DEQ. rn^sx. National Pollutant Discharge Elimination System

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1 rn^sx National Pollutant Discharge Elimination System PERMIT EVALUATION AND FACT SHEET DEQ State of Oregon Department of Environmental Quality March 18,2004 Oregon Department of Environmental Quality Western Region 750 Front St NE, Suite 120 Salem OR (503) Permittee: Permit Information: Source Contact: Source Location: LLID Receiving Stream Proposed Action: Source Category Permit Writer: International Paper Company PO Box 854 Gardiner OR File Number: Permit Number: Expiration Date: 10/31/01 EPA Reference Number: OR Gary Ferguson (541) Mill Manager US Highway 101 Gardiner OR D Pacific Ocean Renew Permit Application Number: Date Received: March 20,2001 NPDES Major - Industrial Steve Schnurbusch (503) ext. 284 Senior Water Quality Permitting Specialist INTRODUCTION The existing National Pollutant Discharge Elimination System (NPDES) Permit expired on October 31, The Department received renewal application number from International Paper Company on March 20, As this renewal application was submitted to the Department in a timely manner prior to the expiration date of the permit, the permit shall not be deemed to expire until final action has been taken on the renewal application as per OAR

2 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 limitations Schedule B - Minimum monitoring and report requirements Schedule C - Compliance conditions and schedules Schedule D - Special conditions Schedule F - General conditions These sections are discussed in detail in this document. This permit is a joint federal and state permit and subject to federal and state regulations. The Clean Water Act, the Code of Federal Regulations, and numerous guidelines of the Environmental Protection Agency provide the federal permit requirements. The Oregon Revised Statutes, Oregon Administrative Rules, and policies and guidelines of the Department of Environmental Quality provide the state permitting requirements. FACILITY DESCRIPTION International Paper Company (IP) owns a pulp and paper mill producing unbleached Kraft paper for use as linerboard in Gardiner, Oregon (see figure 1). The facility ceased production on December 14, All maintenance lay-up and clean-up projects were terminated on February 10, IP intends to keep their permit in force until such time as afinaldecision is made regarding the future of the facility. The facility is currently treating their landfill leachate and discharging it through their diffuser into the Pacific Ocean. The leachate flow rate is about 20,000 gallons per day. In addition to the leachate, the facility continuously pumps water from Siltcoos and Tahkenitch Lakes to maintain enough flow through the diffuser to prevent it from being buried by sand. The total flow through the outfall is about 2 million gallons per day (mgd). Prior to shut down, the facility was producing about 1000 tons of paper per day with an average effluent flow rate of about 9 mgd. When the plant is operating, wastewater is generated from the power house, the pulp mill, the paper mill, the caustic plant, landfill leachate and storm water. Wastewater from the power house, pulp and paper mill, caustic plant, east landfill leachate, and storm water enters a 160 foot diameter clarifier (about 2,000,000 gallons). After clarification, the water flows through a carbon dioxide gas neutralization tank. Then it flows into the aerated stabilization basin (ASB) for further treatment. West and South landfill leachate flows directly into the ASB for treatment, The ASB is a ten acre basin with 8-60 HP aerators located equally to ensure adequate mixing and aeration. Wastewater from the ASB discharges to outfall 001 into an emergency holding pond (approximately nine acres), Non-contact cooling water from the pulp mill discharges directly into the emergency holding pond. Wastewater from the emergency holding pond discharges to outfall 002 into the Pacific Ocean about 3000 feet offshore.

3 Figure 1: Topo View Groundwater Issues The primary groundwater concerns regarding this facility are associated with their landfills. IP Gardiner has a solid waste permit with the Department that addresses the ground water issues associated with the landfills, Storm water General NPDES permits for stormwater are required for facilities of this type if stormwater is collected and discharge from the plant site. Because this facility discharges stormwater from the plant site, a separate stormwater permit has been issued. Stormwater discharges are not addressed in this permit. Sludge Management No sludge is being generated during shutdown. When the facility is in full production, solids generated in the clarifier are dewatered and eventually beneficially applied according to their sludge management plan. Lime mud that is generated from their caustic plant is sent to the landfill. Prior to startup of the mill, the facility will be required to submit an updated sludge management plan for the Department's approval. PERMIT HISTORY Compliance history IP Gardiner was issued a civil penalty for non-permitted discharge of wastewater on April 8, The amount of the penalty was $4800.

