Page 7 of Statement of Basis Permit Number: AR0050148 AFIN: 26-00444 Parameter Water Quality or Technology Justification DO Water Quality Reg. 2.505, Water Quality Model dated December 12, 2019, CWA § 402(o), and previous permit FCB Water Quality Reg. 2.507, CWA § 402(o), and previous permit TP Technology CPP , 40 CFR 122.44(l), and previous permit NO3 + NO2 - N Technology CPP, 40 CFR 122.44(l), and previous permit pH Water Quality Reg. 2.504, CWA § 402(o), and previous permit With the exception of the April limits for FCB, no new information was received to warrant adding, removing, or revising any limitations in the permit. Therefore, the remaining limitations in the permit are consistent with the limitations in the previous permit. The previous permit included the effluent limitations for FCB expressed as 200/400 (Monthly Average/7-Day Average) colonies/100ml during the month of April. These limits are now expressed as 1000/2000 (Monthly Average/7-Day Average) colonies/100ml during the month of April based on Reg. 2.507. B. Anti-backsliding The permit is consistent with the requirements to meet Anti-backsliding provisions of the Clean Water Act (CWA), Section 402(o) [40 CFR 122.44(l)]. The final effluent limitations for reissuance permits must be as stringent as those in the previous permit, unless the less stringent limitations can be justified using exceptions listed in CWA 402(o)(2), CWA 303(d)(4), or 40 CFR 122.44(l)(2)(i). The permit meets or exceeds the requirements of the previous permit, with the exception of revised limitations identified for Fecal Coliform Bacteria during the month of April. This revision is allowed in accordance with CWA § 303(d)(4)(B) based on the seasonal limits defined in APC&EC Reg. 2.507. C. Limits Calculations 1. Mass Limits: In accordance with 40 CFR 122.45(f)(1), all pollutants limited in permits shall have limitations expressed in terms of mass if feasible. 40 CFR 122.45(f)(2) allows for pollutants which are limited in terms of mass to also be limited in terms of other units of measurement. The calculation of the loadings (lbs per day) uses a design flow of 0.85 MGD and the following equation: Mass (lbs/day) = Concentration (mg/l) × Flow (MGD) × 8.34
Page 8 of Statement of Basis Permit Number: AR0050148 AFIN: 26-00444 2. 7-Day Average Limits: The 7-day average limits for NH3-N (May through March) as well as CBOD5 and TSS are based on Section 5.4.2 of the Technical Support Document for Water Quality-based Toxics Control: 7-day average limits = monthly average limits × 1.5 The 7-day average NH3-N limit for the month of April is based on the previous permit. The 7-day average limits for FCB are based on Reg. 2.507. D. 208 Plan (Water Quality Management Plan) There are no changes to the 208 Plan occurring with this permit renewal. 13. SAMPLE TYPE AND FREQUENCY With the exception of nutrients, the requirements for sample type and sampling frequency have been based on the current discharge permit. The sampling frequency for nutrients has been reduced to once per year. The requirements were originally placed in the permit in order to gather data regarding the amount of nutrients being discharged into a Water of the State. Sufficient information has been gathered at this time to allow for the reduction in frequency. Parameter Previous Permit Final Permit Frequency of Sample Sample Type Frequency of Sample Sample Type Flow once/day totalizing meter once/day totalizing meter CBOD5 (May – October) three/month composite three/month composite (November – April) three/month composite three/month composite TSS three/month composite three/month composite NH3-N (April) three/month composite three/month composite (May – October) three/month composite three/month composite (November – March) three/month composite three/month composite DO (May – October) three/month grab three/month grab (November – April) three/month grab three/month grab FCB (May – September) three/month grab three/month grab
