&EPA
Fact Sheet
The U.S. Environmental Protection Agency (EPA)
Proposes to Reissue a National Pollutant Discharge Elimination System (NPDES)
Permit to Discharge Pollutants Pursuant to the Provisions of the Clean Water
Act (CWA) to:
Haines Borough
Haines Borough Wastewater Treatment Plant
Public Comment Start Date: May 4, 2023
Public Comment Expiration Date: June 19, 2023
Technical Contact: Abigail Conner
(206) 553-6358
800-424-4372, ext. 6358 (within Alaska, Idaho, Oregon, and
Washington)
conner.abigail@epa.gov
EPA Proposes to Reissue the NPDES Permit
EPA proposes to reissue the NPDES permit for the facility referenced above. The draft
permit places conditions on the discharge of pollutants from the wastewater treatment
plant to waters of the United States. In order to ensure protection of water quality and
human health, the permit places limits on the types and amounts of pollutants that can be
discharged from the facility.
This Fact Sheet (FS) includes:
¦ information on public comment, public hearing, and appeal procedures
¦ a listing of proposed effluent limitations and other conditions for the facility
¦ a map and description of the discharge location
¦ technical material supporting the conditions in the permit
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Clean Water Act § 401 Certification
EPA is requesting final Clean Water Act (CWA) 401 certification from the State of Alaska
Department of Environmental Conservation (ADEC).
Questions regarding ADEC's intent to certify the permit should be directed to:
Alaska Department of Environmental Conservation
Attn: Gene McCabe, Program Manager, Wastewater Discharge Authorization Program
P.O. Box 111800
Juneau, Alaska 99811
907-269-7580
gene.mccabe@alaska.gov
Clean Water Act § 401(A)(2) Review
Section 401(a)(2) of the CWA requires that, upon receipt of an application and state
certification pursuant to Section 401(a)(1), EPA as the permitting authority, shall notify a
neighboring State or Tribe with Treatment as a State (TAS) when EPA determines that the
discharge may affect the quality of the neighboring State/tribe's waters (33 U.S.C.
1341(a)(2)). There are no neighboring states or tribes with TAS within 300 miles of the
facility. Therefore, EPA has determined that no neighboring states or tribes with TAS will be
impacted by the discharge from this facility.
Public Comment
EPA requests that all comments on EPA's draft permit and tentative 301(h) decision or
requests for a public hearing be submitted via email to Abigail Conner
(conner.abigail@epa.gov). If you are unable to submit comments via email, please call 206-
553-6358.
Persons wishing to comment on or request a public hearing for the draft permit for this
facility may do so in writing by the expiration date of the public comment period. A request
for a public hearing must state the nature of the issues to be raised as well as the
requester's name, address, and telephone number. All comments and requests for public
hearings must be in writing and should be submitted to the EPA as described in the Public
Comments Section of the Public Notice.
After the Public Notice expires, and all comments on the draft permit and tentative 301(h)
decision have been considered, EPA Region 10 will make a final decision regarding 301(h)
eligibility and permit issuance. If no substantive comments are received, the tentative
conditions in the draft permit will become final, the tentative 301(h) decision will be
finalized, and the permit will become effective upon issuance. If substantive comments are
received, EPA will address the comments prior to taking final action on the 301(h) decision
and permit. The permit will become effective no less than 30 days after the issuance date,
unless an appeal is submitted to the Environmental Appeals Board within 30 days pursuant
to 40 CFR 124.19.
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Documents are Available for Review
The draft permit, this Fact Sheet, the 301(h) Tentative Decision Document (301(h) TD), and
the Public Notice can also be found by visiting the Region 10 website at
https://www.epa.gov/npdes-permits/about-region-10s-npdes-permit-program.
The draft Administrative Record for this action contains any documents listed in the
References section. The draft Administrative Record or documents from it are available
electronically upon request by contacting Abigail Conner.
For technical questions regarding the draft permit, this Fact Sheet, or the 301(h) TD, contact
Abigail Conner at (206) 553-6358 or conner.abigail@epa.gov. Services can be made
available to persons with disabilities by contacting Audrey Washington at (206) 553-0523.
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Table of Contents
Acronyms 7
I. Background Information 9
A. General Information 9
B. Modification of Secondary Treatment Requirements 9
C. Permit History 10
D. Tribal Consultation 10
II. Facility Information 11
A. Treatment Plant Description 11
B. Outfall Description 11
C. Effluent Characterization 11
D. Compliance History 12
III. Receiving Water 13
A. Water Quality Standards (WQS) 13
B. Receiving Water Quality 14
1. General Characteristics 15
2. Water Quality Limited Waters 15
IV. Effluent Limitations and Monitoring 16
A. Basis for Effluent Limits 22
1. Pollutants of Concern 22
2. Technology-Based Effluent Limits (TBELs) 23
3. Water Quality-Based Effluent Limits (WQBELs) 27
B. Monitoring Requirements 42
1. Effluent Monitoring 43
2. Receiving Water Monitoring 46
3. Whole Effluent Toxicity (WET) Testing Requirements 48
4. Biological Monitoring for Benthic Infauna and Sediment Analyses 49
5. Electronic Submission of Discharge Monitoring Reports 49
C. Sludge (Biosolids) Requirements 49
V. Other Permit Conditions 50
A. Toxics Control Program 50
1. Chemical Analysis and Source Identification 50
2. Industrial Pretreatment Requirements 50
3. Non-Industrial Source Control Program 50
B. Interim Beach Advisory 50
C. Compliance Schedules 51
D. Quality Assurance Plan 51
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E. Operation and Maintenance Plan 51
F. Sanitary Sewer Overflows and Proper Operation and Maintenance of the Collection
System 52
G. Environmental Justice 53
H. Pretreatment Requirements 53
I. Standard Permit Provisions 54
VI. Other Legal Requirements 54
A. Endangered Species Act 54
B. Essential Fish Habitat 55
C. CWA Section 401 Certification 55
D. Antidegradation 55
E. Permit Expiration 55
VII. References 56
Appendix A. Water Quality Data 57
Appendix A.l. Treatment Plant Effluent Data 57
Appendix A.2. Receiving Water Data 59
Appendix B. Reasonable Potential and WQBEL Formulae 62
Appendix C. Reasonable Potential and WQBEL Calculations 67
Appendix C.l. WET Reasonable Potential Analysis 68
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List of Tables
Table 1. General Facility Information 9
Table 2. Effluent Characterization 11
Table 3 Summary of Effluent Violations 13
Table 4. Receiving Water Quality Data 15
Table 5. Summary of Proposed Changes to Effluent Limits 16
Table 6. Existing 2001 Permit - Effluent Limits and Monitoring Requirements 18
Table 7. Draft Permit - Effluent Limits and Monitoring Requirements 20
Table 8. Secondary Treatment Standards 23
Table 9. Inputs for Calculation of BOD Limits 25
Table 10. Mixing Zones for Haines WWTP 29
Table 11. Applicable Water Quality Standards 30
Table 12. ADEC Proposed Final Fecal Coliform Limits 38
Table 13. Monitoring Changes in Permit 43
Table 14. Receiving Water Monitoring Requirements 47
Table 15. Receiving Water Data Collected by Permittee, 2003-2005 59
Table 16. Port of Haines Sampling Results from 2021 ARRI Report 61
Table 17. Reasonable Potential Analysis for Toxic Pollutants in the Effluent 67
Table 18. Whole Effluent Toxicity Test Results 68
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Acronyms
1Q10
1 day, 10-year low flow
7Q10
7-day, 10-year low flow
Biologically based design flow intended to ensure an excursion frequency
•J U D
of less than once every three years, for a 30-day average flow.
AML
Average Monthly Limit
ASR
Alternative State Requirement
AWL
Average Weekly Limit
BE
Biological Evaluation
BODs
Biochemical oxygen demand, five-day
BOD5u
Biochemical oxygen demand, ultimate
BMP
Best Management Practices
°C
Degrees Celsius
CBODs
Carbonaceous Biochemical Oxygen Demand
CFR
Code of Federal Regulations
CV
Coefficient of Variation
CWA
Clean Water Act
DMR
Discharge Monitoring Report
DO
Dissolved oxygen
EA
Environmental Assessment
EFH
Essential Fish Habitat
EPA
U.S. Environmental Protection Agency
ESA
Endangered Species Act
FR
Federal Register
gpd
Gallons per day
ICIS
Integrated Compliance Information System
LA
Load Allocation
Lbs/day
Pounds per day
LTA
Long Term Average
LTCP
Long Term Control Plan
mg/L
Milligrams per liter
mL
Milliliters
ML
Minimum Level
Hg/L
Micrograms per liter
mgd
Million gallons per day
MDL
Maximum Daily Limit or Method Detection Limit
MLLW
Mean Lower Low Water
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MPN Most Probable Number
N Nitrogen
NOAA National Oceanic and Atmospheric Administration
NOEC No Observable Effect Concentration
NPDES National Pollutant Discharge Elimination System
O&M Operations and maintenance
NTU Nephelometric Turbidity Unit
POTW Publicly owned treatment works
QAP Quality assurance plan
RP Reasonable Potential
RPM Reasonable Potential Multiplier
RWC Receiving Water Concentration
SS Suspended Solids
SSO Sanitary Sewer Overflow
s.u. Standard Units
TD 301(h) Technical Decision Document
TMDL Total Maximum Daily Load
TRC Total Residual Chlorine
TRE/TIE Toxicity Reduction and Identification Evaluation
Technical Support Document for Water Quality-based Toxics Control
(EPA/505/2-90-001)
TSS Total suspended solids
TUa Toxic Units, Acute
TUC Toxic Units, Chronic
USFWS U.S. Fish and Wildlife Service
USGS United States Geological Survey
UV Ultraviolet
WD Water Division
WET Whole Effluent Toxicity
WLA Wasteload allocation
WQBEL Water quality-based effluent limit
WQS Water Quality Standards
WWTP Wastewater treatment plant
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I. Background Information
A. GENERAL INFORMATION
This fact sheet provides information on the draft NPDES permit for the following
entity:
Table 1. General Facility Information
NPDES Permit#:
AK0021385
Applicant:
Haines Borough
Haines Borough Wastewater Treatment Plant
Type of Ownership
Publicly Owned Treatment Works
Physical Address:
229 W Fair Dr.
Haines, AK 99827
Mailing Address:
P.O. Box 1049
Haines, AK 99827
Facility Contact:
Dennis Durr
Water-Wastewater Department Supervisor
ddurr@haines.ak.us
907-766-6452
Facility Location:
Latitude: 59.23447°N, Longitude: -135.465215°W
Receiving Water
Portage Cove
Facility Outfall
Latitude: 59.23710°N, Longitude: -135.431138°W (midpoint of diffuser)
B. MODIFICATION OF SECONDARY TREATMENT REQUIREMENTS
Haines Borough (Haines, the applicant, or the permittee) has requested a
modification, under Section 301(h) of the CWA of the secondary treatment
requirements contained in Section 301(b)(1)(B) of the CWA to discharge wastewater
receiving less than secondary treatment from the Haines Borough Wastewater
Treatment Plant (WWTP) into Portage Cove. The effluent quality attainable by
secondary treatment is defined in the regulations at 40 CFR Part 133 in terms of
biochemical oxygen demand (BODs), total suspended solids (TSS), and pH. Haines has
requested a 301(h) modification of the secondary treatment requirements for BOD5
and TSS, but not pH.
Upon review of the application materials and available data, EPA has tentatively
determined that the Haines WWTP meets the nine statutory requirements of Section
301(h) of the CWA and the implementing regulations at 40 CFR Part 125, Subpart G,
and is proposing to reissue a 301(h)-modified NPDES permit to the facility. EPA has
prepared a tentative decision (301(h) TD) which presents the findings and conclusions
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of the Region as to whether the applicant's proposed discharge complies with the
criteria set forth in Section 301(h) of the CWA, as implemented by regulations at
40 CFR Part 125, Subpart G.
C. PERMIT HISTORY
The most recent NPDES permit for the Haines WWTP was issued on November 20,
2001, became effective on December 24, 2001, and expired on December 26, 2006
(hereafter referred to as the 2001 permit). The 2001 permit is a 301(h)-modified
NPDES permit and includes a modification of secondary treatment requirements, as
approved by EPA. A timely and complete NPDES application for permit issuance was
submitted by the permittee on July 13, 2006. Pursuant to 40 CFR 122.6, the permit has
been administratively continued and remains fully effective and enforceable.
D. TRIBAL CONSULTATION
EPA consults on a government-to-government basis with federally recognized tribal
governments when EPA actions and decisions may affect tribal interests. Meaningful
tribal consultation is an integral component of the federal government's general trust
relationship with federally recognized tribes. The federal government recognizes the
right of each tribe to self-government, with sovereign powers over their members and
their territory. Executive Order 13175 (November 2000) entitled "Consultation and
Coordination with Indian Tribal Governments" requires federal agencies to have an
accountable process to assure meaningful and timely input by tribal officials in the
development of regulatory policies on matters that have tribal implications and to
strengthen the government-to-government relationship with Indian tribes. In May
2011, EPA issued the "EPA Policy on Consultation and Coordination with Indian Tribes"
which established national guidelines and institutional controls for consultation.
The Haines WWTP is located within the traditional and historical territory of the
Chilkoot Indian Association, a federally recognized tribe. EPA notified the Chilkoot
Indian Association of its work on this draft permit in August 2020 and January 2021.
EPA also held an informational webinar for the Chilkoot Indian Association and other
tribes on April 14 and 18, 2022. EPA shared the preliminary draft permit, draft fact
sheet, and draft 301(h) TD with the Chilkoot Indian Association on February 17, 2023.
EPA will invite the Chilkoot Indian Association to participate in formal government-to-
government consultation on the draft 301(h) TD and permitting decisions during the
public notice period.
In addition, the Chilkat Indian Village, a federally recognized tribe, is located 22 miles
north of Haines. EPA notified the Chilkat Indian Village of its work on this draft permit
in April 2023. EPA shared the preliminary draft permit, draft fact sheet, and draft
301(h) TD with the Chilkat Indian Village on April 28, 2023. EPA will invite the Chilkat
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Indian Village to participate in formal government-to-government consultation on the
draft 301(h) TD and permitting decisions during the public notice period.
II. Facility Information
A. TREATMENT PLANT DESCRIPTION
Service Area
Haines Borough owns and operates the WWTP located in Haines, Alaska. The
collection system has no combined sewers. The facility serves a resident population
of approximately 1,800 people. There are two small industrial users, a distillery, and a
brewery, with a maximum combined discharge to the Haines collection system of less
than 10,000 gallons per day (gpd).
Treatment Process
The max monthly design flow of the facility is 1.9 million gallons per day (mgd). The
reported actual flows from the facility range from 0.16 mgd to 0.66 mgd (average
monthly flow). The facility provides primary treatment to all wastewater prior to
discharge. The treatment process consists of two primary screens, a grit chamber
where a polymer is added, then a clarifier. Because the design flow is greater than
1 mgd, the facility is considered a major facility. A schematic of the wastewater
treatment process and a map showing the location of the treatment facility and
discharge are included in Appendix A of the 301(h) TD.
B. OUTFALL DESCRIPTION
The facility outfall is a 16-inch pipe which extends 558 meters from shore at
approximately 24.4 meters (80 feet) below mean lower low water (MLLW). The pipe
ends in a three-port diffuser. One of the three ports on the diffuser was capped in
1986 and is no longer used. The diffuser is 9.1 m (30 feet) in length and the diameter
of each port is 7.6 cm.
C. EFFLUENT CHARACTERIZATION
To characterize the effluent, EPA evaluated discharge monitoring report (DMR) data
from 2016 through 2021 and the results of a 2006 priority pollutant scan. The effluent
quality is summarized in Table 2. Data are provided in Appendix A of this fact sheet
and Appendix C of the 301(h) TD.
Table 2. Effluent Characterization
Parameter
Minimum
Maximum
BOD (monthly avg), mg/L
7.3
245
BOD (monthly avg), lbs/day
16
345
BOD (daily max), mg/L
7.3
245
BOD (daily max), lbs/day
23
610
BOD (monthly avg % removal), %
25
93
TSS (monthly avg), mg/L
22
121
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TSS (monthly avg), lbs/day
40
180
TSS (daily max), mg/L
32
244
TSS (daily max), lbs/day
74
813
TSS (monthly avg % removal), %
31
90
Fecal coliform (monthly avg), #/100 mL
14,100
980,000
Fecal coliform (daily max), #/100 mL
10,000
1,430,000
Copper, total recoverable (monthly avg), |ag/L
0
30
Copper, total recoverable (daily max), |ag/L
0
30
Flow (max daily), mgd
0.21
1.65
Flow (monthly avg), mgd
0.16
0.66
Dissolved oxygen (daily min), mg/L
2.1
11.2
Dissolved oxygen (daily max), mg/L
2.2
16.5
pH (min), standard units
6.5
7.4
pH (max), standard units
7.0
8.0
Temperature (monthly avg), °C
5.6
15.8
Parameter
Avg Daily
Max Daily
Chloroform2, |ag/L
0.26
2
Toluene2, |ag/L
0.39
0.79
Phenol2, |ag/L
2.9
5.9
Di-n-butyl phthalate2, |ag/L
1.6
3.1
1,4-dichlorobenzene2, |ag/L
0.46
9.1
Naphthalene2, |ag/L
1.4
2.7
Bis (2-ethylhexyl phthalate)2, |ag/L
0.75
1.5
Antimony2, |ag/L
0.11
0.22
Arsenic2, |ag/L
0.27
0.545
Chromium2, |ag/L
0.36
0.711
Lead2, |ag/L
0.323
0.646
Nickel2, |ag/L
1.76
2.23
Selenium2, |ag/L
1.31
2.62
Silver2, |ag/L
0.414
0.827
Zinc2, |ag/L
27.4
28.4
Source:
1. Discharge monthly reports (DMR) from 9/30/2016 - 9/30/2021
2. Priority Pollutant Scan, 2006, 2 samples collected for each pollutant
D. COMPLIANCE HISTORY
A summary of effluent violations from 2016 to 2022 is provided in Table 3. Overall, the
facility has a good compliance record. The facility failed to meet the required
30 percent removal for BODs in May 2018, August 2019, and January 2022, the daily
maximum concentration for fecal coliform in July 2021, and the TSS daily maximum
concentration in July 2018, August 2019, and September 2019. The exceedances of
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BOD5 in May 2018 and BOD5 and TSS in August 2019 were due to sampling error after
equipment replacements. The exceedance of TSS in September 2019 was due to
operator error. In each instance, Haines corrected the problem before the next
reporting date.
