NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM WASTE DISCHARGE PERMIT

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1 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM WASTE DISCHARGE PERMIT ISSUED TO: Oregon Department of Environmental Quality 2020 SW Fourth Avenue, Suite 400 Portland, OR Phone: Issued pursuant to ORS 468B.050 and the Federal Clean Water Act SOURCES COVERED BY THIS PERMIT: PERMITTEES: Type of Waste Outfall Outfall Location Number Combined Municipal and Kraft 001 RM 86.9, Columbia River PO Box 278 Mill Aerated Stabilization Basin Effluent St. Helens, OR And Boise Cascade Corporation 1300 Kaster Road St. Helens, OR Effluent from the Municipal Primary Treatment Facility Municipal Primary Treatment Influent Page 1 of Internal Monitoring Point 003 Internal Monitoring Point Kraft Mill Process Wastewater*, Storm Water, Sanitary Wastewater, Water Treatment Plant Filter Backwash 004 Internal Monitoring Point Kraft Mill Bleach Plant Combined 005 Internal Monitoring Point A Bleach Line Kraft Mill Bleach Plant Combined 006 Internal Monitoring Point B Bleach Line Emergency Discharge from ASB 007 RM 0.2, Multnomah Channel Overflow of Sanitary Sewer Collection at Pump Station No RM 86.8, Columbia River Overflow of Pump Stations No. 2, 009 RM 85.8, Columbia River No. 3, and Middle Trunk Mill Intake Screen Return Water 010 RM 1.0, Multnomah Channel * In addition to the normal wastewater discharge, this NPDES permit authorizes discharges associated with or resulting from essential maintenance, regularly scheduled maintenance, during startup and shutdown, spills and releases (whether anticipated or unanticipated) from within the permitted facilities, as long as they are amenable to treatment, routed to the plant s wastewater treatment system and effluent limitations are met.

2 Page 2 of 39 PLANT TYPE AND LOCATION: Combined Plant: Municipal Sewage Treatment Plant 451 Plymouth Street St. Helens, OR Treatment System Class: IV Collection System Class: III and Bleached Kraft Pulp and Paper Mill 1300 Kaster Road St. Helens, OR EPA REFERENCE NO: OR RECEIVING STREAM INFORMATION: Outfall 001: Basin: Lower Columbia Sub-Basin: North Coast Receiving Stream: Columbia River Hydro Code: 10=-COLU 86.9 D LLID: /86.9 County: Columbia Outfall 007: Basin: Willamette Sub-Basin: Lower Willamette Receiving Stream: Multnomah Channel Hydro Code: 22P-MULT 0.2 D County: Columbia This permit is issued in response to Application No received June 22, 1998 from the City of St Helens and supplemental application by Boise Cascade Corporation for status as co-permittee. Neil Mullane Manager, Water Quality Source Control Northwest Region Date Permitted Activities Until this permit expires or is modified or revoked, the permittee is authorized to construct, install, modify or operate a wastewater collection, treatment, control and disposal system and discharge to public waters adequately treated wastewaters only from the authorized discharge point or points established in Schedule A and only in conformance with all the requirements, limitations, and conditions set forth in the attached schedules as follows: Schedule A Waste Discharge Limitations... 4 Mixing Zones... 8 Schedule B Monitoring and Reporting Requirements... 9 Reporting Procedures Reporting of Non-Detect Sample Results and Minimum Levels Monitoring Records Prepared in Ink Procedure for Calculating 7-Day Moving Average of Daily Maximum Values Continuous Monitoring Defined hour Composite Sampling If 24-hour composite samples cannot be collected as a result of equipment breakdown or malfunction, the permittees may use grab sampling techniques to complete monitoring requirements specified in this permit Summary of Selected Permit Report Submittals Schedule C Compliance Conditions and Schedules Certification of Implementation of Best Management Practices (BMPs) in 40 CFR

3 Page 3 of Temperature Study Plan Turbidity Compliance Schedule Compliance Schedule to Meet Provisions for Discharge from Outfall 008 and Responsibility to Meet Compliance Dates Schedule D Special Conditions Schedule E Pretreatment Activities Schedule F General Conditions Unless specifically authorized by this permit, by another NPDES or WPCF permit, or by Oregon Administrative Rule, any other direct or indirect discharge to waters of the state is prohibited, including discharge to an underground injection control system.

4 Page 4 of 39 Schedule A Waste Discharge Limitations 1. Outfall 001: Combined Discharge from the Aerated Stabilization Basin of Municipal Wastewater and Bleached Kraft Pulp/Paper Mill Wastewater to the Columbia River Boise has primary responsibility for compliance with the following discharge limits at this outfall. Parameter Daily Max Monthly Ave BOD5 19,600 lb/d 12,800 lb/d TSS 50,057 lb/d 26,862 lb/d AOX 2206 lb/d 1430 lb/d 2,3,7,8-TCDD mg/day (quarterly average) 0.40 mg/day (annual average) ph within range 5.0 to 9.0 Excess Heat Load2, 3, MW (7-day average of daily maximums) Turbidity (final) (May Oct) 32 NTU N/A (Nov April) 5 55 NTU N/A Turbidity (interim) NTU N/A Boise and the City have joint responsibility for compliance with the following discharge limit from this outfall. Parameter Daily Max Monthly Ave E. coli bacteria 6 406/100 ml 126/100 ml Notes: 1. These 2,3,7,8-TCDD mass discharge limitations (also known as TMDL limits) are based on EPA's total maximum daily load (TMDL) for controlling the discharge of 2,3,7,8-TCDD into the Columbia River Basin promulgated on February 25, The TMDL waste load allocation for the discharge is 0.27 mg/day. This waste load allocation represents the long-term average limitation that must be met by the permittee and is based on a 70-year exposure period. In addition to complying with the quarterly and annual limitations specified above, the permittees must also demonstrate compliance with the following limitations and exposure periods: Exposure Period Effluent Limit 2 years 0.37 mg/day 3 years 0.35 mg/day 4 years 0.34 mg/day 5 years 0.33 mg/day On an annual basis beginning the second year, the permittee must submit a report with effluent 2,3,7,8-TCDD data for the exposure period in question along with an analysis of whether the discharge is meeting the above effluent limits for 2,3,7,8-TCDD. Reports must be submitted two, three, four and five years after permit issuance. 2. The excess heat load limit specified in Schedule A.1 is an interim limit based on historical data. These limits apply from June 1 September 30. A final excess heat load limit will be established upon completion of the temperature study in Schedule C.2. It should also be noted that the Department is currently reviewing its

