View
7
Download
0
Category
Preview:
Citation preview
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 1 of 30
National Pollutant Discharge Elimination System (NPDES) Permit Program
FACT SHEET
Regarding an NPDES Permit To Discharge to Waters of the State of Ohio
for Ironton Wastewater Treatment Plant (WWTP)
Public Notice No.: 18-05-046 Ohio EPA Permit No.: 0PD00007*MD
Public Notice Date: May 15, 2018 Application No.: OH0025852
Comment Period Ends: June 15, 2018
Name and Address of Facility Where
Name and Address of Applicant: Discharge Occurs:
City of Ironton City of Ironton WWTP
P.O. Box 704 810 North Fourth Street
Ironton, OH 45638 Ironton, OH 45638
Lawrence County
Receiving Water: Ohio River
Subsequent Stream Network: Mississippi
INTRODUCTION
Development of a Fact Sheet for NPDES permits is mandated by Title 40 of the Code of Federal Regulations
(CFR), Section 124.8 and 124.56. This document fulfills the requirements established in those regulations by
providing the information necessary to inform the public of actions proposed by the Ohio Environmental
Protection Agency (Ohio EPA), as well as the methods by which the public can participate in the process of
finalizing those actions.
This Fact Sheet is prepared in order to document the technical basis and risk management decisions that are
considered in the determination of water quality based NPDES Permit effluent limitations. The technical basis
for the Fact Sheet may consist of evaluations of promulgated effluent guidelines, existing effluent quality,
instream biological, chemical and physical conditions, and the relative risk of alternative effluent limitations.
This Fact Sheet details the discretionary decision-making process empowered to the Director by the Clean
Water Act (CWA) and Ohio Water Pollution Control Law (Ohio Revised Code [ORC] 6111). Decisions to
award variances to Water Quality Standards (WQS) or promulgated effluent guidelines for economic or
technological reasons will also be justified in the Fact Sheet where necessary.
No antidegradation review was necessary.
Effluent limits based on available treatment technologies are required by Section 301(b) of the CWA. Many of
these have already been established by the United States Environmental Protection Agency (U.S. EPA) in the
effluent guideline regulations (a.k.a. categorical regulations) for industry categories in 40 CFR Parts 405-499.
Technology-based regulations for publicly-owned treatment works are listed in the Secondary Treatment
Regulations (40 CFR Part 133). If regulations have not been established for a category of dischargers, the
director may establish technology-based limits based on best professional judgment (BPJ).
Ohio EPA reviews the need for water-quality-based limits on a pollutant-by-pollutant basis. Wasteload
allocations (WLAs) are used to develop these limits based on the pollutants that have been detected in the
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 2 of 30
discharge, and the receiving water’s assimilative capacity. The assimilative capacity depends on the flow in the
water receiving the discharge, and the concentration of the pollutant upstream. The greater the upstream flow,
and the lower the upstream concentration, the greater the assimilative capacity is. Assimilative capacity may
represent dilution (as in allocations for metals), or it may also incorporate the break-down of pollutants in the
receiving water (as in allocations for oxygen-demanding materials).
The need for water-quality-based limits is determined by comparing the WLA for a pollutant to a measure of the
effluent quality. The measure of effluent quality is called Projected Effluent Quality (PEQ). This is a statistical
measure of the average and maximum effluent values for a pollutant. As with any statistical method, the more
data that exists for a given pollutant, the more likely that PEQ will match the actual observed data. If there is a
small data set for a given pollutant, the highest measured value is multiplied by a statistical factor to obtain a
PEQ; for example if only one sample exists, the factor is 6.2, for two samples - 3.8, for three samples - 3.0. The
factors continue to decline as samples sizes increase. These factors are intended to account for effluent
variability, but if the pollutant concentrations are fairly constant, these factors may make PEQ appear larger than
it would be shown to be if more sample results existed.
SUMMARY OF PERMIT CONDITIONS
New final effluent limits are proposed for Escherichia coli during the summer months. New WQS for E. coli
became effective in April 2016. No compliance schedule is proposed for meeting these new final effluent limits.
Based on best technical judgment, it is expected the facility will be able to comply when the permit becomes
effective.
Annual acute toxicity monitoring is proposed for the life of the permit. This satisfies the minimum testing
requirements of Ohio Administrative Code (OAC) 3754-33-07(B)(11) and will adequately characterize toxicity
in the plant’s effluent.
Monitoring is proposed to continue for dissolved orthophosphate. This monitoring is required by Ohio Senate
Bill 1, which was signed by the Governor on April 2, 2015. Monitoring for orthophosphate is proposed to
further develop nutrient datasets for dissolved reactive phosphorus and to assist stream and watershed
assessments and studies. The current monitoring requirement for total orthophosphate will be removed from the
permit.
This permit no longer authorizes the use of method 4500 CN-I from Standard Methods for free cyanide testing.
As soon as possible, the permittee must begin using either ASTM D7237-10 or OIA-1677-09 both of which are
approved methods for free cyanide listed in 40 CFR 136.
In Part II of the permit, special conditions are included that address sanitary sewer overflow (SSO) reporting;
operator certification, minimum staffing and operator of record; whole effluent toxicity (WET) testing; storm
water compliance; public drinking water intake notifications; and outfall signage.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 3 of 30
Table of Contents
Page
INTRODUCTION................................................................................................................................................... 1
SUMMARY OF PERMIT CONDITIONS ............................................................................................................. 2
PROCEDURES FOR PARTICIPATION IN THE FORMULATION OF FINAL DETERMINATIONS ............ 4
INFORMATION REGARDING CERTAIN WATER QUALITY BASED EFFLUENT LIMITS ....................... 4
LOCATION OF DISCHARGE/RECEIVING WATER USE CLASSIFICATION ............................................... 6
FACILITY DESCRIPTION .................................................................................................................................... 6
DESCRIPTION OF EXISTING DISCHARGE ..................................................................................................... 7
ASSESSMENT OF IMPACT ON RECEIVING WATERS .................................................................................. 8
DEVELOPMENT OF WATER-QUALITY-BASED EFFLUENT LIMITS ......................................................... 8
REASONABLE POTENTIAL/EFFLUENT LIMITS/MANAGEMENT DECISIONS ...................................... 10
OTHER REQUIREMENTS .................................................................................................................................. 13
List of Figures
Figure 1. Location of Ironton WWTP ................................................................................................................... 15 Figure 2. Diagram of Wastewater Treatment System ........................................................................................... 16
List of Tables
Table 1. Sewage Sludge Removal ......................................................................................................................... 17 Table 2. Effluent Violations for Outfall 001 ......................................................................................................... 17 Table 3. Average Annual Effluent Flow Rates for Outfall 001 ............................................................................ 17 Table 4. Sanitary Sewer Overflows Discharges .................................................................................................... 18 Table 5. Combined Sewer Overflow Discharges .................................................................................................. 18 Table 6. Calculated Phosphorus Loadings ............................................................................................................ 18 Table 7. Effluent Characterization Using Ohio EPA data ..................................................................................... 19 Table 8. Effluent Characterization Using Self-Monitoring Data .......................................................................... 20 Table 9. Projected Effluent Quality for Outfall 001 .............................................................................................. 22 Table 10. Summary of Acute and Chronic Toxicity Results ................................................................................ 23 Table 11. Ohio EPA Toxicity Screening Results for Outfall 001 ......................................................................... 23 Table 12. Water Quality Criteria in the Study Area .............................................................................................. 24 Table 13. Instream Conditions and Discharger Flow ............................................................................................ 25 Table 14. Summary of Effluent Limits to Maintain Applicable Water Quality Criteria ....................................... 27 Table 15. Parameter Assessment ........................................................................................................................... 28 Table 16. Final Effluent Limits for Outfall 001 .................................................................................................... 29
List of Addendums
Addendum 1. Acronyms ...................................................................................................................................... 30
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 4 of 30
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, and 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:
Legal Records Section
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 Processing Unit
P.O. Box 1049
Columbus, Ohio 43216-1049
The Ohio EPA 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 Walter Ariss, 614-644-3075,
walter.ariss@epa.ohio,gov .
