Exhibit A EGLE Groundwater Discharge Permit.pdf

PERMIT NO. GW1010022

STATE OF MICHIGAN

DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY

GROUNDWATER DISCHARGE PERMIT

In compliance with the provisions of Part 31, Water Resources Protection, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (NREPA); Part 41, Sewerage Systems, of the NREPA; and Michigan Executive Order 2019-06, DNR-Parks & Recreation Division PO Box 30257

Lansing, MI 48909 is authorized to discharge sanitary sewage in accordance with Rule 2210(y) Authorization of the Part 22 Rules, Groundwater Quality, promulgated pursuant to Part 31 of the NREPA from DNR- Parks & Rec-Clear Lake located at

20500 M-33 North Atlanta, MI 49709 designated as DNR-Parks & Rec-Clear Lake to the groundwaters of the State of Michigan in accordance with effluent limitations, monitoring requirements, and other conditions set forth in this permit.

The issuance of this permit does not authorize violation of any federal, state, or local laws or regulations, nor does it obviate the necessity of obtaining such permits, including any other Michigan Department of Environment, Great Lakes, and Energy (Department) permits, or approvals from other units of government as may be required by law.

This permit is based on an original application submitted on June 10, 2017, as amended through July 29, 2024.

This permit takes effect on January 1, 2025. The provisions of this permit are severable. After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked in whole or in part during its term in accordance with applicable laws and rules. On its effective date, this permit shall supersede Groundwater Permit No. GW1010022 (expired on September 1, 2017).

This permit and the authorization to discharge shall expire at midnight, January 1, 2030. In order to receive authorization to discharge beyond the date of expiration, the permittee shall submit an application that contains such information, forms, and fees as are required by the Department by July 5, 2029.

Issued: December 20, 2024.

Kristine Rendon, Supervisor Groundwater Permits Unit

Permits Section Water Resources Division

PERMIT NO. GW1010022 Page 2 of 39

PERMIT FEE REQUIREMENTS

In accordance with Section 324.3122 of the NREPA, the permittee shall make payment of an annual permit fee to the Department for each December 15 the permit is in effect regardless of occurrence of discharge. The permittee shall submit the fee in response to the Department's annual notice. Payment may be made electronically via the Department’s MiEnviro Portal.

Payment shall be submitted or postmarked by March 1 for notices mailed by January 15. Payment shall be submitted or postmarked no later than 45 days after receiving the notice for notices mailed after January 15.

Permit Fee: IIa

CONTACT INFORMATION

Unless specified otherwise, all contact with the Department required by this permit shall be made to the Gaylord District Office of the Water Resources Division. The Gaylord District Office is located at 2100 West M-32, Gaylord, MI, 49735-9282, Telephone: 989-731-4920, Fax: 989-731- 6181.

CONTESTED CASE INFORMATION

Any person who is aggrieved by this permit may file a sworn petition with the Michigan Administrative Hearing System within the Michigan Department of Licensing and Regulatory Affairs, c/o the Michigan Department of Environment, Great Lakes, and Energy, setting forth the conditions of the permit which are being challenged and specifying the grounds for the challenge.

The Department of Licensing and Regulatory Affairs may reject any petition filed more than 60 days after issuance as being untimely.

AUTHORIZATION TO DISCHARGE

The permittee shall utilize septic tanks discharging to a subsurface sewage disposal system to meet the terms and conditions of this permit.

The authorization to discharge under this permit is based upon the permittee providing treatment as identified in the application submitted on June 10, 2017, as amended through July 2, 2024. If the permittee proposes to modify the treatment system, the permittee shall notify the Department.

The Department may request that the permittee submit a modification request to amend the treatment system described in the application. Upon review of the proposed changes, the Department may terminate the permit, modify the permit, or require a different permit for the proposed discharge.

PERMIT NO. GW1010022 Page 3 of 39

PART I

A. Limitations and Monitoring Requirements

1. Effluent Limitations and Monitoring, EQ-1 (Upper and Lower Toilet Buildings) During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee is authorized to discharge sanitary sewage to the groundwater of the state from EQ-1. The location of EQ-1 shall be specified in the facility’s Sampling and Analysis Plan (SAP) approved by the Department in accordance with Part I.B.1. of this permit. Such discharge shall be limited and monitored by the permittee as specified below.

Parameter Minimum Daily Limit

Maximum Daily Limit Units Monitoring

Frequency Sample Type

Flow (Daily) 13,425 GPD Daily Direct Measurement Flow (Annual) 2,470,200 GPY Annually Calculation Total Inorganic Nitrogen (TIN) (report) mg/L Monthly Calculation

Ammonia Nitrogen (report) mg/L Monthly Grab Nitrate Nitrogen (report) mg/L Monthly Grab Nitrite Nitrogen (report) mg/L Monthly Grab pH (report) (report) S.U. Monthly Grab Biochemical Oxygen Demand (BOD5) (report) mg/L Monthly Grab

Dissolved Oxygen (report) mg/L Monthly Measured Chloride (report) mg/L Monthly Grab Sodium (report) mg/L Monthly Grab Total Phosphorus (report) mg/L Monthly Grab

a. Flow Measurement Device The discharge shall be monitored by a flow measurement device.

b. Sanitary Sewage The sanitary sewage shall not be mixed with any other wastes.

