon treatment. Monitoring for microcystin is a measure of the remaining algal toxin and is relevant to attainment of recreation and agricultural water supply standards. Note that the draft permit specifies that effluent concentrations greater than the recreational threshold for microcystin shall be reported to Ohio EPA.

Ohio EPA Division of Surface Water, in conjunction with the Division of Drinking and Ground Waters, has developed Best Management Practices for discharges during HAB-related events. These controls are listed in Part IV of the draft permit. These are intended to ensure treatment of these wastewaters and prevent bypasses.

The Agency assumes that HAB events will be short-lived for most water treatment plants. Ohio EPA recognizes that a few water treatment plants have HAB-related discharges for the entire summer, or even an entire year. This permit is not directed at the latter facilities. The Agency intends to modify the individual permits for plants that have more frequent HAB-related discharges so that discharge-specific monitoring frequencies for HAB-related parameters can be set.

VIII. Changes from Current Permit

Requirements During HABs When microcystin is detected at the intake above Ohio’s recreational threshold levels, the facility shall take an additional sample for pH, TSS, organic carbon, chlorine, and microcystin. The permittee shall also notify Ohio EPA of any effluent discharges exceeding the threshold level for microcystin. During a HAB event, the plant is required to implement the Best Management Practices described in Part IV of the permit.

Annual Copper Monitoring Monitoring of copper shall be added to each outfall to verify that water quality standards at the receiving stream are met. Monitoring shall occur annually between the months June thru September. Monitoring for this parameter is only necessary for plants which add copper sulfate to the intake water as an algaecide.

Method Detection Levels (MDL) – Total Residual Chlorine, Copper, and Halomethane Compounds Part IV.H of the general permit shall require that total residual chlorine and halomethane compounds are analyzed with a lower MDL and set a standard for copper MDLs. For chlorine and copper, an analysis must have a MDL no higher than 0.010 mg/L and 3.0 µg/L, respectively. For halomethane compounds, the permit requires an MDL of 1.0 µg/L or lower. Based on the most recent five years of data, Ohio EPA has found that chlorine and halomethane compounds are not analyzed with an appropriate MDL. This change ensures that laboratory analyses are able to demonstrate compliance with water quality criteria

7 for human health and aquatic life.

Discharges to Waters with SSH Use Designation Discharges of wastewater associated with water treatment plants to waters with the SSH use designation shall not be covered under this permit. This change was made because the water quality standards in Table 7-1 of OAC 3745-1-07 prohibits the discharge of chlorine into waters applicable to the SSH use designations. The use designation of any receiving water within the state of Ohio is listed in OAC 3745-1-08 thru 32 in the link below. The rule chapters are organized based on the drainage basin, so Ohio EPA recommends the “Water Body Use Designation Index” to locate the rule chapter containing a receiving stream.

OAC 3745-1: http://www.epa.ohio.gov/dsw/rules/3745_1.aspx Water Body Use Designation Index: http://www.epa.ohio.gov/portals/35/rules/water_body_index.pdf

Outfall 001 – TSS Sampling and Reporting of Net Loads Sampling for TSS shall now consist of 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day. This change was made in order to obtain more accurate data. No changes were made to the monitoring frequency of TSS. In addition, the percentage of all net loads shall be reported through eDMR as a general comment.

Outfall 004 – Total Residual Chlorine Monitoring for this pollutant shall now be completed monthly instead of quarterly. Over the past five years, only one facility reported under this outfall. Although the data from this facility did not demonstrate reasonable potential to exceed WQS for chlorine, data from outfall 005 (also lime-soda softening) demonstrates that this process discharges significant amounts of chlorine. Based on best technical judgment, quarterly monitoring does not provide sufficient data to demonstrate compliance with WQS.

