Oregon Department of Environmental Quality. Western Region - Salem Office 750 Front Street NE, Suite 120 Salem, OR (503)

Transcription

1 ^^K DEQ State of Oregon Department of Environmental Quality National Pollutant Discharge Elimination System PERMIT EVALUATION AND FACT SHEET December 22,211 Oregon Department of Environmental Quality Western Region - Salem Office 75 Front Street NE, Suite 12 Salem, OR 9731 (53) Permittee Weyerhaeuser NR Company PO Box 129 Current Permit Sweet Home, OR File Number: 977 Permit Number: Expiration Date: 12/31/21 EPA Reference Number: OR Source Contact Source Location Alvin "Rusty" Flanders, Plant Environmental Manager (541) Engineered Lumber Products - Foster Veneer 611E.Hwy2 Sweet Home, OR Linn County LLID River Mile Proposed Action , Wiley Creek.9 & 1. Renew NPDES Minor - Industrial Permit Application Number: Date Received: July 1,21 Permit Writer April Graybill, Water Quality Specialist DEQ Western Region - Salem Office Phone: (53)

2 Page 2 INTRODUCTION The Department of Environmental Quality (DEQ) proposes to renew the National Pollutant Discharge Elimination System (NPDES) wastewater permit for Weyerhaeuser NR Company for the Engineered Lumber Products - Foster (ELP) facility located near Foster Lake at 611 E. Hwy 2 Sweet Home, OR This permit allows and regulates the treated discharge of boiler blowdown, filter backwash, softener wastewater, vat condensate, non-contact cooling water, log deck sprinkler runoff, discharge from oil/water separator tanks, building & equipment washwater, fire deluge water, non-contact steam condensate, mill yard runoff, veneer dryer condensate, compressor condensate, and stormwater to Wiley Creek a tributary of the South Santiam River in the South Santiam Subbasin of the Willamette Basin. The current NPDES Permit expired on December 31,21. The DEQ received a request for an extension of the renewal application submission prior to 18 days before the permit expiration date and DEQ granted the submission extension in accordance with OAR (1). DEQ then received renewal application number from Weyerhaeuser NR Company on July 1,21. Because the permittee submitted a renewal application to DEQ in a timely manner, the current permit will not expire until DEQ takes final action on the renewal application as per OAR This permit evaluation report describes the basis and methodology used in developing the permit. The permit is divided into several sections: Schedule A - Waste discharge limits Schedule B - Minimum monitoring and reporting requirements Schedule D - Special conditions Schedule F - General conditions The Federal Water Pollution Control Act of 1972 and subsequent amendments require a NPDES permit for the discharge of wastewater to surface waters. Furthermore, Oregon Revised Statutes (ORS 468B.5) also require a discharger be granted a permit for the discharge of wastewater to surface waters. This proposed permit action by the DEQ complies with both federal and state requirements. FACILITY DESCRIPTION Weyerhaeuser NR Company owns the ELP facility. Weyerhaeuser acquired the facility in 22 from Willamette Industries. ELP processes raw logs (primarily Douglas fir) into veneer for transport to other facilities. The logs are hauled in and stored in the log deck sprinkling area. The logs are stripped of bark, cut/bucked, kept soft by warming/steaming in vats, peeled for veneer (many sheets of veneer are dried on site), graded, marked, stacked, and then banded for shipment. Both green and dried veneer is produced and shipped from the facility. The facility uses mechanical debarking which is a waterless process. The debarked pieces are typically used as hog fuel for the boiler.

3 Page 3 Changes made to the facility prior to the 26 permit renewal include relocating the veneer dryer washwater collection area and the decommissioning of a secondary lathe. The number of employees varies at the facility. The facility currently employs 85 people. Three staff members on site are familiar and trained with the required NPDES monitoring. The ELP facility also has the NPDES 12Z Industrial Stormwater water quality permit and the Title V Air Quality permit. ELP previously produced plywood on-site. The facility's three plywood presses were removed from the site in 26 and at this point there is no plan to produce plywood in the future. GROUNDWATER ISSUES A previous permit included requirements to address the potential impacts to groundwater. A compliance condition required the permittee to conduct a Groundwater Impact Assessment which was conducted in 1995 and No contaminants were encountered at levels that required further action by the Permittee. A DEQ hydrogeologist recently reviewed their reports for this permit renewal and reviewed online information to evaluate whether the log pond is posing or could pose a threat to groundwater resources in the site's vicinity. The hydrogeologist concluded that the risk is low, and therefore no groundwater monitoring is necessary. His conclusions were based on the following: - Although there are several wellhead protection areas near the site, none appear to be impacted; Given the topography, shallow groundwater flow direction is toward Foster Lake, although this is likely highly influenced by reservoir levels; - Although there are several shallow wells in the community (individual domestic wells), they appear to be in a cross-gradient direction from the log pond; The NPDES permit requirements regarding groundwater have been satisfied and no further investigation will be required under this permit. STORMWATER Most of the stormwater discharges are regulated by a NPDES General Industrial Stormwater 12-Z Permit assigned to this facility. The 12-Z Permit requires the Permittee to develop and implement a Stormwater Pollution Control Plan (SWPCP). The SWPCP identifies and schedules Best Management Practices (BMP's), and other measures to be implemented to reduce stormwater pollution. The 12-Z also requires monitoring of stormwater runoff. Stormwater is also part of the wastestream discharged according to this individual permit. OUTFALLS ELP's 55 acre log pond receives stormwater,filterbackwash water, softener wastewater, vat condensate, non-contact cooling water, fire deluge water, log deck sprinkler run-off water, noncontact steam condensate, stormwater, boiler blowdown, discharge from oil/water separator, tanks, building and equipment washwater, veneer dryer condensate, and compressor condensate.

