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SOLVAY CHEMICALS, INC.
WASTEWATER ENGINEERING REPORT (Accordance per WAC 173-240-130)
And
CITY OF LONGVIEW
GENERAL SEWER PLAN AMENDMENT
Longview, Washington
Prepared By:
February 2019 Gibbs & Olson Project No. 0788.0189
Solvay Chemicals, Inc. Revised Draft Engineering Report
Table of Contents
Introduction ..................................................................................................................... 1
Wastewater Characteristics, Flow History and Design Values ........................................ 3
TRRWA NPDES Permit & Pretreatment Policy ............................................................... 7
Proposed Pretreatment of pH .......................................................................................... 8
Projected Total Flow to Public System ............................................................................ 8
Proposed Connection to City's Sewer System ................................................................ 9
Funding & Opinion of Project Cost ................................................................................ 14
Schedule ....................................................................................................................... 14
SEPA Compliance ......................................................................................................... 15
Tables
Table 1 – January through December 2013 Wastewater Monitoring Results .................. 4
Table 2 – Wastewater Monitoring Results December 2016 through November 2018 ..... 4
Table 3 – Lab Results for May 2018 Solvay Process Wastewater Composite Samples . 5
Table 4 – Solvay Wastewater Design Criteria ................................................................. 5
Table 5 – TRRWA Local Pollutant Discharge Limits .................................................... 7-8
Figures
Figure 1 – City of Longview General Sewer Plan Sewer Service Area ........................... 2
Figure 2 – Solvay Water Balance Schematic .................................................................. 6
Figure 3 – Site Map ....................................................................................................... 11
Figure 4 – Proposed Sewer Connection to City of Longview Sewer System at Weber Avenue ......................................................................................................... 12
Figure 5 – Connection to Weber Avenue Sewer ........................................................... 13
Appendix
Appendix A – Solvay Chemicals, Inc.State Waste Discharge Permit Number ST0006070 and Fact Sheet.
Appendix B – TRRWA’s NPDES Permit No. WA0037788 and FACT SHEET
Appendix C – Summary Spreadsheet of Solvay’s Monitoring Discharge Monitoring Reports submitted to Ecology for December 2016 through November 2018
Appendix D – Engineer’s Opinion of Project Cost for Sewer System Improvements form Solvay’s Pipe Rack to Discharge Manhole in Weber Avenue
Draft Engineering Report & General Sewer Plan Amendment: February 2019 Solvay Chemicals, Inc., Longview, WA Gibbs & Olson Project No. 0788.0189
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INTRODUCTION
Solvay Chemicals, Inc. (Solvay) operates a facility at 3500 Industrial Way, Longview, Washington (Cowlitz
County parcel numbers 101930100, 10209 and 053603524) which produces hydrogen peroxide and
currently discharges an average daily flow volume of approximately 106,000 gallons per day (gpd), or
0.106 million gallons per day (MGD), of industrial wastewater from this facility under Washington State
Waste Discharge Permit No. ST0006070 to Nippon Dynawave (formerly Weyerhaeuser) Longview’s
wastewater treatment plant. After treatment, the water is discharged to the Columbia River through
Nippon Dynawave Longview’s 001/002 outfalls. Solvay also separately discharges approximately 1,000
gpd of domestic sewage to Nippon’s domestic wastewater treatment facility.
Solvay’s Longview facility typically operates 24 hours per day, seven days per week for 51 weeks per
year producing hydrogen peroxide (SIC code 2819). The process is a continuous closed loop process. In
the process an organic working solution is hydrogenated in the presence of a metal catalyst and then
oxidized. The result is hydrogen peroxide which is soluble in water and removed from the working
solution. Following the hydrogen peroxide extraction, the working solution returns to the hydrogenation
reactor and the process is repeated. The hydrogen used in the process is produced onsite by two steam‐
methane reformers with supplemental hydrogen being supplied from a local chemical facility. Much of
the hydrogen peroxide product is distilled to produce higher product strengths. The hydrogen peroxide
is stored onsite and is loaded into trailers, railcars, or shipped by pipeline to customers in concentrations
from 27 to 70%.
Solvay performs settling and oil water separation for certain wastewater streams and all wastewater
undergoes pH adjustment prior to discharge to the Nippon Dynawave Longview treatment facility.
Solvay desires to change their discharge of industrial wastewater from the Nippon Dynawave Longview
wastewater treatment facility to the Three Rivers Regional Wastewater Treatment Plant by conveying
and discharging their waste flow to the City of Longview’s (City) sanitary sewer conveyance system in
Weber Avenue. Solvay’s Longview facility is in the Longview city limits and in the City’s sanitary sewer
area as shown in the City’s current General Sewer Plan (GSP), see Figure 1.
This report is intended to serve as both an engineering report per Washington Administrative Code
(WAC) 173‐240‐130.
City of LongviewGeneral Sewer Plan Amendment
Sewer Service Area MapFigure 1
0 2500 5000 10000
Scale: (in Feet)
Existing West LongviewSewer Service Area
Existing East LongviewSewer Service Area
LEGEND
Project Location
Longview
WashingtonState
Columbia River
KelsoLongview
Cowlitz River
Rainier
LongviewWye
Interchange
Interstate 5
Hwy. 30
SR 4
33
Exit 36
Exit 39
Exit 40
CoweemanRiver
Mount Solo
SR 4
TRRWAPlant
Future West LongviewSewer Service Areas
Future East LongviewSewer Service Areas
Longview City Boundary
Existing Sewer Sub-BasinsL-15
Sewer Service AreaExpansion as Part of GSPAmendment October 2014
SR 432
Project Area withinSewer Service Area
Draft Engineering Report & General Sewer Plan Amendment: February 2019 Solvay Chemicals, Inc., Longview, WA Gibbs & Olson Project No. 0788.0189
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WASTEWATER CHARACTERISTICS AND FLOW
HISTORY AND DESIGN VALUES
Solvay’s Longview facility was constructed in 1988 and started producing hydrogen peroxide in 1989.
The facility was expanded in 1991. In 1993 a steam methane reformer was installed to produce
hydrogen for the process. An additional expansion in 1995 allowed for an increase in production. A third
expansion to increase production capacity was completed in 2016. Solvay has consistently complied
with the effluent limits and conditions contained within its state waste discharge permit for industrial
process wastewater.
Under its current state waste discharge permit that expires on September 30, 2019 (effective date
October 1, 2014), Solvay is required to continuously monitor its industrial process wastewater for flow
and pH. These are the two constituents Solvay is required to report on its monthly discharge monitoring
reports (DMRs) submitted to Ecology. The current permit requires Solvay’s discharge to have a pH
between 4.0 and 12.2 S.U. A copy of Solvay’s current State Waste Discharge Permit and associated Fact
Sheet are included in Appendix A. Solvay’s average daily discharge of industrial wastewater has been
approximately 106,000 gallons per day (gpd) or 0.106 million gallons per day (mgd).
Solvay plans to implement a project that will result in the termination of Solvay’s wastewater being
discharged to the Nippon Dynawave Longview Wastewater Treatment plant. Solvay’s plan is to obtain
approval from the City, Three Rivers Regional Wastewater Authority (TRRWA) and Ecology to re‐route its
industrial wastewater north and to connect to the City’s existing sanitary sewer conveyance system
which will convey the waste flow to the TRRWA regional collection system and regional treatment plant
for treatment and discharge to the Columbia River under TRRWA NPDES Permit Number WA0037788.
Copies of TRRWA’s NPDES permit and associated Fact Sheet are included in Appendix B.
Primary objectives of wastewater planning are to ensure adequate conveyance and treatment capacity
is provided to meet the community’s needs, to ensure such facilities minimize adverse impacts on the
environment, and to protect the health and safety of the community. This report will document that
Solvay’s proposed discharge of its wastewater to the City of Longview’s conveyance system for
treatment at the Three Rivers Regional Wastewater Treatment Plant will not adversely impact either the
conveyance system or the publicly owned treatment plant.
Both the City’s conveyance system and the TRRWA regional plant have sufficient unused capacity to
support Solvay’s proposed wastewater discharge with no improvements to the public systems being
Draft Engineering Report & General Sewer Plan Amendment: February 2019 Solvay Chemicals, Inc., Longview, WA Gibbs & Olson Project No. 0788.0189
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required. Both the City and TRRWA have been involved in discussions with Solvay in this determination.
With the exception of the standard public connection from the property line to the existing public sewer
in Weber Avenue, all of the required capital improvements will be on Solvay’s privately‐owned industrial
property.
Industrial process wastewater monitoring results for TSS and pH from January 2013 through December
2013 as shown in the current permit’s fact sheet is presented in Table 1 for both TSS and pH. Table 2
shows wastewater monitoring results for December 2016 through November 2018. A more detailed
spreadsheet of this data is in Appendix C.
Table 1: January through December 2013
from the Fact Sheet for Solvay’s current State Waste Discharge Permit
Parameter Units No. of Samples Avg. Value Max. Value
TSS mg/l 151 16 56
Parameter Units No. of Samples Min. Value Max. Value
pH S.U. Continuous 7 11.2
Table 2: Wastewater Monitoring Results December 2016 through November 2018
pH Instantaneous Minimum (S.U.)
pH instantaneous Maximum (S.U.)
Average Daily Flow
(gpd)
Max. Month Avg. Daily Flow
(gpd)
Peak Day Flow (gpd)
5.179 11.375 106,388 142,555 211,370
In April 2018 Gibbs & Olson consulted with TRRWA staff to request a list of wastewater parameters that
TRRWA would require Solvay sample and test for to determine if Solvay’s industrial wastewater would
require pre‐treatment to avoid adversely impacting the regional wastewater treatment plant’s ability to
meet its NPDES permit effluent requirements. TRRWA indicated they would need to see results for TSS,
Biochemical Oxygen Demand (BOD), Ammonia as Nitrogen and pH with composite sampling utilized
rather than a grab or a series of grab samples. Solvay obtained 24‐hour composite samples of its
industrial wastewater on May 15, 2018, May 22, 2018 and May 25, 2018 and submitted each of these
samples to the ALS Environmental lab in Kelso, Washington for testing. Solvay also had testing
performed for total inorganic carbon, total organic carbon (TOC), chemical oxygen demand (COD) and
volatile suspended solids (VSS) in addition to the specific parameters requested by TRRWA. Table 3
presents the lab results for the constituents identified above for each of the three composite samples.
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Table 3: Lab Results for May 2018 Solvay Wastewater Composite Samples
Parameter Tested
Composite Sample Date
5/15/2018 5/22/2018 5/29/2018
Ammonia as Nitrogen 5.08 mg/l 5.26 mg/l 4.93 mg/l
TSS 36 mg/l 43.5 mg/l 24.0 mg/l
BOD 121 mg/l 127 mg/l 121 mg/l
pH 11.35 S.U. 11.25 S.U. 11.26 S.U.
Carbon, Total Inorganic 38.4 mg/l 36.4 mg/l 31.2 mg/l
TOC 480 mg/l 480 mg/l 430 mg/l
COD 1870 mg/l 1600 mg/l 1690 mg/l
VSS ND 8.0 mg/l ND 1 – 12 mg/l is the method reporting limit for the test method, test result was listed as non‐detect
The lab results for the three composite samples presented in Table 3 were shared with TRRWA in late
July of 2018. TRRWA indicated that based on these results, Solvay’s wastewater can be accepted by
TRRWA if Solvay performs pre‐treatment necessary to ensure the pH of the wastewater prior to
discharge to the City’s conveyance system is between 6.0 and 9.0 S.U. No other pretreatment will be
necessary for the Solvay’s wastewater to be acceptable to TRRWA. Solvay’s industrial wastewater flow
will be metered and sampled for pH.
As previously noted, in addition to its industrial wastewater, Solvay discharges approximately 1,000 gpd
of domestic sewage. Under this project, this small stream of domestic wastewater will be combined with
the industrial wastewater and the combined waste flow will be conveyed to the public system. The
domestic wastewater is anticipated to fully meet all TRRWA pre‐treatment requirements and no
sampling or flow metering of the domestic waste flow will occur.
Solvay is implementing process changes that will reduce their average daily discharge from 0.106 mgd to
0.076 mgd. Refer to Solvay’s Water Balance for the Longview Facility in Figure 2 on the next page. Solvay
wastewater design criteria for the proposed discharge to the City’s conveyance system and treatment at
the TRRWA regional wastewater treatment plant is summarized in Table 4 below.
Table 4: Solvay Wastewater Design Criteria
Design Parameter Design Criteria
Average Daily Flow 76,250 gpd
Maximum Month Average Daily Flow 143,000 gpd
Peak Day Flow 240,000 gpd
TSS <350 mg/l
BOD5 <350 mg/l
Ammonia <44 mg/l
pH >6.0 and <9.0 S.U.
Cooling TowerMake-up
200,160 GPD
CT Blowdown20,160 GPD
Evaporation180,000 GPD
Shipping2,880 GPD
Final Product93,780 GPD
Process Water & Make-up
56,330 GPD
Boiler Feed Water94,160 GPD Steam to Reformers (to
produce H2)49,680 GPD
Steam to Distillation63,440 GPD
Deaerator Vent4,170 GPD
Steam to AO plant14,050 GPD
Reversion Wash Water
42,670 GPD
Other Users (filter cleaning, laboratories, maintenance activities)
750 GPD
Effluent Settling Tank27,600 GPD
CPI Separator74,750 GPD
pH Adjustment75,250 GPD
Process Area Stormwater13,530 GPD
Waste Stream to Outfall 00176,250 GPD
Water Usage Schematic and Balance for Solvay Chemicals, Inc. Longview Facility(Flows indicated are average daily flows)
Basis for NPDES Applications
Final Product Stabilizers490 GPD
Nitric Acid3,260 GPD
100 GPD
atm.
Steam Vent2,000 GPD
Boiler Blowdown3,600 GPD
atm.
atm.
15,550 GPD
150 GPD
Effluent Sumps27,600 GPD
56,180 GPD
23,160 GPD 9,760 GPD
4,290 GPD
19,510 GPD
3,160 GPD
32,680 GPD
Acid/Caustic for pH500 GPD
Well Water489,060 GPD
Filtered Water473,760 GPD
Demineralized water141,120 GPD
Continuous Reject water132,480 GPD
Intermittent Reject water20,400 GPD
Product (Water for H2)34,130 GPD
Clean Reject Water to Outfall 002173,040 GPD
(Future 210,190)
Sanitary1,000 GPD
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TRRWA NPDES PERMIT & PRETREATMENT POLICY
Section S6 of TRRWA’s NPDES permit outlines pretreatment requirements that each of the jurisdictions
(City of Longview, City of Kelso, Beacon Hill Water & Sewer District, and Cowlitz County) contributing
flow to the TRRWA regional wastewater treatment must meet. For the proposed Solvay discharge to the
City of Longview’s conveyance system, the City will need to work with Ecology to ensure that Solvay will
be in compliance with the pretreatment regulations in 40 Code of Federal Regulations (CFR) Part 403
and any additional regulations that may be promulgated under Section 307(b) (pretreatment) and 308
(reporting) of the Federal Clean Water Act. Additionally, the City cannot allow Solvay to begin
discharging industrial wastewater to the City’s conveyance system until Solvay receives a wastewater
discharge permit from Ecology in accordance with Chapter 90.48 Revised Code of Washington (RCW).
TRRWA’s pretreatment policy defines a Categorical Industrial User (CIU) as an industrial user subject to a
categorical pretreatment standard or categorical standard. Such industries are regulated by Ecology and
receive a permit from Ecology. Solvay will be CIU under TRRWA’s pretreatment policy and will be
required to obtain a wastewater discharge permit from Ecology prior to being able to discharge flow to
the City’s conveyance system for treatment at the TRRWA regional wastewater treatment. Additionally,
Solvay will be considered a Significant Industrial User (SIU) under TRRWA’s pretreatment policy because
it will discharge more than 25,000 gpd of process wastewater. Local pollutant discharge limits as
identified in TRRWA’s pretreatment policy are listed in Table 4 below.
Table 5: TRRWA Local Pollutant Discharge Limits
Analyte Daily Maximum
Concentration Limit Instantaneous
Concentration Limit
Antimony Arsenic Cadmium Chromium +6 Chromium +3 Copper Cyanide (total) Lead Mercury Molybdenum Nickel Selenium Silver Thallium Zinc Fats, oil, grease (animal/vegetable based)
6.8 mg/l 0.9 mg/l 0.3 mg/l 4.5 mg/l 5.0 mg/l 3.5 mg/l 2.2 mg/l 0.8 mg/l 0.02 mg/l 3.4 mg/l 5.0 mg/l 1.0 mg/l 0.1 mg/l 0.2 mg/l 4.6 mg/l 100 mg/l
6.8 mg/l 0.9 mg/l 0.3 mg/l 4.5 mg/l 5.0 mg/l 3.5 mg/l 2.2 mg/l 0.8 mg/l 0.02 mg/l 3.4 mg/l 5.0 mg/l 1.0 mg/l 0.1 mg/l 0.2 mg/l 4.6 mg/l 100 mg/l
Draft Engineering Report & General Sewer Plan Amendment: February 2019 Solvay Chemicals, Inc., Longview, WA Gibbs & Olson Project No. 0788.0189
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Hydrocarbon based oils & grease Minimum pH Maximum pH Biochemical Oxygen Demand (BOD5) Total Suspended Solids Total Ammonia
100 mg/l 6.0 S.U. 9.0 S.U. 350 mg/l 350 mg/l 44 mg/l
100 mg/l 6.0 S.U. 9.0 S.U. 350 mg/l 350 mg/l 44 mg/l
As previously noted, Solvay will need to perform pretreatment on its wastewater so that the wastewater
discharged into the City’s collection system has a pH between 6.0 and 9.0 S.U. Based on currently
available information, no other pretreatment is required for Solvay’s wastewater to comply with
TRRWA’s local pollutant discharge limits.
PROPOSED PRETREATMENT OF pH
Solvay currently uses nitric acid to adjust alkaline pH and caustic soda to adjust acidic pH. Solvay
understands they will need to modify their pH adjustment process to meet the tighter pH range (> 6.0 to
< 9.0 S.U.) for their wastewater prior to being discharged to the public system. Solvay has run numerous
test trials to adjust their wastewater pH to be between 6.0 to 9.0 S.U. Solvay reports that these trials
have had extremely positive results with minor adjustments to current onsite processes.
To verify adequate pretreatment of pH, Solvay’s current system has two pH meters in parallel which
allows for one meter to be down for planned routine maintenance. As a line of additional safety,
Solvay’s system includes an automatic interlock that closes the discharge line valve when the
measurement on either pH meter exceeds either the minimum or the maximum set points. As necessary
to achieve an acceptable pH, flow is recycled in a closed loop back to the pH adjustment tank until issues
are identified and corrected.
Solvay is considering changing from nitric acid to sulfuric acid to adjust alkaline pH in the future because
sulfuric acid is anticipated to be more cost effective for the tighter pH range required for discharge to
the public system.
PROJECTED TOTAL FLOW TO PUBLIC SYSTEM
Solvay’s wastewater flow will be increase flow from the East Longview Service Service Area (ELSAA). The
City’s current GSP estimated the year 2015 and 2020 annual average daily flow for the ELSSA as 5.12 and
5.15 million gallons per day (MGD), and the maximum month average day flow as 12.96 and 12.99 MGD
respectively. The additional 0.076 MGD annual average daily flow from Solvay is anticipated to increase
Draft Engineering Report & General Sewer Plan Amendment: February 2019 Solvay Chemicals, Inc., Longview, WA Gibbs & Olson Project No. 0788.0189
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the 2020 annual average daily flow from the ELSSA by 1.4 percent. The additional 0.143 MGD maximum
monthly average daily flow from Solvay is anticipated to increase the 2020 maximum monthly average
daily flow from the ELSSA by 1.1 percent. Solvay’s flow will be a minor component of Longview’s overall
sewer flows and will not adversely impact the ability of the City’s sewer conveyance system to convey
flow to the regional treatment plant. They will also not adversely impact the hydraulic capacity of the
City’s conveyance system, TRRWA’s regional conveyance system, or TRRWA’s regional treatment plant.
It is anticipated that the flow from Solvay may help mitigate periodic issues of septicity that occurs
during the dry weather season due to infrequent cycling of the City’s Mint Farm sanitary sewer pump
station. The periodic septic conditions have occasionally created some issues at the regional treatment
plant and the additional flow from Solvay will help reduce cycle times for the Mint Farm pump station
and thereby will help to reduce the potential for the wastewater to become septic.
The current capacity of the TRRWA regional wastewater treatment plant is 26 MGD (Maximum Monthly
Average Daily Flow) and 62.4 MGD (Peak Day Flow) per TRRWA’s current NPDES permit. Section VI of
the City’s 2008 GSP states “….an evaluation was preformed to determine whether the TRRWP would
have enough capacity for area growth, through the year 2030. The evaluation shows that the TRRWP
possesses sufficient capacity to meet DOE Water Quality Standard through the year 2030.” This section
also states, “TRRWA staff actively track and manage the facility to ensure adequate treatment capacity
and to provide a means to manage significant industrial and commercial discharge.” Based on the 2008
GSP and correspondence with TRRWA staff regarding the proposed wastewater flow and waste load
from Solvay, it has been determined the expansion of the SSA proposed herein will not adversely affect
the 2008 GSP evaluation.
The information above supports that no improvements will be required for the public infrastructure to
accept, convey and treat Solvay’s wastewater flow.
PROPOSED CONNECTION TO CITY’S SEWER SYSTEM
Proposed modifications to allow Solvay to discharge to the City’s conveyance system consists of
rerouting both a 2‐inch sanitary forcemain and a 4‐inch process effluent forcemain, a new discharge
manhole, and a new 8‐inch gravity pipeline that will be connected to an existing manhole in Weber
Avenue as shown in Figures 3, 4 and 5. The gravity pipeline within Solvay’s property will be 8‐inch
diameter fusion welded high‐density polyethylene (HDPE) pipe. The gravity pipe will transition to 8‐inch
PVC with a cleanout at the Weber Avenue right‐of‐way as required by the City of Longview. The re‐
Draft Engineering Report & General Sewer Plan Amendment: February 2019 Solvay Chemicals, Inc., Longview, WA Gibbs & Olson Project No. 0788.0189
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routed 2‐inch forcemain will be connected to the 4‐inch process effluent flow main as shown in Figure 3.
The existing 2‐inch and 4‐inch forcemains will be properly decommissioned onsite near where they
currently leave the property to cross CDID1 Ditch 5 and State Highway 432 (Industrial Way) to Nippon
Dynawave’s facility.
Wastewater will be discharged through a 6‐inch forcemain located on Solvay’s above ground pipe rack
system until it reaches the end of the rack located in the far northwest side of the facility within the
existing facility fencing. The total length of forcemain piping to be installed onsite is approximately 500
feet. At an estimated peak hour flow rate of 170 gpm the new 6‐inch forcemain will have a velocity of
1.9 feet per second (fps) and can convey up to 705 gpm at a maximum recommended velocity of 8 fps.
At this point the forcemain will transition to an underground 8‐inch gravity HPDE pipeline within
Solvay’s property and will transition to 8‐inch PVC pipe with cleanout at the Weber Avenue right‐of‐way
as required by the City. Approximately 670 feet of new 8‐inch HDPE pipeline with a minimum
slope of 0.004 feet per foot and 30 feet of 8‐inch PVC pipeline with a minimum slope of .004 feet per foot
will be constructed and will connect to the City’s collection system in Weber Avenue. Solvay intends to
install cleanouts along the 8‐inch HDPE pipeline, as needed, to provide a means to clean the
pipeline in the future. Addtionally, a cleanout will be installed at the Weber Avenue right‐of‐
way on the 8‐inch PVC pipe to allow City crews to be able to clean the portion of the sewer lateral
within the public right‐of‐way. The cleanout at the right‐of‐way will physically delineate the change
in ownership of the new sewer facilities. All items on the private property side of the cleanout
(southside) will be owned, operated, and maintained after construction by Solvay. The cleanout
and everything north of it will be owned and maintained by the City of Longview. Until design survey
and final design is completed, the preliminary location to tie‐in into the existing system is estimated to
connect at an existing manhole at station 39+00 as shown on the Weber Avenue Record Drawing in
Figure 4.
TRRWA has indicated that based on the test results from composite sampling performed in May and
June of 2018, that they will not require composite sampling or flow metering to occur. The City indicated
they will utilize Solvay’s process wastewater flow meter for determining the amount of process flow
each month. Additionally, the small sanitary flow will be determined from Solvay’s potable water meter
reading.
FIG
UR
E 3
SIT
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WA
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~450'
~650'
~330'
~250'
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Pro
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Sew
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Sew
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Rep
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Con
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8"
Sew
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ater
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Sol
vay
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A
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ewer
New
cle
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t at
prop
erty
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New 8" sewer lateral from Solvay see Figs. 3 & 4 for full length
Connection to Weber Ave. MH 10
New cleanout at property line
Figure 5 Connection to Weber Avenue Sewer
Solvay Wastewater Engineering Report
Draft Engineering Report & General Sewer Plan Amendment: February 2019 Solvay Chemicals, Inc., Longview, WA Gibbs & Olson Project No. 0788.0189
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Discussions with the City and TRRWA also resulted in both entities indicating they would not require a
dedicated grab sample port at the property boundary. Solvay agreed that the City and TRRWA will both
be able to obtain samples from within Solvay’s facility at any time without scheduling an appointment.
After Solvay’s flow enters the City’s existing 18‐inch gravity sewer main in Weber Avenue it will then
continue to flow down the gravity sewer main north to Hoehne Ave, west to Prudential Boulevard, and
then north to the Mint Farm Pump Station. As part of the City’s West Longview Sewer Diversion Project
in 2010, the Mint Farm Pump Station was upgraded by installing two additional pumps. The Mint Farm
Pump Station currently has two smaller pumps, each with a capacity of 4,700 gpm (6.8 MGD), and two
larger pumps, each with a capacity of 6,600 gpm (9.5 MGD). The City’s 2008 GSP estimated this pump
station needs to handle 12,000 gpm (17.3 MPD) in 2030. The existing pumps can convey this much flow
with one pump out of service. Currently, the City typically only needs to operate one of the smaller
pumps to handle existing flows.
In summary all the planning level private and public improvements are within existing maximum day
flow rates and recommended component sizing will provide adequate capacity to allow for Solvay to
increase wastewater flow discharged to the public system up to 0.45 MGD, 84% more than Solvay’s
current calculated peak hour flow rate of 0.245 MGD.
All design and construction of the proposed sanitary sewer improvements will be in accordance with
Ecology requirements and City of Longview Standards for work performed within the right of way.
FUNDING & OPINION OF PROJECT COST
The proposed improvements identified in the previous section will be privately financed by Solvay. In
addition, it is anticipated that Solvay will be required to pay a TRRWA impact fee and a City sewer
connection fee upon Ecology, TRRWA and City of Longview approval of the new sewer connection and
issuance of required public improvement permits. The estimated cost of the portion of the proposed
project from the northwest end of Solvay’s pipe rack to Weber Avenue is $227,000 as detailed in
Appendix D.
SCHEDULE
It is planned to have this Engineering Report approved as part of Solvay’s NDPES permit application
process and design is progressing. The project is anticipated to be constructed prior to the end of 2019.
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SEPA COMPLIANCE
Because the pipelines for the proposed sewer improvements summarized in this report are 12‐inches or
less in diameter, SEPA compliance is not required for design and construction of these improvements
per WAC 173‐800‐23.
APPENDICES
Appendix A:
Solvay Chemicals, Inc. State Waste Discharge Permit Number ST0006070
Solvay’s Chemicals, Inc. Fact Sheet for State Waste Discharge Permit ST0006070
Issuance Date: Effective Date: Expiration Date:
September 11, 2014 October 1, 2014 September 30, 2019
State Waste Discharge Permit Number ST0006070
State of Washington Department of Ecology
Olympia, Washington 98504-7600 Industrial Section
PO Box 47600 Olympia, WA 98504-7600
In compliance with the provisions of the State of Washington Water Pollution Control Law
Chapter 90.48 Revised Code of Washington, as amended,
Solvay Chemicals, Inc. 3500 Industrial Way
Longview, Washington 98632
is authorized to discharge wastewater in accordance with the special and general conditions which follow.
Facility Location: 3500 Industrial Way Longview, Washington 98632
Industry Type:
Hydrogen Peroxide Manufacturing
SIC Code: 2819
NAICS Code: 325180
Treatment Facility Receiving Discharge:
Weyerhaeuser NR Company, Longview
Garin Schrieve, P .E. Industrial Section Manager Waste 2 Resources Program
Page 2 of33 Pennit No. ST0006070
Table of Contents
Su1nmary of Pernzit Report Subntittals ......................................................................................... 4
Special Conditio1zs .......................................................................................................................... 5
81. Discharge Li1nits ................................................................................................... 5
S2. Monitoring Requirements .................................................................................... 5 S2.A. Monitoring Requirements ....................................................................................... 5 S2.B. Sampling and Analytical Procedures ...................................................................... 6 S2.C. Flow Measurement and Continuous Monitoring Devices ...................................... 6 S2.D. Laboratory Accreditation ........................................................................................ ? S2.E. Request for Reduction in Monitoring ..................................................................... 7
S3. Reporting and Recording Requirements ............................................................ 7 S3 .A. Reporting ................................................................................................................ 7 S3.B. Permit Submittals and Schedules ............................................................................ 9 S3.C. Records Retention ................................................................................................... 9 S3.D. Recording ofResults ............................................................................................... 9 S3.E. Additional Monitoring by the Pe1mittee ................................................................. 9 S3.F. Repmting Permit Violations ................................................................................. ! 0 S3.G. Other Repmting .................................................................................................... 11 S3.H. Maintaining a Copy of this Permit.. ............................................... , ...................... l2 S3.I. Dangerous Waste Discharge Notification ............................................................. 12 S3.J. Spill Notification ................................................................................................... 12
84. Operation and Maintenance .............................................................................. 12 S4.A. Operations and Maintenance Manual ................................................................... l2 S4.B. Bypass Procedures ................................................................................................ 13
85. Prohibited Discharges ......................................................................................... 15 S5 .A. General Prohibitions ............................................................................................. 15 S5.B. Specific Prohibitions ............................................................................................. 15 S5.C. Prohibited Unless Approved ................................................................................. 16
86. Dilution Prohibited ............................................................................................. 16
87. Solid Waste Disposal ........................................................................................... 16 S7.A. Solid Waste Handling ........................................................................................... 16 S7.B. Leachate ................................................................................................. , .............. 16
S8. Application for Pe1·mit Renewal or Modification for Facility Changes ......... 17
S9. Non-Routine Discharges ..................................................................................... 17
810. Spill Control Plan ................................................................................................ 17 SlO.A. Spill Control Plan Submittals and Requirements .................................................. 17 S 1 O.B. Spill Control Plan Components ............................................................................ 18
811. Slug Discharge Control Plan .............................................................................. 18
Ge1zeral Co1tditio1zs ...................................................................................................................... 20
Gl.
G2.
G3.
G4.
GS.
G6.
G7.
G8.
G9.
GlO.
Gll.
G12.
G13.
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Signatory Requirements ..................................................................................... 20
Right of Entry ...................................................................................................... 20
Perritit Actions ..................................................................................................... 21
Reporting a Cause for Modification .................................................................. 21
Plan Review Required ........................................................................................ 21
Compliance with other Laws and Statutes ....................................................... 21
Transfer of this Permit ....................................................................................... 21
Reduced Production for Compliance ..•.....•....................................................... 22
Removed Substances ........................................................................................... 22
Payment of Fees ................................................................................................... 22
Penalties for Violating Permit Conditions ........................................................ 22
Ducy to Provide Information .............................................................................. 22
Duty to Comply .................................................•.......•....................................•.... 22
Appendix A ................................................................................................................................... 24
Page 4 of33 Pennit No. ST0006070
Summary of Permit Report Submittals
Refer to the Special and General Conditions of this permit for additional submittal requirements.
Permit Submittal Frequency First Submittal Date Section
S3.A. Discharge Monitoring Repott Monthly S3.E Reporting Petmit Violations As necessary S3.F Other Repotting As necessary S4.B Reporting Bypasses As necessary S8. Application for Pennit Renewal !/permit cycle April!, 2019 S9. Non-Routine Discharge Request As necessary SlO. Spill Plan 1/permit cycle, April!, 2015
updates submitted as necessary
Sll. Slug Discharge Control Plan Update 1/permit cycle, April!, 2015 updates submitted as necessary
01. Notice of Change in Authorization As necessary 04. Permit Application for Substantive As necessary
Changes to the Discharge 05. Engineering Repott for Construction or As necessary
Modification Activities 07 Notice of Permit Transfer As necessary 08 Payment of Fees As assessed 010 Duty to Provide Infonnation As necessary
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Permit No. ST0006070
Special Conditions
Sl. Discharge Limits
pH
All discharges and activities authorized by this permit must comply with the terms and conditions of this petmit. The discharge of any of the following pollutants more frequently than, or at a concentration in excess of, that authorized by this petmit violates the terms and conditions of this petmit.
Beginning on the effective date, the Permittee is authorized to discharge wastewater and cooling tower water to the Weyerhaeuser Longview wastewater treatment plant subject to the following limits:
Effluent Limit: Outfall# 001 Latitude 46.135739 Longitude 122.982717 ..
Parameter Effluent Limit 4.0 <pH <12.2
S2. Monitoring Requirements
S2.A. Monitoring Requirements
The Permittee must monitor the wastewater and production according to the following schedule:
The Permittee must monitor in accordance with the following schedule and the requirements specified in Appendix A.
Parameter Units Sampling Sample Type Frequency
(1) Final Wastewater Effluent
Flow gallons/day Continuous a Metered/recorded (gpd)
pH Standard Continuous a Metered/recorded Units
. .
(2) Effluent Characterization -Final Wastewater Effluent
Cyanide ).lg/L 1/Petmit Cycle Grab
Total Phenolic ).lg/L !/Permit Cycle Grab Compounds
Priority Pollutants (PP)- ).lg/L; ng/L !/Permit Cycle 24-Hour composite 0
Total Metals for mercury Grab for mercury
PP -Volatile Organic ).lg/L 1/Petmit Cycle Grab Compounds
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Parameter Units Sampling Sample Type Frequency
PP -Acid-extractable J.lg/L !/Permit Cycle 24-Hour composite o
Compounds
PP- Base-neutral J.lg/L !/Permit Cycle 24-Hour composite b
Compounds
PP- Dioxin pg/L !/Permit Cycle 24-Hour composite b
PP - Pesticides/PCBs J.lg/L 1/Petmit Cycle 24-Hour composite b
a
b
Continuous means uninterrupted except for brief lengths of time for calibration, power failure, or unanticipated equipment repair or maintenance. The Permittee must sample daily when continuous monitoring is not possible .
.
24-hour composite means a series of individual samples collected over a 24-hour period into a single container, and analyzed as one sample.
S2.B. Sampling and Analytical Procedures
Samples and measurements taken to meet the requirements of this permit must represent the volume and nature of the monitored parameters, including representative sampling of any unusual discharge or discharge condition, including bypasses, upsets and maintenance-related conditions affecting effluent quality.
Sampling and analytical methods used to meet the water and wastewater monitoring requirements specified in this permit must confotm to the latest revision of the following rules and documents unless otherwise specified in this permit or approved in writing by Ecology.
• Guidelines Establishing Test Procedures for the Analysis of Pollutants contained in 40 CFR Part 136
• Standard Methods for the Examination of Water and Wastewater (APHA)
S2.C. Flow Measurement and Continuous Monitoring Devices
The Permittee must:
1. Select and use appropriate flow measurement and continuous monitoring devices and methods consistent with accepted scientific practices.
2. Install, calibrate, and maintain these devices to ensure the accuracy of the measurements is consistent with the accepted industry standard and the manufacturer's recommendation for that type of device.
3. Calibrate continuous monitoring instruments weekly unless it can demonstrate a longer period is sufficient based on monitoring records. The Permittee:
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a. Must calibrate continuous pH measurement instruments using a grab sample analyzed in the lab with a pH meter calibrated with standard buffers and analyzed within 15 minutes of sampling.
4. Calibrate flow-monitoring devices at a minimum frequency of at least one calibration per year.
5. Maintain calibration records for at least three years.
S2.D. Laboratory Accreditation
The Pennittee must ensure that all monitoring data required by Ecology for petmit specified parameters is prepared by a laboratory registered or accredited under the provisions of chapter 173-50 WAC, Accreditation of Environmental Laboratories. Flow, temperature, settleable solids, conductivity; pH, and internal process control parameters are exempt from this requirement.
S2.E. Request for Reduction in Monitoring
The Petmittee may request a reduction of the sampling frequency after twelve (12) months of monitoring. Ecology will review each request and at its discretion grant the request when it reissues the petmit or by a petmit modification.
The Permittee must:
1. Provide a written request.
2. Clearly state the parameters for which it is requesting reduced monitoring.
3. Clearly state the justification for the reduction.
83. Reporting and Recording Requirements The Petmittee must monitor and report in accordance with the following conditions. Falsification ofinfmmation submitted to Ecology is a violation of the tetms and conditions of this permit.
S3.A. Reporting
The first monitoring period begins on the effective date of the permit. The Petmittee must:
1. Summarize, report, and submit monitoring data obtained during each monitoring period on the electronic discharge monitoring report (DMR) form provided by Ecology within the Water Quality Petmitting Portal. Include data for each of the parameters tabulated in Special Condition S2 and as required by the form. Rep01t a value for each day sampling occurred (unless specifically exempted in the petmit) and for the summary values (when applicable) included on the electronic form.
To find out more information and to sign up for WQWebDMR go to: http://www.ecy.wa.gov/programs/wq/permits/paris/webdmr.html
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The Petmittee may submit DMRs on the paper form provided by Ecology until December 31, 2014.
2. Enter the "no discharge" reporting code for an entire DMR, for a specific monitoring point, or for a specific parameter as appropriate, if the Petmittee did not discharge wastewater or a specific pollutant during a given monitoring period.
3. Report single analytical values below detection as "less than the detection level (DL)" by entering< followed by the numeric value of the detection level (e.g.< 2.0) on the DMR. If the method used did not meet the minimum DL and quantitation level (QL) identified in the petmit, report the actual QL and DL in the comments or in the location provided.
4. Report the test method used for analysis in the comments if the laboratory used an altemative method not specified in the permit and as allowed in Special Condition S2.
5. Calculate average values (unless otherwise specified in the petmit) using:
a. The reported numeric value for all parameters measured between the agency-required detection value and the agency-required quantitation value.
b. One-half the detection value (for values reported below detection) if the lab detected the parameter in another sample for the repmiing period.
c. Zero (for values reported below detection) if the lab did not detect the parameter in another sample for the reporting period.
6. Repmt single-sample grouped parameters (for example: priority pollutants, PARs, pulp and paper chlorophenolics, TTOs) on the WQWebDMR fmm and include: sample date, concentration detected, detection limit (DL) (as necessary), and laboratory quantitation level (QL) (as necessary).
The Petmittee must also submit an electronic copy of the laboratory repoti as an attachment using WQWebDMR. The contract laboratory repmis must also include infmmation on the chain of custody, QA/QC results, and documentation of accreditation for the parameter.
7. Ensure that DMRs are electronically submitted no later than the dates specified below, unless otherwise specified in this permit.
8. Submit DMRs for parameters with the monitoring frequencies specified in S2 (monthly, qumterly, annual, etc.) at the repmiing schedule identified below. The Permittee must:
a. Submit monthly DMRs by the 15111 day of the following month.
b. Submit effluent characterization monitoring data in WQWebDMR as required in Special Condition S2 by December 31, 2015.
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S3.B. Permit Submittals and Schedules
The Permittee must use the Water Quality Petmitting P01tal- Permit Submittals application (unless otherwise specified in the permit) to submit all other written petmit-required reports by the date specified in the petmit.
When another petmit condition requires submittal of a paper (hard-copy) rep01t, the Permittee must ensure that it is postmarked or received by Ecology no later than the dates specified by this petmit. Send these paper rep01ts to Ecology at:
Water Quality Permit Coordinator Depattment of Ecology Industrial Section PO Box47600 Olympia, WA 98504-7600
S3.C. Records Retention
The Petmittee must retain records of all monitoring information for a minimum of three (3) years. Such inf01mation must include all calibration and maintenance records and all original recordings for continuous monitoring instrumentation, copies of all repotts required by this permit, and records of all data used to complete the application for this permit. The Permittee must extend this period of retention during the course of any unresolved litigation regarding the discharge of pollutants by the Permittee or when requested by Ecology.
S3.D. Recording of Results
For each measurement or sample taken, the Permittee must record the following inf01mation:
1. The date, exact place, method, and time of sampling or measurement
2. The individual who performed the sampling or measurement
3. The dates the analyses were performed
4. The individual who performed the analyses
5. The analytical techniques or methods used
6. The results of all analyses
S3.E. Additional Monitoring by the Permittee
If the Permittee monitors any pollutant more frequently than required by Condition S2 of this petmit, then the Permittee must include the results of such monitoring in the calculation and rep01ting of the data submitted in the Petmittee's DMR unless otherwise specified by Condition S2.
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S3.F. Reporting Permit Violations
The Pe1mittee must take the following actions when it violates or is unable to comply with any pe1mit condition:
1. Immediately take action to stop, contain, and cleanup unauthorized discharges or otherwise stop the noncompliance and correct the problem.
2. If applicable, immediately repeat sampling and analysis. Submit the results of any repeat sampling to Ecology within thhty (30) days of sampling.
a. Immediate Reporting
The Permittee must report any noncompliance that may endanger health or the environment immediately to the Depmtment of Ecology's Regional Office 24-hr. number listed below:
Southwest Regional Office (360) 407-6300
b. Twenty-Four-Hour Reporting
The Permittee must report the following occurrences of noncompliance by telephone, to Ecology at the telephone numbers listed above, within 24 hours Ji'om the time the Permittee becomes aware of any of the following circumstances. The Permittee must report:
1. Any noncompliance that may endanger health or the environment, unless previously reported under immediate reporting requirements.
2. Any unanticipated bypass that causes an exceedance of an effluent limit in the permit (See Part S4.B., "Bypass Procedures").
3. Any upset that causes an exceedance of an effluent limit in the permit. Upset means an exceptional incident in which there is unintentional and temporary noncompliance with technology-based permit effluent limits because of factors beyond the reasonable control of the Pe1mittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.
4. Any violation of a maximum daily or instantaneous maximum discharge limit for any of the pollutants in Special Condition Sl of this permit.
5. Any overflow prior to the treatment works, whether or not such overflow endangers health or the environment or exceeds any effluent limit in the permit.