Outfall 005 – TSS, Total Residual Chlorine, and Total Dissolved Solids Monitoring for TSS and total residual chlorine are proposed to increase to a biweekly schedule because a majority of the facilities discharging through this outfall have demonstrated reasonable potential to exceed the WQS or have violated the limits of at least one of these pollutants (see Attachment D). Monitoring for total dissolved solids is proposed on a weekly basis because the lime-soda softening process is expected to discharge significant amounts of dissolved solids through the wastewater.

Outfall 006 and 007 – TSS, Iron, and Total Residual Chlorine Monitoring for TSS, total residual chlorine, and total suspended iron are proposed to increase to a biweekly schedule because all of the facilities discharging through outfall 006 have demonstrated reasonable potential to exceed the limit for total residual chlorine or have previously violated a limit for TSS and/or iron (see Attachment D). Based on best technical judgment, discharge from outfall 007 will be similar and should therefore require the same monitoring frequencies.

Outfalls 006 and 007 – Process Flow Ratios For total residual chlorine, OMZM criteria shall apply to dischargers with an instream ratio below 1:1 while IMZM criteria apply to dischargers with an instream ratio at or above 1:1. This change is a correction to the previous permit, which had determined the total residual chlorine limit based on whether or not the instream flow ratio exceeded 2:1.

Downstream Visual Inspection As required by Part IV, Item C of the permit, all iron/manganese removal and lime softening plants are required to conduct a routine inspection of the receiving stream downstream of the discharge point for any changes in color or turbidity and report the findings to Ohio EPA. This requirement is to ensure

8 compliance with the narrative WQS in Part V, Item J of the permit. The renewed permit now specifies that the findings shall be recorded through eDMR as a general comment.

Electronic Reporting Ohio EPA will no longer accept hard copies of the following forms from permittees: NOI forms, Notice of Termination (NOT) forms, and DMR forms. Instead, permittees are to submit these forms electronically through the Ohio EPA eBusiness Center at the website below. https://ebiz.epa.ohio.gov

Except for spills or discharge which may endanger human health or the environment, Ohio EPA will no longer accept noncompliance reports by telephone (refer to Part V.S. of the general permit). Instead, permittees are to submit noncompliance report forms via email to Ohio EPA. The contact information, notification timeframe, and other details can be found in Part V.S. of this general permit. The 24-Hour Emergency Hotline should still be contacted to report any spill or discharge which may endanger human health or the environment.

If permittees are unable to access these forms through the agency eBusiness Center due to a demonstrated hardship, these forms may be submitted on paper forms provided by Ohio EPA. The required information shall be typed on the forms. Permittees should contact Ohio EPA, Division of Surface Water at (614) 644-2001 if they wish to receive hard copies of forms.

Permittees now have the option of paying the NOI processing fee through Ohio EPA’s eBusiness Center ePay service.

These changes are in compliance with the US EPA’s NPDES Electronic Reporting Rule which became effective on December 21, 2015.

Permit Transfers Ohio EPA is to receive notification of a transfer at least 30 days prior to the proposed date of the transfer of ownership (refer to Parts II.A.3 and V.E. of the general permit). This change was made to be consistent with OAC 3745-38-02(K)(2).

IX. Notice of Termination

Each individual facility covered by the general permit must submit a Notice of Termination (NOT) form to terminate coverage under this permit. Permittees are to request permit coverage termination once the wastewater discharges are eliminated. Failure to submit an NOT form constitutes a violation of the permit and is a violation of ORC 6111.

X. Information Regarding Certain Water Quality Based Effluent Limits

This draft permit may contain proposed water quality based effluent limitations for parameters that are not priority pollutants. (See the following link for a list of the priority pollutants: http://epa.ohio.gov/portals/35/pretreatment/Pretreatment_Program_Priority_Pollutant_Detection_Limits.p df . ) In accordance with Ohio Revised Code Section 6111.03(J)(3), the Director established these water quality based effluent limits after considering, to the extent consistent with the Federal Water Pollution Control Act, evidence relating to the technical feasibility and economic reasonableness of removing the polluting properties from those wastes and to evidence relating to conditions calculated to result from that action and their relation to benefits to the people of the state and to accomplishment of the purposes of this chapter. This determination was made based on data and information available at

9 the time the permit was drafted, which included the contents of the timely submitted NPDES permit renewal application, along with any and all pertinent information available to the Director.