Additional compliance information for this facility, including compliance with other
environmental statutes, is available on Enforcement and Compliance History Online
(ECHO). The ECHO web address for this facility is: https://echo.epa.gov/detailed-
facility-report?fid=110000761453.
Table 3 Summary of Effluent Violations
Parameter
Limit Type
Units
Number of
Instances
BODs
% Removal
%
3
TSS
Daily Maximum
mg/L
3
Fecal Coliform
Daily Maximum
#/100ml
1
Information accessed in ECHO on May 26, 2022.
EPA conducted an inspection of the facility on July 10, 2017. The inspection
encompassed the wastewater treatment process, records review, operation and
maintenance, and the collection system. The inspection noted several areas of
concern at the facility, including the locations of surface water monitoring, the
procedure for determining effluent flow, the timing of composite samples, the records
of time of day of monitoring, flows used to calculate loadings, missing Quality
Assurance Plan (QAP) requirements for copper monitoring, calibration records, and
maintenance of the effluent sampling tube.
III. Receiving Water
In drafting permit conditions, EPA must analyze the effect of the facility's discharge on the
receiving water. The details of that analysis are provided in the 301(h) TD and in the Water
Quality-Based Effluent Limits (WQBEL) section of this Fact Sheet. This section summarizes
characteristics of the receiving water that impact that analysis.
This facility discharges to Portage Cove in Haines Borough, AK. Portage Cove is located on
the western shoreline of the eastern branch of Chilkoot Inlet on the northern end of Lynn
Canal. For a detailed description of the receiving waters please refer to Section 6 of the
301(h) TD.
A. WATER QUALITY STANDARDS (WQS)
Section 301(b)(1)(C) of the CWA requires the development of limitations in permits
necessary to meet WQS. 40 CFR 122.4(d) requires that the conditions in NPDES
permits ensure compliance with the WQS of all affected States. A state's WQS are
composed of use classifications, numeric and/or narrative water quality criteria and an
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anti-degradation policy. The use classification system designates the beneficial uses
that each water body is expected to achieve, such as drinking water supply, contact
recreation, and aquatic life. The numeric and narrative water quality criteria are the
criteria deemed necessary to support the beneficial use classification of each water
body. The anti-degradation policy represents a three-tiered approach to maintain and
protect various levels of water quality and uses.
Waterbodies in Alaska are designated for all uses unless the water has been
reclassified under 18 Alaska Administrative Code (AAC) 70.230 as listed under
18 AAC 70.230(e). Some waterbodies in Alaska can also have site-specific water quality
criterion per 18 AAC 70.235, such as those listed under 18 AAC 70.236(b). The
receiving water for this discharge, Portage Cove, has not been reclassified, nor have
site-specific water quality criteria been established. Therefore, Portage Cove must be
protected for all marine use classes as per 18 AAC 70.020(a)(2) and 18 AAC 70.050.
The designated use classes for marine water include (A) water supply (aquaculture,
seafood processing, and industrial), (B) water recreation (contact and secondary),
(C) growth and propagation of fish, shellfish, other aquatic life, and wildlife, and
(D) harvesting for consumption of raw mollusks or other raw aquatic life.
B. RECEIVING WATER QUALITY
The water quality of Portage Cove is summarized in Table 4, below, and in Section 6 of
the 301(h) TD. The Haines WWTP collected water quality data in Portage Cove in
accordance with 2001 permit requirements for the following parameters:
temperature, pH, dissolved oxygen, turbidity, and salinity.
From April through August 2021, the Aquatic Restoration and Research Institute
(ARRI) conducted a survey for the Alaska Department of Environmental Conservation
(ADEC) on water quality data in the vicinity of the Haines WWTP for temperature,
salinity, pH, fecal coliform, enterococcus, ammonia, copper, nickel, and zinc. Cruise
ships were not operating in 2021. However, the 2021 values for temperature, salinity,
pH, and dissolved oxygen are similar to data collected by ARRI in 2020, when cruise
ships were actively operating in the area (ARRI, 2022). Therefore, the 2021 ARRI data
are believed to be representative of Portage Cove conditions. The water quality data
in Portage Cove from the 2021 ARRI report and the permittee are summarized below
in Table 4 and Appendix A.
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Table 4. Receiving Water Quality Data
Parameter
Units
Percentile
Value
Temperature1
°C
95th
12.5
pH1
Standard units
5th - 95th
7.5-8.5
Dissolved Oxygen1
mg/L
Minimum
5.2
Turbidity1
NTU
Average
2.9
Salinity1
ppt
5th - 95th
4.5-32
Fecal Coliform2
CFU/100 mL
Max
Geometric
Mean
8
Enterococcus2
MPN/100 mL
Maximum
96
Ammonia2
mg/L
Maximum
0.021
Copper2
Hg/L
Maximum
0.39
Nickel2
Hg/L
Maximum
0.35
Zinc2
Hg/L
Maximum
0.38
Source:
1. Data collected by permittee 2003 - 2005
2. ARRI, 2022. Water Quality Measures in Alaska's Ports and Shipping Lanes, 2021
Annual Report
1. General Characteristics
Portage Cove is located within the saline estuary of Chilkoot Inlet in southeast
Alaska. The circulation pattern within Chilkoot Inlet is characterized by a two-
layer flow system typical of estuaries or fjords. The surface layer flows seaward
and is driven by freshwater inflow, and the bottom layer moves landward. There
is a net transport of water out of the inlet due to freshwater runoff.
2. Water Quality Limited Waters
There are no water quality impairments identified in Portage Cove on the State of
Alaska's 2022 Integrated Report (ADEC, 2022).
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IV. Effluent Limitations and Monitoring
The draft permit includes several changes to the effluent limitations. The changes are
summarized in Table 5 below:
Table 5. Summary of Proposed Changes to Effluent Limits
Parameter
Effluent Limit Change
Basis
BODs
Less stringent limits
EPA is proposing less stringent effluent limits that
reflect facility performance. The less stringent
limits meet an exception to the prohibition on
backsliding as described in Section IV.A.2.b.
TSS
More stringent limits
EPA is proposing more stringent effluent limits that
reflect facility performance. The proposed limits
are at the level of performance which the facility
can consistently achieve.
BODs1
Removing maximum
daily limit/including
average weekly limit
The regulations at 40 CFR 122.45(d)(2) require
effluent limitations for continuous discharges from
POTWs be expressed as average weekly and
average monthly discharge limitations, unless
impracticable. The 2001 permit contained average
monthly and maximum daily effluent limits for
BODs. The draft permit proposes to remove the
maximum daily effluent limit and implement an
average weekly limit. The inclusion of a maximum
daily limit instead of an average weekly limit meets
an exception to the prohibition on backsliding as
described in Section IV.A.2.b.
TSS1
Removing maximum
daily limit/including
average weekly limit
The regulations at 40 CFR 122.45(d)(2) require
effluent limitations for continuous discharges from
POTWs be expressed as average weekly and
average monthly discharge limitations, unless
impracticable. The 2001 permit contained average
monthly and maximum daily effluent limits for TSS.
The draft permit proposes to remove the
maximum daily effluent limit and implement an
average weekly limit. The change in limits meets
an exception to prohibition on backsliding as
described in Section IV.A.2.b.
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Fecal
Coliform
More stringent
maximum daily and
average monthly limits
Section 301(b)(1)(C) of the CWA requires the
development of limitations in permits necessary to
meet WQS. Section 301(h)(9) of the CWA and
40 CFR 125.62 require 301(h) discharges to meet
state WQS and federal CWA 304(a) criteria at the
boundary of the zone of initial dilution (ZID). The
draft permit contains fecal coliform limits that EPA
anticipates the state of Alaska will include as a
condition of the 401 certification. These limits will
ensure Alaska's most protective WQS are met at
the boundary of the chronic mixing zone.
Enterococcus
New effluent limits
Section 301(b)(1)(C) of the CWA requires the
development of limitations in permits necessary to
meet WQS. Section 301(h)(9) and 40 CFR 125.62
require 301(h)-modified discharges to meet all
applicable state water quality standards and
federal CWA Section 304(a) criteria at the
boundary of the ZID. When the 2001 permit was
issued, no WQS was in effect for enterococcus. In
2017, EPA approved Alaska's WQS for
enterococcus. EPA has determined the modified
discharge has reasonable potential to cause or
contribute to a violation of the WQS for
enterococcus and the draft permit contains a
WQBELs for enterococcus developed using the
dilution achieved at the boundary of the chronic
mixing zone.
Copper
More stringent effluent
limits
Section 301(b)(1)(C) of the CWA requires the
development of limitations in permits necessary to
meet WQS. Section 301(h)(9) and 40 CFR 125.62
require 301(h)-modified discharges to meet all
applicable state water quality standards and
federal CWA Section 304(a) criteria at the
boundary of the ZID and at the boundary of the
acute and chronic mixing zones. EPA has
determined the discharge has reasonable potential
to cause or contribute to an exceedance of the
WQS for copper and is including the calculated
limits so the facility meets WQS.
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Chlorine
Removal of effluent
limits
Section 301(b)(1)(C) of the CWA requires the
development of limitations in permits necessary to
meet WQS. Section 301(h)(9) and 40 CFR 125.62
require 301(h)-modified discharges to meet all
applicable state water quality standards and
federal CWA Section 304(a) criteria at the
boundary of the ZID. EPA has determined the
discharge does not have reasonable potential to
cause or contribute to an exceedance of the WQS
for chlorine and removal of the limit is allowed
under the antibacksliding policy as described in
Section IV.A.3.d.
1. Concentration/mass-loading limits only; compliance with 30% removal is still
determined on monthly averaging basis.
Table 6 below presents the existing effluent limits and monitoring requirements in the
2001 Permit. Table 7 below presents the effluent limits and monitoring requirements
proposed in the draft permit.
Table 6. Existing 2001 Permit - Effluent Limits and Monitoring Requirements
Parameter
Units
Effluent Limitations
Monitoring Requirements
Average
Monthly
Limit
Average
Weekly
Limit
Max
Daily
Limit
Sample
Location
Sample
Frequency
Sample
Type
Total Flow
MGD
1.9
-
2.9
Influent
or
Effluent
Continuous
Recorded
BOD5, May 1 -
Sept. 30
mg/L
260
-
300
Influent
and
Effluent
1/month
24-hour
composite
lbs/day
4100
-
4800
BODs, Oct. 1 -
April 30
mg/L
140
-
200
Influent
and
Effluent
1/month
24-hour
composite
lbs/day
2200
-
3200
BODs,%
removal
%
Minimum 30% removal
Influent
and
Effluent
-
Calculation
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Parameter
Units
Effluent Limitations
Monitoring Requirements
Average
Monthly
Limit
Average
Weekly
Limit
Max
Daily
Limit
Sample
Location
Sample
Frequency
Sample
Type
Total
Suspended
Solids (TSS)
mg/L
140
-
200
Influent
and
Effluent
1/week
24-hour
composite
Ibs/day
2200
-
3200
TSS, % removal
%
Minimum 30% removal
Influent
and
Effluent
-
Calculation
Total Residual
Chlorine5
Hg/L
-
-
110
Effluent
1/week
Grab
Fecal Coliform
#
FC/100
mL
1.0 x10s
-
1.5 x 10s
Effluent
1/month
Grab
Copper, Total
Recoverable
Hg/L
78
-
156
Effluent
1/quarter
24-hour
composite
PH
s.u.
Between 6.5 s.u.- 8.5 s.u.
Effluent
1/week
Grab
Dissolved
Oxygen
mg/L
Between 2.0 mg/L- 17 mg/L
Effluent
1/week
Grab
Temperature
°C
-
Effluent
1/week
Grab
Toxic
Pollutants and
Pesticides1
-
-
Effluent
2/permit
term2
24-hour
composite
Whole Effluent
Toxicity
(WET)3, TUC
TUC
-
Effluent
1/permit
term4
24-hour
composite
1. "Toxic Pollutants" are defined as the 126 priority pollutants in 40 CFR 401.15. "Pesticides" are defined at
40 CFR 125.58(p).
2. The permittee shall conduct analyses of the effluent for toxic pollutants and pesticides during the first and
fourth year of the permit term. Monitoring during the first year shall be conducted during the dry season in
the month of July. Monitoring during the fourth year shall be conducted during the wet season in the month
of January. Samples shall be 24-hour composite samples. Sampling and analysis shall be conducted according
to methods approved in 40 CFR Part 136.
3. See Part l.C. of 2001 Permit.
4. Whole Effluent Toxicity monitoring shall be conducted in the first year of the permit term.
5. Chlorine monitoring and the effluent limits are only effective if the facility adds a chlorination process to
the facility as a method of disinfection.
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Table 7. Draft Permit - Effluent Limits and Monitoring Requirements
Parameter
Units
Effluent Limitations
Monitoring Requirements
Average
Monthly
Limit
Average
Weekly
Limit
Max Daily
Limit
Sample
Location
Sample
Frequency
Sample
Type
Total Flow
MGD
1.9
-
2.9
Influent
and
Effluent
Continuous
Recorded
BOD5, May 1
- September
30
mg/L
278
417
-
Influent
and
Effluent
1/month
24-hour
composite
lbs/day
4401
6602
-
Calculation1
BODs, Oct 1 -
April 30
mg/L
164
266
-
Influent
and
Effluent
1/month
24-hour
composite
lbs/day
2596
4210
-
Calculation1
BOD5j %
removal
%
Minimum 30% removal
Influent
and
Effluent
1/month
Calculation2
Total
Suspended
Solids (TSS)
mg/L
90
190
-
Influent
and
Effluent
1/week
24-hour
composite
lbs/day
1426
3010
-
Calculation1
TSS, %
removal
%
Minimum 30% removal
Influent
and
Effluent
1/month
Calculation2
Fecal
Coliform3
(Interim
Limit)
# FC/100
mL
977,OOO4-5
(geomean)
-
1,141,000s-7
(instant,
max)
Effluent
2/month8
Grab
Fecal
Coliform3
(Final Limit)
# FC/100
mL
2005,9
400
8007,9
Effluent
2/month8
Grab
Enterero-
coccus3
Final Limit
#/100 mL
6655,9,10
(geomean)
-
24707,9,11
(instant,
max)
Effluent
2/month8
Grab
PH
s.u.
Between 6.5 - 8.5
Effluent
1/week
Grab
Dissolved
Oxygen
mg/L
Between 2.0 -17.0
Effluent
1/week
Grab
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Copper
M-g/L
21
64
Effluent
1/month
Grab
lbs/day
0.33
1.01
Calculation1
Temperature
°C
-
Report
Report
Effluent
Continuous
Meter
Ammonia
Hg/L
-
Effluent
1/quarter
Grab
Per-and
Polyfluoroalk
yl Substances
(PFAS)
ng/L
Report
-
Report
Influent
and
effluent
2/year10
24-hour
composite
mg/kg
dry
weight
-
-
Report
Sludge
2/year10
Grab
Whole
Effluent
Toxicity
(WET)11, TUC
See Permit Part I.C.
Effluent
2/year12
24-hour
composite
Toxic
Pollutant
Scan13
-
Effluent
Twice every
5 years14
24-hour
composite
loading (in lbs/day) is calculated by multiplying the concentration (in mg/L) by the corresponding flow (in mgd) for the day
of sampling and a conversion factor of 8.34. For more information on calculating, averaging, and reporting loads and
concentrations see the NPDES Self-Monitoring System User Guide (EPA 833-B-85-100, March 1985).
2 Percent Removal. The monthly average percent removal must be calculated from the arithmetic mean of the influent
values and the arithmetic mean of the effluent values for that month using the following equation:
(average monthly influent concentration - average monthly effluent concentration) -f average monthly influent
concentration x 100. Influent and effluent samples must be taken over approximately the same time period.
Reporting is required within 24 hours of a maximum daily limit or instantaneous maximum limit violation. See Paragraph
I.B.O and Part III.G of this permit.
4 Interim average monthly limit is based on the 95th percentile of fecal coliform data between 2016-2021. See Section II.C of
the permit for compliance schedule information.
5 If more than one bacteria sample {FC, Enterococci} is collected within the reporting period, the average result must be
reported as the geometric mean. When calculating the geometric mean, replace all results of zero, 0, with a one, 1. The
geometric mean of "n" quantities is the "nth" root of the product of the quantities. For example, the geometric mean of
100, 200, and 300 is (100 X 200 X 300)1/3 = 181.7.
6 Interim maximum daily limit is based on the 99th percentile of fecal coliform data between 2016-2021. See Section II.C of
the permit for compliance schedule information.
8 Fecal coliform and enterococcus sampling shall coincide with receiving water sampling in Part I.C.
9 Final fecal coliform and enterococcus limits. See Section II.C of the permit for compliance schedule information.
10Monitoring for PFAS chemicals is required for 2 years (8 quarters), beginning at the start of the first complete quarter in
the third year of the permit term.
"Chronic WET testing - See Permit Part I.C
12See monitoring described in Permit Parts I.C.