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c. Report within Five Days
The Permittee must also submit a written report within five days of the time that the Pennittee becomes aware of any reportable event under subparts a or b, above. The report must contain:
1. A description of the noncompliance and its cause.
2. The period of noncompliance, including exact dates and times.
3. The estimated time the Permittee expects the noncompliance to continue if not yet corrected.
4. Steps taken or plarmed to reduce, eliminate, and prevent recurrence of the noncompliance.
5. If the noncompliance involves an overflow prior to the treatment works, an estimate of the quantity (in gallons) of untreated overflow.
d. Waiver of Written Reports
Ecology may waive the written repmi required in subpati c, above, on a case-by-case basis upon request if the Permittee has submitted a timely oral report.
e. All Other Permit Violation Reporting
The Pennittee must repoti all permit violations, which do not require immediate or within 24 hours repmiing, when it submits monitoring reports for S3.A ("Repotiing"). The repotis must contain the information listed in subpart c, above. Compliance with these requirements does not relieve the Permittee from responsibility to maintain continuous compliance with the terms and conditions of this petmit or the resulting liability for failure to comply.
f. Report Submittal
The Petmittee must submit reports to the address listed in Special Condition S3.A.
S3.G. Other Reporting
a. Spills of Oil or Hazardous Materials
The Permittee must report a spill of oil or hazardous materials in accordance with the requirements ofRCW 90.56.280 and chapter 173-303-145. You can obtain further instructions at the following website: http://www.ecy.wa.gov/programs/spills/other/repotiaspill.htm.
b. Failure to Submit Relevant or Correct Facts
Where the Permittee becomes aware that it failed to submit any relevant facts in a petmit application, or submitted incorrect information in a permit
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application, or in any report to Ecology, it must submit such facts or information promptly.
S3.H. Maintaining a Copy of this Permit
The Permittee must keep a copy of this petmit at the facility and make it available upon request to Ecology inspectors.
S3.I. Dangerous Waste Discharge Notification
The Petmittee must notifY the Weyerhaeuser Longview and Ecology in writing of the intent to discharge into the Weyerhaeuser Longview wastewater treatment plant any substance designated as a dangerous waste in accordance with the provisions of WAC 173-303-070. It must make this notification at least 90 days prior to the date that it proposes to initiate the discharge. The Permittee must not discharge this substance until authorized by Ecology and Weyerhaeuser Longview. It must also comply with the notification requirements of Special Condition S8 and General Condition 04.
S3.J. Spill Notification
The Permittee must notifY Weyerhaeuser Longview immediately (as soon as discovered) of all discharges that could cause problems to the Weyerhaeuser Longview wastewater treatment plant, such as process spills and unauthorized discharges (including slug discharges).
S4. Operation and Maintenance
The Permittee must, at all times, properly operate and maintain all facilities or systems of treatment and control (and related appmienances) which are installed to achieve compliance with the terms and conditions of this petmit. Proper operation and maintenance includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems, which are installed by a Permittee only when the operation is necessary to achieve compliance with the conditions of this permit.
S4.A. Operations and Maintenance Manual
a. O&M Manual Submittal and Requirements
The Permittee must:
1. Update the O&M Manual as necessary to meet the requirements of 173-240-150 WAC.
2. Keep the approved O&M Manual at the permitted facility.
3. Follow the instmctions and procedures of this manual.
Page 13 of33 Pennit No. ST0006070
b. O&M Manual Components
In addition to the requirements of WAC 173-240-150(1) and (2), the O&M manual must include:
1. Emergency procedures for plant shutdown and cleanup in event of wastewater system upset, spill, failure, or demand by the wastewater treatment plant treating the discharge.
2. Wastewater system maintenance procedures that contribute to the generation of process wastewater.
3. Any directions to maintenance staff when cleaning, or maintaining other equipment or perfonning other tasks which are necessary to protect the operation of the wastewater system (for example, defining maximum allowable discharge rate for draining a tank, blocking all floor drains before beginning the overhaul of a stationary engine.)
4. Wastewater sampling protocols and procedures for compliance with the sampling and reporting requirements in the wastewater discharge pennit.
5. Minimum staffing adequate to operate and maintain the treatment processes and carry out compliance monitoring required by the permit.
6. Treatment plant process control monitoring schedule.
S4.B. Bypass Procedures
This permit prohibits a bypass, which is the intentional diversion of waste streams from any portion of a treatment facility. Ecology may take enforcement action against a Permittee for a bypass unless one of the following circumstances (1, 2, or 3) applies.
1. Bypass for essential maintenance without the potential to cause violation of pennit limits or conditions.
This permit authorizes a bypass if it allows for essential maintenance and does not have the potential to cause violations of limits or other conditions of this permit, or adversely impact public health as determined by Ecology prior to the bypass. The Pennittee must submit prior notice, if possible, at least ten (10) days before the date of the bypass.
2. Bypass is unavoidable, unanticipated, and results in noncompliance of this pe1mit.
This pennit authorizes such a bypass only if:
a. Bypass is unavoidable to prevent loss of life, personal injury, or severe prope1iy damage. "Severe prope1iy damage" means substantial physical damage to prope1iy, damage to the treatment facilities which would cause them to become inoperable, or substantial and permanent loss of natural
Page 14 of33 Permit No. ST0006070
resources which can reasonably be expected to occur in the absence of a bypass.
b. No feasible altematives to the bypass exist, such as:
• The use of auxiliary treatment facilities. • Retention of untreated wastes. • Stopping production. • Maintenance during normal periods of equipment downtime, but not if
the Permittee should have installed adequate backup equipment in the exercise of reasonable engineering judgment to prevent a bypass.
• Transp01t of untreated wastes to another treatment facility.
c. The Petmittee has properly notified Ecology of the bypass as required in Condition S3 .E of this petmit.
3. If bypass is anticipated and has the potential to result in noncompliance of this permit.
a. The Petmittee must notify Ecology at least thirty (30) days before the planned date of bypass. The notice must contain:
• A description of the bypass and its cause. • An analysis of all known altematives which would eliminate, reduce,
or mitigate the need for bypassing. • A cost-effectiveness analysis of alternatives including comparative
resource damage assessment. • The minimum and maximum duration of bypass under each
altemative. • A recommendation as to the preferred altemative for conducting the
bypass. • The projected date of bypass initiation. • A statement of compliance with SEP A. • A request for modification of water quality standards as provided for
in WAC 173-201A-410, if an exceedance of any water quality standard is anticipated.
• Details of the steps taken or planned to reduce, eliminate, and prevent reoccunence of the bypass.
b. For probable construction bypasses, the Petmittee must notify Ecology of the need to bypass as early in the planning process as possible. The Permittee must consider the analysis required above during preparation of the engineering report or facilities plan and plans and specifications and must include these to the extent practical. In cases where the Permittee determines the probable need to bypass early, the Permittee must continue to analyze conditions up to and including the construction period in an effort to minimize or eliminate the bypass.
c. Ecology will consider the following prior to issuing an administrative order for this type of bypass: ·
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• If the bypass is necessary to perform construction or maintenance-related activities essential to meet the requirements of this permit.
• If feasible altematives to bypass exist, such as the use of auxiliary treatment facilities, retention of untreated wastes, stopping production, maintenance during normal periods of equipment down time, or transport of untreated wastes to another treatment facility.
• If the Permittee planned and scheduled the bypass to minimize adverse effects on the public and the environment.
After consideration of the above and the adverse effects of the proposed bypass and any other relevant factors, Ecology will approve or deny the request. Ecology will give the public an opportunity to comment on bypass incidents of significant duration, to the extent feasible. Ecology will approve a request to bypass by issuing an administrative order nnder RCW 90.48.120.
85. Prohibited Discharges The Permittee must comply with these General and Specific Prohibitions.
SS.A. General Prohibitions
The Permittee must not introduce into the Weyerhaeuser Longview wastewater treatment plant pollutant(s), which cause Pass Through or Interference.
SS.B. Specific Prohibitions
In addition, the Permittee must not introduce the following into the Weyerhaeuser Longview wastewater treatment plant:
1. Pollutants which create a fire or explosion hazard in the treatment plant, including, but not limited to, waste streams with a closed cup flashpoint of less than 60 degrees C ( 140 degrees F) using the test methods specified in 40 CFR261.21.
2. Solid or viscous pollutants in amounts, which will cause obstruction to the flow in the treatment plant resulting in interference.
3. Any pollutant (including BOD5 and fluorosufactants in Aqueous Film Fmming Foam), released in a discharge at a flow rate and/or pollutant concentration that will cause interference with the treatment plant.
4. Heat in amounts which will inhibit biological activity in the treatment plant resulting in interference, but in no case heat in such quantities that the temperature at the treatment plant exceeds 40 degrees C ( 104 degrees F) unless the approval authority, upon request of the treatment plant, approves altemative temperature limits.
5. Petroleum oil, non-biodegradable cutting oil, or products of mineral oil origin in amounts that will cause interference or pass through.
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6. Pollutants which result in the presence of toxic gases, vapors, or fumes within the treatment plant in a quantity that may cause acute worker health and safety problems.
7. Any trucked or hauled pollutants, except at discharge points designated by the treatment plant.
8. Pollutants that will cause conosive structural damage to the Weyerhaeuser Longview wastewater treatment plant.
S5.C. Prohibited Unless Approved
Any of the following discharges are prohibited unless approved by Ecology under extraordinary circumstances (such as a lack of direct discharge alternatives due to combined sewer service or a need to augment sewage flows due to septic conditions):
1. Wastewaters significantly affecting system hydraulic loading, which do not require treatment or would not be afforded a significant degree of treatment by the system.
2. The discharge of dangerous wastes as defined in Chapter 173-303 WAC (Unless specifically authorized in this permit).
S6. Dilution Prohibited
The Permittee must not dilute the wastewater discharge with stormwater or increase the use of potable water, process water, noncontact cooling water, or, in any way, attempt to dilute an effluent as a partial or complete substitute for adequate treatment to achieve compliance with the limits contained in this permit.
S7. Solid Waste Disposal
S7.A. Solid Waste Handling
The Permittee must handle and dispose of all solid waste material in such a manner as to prevent its entry into state ground or surface water.
S7.B. Leachate
The Permittee must not allow leachate from its solid waste material to enter state waters without providing all known, available, and reasonable methods of treatment, nor allow such leachate to cause violations of the State Surface Water Quality Standards, Chapter 173-201A WAC, or the State Ground Water Quality Standards, Chapter 173-200 WAC. The Permittee must apply for a permit or petmit modification as may be required for such discharges to state ground or surface waters.
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S8. Application for Permit Renewal or Modification for Facility Changes
The Permittee must submit an application for renewal of this permit by Aprill, 2019. The Pe1mittee must submit a paper copy and an electronic copy (preferably as a PDF).
The Pe1mittee must also submit a new application or supplement at least one hundred eighty (180) days prior to commencement of discharges, resulting from the activities listed below, which may result. in pe1mit violations. These activities include any facility expansions, production increases, or other planned changes, such as process modifications, in the permitted facility.
S9. Non-Routine Discharges 1. Beginning on the effective date of this pe1mit, the Permittee is authorized to discharge
non-routine wastewater on a case-by-case basis to the wastewater treatment plant if approved by Ecology and Weyerhaeuser Longview. Prior to any such discharge, the Permittee must contact Ecology and at a minimum provide the following information:
a. The proposed discharge location.
b. The nature of the activity that will generate the discharge.
c. Any alternatives to the discharge, such as reuse, storage, or recycling of the water.
d. The total volume of water it expects to discharge.
e. The results of the chemical analysis of the water.
f. The date of proposed discharge.
g. The expected rate of discharge discharged, in gallons per day.
2. The expected rate of discharge in gallons per minute for discharges greater than 20,000 gallons.
3. The Permittee must analyze the water for all constituents limited for the discharge and report them as required by subpart 1.e above. The analysis must also include any parameter deemed necessary by Ecology. All discharges must comply with the effluent limits as established in Condition S1 of this permit and any other limits imposed by Ecology.
4. The discharge cannot proceed until Ecology has reviewed the information provided and has authorized the discharge by letter to the Pe1mittee or by an Administrative Order.
SlO. Spill Control Plan
SlO.A. Spill Control Plan Submittals and Requirements
The Pe1mittee must:
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1. Submit to Ecology an update to the existing spill control plan by April1, 2015. The Permittee must submit a paper copy and an electronic copy (preferably as a PDF).
2. Review the plan at least annually and update the spill plan as needed.
3. Send changes to the plan to Ecology.
4. Follow the plan and any supplements throughout the term of the permit.
S10.B. Spill Control Plan Components
The spill control plan must include the following:
1. A list of all oil and petroleum products and other materials used and/or stored on-site, which when spilled, or otherwise released into the environment, designate as Dangerous Waste (DW) or Extremely Hazardous Waste (EHW) by the procedures set fmih in WAC 173-303-070. Include other materials used and/or stored on-site, which may become pollutants or cause pollution upon reaching state's waters.
2. A description of preventive measures and facilities (including an overall facility plot showing drainage patterns) which prevent, contain, or treat spills of these materials.
3. A description of the repmiing system the Permittee will use to aleti responsible managers and legal authorities in the event of a spill.
4. A description of operator training to implement the plan.
The Permittee may submit plans and manuals required by 40 CFR Pmi 112, contingency plans required by Chapter 173-303 WAC, or other plans required by other agencies, which meet the intent of this section.
811. Slug Discharge Control Plan
a. Slug Discharge Control Plan Submittal and Requirements
If required to complete a spill plan, the Permittee may combine it with the slug discharge control plan. The Permittee must:
1. Review its slug discharge plan and update it as needed.
2. Submit all revisions or updates of this plan to Ecology for review and approval.
3. Keep the cmTent approved plan on the plant site and make it readily available to facility personnel.
4. Follow the approved plan and any approved supplements throughout the term of the permit.
5. Submit an update of the slug discharge control plan, or a certification that it is cu!1'ent by April 1, 2015.
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b. Slug Discharge Control Plan Components
The slug discharge control plan must include the following infonnation and procedures relating to the prevention of unauthorized slug discharges; it must include:
1. A description of a reporting system the Petmittee will use to immediately notify facility management, Weyerhaeuser Longview, and appropriate state, federal, and local authorities of any slug discharges, and provisions to provide a written follow-up repoti within five days.
2. A description of operator training, equipment, and facilities (including overall facility plan) for preventing, containing, or treating slug discharges.
3. Procedures to prevent adverse impact from accidental spills including:
a. Inspection and maintenance of storage areas
b. Handling and transfer of materials
c. Loading and unloading operations
d. Control of plant site run-off
e. Worker training
f. Building of containment structures or equipment
g. Measures for containing toxic organic pollutants (including solvents)
h. Measures and equipment for emergency response
4. A list of all raw materials, products, chemicals, and hazardous materials used, processed, or stored at the facility; the normal quantity maintained on the premises for each listed material; and a map showing where they are located.
5. A description of discharge practices for batch and continuous processes under notmal and non-routine circumstances.
6. A brief description of any unauthorized discharges which occurred during the 36-month period preceding the effective date of this petmit and subsequent measures taken by Permittee to prevent or to reduce the possibility of further unauthorized discharges.
7. An implementation schedule including additional operator training and procurement and installation of equipment or facilities required to properly implement the plan.
Page 20 of33
Permit No. ST0006070
General Conditions
Gl. Signatory Requirements All applications, reports, or inf01mation submitted to Ecology must be signed as follows:
1. All permit applications must be signed by either a principal executive officer or ranking elected official.
2. All rep01is required by this pe1mit and other information requested by Ecology must be signed by a person described above or by a duly authorized representative of that person. A person is a duly authorized representative only if:
a. The authorization is made in writing by the person described above and is submitted to Ecology at the time of authorization, and
b. The authorization specifies either a named individual or any individual occupying a named position.
3. Changes to authorization. If an authorization under paragraph G 1.2. above is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization must be submitted to Ecology prior to or together with any reports, information, or applications to be signed by an authorized representative.
4. Ce1iification. Any person signing a document under this section must make the following certification:
"I certify under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the inf01mation submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering information, the inf01mation submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false inf01mation, including the possibility of fine and imprisonment for knowing violations."
G2. Right of Entry
Representatives of Ecology have the right to enter at all reasonable times in or upon any prope11y, public or private, for the purpose of inspecting and investigating conditions relating to the pollution or the possible pollution of any waters of the state. Reasonable times include normal business hours; hours during which production, treatment, or discharge occurs; or times when Ecology suspects a violation requiring immediate inspection. Representatives of Ecology must be allowed to have access to, and copy at reasonable cost, any records required to be kept under te1ms and conditions of the pe1mit; to inspect any monitoring equipment or method required in the pe1mit; and to sample the discharge, waste treatment processes, or intemal waste streams.
Page 21 of33 Petmit No. ST0006070.
G3. Permit Actions This permit is subject to modification, suspension, or termination, in whole or in part by Ecology for any of the following causes:
1. Violation of any permit term or condition;
2. Obtaining a permit by misrepresentation or failure to disclose all relevant facts;
3. A material change in quantity or type of waste disposal;
4. A material change in the condition of the waters of the state; or
5. Nonpayment of fees assessed pursuant to RCW 90.48.465.
Ecology may also modifY this petmit, including the schedule of compliance or other conditions, if it determines good and valid cause exists, including promulgation or revisions of regulations or new information.
G4. Reporting a Cause for Modification The Permittee must submit a new application, or a supplement to the previous application, along with required engineering plans and reports, whenever a new or increased discharge or change in the nature of the discharge is anticipated which is not specifically authorized by this permit. This application must be submitted at least one hundred eighty (180) days prior to any proposed changes. Submission of this application does not relieve the Permittee of the duty to comply with the existing permit until it is modified or reissued.
G5. Plan Review Required Prior to constructing or modifYing any wastewater control facilities, an engineering report and detailed plans and specifications must be submitted to Ecology for approval in accordance with Chapter 173-240 WAC. Engineering reports, plans, and specifications should be submitted at least 180 days prior to the planned start of construction. Facilities must be constructed and operated in accordance with the approved plans.
G6. Compliance with other Laws and Statutes Nothing in the permit excuses the Petmittee from compliance with any applicable federal, state, or local statutes, ordinances, or regulations.
G7. Transfer of this Permit
This pennit is automatically. transferred to a new owner or operator if:
1. A written agreement between the old and new owner or operator containing a specific date for transfer of permit responsibility, coverage, and liability is submitted to Ecology;
2. A copy of the petmit is provided to the new owner; and
3. Ecology does not notifY the Permittee of the need to modifY the permit.
Page 22 of33 Permit No. ST0006070
Unless this permit is automatically transferred according to Section 1. above, this permit may be transfetTed only if it is modified to identity the new Pennittee and to incorporate such other requirements as determined necessary by Ecology.
G8. Reduced Production for Compliance
The Permittee must control production or discharge to the extent necessary to maintain compliance with the terms and conditions of this pennit upon reduction of efficiency, loss, or failure of its treatment facility until the treatment capacity is restored or an altemative method of treatment is provided. This requirement applies in the situation where, among other things, the primary source of power for the treatment facility is reduced, lost, or fails.
G9. Removed Substances
Collected screenings, grit, solids, sludges, filter backwash, or other pollutants removed in · the course of treatment or control of wastewaters must not be resuspended or reintroduced to the effluent stream for discharge.
GlO. Payment of Fees
The Permittee must submit payment offees associated with this permit as assessed by Ecology. Ecology may revoke this permit if the pennit fees established under Chapter 173-224 WAC are not paid.
Gll. Penalties for Violating Permit Conditions
Any person who is found guilty of willfully violating the terms and conditions of this petmit is guilty of a crime, and upon conviction thereof shall be punished by a fine of up to ten thousand dollars and costs of prosecution, or by imprisonment in the discretion of the comt. Each day upon which a willful violation occurs is a separate and additional violation.
Any person who violates the terms and conditions of a waste discharge permit incurs, in addition to any other penalty as provided by law, a civil penalty in the amount of up to ten thousand dollars for every such violation. Each and every such violation is a separate and distinct offense, and in case of a continuing violation, every day's continuance is a separate and distinct violation.
Gl2. Duty to Provide Information
The Permittee must submit to Ecology, within a reasonable time, all information which Ecology may request to determine whether cause exists for modifYing, revoking and reissuing, or terminating this petmit or to determine compliance with this permit. The Permittee must also submit to Ecology upon request, copies of records required to be kept by this permit.
Gl3. Duty to Comply
The Pennittee must comply with all conditions of this permit. Any pennit noncompliance constitutes a violation of chapter 90.48 RCW and is grounds for
Page23 of33 Permit No. ST0006070
enforcement action; for petmit termination, revocation and reissuance, or modification; or denial of a permit renewal application.
Page 24 of33 Pennit No. ST0006070
Appendix A
List of Pollutants with Analytical Methods, Detection Limits, and Quantitation Levels
The Permittee must use the specified analytical methods, detection limits (DLs) and quantitation levels (QLs) in the following table for petmit and application required monitoring unless:
• Another petmit condition specifies other methods, detection levels, or quantitation levels. • The method used produces measurable results in the sample and EPA has listed it as an
EPA-approved method in 40 CFR Patt 136.
If the Permittee uses an alternative method, not specified in the permit and as allowed above, it must repmt the test method, DL, and QL on the discharge monitoring report or in the required report.
If the Petmittee is unable to obtain the required DL and QL in its effluent due to matrix effects, the Permittee must submit a matrix-specific detection limit (MDL) and a quantitation limit (QL) to Ecology with appropriate laboratory documentation.
When the permit requires the Petmittee to measure the base neutral compounds in the list of priority pollutants, it must measure all of the base neutral pollutants listed in the table below. The list includes EPA required base neutral priority pollutants and several additional polynuclear aromatic hydrocarbons (PAHs). The Water Quality Program added several PAHs to the list of base neutrals below from Ecology's Persistent Bioaccumulative Toxics (PBT) List. It only added those PBT parameters of interest to Appendix A that did not increase the overall cost of analysis unreasonably.
Ecology added this appendix to the permit in order to reduce the number of analytical "nondetects" in permit-required monitoring and to measure effluent concentrations near or below criteria values where possible at a reasonable cost.
CONVENTIONAL PARAMETERS
Pollutant & CAS No. (if available) .
Biochemical Oxygen Demand Soluble Biochemical O.l'ygen Demand
Recommended Analytical Protocol
Detection (DLipg/L
unless ____ _;__specified
SM5210-B
SM5210-B 3
Chemical OxygenDeman.~d~---=c-:Sco:M::-5;-;2cc2o:-0-70Do= Total Organic Carbon. SM5310-B/C/D Total Suspended Solids SM2540-D Total Ammonia (as N) SM4500-NH3-B and
CIDIEIGIH
Quantitation Level(QL) 2
. pg/L unless ;_specified .
2mg/L
2mg/L
10 mg/L 1 mg!L 5 mg/L
20
Page 25 of33 Petmit No. ST0006070
Page 26 of33 Permit No. ST0006070
Detection Quantitation (DL/ 1-lg/L Level (QL/ Pollutant & CAS No. (if
available) Recommended
Analytical Protocol unless ~-tg!L unless . specifi=ed=--_ . specified__j
Sulfate (as mg/L S04) Sulfide (as mg/L S)
i Sulfite( as mg/L S03)
I Total Colifmm
SM4110-B SM4500-S2F/D/E/G ..
SM4500-S03B SM 9221B, 9222B,
9223B
----+-0.2 mg/1_ __ __,__ .. 0.2 mg/1 __ •
2mg!L __ i
Total dissolved solids · Total Hardness
N/A
SM2540 C
SM2340B=---+---200.8 2.0
Specified in method
sample aliquot dependent 1Q_fl1g/L
200 as CaC03 10 . Aluminum, Total (7429-90-
, 5)
I BariumTot!lL(7440-39-3) 200.8 --=----+-0.5 2.0
2 I BTEX (benzene +toluene + I ethyl benzene+ m,o,p ; xylenes) I Boron Total (744c-:Occ--4=2cc=-8~) -~l (::obalt, Total (7440:48:~)
Iron,Total (743,..c9-o-8~9=--6~)~c:--c; Magnesium, Total (7439-95-1 4) ; Molybdenum, Total (7439-1 98-7) I Manganese, Total (7439-96-1 5)
------·
EPA SW 846 8021/8260
200.8 __ --+_--c 200.8
200.7::-----+--200.7
200.8
200.8
• 4-· :NWTPHDx Ecology NWTPH
Dx Ecology NWTPH
---r---
I Tin, Total (7440-o-=-31o-:-c:5)'-=-=---r-I'J:'itanium, Total (7~'!0:32.::~)
Ox
200.8::-------+-200.8
PRIORITY POLLUTANTS
1
Detection Quantitation Pollutant & CAS No. (if
available) Recommended (DL)1 pg/L Level (QL) 2
unless . pg/L unless , Analytical Protocol specijiet[ l ...... specified --"
META1S,(;YANIDE & TOTAJ .. J:>IIENOLS . I
i Antimony, Total (7440-36-0) 200.8 0.3 1.0 Arsenic, Total (7440-38-2) .. 200.8 0.1 0.5 Beryllium, Total (7440-41-7) 200.8 --=O.c.c.1:___ 0.5 _ __j
Page 27 of33 Permit No. ST0006070
Detection Quantitation Pollutant & CAS No. (if Recommended (DL)1 pg/L Level (QL) 2
available) Analytical Protocol i unless pg/L unless sp~ed spec(fied
(;admium, Total (7440-43-9) 200.8 0.05 0.25 i Chromium (hex) dissolved SM3500-Cr EC 0.3 1.2
(18540-29~2} Chromium, Total (7440-47- 200.8 0.2 1.0
I 3) ' Copper, Total (7440-50-8) 200.8 0.4 2.0 i Lead, Total (7439-92-1) 200.8 0.1 0.5 l Mer<;l]ry,'Total (7439~97:~) 1631E 0.0002 0.0005
''""'~·~···-~----
! Nickel, Total (7440-02-0) 200.8 0.1 0.5 I Selenium, Total (7782-49-2) 200.8 1.0 1.0 i Silver, Total (7440-22-4) 200.8 0.04 0.2
Thallium, Total (7440-28-0) 200.8 0.09 0.36 ';?,insJotal (7440-66-6) 200.8 0.5 2.5
-------- ---------
Cyanide, Total{57-12-5) 335.4 5 10 i Cyanide, Weak Acid SM4500-CN I 5 10 I Dissociable · Cyanide, Free Amenable to SM4500-CNG 5 10 I Chlorination (Available
Cyanide) i Phenols, Total EPA420.1 50
-'
Detection Quantitation Pollutant & CAS No. (if Recommended (DL)I pg/L Level (QL) 2
available) i Analytical Protocol unless pg/L unless i - ----------·----------- '
_specified __ L __ specified
ACID COMPOUNDS 2-Chlorophenol (95-57-8) 625 1.0 2.0 2,4-Dichlorophenol (120-83- 625 0.5 1.0 2) 2,4-Dimethylphenol (I 05- 625 0.5 1.0 67-9) 4,6-dinitro-o-cresol (534-52- 625/1625B 1.0 I) (2-methyl-4,6,-dinitrophenol) 2,4 dinitropheno1(51:28-5) 625 1.0 2.0 2-l\litrophenol (88-75-5)_ 625 0.5 1.0 4-nitrophenol (I 00-02-7) 625 0.5 1.0 Parachlorometa cresol (59- 625 1.0 2.0 50-7)
Page 28 of33 Permit No. ST0006070
Pollutant & CAS No. (if available)
Detection Quantitation _J,'
Recommended (DLi pg/L Level (QL) 2
Analytical Protocol ! unless . pg/L unless I --+------'specijielf_' speciji_~_d _I
( 4-chloro-3-methylphenol) ___ _ Pentachlorophenol (87-86-5) 625 Phenol (1 08-95-2) 625 2,4,6-Trichlorophenol (88- 625
----+--- 0.5 -----i-2.0 -----i-2.0
1._:_0 __ 4.0 4.0
'__ __ 0,6-2)
Detection Pollutant & CAS No. (if
_ available) Recommended (DL)1
Analytical Protocol )tg!L unless _ _ __ _ SP_f!£ified
VOLATILE COMPOUNDS ! Acrolein (1 07 -02-8) ---+-------"'-624 i Acrylonitrile (107-13-1) _ 624
' Benzene (71-43:--.-2;;-;)~-- i 624 i Bromoform(75:~~:2) 624 I Carbon tetrachloride (56-23- 624/601 or i 5) SM6230B I Qhlorobenzene (108-90-7),__~-- 624 I Chloroethane (75-00-3) ~--6=24/6:C:0-:-1---;--l2-Chioroethylvinyl Ether 624 I (11 0-75-8)
624 or SM621 OB I Chloroform ( 67-66-3),__ _ ___;_____::_ I Dibromochloromethane I {124-48-1) ! 1,2-Dichlorobenzene (95-50-
_1_) --1 ,3-Dichlorobenzene (541-
1 73-1) I 1,4-Dichlorobenzene (106-i 46-7) ' Dichlorobromomethane (75-[27-4) I l,l:l)icl1l()l"_Oethane (75~31:~}! i 1,2-Diehl oro ethane (1 07-06-i 2) i 1, 1-Dichloroethylene (75-35-14)
1 ,2-Dichloropropane (78-87-J)
I 1 ,3-dichloropropene (mixed · isomers) (1 ,2-dichlor()propylene) (542-75-
624
624
624
624
624
624 --------------
624
624
624
624
--
5 1.0 1.0 1.0 1.0
1.0 1.-.:-0 -.-. ---+---
1.0
1.0 1.0
1.9
1.9
4.4
1.0
1.0 -------
1.0
1.0
1.0
1.0
Quantitation Level (QL) 2
pg/L unless specified
10 2.0 2.0
")
I
-~
2.0 2.0
2.0 2.0 2.0 I
! ----1
2.0 2.0
7.6
7.6
17.6
2.0
2.0 2.0
2.0
2.0
2.0
Page 29 of33 Petmit No. ST0006070
Detection Po11utant & CAS No. (if
available) Recommended . (DLi
i Analytical Protocol i pg/L unless
Quantitation Level(QL) 2
pg/L unless . r specified
VOLATILE COMPOUNDS ~----- ' ~~--,-!6)6- - -
;--;:-;c--;-:---;-;---i Ethylbenzene (1 00-41-4) I Methyl bromide (74-83-9)
(Bromomethanc-::e"=) c-:-:----c------
1 Methyl chloride (74-87-3) · (Chloromethane-';-) -.----o;:;-;:-;;-;o
Methylene chloride (7 5-09-2) 1,1 ,2,2-Tetrachloroethane (79-34-5) Tetrachloroethylene (127-18- i
. 4£..._) c------:-:-::-=-::-::-:c
[ Toll)ene (1 08-88-3) I 1,2-Trans-Dichloroethylene : (156-60-5) (Ethylene _dichloride) ! 1,1,1-Trichloroethane (71-
. 55:6) ~-;--;-------,-;c--1 1,1 ,2-Trichloroethane (79-1 00:5_) _ __c
! --:c;c-;------
624 624/601
----
624
624
624
624
624 624
624
624 ___ i_ ______
624 I Trichloroethylene (79_-0::c1=--6=.~.)'----:-__ ~ (Vinyl chloride (75-01-42 624/SM6200B
- ----
1.0 5.0
1.0
5.0
1.9
1.0
1.0 1.0
1.0
1.0
1.0 1.0
specijie~d~--:
2. 0-;:------~ 10.0
2.0
10.0
2.0
2.0
2.0 2.0
2.0
2.0
Detection Quantitation i Pollutant & CAS No. (if
available) Recommended
Analytical Protocol (DL)1 Level (QL) 2
pg/L finless pg/L unless spec_ijied_ specified _ __ j
BASE/NEUTRAL COMPOUNDS (compounds in bold are EcologYPBTsL__ !Acenaphthene (83-32-9) - · 625 - ' - 0.2 --- 0.4 -
! Acenaphthylene (208-96-8) 625 0.3 0.6 ------: i Anthracene (120-12-7) 625 0.3 0.6 ! BeQ:Z_icline (92-87-5) _ L 625 12 24 I Benzyl butyl phthalate (85- 625 0.3 0.6 I 68-7) i Benzo(a)anthracene (56-55-
13) ... -i Benzo(b )fluoranthene i (3,4-benzofluoranthene) I (205-99-2) 7
i BenzoG)fluoranthene (205-1 82-3) 7
I Benzo(k)fluoranthyne ----~--
625
610/625
625
61 0/62=5----~
0.3 0.6
0.8 1.6
0.5 1.0
0.8 __ _._ ____ 1.6
____ !
--~:
Page 30 of33 Permit No. ST0006070
Detection Quantitation Pollutant & CAS No. (if Recommended (DL)' Level (QL) 2
available) ' Analytical Protocol pg!L unless pg/L unless I sp_ecified spec(fied
BASE/NEUTRALCOMPOUNDS ( cmnpounds in bold are Ecology PBTs) i (11, 12-benzofluoranthene) : 7 ' (207-08-9) l Benzo(r,s,t)pentaphene 625 0.5 1.0 i {189-55-9}
Benzo(a)pyrene (50-32-8) 610/625 0.5 1.0 Benzo(ghi)Perylene (191-24- 610/625 0.5 1.0 2) Bis(2-chloroethoxy)methane 625 5.3 21.2
(111-91-1) I Bis(2-chloroethyl)ether (111- 611/625 0.3 1.0 I 44-4)
~ ~~ ----------- - ---------
I Bis(2-chloroisopropyl)ether 625 0.3 0.6 ~~ (39638-32-9)
: Bis(2-ethylhexyl)phtha1ate 625 0.1 0.5 1 .. (1JZ:81~7)·~~ I 4-Bromophenyl phenyl ether 625 0.2
(101-55~3) 2-Chloronaphthalene (91-58- 625 0.3 0.6 7) 4-Chlorophenyl phenyl ether 625 0.3 0.5
(7005-72-3) - ---
Chrysene (218-0 1-9} 610/625 0.3 0.6 , Dibenzo (a,h)acridine (226- 610M/625M 2.5 10.0
L3~:~L ~ i Dibenzo ( a,j)acridine (224- 610M/625M 2.5 10.0 142-0)-
Dibenzo( a-h )anthracene 625 0.8 1.6 : (53-70-3)(1,2,5,6-
dibenzanthracene} I Dibenzo(a,e)pyrene (192-65- 610M/625M 2.5 10.0 i 4) •
-1 I Dibenzo(a,h)pyrene (189-64- • 625M 2.5 10.0 I O)
- -------------
I 3,3-Dichlorobenzidine (91- 605/625 0.5 1.0 94-_1)
: Diethyl phthalate (84-66-2) 625 1.9 7.6 ' Dimethyl phthalate (131-11- 625 1.6 6.4
3) -~
Di-n-butyl phthalate (84-74- 625 0.5 1.0 _])_ ~~~ ~~-·~~ 2,4-dinitrotoluene (121-14-2) : 609/625 0.2 0.4 2,6-dinitrotoluene (606-20:?) 609/625 0.2 0.4
Page31 of33 Pennit No. ST0006070
---------~-, ~~ -- ~-~~~ i ~ ~ ~~~~--~~~ ----=-------:::------::-:-----c Detection Quantitation
Pollutant & CAS No. (if Recommended (DL)1 · Level (QL) 2
available) i Analytical Protocol I pg/L unless pg/L unless . . ' ' specified sJ1!Eiled
BASE/NEUTRAL COMPOUNDS (com)lounds in bold are Ecology PBTs) iDi-n-octyl phthalate (117-84- ' ~ ~ ~~ 625 -
0
0.3 · 0.6
i_O) ____ ~~- - - --- - - L 1,2-Diphenylhydrazine (as Azobenzene) (122-66-7) Fluoranthene (206-44-0) Fluorene (86-73-7) Hexach1orobenzene (118-74- I 1) Hexachlorobutadiene (87-68- l 3) 0
Hexachlorocyclopentadiene (77-47-4) Hexachloroethane
0
( 67-72-1) Indeno( 1, 2, 3-cd)Pyrene (19}-39-5)
0
Isophorone (78-59-1) ! 3-Methyl cholanthrene (56-I 49-5) i Naphthalene (91 ::fo-=35-l Nitrobenzene (98-95-3) ' N-Nitrosodimethylamine i (62-75-9) N-Nitrosodi-n-propylamine
! (621-64-7) ···~-··············· . l N-Nitrosodiphenylamine i (86-30-6)
1625B 5.0 20
625 0.3 0.6 625 ----+------;oo-:o.3--c----:o::-.6c;---
612/625 0.3 0.6
625
1625B/625
625 610/625
625 625
625 ~ ---------
625 607/625
607/625
625
0.5
0.5
0.5 0.5
1.0
1.0
1.0 1.0
, -~ 0"".5-___+-__ 1"-'.0"-----i 2.0 8.0
0.3 ____ -co-=-:.6c__-; 0.5 ; 1.0 2.0 4.0
i Perylene (198-55-0) 625 [ Phenanthrene (85-0 1-8) 625
I Pyrene (129-00-0) . .... . ................. §~5 [ 1,2,4-Trichlorobenzene 625
(120-82-1)
Pollutant & CAS No. (if available)
2,3, 7,8-Tetra-ChlorodibenzoP-Dioxin (176-40-16) (2,3,7 ,8 TCDD)
-· ··r- -------·· 1 Detection Quantitation
. Recommended 1· (DL)1 Level (QL) 2 i i ! Analytical Protocol 1 pg/L unless pg/L unless ' ' specijie(/ ... J specified
DIOXIN -~~~- -~-=-----,--c---='~
1613B 1.3 pg/L 5 pg/L
Page 32 of33 Permit No. ST0006070
-----
Detection Quantitation Pollutant & CAS No. (if , Recommended I (DLi Level (QL) 2
! t available) 1 Analytical Protocol l pg/L unless pg/L unless
.---------- ...... ___________ i_______ _ . i '_§p(!cified specified __ 1
PESTICIDES/PCBs_'-:c- !
· Al(jrin_(3QC)~00:2) __ ........... . i alpha:J3J:IC{31<)::_8HL I beta-BHC (319-85-7) I gamma-BHC (58-89-9) ' delta-BHC (319-86-8) ! Chlordane (57-74-9) 8--······
i 4,4'-DDT (50-29-3) i 4,4'-DDE (72-55-9) ------- --l1,4' DDD (72-54-8) i l)ieldrin (60-57-1) lalpha-Endosulfan (959-98-8) I beta-Endosulfan (33213-65-i 9) I Endosulfan Sulfate (1 031-1 07-8) I Endrin(72-20-8) i Endrin Aldehyde (7421-93-
1} •- Hepta£_hlor_Q6-44-8) ' Heptachlor Epoxide (1 024-i 57-3) I PCB-1~41_(534~9-21-9) _]:'CB-1254 (11097-69-1) [ PCB-1221 (111 04-28-2) I PCB-1232 (11141-16-5)
PCB-1248 (12672-?<)-6) PCB-1260 (11096-82-5)
I PCB-1016 (12674-11-2) 9
! Toxaphene{8001-35-2)
..
608 0,025 O.Q~ __ 608 0.025 0.05 ___ j 608 ____ o .. o___,2:":5_--+ __ o"_'.o-_-5:______j 608 ---'-- 0.0.-=2=-5 ---+---=0_._,.0:.::_5_----j 608 .. - ---··. 0.0.::.25=-----+--=-0:.::.0=-5 ---+ 608 0,025 ' . 0.05 608 0,025 0.05 608 0.025 0.05 608 0,025 0.05 608 o.m o.o5 608 0,025 0.05
-- -- --------------------------------
608 0.025 0.05
608 0,025
----·-- ----------"-" 608 0,025 0.05 608 0,025 0.05
---------
608 0.025 0.05 608 0,025 0.05
608 0.25 0.5
_-=,_60:c-::8 __ ____; __ 0c-c.2=-=:5c--_--+-..C0.5 . 608 .. .. ... ' Q.}~ .. 0.5
608 0.25 0.5 608 0.25 0.5
608 --iO-'--':.l'C-3---+--0-:-'-.5-::----~ 608 0.13':----~---0-:-'-.-'o-5 --608 0.24 0.5
1. Detectfon level (DL) or detection limit- means the minimum concentration of an analyte (substance) that can be measured and reported with a 99% confidence that the analyte concentration is greater than zero as dete1mined by the procedure given in 40 CFR part 136, Appendix B.
2. Ouantitation Level (QL) also known as Minimum Level ofQuantitation (ML)- The lowest level at which the entire analytical system must give a recognizable signal and acceptable calibration point for the analyte. It is equivalent to the concentration of the lowest calibration standard, assuming that the lab has used all method-specified sample weights, volumes, and cleanup procedures. The QL is calculated by multiplying the MDL by 3.18 and rounding the result to the number nearest to (1, 2, or 5) x 10", where n
is an integer. (64 FR 30417). ALSO GIVEN AS:
Page 33 of33 Permit No. ST0006070
The smallest detectable concentration of analyte greater than the Detection Limit (DL) where the accuracy (precision & bias) achieves the objectives of the intended purpose. (Report of the Federal Advisory Committee on Detection and Quantitation Approaches and Uses in Clean Water Act Programs Submitted to the US Environmental Protection Agency December 2007).
3. Soluble Biochemical Oxvgen Demand method note: First, filter the sample through a Millipore Nylon filter (or equivalent) -pore size of 0.45-0.50 urn (prep all filters by filtering 250 ml of laboratory grade deionized water through the filter and discard). Then, analyze sample as per method 5210-B.
4. NWTPH Dx- Northwest Total Petroleum Hydrocarbons Diesel Extended Range- see http://www.ecy.wa.gov/biblio/97602.html
5. NWTPH Gx- Notihwest Total Petroleum Hydrocarbons Gasoline Extended Range- see http://www.ecy.wa.gov/biblio/97602.html
6. l, 3-dichloroproylene (mixed isomers)- You may report this parameter as two separate parameters: cis-1, 3-dichlorpropropene (1 0061-0 1-5) and trans-1, 3-dichloropropene (1 0061-02-6).
7. Total Benzofluoranthenes- Because Benzo(b)fluoranthene, Benzo(j)fluoranthene and Benzo(k)fluoranthene co-elute you may repoti these three isomers as total benzofluoranthenes.
8. Chlordane- You may report alpha-chlordane (5103-71-9) and gamma-chlordane (5103-74-2) in place of chlordane (57-74-9). If you repott alpha and gamma-chlordane, the DL/PQLs that apply are 0.025/0.050.
PCB 1016 & PCB 1242- You may repoti these two PCB compounds as one parameter called PCB 1016/1242.
Fact Sheet for State Waste Discharge Permit ST0006070
Solvay Chemicals, Inc.
July 2014
Purpose of this Fact Sheet
This fact sheet explains and documents the decisions the Depmiment of Ecology (Ecology) made in drafting the proposed State Waste Discharge pennit for Solvay Chemicals, Inc. that will allow discharge of wastewater to the Weyerhaeuser NR Company, Longview (Weyerhaeuser Longview) wastewater treatment system.
State law requires any commercial or industrial facility to obtain a pe1mit before discharging waste or chemicals to industrial wastewater treatment systems.