4 Page 4 The log pond discharges to Wiley Creek (Outfall 1) approximately 1. River Miles above the confluence with the South Santiam River. The rate and frequency of the discharge is largely determined by precipitation so, there is little or no discharge during the summer season. The mill yard ditch receives runoff from stormwater, fire deluge water, non-contact steam condensate, non-contact cooling water, building and equipment washwater and the oil/water separator tanks. These wastewaters also collect near Outfall 2, but are pumped to the log pond for discharge through Outfall 1. In the rare instance that Outfall 2 does discharge, the discharge is located downstream of Outfall 1. (See Figures 1 & 2) In 2, a pump back system was installed at Outfall 2 to eliminate summer discharges to the creek. Outfall 2 has a float triggered indicator light which alerts staff to rising water at 8" from the weir top and the area is checked daily during screen cleaning. Outfall 2 employs the use of two stationary pumps and as part of the site's preventative maintenance effort maintains a third, mobile pump there as well. This pump is typically activated during heavy rainfall events. FIGURE 1: Aerial Man of Engineered Lumber Products - Foster Veneer Facility

5 Page 5 FIGURE 2: Topographic Map of Engineered Lumber Products - Foster Veneer Facility SLUDGE MANAGEMENT Residuals generated at the mill are handled in accordance with DEQ Solid Waste program rules. COMPLIANCE HISTORY The site was last inspected on July 22, 21. No violations were noted during the inspection. The June 29 through June 21 discharge monitoring reports (DMRs) for the facility were reviewed prior to the inspection and all reports were submitted on time and were in compliance with the facility permit. The facility retains DMRs for at least five years. ELP has received one water quality permit related warning letter during the current permit cycle (permit renewal issued on January 18, 26) for the following: TABLE 1: ELP Enforcement Action MlilloWItie 9/2/28 ;l$m tate 1/15/29 Parameter Discharge from Outfall 2 due to pump failure VioitWiolffiMSlsi Class I RECEIVING WATER Designated Beneficial Uses

6 Page 6 The facility's receiving stream, the Middle Fork Willamette River, is located within the Willamette Basin and South Santiam River Sub-Basin. The water quality standards for the Willamette Basin were developed to protect the beneficial uses for the basin. Applicable water quality standards for the Willamette River are found in Oregon Administrative Rules (OAR) and specifically the Santiam River (OAR ). Included in Table 34A as beneficial uses for the Willamette Basin ("Willamette River Tributaries: Santiam River") are: Public domestic water supply, Private domestic water supply, industrial water supply, irrigation, livestock watering, fish and aquatic life (including core cold water habitat and spawning), wildlife and hunting, fishing, boating, water contact recreation, aesthetic quality, and hydroelectric power. These beneficial uses apply broadly to all streams in this section of the Willamette Basin regardless of their specific characteristics. The DEQ does not currently have the resources to define the beneficial uses at afinerscale. RECEIVING WATER QUALITY Rearing and Migration Period Water temperatures affect the biological cycles of aquatic species and are a critical factor in maintaining and restoring healthy salmonid populations throughout the state. It is the policy of the Environmental Quality Commission (EQC) to protect aquatic ecosystems from adverse warming caused by anthropogenic activities. The puipose of the temperature criteria listed in OAR is to protect designated temperature sensitive beneficial uses, including salmonid life cycle stages in waters of the State. According to the DEQ's fish use maps for this stream (OAR , Figures 34A and 34B), the Fish Use Designation at this location is *Core Cold Water and Habitat' (Figure 34A) and the Salmon and Steelhead Spawning Use Designation is 'Salmon and Steelhead Spawning Use: September 1 - June 15' (Figure 34B). The seven-day-average maximum temperature for a stream having 'Core Cold Water and Habitat' use may not exceed 16. C. The seven-dayaverage maximum temperature for a stream having 'Salmon and Steelhead Spawning Use' use may not exceed 13. C. Receiving Stream Water Quality Limited According to the DEQ's 24/26 Integrated Report Database of 33(d) List of Water Quality Limited Water Bodies, this section of Wiley Creek is limited for temperature. The Willamette