This public notice allows the permittee to provide to the Director for consideration during this public comment period additional site-specific pertinent and factual information with respect to the technical feasibility and economic reasonableness for achieving compliance with the proposed final effluent limitations for these parameters. The permittee shall deliver or mail this information to:

Ohio Environmental Protection Agency Attention: Division of Surface Water Permits Processing Unit P.O. Box 1049 Columbus, Ohio 43216-1049

Should the applicant need additional time to review, obtain or develop site-specific pertinent and factual information with respect to the technical feasibility and economic reasonableness of achieving compliance with these limitations, written notification for any additional time shall be sent to the above address no later than 30 days after the Public Notice Date on Page 1.

Should the applicant determine that compliance with the proposed water quality based effluent limitations for parameters other than the priority pollutants is technically and/or economically unattainable, the permittee may submit an application for a variance to the applicable water quality standard(s) used to develop the proposed effluent limitation in accordance with the terms and conditions set forth in Ohio Administrative Code (OAC) Rule 3745-33-07(D). The permittee shall submit this application to the above address no later than 30 days after the Public Notice Date.

Alternately, the applicant may propose the development of site-specific water quality standard(s) pursuant to OAC Rule 3745-1-35. The permittee shall submit written notification regarding their intent to develop site specific water quality standards for parameters that are not priority pollutants to the above address no later than 30 days after the Public Notice Date.

Attachment A – Description of Water Treatment Plant Processes

Plain Purification Processes are processes where raw water is treated by settling, sand filtration, disinfection and fluoridation. Wastewaters are generated by filter-backwash and settling basin sludge supernatant waters. Pollutants generated include TSS and chlorine. These wastewaters are typically treated by settling to remove solids, and if necessary to meet limits, dechlorination.

Lime-Soda Softening refers to the reduction of water hardness by the application of hydrated lime to precipitate calcium magnesium carbonates and hydroxides. Complete lime softening also requires the addition of soda ash (sodium carbonate). Wastewaters generated by this process include sludge dewatering, clarifier blowdown, and wash water. Pollutants generated include total suspended solids, chlorine, and alkaline pH values. These wastewaters are typically treated by settling, neutralization, and de-chlorination (if necessary to meet limits).

Iron/Manganese Removal refers to the process of removing soluble iron and manganese from ground water by oxidation. Oxidation is accomplished by aeration, chlorine dioxide, or potassium permanganate. Aeration is followed by filtration through a mixed media filter for removal of solids. Wastewaters are generated from iron filter backwash settling tank decant water preceding cleanout, and potassium permanganate regeneration waste from batch regeneration. Pollutants generated include TSS and suspended metals. These wastewaters are typically treated by settling or clarification.

Ion Exchange means the process pertaining to demineralization of water by ion exchange units that use acids, bases, or salts to regenerate the exchange resins. The hydrogen-ion exchangers have cation- exchange resins that can be regenerated with sulfuric or hydrochloric acid. The hydroxide-ion exchangers have anion resins that can be regenerated with sodium hydroxide (NaOH), sodium carbonate (Na2CO3), or Ammonia (NH3). In the case of a sodium cycle ion exchange unit, the zeolite media softener is regenerated with high concentration of sodium chloride (brine). In case of hydrogen- ion and hydroxyl-ion exchangers, the regeneration wastes are neutralized, pH adjusted, and discharged. For sodium cycle ion-exchange units, the regeneration wastewater and the first flush of rinse water contains total dissolved solids and chlorine.

Reverse Osmosis is the process of removing contaminants from the wastewater by passing the water through a membrane filter that will allow water to pass, but not pollutant molecules. The backwash from these facilities contains high concentrations of dissolved solids, as well as concentrated amounts of any other contaminants that might be present in the source water supply.