Ecology makes the draft permit and fact sheet available for public review and comment at least thirty (30) days before it issues the final permit to the facility operator. Copies of the fact sheet and draft permit for Solvay Chemicals, Inc., State Waste Discharge permit ST0006070, are available for public review and comment from July 10,2014 until the close of business August 11, 2014. For more details on preparing and filing comments about these documents, please see Appendix A - Public Involvement Information.
Solvay Chemicals, Inc. reviewed the draft pe1mit and fact sheet for factual accura):y. Ecology corrected any errors or omissions about the facility's location, history, product type, production rate, or discharges prior to publishing this draft fact sheet for public notice.
After the public comment period closes, Ecology will summarize substantive comments and our responses to them. Ecology will include our summary and responses to comments to this fact sheet as Appendix D - Response to Comments, and publish it when we issue the final State Waste Discharge pe1mit. Ecology will not revise the rest of the fact sheet, but the full document including all appendices will become part of the legal history contained in the facility's pe1mit file.
Summary
Solvay Chemicals, Inc. operates a facility in Longview, Washington which produces hydrogen peroxide. Solvay Chemicals, Inc. has applied to renew State Waste Discharge pe1mit No. ST0006070. The permit authorizes the discharge of wastewater to Weyerhaeuser Longview's wastewater treatment plant; once treated the water will be discharge to the Columbia River through Weyerhaeuser Longview's 001/002 outfalls.
Ecology is issuing this state waste discharge permit under the authority found in RCW 90.48.160.
Solvay Chemicals, Inc. perf01ms settling, oil water separation, and pH adjustment to individual or all effluent streams prior to discharge to Weyerhaeuser Longview. The permit effluent limits remain unchanged from the previous pe1mit. Ecology has removed the monitoring requirements for Total Suspended Solids (TSS) and Total Organic Carbon (TOC). Ecology has added monitoring for Priority Pollutants (PP). The previous permit was issued on October 1, 2009 and expired on October 1, 2014. Ecology received the state waste discharge permit renewal application on March 24,2014. A revised application was received on April28, 2014. Ecology reviewed the application and determined the application to be complete on April 28, 2014.
Fact Sheet for State Petmit ST0006070 Solvay Chemicals, Inc. Page 2 of24
Table of Contents L I1ztroduction ............................................................................................................ 4
II. Backgrottnd Information ....................................................................................... 4
A. Facility Description ............................................................................................... 6 History ................................................................................................................................. 6 Industrial Process(s) ............................................................................................................ 6 Wastewater Pretreatment. .................................................................................................... 7
B. Discharge Location to the Weyerhaeuser Longview Wastewater Treatment Plant ....................................................... ; ............................................................... 7
c. Wastewater Characterization .............................................................................. 7
D. Summary of Compliance with Previous Permit Issued ..................................... 8
E. State Environmental Policy Act (SEPA) Compliance ....................................... 9
IlL Proposed Permit Limits .......................................................................................... 9
A. Tecltnology Based Effluent Limits ...................................................................... 9
B. Comparison of effluent limits with the previous permit issued on October 1, 2009 ....................................................................................................................... 10
IV. Monitoring Reqttirements .................................................................................... 10
A. Lab Accreditation .................................. ~ ............................................................ 10
B. Wastewater Monitoring ...................................................................................... 10
v. Other Permit Conditions ...................................................................................... ]]
A. Reporting atld Recordkeeping ........................................................................... 11
B. Operations and Maintenance ............................................................................. 11
c. Prohibited Discharges ......................................................................................... 11
D. Dilution Prohibited ............................................................................................. 11
E. Non Routitte Discharges ..................................................................................... 11
F. Spill Plan .............................................................................................................. 12
G. Slug Discharge Plan ............................................................................................ 12
H. General Conditions ............................................................................................. 12
VL Public Notification of Nonconzpliance ................................................................ 12
VIL Pernzit Issuance Procedttres ................................................................................ 12
A. Permit Modifications .......................................................................................... 12
B. Proposed Permit Issuance .................................................................................. 13
VIIL References for Te~Yt a11d Appe1zdices ................................................................... 13
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 3 of24
Appendi.:tA- Public lJzvolvement lJiformatioll .......................................................................... 14
Appendi .. lC B- Your Right toAppea/ ............................................................................................. 15
Appendix C- Glossary ................................................................................................................. 16
Appentlix D- Respo11se to Co11tme1tts ......................................................................................... 24
Table I General Facility Information ............................................................................................ 4
Table 2 Wastewater Charact.erization ............................................................................................ 8
Table 3 Permit Submittals ............................................................................................................... 8
Table 4 Technology Based Effluent Limits .................................................................................. 10
Table 5 Comparison of Effluent Limits ....................................................................................... 10
Figure I Facility Location Map ...................................................................................................... 6
Figure 2 Wastewater Schematic- Solvay Chemicals, Inc. Longview Facility .............................. 7
Fact Sheet for State Pe1mit ST0006070 Solvay Chemicals, Inc. Page 4 of24
I. Introduction
The legislature defined Ecology's authority and obligations for the wastewater discharge permit program in the Water Pollution Control law, chapter 90.48 RCW (Revised Code of Washington).
Ecology adopted mles describing how it exercises its authority:
• State waste discharge program (chapter 173-216 WAC)
• Submission of plans and repmts for construction of wastewater facilities (chapter 173-240 WAC)
These mles require any industrial facility owner/operator to obtain a State Waste Discharge permit before discharging wastewater to state waters. This rule includes commercial or
· industrial discharges to sewerage systems operated by municipalities or public entities which discharge into public waters of the state. They also help define the basis for limits on each discharge and for other perfmmance requirements imposed by the permit.
Under the State Waste Discharge permit program and in response to a complete and accepted permit application, Ecology generally prepares a draft permit and accompanying fact sheet, and makes it available for public review before final issuance. If the volume of the discharge has not changed or if the characteristics of the discharge have not changed Ecology may choose not to issue a public notice. When Ecology publishes an announcement (public notice); it tells people where they can read the draft pe1mit, and where to send their comments, during a period of thirty days. (See Appendix A-Public Involvement Information for more detail about the public notice and comment procedures). After the public comment period ends, Ecology may make changes to the draft State Waste Discharge permit in response to comment(s). Ecology will summarize the responses to comments and any changes to the permit in Appendix D.
II. Background Information
Table 1 General Facility Information
j Facility Information -~-~--~~-----~~···· ~--~·-·
!
I Applicant
Facility Name and Address
Contact at Facility
Solvay Chemicals, Inc. 3500 Industrial Way Longview, Washington 98632
Name: Stephanie Halver Telephone#: (360)557-7567
Name: David Henry _~_·_~-~·--l Title: Vice President H202 Commercial
Responsible Official
Industry Type Hydrogen Peroxide Manufacturing I
Fact Sheet for State Pe1mit ST0006070 Solvay Chemicals, Inc. Page 5 of24
~;~cility Information l I ~ype. of Treatment b·y.· Industry ·--l Se~~ing, oll-wat~;.~~;~~tion, pH adJ~st~~~----
1 SIC Code.s _ . l~8-19_· _
NAIC Codes 1325_1_8o ___ _
Facility Location (NAD83/WGS84 reference datum)
Latitude: 46.1369 Longitude: -122.9808
r;~e~t~ent Pla~tReceiving Discharge 1\Vey~r~~~~~~~~;;;Co~:an_Y __ _
Discharge ~ocation (NAD83/;G;~~J- ~atitude: 46.1369 . reference datum) Longitude:-122.9808 ---~--- ----•------------ - • ----------c--·-~
Permit Status
Renewal Date of Previous Permit
Application for Pe1mit Renewal Submittal Date
Date of Ecology Acceptance of Application
Inspection Status
Date of Last Non-sampling Inspection Date
October 1, 2009
March 24,2014
April28, 2014
July 8, 2014
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 6 of24
Figure 1 Facility Location Map
A. Facility Description
Hist01y
Solvay Chemicals, Inc. operates a hydrogen peroxide plant in Longview, Washington. Constructed in 1988 and started up in 1989, the facility was expanded in 1991. In 1993 a steam methane reformer was installed to produce hydrogen for the process. An additional expansion in 1995 allowed for an increase in production. Solvay Chemicals, Inc. has applied to renew State Waste Discharge permit No. ST0006070 to allow the discharge of wastewater to the treatment plant at Weyerhaeuser Longview. The wastewater will be treated by Weyerhaeuser Longview and discharged to the Columbia River.
Industrial Process(s)
Solvay Chemicals, Inc. in Longview, Washington operates approximately 24 hours a day, 7 days a week, for 51 weeks a year, producing hydrogen peroxide (SIC code 2819). The process is a continuous closed loop process. In the process an organic working solution is hydrogenated in the presence of a metal catalyst and then oxidized. The result is hydrogen peroxide which is soluble in water and removed from the working solution. Following the hydrogen peroxide extraction, the working solution returns to the hydrogenation reactor and the process is repeated. The hydrogen used in the process is produced on-site by a steam-methane refotmer with supplemental hydrogen being
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 7 of24
supplied from a local chemical facility. Much of the hydrogen peroxide product is distilled to produce higher product strengths. They hydrogen peroxide is stored on-site and loaded into trailers, railcars, or shipped by pipeline to customers in concentrations from 35 to 70%.
Wastewater Pretreatment
Certain wastewater effluent streams are sentthrough an effluent settling tank and an oil water separator. All wastewater effluent undergoes pH adjustment prior to being discharged to the treatment plant at Weyerhaeuser Longview.
Steam Condensate .---cooung 1 ower 9,000 GPD
Slowdown [---> 14 400 GPO Boiler Slowdown
I+- 1,800GPO
Other Users (Filter Nitric Acid Cleaning, Laboratories,
Maintenance Activities) r----- 2,200 GPD
1.000 GPO
Stormwater Wasta Stream 001) 40,300 GPO
----1 110,000 GPO
Ptocess WatQF pH Adjustment 35,300 GPO 110,000 GPO
Figure 2 Wastewater Schematic- Solvay Chemicals, Inc. Longview Facility
B. Discharge Location to the Weyerhaeuser Longview Wastewater Treatment Plant
The discharge of some 123,000 gallons per day (0.123 million gallons per day) from Solvay Chemicals, Inc. is piped into the Weyerhaeuser Longview wastewater treatment system. Weyerhaeuser discharges approximately 50 million gallons per day to the Columbia River through outfalls 001/002 after providing primary and secondary wastewater treatment.
C. Wastewater Characterization
Solvay Chemicals, Inc. repotied the concentration of pollutants in the permit application and in discharge monitoring repmis. The tabulated data represents the quality of the effluent discharged from January 2013 to December 2013. The effluent is characterized as follows:
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 8 of24
Table 2 Wastewater Characterization
Parameter Units #of Average Value Maximum Value
· Total Suspended Solids (TSS)
Samples
mg/L · 151 16 56
. Parameter Units #of Minimum Value: Maximum Value Samples
pH S.U. Continuous I 7
D. Summary of Compliance with Previous Permit Issued
The previous permit placed effluent limits on pH.
11.2
Solvay Chemicals, Inc. has complied with the effluent limits and permit conditions throughout the duration of the permit issued on October 1, 2009. Ecology assessed compliance based on its review of the facility's information in the Ecology Permitting and Reporting Information System (PARIS), discharge monitoring reports (DMRs) and on inspections conducted by Ecology.
The following table summarizes compliance with report submittal requirements over the permit term.
Table 3 Permit Submittals
Submittal
Application for Permit Renewal
Pollution Prevention Plan
Update of Slug Discharge Control Plan
Non-Routine and Unanticipated Discharge
O&M- Confirmation Letter- Annual Review
Submit tal Name
n for Permit ewal
Applicatio Ren
er Pollution Stotmwat Preven tion Plan
lug Discharge Update ofS Conti ·ol Plan
utine and Non-Ro Unanticipat ed Discharge
onfirmation ualReview
O&M-C Letter-Ann
Status
.....
Received
Received
Received
Received
Received
Due Date
04/01/2014
:
Rec D
eived ate
03/2 4/2014
04/01/2014 • 03/2 4/2014
04/01/2014 04/2 8/2014
02113/2014 02/1 3/2014
11/19/2013 • 11/1 9/2013
•
Fact Sheet for State Petmit ST0006070 Solvay Chemicals, Inc. Page 9 of24
E. State Environmental Policy Act (SEPA) Compliance
State law exempts the issuance, reissuance or modification of any wastewater discharge pe1mit from the SEP A process as long as the permit contains conditions are no less stringent than federal and state rules and regulations (RCW 43.21C.0383). The exemption applies only to existing discharges, not to new discharges.
III. Proposed Permit Limits
State regulations require that Ecology base limits in a State Waste Discharge permit on the:
• Technology and treatment methods available to treat specific pollutants (technology-based). Technology-based limits are set by the EPA and published as a regulation (40 CFR 400- 471), or Ecology develops limits on a case-by-case basis (40 CFR 125.3, and RCW 90.48). Dischargers must treat wastewater using all known, available, reasonable methods of prevention, control, and treatment (AKART) ..
• Effects of the pollutants on treatment works. Wastewater must not interfere with the operation of the treatment works. Ecology considers local limits in developing permit limits.
• Applicable requirements of other local, state and federal laws.
Ecology applies the most stringent of these limits to each parameter of concern and further describes the proposed limits below.
The limits in this permit reflect information received in the application and from supp01ting reports (engineering, hydrogeology, monitoring, etc.). Ecology evaluated the permit application and determined the limits needed to comply with the rules adopted by the state of Washington. Ecology does not develop effluent limits for all reported pollutants. Some pollutants are not treatable at the concentrations reported, are not controllable at the source, and are not listed in regulation.
Ecology does not usually develop pe1mit limits for pollutants not reported in the permit application but may be present in the discharge. The pe1mit does not authorize the discharge of the non-reported pollutants. During the five-year permit term, the facility's effluent discharge conditions may change from those conditions rep01ted in the permit application. The facility must notify Ecology if significant changes occur in any constituent. Until Ecology modifies the permit to reflect additional discharge of pollutants, a pe1mitted facility could be violating its pe1mit. ·
A. Technology Based Effluent Limits
Waste discharge permits issued by Ecology specify conditions requiring all available and reasonable methods of prevention, control, and treatment (AKART) of discharges to waters of the state (RCW 90.48). Although, federal effluent guidelines are not applicable to facilities discharging to a wastewater treatment plant of an industrial facility, Ecology has determined that the federal effluent guidelines meet the requirements of AKART.
The federal categorical limits for "inorganic chemicals manufacturing- hydrogen peroxide production" are found under 40 CFR Part 415, Subpart I. There are no pretreatment standards for the discharge from facilities within this subcategory. The
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 10 of24
following permit limits are established on a best-professional-judgment basis and are necessary to satisfy the requirement for AKART:
Table 4 Technology Based Effluent Limits
Parameter Effluent Limit
pH 4.0 <pH< 12.2
B. Comparison of effluent limits with the previous permit issued on October 1, 2009
Table 5 Comparison of Effluent Limits
Parameter
pH
Basis of Limit
Technology
Previous Effluent Limits: Outfall #001
4.0 <pH< 12.2
IV. Monitoring Requirements
1 Proposed Effluent Limits: Outfall #001
4.0 <pH< 12.2
Ecology requires monitoring, recording, and reporting (WAC 173-216-11 0) to verify that the treatment process functions correctly and that the discharge complies with the permit's effluent limits.
If a facility uses a contract laboratory to monitor wastewater, it must ensure that the laboratory uses the methods and meets or exceeds the method detection levels required by the permit. The petmit describes when facilities may use alternative methods. It also describes what to do in certain situations when the laboratory encounters matrix effects. When a facility uses an altemative method as allowed by the petmit, it must report the test method, DL, and QL on the discharge monitoring report or in the required repmi.
A. Lab Accreditation
Ecology requires that facilities must use a laboratory registered or accredited under the provisions of chapter 173-50 WAC, Accreditation of Environmental Laboratories, to prepare all monitoring data (with the exception of cettain parameters).
B. Wastewater Monitoring
Ecology details the proposed monitoring schedule under Special Condition S2. Specified monitoring frequencies take into account the quantity and variability of the discharge, the treatment method, past compliance, significance of pollutants, and cost of monitoring. Monitoring for Total Suspended Solids (TSS) and Total Organic Carbon (TOC) have been removed. These monitoring parameters were originally established based on EPA effluent guidelines for facilities which discharge to surface waters of the United States. Monitoring for these parameters is not applicable to facilities which discharge to privately owned treatment works.
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 11 of24
Ecology has included monitoring for priority pollutants on a once per permit tetm basis. The priority pollutant scan has been included to help ensure that there is no pass-through of low level pollutants at the Weyerhaeuser Longview wastewater treatment plant.
V. Other Permit Conditions
A. Reporting and Recordkeeping
Ecology based Special Condition S3 on its authority to specify any appropriate reporting and recordkeeping requirements to prevent and control waste discharges [WAC 173-216-110 and CFR403.12 (e),(g), and (h)].
B. Operations and Maintenance
Ecology requires dischargers to take all reasonable steps to properly operate and maintain their wastewater treatment system in accordance with state regulations (WAC 173-240-080 and WAC 173-216-110). The facility must have prepared an operation and maintenance (O&M) manual as required by state regulation for the constmction of wastewater treatment facilities (WAC 173-240-150). Implementation of the procedures in the operation and maintenance manual ensures the facility's compliance with the tetms and limits in the permit. Ecology has removed the requirements for the submittal of an updated Operations and Maintenance lvfanual to Ecology and an annual Update or Review Cmifirmation Letter.
C. Prohibited Discharges
Ecology prohibits cetiain pollutants from being discharged to the Weyerhaeuser Longview wastewater treatment plant. These include substances which cause passthrough or interference, pollutants which may cause damage to the treatment plant or harm to the treatment plant workers (chapter 173-216 WAC) and the discharge of designated dangerous wastes not authorized by this petmit (chapter 173-303 WAC).
Solvay has previously discharged process water comingled with Aqueous Film Forming Foam (AFFF) used for fire fighting. The discharge of AFFF, containing fluorsurfactants which are known to interfere with the treatment plant at Weyerhaeuser Longview, is prohibited.
D. Dilution Prohibited
Ecology prohibits the facility from diluting its effluent as a patiial or complete substitute for adequate treatment to achieve compliance with petmit limits.
E. Non Routine Discharges
Occasionally, this facility may generate wastewater not characterized in the permit application because it is not a routine discharge and the facility did not anticipate it at the time of application. These wastes typically consist of waters used to pressure-test storage tanks or fire water systems or of leaks from drinking water systems.
Fact Sheet for State Pennit ST0006070 Solvay Chemicals, Inc. Page 12 of24
The permit authorizes non-routine discharges under certain conditions. The facility must characterize these waste waters for pollutants and examine the opp01tunities for reuse. Depending on the nature and extent of pollutants in this wastewater and on any opportunities for reuse, Ecology may:
• Authorize the facility to discharge the water.
• Require the facility to treat the wastewater.
• Require the facility to reuse the wastewater.
F. Spill Plan
This facility stores a quantity of chemicals on-site that have the potential to cause water pollution and/or interference or pass through at the receiving wastewater treatment plant if accidentally released. Ecology can require a facility to develop best management plans to prevent this accidental release [Section 402(a)(l) of the Federal Water Pollution Control Act (FWPCA) and RCW 90.48.080].
Solvay Chemicals, Inc. developed a plan for preventing the accidental release of pollutants to state waters, to the receiving treatment plant, and for minimizing damages if such a spill occurs. The proposed permit requires the facility to update this plan and submit it to Ecology.
G. Slug Discharge Plan
Ecology determined that Solvay Chemicals, Inc. has the potential for a batch discharge or a spill that could adversely affect the treatment plant, therefore the proposed petmit requires a slug discharge control plan. Slug discharge control plans can be required as a pmt of the pretreatment regulations [40 CFR 403.8 (f)(!) (iii)(B)(6) and (f) (2)(vi)]; although this facility does not discharge to a POTW, the requirement has been included on a best-professional judgment basis.
H. General Conditions
Ecology bases the standardized general conditions on state law and regulations. They are included in all state waste discharge petmits issued by Ecology.
VI. Public Notification of Noncompliance Ecology may annually publish a list of all industrial users in significant noncompliance with Pretreatment Standards or Requirements during any of the previous four qumters in a local newspaper. Accordingly, this petmit Special Condition infotms the Facility that noncompliance with this permit may result in publication of the noncompliance.
VII. Permit Issuance Procedures
A. Permit Modifications
Ecology may modify this permit to impose or change the numerical limits, if necessary to comply with changes in the pretreatment requirements, conditions in local sewer
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 13 of24
ordinances, or based on new information from sources such as inspections and effluent monitoring. It may also modify this permit to comply with new or amended state or federal regulations.
B. Proposed Permit Issuance
This proposed permit meets all statutory requirements for authorizing a wastewater discharge, including those limits and conditions believed necessary to control toxics. Ecology proposes that the permit be ·issued for 5 years.
VIII. References for Text and Appendices
Washington State Department of Ecology.
Laws and Regulations
(http://www.ecy.wa.gov/laws-mles/index.html)
Permit and Wastewater Related Information (http:/lwww.ecy.wa.gov/programs/wq/permits/guidance.html)
December 2011. Permit Writer's Manual, Publication Number 92-109 (https:/lfortress. wa. gov /ecy /publications/SummmyPages/921 09 .html)
February 2007. Focus Sheet on Solid Waste Control Plan, Developing a Solid Waste Control Plan for Industrial Wastewater Discharge Permittees, Publication Number 07-10-024. (http:/lwww.ecy. wa.gov/pubs/071 0024. pdf)
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 14 of24
Appendix A- Public Involvement Information
Ecology proposes to renew a pennit to Solvay Chemicals, Inc. The permit includes wastewater discharge limits and other conditions. This fact sheet describes the facility and Ecology's reasons for requiring permit conditions.
Ecology will place a Public Notice of Draft on July I 0, 2014 in The Daily News to inform the public and to invite comment on the proposed draft State Waste Discharge pennit and fact sheet.
The notice:
• Tells where copies of the draft Pennit and Fact Sheet are available for public evaluation (a local public library, the closest Regional or Field Office, posted on our website).
• Offers to provide the documents in an alternate format to accommodate special needs.
• Urges people to submit their comments, in writing, before the end of the Comment Period.
• Tells how to request a public hearing of comments about the proposed state waste discharge permit.
• Explains the next step( s) in the permitting process.
Ecology published a document, Frequently Asked Questions about Effictive Public Commenting, available on our website at https:/ /fortress. wa.gov/ ecy /publications/Summary Pages/03 07 023 .html.
You may obtain fmiher infotmation from Ecology by telephone, (360) 407-7563 or by writing to the address listed below.
Water Quality Permit Coordinator Department of Ecology Industrial Section POBox47600 Olympia, W A 98504-7600
The primary author of this petmit and fact sheet is Shingo Yamazaki.
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 15 of24
Appendix B- Your Right to Appeal
You have a right to appeal this permit to the Pollution Control Hearing Board (PCHB) within 30 days of the date of receipt of the final petmit. The appeal process is governed by chapter 43.21B RCW and chapter 371-08 WAC. "Date of receipt" is defined in RCW 43.21B.001(2) (see glossary).
To appeal you must do the following within 30 days of the date of receipt of this permit:
• File your appeal and a copy of this permit with the PCHB (see addresses below). Filing means actual receipt by the PCHB during regular business hours.
• Serve a copy of your appeal and this permit on Ecology in paper form - by mail or in person. (See addresses below.) E-mail is not accepted.
· You must also comply with other applicable requirements in chapter 43.21B RCW and chapter 371-08 WAC.
ADDRESS AND LOCATION INFORMATION
Street Addresses
Department of Ecology
Attn: Appeals Processing Desk
300 Desmond Drive SE
Lacey, W A 98503
Pollution Control Hearings Board
1111 Israel RD SW
STE 301
Tumwater, WA 98501
Mailing Addresses
Department of Ecology
Attn: Appeals Processing Desk
PO Box47608
Olympia, W A 98504-7608
Pollution Control Hearings Board
POBox40903
Olympia, W A 98504-0903
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 16 of24
Appendix C - Glossary
1-DMax or 1-Day Maximum Temperature-- The highest water temperature reached on any given day. This measure can be obtained using calibrated maximum/minimum thermometers or continuous monitoring probes having sampling intervals of thirty minutes or less.
7-DADMax or 7-Day Average of the daily maximum temperatures-- The arithmetic average of seven consecutive measures of daily maximum temperatures. The 7-DADMax for any individual day is calculated by averaging that day's daily maximum temperature with the daily maximum temperatures of the three days prior and the three days after that date.
Acute toxicity -- The lethal effect of a compound on an organism that occurs in a shmi time period, usually 48 to 96 hours.
AKART --The acronym for "all known, available, and reasonable methods of prevention, control and treatment." AKART is a technology-based approach to limiting pollutants from wastewater discharges, which requires an engineering judgment and an economic judgment. AKART must be applied to all wastes and contaminants prior to entry into waters of the state in accordance with RCW 90.48.010 and 520, WAC 173-200-030(2)(c)(ii), and WAC 173-216-llO(l)(a).
Alternate Point of Compliance-- An alternative location in the groundwater from the point of compliance where compliance with the groundwater standards is measured. It may be established in the groundwater at locations some distance from the discharge source, up to, but not exceeding the property boundary and is detennined on a site specific basis following an AKART analysis. An "early warning value" must be used when an alternate point is established. An alternate point of compliance must be determined and approved in accordance with WAC 173-200-060(2).
Ambient Water Quality-- The existing enviromnental condition of the water in a receiving water body.
Ammonia --Ammonia is produced by the breakdown of nitrogenous materials in wastewater. Ammonia is toxic to aquatic organisms, exerts an oxygen demand, and contributes to eutrophication. It also increases the amount of chlorine needed to disinfect wastewater.
Annual Average Design Flow (AADF) --Average of the daily flow volumes anticipated to occur over a calendar year.
Average Monthly (Intermittent) Discharge Limit-- The average of the measured values obtained over a calendar months time taking into account zero discharge days.
Average Monthly Discharge Limit -- The average of the measured values obtained over a calendar month's time.
Background Water Quality-- The concentrations of chemical, physical, biological or radiological constituents or other characteristics in or of groundwater at a particular point in time upgradient of an activity that has not been affected by that activity, [WAC 173-200-020(3)]. Background water quality for any parameter is statistically defined as the 95% upper tolerance interval with a 95% confidence based on at least eight hydraulically
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 17 of24
upgradient water quality samples. The eight samples are collected over a period of at least one year, with no more than one sample collected during any month in a single calendar year.
Best Management Practices (BMPs) -- Schedules of activities, prohibitions of practices, maintenance procedures, and other physical, stmctural and/or managerial practices to prevent or reduce the pollution of waters of the state. BMPs include treatment systems, operating procedures, and practices to control: plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. BMPs may be further categorized as operational, source control, erosion and sediment control, and treatment BMPs.
BODS -- Determining the five-day Biochemical Oxygen Demand of an effluent is an indirect way of measuring the quantity of organic material present in an effluent that is utilized by bacteria. The BODS is used in modeling to measure the reduction of dissolved oxygen in receiving waters after effluent is discharged. Stress caused by reduced dissolved oxygen levels makes organisms less competitive and less able to sustain their species in the aquatic environment. Although BOD5 is not a specific compound, it is defined as a conventional pollutant under the federal Clean Water Act.
Bypass-- The intentional diversion of waste streams from any p01tion of a treatment facility.
Categorical Pretreatment Standards --National pretreatment standards specifying quantities or concentrations of pollutants or pollutant properties, which may be discharged to a POTW by existing or new industrial users in specific industrial subcategories.
Chlorine -- A chemical used to disinfect wastewaters of pathogens hatmful to human health. It is also extremely toxic to aquatic life.
Chronic Toxicity-- The effect of a compound on an organism over a relatively long time, often 1/10 of an organism's lifespan or more. Chronic toxicity can measure survival, reproduction or growth rates, or other parameters to measure the toxic effects of a compound or combination of compounds.
Clean Water Act (CWA) --The federal Water Pollution Control Act enacted by Public Law 92-500, as amended by Public Laws 95-217, 95-576, 96-483, 97-117; USC 1251 et seq.
Compliance Inspection-Without Sampling-- A site visit for the purpose of detetmining the compliance of a facility with the terms and conditions of its permit or with applicable statutes and regulations.
Compliance Inspection-With Sampling -- A site visit for the purpose of determining the compliance of a facility with the tetms and conditions of its permit or with applicable statutes and regulations. In addition it includes as a minimum, sampling and analysis for all parameters with limits in the petmit to ascettain compliance with those limits; and, for municipal facilities, sampling of influent to ascettain compliance with the 85 percent removal requirement. Ecology may conduct additional sampling.
Composite Sample -- A mixture of grab samples collected at the same sampling point at different times, fotmed either by continuous sampling or by mixing discrete samples. May be "time-composite" (collected at constant time intervals) or "flow-prop01tional" (collected either as a constant sample volume at time intervals propottional to stream flow, or collected
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 18 of24
by increasing the volume of each aliquot as the flow increased while maintaining a constant time interval between the aliquots).
Construction Activity -- Clearing, grading, excavation, and any other activity, which disturbs the surface of the land. ·Such activities may include road building; construction of residential houses, office buildings, or industrial buildings; and demolition activity.
Continuous Monitoring-- Unintenupted, unless othetwise noted in the petmit.
Critical Condition -- The time during which the combination of receiving water and waste discharge conditions have the highest potential for causing toxicity in the receiving water environment. This situation usually occurs when the flow within a water body is low, thus, its ability to dilute effluent is reduced.
Date of Receipt~- This is defined in RCW 43.21B.001(2) as five business days after the date of mailing; or the date of actual receipt, when the actual receipt date can be proven by a preponderance of the evidence. The recipient's swom affidavit or declaration indicating the date of receipt, which is unchallenged by the agency, constitutes sufficient evidence of actual receipt. The date of actual receipt, however, may not exceed forty-five days from the date of mailing.
Detection Limit -- The minimum concentration of a substance that can be measured and reported with 99 percent confidence that the pollutant concentration is above zero and is determined from analysis of a sample in a given matrix containing the pollutant.
Dilution Factor (DF) -- A measure of the amount of mixing of effluent and receiving water that occurs at the boundary of the mixing zone. Expressed as the inverse of the percent effluent fraction, for example, a dilution factor of 10 means the effluent comprises 10% by volume and the receiving water 90%.
Distribution Uniformity -- The uniformity of infiltration (or application in the case of sprinkle or trickle inigation) throughout the field expressed as a percent relating to the average depth infiltrated in the lowest one-quarter of the area to the average depth of water infiltrated.
Early Warning Value -- The concentration of a pollutant set in accordance with WAC 173-200-070 that is a percentage of an enforcement limit. It may be established in the effluent, groundwater, surface water, the vadose zone or within the treatment process. This value acts as a trigger to detect and respond to increasing contaminant concentrations prior to the degradation of a beneficial use.
Enforcement Limit-- The concentration assigned to a contaminant in the groundwater at the point of compliance for the purpose of regulation, [WAC 173-200-020(11 )]. This limit assures that a groundwater criterion will not be exceeded and that background water quality will be protected.
Engineering Report-- A document that thoroughly examines the engineering and administrative aspects of a particular domestic or industrial wastewater facility. The repmt must contain the appropriate information required in WAC 173-240-060 or 173-240-130,
Fecal Coliform Bacteria --Fecal coliform bacteria are used as indicators of pathogenic bacteria in the effluent that are harmful to humans. Pathogenic bacteria in wastewater discharges are
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 19 of24
controlled by disinfecting the wastewater. The presence of high numbers offecal colifmm bacteria in a water body can indicate the recent release of untreated wastewater and/or the presence of animal feces.
Grab Sample -- A single sample or measurement taken at a specific time or over as shmt a period of time as is feasible.
Groundwater -- Water in a saturated zone or stratum beneath the surface of land or below a surface water body.
Industrial User-- A discharger of wastewater to the sanitary sewer that is not sanitary wastewater or is not equivalent to sanitary wastewater in character.
Industrial Wastewater-- Water or liquid-carried waste from industrial or commercial processes, as distinct from domestic wastewater. These wastes 'may result from any process or activity of industry, manufacture, trade or business; from the development of any natural resource; or from animal operations such as feed lots, poultry houses, or dairies. The te1m includes contaminated storm water and, also, leachate from solid waste facilities.
Interference -- A discharge which, alone or in conjunction with a discharge or discharges from other sources, both:
• Inhibits or distupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal; and
• Therefore is a cause of a violation of any requirement of the POTW's NPDES pe1mit (including an increase in the magnitude or duration of a violation) or of the prevention of sewage sludge use or disposal in compliance with the following statutory provisions and regulations or pe1mits issued thereunder (or more stringent State or local regulations): Section 405 of the Clean Water Act, the Solid Waste Disposal Act (SWDA) (including title II, more commonly referred to as the Resource Conservation and Recovery Act (RCRA), and including State regulations contained in any State sludge management plan prepared pursuant to subtitleD of the SWDA), sludge regulations appearing in 40 CFR Part 507, the Clean Air Act, the Toxic Substances Control Act, and the Marine Protection, Research and Sanctuaries Act.
Local Limits -- Specific prohibitions or limits on pollutants or pollutant parameters developed byaPOTW.
Major Facility-- A facility discharging to surface water with an EPA rating score of> 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact.
Maximum Daily Discharge Limit -- The highest allowable daily discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. The daily discharge is calculated as the average measurement of the pollutant over the day.
Maximum Day Design Flow (MDDF) --The largest volume of flow anticipated to occur during a one-day period, expressed as a daily average.
Fact Sheet for State Petmit ST0006070 Solvay Chemicals, Inc. Page 20 of24
Maximum Month Design Flow (MMD F) --The largest volume of flow anticipated to occur during a continuous 30-day period, expressed as a daily average.
Maximum Week Design Flow (MWDF) --The largest volume of flow anticipated to occur during a continuous 7 -day period, expressed as a daily average.
Method Detection Level (MDL) -- See Method Detection Level.
Minor Facility -- A facility discharging to surface water with an EPA rating score of< 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact.
Mixing Zone -- An area that su11'ounds an effluent discharge within which water quality criteria may be exceeded. The petmit sp~cifies the area of the authorized mixing zone that Ecology defines following procedures outlined in state regulations (chapter 173-201 A WAC).
National Pollutant Discharge Elimination System (NPDES) -- The NPDES (Section 402 of the Clean Water Act) is the federal wastewater permitting system for discharges to navigable waters of the United States. Many states, including the state of Washington, have been delegated the authority to issue these permits. NPDES permits issued by Washington State permit writers are joint NPDES/State permits issued under both state and federal laws.
pH -- The pH of a liquid measures its acidity or alkalinity. It is the negative logarithm of the hydrogen ion concentration. A pH of 7 is defined as neutral and large variations above or below this value are considered harmful to most aquatic life.
Pass-Through-- A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or in conjunction with a discharge or discharges from other sources, is a cause of a violation of any requirement of the POTW's NPDES permit (including an increase in the magnitude or duration of a violation), or which is a cause of a violation of State water quality standards.
Peal• Hour Design Flow (PHDF) -- The largest volume of flow anticipated to occur during a one-hour period, expressed as a daily or hourly average.
Peak Instantaneous Design Flow (PIDF) -- The maximum anticipated instantaneous flow.
Point of Compliance -- The location in the groundwater where the enforcement limit must not be exceeded and a facility must comply with the Ground Water Quality Standards. Ecology detetmines this limit on a site-specific basis. Ecology locates the point of compliance in the groundwater as near and directly downgradient from the pollutant source as technically, hydrogeologically, and geographically feasible, unless it approves an alternative point of compliance.
Potential Significant Industrial User (PSIU) --A potential significant industrial user is defined as an Industrial User that does not meet the criteria for a Significant Industrial User, but which discharges wastewater meeting one or moreofthe following criteria:
a. Exceeds 0.5 % of treatment plant design capacity criteria and discharges <25,000 gallons per day; or
b. Is a member of a group of similar industrial users which, taken together, have the potential to cause pass through or interference at the POTW (e.g. facilities which develop
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 21 of24
photographic film or paper, and car washes). Ecology may determine that a discharger initially classified as a potential significant industrial user should be managed as a significant industrial user.
Quantitation Level (QL) --Also known as Minimum Level of Quantitation (ML)- The lowest level at which the entire analytical system must give a recognizable signal and acceptable calibration point for the analyte. It is equivalent to the concentration of the lowest calibration standard, assuming that the lab has used all method-specified sample weights, volumes, and cleanup procedures. The QL is calculated by multiplying the MDL by 3.18 and rounding the result to the number nearest to (1 ,2,or 5) x 1 0", where n is an integer. (64 FR 30417). ALSO GIVEN AS: The smallest detectable concentration of analyte greater than the Detection Limit (DL) where the accuracy (precision & bias) achieves the objectives of the intended purpose. (Report of the Federal Advisory Committee on Detection and Quantitation Approaches and Uses in Clean Water Act Programs Submitted to the US Environmental Protection Agency December 2007).
Reasonable Potential-- A reasonable potential to cause a water quality violation, or loss of sensitive and/or important habitat.
Responsible Corporate Officer-- A president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who perfonns similar policy- or decision-making functions for the corporation, or the manager of one or more manufacturing, production, or operating facilities employing more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars), if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures (40 CFR 122.22).
Significant Industrial User (SIU) --
1) All industrial users subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR Chapter I, Subchapter N; and
2) Any other industrial user that: discharges an average of25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, noncontact cooling, and boiler blowdown wastewater); contributes a process wastestream that makes up 5 percent or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant; or is designated as such by the Control Authority* on the basis that the industrial user has a reasonable potential for adversely affecting the POTW's operation or for violating any pretreatment standard or requirement [in accordance with 40 CFR 403.8(f)(6)].
Upon finding that the industrial user meeting the criteria in paragraph 2, above, has no reasonable potential for adversely affecting the POTW's operation or for violating any pretreatment standard or requirement, the Control Authority* may at any time, on its own initiative or in response to a petition received from an industrial user or POTW, and in accordance with 40 CFR 403.8(±)(6), dete1mine that such industrial user is not a significant industrial user.
*The term "Control Authority" refers to the Washington State Department of Ecology in the case of non-delegated POTWs or to the POTWin the case of delegated POTWs.
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 22 of24
Slug Discharge --Any discharge of a non-routine, episodic nature, including but not limited to an accidental spill or a non-customary batch discharge to the POTW. This may include any pollutant released at a flow rate that may cause interference or pass through with the POTW or in any way violate the permit conditions or the POTW' s regulations and local limits.
Soil Scientist -- An individual who is registered as a Certified or Registered Professional Soil Scientist or as a Certified Professional Soil Specialist by the American Registry of Cet1ified Professionals in Agronomy, Crops, and Soils or by the National Society of Consulting Scientists or who has the credentials for membership. Minimum requirements for eligibility are: possession of a baccalaureate, masters, or doctorate degree from a U.S. or Canadian institution with a minimum of 30 semester hours or 45 quarter hours professional core courses in agronomy, crops or soils, and have 5,3,or 1 years, respectively, of professional experience working in the area of agronomy, crops, or soils.
Solid Waste-- All putrescible and non-putrescible solid and semisolid wastes including, but not limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, demolition and constmction wastes, abandoned vehicles or patis thereof, contaminated soils and contaminated dredged material, and recyclable materials.
Soluble BODs-- Detennining the soluble fraction of Biochemical Oxygen Demand of an effluent is an indirect way of measuring the quantity of soluble organic material present in an effluent that is utilized by bacteria. Although the soluble BODs test is not specifically described in Standard Methods, filtering the raw sample through at least a 1.2 urn filter prior to tunning the standard BODs test is sufficient to remove the particulate organic fraction.
State Waters -- Lakes, rivers, ponds, streams, inland waters, underground waters, salt waters, and all other surface waters and watercourses within the jurisdiction of the state of Washington.
Stormwate1· -- That pot1ion of precipitation that does not naturally percolate into the ground or evaporate, but flows via overland flow, interflow, pipes, and other features of a storm water drainage system into a defined surface water body, or a constmcted infiltration facility.
Technology-Based Effluent Limit-- A permit limit based on the ability of a treatment method to reduce the pollutant.
Total Coliform Bacteria --A microbiological test, which detects and enumerates the total coliform group of bacteria in water samples.
Total Dissolved Solids-- That pot1ion of total solids in water or wastewater that passes through a specific filter.
Total Maximum Daily Load (TMDL) --A detetmination of the amount of pollutant that a water body can receive and still meet water quality standards.
Total Suspended Solids (TSS) --Total suspended solids is the pat1iculate material in an effluent. Large quantities of TSS discharged to a receiving water may result in solids accumulation. Apat1 from any toxic effects attributable to substances leached out by water, suspended solids may kill fish, shellfish, and other aquatic organisms by causing abrasive injuries and by clogging the gills and respiratory passages of various aquatic fauna.
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 23 of24
Indirectly, suspended solids can screen out light and can promote and maintain the development of noxious conditions through oxygen depletion.
Upset-- An exceptional incident in which there is unintentional and temporary noncompliance with technology-based pe1mit effluent limits because of factors beyond the reasonable control of the Permittee. An upset does not include noncompliance to the extent caused by operational elTOr, improperly designed treatment facilities, lack of preventative maintenance, or careless or improper operation.
Water Quality-Based Effluent Limit-- A limit imposed on the concentration of an effluent parameter to prevent the concentration of that parameter from exceeding its water quality criterion after discharge into receiving waters.
Fact Sheet for State Permit ST0006070 Solvay Chemicals, Inc. Page 24 of24
Appendix D- Response to Comments
Weyerhaeuser Longview Comment:
Weyerhaeuser requests that two items be added to the Solvay Permit. First, condition S5.B. should specifically prohibit the discharge of Aqueous Film Forming Foam, (AFFF) containing fluorosurfactants known to impair the health of the biomass in activated sludge waste water treatment plants. Second, the Priority Pollutant scan should be moved up to the first year of the permit to enable Weyerhaeuser and Ecology to fully assess possible impacts to the treatment plant.
Ecology Response to Comment:
Although the permit already includes language prohibiting the discharge of pollutants in concentrations "that will cause interforence with the treatment plant, "Ecology has added additional language to ensure that fire fighting foam which may harm the Weyerhaeuser Longview wastewater treatment plant is prohibited.
Ecology has changed the effluent characterization requirements. The effluent characterization must be completed and reported to Ecology within the first full calendar year of the effective permit.
Appendix B:
TRRWA NPDES Permit No. WA0037788
TRRWA’s Fact Sheet for NPDES Permit No. WA0037788
Page 1 of 42
Permit No. WA0037788
a The Three Rivers Regional Wastewater Plant (TRRWP) is the primary Permittee and has day-to-day responsibility for the treatment plant and all permit conditions,
except as otherwise noted. The cities of Longview, and Kelso, the Beacon Hill Sewer District and Cowlitz County are contributing jurisdictions to the treatment plant.