7 Page 7 Basin Total Maximum Daily Load (TMDL) also addresses this section as currently water quality limited for temperature (see Table 2). TABLE 2: 33(d) Listings for Wilev Creek Watcrbody Name Wiley Creek Wiley Creek Listed River Mile to7 to 17.2 Parameter Temperature Temperature Season September 1 - June 15, Spawning Year Around (Non-Spawning), Core cold water TMDL Approved Yes Yes Willamette Basin Total Maximum Daily Load - Temperature The Willamette Basin Total Maximum Daily Load (TMDL) was issued as an order by the DEQ on September 21, 26. This TMDL was issued in response to specific streams being included on the DEQ's list of impaired waterbodies ("33(d) List") which was submitted to the United States Environmental Protection Agency (EPA) for approval in 1998 and 22. The federal Clean Water Act (CWA) requires that these listed streams have TMDLs developed to determine appropriate pollutant limits to ensure water quality standards will be met. These Willamette Basin TMDLs provide pollutant Waste Load Allocations (WLAs) for temperature, fecal bacteria, and mercury. Water quality assessments have been performed for each of these parameters and WLAs have been assigned to point sources found to be contributing to the water quality violations. ELP ~ Foster is listed in the South Santiam Subbasin part of the TMDL on page -14. ELP - Foster is incorrectly listed as not discharging "... during May 1 to October 31, the critical period for salmonid spawning and rearing, and therefore will not be given a temperature waste load allocation". The current permit prohibits Outfall 2 from discharging during this time period, but discharge from Outfall 1 is allowed year-round. Since ELP - Foster was not assigned a WLA during TMDL issuance, possible temperature impacts must be assessed by the permit writer. Determining if WLAs are necessary for a source that discharges to tributary streams that did not receive a WLA in the TMDL must be determined according to an outlined process. This is explained in more detail in the section below. Effluent temperature data were available for the period during ELP - Foster's regular discharge period in order to assess temperature impacts under the temperature section for this TMDL. Since Outfall 2 does not discharge during the TMDL period, only Outfall 1 was assessed for temperature. Using the available effluent temperature data, the assessment was conducted in accordance with the Subbasins TMDL WLAs by using aflowchart process contained in Figure 4.4, page 4-86, in the Willamette Basin TMDL as follows: Does the point source discharge warm the river less than.3 C above numeric criterion given 25% of 7Q1 flow? If no, and determination that the discharge is the only source to the waterbody: Allow minimum increase inflowfor dilution up to 1% of 7Q1 lowflow,for a maximum allowable temperature increase of.2 C at the point of maximum impact.

8 Page 8 ELP is the only discharge to Wiley Creek, therefore their allocation allows for a.2 C increase at the point of maximum impact at 1% of the critical 7Q1 flow. The point of maximum impact will occur when the effluent from ELP completely mixes with the stream because they are the only discharge to Wiley Creek. Temperature balance calculations were made using the critical monthly 7Q1, the applicable temperature criterion, and the maximum 3-day average effluent temperature (no 7-day average values were available). Table 3 below contains these values and then provides the maximum allowable flow rate to ensure the temperature in the creek is not increased by more than.2 C. The last column of the table shows theflowrestrictions contained in the existing permit. The existing permit also allows discharging at a greaterflowrate based on equations in the permit that take into account real-time streamflowand temperature. 7Q1 values were calculated from the Wiley Creek near the Foster USGS gauge. Effluent temperature andflowwas taken from monthly reports submitted by the permittee. The permittee measured temperature 3 days per week on consecutive days. The maximum 3-day average was used since a 7-day average could not be calculated. DEQ's fish use maps designate Wiley Creek th as spawning (13 C) from September 1 - June 15 and cold core water (16 C) the remainder of the year. Table 3: Allowable Effluent Flow Month/Period May Jun 1-15 Jun 16-3 Jul - Aug Sep Oct Nov 7Q1 (cfs) day Effluent Temperature (deg C) Temperature Criterion (deg C) Maximum Allowable Effluent Flow (mgd) Maximum Effluent Flow in Existing Permit (mgd) na na na Dilution at 25% of 7Q1 na na The equation used to calculate the maximum allowable effluent flow is shown below: Qe = T r " where: Qe = Allowable effluent flow (mgd) Qr = 7Q1 stream flow (mgd) Tc = Applicable temperature criterion (deg C) Tin = Allowable temperature at complete mix (deg C) Te = Effluent temperature (deg C)

9 Page 9 The calculated allowable effluent flows for each month are greater than those in the current permit. The existingflowrestrictions were retained in the proposed permit since the permittee has demonstrated that they are able to comply with these. An additionalflowlimit of.38 mgd was added to the proposed permit for the June 1-15 time period. The previous permit evaluation report stated there was no reasonable potential to exceed the temperature standard during this time period. More recent flow and temperature data demonstrates there is a potential to exceed the temperature standard. The maximum 3-day average effluent temperature was 24.7 C which equates to a maximum allowable effluent flow of.38 mgd. Recent data (from the past 3 years) shows a 7-day average flow of.717 mgd occurred during this time period. Therefore an effluent flow limit of.38 mgd was added to Schedule A of the permit along with the existing flow limits. Willamette Basin Total Maximum Daily Load - Mercury The Department's 33(d) List indicates the Willamette River is water quality limited for mercury because of excess concentrations found in fish tissues. The DEQ is proposing to perform the TMDL in a two-phased approach. Thefirstphase has been completed and has received EPA approval. Thefirstphase of the TMDL lays out an implementation strategy to gain a better understanding of the fate and transport of mercury in the Willamette Basin. The implementation strategy requires certain point sources (including ELP) to conduct monitoring for mercury and methylmercury and to submit a mercury minimization plan if a source is found to be a significant contributor of mercury. The proposed permit requires the facility to monitor for total and dissolved mercury and methylmercury twice per year using EPA method 1631E. Total and dissolved mercury must achieve a detection limit of.73 ng/l and total and dissolved methylmercury must achieve a detection limit of.599 ng/l unless otherwise approved in writing by the DEQ. The permittee may request the mercury monitoring be eliminated after one year of monitoring if the DEQ is satisfied with the results of the data. If there is wide variability within the results or any indication of potential impacts, the DEQ may require additional monitoring. The TMDL implementation plan may require ELP to develop a mercury reduction plan or include effluent limits if ELP's mercury monitoring indicates that the facility is a significant contributor of mercury loading into the receiving stream. Thermal Plume Analysis The DEQ also evaluated the facility's discharge for compliance with the thermal plume limitations in accordance with OAR (2)(d) to ensure the discharge does not potentially cause adverse effects to salmonids that my result from thermal plumes. Impairment of an active salmonid spawning area where spawning redds are located or likely to be located is prevented or minimized by limiting potential fish exposure to temperatures of 13 C or more for salmon and steelhead. The key anadromous fish that are native to the South Santiam Basin (including Wiley Creek) are spring Chinook salmon and winter steelhead with spring Chinook salmon spawning occurring primarily in September and October (South Santiam

