FACT SHEET and NPDES WASTEWATER DISCHARGE PERMIT EVALUATION

Transcription

1 FACT SHEET and NPDES WASTEWATER DISCHARGE PERMIT EVALUATION Department of Environmental Quality Western Region - Eugene Office 1102 Lincoln St. Suite 210 Eugene, OR (541) PUBLIC NOTICE PERMITTEE; SOURCE CONTACT: SOURCE LOCATION: PERMIT WRITER: PROPOSED ACTION: SOURCE CATEGORY: PERMIT APPLICATION DATE: PERMIT APPLICATION NUMBER: J.H. Baxter & Co., Inc. P.O. Box 5902 San Mateo, CA Georgia Baxter Telephone Number: N. Baxter Road, Eugene Julie Berndt Renewal NPDES Permit Industrial Minor 2/6/ BACKGROUND Introduction J.H, Baxter & Co. (JHB) owns and operates a wood treating facility at 85 N. Baxter Road, Eugene, Oregon, JHB has applied for renewal of their National Pollutant Discharge Elimination System (NPDES) Permit. The current permit was issued April 13, 1993 and expired September 30, As the application for renewal was made on time, JHB continues to operate under the provisions of the expired permit. Facility Description The facility pressure treats wood products including utility poles, railroad ties, piling, guardrail posts, and other lumber products. The preservatives used are either an oil borne solution containing pentachlorophenol (PCP) or creosote, or water borne formulations of ammoniacal copper quaternary (AQC) and ammoniacal copper zinc arsenate (ACZA). In the past, formulations containing chromium were also used. Due to past practices at the site, groundwater and onsite soils are contaminated with, copper, zinc, arsenic, and chromium. JHB has installed and operates a groundwater treatment system under the oversight of DEQ's Environmental Cleanup Division. Contaminated groundwater is treated using slow sand filtration and activated carbon filtration prior to discharge at Outfall 002.

2 Page 2 Stormwater is collected at four sumps on site and pumped to an equalization tank for flow equalization and initial clarification prior to pumping to the treatment system. The treatment system is fully automated and uses chemical precipitation, flocculation, clarification, and multi-media filtration, for s; removal of copper and zinc. Activated alumina is used to remove arsenic, and activated carbon is used "I %.JlfDif reni^ap of f enfeehlprophenoi and final polishing. The treated stormwater is discharged at Outfall Outfalls The facility has two wastewater discharge outfalls. Outfall 001 is located in the southwest corner of the plant and discharges to an unnamed ditch, which flows west along the south side of the property, and eventually to Amazon Creek at river mile Outfall 002 is located at the northwest corner of the property and flows via an unnamed ditch to the Roosevelt Channel and thence to Amazon Creek. Pollutants Discharged Potential pollutants at the site include arsenic, copper, chromium, zinc, pentachlorophenol, and dioxin from contaminated soils and groundwater. Other pollutants common to industrial stormwater include oil & grease, total suspended solids (TSS), and other metals (such as lead). Schedule A of the permit contains discharge limitations for pentachlorophenol, BOD5, arsenic, copper, chromium, zinc, temperature, and at Outfall 001, and Outfall 002. Schedule A also includes stormwater benchmarks for Lead, TSS, and Oil & Grease at Outfall 001. Schedule B of the permit includes monitoring requirements for these pollutants. Receiving Streams/Impact Contaminated groundwater and stormwater at the site are treated to remove contaminants prior to discharge, Treated wastewater from both the groundwater and stormwater treatment systems is discharged to drainage ditches, which flow in a westerly direction to Amazon Creek at river mile Amazon Creek is a tributary of the Long Tom River, which is Water Quality Limited for temperature during the summer. Due to the temperature listing, no wastewater with temperatures in excess of 64 F can be discharged during the summer months without an approved Management Plan (TMP). Both stormwater and groundwater at the site are treated using systems that may add heat to the wastewater. Although the stormwater discharge occurs primarily during the rainy season, there is a potential for discharge during the summer months, when the receiving stream is listed for temperature. The groundwater treatment system discharges all year. Records indicate that the discharge from the system has consistently been below 64 F, These discharges should not contribute to temperature exceedances in the receiving stream. A Management Plan will not be required. Schedule A of the draft permit contains a seasonal (May 1 to October 31) discharge limitation of 64 F for both outfalls. Schedule B requires monthly monitoring for temperature during the same period for both outfalls. Groundwater Due to past practices at the site, groundwater is contaminated with pentachlorophenol, copper, zinc, arsenic, and chromium. JHB has installed, and operates a groundwater treatment system under the oversight of DEQ's Environmental Cleanup Division. Contaminated groundwater is treated using slow sand filtration and activated carbon filtration prior to discharge at Outfall 002.