The TRRWP has responsibility for the plant and discharge. The jurisdictions are responsible for their respective collection systems and lift stations, and the discharge
of waste from their systems to the Three Rivers Waste Water Treatment Plant system.
Issuance Date: October 24, 2012
Effective Date: November 1, 2012
Expiration Date: October 31, 2017
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT NO. WA0037788
State of Washington DEPARTMENT OF ECOLOGY
Olympia, Washington 98504-7775
In compliance with the provisions of The State of Washington Water Pollution Control Law
Chapter 90.48 Revised Code of Washington and
The Federal Water Pollution Control Act (The Clean Water Act)
Title 33 United States Code, Section 1251 et seq.
The Three Rivers Regional Wastewater Authority
(Formerly known as the Cowlitz Sewer Operating Board)
and the Contributing Jurisdictionsa of
City of Longview
P.O. Box 128 Longview, WA 98632
City of Kelso
203 South Pacific
Avenue, Suite 217 Kelso, WA 98626
Beacon Hill Sewer District
1121 Westside Hwy
Kelso, WA 98626
Cowlitz County 207 4
th Avenue Northt
Kelso, WA 98626
Plant Location:
467 Fibre Way
Longview, Washington 98632
Receiving Water:
Columbia River
Water Body I.D. No.:
1240014462974
Discharge Location:
Latitude: 46.09804
Longitude: -122.93472
Plant Type: Activated Sludge, Chlorine Disinfection
is authorized to discharge in accordance with the special and general conditions that follow.
Robert W. Bergquist, LEED© AP
Southwest Region Manager
Water Quality Program
Washington State Department of Ecology
Page 2 of 42
Permit No. WA0037788
TABLE OF CONTENTS
SUMMARY OF PERMIT REPORT SUBMITTALS .................................................................................. 4
Submittals for the Three Rivers Wastewater Treatment Plant
S1. DISCHARGE LIMITS .................................................................................................................... 6
A. Effluent Limits
B. Mixing Zone Descriptions
S2. MONITORING REQUIREMENTS ................................................................................................ 7
A. Monitoring Schedule
B. Sampling and Analytical Procedures
C. Flow Measurement
D. Laboratory Accreditation
S3. REPORTING AND RECORDING REQUIREMENTS ............................................................... 11
A. Reporting
B. Records Retention
C. Recording of Results
D. Additional Monitoring by the Permittee
E. Reporting Permit Violations
F. Other Reporting
G. Maintaining a Copy of This Permit
S4. FACILITY LOADING .................................................................................................................. 15
A. Design Criteria
B. Plans for Maintaining Adequate Capacity
C. Duty to Mitigate
D. Notification of New or Altered Sources
E. Infiltration and Inflow Evaluation
F. Wasteload Assessment
S5. OPERATION AND MAINTENANCE ......................................................................................... 17
A. Certified Operator
B. Operation & Maintenance (O&M) Program
C. Short-term Reduction
D. Electrical Power Failure
E. Prevent Connection of Inflow
F. Bypass Procedures
G. Operations and Maintenance Manual
S6. PRETREATMENT ........................................................................................................................ 20
A. General Requirements
B. Wastewater Discharge Permit Required
C. Identification and Reporting of Existing, New, and Proposed Industrial Users
D. Industrial User Survey
E. Establishment of Local Limits (applies to each Jurisidiction)
F. Duty to Enforce Discharge Prohibitions (applies to all Permittees)
S7. RESIDUAL SOLIDS ..................................................................................................................... 23
Page 3 of 42
Permit No. WA0037788
S8. APPLICATION FOR PERMIT RENEWAL ................................................................................ 23
S9. RECEIVING WATER AND EFFLUENT STUDY ...................................................................... 23
S10. ACUTE TOXICITY ...................................................................................................................... 24
A. Testing Requirements
B. Sampling and Reporting Requirements
S11. CHRONIC TOXICITY .................................................................................................................. 25
A. Testing Requirements
B. Sampling and Reporting Requirements
S12. OUTFALL EVALUATION .......................................................................................................... 26
GENERAL CONDITIONS
G1. SIGNATORY REQUIREMENTS ................................................................................................. 27
G2. RIGHT OF INSPECTION AND ENTRY ..................................................................................... 27
G3. PERMIT ACTIONS....................................................................................................................... 28
G4. REPORTING PLANNED CHANGES .......................................................................................... 29
G5. PLAN REVIEW REQUIRED ....................................................................................................... 29
G6. COMPLIANCE WITH OTHER LAWS AND STATUTES ......................................................... 29
G7. TRANSFER OF THIS PERMIT ................................................................................................... 30
G8. REDUCED PRODUCTION FOR COMPLIANCE ...................................................................... 30
G9. REMOVED SUBSTANCES ......................................................................................................... 30
G10. DUTY TO PROVIDE INFORMATION ....................................................................................... 30
G11. OTHER REQUIREMENTS OF 40 CFR ....................................................................................... 31
G12. ADDITIONAL MONITORING .................................................................................................... 31
G13. PAYMENT OF FEES .................................................................................................................... 31
G14. PENALTIES FOR VIOLATING PERMIT CONDITIONS.......................................................... 31
G15. UPSET ........................................................................................................................................... 31
G16. PROPERTY RIGHTS .................................................................................................................... 31
G17. DUTY TO COMPLY .................................................................................................................... 32
G18. TOXIC POLLUTANTS................................................................................................................. 32
G19. PENALTIES FOR TAMPERING ................................................................................................. 32
G20. REPORTING ANTICIPATED NON-COMPLIANCE ................................................................. 32
G21. REPORTING OTHER INFORMATION ...................................................................................... 32
G22. COMPLIANCE SCHEDULES ..................................................................................................... 32
APPENDIX A ................................................................................................................................33
Page 4 of 42
Permit No. WA0037788
SUMMARY OF PERMIT REPORT SUBMITTALS
Refer to the Special and General Conditions of this permit for additional submittal requirements.
Submittals for the Three Rivers Regional Wastewater Treatment Plant:
Permit
Section Submittal Frequency First Submittal Date
S3. Discharge Monitoring Report Monthly December 15, 2012
S3.E. Reporting Permit Violations As necessary
S4. See additional Submittals for the
Juridictional Permittees Below
S4.B. Plans for Maintaining Adequate Capacity As necessary
S4.D. Notification of New or Altered Sources As necessary
S4.E.2. Infiltration and Inflow Evaluation Annually June 15, 2013
S4.F. Wasteload Assessment Annually June 15, 2013
S5. See additional Submittals for the
Juridictional Permittees Below
S5.B. Operations and Maintenance Manual
Update As necessary
S5.G. Operations and Maintenance Manual
Update or Review Confirmation Letter Annually June 15, 2013
S6. See additional Submittals for the
Juridictional Permittees Below
S6.E. Establish Local Limits 1/permit cycle June 27, 2013
S7. Residual Solids Management Plan 1/permit cycle April 15, 2016
S8. Application for Permit Renewal 1/permit cycle April 1, 2017
S9. Draft Scope of Work, Quality Assurance
Project Plan and Field Sampling Plan 1/permit cycle September 15, 2013
S9. Final Scope of Work, Quality Assurance
Project Plan and Field Sampling Plan 1/permit cycle December 31, 2013
S9. Draft Field Sampling Data and Data
Analysis 1/permit cycle September 15, 2015
S9. Final Field Sampling Data and Data
Analysis 1/permit cycle December 31, 2015
S10.A.
Acute Toxicity Effluent Test Results
following tests and with Permit Renewal
Application
2/permit cycle
September 15, 2016,
March 15, 2017
April 1, 2017
Page 5 of 42
Permit No. WA0037788
Permit
Section Submittal Frequency First Submittal Date
S11.A.
Chronic Toxicity Effluent Test Results
following tests and with Permit Renewal
Application
2/permit cycle
September 15, 2016,
March 15, 2017, &
April 1, 2017
S12. Outfall Evaluation 1/permit cycle November 15, 2016
G1. Notice of Change in Authorization As necessary
G4. Reporting Planned Changes As necessary
G5. Engineering Report for Construction or
Modification Activities As necessary
G20. Reporting Anticipated Non-compliance As necessary
G21. Reporting Other Information As necessary
Submittals for the Following Jurisdictions:
City of Longview, the City of Kelso, the Beacon Hill Sewer District, and Cowlitz County:
Permit
Section Submittal Frequency First Submittal Date
S4.D. Notification of New or Altered Sources As necessary
S4.E.2 Infiltration and Inflow Evaluation Annually June 15, 2013
S5.B. O&M Manual for Collection System
Update As necessary
S6.D. Industrial User Survey Update* Annually November 15, 2012
S6.E. Establish Local Limits 1/permit cycle June 27, 2013
*Beacon Hill Sewer District is not required to submit the Industrial User Survey or the Industrial User
Survey Update reports.
Page 6 of 42
Permit No. WA0037788
SPECIAL CONDITIONS
The term “Permittee” applies to each of the entities named on the cover of this permit, with the following
clarifications:
The Three Rivers Regional Wastewater Treatment Authority (TRRWTP) is the Permittee responsible for
the operation the treatment plant. As such, this Permittee is responsible for operation, maintenance,
monitoring, reporting and all other permit requirements related to the ultimate treatment and discharge of
treated sewage from the Three Rivers Regional Wastewater Treatment Plant (TRRWTP). This
Permittee’s responsibilities also include any permit requirements related to conveyance systems or trunk
lines that are under the authority of the TRRWTP or ownership.
Longview, Kelso, the Beacon Hill Sewer District, and Cowlitz County are the additional Permitted
“Jurisdictions” responsible for operation of the sewage collection, conveyance and storage facilities
within their jurisdictions or under their ownership. As such, these Permittees are responsible for all
operation, maintenance, monitoring, reporting and compliance with all other permit requirements related
to their respective sewage collection, conveyance and storage systems tributary to the TRRWTP.
Included among the applicable requirements for these Permittees are the sections regarding
implementation of the Inflow and Infiltration (I/I) management and pretreatment programs within their
jurisdictions. Where a permit condition related to the sewage collection, conveyance and storage systems
applies to only one of these entities, it will be specified in the appropriate section.
Each of the Permittees shall be held independently responsible for compliance with the permit
requirements applicable to their operations as discussed above.
S1. DISCHARGE LIMITS
A. Effluent Limits
All discharges and activities authorized by this permit shall be consistent with the terms
and conditions of this permit. The discharge of any of the following pollutants more
frequently than, or at a level in excess of, that identified and authorized by this permit
shall constitute a violation of the terms and conditions of this permit.
Beginning on the effective date of this permit and lasting through the expiration date, the
Permittee is authorized to discharge municipal wastewater at the permitted location
subject to complying with the following limitations:
EFFLUENT LIMITSa: OUTFALL #001
Parameter Average Monthly Average Weekly
Carbonaceous Biochemical Oxygen Demand
b (5 day)
25 mg/L, 3978 lbs/day 85% removal of influent
CBOD 40 mg/L, 5867 lbs/day
Total Suspended Solids 30 mg/L, 4815 lbs/day
85% removal of influent TSS
45 mg/L, 7223 lbs/day
Fecal Coliform Bacteria 200 org./100 ml 400 org./100 ml
Total Residual Chlorineb 0.03 mg/L, 7 lbs/day 0.09 mg/L, 20 lbs/day
Page 7 of 42
Permit No. WA0037788
EFFLUENT LIMITSa: OUTFALL #001
Parameter Average Monthly Average Weekly
Total Ammonia (as NH3-N) Operate Facility to Minimize Ammonia
(May through October) 15 mg/L, 3253 lbs/day (Summer)
33.7 mg/L, 7308 lbs/day (Summer)
(November through April) 22.8 mg/L, 4944 lbs/day (Winter)
51.5 mg/L, 11,167 lbs/day (Winter)
pHc
Daily minimum is equal to or greater than 6.0 and the daily maximum is less than or equal to 9.0.
a The average monthly and weekly effluent limitations are based on the arithmetic
mean of the samples taken with the exception of fecal coliform, which is based on the geometric mean.
b This effluent limit applies whenever chlorine is used in the facility. If no chlorine is
used during the monitoring period enter “no discharge of chlorine” on the DMR for the
period.
c Indicates the range of permitted values. The instantaneous maximum and minimum
pH shall be reported monthly. The pH shall not be averaged
B. Mixing Zone Descriptions
The maximum boundaries of the mixing zones are defined as follows:
This reach of the Columbia River is tidally influenced and the dimensions of the
mixing zone boundaries are therefore similar to those of the marine estuary. The
chronic mixing zone boundary is not to exceed 235 feet beyond any diffuser port.
The width of the chronic mixing zone shall not exceed 25 percent of the width of
the Columbia River at the diffuser location. The acute mixing zone boundaries
are ten percent of the chronic mixing zone boundaries or 23.5 feet upstream and
downstream of the outboard diffuser ports and not to exceed 2.5 percent of the
width of the river. The mixing zone extends from the river bottom to the top of
the water surface.
The acute dilution factor is 6.4:1 and the chronic dilution factor is 15.6:1.
S2. MONITORING REQUIREMENTS
A. Monitoring Schedule
The Permittee shall monitor in accordance with the following schedule:
Category Parameter Units Sample
Point
Minimum
Sampling
Frequency
Sample
Type
Wastewater
Influent CBOD5
mg/L
lbs/day Influent 3/week
24-Hour
Composite
Page 8 of 42
Permit No. WA0037788
Category Parameter Units Sample
Point
Minimum
Sampling
Frequency
Sample
Type
Wastewater
Influent TSS
mg/L
lbs/day Influent 3/week
24-Hour
Composite
Wastewater
Influent Flow MGD
Influent
Parshall
Flume
Continuousa Recording
On-line
Wastewater
Effluent
CBOD5
mg/L Effluent 3/week 24-Hour
Composite
Wastewater
Effluent lbs/day Effluent 3/week
24-Hour
Composite
Wastewater
Effluent % removal Effluent 3/week Calculation
Wastewater
Effluent
TSS
mg/L Effluent 3/week 24-Hour
Composite
Wastewater
Effluent lbs/day Effluent 3/week
24-Hour
Composite
Wastewater
Effluent % removal Effluent 3/week Calculation
Wastewater
Effluent pH
Standard
Units Effluent Daily
Grab
Wastewater
Effluent Temperature
f C
Effluent
(End of
Contact
Chamber)
Continuousa Measurem
ent
Wastewater
Effluent
Total Residual
Chlorine
mg/L
lbs/day Effluent Daily Grab
Wastewater
Effluent Fecal Coliform
Org./100
ml Effluent Daily Grab
Wastewater
Effluent
Total
Ammonia
mg/L
lbs/day Effluent 1/week
24-Hour
Composite
Rainfall Inches Daily Measurem
ent
Pretreatment As specified in section S6.
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Permit No. WA0037788
Category Parameter Units Sample
Point
Minimum
Sampling
Frequency
Sample
Type
Receiving
Water and
Effluent
Study
(Temperature,
ammonia, pH,
hardness, &
alkalinity)
mg/L Mixing
zone
boundary
As specified
in project
plan to be
submitted.
See S9.
As
specified
in future
project
plan
Acute
Toxicity
Testing
WET test
As
specified
in S10.
Final
Effluent
Quarterlyb
in year
before
permit
renewal
24-Hour
Composite
Chronic
Toxicity
Testing
WET test
As
specified
in S11.
Final
Effluent
Twicec in
year before
permit
renewal
24-Hour
Composite
Reapplicatio
n Monitoring
Dissolved
Oxygen mg/L Effluent Quarterly
b
24-Hour
Composite
Reapplicatio
n Monitoring
Total Kjeldahl
Nitrogen mg/L N Effluent Quarterly
b
24-Hour
Composite
Reapplicatio
n Monitoring
Nitrate plus
Nitrite N mg/L N Effluent Quarterly
b
24-Hour
Composite
Reapplicatio
n Monitoring Oil and Grease mg/L Effluent Quarterly
b Grab
Reapplicatio
n Monitoring
Phosphorus
(Total) mg/L P Effluent Quarterly
b
24-Hour
Composite
Reapplicatio
n Monitoring
Total
Dissolved
Solids
mg/L Effluent Quarterlyb
24-Hour
Composite
Reapplicatio
n Monitoring BOD5
d mg/L
Influent &
Effluent
1/month in
2016
24-Hour
Composite
Reapplicatio
n Monitoring Total Hardness mg/L Effluent Quarterly
b Grab
Reapplicatio
n Monitoring
EPA Priority
Pollutants -
metals, cyanide
and total
phenols. 1M-
15M
µg/L Influent &
Effluent Quarterly
b
24-Hour
Composite
Page 10 of 42
Permit No. WA0037788
Category Parameter Units Sample
Point
Minimum
Sampling
Frequency
Sample
Type
Reapplicatio
n Monitoring
EPA Priority
Pollutants –
Volatile
Organic
Compounds.
1V – 31V
µg/L Influent &
Effluent 1/year
e
24-Hour
Composite
Reapplicatio
n Monitoring
EPA Priority
Pollutants –
Acid-
extractable
compounds 1A
– 11A
µg/L Influent &
Effluent 1/year
e
24-Hour
Composite
Reapplicatio
n Monitoring
EPA Priority
Pollutants –
Base-neutral
compounds 1B
– 46B
µg/L Influent &
Effluent 1/year
e
24-Hour
Composite
a Continuous means uninterrupted except for brief lengths of time for calibration, for
power failure, or for unanticipated equipment repair or maintenance. Sampling shall be
taken twice daily when continuous monitoring is not possible.
b Quarterly samples for acute WET testing means: April 15, 2016; July 15, 2016;
October 15, 2016; and January 15, 2017. Samples from each event must include testing
on one fish and one invertebrate as described in section S10.
c Twice in one year sampling for chronic WET testing means: July 15, 201 & January 15,
2017. Samples from each event must include testing on one fish and one invertebrate as
described in section S11.
d Monitor BOD5 once per month in the last year before the permit application is due in
2016. Sample each BOD5 at the same time that a CBOD5 is taken.
e Yearly is defined as January through December.
f Temperature shall be reported as a daily maximum, seven-day running average of the
daily maximum, and the monthly maximum of the seven-day running average of the
daily maximum. When continuous recording is not available, temperature must be
monitored twice daily. Once near the late morning and once in the late afternoon.
B. Sampling and Analytical Procedures
Samples and measurements taken to meet the requirements of this permit shall be
representative of the volume and nature of the monitored parameters, including
representative sampling of any unusual discharge or discharge condition, including
bypasses, upsets and maintenance-related conditions affecting effluent quality.
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Permit No. WA0037788
Sampling and analytical methods used to meet the monitoring requirements specified in
this permit shall conform to the latest revision of the Guidelines Establishing Test
Procedures for the Analysis of Pollutants contained in 40 Code of Federal Regulations
(CFR) Part 136.
C. Flow Measurement
Appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of
measurements of the quantity of monitored flows. The devices shall be installed,
calibrated, and maintained to ensure that the accuracy of the measurements are consistent
with the accepted industry standard for that type of device. Frequency of calibration shall
be in conformance with manufacturer's recommendations and at a minimum frequency of
at least one calibration per year. Calibration records shall be maintained for at least three
years.
D. Laboratory Accreditation
All monitoring data required by the Department of Ecology (Ecology) shall be prepared
by a laboratory registered or accredited under the provisions of, Accreditation of
Environmental Laboratories, Chapter 173-50 WAC. Flow, temperature, settleable solids,
conductivity, pH, and internal process control parameters are exempt from this
requirement. Conductivity and pH shall be accredited if the laboratory must otherwise be
registered or accredited. Ecology exempts crops, soils, and hazardous waste data from
this requirement pending accreditation of laboratories for analysis of these media.
S3. REPORTING AND RECORDING REQUIREMENTS
The Permittee must monitor and report in accordance with the following conditions. Falsification
of information submitted to Ecology is a violation of the terms and conditions of this permit.
A. Reporting
The first monitoring period begins on the effective date of the permit. The Permittee
must:
1. Submit monitoring results each month.
2. Summarize, report, and submit monitoring data obtained during each monitoring
period on a Discharge Monitoring Report (DMR) form provided, or otherwise
approved, by Ecology.
3. Submit DMR forms monthly whether or not the facility was discharging. If the
facility did not discharge during a given monitoring period, submit the form as
required with the words "NO DISCHARGE" entered in place of the monitoring
results.
4. Ensure that DMR forms are postmarked or received by Ecology no later than the
15th day of the month following the completed monitoring period, unless
otherwise specified in this permit.
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Permit No. WA0037788
5. Submit priority pollutant analysis data no later than 45 days following the
monitoring.
6. Send report(s) to Ecology at:
Water Quality Permit Coordinator
Department of Ecology
Southwest Regional Office
P.O. Box 47775
Olympia, WA 98504-7775
All laboratory reports providing data for organic and metal parameters must include the
following information: sampling date, sample location, date of analysis, parameter name,
CAS number, analytical method/number, method detection limit (MDL), laboratory
practical quantitation limit (PQL), reporting units, and concentration detected. Analytical
results from samples sent to a contract laboratory must include information on the chain
of custody, the analytical method, QA/QC results, and documentation of accreditation for
the parameter.
B. Records Retention
The Permittee must retain records of all monitoring information for a minimum of three
years. Such information must include all calibration and maintenance records and all
original recordings for continuous monitoring instrumentation, copies of all reports
required by this permit, and records of all data used to complete the application for this
permit. The Permittee must extend this period of retention during the course of any
unresolved litigation regarding the discharge of pollutants by the Permittee or when
requested by Ecology.
C. Recording of Results
For each measurement or sample taken, the Permittee must record the following
information:
1. The date, exact place, method, and time of sampling or measurement.
2. The individual who performed the sampling or measurement.
3. The dates the analyses were performed.
4. The individual who performed the analyses.
5. The analytical techniques or methods used.
6. The results of all analyses.
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Permit No. WA0037788
D. Additional Monitoring by the Permittee
If the Permittee monitors any pollutant more frequently than required by Condition S2 of
this permit, then the Permittee must include the results of such monitoring in the
calculation and reporting of the data submitted in the Permittee's DMR.
E. Reporting Permit Violations
The Permittee must take the following actions when it violates or is unable to comply
with any permit condition:
• Immediately take action to stop, contain, and cleanup unauthorized discharges or
otherwise stop the noncompliance and correct the problem.
• If applicable, immediately repeat sampling and analysis. Submit the results of
any repeat sampling to Ecology within 30 days of sampling.
1. Immediate Reporting
The Permittee must report any failure of the disinfection system immediately to
the Department of Ecology's Regional Office 24-hour number listed below:
Southwest Regional Office 360-407-6300
The Permittee must report any failure of the disinfection system, any collection
system overflows, or any plant bypass discharging to a waterbody used as a
source of drinking water immediately to the Department of Ecology and the
Department of Health, Drinking Water Program at the numbers listed below:
Southwest Regional Office 360-407-6300
Department of Health Drinking Water 360-521-0323
Program (business hours)
360-481-4901
(after business hours)
2. Twenty-Four (24)-Hour Reporting
The Permittee must report the following occurrences of noncompliance by
telephone, to Ecology at 360-407-6300, within 24 hours from the time the
Permittee becomes aware of any of the following circumstances:
a. Any noncompliance that may endanger health or the environment, unless
previously reported under subpart 1, above.
b. Any unanticipated bypass that exceeds any effluent limitation in the
permit (See Part S4.B., “Bypass Procedures”).
c. Any upset that exceeds any effluent limitation in the permit (See G.15,
“Upset”).
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Permit No. WA0037788
d. Any violation of a maximum daily or instantaneous maximum discharge
limitation for any of the pollutants in Section S1.A of this permit.
e. Any overflow prior to the treatment works, whether or not such overflow
endangers health or the environment or exceeds any effluent limitation in
the permit.
3. Report Within Five Days
The Permittee must also provide a written submission within five days of the
time that the Permittee becomes aware of any event required to be reported under
subparts 1 or 2, above. The written submission must contain:
a. A description of the noncompliance and its cause.
b. The period of noncompliance, including exact dates and times.
c. The estimated time noncompliance is expected to continue if it has not
been corrected.
d. Steps taken or planned to reduce, eliminate, and prevent recurrence of
the noncompliance.
e. If the noncompliance involves an overflow prior to the treatment works,
an estimate of the quantity (in gallons) of untreated overflow.
4. Waiver of Written Reports
Ecology may waive the written report required in subpart 3, above, on a
case-by-case basis upon request if a timely oral report has been received.
5. All Other Permit Violation Reporting
The Permittee must report all permit violations, which do not require immediate
or within 24 hours reporting, when it submits monitoring reports for S3.A
("Reporting"). The reports must contain the information listed in paragraph E.3,
above. Compliance with these requirements does not relieve the Permittee from
responsibility to maintain continuous compliance with the terms and conditions
of this permit or the resulting liability for failure to comply.
6. Report Submittal
The Permittee must submit reports to the address listed in S3.
F. Other Reporting
The Permittee must report a spill of oil or hazardous materials in accordance with the
requirements of RCW 90.56.280 and chapter 173-303-145. You can obtain further
Page 15 of 42
Permit No. WA0037788
instructions at the following website:
http://www.ecy.wa.gov/programs/spills/other/reportaspill.htm.
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application, or in any report to
Ecology, it must submit such facts or information promptly.
The Permittee must submit a new application or supplement at least 180 days prior to
commencement of discharges, resulting from the activities listed below, which may result
in permit violations. These activities include: any facility expansions, production
increases, or other planned changes, such as process modifications, in the permitted
facility.
G. Maintaining a Copy of This Permit
The Permittee must keep a copy of this permit at the facility and make it available upon
request to Ecology inspectors.
S4. FACILITY LOADING
A. Design Criteria
Flows or waste loadings of the following design criteria for the permitted treatment
facility shall not be exceeded:
Average flow for the maximum month: 26.0 MGD
BOD5 loading for maximum month: 31,200 lbs/day
TSS loading for maximum month: 32,100 lbs/day
B. Plans for Maintaining Adequate Capacity
The Permittee shall submit to Ecology a plan and a schedule for continuing to maintain
capacity when:
1. The actual flow or waste load reaches 85 percent of any one of the design criteria
in S4.A for three consecutive months; or
2. The projected increase would reach design capacity within five years,
Whichever occurs first. If such a plan is required, it shall contain a plan and schedule for
continuing to maintain capacity. The capacity as outlined in this plan must be sufficient
to achieve the effluent limitations and other conditions of this permit. This plan shall
address any of the following actions or any others necessary to meet the objective of
maintaining capacity.
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Permit No. WA0037788
1. Analysis of the present design including the introduction of any process
modifications that would establish the ability of the existing facility to achieve
the effluent limits and other requirements of this permit at specific levels in
excess of the existing design criteria specified in paragraph A above.
2. Reduction or elimination of excessive infiltration and inflow of uncontaminated
ground and surface water into the sewer system.
3. Limitation on future sewer extensions or connections or additional waste loads.
4. Modification or expansion of facilities necessary to accommodate increased flow
or waste load.
5. Reduction of industrial or commercial flows or waste loads to allow for
increasing sanitary flow or waste load.
Engineering documents associated with the plan must meet the requirements of WAC
173-240-060, "Engineering Report," and be approved by Ecology prior to any
construction. If the Permittee intends to apply for State or Federal funding for the design
or construction of a facility project, the plan must also meet the requirements of a
“Facility Plan” as described in 40 CFR 35.2030. The plan shall specify any contracts,
ordinances, methods for financing, or other arrangements necessary to achieve this
objective.
C. Duty to Mitigate
The Permittee is required to take all reasonable steps to minimize or prevent any
discharge or sludge use or disposal in violation of this permit that has a reasonable
likelihood of adversely affecting human health or the environment
D. Notification of New or Altered Sources
The Permittee shall submit written notice to Ecology whenever any new discharge or a
substantial change in volume or character of an existing discharge into the Publicly
Owned Treatment Works (POTW) is proposed which: (1) would interfere with the
operation of, or exceed the design capacity of, any portion of the POTW; (2) is not part of
an approved general sewer plan or approved plans and specifications; or (3) would be
subject to pretreatment standards under 40 CFR Part 403 and Section 307(b) of the Clean
Water Act. This notice shall include an evaluation of the POTW's ability to adequately
transport and treat the added flow and/or waste load, the quality and volume of effluent to
be discharged to the POTW, and the anticipated impact on the Permittee’s effluent [40
CFR 122.42(b)].
E. Infiltration and Inflow Evaluation
1. The Permittees (the TRRWTP, Longview, Kelso, Beacon Hill Sewer District,
and Cowlitz County) shall each conduct an infiltration and inflow evaluation for
their portion of the collection system. Refer to the U.S. Environmental
Protection Agency (EPA) publication, I/I Analysis and Project Certification,
available as Publication No. 97-03 at: Publications Office, Department of
Page 17 of 42
Permit No. WA0037788
Ecology, P.O. Box 47600, Olympia, Washington 98504-7600. Plant monitoring
records may be used to assess measurable infiltration and inflow.
2. A report shall be prepared which summarizes any measurable infiltration and
inflow. If infiltration and inflow have increased by more than 15 percent from
that found in the first report based on equivalent rainfall, the report shall contain
a plan and a schedule for: (1) locating the sources of infiltration and inflow; and
(2) correcting the problem. The reports shall be submitted by June 15, 2013, and
annually thereafter.
3. Any infiltration or inflow identified in segments of the collection system which
are under or adjacent to surface water (50 feet) shall be further characterized for
the existence of exfiltration.
F. Wasteload Assessment
The Permittee shall conduct an assessment of its flow and waste load and submit a report
to Ecology by June 15, 2013, and annually thereafter. The report shall contain the
following: an indication of compliance or noncompliance with the permit effluent
limitations; a comparison between the existing and design monthly average dry weather
and wet weather flows, peak flows, BOD, and total suspended solids loadings; and the
percentage increase in these parameters since the last annual report. The report shall also
state the present and design population or population equivalent, projected population
growth rate, and the estimated date upon which the design capacity is projected to be
reached, according to the most restrictive of the parameters above. The interval for
review and reporting may be modified if Ecology determines that a different frequency is
sufficient.
S5. OPERATION AND MAINTENANCE
The Permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed to achieve compliance with
the terms and conditions of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the
operation of back-up or auxiliary facilities or similar systems, which are installed by a Permittee
only when the operation is necessary to achieve compliance with the conditions of this permit.
A. Certified Operator
An operator certified for at least a Class IV plant by the state of Washington shall be in
responsible charge of the day-to-day operation of the wastewater treatment plant. An
operator certified for at least a Class III plant shall be in charge during all regularly
scheduled shifts.
B. Operation and Maintenance (O&M) Program
The Permittees (applies to each jurisdiction to the extent they are responsible for its
mechanical components) shall institute an adequate operation and maintenance program
for the sewage system tributary to TRRWTP. Maintenance records shall be maintained
on all major electrical and mechanical components of the treatment plant, as well as the
Page 18 of 42
Permit No. WA0037788
pumping stations and sewage collection system. Such records shall clearly specify the
frequency and type of maintenance recommended by the manufacturer and shall show the
frequency and type of maintenance performed. These maintenance records shall be
available for inspection at all times.
The O&M Manual shall be prepared by the Permittees in accordance with WAC 173-
240-080 to the extent practicable, and be submitted to Ecology for approval. In addition
to requirements of WAC 173-240-080 (1) through (5) the O&M Manual shall include:
1. Emergency procedures for plant shutdown and cleanup in the event of
wastewater system upset or failure.
2. Wastewater system maintenance procedures that contribute to the generation of
process wastewater.
3. Any directions to maintenance staff when cleaning, or maintaining other
equipment or performing other tasks which are necessary to protect the operation
of the wastewater system (e.g., defining maximum allowable discharge rate for
draining a tank, blocking all floor drains before beginning the overhaul of a
stationary engine, etc.).
C. Short-term Reduction
If a Permittee contemplates a reduction in the level of treatment that would cause a
violation of permit discharge limitations on a short-term basis for any reason, and such
reduction cannot be avoided, the Permittee shall give written notification to Ecology, if
possible, 30 days prior to such activities, detailing the reasons for, length of time of, and
the potential effects of the reduced level of treatment. This notification does not relieve
the Permittee of its obligations under this permit.
D. Electrical Power Failure
The Permittees (including all jurisdictions) are responsible for maintaining adequate
safeguards to prevent the discharge of untreated wastes or wastes not treated in
accordance with the requirements of this permit during electrical power failure at the
treatment plant and/or sewage lift stations either by means of alternate power sources,
standby generator, or retention of inadequately treated wastes.
The Permittee (this applies only to the TRRWTP) shall maintain Reliability Class II
(EPA 430/9-74-001) at the wastewater treatment plant, which requires a backup power
source sufficient to operate all vital components and critical lighting and ventilation
during peak wastewater flow conditions, except vital components used to support the
secondary processes (i.e., mechanical aerators or aeration basin air compressors) need not
be operable to full levels of treatment, but shall be sufficient to maintain the biota.
E. Prevent Connection of Inflow
The Permittees (shall strictly enforce their jurisdictional sewer ordinances and not allow
the connection of inflow (roof drains, foundation drains, etc.) to the sanitary sewer
system.
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Permit No. WA0037788
F. Bypass Procedures
Bypass, which is the intentional diversion of waste streams from any portion of a
treatment facility, is prohibited, and Ecology may take enforcement action against a
Permittee for bypass unless one of the following circumstances (1, 2, or 3) is applicable.
1. Bypass for essential maintenance without the potential to cause violation of
permit limits or conditions.
Bypass is authorized if it is for essential maintenance and does not have the
potential to cause violations of limitations or other conditions of this permit, or
adversely impact public health as determined by Ecology prior to the bypass.
The Permittee shall submit prior notice, if possible at least ten (10) days before
the date of the bypass.
2. Bypass which is unavoidable, unanticipated and results in noncompliance of this
permit.
This bypass is permitted only if:
a. Bypass is unavoidable to prevent loss of life, personal injury, or severe
property damage. “Severe property damage” means substantial physical
damage to property, damage to the treatment facilities which would
cause them to become inoperable, or substantial and permanent loss of
natural resources which can reasonably be expected to occur in the
absence of a bypass.
b. There are no feasible alternatives to the bypass, such as the use of
auxiliary treatment facilities, retention of untreated wastes, stopping
production, maintenance during normal periods of equipment downtime
(but not if adequate backup equipment should have been installed in the
exercise of reasonable engineering judgment to prevent a bypass which
occurred during normal periods of equipment downtime or preventative
maintenance), or transport of untreated wastes to another treatment
facility.
c. Ecology is properly notified of the bypass as required in condition S3E
of this permit.
3. Bypass which is anticipated and has the potential to result in noncompliance of
this permit
The Permittee shall notify Ecology at least 30 days before the planned date of
bypass. The notice shall contain: (1) a description of the bypass and its cause;
(2) an analysis of all known alternatives which would eliminate, reduce, or
mitigate the need for bypassing; (3) a cost-effectiveness analysis of alternatives
including comparative resource damage assessment; (4) the minimum and
maximum duration of bypass under each alternative; (5) a recommendation as to
the preferred alternative for conducting the bypass; (6) the projected date of
bypass initiation; (7) a statement of compliance with SEPA; (8) a request for
modification of water quality standards as provided for in WAC 173-201A-110,
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Permit No. WA0037788
if an exceedance of any water quality standard is anticipated; and (9) steps taken
or planned to reduce, eliminate, and prevent reoccurrence of the bypass.
For probable construction bypasses, the need to bypass is to be identified as early
in the planning process as possible. The analysis required above shall be
considered during preparation of the engineering report or facilities plan and
plans and specifications and shall be included to the extent practical. In cases
where the probable need to bypass is determined early, continued analysis is
necessary up to and including the construction period in an effort to minimize or
eliminate the bypass.
Ecology will consider the following prior to issuing an administrative order for
this type bypass:
a. If the bypass is necessary to perform construction or maintenance-related
activities essential to meet the requirements of this permit.
b. If there are feasible alternatives to bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, stopping production,
maintenance during normal periods of equipment down time, or transport
of untreated wastes to another treatment facility.
c. If the bypass is planned and scheduled to minimize adverse effects on the
public and the environment.
After consideration of the above and the adverse effects of the proposed bypass
and any other relevant factors, Ecology will approve or deny the request. The
public shall be notified and given an opportunity to comment on bypass incidents
of significant duration, to the extent feasible. Approval of a request to bypass
will be by administrative order issued by Ecology under Revised Code of
Washington (RCW) 90.48.120.
G. Operations and Maintenance Manual
The approved O&M Manual shall be kept available at the treatment plant and all
operators shall follow the instructions and procedures of this manual.
The O&M Manual shall be reviewed by the Permittee at least annually and the Permittee
shall confirm this review by letter and submit it to Ecology by June 15, 2013, and
annually thereafter. Substantial changes or updates to the O&M Manual shall be
submitted to Ecology for review and approval whenever they are incorporated into the
manual.
S6. PRETREATMENT
The following subsections A through C applies only to the contributing jurisdictions of
Longview, Kelso, Beacon Hill, and Cowlitz County:
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Permit No. WA0037788
A. General Requirements
The Permittees (the jurisdictions) shall work with Ecology to ensure that all commercial
and industrial users of the POTW are in compliance with the pretreatment regulations
promulgated in 40 CFR Part 403 and any additional regulations that may be
promulgated under Section 307(b) (pretreatment) and 308 (reporting) of the Federal
Clean Water Act.
B. Wastewater Discharge Permit Required
The Permittees (the jurisdictions) shall not allow significant industrial users (SIUs) to
discharge wastewater to the Permittee's sewerage system until such user has received a
wastewater discharge permit from Ecology in accordance with Chapter 90.48 RCW and
Chapter 173-216 WAC, as amended.
C. Identification and Reporting of Existing, New, and Proposed Industrial Users
1. The Permittees (the jurisdictions) shall take continuous, routine measures to
identify all existing, new, and proposed SIUs and potential significant industrial
users (PSIUs) discharging or proposing to discharge to the Permittee's sewerage
system (see Appendix B of Fact Sheet for definitions).
2. Within 30 days of becoming aware of an unpermitted existing, new, or proposed
industrial user who may be an SIU, the Permittee shall notify such user by
registered mail that, if classified as an SIU, they shall be required to apply to
Ecology and obtain a State Waste Discharge Permit. A copy of this notification
letter shall also be sent to Ecology within this same 30-day period.
3. The Permittees (the jurisdictions) shall also notify all PSIUs, as they are
identified, that if their classification should change to an SIU, they shall be
required to apply to Ecology for a State Waste Discharge Permit within 30 days
of such change.
D. Industrial User Survey (applies to the individual jurisdictions of Longview, Kelso, and
Cowlitz County):
The Permittees (the jurisdictions) shall annually update this survey based on
information gained over the prior calendar year from ongoing review processes (e.g. plan
reviews, review of water billing records, business license and permit applications,
physical reconnaissance, etc.) and summarize the results of survey forms which it shall
require of industries and commercial operations discharging nondomestic wastewater that
started business or significantly changed processes during the previous calendar year.
The update shall show the deletions and additions to the prior year's list and shall include
completed survey forms for all unpermitted industries which the Permittee considers a
"Categorical Industrial User" or "Significant Industrial User." The update shall be
submitted to Ecology by November 15, 2012, and annually thereafter.
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Permit No. WA0037788
E. Establishment of Local Limits (applies to each jurisdiction)
Each jurisdiction shall codify a pretreatment ordinance by June 27, 2013. The
ordinance shall reinforce pretreatment standards and requirements including: prohibited
discharge standards, requirements to obtain a permit, the recommended local limits, and
requirements to complete periodic surveys. The Ordinance shall also provide remedies
for non-compliance with these provisions. The Cowlitz County ordinance shall be
written to be applicable to all sources of wastewater tributary to the Three Rivers
Regional Wastewater Plant outside of Longview and Kelso. The Beacon Hill Sewer
District shall comply to the extent the authorities granted to sewer districts in these
regards allows. Upon request, Ecology will provide a format for a pretreatment
ordinance into which local limits may be inserted.
F. Duty to Enforce Discharge Prohibitions (applies to all Permittees)
1. In accordance with 40 CFR 403.5(a), the Permittee shall not authorize or
knowingly allow the discharge of any pollutants into its POTW which cause pass
through or interference, or which otherwise violates general or specific discharge
prohibitions contained in 40 CFR Part 403.5 or WAC-173-216-060.
2. The Permittee shall not authorize or knowingly allow the introduction of any of
the following into their treatment works:
a. Pollutants which create a fire or explosion hazard in the POTW
(including, but not limited to waste streams with a closed cup flashpoint
of less than 140 degrees Fahrenheit or 60 degrees Centigrade using the
test methods specified in 40 CFR 261.21).
b. Pollutants which will cause corrosive structural damage to the POTW,
but in no case discharges with pH lower than 5.0, or greater than 11.0
standard units, unless the works are specifically designed to
accommodate such discharges.
c. Solid or viscous pollutants in amounts that could cause obstruction to the
flow in sewers or otherwise interfere with the operation of the POTW.
d. Any pollutant, including oxygen demanding pollutants, (BOD, etc.)
released in a discharge at a flow rate and/or pollutant concentration
which will cause interference with the POTW.
e. Petroleum oil, nonbiodegradable cutting oil, or products of mineral
origin in amounts that will cause interference or pass through.
f. Pollutants which result in the presence of toxic gases, vapors, or fumes
within the POTW in a quantity which may cause acute worker health and
safety problems.
g. Heat in amounts that will inhibit biological activity in the POTW
resulting in interference but in no case heat in such quantities such that
the temperature at the POTW headworks exceeds 40ºC (104ºF) unless
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Permit No. WA0037788
Ecology, upon request of the Permittee, approves, in writing, alternate
temperature limits.
h. Any trucked or hauled pollutants, except at discharge points designated
by the Permittee.
i. Wastewaters prohibited to be discharged to the POTW by the Dangerous
Waste Regulations (Chapter 173-303 WAC), unless authorized under the
Domestic Sewage Exclusion (WAC 173-303-071).
3. All of the following are prohibited from discharge to the POTW unless approved
in writing by Ecology under extraordinary circumstances (such as a lack of direct
discharge alternatives due to combined sewer service or the need to augment
sewage flows due to septic conditions):
a. Noncontact cooling water in significant volumes.
b. Stormwater, and other direct inflow sources.
c. Wastewaters significantly affecting system hydraulic loading, which do
not require treatment, or would not be afforded a significant degree of
treatment by the system.
4. The Permittee (all Permittees) shall notify Ecology if any industrial user violates
the prohibitions listed in this section.
S7. RESIDUAL SOLIDS
Residual solids include screenings, grit, scum, primary sludge, waste activated sludge, and other
solid waste. The Permittee shall store and handle all residual solids in such a manner so as to
prevent their entry into state ground or surface waters. The Permittee shall not discharge leachate
from residual solids to state surface or ground waters. The Permittee shall submit a residual
solids management plan to Ecology by April 15, 2016.
S8. APPLICATION FOR PERMIT RENEWAL
The Permittee shall submit an application for renewal of this permit by April 1, 2017.