13Toxic Pollutant Scan- See NPDES Permit Application Form 2A, Table B, Table C, and Permit Part II.D.l. for the list of
pollutants to be included in this testing. The Permittee must use sufficiently sensitive analytical methods in accordance
with Permit Part I.B.7.
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"Testing must occur twice every five years, once during the wet weather season and once during the dry weather season.
See Permit Part II.D.
A. BASIS FOR EFFLUENT LIMITS
In general, the CWA requires that the effluent limits for a particular pollutant be the
more stringent of either TBELs or WQBELs. TBELs are set according to the level of
treatment that is achievable using available technology. A WQBEL is designed to
ensure that the WQS applicable to a waterbody are being met and may be more
stringent than TBELs.
1. Pollutants of Concern
Pollutants of concern are those that either have TBELs or may need WQBELs. EPA
identifies pollutants of concern for the discharge based on those which:
• Have a TBEL
• Have an assigned wasteload allocation (WLA) from a TMDL
• Had an effluent limit in the previous permit
• Are present in the effluent monitoring. Monitoring data are reported in the
application and DMR and any special studies
• Are expected to be in the discharge based on the nature of the discharge
The wastewater treatment process for this facility includes primary treatment.
Pollutants expected in the discharge from a facility with this type of treatment,
include but are not limited to: BOD5, TSS, fecal coliform and enterococcus
bacteria, pH, temperature, and dissolved oxygen (DO).
Based on this analysis, pollutants of concern are as follows:
• BODs
• DO
• TSS
• pH
• Temperature
• Chlorine
• Bacteria (fecal coliform, enterococcus)
• Copper
• Ammonia
• Other Toxics (antimony, arsenic, benzidine, bis (2-ethylhexyl) phthalate,
chloroform, chromium, di-n-butyl phthalate, 1,4 dichloro benzene, lead,
naphthalene, nickel, phenol, selenium, silver, toluene, zinc)
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2. Technology-Based Effluent Limits (TBELs)
a. Federal Primary Treatment Effluent Limits
The CWA requires POTWs to meet performance-based requirements based
on available wastewater treatment technology. Section 301 of the CWA
established a required performance level, referred to as "secondary
treatment," which POTWs were required to meet by July 1, 1977. EPA has
developed and promulgated "secondary treatment" effluent limitations,
which are found in 40 CFR 133.102. These TBELs identify the minimum level
of effluent quality attainable by application of secondary treatment in terms
of BODs, TSS, and pH.
Table 8. Secondary Treatment Standards
1 Parameter
30-day average
7-day average
| BODs
30 mg/L
45 mg/L
(or 40 mg/LCBODs)
l
1 TSS
30 mg/L
45 mg/L
I BOD5and
| TSS removal
not less than 85%
-
PH
within the limits of 6.0-9.0
Section 301(h) of the CWA provides for a waiver from secondary treatment if
the permittee meets several specific criteria, including a requirement to
achieve primary treatment. Primary treatment is defined in Section 301(h) of
the CWA as 30 percent removal of BOD5 and TSS from the influent. The
current permit requires 30 percent removal of BOD5 and TSS on a monthly
basis and the applicant has requested to maintain these limits.
Unlike secondary treatment standards, which require POTWs to meet
monthly average and weekly average concentration limits for BOD5 and TSS,
the primary treatment standards do not include concentration-based TBELs
for BOD5 and TSS. Instead, concentration-based limitations, and by extension
mass-based limits, are established on a case-by-case basis using state WQS
and the level of treatment performance the facility is consistently able to
achieve. See Section IV.A.2.a for more information on concentration and
mass limits.
EPA has tentatively determined that the Haines WWTP qualifies for a
continuation of their waiver from secondary treatment under Section 301(h)
of the CWA. Therefore, the draft permit maintains the 30 percent minimum
removal limits for TSS and BOD5 on a monthly basis. Haines did not request a
301(h)-modification for pH.
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b. Concentration and Mass Based Limits
40 CFR 122.45(f) requires that effluent limits be expressed in terms of mass,
except under certain conditions. 40 CFR 122.45(b) requires that effluent
limitations for POTWs be calculated based on the design flow of the facility.
The mass-based limits are expressed in pounds per day and are calculated as
follows:
Mass-based limit (lbs/day) = concentration limit (mg/L) x design flow (mgd) x
8.34.1
In the 2001 permit, monthly average and maximum daily concentration-
based limits for TSS and BODs were specified by ADEC in their June 21, 2001
final Certificate of Reasonable Assurance issued pursuant to Section 401 of
the CWA.
For this draft permit, EPA assessed influent and effluent data (2016-2021) for
BOD5 and TSS to establish concentration-based limits reflective of facility
performance.
Instead of including maximum daily limits for BOD5 and TSS, the draft permit
imposes average weekly limits. This is consistent with 40 CFR 122.45(d)(2)
which requires average weekly and average monthly discharge limitations for
POTWs.
BODs
DMR data indicates the discharge is consistently achieving greater BOD5
removal than the federal primary treatment standard of 30%. Average
percent removal between 2016 and 2021 was 49%. The 2001 permit includes
seasonal limits for BOD5, based on the requirements in ADEC's 401
certification of the 2001 permit which cited greater loading during the
summer months. The draft permit continues to have seasonal limits. Influent
BOD concentrations are higher during the summer months as shown in the
facility DMR data between 2016-2021.
Average Monthly Limit (AML): EPA used the 95th percentile of influent data
from 2016 to 2021 and an assumed 30% removal to calculate an AML of 278
mg/L (May 1 - Sept 30) and 164 mg/L (Oct 1 - April 30). This is less stringent
than the current AMLs in the 2001 permit. EPA is proposing to include the
calculated limits in the draft permit.
1 8.34 is a conversion factor with units (lb x L)(mg x gallon x 106). See Exhibit 5-7 in the
NPDES Permit Writer's Manual.
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Average Weekly Limit (AWL): EPA used the multiplier from Table 5-3 of the
Amended Technical Support Document for Water Quality-Based Toxics
Control and the calculated AMLs to calculate AWLs of 417 mg/L
(May 1 - Sept 30) and 266 mg/L (Oct 1 - Apr 30). EPA is proposing to include
the calculated limits in the draft permit. EPA is removing the maximum daily
limits that were in the 2001 permit. See Antibacksliding discussion, below.
Using these concentrations in the equation above, the mass-based limits for
BODs are as follows:
BOD5 (May - September)
Average Monthly Limit = 277.76 mg/L x 1.9 mgd x 8.34 = 4,401 lbs/day
Average Weekly Limit = 416.64 mg/L x 1.9 mgd x 8.34 = 6,602 lbs/day
BOD5 (October - April)
Average Monthly Limit = 163.8 mg/L x 1.9 mgd x 8.34 = 2,596 lbs/day
Average Weekly Limit = 265.68 mg/L x 1.9 mgd x 8.34 = 4,210 lbs/day
Table 9. Inputs for Calculation of BOD Limits
Parameter
May 1 -
Sept 30
Oct 1-
April 30
95th Percentile of Influent
Data (mg/L)
397
233
Final Effluent After 30%
Removal (mg/L)
277.76
163.8
CV of Effluent Data
0.4
0.5
Samples per month
2
2
TSD Multiplier (99th/95th)
1.50
1.622
TSS
DMR data indicates the discharge is consistently achieving greater TSS
removal than the federal primary treatment standard of 30%. Average
percent removal between 2016 and 2021 was 65%. As discussed below, EPA
proposes to establish TSS concentration limits that reflect facility
performance.
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Average Monthly Limit (AML): Using effluent data from 2016 to 2021, EPA
conducted a statistical analysis to calculate an average monthly TSS
limitation based on facility performance. The performance-based AML was
90 mg/L. This is more stringent than the current AML of 140 mg/L and
reflects facility performance for TSS. The draft permit contains an AML of 90
mg/L which is the level of performance that the facility can consistently
achieve.
Average Weekly Limit (AWL): Using effluent data from 2016 to 2021, EPA
conducted a statistical analysis to calculate an AWL for TSS based on facility
performance. The performance-based AWL was 190 mg/L, which reflects
facility performance for TSS. The 2001 permit included maximum daily limit
(MDL) of 200 mg/L. The draft permit contains an AWL of 190 mg/L which is
the level of performance that the facility can consistently achieve.
Using these concentration limits in the equation above, the mass-based
limits for TSS are as follows:
Average Monthly Limit = 90 mg/L x 1.9 mgd x 8.34 = 1,426 lbs/day
Average Weekly Limit = 190 mg/L x 1.9 mgd x 8.34 = 3,010 lbs/day
Antibacksliding: TBELs
CWA section 402(o) and 40 CFR 122.44 (I) generally prohibit the renewal,
reissuance, or modification of an existing NPDES permit that contains
effluent limits, permit conditions or standards that are less stringent than
those established in the previous permit (i.e., anti-backsliding) but also
provides limited exceptions to antibacksliding. For explanation of the
antibacksliding exceptions refer to Chapter 7 of the Permit Writers Manual
Final Effluent Limitations and Anti-backsliding.
EPA is proposing to remove the maximum daily BOD5 and TSS limits and
establish average monthly and average weekly limits pursuant to 40 CFR
122.45(d)(2). 40 CFR 122.45(d)(2) requires that effluent limitations for
continuous discharges from POTWs be expressed as average weekly and
average monthly discharge limitations, unless impracticable.
40 CFR 122.44(l)(l) states that a permit can be made less stringent if "the
circumstances on which the previous permit was based have materially and
substantially changed since the time the permit was issued and would
constitute cause for permit modification...under §122.62." Here, EPA is
removing the maximum daily limits for BOD5 and TSS. Since EPA is including
both average monthly and average weekly limits, maximum daily limits are
no longer necessary, and the permit is as stringent as it was previously.
However, even assuming that removal of the maximum daily limits results in
less stringent effluent limits, EPA can remove the limits. One of the causes
for modification is to allow for the correction of technical mistakes.
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40 CFR 122.62(a)(15). The 2001 BOD5 average weekly and maximum daily
effluent limits were specified in ADEC's 401 certification; it is unknown what
assumptions these limits were based on, and EPA is unable to determine how
these limits were calculated. During preliminary discussions, ADEC has
indicated they will not include maximum daily limits in their 401 certification.
If this changes upon receipt of theirfinal certification, EPA will include the
effluent limits in the final permit. Therefore, EPA is correcting this technical
mistake and an exception to antibacksliding applies.
3. Water Quality-Based Effluent Limits (WQBELs)
a. Statutory and Regulatory Basis
Section 301(b)(1)(C) of the CWA requires the development of limits in
permits necessary to meet all applicable WQS. Discharges to state or tribal
waters must also comply with conditions imposed by the state or tribe as
part of the CWA 401 certification of the permit. See 33 U.S.C. 1341.
40 CFR 122.44(d)(1), which implements Section 301(b)(1)(C) of the CWA,
requires that permits include limits for all pollutants or parameters that are
or may be discharged at a level which will cause, have the reasonable
potential to cause, or contribute to an excursion above any state or tribal
WQS, including narrative criteria for water quality. Effluent limits must also
meet the applicable water quality requirements of affected States other than
the State in which the discharge originates, which may include downstream
States. 40 CFR 122.4(d) and 122.44(d)(4), see also 33 U.S.C. 1341(a)(2). These
requirements are applicable to all NPDES permits.
For 301(h)-modified dischargers, water quality-based effluent limits must
consider the following separate regulatory provisions which overlap to some
extent with the provisions discussed above.
Section 301(h)(9) of the CWA, and its implementing regulations at 40 CFR
125.62(a), require 301(h)-modified discharges to meet all applicable state
WQS as well as water quality criteria established under Section 304(a)(1) of
the CWA after initial mixing in the waters surrounding or adjacent to the
discharge point. See 33 U.S.C. 1311(h)(9).
Section 301(h)(1) of the CWA, and its implementing regulations at 40 CFR
125.61, require that there must be a water quality standard applicable to
each pollutant for which the 301(h) modification is requested (i.e., BOD5 and
TSS, or surrogates) and the applicant must demonstrate the proposed
modified discharge will comply with these standards after initial mixing. 33
U.S.C. 1311(h)(1).
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In addition, effluent limits must be stringent enough to ensure that WQS are
met and must be consistent with any available wasteload allocation (WLA)
for the discharge in an approved total maximum daily load (TMDL). 40 CFR
122.44. There are no approved TMDLs that specify WLAs for this discharge;
therefore, all of the WQBELs are calculated directly from the applicable WQS.
Alaska's WQS can be found at 18 AAC 70 (ADEC 2020) and the Alaska Water
Quality Criteria Manual for Toxic and Other Deleterious Organic and
Inorganic Substances (ADEC 2008). As discussed in Section III.A of this Fact
Sheet, Alaska's WQS are composed of use classifications, numeric and/or
narrative water quality criteria, and an antidegradation policy. The use
classification system identifies the designated uses that each waterbody is
expected to achieve. The numeric and/or narrative water quality criteria are
the criteria deemed necessary by the state to support the designated use
classification of each waterbody and are the values used in EPA's reasonable
potential analysis.
b. Reasonable Potential Analysis and Need for WQBELs
EPA used Alaska WQS and the processes described in the Amended Section
301(h) Technical Support Document (301(h) TSD) and the 1991 Technical
Support Document for Water Quality-based Toxics Control to determine
reasonable potential. To determine if there is reasonable potential for the
discharge to cause or contribute to an excursion above any state WQS for a
given pollutant, EPA compares the maximum projected receiving water
concentration to the water quality criteria for that pollutant. If the projected
receiving water concentration exceeds the WQS, there is reasonable
potential, and a WQBEL must be included in the permit. 40 CFR
125.62(a)(l)(iv) requires this evaluation be based upon conditions reflecting
periods of maximum stratification and during other periods when discharge
characteristics, water quality, biological seasons, or oceanographic
conditions indicate more critical situations may exist. Such periods are
commonly referred to as critical conditions.
In some cases, a dilution allowance or mixing zone is permitted within a
receiving water. A mixing zone is a limited area or volume of water where
initial dilution of a discharge takes place and within which certain WQS may
be exceeded (EPA 2014). Under the 301(h) program, this mixing area is
referred to as the zone of initial dilution, or ZID, and is defined at 40 CFR
125.58(dd) as, "the region of initial mixing surrounding or adjacent to the end
of the outfall pipe or diffuser ports, provided that the ZID may not be larger
than allowed by mixing zone restrictions in applicable water quality
standardsWhile the acute and chronic criteria may be exceeded within the
ZID, the use and size of the ZID must be limited such that the waterbody as a
whole will not be impaired, all designated uses are maintained, and acutely
toxic conditions are prevented.
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As discussed above, Section 301(h)(9) of the CWA and 40 CFR 125.62(a)
require 301(h)-modified discharges to meet the water quality criteria
established under Section 304(a)(1) of the CWA after initial mixing at the
edge of the ZID, unless states have adopted more stringent criterion, in
which case those must be met. Consistent with the recommendations in the
301(h) TSD for setting spatial boundaries for the ZID, EPA has established the
spatial dimensions of the ZID to include the entire water column within a
rectangle 209 feet (63.7m) long (perpendicular to shore) and 180 feet
(54.9m) wide, centered on the 30-foot diffuser. This is the same ZID spatial
boundary as the 2001 permit.
The ZID for the applicant's outfall was calculated using a discharge depth of
80 ft (24.4m) below MLLW, a mean tide level of 8.7 ft (2.65 m), and a port
height above sea bottom of 0.7 ft (0.2m). Using the diffuser length of 30 ft
(9.1m), and a diameter of 16 in (1.33 ft; 0.41m), the ZID was calculated to be
a rectangle of 209 ft (63.7m) long (perpendicular to shore) and 180 ft (54.9m)
wide, centered on the diffuser and perpendicular to the shoreline.
The ZID dimension calculations are as follows:
Width (units in feet) = 1.33 + 2 x (80 + 8.7 + 0.7) = 180 ft
Length (units in feet) = 30 + 2 x (80 + 8.7 + 0.7) = 209 ft
18 AAC 70.240 provides Alaska's mixing zone policy for point source
discharges. In preliminary discussions with EPA, ADEC proposes to authorize
mixing zones within the spatial boundaries of the ZID. The mixing zones and
their associated dilution factors that EPA has used in the draft permit are
summarized below. All dilution factors are calculated with the effluent flow
rate set equal to the design flow of 1.9 mgd.
Table 10. Mixing Zones for Haines WWTP
Criteria Type
Dilution Factor
Acute Aquatic Life
11*
Chronic Aquatic Life
19*
*EPA anticipates that the condition will be
contained in ADEC's CWA Section 401 Certification.
The reasonable potential analysis and WQBEL calculations were based on the
dilution factors shown in Table 10 above. If ADEC revises the allowable
mixing zone in its 401 certification of this permit, the reasonable potential
analysis and WQBEL calculations will be revised accordingly.
As discussed in Part I.A.I. Pollutants of Concern, the pollutants of concern in
the discharge are BODs, DO, TSS, pH, temperature, fecal coliform,
enterococci bacteria, chlorine, copper, and other toxics and metals as listed
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above. Each parameter is summarized in Part IV.A. Basis for Effluent Limits,
and the equations used to conduct the reasonable potential analysis and
calculate the WQBELs are provided in Appendix B: Reasonable Potential and
WQBEL Formulae and Section 8.C of the 301(h) TD. The relevant WQS are
shown below. Since Portage Cove is designated for all uses, the listed use is
the one with the most protective criteria.