INFORMATION REGARDING CERTAIN WATER QUALITY BASED EFFLUENT LIMITS
This draft permit may contain proposed water-quality-based effluent limits (WQBELs) 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.pdf .)
In accordance with ORC 6111.03(J)(3), the Director established these WQBELs 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
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 5 of 30
available at 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 WQBELs 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 WQS used to develop the proposed effluent limitation in accordance with the terms
and conditions set forth in OAC 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 WQS pursuant to OAC 3745-1-39. The
permittee shall submit written notification regarding their intent to develop site specific WQS for parameters
that are not priority pollutants to the above address no later than 30 days after the Public Notice Date.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 6 of 30
LOCATION OF DISCHARGE/RECEIVING WATER USE CLASSIFICATION
City of Ironton WWTP discharges to the Ohio River at mile point 327.2. Figure 1 shows the approximate
location of the facility.
This segment of the Ohio River is described by Ohio EPA River Code: 25-300, County: Lawrence, Ecoregion:
Western Allegheny Plateau. The Ohio River is designated for the following uses under Ohio’s Water Quality
Standards (OAC 3745-1-32): Warmwater Habitat (WWH), Public Water Supply (PWS), Agricultural Water
Supply (AWS), Industrial Water Supply (IWS), and Bathing Waters (BW).
Use designations define the goals and expectations of a waterbody. These goals are set for aquatic life
protection, recreation use and water supply use, and are defined in the Ohio WQS (OAC 3745-1-07). The use
designations for individual waterbodies are listed in rules -08 through -32 of the Ohio WQS. Once the goals are
set, numeric WQS are developed to protect these uses. Different uses have different water quality criteria.
Use designations for aquatic life protection include habitats for coldwater fish and macroinvertebrates,
warmwater aquatic life and waters with exceptional communities of warmwater organisms. These uses all meet
the goals of the federal CWA. Ohio WQS also include aquatic life use designations for waterbodies which
cannot meet the CWA goals because of human-caused conditions that cannot be remedied without causing
fundamental changes to land use and widespread economic impact. The dredging and clearing of some small
streams to support agricultural or urban drainage is the most common of these conditions. These streams are
given Modified Warmwater or Limited Resource Water designations.
Recreation uses are defined by the depth of the waterbody and the potential for wading or swimming. Uses are
defined for bathing waters, swimming/canoeing (Primary Contact Recreation) and wading only (Secondary
Contact which are generally waters too shallow for swimming or canoeing).
Water supply uses are defined by the actual or potential use of the waterbody. Public Water Supply
designations apply near existing water intakes so that waters are safe to drink with standard treatment. Most
other waters are designated for agricultural water supply and industrial water supply.
FACILITY DESCRIPTION
City of Ironton WWTP was constructed in 1953, with the last major upgrade in 1987. The average design flow
is 1.7 million gallons per day (MGD). City of Ironton WWTP has the following treatment processes which are
shown on Figure 2:
• Influent Pumping
• Bar Screen
• Grit Removal
• Preaeration
• Primary Settling
• Trickling Filters
• Secondary clarification
• Chlorination and Dechlorination
City of Ironton WWTP utilizes the following sewage sludge treatment processes also shown in Figure 2.
• Gravity thickening
• Anaerobic Digesters
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 7 of 30
• Filter Press
• Landfilling
Table 1 shows the last five years of sludge removed from City of Ironton WWTP.
The Ironton collection system includes both combined sewers (approximately 60 percent) and separate sanitary
sewers. There are nine combined sewer overflows (CSOs) on the system that are regulated under the NPDES
permit for the wastewater plant.
In March 2009, a consent decree was filed in the United States District Court, Southern District of Ohio,
Western Division (Case 1:09-cv-00011-MRB). The decree states that on the date of lodging, the City was
implementing the nine minimum controls for CSOs; that the City shall undertake long-term control of its CSOs
through sewer separation, which must be completed by December 31, 2026; that the City must implement an
ongoing program to identify and eliminate sources of infiltration and inflow into its sanitary sewer system; and
that the City shall implement procedures for investigating, reporting and eliminating dry weather overflows.
Appendix D of the decree includes a compliance schedule for implementing the CSO long-term control plan. A
copy of the decree is available through the following Ohio EPA web site:
http://epa.ohio.gov/dsw/enforcement/enf_actions_2009.aspx .
Ironton does not implement an approved industrial pretreatment program. Two industrial users haul leachate to
the Ironton plant under indirect discharge permits issued by Ohio EPA.
The City of Ironton’s potable water comes from the Ohio River that is treated at the City of Ironton Water
Treatment Plant.
DESCRIPTION OF EXISTING DISCHARGE
City of Ironton WWTP had several effluent violations which are shown on Table 2. These violations were not
caused by a known process error or upset condition. These violations have been addressed.
The average annual effluent flow rate for City of Ironton WWTP for the previous five years is presented on
Table 3. City of Ironton WWTP has an estimated infiltration/inflow (I/I) rate of 0.300 MGD and performs the
following activities to minimize I/I: sewer lining and elimination of combined sewers.
City of Ironton WWTP reports SSOs at station 300. The number of SSOs and dates recorded is presented in
Table 4. The number of SSOs dropped dramatically in 2015. This is due to an inaccurate counting and reporting
of the actual number of SSO events by the prior WWTP superintendent. The error and corrective measures were
documented in a Resolution of Violation issued by Ohio EPA dated June 9, 2016. The number of SSOs reported
prior to August 2015 should not be considered accurate. City of Ironton WWTP has nine combined sewer
overflows (CSOs). The number of CSOs and dates reported is presented in Table 5.
Under the provisions of 40 CFR 122.21(j), the Director has waived the requirement for submittal of expanded
effluent testing data as part of the NPDES renewal application. Ohio EPA has access to substantially identical
information from Ohio EPA effluent testing conducted.
Table 7 presents chemical specific data compiled from data collected by Ohio EPA.
Table 8 presents a summary of unaltered Discharge Monitoring Report (DMR). Data are presented for the
period October 1, 2012 through September 30, 2017, and current permit limits are provided for comparison.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 8 of 30
Table 9 summarizes the chemical specific data for outfall 001 by presenting the average and maximum PEQ
values.
Table 10 summarizes the results of acute and chronic WET tests of the final effluent.
Table 11 summarizes the screening results of Ohio EPA bioassay sampling of the final effluent.
ASSESSMENT OF IMPACT ON RECEIVING WATERS
The City of Ironton WWTP discharges directly to the Ohio River in the Greenup pool. Water quality monitoring
on the Ohio River is performed by the Ohio River Valley Water Sanitation Commission (ORSANCO). This
information can be found in the 2016 Biennial Assessment of Ohio River Water Quality Conditions (305b)
Report and/or biological survey results/pool reports.
The Biennial Report can be found at this website:
http://www.orsanco.org/wp-content/uploads/2016/07/2016-305b-Report-Final-Draft.pdf
The Greenup Dam pool was assessed in 2016 by ORSANCO. A copy of the dam pool report can be found at this
website:
http://www.orsanco.org/wp-content/uploads/2016/11/2016-Combined-Pool-Report-Final.pdf
ORSANCO evaluates the river for four uses: aquatic life, contact recreation impairment, public water supply,
and fish consumption. The segment of the Ohio River that City of Ironton WWTP discharges to fully supports
aquatic life and public water supply uses The segment of the Ohio River that City of Ironton WWTP discharges
to is impaired for contact recreation use and fish consumption. Contact recreation season data from 2010
through 2014 and longitudinal bacteria survey data from 2003 through 2008 were used in the assessment.
Sample results in the Greenup pool at mile point 327.4 earned a rating of partial support (fair water quality) with
13% of the samples reported above the geometric mean. To be in attainment the results have to be 10% or less.