S9. RECEIVING WATER AND EFFLUENT STUDY
The Permittee shall collect additional receiving water data as recommended in the Ambient Water
Quality Conditions Study submitted to Ecology (Cosmopolitan Engineering Group, April 2011).
A Draft Scope of Work, Quality Assurance Project Plan (Ecology Publication 91-16 for QA/QC
guidance), and Field Sampling Plan shall be submitted to Ecology prior to and be approvable by
September 15, 2013. A new Draft follow up Water Quality Report (Report) containing the Field
Sampling Data and Data Analysis shall be submitted to Ecology prior to and be approvable by
September 15, 2015. The Report shall contain the following items:
Effluent and ambient data analysis
Acute and chronic dilution factors based on existing mixing zone study
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Permit No. WA0037788
Wasteload allocations and long-term averages for acute and chronic conditions
Reasonable potential assessment for ammonia compliance
Potential seasonal alternatives for effluent limitations
Recommendations for effluent limitations for ammonia-nitrogen
The Permittee will submit Final Scope of Work, Quality Assurance Project Plan, and Field
Sampling Plan by December 31, 2013; and Final Water Quality Report by December 31, 2015.
S10. ACUTE TOXICITY
A. Testing Requirements
The Permittee shall test final effluent once in the last summer by September 15, 2016,
and once in the last winter by March 15, 2017. Results are to be submitted within 30
days of the completion dates and again with the permit renewal application by
April 1, 2017. The two species listed below shall be used on each sample and the results
submitted to Ecology as a part of the permit renewal application process. The Permittee
shall conduct acute toxicity testing on a series of five concentrations of effluent and a
control in order to be able to determine appropriate point estimates and an NOEC. The
percent survival in 100 percent effluent shall also be reported.
Acute toxicity tests shall be conducted with the following species and protocols:
1. Fathead minnow, Pimephales promelas (96-hour static-renewal test, method:
EPA-821-R-02-012).
2. Daphnid, Ceriodaphnia dubia, Daphnia pulex, or Daphnia magna (48-hour static
test, method: EPA-821-R-02-012). The Permittee shall choose one of the three
species and use it consistently throughout effluent characterization.
B. Sampling and Reporting Requirements
1. All reports for effluent characterization or compliance monitoring shall be
submitted in accordance with the most recent version of Department of Ecology
Publication # WQ-R-95-80, Laboratory Guidance and Whole Effluent Toxicity
Test Review Criteria in regards to format and content. Reports shall contain
bench sheets and reference toxicant results for test methods. If the lab provides
the toxicity test data on floppy disk for electronic entry into Ecology’s database,
then the Permittee shall send the disk to Ecology along with the test report, bench
sheets, and reference toxicant results.
2. Testing shall be conducted on 24-hour composite effluent samples. Samples
taken for toxicity testing shall be cooled to 0 - 6 degrees Celsius while being
collected and shall be sent to the lab immediately upon completion. The lab shall
begin the toxicity testing as soon as possible but no later than 36 hours after
sampling was ended.
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Permit No. WA0037788
3. All samples and test solutions for toxicity testing shall have water quality
measurements as specified in Ecology Publication # WQ-R-95-80, Laboratory
Guidance and Whole Effluent Toxicity Test Review Criteria or most recent
version thereof.
4. All toxicity tests shall meet quality assurance criteria and test conditions in the
most recent versions of the EPA manual listed in subsection A and Ecology
Publication # WQ-R-95-80, Laboratory Guidance and Whole Effluent Toxicity
Test Review Criteria. If test results are determined to be invalid or anomalous by
Ecology, testing shall be repeated with freshly collected effluent.
5. Control water and dilution water shall be laboratory water meeting the
requirements of the EPA manual listed in subsection A or pristine natural water
of sufficient quality for good control performance.
6. The whole effluent toxicity tests shall be run on an unmodified sample of final
effluent.
7. The Permittee may choose to conduct a full dilution series test during compliance
monitoring in order to determine dose response. In this case, the series must
have a minimum of five (5) effluent concentrations and a control. The series of
concentrations must include the ACEC.
S11. CHRONIC TOXICITY
A. Testing Requirements
The Permittee shall test final effluent once in the last summer by September 15, 2016,
and once in the last winter by March 15, 2017. Results are to be submitted within 30
days of the completion dates and again with the permit renewal application by
April 1, 2017. All of the chronic toxicity tests listed below shall be conducted on each
sample. The results of this chronic toxicity testing shall be submitted to Ecology as a part
of the permit renewal application process.
The Permittee shall conduct chronic toxicity testing on a series of at least five
concentrations of effluent and a control in order to be able to determine appropriate point
estimates and an NOEC. This series of dilutions shall include the acute critical effluent
concentration (ACEC). The ACEC equals 15.6 percent effluent. The Permittee shall
compare the ACEC to the control using hypothesis testing at the 0.05 level of
significance as described in Appendix H, EPA/600/4-89/001.
Chronic toxicity tests shall be conducted with the following species and the most recent
version of the following protocols:
Freshwater Chronic Test Species Method
Fathead minnow Pimephales promelas EPA-821-R-02-013
Water flea Ceriodaphnia dubia EPA-821-R-02-013
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Permit No. WA0037788
B. Sampling and Reporting Requirements
1. All reports for effluent characterization or compliance monitoring shall be
submitted in accordance with the most recent version of Ecology Publication #
WQ-R-95-80, Laboratory Guidance and Whole Effluent Toxicity Test Review
Criteria in regards to format and content. Reports shall contain bench sheets and
reference toxicant results for test methods. If the lab provides the toxicity test
data on floppy disk for electronic entry into Ecology’s database, then the
Permittee shall send the disk to Ecology along with the test report, bench sheets,
and reference toxicant results.
2. Testing shall be conducted on 24-hour composite effluent samples. Samples
taken for toxicity testing shall be cooled to 0 - 6 degrees Celsius while being
collected and shall be sent to the lab immediately upon completion. The lab shall
begin the toxicity testing as soon as possible but no later than 36 hours after
sampling was ended.
3. All samples and test solutions for toxicity testing shall have water quality
measurements as specified in Ecology Publication # WQ-R-95-80, Laboratory
Guidance and Whole Effluent Toxicity Test Review Criteria or most recent
version thereof.
4. All toxicity tests shall meet quality assurance criteria and test conditions in the
most recent versions of the EPA manual listed in subsection A and Ecology
Publication # WQ-R-95-80, Laboratory Guidance and Whole Effluent Toxicity
Test Review Criteria. If test results are determined to be invalid or anomalous by
Ecology, testing shall be repeated with freshly collected effluent.
5. Control water and dilution water shall be laboratory water meeting the
requirements of the EPA manual listed in subsection A or pristine natural water
of sufficient quality for good control performance.
S12. OUTFALL EVALUATION
The Permittee shall inspect the submerged portion of the outfall line and diffuser to document its
integrity and continued function. If conditions allow for a photographic verification, it shall be
included in the report. By November 15, 2016, the inspection report shall be submitted to
Ecology.
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Permit No. WA0037788
GENERAL CONDITIONS
G1. SIGNATORY REQUIREMENTS
All applications, reports, or information submitted to Ecology shall be signed and certified.
A. All permit applications shall be signed by either a principal executive officer or a ranking
elected official.
B. All reports required by this permit and other information requested by Ecology shall be
signed by a person described above or by a duly authorized representative of that person.
A person is a duly authorized representative only if:
1. The authorization is made in writing by a person described above and submitted
to Ecology.
2. The authorization specifies either an individual or a position having
responsibility for the overall operation of the regulated facility, such as the
position of plant manager, superintendent, position of equivalent responsibility,
or an individual or position having overall responsibility for environmental
matters. (A duly authorized representative may thus be either a named individual
or any individual occupying a named position.)
C. Changes to authorization. If an authorization under paragraph B.2 above is no longer
accurate because a different individual or position has responsibility for the overall
operation of the facility, a new authorization satisfying the requirements of paragraph B.2
above must be submitted to Ecology prior to or together with any reports, information, or
applications to be signed by an authorized representative.
D. Certification. Any person signing a document under this section shall make the following
certification:
I certify under penalty of law, that this document and all
attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified
personnel properly gathered and evaluated the information
submitted. Based on my inquiry of the person or persons who
manage the system or those persons directly responsible for
gathering information, the information submitted is, to the best
of my knowledge and belief, true, accurate, and complete. I am
aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment
for knowing violations.
G2. RIGHT OF INSPECTION AND ENTRY
The Permittee shall allow an authorized representative of Ecology, upon the presentation of
credentials and such other documents as may be required by law:
A. To enter upon the premises where a discharge is located or where any records must be
kept under the terms and conditions of this permit.
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Permit No. WA0037788
B. To have access to and copy - at reasonable times and at reasonable cost - any records
required to be kept under the terms and conditions of this permit.
C. To inspect - at reasonable times - any facilities, equipment (including monitoring and
control equipment), practices, methods, or operations regulated or required under this
permit.
D. To sample or monitor - at reasonable times - any substances or parameters at any location
for purposes of assuring permit compliance or as otherwise authorized by the Clean
Water Act.
G3. PERMIT ACTIONS
This permit may be modified, revoked and reissued, or terminated either at the request of any
interested person (including the Permittee) or upon Ecology’s initiative. However, the permit
may only be modified, revoked and reissued, or terminated for the reasons specified in 40 CFR
122.62, 122.64 or WAC 173-220-150 according to the procedures of 40 CFR 124.5.
A. The following are causes for terminating this permit during its term, or for denying a
permit renewal application:
1. Violation of any permit term or condition.
2. Obtaining a permit by misrepresentation or failure to disclose all relevant facts.
3. A material change in quantity or type of waste disposal.
4. A determination that the permitted activity endangers human health or the
environment, or contributes to water quality standards violations and can only be
regulated to acceptable levels by permit modification or termination [40 CFR
Part 122.64(3)].
5. A change in any condition that requires either a temporary or permanent
reduction, or elimination of any discharge or sludge use or disposal practice
controlled by the permit [40 CFR Part 122.64(4)].
6. Nonpayment of fees assessed pursuant to RCW 90.48.465.
7. Failure or refusal of the Permittee to allow entry as required in RCW 90.48.090.
B. The following are causes for modification but not revocation and reissuance except when
the Permittee requests or agrees:
1. A material change in the condition of the waters of the state.
2. New information not available at the time of permit issuance that would have
justified the application of different permit conditions.
3. Material and substantial alterations or additions to the permitted facility or
activities which occurred after this permit issuance.
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Permit No. WA0037788
4. Promulgation of new or amended standards or regulations having a direct bearing
upon permit conditions, or requiring permit revision.
5. The Permittee has requested a modification based on other rationale meeting the
criteria of 40 CFR Part 122.62.
6. Ecology has determined that good cause exists for modification of a compliance
schedule, and the modification will not violate statutory deadlines.
7. Incorporation of an approved local pretreatment program into a municipality’s
permit.
C. The following are causes for modification or alternatively revocation and reissuance:
1. Cause exists for termination for reasons listed in A1 through A7 of this section,
and Ecology determines that modification or revocation and reissuance is
appropriate.
2. Ecology has received notification of a proposed transfer of the permit. A permit
may also be modified to reflect a transfer after the effective date of an automatic
transfer (General Condition G8) but will not be revoked and reissued after the
effective date of the transfer except upon the request of the new Permittee.
G4. REPORTING PLANNED CHANGES
The Permittee shall, as soon as possible, but no later than 60 days prior to the proposed changes,
give notice to Ecology of planned physical alterations or additions to the permitted facility,
production increases, or process modification which will result in: 1) the permitted facility being
determined to be a new source pursuant to 40 CFR 122.29(b); 2) a significant change in the
nature or an increase in quantity of pollutants discharged; or 3) a significant change in the
Permittee’s sludge use or disposal practices. Following such notice, and the submittal of a new
application or supplement to the existing application, along with required engineering plans and
reports, this permit may be modified, or revoked and reissued pursuant to 40 CFR 122.62(a) to
specify and limit any pollutants not previously limited. Until such modification is effective, any
new or increased discharge in excess of permit limits or not specifically authorized by this permit
constitutes a violation of the terms and conditions of this permit.
G5. PLAN REVIEW REQUIRED
Prior to constructing or modifying any wastewater control facilities, an engineering report and
detailed plans and specifications shall be submitted to Ecology for approval in accordance with
Chapter 173-240 WAC. Engineering reports, plans, and specifications shall be submitted at least
180 days prior to the planned start of construction unless a shorter time is approved by Ecology.
Facilities shall be constructed and operated in accordance with the approved plans.
G6. COMPLIANCE WITH OTHER LAWS AND STATUTES
Nothing in this permit shall be construed as excusing the Permittee from compliance with any
applicable federal, state, or local statutes, ordinances, or regulations.
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Permit No. WA0037788
G7. TRANSFER OF THIS PERMIT
In the event of any change in control or ownership of facilities from which the authorized
discharge emanate, the Permittee shall notify the succeeding owner or controller of the existence
of this permit by letter, a copy of which shall be forwarded to Ecology.
A. Transfers by Modification
Except as provided in paragraph (B) below, this permit may be transferred by the
Permittee to a new owner or operator only if this permit has been modified or revoked
and reissued under 40 CFR 122.62(b)(2), or a minor modification made under 40 CFR
122.63(d), to identify the new Permittee and incorporate such other requirements as may
be necessary under the Clean Water Act.
B. Automatic Transfers
This permit may be automatically transferred to a new Permittee if:
1. The Permittee notifies Ecology at least 30 days in advance of the proposed
transfer date.
2. The notice includes a written agreement between the existing and new Permittees
containing a specific date transfer of permit responsibility, coverage, and liability
between them.
3. Ecology does not notify the existing Permittee and the proposed new Permittee of
its intent to modify or revoke and reissue this permit. A modification under this
subparagraph may also be minor modification under 40 CFR 122.63. If this
notice is not received, the transfer is effective on the date specified in the written
agreement.
G8. REDUCED PRODUCTION FOR COMPLIANCE
The Permittee, in order to maintain compliance with its permit, shall control production and/or all
discharges upon reduction, loss, failure, or bypass of the treatment facility until the facility is
restored or an alternative method of treatment is provided. This requirement applies in the
situation where, among other things, the primary source of power of the treatment facility is
reduced, lost, or fails.
G9. REMOVED SUBSTANCES
Collected screenings, grit, solids, sludges, filter backwash, or other pollutants removed in the
course of treatment or control of wastewaters shall not be resuspended or reintroduced to the final
effluent stream for discharge to state waters.
G10. DUTY TO PROVIDE INFORMATION
The Permittee shall submit to Ecology, within a reasonable time, all information which Ecology
may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also
submit to Ecology upon request, copies of records required to be kept by this permit.
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Permit No. WA0037788
G11. OTHER REQUIREMENTS OF 40 CFR
All other requirements of 40 CFR 122.41 and 122.42 are incorporated in this permit by reference.
G12. ADDITIONAL MONITORING
Ecology may establish specific monitoring requirements in addition to those contained in this
permit by administrative order or permit modification.
G13. PAYMENT OF FEES
The Permittee shall submit payment of fees associated with this permit as assessed by Ecology.
G14. PENALTIES FOR VIOLATING PERMIT CONDITIONS
Any person who is found guilty of willfully violating the terms and conditions of this permit shall
be deemed guilty of a crime, and upon conviction thereof shall be punished by a fine of up to
$10,000 and costs of prosecution, or by imprisonment in the discretion of the court. Each day
upon which a willful violation occurs may be deemed a separate and additional violation.
Any person who violates the terms and conditions of a waste discharge permit shall incur, in
addition to any other penalty as provided by law, a civil penalty in the amount of up to $10,000
for every such violation. Each and every such violation shall be a separate and distinct offense,
and in case of a continuing violation, every day's continuance shall be deemed to be a separate
and distinct violation.
G15. UPSET
Definition – “Upset” means an exceptional incident in which there is unintentional and temporary
noncompliance with technology-based permit effluent limitations because of factors beyond the
reasonable control of the Permittee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed treatment facilities, inadequate treatment
facilities, lack of preventive maintenance, or careless or improper operation.
An upset constitutes an affirmative defense to an action brought for noncompliance with such
technology-based permit effluent limitations if the requirements of the following paragraph are
met.
A Permittee who wishes to establish the affirmative defense of upset shall demonstrate, through
properly signed, contemporaneous operating logs, or other relevant evidence that: 1) an upset
occurred and that the Permittee can identify the cause(s) of the upset; 2) the permitted facility was
being properly operated at the time of the upset; 3) the Permittee submitted notice of the upset as
required in condition S3.E; and 4) the Permittee complied with any remedial measures required
under S4.C of this permit.
In any enforcement preceding the Permittee seeking to establish the occurrence of an upset has
the burden of proof.
G16. PROPERTY RIGHTS
This permit does not convey any property rights of any sort, or any exclusive privilege.
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Permit No. WA0037788
G17. DUTY TO COMPLY
The Permittee shall comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit renewal application.
G18. TOXIC POLLUTANTS
The Permittee shall comply with effluent standards or prohibitions established under Section
307(a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that
establish those standards or prohibitions, even if this permit has not yet been modified to
incorporate the requirement.
G19. PENALTIES FOR TAMPERING
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders
inaccurate any monitoring device or method required to be maintained under this permit shall,
upon conviction, be punished by a fine of not more than $10,000 per violation, or by
imprisonment for not more than two years per violation, or by both. If a conviction of a person is
for a violation committed after a first conviction of such person under this Condition, punishment
shall be a fine of not more than $20,000 per day of violation, or by imprisonment of not more
than four years, or by both.
G20. REPORTING ANTICIPATED NON-COMPLIANCE
The Permittee shall give advance notice to Ecology by submission of a new application or
supplement thereto at least 180 days prior to commencement of such discharges, of any facility
expansions, production increases, or other planned changes, such as process modifications, in the
permitted facility or activity which may result in noncompliance with permit limits or conditions.
Any maintenance of facilities, which might necessitate unavoidable interruption of operation and
degradation of effluent quality, shall be scheduled during noncritical water quality periods and
carried out in a manner approved by Ecology.
G21. REPORTING OTHER INFORMATION
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application, or in any report to
Ecology, it shall promptly submit such facts or information.
G22. COMPLIANCE SCHEDULES
Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be submitted no later than 14 days following each schedule date.
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Permit No. WA0037788
APPENDIX A
LIST OF POLLUTANTS WITH ANALYTICAL METHODS, DETECTION LIMITS AND
QUANTITATION LEVELS
The Permittee must use the specified analytical methods, detection limits (DLs) and quantitation levels
(QLs) in the following table for permit and application required monitoring unless:
Another permit condition specifies other methods, detection levels, or quantitation levels.
The method used produces measurable results in the sample and EPA has listed it as an EPA-
approved method in 40 CFR Part 136.
If the Permittee uses an alternative method, not specified in the permit and as allowed above, it must
report the test method, DL, and QL on the discharge monitoring report or in the required report.
When the permit requires the Permittee to measure the base neutral compounds in the list of priority
pollutants, it must measure all of the base neutral pollutants listed in the table below. The list includes
EPA required base neutral priority pollutants and several additional polynuclear aromatic hydrocarbons
(PAHs). The Water Quality Program added several PAHs to the list of base neutrals below from
Ecology’s Persistent Bioaccumulative Toxics (PBT) List. It only added those PBT parameters of interest
to Appendix A that did not increase the overall cost of analysis unreasonably.
Ecology added this appendix to the permit in order to reduce the number of analytical “non-detects” in
permit-required monitoring and to measure effluent concentrations near or below criteria values where
possible at a reasonable cost.
CONVENTIONAL PARAMETERS
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
Biochemical Oxygen Demand SM5210-B 2 mg/L
Chemical Oxygen Demand SM5220-D 10 mg/L
Total Organic Carbon SM5310-B/C/D 1 mg/L
Total Suspended Solids SM2540-D 5 mg/L
Total Ammonia (as N) SM4500-NH3-
GH 0.3 mg/L
Flow Calibrated device
Dissolved oxygen SM4500-OC/OG 0.2 mg/L
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Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
Temperature (max. 7-day avg.)
Analog recorder
or Use micro-
recording devices
known as
thermistors
0.2º C
pH SM4500-H+
B N/A N/A
NONCONVENTIONAL PARAMETERS
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
Total Alkalinity SM2320-B 5 mg/L as
CaCO3
Chlorine, Total Residual SM4500 Cl G 50.0
Color SM2120 B/C/E 10 color units
Fecal Coliform SM
9221D/E,9222 N/A N/A
Fluoride (16984-48-8) SM4500-F E 25 100
Nitrate-Nitrite (as N) SM4500-NO3-
E/F/H 100
Nitrogen, Total Kjeldahl (as N) SM4500-NH3-
C/E/FG 300
Ortho-Phosphate (PO4 as P) SM4500- PE/PF 3 10
Phosphorus, Total (as P) SM4500-PE/PF 3 10
Oil and Grease (HEM) 1664A 1,400 5,000
Salinity SM2520-B 3 PSS
Settleable Solids SM2540 -F 100
Sulfate (as mg/L SO4) SM4110-B 200
Sulfide (as mg/L S) SM4500-
S2F/D/E/G
200
Sulfite (as mg/L SO3) SM4500-SO3B 2000
Total Coliform SM 9221B, N/A N/A
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Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
9222B, 9223B
Total dissolved solids SM2540 C 20 mg/L
Total Hardness SM2340B 200 as CaCO3
Aluminum, Total (7429-90-5) 200.8 2.0 10
Barium Total (7440-39-3) 200.8 0.5 2.0
BTEX (benzene +toluene +
ethylbenzene + m,o,p xylenes)
EPA SW 846
8021/8260 1 2
Boron Total (7440-42-8) 200.8 2.0 10.0
Cobalt, Total (7440-48-4) 200.8 0.05 0.25
Iron, Total (7439-89-6) 200.7 12.5 50
Magnesium, Total (7439-95-4) 200.7 10 50
Molybdenum, Total (7439-98-
7) 200.8 0.1 0.5
Manganese, Total (7439-96-5) 200.8 0.1 0.5
NWTPH Dx Ecology NWTPH
Dx 250 250
NWTPH Gx Ecology NWTPH
Gx 250 250
Tin, Total (7440-31-5) 200.8 0.3 1.5
Titanium, Total (7440-32-6) 200.8 0.5 2.5
PRIORITY POLLUTANTS
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
METALS, CYANIDE & TOTAL PHENOLS
Antimony, Total (7440-36-0) 200.8 0.3 1.0
Arsenic, Total (7440-38-2) 200.8 0.1 0.5
Beryllium, Total (7440-41-7) 200.8 0.1 0.5
Cadmium, Total (7440-43-9) 200.8 0.05 0.25
Chromium (hex) dissolved SM3500-Cr EC 0.3 1.2
Page 36 of 42
Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
METALS, CYANIDE & TOTAL PHENOLS
(18540-29-9)
Chromium, Total (7440-47-3) 200.8 0.2 1.0
Copper, Total (7440-50-8) 200.8 0.4 2.0
Lead, Total (7439-92-1) 200.8 0.1 0.5
Mercury, Total (7439-97-6) 1631E 0.0002 0.0005
Nickel, Total (7440-02-0) 200.8 0.1 0.5
Selenium, Total (7782-49-2) 200.8 1.0 1.0
Silver, Total (7440-22-4) 200.8 0.04 0.2
Thallium, Total (7440-28-0) 200.8 0.09 0.36
Zinc, Total (7440-66-6) 200.8 0.5 2.5
Cyanide, Total (57-12-5) 335.4 5 10
Cyanide, Weak Acid
Dissociable SM4500-CN I 5 10
Phenols, Total EPA 420.1 50
ACID COMPOUNDS
2-Chlorophenol (95-57-8) 625 1.0 2.0
2,4-Dichlorophenol (120-83-2) 625 0.5 1.0
2,4-Dimethylphenol (105-67-9) 625 0.5 1.0
4,6-dinitro-o-cresol (534-52-1)
(2-methyl-4,6,-dinitrophenol) 625/1625B 1.0 2.0
2,4 dinitrophenol (51-28-5) 625 1.0 2.0
2-Nitrophenol (88-75-5) 625 0.5 1.0
4-nitrophenol (100-02-7) 625 0.5 1.0
Parachlorometa cresol (59-50-
7) (4-chloro-3-methylphenol) 625 1.0 2.0
Pentachlorophenol (87-86-5) 625 0.5 1.0
Phenol (108-95-2) 625 2.0 4.0
2,4,6-Trichlorophenol (88-06-2) 625 2.0 4.0
Page 37 of 42
Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
VOLATILE COMPOUNDS
Acrolein (107-02-8) 624 5 10
Acrylonitrile (107-13-1) 624 1.0 2.0
Benzene (71-43-2) 624 1.0 2.0
Bromoform (75-25-2) 624 1.0 2.0
Carbon tetrachloride (56-23-5) 624/601 or
SM6230B 1.0 2.0
Chlorobenzene (108-90-7) 624 1.0 2.0
Chloroethane (75-00-3) 624/601 1.0 2.0
2-Chloroethylvinyl Ether
(110-75-8) 624 1.0 2.0
Chloroform (67-66-3) 624 or SM6210B 1.0 2.0
Dibromochloromethane
(124-48-1) 624 1.0 2.0
1,2-Dichlorobenzene (95-50-1) 624 1.9 7.6
1,3-Dichlorobenzene (541-73-
1) 624 1.9 7.6
1,4-Dichlorobenzene (106-46-
7) 624 4.4 17.6
Dichlorobromomethane (75-27-
4) 624 1.0 2.0
1,1-Dichloroethane (75-34-3) 624 1.0 2.0
1,2-Dichloroethane (107-06-2) 624 1.0 2.0
1,1-Dichloroethylene (75-35-4) 624 1.0 2.0
1,2-Dichloropropane (78-87-5) 624 1.0 2.0
1,3-dichloropropene (mixed
isomers) (1,2-
dichloropropylene) (542-75-6) 3
624 1.0 2.0
Ethylbenzene (100-41-4) 624 1.0 2.0
Methyl bromide (74-83-9)
(Bromomethane) 624/601 5.0 10.0
Page 38 of 42
Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
METALS, CYANIDE & TOTAL PHENOLS
Methyl chloride (74-87-3)
(Chloromethane) 624 1.0 2.0
Methylene chloride (75-09-2) 624 5.0 10.0
1,1,2,2-Tetrachloroethane
(79-34-5) 624 1.9 2.0
Tetrachloroethylene (127-18-4) 624 1.0 2.0
Toluene (108-88-3) 624 1.0 2.0
1,2-Trans-Dichloroethylene
(156-60-5) (Ethylene
dichloride)
624 1.0 2.0
1,1,1-Trichloroethane (71-55-6) 624 1.0 2.0
1,1,2-Trichloroethane (79-00-5) 624 1.0 2.0
Trichloroethylene (79-01-6) 624 1.0 2.0
Vinyl chloride (75-01-4) 624/SM6200B 1.0 2.0
BASE/NEUTRAL COMPOUNDS (compounds in bold are Ecology PBTs)
Acenaphthene (83-32-9) 625 0.2 0.4
Acenaphthylene (208-96-8) 625 0.3 0.6
Anthracene (120-12-7) 625 0.3 0.6
Benzidine (92-87-5) 625 12 24
Benzyl butyl phthalate (85-68-
7) 625 0.3 0.6
Benzo(a)anthracene (56-55-3) 625 0.3 0.6
Benzo(b)fluoranthene
(3,4-benzofluoranthene) (205-
99-2) 4
610/625 0.8 1.6
Benzo(j)fluoranthene (205-82-
3) 4
625 0.5 1.0
Benzo(k)fluoranthene
(11,12-benzofluoranthene)
(207-08-9) 4
610/625 0.8 1.6
Benzo(r,s,t)pentaphene 625 0.5 1.0
Page 39 of 42
Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
METALS, CYANIDE & TOTAL PHENOLS
(189-55-9)
Benzo(a)pyrene (50-32-8) 610/625 0.5 1.0
Benzo(ghi)Perylene (191-24-2) 610/625 0.5 1.0
Bis(2-chloroethoxy)methane
(111-91-1) 625 5.3 21.2
Bis(2-chloroethyl)ether (111-
44-4) 611/625 0.3 1.0
Bis(2-chloroisopropyl)ether
(39638-32-9) 625 0.3 0.6
Bis(2-ethylhexyl)phthalate
(117-81-7) 625 0.1 0.5
4-Bromophenyl phenyl ether
(101-55-3) 625 0.2 0.4
2-Chloronaphthalene (91-58-7) 625 0.3 0.6
4-Chlorophenyl phenyl ether
(7005-72-3) 625 0.3 0.5
Chrysene (218-01-9) 610/625 0.3 0.6
Dibenzo (a,j)acridine (224-42-
0) 610M/625M 2.5 10.0
Dibenzo (a,h)acridine (226-36-
8) 610M/625M 2.5 10.0
Dibenzo(a-h)anthracene
(53-70-3)(1,2,5,6-
dibenzanthracene)
625 0.8 1.6
Dibenzo(a,e)pyrene (192-65-4) 610M/625M 2.5 10.0
Dibenzo(a,h)pyrene (189-64-0) 625M 2.5 10.0
3,3-Dichlorobenzidine (91-94-
1) 605/625 0.5 1.0
Diethyl phthalate (84-66-2) 625 1.9 7.6
Dimethyl phthalate (131-11-3) 625 1.6 6.4
Di-n-butyl phthalate (84-74-2) 625 0.5 1.0
2,4-dinitrotoluene (121-14-2) 609/625 0.2 0.4
Page 40 of 42
Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
METALS, CYANIDE & TOTAL PHENOLS
2,6-dinitrotoluene (606-20-2) 609/625 0.2 0.4
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
BASE/NEUTRAL COMPOUNDS (compounds in bold are Ecology PBTs)
Di-n-octyl phthalate (117-84-0) 625 0.3 0.6
1,2-Diphenylhydrazine (as
Azobenzene) (122-66-7) 1625B 5.0 20
Fluoranthene (206-44-0) 625 0.3 0.6
Fluorene (86-73-7) 625 0.3 0.6
Hexachlorobenzene (118-74-1) 612/625 0.3 0.6
Hexachlorobutadiene (87-68-3) 625 0.5 1.0
Hexachlorocyclopentadiene
(77-47-4) 1625B/625 0.5 1.0
Hexachloroethane (67-72-1) 625 0.5 1.0
Indeno(1,2,3-cd)Pyrene
(193-39-5) 610/625 0.5 1.0
Isophorone (78-59-1) 625 0.5 1.0
3-Methyl cholanthrene (56-
49-5) 625 2.0 8.0
Naphthalene (91-20-3) 625 0.3 0.6
Nitrobenzene (98-95-3) 625 0.5 1.0
N-Nitrosodimethylamine (62-
75-9) 607/625 2.0 4.0
N-Nitrosodi-n-propylamine
(621-64-7) 607/625 0.5 1.0
N-Nitrosodiphenylamine (86-
30-6) 625 0.5 1.0
Perylene (198-55-0) 625 1.9 7.6
Page 41 of 42
Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
METALS, CYANIDE & TOTAL PHENOLS
Phenanthrene (85-01-8) 625 0.3 0.6
Pyrene (129-00-0) 625 0.3 0.6
1,2,4-Trichlorobenzene
(120-82-1) 625 0.3 0.6
DIOXIN
2,3,7,8-Tetra-Chlorodibenzo-P-
Dioxin (176-40-16) 1613B 1.3 pg/L 5 pg/L
PESTICIDES/PCBs
Aldrin (309-00-2) 608 0.025 0.05
alpha-BHC (319-84-6) 608 0.025 0.05
beta-BHC (319-85-7) 608 0.025 0.05
gamma-BHC (58-89-9) 608 0.025 0.05
delta-BHC (319-86-8) 608 0.025 0.05
Chlordane (57-74-9) 5 608 0.025 0.05
4,4’-DDT (50-29-3) 608 0.025 0.05
4,4’-DDE (72-55-9) 608 0.025 0.0510
4,4’ DDD (72-54-8) 608 0.025 0.05
Dieldrin (60-57-1) 608 0.025 0.05
alpha-Endosulfan (959-98-8) 608 0.025 0.05
beta-Endosulfan (33213-65-9) 608 0.025 0.05
Endosulfan Sulfate (1031-07-8) 608 0.025 0.05
Endrin (72-20-8) 608 0.025 0.05
Endrin Aldehyde (7421-93-4) 608 0.025 0.05
Heptachlor (76-44-8) 608 0.025 0.05
Heptachlor Epoxide (1024-57-
3) 608 0.025 0.05
PCB-1242 (53469-21-9) 6 608 0.25 0.5
PCB-1254 (11097-69-1) 608 0.25 0.5
PCB-1221 (11104-28-2) 608 0.25 0.5
Page 42 of 42
Permit No. WA0037788
Pollutant & CAS No. (if
available)
Recommended
Analytical
Protocol
Detection
(DL)1
µg/L
unless
specified
Quantitation
Level (QL) 2
µg/L unless
specified
METALS, CYANIDE & TOTAL PHENOLS
PCB-1232 (11141-16-5) 608 0.25 0.5
PCB-1248 (12672-29-6) 608 0.25 0.5
PCB-1260 (11096-82-5) 608 0.13 0.5
PCB-1016 (12674-11-2) 6 608 0.13 0.5
Toxaphene (8001-35-2) 608 0.24 0.5
1. Detection level (DL) or detection limit means the minimum concentration of an analyte
(substance) that can be measured and reported with a 99percent confidence that the
analyte concentration is greater than zero as determined by the procedure given in 40
CFR part 136, Appendix B.
2. Quantitation Level (QL) also known as Minimum Level of Quantitation (ML) – The
lowest level at which the entire analytical system must give a recognizable signal and
acceptable calibration point for the analyte. It is equivalent to the concentration of the
lowest calibration standard, assuming that the lab has used all method-specified sample
weights, volumes, and cleanup procedures. The QL is calculated by multiplying the MDL
by 3.18 and rounding the result to the number nearest to (1, 2, or 5) x 10n, where n is an
integer. (64 FR 30417).
ALSO GIVEN AS: The smallest detectable concentration of analyte greater than the
Detection Limit (DL) where the accuracy (precision & bias) achieves the objectives of
the intended purpose. (Report of the Federal Advisory Committee on Detection and
Quantitation Approaches and Uses in Clean Water Act Programs Submitted to the US
Environmental Protection Agency December 2007).
3. 1, 3-dichloroproylene (mixed isomers) You may report this parameter as two separate
parameters: cis-1, 3-dichlorpropropene (10061-01-5) and trans-1, 3-dichloropropene
(10061-02-6).
4. Total Benzofluoranthenes - Because Benzo(b)fluoranthene, Benzo(j)fluoranthene and
Benzo(k)fluoranthene co-elute you may report these three isomers as total
benzofluoranthenes.
5. Chlordane – You may report alpha-chlordane (5103-71-9) and gamma-chlordane (5103-
74-2) in place of chlordane (57-74-9). If you report alpha and gamma-chlordane, the
DL/PQLs that apply are 0.025/0.050.
6. PCB 1016 & PCB 1242 – You may report these two PCB compounds as one parameter
called PCB 1016/1242.
FACT SHEET FOR NPDES PERMIT WA0037788 THREE RIVERS REGIONAL WASTEWATER AUTHORITY
(Formerly known as the Cowlitz Sewer Operating Board) Including
The Collection Systems Located in and Maintained by the Cities of Longview, Kelso, Beacon Hill Sewer District and Cowlitz County
SUMMARY
This facility treats wastewater from the City of Kelso, part of the City of Longview, the Beacon Hill Sewer District, and areas in unincorporated Cowlitz County, including the Port of Longview. The facility was upgraded in 2002, more than doubling the capacity of the facility. The facility uses the conventional activated sludge process with secondary clarification. The effluent is disinfected with liquid sodium-hypochlorite and dechlorinated with sodium-bisulfite the facility discharges to the Columbia River just downstream of the mouth of the Cowlitz River.
SUMMARY OF CHANGES TO THE FACT SHEET
FOLLOWING THE PUBLIC REVIEW. Appendix D (Response to Comments) shows the comments received during the public review and the Department of Ecology’s (Department) responses. The changes made to both the permit and fact sheet are shown in Appendix D. The content of the fact sheet may be different than the permit. The reasons are shown in Appendix D. These changes include the following:
The plant capacity has been temporarily adjusted to 19.5 mgd MMDF based on the number of the operating clarifiers. This capacity rating is interim until the plant can replace the clarifiers which have sustained structural damage. Prior to clarifier replacement, the facility must have the clarifiers’ peak flow capacity-rated, based upon a pre-engineering design report, and Department engineering guidelines. Prior to clarifier replacement, the facility must have the capacity rated, based on the pre-engineering design report and Department engineering guidelines. (See section S4.A in the permit.) As a result of this temporary downgrading, the interim loading values for CBOD and TSS were calculated on a ratio of the reduced flow to final flow. This loading for CBOD is calculated as 19.5 mgd/26 mgd = 0.75. The interim CBOD loading is 3884 lbs/day x 0.75 = 2913 lbs/day monthly and 2913 x 1.5 = 4370 lbs/day weekly. TSS was similarly reduced to 3611 lbs/day monthly and 5417 lbs/day weekly.
Small language and date changes were made to the final permit as described in Appendix D.
4/9/2007
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
TABLE OF CONTENTS
INTRODUCTION ...........................................................................................................................1
BACKGROUND INFORMATION ................................................................................................2 DESCRIPTION OF THE FACILITY .................................................................................2
History......................................................................................................................2 Collection System Status .........................................................................................2 Treatment Processes.................................................................................................3 Discharge Outfall .....................................................................................................6 Residual Solids.........................................................................................................6
PERMIT STATUS...............................................................................................................8 SUMMARY OF COMPLIANCE WITH THE PREVIOUS PERMIT ...............................8 WASTEWATER CHARACTERIZATION ........................................................................8 SEPA COMPLIANCE.......................................................................................................10
PROPOSED PERMIT LIMITATIONS.........................................................................................11 DESIGN CRITERIA .........................................................................................................11 TECHNOLOGY-BASED EFFLUENT LIMITATIONS..................................................11
Final Mass Loading Limits ....................................................................................12 Interim Mass Loading Limits.................................................................................13
SURFACE WATER QUALITY-BASED EFFLUENT LIMITATIONS .........................13 Numerical Criteria for the Protection of Aquatic Life...........................................13 Numerical Criteria for the Protection of Human Health........................................13 Narrative Criteria ...................................................................................................13 Antidegradation......................................................................................................14 Critical Conditions .................................................................................................14 Mixing Zones .........................................................................................................14 Description of the Receiving Water.......................................................................16 Surface Water Quality Criteria ..............................................................................17 Consideration of Surface Water Quality-Based Limits for Numeric Criteria ...................................................................................................................17 Whole Effluent Toxicity ........................................................................................21 Human Health ........................................................................................................22 Sediment Quality ...................................................................................................22
GROUND WATER QUALITY LIMITATIONS..............................................................22 COMPARISON OF EFFLUENT LIMITS WITH THE EXISTING PERMIT
ISSUED IN 2002 ...................................................................................................22
MONITORING REQUIREMENTS..............................................................................................24 EFFLUENT LIMITS BELOW QUANTITATION OR DETECTION.............................25 LAB ACCREDITATION ..................................................................................................25
OTHER PERMIT CONDITIONS .................................................................................................25 REPORTING AND RECORDKEEPING .........................................................................25 PREVENTION OF FACILITY OVERLOADING...........................................................26 OPERATION AND MAINTENANCE (O&M)................................................................26
4/9/2007 Page 2
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
RESIDUAL SOLIDS HANDLING...................................................................................27 PRETREATMENT............................................................................................................27
Federal and State Pretreatment Program Requirements ........................................28 Wastewater Permit Required .................................................................................29 Requirements for Routine Identification and Reporting of Industrial Users.........29 Requirements for Performing an Industrial User Survey ......................................29 Duty to Enforce Discharge Prohibitions ................................................................29 Support by the Department for Developing Partial Pretreatment Program by POTW ...............................................................................................................30
OUTFALL EVALUATION ..............................................................................................30 GENERAL CONDITIONS ...............................................................................................30
PERMIT ISSUANCE PROCEDURES .........................................................................................30 PERMIT MODIFICATIONS ............................................................................................30 RECOMMENDATION FOR PERMIT ISSUANCE ........................................................30
REFERENCES FOR TEXT AND APPENDICES........................................................................31
APPENDIX A--PUBLIC INVOLVEMENT INFORMATION....................................................33
APPENDIX B--GLOSSARY ........................................................................................................34
APPENDIX C--TECHNICAL CALCULATIONS .......................................................................39
APPENDIX D--RESPONSE TO COMMENTS ...........................................................................47
4/9/2007 Page 3
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
INTRODUCTION
The Federal Clean Water Act (FCWA, 1972, and later modifications, 1977, 1981, and 1987) established water quality goals for the navigable (surface) waters of the United States. One of the mechanisms for achieving the goals of the Clean Water Act is the National Pollutant Discharge Elimination System (NPDES) of permits, which is administered by the Environmental Protection Agency (EPA). The EPA has authorized the state of Washington to administer the NPDES permit program. Chapter 90.48 Revised Code of Washington (RCW) defines the Department of Ecology's (Department) authority and obligations in administering the wastewater discharge permit program.
The regulations adopted by the State include procedures for issuing permits [Chapter 173-220 Washington Administrative Code (WAC)], technical criteria for discharges from municipal wastewater treatment facilities (Chapter 173-221 WAC), water quality criteria for surface and ground waters (Chapters 173-201A and 200 WAC), and sediment management standards (Chapter 173-204 WAC). These regulations require that a permit be issued before discharge of wastewater to waters of the state is allowed. The regulations also establish the basis for effluent limitations and other requirements which are to be included in the permit. One of the requirements (WAC 173-220-060) for issuing a permit under the NPDES permit program is the preparation of a draft permit and an accompanying fact sheet. Public notice of the availability of the draft permit is required at least thirty (30) days before the permit is issued (WAC 173-220-050). The fact sheet and draft permit are available for review (see Appendix A--Public Involvement of the fact sheet for more detail on the Public Notice procedures).
The fact sheet and draft permit have been reviewed by the Permittee. Errors and omissions identified in this review have been corrected before going to public notice. After the public comment period has closed, the Department will summarize the substantive comments and the response to each comment. The summary and response to comments will become part of the file on the permit and parties submitting comments will receive a copy of the Department's response. The fact sheet will not be revised. Comments and the resultant changes to the permit will be summarized in Appendix D--Response to Comments.
GENERAL INFORMATION
Applicant Three Rivers Regional Wastewater Authority Jointly managed by: Beacon Hill Sewer District, Cowlitz County, City of Kelso, and the City of Longview, mailing address: 207 Fourth Avenue North Kelso, Washington 98626
Facility Name and Address
Three Rivers Regional Wastewater Plant 467 Fibre Way Longview, Washington
Type of Treatment Activated Sludge, Chlorine Disinfection
Discharge Location Columbia River Latitude: 46° 05' 53" N Longitude: 122° 56' 05" W.