Table 11. Applicable Water Quality Standards
Pollutant
Designated Use
Marine Criteria
Basis
Antimony
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
4300 ng/L (human
health; organisms only)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Arsenic, dissolved
Aquatic life
69 ng/L(acute)
36 ng/L (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Benzidine
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
0.0054 ng/L (human
health, organisms only)
National Toxics Rule, 40 CFR
131.36
Bis (2-ethylhexyl)
phthalate
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
59 ng/L (human;
organisms only)
National Toxics Rule, 40 CFR
131.36
Chloroform
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
4700 ng/L (human
health; organisms only)
National Toxics Rule, 40 CFR
131.36
Chromium VI,
Dissolved
Aquatic life
1,100 ng/L (acute)
50 ng/L (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Copper, Dissolved
Aquatic life
4.8 ng/L (acute)
3.1 ng/L (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
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Deleterious Organic and Inorganic
Substances (ADEC 2008)
Deleterious organic
and inorganic
substances
Growth and
Propagation of
Fish, Shellfish,
Other Aquatic
Life, and Wildlife
Narrative Criteria
18 AAC 70.020(b)(23)(C)
Di-n-butyl
phthalate
Aquatic life
12,000 ng/L (human
health; organisms only)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
1,4
dichlorobenzene
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
2,600 ng/L (human
health; organisms only)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
DO
Aquaculture
>5 mg/L, <17 mg/L
18 AAC 70.020(b)(15)(A)(i)
Enterococcus
Primary contact
recreation
35 CFU/lOOmL (acute)
130 CFU/lOOmL
(chronic)
18 AAC 70.020(b)(14)(b)(i)
Fecal coliform
Harvesting for
consumption of
raw mollusks or
other raw aquatic
life
14 CFU/lOOmL (acute)
43 CRU/lOOmL (chronic)
18 AAC 70.020(b)(14)(D)
Lead, Dissolved
Aquatic life
210 ng/L(acute)
8.1 ng/L (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Nickel, Dissolved
Aquatic life
74 ng/L(acute)
8.2 ng/L (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
4,600 ng/L (human
health; organisms only)
PH
Aquaculture
6.5—8.5 s.u.
18 AAC 70.020(b)(18)(A)(i)
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Phenol
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
4,600,000 (human
health; organisms only)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Residues
Growth and
Propagation of
Fish, Shellfish,
Other Aquatic
Life, and Wildlife
Narrative Criteria
18 AAC 70.020
Sediment
Contact recreation
No measurable increase
in concentration of
settleable solids above
natural conditions, as
measured by the
volumetric Imhoff cone
method.
18 AAC 70.020(21)(B)(i)
Selenium,
Dissolved
Aquatic life
290 (acute)
71 (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Growth and
Propagation of
Fish, Shellfish,
Other Aquatic
Life, and Wildlife
11,000 ng/L (human
health; organisms only)
Silver, Dissolved
Aquatic life
1.9 ng/L (acute)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Temperature
Seafood
Processing,
Aquaculture
May not exceed 15°C
and may not cause the
weekly average
temperature to increase
more than 1°C. The
maximum rate of change
may not exceed 0.5°C
per hour. Normal daily
temperature cycles may
not be altered in
amplitude or frequency.
18 AAC 70.020(22)(A)(i))
Toluene
Growth and
Propagation of
Fish, Shellfish,
200,000 (human health;
organisms only)
Alaska Water Quality Criteria
Manual for Toxic and Other
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other Aquatic Life
and Wildlife
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Total residual
chlorine
Aquatic life
13 ng/L (acute)
7.5 ng/L (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Turbidity
Aquaculture
Aquatic life
25 NTU (aquaculture)
May not reduce the
depth of the
compensation point for
photosynthetic activity
by more than 10%. May
not reduce the
maximum secchi disk
depth by more than
10%. (aquatic life)
18 AAC 70.020(b)(24)(A)(i)
18 AAC 70.020(b)(24)(C)
Whole Effluent
Toxicity
Growth and
Propagation of
Fish, Shellfish,
Other Aquatic
Life, and Wildlife
1.0 TUC
18 AAC 70.030
Zinc, Dissolved
Aquatic life
90 ng/L(acute)
81 ng/L (chronic)
Alaska Water Quality Criteria
Manual for Toxic and Other
Deleterious Organic and Inorganic
Substances (ADEC 2008)
Growth and
Propagation of
Fish, Shellfish,
other Aquatic Life
and Wildlife
69,000 ng/L (human
health; organisms only)
c. Reasonable Potential and WQBELs
The reasonable potential and WQBELs for specific parameters are
summarized below. The calculations are provided in Appendix C.
fiH
The Alaska WQS for the protection of aquatic life require that ambient pH
may not be less than 6.5 or greater than 8.5 standard units (s.u.) and may not
vary more than 0.2 s.u. outside of the naturally occuring range. Mixing zones
are generally not granted for pH, therefore the most stringent water quality
criterion must be met before the effluent is discharged to the receiving
water.
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Effluent pH data were compared to the water quality criteria. Between 2016-
2021, effluent pH ranged from 6.5 to 8.0 s.u. The applicant has not requested
a CWA Section 301(h) modification for pH. The draft permit retains the
current pH limits of 6.5 to 8.5 s.u.
Dissolved Oxygen (DO) and BODs
Natural decomposition of organic material in wastewater effluent impacts
DO in the receiving water at distances far outside of the regulated mixing
zone. The BOD5 of an effluent sample indicates the amount of biodegradable
material in the wastewater and estimates the magnitude of oxygen
consumption the wastewater will generate in the receiving water.
Alaska does not have WQS for BOD and instead uses DO. The standard
applicable to marine waters provides that for estuarine water the
concentration of DO shall not be less than 5.0 mg/L except where natural
conditions cause this value to be depressed, and in no case can DO exceed
17.0 mg/L.
The reasonable potential to cause or contribute to violations of the DO
criteria of 5.0 mg/L at the edge of the ZID can be evaluated using equation
B-5 in the 301(h) TSD, which calculates the DO depletion caused by the BOD5
of the effluent. These equations were used to calculate the DO concentration
at the completion of initial dilution and at the edge of the chronic mixing
zone, using worst-case effluent and receiving water conditions as required by
40 CFR 125.62(a)(l)(iv) and the 301(h) TSD. This process was repeated for
bottom, mid, and surface depths based on receiving water data. To assess
the potential for far field impacts to DO, the final BOD5 concentration after
initial mixing was determined using the simplified procedures described in
Appendix B of the 301(h) TSD.
The analysis indicates the effluent BOD5 will result in a DO depletion of 1.2%
at the completion of initial mixing and DO depletion of 7.0% at the edge of
the chronic mixing zone, with a final BOD5 concentration of 4.38 mg/L after
initial mixing. At the edge of the chronic mixing zone, the effluent BOD5 will
result in a DO depletion of 7.0%, with a BOD5 concentration of 23 mg/L at the
edge of the chronic mixing zone These results indicate that both near field
and far field DO impacts meet Alaska WQS. For a complete analysis of DO
please refer to Appendix E of the 301(h) TD.
Based on the above analyses and that presented in the 301(h) TD, the
discharge will not contribute to a violation of AK WQS for DO. The permit
retains the DO limits from the 2001 permit to ensure the facility continues to
meet Alaska WQS.
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Total Suspended Solids and Turbidity
Alaska does not have WQS for TSS but uses turbidity as a surrogate. Alaska
WQS applicable to the estuarine waters of Portage Cove provide that
turbidity shall not exceed 25 nephelometric turbidity units (NTU) and shall
not reduce the depth of the compensation point for photosynthetic activity
by more than 10%. In addition, the turbidity shall not reduce the maximum
Secchi disc depth by more than 10%. The permittee collected ambient
receiving water data for turbidity and Secchi data at the outfall and reference
sites between 2016 and 2021. The data are presented in Part 8.B of the
301(h) TD.
NTU Monitoring Data
The applicant collected ambient NTU data within the receiving water in
August 2003, February 2004, and September 2005. The turbidity results from
2003-2005 indicate that turbidity is generally higher at the surface and that
Portage Cove has elevated levels of sediment in the summer months due to
freshwater and sediment inputs from nearby rivers. None of the NTU
measurements within the water column at any of the sampling sites exceed
the Alaska WQS of 25 NTU. The maximum reported value across all samples
is 8.8 NTU, which meets the 25 NTU criterion. Therefore, the facility's TSS
discharge is not expected to violate Alaska's water quality criteria for
turbidity.
Secchi Monitoring Data
The applicant collected ambient Secchi data in the receiving water between
2003 and 2005. The data collected at reference and outfall sites is presented
in Table 3 of the 301(h) TD.
The change in suspended solids in the water column is indirectly related to
turbidity measurements. The increase in receiving water suspended solids
concentration following initial dilution can be calculated from formula B-32
in the 301(h) TSD:
SS = SSe/Sa where,
SS = change in suspended solids concentration following initial dilution
SSe = effluent suspended solids concentration (190 mg/L)
Sa = initial dilution (100:1)
Solving the above equation using the maximum allowable TSS concentration
results in a 1.9 mg/L increase in suspended solids after initial dilution, or 1%.
The 301(h) guidance states that a TSS increase of less than 10% after initial
dilution is not expected to have a substantial impact on water quality.
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Based on the above analyses and that presented in Appendix B of the 301(h)
TD, the discharge will not cause or contribute to a violation of AK WQS for
turbidity.
Copper
The Alaska WQS for the protection of aquatic life are an acute criterion of 4.8
Hg/L and a chronic criterion of 3.1 |ag/L for dissolved copper. The 2001 permit
includes effluent limits for copper of 78 |ag/L (1.236 lbs/day) and a maximum
daily limit of 156 |ag/L (2.472 lbs/day). In preliminary discussions, ADEC has
indicated it will authorize acute and chronic dilution factors of 11:1 and 19:1,
respectively, for copper.
Based on the DMR data (2016-2021), Alaska WQS, and the mixing zone ADEC
has proposed, the Haines WWTP discharge has reasonable potential to cause
or contribute to a violation of the aquatic water quality criterion for copper.
The facility does not have reasonable potential to exceed the human health
criterion for copper.
Since there is reasonable potential to cause or contribute to a violation of the
aquatic WQS for copper, EPA calculated the following WQBELs for copper:
an average monthly limit of 21 |ag/L (0.33 lbs/day) and a maximum daily limit
of 64 |ag/L (1.01 lbs/day). These limits are more stringent than the limits in
the 2001 permit.
The 95th percentile effluent concentration from 2016-2021 for copper is
30 |-ig/L. The average copper effluent concentration from 2016-2021 is
8.8 |-ig/L. The range of copper effluent concentrations from 2015-2021 is a
minimum of 0 |ag/L and a maximum of 100 |ag/L. Based on this data, EPA
believes the facility will be able to meet the proposed limits. Therefore, EPA
is not proposing a compliance schedule for copper. The draft permit
proposes to increase copper effluent monitoring to twice a month to support
the effluent limits. See Appendix C for reasonable potential calculations for
copper.
Chlorine
Chlorine is often used to disinfect municipal wastewater prior to discharge.
The Haines WWTP does not currently provide consistent disinfection of its
effluent but will need to in order to achieve the final bacteria limits in the
draft permit. In addition, Haines did not include the use of chlorine in its
permit application and did not provide any indication that chlorine was being
used at the facility. Since the Haines WWTP does not use chlorine, EPA has
determined that the Haines WWTP does not have reasonable potential to
exceed the water quality standard for chlorine and is not including a limit for
chlorine in the proposed permit. If the facility begins to use chlorine, it will
need to notify EPA pursuant to Part IV.I of the permit so that EPA can
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determine whether to modify the permit to include chlorine limits. Until that
time, the Haines WWTP is not authorized to discharge chlorine.
Fecal Coliform
Alaska's most restrictive marine criterion for fecal coliform bacteria
concentrations are in areas protected for the harvesting and use of raw
mollusks and other aquatic life. The criterion specifies that the geometric
mean of samples shall not exceed 14 fecal coliform/100 mL, and that not
more than 10 percent of the samples shall exceed 43 most probable number
(MPN)/100 mL for a five-tube decimal dilution test. MPN is the statistic that
represents the number of individuals most likely present in a given sample,
based on test data. Because Portage Cove is protected for raw aquatic life
consumption, this standard must be met at the edge of the ZID.
40 CFR 122.45(d)(2) requires effluent limitations for continuous discharges
from POTWs be expressed as average weekly and average monthly
limitations, unless impracticable. Additionally, the terms "average weekly
discharge limitation" and "average monthly discharge limitation" are defined
in 40 CFR 122.2 as being arithmetic (as opposed to geometric) averages. It is
impracticable to properly implement a 30-day geometric mean criterion in a
permit using monthly and weekly arithmetic average limits. The geometric
mean of a given data set is equal to the arithmetic mean of that data set if
and only if all of the values in that data set are equal. Otherwise, the
geometric mean is always less than the arithmetic mean. In order to ensure
that the effluent limits are "derived from and comply with" the geometric
mean water quality criterion, as required by 40 CFR 122.44(d)(l)(vii)(A), it is
necessary to express the effluent limits as a monthly geometric mean and an
instantaneous maximum limit.
EPA derived WQBELs for fecal coliform by multiplying the dilution factor of
19:1 achieved at the edge of the chronic mixing zone by the criteria. The
WQBEL calculations are shown below:
Monthly geometric mean limit = 14 CFU/100 mL x 19 = 266 CFU/100 mL
Instantaneous maximum limit = 43 CFU/100 mL x 19 = 817 CFU/100 mL
These WQBELs will be protective of Alaska WQS for fecal coliform at the
boundary of the chronic mixing zone.
During review of the preliminary draft permit, ADEC indicated that they will
require the final fecal coliform limitations in the table below as a condition of
their final 401 Certification of the reissued permit. Since these limits are
more stringent than the WQBELs developed above, EPA has included these
limits in the draft permit. ADEC will accept comment on their proposed limits
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during public notice of the 401 certification. If ADEC includes these limits in
the final 401 certification, then EPA must include them in the permit
pursuant to CWA section 401(d). If ADEC does not include these limits in the
final 401 certification of this permit, the fecal coliform effluent limits will be
based on the WQBELs that EPA has calculated. EPA is accepting comment on
the calculated WQBELs that will be imposed if ADEC does not include the
fecal coliform limits as indicated in its 401 certification.
These limits would become effective at the end of the compliance schedule.
Table 12. ADEC Proposed Final Fecal Coliform Limits
Average
Monthly
(FC/100 mL)
Average
Weekly
(FC/100 mL)
Maximum
Daily
(FC/100 mL)
2001
4001
800
1. 18 AAC 72.990(21)
The 2001 permit contains effluent limits for fecal coliform of a monthly
average limit of 1,000,0000 FC/lOOmL and a maximum daily limit of
1,500,000 FC/lOOmL. The Haines WWTP does not currently have the
technology necessary to meet the more stringent WQBELs for fecal coliform
in the draft permit. EPA expects that ADEC will authorize a five-year
compliance schedule for the facility in its 401 Certification to meet the final
fecal coliform limits in the draft permit. EPA has included the terms of the
compliance schedule in the draft permit.
The draft permit includes interim performance-based limits that apply until
the end of the compliance schedule. The interim limits were derived by
taking the 95th percentile of fecal coliform effluent data for the facility. The
proposed interim fecal coliform limits are an average monthly limit of
977,000 cfu/100 mL and a maximum daily limit of 1,141,000 CFU/100 mL.
(See Appendix A for water quality data.)
Section V.C. of this Fact Sheet describes the compliance schedule for fecal
coliform. The WQBELs developed for fecal coliform will be protective of
Alaska WQS after mixing at the edge of the ZID and will satisfy the
requirements of Section 301(h)(9) of the CWA and 40 CFR 125.63(a).
Enterococcus
Enterococci bacteria are indicator organisms of harmful pathogens
recommended by the EPA to protect primary contact recreation for marine
waters. The EPA Beaches Environmental Assessment and Coastal Health Act
(BEACH Act) requires states and territories with coastal recreation waters to
adopt enterococci bacteria criteria into their WQS. EPA approved Alaska's
WQS for enterococcus in 2017. The WQS at 18 AAC 70.020(b)(14)(B) for
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contact recreation specifies that the enterococci bacteria concentration shall
not exceed 35 enterococci CFU/lOOmL, and not more than an 10% of the
samples may exceed a concentration of 130 enterococci CFU/lOOmL.
The 2001 permit does not contain effluent limitations for enterococcus
bacteria because there was no applicable enterococcus standard in effect
when the permit was issued in November 2001.
40 CFR 122.44(d)(1) requires EPA to account for existing controls on
discharges when determining whether a discharge has the reasonable
potential to cause or contribute to an excursion of state WQS. The WWTP
does not currently disinfect its effluent, resulting in the high bacterial loads
observed in the available fecal coliform data. The 2001 permit did not require
enterococcus monitoring, but high fecal coliform loads such as what was
observed during the last permit cycle, are indicative of high concentrations of
other pathogens commonly found in WWTP effluents, including
enterococcus. With the available fecal coliform data and lack of disinfection
capacity at the facility, EPA has determined there is reasonable potential for
the discharge to cause or contribute to a violation of Alaska WQS for
enterococcus at the edge of the chronic mixing zone. EPA calculated WQBELs
using the same procedure used for fecal coliform. The enterococcus limits
are expressed in terms of a geometric mean and instantaneous limit for the
same reasons as explained above in the fecal coliform section.
Monthly geometric mean limit = 35 CFU/100 mL x 19 = 665 CFU/100 mL
Instantaneous maximum limit = 130 CFU/100 mL x 19 = 2,470 CFU/100 mL
These WQBELs will be protective of Alaska WQS for enterococci at the
boundary of the chronic mixing zone. The Haines WWTP does not currently
have the disinfection technology necessary to meet these limits. EPA expects
that ADEC will authorize a five-year compliance schedule for the Haines
WWTP in its 401 Certification to meet the final enterococcus limits in the
draft permit.