c. Total Inorganic Nitrogen (TIN) The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

d. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the Department in accordance with Part I.B.1. of this permit.

e. Discharge Monitoring Reports (DMR) Monthly discharge monitoring reports (DMR) shall be submitted each calendar month whether or not there has been a discharge. The total annual flow for a year shall be submitted in the DMR for the month of December. DMRs shall be submitted via the Department’s MiEnviro portal. If the toilet buildings do not discharge during the period in question, a sample is not required for that month. For any month in which a sample is not taken, the permittee shall enter “*G” on the DMR. (For purposes of https://mienviro.michigan.gov/

PERMIT NO. GW1010022 Page 4 of 39 reporting on the Daily tab of the DMR, the permittee shall enter “*G” on the first day of the month only.)

f. Monitoring Frequency Reduction After the submittal of 24 months of data, the permittee may request, in writing, Department approval for a reduction in monitoring frequency for any parameter required in Part I.A.1. of this permit. Monitoring frequency reduction requests shall be made to the Department via a “Groundwater Various Unscheduled – Groundwater Unscheduled Permit Required Report” via the Department’s MiEnviro portal. These requests shall contain an explanation as to why the reduced monitoring is appropriate.

Upon receipt of written approval and consistent with such approval, the permittee may reduce the monitoring frequency as indicated in Part I.A.1. of this permit. The monitoring frequency shall not be reduced to less than annually. The Department may revoke the approval for reduced monitoring at any time upon notification to the permittee.

2. Effluent Limitations and Monitoring, EQ-2 (Sanitation Station) During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee is authorized to discharge sanitary sewage to the groundwater of the state from EQ-2. The location of EQ-2 shall be specified in the facility’s Sampling and Analysis Plan (SAP) approved by the Department in accordance with Part I.B.1. of this permit. Such discharge shall be limited and monitored by the permittee as specified below.

Parameter Minimum Daily Limit

Maximum Daily Limit Units Monitoring

Frequency Sample Type

Flow (Daily) 1,000 GPD Weekly Calculation Flow (Annual) 184,000 GPY Annually Calculation Total Inorganic Nitrogen (TIN) (report) mg/L Annually Calculation

Ammonia Nitrogen (report) mg/L Annually Grab Nitrate Nitrogen (report) mg/L Annually Grab Nitrite Nitrogen (report) mg/L Annually Grab pH (report) (report) S.U. Annually Grab Biochemical Oxygen Demand (BOD5) (report) mg/L Annually Grab

Dissolved Oxygen (report) mg/L Annually Measured Chloride (report) mg/L Annually Grab Sodium (report) mg/L Annually Grab Total Phosphorus (report) mg/L Annually Grab Formaldehyde (report) mg/L Annually Grab

a. Weekly Average Flow Monitoring The permittee shall record the average daily flow on a weekly basis and the total flow annually in a log that shall be available for review upon request by the Department or the county, district, or city health department that has jurisdiction.

b. Annual Flow Reports The permittee shall submit to the Department a report of the average daily flows and annual total flow by January 31st of each year for each preceding year. Submittals

PERMIT NO. GW1010022 Page 5 of 39 shall be made via the Department’s MiEnviro Portal system. The MiEnviro Portal website is located at https://mienviro.michigan.gov/ncore.

c. Flow Measurement Device The discharge shall be monitored by a flow measurement device or alternative method approved by the Department.

d. Sanitary Sewage The sanitary sewage shall not be mixed with any other wastes.

e. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the

Department in accordance with Part I.B.1. of this permit.

f. Total Inorganic Nitrogen (TIN) The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

g. Annual Monitoring Annual samples shall be taken during the month of August.

3. Effluent Limitations and Monitoring, EQ-3, EQ-4 and EQ-5 (Day Use Pavilion, Office, and Camp Office) During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee is authorized to discharge sanitary sewage to the groundwater of the state from EQ-3, EQ-4, and EQ-5.

4. Groundwater Monitoring and Limits for Field Parameters, MW-1S, MW-1D, and MW-5 During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee shall monitor the groundwater from the hydraulically upgradient and side-gradient groundwater monitoring wells MW-1S, MW-1D, and MW-5, to evaluate groundwater quality, as specified below. The location and depth of all monitoring wells shall be consistent with the facility’s SAP approved by the Department in accordance with Part I.B.1. of this permit.

Parameter Minimum Daily Limit

Maximum Daily Limit

Daily Concentration Units Monitoring

Frequency Sample

Type Dissolved Oxygen (report) mg/L Quarterly Reading pH (report) (report) S.U. Quarterly Grab Turbidity (report) NTU Annually Reading

Specific Conductance (report) umhos/cm Quarterly Reading Static Water Elevation (report) USGS-Ft Quarterly Reading

a. Monitoring Well Sampling Preparation The permittee shall complete the following steps prior to obtaining a groundwater sample from a monitoring well:

i. Measure the water level and the total depth of the well to determine the volume of water in the well.

https://mienviro.michigan.gov/ncore

PERMIT NO. GW1010022 Page 6 of 39

ii. Purge stagnant water from the well casing prior to obtaining a groundwater sample.