Water Body ID No. Old ID No.: WA-CR-1010; New ID No.: 1240014462974
4/9/2007 Page 1
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
BACKGROUND INFORMATION
DESCRIPTION OF THE FACILITY
HISTORY In 1972, the Cities of Longview, Kelso, and the Beacon Hill Sewer District along with Cowlitz County formed an agreement to treat regional sewage. At this time, however, there is only a small amount of sewage collection from unincorporated areas of Cowlitz County. The name of the managing board was changed recently from the “Cowlitz Sewer Operating Board” to the “Three Rivers Regional Wastewater Authority (TRRWTA).” This group oversees the management, planning, design, construction, and operation of some of the pump stations in the vicinity of the treatment plant. The rest of the wastewater collection system is operated and managed by the individual jurisdictions. In October 2002, a treatment plant upgrade was completed where a new free standing plant (south-plant) was added to the original plant (north-plant). The design flow for the original north-plant was 10 million gallons per day (mgd). The new south-plant has a design limit of 16 mgd. The combined total plant capacity is 26 mgd. The north-plant is now used to treat mainly high flows. The waste stream from both plants is recombined for disinfection. The City of Longview sends approximately 55 percent of its flow to the regional treatment works. The rest of Longview’s flows are treated in a lagoon system that is covered under another permit. At some point in the future, the lagoons will be abandoned and the remaining flow will be sent to the regional treatment works. Although the north-plant has its own secondary clarifiers, there has been settling and cracking of the clarifiers. Only one of the north-plant clarifiers is operational at this time. Both of the north-plant clarifiers are anticipated to be replaced within the next couple of years. The TRRWTA is in the process of seeking to secure funding from the Public Works Trust Fund to replace the clarifiers.
COLLECTION SYSTEM STATUS The collection system is separated into four main basins each with multiple sub-basins. These main basins (the Jurisdictions) include the City of Kelso, the Beacon Hill Sewer district, the City of Longview and West Longview, and a small portion of unincorporated Cowlitz County. The collection system for West Longview is not included at this time under this permit. Each of the main basins in the collection system is operated by each of the jurisdictions as shown in the summary below. Therefore, the permit includes these jurisdictions on the title page. This listing is needed to make it clear that each jurisdiction is responsible for its portion of the collection system. The following table lists the number of pump stations in each jurisdiction. Summary of Collection Systems and Pump Stations
Beacon Hill Sewer District 7 pump stations City of Kelso 10 pump stations City of Longview (east) 15 pump stations
The following basin discharges to Longview lagoon system and not the TRRWTA System at this time, but likely will in the future:
West Longview 22 pump stations
4/9/2007 Page 2
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority The collection system (excluding West Longview) has approximately 170 miles of pipe ranging in diameter from 8-inch to 30-inch interceptors. Each jurisdiction and sewer district maintains its own portion of the system. This separation of each jurisdiction from the plant can create problems with consistency in dealing with city ordinances for grease and traps; inconsistent management of infiltration and inflow into the collection systems; the listing of industrial users under pretreatment; and even differences in parameters such as pH collected at the plant. For these reasons the jurisdictions are responsible under the permit for the operation and maintenance of their portion of the collection system The last general sewer plan and facility plan, written in 1996 and 1999, had many recommendations to improve aging lift stations and bottlenecks in the system. Many of these problems have been fixed. It is believed that the system now meets the capacity for the year 2013 design capacity flows. There still is, however, an Infiltration and Inflow (I/I) problem. The 2004 I/I report shows that I/I was approximately 6.6 mgd and comprised approximately 27.4 percent of the average design flow of 26 mgd. The extra flow infiltrating into the system may be enough to overload the treatment works during high flows. The cities and jurisdictions contributing to the system are continuing to grow. The application for this permit states that the population served as of October 2005 was 45,504. It is likely that the area will be growing soon with new developments planned and the facility has room to grow. The design flow was based on a population projection for 2013 of 66,500 capita which includes the West Longview area that is now discharging to the lagoon treatment system. The facility modifications that were completed in 2002 were planned to last until 2013 before the next phase of expansion would take place. The population in the area has not expanded as quickly as anticipated. There were down-turns in the economy and several large industries left in the early 1990s. The 1999 facility plan was based on 1990 census figures. If the Cities grow as anticipated, the Permittee and facility operating board may need to start planning for the next expansion of the facility during this coming permit cycle.
TREATMENT PROCESSES The treatment works are actually two similar plants in one compound (see schematic of entire facility below). The north-end plant is the original older plant and is used mainly to assist the south-end plant during higher flows and add additional redundancy. (See schematic below). The south-end plant was completed in 2002. The flow enters the compound and enters a common headworks for both the north and south plants. At the new headworks, flow is measured with a Parshall flume after which the wastewater is screened with new reciprocating-rake screens. The flow is then degritted in two parallel cyclone grit chambers. Flow is split and sent to each plant as needed.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority North-End Plant—10 mgd (average flow for max month):
The north-end plant flow is monitored by two parallel Parshall flumes. The flow then enters two parallel primary clarifiers followed by two parallel aeration basins with four connected channels and with selector zones at the start. The flow then is sent to two parallel secondary clarifiers, after which it is combined back with the flow from the south-plant before disinfection.
South-End Plant—16 mgd (average flow for max month)
The south-end plant is 60 percent larger in flow than the north-end plant and has new equipment. Otherwise, the north and south plants are very similar. Both plants can be operated in complete-mix activated-sludge mode during low flows or in contact-stabilization mode during higher flows to prevent solids wash-out.
After the flows from the north and south plants are recombined, the effluent is disinfected with liquid sodium-hypochlorite in a contact basin. The effluent is then dechlorinated with sodium bisulfite solution. The effluent is pumped at times of high river flow. In October 2003, it was found that the secondary clarifiers in the north-plant were differentially sinking and floating. This settling is causing pipes to shear and the base to crack. Both of the north-end clarifiers have been regrouted, but only one of the clarifiers is available for operation. The north-plant is therefore used only during the higher flows, when the south-end plant is at capacity. Both north-end clarifiers are planned to be replaced within the next two years. The Three Rivers Board has applied for Public Works Trust Fund money to replace the clarifiers. If this money is available, The Board should begin replacing the clarifiers by fall 2006. The new permit will contain a requirement for engineering plans and replacement of the clarifiers by a certain date. The facility receives wastewater from several industrial users. The Beacon Hill Sewer District does not have any Significant Industrial Users (SIUs) or Potentially Significant Industrial Users (PSIUs). The City of Kelso has three SIUs: • Foster Farms, • Columbia Analytical Services, and • The City Water Treatment Plant The City of Longview has two SIUs, and one PSIU: • Wayron (SIU), • KEMIRA (SIU), and • Mirant & Avista Power (PSIU) (Not built and would discharge through the Weyerhaeuser Paper
mill discharge an not the TRRWP discharge.) Cowlitz County has one SIU, and two PSIUs: • Cowlitz County Landfill (SIU), • CES Power Plant also known as Longview Energy Development (LED) (PSIU. This facility has
never been built), and • Nordic Biofuels Ethanol Plant (PSIU) – No longer active
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority In addition to these industrial users shown above, the Permittee conducted a survey in April 2004 of all non-residential businesses and found 243 establishments. Many of those businesses listed were restaurants, schools, or auto shops that discharge a small amount of wastewater that is domestic in nature, but also with oil and grease to the Three River Plant. There will be more about pretreatment of SIU wastewater later in this fact sheet. The permit will require a new list of SIUs, PSIUs and a new survey of all of the non-residential businesses. The facility is classified as Class IV based on size (greater than 10 mgd) and technology (activated sludge). The lead operator in responsible charge of this treatment plant must have at least a group IV certification. The operators in charge of a shift must have at least a group III certification. There are four lead operators at the facility, three of which have group IV certification and one has a group III certification. The rest of the staff at the facility have group II to group IV certification. The plant is staffed seven (7) days per week for two (2) shifts per day. A Supervisory Control and Data Acquisition (SCADA) system monitors the plant operations during unmanned hours, and staff can be called in when equipment malfunctions.
DISCHARGE OUTFALL
Secondary treated and disinfected effluent is discharged from the facility into the Columbia River at a depth of approximately 35-feet below Mean Lower Low Water (MLLW) and approximately 350-feet from shore. The discharge point is just downstream from the confluence with the Cowlitz River and it is approximately 500 feet downstream of the outfall for Longview Fibre. The downstream edge of the Longview Fibre’s chronic mixing zone is approximately 60 feet from the upstream edge of the TRRWTP chronic mixing zone. The outfall diffuser is parallel with the shore and current, is 77-feet long and has 14 orifices spaced at 4.75-foot intervals. The orifices are 6.5-inches in diameter face up 20 degrees from horizontal and alternate between facing away from shore and towards shore.
Although the Longview Fibre mixing zone boundary does not overlap with the TRRWTP mixing zone, its diluted plume does travel over and into the TRRWTP plume. Because the Longview Fibre effluent is warm, it likely rises to the surface and creates a partially stratified layer. The TRRWTP’s effluent may also be warm, but not as warm as the Longview Fibre effluent during some period of each year. The mixing zones and dilution were studied (Cosmopolitan, 1999) and dilution will be covered in a later section of this fact sheet.
RESIDUAL SOLIDS At the front of the plant is the screening of residual solids, (rags, scum, and other debris) are collected and sent the Cowlitz County Landfill. The facility also removes grit which is classified and disposed of in the Cowlitz County Landfill. The rest of this discussion concerns the solids that start as sludge. The processing of sludge solids to biosolids at the facility is very complex. A schematic below shows the entire solids processing train (Brown & Caldwell, 2004). A major portion of the existing solids processing is being replaced and should be operational late in 2007. This description is focused on the new process. Solids other than screenings are generated from primary clarifiers and from the secondary clarifiers. The north-end and south-end primary clarifiers are labeled as “3” and “6” on the facility schematic above. The waste from the north-end primary clarifiers goes through a pair of gravity thickener basins before the being sent to the sludge strainer. Where as, the waste from the south-end primary clarifiers, is sent directly to the sludge strainer. Waste activated sludge from the secondary clarifiers from both plants is thickened in a gravity belt thickener with polymers and then sent on to sludge blending. The waste sludge from all these sources is then blended and sent to dewatering centrifuges after more polymer is added. A thermo-blending process with lime and heat will end up with Pasteurized solids which can be trucked
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority away as biosolids. These biosolids at the present time are composted and used as cover at the Cowlitz County Landfill. Because there will be new equipment and operation, the Operation and Maintenance (O&M) Manual will need to be updated. This O&M item will be a requirement in the new permit.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
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PERMIT STATUS
The previous permit for this facility was issued on January 29, 2001. The previous permit placed effluent limitations on:
• Five (5)-day Carbonaceous Biochemical Oxygen Demand (CBOD5), • Total Suspended Solids (TSS), • pH, • fecal coliform bacteria, • total residual chlorine, and • total ammonia
An application for permit renewal was submitted to the Department in October 2005 and accepted by the Department on November 2005.
SUMMARY OF COMPLIANCE WITH THE PREVIOUS PERMIT
The facility received its last inspection on February 22, 2006. No major problems with the facility operation were found at that time. The facility received an award from the Department for their performance in 2005.
During the history of the previous permit, the Permittee has remained in compliance, based on Discharge Monitoring Reports (DMRs) submitted to the Department and inspections conducted by the Department.
WASTEWATER CHARACTERIZATION
The concentration of pollutants in the discharge was reported in the NPDES application and in discharge monitoring reports. The effluent is characterized as follows:
Table 1: Wastewater Characterization (for Jan 2002 – Dec 2005)
Parameter Concentrations and Loads Limits and Design Standards
Flow (mgd) 12.3 mgd (avg for max month) 30.4 mgd (maximum day)
26 mgd (max month design flow) 62.4 mgd (peak day design flow)
CBOD5 19 mg/L (max 30-day average) 28 mg/L (max 7-day average) 86% removal (5th percentile)
1,283 lbs/day (max 30-day average) 1,568 lbs/day (max 7-day average)
25 mg/L (average monthly) 40 mg/L (average weekly)
85% minimum removal 3,900 lbs/day (average monthly) 5,800 lbs/day (average weekly)
TSS 20 mg/L (max 30 day average) 31 mg/L (max 7 day average) 89% removal (5th percentile)
1,459 lbs/day (max 30 day avg) 2,535 lbs/day (max week)
30 mg/L (average monthly) 45 mg/L (average weekly)
85% minimum removal 4,815 lbs/day (average monthly) 7,223 lbs/day (average weekly)
Fecal Coliform 24 org/100 ml (max 30-day g-mean) 107 org/100 ml (max 7-day g-mean)
200 org/100 ml (average monthly) 400 org/100 ml (average weekly)
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
Parameter Concentrations and Loads Limits and Design Standards
pH 6.5 S.U. (5th percentile) 5.9 max
7.4 S.U. (95th percentile) 8.1 max
shall not be less than 6 or greater than 9
Total Residual Chlorine
Less than 0.001 (95th percentile) 5.0 max
0.03 mg/L monthly, 0.09 mg/L weekly
Total Ammonia
(May-Oct) (Nov-Apr)
24.5 mg/L (95th percentile) 23 (max monthly avg)
13.4 mg/L (95th percentile) 14.2 (max monthly avg)
15 mg/L (avg monthly)
22.8 mg/L (avg monthly)
Copper 6.25 µg/L (95th percentile of 27 samples after 6/30/04 when water supply corrosion controls started)
11.2 µg/L (avg monthly) 16.4 µg/L (max daily)
Mercury 0.10 µg/L (95th percentile of 21 samples)
0.21 µg/L (avg monthly) 0.31 µg/L (max daily)
Lead 0.0 µg/L (undetected in 41 samples) 3.1 µg/L (avg monthly)
4.5 µg/L (max daily) Effluent characterization in table 1 above is intended to show facility operations over the last three to five years. The facility operation has, for the most part, been good. The facility has met its permit limits for ammonia in all but three (3) months. The average monthly limit was 15 mg/L (from May through October final permit limit); and limits were exceeded in August 2003 along with September and October 2005. The average ammonia was 23 mg/L in both September and October 2005. These sample exceedances occurred in warmer months of late summer and early fall. This is usually the period with greatest ammonia toxicity. (See ammonia graph below). The flow was well within design limits. The CBOD5 and TSS limits for concentrations (mg/L), loadings (lbs/day), and removal percentages were all well within limits. The fecal coliform limits were easily met. The fecal coliform limits are based on a geometric-mean. Even though there were a couple of individual samples that were greater than 200 on a weekly basis and greater than 400 on a monthly basis, there were no limit violations. The disinfection system, which uses chlorine to disinfect, and uses sodium-bisufite to dechlorinate. The result is that the chlorine samples were mostly below detection (below 10 µg/L) and were therefore well within the chlorine limit of 30 µg/L monthly. Occasionally there have been residual chlorine samples of up to 40 µg/L; however, these have not caused an exceedance of limits on a monthly or weekly basis.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
Three Rivers Effluent Ammonia
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-Apr
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The effluent values for the three main metals (copper, mercury, and lead) were all below the limits. The copper was sampled many times throughout the sampling period. The water supply to the cities was changed in June 2004 which resulted in lower amounts of copper entering the treatment plant. Only the period after June 2004 was used to evaluate copper. The effluent samples for lead were all below detection. The effluent samples for mercury were mostly below detection and a 95th percentile was calculated at 0.10 µg/L. Other metals were sampled however all had values that were below detection or were not of concern. Priority pollutant scans were required to be conducted annually. There have been four rounds of priority pollutant sampling that have taken place since the new plant came on-line. The results showed either non-detection of the toxic substances or the amounts were not in toxic quantities. The possible sources of toxics are the significant industrial users. These include: • Cytec Industries which produces polymers and coagulants. This discharge has local limits; • Foster Farms which processes chickens for market. This discharge has local limits; • Toyocom Industries which produces synthetic quartz crystals. This industry uses natural quartz
rock and 4 percent sodium hydroxide. This industry has local limits and categorical pretreatment standards.
• The Cowlitz County Landfill discharges leachate to the treatment works. This discharge has local limits.
SEPA COMPLIANCE Prior to the construction of the new south-end of the plant, State Environmental Policy Act (SEPA) was complied with and there was a declaration of non significance, which means that an Environmental Impact Statement (EIS) was not required (Gibbs & Olson, 2000). A declaration of non-significance was also filed in May 2006 for the new biosolids processing facility that will replace the existing biosolids processing facility.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
PROPOSED PERMIT LIMITATIONS
Federal and state regulations require that effluent limitations set forth in a NPDES permit must be either technology-based or water quality-based. Technology-based limitations for municipal discharges are set by regulation (40 CFR 133, and Chapters 173-220 and 173-221 WAC). Water quality-based limitations are based upon compliance with the Surface Water Quality Standards (Chapter 173-201A WAC), Ground Water Standards (Chapter 173-200 WAC), Sediment Quality Standards (Chapter 173-204 WAC) or the National Toxics Rule (40 CFR 131.36.) The most stringent of these types of limits must be chosen for each of the parameters of concern. Each of these types of limits is described in more detail below.
The limits in this permit are based in part on information received in the application. The effluent constituents in the application were evaluated on a technology- and water quality-basis. The limits necessary to meet the rules and regulations of the state of Washington were determined and included in this permit. The Department does not develop effluent limits for all pollutants that may be reported on the application as present in the effluent. Some pollutants are not treatable at the concentrations reported, are not controllable at the source, are not listed in regulation, and do not have a reasonable potential to cause a water quality violation. Effluent limits are not always developed for pollutants that may be in the discharge but not reported as present in the application. In those circumstances the permit does not authorize discharge of the non-reported pollutants. Effluent discharge conditions may change from the conditions reported in the permit application. If significant changes occur in any constituent, as described in 40 CFR 122.42(a), the Permittee is required to notify the Department. The Permittee may be in violation of the permit until the permit is modified to reflect additional discharge of pollutants.
DESIGN CRITERIA
In accordance with WAC 173-220-150 (1)(g), flows or waste loadings shall not exceed approved design criteria.
The design criteria for this treatment facility are taken from the Facility Plan prepared by Gibbs & Olson with Corollo Engineers in 1999 (Table IV-2) and are as follows:
Table 1: Design Standards for the Cowlitz Three Rivers WWTP.
Parameter Design Quantity (2013) Monthly average flow (max. month) 26.0 MGD Instantaneous peak day flow 62.4 MGD CBOD5 influent loading 31,200 lb./day TSS influent loading 32,100 lb./day Design population equivalent 66,500 The existing population is as shown on DMRs is 45,000.
TECHNOLOGY-BASED EFFLUENT LIMITATIONS
Municipal wastewater treatment plants are a category of discharger for which technology-based effluent limits have been promulgated by federal and state regulations. These effluent limitations are given in the Code of Federal Regulations (CFR) 40 CFR Part 133 (federal) and in Chapter 173-221 WAC (state). These regulations are performance standards that constitute All Known Available and Reasonable methods of prevention, control, and Treatment (AKART) for municipal wastewater.
The following technology-based limits for pH, fecal coliform, BOD5, and TSS were taken from Chapter 173-221 WAC and are:
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Table 2: Technology-based Limits.
Parameter Limit
pH: shall be within the range of 6 to 9 standard units.
Fecal Coliform Bacteria Monthly Geometric Mean = 200 organisms/100 ml Weekly Geometric Mean = 400 organisms/100 ml
BOD5 (concentration)
Average Monthly Limit is the most stringent of the following: - 30 mg/L (25 mg/L for CBOD) - may not exceed fifteen percent (15%) of the average influent concentration Average Weekly Limit = 45 mg/L (40 mg/L for CBOD)
TSS (concentration)
Average Monthly Limit is the most stringent of the following: - 30 mg/L - may not exceed fifteen percent (15%) of the average influent concentration Average Weekly Limit = 45 mg/L
Residual Chlorine Average Monthly Limit = 0.5 mg/L Average Weekly Limit = 0.75 mg/L
The technology-based monthly average limitation for chlorine is derived from standard operating practices. The Water Pollution Control Federation's Chlorination of Wastewater (1976) states that a properly designed and maintained wastewater treatment plant can achieve adequate disinfection if a 0.5 mg/liter chlorine residual is maintained after fifteen minutes of contact time. See also Metcalf and Eddy, Wastewater Engineering, Treatment, Disposal and Reuse, Third Edition, 1991. A treatment plant that provides adequate chlorination contact time can meet the 0.5 mg/liter chlorine limit on a monthly average basis. According to WAC 173-221-030(11)(b), the corresponding weekly average is 0.75 mg/liter.
However, the previous permit had a total residual chlorine limit of 0.03 mg/L on a monthly average basis and a limit of 0.09 mg/L on an average weekly basis. Because the facility was able to comply with these limits they will need to stay in new permit to avoid backsliding.
FINAL MASS LOADING LIMITS
The final loading limits are based on having all systems functioning and operational at the treatment plant. The facility currently has problems with the secondary clarifiers in the north-end of the plant. The facility is in the process of studying options for replacing both of the north-end clarifiers. There will be therefore interim and final limits. The final limits will not be in force until the Department receives a declaration of construction.
The following technology-based mass limits for Carbonaceous Biological Oxygen Demand (CBOD5) are based on WAC 173-220-130(3)(b) and 173-221-030(11)(b).
Monthly effluent mass loadings (lbs/day) for CBOD5 were calculated as the maximum monthly influent design loading (31,200 lbs/day) x 0.15 = 4,680 lbs/day.
This facility, however, requested in the past to have their BOD5 limits based on CBOD5. The monthly CBOD5 concentration limit is 25 mg/L compared to BOD5 which is 30 mg/L. A ratio of CBOD to BOD (25/30 = 0.83) was applied to determine the loading rate for CBOD. The monthly effluent CBOD loading limit therefore is 4,680 x 0.85 = 3,884 lbs/day.
The weekly average effluent mass loading is calculated as 1.5 x monthly loading = 5826 lbs/day.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Monthly effluent mass loadings (lbs/day) for TSS were calculated as the maximum monthly influent design loading (32,100 lbs/day) x 0.15 = 4,815 lbs/day.
The weekly average effluent mass loading for TSS is calculated as 1.5 x monthly loading = 7,223 lbs/day.
INTERIM MASS LOADING LIMITS
The following mass loading limits will be interim until the north-end clarifiers have been replaced. The monthly CBOD5 concentration limit is 25 mg/L compared to BOD5 which is 30 mg/L. A ratio of CBOD to BOD (25/30 = 0.83) was applied to determine the loading rate for CBOD. The monthly effluent CBOD loading limit therefore is 4,680 x 0.85 = 3,884 lbs/day. However, because one clarifier out of four total is completely out of service, the limit will be 3,884 x 0.81 = 3,146 lbs/day monthly.
The weekly average effluent mass loading is calculated as 1.5 x monthly loading = 4,719 lbs/day.
Monthly effluent mass loadings (lbs/day) for TSS were calculated as the maximum monthly influent design loading (32,100 lbs/day) x 0.15 = 3,611 lbs/day .
The weekly average effluent mass loading for TSS is calculated as 1.5 x monthly loading = 5,417 lbs/day.
SURFACE WATER QUALITY-BASED EFFLUENT LIMITATIONS
In order to protect existing water quality and preserve the designated beneficial uses of Washington's surface waters, WAC 173-201A-060 states that waste discharge permits shall be conditioned such that the discharge will meet established Surface Water Quality Standards. The Washington State Surface Water Quality Standards (Chapter 173-201A WAC) is a state regulation designed to protect the beneficial uses of the surface waters of the state. Water quality-based effluent limitations may be based on an individual waste load allocation (WLA) or on a WLA developed during a basin-wide total maximum daily loading study (TMDL).
NUMERICAL CRITERIA FOR THE PROTECTION OF AQUATIC LIFE
"Numerical" water quality criteria are numerical values set forth in the state of Washington's Water Quality Standards for Surface Waters (Chapter 173-201A WAC). They specify the levels of pollutants allowed in a receiving water while remaining protective of aquatic life. Numerical criteria set forth in the Water Quality Standards are used along with chemical and physical data for the wastewater and receiving water to derive the effluent limits in the discharge permit. When surface water quality-based limits are more stringent or potentially more stringent than technology-based limitations, they must be used in a permit.
NUMERICAL CRITERIA FOR THE PROTECTION OF HUMAN HEALTH
The state was issued 91 numeric water quality criteria for the protection of human health by the U.S. EPA (EPA 1992). These criteria are designed to protect humans from cancer and other disease and are primarily applicable to fish and shellfish consumption and drinking water from surface waters.
NARRATIVE CRITERIA
In addition to numerical criteria, "narrative" water quality criteria (WAC 173-201A-030) limit toxic, radioactive, or deleterious material concentrations below those which have the potential to adversely affect characteristic water uses, cause acute or chronic toxicity to biota, impair aesthetic values, or adversely affect human health. Narrative criteria protect the specific beneficial uses of all fresh (WAC 173-201A-130) and marine (WAC 173-201A-140) waters in the state of Washington.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority ANTIDEGRADATION
The state of Washington's Antidegradation Policy requires that discharges into a receiving water shall not further degrade the existing water quality of the water body. In cases where the natural conditions of a receiving water are of lower quality than the criteria assigned, the natural conditions shall constitute the water quality criteria. Similarly, when receiving waters are of higher quality than the criteria assigned, the existing water quality shall be protected. More information on the State Antidegradation Policy can be obtained by referring to WAC 173-201A-070.
The Department has reviewed existing records and is unable to determine if ambient water quality is either higher or lower than the designated classification criteria given in Chapter 173-201A WAC; therefore, the Department will use the designated classification criteria for this water body in the proposed permit. The discharges authorized by this proposed permit should not cause a loss of beneficial uses.
There are several parameters listed on the 303(d) list of limited water bodies in this segment of the Columbia River. The 2004 303(d) listing for this area near the Permittee’s discharge has listings for fecal coliform, temperature, and tissue listings for PCBs and Dieldrin.
A temperature TMDL was started several years ago for the Snake and Columbia Rivers by EPA, but has been held up and not completed. Diminishing riparian vegetation, increased thermal absorption due to dams (with shallower backwaters), return flows from irrigation, and increased numbers of thermal discharges have all had significant effects on the Columbia River temperature as a whole. This is measurable in all areas of the river including the area of the Permittee’s outfall. More will be discussed under Considerations for Surface Waters below.
Fecal coliform is noted in a segment approximately two miles downstream of the Permittee’s outfall. However, the background fecal coliform used in evaluating this discharge was not in violation of the water quality criteria. The Permittee’s facility is equipped with a chlorination disinfection system which can easily meet the technology and water quality limits. The PCBs and Dieldrin are not typical components of municipal discharges, are unlikely from this municipal discharge, and have not been detected in the discharge.
CRITICAL CONDITIONS
Surface water quality-based limits are derived for the water body’s critical condition, which represents the receiving water and waste discharge condition with the highest potential for adverse impact on the aquatic biota, human health, and existing or characteristic water body uses. The critical condition for the pollutants in this discharge is a combination of low river flows and high temperatures. The lower Columbia River in this area does not have a true low flow because it is highly controlled and a 7Q10 low flow is not realistic. However, the lowest period of flow occurs in late August through early September. The maximum daily water temperatures occur in early June to September and then start to taper off (see the graph of max daily temperatures below). The maximum daily temperature and minimum dilution are important factors in setting a critical condition. A critical summer condition should therefore be June through September. It appears that high pH conditions occur during the winter months and therefore a critical winter condition should be October through May. The pH is used in calculating ammonia toxicity and high pH tends to results in higher ammonia toxicity.
MIXING ZONES This permit authorizes an acute and a chronic mixing zone around the point of discharge as allowed by Chapter 173-201A WAC, Water Quality Standards for Surface Waters of the State of Washington. The Water Quality Standards stipulate some criteria be met before a mixing zone is allowed. The requirements and the Department’s actions are summarized as follows:
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority 1. The allowable size and location be established in a permit.
For this discharge, the percent volume restrictions of the Water Quality Standards resulted in a lower dilution factor than the distance and width restrictions. Therefore, the dilution factor calculated at a ten (10)-year low flow was used to determine reasonable potential to exceed water quality standards.
2. Fully apply “all known available and reasonable methods of treatment” (AKART).
The technology-based limitations determined to be AKART are discussed in an earlier Section of this fact sheet.
3. Consider critical discharge condition.
The critical discharge condition is often pollutant-specific or water body-specific and is discussed above.
4. Supporting information clearly indicates the mixing zone would not have a reasonable
potential to cause the loss of sensitive or important habitat, substantially interfere with the existing or characteristic uses, result in damage to the ecosystem or adversely affect public health.
The Department has reviewed the information on the characteristics of the discharge, receiving water characteristics and the discharge location. Based on this information, the Department believes this discharge does not have a reasonable potential to cause the loss of sensitive or important habitat, substantially interfere with existing or characteristics uses, result in damage to the ecosystem or adversely affect public health.
5. Water quality criteria shall not be violated (exceeded) outside the boundary of a mixing
zone.
A reasonable potential analysis, using procedures established by USEPA and the Department, was conducted for each pollutant to assure there will be no violations of the water quality criteria outside the boundary of a mixing zone.
6. The size of the mixing zone and the concentrations of the pollutants shall be minimized.
The size of the mixing zone (in the form of the dilution factor) has been minimized by the use of design criteria with low probability of occurrence. For example, the reasonable potential analysis used the expected 95th percentile pollutant concentration, the 90th percentile background concentration, the centerline dilution factor and the low flow occurring once in every ten (10) years. The concentrations of the pollutants in the mixing zone have been minimized by requiring pollution prevention measures where applicable.
The Longview Fibre Company’s mixing zone is approximately 88 feet upstream of the Permittee’s chronic mixing zone. The modeling of the Longview Fibre dilution shows that they have a very high rate of dilution of 120:1. It is unlikely that the Longview Fibre’s effluent will have much effect on the background to the Permittee’s discharge.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority 7. Maximum size of mixing zone
The authorized mixing zone does not exceed the maximum size restriction. 8. Acute Mixing Zone
A. Acute criteria met as near to the point of discharge as practicably attainable
The acute criteria have been determined to be met at 10 percent of the distance of the chronic mixing zone.
B. The concentration of, and duration and frequency of exposure to the discharge, will
not create a barrier to migration or translocation of indigenous organisms to a degree that has the potential to cause damage to the ecosystem.
The toxicity of pollutants is dependent upon the exposure which in turn is dependent upon the concentration and the time the organism is exposed to that concentration. For example EPA gives the acute criteria for copper as “freshwater aquatic organisms and their uses should not be affected unacceptably if the one (1)-hour average concentration (in µg/l) does not exceed the numerical value given by (0.960)(e(0.9422[ln(hardness)] - 1.464)) more than once every three years on the average.” The limited acute mixing zone authorized for this discharge will assure that it will not create a barrier to migration. The effluent from this discharge will rise as it enters the receiving water assuring that it will not cause translocation of indigenous organism near the point of discharge.
C. Comply with size restrictions
The mixing zone authorized for this discharge meets the size restrictions of WAC 173-201A.
9. Overlap of Mixing Zones
This mixing zone does not overlap another mixing zone. As noted above, the mixing zone is some distance and offset in the River from the Longview Fibre mixing zone.
The National Toxics Rule (EPA, 1992) allows the chronic mixing zone to be used to meet human health criteria.
DESCRIPTION OF THE RECEIVING WATER
The facility discharges to the Columbia River which is designated as a Class A receiving water in the vicinity of the outfall. Other nearby point source outfalls as noted above includes that of the Longview Fibre pulp and paper mill. Across the Columbia River and slightly downstream of the Permittee’s discharge is the discharge for the Oregon town of Rainier. Stormwater from the cities of Longview and Kelso is under the process of being covered under a general stormwater permit that will require these municipalities to treat and manage their stormwater with the best available technology. Significant nearby non-point sources of pollutants include livestock and siliviculture operations whose runoff may affect the Cowlitz River prior to discharging to the Columbia River.
Characteristic uses of Class A water includes the following: water supply (domestic, industrial, agricultural); stock watering; fish migration; fish rearing, spawning and harvesting; wildlife habitat; primary contact recreation; sport fishing; boating and aesthetic enjoyment; commerce and navigation.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Water quality of this class shall meet or exceed the requirements for all or substantially all uses.
SURFACE WATER QUALITY CRITERIA
Applicable criteria are defined in Chapter 173-201A WAC for aquatic biota. In addition, U.S. EPA has promulgated human health criteria for toxic pollutants (EPA 1992). Criteria for this discharge are summarized below:
Fecal Coliforms 100 organisms/100 ml maximum geometric mean
Dissolved Oxygen 8 mg/L minimum
Temperature 18 degrees Celsius maximum or incremental increases above background
pH 6.5 to 8.5 standard units
Turbidity less than 5 NTUs above background
Toxics No toxics in toxic amounts (see Appendix C for numeric criteria for toxics of concern for this discharge)
CONSIDERATION OF SURFACE WATER QUALITY-BASED LIMITS FOR NUMERIC CRITERIA
Pollutant concentrations in the proposed discharge exceed water quality criteria with technology-based controls which the Department has determined to be AKART. A mixing zone is authorized in accordance with the geometric configuration, flow restriction, and other restrictions for mixing zones in Chapter 173-201A WAC and are defined as follows:
235 feet in any horizontal direction from any diffuser port
The dilution factors of effluent to receiving water that occur within these zones have been determined at the critical condition by the use of modeling. The Permittee’s consultant used the UM3 model for the acute dilution and CORMIX2 for the chronic dilution which were calibrated with a dye study (Cosmopolitan Eng., 1999). The dilution factors have been determined to be:
Acute Chronic
Aquatic Life 6.4 15.6
Human Health, Carcinogen 15.6
Human Health, Non-carcinogen 15.6
Pollutants in an effluent may affect the aquatic environment near the point of discharge (near field) or at a considerable distance from the point of discharge (far field). Toxic pollutants, for example, are near-field pollutants--their adverse effects diminish rapidly with mixing in the receiving water. Conversely, a pollutant such as BOD is a far-field pollutant whose adverse effect occurs away from the discharge even after dilution has occurred. Thus, the method of calculating water quality-based effluent limits varies with the point at which the pollutant has its maximum effect.
The derivation of water quality-based limits also takes into account the variability of the pollutant concentrations in both the effluent and the receiving water.
The critical condition for the Columbia River as noted above is June through September. This is based on a minimum flow and water temperatures. The classic seven day average low river flow with a recurrence interval of ten (10) years (7Q10) is not possible on the Columbia because it is a controlled river. Ambient data at critical conditions in the vicinity of the outfall were taken from multiple sources as noted below.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
Parameter Value used
Critical Low flow 97,400 cfs (Columbia controlled flow. This is used in place of a 7Q10 for the mixing zone modeling)
Velocity 0.0 m/s (10th percentile current velocity)
0.3 m/s (90th percentile current velocity)
Depth of diffuser 35 feet
Width 2790 feet
Temperature 21.78o C (90th percentile June – Sept.),
14.44º C (90th percentile Oct. – May).
pH (high) Nearby ambient values for pH are not available at this time a
Dissolved Oxygen 9.9 mg/L
Total Ammonia-N 12 µg/L (July 2004 monitoring near outfall)
Fecal Coliform 52.2/100 ml dry weather
Turbidity 9.8 NTU
Hardness Nearby ambient values for hardness are not available at this time a
Lead 9.0 µg/L
Copper 4.5 µg/L (total recoverable estimated value)
Zinc 20.4 µg/L (total recoverable estimated value)
Arsenic 20.0 µg/L
All Other Metals 0.0 (below detection limits) a The Department typically uses upstream water quality data and effluent data to determine if there is a reasonable potential to violate water quality standards. Unfortunately, there is little water quality data for pH and hardness in the area immediately above Three River’s outfall. pH and hardness values are critical for determining water quality based effluent limits. As a result of the lack of data, the Department is requiring the discharger to collect upstream receiving water data as part of this permit.
We did use data that is available (from sampling stations that are located several miles above the confluence of the Columbia and Cowlitz Rivers and Longview Fibre’s outfall), with some assumptions of mixing below the confluence to illustrate the potential for water quality violations and the need to collect site specific data. The mixing is discussed in more detail below under toxic pollutants and ammonia.
In the Columbia River at river mile 59, above its confluence with the Cowlitz, the 90th percentile value pH was 8.44 in winter and 7.96 in the summer. In the Cowlitz River above the confluence, the pH 90th percentile pH was 7.66 in winter and 7.60 in the summer.
The hardness in the Columbia at river mile 59 was 45 mg/L as CaCO3 and the hardness in the Cowlitz near Kelso was 16 mg/L as CaCO3 (90th percentile). There was no appreciable difference between summer and winter hardness.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
The ammonia values were collected near the outfall and were therefore included in the above table. Because a new data collection of pH, hardness, and temperature will be recommended for evaluating ammonia, it is also recommended that new ammonia date be gathered as well.
CBOD5-- In 1986 the plant superintendent petitioned the Department to be allowed to use Carbonaceous Biological Oxygen Demand (CBOD) instead of BOD for reporting and monitoring. US EPA has extensively studied the use of a CBOD limit in lieu of a BOD limit. They concluded that a 25 mg/L CBOD5 limit is effectively equivalent to a 30 mg/L BOD5 limit. Permission was granted and CBOD5 has been used in the last several rounds of permitting. Using CBOD5, a municipality could discharge more oxygen-demanding nitrogenous material than when using BOD5.
This discharge with technology-based limitations results in a small amount of CBOD5 loading relative to the large amount of dilution occurring in the receiving water at critical conditions. Technology-based limitations will be protective of dissolved oxygen criteria in the receiving water. With initial dilution the dissolved oxygen would not be depressed more than 0.3 mg/L.
Temperature and pH--The impact of pH and temperature were modeled using the calculations from EPA, 1988. The input variables were: dilution factor 15.6, upstream temperature 21.78ºC, upstream pH 8.44, upstream alkalinity 45 (as mg CaCO3/L), effluent temperature 20ºC (assumed), effluent pH of 7.4, effluent pH of 9, and effluent alkalinity 150 (as mg CaCO3/L, assumed). The ambient temperature was measured by the placement of recording thermisters upstream of the Longview Fibre discharge. These thermisters were set to record the temperature every half hour from June-September of 2000 and 2001. The daily maximum temperature was then determined and used in the ammonia and temperature analysis. (See the graph of summer temperatures below). This evaluation also takes into account the mixing of the Cowlitz River into the Columbia River. With a dilution factor for the Cowlitz to the Columbia Rivers of 3.3 in the winter and 7.2 in the summer, the resultant summer pH would be 7.93 at the edge of the mixing zone. and the winter pH would be 8.23 at the edge of the mixing zone. These are rough estimates because the true dilution ratio of the Cowlitz to the Columbia River in the vicinity of the Permittee’s mixing zone is unknown. The minimum flow for the Columbia River was published in the mixing zone analysis as 95,161 cfs (Cosmopolitan, 1999). The 7Q10 flow for the Cowlitz at Castle Rock was determined as 2,238.4 cfs (Williams, 1985). The Permittee’s effluent temperature has not been reported. However, effluent temperature from municipal discharges in this area are typically around 20ºC. The water quality standards allow a 0.3ºC increase in temperature above background. The water quality temperature criterion will therefore be met. A study conducted on the Longview Fibre discharge showed that the temperature did not exceed the 0.3ºC at the edge of their mixing zone (Parametrix, 2004).
Under critical conditions there is no predicted violation of the water quality criteria for pH. Therefore, the technology-based effluent limitations for pH were placed in the permit and temperature was not limited.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
Columbia River Temperature At the Cowlitz River (Daily Max Values)
0
5
10
15
20
25
9-Ja
n-01
10-M
ar-0
19-
May
-01
8-Ju
l-01
6-Se
p-01
5-N
ov-0
14-
Jan-
025-
Mar
-02
4-M
ay-0
23-
Jul-0
21-
Sep-
0231
-Oct
-02
Date
Tem
p (
ºC)
Fecal coliform--The numbers of fecal coliform were modeled by simple mixing analysis using the technology-based limit of 400 organisms per 100 ml and a dilution factor of 15.6.
Under critical conditions there is no predicted violation of the Water Quality Standards for Surface Waters with the technology-based limit. Therefore, the technology-based effluent limitation for fecal coliform bacteria was placed in the proposed permit.
Toxic Pollutants--Federal regulations (40 CFR 122.44) require NPDES permits to contain effluent limits for toxic chemicals in an effluent whenever there is a reasonable potential for those chemicals to exceed the surface water quality criteria. This process occurs concurrently with the derivation of technology-based effluent limits. Facilities with technology-based effluent limits defined in regulation are not exempted from meeting the Water Quality Standards for Surface Waters or from having surface water quality-based effluent limits.
The following toxics were determined to be present in the discharge: chlorine, ammonia, arsenic, copper, lead, mercury, zinc, and other heavy metals. In addition, there were minute amounts of other toxic pollutants which were not, however, found in toxic amounts (see Appendix C). A reasonable potential analysis (See Appendix C) was conducted on these parameters to determine whether or not effluent limitations would be required in this permit. For the purpose of establishing pH and ammonia toxicity, pH values from the Columbia were mixed with pH from the Cowlitz for both summer and winter to estimate background water quality. No background data on pH was found in the area immediately upstream of the discharge (the evaluation of mixed pH values may be found in Appendix C). Because the mixed data has too many unknown variables, the Permittee will need to establish the background pH and ammonia in the vicinity of the outfall over the next permit cycle. That is the Department will require the Permittee to measure the actual pH in the Columbia River along with the temperature and ammonia, to determine background concentrations resulting from mixture of the flows of the Columbia and Cowlitz Rivers.
Therefore site specific testing for pH, temperature and ammonia will be required in the permit. The existing permit limits for ammonia will remain in place until new limits can be determined or until the next permit cycle.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Because the possible new ammonia limits calculated from mixing Columbia and Cowlitz River waters (discussed in Appendix C) appears to be low, it would take the Permittee time to apply these limits. Retrofitting equipment needed to apply these lower limits would likely include engineering plans, approval, and construction of new equipment. In addition, there would also need to be adjustments made to the operation of the facility to achieve these low limits. In this same period of time we think it is possible to accurately determine both the true background and what limits are achievable through operation of existing equipment to reduce ammonia.
The permit will have interim ammonia limits based on the 2002 permit and final limits to be determined by a water quality study upstream of the Permittee’s outfall.
The permit will require the Permittee to conduct ambient monitoring in the river upstream of their outfall. The Permittee would likely need to gather the following items:
• Weekly ammonia, • Nearly continuous temperature, and • Daily grab samples of pH during the critical time of day and year.
There must be enough pH data to calculate 90th percentile values. The ambient monitoring must take place as close as possible to the upstream boundary of the mixing zone which is closest to the Longview Fibre outfall. A monitoring plan must be submitted to the Department for approval as required by the permit.