The City of Ironton WWTP’s reported bacteria discharges have been well below their permit limit for fecal
coliform and is unlikely contributing to the contact recreation impairments in the Ohio River. It is possible that
the CSO discharges contribute to elevated bacterial counts in the river. The continued implementation of the
LTCP should help to address any of these contributions to the partial support status.
The Ohio River fish consumption use was assessed based on fish tissue data as well as PCBs, dioxin, and
mercury water quality data. For PCB’s and dioxin, impairment exists if water quality criteria for one or more
pollutants are exceeded in greater than ten percent of samples. Based on these criteria, the entire river is
designated as partially supporting fish consumption use for PCBs and dioxin. The water quality criterion for
total mercury in the water column is established to protect against undesirable accumulation in fish tissue.
Utilizing the USEPA’s methodology for assessing the fish consumption use for methyl mercury utilizing fish
tissue data, all pools had a fish consumption weighted methyl mercury fish tissue average below 0.3 mg/kg. As a
result, utilizing a weight of evidence approach relying on the fish tissue data as more reliable assessment
methodology, the entire river is classified as fully supporting the fish consumption use for methyl mercury.
DEVELOPMENT OF WATER-QUALITY-BASED EFFLUENT LIMITS
Determining appropriate effluent concentrations is a multiple-step process in which parameters are identified as
likely to be discharged by a facility, evaluated with respect to Ohio water quality criteria, and examined to
determine the likelihood that the existing effluent could violate the calculated limits.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 9 of 30
Parameter Selection
Effluent data for the City of Ironton WWTP were used to determine what parameters should undergo WLA.
The parameters discharged are identified by the data available to Ohio EPA, DMR data submitted by the
permittee, compliance sampling data collected by Ohio EPA, and any other data submitted by the permittee,
such as priority pollutant scans required by the NPDES application or by pretreatment, or other special
conditions in the NPDES permit. The sources of effluent data used in this evaluation are as follows:
Self-monitoring data (DMR) October 2012 through September 2017
Ohio EPA bioassay sampling data February 2016
Statistical Outliers and Other Non-representative Data
The data were examined, and no values were removed from the evaluation. A Method A calculation was
completed for TDS, chromium, and dissolved hexavalent chromium in order to address low R2 values in the
Method B calculation.
This data is evaluated statistically, and PEQ values are calculated for each pollutant. Average PEQ (PEQavg)
values represent the 95th percentile of monthly average data, and maximum PEQ (PEQmax) values represent the
95th percentile of all data points (see Table 9).
The PEQ values are used according to Ohio rules to compare to applicable WQS and allowable WLA values for
each pollutant evaluated. Initially, PEQ values are compared to the applicable average and maximum WQS. If
both PEQ values are less than 25 percent of the applicable WQS, the pollutant does not have the reasonable
potential to cause or contribute to exceedances of WQS, and no WLA is done for that parameter. If either
PEQavg or PEQmax is greater than 25 percent of the applicable WQS, a WLA is conducted to determine whether
the parameter exhibits reasonable potential and needs to have a limit or if monitoring is required (see Table 15).
Wasteload Allocation
For those parameters that require a WLA, the results are based on the uses assigned to the receiving waterbody
in OAC 3745-1. Dischargers are allocated pollutant loadings/concentrations based on the Ohio WQS (OAC
3745-1). Most pollutants are allocated by a mass-balance method because they do not break down in the
receiving water. For free flowing streams, WLAs using this method are done using the following general
equation: Discharger WLA = (downstream flow x WQS) - (upstream flow x background concentration).
Discharger WLAs are divided by the discharge flow so that the allocations are expressed as concentrations.
The applicable waterbody uses for this facility’s discharge to the Ohio River and the associated stream design
flows are as follows:
Aquatic life (Warmwater Habitat)
Toxics (metals, organics, etc.) Average 10% of annual 7Q10
Maximum 1% of annual 1Q10
Agricultural Water Supply 10% of harmonic mean flow
Human Health (carcinogens) 10% of harmonic mean flow
Human Health (non-carcinogens) 100% of 7Q10
Allocations are developed using a percentage of stream design flow as specified in Table 13, and allocations
cannot exceed the Inside Mixing Zone Maximum (IMZM) criteria.
The data used in the WLA are listed in Table 12 and Table 13. The WLA results to maintain all applicable
criteria are presented in Table 14.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 10 of 30
Whole Effluent Toxicity Wasteload Allocation
WET is the total toxic effect of an effluent on aquatic life measured directly with a toxicity test. Acute WET
measures short term effects of the effluent while chronic WET measures longer term and potentially more subtle
effects of the effluent.
WQS for WET are expressed in Ohio’s narrative “free from” WQS rule [OAC 3745-1-04(D)]. These “free
froms” are translated into toxicity units (TUs) by the associated WQS Implementation Rule (OAC 3745-2-09).
WLAs can then be calculated using TUs as if they were water quality criteria.
The WLA calculations for WET are similar to those for aquatic life criteria - using the chronic toxicity unit
(TUc) and 10 percent of the 7Q10 flow for the average and the acute toxicity unit (TUa) and 1 percent of the
7Q10 flow for the maximum. These values are the levels of effluent toxicity that should not cause instream
toxicity during critical low-flow conditions. For the Ironton WWTP, the WLA values are 1.0 TUa and 381 TUc.
However, Ironton WWTP is not required to monitor for TUc because the ratio of the downstream to discharge
flow is more than twenty to one [OAC 3745-33-07(B)(11)(c)]. According to the data in Table 13, the dilution
ratio for Ironton WWTP to the Ohio River is approximately 381 to one.
Stream Dilution Ratio = 10% of 7Q10 + [WWTP flow rate] = 1000 cfs + 2.63 cfs = 381
[WWTP flow rate] 2.63 cfs
The chronic toxicity unit (TUc) is defined as 100 divided by the estimate of the effluent concentration which
causes a 25% reduction in growth or reproduction of test organisms (IC25):
TUc = 100/IC25
This equation applies outside the mixing zone for warmwater, modified warmwater, exceptional warmwater,
coldwater, and seasonal salmonid use designations except when the following equation is more restrictive
(Ceriodaphnia dubia only):
TUc = 100/geometric mean of No Observed Effect Concentration and Lowest Observed Effect Concentration
The acute toxicity unit (TUa) is defined as 100 divided by the concentration in water having 50% chance of
causing death to aquatic life (LC50) for the most sensitive test species:
TUa = 100/LC50
This equation applies outside the mixing zone for warmwater, modified warmwater, exceptional warmwater,
coldwater, and seasonal salmonid use designations.
REASONABLE POTENTIAL/EFFLUENT LIMITS/MANAGEMENT DECISIONS
After appropriate effluent limits are calculated, the reasonable potential of the discharger to violate the WQS
must be determined. Each parameter is examined and placed in a defined "group". Parameters that do not have
a WQS or do not require a WLA based on the initial screening are assigned to either group 1 or 2. For the
allocated parameters, the preliminary effluent limits (PEL) based on the most restrictive average and maximum
WLAs are selected from Table 14. The average PEL (PELavg) is compared to the average PEQ (PEQavg) from
Table 9, and the PELmax is compared to the PEQmax. Based on the calculated percentage of the allocated value
[(PEQavg ÷ PELavg) X 100, or (PEQmax ÷ PELmax) X 100)], the parameters are assigned to group 3, 4, or 5. The
groupings are listed in Table 15.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 11 of 30
The final effluent limits are determined by evaluating the groupings in conjunction with other applicable rules
and regulations. Table 16 presents the final effluent limits and monitoring requirements proposed for City of
Ironton WWTP outfall 001 and the basis for their recommendation. Unless otherwise indicated, the monitoring
frequencies proposed in the permit are continued from the existing permit.