If no stagnant water is found in the well casing, purging in not required.

iii. Measure field parameters on-site prior to collection of laboratory samples.

b. Static Water Elevation

The permittee shall measure all Static Water Elevations from a clearly identified location on each well casing and shall be related to a known USGS datum. Water levels shall be reported to an interval of 0.01-foot.

c. Turbidity The permittee shall not complete sampling of any groundwater monitoring well until the well has achieved sufficient stability of water quality parameters and adequately low turbidity. Turbidity should be at or below 10 Nephelometric Turbidity Units (NTUs) prior to the collection of laboratory samples.

d. Quarterly and Annual Monitoring The permittee shall collect and analyze quarterly samples during the months of February, May, August, and November. The permittee shall collect and analyze annual sampling during the month of August.

e. Discharge Monitoring Report (DMR) Monthly discharge monitoring reports shall be submitted for the months of February, May, August, and November whether or not there has been a discharge.

f. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the Department in accordance with Part I.B.1. of this permit whether or not there has been a discharge.

g. Monitoring Well Modifications The permittee shall request approval if proposing to modify any part of the monitoring well network in accordance with Part II.D.13., Modification of Monitoring Well Network, of this permit.

5. Groundwater Monitoring and Limits for Laboratory Parameters, MW-1S, MW-1D, and MW-5 During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee shall monitor the groundwater from the hydraulically upgradient and side-gradient groundwater monitoring wells MW-5, MW-1S, and MW-1D to establish upgradient concentrations of parameters necessary to evaluate groundwater quality at EQ-1 and EQ-2, as specified below. The location and depth of all monitoring wells shall be consistent with the facility’s SAP approved by the Department in accordance with Part I.B.1. of this permit.

Parameter Minimum Daily Limit

Maximum Daily Limit Units Monitoring

Frequency Sample

Type Total Inorganic

Nitrogen (report) mg/L Quarterly Calculation

Ammonia Nitrogen (report) mg/L Quarterly Grab Nitrate Nitrogen (report) mg/L Quarterly Grab Nitrite Nitrogen (report) mg/L Quarterly Grab

Chloride (report) mg/L Quarterly Grab Sodium (report) mg/L Quarterly Grab

PERMIT NO. GW1010022 Page 7 of 39

Total Phosphorus (report) mg/L Quarterly Grab Calcium (report) mg/L Annually Grab

Total Arsenic (report) ug/L Annually Grab Total Iron (report) ug/L Annually Grab

Magnesium (report) mg/L Annually Grab Total Manganese (report) ug/L Annually Grab

Potassium (report) mg/L Annually Grab Bicarbonate (report) mg/L Annually Grab

Sulfate (report) mg/L Annually Grab

a. Quarterly and Annual Monitoring The permittee shall collect and analyze quarterly samples during the months of February, May, August, and November. The permittee shall collect and analyze annual sampling during the month of August.

b. Discharge Monitoring Report (DMR) Monthly discharge monitoring reports shall be submitted for the months of February, May, August, and November whether or not there has been a discharge.

c. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the Department in accordance with Part I.B.1. of this permit whether or not there has been a discharge.

d. TIN at Groundwater Monitoring Points The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

e. Monitoring Well Modifications The permittee shall request approval if proposing to modify any part of the monitoring well network in accordance with Part II.D.13., Modification of Monitoring Well Network, of this permit.

6. Groundwater Monitoring and Limits for Field Parameters, MW-2, MW-3, and MW-4 During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee shall monitor the groundwater from the hydraulically downgradient groundwater monitoring well MW-2, MW-3, and MW-4, to ensure limitations established to protect groundwater quality are met, as specified below.

The location and depth of all monitoring wells shall be consistent with the facility’s SAP approved by the Department in accordance with Part I.B.1. of this permit.

Parameter Minimum Daily Limit

Maximum Daily Limit

Daily Concentration Units Monitoring

Frequency Sample

Type Dissolved Oxygen (report) mg/L Quarterly Reading pH 6.5 9.0 S.U. Quarterly Grab Turbidity (report) NTU Annually Reading

Specific Conductance (report) umhos/cm Quarterly Reading Static Water Elevation (report) USGS-Ft Quarterly Reading

PERMIT NO. GW1010022 Page 8 of 39

a. Monitoring Well Sampling Procedure The permittee shall complete the following steps prior to obtaining a groundwater sample from a monitoring well:

i. Measure the water level in the well and the total depth of the well to determine the volume of water in the well.

ii. Purge stagnant water from the well casing prior to obtaining a groundwater sample.

If no stagnant water is found in the well casing, purging in not required.

iii. Measure field parameters on-site prior to collection of laboratory samples.

b. Static Water Elevation The permittee shall measure all Static Water Elevations from a clearly identified location on each well casing and shall be related to a known USGS datum. Water levels shall be recorded to an interval of 0.01-foot.

c. Turbidity The permittee shall not complete sampling of any groundwater monitoring well until the well has achieved sufficient stability of water quality parameters and adequately low turbidity. Turbidity should be at or below 10 Nephelometric Turbidity Units (NTUs) prior to the collection of laboratory samples.

d. Quarterly and Annual Monitoring The permittee shall collect and analyze quarterly samples during the months of February, May, August, and November. The permittee shall collect and analyze annual sampling during the month of August.

e. Discharge Monitoring Report (DMR) Monthly discharge monitoring reports shall be submitted for the months of February, May, August, and November whether or not there has been a discharge.

f. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the Department in accordance with Part I.B.1. of this permit whether or not there has been a discharge.

g. Monitoring Well Modifications The permittee shall request approval if proposing to modify any part of the monitoring well network in accordance with Part II.D.13. of this permit.

7. Groundwater Monitoring and Limits for Laboratory Parameters, MW-2, MW-3, and MW-4 During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee shall monitor the groundwater from the hydraulically downgradient groundwater monitoring well MW-2, MW-3, and MW-4, to ensure limitations established to protect groundwater quality are met at EQ-2, as specified below. The location and depth of all monitoring wells shall be consistent with the facility’s SAP approved by the Department in accordance with Part I.B.1. of this permit.

Parameter Minimum Daily Limit

Maximum Daily Limit Units Monitoring

Frequency Sample

Type Total Inorganic

Nitrogen 5.0 mg/L Quarterly Calculation

Ammonia Nitrogen (report) mg/L Quarterly Grab Nitrate Nitrogen (report) mg/L Quarterly Grab

PERMIT NO. GW1010022 Page 9 of 39

Nitrite Nitrogen (report) mg/L Quarterly Grab Chloride 250 mg/L Quarterly Grab Sodium 230 mg/L Quarterly Grab

Total Phosphorus 1.0 mg/L Quarterly Grab Calcium (report) mg/L Annually Grab

Total Arsenic 5.0 ug/L Annually Grab Total Iron 300 ug/L Annually Grab

Magnesium (report) mg/L Annually Grab Total Manganese 50 ug/L Annually Grab

Potassium (report) mg/L Annually Grab Bicarbonate (report) mg/L Annually Grab

Sulfate 250 mg/L Annually Grab

a. Quarterly and Annual Monitoring The permittee shall collect and analyze quarterly samples during the months of February, May, August, and November. The permittee shall collect and analyze annual sampling during the month of August.

b. Discharge Monitoring Report (DMR) Monthly discharge monitoring reports shall be submitted for the months of February, May, August, and November whether or not there has been a discharge.

c. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the Department in accordance with Part I.B.1. of this permit whether or not there has been a discharge.

d. TIN at Groundwater Monitoring Points The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

e. Monitoring Well Modifications The permittee shall request approval if proposing to modify any part of the monitoring well network in accordance with Part II.D.13., Modification of Monitoring Well Network, of this permit.

8. Groundwater Monitoring and Limits for Field Parameters, MW-6 (New), and MW-7 (New) During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee shall monitor the groundwater from the hydraulically downgradient groundwater monitoring well MW-6 (New), and MW-7 (New), to ensure limitations established to protect groundwater quality are met, as specified below.

The location and depth of all monitoring wells shall be consistent with the facility’s SAP approved by the Department in accordance with Part I.B.1. of this permit.

Parameter Minimum Daily Limit

Maximum Daily Limit

Daily Concentration Units Monitoring

Frequency Sample

Type Dissolved Oxygen (report) mg/L Quarterly Reading pH

PERMIT NO. GW1010022 Page 10 of 39

Through 2 Years After Monitoring Well Installation (report) (report) S.U. Quarterly Grab

Beginning 2 Years After Monitoring Well Installation

6.5 9.0 S.U. Quarterly Grab

Turbidity (report) NTU Annually Reading Specific Conductance (report) umhos/cm Quarterly Reading Static Water Elevation (report) USGS-Ft Quarterly Reading

a. Monitoring Well Sampling Procedure The permittee shall complete the following steps prior to obtaining a groundwater sample from a monitoring well:

i. Measure the water level in the well and the total depth of the well to determine the volume of water in the well.

ii. Purge stagnant water from the well casing prior to obtaining a groundwater sample.

If no stagnant water is found in the well casing, purging in not required.

iii. Measure field parameters on-site prior to collection of laboratory samples.

b. Static Water Elevation The permittee shall measure all Static Water Elevations from a clearly identified location on each well casing and shall be related to a known USGS datum. Water levels shall be recorded to an interval of 0.01-foot.

c. Turbidity The permittee shall not complete sampling of any groundwater monitoring well until the well has achieved sufficient stability of water quality parameters and adequately low turbidity. Turbidity should be at or below 10 Nephelometric Turbidity Units (NTUs) prior to the collection of laboratory samples.

d. Quarterly and Annual Monitoring The permittee shall collect and analyze quarterly samples during the months of February, May, August, and November. The permittee shall collect and analyze annual sampling during the month of August.

e. Discharge Monitoring Report (DMR) Monthly discharge monitoring reports shall be submitted for the months of February, May, August, and November whether or not there has been a discharge.

f. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the Department in accordance with Part I.B.1. of this permit whether or not there has been a discharge.

g. Monitoring Well Modifications The permittee shall request approval if proposing to modify any part of the monitoring well network in accordance with Part II.D.13. of this permit.

9. Groundwater Monitoring and Limits for Laboratory Parameters, MW-6 (New), and MW-7 (New) During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee shall monitor the groundwater from the hydraulically downgradient groundwater monitoring well MW-6 and MW-7, to ensure limitations established to protect groundwater quality are met at EQ-1, as specified below.

PERMIT NO. GW1010022 Page 11 of 39

The location and depth of MW-6 and MW-7 shall be consistent with the facility’s SAP approved by the Department in accordance with Part I.B.1. of this permit.

Parameter Minimum Daily Limit

Maximum Daily Limit Units Monitoring

Frequency Sample

Type Total Inorganic Nitrogen Through 2 Years After Monitoring Well Installation

(report) S.U. Quarterly Calculation Beginning 2 Years After Monitoring Well Installation

5.0 mg/L Quarterly Calculation Ammonia Nitrogen (report) mg/L Quarterly Grab

Nitrate Nitrogen (report) mg/L Quarterly Grab Nitrite Nitrogen (report) mg/L Quarterly Grab

Chloride Through 2 Years After Monitoring Well Installation

(report) mg/L Quarterly Grab Beginning 2 Years After Monitoring Well Installation

250 mg/L Quarterly Grab Sodium Through 2 Years After Monitoring Well Installation

(report) mg/L Quarterly Grab Beginning 2 Years After Monitoring Well Installation

230 mg/L Quarterly Grab Total Phosphorus Through 2 Years After Monitoring Well Installation

(report) mg/L Quarterly Grab Beginning 2 Years After Monitoring Well Installation

1.0 mg/L Quarterly Grab Calcium (report) mg/L Annually Grab

Total Arsenic Through 2 Years After Monitoring Well Installation

(report) ug/L Annually Grab Beginning 2 Years After Monitoring Well Installation

5.0 ug/L Annually Grab Total Iron Through 2 Years After Monitoring Well Installation

(report) ug/L Annually Grab Beginning 2 Years After Monitoring Well Installation

300 ug/L Annually Grab Magnesium (report) mg/L Annually Grab

Total Manganese Through 2 Years After Monitoring Well Installation

PERMIT NO. GW1010022 Page 12 of 39

(report) ug/L Annually Grab Beginning 2 Years After Monitoring Well Installation

50 ug/L Annually Grab Potassium (report) mg/L Annually Grab

Bicarbonate (report) mg/L Annually Grab Sulfate Through 2 Years After Monitoring Well Installation

(report) mg/L Annually Grab Beginning 2 Years After Monitoring Well Installation

250 mg/L Annually Grab

a. Quarterly and Annual Monitoring The permittee shall collect and analyze quarterly samples during the months of February, May, August, and November. The permittee shall collect and analyze annual sampling during the month of August.

b. Discharge Monitoring Report (DMR) Monthly discharge monitoring reports shall be submitted for the months of February, May, August, and November whether or not there has been a discharge.

c. Sample Collection and Analytical Methods The permittee shall perform all sampling in accordance with the SAP approved by the Department in accordance with Part I.B.1. of this permit whether or not there has been a discharge.

d. TIN at Groundwater Monitoring Points The daily maximum value for TIN shall be reported as the sum of the daily maximum values for ammonia nitrogen, nitrate nitrogen, and nitrite nitrogen.

e. Monitoring Well Modifications The permittee shall request approval if proposing to modify any part of the monitoring well network in accordance with Part II.D.13., Modification of Monitoring Well Network, of this permit.

10. Facility Operation and Maintenance The permittee shall complete site observations to ensure compliance with the terms and conditions of this permit. Observations shall be recorded in a written log, maintained by the permittee. The facility operation and maintenance log template is available on the Groundwater Discharge Permit webpage at: www.michigan.gov/groundwaterdischarge.

The log shall be retained on site in accordance with Part II.C.6 of this permit and made available for inspection by the Department upon request. The following are the requirements of the observation log:

a. Drainfield(s)

The following weekly observations shall be made:

i. Ponding and Outbreaks

The permittee shall visually observe all drainfields for any standing water or any other signs of damage or failure of the drainfield.

ii. Odors The permittee shall identify any foul odors that may produce nuisance conditions for neighboring properties or indicate failure of the drainfield.

http://www.michigan.gov/groundwaterdischarge

PERMIT NO. GW1010022 Page 13 of 39

iii. Vegetation The permittee shall visually observe all drainfields for any woody vegetation, shrubs, trees, and proper vegetation height over the drainfield.

b. Septic Tank(s) The following annual observations shall be made:

i. Depth of Sludge

The permittee shall physically measure the depth of sludge in all septic tanks with a proper measurement device.

ii. Watertight Construction The permittee shall visually observe the land around all septic tanks for any saturation, slumping, or other unusual settling of the soil.

The permittee shall immediately complete proper corrective actions if the observation identifies parts of the facility that are not in good working order.

11. Compliance Requirements The permittee shall comply with all applicable requirements set forth in Parts 31 and 41 of the NREPA and related regulations and rules. The permittee shall report all instances of noncompliance with concentration limitations of effluent or groundwater in accordance with the following requirements:

a. If the facility is in a wellhead protection area, within 48 hours from the time the permittee becomes aware of the noncompliance, the permittee shall report noncompliance to the public water supply manager.

b. Within seven days from the time the permittee becomes aware of the noncompliance, the permittee shall report, in writing, all instances of noncompliance. Written reporting shall include all of the following:

i. The name of the substance(s) for which a limit was exceeded.

ii. The concentration at which the substance was found.

iii. The location(s) at which the limit was exceeded.

c. Within 14 days from the time the permittee becomes aware of the noncompliance, the permittee shall resample the monitoring point at which the limit was exceeded for the substance for which a limit was exceeded.

d. Within 60 days from the time the permittee becomes aware of the noncompliance, the permittee shall submit a written report that shall include all of the following:

i. The results of the confirmation sampling.

ii. An evaluation of the cause for the limit being exceeded and the impact of that event on the groundwater.

iii. A proposal detailing steps taken or to be taken to prevent recurrence.

e. In accordance with R 323.2227 of the Part 22 Rules, the Department may require additional activities including, but not limited to, the following:

i. Change the monitoring program, including increasing the frequency of effluent monitoring, groundwater sampling, or both.

ii. Develop and implement a groundwater monitoring program if one is not in place.

iii. If the discharge is in a designated wellhead protection area, assess the effects of the discharge on the public water supply system.

iv. Review the operational or treatment procedures, or both, at the facility.

PERMIT NO. GW1010022 Page 14 of 39

v. Define the extent to which groundwater quality exceeds the applicable criteria that would designate the site as a facility under Part 201, Environmental Remediation, of the NREPA.

vi. Revise the operational procedures at the facility.

vii. Change the design or construction of the wastewater operations at the facility.

viii. Initiate an alternative method of waste treatment or disposal.

ix. Remediate contamination to comply with the terms of Part 201 of the NREPA, if applicable.

f. If the Department determines that a change in groundwater quality from a normal operating baseline has occurred that indicates the concentration of a substance in groundwater may exceed an applicable limit, then upon written notification from the Department the permittee shall take the following actions:

i. Change the monitoring program, including increasing the frequency of effluent sampling, groundwater sampling, or both.

ii. Review the operational or treatment procedures, or both, at the facility.

12. Schedule of Compliance (SOC) The permittee shall make submittals in compliance with the following schedule, established in accordance with R 323.2206(4) of the Part 22 Rules.

a. Schedule of Compliance for Permit Documents

i. On or before March 1, 2025, the permittee shall submit to the Department for review and approval an Operations and Maintenance Manual (O&M Manual) as required under Part I.B.2 of this permit.

ii. On or before March 1, 2025, the permittee shall submit to the Department for review and approval an SAP as required under Part I.B.1 of this permit.

b. Schedule of Compliance Flow Measurement Device

i. On or before October 1, 2026, the permittee shall submit for review and approval a workplan for the installation of effluent flow measurement devices or alternative measurement methods that will measure the flow being discharged from the upper and lower toilet buildings system (EQ-1) and the sanitation stations system (EQ-2) on site. The workplan shall include, at a minimum, the location(s) of measurement, type of flow measurement device or detailed actions for the alternative method of measurement.

1. On or before 90 days after the approval of the workplan, the permittee shall complete installation of the flow measurement devices or initiation of the measurement method.

2. On or before 90 days after the complete installation of the flow measurement devices or initiation of the approved measurement method, the permittee shall submit an updated O&M Manual that includes the flow measurement method or device, in accordance with Part I.B.2 of this permit.

c. Schedule of Compliance for Groundwater Monitoring Wells

i. On or before April 1, 2025, the permittee shall submit to the Department for review and approval a work plan for the installation of the following groundwater monitoring wells:

1. The facility shall submit a work plan for the installation of a minimum of two monitoring wells (MW-6 and MW-7) around the drainfield for the upper and

PERMIT NO. GW1010022 Page 15 of 39 lower toilet buildings system (EQ-1). The work plan shall include, at a minimum, the following:

(i) All information required under R 323.2221(3)(b)(v) of the Part 22 Rules which includes, number, location, depth, drilling method, construction materials, and development method of all wells.

(ii) All information required under R 323.221(3)(b)(vi) of the Part 22 Rules which includes, number of proposed soil borings, location, depth, drilling and plugging method.

ii. On or before 90 days after approval of the workplan, the permittee shall complete the installation of all required monitoring wells.

iii. On or before 30 days after complete installation of all required monitoring wells, the permittee shall submit to the Department for review, a well installation report for all complete monitoring wells. The report shall include, at a minimum, the following:

1. Soil boring logs for all soil borings completed.

2. Construction wells logs for all wells installed.

3. Updated site map with new wells identified.

4. A complete survey of all monitoring wells around EQ-1. A complete survey shall include, at a minimum the following:

(i) Top of casing.

(ii) Ground surface elevations surveyed to a United States Geological

Survey (USGS) datum as required in R 323.2221(4)(a)(vi), R 323.221(4)(g)(iv), and R 323.2223(3)(b).

iv. On or before 60 days after the installation of the monitoring wells, the permittee shall submit to the Department for review and approval an updated SAP as required under Part I.B.1 of this permit.

v. Immediately upon receipt of written approval from the Department for the SAP, the permittee shall commence groundwater sampling as specified in the approved SAP. Prior to installation of the monitoring wells, groundwater samples are not required to be collected. For any of the specified sampling quarters, prior to the installation of the wells, the permittee shall enter “*G” on the Discharge Monitoring Report (DMR) for all groundwater sampling locations.

d. SOC for Corrective Action Plan (CAP)

i. The permittee shall complete the following SOC to achieve the groundwater limits for pH; TIN; Chloride; Sodium; Total Phosphorus; Total Arsenic; Total Iron; Total Manganese; and Sulfate specified in Part 1.A.8 and Part 1.A.9 of this permit. The schedule requires continued work to reduce pH; TIN; Chloride; Sodium; Total Phosphorus; Total Arsenic; Total Iron; Total Manganese; and Sulfate in the Groundwater, if unable to comply with final groundwater limits beginning on the date exactly 2 years following the installation of MW-6 and MW-7, then a CAP shall be submitted as specified herein.

(a) On or before June 30th or December 31st (whichever comes first) of the year that the new monitoring wells (MW-6 and MW-7) is installed, the permittee shall submit the first semi-annual status report that analyzes the

PERMIT NO. GW1010022 Page 16 of 39 groundwater data collected in MW-6 and MW-7. This status report shall include, at a minimum, the following:

(i) All effluent and groundwater data for the past six months.

(ii) An evaluation of any general trends in the effluent and groundwater indicating that the discharge cannot meet the limitations specified in Part 1.A.8 and Part 1.A.9 of this permit.

(iii) Any steps taken to bring the discharge in compliance with the limitations such as, source reduction, best management practices, treatment, or prevention of pH; TIN; Chloride; Sodium; Total Phosphorus; Total Arsenic;

Total Iron; Total Manganese; and Sulfate from entering the treatment system.

Semi-annual status reports are due by June 30 and December 31 of each year.

Status reports shall be submitted in MiEnviro via the “Ongoing Groundwater Report.”

(b) On or before 2 years following the installation of MW-6 and MW-7, the permittee shall achieve compliance with final groundwater limits specified in Part 1.A.8 and Part 1.A.9. of this permit. Alternatively, if the permittee is unable to consistently comply with the final groundwater limits six months prior to commencement of the limit, a CAP shall be submitted to the Department for review and approval by the date exactly 2 years following the installation of MW-6 and MW-7. Once approved, the CAP shall become an enforceable part of this permit. The CAP shall include, but is not limited to, the following:

(i) Clearly indicate and provide adequate justification for the correction actions chosen to bring the facility into compliance with the groundwater limitations specified in Part 1.A.8 and Part 1.A.9. of this permit.

(ii) Include a schedule with sufficient dates so that no period covered under the schedule exceeds three months. The schedule shall include any necessary updates to the SAP, or Operations and Maintenance Manual (O&M Manual).

e. Local Health Department Approval

i. On or before July 5, 2029, with the application for reissuance the permittee shall submit to the Department for review a copy of any construction permits for the Sanitation Station, Day Use Pavilion, Office, and Camp Office discharge systems (EQ-2, EQ-3, EQ-4 and EQ-5) from the local county, district, or city health department that has jurisdiction. If the permittee cannot provide approvals, then the permittee shall submit notification that these approvals cannot be provided.

Submittals shall be made via the Department’s MiEnviro portal. If any document required to be submitted is disapproved by the Department, the permittee shall, within 30 days of receiving written disapproval, submit a revised document addressing the deficiencies.

13. Septage Waste Before the sludge volume occupies 25 percent of the holding tank capacity, septic tanks shall be pumped by a septage hauler licensed pursuant to Part 117, Septage Waste Servicers, of the NREPA. Septage shall be disposed of in accordance with Part 117.

PERMIT NO. GW1010022 Page 17 of 39

14. Additives This permit does not authorize the use of any additive without prior written approval from the Department. Such approval is authorized under separate correspondence. Additives include any substance added to water to enhance its effectiveness for uses such as, but not limited to, cleaning, disinfecting, heating, and cooling., A substance may be added to water directly or indirectly by being added to a process in such a way that it becomes a constituent of the wastewater. Permittees proposing to use any additives, including a proposed increased concentration of a previously approved additive, shall submit a request for approval via the Department’s MiEnviro Portal system. The application form name is “Groundwater Discharge Water Treatment Additive (WTA) Request Form” and can be found under the “Apps, Requests, and Reports”. The MiEnviro Portal website is located at https://mienviro.michigan.gov/ncore. A separate application form is required for each additive. Additional monitoring and reporting may be required as a condition of approval to use the water treatment additive.

A request for approval to use water additives shall include all of the following usage and discharge information for each water additive proposed to be used:

a. The Safety Data Sheet (SDS);

b. Ingredient information, including the name of each ingredient, Chemical Abstract

Service (CAS) number for each ingredient, and fractional content by weight for each ingredient;

c. The proposed water additive discharge concentration with supporting calculations;

d. The discharge frequency (i.e., number of hours per day and number of days per year);

e. The outfall(s) and/or monitoring point(s) from which the water additive is to be discharged;

f. The type of removal treatment, if any, that the water additive receives prior to discharge;

g. The WTA’s function (i.e., microbiocide, flocculant, etc.);

h. The SDS shall include a 48-hour LC50 or EC50 for a North American freshwater planktonic crustacean (either Ceriodaphnia sp., Daphnia sp., or Simocephalus sp.).

The results shall be based on the whole water additive, shall not be results based on a similar product, and shall not be estimated; and

i. The SDS shall include the results of a toxicity test for one (1) other North American freshwater aquatic species (other than a planktonic crustacean) that meets a minimum requirement of R 323.1057(2) of the Water Quality Standards. The results shall be based on the whole water additive, shall not be results based on a similar product, and shall not be estimated. Examples of tests that would meet this requirement include a 96-hour LC50 for rainbow trout, bluegill, or fathead minnow.

15. Sanitary Sewage Discharges The permittee is prohibited from receiving waste other than sanitary sewage.

To request approval to accept other wastes, the permittee shall submit a request for a major modification to this permit prior to receiving the wastewater, via the Department’s MiEnviro portal. Following the review of such a request, the Department may modify the permit according to applicable laws and rules to specify and limit any pollutant not previously limited, or require additional treatment by the facility.

PERMIT NO. GW1010022 Page 18 of 39

B. Required Documentation

1. Sampling and Analysis Plan (SAP)

The permittee shall complete all measurement, sampling, and analysis procedures in accordance with the SAP approved by the Department. The SAP approved by the Department is an enforceable requirement under this permit. The SAP shall meet the requirements of R 323.2223(3) if groundwater sampling is required by this permit and shall include, at a minimum, the following information:

a. Effluent Monitoring.

i. Location of effluent sampling.

ii. Sample frequency.

iii. A list of substances to be sampled.

(a) The following parameters shall be performed on-site, if required to be sampled by this permit: pH, Dissolved Oxygen

iv. Sampling procedures, including all of the following:

(a) The method and volume of water removed during sampling.

(b) Steps taken to prevent cross-contamination.

(c) Sample handling and preservation methods.

(d) Laboratory analysis method.

(e) Laboratory method detection level.

(f) Quality assurance and quality control program.

b. Groundwater Monitoring, if required under this permit.

i. The number and location of wells to be included in the groundwater monitoring program.

ii. For each well, the depth and screened interval for each monitoring well. The screened interval shall be referenced to United States Geological Survey data.

iii. Well construction materials and installation techniques.

iv. Sampling frequency.

v. A list of substances to be sampled.

(a) The following parameters shall be analyzed on-site, if required to be sampled by this permit pH, Dissolved Oxygen, Specific Conductance, Static Water Elevation, and Turbidity.

vi. Sampling procedure, including all of the following:

(a) The method and volume of water removed from each well during sampling.

(b) Steps taken to prevent cross-contamination between wells.

(c) Sample handling and preservation methods.

(d) Laboratory analysis method.

(e) Laboratory method detection level.

(f) Quality assurance and quality control (QA/QC) program.

vii. A description of the techniques used to present and evaluate groundwater quality monitoring data.

viii. A description of the method used to collect static water levels and present groundwater flow data. Static water level precision shall be to 0.01 feet.

PERMIT NO. GW1010022 Page 19 of 39

Prior to implementation of any modifications to the procedures specified in the approved SAP, the permittee shall submit to the Department for review and approval a written request for modification of the SAP. Such requests shall explain the nature of the modification, provide adequate rationale for the modification, and include all necessary supporting documentation to enable a full review of the SAP. Approved modifications shall become enforceable requirements under this permit upon the date of the Department’s written approval.

The permittee shall keep a copy of the approved SAP, including any approved modification, at the facility permanently and shall be provided to the Department upon request. The Department may review any document in whole or in part at its discretion and upon written notification require modifications if portions are determined to be inadequate.

The permittee shall immediately initiate steps to correct any condition that is not in accordance with the SAP approved by the Department.

2. Operations and Maintenance Manual (O&M Manual) The permittee shall operate the facility in accordance with the O&M Manual approved by the Department. The O&M Manual approved by the Department is an enforceable requirement under this permit. The O&M Manual shall include, at a minimum, the following information:

a. Descriptions and operation information for all equipment.

b. An emergency operation plan.

c. Monitoring program to monitor process efficiency.

d. Inspection instructions and plan for the collection system and pump stations.

e. Maintenance plan for equipment.

f. Documentation of maintenance and inspection.

g. List of relevant environmental regulations.

Prior to implementation of any modifications to the procedures specified in the approved O&M Manual, the permittee shall submit to the Department for review and approval a written request for modification of the O&M Manual. Such requests shall explain the nature of the modification, provide adequate rational for the modification, and include all necessary supporting documentation to enable a full review of the O&M Manual. Approved modifications shall become enforceable requirements under this permit upon the date of Department written approval.

The permittee shall keep an approved copy of the O&M Manual, including any approved modification, at the facility and shall be provided to the Department upon request. The Department may review any document in whole or in part at its discretion and upon written notification require modifications if portions are determined to be inadequate. The permittee shall immediately initiate steps to correct any condition that is not in accordance with the O&M Manual approved by the Department.

PERMIT NO. GW1010022 Page 20 of 39

PART II

Part II may include terms and/or conditions not applicable to discharges covered under this permit.

A. Definitions 24-Hour Composite Sample is a flow-proportioned composite sample consisting of hourly or more frequent portions that are taken over a 24-hour period.

Additive means a substance added to water to enhance its effectiveness for uses such as, but not limited to, cleaning, disinfecting, heating, and cooling. A substance may be added to water directly or indirectly by being added to a process in such a way that it becomes a constituent of the water.

Annual Monitoring Frequency refers to a calendar year beginning on January 1 and ending on December 31.

For effluent monitoring, when required by this permit, an analytical result, reading, value, or observation must be reported for that period if a discharge occurs during that period.

For groundwater monitoring, when required by this permit, an analytical result, reading, value, or observation must be reported for that period regardless if the discharge occurs during that period.

Best Management Practices means structural devices or nonstructural practices that are designed to prevent pollutants from entering groundwater.

Biosolids are the solid, semisolid, or liquid residues generated during the treatment of sanitary sewage or domestic sewage in a treatment works. This includes, but is not limited to, scum or solids removed in primary, secondary, or advanced wastewater treatment processes and a derivative of the…