The ammonia criteria calculations, reasonable potential table and limit calculation table are all shown in Appendix C.
The following metals were evaluated in detail: copper, lead, mercury, and zinc. A hardness of 45 mg/L as CaCO3 was used in the metals evaluation. Hardness is used in determining the water quality criteria for the particular metal.
The copper, lead, mercury, and zinc were not found to have a reasonable potential to violate water quality criteria. Copper was sampled many times throughout the sampling period; however, the Permittee’s water supply has under gone a corrosion treatment program which began in June of 2004. The corrosion control resulted in lower amounts of copper entering the treatment plant and found in the effluent. Therefore, only the copper data, following the implementation of the corrosion control, were used in the analysis. The 2002 permit had limits for copper, mercury, and lead. All of the effluent values sampled for these metals were below the limits. The effluent samples for lead were all below detection. The effluent samples for mercury were mostly below detection and a 95th percentile was calculated at 0.10 µg/L. Other metals were sampled; however all had values that were below detection or were not of concern.
WHOLE EFFLUENT TOXICITY
The WET tests during effluent characterization prior to application for this permit indicate that no reasonable potential exists to cause receiving water acute or chronic toxicity, and the Permittee will not be given an acute or chronic WET limit and will only be required to:
Retest the effluent prior to application for permit renewal in order to demonstrate that acute or chronic toxicity has not increased in the effluent.
The Permittee conducted seven chronic and seven acute toxicity tests since 2002 and no acute toxicity was shown in the tests. A slight depression in flathead minnow weight was shown in one of the chronic toxicity tests, which may or may not have been caused by toxicity. However, because only one of the tests was involved, it was determined that a limit would not be required.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority If the Permittee makes process or material changes which, in the Department's opinion, results in an increased potential for effluent toxicity, then the Department may require additional effluent characterization in a regulatory order, by permit modification, or in the permit renewal. Toxicity is assumed to have increased if WET testing conducted for submission with a permit application fails to meet the performance standards in WAC 173-205-020, "whole effluent toxicity performance standard." The Permittee may demonstrate to the Department that changes have not increased effluent toxicity by performing additional WET testing after the time the process or material changes have been made.
HUMAN HEALTH
Washington’s water quality standards now include 91 numeric health-based criteria that must be considered in NPDES permits. These criteria were promulgated for the state by the U.S. EPA in its National Toxics Rule (Federal Register, Volume 57, No. 246, Tuesday, December 22, 1992).
The Department has determined that the effluent is likely to have chemicals of concern for human health. The discharger's high priority status is based on the discharger’s status as a major discharger.
A determination of the discharge's potential to cause an exceedance of the water quality standards was conducted as required by 40 CFR 122.44(d). The reasonable potential determination was evaluated with procedures given in the Technical Support Document for Water Quality-Based Toxics Control (EPA/505/2-90-001) and the Department's Permit Writer's Manual (Ecology Publication 92-109, July, 1994). The determination indicated that the discharge has no reasonable potential to cause a violation of water quality standards, thus an effluent limit is not warranted.
SEDIMENT QUALITY
The Department has promulgated aquatic sediment standards (Chapter 173-204 WAC) to protect aquatic biota and human health. These standards state that the Department may require Permittees to evaluate the potential for the discharge to cause a violation of applicable standards (WAC 173-204-400).
The Department has been unable to determine at this time the potential for this discharge to cause a violation of sediment quality standards. If the Department determines in the future that there is a potential for violation of the Sediment Quality Standards, an order will be issued to require the Permittee to demonstrate that either the point of discharge is not an area of deposition or, if the point of discharge is a depositional area, that there is not an accumulation of toxics in the sediments.
GROUND WATER QUALITY LIMITATIONS
The Department has promulgated Ground Water Quality Standards (Chapter 173-200 WAC) to protect uses of ground water. Permits issued by the Department shall be conditioned in such a manner so as not to allow violations of those standards (WAC 173-200-100).
This Permittee has no discharge to ground and therefore no limitations are required based on potential effects to ground water.
COMPARISON OF EFFLUENT LIMITS WITH THE EXISTING PERMIT ISSUED IN 2002
Existing Limits from 2002 Permit
Parameter Average Monthly Average weekly
CBOD5 25 mg/L, 3900 lbs/day 40 mg/L, 5850 lbs/day
TSS 30 mg/L, 4815 lbs/day 45 mg/L, 7223 lbs/day
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
Existing Limits from 2002 Permit
Parameter Average Monthly Average weekly
Fecal Coliform 200/100 ml 400/100 ml
pH Daily minimum is equal to or greater than 6.0 and the daily maximum is less than or equal to 9.0.
Total Ammonia (Summer)
15 mg/L, 3253 lbs/day (May -- Oct)
33.7 mg/L, 7308 lbs/day (May -- Oct)
Total Ammonia (Winter)
22.8 mg/L, 4944 lbs/day (Nov – Apr)
51.5 mg/L, 11,167 lbs/day (Nov – Apr)
Total Residual Chlorine
0.03 mg/L, 7 lbs/day 0.09 mg/L, 20 lbs/day
Copper 11.2 µg/L 16.4 µg/L
Mercury 0.21 µg/L 0.31 µg/L
Lead 3.1 µg/L 4.5 µg/L
Proposed Interim Limits for 2006 Draft Permit
Parameter Average Monthly Average weekly
CBOD5 25 mg/L, 2913 lbs/day 40 mg/L, 4370 lbs/day
TSS 30 mg/L, 3611 lbs/day 45 mg/L, 5417 lbs/day
Fecal Coliform 200/100 ml 400/100 ml
pH Daily minimum is equal to or greater than 6.0 and the daily maximum is less than or equal to 9.0.
Total Ammonia (Summer)
15 mg/L, 3253 lbs/day (May-Oct)
33.7 mg/L 7308 lbs/day (Nov – Apr)
Total Ammonia (Winter)
22.8 mg/L, 4944 lbs/day(June – Sept)
51.5 mg/L, 11,167 lbs/day (Nov – Apr)
Total Residual Chlorine
0.03 mg/L, 7 lbs/day 0.09 mg/L, 20 lbs/day
Copper No Limita No Limita
Mercury No Limita No Limita
Lead No Limita No Limita
aCalculations show that there is “No Reasonable Potential” for a limit at this time.
The proposed limits for the draft permit were changed from the 2000 permit in a couple of areas. The metals limits were removed. New data showed the metals did not have a reasonable potential to pollute.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority The ammonia limits were identified as possibly needing to be lowered. The existing ammonia limits have been left in place until testing has been completed and new limits can be established. It is recommended that the critical season for ammonia be determined. Preliminary data suggests the seasons be changed to June through September for summer and October through May for winter based on temperature. The interim CBOD5 and TSS loading number are lower because one of the secondary clarifiers is out of service. When both of the north-end clarifiers have been replaced and Ecology received a declaration of construction, the final limits will take effect.
Proposed Final Limits for 2006 Draft Permit
Parameter Average Monthly Average weekly
CBOD5 25 mg/L, 3978 lbs/day 40 mg/L, 5867 lbs/day
TSS 30 mg/L, 4815 lbs/day 45 mg/L, 7223 lbs/day
Fecal Coliform 200/100 ml 400/100 ml
pH Daily minimum is equal to or greater than 6.0 and the daily maximum is less than or equal to 9.0.
Total Ammonia (Summer)
15 mg/L, 3253 lbs/day (May-Oct)
33.7 mg/L 7308 lbs/day (Nov – Apr)
Total Ammonia (Winter)
22.8 mg/L, 4944 lbs/day(June – Sept)
51.5 mg/L, 11,167 lbs/day (Nov – Apr)
Total Residual Chlorine 0.03 mg/L, 7 lbs/day 0.09 mg/L, 20 lbs/day
Copper No Limita No Limita
Mercury No Limita No Limita
Lead No Limita No Limita
aCalculations show that there is “No Reasonable Potential” for a limit at this time.
MONITORING REQUIREMENTS
Monitoring, recording, and reporting are required (WAC 173-220-210 and 40 CFR 122.41) to verify that the treatment process is functioning correctly and the effluent limitations are being achieved.
Monitoring is being required to further characterize the effluent. The following parameters are used in the calculations of metals and ammonia toxicity. Temperature should be monitored using continuous reading thermisters and the alkalinity and hardness should be monitored for only a short span of a couple of months. However, the exact monitoring details will be determined in a Receiving Water Study Plan (see S9 of the Permit).
Monitoring of sludge quantity and quality is necessary to determine the appropriate uses of the sludge. Sludge monitoring is required by the current state and local solid waste management program and also by EPA under 40 CFR 503.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority The monitoring schedule is detailed in the proposed permit under Condition S.2. Specified monitoring frequencies take into account the quantity and variability of the discharge, the treatment method, past compliance, significance of pollutants, and cost of monitoring. The required monitoring frequency is consistent with agency guidance given in the current version of Ecology’s Permit Writer's Manual (July 1994) for an activated sludge facility of this volume.
Additional monitoring is required in order to further characterize the effluent. These monitored pollutants could have a significant impact on the quality of the surface water.
Additional monitoring, called reapplication monitoring in the permit, is required to prepare the Permittee to meet the requirements of the next permit application.
As a non-delegated pretreatment POTW, the Three Rivers Regional Wastewater Plant is required to have influent, primary clarifier effluent, final effluent, and sludge sampled for toxic pollutants in order to characterize the industrial input. Sampling is also done to determine if pollutants interfere with the treatment process or pass through the plant to the sludge or the receiving water. The monitoring data will be used by the Three Rivers Plant to rework the local limits which commercial and industrial users must meet. The individual jurisdictions (Longview, Kelso, Beacon Hill, and Cowlitz County) must codify these limits, so as to be able to enforce against industrial users that send waste water to the plant. These limits are necessary to protect the surface water, the wastewater plant, operators, and the collection system. The Department can assist the plant and jurisdictions in this task.
EFFLUENT LIMITS BELOW QUANTITATION OR DETECTION
For maximum daily effluent limits, if the measured effluent concentration is below the Quantitation Level, the Permittee reports NQ for non-quantifiable. For average monthly effluent limits, all effluent concentrations below the Quantitation Level but above the Method Detection Level are used as reported for calculating the average monthly value.
The Method Detection Level (MDL) is the minimum concentration of an analyte that can be measured and reported with a 99 percent confidence that its concentration is greater than zero as determined by a specific laboratory method. For maximum daily limits, if the concentrations are below the MDL, the Permittee must report ND for non-detectable. For average monthly limits, all values above the MDL are used as reported and all values below the MDL are calculated as zero.
At this time there are no recommended limits below the quantitation or detection levels.
LAB ACCREDITATION
With the exception of certain parameters the permit requires all monitoring data to be prepared by a laboratory registered or accredited under the provisions of Chapter 173-50 WAC, Accreditation of Environmental Laboratories. The laboratory at this facility is accredited for: General Chemistry and micro-biology, which includes BOD/CBOD, total chlorine residual, dissolved oxygen, pH, total suspended solids, and fecal coliform. The laboratory is accredited through February 10, 2007.
OTHER PERMIT CONDITIONS
REPORTING AND RECORDKEEPING The conditions of S3 are based on the authority to specify any appropriate reporting and recordkeeping requirements to prevent and control waste discharges (WAC 173-220-210).
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority PREVENTION OF FACILITY OVERLOADING
Overloading of the treatment plant is a violation of the terms and conditions of the permit. To prevent this from occurring, RCW 90.48.110 and WAC 173-220-150 require the Permittee to take the actions detailed in proposed permit requirement S.4 to plan expansions or modifications before existing capacity is reached and to report and correct conditions that could result in new or increased discharges of pollutants. Condition S.4 restricts the amount of flow.
OPERATION AND MAINTENANCE (O&M)
The proposed permit contains condition S.5 as authorized under RCW 90.48.110, WAC 173-220-150, Chapter 173-230 WAC, and WAC 173-240-080. It is included to ensure proper operation and regular maintenance of equipment, and to ensure that adequate safeguards are taken so that constructed facilities are used to their optimum potential in terms of pollutant capture and treatment.
The Three River Regional Wastewater Plant has been up to date on the O&M Manuals. However, there have been no manuals submitted for the collection system operated and maintained by the individual jurisdictions. These O&M Manuals for jurisdictions should include operation of pump stations; work on reducing inflow and infiltration, prevention of possible overflows, etc. The procedures discussed in O&M Manuals would also include what to do about overflows, pipe failures and testing of submerged lines. These O&M procedures have never been documented for the collection system elements controlled by the jurisdictions included under this permit.
The permit will therefore have requirements for each jurisdiction to do for their portion of the O&M Manual. In the past, I/I reports were written by the Three Rivers staff which relied upon each jurisdiction to submit data to them. The Tree Rivers staff may still coordinate with the jurisdictions to compile the I/I reports, but it will also be the responsibility of each jurisdiction to submit the data and report in a timely manner. The age of the collection system has not been recently documented. Portions of the collection system are assumed to be fairly old. These older areas of the system were likely constructed using techniques such as concrete or asbestos pipes with oakum packing and/or have numerous manholes which were not installed using modern materials. Leaks are anticipated to be present in significant quantities or in sensitive locations. The permit will require characterization of the size and location of leaks as noted below. Three good references to aid in these tasks are: 1) American Society of Civil Engineers and Water Environment Federation Manual of Practice FD-6. Existing Sewer Evaluation and Rehabilitation, 2) U.S. Environmental Protection Agency. Handbook for Sewer System Infrastructure Analysis and Rehabilitation. EPA/625/6-91/030. 1991, and 3) Washington State Department of Transportation. Standard Specifications for Road, Bridge, and Municipal Construction 2002. Due to the age and construction methods employed during installation of the collection system, leaks are expected to be present. The permit will require the collection system to be characterized for the presence of leaks, including:
• How much of the annual average and peak daily flow under worst conditions (inflow or infiltration) can be attributed to leaks?
• Where are the (individual) leaks? • How large is each leak or how much inflow or infiltration does a run of sewer contribute?
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority • Are the force mains and/or inverted siphons experiencing exfiltration? Following characterization of the leaks, corrective actions may be required. Typically this would be done through an administrative order following review of the assessment.
RESIDUAL SOLIDS HANDLING
To prevent water quality problems the Permittee is required in permit condition S7. to store and handle all residual solids (grit, screenings, scum, sludge, and other solid waste) in accordance with the requirements of RCW 90.48.080 and State Water Quality Standards.
The final use and disposal of sewage sludge from this facility is regulated by U.S. EPA under 40 CFR 503, and by the Department under Chapter 70.95J RCW, Chapter 173-308 WAC “Biosolids Management,” and Chapter 173-350 WAC “Solid Waste Handling Standards.” The disposal of other solid waste is under the jurisdiction of the Cowlitz County Health Department.
The facility produces 2200 dry tons of biosolids which is all composted and sent to the local landfill to be used for daily cover.
Requirements for monitoring sewage sludge and recordkeeping are included in this permit. This information will by used by the Department to develop or update local limits and is also required under 40 CFR 503.
PRETREATMENT
The Permittee shall, in consultation with the Department, reevaluate its local limits in order to prevent pass through or interference. The Three Rivers facility has local limits for some of its industrial dischargers. Upon determination by the Department that any pollutant present causes pass through or interference, or exceeds established sludge standards, the Permittee shall establish new local limits or revise existing local limits as required by 40 CFR 403.5. In addition, the Department may require revision or establishment of local limits for any pollutant that causes an exceedance of the Water Quality Standards or established effluent limits, or that causes whole effluent toxicity. The determination by the Department shall be in the form of an Administrative Order. In order to develop these local limits, the Department will provide environmental criteria or limits for the various pollutants of concern.
The Department may modify this permit to incorporate additional requirements relating to the establishment and enforcement of local limits for pollutants of concern. Any permit modification is subject to formal due process procedures pursuant to state and federal law and regulation.
Additional monitoring, called reapplication monitoring in the permit, is required to prepare the Permittee to meet the requirements of the next permit application. Some of this monitoring can be used to determine what pollutants should be a concern for the POTW and for which local limits should be developed.
As a POTW receiving non-domestic wastewater, but without a delegated pretreatment program, the Three Rivers Regional Wastewater Plant must collect data from which to update or develop new local limits so that the Department can impose these limits to protect the POTW. To facilitate local limits, the POTW must collect data on the concentrations of pollutants in the influent, final effluent, and sludge for toxic pollutants. This will allow the POTW to quantify their industrial loadings. Sampling is also done to determine if pollutants interfere with the treatment process or pass through the plant to the sludge or the receiving water. The monitoring data will be used by the Three Rivers Plant to update or develop new local limits which commercial and industrial users must meet.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority The individual jurisdictions (Longview, Kelso, Beacon Hill, and Cowlitz County) must then codify the proposed local limits in order to facilitate the Department’s control of industrial users within their respective service areas. Local limits are “Pretreatment Standards” under section 301 of the Clean Water Act. The limits are necessary for the Department to, in turn; write permits which are protective of the surface water, the wastewater plant, operators, and the collection system. The Department can assist the plant and jurisdictions in this task through review of the calculations, laying out options and alternatives, and providing a format for a pretreatment ordinance.
Local jurisdictions must also codify provisions which enable them to compel production of information. This information is necessary to:
• determine whether any sewer customer meets the definition of a non-domestic discharger,
• prohibit the use of sewer services before any non-domestic discharger has applied for a permit, and
• prohibit sewer service before any person meeting the definition of a “Significant Industrial User” has obtained a permit from the Department.
Periodically, Local jurisdictions must complete an Industrial User Survey (as described below) to confirm that all sources of non-domestic wastewater that merit a permit have been permitted by the Department. Such a requirement is contained in this permit.
FEDERAL AND STATE PRETREATMENT PROGRAM REQUIREMENTS
Under the terms of the addendum to the “Memorandum of Understanding between Washington Department of Ecology and the United States Environmental Protection Agency, Region 10” (1986), the Department has been delegated authority to administer the Pretreatment Program (i.e. act as the Approval Authority for oversight of delegated POTWs). Under this delegation of authority, the Department has exercised the option of issuing wastewater discharge permits for significant industrial users discharging to POTWs which have not been delegated authority to issue wastewater discharge permits.
There are a number of functions required by the Pretreatment Program which the Department is delegating to such POTWs because they are in a better position to implement the requirements (e.g. tracking the number and general nature of industrial dischargers to the sewerage system). The requirements for a Pretreatment Program are contained in Title 40, part 403 of the Code of Federal Regulations. Under the requirements of the Pretreatment Program [40 CFR 403.8(f)(1)(iii)], the Department is required to approve, condition, or deny new discharges or a significant increase in the discharge for existing significant industrial users (SIUs) [40 CFR 403.8 (f)(1)(i)].
The Department is responsible for issuing State Waste Discharge Permits to SIUs and other industrial users of the Permittee's sewer system. Industrial dischargers must obtain these permits from the Department prior to the Permittee accepting the discharge [WAC 173-216-110(5)] (Industries discharging wastewater that is similar in character to domestic wastewater are not required to obtain a permit. Such dischargers should contact the Department to determine if a permit is required.). Industrial dischargers need to apply for a State Waste Discharge Permit sixty (60) days prior to commencing discharge. The conditions contained in the permits will include any applicable conditions for categorical discharges, loading limitations included in contracts with the POTW, and other conditions necessary to assure compliance with state water quality standards and biosolids standards.
The Department requires this POTW to fulfill some of the functions required for the Pretreatment Program in the NPDES permit (e.g. tracking the number and general nature of industrial dischargers to the sewage system). The POTW's NPDES permit will require that all SIUs currently discharging to the POTW be identified and notified of the requirement to apply for a wastewater discharge permit from the
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Department. None of the obligations imposed on the POTW relieve an industrial or commercial discharger of its primary responsibility for obtaining a wastewater discharge permit (if required), including submittal of engineering reports prior to construction or modification of facilities [40 CFR 403.12(j) and WAC 173-216-070 and WAC 173-240-110, et seq.].
WASTEWATER PERMIT REQUIRED
RCW 90.48 and WAC 173-216-040 require SIUs to obtain a permit prior to discharge of industrial waste to the Permittee's sewerage system. This provision prohibits the POTW from accepting industrial wastewater from any such dischargers without authorization from the Department.
REQUIREMENTS FOR ROUTINE IDENTIFICATION AND REPORTING OF INDUSTRIAL USERS
The NPDES permit requires non-delegated POTWs to " take continuous, routine measures to identify all existing, new, and proposed SIUs and potential significant industrial users (PSIUs) discharging to the Permittee's sewerage system." Examples of such routine measures include regular review of business tax licenses for existing businesses and review of water billing records and existing connection authorization records. System maintenance personnel can also be diligent during performance of their jobs in identifying and reporting as-yet unidentified industrial dischargers. Local newspapers, telephone directories, and word-of-mouth can also be important sources of information regarding new or existing discharges. The POTW is required to notify an industrial discharger, in writing, of their responsibilities regarding application for a state waste discharge permit and to send a copy of the written notification to the Department. The Department will then take steps to solicit a State waste discharge permit application.
REQUIREMENTS FOR PERFORMING AN INDUSTRIAL USER SURVEY
This POTW has the potential to serve significant industrial or commercial users and is required to perform an Industrial User Survey. The goal of this survey is to develop a list of SIUs and PSIUs, and of equal importance, to provide sufficient information about industries which discharge to the POTW, to determine which of them require issuance of state waste discharge permits or other regulatory controls. An Industrial User Survey is an important part of the regulatory process used to prevent interference with treatment processes at the POTW and to prevent the exceedance of water quality standards. The Industrial User Survey also can be used to contribute to the maintenance of sludge quality, so that sludge can be a useful biosolids product rather than an expensive waste problem. An Industrial User Survey is a rigorous method for identifying existing, new, and proposed significant industrial users and potential significant industrial users.
DUTY TO ENFORCE DISCHARGE PROHIBITIONS
This provision in the permit prohibits the POTW from authorizing or permitting an industrial discharger to discharge certain types of waste into the sanitary sewer. The first portion of the provision prohibits acceptance of pollutants which cause pass through or interference. The definitions of pass-through and interference are in Appendix B of the fact sheet..
The second portion of this provision prohibits the POTW from accepting certain specific types of wastes, namely those which are explosive, flammable, excessively acidic, basic, otherwise corrosive, or obstructive to the system. In addition, wastes with excessive BOD, petroleum based oils, or which result in toxic gases is prohibited to be discharged. The regulatory basis for these prohibitions is 40 CFR Part 403, with the exception of the pH provisions which are based on WAC 173-216-060.
The third portion of this provision prohibits certain types of discharges unless the POTW receives prior authorization from the Department. The discharges include cooling water in significant volumes, stormwater and other direct inflow sources, and wastewaters significantly affecting system hydraulic loading, which do not require treatment.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority SUPPORT BY THE DEPARTMENT FOR DEVELOPING PARTIAL PRETREATMENT PROGRAM BY POTW
The Department has committed to providing technical and legal assistance to the Permittee in fulfilling these joint obligations, in particular assistance with developing an adequate sewer use ordinance, notification procedures, enforcement guidelines, and developing local limits and inspection procedures.
OUTFALL EVALUATION
Proposed permit condition S.12 requires the Permittee to conduct an outfall inspection and submit a report detailing the findings of that inspection. The purpose of the inspection is to determine the condition of the discharge pipe and diffusers and to determine if sediment is accumulating in the vicinity of the outfall.
GENERAL CONDITIONS
General Conditions are based directly on state and federal law and regulations and have been standardized for all individual municipal NPDES permits issued by the Department.
PERMIT ISSUANCE PROCEDURES
PERMIT MODIFICATIONS
The Department may modify this permit to impose numerical limitations, if necessary to meet Water Quality Standards, Sediment Quality Standards, or Ground Water Standards, based on new information obtained from sources such as inspections, effluent monitoring, outfall studies, and effluent mixing studies.
The Department may also modify this permit as a result of new or amended state or federal regulations.
RECOMMENDATION FOR PERMIT ISSUANCE
This proposed permit meets all statutory requirements for authorizing a wastewater discharge, including those limitations and conditions believed necessary to protect human health, aquatic life, and the beneficial uses of waters of the State of Washington. The Department proposes that this permit be issued for five (5) years.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
REFERENCES FOR TEXT AND APPENDICES
Gibbs & Olson Inc.
1999. Cowlitz Sewer Operating Board. System Improvements Project, Facility Plan/Pre-Design Report. Longview and Olympia, WA. With ACE Consultants, Inc., Corrollo Engineers.
2000. Cowlitz Sewer Operating Board. System Improvements Project, Facility Plan/Pre-Design Report, SEPA Supplement. Longview and Olympia, WA. With ACE Consultants, Inc., Corrollo Engineers.
Cosmopolitan Engineering Group.
1999. Mixing Zone Study, Cowlitz Water Pollution Control. Tacoma, WA. No. COW002.
Environmental Protection Agency (EPA)
1992. National Toxics Rule. Federal Register, V. 57, No. 246, Tuesday, December 22, 1992.
1991. Technical Support Document for Water Quality-based Toxics Control. EPA/505/2-90-001.
1988. Technical Guidance on Supplementary Stream Design Conditions for Steady State Modeling. USEPA Office of Water, Washington, D.C.
1985. Water Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in Surface and Ground Water. EPA/600/6-85/002a.
1983. Water Quality Standards Handbook. USEPA Office of Water, Washington, D.C.
Metcalf and Eddy.
1991. Wastewater Engineering, Treatment, Disposal, and Reuse. Third Edition.
Parametrix.
2004. Supplemental Report. Temperature Study Results for Critical Period, June 15 to September 15, 2003 for Columbia River and White/Stuck River. Project No. 215-3276-002(02). Sumner, WA 98390-1516.
Tsivoglou, E.C., and J.R. Wallace.
1972. Characterization of Stream Reaeration Capacity. EPA-R3-72-012. (Cited in EPA 1985 op.cit.)
Washington State Department of Ecology.
Laws and Regulations( http://www.ecy.wa.gov/laws-rules/index.html )
Permit and Wastewater Related Information (http://www.ecy.wa.gov/programs/wq/wastewater/index.html
Washington State Department of Ecology.
1994. Permit Writer’s Manual. Publication Number 92-109
Water Pollution Control Federation.
1976. Chlorination of Wastewater.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Williams, J.R. and H.E. Pearson
1985. Streamflow Statistics and Drainage-Basin Characteristics for the Southwestern and Eastern Regions, Washington. Volume 1. Southwestern Washington. U.S Geological Survey Open-File Report 84-145-A. Tacoma, WA.
Wright, R.M., and A.J. McDonnell.
1979. In-stream Deoxygenation Rate Prediction. Journal Environmental Engineering Division, ASCE. 105(EE2). (Cited in EPA 1985 op.cit.)
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
APPENDIX A--PUBLIC INVOLVEMENT INFORMATION
The Department has tentatively determined to reissue a permit to the applicant listed on page 1 of this fact sheet. The permit contains conditions and effluent limitations which are described in the rest of this fact sheet.
Public notice of application was published on June 20, 2005, June 30, 2005, June 19, 2006, and June 26, 2006, in the Longview Daily News to inform the public that an application had been submitted and to invite comment on the reissuance of this permit.
The Department will publish a Public Notice of Draft (PNOD) on January 11, 2007, in the Longview Daily News to inform the public that a draft permit and fact sheet are available for review. Interested persons are invited to submit written comments regarding the draft permit. The draft permit, fact sheet, and related documents are available for inspection and copying between the hours of 8:00 a.m. and 5:00 p.m. weekdays, by appointment, at the regional office listed below. Written comments should be mailed to:
Carey Cholski Department of Ecology Southwest Regional Office P.O. Box 47775 Olympia, WA 98504-7775
Any interested party may comment on the draft permit or request a public hearing on this draft permit within the thirty (30)-day comment period to the address above. The request for a hearing shall indicate the interest of the party and the reasons why the hearing is warranted. The Department will hold a hearing if it determines there is a significant public interest in the draft permit (WAC 173-220-090). Public notice regarding any hearing will be circulated at least thirty (30) days in advance of the hearing. People expressing an interest in this permit will be mailed an individual notice of hearing (WAC 173-220-100).
Comments should reference specific text followed by proposed modification or concern when possible. Comments may address technical issues, accuracy and completeness of information, the scope of the facility’s proposed coverage, adequacy of environmental protection, permit conditions, or any other concern that would result from issuance of this permit.
The Department will consider all comments received within thirty (30) days from the date of public notice of draft indicated above, in formulating a final determination to issue, revise, or deny the permit. The Department's response to all significant comments is available upon request and will be mailed directly to people expressing an interest in this permit.
Further information may be obtained from the Department by telephone at (360) 407-6554, or by writing to the address listed above.
This permit and fact sheet were written by Eric Schlorff.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
APPENDIX B--GLOSSARY
Acute Toxicity--The lethal effect of a pollutant on an organism that occurs within a short period of time, usually 48 to 96 hours.
AKART-- An acronym for “all known, available, and reasonable methods of prevention, control, and treatment”.
Ambient Water Quality--The existing environmental condition of the water in a receiving water body.
Ammonia--Ammonia is produced by the breakdown of nitrogenous materials in wastewater. Ammonia is toxic to aquatic organisms, exerts an oxygen demand, and contributes to eutrophication. It also increases the amount of chlorine needed to disinfect wastewater.
Average Monthly Discharge Limitation --The highest allowable average of daily discharges over a calendar month, calculated as the sum of all daily discharges measured during a calendar month divided by the number of daily discharges measured during that month (except in the case of fecal coliform). The daily discharge is calculated as the average measurement of the pollutant over the day.
Average Weekly Discharge Limitation -- The highest allowable average of daily discharges over a calendar week, calculated as the sum of all daily discharges measured during a calendar week divided by the number of daily discharges measured during that week. The daily discharge is calculated as the average measurement of the pollutant over the day.
Best Management Practices (BMPs)--Schedules of activities, prohibitions of practices, maintenance procedures, and other physical, structural and/or managerial practices to prevent or reduce the pollution of waters of the State. BMPs include treatment systems, operating procedures, and practices to control: plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. BMPs may be further categorized as operational, source control, erosion and sediment control, and treatment BMPs.
BOD5--Determining the Biochemical Oxygen Demand of an effluent is an indirect way of measuring the quantity of organic material present in an effluent that is utilized by bacteria. The BOD5 is used in modeling to measure the reduction of dissolved oxygen in a receiving water after effluent is discharged. Stress caused by reduced dissolved oxygen levels makes organisms less competitive and less able to sustain their species in the aquatic environment. Although BOD is not a specific compound, it is defined as a conventional pollutant under the federal Clean Water Act.
Bypass--The intentional diversion of waste streams from any portion of a treatment facility.
CBOD5 – The quantity of oxygen utilized by a mixed population of microorganisms acting on the nutrients in the sample in an aerobic oxidation for five days at a controlled temperature of 20 degrees Celsius, with an inhibitory agent added to prevent the oxidation of nitrogen compounds. The method for determining CBOD5 is given in 40 CFR Part 136.
Chlorine--Chlorine is used to disinfect wastewaters of pathogens harmful to human health. It is also extremely toxic to aquatic life.
Chronic Toxicity--The effect of a pollutant on an organism over a relatively long time, often 1/10 of an organism's lifespan or more. Chronic toxicity can measure survival, reproduction or growth rates, or other parameters to measure the toxic effects of a compound or combination of compounds.
Clean Water Act (CWA)--The Federal Water Pollution Control Act enacted by Public Law 92-500, as amended by Public Laws 95-217, 95-576, 96-483, 97-117; USC 1251 et seq.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Combined Sewer Overflow (CSO)--The event during which excess combined sewage flow caused by
inflow is discharged from a combined sewer, rather than conveyed to the sewage treatment plant because either the capacity of the treatment plant or the combined sewer is exceeded.
Compliance Inspection - Without Sampling--A site visit for the purpose of determining the compliance of a facility with the terms and conditions of its permit or with applicable statutes and regulations.
Compliance Inspection - With Sampling--A site visit to accomplish the purpose of a Compliance Inspection - Without Sampling and as a minimum, sampling and analysis for all parameters with limits in the permit to ascertain compliance with those limits; and, for municipal facilities, sampling of influent to ascertain compliance with the percent removal requirement. Additional sampling may be conducted.
Composite Sample--A mixture of grab samples collected at the same sampling point at different times, formed either by continuous sampling or by mixing a minimum of four discrete samples. May be "time-composite"(collected at constant time intervals) or "flow-proportional" (collected either as a constant sample volume at time intervals proportional to stream flow, or collected by increasing the volume of each aliquot as the flow increased while maintaining a constant time interval between the aliquots).
Construction Activity--Clearing, grading, excavation and any other activity which disturbs the surface of the land. Such activities may include road building, construction of residential houses, office buildings, or industrial buildings, and demolition activity.
Continuous Monitoring –Uninterrupted, unless otherwise noted in the permit.
Critical Condition--The time during which the combination of receiving water and waste discharge conditions have the highest potential for causing toxicity in the receiving water environment. This situation usually occurs when the flow within a water body is low, thus, its ability to dilute effluent is reduced.
Dilution Factor--A measure of the amount of mixing of effluent and receiving water that occurs at the boundary of the mixing zone. Expressed as the inverse of the effluent fraction e.g., a dilution factor of 10 means the effluent comprises 10% by volume and the receiving water 90%.
Engineering Report--A document which thoroughly examines the engineering and administrative aspects of a particular domestic or industrial wastewater facility. The report shall contain the appropriate information required in WAC 173-240-060 or 173-240-130.
Fecal Coliform Bacteria--Fecal coliform bacteria are used as indicators of pathogenic bacteria in the effluent that are harmful to humans. Pathogenic bacteria in wastewater discharges are controlled by disinfecting the wastewater. The presence of high numbers of fecal coliform bacteria in a water body can indicate the recent release of untreated wastewater and/or the presence of animal feces.
Grab Sample--A single sample or measurement taken at a specific time or over as short period of time as is feasible.
Industrial User-- A discharger of wastewater to the sanitary sewer which is not sanitary wastewater or is not equivalent to sanitary wastewater in character.
Industrial Wastewater--Water or liquid-carried waste from industrial or commercial processes, as distinct from domestic wastewater. These wastes may result from any process or activity of industry, manufacture, trade or business, from the development of any natural resource, or from animal operations such as feed lots, poultry houses, or dairies. The term includes contaminated storm water and, also, leachate from solid waste facilities.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Infiltration and Inflow (I/I)--"Infiltration" means the addition of ground water into a sewer through
joints, the sewer pipe material, cracks, and other defects. "Inflow" means the addition of precipitation-caused drainage from roof drains, yard drains, basement drains, street catch basins, etc., into a sewer.
Interference -- A discharge which, alone or in conjunction with a discharge or discharges from other sources, both:
Inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal and;
Therefore is a cause of a violation of any requirement of the POTW's NPDES permit (including an increase in the magnitude or duration of a violation) or of the prevention of sewage sludge use or disposal in compliance with the following statutory provisions and regulations or permits issued there under (or more stringent State or local regulations): Section 405 of the Clean Water Act, the Solid Waste Disposal Act (SWDA) (including title II, more commonly referred to as the Resource Conservation and Recovery Act (RCRA), and including State regulations contained in any State sludge management plan prepared pursuant to subtitle D of the SWDA), sludge regulations appearing in 40 CFR Part 507, the Clean Air Act, the Toxic Substances Control Act, and the Marine Protection, Research and Sanctuaries Act.
Major Facility--A facility discharging to surface water with an EPA rating score of > 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact.
Maximum Daily Discharge Limitation--The highest allowable daily discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. The daily discharge is calculated as the average measurement of the pollutant over the day.
Method Detection Level (MDL)--The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is above zero and is determined from analysis of a sample in a given matrix containing the analyte.
Minor Facility--A facility discharging to surface water with an EPA rating score of < 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact.
Mixing Zone--A volume that surrounds an effluent discharge within which water quality criteria may be exceeded. The area of the authorized mixing zone is specified in a facility's permit and follows procedures outlined in State regulations (Chapter 173-201A WAC).
National Pollutant Discharge Elimination System (NPDES)--The NPDES (Section 402 of the Clean Water Act) is the Federal wastewater permitting system for discharges to navigable waters of the United States. Many states, including the State of Washington, have been delegated the authority to issue these permits. NPDES permits issued by Washington State permit writers are joint NPDES/State permits issued under both State and Federal laws.
Pass through -- A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or in conjunction with a discharge or discharges from other sources, is a cause of a violation of any requirement of the POTW's NPDES permit (including an increase in the magnitude or duration of a violation), or which is a cause of a violation of State water quality standards.
pH--The pH of a liquid measures its acidity or alkalinity. A pH of 7 is defined as neutral, and large variations above or below this value are considered harmful to most aquatic life.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Potential Significant Industrial User--A potential significant industrial user is defined as an Industrial
User which does not meet the criteria for a Significant Industrial User, but which discharges wastewater meeting one or more of the following criteria:
a. Exceeds 0.5 % of treatment plant design capacity criteria and discharges <25,000 gallons per day or;
b. Is a member of a group of similar industrial users which, taken together, have the potential to cause pass through or interference at the POTW (e.g. facilities which develop photographic film or paper, and car washes).
The Department may determine that a discharger initially classified as a potential significant industrial user should be managed as a significant industrial user.
Quantitation Level (QL)-- A calculated value five times the MDL (method detection level).
Significant Industrial User (SIU)--
1) All industrial users subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 40 CFR Chapter I, Subchapter N and;
2) Any other industrial user that: discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, noncontact cooling, and boiler blow-down wastewater); contributes a process waste stream that makes up 5 percent or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant; or is designated as such by the Control Authority* on the basis that the industrial user has a reasonable potential for adversely affecting the POTW's operation or for violating any pretreatment standard or requirement (in accordance with 40 CFR 403.8(f)(6)).
Upon finding that the industrial user meeting the criteria in paragraph 2, above, has no reasonable potential for adversely affecting the POTW's operation or for violating any pretreatment standard or requirement, the Control Authority* may at any time, on its own initiative or in response to a petition received from an industrial user or POTW, and in accordance with 40 CFR 403.8(f)(6), determine that such industrial user is not a significant industrial user.
*The term "Control Authority" refers to the Washington State Department of Ecology in the case of non-delegated POTWs or to the POTW in the case of delegated POTWs.
State Waters--Lakes, rivers, ponds, streams, inland waters, underground waters, salt waters, wetlands, and all other surface waters and watercourses within the jurisdiction of the state of Washington.
Stormwater--That portion of precipitation that does not naturally percolate into the ground or evaporate, but flows via overland flow, interflow, pipes, and other features of a storm water drainage system into a defined surface water body, or a constructed infiltration facility.
Technology-based Effluent Limit--A permit limit that is based on the ability of a treatment method to reduce the pollutant.
Total Suspended Solids (TSS)--Total suspended solids are the particulate materials in an effluent. Large quantities of TSS discharged to a receiving water may result in solids accumulation. Apart from any toxic effects attributable to substances leached out by water, suspended solids may kill fish, shellfish, and other aquatic organisms by causing abrasive injuries and by clogging the gills and respiratory passages of various aquatic fauna. Indirectly, suspended solids can screen out light and can promote and maintain the development of noxious conditions through oxygen depletion.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Upset--An exceptional incident in which there is unintentional and temporary noncompliance with
technology-based permit effluent limitations because of factors beyond the reasonable control of the Permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, lack of preventative maintenance, or careless or improper operation.
Water Quality-based Effluent Limit--A limit on the concentration or mass of an effluent parameter that is intended to prevent the concentration of that parameter from exceeding its water quality criterion after it is discharged into a receiving water.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
APPENDIX C--TECHNICAL CALCULATIONS
Several of the Excel® spreadsheet tools used to evaluate a discharger’s ability to meet Washington State water quality standards can be found on the Department’s homepage at (http://www.ecy.wa.gov/programs/wq/wastewater/index.html
Discussion of Ammonia and pH as a Result of the Mixture of Columbia and Cowlitz Rivers: The estimate of how much Cowlitz River water mixes into the Columbia was estimated through visual interpolation of aerial photos. These values which follow should be determined with site specific sampling. This was therefore a rough estimate of the Cowlitz to Columbia River dilution which may in reality range from almost no Cowlitz River water to a more complete mix. The Cowlitz River appears to enter into the Columbia River to a certain width, visually discernable on some aerial photos. It was assumed that the flow of the Columbia that actually mixes with the Cowlitz is approximately 15 percent in the summer to 5 percent in the winter. This percentage was then cut by 2/3 because the flow was confined to the shallow area of the bank. A seasonal variation was also determined where the Cowlitz River makes up a greater percentage of the flow in the winter months compared to the Columbia. The winter dilution factor was therefore twice the summer factor. The end result is that the dilution of the Cowlitz River to the Columbia River was estimated to be 7.2:1 in the winter and 3.6:1 in the summer The pH of the Columbia River has been shown to be high and the pH of the Cowlitz is fairly neutral. The result of mixing these flows using winter flows is a pH of 8.23 which is still high, in that it will drive-up ammonia toxicity, but not toxic because of the pH directly. The pH at marker 59 on the Columbia River (near Woodland) was the nearest Columbia River point with a fair sample size of 24 points and fairly recent data from June 2000 through October 2003. The pH at this location was consistent with the pH further upstream on the Columbia. The 90th percentile pH at this location was 8.44 S.U. over winter months. The pH from the Cowlitz River was 7.60 S.U. in the winter months. The mixing of the summer pH values for the Columbia and Cowlitz rivers results in a pH of 7.93. A site-specific ammonia value for the Columbia River was used as the background (0.012 mg/L NH3-N maximum value determined from sampling near the outfall in July 2004). Temperature from the Cowlitz was not mixed with the Columbia because the temperature values were from continuously recording thermisters that were placed upstream of the Longview Fibre Outfall.
The determination of the reasonable potential for ammonia to exceed the water quality criteria was evaluated with procedures given in EPA, 1991 (Appendix C) at the critical condition. The critical conditions in this case were evaluated for the summer season (June through September) and the winter season (October through May). Although the warm summer temperatures are critical to ammonia toxicity, the high pH is much more critical. It appears that the high winter pH of 8.23 SU has a great effect on the toxicity of ammonia. The parameters used in the critical condition modeling are as follows: acute dilution factor 6.4 (Permittee’s discharge to the Columbia), chronic dilution factor 15.6, summer receiving water temperature 21.78oC, and winter receiving water temperature 14.44ºC. As noted above, the pH background values were mixed in order to take in to affect the Cowlitz River. The ammonia in the effluent, as shown in the graph above, has had values well above 20 mg/L in the last year. The high effluent ammonia can also increase the likelihood of the reasonable potential not being met.
A possible outcome of the high pH and high effluent ammonia would be lower ammonia limits. The pH could range from values near that to the Cowlitz River to near that of the Columbia River. There may also be some small influence of the Longview Fibre discharge but with Longview Fibre’s dilution of 120:1 it is likely to be very small. The true mixing of the Cowlitz River to the Columbia River is unknown. If the background pH is that of the Cowlitz, no ammonia limits will be required.
