National Pollutant Discharge Elimination System
PERMIT EVALUATION AND FACT SHEET
Oregon Department of Environmental Quality
Western Region
750 Front St NE, Suite 120
Salem OR 97301
(503) 378-8240
U t vf
State of Oregon
Department of
Environmental
Quality
Permittee:
Existing Permit
Information:
Georgia Pacific West, Inc.
1400 S.E Butler Bridge Rd
Toledo, OR 97391
File Number: 32947
Permit Number: 101409
Expiration Date: July 31, 2001
Source Contact:
EPA Reference Number: OR000134-1
Sam Adams 541-336-8041
Environmental Superintendent
Source Location:
100 S.E. Butler Bridge Rd
Toledo, OR
LLID
1240682445993-99-D
Receiving Stream
Pacific Ocean, Yaquina River
Proposed Action:
Renew Permit
Application Number: 988110
Date Received: February 6, 2001
Source Category
NPDES Major - Industrial
Permit Writer:
Steve Schnurbusch (503) 378-8240 ext. 284
Senior Water Quality Permitting Specialist
Changes made to the permit after PN are not reflected in this evaluation
report. Please refer to the response to comments for changes.
1.0 INTRODUCTION
The existing National Pollutant Discharge Elimination System (NPDES) Permit expired on July
31, 2001. The Department received renewal application number 988110 from Georgia Pacific
West, Inc. on February 6, 2001. 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 to issue the new permit as per
OAR 340-045-0040.
This permit evaluation report describes the basis and methodology used in developing the permit.
The permit is divided into several sections:
Schedule A Schedule B Schedule C Schedule D Schedule F -
Waste discharge limitations
Minimum monitoring and report requirements
Compliance conditions and schedules
Special conditions
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.050) also require a discharger be granted a permit for the discharge of wastewater to
surface waters. This proposed permit action by the Department complies with both federal and
state requirements.
2.0 FACILITY DESCRIPTION
2.1 General
The Georgia-Pacific West, Inc. facility in Toledo, Oregon was constructed in 1956-57 and the
first roll of paper was produced in December 1957. The mill is located along Yaquina Bay at
about river mile 12.3. Treated effluent is pumped via two pipelines from the mill through the
City of Newport to a single pipeline at Nye Beach. The outfall pipe runs offshore from Nye
Beach about 4000 feet into the Pacific Ocean (See Figure 1). The manufacturing of paper
products is carried out in two distinct phases: (1) the pulping processes and (2) the manufacturing
of paper. The primary markets for products produced at this facility are linerboard and
corrugating medium. Production of paper at this facility has averaged about 2300 tons/day
(machine dry tons) since 1998.
Approximate outfall
001 location
Facility Location
Approximate outfall
003 location
Figure 1: Facility Location
2.2 Chemical Pulping Process
Pulping consists of the chemical and physical separation of wood fibers from the lignin and
recovery of the pulping chemicals. Lignin is the intercellular material that binds the fibers
together. GP Toledo employs unbleached Kraft chemical pulping and the semi-chemical pulping
processes. The unbleached Kraft process involves cooking wood chips in an alkaline solution
(sodium hydroxide and sodium sulfide). GP Toledo has eleven batch digesters that produce pulp
from softwood chips using the unbleached Kraft process. The semi-chemical process combines
chemical and mechanical methods. The chips are partially digested using chemicals and the
remainder of the pulping process is performed by mechanical means. . The facility has one
continuous digester that produces semi-chemical pulp from hardwood chips. The chemical
recovery system combusts the spent chemical cooking liquor to produce steam and regenerate
fresh cooking liquor. The provisions of 40 CFR 430 subpart C apply to these two portions of the
process. This mill also has two secondary fiber systems that produce a post-consumer recycle
pulp from old corrugating containers. Clippings from converting plants are recycled into pulp
using the paper machine repulper. The provision of 40 CFR 420 subpart J applies to these
processes.
2.3 Chemical Recovery Process
The mixture of spent pulping chemicals and lignins from the digestion process, known as black
liquor, is processed to recover and recycle pulping chemicals and to produce energy. The black
liquor, which initially contains a high percentage of water and is called weak black liquor, is first
concentrated in a set of evaporators. Water is evaporated from the black liquor to produce heavy
black liquor, which is approximately 60-70 percent solids. Heavy black liquor is combustible,
and is the primary fuel used in the recovery furnace. The heat from combustion of black liquor is
used to make steam for use in the mill, while the pulping chemicals form a molten sodium
sulfide/sodium carbonate salt, called smelt, which collects in the bottom of the recovery furnace
and flows into a smelt dissolving tank. The smelt solution is called green liquor. The green
liquor is clarified and treated by the addition of quicklime (calcium oxide), which results in the
reformation of white liquor, which is reused in the digestion process. A calcium carbonate
precipitate also forms, called lime mud; lime mud is heated in a lime kiln to convert it back to
quicklime, which is then reused in the white liquor cycle.
2.4 Wastewater Treatment
The treatment facility is based upon aerated stabilization basins. Wastewater is produced at three
different parts of this facility. These are as follows (See Appendix A for a wastewater flow
diagram):
1) Paper Mill discharges consist of the white water purge from the paper machine, drop box
drainages (from the No 3 paper machine stock cleaning system and the secondary fiber
cleaners and screens), Hogged fuel boiler blowdown and area drains and fiber spills.
Paper mill effluent passes over a traveling bar screen into a primary clarifier and then into
a three cell unlined thermal pond. Underflow of approximately 1 MGD from the primary
clarifier is pumped to the old corrugated cardboard (OCC) plant. The underflow, or
primary sludge, is typically dewatered and burned as fuel in the hog fuel boiler in
accordance with Title V air permit 21-00005. Occasionally, the primary sludge is
satisfactory for recycle as secondary fiber pulp.
2) Causticizing discharges consist of green liquor dregs washing water, slaker grits washing
water, wet fan drainage from the lime kiln and purge water from the lime kiln scrubbermedium recycle loops. Causticizing wastewater bypasses the primary clarifier and
discharges directly into the thermal pond.
3) Pulp Mill discharges consist of chip washer discharges from the continuous digester, foul
condensate from batch digesters, foul condensates from the evaporator-turpentine
recovery system, boiler blowdown from power recovery boilers, feedwater filter and ionexchange backwash system and spills of fiber. Pulp mill condensates containing
hazardous air pollutants are regulated under EPA's Maximum Achievable Control
Technology (MACT) standard (40 CFR Part 63, Subpart S). These liquid condensates
are collected and pumped in a closed pipeline to the treatment pond where they are
discharged below the surface of the pond and subsequently treated as per MACT
requirements. Pulp mill effluent passes over a sidehill screen and discharges into the load
level unlined pond where it is combined with effluent from the thermal pond. This
effluent then flows into the treatment pond where foul condensate from the pulp mill is
discharged for treatment. Treated effluent from the treatment pond then flows into the
lined settling pond where it passes over another traveling bar screen and is pumped via
two pipe lines, 18 and 21 inches in diameter, through the City of Newport and to the
ocean outfall (001) at Nye Beach. A graphic description of the entire wastewater
treatment system is included in Attachment A.
4) In addition to the normal wastewater discharge, Georgia-Pacific is authorized to
discharge through outfall 001 wastewater associated with or resulting during essential
maintenance, regularly scheduled maintenance, during startup and shutdown, spills and
releases (whether anticipated or unanticipated) from within the permitted facility as long
as they are amenable to treatment, routed to the plant's wastewater treatment system and
effluent limitations are met. This does not relieve the facility from spill reporting
requirements and the Department may require the facility to conduct additional effluent
monitoring for pollutants associated with the spill.
The load level pond is 3.8 surface acres and 1,761,500 cubic feet in volume, the treatment pond is
22.6 surface acres and has a volume of 11,031,700 cubic feet. The settling pond is 5.2 acres and
2,506,900 cubic feet in volume and the thermal ponds are 8.0 acres and 3,655,970 cubic feet of
volume. Aeration is provided to enhance biological activity in the treatment system and reduce
the amount of organic waste in the effluent.
