Toxicants such as chlorine, ammonia, metals and other pollutants will also be allowed to discharge from the proposed outfall despite remedies for their removal being available but not implemented.


This is not true and it is difficult to see how this interpretation could be made. Only effluent being utilized for reuse would be chlorinated. There is no chlorination in the plans for any effluent that would potentially be sent to the Gallatin River in the future. Also, the MBR system is designed to “fully nitrify” ammonia. The result of this process will be ammonia levels less than 1.5 mg/L, which is less than the acute criterion for the Gallatin River (2.14 mg/L) even without dilution credits. Finally, based on initial screening of the District’s existing effluent, there are no metals which show the potential to cause or contribute to a water quality criteria exceedance, therefore, putting in a very chemical-intensive metals removal treatment process does not make sense.