CBOD5 and Total Suspended Solids
The limits recommended for suspended solids and CBOD5 are technology-based treatment standards included in
40 CFR Part 133, Secondary Treatment Regulation. Secondary treatment is defined by the Best Practicable
Waste Treatment Technology criteria, which are minimum standards required of all publicly owned treatment
works.
Oil and Grease, pH, and E-coli
Limits proposed for oil and grease are based on Water Quality Standards found in OAC 3745-1-37 for the
protection of adverse aesthetic conditions. Limits for pH are based on Water Quality Standards found in OAC
3745-1-35 for the protection of aquatic life. These are a continuation of existing permit limits.
The 2015 Ohio River Valley Water Sanitation Commission (ORSANCO) Pollution Control Standards no longer
include fecal coliform criteria for the summer recreation season. Only E. coli criteria apply. Ohio’s WQS for the
protection of recreation use designations, OAC 3745-1-37, and for the Ohio River, OAC 3745-1-32, also include
summer E. coli criteria. The proposed summer E. coli limits are based on these standards. Based on best
technical judgment (BTJ), it is expected the plant can comply with the new limits at the start of the next
disinfection season and does not require a compliance schedule. The limits proposed for winter fecal coliform
are based on the Water Quality Standards for the Ohio River (OAC 3745-1-32) which are also protective of the
ORSANCO human health public water supply use designation.
Residual Chlorine
The proposed limit for total residual chlorine is based on wasteload allocation as limited by the inside mixing
zone maximum (IMZM). The IMZM is a value calculated to avoid rapidly lethal conditions in the effluent
mixing zone. This is a continuation of the existing permit limit. The effluent limit for chlorine at outfall 001 is
less than the quantification level of 0.050 mg/L. However, a pollutant minimization program is not required
because the dosing rate of dechlorination chemicals ensures that the water quality based effluent limit is being
met.
Mercury
The Ohio EPA risk assessment (Table 15) places Mercury in group 5. This placement, as well as the data in
Table 10 and Table 11, indicates that the reasonable potential to exceed WQS exists and limits are necessary to
protect water quality. For these parameters, the PEQ is greater than 100 percent of the WLA. Pollutants that
meet this requirement must have permit limits under OAC 3745-33-07(A)(1).
Ohio EPA granted the City of Ironton coverage under the Ohio general mercury variance in the NPDES permit
0PD00007*KD that became effective on October 1, 2012. The permit included a monthly average variance
based limit of 53 ng/l until October 1, 2013, along with requirements for the City to implement a pollutant
minimization program for mercury. A compliance schedule item was included to obtain variance coverage from
the Ohio River Valley Water Sanitation Commission (ORSANCO) under Section 4-F of their Pollution Control
Standards (2012 Revision) or comply with a monthly average water quality based effluent limit of 12.ng/l.
On June 6, 2013, ORSANCO passed Resolution 1-13 which considered a discharger in compliance with Section
4-F of its 2012 Standards if the discharger is subject to an NPDES permit that includes a compliance schedule
for the eventual elimination of the mixing zone for bioaccumulative chemicals of concern on or before October
16, 2013. The NPDES permit was modified effective on October 1, 2013, to 0PD00007*LD which:
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 12 of 30
- Removed the existing compliance schedule for submitting a variance application to ORSANCO.
- Add a new compliance schedule that required the City to continue implementation of its pollutant
minimization program (PMP).
- Included an interim monthly average mercury limit of 53 ng/l effective until September 1, 2017.
- Included a final monthly average mercury limit of 12 ng/l beginning September 1, 2017.
- Removed language authorizing coverage under Ohio’s mercury variance from Part II of the permit.
These changes aligned the NPDES permit with the ORSANCO standards, and granted a full five years to
comply with the WQBEL for mercury of 12 ng/L. The following language was included in the modification fact
sheet, “If it is able to meet the Oho EPA and ORSANCO application requirements in place in early 2017, the
City can apply for mercury variance coverage at that time.”
At the time of the application submittal for this renewal, Ironton WWTP was not meeting an annual average
effluent concentration for mercury of 12 ng/L. Since the Agency has effectively already granted a five year term
to be able to meet this average criteria for general variance coverage, it has been determined that Ironton WWTP
is not eligible for coverage under the general mercury variance and therefore the WQBEL will remain in the
permit.
If in the future, Ironton WWTP is able to demonstrate the ability to achieve the 12 ng/L annual average effluent
concentration it may be eligible for coverage under the general mercury variance provisions.
Bromomethane, Copper, and Dissolved Hexavalent Chromium
The Ohio EPA risk assessment (Table 15) places bromomethane, copper, and dissolved hexavalent chromium
in group 4. This placement, as well as the data in Table 10 and Table 11, support that these parameters do not
have the reasonable potential to contribute to WQS exceedances, and limits are not necessary to protect water
quality. Monitoring for Group 4 pollutants (where PEQ exceeds 50 percent of the WLA) is required by OAC
3745-33-07(A)(2). Monitoring at a low frequency for copper and dissolved hexavalent chromium is proposed to
document that these pollutants continue to remain at low levels. Monitoring for bromoethane will be completed
as part of priority pollutants scans to be completed in preparation for future NPDES permit renewals. This
information should be sufficient to document low reasonable potential for Bromomethane.
Cadmium, Chromium, Lead, Nickle, Total Filterable Residue, and Zinc
The Ohio EPA risk assessment (Table 15) places cadmium, chromium, lead, total filterable residue, and zinc in
groups 2 and 3. This placement, as well as the data in Table 10 and Table 11, support that these parameters do
not have the reasonable potential to contribute to WQS exceedances, and limits are not necessary to protect
water quality. Monitoring at a low frequency is proposed to document that these pollutants continue to remain at
low levels.
Arsenic, Barium, Bis-2ethylhexyl phthalate, Butyl benzyl phthalate, Chloroform, Chrysene, Di-n-butyl
phthalate, 1,4-Dichlorobenzene, 2,4-Dichlorophenol, Diethyl phthalate, Fluoranthene, Iron, Phenanthrene,
Selenium, Strontium
The Ohio EPA risk assessment (Table 15) places arsenic, barium, bis-2ethylhexyl phthalate, butyl benzyl
phthalate, chloroform, chrysene, di-n-butyl phthalate, 1,4-dichlorobenzene, 2,4-dichlorophenol, diethyl
phthalate, fluoranthene, iron, phenanthrene, selenium, strontium in groups 2 and 3. This placement, as well as
the data in Table 10 and Table 11, support that these parameters do not have the reasonable potential to
contribute to WQS exceedances, and limits are not necessary to protect water quality. No new monitoring is
proposed.
Flow Rate and Temperature
Monitoring for flow rate and temperature is proposed to continue in order to evaluate the performance of the
treatment plant.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 13 of 30
Dissolved Oxygen and Ammonia-Nitrogen
For a facility required to meet secondary treatment standards, monitoring of ammonia-N and dissolved oxygen
is appropriate and is proposed. These are a continuation of existing permit conditions. Current ammonia and
dissolved oxygen levels were compared to the WLA and show low reasonable potential to exceed the WQS.
Total Phosphorus and Dissolved Orthophosphate
Monitoring for total phosphorus and dissolved orthophosphate (as P) is required by Ohio Senate Bill 1 (ORC
6111.03), which was signed by the Governor on April 2, 2015. Monitoring for total phosphorus and dissolved
orthophosphate will further develop nutrient datasets that are used in stream and watershed assessments and
studies. Because Ohio EPA monitoring, as well as other in-stream monitoring, is taken by grab sample, grab
samples are proposed for orthophosphate to maintain consistent data. The grab samples must be filtered within
15 minutes of collection using a 0.45-micron filter. The filtered sample must be analyzed within 48 hours.
Total Kjeldahl nitrogen (TKN) and Nitrate+nitrite-nitrogen
Based on best technical judgment, monitoring is proposed to continue for total Kjeldahl nitrogen (TKN) and
nitrate+nitrite-nitrogen. The purpose of the monitoring is to obtain data that can be used in evaluating nutrient
impacts in the Ohio River.