Two sludge ponds, 15-acre and 30-acre, are used to manage the wastewater treatment system
level by providing temporary storage of rainfall and wastewaters via a pipeline under the Yaquina
River. Process solids produced by the mill are transported via truck to the landfill for disposal.
Leachate from the landfill operation flows into the 15-acre pond and is then pumped under the
Yaquina River to the treatment system. The landfill is operated under a DEQ Solid Waste Permit,
No. 1059, and requires groundwater monitoring of the landfill and the sludge pond areas.
Primary solids settled out in the primary clarifier are pumped to the OCC plant. The primary
sludge is typically dewatered and burned as fuel in the Hog Fuel Boiler in accordance with Title
V air permit 21-00005. Occasionally, the primary sludge is satisfactory for recycle as secondary
fiber pulp. Secondary solids are dredged from the aerated ponds and placed in the non-aerated
15-acre and 30-acre ponds.
This facility generates an average of 11.5 MGD of wastewater. The outfall is located 4,000 feet
from the shore and consists of a 21-inch outfall pipe connected to a 15-inch "Y" shaped diffuser
in 36 feet of water. There are 28 six-inch ports on the diffuser arms. Two whole effluent toxicity
bioassay tests are required by the permit each year. No toxicity has been noted to date.
2.5 Changes in Operation
An additional six, 75 hp aerators were added to the thermal pond as part of the mill
reconfiguration in 1996. This was necessary to treat additional BOD generated by increased
usage of old corrugated containers. In 2004 a step-feed system was added to allow balancing the
oxygen demand with the available installed aerators in the Thermal Ponds and the Load Leveling
Pond. Also, three stand-by aerators were installed in the Thermal Ponds. These three aerators
each shares a starter with an aerator in the Treatment Pond so there will be no increase in the
number of aerators operating, but they allow additional flexibility in matching the aeration
capacity to the oxygen demand at the front end of the treatment system. An oxygen supply
system will be installed in 2005 to add oxygen to the paper mill influent.
Upgrades to the hog fuel boiler discharge at Outfall 003 to minimize upsets have also been
implemented. During heavy rainfall events, the sump can be overwhelmed with storm water and
a discharge will occur until such time as the rainfall intensity declines and the sump pump is able
to recover. The mill has installed a backup power supply, a trash screen, and a backup pump.
2.6 Groundwater Issues
Groundwater is a concern primarily because of GP's landfill, treatment ponds, and their sludge
ponds. Groundwater issues are being addressed primarily through the Department's Solid Waste
section. GP submits an annual ground water monitoring report that is reviewed in detail by the
Department's Solid Waste section. The primary objective of the annual groundwater quality
monitoring program is to identify any potential impacts on groundwater and surface water quality
resulting from the operation of their landfill. Because the ponds are adjacent to the landfill,
groundwater is monitored in accordance with OAR 340-040 so that it meets the needs of both the
Solid Waste and Water Quality programs. As part of the ongoing ground water studies, the
Department is requiring GP to submit a plan describing how the facility is going to develop site
specific concentration limits. The permit is requiring this plan to be submitted within 90 days
from permit issuance.
2.7 Storm Water
Storm water is primarily addressed through the facility's general NPDES 1200-Z permit.
However, some storm water is occasionally discharged through outfall 003 which is discussed in
more detail below.
2.8 Outfalls
Treated effluent is discharged through Outfall 001 which is extends from the shore into the
Pacific Ocean, running due east to west and ends in a Y-shaped multi-port diffuser. It is a 20 inch
diameter pipe, 3,890 feet long, with a Y-shaped diffuser with 280 feet long arms. The outfall
makes an angle of 76 degrees with the shore line. The diffuser arms make an angle of 20 degrees
with the main outfall pipe. It is located at Latitude of 44.6441 and Longitude of-124.0721. The
diffuser orientation is such that the arms of the 'Y' are oriented in a direction parallel to the shore
such that incident waves approach the diffuser normal to axis of the arms. Each diffuser branch is
a 15-inch diameter pipe and has 14 3-inch diameter ports ejecting effluent perpendicular to the
diffuser. Ports alternate along each arm with 20 feet spacing between them. Ports are
approximately one foot above the sea floor. Angle between two arms of the diffuser is 140
degrees. Latest inspection on Jan 22, 2004 showed that 9 ports in southern leg of the diffuser are
buried under the sand and 1 port in the northern leg is missing (GP Outfall Diver Inspection
Report, 2004). The outfall diffuser is at a depth of 35 feet below the mean sea level. Outfall pipe
and the diffuser branches are buried under the sea floor. Outfall extension slopes down gradually
from the bank into the ocean. Bathymetry close to the shore is uneven with presence of rocky
reefs.
An emergency overflow outfall (003) discharges storm water mixed with hogged fuel boiler
blowdown, area drainage and shed #5 drainage. Typically this water is collected in a sump and
pumped to the #1 OCC plant for filtration and reuse, however during extreme storm events this
sump occasionally overflows. If the sump pump capacity is exceeded, the excess water overflows
to the Yaquina River via outfall 003. Discharges at this outfall have occurred only ten times since
1999 and there has been no discharge since August 2003.
3.0 PERMIT HISTORY
3.1 Compliance history
This facility was last inspected December 13, 2004 and was found to be operating in compliance
with the permit. The following Notices of Noncompliance (NON) have been issued for violations
documented at this facility since 1996:
Date of NON
6/10/2003
8/9/2000
11/25/1998
6/30/1998
NON Class
2
2
2
2
Description of Violation
Exceeded pH and TSS Limitation
Exceeded Permit Limits
Exceeded Permit Limits
Exceeded Permit Limits
at Outfall
at Outfall
at Outfall
at Outfall
003
003
003
003
These violations are either considered to be minor and/or have been corrected. Therefore, the
Department considers this facility to be in substantial compliance with the terms of the current
permit. There is no record of any complaints about this facility with respect to wastewater
discharges.
4.0 RECEIVING WATER
4.1 Receiving Stream Water Quality
Effluent from Outfall 001 discharges to the Pacific Ocean. The Pacific Ocean is not routinely
monitored by the Department's laboratory but the Department is not aware of any pollutants of
concern off the shores of Oregon. Effluent from Outfall 003 discharges to the Yaquina River
during heavy rainfall events. The Yaquina River is water quality limited for bacteria year round
below outfall 003.
As part of an extensive mixing zone study, GP contracted with Battelle to perform a receiving
water study to collect background water chemistry data. Receiving Water Quality Study data are
required to establish background concentrations in the outfall area for compliance evaluation and
reasonable potential analysis. Low-level metals techniques including "clean techniques" for
sample collection, handling and ultimately analyses were employed to precisely quantify the
concentrations of parameters of concern in seawater, which typically have ambient concentrations
on the order of less than a part per billion (ppb). 1 Ten representative receiving water samples
plus one field duplicate were collected along a transect located offshore of the Yaquina Reef,
which is outside of the dilution zone of the GP outfall 001 (Figure 1). Receiving water samples
were collected utilizing a boat and field team from the Battelle Marine Sciences Laboratories
(MSL). Physical parameters collected in the field included pH, temperature, salinity, and
dissolved oxygen. Additional total and dissolved metals were analyzed for baseline values
[arsenic, beryllium, cadmium, chromium, copper, lead, manganese, mercury, nickel, silver and
zinc]. The results of the sampling demonstrated receiving water concentrations were well below
water quality criteria and similar in magnitude to average seawater data collected both regionally
(Sequim Bay, WA) and globally.
4.2 Mixing Zone Analysis (See response to comments for changes to mixing zone)
Federal regulations (40 CFR 131.13) allow for the use of mixing zones, also known as "allocated
impact zones". Application of mixing zones must ensure acute toxicity to drifting organisms is
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 may 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 340-041-0053(1) provides that the Department 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. In addition, OAR 340-041-0053(2) has a series
of conditions the mixing zone must meet which are discussed in the following sections.