EPA has included the terms of the compliance schedule in the draft permit.
Because this is a new effluent limit, no interim limits are being proposed.
Section V.C. of this Fact Sheet describes the compliance schedule for
enterococcus. The WQBELs developed for enterococcus will be protective of
Alaska WQS after initial mixing at the edge of the ZID and will satisfy the
requirements of Section 301(h)(9) of the CWA and 40 CFR 125.63(a).
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Residues
The Alaska WQS require that surface waters of the State be free from
floating, suspended or submerged matter of any kind in concentrations
impairing designated beneficial uses. The draft permit contains a narrative
limitation prohibiting the discharge of such materials.
Temperature
Alaska's WQS for water temperature provides that the discharge may not
exceed 15°C for marine uses. In addition, for waters protected for the
aquaculture designated use, the discharge may not cause the weekly average
temperature to increase more than 1°C. The maximum rate of change may
not exceed 0.5°C per hour, and normal daily temperature cycles may not be
altered in amplitude or frequency. EPA reviewed surface water and DMR
data between 2016 and 2021 to assess whether the modified discharge will
comply with the Alaska WQS for temperature.
The maximum ocean temperature recorded at the trapping depth of the
discharge during receiving water monitoring from 2003 to 2005 was 11.2°C,
and the maximum recorded effluent temperature between 2016 and 2021
was 15.8°C. EPA conducted a mass balance analysis using these values and
calculated a final receiving water temperature of 11.2°C after initial dilution.
Ce + [ Cu ( Sa - 1) ]
Cd = where
Sa
Cd = Resultant temperature at edge of mixing zone, °C
Ce = Maximum projected effluent temperature, (15.8 °C)
Cu = Background receiving water temperature, °C (11.2 °C)
Sa = dilution factor (100)
Cd = 11.2 °C
The temperature of the receiving water after initial dilution is effectively the
same as the ambient ocean temperature.
Based upon the above analysis, the proposed discharge is expected to
comply with Alaska WQS for temperature after initial mixing at the edge of
the ZID. Therefore, the permit does not contain a temperature effluent limit.
Ammonia
Marine ammonia criteria are based on a formula, which relies on the pH,
temperature, and salinity of the receiving water, because the fraction of
ammonia present as the toxic, un-ionized form increases with increasing pH
and temperature and decreases with salinity. Therefore, the criteria become
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more stringent as pH and temperature increase and less stringent as salinity
increases. Appendices F and G of the Alaska Water Quality Criteria Manual
for Toxic and Other Deleterious Organic and Inorganic Substances includes
tables to determine acute and chronic criteria based upon these
parameters.
No ammonia effluent data was available since the 2001 permit was issued.
Therefore, EPA did not have any samples to evaluate for reasonable potential
to exceed the water quality standards for ammonia. Since ammonia is a
commonly discharged pollutant by wastewater treatment plants, and the
Haines WWTP is a major facility, EPA is requiring quarterly ammonia effluent
samples so that reasonable potential for ammonia can be evaluated during
the next permit cycle. The proposed permit also requires that the permittee
conduct receiving water monitoring of pH, temperature, and salinity, to allow
calculation of applicable ammonia criteria for the next permit cycle.
Benzidine
Benzidine is predominately used in the production of dyes, but its
carcinogenic properties have decreased its use. The production of benzidine
was banned in the US in 1973, and benzidine is no longer imported into the
US, although benzidine-based dyes may still be imported 2. EPA's National
Toxics Rule at 40 CFR 131.36 establishes a human health criteria for
benzidine, for protection of organisms, that is applicable to Alaska, of 0.0054
Hg/L.
The Haines WWTP detected benzidine in two samples submitted with the
priority pollutant scans in 2006. However, since benzidine is expected to
now be less prevalent in wastewater discharges than in 2006, in March 2022,
EPA requested that the facility submit 3 new effluent samples of benzidine.
All three samples of benzidine submitted in 2022 resulted in non-detects.
EPA used these recent samples to determine that the facility does not have
reasonable potential to exceed the water quality standards for benzidine.
Therefore, the permit does not contain an effluent limit for benzidine.
Other Pollutants of Concern
EPA also evaluated reasonable potential for other pollutants the facility
detected during required monitoring of priority pollutants. These pollutants
include lead, nickel, silver, zinc, antimony, arsenic, bis (2-ethylhexyl)
phthalate, chloroform, chromium, di-n-butyl phthalate, 1,4 dichloro benzene,
naphthalene, phenol, selenium, and toluene. EPA did not find reasonable
2 USEPA Benzidine IRIS Summary, Accessed at
https://iris.epa.gov/Chemicall_anding/&substance nmbr=135
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potential to exceed the water quality criteria for any of these pollutants and
effluent limits are therefore not included in the draft permit. Reasonable
potential calculations can be found in Appendix C.
d. Antibacksliding: WQBELs
Section 402(o) of the CWA and 40 CFR 122.44(1) generally prohibit the
renewal, reissuance, or modification of an existing NPDES permit that
contains effluent limits, permit conditions or standards that are less stringent
than those established in the previous permit (i.e., anti-backsliding) but
provides limited exceptions. For explanation of the antibacksliding
exceptions refer to Chapter 7 of the Permit Writers' Manual Final Effluent
Limitations and Anti-backsliding.
According to the U.S. EPA NPDES Permit Writers' Manual (EPA-833-K-10-001),
backsliding is allowed if it is consistent with the provisions of CWA section
303(d)(4) or if one of the exceptions in CWA section 402(o)(2) is met (except for
Sections 402(o)(2)(B)(ii) and 402(o)(2)(D)). Section 303(d)(4) of the CWA states
that, for water bodies where the water quality meets or exceeds the level
necessary to support the water body's designated uses, WQBELs may be revised
as long as the revision is consistent with the State's antidegradation policy. EPA
is proposing to backslide for chlorine limits.
Here, the waterbody is in attainment of WQS, thus supports the waterbody's
designated uses. The facility has a chlorine limit in the 2001 permit that
applies if the facility uses chlorine. The facility does not provide chlorination
of the effluent and does not have reasonable potential to exceed the water
quality standard for chlorine. ADEC will conduct an antidegradation analysis
during the 401-certification process as described in Fact Sheet Section VI.D.
Assuming that ADEC concludes that their antidegradation policy is met,
backsliding is allowed.
B. MONITORING REQUIREMENTS
Section 308 of the CWA and 40 CFR 122.44(i) require monitoring in permits to
determine compliance with effluent limitations. Monitoring may also be required to
gather effluent and surface water data to determine if additional effluent limitations
are required and/or to monitor effluent impacts on receiving water quality.
The draft permit requires the permittee to perform effluent monitoring required by
the NPDES Form 2A application, so that these data will be available when the
permittee applies for a renewal of its NPDES permit.
The draft permit also requires the permittee to perform effluent monitoring required
by Tables A, B, and C of the NPDES Form 2A application, so that these data will be
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available when the permittee applies for a renewal of its NPDES permit and EPA can
assess compliance with Section 301(h) of the CWA.
The permittee is responsible for conducting the monitoring and for reporting results
on DMRs or on the application for renewal, as appropriate, to EPA.
1. Effluent Monitoring
Monitoring frequencies are based on the nature and effect of the pollutant, as
well as a determination of the minimum sampling necessary to adequately
monitor the facility's performance. Permittees have the option of taking more
frequent samples than are required under the permit. These samples must be
used for averaging if they are conducted using EPA-approved test methods
(generally found in 40 CFR Part 136) or as specified in the permit.
a. Effluent Monitoring Changes from the Previous Permit
The draft permit maintains the effluent monitoring schedule from the 2001
permit except for the following proposed changes:
Table 13. Monitoring Changes in Permit
Parameter
Monitoring Change
Basis
Fecal
Coliform
Increase in effluent
monitoring frequency
from once per month to
twice per month.
The draft permit contains new, more
stringent, fecal coliform limits which the
permittee will be working to achieve in
accordance with the compliance schedule
outlined Section II.C of the draft permit.
Monitoring twice per month is more
appropriate and representative than
monthly monitoring and required to
ensure compliance with the fecal coliform
limits and protection of Alaska WQS.
Enterococcus
New effluent
monitoring
requirement, twice per
month
The draft permit contains a new effluent
limit for enterococcus that the permittee
will be working to achieve in accordance
with the compliance schedule outlined
Section II.C of the draft permit.
Monitoring twice per month is necessary
to ensure compliance with the limit and
protection of Alaska WQS.
Copper
Increase effluent
monitoring from
quarterly monitoring to
once per month
The prior permit required quarterly
monitoring for copper to support the
effluent limits. EPA determined the
permittee has reasonable potential to
exceed the WQS for copper and is
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proposing more stringent copper effluent
limits to meet Alaska WQS. EPA is
increasing the effluent monitoring
requirement to support the more
stringent limits.
Ammonia
New effluent
monitoring
requirement, quarterly
Ammonia is a pollutant of concern at
wastewater treatment plants. Quarterly
monitoring will provide data for the next
permit cycle for evaluating compliance
with Alaska WQS.
Whole
Effluent
Toxicity
Increase in monitoring
Haines is classified as a major facility and
requires more frequency toxicity
monitoring. Increased monitoring will
also help to better characterize WET for
the next permit cycle.
Toxic
Pollutants
Monitoring
Clarified effluent
monitoring
requirements
The draft permit clarifies the required
toxic pollutants to monitor in effluent to
comply with CWA regulations.
PFAS
New effluent
monitoring
requirements
PFAS are widespread and persistent in
the environment. The draft permit
requires monitoring to determine if the
effluent contains PFAS. See Section
IV.B.l.b, below.
1 Concentration/mass-loading limits only; compliance with 30% removal is still
determined on monthly averaging basis.
b. PFAS Monitoring
Per- and polyfluoroalkyl substances (PFAS) are a group of synthetic chemicals
that have been in use since the 1940s. PFAS are found in a wide array of
consumer and industrial products. Due to their widespread use and
persistence in the environment, most people in the United States have been
exposed to PFAS. Discharges of PFAS above certain levels may cause adverse
effects to human health or aquatic life.3, 4
Since PFAS chemicals are persistent in the environment and may lead to
adverse human health and environmental effects, the draft permit requires
3 EPA, EPA's Per- and Polyfluoroalkyl Substances (PFAS) Action Plan, EPA 823R18004, February 2019. Available at:
https://www.epa.gov/sites/production/files/2019-02/documents/pfas action plan 021319 508compliant l.pdf
4 EPA, Fact Sheet: Draft 2022 Aquatic Life Ambient Water Quality Criteria for Perfluorooctanoic acid (PFOA) and Perfluorooctane Sulfonic
Acid (PFOS). Available at: https://www.epa.gov/svstem/files/documents/2022-04/pfoa-pfos-draft-factsheet-2022.pdf
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that the permittee conduct twice yearly influent, effluent, and sludge
sampling for PFAS chemicals. This will result in 10 samples being collected
over the 5-year permit term. 10 results are the minimum sample size
necessary to calculate the standard deviation and mean of the data with
sufficient confidence (USEPA, 1991).
The draft permit also requires that the permittee either submit a certification
meeting the requirements of 40 CFR 125.66(a)(2) that there are no industrial
users and documents the certification with an industrial user survey as
described by 40 CFR 403.8(f)(2) or inventory the industrial users (lUs) of the
treatment works, to identify lUs of the POTW that may discharge pollutants,
including PFAS chemicals, to the collection system. Industry sectors known or
suspected to discharge PFAS include, but are not limited to, organic
chemicals, plastics & synthetic fibers (OCPSF); metal finishing; electroplating;
electric and electronic components; landfills; pulp, paper & paperboard;
leather tanning & finishing; plastics molding & forming; textile mills; paint
formulating, and airports..5, 6 EPA's website has public databases such as
Enforcement and Compliance History Online (ECHO) (https://echo.epa.gov/)
and Envirofacts (https://enviro.epa.gov/) which may be useful in identifying
such industrial users.
If PFAS chemicals are detected in the influent, effluent, or sludge in the first
year of sampling, then the permittee must sample the lUs identified as
potential PFAS sources at least once during the following calendar year.
The purpose of these monitoring and reporting requirements is to better
understand potential discharges of PFAS from this facility and to inform
future permitting decisions, including the potential development of water
quality-based effluent limits. EPA is authorized to require this monitoring and
reporting by CWA section 308(a). The permit conditions reflect EPA's
commitments in the PFAS Strategic Roadmap, which directs the Office of
Water to leverage NPDES permits to reduce PFAS discharges to waterways
"at the source and obtain more comprehensive information through
monitoring on the sources of PFAS and quantity of PFAS discharged by these
sources."
There is currently no analytical method approved in 40 CFR Part 136 for
PFAS. As stated in 40 CFR 122.44(i)(l)(iv)(B), in the case of pollutants or
pollutant parameters for which there are no approved methods under 40
CFR Part 136 or methods are not otherwise required under 40 CFR chapter I,
subchapter N or 0, monitoring shall be conducted according to a test
5 EPA, "Addressing PFAS Discharges in NPDES Permits and Through the Pretreatment Program and Monitoring Programs." Available
at: https://www.epa.gov/svstem/files/documents/2022-12/NPDES PFAS State%20Memo December 2022.pdf.
6 A spreadsheet listing industries that may discharge PFAS, including Standard Industrial Classification (SIC) and North American Industry
Classification System (NAICS) codes, and a spreadsheet listing Superfund sites with PFAS detections, are available on EPA's website
at: https://echo.epa.goV/tools/data-downloads/national-pfas-datasets#about.
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procedure specified in the permit for such pollutants or pollutant
parameters. Therefore, the Permit specifies that until there is an analytical
method approved in 40 CFR Part 136 for PFAS, monitoring shall be conducted
using Draft Method 1633.
2. Receiving Water Monitoring
In general, receiving water monitoring may be required for pollutants of concern
to assess the assimilative capacity of the receiving water for the pollutant. In
addition, receiving water monitoring may be required for pollutants for which the
water quality criteria are dependent and to collect data forTMDL development if
the facility discharges to an impaired water body. Pursuant to Section 301(h)(3) of
the CWA and 40 CFR 125.63(c), facilities operating under 301(h)-modified permits
are required to establish and implement a water quality monitoring program to
provide adequate data for evaluating compliance with WQS or federal water
quality criteria and measure the presence of toxic pollutants that have been
identified or reasonably may be expected to be present in the discharge.
EPA is retaining most of the receiving water monitoring program from the 2001
permit in the draft permit. Changes to the receiving water monitoring program
include the addition of enterococcus to the suite of parameters analyzed and the
addition of sampling at the center of the ZID, and at the west and east side of the
ZID. These additional sampling points will provide more complete information on
dilution at the boundary of the ZID.
A detailed description of the receiving water monitoring program in the draft
permit can be found in Section 8.G.2 of the 301(h) TD, Part I.D.I of the draft
permit, and Table 12 below. Locations of the receiving water monitoring for each
parameter can be found in Permit Part I.D.2.
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Table 14. Receiving Water Monitoring Requirements
Parameter
Units
Sample
Type
Sample Depth
Frequency
Location
Temperature
°C
Grab
Surface, every
5m to bottom
Annually
(July or
August)
ZID Station, ZID
Boundary,
Reference Sites1
Salinity
Ppt
Grab
Surface, every
5m to bottom
Annually
(July or
August)
ZID Station, ZID
Boundary,
Reference Sites1
Dissolved Oxygen
Mg/L
Grab
Surface, every
5m to bottom
Annually
(July or
August)
ZID Station, ZID
Boundary,
Reference Sites1
pH
Standard
units
Grab
Surface, every
5m to bottom
Annually
(July or
August)
ZID Station, ZID
Boundary,
Reference Sites1
Secchi Disk Depth
Feet
Visual
Surface, every
5m to bottom
Annually
(July or
August)
ZID Station, ZID
Boundary,
Reference Sites1
Turbidity
NTU
Grab
Surface, every
5m to bottom
Annually
(July or
August)
ZID Station, ZID
Boundary,
Reference Sites1
Fecal Coliform
#/100 mL
Grab
Surface
(or just below)
Monthly3
(May to
September)
ZID Station, ZID
Boundary,
Reference Sites,
Near Shore Sites2
Enterococcus
#/100mL
Grab
Surface
(or just below)
Monthly3
(May to
September)
ZID Station, ZID
Boundary,
Reference Sites,
Near Shore Sites2
Biological
Monitoring for
Benthic Infauna and
Sediment Analysis
Per
method
Grab
Per method
Once every
5 years4
ZID Station, ZID
Boundary,
Reference Sites1
1Monitoring is required at the following: ZID Station, ZID Boundary Sites and Reference Sites as described in Permit Part I.D.2.a,b,c.
2Monitoring is required at the following: ZID Station, ZID Boundary Sites and Reference Sites as described in Permit Part I.D.2.a,b,c,d.
3Monitoring is required once a month in May, June, July, August, and September. Fecal Coliform and enterococcus sampling shall
coincide with effluent sampling in Permit Part I.B.
4Biological monitoring shall be conducted in August of the fourth year of the permit and every five years thereafter.
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3. Whole Effluent Toxicity (WET) Testing Requirements
EPA and individual States implement three approaches to protect water quality.
These approaches include chemical-specific control, toxicity testing control (i.e.,
whole effluent toxicity testing), and biological criteria/bioassessments (EPA
1991).
WET requirements in NPDES permits protect aquatic life from the aggregate toxic
effect of a mixture of pollutants in the effluent. WET tests use small vertebrate
and invertebrate species and/or plants to measure the aggregate toxicity of an
effluent. The end point and results of WET tests are typically reported in acute
and chronic toxic units, TUa and TUc, respectively. The TUa and TUc test results
are treated the same as other reported permit parameters and used in the same
manner in the TSD calculations for determining reasonable potential and
establishing WQBELs for WET.