4 Since 1998, IP Gardiner was issued notices of non-compliance (NON) for the following violations: 1, Violating their ph limit on October 29, Discharge of hydraulic oil on December 8, 1998 The facility was last inspected on August 27,2003 and the facility was in compliance with their permit. RECEIVING WATER Receiving Stream Water Quality IP discharges effluent to the Pacific Ocean about 3300 feet offshore from Winchester Bay. The Pacific Ocean is not water quality limited in this area and there are no known adverse water quality impacts associated with this discharge. Mixing Zone Analysis Federal regulations (40 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 waterbody 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. The Department has adopted the two-number aquatic life criteria and developed mixing zone regulations with respect to that. The regulations are primarily narrative and essentially require the permit writer to use best professional judgment in establishing the size of the mixing zone. Based on EPA guidance and the Department'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". The acute mixing zone is designed to prevent lethality to organisms passing through the ZID. The chronic mixing zone 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 to the same water body, location of drinking water intakes, and other considerations, More specific guidance is available from EPA regarding criteria used in appropriately sizing a ZID. Primarily the ZID must be designed to prevent lethality to drifting organisms. The existing permit allows for the following mixing zone at outfall 002: The allowable mixing zone shall consist of that portion of the Pacific Ocean which has an origin at the up current edge of the visible plume and consists of an isosceles triangle with its axis parallel to the current, with a height of 1500 feet and with an included angle of 55. This mixing zone description is somewhat ambiguous as it is difficult to determine where the visible plume is located. The Department is proposing to clarify the description of the mixing zone and reduce the size of it since the facility is currently shut down. The Department is proposing to reduce the size of the mixing zone to be a radius of 500 feet from the point of discharge. Dilution modeling was performed on this outfall in The modeling is outdated and lacks critical information the Department would require for a new mixing zone study. The proposed permit will

5 require the permittee to submit a mixing zone study to the Department prior to start up of the mill. The permittee will be required to submit a mixing zone study scope of work to the Department for approval prior to conducting the mixing zone study. Upon completion of the study, the Department may reopen the permit if necessary to change permit limits or incorporate new ones. A review of the effluent quality data submitted in the March 2001 application indicates cadmium, copper, cyanide, lead, and zinc are parameters of concern when the plant is producing pulp and paper. The primary concern is with acute toxicity. The existing permit does not contain a zone of initial dilution (acute mixing zone) which requires the source to meet all acute criteria at the end of pipe. Upon completion of the mixing zone study, IP Gardiner may request a modification of the permit to incorporate a zone of initial dilution. PERMIT LIMITATIONS Two categories of effluent limitations exist for NPDES permits: 1) Technology based effluent limits, and 2) Water quality based effluent limits, Technology based effluent limits are developed by applying the national effluent limitation guidelines (ELGs) established by EPA for specific industrial categories. Technology based effluent limits were established to require a minimum level of treatment for industrial or municipal sources using available technology. Water quality based effluent limits are designed to be protective of the beneficial uses of the receiving water and are independent of the available treatment technology. In addition, when performing a permit renewal, there are existing permit limits. These may be technology-based limits, water quality-based limits, or limits based on best professional judgement. When renewing a permit, the most stringent of technology based, water quality based, and existing effluent limits apply. Existing Permit Limits The existing permit limits for IP Gardiner's permit are as follows: Parameter Outfall 001 BODS TSS Daily Maximum (lb/day) 11,100 23,400 Daily Average (lb/day) 5,500 11,700 Outfall 002 ph Shall not be outside the range of Technology-Based Effluent Limits IP Gardiner's facility falls under EPA's Timber Products category 40 CFR 430. They produce unbleached Kraft making them subject to Subpart C - Unbleached Kraft Subcategory. They also use wastepaper in their process which subjects them to Subpart J - Secondary Fiber Non-Deink Subcategory. The effluent limits guideline for both subcategories limit BOD 5 and TSS based on the amount of production. The production associated with Subpart C is 1000 dry tons per day and with subpart J is 40 dry tons per day, The applicable technology-based effluent limits are listed in table 1. Table 1: Effluent Limit Guidelines Pollutant Daily Maximum (lb/1000 lb of product) Daily Average (lb/1000 Ib of product) Subpart C BODS TSS ph Shall be within the range of 6.0 to 9,0