Whole Effluent Toxicity Reasonable Potential
Based on evaluating the WET data presented in Table 10 and Table 11 and other pertinent data under the
provisions of OAC 3745-33-07(B), the City of Ironton WWTP is placed in Category 3 with respect to WET.
While this indicates that the plant's effluent does not currently pose a toxicity problem, annual toxicity testing is
proposed consistent with the minimum monitoring requirements at OAC 3754-33-07(B)(11). Annual acute
toxicity monitoring is proposed for the life of the permit. The proposed monitoring will adequately characterize
toxicity in the plant's effluent to assure it does not exhibit reasonable potential.
Additional Monitoring Requirements
Additional monitoring requirements proposed at the influent station are included for all facilities in Ohio and
vary according to the type and size of the discharge. In addition to permit compliance, this data is used to assist
in the evaluation of effluent quality and treatment plant performance and for designing plant improvements and
conducting future stream studies.
Sludge
Limits and monitoring requirements proposed for the disposal of sewage sludge by the following management
practices are based on OAC 3745-40, removal to sanitary landfill.
OTHER REQUIREMENTS
Sanitary Sewer Overflow Reporting
Provisions for reporting SSOs are again proposed in this permit. These provisions include: the reporting of the
system-wide number of SSO occurrences on monthly operating reports; telephone notification of Ohio EPA and
the local health department, and 5-day follow up written reports for certain high risk SSOs; and preparation of
an annual report that is submitted to Ohio EPA and made available to the public. Many of these provisions were
already required under the “Noncompliance Notification”, “Records Retention”, and “Facility Operation and
Quality Control” general conditions in Part III of Ohio NPDES permits.
Operator Certification and Operator of Record
Operator certification requirements have been included in Part II of the permit in accordance with rules adopted
in December 2006 (OAC 3745-7-02). These rules require the City of Ironton WWTP to have a Class III
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 14 of 30
wastewater treatment plant operator in charge of the sewage treatment plant operations discharging through
outfall 001. These rules also require the permittee to designate one or more operator of record to oversee the
technical operation of the sewerage system.
Outfall Signage
Part II of the permit includes requirements for the permittee to place and maintain a sign at each outfall to the
Ohio River providing information about the discharge. Signage at outfalls is required pursuant to OAC 3745-
33-08(A).
Public Water Supply Notification
An addition to OAC 3745-33-08 requires that permittees discharging wastewater within ten miles of a
downstream public water supply intake located on the same waterway must develop and implement notification
procedures in conjunction with the downstream public water supply operator in the event of a spill, separate
sewer overflow, bypass or upset that reaches waters of the state. Since the cities of Ironton, Ohio and Russel,
Kentucky operate public water supply intakes less than ten miles downstream from the City of Ironton WWTP,
an item in Part II of the permit requires the development of notification procedures within six months after the
effective date of the permit.
Part III
Part III of the permit details standard conditions that include monitoring, reporting requirements, compliance
responsibilities, and general requirements.
Storm Water Compliance
To comply with industrial storm water regulations, the permittee submitted a form for "No Exposure
Certification" which was signed on March 19, 2018. The certification number is 0GRN00354*AG. Compliance
with the industrial storm water regulations must be re-affirmed every five years. No later than March 16, 2023,
the permittee must submit a new form for "No Exposure Certification" or make other provisions to comply with
the industrial storm water regulations.
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 15 of 30
Figure 1. Location of Ironton WWTP
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 16 of 30
Figure 2. Diagram of Wastewater Treatment System
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 17 of 30
Table 1. Sewage Sludge Removal
0PD00007 between 10/1/2012 - 10/1/2017
Year Dry Tons Removed
Code 51129
2012a 459
2013 262
2014 190
2015 582
2016b 888 a = data set begins on 10/1/12 b = data set ends on 10/1/17
Table 2. Effluent Violations for Outfall 001
0PD00007 between 10/1/2012 - 10/1/2017
PARAMETER 2012a 2013 2014 2015 2016 2017b
CBOD 5 day 0 0 0 0 3 0
Chlorine, Total Residual 4 3 3 0 0 0
Fecal Coliform 0 1 0 1 0 1
Mercury, Total (Low Level) 0 0 0 1 0 0
Oil and Grease 0 3 2 1 1 0
Total Suspended Solids 4 0 0 0 0 0
pH, Maximum 1 0 0 0 0 0
pH, Minimum 3 0 0 0 0 0
Total 12 7 5 3 4 1 a = data set begins on 10/1/12 b = data set ends on 10/1/17
Table 3. Average Annual Effluent Flow Rates for Outfall 001
0PD00007 between 10/1/2012 - 10/1/2017
Flow Rate (Million Gallons per Day)
Year # obs Average Median 95th Percentile Maximum
2012a 92 1.951586957 1.7625 3.852 4.44
2013 362 1.549497238 1.345 2.83 4.16
2014 363 1.566446281 1.36 2.746 3.55
2015 365 1.57860274 1.33 2.886 3.9
2016 366 1.680382514 1.54 2.77 4.16
2017b 273 1.628681319 1.39 2.724 20.4 a = data set begins on 10/1/12 b = data set ends on 10/1/17
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 18 of 30
Table 4. Sanitary Sewer Overflows Discharges
0PD00007 between 10/1/2012 - 10/1/2017
Year Number of SSOs
2012a 87.5
2013 452
2014 522
2015 135
2016 3
2017b 2 a = data set begins on 10/1/12 b = data set ends on 10/1/17
Table 5. Combined Sewer Overflow Discharges
0PD00007 between 10/1/2012 - 10/1/2017
Station # Of CSOs
002 24
004 29
007 401
008 166
009 59
010 111
011 88
017 116
018 139
Table 6. Calculated Phosphorus Loadings
0PD00007 between 10/1/2012 - 10/1/2017