Alaska WQS at 18 AAC 70.030 require that an effluent discharged to a waterbody
may not impart chronic toxicity to aquatic organisms, expressed as 1.0 chronic
toxic unit (TUc), at the point of discharge, or if the Department authorizes a
mixing zone in a permit, approval, or certification, at or beyond the mixing zone
boundary, based on the minimum effluent dilution achieved in the mixing zone.
18 AAC 83.435 requires that a permit contain limitations on WET when a
discharge has reasonable potential to cause or contribute to an exceedance of a
WQS.
The Haines WWTP conducted a WET test in 2001 pursuant to the terms of the
2001 permit. The reported TUC is 3.1. With only one data point collected over 20
years ago, the toxicity of the current discharge is highly uncertain. To characterize
the toxicity of the effluent for the protection of Alaska WQS, the permit proposes
to increase WET monitoring to two tests per year while the permit remains in
effect.
A WET trigger of 19 TUc has been established which, if exceeded, will require the
Permittee to implement the toxicity identification evaluation (TIE) and toxicity
reduction evaluation (TRE) procedures specified in Part I.C. of the draft permit. If
the WET trigger is not exceeded after six (6) consecutive WET tests the Permittee
may reduce the frequency of WET testing to annually while the permit remains in
effect. At the completion of the TIE/TRE process the Permittee must revert to
testing twice per year. To assess and monitor for any seasonal variation in results,
biannual testing must be conducted during different seasons and annual testing
must be done on a rotating quarterly schedule, so that each annual test is
conducted during a different quarter than the previous year's test.
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4. Biological Monitoring for Benthic Infauna and Sediment Analyses
Facilities operating under 301(h)-modified NPDES permits are required by
40 CFR 125.63(b) to have a biological monitoring program in place that provides
adequate data to evaluate the impact of the discharge on marine biota. The draft
permit requires biological monitoring, consisting of a benthic survey and
sediment analysis for total volatile solids (TVS) within the ZID, at a reference
location, and within 5 m beyond the ZID boundary.
The 2001 Permit required one benthic survey and sediment analysis for TVS,
completed in 2006. The results of the survey do not indicate that the sewer
outfall discharge is causing significant changes in the benthic community
structure.
To continue to monitor the effect of the discharge on the surrounding benthic
community, the biological monitoring program from the 2001 permit is being
retained in the draft permit. The draft permit requires biological monitoring
during the fourth year of the permit and every five years thereafter. See Permit
Part I.E.
5. Electronic Submission of Discharge Monitoring Reports
The draft permit requires that the permittee submit DMR data electronically
using NetDMR. NetDMR is a national web-based tool that allows DMR data to be
submitted electronically via a secure Internet application.
Further information about NetDMR, including upcoming trainings and contacts, is
provided on the following website: https://npdes-ereporting.epa.gov/net-
netdmr.
Permit Part III.B.3 requires that the Permittee submit a copy of the DMR to ADEC.
The permittee may submit a copy by adding the email address for to the
electronic submittal through NetDMR
C. SLUDGE (BIOSOLIDS) REQUIREMENTS
EPA Region 10 separates wastewater and sludge permitting. EPA has authority under
the CWA to issue separate sludge-only permits for the purposes of regulating
biosolids. EPA may issue a sludge-only permit to each facility at a later date, as
appropriate.
Until future issuance of a sludge-only permit, sludge management and disposal
activities at each facility continue to be subject to the national sewage sludge
standards at 40 CFR Part 503 and any requirements of the State's biosolids program.
The Part 503 regulations are self-implementing, which means that facilities must
comply with them whether or not a permit has been issued.
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V. Other Permit Conditions
a. toxics control program
1. Chemical Analysis and Source Identification
The 301(h) regulations at 40 CFR 125.66(a) require applicants to submit at the
time of application an analysis of their effluent for the toxic substances and
pesticides identified in 40 CFR 401.15. The draft permit requires monitoring of
toxic substances and pesticides as detailed in the NPDES Application Form 2A,
Table B, C, and Permit Part I.B.10 which includes those in 40 CFR 401.15.
Pursuant to 40 CFR 125.66(b), facilities must also provide an analysis of the
known or suspected sources of any detected parameters. The draft permit
includes these requirements in Part II.D.l.
2. Industrial Pretreatment Requirements
The 301(h) regulations at 40 CFR 125.66(c) require applicants with known or
suspected industrial sources of toxic pollutants to develop and implement an
approved pretreatment program in accordance with 40 CFR Part 403. This
provision does not apply to applicants that certify they have no known or
suspected industrial sources of toxics in their discharge. Haines has certified they
have no known or suspected industrial sources of toxics in their discharge. The
draft permit requires the facility to maintain and submit a list of any industrial
users at the time of permit renewal application or submit a new certification
stating there are no known or suspected industrial sources of toxics pollutants in
their discharge.
3. Non-Industrial Source Control Program
The 301(h) regulations at 40 CFR 125.66(d) require the permittee to implement a
public education program designed to minimize the entrance of nonindustrial
toxic pollutants and pesticides into its POTW. The draft permit requires the
permittee to continue to implement a public education and outreach program
designed to minimize the introduction of nonindustrial sources of toxics into the
treatment plant.
B. INTERIM BEACH ADVISORY
The draft permit retains the requirement for a beach advisory sign placed on the
nearshore area around the outfall advising against bathing or the consumption of raw
shellfish from the area. The sign must remain in place until the final WQBELs for fecal
coliform and enterococcus are achieved.
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C. COMPLIANCE SCHEDULES
Compliance schedules are authorized by federal NPDES regulations at 40 CFR 122.47
and Alaska WQS at 18 AAC 70.910. Compliance schedules allow a discharger to phase
in, over time, compliance with WQBELs when limitations are in the permit for the first
time.
The draft permit proposes a compliance schedule for fecal coliform and enterococcus
because the discharge cannot immediately comply with the new effluent limits on the
effective date of the permit. The draft permit proposes the following:
• Interim performance-based limits for fecal coliform, based on fecal
coliform effluent data from 2016-2021, effective until the end of the
compliance schedule when final limits for fecal coliform become effective;
• Monitoring for enterococcus and final limits for enterococcus, which
become effective at the end of the compliance schedule;
• A compliance schedule that allows 5 years for the facility to comply with
the new effluent limits and includes interim milestones as set forth in
Permit Part II.C.
ADEC authorizes compliance schedules in its 401 certification. EPA will amend the
compliance schedule, if needed, after receiving final 401 certification from ADEC. For
more information on the details of the compliance schedule refer to the 401-
certification and Part II.C of the draft permit.
D. QUALITY ASSURANCE PLAN
The Haines WWTP is required to update the Quality Assurance Plan (QAP) within 180
days of the effective date of the permit. The QAP must consist of standard operating
procedures the permittee must follow for collecting, handling, storing and shipping
samples, laboratory analysis, and data reporting. The plan must be retained on site
and made available to EPA and the ADEC upon request.
E. OPERATION AND MAINTENANCE PLAN
The permit requires the Haines WWTP to properly operate and maintain all facilities
and systems of treatment and control. Proper operation and maintenance is essential
to meeting discharge limits, monitoring requirements, and all other permit
requirements at all times. The permittee is required to develop and implement an
operation and maintenance plan for their facility within 180 days of the effective date
of the permit. The plan must be retained on site and made available to EPA and ADEC
upon request.
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F. SANITARY SEWER OVERFLOWS AND PROPER OPERATION AND MAINTENANCE OF
THE COLLECTION SYSTEM
Sanitary Sewer Overflows (SSOs) are not authorized under this permit. The permit
contains language to address SSO reporting and public notice and operation and
maintenance of the collection system. The permit requires that the permittee identify
SSO occurrences and their causes. In addition, the permit establishes reporting, record
keeping and third-party notification of SSOs. Finally, the permit requires proper
operation and maintenance of the collection system.
The following specific permit conditions apply:
Immediate Reporting - The permittee is required to notify EPA of an SSO within 24
hours of the time the permittee becomes aware of the overflow. (See
40 CFR122.41(I)(6))
Written Reports - The permittee is required to provide EPA a written report within
five days of the time it became aware of any overflow that is subject to the immediate
reporting provision. (See 40 CFR 122.41(l)(6)(i)).
Third Party Notice - The permit requires that the permittee establish a process to
notify specified third parties of SSOs that may endanger health due to a likelihood of
human exposure; or unanticipated bypass and upset that exceeds any effluent
limitation in the permit or that may endanger health due to a likelihood of human
exposure. The permittee is required to develop, in consultation with appropriate
authorities at the local, county, tribal and/or state level, a plan that describes how,
under various overflow (and unanticipated bypass and upset) scenarios, the public, as
well as other entities, would be notified of overflows that may endanger health. The
plan should identify all overflows that would be reported and to whom, and the
specific information that would be reported. The plan should include a description of
lines of communication and the identities of responsible officials. (See
40 CFR122.41(I)(6)).
Record Keeping - The permittee is required to keep records of SSOs. The permittee
must retain the reports submitted to EPA and other appropriate reports that could
include work orders associated with investigation of system problems related to a
SSO, that describes the steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the SSO. (See 40 CFR 122.41(j)).
Proper Operation and Maintenance - The permit requires proper operation and
maintenance of the collection system. (See 40 CFR 122.41(d) and (e)). SSOs may be
indicative of improper operation and maintenance of the collection system. The
permittee may consider the development and implementation of a capacity,
management, operation and maintenance (CMOM) program.
The permittee may refer to the Guide for Evaluating Capacity, Management,
Operation, and Maintenance (CMOM) Programs at Sanitary Sewer Collection Systems
(EPA 305-B-05-002). This guide identifies some of the criteria used by EPA inspectors
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to evaluate a collection system's management, operation and maintenance program
activities. Owners/operators can review their own systems against the checklist
(Chapter 3) to reduce the occurrence of sewer overflows and improve or maintain
compliance.
G. ENVIRONMENTAL JUSTICE
As part of the permit development process, EPA Region 10 conducted a screening
analysis to determine whether this permit action could affect overburdened
communities. "Overburdened" communities can include minority, low-income, tribal,
and indigenous populations or communities that potentially experience
disproportionate environmental harms and risks. EPA used a nationally consistent
geospatial tool that contains demographic and environmental data for the United
States at the Census block group level. This tool is used to identify permits for which
enhanced outreach may be warranted.
The Haines WWTP is not located within or near a Census block group that is
potentially overburdened. The draft permit does not include any additional conditions
to address environmental justice.
Regardless of whether a facility is located near a potentially overburdened
community, EPA encourages permittees to review (and to consider adopting, where
appropriate) Promising Practices for Permit Applicants Seeking EPA-lssued Permits:
Ways To Engage Neighboring Communities (see
https://www.federalregister.gOv/d/2013-10945). Examples of promising practices
include: thinking ahead about community's characteristics and the effects of the
permit on the community, engaging the right community leaders, providing progress
or status reports, inviting members of the community for tours of the facility,
providing informational materials translated into different languages, setting up a
hotline for community members to voice concerns or request information, follow up,
etc.
For more information, please visit https://www.epa.gov/environmentaliustice and
Executive Order 12898, Federal Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations.
H. PRETREATMENT REQUIREMENTS
Because the Haines WWTP does not have an approved POTW pretreatment program
per 40 CFR 403.8, EPA is the Control Authority of industrial users that might introduce
pollutants into the Haines WWTP. 40 CFR 125.66(c) provides that an applicant that has
known or suspected industrial sources of toxic pollutants shall have an approved
pretreatment in accordance with 40 CFR part 403. This requirement does not apply to
any applicant which certifies that the applicant is not known or suspected industrial
sources of toxic pollutants or pesticides. The permittee provided this certification on
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April 8, 2022. Since EPA does not know of or suspect any industrial sources of toxic
pollutants, the facility is not required to have an approved pretreatment program.
Permit Part II.D reminds the Permittee that it cannot authorize discharges that may
violate the national specific prohibitions of the General Pretreatment Program.
Although not a permit requirement, the Permittee may wish to consider developing
the legal authority enforceable in Federal, State or local courts which authorizes or
enables the POTW to apply and to enforce the requirement of CWA sections 307 (b)
and (c) and 402(b)(8), as described in 40 CFR403.8(f)(1). Where the POTW is a
municipality, legal authority is typically through a sewer use ordinance, which is
usually part of the city or county code. EPA has a Model Pretreatment Ordinance for
use by municipalities operating POTWs that are required to develop pretreatment
programs to regulate industrial discharges to their systems (EPA, 2007). The model
ordinance should also be useful for communities with POTWs that are not required to
implement a pretreatment program in drafting local ordinances to control
nondomestic dischargers within their jurisdictions.
I. STANDARD PERMIT PROVISIONS
Permit Parts III., IV. and V. contain standard regulatory language that must be included
in all NPDES permits. The standard regulatory language covers requirements such as
monitoring, recording, and reporting requirements, compliance responsibilities, and
other general requirements.
VI. Other Legal Requirements
A. ENDANGERED SPECIES ACT
The Endangered Species Act (ESA) requires federal agencies to consult with National
Oceanic and Atmospheric Administration Fisheries (NOAA Fisheries) and/or the U.S.
Fish and Wildlife Service (USFWS) if their actions could beneficially or adversely affect
any threatened or endangered species. EPA has prepared a biological evaluation and
determined the discharge has the potential to affect the endangered western distinct
population segment of Steller sea lion. Pursuant to Section 7 of the ESA, EPA will
consult with NOAA Fisheries prior to taking final action on the permit.
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B. ESSENTIAL FISH HABITAT
Essential fish habitat (EFH) is the waters and substrate (sediments, etc.) necessary for
fish to spawn, breed, feed, or grow to maturity. The Magnuson-Stevens Fishery
Conservation and Management Act (January 21, 1999) requires EPA to consult with
NOAA Fisheries when a proposed discharge has the potential to adversely affect EFH
(i.e., reduce quality and/or quantity of EFH).
The EFH regulations define an adverse effect as any impact that reduces quality
and/or quantity of EFH and may include direct (e.g., contamination or physical
disruption), indirect (e.g., loss of prey, reduction in species' fecundity), site specific, or
habitat-wide impacts, including individual, cumulative, or synergistic consequences of
actions.
EPA will prepare an EFH assessment to assess the impacts of the discharge on EFH. If
the EFH assessment concludes there will be adverse impacts, EPA will consult with
NOAA Fisheries prior to final permit action.
C. CWA SECTION 401 CERTIFICATION
Section 401 of the CWA requires the state in which the discharge originates to certify
that the discharge complies with the appropriate sections of the CWA, as well as any
appropriate requirements of state law. See 33 U.S.C. 1341(d). As a result of the
certification, the state may require more stringent permit conditions or additional
monitoring requirements to ensure that the permit complies with WQS, or treatment
standards established pursuant to any state law or regulation.
EPA had preliminary discussions with ADEC regarding its CWA Section 401 Certification
during development of the draft permit. On February 17, 2023, EPA sent ADEC a pre-
filing certification meeting request. EPA will request final 401 certification from ADEC
with the public notice of this draft permit. EPA cannot issue the permit until ADEC has
granted or waived certification. If ADEC denies certification, EPA cannot issue the
permit.
D. ANTIDEGRADATION
ADEC will conduct an antidegradation analysis of the discharge following its
antidegradation policy and implementation methods outlined in 18 AAC 70.015 and 18
AAC 70.016, respectively. The antidegradation review will be included in the CWA
section 401 Certification for this permit. Questions regarding the CWA section 401
Certification or antidegradation review can be submitted to ADEC as set forth above
(see State Certification on Page 1 of this Fact Sheet).
E. PERMIT EXPIRATION
The permit will expire five years from the effective date.
Fact Sheet: AK0021385 - Haines WWTP
Page 55 of 68
-------
VII. References
ADEC. 2021.18AAC 70, Water Quality Standards, As Amended Through March 5,
2020. Approved by the EPA in 2021. https://www.epa.gov/wqs-tech/water-quality-
standards-regulations-alaska.
ADEC, 2008. Alaska Water Quality Criteria Manual for Toxics and Other Deleterious
Organic and Inorganic Substances. December 2008.
ADEC. 2020. Integrated Water Quality Monitoring and Assessment Report.
Aquatic Restoration and Research Institute, 2022. Water Quality Measures in Alaska's
Ports and Shipping Lanes: 2021 Annual Report. Prepared for ADEC. January 2022.
EPA. 1991. Technical Support Document for Water Quality-based Toxics Control. US
Environmental Protection Agency, Office of Water, EPA/505/2-90-001.
https://www3.epa.gov/npdes/pubs/owm0264.pdf
USEPA. 1994. Amended Section 301(h) Technical Support Document. EPA-842-B-94-
007.
Water Pollution Control Federation. Subcommittee on Chlorination of Wastewater.
Chlorination of Wastewater. Water Pollution Control Federation. Washington, D.C.
1976.
EPA, 2007. EPA Model Pretreatment Ordinance, Office of Wastewater
Management/Permits Division, January 2007.
EPA. 2010. NPDES Permit Writers' Manual. Environmental Protection Agency, Office of
Wastewater Management, EPA-833-K-10-001. September 2010.
https://www3.epa.gov/npdes/pubs/pwm 2010.pdf
EPA. 2011. EPA Policy on Consultation and Coordination with Indian Tribes.
https://www.epa.gov/sites/default/files/2013-08/documents/cons-and-coord-with-
indian-tribes-policy.pdf
EPA, 2011. Introduction to the National Pretreatment Program, Office of Wastewater
Management, EPA 833-B-11-011, June 2011.
EPA, 2014. Water Quality Standards Handbook Chapter 5: General Policies.