6 Subpart J BOD5 TSS ph Shall be within the range of 6.0 to The limits are calculated as follows: Subpart C: BOD Daily Max: 1000 tons/day x 5.6 lb BOD/day x 2000 tons/10001b = 11,200 lb BOD/day Daily Avg: 1000 tons/day x 2.8 lb BOD/day x 2000 tons/looolb = 5,600 lb BOD/day TSS Daily Max: 1000 tons/day x 12 lb TSS/day x 2000 tons/looolb = 24,000 lb TSS/day Daily Avg: 1000 tons/day x 6 lb TSS/day x 2000 tons/10001b = 12,000 lb TSS/day Subpart J: BOD Daily Max: 40 tons/day x 3 lb BOD/day x 2000 tons/1000 lb = 240 lb BOD/day Daily Avg: 40 tons/day x 1.5 lb BOD/day x 2000 tons/1000 lb = 120 lb BOD/day TSS Daily Max: 40 ton/day x 5 lb TSS/day x 2000 tons/1000 lb = 400 Ib TSS/day Daily Avg: 40 ton/day x 2.5 lb TSS/day x 2000 tons/1000 lb = 200 lb TSS/day Final Limits: BOD Daily Max = 11,200 lb/day lb/day = 11,440 lb BOD/day BOD Daily Avg = 5,600 lb/day lb/day = 5,720 lb BOD/day TSS Daily Max = 24,000 lb/day lb/day = 24,400 lb BOD/day TSS Daily Avg = 12,000 lb/day lb/day - 12,200 lb TSS/day Water Quality-Based Effluent Limits With the mill not running, the Department does not consider the discharge to be causing or contributing to an exceedance of any water quality criteria. The only pollutant that is likely to be above the water quality criterion is temperature. However, with the mill shutdown, the effluent temperature is expected to be only slightly greater than the ambient temperature. The temperature standard allows dischargers to cause an increase of 0.3C above ambient at the edge of the mixing zone. This discharge will easily meet this part of the standard because of their low effluent temperatures and large amount of dilution available, Prior to the mill beginning operations again, a mixing zone study will need to be submitted to the Department for review. At that time, the Department will conduct a full reasonable potential analysis to determine if there are any pollutants of concern. If so, the Department may reopen the permit to incorporate new permit limits and or conditions,

7 ph The permit requires the effluent ph to be within the range of The marine instream water quality standard for ph is 7,0-8,5. A ph mixing analysis demonstrates enough buffering capacity exists in the ocean to insure the marine criteria will be met at the edge of the mixing zone. Whole Effluent Toxicity WET tests have been reviewed consistently since the last permit renewal. WET test results indicate their discharge is not acutely or chronically toxic. The proposed permit will require the same WET testing frequency if the facility begins production again, No WET testing will be required with the facility operating in its current state. Antidegradation An Antidegradation Review was performed for this discharge. The Department has determined the proposed discharge complies with the Antidegradation Policy for Surface Waters found in OAR (see Appendix A). PERMIT DRAFT DISCUSSION Face Page The face page of the permit describes the legal name of the facility, the type of waste generated at the facility, and the facility's outfall location where the wastewater enters into the State's receiving waters. Schedule A, Waste Discharge Limitations The wastewater permit limits were determined using the most stringent limits generated from the technology based limits, water quality based limits, and existing limits. The development of these limits is described above. The most stringent limits are the limits in the existing permit and are contained in the proposed permit as follows; 1. Waste Discharge Limitations not to be exceeded after permit issuance. a. Outfall 001 (to the emergency holding pond) Effluent Loadings Parameter BOD 5 TSS Monthly Average Ibs/dav Daily Maximum Ibs/day b. Outfall 002 fto the Pacific Ocean) Other Parameters m. Shall not be outside the range of

8 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 and zone of initial dilution: The mixing zone shall consist of that portion of the Pacific Ocean extending from the ocean floor to the surface and 500 feet laterally in all directions from the diffuser outfall. Schedule B - Minimum Monitoring and Reporting Requirements 1. Minimum Monitoring and Reporting Requirements to be met after permit issuance (unless otherwise approved in writing by the Department). The permittee shall monitor the parameters as specified below at the locations indicated, The laboratory used by the permittee to analyze samples shall have a quality assurance/quality control (QA/QC) program to verify the accuracy of sample analysis. If QA/QC requirements are not met for any analysis and cannot be re-analyzed, then the results shall be included in the report, but not used in calculations required by this permit. When the permittee cannot re-analyze the existing sample, then they shall re-sample in a timely manner for parameters failing the QA/QC requirements, analyze the samples, and report the results. a. Outfall 001 : m:mmmm!]^^m^wcmm\^::::: ' : ' :: ' ::]: - : m : Flow BOD 5 (See Note 1) TSS (See Note 1) ph (See Note 1) Turpentine Flow rate b. Outfall 002 Item or Parameter Flow ph Temperature Color (See Note 1) VOC Metals: Iron, Cadmium, Copper, Lead, Zinc (See Note 1) Chronic WET test (See Note 1) Minimum Frequency Daily Daily, when discharging Minimum Frequency Daily Weekly Quarterly 2/Year (approximately 6 months apart) Type of Sample Continuous 24-hour composite 24-hour composite Composite Measurement Type of Sample Continuous Composite Grab Grab Grab 24-hr composite 24-hr composite c. Pulp/Paper Production (See Note 1) Item or Parameter Pulp Produced (New Pulp and Waste) Paper Minimum Frequency - Type of Sample Average air-dry tons/day for reporting period Off-the-machine production for reporting period in air dry tons/day