Page 9 of Statement of Basis Permit Number: AR0050148 AFIN: 26-00444 Parameter Previous Permit Final Permit Frequency of Sample Sample Type Frequency of Sample Sample Type (October – April) three/month grab three/month grab TP once/month grab once/year grab NO3 + NO2 - N once/month grab once/year grab pH three/month grab three/month grab 14. PERMIT COMPLIANCE SCHEDULE A Schedule of Compliance has not been included in this permit. Compliance with all permit requirements is required on the effective date of the permit. 15. MONITORING AND REPORTING The applicant is at all times required to monitor the discharge on a regular basis and report the results monthly. The monitoring results will be available to the public. 16. SOURCES The following sources were used to draft the permit: a. Application No. AR0050148 received May 29, 2019, with all additional information received by June 18, 2019. b. Arkansas Water Quality Management Plan (WQMP). c. APC&EC Regulation No. 2. d. APC&EC Regulation No. 3. e. APC&EC Regulation No. 6 which incorporates by reference certain federal regulations included in Title 40 of the Code of Federal Regulations at Reg. 6.104. f. 40 CFR Parts 122, 125, 133 and 403. g. Discharge permit file AR0050148. h. Discharge Monitoring Reports (DMRs). i. “2016 Integrated Water Quality Monitoring and Assessment Report”, ADEQ. j. “2016 List of Impaired Waterbodies (303(d) List)”, ADEQ, July 2017. k. USGS StreamStats l. Continuing Planning Process (CPP). m. Technical Support Document for Water Quality-based Toxic Control. n. Inspection Report dated April 18, 2019. o. Compliance Review Memo from Leslie Allen-Daniel to Loretta Carstens, P.E. dated June 18, 2019. p. Water Quality Model dated December 12, 2019.
Page 10 of Statement of Basis Permit Number: AR0050148 AFIN: 26-00444 17. PUBLIC NOTICE The public notice of the draft permit was published for public comment on March 11, 2020. The last day of the comment period was thirty (30) days after the publication date. No public comments were received on the draft permit. Copies of the draft permit and public notice were sent via email to the Corps of Engineers, the Regional Director of the U.S. Fish and Wildlife Service, the Department of Arkansas Heritage, the EPA, and the Arkansas Department of Health. 18. PERMIT FEE In accordance with Reg. No. 9.403(C)(1), the annual fee for the permit is calculated from the Design Flow (Q, in MGD) as follows: Fee = $200 + (5,600 × Q) = $200 + (5,600 × 0.85) = $4,960 19. POINT OF CONTACT For additional information, contact: Loretta Carstens, P.E. Permits Branch, Office of Water Quality Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas 72118-5317 Telephone: (501) 682-0612
ATTACH MONITORING RESULTS FOR ANN REPORTING YEAR: _____ / _____ PERMITTEE NAME: ____________________ AVERAGE POTW FLOW: _____MGD POLLUTANT (Total) MAHC2 (µg/l) INFLUENT DATES SAMPLED (µg/l) once/quarter WQ level / limi (µg/l) Date Date Date Date Antimony N/A N/A Arsenic Beryllium Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Thallium N/A N/A Zinc Cyanide Phenols N/A N/A Molybdenum N/A Flow, MGD N/A N/A 3 3 3 3
HMENT I NUAL PRETREATMENT REPORT _ / _____ TO _____ / _____ / _____ __ NPDES PERMIT NO. ________________ PERCENT INDUSTRIAL FLOW: _____% it2 EFFLUENT DATES SAMPLED (µg/l) once/quarter LABORATORY ANALYSIS EPA MQL1 (µg/l) EPA Method Used1 Detection Level Achieved (µg/l) Date Date Date Date 60 0.5 0.5 0.5 10 0.5 0.5 0.005 0.5 5 0.5 0.5 20 10 5
POLLUTANT (Total) MAHC2 (µg/l) INFLUENT DATES SAMPLED (µg/l) once/quarter WQ level / limi (µg/l) 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 1 It is advised that the influent and effluent samples are collected considering flow detention time t the influent) so the data can also be used for Local Limits assessment and NPDES applicatio 2 This value was calculated during the development of technically-based local limits (TBLLs) based the permittee’s consultant with concurrence from ADEQ Pretreatment staff. 3 Record the name of any pollutant [40 CFR 122, Appendix D, Table II and/or Table V] detected an MAHC - Maximum Allowable Headworks Concentration WQ - “Water Quality Levels not to exceed” OR actual permit limit.