The Department has developed mixing zone regulations and policy based in part on the acute and
chronic aquatic life criteria. Based on EPA guidance and the Department's mixing zone
1
Battelle. June 2004. Field Sampling Plan / Quality Assurance Project Plan for Establishing Chemical
Characterization of the Receiving Water off Newport, Oregon. Prepared by Battelle Marine Science
Laboratory for GP Toledo.
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 with the mixing zone and 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.
GP has conducted several mixing zone studies in the past dating back to 1984 and most recently a
zone of initial dilution study in 1996. The Department requested that GP update their mixing
zone study because previous studies were outdated. In 2003, GP contracted with Battelle to
conduct a comprehensive mixing zone study. The study involved collecting background water
chemistry data as discussed above. A field dye study was performed to obtain data for calibration
of a hydrodynamic mixing zone model and a tidal circulation and transport model. Data from the
field study was used to develop the tidal circulation and effluent transport model used for
predicting the plume behavior and obtain dilution estimates. As part of this mixing zone study,
Battelle also performed an environmental mapping exercise. This exercise provided information
showing areas of unique habitat in relation to the discharge location. The dye study, mixing zone
modeling, and environmental mapping are discussed briefly below. They are discussed in more
detail in the final mixing zone study report written by Battelle for GP.
4.3 Environmental Mapping
Environmental mapping is an integral tool to help assure that the mixing zone minimizes risk to
beneficial uses in the local region and avoids critical areas such as drinking water supplies,
breeding grounds, areas with sensitive biota and recreational areas. This is done to insure the
mixing zone minimizes adverse affects on the indigenous biological community and does not
block passage of aquatic life as required by OAR 340-041-0053(2)(c)(C). This is done by
examining significant habitats and resources in relation to the mixing zone areas to determine if
potential impacts exist.
Battelle employed a wide variety of data sources to acquire as much publicly available GIS data
as possible within the scope and timeframe of the project. A majority of the data was acquired
via online databases maintained by State or regional entities, with the exception of the local
government agencies contacted directly.
The available GIS data was summarized and is presented as a series of maps covering ten topic
areas. A detailed description of all map layers and data sources and results is presented in Section
5 of the Mixing Zone Study Report.2 The results of the environmental mapping demonstrated
there was no critical or unique habitat in proximity to outfall 001 that could be affected by this
discharge. In addition, bottom dwelling organisms would not be adversely impacted by the
discharge because the plume is more buoyant than the seawater causing the plume to rise. The
sediment modeling also demonstrated there is no measurable settling of any solids from this
discharge. Annual outfall inspections including video footage have not indicated any adverse
impacts to the aquatic life in the area of the outfall and there is no indication of the discharge
creating any fungal or bacterial growths or any floating debris. This demonstrates compliance
with the Department's biocriteria (OAR 340-041-0011) and OAR-340-041-0053(2)(a).
2
Battelle. November 2004. Mixing Zone Study - GP Toledo, NPDES Permit No. 101409 Prepared for GP
Toledo, Toledo, OR.
There is softshell clam habitat downstream of outfall 003 (not within the mixing zone) but this
discharge is very infrequent (no discharge has occurred since August 2003) and the discharge is
very small and short in duration. The discharge from 003 is not expected to have an adverse
impact on the softshell clams within Yaquina Bay.
Anadromous fish within the Yaquina Bay system include coho salmon, fall chinook salmon,
winter steelhead, chum salmon, and cutthroat trout. Resident fish include the white sturgeon.
None of these are currently on the endangered species list, however, there is an ongoing debate
with respect to the listing of coho salmon. Outfall 001 is about 4000 feet from the shore and not
in the direct path of any anadromous species that would prevent their free passage. This mixing
zone avoids overlap with any other mixing zones with the nearest outfall and mixing zone being
the City of Newport's which is approximately 1800 feet from shore and about 2200 feet from
GP's outfall. The mixing zone complies with OAR 340-041-0053(2)(c)(C).
4.4 Field Dye Study
A field dye study was performed on July 13, 2004. This time of year was chosen because of the
stratification that occurs in the ocean was assumed to create worse-case mixing conditions. The
purpose of the field dye dilution study was to obtain data for calibration of the two models being
used. The objective was to measure the effluent concentration in the field to generate actual
effluent dilution data and to gain an understanding of the plume behavior. This was
accomplished by pumping a known concentration of a fluorescent dye through the outfall and
measuring the dye within the mixing zone. The data demonstrated the plume became trapped at
the pycnoline between a depth of about 4 to 6 meters. Figure 2 provides dilution results obtained
during the study. This data indicates minimum dilutions of about 50 in the near field and 125 at
the end of the mixing zone. Detailed discussion of the methods and results are presented in the
Field Dye Dilution Study Report.3
4.5 Mixing Zone Modeling — Outfall 001(See response to comments for changes to
mixing zone)
GP Toledo submitted mixing zone modeling results performed by Battelle. Battelle used UM3
(an EPA supported mixing zone model) to model the discharge. UM3 is a steady state model
designed to simulate stable plume behavior. Battelle also used a tidal circulation and transport
model (FVCOM) to model the plume transport to verify results obtained with the steady state
models. FVCOM is a dynamic model which was used to predict the fate and transport of the
effluent beyond the mixing zone and to simulate re-entrainment of the plume.
UM3 was first used to simulate the ambient and effluent conditions present during the dye study.
Model simulations demonstrated good agreement between model predictions and dye study
results. UM3 predicts the plume becomes trapped between a depth of 5 and 7 meters
corresponding well to dye study results. The dilutions within this trapping level range from about
50 to 70 which is in the range of dilutions measured during the dye study. The model was able to
adequately predict the plume behavior for conditions observed during the dye study and therefore
was used to model other conditions to determine a worse case dilution scenario.
Several combinations of ambient and effluent conditions were simulated to determine which
combination resulted in the lowest dilution. EPA suggests the critical ambient design period for
3
Battelle. October 2004. Survey Report for Field Dye Collection for Characterization of Nearfield
Mixing, Prepared for Georgia-Pacific Toledo, OR.
coastal discharges is during the time of maximum density stratification. Under these conditions,
plumes tend to become trapped below the surface reducing the amount of mixing in the vertical
direction. These conditions were present during the dye study and simulated with UM3.
Through series of sensitivity analyses, the conditions that provided the least amount of dilution
were a combination of high effluent flow, low ambient velocity, and a stratified environment.
These worse-case ambient conditions were present during the dye study, however the effluent
flow was relatively low. An analysis of the past five year's of effluent flow was performed to
determine an appropriate effluent flow rate to simulate. The Department recommends the
maximum monthly flow rate to be used for industrial discharges. The calculated maximum
month flow rate corresponding to the time of year when the critical ambient conditions are
expected to occur is 11.4 mgd.
The existing mixing zone is described in the permit as follows:
The allowable mixing zone shall not exceed a segment 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 an
included angle of 55 degrees. The zone of initial dilution shall not exceed a portion
of the Pacific Ocean from the outfall diffuser perpendicular to the pipes centerline
extending seven meters (or 23 feet) in all directions about the ocean floor.
The existing mixing zone is somewhat ambiguous and does not reflect the location and
dimensions of the plume as determined by the recent mixing zone study. The proposed permit is
re-defining the dimensions of the mixing zone based on new information provided in the mixing
zone study. The new mixing zone is being defined as a rectangle with its center occurring at the
center of the diffuser and extending parallel with the shore 1500 feet in the northerly and
southerly direction and extending perpendicular to the shore 750 feet in the westerly and easterly
direction (see Figure 3).