10 Page 1 Watershed Assessment, 2). Although there may be sufficient spawning habitat in Wiley Creek, the limited flow and irrigation diversion could pose a barrier to fish use. Acute impairment or instantaneous lethality is prevented or minimized by limiting potential fish exposure to temperatures of 32 C or more to less than two seconds. Acute impairment requirements are met because all of ELP's effluent temperature data was below this temperature. Thermal shock is prevented or minimized by limiting potential fish exposure to temperatures of 25 C or more to less than 5 percent of the cross section of the water body. Thermal shock requirements are met because all of ELP's effluent temperature data was below this temperature. Migration blockage is prevented or minimized by limiting potential fish exposure to temperatures of 21 C or more to less than 25 percent of the cross section of the water body. An analysis was performed for June, July, and August because the effluent temperature exceeds 21 C at times during these months. The analysis demonstrated there was no reasonable potential to warm the temperature beyond 21 C for more than 25% of the stream width. During June, the maximum temperature after mixing with 25% of the stream was 13.8 C and during July/August the maximum temperature in the stream was 16.7 C. Effluent temperature, 7Q1 stream flow and stream criteria listed in Table 3 were used for the analysis. The analysis was performed using DEQ's temperature reasonable potential analysis (RPA) spreadsheet. Migration blockage requirements are met since it was determined that there was no reasonable potential (See Attachments #1 & 2) MIXING ZONE ANALYSIS Federal regulations (4 CFR ) allow for the use of mixing zones, also known as "allocated impact zones". When using mixing zones, acute toxicity to drifting organisms must be prevented and the integrity of the water body as a whole may not be impaired. Mixing zones allow the initial mixing of waste and receiving water, but are not designed to allow for treatment. EPA does not have specific regulations pertaining to mixing zones. Each state must adopt its own mixing zone regulations that are subject to review and approval by EPA. In States that lack approved mixing zone regulations, ambient water quality standards must be met at the end of the pipe. OAR (1) provides that the DEQ may suspend all or part of the water quality standards in a designated portion of the receiving water to serve as a zone of dilution for wastes and receiving waters to mix thoroughly. The DEQ has developed mixing zone regulations and policy based in part on the acute and chronic aquatic life criteria. Based on EPA guidance and the DEQ's mixing zone regulations, two mixing zones may be developed for each discharge that reflect acute and chronic effects: 1) The acute mixing zone, also known as the "zone of initial dilution" (ZID), and 2) the chronic mixing zone, usually referred to as "the mixing zone". Acute criteria are suspended within the ZID but it is designed to prevent lethality to organisms passing through the ZID. Chronic criteria are suspended within the mixing zone and it is designed to protect the integrity of the entire water body as a whole. The allowable size of the mixing zone should be based upon the relative size of the discharge to the receiving stream, the beneficial uses of the receiving stream, location of other discharges nearby, location of drinking water intakes, and other considerations. More specific guidance is available

11 Page 11 from EPA regarding criteria used in appropriately sizing a ZID. Primarily the ZID must be designed to prevent lethality to drifting organisms. A mixing zone study was submitted to the DEQ on June 12,21 as required by a prior permit. ELP was required to submit a more current study as part of the permit renewal process. The latest mixing zone study was conducted by CH2M Hill in the summer of 21 and followed the 27 DEQ Internal Management Directive (IMD) on Regulatory Mixing Zones. The study included a level II study for Outfall 1 and a level I study for Outfall 2 using the IMD for mixing zones and DEQ received the completed study in March 211. The United States Geological Survey (USGS) gage station (WILEY CREEK NEAR FOSTER, OR) upstream of the discharge at RM 4.4 on Wiley Creek was used for ambient flow rates. The study characterized an appropriate mixing zone within the receiving stream to see if the facility was capable of complying with acute and chronic water quality standards at the edge of the ZID and MZ. The mixing zones of outfall 1 and outfall 2 were modeled using CORMIX 3, an EPA/Cornell University developed model for predicting mixing of effluent discharges with receiving waters. The study results from the modeling are available in the hard copy files in the Salem DEQ office. DEQ reviewed the mixing zone study and determined some of the analyses were overly conservative. DEQ calculated applicable dilution values to apply at the edge of the ZID and mixing zone of 4 and 7 respectively. This analysis is contained in an October 2, 211 temperature analysis internal memo. Schedule A condition 2 of the current permit states: Except as provided for in OAR , no wastes shall be discharged and no activities shall be conducted which violate Water Quality Standards as adopted in OAR except in the following defined mixing zone: The allowable mixingzone is that portion of Wiley Creek where the effluent mixes with 25 percent of the stream flow bat in no case shall it extend farther than seven (7) feet from the northeast bank of the creek and from a point 2 feet upstream to 25 feet downstream from the discharge points for Outfalls 1 and 2. Schedule A of the proposed permit retains similar language with the addition of ZID language. The proposed permit contains the following mixing zone language: No wastes may be discharged or activities conducted that cause or contribute to a violation of water quality standards in OAR applicable to the Willamette basin except as provided for in OAR and the following regulatory mixing zone: The allowable mixingzone for Outfall 1 is defined as that portion of Wiley Creek where the effluent mixes with 25 percent of the stream flow but in no case should it extend more than 25 feet downstreamfromthe outfall The Zone of Immediate Dilution (ZID) must be