3 Page 3 Stormwater Due to past practices at the site, groundwater and onsite soils are contaminated with pentachlorophenol, copper, zinc, arsenic, and chromium. Stormwater is collected at four sumps on site and pumped to an equalization tank for flow equalization to the treatment system, and initial clarification. The treatment system is fully automated and uses chemical precipitation,flocculation,clarification, and multi-media filtration, for removal of copper and zinc. Activated alumina is used to remove arsenic, and activated carbon is used for removal of and final polishing. Treated stormwater is discharged at Outfall 001. Compliance History The current permit was issued April 13, The Department and JHB entered into a Stipulation and Final Order (SFO) which allowed JHB to exceed their discharge limitations for a period of time while they completed design and installation of a stormwater treatment system. JHB was unable to achieve compliance with discharge limitations in the permit with the original treatment facilities. On August 22, 2000, the Department and JHB entered into a new Mutual Agreement and Order (MAO). The MAO contained a sizeable up front civil penalty, and required JHB to complete modifications to their storrmwater treatment system by November 2001, and be in compliance with permit discharge limitations by February The MAO had stipulated penalties for failure to comply. JHB had the modifications completed on time and met discharge limitations by February The MAO was terminated March 23,2001, and JHB has continued to meet permit discharge limitations. PERMIT DISCUSSION Face Page The permittee is authorized to construct, install, modify, or operate a wastewater collection, treatment, control and disposal system. Permits discharge of treated effluent to the drainage ditches and thence to Amazon Creek. All other discharges are prohibited. Under types of waste for Outfall 001 Boiler Blowdown has been added. This is not a new wastestream, but was not included in the previous permit. Schedule A - Waste Discharge limitations Condition 1. a. of Schedule A (See Below) lists the discharge limitations from the stormwater treatment plant to the storm ditch. The discharge limitations are similar to those in the previous permit except for the following changes: The discharge limitation for chromium (VI) has been removed from the permit as it has never been detected. The discharge limitation for formaldehyde has been removed from the permit as it has never been detected, and is no longer used in the process. The discharge limitations for TSS and Oil & Grease have been replaced by stormwater benchmarks used in other industrial stormwater permits (see 1.b below). A limitation of 64 F has been added because the receiving stream is a tributary of the Long Tom River, which is water quality limited for temperature during the summer months. No Management Plan is required as records indicate that the discharge is constantly below 64 F.

4 Page 4 The monthly average and daily maximum limits for pentachlorophenol, arsenic, copper, chromium (III) and zinc are based on the chronic and acute toxicity criteria respectively, The limitations based on toxicity and the and temperature limits are designed to assure compliance with instream water quality standards, and are similar to those used in permits for similar discharges throughout the State. The limits on BOD 5 and nitrate are technology-based limits. a. Outfall Number 001 (Stormwater Treatment Plant Discharge) Parameters BOD 5 Nitrate Nitrogen Other Parameters Effluent Concentrations Avg. Daily Max Limitations Shall be within the range of Shall not exceed 64 F during the period of May 1 to October 31 Condition 1. b. (see below) contains stormwater benchmarks for Outfall 001. Exceedance of these benchmarks requires the permittee to review the existing Stormwater Pollution Control Plan (SWPCP), identify and implement additional best management practices, which may be needed to meet the benchmark values, and update the SWPCP to include the changes. b. Outfall Number 001 (Stormwater Benchmarks) Benchmarks Benchmarks are guideline concentrations not limitations. They are designed to assist the permittee in determining if the implementation of their SWPCP is reducing pollutant concentrations to below levels of concern. For facilities that are subject to federal limitations, benchmarks apply to only those pollutants that are not limited by the federal regulations. The following benchmarks apply to each point source discharge of storm water associated with industrial activity: Parameter Total Lead Total Suspended Solids Oil & Grease Benchmark 0.4 mg/l 130 mg/l Shall not exceed 10 mg/l Review of SWPCP If benchmarks are not achieved,' the permittee shall review their SWPCP within 60 days of receiving sampling results. The purpose of this review is to determine if the SWPCP is being followed and to identify any additional technically and economically feasible site controls that need to be implemented to further improve the quality of storm water discharges. These site controls include best management practices, spill prevention and response procedures, preventative maintenance, and employee education procedures.