The dye study and model results were in good agreement with each other. The plume becomes
trapped due to the stratification that occurs. During times when the ocean is not stratified the
plume will reach the surface and receive a greater amount of dilution. The plume generally
follows a north or south direction (parallel to the shore) depending on the prevailing ocean
currents. Ocean currents typically flow north in the winter and south in the summer. The mixing
zone is sized spatially in the north and south direction to allow for these changing currents. At no
time will the discharge encompass the entire mixing zone. The critical dilution at the edge of the
mixing zone under critical worse-case conditions was estimated to be 186. Under these critical
stratified conditions, this dilution occurred at 5-7 feet below the surface.
The environmental mapping discussed above demonstrates the lateral extent of the regulatory
mixing zone does not overlap any sensitive aquatic habitat and will be protective of human health
and the beneficial uses in the vicinity of the outfall. Annual inspections of the outfall have
demonstrated abundant sea life in the area of the diffuser. This mixing zone is small relative to
the size of its receiving stream and is consistent with the mixing zones that existed at other paper
mills with ocean discharges prior to those facilities halting operations. The Department believes
the mixing zone meets the conditions in OAR 340-41-0053.
The existing ZID is defined as that portion of the Pacific Ocean from the outfall diffuser
perpendicular to the pipe centerline extending in seven meters in all directions about the ocean
floor. The size of the ZID in the existing permit was based on modeling performed in 1997 that
demonstrated initial mixing of the effluent was completed approximately 23 feet downstream.
10
This modeling assumed all ports were functioning. With new information regarding the diffuser
and several of the ports being buried, modeling demonstrates initial mixing occurs slightly further
way from the diffuser. Under effluent flows of 11.4 mgd and assuming only 18 ports are
functioning, the model predicts initial mixing is completed approximately 32 feet downstream at
a depth of 15 feet below the surface. The estimated dilution at the edge of the ZID is 66. Based
on this new information, the Department is proposing to expand the size of the ZID from 23 feet
to 32 feet. Modeling results, combined with an analysis of concentrations and hydraulic
residence times, indicate drifting organisms drifting through the centerline of the plume would
not be exposed to concentrations exceeding the acute criteria when averaged over the one hour
time period for acute critera.
-
Zone of Initial Dilution
I
Zone of Initial
Dilution
Shore Line
—-
Pt. B
/
...
-
Mixing Zone
Outfall Pipe
X-
-:"*
1. Current direction is assumed to be North-South
2. Units are In feet
3. Location of Pt A Lat=44 6366, Long=124 05497
4. Location of Pt B Lat=44.64112, Long=124 07728
Pt. A
—I
FIGURE 3
Revised Mixing Zone associated with Outfall 001
Battelle
DRAW»
!.C.O„.,il,
D,l, , / 1 « 2 . «
Mixing Zone Study
Georgia-Pacific
Toledo, OR
HLE»,
CHECH
Figure 2: Mixing Zone and ZID
4.6 Sediment Deposition Analysis
The sediment deposition analysis for the GP Toledo outfall 001 site was conducted according to
the general guidelines established by U. S. EPA's Section 301 (h) Technical Support Document
(EPA, 1994). 4 The analysis method calculates the travel distance for each group of total
suspended solids (TSS) and the annual deposition rate on the seafloor based on the effluent
concentration, flow rate, effluent trapping depth, effluent suspended solid grain sizes and settling
velocities, and ambient receiving water transport velocities.
The effluent data were obtained from GP Toledo. The effluent plume trapping depth was
calculated using the initial dilution results from Visual Plumes model. The net ambient transport
velocities were calculated based the field survey data collected by Battelle. Effluent TSS grain
size distribution and settling velocities were not available for the GP Toledo outfall 001 site, and
data from a similar effluent outfall of Ketchikan Pulp Company were used in the study. A total of
10 groups of grain sizes with different settling velocities were considered in the calculation.
Because the settling velocities of suspended solids for secondary outfall are very small, the
calculations show that they are transported considerable distance away from the outfall before
depositing down to the seafloor. Results indicate that the TSS deposition rate near the outfall is
4
EPA. September 1994. Amended Section 301 (h) Technical Support Document. EPA 842-B-96-007.
11
very small. Using the 90th percentile TSS loading scenario, the highest TSS annual deposition
rate is 2.02 g/m2/yr. This results in a steady-state accumulation rate of 0.96 g/m2 under the
default decay rate of 0.01/day, which is much smaller than the critical steady-state sediment
accumulation rate of 25 g/m2 (EPA, 1994). [For relative comparison, this deposition rate is
negligible compared to the minimum natural background deposition rate of 460 g/m2/yr in the
Puget Sound region reported by Carpenter et. al. (1996)5]. The zone of sediment deposition at the
rate of 2.02 g/m2/yr is distributed over an area of 3700 m along the shore and 2700 m cross the
shore.
A detailed description of DO-BOD analysis summarized above is provided in the Coastal
Circulation and Effluent Dispersion Modeling Report6 prepared as part of the Mixing
Zone Study.
4.7 Mixing Zone Modeling - Outfall 003
Outfall 003 is an emergency overflow outfall that discharges on a rare occasion during heavy rain
events. Only ten discharges have occurred from this outfall since 1999. No discharges have
occurred since August 2003. The average flow rate since 1999 is about 0.14 mgd with a
maximum of 0.24 mgd. Discharges typically occur for a short period of time (less than 24 hours).
Under worst-case conditions (mean low tide) the outfall is exposed and considered a surface
discharge.
The existing mixing zone at Outfall 003 is defined as follows:
The allowable mixing zone shall not exceed a portion of the Yaquina River from
the point of discharge extending to a radius of 25 feet.
The Department is proposing to include a zone of initial dilution of 17 feet where acute criteria
could be exceeded. Battelle performed a mixing zone analysis using CORMIX3 which is
designed to simulate surface discharges. The mixing zone modeling predicted a dilution of 10 at
the edge of the ZID and 14 at the edge of the mixing zone. Assuming an ambient velocity of 0.15
ft/s, a drifting organism would pass through the ZID in less than 2 minutes and the mixing zone in
less than 3 minutes. Acute criteria are based on one hour exposure periods. The Department
believes the proposed ZID and existing mixing zone would produce negligible or no measurable
affects on the aquatic community. The small size and location of the mixing zone combined with
infrequency of the discharge should not prevent or impair free passage of any aquatic species
including anadromous and resident fish within the Yaquina River system.
5
Carpenter, R, M. L. Peterson and J. T. Bennett, 1986. 210Pb-Derived Sediment Accumulation and Mixing
Rates for the Greater Puget Sound Region. Marine Geology, 64, 291-312.
6
Battelle. December 2004. Coastal Circulation and Effluent Dispersion Modeling for GO Toledo's
Outfalls 001 and 003, on the Yaquina River and Newport Bay, OR. Prepared for GP Toledo, Toledo, OR.
12
5.0 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 qualitybased limits, or limits based on best professional judgment. When renewing a permit, the most
stringent of technology based or water quality based limits apply.
5.1 Current Permit Limits
Schedule A of the existing permit contains the following effluent limits:
a. Outfall 001, ASB Effluent
Effluent Loadings
Parameter
BOD5
TSS
pH
Monthly
Daily
Average
Maximum
lbs/day
lbs/day
12,800
25,700
20,200
40,400
Shall not be outside the
range of 6.0-9.0.
b. Outfall 003, Hogged fuel boiler area drainage
Effluent Loadings
Parameter
Temperature
TSS
pH
Monthly
Daily
Average
Maximum
lbs/day
lbs/day
Shall not exceed 90 °F
Shall not exceed 50 mg/L
Shall not be outside the
range of 6.0-9.0.