Attachment B – Total Suspended Solids Net Increase Example Calculation

Intake Sampling Results 9/8/16 TSS 98 mg/L Flow 0.28 MGD 9/15/16 TSS 102 mg/L Flow 0.33 MGD

Discharge Sampling Results 9/8/16 TSS 108 mg/L Flow 0.27 MGD 9/15/16 TSS 114 mg/L Flow 0.31 MGD

30-day Average Concentration Intake TSS 100 mg/L Flow 0.305 MGD Discharge TSS 111 mg/L Flow 0.29 MGD

TSS Loading Equation L = C * F * 3.785 Where L = Loading (kg/day) C = TSS Average Concentration (mg/L) F = Flow (MGD) 3.785 = Conversion Factor

Intake Loading 115.44 kg/day Discharge Loading 121.84 kg/day

Net Increase

Net Increase = (Lintake – Ldischarge) / Lintake = (121.84 kg/day – 115.44 kg/day) / 115.44 kg/day = 0.0554 = 5.54%

Attachment C – pH Wasteload Allocation for a 1:3 Instream Ratio Based on the procedure in the DESCON program described in the “Technical Guidance on Supplementary Stream Design Conditions for Steady State Modeling” (U.S. EPA Office of Water, Washington D.C., 1988).

Upstream flow (cfs) 0.12 Effluent flow (cfs) 0.04

-- --

INPUT

1. DILUTION FACTOR AT MIXING ZONE BOUNDARY 4.000

2. UPSTREAM/BACKGROUND CHARACTERISTICS Temperature (°C) 4.00 pH (S.U.) 8.00 Alkalinity (mg CaCO3/L) 50.00

3. EFFLUENT CHARACTERISTICS Temperature (°C) 25.00 pH (S.U.) 11.00 Alkalinity (mg CaCO3/L) 1,300.00

OUTPUT

1. IONIZATION CONSTANTS Upstream/Background pKa 6.52 Effluent pKa 6.35

2. IONIZATION FRACTIONS Upstream/Background Ionization Fraction 0.97 Effluent Ionization Fraction 1.00

3. TOTAL INORGANIC CARBON Upstream/Background Total Inorganic Carbon (mg CaCO3/L) 51.67 Effluent Total Inorganic Carbon (mg CaCO3/L) 1,300.03

4. CONDITIONS AT MIXING ZONE BOUNDARY Temperature (°C) 9.25 Alkalinity (mg CaCO3/L) 362.50 Total Organic Carbon (mg CaCO3/L) 363.76 pKa 6.47

pH at Mixing Zone Boundary 8.93

Attachment D – Review of Sampling Results

Only data relevant to changes in permit conditions will be included in this attachment. Determination of reasonable potential follows OAC 3745-2-06(B) and is only applicable to WQBELs (i.e. chlorine). Projected effluent quality (PEQ) calculations are based on Modeling Guidance 1 in the link below: http://www.epa.ohio.gov/dsw/guidance/guidance.aspx#115485538-modeling-guidance

Data is collected from January 2012 – August 2016.

Outfall 005 – Total Suspended Solids a Permit # - Observations Sampling Data (mg/L) Total # of Violations Observations Dates of Violations Station # > MDL Maximum Average Maximum Limit Average Limit 0GW00003 55 55 26 15.65 0 0 1GW00001- 55 55 47.4 10.7 1 1 12/2012 001 1GW00001- 46 43 23.8 b 4.38 b 1 0 10/2015 002 1GW00002- 135 135 25.0 3.54 0 0 003 3GW00001- 56 56 26.4 7.22 0 0 001 3GW00001- 57 57 37.7 5.55 0 0 002 4GW00001 54 54 40 3.83 0 1 9/2012 4GW00002 56 56 22.4 9.13 0 0 a Daily maximum limit 45 mg/L; monthly average limit 30 mg/L b Removed one high outlier; 133 mg/L; 10/9/2015 “MDL” means Method Detection Level No data was available for permit 0GW00010