12 Page 12 defined as that portion of Wiley Creek where the effluent mixes with 1 percent of the stream flow but in no case should it extend more than 25 feet downstreamfromthe outfall The allowable mixing zone for Outfall 2 is defined as that portion of Wiley Creek where the effluent mixes with 25 percent of the stream flow but in no case should it extend more than 25 feet downstreamfromthe outfall The Zone ofimmediate Dilution (ZID) must be defined as that portion of Wiley Creek where the effluent mixes with 1 percent of the stream flow but in no case should it extend more than 25 feet downstream from the outfall ZID language was inadvertently left out of the current permit, so the language was added into the proposed permit. PERMIT LIMITS There are two categories of effluent limits for NPDES permits: 1) Technology-based effluent limits (TBEL) and 2) Water quality-based effluent limits (WQBEL). Technology-based effluent limits define a minimum level of treatment using readily-available technology. EPA establishes for technology-based effluent limits through Effluent Limitation Guidelines (ELGs) specific industrial categories. Technology-based effluent limits define a minimum level of treatment using readily-available technology. If there are no applicable ELGs, best professional judgment may be used. By contrast, water quality-based effluent limits are developed independent of the available treatment technology and, instead, take into account the water quality and quantity of the receiving stream. Water quality-based effluent limits are typically more stringent than technology-based permit limits when the receiving stream is small, is water quality-limited or shows evidence of impairment. When renewing/reissuing a permit, a permit writer typically evaluates the existing limits in the permit against changes to technology based standards and water quality standards that may have occurred during the permit term. With some exceptions, the anti-backsliding provisions (described in CFR (1)) do not allow relaxation of effluent limits in renewed/reissued permits. The most stringent of the existing or new limits must be included in the new permit. Existing Permit Limits The following are the permit limits contained in the current permit: 1. Waste Discharge Limitations not to be exceeded after permit issuance, a. Outfall Number 1 (Log Pond Discharge)

13 Page 13 Flow, gpm ph Oil & Grease Floating Solids Debris* Parameter Limitations As low as practicable as necessitated by precipitation (see Note 1) Shall be within the range of Shall not exceed 1 mg/1 No visible discharge No discharge permitted b. Outfall Number 2 (Millyard Runoff) (1) No discharge allowed from May 1 to October 31, unless necessitated by excess precipitation. Parameter Limitations Flow, gpm PH Oil & Grease Floating Solids Debris* As low as practicable as necessitated by precipitation Shall be within the range of Shall not exceed 1 mg/1 No visible discharge No discharge permitted * Debris is defined as anything that will be retained by a 5 mesh screen 2. Except as provided for in OAR , no wastes shall be discharged and no activities shall be conducted which violate Water Quality Standards as adopted in OAR except in the following defined mixing zone: The allowable mixing zone is that portion of Wiley Creek where the effluent mixes with 25 percent of the stream flow but in no case shall it extend farther than seven (7) feet from the northeast bank of the creek and from a point 2 feet upstream to 25 feet downstream from the discharge points for Outfalls 1 and No process wastewater shall be discharged from the barking process to waters of the state. No adhesive or adhesive wastewater shall be discharged to waters of the state. Notes: 1. Effluent flow rate is restricted during the following months as indicated below: Jun 15-3: Flow on any given day is restricted to 36, gpd. If the permittee needs to discharge more than this, they must meet the conditions described in note 1.a. Data necessary to demonstrate compliance with these conditions must be submitted as part of the monthly discharge monitoring report.

14 Page 14 Jul - Aug: September: October: Flow on any given day is restricted to 27,8 gpd. If the permittee needs to discharge more than this, they must meet the conditions described in note La. Data necessary to demonstrate compliance with these conditions must be submitted as part of the monthly discharge monitoring report. Flow on any given day is restricted to 25,2 gpd. If the permittee needs to discharge more than this, they must meet the conditions described in note Lb or l.c (whichever is applicable). Data necessary to demonstrate compliance with these conditions must be submitted as part of the monthly discharge monitoring report. Flow on any given day is restricted to 5,4 gpd. If the permittee needs to discharge more than this, they must demonstrate to the Department that they meet the conditions described in note 1.b or l.c (whichever is applicable). Data necessary to demonstrate compliance with these conditions must be submitted as part of the monthly discharge monitoring report. a. Permittee must demonstrate the discharge will not increase 25% of the receiving stream by more than.3 C over the criterion using equation 1. Equation 1 Q e T e +.25Q r T c c -_T C _S.3 C a+.25a where: Q e = Effluent flow rate (cfs) Q r = Wiley Creek flow rate upstream from discharge (cfs) T e = Effluent temperature ( C) T r = Wiley Creek temperature upstream from discharge ( C) T c = Applicable temperature criterion (13 C or as superseded) If the ambient stream temperature is above 12.8 C, permittee must demonstrate the discharge will not increase 25% of the receiving stream by more than.3 C over the criterion using equation 1. If the ambient stream temperature is 12.8 C or lower, permittee must demonstrate the discharge will not increase the temperature of the receiving stream by more than.5 C using equation 2: Equation 2 Q.T. + g-r. -T<.5'C Qe+Qr