For Months May - October
Year
Median Phosphorus
(mg/L)
Median Flow
(MGD)
Median Loading
(kg/day)
2013 3.12 1.215 14.4
2014 2.23 1.97 16.7
2015 2.75 1.14 11.6
2016 2.72 1.265 12.5
2017 2.15 1.35 10.8 MGD = million gallons per day
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 19 of 30
Table 7. Effluent Characterization Using Ohio EPA data
Parameter Units 5/16/2012
Aluminum µg/l 555
Arsenic µg/l 1.6
Barium µg/l 35
Bis(2-ethylhexyl) phthalate µg/l 1.7
Bromomethane µg/l 8.8
Di-N-Butylphthalate µg/l 0.3
Butyl benzyl phthalate µg/l 0.6
Chloroform µg/l 0.58
Chrysene µg/l 0.1
1,4-Dichlorobenzene µg/l 0.49
2,4-Dichlorophenol µg/l 0.1
Diethyl phthalate µg/l 0.9
Fluoranthene µg/l 0.1
Copper µg/l 9.1
Iron µg/l 623
Magnesium mg/l 8.7
Manganese µg/l 327
Nickel µg/l 3.6
Phenanthrene µg/l 0.1
Selenium µg/l 2
Strontium µg/l 166
Toluene µg/l 0.6
Total Filterable Residue mg/l 324
2,4,6-Trichlorophenol µg/l 0.1
Zinc µg/l 34
AA = not detected (analytical method detection limit)
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 20 of 30
Table 8. Effluent Characterization Using Self-Monitoring Data
Effluent Monitoring Data for 0PD00007*MD between 10/1/2012 and 10/1/2017
Outfall Parameter
Current Permit
Limits Percentiles
Data Range Unit 30 Day Daily # Obs 50th 95th
001
Water Temperature °C Monitoring Only 1810 17 26 0 - 35
Dissolved Oxygen mg/L Monitoring Only 1298 5.53 8.69 1.4 - 56.2
Total Suspended Solids kg/day 194 290w 772 43.2 168 0 - 670
Total Suspended Solids mg/L 30 45w 772 8 23 0 - 101
Oil and Grease, mg/L -- 10 242 0 7.16 0 - 55.5
Nitrogen, Ammonia mg/L Monitoring Only 767 7.77 17.9 .3 - 36
Nitrogen Kjeldahl, Total mg/L Monitoring Only 65 9.9 25.4 2.05 - 29.6
Nitrite Plus Nitrate, Total mg/L Monitoring Only 58 9.48 14 .56 - 16.7
Ortho Phospate, Total mg/L Monitoring Only 13 1.23 2.96 0 - 4.68
Phosphorus, Total (P) mg/L Monitoring Only 32 2.14 3.49 .05 - 7.9
Dissolved Orthophosphate mg/L Monitoring Only 17 1.64 2.33 .73 - 2.35
Nickel µg/L Monitoring Only 18 4.05 5.38 0 - 6.4
Zinc µg/L Monitoring Only 18 39.4 51.9 20.2 - 55.8
Cadmium µg/L Monitoring Only 18 -- -- 0 - 0
Lead µg/L Monitoring Only 18 1.4 5.84 .8 - 10
Chromium µg/L Monitoring Only 18 .5 1.32 0 - 1.4
Copper µg/L Monitoring Only 18 13.7 21.5 1.3 - 21.8
Chromium, Dissolved
Hexavalent µg/L Monitoring Only 17 0 1.96 0 - 7
Fecal Coliform - Summer #/100 mL 200 400w 377 160 215 54 - 3120
Fecal Coliform - Winter #/100 mL 1000 2000w 388 292 1630 0 - 1960
Flow Rate MGD Monitoring Only 1821 1.41 2.88 .13 - 20.4
Chlorine, Total Residual mg/L -- 0.038 1295 .002 .03 0 - 2.2
Mercury, Total (Low Level) kg/day 0.000342 0.011 59 .0000637 .000233
.0000149 -
.000479
Mercury, Total (Low Level) ng/L 53 1700 59 12.4 43.4 2.86 - 50.7
Acute Toxicity,
Ceriodaphnia dubia TUa Monitoring Only 5 1 4.2 0 - 5
Acute Toxicity, Pimephales
promelas TUa Monitoring Only 5 1 8.2 0 - 10
pH, Maximum S.U. -- 9.0 1298 7.2 7.53 6.1 - 9.94
pH, Minimum S.U. -- 6.5m 1299 7 7.3 6.19 - 7.6
Residue, Total Filterable mg/L Monitoring Only 18 350 477 10 - 540
CBOD 5 day kg/day 161 258w 768 55.9 164 4.16 - 364
CBOD 5 day mg/L 25 40w 768 10 23 1 - 44
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 21 of 30
Table 8 Effluent Characterization Using Self-Monitoring Data (continued)
Effluent Monitoring Data for 0PD00007*MD between 10/1/2012 and 10/1/2017
Outfall Parameter
Current Permit
Limits Percentiles Data Range
Unit 30 Day Daily # Obs 50th 95th
002 Overflow Occurrence No./Month Monitoring Only 43 1 1 0 - 1
004 Overflow Occurrence No./Month Monitoring Only 29 1 1 1 - 1
007
Flow Rate MGD Monitoring Only 74 .132 10 0 - 1000
Overflow Occurrence No./Month Monitoring Only 395 1 1 0 - 9
Bypass Duration Hr/Month Monitoring Only 60 .25 10.2 0 - 24
008 Flow Rate MGD Monitoring Only 1 1 1 1 - 1
Overflow Occurrence No./Month Monitoring Only 166 1 1 1 - 1
009 Flow Rate MGD Monitoring Only 1 1 1 1 - 1
Overflow Occurrence No./Month Monitoring Only 59 1 1 1 - 1
010
Flow Rate MGD Monitoring Only 17 1 1 1 - 1
Overflow Occurrence No./Month Monitoring Only 111 1 1 1 - 1
Bypass Duration Hr/Month Monitoring Only 1 1 1 1 - 1
011
Flow Rate MGD Monitoring Only 3 .1 .91 .07 - 1
Overflow Occurrence No./Month Monitoring Only 87 1 1 1 - 2
Bypass Duration Hr/Month Monitoring Only 2 4.25 7.63 .5 - 8
017 Flow Rate MGD Monitoring Only 6 1 1 1 - 1
Overflow Occurrence No./Month Monitoring Only 116 1 1 1 - 1
018
Flow Rate MGD Monitoring Only 4 .56 30.8 .12 - 36
Overflow Occurrence No./Month Monitoring Only 139 1 1 1 - 1
Bypass Duration Hr/Month Monitoring Only 2 4.25 7.63 .5 - 8
300 Overflow Occurrence No./Month Monitoring Only 400 1 10 0 - 16
586 Sludge Fee Weight dry tons Monitoring Only 5 459 827 190 - 888
601
Total Precipitation Inches Monitoring Only 1820 0 .8 0 - 15
pH S.U. Monitoring Only 1307 7.25 7.52 6.08 - 8.2
Total Suspended Solids mg/L Monitoring Only 768 76 236 1.26 - 800
Flow, Peak Rate MGD Monitoring Only 1823 2 4 .2 - 158
Mercury, Total (Low Level) ng/L Monitoring Only 58 28.2 118 0 - 188
CBOD 5 day mg/L Monitoring Only 768 101 171 1.27 - 981
w = weekly average
m = minimum value
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 22 of 30
Table 9. Projected Effluent Quality for Outfall 001
Parameter Units Number of
Samples
Number
>MDL
PEQ
Average
PEQ
Maximum
Aluminum μg/L 1 1 2511.93 3441
Ammonia (Summer) mg/L 260 260 10.477 20.585
Ammonia (Winter) mg/L 191 191 13.067 24.225
Arsenic μg/L 1 1 7.2416 9.92
Barium μg/L 1 1 158.41 217
Bis(2-ethylhexyl)phthalate μg/L 1 1 7.6942 10.54
Bromomethane μg/L 1 1 39.8288 54.56
Butyl benzyl phthalate μg/L 1 1 2.7156 3.72
Cadmium μg/L 18 0 -- --
Chloroform
(Trichloromethane) μg/L 1 1 2.62508 3.596
Chlorine, Total Residual mg/L 1327 754 0.025215 0.052094
Chromium μg/L 18 9 1.431 1.96
Hexavalent Chromium
(Dissolved) μg/L 17 8 13.29 18.2
Chrysene μg/L 1 1 0.4526 0.62
Copper μg/L 19 19 22.28 30.52
Di-n-butyl phthalate μg/L 1 1 1.3578 1.86
1,4-Dichlorobenzene μg/L 1 1 2.21774 3.038
2,4-Dichlorophenol μg/L 1 1 0.4526 0.62
Diethyl phthalate μg/L 1 1 4.0734 5.58
Fluoranthene μg/L 1 1 0.4526 0.62
Iron μg/L 1 1 2819.698 3862.6
Lead μg/L 18 18 4.8813 8.417
Magnesium mg/L 1 1 39.3762 53.94
Manganese μg/L 1 1 1480.002 2027.4
Mercury ng/L 60 60 27.274 41.85
Nickel μg/L 19 18 5.0977 6.3769
Nitrate-N + Nitrite-N mg/L 59 59 16.156 24.092
Phenanthrene μg/L 1 1 0.4526 0.62
Phosphorus mg/L 33 33 7.2198 12.015
Selenium μg/L 1 1 9.052 12.4
Strontium μg/L 1 1 751.316 1029.2
TKN mg/L 66 66 20.007 29.802
Toluene μg/L 1 1 2.7156 3.72
Total Filterable Residue mg/L 19 19 551.9 756
Zinc μg/L 19 19 52.243 67.685 MDL = analytical method detection limit
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 23 of 30
Table 10. Summary of Acute and Chronic Toxicity Results
Ceriodaphnia Dubia Pimephales promelas
Date TUa TUa
6/18/2013 5 10
6/6/2014 AA --
6/29/2014 -- AA
6/5/2015 1 1
6/14/2016 AA AA
6/2/2017 1 1
AA = non-detection; analytical method detection limit of 1.0 TUa,
TUa = acute toxicity unit
Table 11. Ohio EPA Toxicity Screening Results for Outfall 001
Pimephales promelas Ceriodaphnia dubia
%M %M
Date 24 hours 48 hours 24 hours 48 hours
2/22/2016 0 0 0 0
2/23/2016 0 0 0 0
2/22/16-2/23/16a 0 5 0 0 a = 24-hour composite sample
%M = percent mortality in 100% effluent
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 24 of 30
Table 12. Water Quality Criteria in the Study Area
Outside Mixing Zone Criteria Inside
Average Maximum Mixing
Human Agri- Aquatic Aquatic Zone
Parameter Units Health culture Life Life Maximum
Aluminum μg/L -- -- -- -- --
Ammonia (Summer) mg/L -- -- 0.5 -- --
Ammonia (Winter) mg/L -- -- 0.9 -- --
Arsenic μg/L 50 100 150 340 680
Barium μg/L -- -- 220 2000 4000
Bis(2-ethylhexyl)phthalate μg/L 18c -- 8.4 1100 2100
Bromomethane μg/L 48 -- 16 38 75
Butyl benzyl phthalate μg/L 3000 -- 23 130 260
Cadmium μg/L -- 50 2.9 5.8 12
Chlorine, Total Residual mg/L -- -- 0.011 0.019 0.038
Chloroform (Trichloromethane) μg/L 57c -- 140 1300 2600
Chromium μg/L -- 100 100 2200 4300
Hexavalent Chromium
(Dissolved) μg/L -- -- 11 16 31
Chrysene μg/L 0.044c -- -- -- --
Copper μg/L 1300 500 11 17 34
Di-n-butyl phthalate μg/L 2700 -- -- -- --
1,4-Dichlorobenzene μg/L 400 -- 9.4 57 110
2,4-Dichlorophenol μg/L 93 -- 11 110 210
Diethyl phthalate μg/L 23000 -- 220 980 2000
Fluoranthene μg/L 300 -- 0.8 3.7 7.4
Iron μg/L -- 5000 -- -- --
Lead μg/L -- 100 8.4 160 320
Total Filterable Residue mg/L -- -- 1500 -- --
Magnesium mg/L -- -- -- -- --
Manganese μg/L -- -- -- -- --
Mercury ng/L 12 10000 910 1700 3400
Nickel - TR μg/L 610 200 63 560 1100
Nitrate-N + Nitrite-N mg/L 10 100 -- -- --
Phenanthrene μg/L -- -- 2.3 31 61
Phosphorus mg/L -- -- -- -- --
Selenium μg/L 170 50 5 -- --
Strontium μg/L -- -- 21000 40000 81000
TKN mg/L -- -- -- -- --
Toluene μg/L 6800 -- 62 560 1100
Zinc μg/L 9100 25000 140 140 290
c = carcinogen
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 25 of 30
Table 13. Instream Conditions and Discharger Flow
Parameter Units Season Value Basis
Stream Flows
1Q10 cfs annual 10000 ORSANCO 2015 Pollution control standards
7Q10 cfs annual 10000 ORSANCO 2015 Pollution control standards
summer 0
winter 0
30Q10 cfs summer 1000 10% of 7Q10 for Ohio river direct
winter 1000 10% of 7Q10 for Ohio river direct
90Q10 cfs annual 0
Harmonic Mean cfs annual 38400 ORSANCO 2015 Pollution control standards
Mixing Assumption % average 10
maximum 1
Hardness, OMZ mg/L annual 124 ORSANCO, n=69: (2003-2015); median
Hardness, IMZ mg/L annual 124 ORSANCO, n=69: (2003-2015); median
pH S.U. summer 8.322 ORSANCO Greenup Pool 9/2011 - 1/2016, 75th percentile
winter 8.65 ORSANCO Greenup Pool 9/2011 - 1/2016, 75th percentile
Temperature ºC summer 25.38 ORSANCO Greenup Pool 9/2011 - 1/2016, 75th percentile
winter 5.75 ORSANCO Greenup Pool 9/2011 - 1/2016, 75th percentile
Ironton WWTP flow cfs annual 2.6303
Background Water Quality
Aluminum μg/L 392.62 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Arsenic μg/L 0.705 ORSANCO; 1/03 - 9/14; n=72; 5<MDL; 50th Percentile
Barium μg/L 42.935 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Bis(2-ethylhexyl)phthalate μg/L No representative data available.
Bromomethane μg/L No representative data available.
Butyl benzyl phthalate μg/L No representative data available.
Cadmium μg/L 0.05 ORSANCO; 1/03 - 9/14; n=72; 68<MDL; 50th Percentile
Chloroform
(Trichloromethane) μg/L No representative data available.
Chromium μg/L 1.415 ORSANCO; 1/03 - 9/14; n=72; 4<MDL; 50th Percentile
Hexavalent Chromium
(Dissolved) μg/L No representative data available.
Chrysene μg/L No representative data available.
Copper μg/L 2.15 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Di-n-butyl phthalate μg/L No representative data available.
1,4-Dichlorobenzene μg/L No representative data available.
2,4-Dichlorophenol μg/L No representative data available.
Diethyl phthalate μg/L No representative data available.
Fluoranthene μg/L No representative data available.
Iron μg/L 711 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Lead μg/L 0.835 ORSANCO; 1/03 - 9/14; n=72; 6<MDL; 50th Percentile
Total Filterable Residue mg/L 189 ORSANCO; 2011-2012; n=38; 0<MDL; 50th Percentile
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 26 of 30
Magnesium mg/L 8.46 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Manganese μg/L 101.15 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Mercury ng/L 2.55 ORSANCO; 1/03 - 9/14; n=71; 16<MDL; 50th Percentile
Nickel μg/L 2.675 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Nitrate-N + Nitrite-N mg/L 0.78 ORSANCO; 1/03 - 5/15; n=68; 0<MDL; 50th Percentile
Phenanthrene μg/L No representative data available.
Phosphorus mg/L 0.0565 ORSANCO; 1/03 - 5/15; n=69; 0<MDL; 50th Percentile
Selenium μg/L 0.52 ORSANCO; 1/03 - 9/14; n=72; 30<MDL; 50th Percentile
Strontium μg/L 685 Ohio EPA; 1999-2003; n=1731; 0<MDL; 50th Percentile
TKN mg/L 0.5 ORSANCO; 1/03 - 5/15; n=69; 3<MDL; 50th Percentile
Toluene μg/L No representative data available.
Zinc μg/L 5.35 ORSANCO; 1/03 - 9/14; n=72; 0<MDL; 50th Percentile
Chlorine, Total Residual mg/L No representative data available.