5.2 Technology-Based Effluent Limits
The applicable technology based standards for the Georgia-Pacific Toledo Mill are contained in
40 CFR 430 - Pulp, Paper, and Paperboard Point Source Category. Portions of these technologybased standards were updated by EPA in 1998 in a rulemaking effort called the Cluster Rule. The
technology utilized by the GP Toledo Mill is considered by EPA to represent Best Practicable
Control Technology Currently Available (BPT). The Department relies on EPA for the
establishment of technology-based effluent guidelines for the many industrial sectors within the
13
State of Oregon and has concluded that primary and secondary treatment employed by the GP
Toledo Mill represents "highest and best" technology. [OAR 340-041-0007]
Georgia Pacific's Kraft pulp mill and the semi-chemical pulp mill fall under 40 CFR 430, subpart
C. The secondary fiber (non-deink) systems fall under subpart J. EPA has developed technology
based permit limits for biochemical oxygen demand (BOD), total suspended solids (TSS), and
pH. The BOD and TSS limits are based on production and pH is limited to the range of 6.0 - 9.0.
The table below shows the annual average production numbers broken down into Kraft pulp,
semi-chemical pulp, and total paper.
Start:
End:
Kraft Pulp
(ADT/day)
Nov-98
Oct-03
Average
859
36%
Production
Recycled Pulp
(ADT/day)
Semi-Chem
(ADT/day)
297
13%
1212
51%
Paper
Total Pulp
(ADT/day) (MDT/day (ADT/day)
2368
2302
2430
The average amount of paper produced per day since November 1998 was 2430 ADT/day
(ADT=air dry tons). The amount of pulp produced from each of the three processes is shown in
the table above. The percentage of the total pulp produced was calculated and is shown next to
the tonnage. This same percentage was multiplied by the total paper produced to calculate the
paper production associated with each process. The technology-based limits calculations are
shown in the following table along with the existing permit limits. The existing limits are
technology based limits that have been in the permit since it was issued in 1990.
Conversions
Paper
ELG
Percentage
Monthly Avg BOD5
ADT/day lbs/1000lb
Kraft
B P T / B C T 2430 x
2.8
x 36%
x 2000 Ib/t •* 1000 =
Semi-chem
BCT
2430 x
4.0
x 13%
x 2000 Ib/t •* 1000 =
Secondary Fiber
BPT
2430 x
2.8
x 51%
x 2000 Ib/t - 1000 =
Daily Max BOD5
Kraft
BPT/BCT
Semi-chem
BCT
Secondary Fiber
BPT
Monthly Avg TSS
Kraft
BPT/BCT
Semi-chem
BCT
Secondary Fiber
BPT
Daily Max TSS
Kraft
Semi-chem
Secondary Fiber
BPT/BCT
BCT
BPT
2430 x
2430 x
2430 x
2430 x
2430 x
2430 x
2430 x
2430 x
2430 x
5.6
8.0
5.7
6
6.25
4.6
12
12.5
9.2
x 36%
x 13%
x 51%
x 36%
x 13%
x 51%
x 36%
x 13%
x 51%
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
x 2000 Ib/t - 1000 =
Total
Ibs/day
4,900
2,400
7,000
14,300
Current
Limit
Ibs/day
12,800
9,900
4,900
14,200
29,000
25,700
10,600
3,800
11,400
25,800
20,200
21,200
7,600
22,900
51,700
40,400
5.3 Water Quality-Based Effluent Limits
Reasonable Potential Analysis
The Department performs an analysis to determine if there is a reasonable potential to cause or
contribute to violations of instream water quality criteria. The Department has adopted EPA's
recommended methodology for performing a reasonable potential analysis (RPA). This
methodology was developed primarily for acute and chronic criteria but can be adopted to other
criteria based on different frequencies and durations. This RPA takes into account effluent
14
variability, available dilution (if applicable), and receiving stream water quality. The RPA for
specific parameters are discussed below.
Metals
GP provided a single sample result for a series of metals as required in their permit renewal
application. Copper, lead, and zinc were the only metals that were detected in the final effluent.
The Department performed an RPA to determine if there was a reasonable potential to cause or
contribute to a violation of a water quality criteria for any of these metal's. Using EPA's
recommended methodology, the Department determined there was no reasonable potential to
violate the acute or chronic criteria for copper, lead, or zinc, outside the regulatory zone of initial
dilution or mixing zone (See Appendix B).
Ammonia
The effluent ammonia result submitted with the renewal application was low (1.12 mg/L). A
reasonable potential analysis was performed which demonstrated there was no reasonable
potential to violate the acute or chronic ammonia criteria outside of the regulatory zone of initial
dilution or mixing zone (See Appendix B)
Bacteria
The Department has two bacteria criterion that are applicable to GP's discharge, one of which
was recently promulgated by EPA. These criteria are designed to protect human health from
pathogenic species associated with excrement from warm blooded animals. Both criteria act as a
surrogate to indicate the presence of human pathogens because it is not practical to test for all
human pathogens that could be present in water samples. The application of these criterion are
discussed below.
Fecal Coliform
The Departments' bacteria criterion for marine environments is based on fecal coliform. For
marine waters and estuarine shellfish growing waters the standard for fecal coliform is a median
concentration of 14 organisms per 100 milliliters, with not more than ten percent of the samples
exceeding 43 organisms per 100 ml (OAR 340-041-0009). This criterion was established
primarily to protect human health from consumption of contaminated shellfish. Pulp and paper
effluent would not be expected to contain any pathogens or bacteria (such as fecal coliform)
associated with warm blooded animals. However, there is a group of bacteria named Klebsiella
that is commonly found in pulp and paper effluent (associated with wood fibers) that can give a
false positive reading for the fecal coliform test. GP Toledo recently sampled their effluent for
the presence of fecal coliform and Klebsiella. The first test demonstrated the presence of
Klebsiella and fecal coliform with fecal coliform being measure above the standard. Fecal
coliform was not detected in the second sample while Klebsiella was measured at a level above
the detection point.
GP also tested for fecal coliform and Klebsiella in several internal waste streams. The highest
levels of both Klebsiella and fecal coliform were found in the paper mill effluent. All fecal
coliform results were less than the Klebsiella results indicating the fecal coliform results are
likely due to the interference with the fecal coliform test. The Department has seen similar
results at other wood waste facilities and the Klebsiella interference with the fecal coliform test is
well documented.
15
Enterococcus
EPA recently promulgated a new bacteria standard applicable to states with coastal recreation
waters that is based on enterococcus as an indicator organism. This new standard is designed to
protect the beneficial use of water contact recreation in coastal recreation waters. The standard
consists of a single maximum and an average criterion. The single maximum criterion varies
based on the level of use as defined in the rule. GP's outfall is located 4000 feet into the ocean at
a depth of about 35 feet. The Department considers the waters at the outfall location to be
"infrequent use coastal recreation waters" based on the use designations defined in the rule. The
single maximum criterion associated with this designation is 501 organisms/100 milliliters. The
average concentration is 35 organisms/100 milliliters and is based on a geometric mean. The
average concentration applies to all use designations.
As part of the recent bacteria sampling, GP Toledo analyzed for enterococcus in their final
effluent. One sample result was above the single maximum criteria of 501 organisms/100 ml and
the other was below it but still higher than the geometric mean of 35 organisms/100 milliliters.
High levels of enterococcus were found in samples collected from some internal waste streams.
E. coli
GP Toledo also analyzed for E. coli during the second round of sampling. Results were mostly
non-detects except for a result of 2300 cts/100 ml measured in the paper mill effluent, 130 cts/100
ml in the clarifier effluent, and 20 cts/100 ml in the load leveling pond effluent. Final effluent
samples were all below detection level.
The Department is unable to draw any conclusions regarding bacteria with the existing data set.
The final effluent bacteria concentrations do not appear to be at levels the Department considers
harmful to human health. However the Department is concerned about high levels of bacteria
found in the paper mill effluent and other internal waste streams. This may be due to a cross
connection, raw material contamination from the recycled OCC, wildlife activity, or could be
interference with the testing methods. Schedule C requires GP Toledo to submit a bacteria
monitoring plan to the Department to evaluate potential bacteria problems. If results from the
monitoring indicate a source of contamination or cross connection, GP Toledo will be required to
correct the problem according to the time line in Schedule C. If results indicate the source of
contamination is beyond the control of GP, they may request a variance.