15 Page 15 TECHNOLOGY-BASED EFFLUENT LIMITS In January 1981, EPA promulgated effluent guidelines for wastewater discharges from timber products processing directly into waters of the state and are contained in 4 CFR Timber Products Processing Point Source Category. National effluent limitation guidelines (ELGs) were established by EPA to require a minimum level of treatment for industrial or municipal sources using available technology. Subpart A - Barking Subcategory and Subpart I - Wet Storage are applicable to the ELP facility. The limitations that apply to all mechanical debarking installations is, "There shall be no discharge of process wastewater pollutants into navigable waters." The facility uses mechanical debarking without water so no wastewater is created in the process. The limitations that apply for facilities that do wet decking are, "There shall be no debris discharged and the ph shall be within the range of 6. to 9.." The limits for debris and ph are retained in the proposed permit. The term "debris" is defined in 4 CFR 429 as "woody material such as bark, twigs, branches, heartwood or sapwood that will not pass through a 2.54 cm (1. in) diameter round opening and is present in the discharge from a wet storage facility." As defined in 4 CFR 429, the term "process wastewater" specifically excludes non-contact cooling water, material storage yard runoff (either raw material or processed wood storage), boiler blowdown, and wastewater from washout of thermal oxidizers or catalytic oxidizers, wastewater from biofilters, or wastewater from wet electrostatic precipitators used upstream of thermal oxidizers or catalytic oxidizers. WATER QUALITY-BASED EFFLUENT LIMITS EPA has developed a methodology called reasonable potential analysis (RPA) for determining if there is a reasonable potential for a discharge to cause or contribute to violations of water quality standards. RPA takes into account effluent variability, available dilution (if applicable), receiving stream water quality, aquatic health water quality standards, and human health water quality standards. DEQ has adopted EPA's methodology for RPA. If the RPA results indicate that there is a potential for the discharge to cause or contribute to exceedances of water quality standards, the methodology is then used to determine permit limits for the discharge so as to not cause or contribute to violations of water quality standards. Ammonia A reasonable potential analysis (RPA) for ammonia was performed by evaluating effluent data in a DEQ spreadsheet. The RPA (See Attachment #3) for ammonia indicated that there is no reasonable potential for the discharge to cause or contribute to an excursion above the water quality criteria for ammonia during the year around discharge period. As a result, the proposed permit will not include an ammonia limit. Oil & Grease Oil & grease DMR data since the last permit renewal was reviewed. All oil & grease data in the permit was non-detect with a detection limit at 5 mg/1 for both outfalls. The existing limit of 1

16 Page 16 mg/1 was retained in the proposed permit. This concentration is approximately where oil and grease become visible on the surface of water. Visibility of oily sheen is a water quality-based narrative criterion (OAR (14)). Biochemical Oxygen Demand Biochemical Oxygen Demand (BOD) DMR data from were reviewed. There are no industrial facility standards for BOD, but ELP's data was similar to what is required of the minimum design criteria for sewage waste facilities of the Willamette Basin. Most of the data results were <3 mg/1 for BOD 5. No BOD limits were added to the proposed permit. ph The ph is a measure of how acidic or basic a solution is. At a ph of 7. s.u. the solution is considered neutral. The purpose of an in-stream water quality ph standard is generally the protection of aquatic life since most aquatic organisms can only tolerate a fairly narrow range around 7. s.u. The Willamette River Basin water quality standard for ph is 6.5 to 8.5, found in OAR (l)(a). The DEQ reviewed ELP's data contained in the monthly DMR reports and all outfall data was within the basin standard of 6.5 to 8.5. The current effluent limits for ph are 6. to 9. for Outfall 1. The water quality standard for ph does not have to be met within the permittee's mixing zone. The DEQ determined there was no reasonable potential to violate the basin ph standard at the edge of the mixing zone (See Attachment #4). The DEQ is proposing to retain the current ph limits in this permit renewal. The DEQ considers the proposed permit limits to be protective of the water quality standard. Since Outfall 2 did not discharge, there was no ph data available for analysis. Temperature As discussed above, an assessment was conducted in accordance with the South Santiam Subbasin TMDL. Effluent flow limits were developed to insure there is no reasonable potential for the discharge to violate the temperature standard. Solids Solids can be of concern because of its negative impact on receiving streams. Solids can cause turbidity and siltation problems that decrease fish spawning habitat. Its presence can also decrease oxygen and sunlight availability to aquatic life. In addition, metals toxic to aquatic life are often associated with solids. The DEQ is retaining the current limit of "no visible discharge" offloatingsolids and "no discharge permitted" for debris. This limit is based on a best management practice approach since there is no total suspended solids water quality standard for industrial facilities. Other Pollutants / Toxics DEQ reviewed the toxics data submitted with the permit application. The application only requires one data value to be submitted for each pollutant. Most of the results were below detection limits. All of the pollutants that were detected, with the exception of iron, were at or