Ammonia (Summer) mg/L 0.015
ORSANCO; 11/12- 11-17; n=22; 13<MDL; RC Byrd
pool bimonthly data, 50th Percentile
Ammonia (Winter) mg/L 0.0435
ORSANCO; 11/12- 11-17; n=4; 1<MDL; RC Byrd pool
bimonthly data, 50th Percentile MDL = analytical method detection limit
n = number of samples
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 27 of 30
Table 14. Summary of Effluent Limits to Maintain Applicable Water Quality Criteria
Outside Mixing Zone Criteria Inside
Average Maximum Mixing
Human Agri- Aquatic Aquatic Zone
Parameter Units Health culture Life Life Maximum
Aluminum μg/L -- -- -- -- --
Ammonia (Summer) mg/L -- -- 18.94 -- --
Ammonia (Winter) mg/L -- -- 33.46 -- --
Arsenic μg/L 187462 145062 56910 13239 680
Barium μg/L -- -- 67537 76405 4000
Bis(2-ethylhexyl)phthalate μg/L 26296 -- 3202 42920 2100
Bromomethane μg/L 182537 -- 6099 1483 75
Butyl benzyl phthalate μg/L 11408543 -- 8767 5072 260
Cadmium μg/L -- 72972 1086 224 12
Chlorine, Total Residual mg/L -- -- 4.2 0.74 0.038
Chloroform (Trichloromethane) μg/L 83272 -- 53366 50724 2600
Chromium μg/L -- 144025 37581 85787 4300
Hexavalent Chromium
(Dissolved) μg/L -- -- 4193 624 31
Chrysene μg/L 64 -- -- -- --
Copper μg/L 4935528 727316 3376 582 34
Di-n-butyl phthalate μg/L 10267689 -- -- -- --
1,4-Dichlorobenzene μg/L 1521139 -- 3583 2224 110
2,4-Dichlorophenol μg/L 353665 -- 4193 4292 210
Diethyl phthalate μg/L 87465497 -- 83861 38238 2000
Fluoranthene μg/L 1140854 -- 305 144 7.4
Iron μg/L -- 6266552 -- -- --
Lead μg/L -- 144872 2884 6211 320
Total Filterable Residue mg/L -- -- 499922 -- --
Magnesium mg/L -- -- -- -- --
Manganese μg/L -- -- -- -- --
Mercury ng/L 12 10000 910 1700 3400
Nickel μg/L 2309567 288277 22998 21749 1100
Nitrate-N + Nitrite-N mg/L 35063 144952 -- -- --
Phenanthrene μg/L -- -- 877 1210 61
Phosphorus mg/L -- -- -- -- --
Selenium μg/L 644507 72286 1708 -- --
Strontium μg/L -- -- 7744454 1534696 81000
TKN mg/L -- -- -- -- --
Toluene μg/L 25859364 -- 23633 21850 1100
Zinc μg/L 34585574 36514927 51332 5259 290
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 28 of 30
Table 15. Parameter Assessment
Group 1: Due to a lack of criteria, the following parameters could not be evaluated at this time.
Aluminum Magnesium Manganese
TKN
Group 2: PEQ < 25 percent of WQS or all data below minimum detection limit.
WLA not required. No limit recommended; monitoring optional.
Arsenic Butyl benzyl phthalate Cadmium
Chloroform (Trichloromethane) Chromium Di-n-butyl phthalate
1,4-Dichlorobenzene 2,4-Dichlorophenol Diethyl phthalate
Nickel Phenanthrene Strontium
Toluene
Group 3: PEQmax < 50 percent of maximum PEL and PEQavg < 50 percent of average PEL.
No limit recommended; monitoring optional.
Barium Bis(2-ethylhexyl) phthalate Chrysene
Fluoranthene Iron Lead
Dissolved Solids Nitrate-N + Nitrite-N Selenium
Zinc
Group 4: PEQmax >= 50 percent, but < 100 percent of the maximum PEL or
PEQavg >= 50 percent, but < 100 percent of the average PEL. Monitoring is appropriate.
Bromomethane Hexavalent Chromium
(Dissolved)
Copper
Group 5: Maximum PEQ >= 100 percent of the maximum PEL or average PEQ >= 100
percent of the average PEL, or either the average or maximum PEQ is between 75
and 100 percent of the PEL and certain conditions that increase the risk to the
environment are present. Limit recommended.
Limits to Protect Numeric Water Quality Criteria
Recommended Effluent Limits
Parameter Units Average Maximum
Mercury ng/L 12 1700
Chlorine, Total Residual mg/L -- 0.038
PEL = preliminary effluent limit
PEQ = projected effluent quality
WLA = wasteload allocation
WQS = water quality standard
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 29 of 30
Table 16. Final Effluent Limits for Outfall 001
Parameter Units
Concentration Loadinga Basis
30 Day
Average
Daily
Maximum
30 Day
Average
Daily
Maximum
Water Temperature °C Monitoring Only M
Dissolved Oxygen mg/L Monitoring Only BPJ/RP
Total Suspended Solids mg/L 30 45w 194 290w BPT
Oil and Grease mg/L -- 10 -- -- WQS
Nitrogen, Ammonia (NH3) mg/L Monitoring Only BPJ/RP
Nitrogen Kjeldahl, Total mg/L Monitoring Only M
Nitrite Plus Nitrate, Total mg/L Monitoring Only M
Phosphorus, Total (P) mg/L Monitoring Only SB1
Orthophosphate, Dissolved (as P) mg/L Monitoring Only SB1
Nickel, Total Recoverable µg/L Monitoring Only RP
Zinc, Total Recoverable µg/L Monitoring Only RP
Cadmium, Total Recoverable µg/L Monitoring Only RP
Lead, Total Recoverable µg/L Monitoring Only RP
Chromium, Total Recoverable µg/L Monitoring Only RP
Copper, Total Recoverable µg/L Monitoring Only RP
Chromium, Dissolved Hexavalent µg/L Monitoring Only RP
Fecal Coliform (Winter) #/100 mL 200 400w -- -- WQS
E. coli (Summer) #/100 mL 126 284w -- -- WQS
Flow Rate MGD Monitoring Only M
Chlorine, Total Residual mg/L -- 0.038 -- -- WLA
Mercury, Total (Low Level) ng/L 12 1700 0.000078 0.011 WLA
Acute Toxicity, Ceriodaphnia dubia TUa Monitoring Only WET
Acute Toxicity, Pimephales
promelas TUa Monitoring Only WET
pH, Maximum S.U. -- 9.0 -- -- WQS
pH, Minimum S.U. -- 6.5m -- -- WQS
Total Filterable Residue mg/L Monitoring Only RP
CBOD 5 day mg/L 25 40w 161 258w BPT a Effluent loadings based on average design discharge flow of 1.7 MGD.
b Definitions: BPJ = Best Professional Judgment; BPT = Best Practicable Waste Treatment Technology, 40 CFR Part 133,
Secondary Treatment Regulation; M = Division of Surface Water NPDES Permit Guidance 1: Monitoring
frequency requirements for Sanitary Discharges; RP = Reasonable Potential for requiring water quality-based
effluent limits and monitoring requirements in permits (OAC 3745-33-07(A)); SB1 = Implementation of
Senate Bill 1 (ORC 6111.03); WET = Minimum testing requirements for whole effluent toxicity [OAC 3745-
33-07(B)(11)]; WLA = Wasteload Allocation procedures (OAC 3745-2); WLA/IMZM = Wasteload
Allocation limited by Inside Mixing Zone Maximum; WQS = Ohio Water Quality Standards (OAC 3745-1) m minimum w weekly average limit
Fact Sheet for NPDES Permit Renewal, Ironton WWTP, 2018
Page 30 of 30
Addendum 1. Acronyms
ABS Anti-backsliding
BPJ Best professional judgment
CFR Code of Federal Regulations
CMOM Capacity Management, Operation, and Maintenance
CONSWLA Conservative substance wasteload allocation
CSO Combined sewer overflow
CWA Clean Water Act
DMR Discharge Monitoring Report
DMT Dissolved metal translator
IMZM Inside mixing zone maximum
LTCP Long-term Control Plan
MDL Analytical method detection limit
MGD Million gallons per day
NPDES National Pollutant Discharge Elimination System
OAC Ohio Administrative Code
Ohio EPA Ohio Environmental Protection Agency
ORC Ohio Revised Code
ORSANCO Ohio River Valley Water Sanitation Commission
PEL Preliminary effluent limit
PEQ Projected effluent quality
PMP Pollution Minimization Program
PPE Plant performance evaluation
SSO Sanitary sewer overflow
TMDL Total Daily Maximum Load
TRE Toxicity reduction evaluation
TU Toxicity unit
U.S. EPA United States Environmental Protection Agency
WET Whole effluent toxicity
WLA Wasteload allocation
WPCF Water Pollution Control Facility
WQBEL Water-quality-based effluent limit
WQS Water Quality Standards
WWTP Wastewater Treatment Plant
Recommended