Temperature
The Department's temperature standard allows a 0.3 °C increase at the edge of the mixing zone
for sources discharging to oceans and bays (OAR 340-41-0028(7)). Assuming a maximum
discharge temperature of 32.8 °C and a background temperature of 10.6 °C the increase at the
edge of the mixing zone was calculated to be 0.12 °C (See Appendix B). No reasonable potential
exists to violate the temperature standard.
Dissolved Oxygen
Dissolved oxygen can be reduced in the receiving water due to oxygen demanding materials
present in wastewater effluent. The strength of the oxygen demand is commonly measured by the
term biochemical oxygen demand (BOD). Higher strength BOD exerts more demand and can
reduce the dissolved oxygen levels within a receiving stream to undesirable levels and adversely
affect aquatic life.
16
The Department's dissolved oxygen standard for ocean waters states that no measurable reduction
in dissolved oxygen concentration is allowed (OAR 340-41-0016(l)(f)). A measurable reduction
in dissolved oxygen has typically been interpreted as more than 0.1 mg/L dissolved oxygen (OAR
340-4 l-0004(3)(d)).
A dissolved oxygen analysis was performed as outlined in USEPA's 301(h) Technical Support
Document for marine discharges. This modeling analysis is similar to the widely used StreeterPhelps model. The model accounts for effluent and ambient water quality parameters (BOD,
dissolved oxygen, temperature, BOD decay rates). Dilution results from the mixing zone
modeling were used. A maximum effluent BOD of 175 mg/L was used where the effluent BOD
typically averages around 60 mg/L BOD. A conservative decay rate of 0.23/day was used where
typical pulp and paper effluents have a decay rate on the order of 0.1/day or less. The dilutions
obtained from the mixing zone model results were based on conservative worst-case conditions.
Based on this conservative analysis, the reduction in dissolved oxygen was predicted to be about
0.06 mg/L (See Appendix C). There is no reasonable potential to violate the Department's
dissolved oxygen standard based on these results.
pH
The pH standard for marine waters is 7.0-8.5. GP Toledo maintains pH of its treated effluent
from Outfall 001 between 6.0 and 9.0 at all times. The alkalinity of the ocean is typically around
100 mg/L CaC03 providing a large buffering capacity for the effluent. Neutralization of effluent
will occur quickly within the mixing zone. There is no reasonable potential to violate the pH
standard of 7.0-8.5 for Marine waters. [OAR 340-041-0021 ].
5.4 W h o l e Effluent Toxicity (See response to comments for changes to WET dilutions)
Whole Effluent Toxicity (WET) is a term used to describe the aggregate toxic effect of an
aqueous sample (e.g., whole effluent wastewater discharge) as measured by an organism's
response upon exposure to the sample (e.g., lethality, impaired growth or reproduction). WET
tests replicate, to the greatest extent possible, the total effect and actual environmental exposure
of aquatic life to toxic pollutants in an effluent without requiring the identification of the specific
pollutants. WET testing is a vital component of the water quality standards implementation
through the NPDES permitting process.
EPA's promulgated WET test methods include an acute test (96 hours or less, endpoint:
mortality), and a chronic test (7 day life-cycle test, endpoints: growth, reproduction, and
mortality). EPA has developed WET test protocols using both freshwater and marine and
estuarine test species. EPA recommends running tests using an invertebrate, vertebrate and a
plant to identify the most sensitive species for developing NPDES WET permit limits or testing
requirements. Organisms used in WET tests (e.g., Ceriodaphnia dubia - freshwater flea and
Pimephales promelas - fathead minnow) are indicators or surrogates for the aquatic community to
be protected, and a measure of the real biological impact from exposure to the toxic pollutants. To
protect water quality, EPA recommends that WET tests be used in NPDES permits together with
requirements based on chemical-specific water quality criteria.
WET tests are designed to predict the impact and toxicity of effluents discharged from point
sources into waters of the United States. WET monitoring requirements are included in NPDES
permits to generate data for use in assessing whether a WET limit has been exceeded (i.e.
compliance monitoring) or to assess if a WET limit is needed. The tests are used to determine the
percentage of effluent that produces an adverse effect on a group of test organisms. The
measured effect may be fertilization, growth, reproduction, or survival. An acute WET test is
considered to show toxicity if the "No Observed Effect Concentration" (NOEC) occurs at
17
dilutions greater than that which is found at the edge of the zone of immediate dilution (ZID). A
chronic WET test is considered to show toxicity if "a significant difference in survival, growth or
reproduction" occurs at dilutions greater than that which is known to occur at the edge of the
mixing zone.
GP Toledo conducted semiannual WET tests for the duration of the previous permit. The dilution
series used for the chronic tests were 0, 0.05, 0.1, 0.5, 1.3, 4.0 percent effluent. The dilution
series for the acute tests were 0, 0.05, 0.1, .2, .5, 1.0 percent effluent. There was no acute or
chronic toxicity demonstrated at any of these dilutions demonstrating the discharge complies with
OAR 340-041-0053(2)(a)(A) and 0053(2)(b)(A). The proposed permit is changing the dilution
series to reflect the results of the mixing zone modeling. The critical dilution at the edge of the
ZID is 66 which corresponds to an effluent percentage of 1/66 = 1.5 percent. The acute WET test
should bracket this effluent percentage. Therefore the permit is requiring the following dilution
series for acute WET tests: 1%, 1.5%, 2.5%, 5%, and the highest effluent percentage practicable
by the contract laboratory. The critical dilution at the edge of the mixing zone is 189 which
equates to an effluent percentage of 1/189 = 0.5%. The proposed permit is requiring the
following dilution series for chronic WET tests: 0.25%, 0.5%, 1%, 2.5%, and the highest effluent
percentage practicable by the contract laboratory. If a combined acute/chronic test is being
conducted the following dilution series should be used: 0.25%, .5%, 1.5%, 2.5%, and the highest
effluent percentage practicable by the contract laboratory. It is impracticable to perform saltwater
WET tests at 100% effluent. Because the effluent is freshwater sea salts needs to be added to the
fresh effluent. With bivalve and echinoderm tests, the use of sea salts to increase salinity is not
advisable since these salts can cause abnormal results. For bivalve and echinoderm tests the
normal method is to use concentrated sea water brine, but this limits the test concentrations to
approximately 68% to 70%.
5.5 Antidegradation
An Antidegradation Review was performed for this discharge. The permit is being renewed
without any increase in discharge loadings. Permit renewals with the same discharge loadings as
the previous permit are not considered to lower water quality from the existing condition. Based
on the antidegradation review, the Department determined the proposed discharge complies with
the Antidegradation Policy for Surface Waters found in OAR 340-041-0026 (see Appendix D).
5.6 Outfall 003
Due to the modifications made by GP at the overflow point to outfall 003, there has not been a
discharge since August 2003. DMR data for manganese, zinc, and iron were reviewed and found
there was no reasonable potential to violate water quality criteria. This analysis took into account
the magnitude of the data and the frequency of the discharge. The application was reviewed for
additional parameters with copper being raised as a parameter of concern. Only one effluent
sample was available for copper which was high enough to raise concern but low enough for the
Department not to impose a permit limit. The proposed permit requires monitoring of copper
from this outfall during the next permit cycle and to be evaluated at the next permit renewal.
Monitoring for zinc, manganese, and iron have been eliminated.
The Department analyzed this outfall with respect to the Department's temperature standard and
thermal plume limitations within the mixing zone rule. The mixing zone analysis Battelle
performed on outfall 003 demonstrated the temperature drops drastically just outside the outfall to
levels that will not adversely impact aquatic life and approaches ambient temperature within 1520 seconds.
The temperature standard and the individual numeric criteria are based on 7-day values. Because
this discharge is intermittent, this standard is not applicable. The thermal plume limitations
contained in the mixing zone rule are applicable and were reviewed. OAR 340-0410053(2)(d)(B) states that acute impairment or instantaneous lethality is prevented or minimized
by limiting potential fish exposure to temperatures of 32 °C or more to less than 2 seconds. The
permit limits the discharge to a temperature of 90°F (32°C) at the end of the pipe so this provision
of the rule is met. The other two provisions are met because the outfall discharges to a large
water body with ample dilution and room for fish migration.
6.0 PERMIT DRAFT DISCUSSION
6.1 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 the Pacific
Ocean and Yaquina River within limits set by Schedule A and the following schedules. All other
discharges are prohibited.
6.2 Schedule A, Waste Discharge limitations
Georgia Pacific did not request a mass load increase as part of their permit application. The
existing technology limits in the existing permit are more stringent than any water quality based
limits would be. The existing technology based limits will remain in effect for this next permit
cycle. The following tables list the permit limits that are contained in the proposed permit.
a. Outfall 001, ASB Effluent
Effluent Loadings
Parameter
BOD5
TSS
pH
Monthly
Daily
Average
Maximum
lbs/day
lbs/day
12,800
25,700
20,200
40,400
Shall not be outside the
range of 6.0-9.0.
b. Outfall 003, Hogged fuel boiler area drainage
Effluent Loadings
Parameter
Temperature
TSS
pH
Monthly
Daily
Average
Maximum
lbs/day
lbs/day
Shall not exceed 90 °F
Shall not exceed 50 mg/L
Shall not be outside the
range of 6.0-9.0.
19
6.3 Schedule B - M i n i m u m Monitoring and Reporting Requirements (see
response to comments for changes in effluent monitoring requirements)
a. Outfall 001
Parameter
Flow
BOD5
TSS
Color
Temperature
pH
Whole Effluent Toxicity Testing
b.
Minimum Frequency
Daily
3/Week
3/Week
3/Week
3/Week
3/Week
2/Year
Type of Sample
Continuous
24-hour composite
24-hour composite
24-hour composite
Grab
Grab
24-hour composite
Minimum Frequency
Daily, during discharge
Daily, during discharge
Daily, during discharge
Daily, during discharge
Daily, during discharge
Type of Sample
Grab
Grab
Grab
Grab
Grab
Outfall 003
Parameter
Flow
Temperature
pH
Total Copper
TSS
Sludge Monitoring
Parameter
Average depth of sludge in
aeration basin
Note:
Minimum Frequency
Type of Sample
1/year (approximately Calculated Estimate
12 months apart)
All sludge shall be handled in accordance with the Sludge Management Plan
approved by the Department per Schedule C, Condition 1. A management plan
is not required unless the facility changes its current sludge practice.
Production
Parameter
Pulp
Secondary Fiber
Paper
Minimum Frequency
Average air-dry tons/day for reporting period
Average air-dry products, tons/day, for reporting
period
Machine-dry tons/day for reporting period
Type of Sample
Calculation
Calculation
Calculation
6.4 Schedule C, Compliance Schedules and Conditions (see response to comments
for changes to the compliance conditions)
The proposed permit contains the following four compliance conditions:
20
1. If the facility changes their existing sludge management practices of disposing of their
sludge to their DEQ approved solid waste facility, the permittee submit a Sludge
Management Plan for Department approval.
2. The permittee is required to inspect their outfall diffuser and the surrounding marine
environment on a yearly basis.
3. The permittee is required to propose permit-specific
groundwater.
concentration limits for
4. The permittee is required to perform a bacteria monitoring study
The final condition requires the permittee to meet the compliance dates established in this
schedule or notify the Department within 14 days following any lapsed compliance date.
21
6.5 Schedule D - Special Conditions
The proposed permit contains the following nine special conditions:
1. The permittee is required to implement a contingency plan for prevention and handling of
spills and have a continuing program of employee orientation and education.
2. The facility is required to control the total discharge to maintain a reasonable constant flow
rate throughout each 24-hour operating period.
3. Sanitary wastes are required to be discharged to the City of Toledo sanitary sewage system.
4. Filter backwash, solids, sludge, dirt, sandy, or other pollutants separated from or resulting
from the treatment of intake or supply water shall not be discharged to state waters without
first receiving adequate treatment (which has been approved by the Department) for removal
of the pollutants. Flushing of the fresh water purge tank back to Olalla Creek is an activity
approved by authority of this permit.
5. This condition requires the facility to have a continual effort to reduce their total fresh water
consumption by increased utilization of soiled waters.
6. The facility is required to have a site contact person designated to coordinate and carry out
all necessary functions related to operation and maintenance of waste collection, treatment,
and disposal facilities.
7. This condition prohibits the use of slimicides and biocides containing trichlorophenol and
pentachlorophenol.
8. This condition requires the permittee to notify the DEQ Western Region office of any plant
malfunction that may cause an adverse impact to the environment or public health.
9. This conditions describes the necessary procedures for conducting whole effluent toxicity
testing.
10. This condition prohibits discharge of pollutants related to treatment of intake water and
allows permittee to blow back stream debris collected on intake screens into Olalla Creek.
6.6 Schedule F, NPDES General Conditions
All 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.
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,
22
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.
6.7 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.
23
Appendix A
Wastewater Treatment Diagram
Fresh Water Supply
Olalla Reseivoir
1
Pulp Mill
Digesters
Washers
Evaporators
Recovery Furnaces
Boiler Feedwater
Car Wash
Paper Mill
Paper Machines
Secondary Fiber
Whitewater Systems
Recausticizing
Green Liquor Clarifier
Slaker
Causticizers
White Liquor Clarifier
Mud Washing
Calcining
General Mill Uses
Fi rehouses
Wash down Hoses
General Mill Uses
Fi rehouses
Wash down Hoses
General Mill Uses
Fi rehouses
Wash down Hoses
Effluent Sump
and Pumps
Booster Station
Pumps
Water Supply and Discharge Schematic
Georgia-Pacific West, Inc.
Toledo Paper Operations
NOTE: This sketch provides only a general description of mill processes.
24
revised 11 - 04 - 2004
Appendix B
Reasonable Potential Analysis
(Metals, Ammonia, and Temperature)
METALS
Facility Name: GP Toledo
Dilution Values? (Y/N)
Y calculated
Dilution @ ZID
66
Dilution @ MZ
186
IF no dilution values enter info below
Facility Effluent Flow
*
7Q10
*
1Q10
*
% dilution at ZID
10
% dilution at MZ
25
Fresh Water? (Y/N)
n
PARAMETER
Date:
#of
Samples
Hardness
*
*
Effluent
Stream
Mixed
ZID
MZ
MGD
CFS
CFS
%
%
Coef. of
Varience
pg/i
COPPER +
LEAD +
ZINC +
2
2
1
100
400
19.00
21.00
48.00
0.60
0.60
0.60
(Hardness values should
be >25 and <400 mg/L)
395
398
Confidence Level
Probability Basis
Highest
Cone.
06/15/2005
95%
99%
Maximum
Effluent
Cone.
Background
Cone.
Maximum
Cone, at
ZID
pg/i
ug/i
Mg/i
104.50
115.50
432.00
0.2001
0.03709
0.8894
Maximum
Cone, at
MZ
ug/i
1.78
1.79
7.42
0.76
0.66
3.21
WQ CRITERIA
lHour
4 Day
(CMC)
(CCC)
Mg/i
2.90
140.00
95.00
NOTES :
All units in ug/L
Italics indicate pararameter was not detected, value is 1/2 the detection limit
* Insufficient data to develop criteria; value presented is the Lowest Observed Effect Level
+ Hardness dependent criteria
* - No acute standard. The CMC is estimated as 2X the CCC.
t - Not DEQ Criteria
A
Marine acute criterion has insufficient data to develop criteria; value = LOEL
25
pg/i
2.90
5.60
86.00
REASONABLE
POTENTIAL ?
ACUTE
NO
NO
NO
CHRONIC
NO
NO
NO
ZID
ZID
ZID
MZ
MZ
MZ
MZ
AMMONIA
Dilution Values? ( Y / N )
Y
calculated
Low Flow Dilution @ ZID (1Q10)
66
1.1
Low Flow Dilution @ MZ (7Q10)
Low Flow Dilution @ MZ (30Q5)
186
1.2
pH* =
186
1.2
High Flow Dilution @ ZID (1Q10)
1
High Flow Dilution @ MZ (7Q10)
High Flow Dilution @ MZ (30Q5)
1
1
Summer data
Effluent
Stream
8.0
8.0
( 6.5-9 )
Temp * =
20
20
20.0
20.0
°C
1.1
Alkalinity =
100
400
1.2
1.2
Salmonids Present? (Y/N)
Salmonid Spawning? (Y/N)
Fresh Water ? (Y/N)
Salinity (ppt)
y
n
0
n
33
32.5
32.8
7.0
20.0
7.0
20.0
0.0
0.0
1
1
1Q10 (CFS) =
7Q10 (CFS) =
1
1
1
1
pH* =
Temp * =
7
20
7
20
30Q5 (CFS) =
% dilution at MZ =
1
1
25
25
25
10
25
10
Alkalinity =
Salmonids Present? (Y/N)
Winter data
Probability Basis =
95%
#of
PARAMETER
Highest
Samples
Cone.
mg/l
Coef. of
Variance
Maximum
Effluent
Background
Cone.
mg/l
Cone.
mg/l
y
20
Salinity (ppt)
0
Maximum
Cone, at
Maximum
Cone, at
ZID
mg/l
( 6.5-9 )
°C
y
y
Salmonid Spawning? (Y/N)
Fresh Water ? (Y/N)
99%
MZ
8
Effluent Flow (mgd) =
Confidence Level =
Mixed
ZID
8
Enter data below if no dilution data is available
Data to estimate dilution
Summer
Winter
% dilution at ZID =
06/15/2005
Date:
Facility Name: GP Toledo
MZ
mg/l
WQ CRITERIA
Acute
Chronic
(CMC)
mg/l
(CCC)
mg/l
REASONABLE
POTENTIAL ?
ACUTE
CHRONIC
NO
NO
Low Flow Season
AMMONIA - 1986*
1
1.12
0.60
10.1
0.6
-NOTES
Temperature must be between 0 and 30 ° C
pH must be between 6.5 and 9
Ammonia is total ammonia as N
26
0.74
0.65
6.0
0.9
TEMPERATURE
Facility Name:
GP Toledo
Date:
2/17/2005
Enter data into white cells below:
Equation used to calculate - T at edge of MZ
Dilution =
186
AT
=f+(S-l)Ta
Ambient Temperature or Criterion
10.6 °C
S
Effluent Temperature
32.8 °C
Equation used to calculate thermal load limit
Allowable increase =
0.3 °C
TLL= 3.7%541QeSATallCpp
Effluent Flow Rate =
11.5 mgd
Where:
-J at edge of MZ=
Thermal Load Limit :
0.12 °C
N/A
No Reasonable Potential
Qe = Effluent Flow in mgd
S = Dilution
-^airSCAIIowable temperature increase
at edge of IV1Z (°C)
Cp = Specific Heat of Water (1 cal/g °C)
—ffl Density of Water (1 g/cm 3 )
3785.41 = Flow conversion from mgdtom'Vday
Million Kcals
27
Appendix C
Dissolved Oxygen Analysis
Modified Streeter-Phelps Dissolved Oxygen Model: Ocean Discharge
Taken from Amended Section 301(h) Technical Support Docment: EPA 842-B-94-007
Dist
Effluent
Temp (C)
26
DO(mg/L)
BOD 5 (mg/L)
(ml)
0.00
0.50
1.00
1.50
2.00
2.50
1
175
NH 3 -N(mg/L)
*
*
TKN ( m g / L )
Q (mgd)
K!(@20 C)
RM counter
0.5
11.50
0.23
Temp (C)
DO
BOD5
NH3
TKN
Initial Q (cfs)
10.6
9.02
1
0
0
1887 (calculated)
0.23
0.149
0.16
2.68
107
1887 cfs
1
Kd
U (fps)
U (mpd)
Initial Dilution
Corresponding Qe
IDOD
Calculations
0.2910
River
Tmix
UBODe ( m g / L )
UBODr(mg/L)
UBOD m (L„)
10.7
256.1
1.46
3.84
283.9
*
*
NH3 m
Norg m
Dosat mix
DO,
Do
9.02
8.94
0.08
D0100% sat
Temperature coefficients
Theta CBOD
Theta 0 2
Theta SOD
Theta NBOD
mg/L
1.047
1.024
1.065
1.08
9.02
33 Salinity
0 Elevation
Initial DO
DOi
UU
-- UDO
U
a
3.00
3.50
4.00
4.50
5.00
5.50
6.00
6.50
7.00
7.50
8.00
8.50
9.00
9.50
10.00
10.50
11.00
11.50
12.00
12.50
Dist
(ft)
0
2640
5280
7920
10560
13200
15840
18480
21120
23760
26400
29040
31680
34320
36960
39600
42240
44880
47520
50160
52800
55440
58080
60720
63360
66000
Time
1.118
1.304
1.491
1.677
1.863
2.049
2.236
2.422
2.608
2.795
2.981
3.167
3.354
3.540
3.726
3.913
4.099
4.285
4.472
4.658
Deficit Equation (Column O)
1
'
e
-IDOD-
sf
~DOa
D --
L0
kt
- ( 1 - - e~
S
28
Dilution
Dilution
(days) (from Plumes) After Init.
0.000
107
0
0.186
258
2.41
0.373
409
3.83
0.559
560
5.24
0.745
711
6.66
0.932
862
8.07
1013
1164
1315
1466
1617
1768
1919
2070
2221
2372
2523
2674
2825
2976
3127
3278
3429
3580
3731
3882
Deficit
fOm|j(|ng
(mg/L)
8.94
8.99
9.00
9.00
9.01
9.01
9.49
10.90
12.31
13.73
15.14
16.56
17.97
19.38
20.80
22.21
23.63
25.04
26.46
27.87
29.28
30.70
32.11
33.53
34.94
36.35
DOmJx&decay
(mg/L)
9.01
9.01
9.01
9.01
9.01
9.01
9.02
9.02
9.02
9.02
9.02
9.02
9.02
9.02
9.02
9.02
9.02
9.02
9.02
9.02
0.04
0.05
0.06
0.06
0.06
(mg/L)
9.02
8.94
8.94
8.95
8.95
8.95
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.06
0.05
0.05
0.05
0.05
8.95
8.95
8.95
8.95
8.95
8.95
8.95
8.96
8.96
8.96
8.96
8.96
8.96
8.96
8.96
8.96
8.96
8.96
8.96
8.96
DO Equation (Column M)
DO
)
DO = DOa + (
-DO
2-)
l
Appendix D: 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: Discharge of treated pulp and paper effluent
Is this review for a ( renewal) OR new
Go to Step 2.
V__^X
2.
Is this surface water an Outstanding Resource Water or upstream from an Outstanding
Resource Water?
^-¥es^
f No. J )
3.
Go to Step 5.
Go to Step 3.
Is this surface water a High Quality Water?
Yesy
No.
8.
(circle one) permit application?
Go to Step 8.
Go to Step 4.
Will the proposed activity result in a Lowering of Water Quality in the High Quality Water?
G o t0
J£&L
Step 9.
f No. j Proceed with Permit Application. Applicant should provide basis for conclusion. Go to
^
s
Step 24.
This conclusion is explained and supported by data and evaluations included with the permit evaluation
report and attachments accompanying the proposed NPDES permit renewal. This is an existing discharge
and there is no change in their operation. There is no request for a mass load increase.
24.
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:
Phone:
Date Prepared:
Western Region - WQ Permitting
Steve Schnurbusch_
503-378-8240 x284
February 9, 2004
29