17 Page 17 below the water quality criteria. Iron was slightly above the criterion, but with available dilution at the edge of the mixing zone and additional effluent samples it's unlikely that there would be a reasonable potential to violate the iron water quality criterion. Additional toxics monitoring is being required in the proposed permit according to DEQ's RPA IMD. This monitoring will provide DEQ enough data to perform a robust RPA after two years of permit issuance. This RPA could result in DEQ requiring additional effluent and ambient monitoring at the facility. Antidegradation An Antidegradation Review (see OAR ) was performed for this discharge. The DEQ has determined there was no increase in pollutant loadings from this facility and therefore recommends proceeding with this permit action (see Attachment #5). Permit renewals with the same discharge loadings as the previous permit are not considered to lower water quality from the existing condition. The EPA NPDES Permit Rating Work Sheet was also filled out with the facility's information. The work sheet is used for rating industrial dischargers as a 'minor' or 'major' facility. The ELP facility was determined to be a 'minor' discharger (see Attachment #6). PERMIT DRAFT DISCUSSION Face Page The face page provides information about the permittee, description of the wastewater, outfall locations, receiving stream information, permit approval authority, and a description of permitted activities. The permittee is authorized to construct, install, modify, or operate a wastewater collection, treatment, control, and disposal system. The permit allows discharge to Wiley Creek through Outfalls 1 and 2 within limits set by Schedule A and the following schedules. It prohibits all other discharges. In accordance with state and federal law, NPDES permits will be effective for a fixed term not to exceed 5 years. Upon issuance, this permit will be effective for no more than 5 years. Schedule A - Waste Discharge limitations The proposed effluent limits for the discharge (outfalls 1 & 2) are as follows: 1. Waste Discharge Limitations not to be exceeded after permit issuance, a. Outfall Number 1 (Log Pond Discharge) ^x> v ' ;^^^-w:.;raranieter: ;v^'/:v > < Flow, gallons per day (GPD) ph Oil & Grease Floating Solids Debris* Liniitations -&.i As low as practicable as necessitated by precipitation (see Note 1 forflowlimitations) Must be within the range of Must not exceed 1 mg/1 No visible discharge No discharge permitted b. Outfall Number 2 (Millyard Runoff)

18 Page 18 (1) No discharge allowed from May 1 to October 31, unless necessitated by excess precipitation. (2) November 1 - April 3 only if necessitated by excess precipitation: Parameter Flow, GPD PH Oil & Grease Floating Solids Debris* :.:.'.5V_ :.. : ;;^CiiKiitftiioii9/ As low as practicable as necessitated by precipitation Must be within the range of Must not exceed 1 mg/1 No visible discharge No discharge permitted * Debris means woody material such as bark, twigs, branches, heartwood or sapwood that will not pass through a 2.54 cm (1. in) diameter round opening 2. Permittee is prohibited from discharging wastes or activities that cause or contribute to a violation of water quality standards in OAR applicable to the Willamette basin except as provided for in OAR and the following regulatory mixing zone: The allowable mixing zone for Outfall 1 is defined as that portion of Wiley Creek where the effluent mixes with 25 percent of the stream flow but in no case should it extend more than 25 feet downstream from the outfall. The Zone of Immediate Dilution (ZID) is defined as that portion of Wiley Creek where the effluent mixes with 1 percent of the stream flow but in no case should it extend more than 25 feet downstream from the outfall. The allowable mixing zone for Outfall 2 is defined as that portion of Wiley Creek where the effluent mixes with 25 percent of the stream flow but in no case should it extend more than 25 feet downstream from the outfall. The Zone of Immediate Dilution (ZID) is defined as that portion of Wiley Creek where the effluent mixes with 1 percent of the stream flow but in no case should it extend more than 25 feet downstream from the outfall. 3. Permittee is prohibited from discharging log debarking process wastewater to waters of the state. Mechanical debarking, which is a waterless process, is therefore exempt from this issue since no wastewater is produced. Notes: 1. Effluent flow rate is restricted during the following months as indicated below: Jun 1-14: Jun 15-3: Jul - Aug: Flow is restricted to 38, gpd unless the conditions in Note 1.b. or l.c. are met. Permittee may only exceed the 38, gpd limit if it submits the data necessaiy to demonstrate compliance with the Note 1.b. or 1.c. conditions with its discharge monitoring report. Flow is restricted to 36, gpd unless the conditions in Note La. are met. Permittee may only exceed the 36, gpd limit if it submits the data necessary to demonstrate compliance with the Note 1.a. conditions with its discharge monitoring report. Flow is restricted to 27,8 gpd unless the conditions in Note 1.a. are met. Permittee may only exceed the 27,8 gpd limit if it submits the