it2 EFFLUENT DATES SAMPLED (µg/l) once/quarter LABORATORY ANALYSIS EPA MQL1 EPA M th d Detection L l through each plant. Analytical MQLs must be met for the effluent (and SHOULD be met for on purposes. d on State WQ criteria, EPA guidance, and either ADEQ Pretreatment staff Excel spreadsheets or nd the concentration at which they were detected.
ATTACH PRETREATMENT PROG UPDATED SIGNIFICANT I Industrial User Name SIC/NAICS Code 40 CFR XXX or N/A Control Document New User Tim Insp Y/N Last Action Include NAICS code(s) 3rd column – include the CFR # only if the Category has Pretreatment Standards (numeric or narrative) Please footnote N/A reason
HMENT II GRAM STATUS REPORT INDUSTRIAL USERS LIST mes pected Times Sampled Compliance Status (N/A, C, NC, or SNC) Permit Limits (denote parameter violated & number of times) Reports BMR 90-day Compliance Semi Annual Self Monitoring
ATTACH SIGNIFICANT NON-COMPLIANT (SNC) INDU Industrial User Name Nature of Violation Number of Action T Reports Limits N.O.V. A.O. Civil
HMENT III USTRIES - ENFORCEMENT ACTIONS TAKEN Taken Penalties Collected Compliance Schedule Current Status Comments Criminal Other Date Issued Date Due
ATTACHMENT IV PRETREATMENT PERFORMANCE SUMMARY (PPS) NOTE: All questions refer to the Industrial Pretreatment Program as approved by the ADEQ. The permittee should not answer the questions based on changes made to the Approved Program without Department Authorization. II. General Information Control Authority Name: Mailing Address: City: State / Zip Code: Pretreatment Contact: Title: Contact Telephone Number: NPDES Permit Number(s): Reporting Period: (Beginning month, day, and year) (Ending month, day, and year) Total Number of Categorical IUs: Total Number of Significant Non-categorical IUs: Total Number of Non-significant (yet permitted) IUs: III. Significant Industrial User Compliance Significant Industrial Users Categorical Non-categorical 1) Number of SIUs Submitting BMRs N/A Total Number Required N/A 2) Number of SIUs Submitting 90-day Compliance Reports N/A Total Number Required N/A 3) Number of SIUs Submitting Semiannual Reports Total Number Required 4) Number of SIUs Meeting Compliance Schedule Total Number Required to Meet Schedule 5) Number of SIUs in Significant Noncompliance Total Number of SIUs 6) Rate (%) of Significant Noncompliance for all SIUs (categorical and non-categorical)
IV. Compliance Monitoring Program Significant Industrial Users Categorical Non-categorical 1) Number of Control Documents Issued Total Number Required 2) Number of Non-sampling Inspections Conducted Total Number Required 3) Number of Sampling Visits Conducted Total Number Required 4) Number of Facilities Inspected (non-sampling) Total Number Required 5) Number of Facilities Sampled Total Number Required V. Enforcement Actions Significant Industrial Users Categorical Non-categorical 1) Number of Compliance Schedules Issued Total Number of Schedules Required 2) Number of Notices of Violation Issued to SIUs 3) Number of Administrative Orders Issued to SIUs 4) Number of Civil Suits Filed 5) Number of Criminal Suits Filed 6) Number of Significant Violators (attach newspaper publication) 7) Amount of Penalties (not surcharges) Collected (Total Dollars) $ $ (Total Number of IUs Assessed) 8) Other Actions (sewer bans, etc.) The following certification must be signed in order for this form to be considered complete: I certify that the information contained herein is complete and accurate to the best of my knowledge. Authorized Representative: Date: Page 2 of Attachment IV
APPENDIX 3 Davidson Drive WWTP Master Plan