5 Page 5 of 39 temperature standard. Upon adoption of a new temperature standard, the permittee may request modification of the excess heat load limits in the permit. 3. The excess heat load limits in Schedules A.1, the temperature monitoring requirements in Schedule B, and the compliance conditions in Schedule C.2 of this permit constitute the permitttees Department-approved surface water temperature management plan (TMP) pursuant to OAR (3)(a)(D). In accordance with OAR (3)(a)(D)(vi), the permittee is deemed to be in compliance with in-stream temperature water quality standards and shall not be deemed to be causing or contributing to a violation of the water quality standards for temperature if the permittee is in compliance with this approved TMP. 4. In the event the permittee experiences an exceptional event in which there is unintentional and temporary noncompliance with excess heat load limits in the NPDES permit because of factors beyond the reasonable control of the permittee (i.e. high background stream temperatures), the permittee may claim an affirmative defense to an action brought for noncompliance with the excess heat load limits. The affirmative defense does not include noncompliance to the extent caused by operation error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventative maintenance, or careless or improper operation. In an enforcement proceeding, the permittee seeking to establish the occurrence of an exceptional event has the burden of proof. To claim an affirmative defense, the Permittee must demonstrate through properly signed contemporaneous operating logs, or other relevant evidence that: (1) An exceptional event occurred and that the permittee can identify the cause(s) of the event; (2) The permitted facility was at the time being properly operated; (3) The permittee submitted notice of the exceptional event as required in the General Condition D.5 (24-hour notice); and (4) The permittee complied with any remedial measures required under General Condition A The interim turbidity limit is effective upon permit issuance. The final turbidity limit is effective upon completion of the compliance schedule in Schedule C.3 of the permit. Note, however, that the final turbidity limits are based on the existing turbidity standard and existing mixing zone dilution. Both the turbidity standard and the mixing zone dilution are expected to change within this permit cycle. Schedule C.3 of the NPDES permit includes a compliance schedule that requires Boise to implement in-plant controls and relocate the outfall structure, which would result in increased dilution. Additionally, the Department is in the process of reviewing its turbidity standard. Revision to the turbidity standard and outfall 001 relocation will result in changes to the final effluent turbidity limits. The permittees may apply for modification to the NPDES permit to revise the final turbidity limits. Until such time as the Department takes action on the modification request or renews the NPDES permit, the interim limits specified herein would apply. 6. Monthly average must be calculated as 30-day log mean. If the daily maximum is exceeded in any month, the permittee may take at least five consecutive re-samples at four-hour intervals beginning no later than 28 hours after the original sample was taken, or 4 hours after the permittee is notified of the exceedance if notification was made more than 28 hours after the original sample was taken. If the log mean of the five or more re-samples is less than or equal to 126/100 ml, no violation of the daily maximum shall be deemed to have occurred. For a month in which an exceedance of the daily maximum occurred and the permittee performed re-sampling, the re-samples shall replace the exceedance sample in calculating the monthly average, if the log mean of the re-samples is less than or equal to 126/100 ml. If the log mean of the re-samples is greater than 126/100 ml, then the monthly average shall be calculated as a log mean of all samples for the month. 2. Outfall 002 (Internal Monitoring Point): Discharge from the Municipal Primary Treatment Facility to the Aerated Stabilization Basin This is the discharge from the municipal primary treatment facility s chlorine contact chamber into the combined aerated stabilization basin. The has the primary responsibility for the discharge from this outfall. There are no limits applicable to this outfall. 3. Outfall 003 (Internal Monitoring Point): Influent to the Municipal Primary Treatment Facility Except for wastewater from the Boise pulp and paper mill, all domestic and industrial wastewater (including leachate from the Boise landfill) enter the municipal primary treatment facility at this location. The has primary responsibility for this outfall. There are no limits applicable to this outfall.

6 Page 6 of Outfall 004 (Internal Monitoring Point): Discharge from the Boise Kraft Mill to the Aerated Stabilization Basin This is the discharge from the Boise primary treatment system into the combined aerated stabilization basin. Outfall 004 piping is maintained by Boise. Waste sources include the combined bleach Kraft mill wastewaters, cooling waters, storm water runoff, precipitated calcium carbonate plant, and all other integrated and ancillary process wastewaters resulting from operation and maintenance activities at the mill. This discharge also includes wastewater from the mill s sanitary sewage treatment facility. Boise has primary responsibility for the discharge from this outfall. There are no limits applicable to this outfall. 5. Outfall 005 (Internal Monitoring Point): Discharge from the Kraft Mill Bleach Plant Combined A Bleach Line This is the hypothetical combined Boise "A" bleach line discharge, defined as representative samples from A bleach line acid (005 acid) and A bleach line caustic (005 caustic) sewers, and includes bleaching process filtrates and wastewaters generated at the mill. Boise has primary responsibility for the discharge from this outfall. Parameter Daily Max Monthly Ave 2,3,7,8-TCDD <10 pg/l -- 2,3,7,8-TCDF 31.9 pg/l -- Trichlorosyringol <2.5 µg/l -- 3,4,5-trichlorocatechol <5.0 µg/l -- 3,4,6-trichlorocatechol <5.0 µg/l -- 3,4,5-trichloroguaiacol <2.5 µg/l -- 3,4,6-trichloroguaiacol <2.5 µg/l -- 4,5,6-trichloroguaiacol <2.5 µg/l -- 2,4,5-trichlorophenol <2.5 µg/l -- 2,4,6-trichlorophenol <2.5 µg/l -- Tetrachlorocatechol <5.0 µg/l -- Tetrachloroguaiacol <5.0 µg/l -- 2,3,4,6-tetrachlorophenol <2.5 µg/l -- Pentachlorophenol <5.0 µg/l -- Chloroform lb/d 4.76 lb/d

7 Page 7 of Outfall 006(Internal Monitoring Point): Discharge from the Kraft Mill Bleach Plant Combined B Bleach Line This is the hypothetical combined Boise "B" bleach line discharge, defined as representative samples from B bleach line acid (006 acid) and B bleach line caustic (006 caustic) sewers, and includes bleaching process filtrates and wastewaters generated at the mill. Boise has primary responsibility for the discharge from this outfall. Parameter Daily Max Monthly Ave 2,3,7,8-TCDD <10 pg/l -- 2,3,7,8-TCDF 31.9 pg/l -- Trichlorosyringol <2.5 µg/l -- 3,4,5-trichlorocatechol <5.0 µg/l -- 3,4,6-trichlorocatechol <5.0 µg/l -- 3,4,5-trichloroguaiacol <2.5 µg/l -- 3,4,6-trichloroguaiacol <2.5 µg/l -- 4,5,6-trichloroguaiacol <2.5 µg/l -- 2,4,5-trichlorophenol <2.5 µg/l -- 2,4,6-trichlorophenol <2.5 µg/l -- Tetrachlorocatechol <5.0 µg/l -- Tetrachloroguaiacol <5.0 µg/l -- 2,3,4,6-tetrachlorophenol <2.5 µg/l -- Pentachlorophenol <5.0 µg/l -- Chloroform lb/d 4.76 lb/d Notes: 7. On September 19, 2002, EPA published in the Federal Register (67 Fed. Reg ) a final rule allowing mills subject to the Cluster rule effluent discharge monitoring requirements to opt for a certification program, instead of conducting the weekly chloroform monitoring required by the rule. If, after two years of weekly monitoring demonstrating compliance with the chloroform limitation contained in Schedule A.5 and A.6, Boise decides to implement this alternative, it must notify the Department 90 days in advance of its intent to implement the compliance certification alternative as outlined in the rule (40 CFR (f)). Certification requirements are incorporated into this permit by reference. 7. Outfall 007: Emergency Discharge from the Aerated Stabilization Basin This is the emergency discharge from the aerated stabilization basin to the Multnomah Channel. Waste sources include all of the sources that are normally included in Outfall 001. Use of this outfall is restricted to emergency situations during periods of high Columbia River level when there is insufficient hydraulic head to discharge the entire secondary ASB effluent flow through the normal Outfall 001 diffuser. The effluent limitations that apply at Outfall 001 also apply to Outfall 007. Boise and the City have joint responsibility for the discharge from this outfall. 8. Outfalls 008 and 009: Emergency Overflows from Pump Stations The has the primary responsibility for the discharge from these outfalls. Except as otherwise provided by law, no wastes shall be discharged from these outfalls and no activities shall be conducted which violate water quality standards as adopted in OAR and OAR , unless the cause of the discharge is due to storm events as allowed under OAR (13) and (14) as follows:

8 Page 8 of 39 Emergency overflow discharges are prohibited to Waters of the State from May 22 through October 31, except during a storm event greater than the one-in-ten-year, 24-hour duration storm event. In the wet season, emergency overflow discharges are allowed until December 31, On and after January 1, 2010, overflows are prohibited from November 1 through May 21 except during a storm event greater than a one-in-five-year, 24-hour storm event. If an overflow occurs between May 22 and June 1, and if the permittee demonstrates to the Department s satisfaction that no increase in risk to beneficial uses occurred because of the overflow, no violation shall be triggered if the storm associated with the overflow was greater than the one-in-five-year, 24-hour duration storm event. 9. Outfall 010: Mill Intake Screen Return Water River water is used to flush the mill intake screen. The mill intake screen return water is discharged to Multnomah Channel. Boise has primary responsibility for the discharge from this outfall. There are no limits applicable to this outfall. 10. Mixing Zones 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: Outfall 001: The allowable mixing zone is that portion of the Columbia River within a parallelogram shaped area extending 100 feet upstream and 400 feet downstream and 100 feet off each end of the diffuser. The Zone of Immediate Dilution (ZID) is that portion of the Columbia River within 24 feet of any part of the diffuser between and including the end-most discharge ports. 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: Outfall 007: The allowable mixing zone is that portion of Multnomah Channel within a radius of 100 ft from the end of the discharge pipe. A Zone of Immediate Dilution (ZID) is that portion of the Multnomah Channel within a 10 foot radius from the end of the discharge pipe. Outfall 010: The allowable mixing zone is that portion of Multnomah Channel within a radius of 10 ft from the end of the discharge pipe.

9 Page 9 of 39 Schedule B Monitoring and Reporting Requirements 1. Monitoring Requirements The permittee must monitor the parameters as specified below at the locations indicated. The laboratory used by the permittee to analyze samples must 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, the results must be included in the report, but not used in the calculations required by this permit. When possible, the permittee must re-sample in a timely manner for parameters failing QA/QC requirements, analyze samples, and report results. a) Outfall 001: Combined Discharge from the Aerated Stabilization Basin of Municipal Wastewater and Bleached Kraft Pulp/Paper Mill Wastewater to the Columbia River The monitoring location is the discharge pipe from the aerated stabilization basin. The City of St. Helens has primary responsibility for conducting the monitoring at outfall 001. Parameter Minimum Frequency Sample Type Flow Daily Continuous Recorder BOD5 Daily 24-hour composite TSS Daily 24-hour composite ph Daily Grab AOX 1 Daily 24-hour composite Temperature Daily Continuous Recorder Turbidity Daily 24-hour composite E. coli bacteria 2 2/week Grab Color 1/week Grab NH3-N 1/month 24-hour composite Total Dissolved Solids 3 1/month 24-hour composite 2,3,7,8-TCDD 1/quarter 24-hour composite Whole effluent toxicity 4 1/quarter 24-hour composite Priority Pollutant Scan 5 1/quarter 24-hour composite Outfall condition 6 2 nd and 4 th year Visual Inspection Notes: 1. Upon written approval by the Department, AOX monitoring will be reduced to once per week after completion of the five year minimum monitoring requirement as allowed by 63 FR dated April 15, Monthly results must be reported as a 30-day log mean. E. coli monitoring must be conducted according to any of the following test procedures as specified in Standard Methods for the Examination of Water and Wastewater, 19th Edition (except mtec agar which is to be conducted with the 18th Edition) or according to any test procedure that has been authorized and approved in writing by the Director or his authorized representative. Resamples may be held for up to 30 hours prior to analysis:

10 Page 10of 39 Method Reference Page Method Number mtec agar MF Standard Methods, 18th Edition D NA-MUG, MF Standard Methods, 19th Edition G Chromogenic Substrate, MPN Standard Methods, 19th Edition B Colilert QT Idexx Laboratories, Inc. 3. Monitoring for this parameter is only required for 1 year from the time of permit issuance. 4. Monitoring to be conducted once during each calendar quarter (January March, April June, July September, October December). Results are to be reported the month following receipt of test results. 5. The permittee must perform chemical analysis of the effluent for the specific toxic pollutants listed in Tables II and III of Appendix D of 40 CFR 122 in accordance with the sampling frequency specified above. Monitoring results must be submitted with Whole Effluent Toxicity test results. Monitoring results must also be submitted with the Pretreatment Program Annual Report as required in Schedule E. The monitoring for metals and cyanide required by the industrial pretreatment program are included in Table III, Appendix D, 40 CFR 122. The effluent samples must be 24-hour composites, except where sampling volatile compounds and cyanide. For these pollutants, at least four discrete samples (not less than 100 ml) collected over the operating day are acceptable. The permittee must take special precautions in compositing the individual grab samples for the volatile organics to ensure sample integrity (i.e. no exposure to outside air). Alternatively, the discrete samples collected for volatiles may be analyzed separately and averaged. For cyanide, each aliquot must be collected and composited into a larger container which has been preserved with sodium hydroxide to insure sample integrity. 6. The City must conduct an inspection of the outfall pipe and diffuser system for Outfall 001 in the second and fourth years of the permit term. Modification of the outfall structure, if applicable, shall serve to satisfy one of the yearly inspections. A written report must be submitted to the Department with the next Discharge Monitoring Report. The report must include, at a minimum, the condition of the outfall pipe and diffusers and any maintenance required for proper operation of the outfall. b) Outfall 001: Temperature Data The has primary responsibility for conducting the monitoring at outfall 001. Parameter Minimum Frequency Sample Type Temperature (daily maximum) 1/day Calculate Temperature (7-day average of daily maximums) 1/week Calculate Excess Heat Load (Daily Maximum) 7 1/day Calculate Excess Heat Load (7-day Average of Daily Maximums) 7 1/week Calculate Notes: 7. The daily maximum excess heat load must be calculated using the daily maximum temperature and the total discharge flow for the day. The 7-day average of daily maximum heat load is a moving average of the daily maximum heat loads. Excess heat loads must be calculated using the formula. If the calculation results in a heat load value less than zero, the results must be recorded as zero. Individual values of zero must be used in calculating the average values.

11 Page 11of 39 Where: H = Excess heat load (Megawatts (MW)) ρ = Density of water, (1.0 kg/l) Cp = Specific heat of water, (4182 Joules/kg-ºC) Q = Discharge flow, (meters 3 /sec) ΔT = Daily maximum effluent temperature (ºC) minus criterion (20ºC) for calculation of daily maximum excess heat load. c) Outfall 003 (Internal Monitoring Point): Influent to the Municipal Primary Treatment Facility The monitoring location for outfall 003 is the primary influent flume. The has primary responsibility for conducting the monitoring at outfall 003. Metals (Ag, As, Cd, Cr, Cu, Hg, Mo, Ni, Pb, Se, Zn) & Cyanide, measured as total 8 Parameter Minimum Type of Sample Frequency Flow (measured at effluent from Daily Continuous Recorder primary treatmentt facility) BOD5 2/week 24-hour composite TSS 2/week 24-hour composite ph Daily Grab NH3-N 1/month 24-hour composite Quarterly 24-hour composite Notes: 8. Monitoring results for these pollutants must be submitted with the Pretreatment Program Annual Report as required in Schedule E. For cyanide, at least four (4) discrete grab samples must be collected over the operating day. Each aliquot shall not be less than 100 ml and must be collected and composited into a larger container which has been preserved with sodium hydroxide for cyanide samples to insure sample integrity. d) Production Data Boise must provide the following production data. Parameter Units Minimum Frequency Unbleached Pulp Production ADMT Monthly Bleached Kraft Market Pulp ADMT Monthly Bleached Kraft Fine Papers ADMT Monthly Bleached Kraft Tissue ADMT Monthly e) Outfalls 005 (Internal Monitoring Point): Discharge from the Kraft Mill Bleach Plant Combined A Bleach Line. The monitoring location is the A Bleach discharge lines, specifically the flow proportioned combination of 005 Acid and 005 Caustic samples. Boise has primary responsibility for conducting the monitoring at this outfall.

12 Page 12of 39 Parameter Minimum Frequency Type of Sample Flow 9 1/week 24-hour composite 2,3,7,8-TCDD 10 1/month 24-hour composite 2,3,7,8-TCDF 10 1/month 24-hour composite Trichlorosyringol 10 1/month 24-hour composite 3,4,5-trichlorocatechol 10 1/month 24-hour composite 3,4,6-trichlorocatechol 10 1/month 24-hour composite 3,4,5-trichloroguaiacol 10 1/month 24-hour composite 3,4,6-trichloroguaiacol 10 1/month 24-hour composite 4,5,6-trichloroguaiacol 10 1/month 24-hour composite 2,4,5-trichlorophenol 10 1/month 24-hour composite 2,4,6-trichlorophenol 10 1/month 24-hour composite Tetrachlorocatechol 10 1/month 24-hour composite Tetrachloroguaiacol 10 1/month 24-hour composite 2,3,4,6-tetrachlorophenol 10 1/month 24-hour composite Pentachlorophenol 10 1/month 24-hour composite Chloroform 11, 12 1/week 24-hour composite f) Outfall Number 006 (Internal Monitoring Point): Discharge from the Kraft Mill Bleach Plant Combined B Bleach Line. The monitoring location is the B Bleach discharge lines, specifically the flow proportioned combination of 006 Acid and 006 Caustic samples. Boise has primary responsibility for conducting the monitoring at this outfall. Parameter Minimum Frequency Type of Sample Flow 9 1/week 24-hour composite 2,3,7,8-TCDD 10 1/month 24-hour composite 2,3,7,8-TCDF 10 1/month 24-hour composite Trichlorosyringol 10 1/month 24-hour composite 3,4,5-trichlorocatechol 10 1/month 24-hour composite 3,4,6-trichlorocatechol 10 1/month 24-hour composite 3,4,5-trichloroguaiacol 10 1/month 24-hour composite 3,4,6-trichloroguaiacol 10 1/month 24-hour composite 4,5,6-trichloroguaiacol 10 1/month 24-hour composite 2,4,5-trichlorophenol 10 1/month 24-hour composite 2,4,6-trichlorophenol 10 1/month 24-hour composite Tetrachlorocatechol 10 1/month 24-hour composite Tetrachloroguaiacol 10 1/month 24-hour composite 2,3,4,6-tetrachlorophenol 10 1/month 24-hour composite Pentachlorophenol 10 1/month 24-hour composite Chloroform 11, 12 1/week 24-hour composite

13 Page 13of 39 Notes: 9. Flow is calculated using a water balance model; report daily average and monthly average flow. 10. Samples from individual acid and caustic sewers may be composited in proportion to flow so that a single analysis representative of the bleach line is obtained. 11. The 24-hour composite sampling for chloroform must consist of a minimum of four individual samples collected during a 24-hour period and quantitatively composited in the laboratory. The permittee must include, a detailed description of the method used to composite the samples with the first report, and with subsequent reports where there is a change of the compositing method. If an automated continuous or grab compositing device is used, the report must include a description of the system and the name of the manufacturer. 12. The 24-hour composite samples for chloroform from individual acid and caustic sewers are to be analyzed individually. Results from these analyses may be mathematically combined in proportion to flow and reported as a single value representative of the bleach line. g) Outfall 007: Emergency Discharge from the Aerated Stabilization Basin The monitoring location is the overflow structure discharge weir. The has primary responsibility for conducting the monitoring at outfall 007. Parameter Minimum Frequency Type of Sample Flow Daily When Discharging Estimate BOD, TSS, and AOX 13 Daily When Discharging Calculate Notes: 13. Due to the proximity of the discharge points for Outfall 007 and Outfall 001, monitoring at Outfall 001 is deemed equivalent to monitoring at Outfall 007 when Outfall 007 is being used. When discharging from outfall 007, the BOD, TSS, and AOX analytical results from outfall 001 must be used with the flow at outfall 007 to calculate effluent mass load. The mass load at outfall 007 must be combined to the mass load calculated at outfall 001 to determine compliance with the mass load limits specified at outfall 001. h) Outfalls 008 and 009: Emergency Overflows from Pump Stations For outfall 008, the monitoring location is at the overflow pipe inlet at manhole IA25. For outfall 009, the monitoring location is at the Pump Station No. 3 wet well overflow pipe, manhole IF 23 on the inlet line to Pump Station No. 2, and the overflow pipe on the middle trunk at manhole M1. The has primary responsibility for conducting the monitoring at outfalls 008 and 009. Parameter Minimum Frequency Type of Sample Flow Daily (during each occurrence) Estimate duration and volume i) Columbia River Monitoring Temperature and turbidity monitoring will be conducted as part of the temperature and turbidity studies specified in Schedule C.2 and C.3. The purpose of the monitoring program will be to establish background temperature and turbidity levels. In addition to conducting in-stream monitoring, the permittees may also use existing temperature and turbidity data, if appropriate, to characterize background temperature and turbidity levels. 2. Reporting Procedures Monitoring results must be reported on approved forms. The reporting period is the calendar month. Reports must be submitted to the Department s Northwest Region Office by the 45th day after the end of the monitoring period. If analytical results are not received on time (i.e., at least 5 days before the report is due), then the results must be submitted with the following month s report.

14 Page 14of 39 Boise and the must each report monitoring results for their respective areas of responsibility as identified in this permit. An authorized representative for each permittee must sign the forms for which it is responsible and the combined report must be submitted by the City of St. Helens to the Department s Northwest Region Office. 3. Reporting of Non-Detect Sample Results and Minimum Levels For all pollutants, if a value is less than the permit limit and less than the minimum quantitative level (MQL), the permittee must report Non-Detect ND (detection level in mg/l) for the parameter. For example, if the MQL for a pollutant is 10 µg/l and the value of the analytical result is below the MQL, the permittee must report ND ( mg/l)" in the Discharge Monitoring Report. For those pollutants for which a Minimum Level (ML) has been established in 40 CFR 430, if a value is less than the ML, the permittee must report "less than [insert ML]" for the parameter. The ML represents the minimum level as defined by regulation for the particular pollutant. For example, if the ML for a pollutant is 10 pg/l and the value of the analytical result is below the ML, the permittee must report "less than 10 pg/l" for the Discharge Monitoring Report. For 2,3,7,8-TCDD, ML represents the minimum level as defined in 40 CFR (i) for this pollutant. 4. Monitoring Records Prepared in Ink All bench sheets, laboratory analysis sheets, and other records to support the data reported on the Discharge Monitoring Report (DMR) must be prepared in ink. Pencil entries or liquid paper corrections must be prohibited by appropriate laboratory operating procedures. Changes to any supporting records that may be required to correct the original data must be made by lining through the original data. The date of the change and the initials of the individual making the change must be recorded in ink adjacent to the change. 5. Procedure for Calculating 7-Day Moving Average of Daily Maximum Values The 7-day moving average of daily maximums must be calculated by averaging the daily maximum values of the previous 6 days with the daily maximum value for the day for which the 7-day moving average of daily maximums is being calculated. The 7-day moving average of daily maximums must be calculated continuously and must not be restarted at the beginning of a new month or period. If there is a break in the record of monitoring data for 3 days or fewer, such as due to malfunction of equipment, the 7-day moving average of daily maximums must be calculated using the average of the available data spanning the break in data. If there is a break in the record of monitoring data for 4 or more days, a new moving average must be calculated and reported beginning on the day that a total of 7 days of record have been accumulated. The days for which no 7-day average can be calculated must be reported as "no data". 6. Continuous Monitoring Defined Continuous monitoring means the use of a primary device and instrument system to measure on a continuous basis the specified parameter. The device must measure the parameter (e.g. flow, temperature) a specific frequency (at least once every 15 minutes) and transmit data to be processed to provide the required result for the specified time period (e.g. daily maximum, daily average, etc.) hour Composite Sampling If 24-hour composite samples cannot be collected as a result of equipment breakdown or malfunction, the permittees may use grab sampling techniques to complete monitoring requirements specified in this permit. 8. Summary of Selected Permit Report Submittals

15 Page 15of 39 Selected submittals required under this permit are summarized below. In the event of conflict or omission, the submittals required by the specific permit condition or other requirement shall govern. Permit Condition Submittal Frequency First Submittal Date Schedule B.1.a) Outfall Condition 2 nd and 4 th Within 30 days after inspection year Schedule B.2 Discharge Monitoring Report 1/month By 45 th day after the end of the monitoring period Schedule C.1 Certification of BMP plan Once within 30 days of issuance Schedule C.2 Temperature Study Plan N/A See Schedule C Schedule C.3 Turbidity Study N/A See Schedule C Schedule C.4 Emergency Overflow Outfall Use N/A See Schedule C Schedule D.3 BMP Annual Report 1/year April 15 th Schedule D.5 Dredging Management Plan as required 60 days prior to dredging Schedule D.14 Biocides Certification Once within 30 days of permit issuance Schedule E.11 Pretreatment Program Annual Report 1/year March 1

16 Page 16of 39 Schedule C Compliance Conditions and Schedules 1. Certification of Implementation of Best Management Practices (BMPs) in 40 CFR 430. Within thirty (30) days after permit issuance date, Boise Cascade must submit a certification to the Department s Northwest Region Office in Portland whether the BMPs specified in 40 CFR 430 have been implemented. With the certification, the permittee must submit a copy of the BMP plan. 2. Temperature Study Plan Boise must comply with the following schedule: Complete by: Upon permit issuance Within 6 months after permit issuance Within 12 months after permit issuance Requirement: Boise must begin the evaluation of alternatives to reduce effluent heat load in accordance with Department s guidance. Boise must submit a Water Quality Study Report to the Department s Northwest Region Office. The Water Quality Study Report will contain an evaluation of the effect of the existing discharge on water quality within the stream segment where the facility discharges. Boise must submit to the Department s Northwest Region Office for review and approval an Evaluation of Alternatives to Reduce Effluent Heat Load. Within 18 months after permit issuance Within 18 months after Department approval of the Evaluation of Alternatives to Reduce Effluent Heat Load The Evaluation of Alternatives to Reduce Effluent Heat Load must include an inventory of the heat sources that are affecting the heat load discharged from the facility. The Alternatives Evaluation must consider alternatives for: (1) recycling and eliminating or reducing part of the discharge; (2) recycling selected waste streams to reduce the thermal load being discharged; (3) directly removing heat load from the wastewater and transferring it back to the process and (4) treatment technologies to reduce heat load from selected waste streams or treatment technologies to reduce overall heat load of the discharge. The Alternatives Evaluation must include criteria to rank projects. At a minimum, the criteria must include expected time to complete the project, technical feasibility, cost per unit of heat load reduced, and collateral environmental effects. The Alternatives Evaluation must include recommendations for preferred alternatives, which are reasonably available, and can be implemented to reduce effluent heat load. Unless Boise can demonstrate through improved effluent quality that the existing outfall location addresses water quality issues, Boise must submit its plan for relocation of outfall 001 to the Department s Northwest Region Office for review and approval. The Outfall Modification Plan must provide information justifying the location of the outfall and must include mixing and dilution analysis using EPA approved models for the new outfall location. The submittal must also provide plans and specifications, and a schedule for outfall relocation. Within two (2) months after Department approval, the permittees must submit all applications and supporting materials to the appropriate agencies as necessary to secure required approvals/permits for the project. Boise must implement necessary non-capital preferred alternatives to reduce effluent heat load discharged from the facility.

17 Page 17of 39 Within 30 months after Department approval of the Evaluation of Alternatives to Reduce Effluent Heat Load Within 24 months after Department approval of the Outfall Modification Plan and permits/ approval from all required agencies Within 6 months of completion of the outfall structure, if necessary Boise must implement necessary capital preferred alternatives (excluding outfall modification) to reduce effluent heat load discharged from the facility. Boise must complete modifications to the outfall structure, and provide written notice to the Department s Northwest Region Office. Boise will not be in violation of this compliance schedule due to any delays caused by circumstances beyond the reasonable control of the permittees, including but not limited to: delays in obtaining required agency permit approvals, river conditions that prevent the safe installation of required structures, or any others delays that would prevent construction during the available window for in-stream project work. In such circumstances, the Department will extend the time frame for modification of the outfall structure, commensurate with the period of delay. Boise must submit a mixing zone/dilution technical evaluation report for the modified outfall structure to the Department s Northwest Region Office. The mixing zone/dilution technical evaluation report will provide the applicable dilution factor(s) for the modified outfall structure, and for demonstrating compliance with water quality standards. Boise shall also submit a request for permit modification and applicable fees for revising temperature and/or heat load limits to comply with applicable water quality standards and/or applicable TMDL for temperature. The notification must also specify any additional actions necessary to meet the effluent limits for temperature. Upon issuance of the The permittees must comply with the temperature standard in OAR modified NPDES Permit (2)(b) or any TMDL in effect at that time, or such numerical effluent heat load limits as may be in the permit at that time. Plans, reports and all other submittals may be combined with those required by Schedule C Turbidity Compliance Schedule Boise must comply with the following schedule: Complete by: Within 3 months after permit issuance Within 6 months after permit issuance Within 18 months after permit issuance Within 24 months after permit issuance Within 30 months after permit issuance Requirement: Boise must submit a Turbidity Study plan to the Department s Northwest Region Office. The study plan must include proposed methods, schedule and frequency for measuring turbidity at the following: one or more locations upstream of the Outfall 001 diffuser, at the downstream edge of the Outfall 001 mixing zone, and effluent turbidity. Boise must commence the Turbidity Study. Boise must submit an Interim Feasibility Evaluation that identifies reasonable methods that Boise can implement to reduce effluent turbidity through process changes, modification of existing equipment, outfall structure dilution improvements, or other modifications, controls or procedures. Boise must submit the completed Turbidity Study to the Department s Northwest Region Office. Boise must implement non-capital projects identified as preferred alternatives in the Interim Feasibility Evaluation.

18 Page 18of 39 Within 42 months after permit issuance Boise must implement capital projects identified as preferred alternatives in the Interim Feasibility Evaluation, with the exception of any modifications to the outfall structure. Within 6 months of completion of the outfall structure Upon issuance of the modified NPDES Permit Outfall structure modifications are subject to the compliance schedule requirements of Condition C.2. Boise must submit a mixing zone/dilution technical evaluation report for the modified outfall structure to the Department s Northwest Region Office. The mixing zone/dilution technical evaluation report will provide the applicable dilution factor(s) for the modified outfall structure, and for demonstrating compliance with water quality standards. Boise shall also submit a request for permit modification and applicable fees for establishing turbidity limits to comply with applicable water quality standards. The notification must also specify any additional actions necessary to meet the effluent limits for turbidity. Until such time as the Department takes action on the modification request or renews the NPDES permit, the interim turbidity limits specified in Schedule A of the permit would apply. The permittees must comply with the turbidity standard in effect at that time, or such numerical effluent turbidity limits as may be in the permit at that time. Plans, reports and all other submittals may be combined with those required by Schedule C Compliance Schedule to Meet Provisions for Discharge from Outfall 008 and 009 Schedule A.8 requires the emergency overflows (outfall 008 and 009) to meet specific criteria for discharge. For example, emergency overflow discharges are prohibited to Waters of the State from May 22 through October 31 (dry season), except during a storm event greater than the one-in-ten-year, 24-hour duration storm event. In the wet season, emergency overflow discharges are allowed until December 31, On and after January 1, 2010, overflows are prohibited from November 1 through May 21 except during a storm event greater than a one-in-five-year, 24-hour storm event. With six (6) months after permit issuance date, the City must submit a report regarding whether the discharge from these outfalls meets the dry season criteria for overflow discharges to Waters of the State. Along with the report, the City must submit an implementation plan and schedule for complying with wet season overflow requirements by January 1, Responsibility to Meet Compliance Dates The permittees are expected to meet the compliance dates that have been established in this schedule. Either prior to or no later than 14 days following any lapsed compliance date, the permittee must submit to the Department a notice of compliance or noncompliance with the established schedule. The Director may revise a schedule of compliance if he determines good and valid cause resulting from events over which the permittees have little or no control.

19 Page 19of 39 Schedule D Special Conditions 1. Primary Responsibility Defined "City", "City of St Helens", and "municipal" mean the City of St Helens, a municipal corporation, or its authorized representatives. "Boise", "Boise Cascade", or "BCC," mean Boise Cascade Corporation, St Helens Kraft pulp and paper mill, its authorized representatives, or its successors. "Joint" means the City of St Helens and Boise Cascade Corporation acting together by mutual agreement, contract, or other arrangement to fulfill the responsibilities and obligations of this NPDES permit. "Permittee" or "permittees" mean either the City of St Helens or Boise Cascade Corporation or both entities acting together depending on the context in which the term is used. a) Notwithstanding paragraphs b) and c), the Department and the permittees agree that each permittee has primary responsibility for certain limitations and/or obligations. For a violation of a condition that is designated the primary responsibility of one permittee as set forth in Schedule A or other condition of this permit, any resulting enforcement action will be directed against the permittee with primary responsibility. However, if the permittee assigned primary responsibility does not act or respond in a timely manner upon its assigned responsibility, then the Department may proceed against both permittees at its discretion. For a violation of a condition that is designated as joint responsibility, any resulting enforcement action by the Department will be directed against both permittees. b) The permittees are jointly and severally responsible for compliance with this permit, and nothing herein shall preclude the Department from taking action against either or both permittees to enforce the terms and conditions of this permit. c) The Department considers the permittees to be a single entity for the purpose of escalating enforcement action in accordance with Department rules and policies. d) Primary responsibility is as follows: Boise Responsibility: Boise has primary responsibility for any violation of effluent limitations or other obligation of this permit identified as a Boise responsibility. City Responsibility: The City of St Helens shall have primary responsibility for any violation of effluent limitation or other obligation of this permit identified as "". Joint Responsibility: The City and Boise shall have joint responsibility for any violation of effluent limitations or other obligation of this permit identified as "Joint" or "Joint Responsibility" in this permit, and for any violation or other obligation of this permit that is not clearly identified in this permit as the primary responsibility of one or the other permittee. e) Nothing in this permit shall be construed as preventing the permittees from assigning responsibility between themselves in any way they mutually agree upon, except that such agreement will have no effect upon the Department or this permit. f) Designation of primary responsibility in this permit may be changed only by modification of this permit following the appropriate modification procedures.

20 Page 20of Whole Effluent Toxicity (Bioassay) Testing- Primary responsibility: Joint. a)the permittee must conduct whole effluent toxicity tests as specified in Schedule B of this permit. b)bioassay tests may be dual end-point tests, only for the fish tests, in which both acute and chronic end-points can be determined from the results of a single chronic test (the acute end-point shall be based upon a 48-hour time period). c)acute Toxicity Testing - Organisms and Protocols (1) The permittee must conduct 48-hour static renewal tests with the Ceriodaphnia dubia (water flea) and the Pimephales promelas (fathead minnow). (2) The presence of acute toxicity will be determined as specified in Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, Fourth Edition, EPA/600/4-90/027F, August 1993 or newer. (3) An acute bioassay test must be considered to show toxicity if there is a statistically significant difference in survival between the control and 100 percent effluent, unless the permit specifically provides for a Zone of Immediate Dilution (ZID). If the permit specifies such a ZID, acute toxicity must be indicated when a statistically significant difference in survival occurs at dilutions greater than that which is found to occur at the edge of the ZID. d) Chronic Toxicity Testing - Organisms and Protocols (1) The permittee must conduct tests with: Ceriodaphnia dubia (water flea) for reproduction and survival test endpoint, Pimephales promelas (fathead minnow) for growth and survival test endpoint, and Raphidocelis subcapitata (green alga formerly known as Selanastrum capricornutum) for growth test endpoint. (2) The presence of chronic toxicity shall be estimated as specified in Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms, Third Edition, EPA/600/4-91/002, July 1994 or newer. (3) A chronic bioassay test is considered to show toxicity if a statistically significant difference in survival, growth, or reproduction occurs at dilutions greater than that which is found to occur at the edge of the mixing zone. If there is no dilution data for the edge of the mixing zone, any chronic bioassay test that shows a statistically significant effect in 100 percent effluent as compared to the control is considered to show toxicity. e) Quality Assurance (1) Quality assurance criteria, statistical analyses and data reporting for the bioassays must be in accordance with the EPA documents stated in this condition and the Department's Whole Effluent Toxicity Testing Guidance Document, January f) Evaluation of Causes and Exceedances (1) If toxicity is shown, as defined in sections c.(3) or d.(3) of this permit condition, another toxicity test using the same species and Department approved methodology must be conducted within two weeks, unless otherwise approved by the Department. If the second test also indicates toxicity, the permittee shall follow the procedure described in section f.(2) of this permit condition.