Environmental Protection Agency. Office of Water. EPA 820-B-14-004. September
2014. https://www.epa.gov/sites/production/files/2014-09/documents/handbook-
chapter5.pdf
Great Lakes Environmental Center, Inc, 2021. Mixing Zone Dilution Modeling for Six
Alaska POTWs. Prepared for EPA Region 10. August 2021.
Fact Sheet: AK0021385 - Haines WWTP
Page 56 of 68
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Appendix A. Water Quality Data
Appendix A.l. Treatment Plant Effluent Data
Parameter
Flow
BOD, 5 day, 20
deg C (mg/L)
BOD, 5 day, 20
deg C (mg/L)
BOD, 5 day, 20 deg
C (lbs/day)
BOD %
removal
TSS
(mg/L)
TSS (mg/L)
TSS (lbs/day)
TSS %
removal
Statistical Base
MX DAY
MO AVE
Influent
MO
AVE
MX
DAY
MO AVE
MX DAY
MO AVE
Influent
MO AVE
MX DAY
MO AVE
MX DAY
MO AVE
Sep-16
0.720
0.386
133
72
72
231
432
46
81
49
81
157
260
48
Oct-16
0.450
0.229
158
44
44
84
165
72
56
33
56
63
210
75
Nov-16
0.762
0.326
82
48
48
130
305
42
77
41
77
111
489
50
Dec-16
0.618
0.326
60
40
40
109
109
32
32
25
32
68
87
48
Jan-17
1.200
0.456
88
45
45
170
450
45
32
24
32
83
320
66
Feb-17
1.101
0.300
78
52
52
130
477
33
35
31
35
77
321
55
Mar-17
0.408
0.218
140
60
60
109
204
60
35
22
35
40
119
80
Apr-17
0.450
0.255
74
39
39
83
146
48
93
48
93
102
198
53
May-17
0.501
0.219
124
74
74
135
309
41
58
23
58
42
242
63
Jun-17
0.405
0.202
246
132
132
225
445
46
106
83
106
153
566
61
Jul-17
0.447
0.200
280
150
150
250
559
46
124
87
124
145
462
70
Auq-17
0.318
0.199
368
188
188
312
528
49
148
92
148
153
392
61
Sep-17
0.669
0.302
164
67
67
169
374
60
59
48
59
121
329
90
Oct-17
0.450
0.262
226
78
78
170
189
66
118
32
118
70
443
61
Nov-17
0.453
0.192
246
65
65
104
246
73
59
46
59
74
223
77
Dec-17
0.825
0.391
100
64
64
209
440
35
33
24
33
78
227
80
Jan-18
0.486
0.288
140
75
75
180
304
47
46
31
46
74
186
77
Feb-18
0.369
0.184
329
109
109
167
335
67
60
46
60
70
185
84
Mar-18
0.552
0.266
68
47
47
104
216
30
55
43
55
97
187
67
Apr-18
0.424
0.263
113
7.3
7.3
16
23
93
54
31
54
68
167
79
May-18
0.437
0.257
105
80
87
171
313
25
135
82
135
176
260
31
Jun-18
0.258
0.202
181
117
117
197
251
36
79
64
79
108
170
66
Jul-18
0.238
0.182
200
106
106
161
209
47
203
116
203
176
403
64
Auq-18
0.287
0.187
233
111
111
172
266
52
81
70.5
81
172
194
76
Sep-18
0.213
0.167
244
154
154
214
274
37
82
50
82
70
146
85
Oct-18
0.770
0.313
174
95
95
248
610
45
92
55
92
144
591
55
Nov-18
0.670
0.253
111
58
58
122
292
58
55
40
55
84
277
62
Dec-18
0.762
0.342
98
15
15
43
95
84
128
58
128
165
813
34
Jan-19
0.698
0.307
76
51
51
131
297
33
87
35
87
90
506
53
Feb-19
0.435
0.195
124
33.4
33.4
55
121
72
76
45
76
74
276
60
Mar-19
0.952
0.319
52
21.5
21.5
57.2
166
58
52
34.25
52
86
423
79
Apr-19
0.449
0.269
191
128
128
287
479
33
41
37
41
83
153
59
May-19
0.360
0.204
197
74
74
126
222
62
82
58
82
99
174
61
Jun-19
0.266
0.192
305
173
173
277
383
43
106
69
106
110
318
66
Jul-19
0.250
0.184
337
222
222
340
462
34
126
102
126
157
263
71
Auq-19
0.237
0.171
262
192.5
192.5
275
294
27
208
121
208
173
328
39
Sep-19
0.322
0.192
434
245
245
345
345
44
244
119
244
175
350
44
Oct-19
0.610
0.272
145
96.5
96.5
213
213
33
122
69.5
122
148
255
43
Nov-19
0.771
0.376
80
41
45
125
137
40
108
42
108
180
287
42
Dec-19
0.986
0.414
73
36
36
74
74
50
36
23
36
91
92
63
J an-20
0.789
0.328
67
42
42
118
118
37
76
64
76
160
232
65
Feb-20
0.724
0.401
61
29
29
96
96
53
52
38
52
125
185
73
Mar-20
0.680
0.359
69
47
47
218
218
31
54
44
54
142
159
73
Apr-20
0.507
0.357
125
49
49
120
120
49
59
48
59
129
162
75
May-20
0.390
0.222
232.9
80.1
80.1
148
148
66
172
74.5
172
123
261
81
Jun-20
0.231
0.170
205.7
98.4
98.4
136
136
52
128
65
128
91
178
63
Jul-20
0.275
0.178
404
97
97
123
123
76
104
68
104
96
132
80
Aug-20
0.283
0.211
354
130
130
162
162
63
64
45
64
67
80
76
Sep-20
0.405
0.174
189
89
89
116
116
53
140
115
140
157
207
57
Oct-20
0.413
0.231
213
113
113
175
175
47
108
67
108
110
185
68
Nov-20
0.547
0.234
173
67
67
108
108
61
66
33
66
72
109
70
Dec-20
1.650
0.658
62
42
42
157
157
32
59
34
59
124
165
62
J an-21
1.070
0.458
100
46
46
171
171
54
35
33
35
131
214
77
Feb-21
0.300
0.236
116
80
80
159
159
31
52
40
52
83
102
66
Mar-21
0.486
0.265
165
110
110
258
258
33
105
52
105
52
173
56
Apr-21
0.486
0.265
165
110
110
257
257
33
105
52
105
122
173
56
Mav-21
0.449
0.233
274
84
84
138
138
84
67
33
67
61
123
78
Jun-21
0.253
0.220
193
103
103
155
155
47
49
24
49
40
74
73
Jul-21
0.222
0.163
245
165
165
263
263
32
126
102
126
140
162
71
Auq-21
0.286
0.174
149
44
44
58
58
70
156
58
156
96
200
78
Sep-21
0.578
0.250
114
70
70
96
96
41
63
47
63
117
117
59
Average
0.533
0.265
174.9
86.9
87.0
163.9
242.9
48.8
88.3
54.3
88.3
108.9
251.1
64.9
Minimum
0.213
0.163
52.0
7.3
7.3
16.0
23.0
25.0
32.0
22.0
32.0
40.0
74.0
31.0
Maximum
1.650
0.658
434.0
245.0
245.0
345.0
610.0
93.0
244.0
121.0
244.0
180.0
813.0
90.0
Count
59
59
58
58
58
58
58
58
59
59
59
59
59
59
Std Dev
0.281
0.092
94.7
51.1
51.0
74.0
137.0
15.8
46.6
26.2
46.6
39.3
143.3
13.0
CV
0.527
0.346
0.54
0.59
0.59
0.45
0.56
0.32
0.53
0.48
0.53
0.36
0.57
0.2
95th Percentile
1.073
0.418
356.1
188.7
188.7
290.8
486.4
77.2
175.1
115.1
175.1
175.1
512.0
81.3
5th Percentile
0.236
0.171
61.9
27.9
27.9
56.9
91.9
30.9
34.8
23.9
34.8
51.0
91.5
41.7
90th percentile
0.850
0.379
312.2
157.3
157.3
266.6
453.6
70.6
141.6
94.0
141.6
166.4
446.8
80.0
50th percentile
0.450
0.250
164.5
76.5
76.5
158.0
214.5
47.0
77.0
47.0
77.0
102.0
200.0
66.0
Fact Sheet: AK0021385 - Haines WWTP
Page 57 of 68
-------
Parameter
pH (s.u.)
Fecal Coliform (#100/mL)
Copper (ug/L)
Dissolved Oxygen
(mg/L)
Temperature
(deg C)
Statistical Base
max
min
DAILY MAX
MO GEO
DAILY MAX
MO AVG
MAX
MIN
MO AVG
Sep-16
7.58
6.99
470,000
470,000
3
3
4.04
2.55
13.6
Oct-16
7.72
6.98
6.78
5.23
11.8
Nov-16
7.9
7.1
270,000
243,721
9.9
6.7
9.45
Dec-16
7.8
7.4
4
4
10.7
6.7
7.6
Jan-17
7.96
7.34
270,000
270,000
11.33
8.08
5.85
Feb-17
7.36
6.88
11.47
9.47
5.95
Mar-17
7.9
7
660,000
544,977
2
2
9.3
8.9
5.6
Apr-17
7.9
7.14
9.4
8
6.7
May-17
7.37
7.31
340,000
314,006
8.61
3.77
10.5
Jun-17
7.4
7.2
1,030,000
836,899
3
3
9.1
2.7
11.6
Jul-17
7.38
7.28
1,150,000
976,985
2.93
2.32
12.6
Aug-17
7.39
7.19
600,000
579,655
3.72
2.95
14
Sep-17
7.2
7.1
270,000
270,000
4
4
4.31
2.08
13.9
Oct-17
7.1
7
5.62
2.13
12.4
Nov-17
7.14
7.06
180,000
179,722
5.28
2.31
10.4
Dec-17
7.13
7.02
4
4
9.72
8.05
8.3
Jan-18
7.2
7.3
790,000
540,648
9.3
7.7
7.3
Feb-18
7.32
7.19
9.66
6.94
7.9
Mar-18
7.28
7.04
300,000
256,905
3
3
9.45
7.11
7.5
Apr-18
7.24
7.14
9.32
7.2
7.1
May-18
7.1
7
210,000
177,482
6.6
5.3
8.2
Jun-18
7.22
7.13
530,000
519,903
2
2
3.9
3.51
12.1
Jul-18
7.32
6.89
920,000
830,662
2.2
2.1
14.8
Aug-18
7.45
7.08
1,100,000
932,201
4.62
2.07
14.8
Sep-18
7.33
7.19
210,000
210,000
4
4
3.9
2.9
14
Oct-18
7.52
7.17
9.6
3.68
13.5
Nov-18
7.5
6.7
960,000
924,337
16.5
9.8
11
Dec-18
7.19
7.07
3
3
13.2
8.4
9
Jan-19
7.2
7.1
345,000
321,714
9.17
7.47
8.5
Feb-19
7.32
7.1
14.6
7.8
7.9
Mar-19
7.1
6.8
360,000
344,674
0
0
11.4
7.3
8.15
Apr-19
7.5
6.9
9.6
9.3
8.1
May-19
7.2
6.83
590,000
590,000
6.58
3.98
11.125
Jun-19
7.22
6.74
790,000
519,904
23
23
4.33
4.16
9.175
Jul-19
7.19
6.94
980,000
980,000
4.4
2.45
15.35
Aug-19
7.25
6.78
850,000
819,451
4.62
2.83
15.6
Sep-19
6.97
6.91
610,000
610,000
0
0
6.91
2.12
15.8
Oct-19
7.17
6.85
8.24
4.27
12.92
Nov-19
7.15
6.83
520,000
420,476
10.25
8.33
11.3
Dec-19
7.12
6.56
0
0
12.13
7.64
8.85
Jan-20
7.44
7.02
10,000
14,142
10.02
8.72
8.13
Feb-20
7.37
6.51
10.39
9.43
8.34
Mar-20
7.31
7.11
750,000
739,932
0
0
11.4
9.05
8.95
Apr-20
7.31
7.08
10.9
8.88
7.3
May-20
7.21
7.09
42,000
388,844
9.55
6.52
11.13
Jun-20
7.23
7.02
980,000
980,000
0
0
4.02
3.62
14
Jul-20
7.17
7.02
710,000
604,618
4.1
2.15
14.55
Aug-20
7.22
7.08
760,000
616,441
5.02
2.53
14.4
Sep-20
7.16
7.09
670,000
542,955
8.71
2.96
13.7
Oct-20
7.22
7.11
7.7
3.6
12.15
Nov-20
7.45
7.14
170,000
92,195
8.66
7.23
10.8
Dec-20
7.16
6.98
0
0
13.33
11.18
7
Jan-21
7.15
6.74
360,000
317,490
11.92
10.43
8.1
Feb-21
7.04
6.86
10.64
10.39
9.2
Mar-21
7.14
6.86
500,000
374,166
0
0
11.2
8.51
7.05
Apr-21
7.14
6.86
11.2
8.51
7.05
May-21
7.23
6.98
510,000
468,295
8.68
5.33
7.09
Jun-21
7.39
7.05
810,000
661,362
30
30
7.33
4.31
13
Jul-21
7.34
7.05
1,140,000
900,000
4.4
3.03
14.5
Aug-21
7.28
7
1,430,000
770,324
6.69
2.42
14.52
Sep-21
6.99
6.89
200,000
200,000
0
0
9.25
3.48
13
Average
7.30
7.01
597,000
522,000
4.3
4.3
8.42
5.78
10.49
Minimum
6.97
6.51
10,000
14,142
0
0
2.20
2.07
5.60
Maximum
7.96
7.40
1,430,000
980,000
30.0
30.0
16.50
11.18
15.80
Count
59.00
59.00
40
40
19.0
19.0
59.00
59.00
59.00
Std Dev
0.22
0.18
346,000
273,000
8.1
8.1
3.15
2.82
3.01
C V
0.03
0.03
0.58
0.52
1.87
1.87
0.37
0.49
0.29
95th Percentile
7.90
7.30
1,141,000
977,000
23.7
23.7
13.21
9.86
14.86
5th Percentile
7.09
6.74
164,000
173,000
0
0
3.88
2.12
6.63
90th percentile
7.50
7.19
1,037,000
925,000
7.8
7.8
11.56
9.33
14.53
50th percentile
7.23
7.04
595,000
530,000
2.0
2.0
9.25
6.52
10.40
Fact Sheet: AK0021385 - Haines WWTP
Page 58 of 68
-------
Appendix A.2. Receiving Water Data
Table 15. Receiving Water Data Collected by Permittee, 2003-2005
Site
Time
Depth (m)
Temp (C)
Salinity
(PPt)
DO
(mg/L)
PH
(s.u.)
Turbidity
(NTU)
Secchi
Disc (ft)
8/13/2003
Site 1
9:10am
0
12.50
17
10.4
8.37
5.49
7
9:10am
5
12.30
19
10.2
8.42
6.38
9:10am
10
11.60
23
10.2
8.41
2.45
9:10am
15
10.70
26
9.5
8.35
2.32
9:10am
20
11.20
22
9.4
8.4
2.4
9:10am
25/bottom
10.50
29
9.4
8.28
2.9
Site 2
9:55am
0
12.00
18
9.9
8.5
7.74
7
9:55am
5
12.50
19
9.5
8.4
4.36
9:55am
10
11.90
21
9.54
8.45
2.64
9:55am
15
10.80
26
9.32
8.35
1.88
9:55am
20
9.60
29
9.23
8.28
1.24
9:55am
25/bottom
9.50
30
9.08
8.26
2.03
Site 3
10:35am
0
12.10
17
9.54
8.51
8.26
7
10:35am
5
12.20
19
9.36
8.47
8.26
10:35am
10
12.00
20
8.89
8.45
3.59
10:35am
15
10.70
25
9.44
8.37
2.31
10:35am
20/bottom
10.20
26
9.02
8.34
1.43
Site 4
10:55am
0
12.40
17
9.6
8.5
6.37
7
10:55am
5
12.50
19
9.36
8.47
2.43
10:55am
10
12.30
20
9.17
8.46
2.3
10:55am
15
10.70
25
9.26
8.37
1.83
10:55am
20
9.00
30
8.96
8.27
1.71
10:55am
25/bottom
8.80
30
8.7
8.26
2.05
2/25/2004
Site 1
10:00am
0
4.10
31
8.42
7.57
1.13
27
10:00am
5
4.00
31.4
10.19
7.8
1.11
10:00am
10
3.50
31
10.45
7.7
1.21
10:00am
15
4.00
32
9.6
7.7
1.21
10:00am
20
4.50
32
10.29
7.6
1.19
10:00am
25/bottom
3.70
32
10.36
7.58
1.29
Site 2
10:20am
0
4.10
32.1
9.4
7.48
1.09
26
10:20am
5
4.30
32
9.76
7.51
1.11
10:20am
10
4.10
32
9.94
7.55
1.45
10:20am
15
4.20
32
9.57
7.6
1.4
10:20am
20
4.40
32
9.73
7.64
1.06
10:20am
25/bottom
3.70
32
10.31
7.67
1.22
Fact Sheet: AK0021385 - Haines WWTP
Page 59 of 68
-------
Site 3
11:00am
0
3.60
31
10.1
7.7
1.09
30
11:00am
5
4.10
32
9.62
7.7
0.98
11:00am
10
4.00
32
9.44
7.7
0.98
11:00am
15
4.40
32
8.91
7.79
1.09
11:00am
20
4.10
32
10.17
7.8
0.83
11:00am
25/bottom
4.10
32
9.89
7.8
2.74
Site 4
11:25am
0
4.10
32
10.46
7.8
1.15
32
11:25am
5
3.60
32
10.15
7.88
0.93
11:25am
10
4.50
32
10.03
7.8
1.05
11:25am
15
4.10
32
10.45
7.9
0.75
11:25am
20/bottom
3.90
32
9.32
7.9
2.59
9/1/2005
Site 1
12:30pm
0
12.70
8
6.45
7.26
8.77
4
12:30pm
5
12.30
8
6.14
8.27
5.81
12:30pm
10
11.50
18
7.23
8.39
7.71
12:30pm
15
10.60
17
5.78
8.13
2.76
12:30pm
20
9.40
27
5.8
8.14
2.15
12:30pm
25
8.40
29
5.57
8.13
1.58
12:30pm
30/bottom
7.90
32
5.23
8.13
2.16
Site 2
1:30pm
0
10.20
4
7.05
8.58
6.98
5
1:30pm
5
8.06
5
9.5
8.06
2.91
1:30pm
10
4.15
18
10.3
8.12
4.15
1:30pm
15
8.50
18
10.5
8.13
2.59
1:30pm
20/bottom
8.10
29
9.5
8.15
3.03
Site 3
2:00pm
0
10.90
4
7.05
8.58
5.92
5
2:00pm
5
10.50
7
11.4
8.4
3.03
2:00pm
10
9.60
25
9.4
8.26
3.39
2:00pm
15
8.30
28
10.4
8.18
2.83
2:00pm
20/bottom
8.10
29
10.44
8.21
3.03
Site 4
3:00pm
0
11.30
3
6.2
8.56
5.92
5
3:00pm
5
10.40
5
10.5
8.43
3.57
3:00pm
10
9.40
10
9.3
8.26
2.54
3:00pm
15
8.60
27
9
8.21
2.54
3:00pm
20
8.10
29
8.92
8.23
2.88
3:00pm
25/bottom
8.10
29
7.56
8.2
5.07
Fact Sheet: AK0021385 - Haines WWTP
Page 60 of 68
-------
Table 16. Port of Haines Sampling Results from 2021ARRI Report
Site
Ammonia-N
Cu
Ni
Zn
(mg/L)
(Hg/L)
(Hg/L)
(Hg/L)
HA01
0.007
0.32
0.34
0.10
HA02
0.007
0.36
0.32
0.10
HA03
0.007
0.33
0.34
0.10
HA04
0.021
0.48
0.35
0.38
HA06
0.009
0.35
0.32
0.10
Average
0.010
0.38
0.33
0.16
Fact Sheet: AK0021385 - Haines WWTP
Page 61 of 68
-------
Appendix B. Reasonable Potential and WQBEL Formulae
EPA uses the process described in the Technical Support Document for Water Quality-
based Toxics Control (EPA 1991) to determine reasonable potential. To determine if
there is reasonable potential for the discharge to cause or contribute to an
exceedance of water quality criteria for a given pollutant, EPA compares the maximum
projected receiving water concentration to the water quality criteria for that pollutant.