Outfall 005 – Total Residual Chlorine Sampling Maximum Total # of Permit # - Observations MDL Data PEQ/Limit a Dates of Observations PEQ (mg/L) Limit Station # > MDL (mg/L) Maximum (%) Violations Violations (mg/L) 0GW00003 55 0 Unknown None None None 0 1GW00001- 1/2012, 54 11 0.038 0.07 0.07 184.2 2 001 5/2012 1GW00001- 46 5 0.038 0.08 0.088 231.6 1 5/2015 002 1GW00002- 135 4 0.02 0.04 0.032 84.2 0 003 3GW00001- 56 0 0.05 None None None 0 001 3GW00001- 50 3 0.01 0.03 0.03 78.9 0 002 4GW00001 56 2 Unknown 0.001 0.001 2.6 0 4GW00002 56 0 0.00001 None None None 0 a Daily maximum limit 0.038 mg/L “None” indicates that this value cannot be calculated due to a lack of results above the MDL No data was available for permit 0GW00010 Values in bold indicate reasonable potential (PEQ is equal to or greater than 50% of the limit)

Outfall 006 – Total Suspended Solids Observations Sampling Data (mg/L) Total # of Limit Violations a Permit # Observations Dates of Violations > MDL Maximum Average Maximum Average 0GW00004 7 7 36 13.2 0 1 6/2016 0GW00006 56 56 19 4.88 0 0 0GW00007 b 59 40 9.0 1.94 0 0 0GW00008 c 50 21 24 3.05 0 0 1/2012, 2/2012, 2GW00004 56 56 47 8.63 1 3 1/2013 1/2012, 2/2012, 4GW00003 b 30 29 143 22.0 4 4 7/2015, 12/2015 a Daily maximum limit 45 mg/L; monthly average limit 30 mg/L b The MDL for total suspended solids recorded for this permit is 1.0 mg/L c The MDL for total suspended solids recorded for this permit is unknown “MDL” means Method Detection Level

Outfall 006 – Total Suspended Iron a Permit # Observations Sampling Data (mg/L) Total # of Limit Violations Dates of Violations Observations > MDL Maximum Average Maximum Average 0GW00004 b 7 5 30 12.6 0 0 0GW00006 56 56 2,380 230.9 1 1 11/2015 0GW00007 b 59 5 150 9.08 0 0 0GW00008 c 54 39 1,630 150 0 0 2GW00004 1/2012, 2/2012, 56 56 2,800 d 514.8 d 2 4 4/2012, 12/2012 4GW00003 b 31 22 199 34.3 0 0 a Daily maximum limit 2,000 µg/L; monthly average limit 1,000 µg/L b The MDL for total suspended solids recorded for this permit is 8.0 µg/L c The MDL for total suspended solids recorded for this permit is unknown d Removed one high outlier; 6,500 µg/L; 1/27/2012 “MDL” means Method Detection Level

Outfall 006 – Total Residual Chlorine Sampling Data Maximum Total # of Observations MDL PEQ/Limit a Dates of Permit # Observations Maximum PEQ Limit > MDL (mg/L) (%) Violations (mg/L) (mg/L) Violations 11/2015, 0GW00004 11 10 Unknown 0.163 0.2771 1,458.4 6 6/2016, 7/2016 0GW00006 56 0 Unknown None None None 0 0GW00007 58 58 Unknown 0.019 0.019 100.0 0 0GW00008 52 20 0.01 0.02 0.02 105.3 0 2GW00004 56 0 0.05 None None None 0 4GW00003 32 9 0.02 0.10 0.12 631.6 1 12/2015 a Daily maximum limit 0.019 mg/L “None” indicates that this value cannot be calculated due to a lack of results above the MDL Values in bold indicate reasonable potential (PEQ is equal to or greater than 50% of the limit)

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