9 Sludge Monitoring (See Note 1) Item or Parameter Average depth of sludge in pond three 3. Reporting Procedures Minimum Frequency 1/year (approximately 12 months apart) Type of Sample Measurement a. 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. b. For compliance, the analytical results below the level of detection should be reported as Not Detected and the detection limit listed. Notes: 1, Monitoring for these parameters is only required when the pulp and paper mill is in operation. Schedule C, Compliance Schedules and Conditions 1. The first condition requires the permittee to conduct and have approved by the Department a mixing zone study prior to start up of the facility. The condition states the based on the results of the mixing zone study, the Department may reopen the permit if necessary. 2. The second condition requires the permittee to visually inspect the area surrounding the ocean outfall prior to start up and once during each calendar year thereafter, 3. The third condition requires the permittee to submit an updated sludge management plan to the Department for approval prior to start up of the facility. 4. Thefinalcondition states the permittee is expected to meet the compliance dates which have been established in this schedule. Schedule D - Special Conditions 1, The first condition requires the permittee to implement a contingency plan for prevention and handling of spills and unplanned discharges and to maintain a continuing employee education program, 2. The final condition describes the WET testing requirements in detail. Schedule F, NPDES General Conditions AH NPDES permits issued in the State of Oregon contain certain conditions that remain the same regardless of the type of discharge and the activity causing the discharge. These conditions are called General Conditions. These conditions can be changed or modified only on a statewide basis. The latest edition of the NPDES General Conditions is December 1, 1995 and this edition is included as Schedule F of the draft permit.

10 Section A contains standard conditions which include compliance with the permit, assessment of penalties, mitigation of noncompliance, permit renewal application, enforcement actions, toxic discharges, property rights and referenced rules and statutes. Section B contains requirements for operation and maintenance of the pollution control facilities. This section includes conditions for proper operation and maintenance, duty to halt or reduce activity in order to maintain compliance, bypass of treatment facilities, upset conditions, treatment of single operational events, overflows from wastewater conveyance systems and associated pump stations, public notification of effluent violation or overflow, and disposal of removed substances. Section C contains requirements for monitoring and reporting. This section includes conditions for representative sampling, flow measurement, monitoring procedures, penalties of tampering, reporting of monitoring results, additional monitoring by the permittee, averaging of measurements, retention of records, contents of records, and inspection and entry. Section D contains reporting requirements and includes conditions for reporting planned changes, anticipated noncompliance, permit transfers, progress on compliance schedules, noncompliance which may endanger public health or the environment, other noncompliances, and other information. Section D also contains signatory requirements and the consequences of falsifying reports. Section E contains the definitions used throughout the permit, PERMIT PROCESSING/PUBLIC COMMENT/APPEAL PROCESS The beginning and end date of the public comment period to receive written comments regarding this permit, and the contact name and telephone number are included in the public notice (See Attachment G), The permittee is the only party having standing to file a permit appeal, If the Permittee is dissatisfied with the conditions of the permit when issued, they may request a hearing before the EQC or it's designated hearing officer, within 20 days of the final permit being mailed, The request for hearing must be sent to the Director of the Department, Any hearing held shall be conducted pursuant to regulations of the Department.

11 Appendix A; Antidegradation Review Sheet ANTIDEGRADATION REVIEW SHEET FOR A PROPOSED INDIVIDUAL NPDES DISCHARGE 1, What is the name of Surface Water that receives the discharge? Pacific Ocean Briefly describe the proposed activity: Is this review for a (renewalj OR new (circle one) permit application? Go to Step 2. V J 2. Is this surface water an Outstanding Resource Water or upstream from an Outstanding Resource Water? cs>. Go to Step 5. (No. J GO to Step IrtKiif&urfaee water a High Quality Water? V^es^/ Go to Step 8. No. Go to Step Will the proposed activity result in a Lowering of Water Quality in the High Quality Water? - gs. Go to Step 9. ( Nog Proceed with Permit Application. Applicant should provide basis for ^ -^ conclusion, Go to Step On the basis of the Antidegradation Review, the following is recommended: X Proceed with Application to Interagency Coordination and Public Comment Phase. Deny Application; return to applicant and provide public notice. Action Approved Section: Review Prepared By: Steve Sehnurbusch Phone: x284 Date Prepared: January 13, 2004