5 Page 5 2. SWPCP Revision Any newly identified site controls shall be implemented in a timely manner and incorporated into the SWPCP as an update. A new SWPCP is not required. If no additional site controls are identified, the permittee shall state as such in an update to the SWPCP, 3. SWPCP Revision Submittal Results of this review shall be submitted to the Department in accordance with Schedule B.2 and made available upon request to government agencies responsible for storm water management in the permittee's area. Condition I.e. (see below) lists the limitations for the discharge from the groundwater treatment plant to the storm ditch. The limitations are the same as those in the previous permit except for the following changes: A limitation of 64 F has been added because the receiving stream is a tributary of the Long Tom River, which is water quality limited for temperature during the summer months. No Management Plan is required as records indicate that the discharge is constantly below 64 F. Discharge limitations for chromium (VI), Nitrate Nitrogen, Formaldehyde, and TSS have been removed from the permit as they have never been detected in the effluent. These limitations are designed to assure compliance with instream water quality standards, and are similar to those used in permits for similar discharges throughout the State. c. Outfall Number 002 (Groundwater Treatment Plant Discharge) Parameters Effluent Concent rations Avg. Daily Max Other Parameters Schedule B - Minimum Monitoring and Reporting Requirements Limitations Shall be within the range of Shall not exceed 64 F during the period of May 1 to October 31 Condition 1, a. (below) contains the required monitoring for the discharge from Outfall 001. The Monitoring requirements in the draft permit are similar to the previous permit. Following is a brief summary of the proposed changes: The bioassay requirements have been changed from the previous permit to require a both chronic and acute testing. The protocol specified in Schedule D of the permit is for a dual end test, which will provide both results. monitoring has been added as the discharge is to a tributary of the Long Tom River, and the Long Tom is water quality Limited for temperature. Monitoring frequency for BOD s and Polynuclear Aromatic Hydrocarbons (PAH's) have been reduced from twice/month to monthly. The permittee has upgraded their stormwater treatment system. During the first four months of operation all parameters were within permit limitations, and most were nondetect. A note has been added to allow the permittee to ask for the monitoring frequency for arsenic, copper, zinc, chromium, PCP, and to be reduced to monthly, if they continue to meet the discharge limitations for one full year.

6 J.H, Baxter & Co, Evaluation Report Page 6 The permittee has been doing Bioassay testing at Outfall 001 since 1993, and has not noted any toxicity. The bioassay testing required in the original permit only evaluated acute toxicity. The current bioassay protocol contained in Schedule D, condition 5 of the draft permit requires both acute and chronic testing. A note has been added to allow the permittee to request that the Department remove the bioassay testing requirement from the permit if two years of testing with the new method does not show any acute or chronic toxicity. a. Outfall Number 001 Item or Parameter Flow BOD 5 Polynuclear Aromatic Hydrocarbons Oil & Grease TSS Lead PCDD, PCDF Bioassay Testing Minimum Frequency Daily 2/Month' 2/Month' Twice /Year Twice /Year Twice /Year Annually (May Through October) Semi-annually Type of Sample Measurement z z A 3 Acute & Chronic Bioassay Condition Lb, below, contains the monitoring requirements for Outfall 002. Following is a summary of the proposed changes in monitoring for Outfall 002. monitoring has been added as the discharge is to a tributary of the Long Tom River, and the Long Tom is water quality Limited for temperature. Monitoring requirements for chromium (VI), Nitrate Nitrogen, Formaldehyde, and TSS have been removed from the permit as they have never been detected in the effluent. Monitoring requirements for arsenic, copper, zinc, chromium, and PAH's have been reduced to, as they have been non-detect since the permit was issued, b. Outfalls Number 002 Item or Parameter Flow Polynuclear Aromatic Hydrocarbons Minimum Frequency Daily (May Through October) Type of Sample Measurement 24-hi composite

7 Page 7 2. Reporting Procedures Monitoring results shall be reported on approved forms. The reporting period is the calendar month. Reports must be submitted to the appropriate Department office by the 15th day of the following month. NOTES: 1. If monitoring results for these parameters are consistently in compliance with permit limits for one full year after permit issuance the monitoring frequency will be reduced to monthly. 2. samples that are representative of the discharge shall be taken at least 60 days apart. It is preferred, but not required, that one sample be collected in the fall and one in the spring, Compositing of samples from different drainage areas is not allowed, 3. PCDD and PCDF shall be analyzed using EPA Method 1613 or equivalent. 4. Bioassy testing shall be done in accordance with the protocol specified in Schedule D, Condition 5 of this permit. 5. I f two years of bioassy testing show no acute or chronic toxicity, the permittee may submit a written request to the Department to remove the bioassy testing requirement from this permit. 6. If modifications are made to the groundwater treatment system the Department may reopen the permit and modify the monitoring requirements in Schedule B, Schedule C - Compliance Conditions This permit contains no compliance conditions. Schedule D - Special Conditions The proposed permit includes eight special conditions. They concern disposal of sanitary wastes, Department approval of plans and specifications prior to any facility modifications or upgrades, a spill contingency plan, designation of an environmental supervisor, continued implementation of the approved Stormwater Pollution Control Plan, a requirement that all treated product be stored under cover from Nov, 1 to May 1, notification of malfunctions, and protocol for bioassay testing.