19 Page 19 data necessaiy to demonstrate compliance with the Note 1.a. conditions with its discharge monitoring report. September: October: Flow is restricted to 25,2 gpd unless the conditions in Note 1.b. or 1.c. are met. Permittee may only exceed the 25,2 gpd limit if it submits the data necessaiy to demonstrate compliance with the Note 1.b. or 1.c. conditions with its discharge monitoring report. Flow is restricted to 5,4 gpd unless the conditions in Note Lb. or l.c. are met. Permittee may only exceed the 5,4 gpd limit if it submits the data necessaiy to demonstrate compliance with the Note Lb. or lc. conditions with its discharge monitoring report. a. Permittee may discharge above the applicableflowlimit if it demonstrates the discharge will not increase 25% of the receiving stream by more than.3 C over the criterion using equation 1: Equation! ^ ± ^ ^ Q. +.25Q, where: Q e = Effluent flow rate (cfs) Q r = Wiley Creekflowrate upstream from discharge (cfs) T e = Effluent temperature ( C) T r = Wiley Creek temperature upstream from discharge ( C) T c = Applicable temperature criterion (13 C or as superseded) b. If the ambient stream temperature is above 12.8 C, permittee must demonstrate the discharge will not increase 25% of the receiving stream by more than.3 C over the criterion using equation 1. c. If the ambient stream temperature is 12.8 C or lower, permittee must demonstrate the discharge will not increase the temperature of the receiving stream by more than.5 C using equation 2: Equation 2 Qe+Qr -T. _<.5 C Most of the permit limits remain the same in the proposed permit. The mixing zone language was updated and an additional flow limit for June 1-14 was added. Schedule B - Minimum Monitoring and Reporting Requirements Schedule B describes the minimum monitoring and reporting necessaiy to demonstrate compliance with the conditions of this permit. The authority to require periodic reporting by permittees is included in ORS (5). Self-monitoring requirements are the primary means of ensuring that permit limits are being met. Other parameters may also need to be monitored when insufficient data exist to establish a limit, but where there is a potential for a water quality concern.

20 Page 2 The permittee is required to have a laboratory Quality Assurance/Quality Control program. DEQ recognizes that some tests do not accurately reflect the performance of a treatment facility due to quality assurance/quality control problems. These tests should not be considered when evaluating the compliance of the facility with the permit limits. Thus, DEQ proposes a statement in the opening paragraph of Schedule B recognizing that some test results may be inaccurate, invalid, or do not adequately represent the facility's performance and should not be used in calculations required by the permit. All required monitoring and reporting has been completed. Both Outfalls 1 and 2 have a V- notch weir installed for measuring flow. Outfall 1 measures flow primarily with an ultrasonic Stevens AXSYS MPU total flow meter. The initial installation (on June 16,26) and calibration documentation was provided to DEQ at the time of inspection. The Extech Model ph meter is used for measuring ph and temperature. A back-up thermometer is also used for checking temperature reading accuracy. Buffer solutions are used to calibrate the ph for each weekly monitoring event. Most NPDES monitoring is performed/analyzed on site. The exception is monitoring samples for BOD5 which are sent to the Weyerhaeuser laboratory located in Federal Way, Washington. Samples sent to Washington are put on ice in a cooler for transport. The Federal Way laboratory has a Quality Assurance / Quality Control (QA/QC) document which was also available on-site at the ELP facility. An instruction manual and operating procedures document is used for the regular monitoring conducted on site. The QA/QC language in Schedule B was updated. The language "unless otheiwise approved in wilting by the Department" was removed from Schedule B of the permit. Below is a discussion of some of the minimum monitoring requirements contained in the proposed permit. Outfalls 1 & 2 (Effluent) Monitoring Monitoring changesfromthe current permit include: Flow reported as Gallons per Day (GPD) rather than Gallons per Minute (GPM) Addition of monitoring for metals, cyanide, phenols, and hardness Addition of monitoring for total and dissolved mercury for TMDL requirements Addition of monitoring for volatile, acid-extractable, base/neutral, and pesticide compounds Addition of rainfall measurements or NOAA data when Outfall 2 is discharging Addition of notes regarding quantitation levels, detection limits, toxics frequencies, composite sampling, and mercury sampling requirements Wiley Creek Monitoring Clarification was also added to the notes in Schedule B based on a January 25,26 DEQ Permit Action Letter that states that so long as the effluentflowrate limits are not exceeded, no temperature monitoring of Wiley Creek is required.

21 Page 21 Rainfall Addition of rainfall measurement or NOAA data was added Reporting The reporting period is the calendar month. Discharge monitoring reports must be submitted to the DEQ monthly by the 15th day of the following month, including "no discharge" reports if any. Schedule C - Compliance Conditions The Clean Water Act requires that state-issued individual NPDES permits include effluent limits as stringent as necessaiy to meet water quality standards. Sometimes a permittee cannot immediately comply with new or newly applied water quality-based effluent limits upon the effective date of the permit because the permittee needs time to perform substantial modifications to their facility or processes in order to meet the new limits. Depending upon the circumstances, NPDES permits may include a series of required steps and deadlines (i.e., a compliance schedule), which upon completion, enables the permittee to meet the permit's water quality-based effluent limits (see 4 CFR and OAR (16)). Interim effluent permit limits may also be included in certain circumstances. The current permit contained two compliance conditions with compliance deadlines: Submittal of an evaluation of whether or not the treatment facilities can consistently comply with the Waste Load Allocation (WLA) and all other requirements of the TMDL for temperature. If the evaluation indicates that the facilities cannot consistently comply with the TMDL, then the permittee shall complete an additional schedule necessary for compliance with the TMDL. Thefinalcondition requires the permittee to meet the compliance dates established in this schedule or notify the DEQ within fourteen days following any lapsed compliance date. DEQ notified ELP of the TMDL approval on October 17, 26. DEQ received a timely reply letter on February 26, 27, which indicated that the facility can consistently comply with TMDL temperature requirements. Therefore, the compliance schedule is fulfilled. There are no compliance schedules in the proposed permit. Schedule D - Special Conditions The facility was in compliance with Schedide D at the time of the last site inspection. A spill plan document was available for viewing during the inspection. The log pond was cleaned after DEQ approval in August 29 (outfall area only), May 22, and May The proposed permit includes seven special conditions. The requirements include: