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7 <br /> <br />2.3 Reasonable Potential Analysis <br />Preview the Ecology Permit Writer’s renewal process for the City of conducting a <br />Reasonable Potential Analysis (RPA) using the data the City submitted in the April 2020 <br />permit renewal package. Identify the parameters with reasonable potential for <br />exceedance, if any, and examine the data that will be used in the analysis. The goal is to <br />highlight whether the data submitted to Ecology triggers new or modified effluent limits, <br />such as ammonia, metals, organics, human health toxics, etc. Review data for <br />inconsistencies to verify they are representative of current City’s conditions. Revise the <br />data submittal to Ecology as necessary to eliminate non-representative data. <br /> 2.4 Prepare Draft Sampling Plan <br />It may be advantageous to the City to collect additional water quality samples from Port <br />Gardner Bay, the Snohomish River and/or plant effluent. Review of the draft permit <br />application for potential future limits will inform the need for the water quality <br />monitoring data and whether the April 2020 data accurately represents the City’s <br />discharge. Prepare a draft water quality sampling plan for City review, which may <br />include various graphics or a map. 2.5 Meet with Washington Department of Ecology (Ecology) <br />Coordinate with City staff to prepare for and attend meetings with Ecology regarding the <br />NPDES permit renewal. Meetings will be to review the draft permit application and to <br />discuss Ecology’s response to the permit application and options to move the permit <br />forward. Submit meeting notes to City. <br /> 2.6 Meet with the City <br />Attend meetings with the City to review the draft permit application and before and after <br />each meeting with Ecology. Meetings are expected to be online/virtual and may be hosted <br />by either the City or HDR. <br /> 2.7 Provide Comment Letter on draft Permit and Fact sheet. <br />Support the City’s review of a pre-public notice courtesy copy of Ecology’s draft <br />NPDES permit, prior to public notice of the formal Draft Permit, with technical <br />analysis of Ecology’s approach. Once Ecology releases the permit for public comment, <br />provide a draft comment letter on the permit and fact sheet for the City’s review. <br /> <br />Key activities to support NPDES permitting are as follows: <br />• Assist the City in preparation or updates to the NPDES permit renewal application for <br />the City’s individual NPDES permit. <br />• Conduct screening level preview Reasonable Potential Analysis (RPA) to identify the <br />potential for the reported effluent monitoring data to trigger Water Quality Based <br />Effluent Limits (WQBELs) for any parameters. <br />• Review Ecology’s Reasonable Potential Analysis (RPA) calculations. <br />• Meet with City and Ecology staff as necessary to support the City’s individual NPDES <br />permit renewal. <br />• Assist the City in review of pre-publication drafts of the NPDES Permit and Fact <br />Sheet for factual review. Provide written review comments for City consideration for