If the projected receiving water concentration exceeds the criteria, there is reasonable
potential, and a WQBEL must be included in the permit.
1. Mass Balance
For discharges to flowing water bodies, the maximum projected receiving water
concentration is determined using the following mass balance equation:
CdQd = CeQe + CuQu Equation 1
Receiving water concentration downstream of the effluent
discharge (that is, the concentration at the edge of the mixing
zone)
Maximum projected effluent concentration
95th percentile measured receiving water upstream
concentration
Receiving water flow rate downstream of the effluent discharge
= CU+Qu
Effluent flow rate (set equal to the design flow of the WWTP)
Receiving water low flow rate upstream of the discharge (1Q10,
7Q10 or 30B3)
where,
Cd
Ce
Cu
Qd
a
Qu
When the mass balance equation is solved for Cd, it becomes:
_ CeXQe + CUX Qu Equation 2
Qe + Qu
The above form of the equation is based on the assumption that the discharge is
rapidly and completely mixed with 100% of the receiving stream.
If the mixing zone is based on less than complete mixing with the receiving water,
the equation becomes:
Ce X Qe + Cu X (Qu X %MZ) .
Cd = ; t Equation 3
Qe + (Qu x %MZ)
Where:
% MZ = the percentage of the receiving water flow available for mixing.
Fact Sheet: AK0021385 - Haines WWTP
Page 62 of 68
-------
If a mixing zone is not allowed, dilution is not considered when projecting the
receiving water concentration and,
Cd = Ce Equation 4
A dilution factor (D) can be introduced to describe the allowable mixing. Where
the dilution factor is expressed as:
n Qe + Qu X %MZ
D ~ q Equation 5
After the dilution factor simplification, the mass balance equation becomes:
C -C
6 U
Cd=—~—+CU Equation 6
If the criterion is expressed as dissolved metal, the effluent concentrations are
measured in total recoverable metal and must be converted to dissolved metal as
follows:
CFxCe-Cu
Cd= +CU Equation 7
Where Ce is expressed as total recoverable metal, Cu and Cd are expressed as
dissolved metal, and CF is a conversion factor used to convert between dissolved
and total recoverable metal.
The above equations for Cd are the forms of the mass balance equation which
were used to determine reasonable potential and calculate wasteload allocations.
2. Maximum Projected Effluent Concentration
When determining the projected receiving water concentration downstream of
the effluent discharge, EPA's Technical Support Document for Water Quality-
based Toxics Controls (TSD, 1991) recommends using the maximum projected
effluent concentration (Ce) in the mass balance calculation (see equation 3, page
C-5). To determine the maximum projected effluent concentration (Ce) EPA has
developed a statistical approach to better characterize the effects of effluent
variability. The approach combines knowledge of effluent variability as estimated
by a coefficient of variation (CV) with the uncertainty due to a limited number of
data to project an estimated maximum concentration for the effluent. Once the
CV for each pollutant parameter has been calculated, the reasonable potential
multiplier (RPM) used to derive the maximum projected effluent concentration
(Ce) can be calculated using the following equations:
Fact Sheet: AK0021385 - Haines WWTP
Page 63 of 68
-------
First, the percentile represented by the highest reported concentration is
calculated.
pn = (1 - confidence level)1/n Equation 8
where,
pn = the percentile represented by the highest reported concentration
n = the number of samples
confidence level = 99% = 0.99
and
r „Zqqxa-0.5xa2
l~qq K _ .
RPM= — = Equation 9
Cp „ZP xa-O.Bxa2
-Pn 6 n
Where
a2 = ln(CV2 +1)
Z99 = 2.326 (z-score for the 99th percentile)
z-score for the Pn percentile (inverse of the normal cumul
distribution function at a given percentile)
Zpn —
CV = coefficient of variation (standard deviation -f mean
The maximum projected effluent concentration is determined by simply
multiplying the maximum reported effluent concentration by the RPM:
Ce = (RPM)(MRC) Equation 10
where MRC= Maximum Reported Concentration
3. Maximum Projected Effluent Concentration at the Edge of the Mixing Zone
Once the maximum projected effluent concentration is calculated, the maximum
projected effluent concentration at the edge of the acute and chronic mixing
zones is calculated using the mass balance equations presented previously.
4. Reasonable Potential
The discharge has reasonable potential to cause or contribute to an exceedance
of water quality criteria if the maximum projected concentration of the pollutant
at the edge of the mixing zone exceeds the most stringent criterion for that
pollutant.
Fact Sheet: AK0021385 - Haines WWTP
Page 64 of 68
-------
B. WQBEL Calculations
1. Calculate the Wasteload Allocations (WLAs)
Wasteload allocations (WLAs) are calculated using the same mass balance
equations used to calculate the concentration of the pollutant at the edge of the
mixing zone in the reasonable potential analysis. To calculate the wasteload
allocations, Cd is set equal to the acute or chronic criterion and the equation is
solved for Ce. The calculated Ce is the acute or chronic WLA. Equation 6 is
rearranged to solve for the WLA, becoming:
Ce = WLA = D X (Cd — Cu) + Cu Equation 11
Alaska's water quality criteria for some metals are expressed as the dissolved
fraction, but the Federal regulation at 40 CFR 122.45(c) requires that effluent
limits be expressed as total recoverable metal. Therefore, EPA must calculate a
wasteload allocation in total recoverable metal that will be protective of the
dissolved criterion. This is accomplished by dividing the WLA expressed as
dissolved by the criteria translator, as shown in equation . The criteria
translator (CT) is equal to the conversion factor, because site-specific translators
are not available for this discharge.
Dx(Cd-C11)+C11 .
C =WLA=——————- Equation 12
8 CT
The next step is to compute the "long term average" concentrations which will be
protective of the WLAs. This is done using the following equations from EPA's
Technical Support Document for Water Quality-based Toxics Control (TSD):
LTAa=WLAaxe(a5c72- z Equation 13
LTAc=WLAcxe^0,5c7^"zc74) Equation 14
where,
o2 = ln(CV2 +1)
Z99 = 2.326 (z-score for the 99th percentile probability basis)
CV = coefficient of variation (standard deviation 4- mean)
o42 = ln(CV2/4 +1)
For ammonia, because the chronic criterion is based on a 30-day averaging
period, the Chronic Long-Term Average (LTAc) is calculated as follows:
LTAc=WLAcxe(0,5c75o"zc73o) Equation 15
where,
o302 = ln(CV2/30 +1)
The LTAs are compared and the more stringent is used to develop the daily
maximum and monthly average permit limits as shown below.
Fact Sheet: AK0021385 - Haines WWTP
Page 65 of 68
-------
2. Derive the maximum daily and average monthly effluent limits
Using the TSD equations, the MDL and AML effluent limits are calculated as
follows:
where a, and o2 are defined as they are for the LTA equations above, and,
on2 = ln(CV2/n +1
za = 1.645 (z-score for the 95th percentile probability basis)
zm = 2.326 (z-score for the 99th percentile probability basis)
number of sampling events required per month. With the
exception of ammonia, if the AML is based on the LTAC, i.e.,
LTAminimum = LTAC), the value of "n" should is set at a
minimum of 4. Forammonia, In the case of ammonia, if the
AML is based on the LTAC, i.e., LTAminimum = LTAC), the value
of "n" should is set at a minimum of 30.
MDL = LTAX e(z-a"a5a2)
AML = LTA X e^a"-a5a")
Equation 16
Equation 17
Fact Sheet: AK0021385 - Haines WWTP
Page 66 of 68
-------
Appendix C. Reasonable Potential and WQBEL Calculations
Table 17. Reasonable Potential Analysis for Toxic Pollutants in the Effluent
Pollutants of Concern
COPPER -
SEE Toxic
BiOp
LEAD - SEE
Toxic BiOp
NICKEL -
SEE Toxic
BiOp
SILVER
ZINC - SEE
Toxic BiOp
ANTIMONY
(INORGANIC
)
ARSENIC -
SEE Toxic
BiOp
BENZIDINE
BIS(2-
ETHYLHEXYL)
PHTHALATE
CHLOROFO
RM
CHROMIUM)
HEX)
DI-n-BUTYL
PHTHALATE
1,4
DICHLOROB
ENZENE
NAPHTHALE
NE
PHENOL
SELENIUM,
Lotic
TOLUENE
Number of Samples in Data Set (n)
19
2
2
2
2
2
2
3
2
2
2
2
2
2
2
2
2
Effluent Data
Coefficient of Variation (CV) = Std. Dev./Mean (default CV= 0.6)
1.87
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
Effluent Concentration, ug/L (Max. or 95th Percentile
-(Ce)
23.7
0.646
2.23
0.827
28.4
0.22
0.545
0
1.5
2
0.711
3.1
0.91
2.7
5.9
2.62
0.79
Calculated 5tfh % Effluent Cone, (when n>10). Human Health Onlv
Receiving Water Data
9tfh Percentile Cone., ug/L - (CJ
0
Geometric Mean, |ig/L, Human Health Criteria Only
0
Aquatic Life Criteria, ug/L
''Acute
4.8
210.
74.
1.9
90.
69.
1,100.
290.
Aquatic Life Criteria, ug/L
Chronic
3.1
8.1
8.2
81.
36.
50.
71.
Acute:chronic ratio
1.55
25.93
9.02
1.11
1.92
22.00
4.08
Applicable
Water Quality Criteria
Human Health Water and Organism, ug/L
Human Health, Organism Only, ug/L
N/A
Narrative
4,600.
N/A
69,000.
4,300.
N14
.00054
5.9
470.
WA
12,000.
2,600.
WA
4,600,000.
11,000.
200,000.
Metals Criteria Translator, decimal (or default use
''Acute
.83
.951
.99
.85
.946
1.
.993
.998
Conversion Factor)
Chronic
.83
.951
.99
na
.946
1.
.993
.998
Carcinogen (Y/N), Human Health Criteria Only
N
N
N
N
N
N
Y
Y
Y
N
N
N
N
N
N
N
Percent River Flow
Default Value =
0%
Aquatic Life - Acute
Aquatic Life - Chronic
Human Health - Non-Carcinogen
Human Health - Carcinogen
1Q10
7Q10 or 4B3
30B3 or 30Q10/30Q5
Harmonic Mean
Harmonic Mean
0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
Calculated
Dilution Factors (DF)
(or enter Modeled DFs)
Aquatic Life - Acute
Aquatic Life - Chronic
Aquatic Life - Chronic Ammonia
Human Health - Non-Carcinogen
Human Health - Carcinogen
1Q10
7Q10 or 4B3
30B3 or 30Q10/30Q5
Harmonic Mean
Harmonic Mean
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
11.0
19.0
19.0
19.0
19.0
Aquatic Life Reasonable Potential Analysis
CT
o^lnfCVM)
1.226
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
Pn
=(1 -c onfiden ce level)1'", wh ere c onfi dene e level =
99%
0.785
0.100
0.100
0.100
0.100
0.100
0.100
0.215
0.100
0.100
0.100
0.100
0.100
0.100
0.100
0.100
0.100
Multiplier (TSD p. 57)
=exp(zo-0. 5cr2)/expjnormsi nv( PJo-0. 5c2], wh ere
95%
2.9 5.1 5.1 5.1 5.1 5.1 5.1 3.9 5.1 5.1 5.1 5.1 5.1 5.1 5.1 5.1 5.1
Statistically projected crifi
ge concentratio
67.74
0.00
7.60
4.00
Predicted max. conc.(ugZL) at Edge
of-Mi xing Zone
Acute
5.11 0.28 1.02 0.32 12.38 0.10 0.25 0.00 0.69 0.92 0.33 1.43 0.42 1.24 2.72 1.20 0.36
issolved using conversion factor as translator)
Chronic
2.96
0.00
0.40
0.21
Reasonable Potential to exceed
\quatic Life Criteria
YES
NO
NO
NO
NO
NA
NO
NA
NA
NA
NO
NA
NA
NA
NA
NO
NA
Aquatic Life Effluent Limit Calculations
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
n used to calculate AML (if chronic
limiting then use min=4 or for ammonia min=30)
4
LTA Coeff. Var. (CV), decimal
(Use CV of data set or default = 0.6)
1.870
Permit Limit Coeff. Var. (CV), decimal (Use CV from data set or default = 0.6)
1.870
Acute WLA, ug/L
Cd= (Acute Criteria x MZa) - Cux (MZa-1)
Acute
52.8
Chronic WLA, ug/L
Cd= (Chronic Criteria x MZC) - Cux(MZc-1)
Chronic
58.9
Long Term Ave (LTA), ug/L
WLAa x exp(0.5a2-zu), Acute
99%
6.5
(99th % occurrence prob.)
WLAc x exptO.Sc^-zo); ammonia n=30, Chronic
"*99%
12.8
Limiting LTA, ug/L
used as basis for limits calculation
6.5
Applicable Metals Criteria Translator (metals limits as total recoverable)
0.83
Average Monthly Limit (AML), ug/L , where % occurrence prob =
Maximum Daily Limit (MDL), uq/L , where % occurrence prob =
95%
99%
21
64
Average Monthly Limit (AML), mg/L
Maximum Daily Limit (MDL), mg/L
0.021
0.064
Average Monthly Limit (AML), lb/day
Maximum Daily Limit (MDL), lb/day
0.332
1.008
Human Health Reasonable Potential Analysis
CT
1.226
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
0.555
Pn
=( 1 -c onf iden ce level)1'" where c onfi den ce level =
95%
0.854
0.224
0.224
0.224
0.224
0.224
0.224
0.368
0.224
0.224
0.224
0.224
0.224
0.224
0.224
0.224
0.224
Multiplier
=exp(2.326CT-0.5CT2)/exp[invnorm(PM,CT-0.5o2l, prob. =
50%
0.275
1.524
1.524
1.524
1.524
1.524
1.524
1.205
1.524
1.524
1.524
1.524
1.524
1.524
1.524
1.524
1.524
Dilution Factor (for Human Health Criteria)
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
19.0
Max Cone, at edge of Chronic Zone
ug'L (Cd)
0.342
0.052
0.179
0.066
2.278
0.018
0.044
0.120
0.160
0.057
0.249
0.073
0.217
0.473
0.210
0.063
Reasonable Potential to exceed
Reasonable Potential to exceed
HH Water & Organism
IH Organism Only
NO
NO
NO
NO
NO
NO
o o
z z
o o
z z
o o
z z
o o
z z
o o
z z
o o
z z
NO
o o
z z
O O
z z
NO
o o
z z
O O
z z
o o
z z
Fact Sheet: AK0021385 - Haines WWTP Page 67 of 68
-------
Appendix C.l. WET Reasonable Potential Analysis
The 2001 permit required the facility to conduct chronic whole effluent toxicity
testing once in the summer during the permit term. The results of chronic WET testing
in 2001 using the sand dollar (Dendraster excentricus) test approach was 3.1 TUc,
respectively (see Table 1 below).
Table 18. Whole Effluent Toxicity Test Results
Test Date
Species and Test Type
NOEC (%)
IC25 (%)
TUc
TUa
(Tc/10)
10-07-2002
Sand Dollar
32
>68
3.1
0.31
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