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Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority The most stringent and lowest value of ammonia calculated at this time are based on a partial mix of the Cowlitz and Columbia River pH and site specific ammonia and temperature:
Ammonia based on Cowlitz River pH
Average Monthly Max Daily
Winter (October through May) No Limit Requireda No Limit Requireda
Summer (June through September) No Limit Requireda No Limit Requireda
aNo ammonia limit would be required as a result of a “No Reasonable Potential.”
Ammonia Partial Mix Scenario A of Columbia River and Cowlitz (Rough Guess at this time without site specific information and no Longview Fibre Discharge)
Average Monthly Max Daily
Winter (October through May) 10 mg/L, 2168 lbs/day 20 mg/L
Summer (June through September) 11 mg/L, 2385 lbs/day 23 mg/L
pH (mixed) and Near Actual Temperature Values Used in Above Scenario
pH (90th Percentile) Temperature (90th percentile)
Winter max pH and Temperature 8.23 S.U 14.44ºC
Summer max pH and Temperature 7.93 S.U 21.78ºC
Ammonia Partial Mix Scenario B (One-Half of Columbia River Flow and All of Cowlitz River Flow Without the Longview Fibre Discharge)
Average Monthly Max Daily
Winter (October through May) 7 mg/L, 1518 lbs/day 14 mg/L
Summer (June through September) 10 mg/L, 2168 lbs/day 21 mg/L
pH (mixed) and Near Actual Temperature Used in Above Scenario
pH (90th Percentile) Temperature (90th percentile)
Winter max pH and Temperature 8.40 S.U 14.44ºC
Summer max pH and Temperature 7.98 S.U 21.78ºC
The above pH values in each scenario represent mixed values of the Columbia and the Cowlitz, but the temperature is from recording thermisters upstream of the Longview Fibre Discharge. There was not enough data to take into account the influence of the Longview Fibre Discharge in either of these scenarios.
There were statements in the effluent mixing zone study (Cosmopolitan, 1999) that the Cowlitz River water flowed along the bank of the Columbia in the vicinity of the Permittee’s outfall. However, our
4/9/2007 Page 40
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority examination of the temperatures shows that this may not be the case. Three sites were compared: daily max temperatures from thermisters placed upstream of the Longview Fibre outfall, the Cowlitz River upstream of its mouth, and in the Columbia River near Camas. The Cowlitz River maximum daily temperatures are near 3.0 degrees cooler on average than either the Columbia River above Longview Fibre or the Columbia at Camas.
4/9/2007 Page 41
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
Calculation of pH of a mixture of two flows. Based on theprocedure in EPA's DESCON program (EPA, 1988. Technical
Guidance on Supplementary Stream Design Conditions for SteadyState Modeling. USEPA Office of Water, Washington D.C.)
Based on Lotus File PHMIX2.WK1 Revised 19-Oct-93Summer Condition
INPUT
1. DILUTION FACTOR AT MIXING ZONE BOUNDARY (Between Columbia and Cowlitz a 3.3007Q10 flows. Mix with approx. 3.3:1 of Columbia flow from aerial photo interpretation of Cowlitz water hugging the bank of the Columbia)1. UPSTREAM/BACKGROUND CHARACTERISTICS (of Columbia River) Temperature (deg C): (From Thermister data upstream of Longview Fibre) 21.78 pH: (From EAP data at Marker 59) 7.99 Alkalinity (mg CaCO3/L): (From EAP data at Marker 59) 45.00
2. EFFLUENT CHARACTERISTICS (of Cowlitz River) Temperature (deg C): (From EAP data at Kelso) 17.14 pH: (From EAP data at Kelso) 7.66 Alkalinity (mg CaCO3/L): (From USGS data Cowlitz.) 16.00
OUTPUT
1. IONIZATION CONSTANTS Upstream/Background pKa: 6.37 Effluent pKa: 6.40
2. IONIZATION FRACTIONS Upstream/Background Ionization Fraction: 0.98 Effluent Ionization Fraction: 0.95
3. TOTAL INORGANIC CARBON Upstream/Background Total Inorganic Carbon (mg CaCO3/L): 46.08 Effluent Total Inorganic Carbon (mg CaCO3/L): 16.88
4. CONDITIONS AT MIXING ZONE BOUNDARY Temperature (deg C): 20.37 Alkalinity (mg CaCO3/L): 36.21 Total Inorganic Carbon (mg CaCO3/L): 37.23 pKa: 6.38
pH at Mixing Zone Boundary: 7.93
4/9/2007 Page 42
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
Calculation of pH of a mixture of two flows. Based on theprocedure in EPA's DESCON program (EPA, 1988. Technical
Guidance on Supplementary Stream Design Conditions for SteadyState Modeling. USEPA Office of Water, Washington D.C.)
Based on Lotus File PHMIX2.WK1 Revised 19-Oct-93Winter Condition
INPUT
1. DILUTION FACTOR AT MIXING ZONE BOUNDARY (Between Columbia and Cowlitz a 3.6007Q10 flows. Mix with approx. 7.2:1 of Columbia flow from aerial photo interpretation of Cowlitz water hugging the bank of the Columbia. This include a 1/2 reduction from summer flows)1. UPSTREAM/BACKGROUND CHARACTERISTICS (of Columbia River) Temperature (deg C): (From Thermister data upstream of Longview Fibre) 14.44 pH: (From EAP data at Marker 59) 8.44 Alkalinity (mg CaCO3/L): (From EAP data at Marker 59) 45.00
2. EFFLUENT CHARACTERISTICS (of Cowlitz River) Temperature (deg C): (From EAP data at Kelso) 12.45 pH: (From EAP data at Kelso) 7.66 Alkalinity (mg CaCO3/L): (From USGS data Cowlitz.) 16.00
OUTPUT
1. IONIZATION CONSTANTS Upstream/Background pKa: 6.42 Effluent pKa: 6.44
2. IONIZATION FRACTIONS Upstream/Background Ionization Fraction: 0.99 Effluent Ionization Fraction: 0.94
3. TOTAL INORGANIC CARBON Upstream/Background Total Inorganic Carbon (mg CaCO3/L): 45.43 Effluent Total Inorganic Carbon (mg CaCO3/L): 16.96
4. CONDITIONS AT MIXING ZONE BOUNDARY Temperature (deg C): 13.89 Alkalinity (mg CaCO3/L): 36.94 Total Inorganic Carbon (mg CaCO3/L): 37.53 pKa: 6.43
pH at Mixing Zone Boundary: 8.23
The calculations for pH, ammonia, and the reasonable potential for ammonia are based on an estimated and assumed mixing of the Cowlitz River into the Columbia River. The dilution factor used for the Cowlitz to Columbia was 7.2 in the summer and 3.6 in the winter. The Department thinks, however, that site specific pH, ammonia and temperature should be gathered at the upgradient edge of the Permittee’s mixing zone.
4/9/2007 Page 43
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
INPUT Aummer dry season (June through September) partial mix Scenario 1. Ambient Temperature (deg C; 0<T<30) 21.78
2. Ambient pH (6.5<pH<9.0) 7.93
3. Acute TCAP (Salmonids present- 20; absent- 25) 20
4. Chronic TCAP (Salmonids present- 15; absent- 20) 15
OUTPUT 1. Intermediate Calculations: Acute FT 1.00 Chronic FT 1.41 FPH 1.04 RATIO 14 pKa 9.34 Fraction Of Total Ammonia Present As Un-ionized 3.7053%
2. Un-ionized Ammonia Criteria Acute (1-hour) Un-ionized Ammonia Criterion (ug NH3/L) 250.9 Chronic (4-day) Un-ionized Ammonia Criterion (ug NH3/L) 40.5
3. Total Ammonia Criteria: Acute Total Ammonia Criterion (mg NH3+ NH4/L) 6.8 Chronic Total Ammonia Criterion (mg NH3+ NH4/L) 1.1
4. Total Ammonia Criteria expressed as Nitrogen: Acute Ammonia Criterion as mg N 5.6 Chronic Ammonia Criterion as N 0.90
Calculation Of Ammonia Concentration and Criteria for fresh water. Based on EPA Quality Criteria for Water (EPA 400/5-86-001) and WAC 173-201A. Revised 1-5-94 (corrected total ammonia criterion). Revised
3/10/95 to calculate chronic criteria in accordance with EPA Memorandum from Heber to WQ Stds Coordinators dated July 30, 1992.
Summer Using 3.6:1 cowlitz to Columbia Water
4/9/2007 Page 44
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
INPUT Winter Wet season (June through September) Partial mix Scenario 1. Ambient Temperature (deg C; 0<T<30) 14.4
2. Ambient pH (6.5<pH<9.0) 8.23
3. Acute TCAP (Salmonids present- 20; absent- 25) 20
4. Chronic TCAP (Salmonids present- 15; absent- 20) 15
OUTPUT 1. Intermediate Calculations: Acute FT 1.47 Chronic FT 1.47 FPH 1.00 RATIO 14 pKa 9.58 Fraction Of Total Ammonia Present As Un-ionized 4.2547%
2. Un-ionized Ammonia Criteria Acute (1-hour) Un-ionized Ammonia Criterion (ug NH3/L) 176.6 Chronic (4-day) Un-ionized Ammonia Criterion (ug NH3/L) 40.2
3. Total Ammonia Criteria: Acute Total Ammonia Criterion (mg NH3+ NH4/L) 4.2 Chronic Total Ammonia Criterion (mg NH3+ NH4/L) 0.9
4. Total Ammonia Criteria expressed as Nitrogen: Acute Ammonia Criterion as mg N 3.4 Chronic Ammonia Criterion as N 0.78
Calculation Of Ammonia Concentration and Criteria for fresh water. Based on EPA Quality Criteria for Water (EPA 400/5-86-001) and WAC 173-201A. Revised 1-5-94 (corrected total ammonia criterion). Revised
3/10/95 to calculate chronic criteria in accordance with EPA Memorandum from Heber to WQ Stds Coordinators dated July 30, 1992.
Winter Using 7.2:1 cowlitz to Columbia Water
The following toxic substances where detected in priority pollutant scans of the effluent and shown in the application:
Parameter Maximum
concentration detected
Estimated daily concentration
Concentration at edge of mixing
zone base on DF o 15.6
Total Phenolic Components 0.08 mg/L 0.02 mg/L 0.0013 mg/L Chloroform 3.5 µg/L 2.4 µg/L 0.15 µg/L Methylene Chloride 2.0 µg/L 1.3 µg/L 0.08 µg/L Tolulene 1.2 µg/L 0.78 µg/L 0.05 µg/L Phenol 0.74 µg/L 0.46 µg/L 0.03 µg/L 2,4, Dichlorophenol 0.36 µg/L 0.12 µg/L 0.008 µg/L Bis(2Exyhexyl)Phthalate 3.8 µgL 1.3 µg/L 0.08 µg/L DI-N-Butyl Phthalate 0.69 µg/L 0.23 µg/L 0.014 µg/L
4/9/2007 Page 45
Fact
She
et fo
r NPD
ES P
erm
it N
o. W
A003
7788
Th
ree
Rive
rs R
egio
nal W
aste
wat
er A
utho
rity
R
easo
nabl
e Po
tent
ial C
alcu
latio
n Sp
read
shee
t C
AL
CU
LA
TIO
NS
Sta
te W
ater
Qua
lity
Sta
ndar
d
Met
al C
rite
ria
Tra
nsla
tor
as
deci
mal
Met
al C
riter
ia
Tra
nsla
tor
as
dec
imal
Am
bie
nt
Con
cent
rati
on (m
etal
s as
di
ssol
ved)
Acu
teC
hron
ic
Max
eff
lue
nt
con
c.
me
asur
ed
(met
als
as t
otal
reco
vera
ble)
Coe
ff
Va
riatio
n#
of
sam
ple
s
Acu
te
Dil'
n
Fac
tor
Ch
roni
c D
il'n
Fa
cto
rP
aram
eter
Acu
teC
hron
icug
/Lug
/Lug
/Lug
/LC
Vn
a (S
umm
er
1.0
01.
001
256
0090
0.00
2340
00
.60
610
.60
0.6
0
Max
co
ncen
trat
ion
at
edge
of.
..
Acu
te
Mix
ing
Zon
e
Chr
oni
c M
ixin
g Z
one
LIM
IT
RE
Q'D
?
Eff
luen
t p
erce
ntil
e va
lue
Mul
tiplie
rug
/Lug
/LP
ns
Am
mon
i3.
6:1
mix
).0
036
25.4
014
94.4
2Y
ES
0.9
50.
952
.00
0.55
0.99
616
Am
mon
ia (
Win
ter
7.2:
1 m
ix)
1.0
01.
001
234
00.0
078
0.00
2547
.66
1052
.27
YE
S0.
95
0.97
319
010
.00
0.55
110
0.85
616
Cop
per
0.99
60
.99
65
8.7
66.
215
.01
4.7
1N
O0.
95
0.89
56.
250.
5527
1.24
616
Lead
0.46
60
.46
69
29.8
01.
167
.59
8.4
2Y
ES
0.9
50.
930
0.00
0.55
411.
106
16M
ercu
ry0
.85
1.00
2.1
00.
010
.02
0.0
1N
O0.
95
0.87
80.
100.
5523
1.31
616
Zin
c0.
996
0.9
96
20
62.9
75
7.5
025
.38
22.4
4N
O0.
95
0.82
93
5.7
00.
5516
1.47
616
Ars
enic
1.0
01.
002
03
60.0
019
0.00
17.0
318
.78
NO
0.9
50.
829
0.66
0.55
161.
476
16
0.6
00
.60
0.6
00
.60
wat
er s
ampl
e a
nd
the
efflu
ent s
am
ple
for
lead
are
bel
ow d
etec
tion,
ther
efor
e a
limit
is n
ot w
arra
nted
.C
hlo
rine
1.0
01.
000
1
1.0
00
.00
0.0
0Y
ES
0.9
50.
998
0.00
0.55
1469
0.51
616
0.6
0
Am
mo
nia
(Sum
me
r C
ow
litz
only
)1
.00
0.6
01
.00
0.6
01.
0012
.00
9800
.00
1770
.00
3625
.40
1494
.42
NO
0.9
50.
952
2340
0.0
00.
5561
0.99
616
Am
mon
ia (
Win
ter
Co
wlit
z on
ly)
1.00
12.0
010
800.
0021
20.0
025
47.6
610
52.2
7N
O0.
95
0.97
319
010
.00
0.55
110
0.85
616
Thi
s sp
read
shee
t ca
lcul
ates
the
rea
sona
ble
pote
ntia
l to
exce
ed s
tate
wat
er q
ualit
y st
anda
rds
for
a sm
all n
umbe
r of
sam
ples
. T
he p
roce
dure
and
cal
cula
tions
are
do
ne p
er t
he p
roce
dure
in T
echn
ical
Sup
port
Doc
umen
t fo
r W
ater
Qua
lity-
base
d T
oxic
s C
ontr
ol,
U.S
. E
PA
, M
arch
, 19
91 (
EP
A/5
05/2
-90-
001)
on
page
56.
U
ser
inpu
t co
lum
ns a
re s
how
n w
ith r
ed h
eadi
ngs.
C
orre
cted
fo
rmul
as in
col
G
and
H
on 5
/98
(GB
)
Th
e di
lutio
n fa
ctor
s use
d in
the
abov
e ta
ble
for t
he R
easo
nabl
e Po
tent
ial w
ere
6.4:
1 fo
r acu
te a
nd 1
5.6:
1 fo
r chr
onic
. Th
e M
ercu
ry a
mbi
ent c
once
ntra
tions
are
bot
h be
low
det
ectio
n an
d as
sum
ed to
be
zero
. Th
e am
bien
t val
ue fo
r am
mon
ia-N
, lea
d an
d zi
nc w
ere
base
d on
the
upst
ream
con
cent
ratio
n de
tect
ed fr
om th
e Lo
ngvi
ew F
ibre
plu
me.
The
sam
ples
for e
fflu
ent l
ead
are
also
bel
ow d
etec
tion
and
the
final
val
ue u
se w
as a
ssum
ed to
be
zero
and
ther
efor
e no
lim
it is
just
ified
. Th
e fo
llow
ing
tabl
e ca
lcul
ates
lim
its b
ased
on
the
abov
e re
ason
able
pot
entia
l fo
r am
mon
ia a
nd th
e am
mon
ia fr
eshw
ater
tabl
es.
Bec
ause
the
faci
lity
is d
owns
tream
of t
he c
onflu
ence
of t
he C
owlit
z R
iver
, the
pH
dat
a us
ed in
the
amm
onia
cal
cula
tions
from
the
Col
umbi
a R
iver
and
the
Cow
litz
Riv
er w
ere
mix
ed u
sing
a d
ilutio
n fa
ctor
of 3
.6 fo
r sum
mer
and
7.2
for w
inte
r flo
w.
Lim
its C
alcu
latio
ns fo
r A
mm
onia
P
erm
it L
imit
Ca
lcu
lati
on
Su
mm
ary
Sta
tistic
al v
aria
ble
s fo
r pe
rmit
limit
calc
ula
tion
Acu
te
Dil'
n F
acto
r
Ch
roni
c D
il'n
Fac
tor
Met
al
Crit
eria
T
rans
lat
or
Met
al
Cri
teria
T
rans
lat
or
Am
bie
nt
Con
cen
tra
tion
Wat
er
Qu
ality
S
tand
ard
A
cute
Wat
er
Qua
lity
Sta
ndar
d C
hron
ic
Ave
rag
e L
TA
C
oeff
. V
ar.
(CV
)
Coe
ff.
Va
r.
(CV
)
# o
f S
am
ple
s pe
r M
onth
PA
RA
ME
TE
RA
cute
Chr
oni
cug
/Lug
/Lug
/Lde
cim
a
Was
te L
oad
All
oca
tio
n (
WL
A)
and
Lo
ng
Te
rm
Ave
rag
e (
LT
A)
Cal
cu
lati
on
s
Mon
thly
Li
mit
(AM
L)
Max
imum
D
aily
Lim
it (M
DL
)C
om
men
tsW
LA
Acu
teW
LA
Chr
onic
LTA
A
cute
LTA
C
hron
ic
LTA
P
rob'
y B
asis
Lim
itin
g L
TA
AM
L
Pro
b'y
Bas
is
MD
L
Pro
b'y
B
asis
ug/
Lug
/Lug
/Lug
/Lug
/Lug
/Ll
deci
mal
ug/L
deci
mal
deci
mal
deci
mal
nA
mm
6:1
mi
onia
(su
mm
er3
.x
6.4
15.
605
001
135
2.5
2277
5.3
357
75
138
64.8
01
148
6.8
7312
.80.
9973
12.
80.
950.
99A
mm
oni
a (
win
ter
7:1
mix
)6.
41
5.60
1.00
1.00
12.
0034
00.0
078
0.00
9819
.719
700
.22
169
511
992
.80
6966
.063
25.4
0.99
632
5.4
0.95
0.99
1.00
1.00
12.
006
00.
900.
000.
600.
604
.00
1.0
00.
600.
604
.00
1.0
0
Dilu
tion
(Dil'
n) f
acto
r is
the
inve
rse
of t
he p
erce
nt e
fflu
ent
conc
entr
atio
n at
the
edg
e of
the
acu
te o
r ch
roni
c m
ixin
g zo
ne.
Pote
ntia
l Am
mon
ia li
mits
from
abo
ve li
mits
tabl
e: S
umm
er a
vera
ge m
onth
ly:
11 m
g/L,
max
dai
ly: 2
3 m
g/L;
Win
ter a
vera
ge m
onth
ly: 1
0 m
g/L,
max
dai
ly: 1
9 m
g/L.
4/9/
2007
Pa
ge 4
6
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
APPENDIX D--RESPONSE TO COMMENTS Response to Comments Received During the public notice of the draft permit of the Three Rivers Permit Ending February 12, 2007: Comments were received from: • The Three Rivers Regional Wastewater Authority (TRRWA) • City of Longview • City of Kelso • The Beacon Hill Sewer District Similar comments were received from each of the above entities. The following comments are summarized from these entities. Comment 1 (from TRRWA, Longview, and Kelso):
The TRRWA has invested more than $65,000,000 in upgrading the facility in the past 10 years. Accomplishing these upgrades has resulted in significant increases to the TRRWA ratepayers. Many of the proposed changes in the permit will further increase operating and capital expenses at the treatment facility. Among the changes with cost impacts are:
1. Field Instruments for monitoring pH and temperature. 2. Studies for Inflow and Infiltration for the entities that comprise the TRRWA. 3. Developing Operations and Maintenance manuals for the collection systems. 4. Additional staffing and/or overtime for pretreatment monitoring. 5. Outfall Mixing Zone Study. 6. Additional costs for analytical monitoring requirements.
Of these items, only the outfall zone study is currently budgeted. The TRRWA proposes the other items in this list be reconsidered further with the TRRWA staff during this permit cycle, and if they are still determined as needed, be accomplished during the following permit cycle.
Department Response 1:
As a clarification of the permit requirements, the Department is not requiring a new dilution study. The existing dilution factors appear to be accurate and calculated using the Department’s policy for determining dilution factors and then calibrated with a dye study. Rather, the Department requires a Receiving Water and Effluent Study in section S9 and a routine Outfall Evaluation in section S12. The Receiving Water Study is needed to determine the background parameters and establish the toxicity of ammonia. These parameters include temperature, pH, and ammonia. The Department must show that a discharge is not toxic. Because ammonia is likely in the effluent, the Department must evaluate the background data. There are high pH conditions that are suspected in the Columbia, which increases ammonia toxicity. However, we will work with Three Rivers to develop a new dilution study if they believe the existing study does not represent river hydraulics or dilution.
The Outfall Evaluation, required in S12, is different than a mixing zone study. This evaluation is meant to examine the condition and integrity of the outfall. The Department requires this
4/9/2007 Page 47
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
evaluation of every municipal Permittee with a submerged discharge to potentially turbulent waters. The Department’s experience is that damaged outfalls will go unchecked and un-repaired, especially in a river such as the Columbia which has dredging.
Comment 2 (from TRRWA, Kelso, and Beacon Hill Sewer District):
Additional Analytical Requirements
There appears to be more monitoring requirements in the draft permit than in the previous permit.
The additional testing appears as follows:
1. Reapplication monitoring has increased to quarterly for dissolved oxygen, Total Kjeldahl Nitrogen, Nitrate, Nitrite, Oil & Grease, Phosphorous, Total Dissolved Solids, BOD, and Total Hardness, Phenols.
2. Routine Fecal Coliform testing has increased from 5/7 Days to 7/7/days. This will require additional staffing in the laboratory.
The discharge from the TRRWA plant is generally stable and predictable, and we believe this additional testing is unnecessary. The TRRWA would like the Department of Ecology (DOE) to retain the existing monitoring scheduled; if the new schedule remains in the final permit, please explain the reason for increasing the monitoring schedule for these parameters.
Department Response 2:
The first item is required testing by the NPDES permit application. This is not a new requirement. We simply put the required application sampling in the permit to make it plain and clear. This sampling may not have been clear in the past when it was in the application. The phenols grouped with metals sampling is “total phenols” and is to be sampled quarterly. There are the acid-extractible phenols which are to be sampled yearly.
Regarding the second item for sampling fecal coliform, it is the Department’s policy to sample fecal coliform seven-days per week for any facility that discharges at greater than five MGD and which uses the activated sludge process. The testing will be consistent with other plants of this size and type.
Comment 3 (from TRRWA, Kelso, and the Beacon Hill Sewer District):
Mixing Zone Study
The TRRWA is committed to conducting an outfall Mixing Zone Study. However, the DOE deadline of having the plan set by March 15, 2007, is not attainable. Getting a consultant under contract and developing the scope for the study cannot be accomplished by the DOE deadline. The Mixing Zone Study is a key feature in determining whether or not ammonia limits will be required in future permits, so the consultant selection process and study scope require evaluation by the TRRWA.
Department Response 3:
As noted above, in item No. 1, the Department is not requiring a new Mixing Zone Study. The March 15, 2007, date under section S9 is for a Receiving Water and Effluent Study Sampling and
4/9/2007 Page 48
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
QAP. This date has been changed to June to give adequate time to write a study plan. The data collection will take place over the next couple of years, if necessary.
Comment 4 (from TRRWA, Kelso, and the Beacon Hill Sewer District):
Pretreatment
The Mixing Zone Study, which is budgeted for 2007, may result in a changed paradigm for our effluent characterization. The TRRWA proposes that any decision on local limits be deferred until after the Mixing Zone Study is completed and those results agreed upon between the TRRWA and DOE. Changing local ordinances for the TRRWA also involves all four Entities. The Entities and TRRWA propose to do this work using the best information available, which would be after the Mixing Zone Study is completed.
Department Response 4:
The Permittee is not obliged to revisit mixing. The Department believes that mixing has been properly determined. Also, mixing is only one of several considerations that go into local limits. The Department cannot delay progress on potential local limits of the permit for the effluent testing. The dilution factors are not expected to change, as noted above.
The pretreatment testing, for the establishment of local limits, in S6.D, is important to determine if pollutants are present from industrial dischargers to the TRRWTP. Local limits are not limits on the plant but rather limits on discharges to the plant. The local limits protect the plant from having pollutants in their discharge which are preventable. Before local limits are established, the influent and effluent needs to be sampled. This sampling can occur at the same time as the receiving water sampling.
The Department is willing to work with the TRRWA to develop a new mixing zone study. But, we will not delay implementation of the pretreatment requirements until the next permit cycle. However, to accommodate the desire for a new mixing zone study, the Department will move the requirement for local limits to 2010.
Comment 5 (from TRRWA, Kelso, and the Beacon Hill Sewer District):
Collection System
There is a considerable amount of emphasis on the collection systems of the Entities that are permit items. In particular, accomplishing and documenting the Inflow and Infiltration studies that are outlined in the draft permit will take considerable time and resources. There are also specific comments in the attached draft permit asking how DOE defines technical issues and how they will measure performance regarding these issues. The Entities and TRRWA propose that these items be deferred until the next permit cycle, if they are done at all. A reasonable point on the part of the TRRWA is why DOE proposes that the Entities do Inflow and Infiltration studies when the overall system Inflow and Infiltration Study is done annually by the TRRWA.
Additionally, the request for Operations and Maintenance Manuals is very time consuming. Due to the age of some of the equipment, some of the operational information may not be attainable. The Entities and TRRWA propose that this requirement be satisfied by submitting Standard Operating Procedures along with maintenance materials that are available.
4/9/2007 Page 49
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Department Response 5:
The NPDES permits have in the past applied to the collection systems too. The new permit makes it clear who needs to do what. The content of the inflow and infiltration studies do not need to change so long as all of the tributary collection systems are participating. In the past, we have had difficulty getting contributors to comply with requirements already in the permits. If the contributors have not been complying, then it may result in more work, to begin monitoring and documenting the problems, than in the past. If the contributors to the plant have a program in place, then it should not be any more difficult. The numbers provided by each tributary collection system can then be easily combined into one report and the plant will have a better idea of flows and can spot inflow or infiltration problems. These items need to remain in this permit.
This O&M Manual for collection systems applies mainly to the pump stations, but also to pressure lines and an overall maintenance schedule for inspecting an aging system. The O&M Manuals need not be onerous. The existing documentation on pump maintenance and repair frequency should be bundled (the Jurisdictions may work together on bundling their reports). Where there is no existing documentation, the cities should establish the standard operating procedures. Where information is not written, but there is a procedure, it should be written. The cities and county should put together what they have on the pump stations in an indexed, organized manner. The following can be expected in a collection system O&M Manual: • Emergency procedures and spill notification procedures • Backup power availability • Telemetry and SCADA availability • Maintenance schedules • Manhole inspection frequency • Line cleaning and inspection frequency • Existing drawings • Pump curves • Control systems—flow, level control, pump start/speed control, alarm, etc.
The date for this activity has been moved to 2010. It seems more than reasonable to give more than three years to complete a first O&M Manual for the collection systems.
Comment 6 (from TRRWA, Kelso, and the Beacon Hill Sewer District):
Plant Capacity
The previous permit rated the South Plant and North Plant each at 13 MGD for a total of 26 MGD. The new permit shows the South Plant at 16 MGD and North Plant at 10 MGD. While the total plant capacity has remained at 26 MGD, the TRRWA has some level of concern as to the basis for the change of rating for the North and South Plants.
The DOE approved facilities plan for the TRRWA upgrades identified the South Plant and North Plant capacities as 13 MGD each. The TRRWA does not believe there is a reason to change those ratings.
Regardless of the how the total 26 MGD is distributed between the North and South Plants, the TRRWA will expect that DOE will honor that allocation in future permits. The TRRWA will resist utilizing resources to perform studies to justify the 26 MGD rating that DOE already has
4/9/2007 Page 50
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
approved. The division of capacity between the North and South Plants also plays a role in the interim loading limits described below.
Department Response 6:
The treatment plant will have an interim capacity rating of 19.5 MGD maximum month design flow (MMDF). This is based on one clarifier that is 90 feet in diameter and two clarifiers that are 110 feet in diameter.
The above capacity rating of 19.5 MGD MMDF is based on the Cowlitz sewer Operating Board, System Improvements Project, Facility Plan/Pre-Design Report, November 1999 (Plan), Section IV and one North Plant secondary clarifier being currently damaged and inoperable. This plant rating will give TRRWA more time and capacity to plan for improvements to the plant to bring it up to the fully rated MMDF capacity of 26 MGD. The Department will use the following criteria to rate any future plant upgrades: 90.48 RCW, 173-240 WAC, and Washington State Criteria for Sewage Works Design standards (Department standards).
Comment 7 (from TRRWA, Kelso, and the Beacon Hill Sewer District):
North Plant Secondary Clarifiers
The new permit has interim limits that reflect reduced capacity for the North Plant, based on one secondary clarifier being out of service. The North Plant capacity is important because it influences the interim loading limit.
The TRRWA is Studying rehabilitating or replacing one or both of the North Secondary Clarifiers. The TRRWA hopes to apply for a PWTF Loan in 2007, so that construction could occur in 2008. Since rating for the North Plant will dictate the clarifier sizing, and PWTF Loan application is due in April, the North Plant rating needs to be decided on a timely basis.
Department Response 7:
Part of the answer to this comment is included under response number 6. There will be a footnote in the permit under the plant capacity in section S4.A. The footnote explains that the capacity has been temporarily reduced.
Comment 8 (from TRRWA, Kelso, and the Beacon Hill Sewer District):
Conclusions
There are a number of issues in the Draft Permit Fact Sheet that TRRWA has concerns about.
Increases in workload for TRRWA staff and Entity employees either cause increased costs due to overtime or elimination of duties which the TRRWA and Entities believe are needed to sustain their respective operations. Another alternative is to hire more staff which is also a ratepayer impact. The TRRWA experienced major increases in costs over the past ten years and some level of ratepayer relief is desired.
The TRRWA believes the analytical monitoring requirements have increased. Given the excellent record of TRRWA permit compliance; the TRRWA would like to have this increase in testing justified by DOE.
4/9/2007 Page 51
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Department Response 8:
It is important to sustain the plant and collection system operation. As stated above under point No. 2 the sampling frequency the Department uses is guided by size and type of plant. Adding fecal coliform sampling on the weekends does not add an undue burden. Part of updating a permit every five years is to incorporate changes to regulations and policy, and to reexamine the water quality conditions at the new plant flows. More information is now available to show that the existing permit may have not been accurate and new analysis is needed.
Following are additional comments from the cities and TRRWA which were stated and partially answered above. The City of Longview made comments on direct sections of the permit and fact sheet. The items that have not been answered above are included below. Comment 9 (from City of Longview):
Special Conditions – Page 6
The Fact Sheet (page 2, paragraph 4) states that the collection system for West Longview is not included under this permit. That exclusion should also apply to any Cowlitz County Collection systems not tributary to the TRRWTP, and such exclusions are not identified in the permit. To reflect those exclusions in the permit, the third paragraph on page 6 should be revised to read as follows:
“...these Permittees are responsible for all operation, maintenance, monitoring, reporting and compliance with all other permit requirements related to their respective sewage collection, conveyance, and storage systems tributary to the TRRWTP. Included among the applicable…”
Department Response 9:
The following portion of the sentence: “… tributary to the TRRWTP.” has been added to this section of the permit.
Comment 10 (from City of Longview):
Special Condition S4E. – Infiltration and Inflow Evaluation
S4.E.1, 2, &3. The City requests that this requirement of the individual entities be deleted since the TRRWA is already providing inflow and infiltration data annually that reflect the overall system performance and can be used to assess inflow and infiltration. It is unclear what is required to comply with these conditions, and why this is necessary since the TRRWA has been reporting this data for many years and there has been no indication of concern from DOE. Since plant monitoring data can be used, that information is already being provided.
Department Response 10:
This item was answered under point No. 5, that the City has been sending in reports, but should follow the permit guidelines so that the I&I information from all jurisdictions is consistent and available for the Department’s review.
4/9/2007 Page 52
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Comment 11 (from City of Longview):
If additional flow data or actual measurements of inflow and infiltration are required, doing so would create a significant burden on the City. Most of the flow in the City’s collection system is not metered, therefore significant expense would be required to retrofit our system with permanent flow meters or flow loggers to measure inflow and infiltration. If we do not install and maintain permanent equipment, we would have to contract annual [sic] for flow studies, which are very costly and we are not assured of getting representative flows during the period when flow loggers are installed in the pipelines. Any requirements for measuring inflow and infiltration will impose a significant additional financial burden on the City’s ratepayers at a time when they are faced with additional operating and maintenance costs at the TRRWA plant, and capital costs to upgrade the City’s West Longview Lagoon Treatment Plant. The City requests that this requirement of the individual entities be deleted. If the TRRWA data during the next permit period indicates that the plant is approaching its wet weather capacity, the entity inflow and infiltration reporting could be considered for the following permit cycle.
Department Response 11:
The TRRWA and the Department need good flow data to make decisions and to assess where the worst I&I problems exist. Many of the worst permit violations that we see involve spills from collection systems. The City does need to monitor and send in accurate information. This section is standard for all permits and the jurisdictions contributing to them. This section of the permit will remain.
Comment 12 (from City of Longview):
S4.E.4 - The intent of this requirement is unclear. Does this requirement apply to pumped pressure mains, or also to gravity mains that periodically and/or regularly surcharge up the manhole barrels? The City recommends that this requirement apply only to pumped force mains exceeding 400 LF in length, and that force mains constructed of welded HDPE or other similar material be exempt from this regular testing.
Welded HDPE force mains have little risk of exfiltration, and the consequences of exfiltration from short force mains is minimal and not worth the expense of isolating the main and implementing bypass pumping in order to conduct the leak test. In addition we have many lift stations with short discharge pressure mains (less than 150 LF). Again, the consequence of exfiltration from a short main is minimal, and the expense of bypass pumping is high relative to the benefit that might be derived.
With gravity mains, we have many mains that become surcharged up the manhole barrel periodically. Leak testing all gravity mains that periodically surcharge would mean testing a substantial portion of our collection and incurring significant costs to bypass pump during the leak testing. We believe there is little benefit to doing so and recommend, as noted above, that the leak testing be limited to force mains.
Department Response 12:
The intent is to prevent exfiltration of sewage to ground or surface waters. Federal and state laws do not allow the discharge of sewage or other pollutants to surface water and state law does not allow the discharge of pollutants to ground water. That said, the Department does not dictate the
4/9/2007 Page 53
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority
type of testing or detection methods to determine a loss of fluid from one end of a pressure main to another. The Cities and County with collection systems should prioritize the worst suspected problems first and work their way to the lesser problems. All of the collection system should be inspected over time and a schedule of inspections should be proposed. The purveyor could use metering, in line piezometers, or pressure testing to detect fluid losses in the pressure lines or pressure test in the evening hours and the type of system used to hold the sewage. The shorter sections should not be off the list. HDPE pipe would obviously have a lower priority. Over time, this pipe may move up the list as abuses to the system accumulate. This section will remain as written.
The surcharging of manholes is not a problem unless it results in exfiltration or the discharge of sewage to the surface. Either of these problems would be considered a spill and must be reported. Simple surcharge and pumping within the manhole would not need to be reported.
Comment 13 (from City of Longview):
Special Condition S5.B. – Operation and Maintenance (O&M) Program
The request for Operations and Maintenance is very time consuming and not attainable. Due to the age of some of the equipment, manufacturers information is not be available [sic]. In addition, the word adequate is not defined and can be broadly interpreted. The City recommends that the result desired by DOE can be satisfied by submitting standard operating and maintenance procedure manuals along with appropriate maintenance materials that are available for the critical equipment. The City recommends that the first three paragraphs of this section be revised to read as follows:
“The Permittees (applies to each jurisdictions for the mechanical components in their respective collection systems) shall institute an operation and maintenance program for the entire sewage system tributary to the TRRWTP. Maintenance records shall be maintained on all major electrical and mechanical components of the treatment plant, pumping stations, and sewage collection systems. Such records shall clearly specify the frequency and type of maintenance recommended by the manufacturer, if available, and shall show the frequency and type of maintenance performed. If manufacturer recommendations are not available, Permittees’ staff shall identify the recommended maintenance.
In addition, the TRRWTP, Longview, Kelso, the Beacon Hill Sewer District, and Cowlitz County shall develop, submit, and maintain standard operating and maintenance procedures manuals for pump stations, lagoons, equalization basins, and other critical components that are used throughout the collection system tributary to the TRRWTP. The standard operating and maintenance procedures manuals are due by November 15, 2009, and must be updated as necessary when improvements are made.
These procedures manuals shall be prepared by the Permittees in accordance with WAC 173-240-080 to the extent practicable, and submitted to the Department for approval. In addition to the requirements of WAC 173-240-080, the procedures manuals shall include: {{then continue with the listed items}}.”
4/9/2007 Page 54
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Department Response 13:
It is true that the Permittee does need to determine and have a manual available for staff to schedule required maintenance. The Department will, however, make modifications to the permit language. The language in the permit, in S5.B in the first paragraph, has been partially modified to say “…sewage system tributary to the TRRWP” instead of the “entire sewage system.” The Department will add the following underlined portion to the second paragraph, first sentence:
“…O&M procedure manuals for…” The date will be advanced to November 15, 2010. Comment 14 (from City of Longview):
Special Condition S6. –Pretreatment
S6.A - The phrase “…shall work with the Department…” is subjective and needs clarification. Department Response 14:
Because the Department is assuming responsibilities for permitting, it is the cooperation of the Permittees in not only the identified tasks, but must also be willing to help control the tributary users. This is standard permit language in all of our permit shells and is explained and detailed in the next several paragraphs of implementation language following S6.A.
Comment 15 (from City of Longview):
S6.C - This section is redundant with the provisions in section E., Industrial User Survey, and is unreasonable in requiring the Permittees to take continuous measures. This section should be modified to retain only provisions C.2., revised to read as follows:
“Within 30 days of becoming aware of an unpermitted existing, new, or proposed industrial user who may be an SIU or PSIU, the Permittee shall notify such user that, if classified as an SIU, they shall be required to apply to the Department and obtain a State Waste Discharge Permit. The Permittee shall be considered aware of proposed industrial users at such time as the SIU or PSIU submits a development application. Notification may be made through the development review process or by separate letter. A copy of the notification shall also be sent to the Department at the time the SIU or PSIU is notified.”
Department Response 15:
Part of this language applies to the plant and part applies to the collection system. The City must continually examine incoming industry through permits and drive through examination when possible. As you are already aware, the treatment plant is the community’s most expensive asset and should be protected. Carefully managing the tributary industries can prevent illegal over-loading, washing out of the biota, and/or allowing toxins to kill biota or pass through the plant.
The suggested language does not capture all of what the Department needs accomplished. Section S6.C is intended to convey the requirements for the Permittee. The Permittee needs to report both periodically (quarterly or yearly) and continually (as needed to collect information from applicants) to identify all tributary users which may need permits. The original language will remain.
4/9/2007 Page 55
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Comment 16 (from City of Longview):
S6.D - The mixing zone study, which is budgeted for 2007, may result in a changed paradigm for the TRRWA effluent characterization. Any decision on local limits must be deferred until after the Mixing Zone Study is completed and the results and recommendations agreed upon between the TRRWA and DOE. Adopting local limit before the Study is complete may result in setting limits that may be insufficient to protect water quality or be excessively strict and overly burdensome on our customers. Establishing local limit and adopting a pretreatment ordinance should occur after the Mixing Zone Study is completed, which will not occur in time to meet the April 15, 2008, deadline for recommending local limits.
Department Response 16:
This point is in part answered in the Department’s Response Number 1. The pretreatment section must continue separately from any receiving water study. A mixing zone analysis is not required or recommended. Any pollutants found through the local limits sampling will result in a limit that is independent of the existing dilution factors.
As stated above, the proposed study requirement in the permit is to sample for the background parameters for determining ammonia toxicity and not to re-determine the dilution factors. These studies, ammonia toxicity and local limits, can be conducted concurrently.
Comment 17 (from City of Longview):
S6.E - The requirement in the second paragraph of E.1 to “compel” completion of survey forms is undefined and could be interpreted in a very onerous manner and unreasonably subject the Permittees to permit violations if we do not take escalating enforcement action to ensure completion of the form. For example, it would be unreasonable for the City to terminate service to a customer solely because they will not complete the industrial survey. The second paragraph should be revised to read as follows:
“The Permittees shall develop and take reasonable actions to compel completion of survey forms, and collect…”
Department Response 17:
This is standard permit language. Many other jurisdictions throughout the state and nation have these requirements. The existing language reflects those requirements and will need to remain.
Comment 18 (from City of Longview):
Comments on the Fact Sheet
Page 2, 2nd Paragraph: The last sentence of this paragraph should be revised to read as follows:
“The City of Longview is evaluating the feasibility of upgrading the West Longview Lagoons treatment plant, and at some point in the future may abandon the lagoons and divert that flow to the regional treatment works.”
4/9/2007 Page 56
Fact Sheet for NPDES Permit No. WA0037788 Three Rivers Regional Wastewater Authority Department Response 18:
The first part of the above sentence was included in the fact sheet language. However, the City of Longview cannot continue to discharge at the existing location because of water quality concerns. Permitting of the discharge at the existing location is very unlikely. The alternatives are to hook up to the TRRWTP or build a facility that provides a very high level of treatment and discharge to land or discharge to the Columbia River. It may be difficult to obtain the required permits for a Columbia River discharge.
The City of Longview included several points that were identical to the point presented and answered under comment number 1 above.
4/9/2007 Page 57
Appendix C:
Summary Spreadsheet of Solvay’s Monitoring Discharge Monitoring Reports submitted to Ecology for December 2016 through November 2018
Solvay Chemicals, Inc. - Longview, WA
Daily Monitoring Reports Summary - December 2016 through November 2018
Avg. Peak
pH pH Monthly Day
Inst. Min. Inst. Max. Flow Flow
(SU) (SU) (gpd) (gpd)
2016 Dec. 7.024 11.241 84621 194398
2017 Jan. 6.468 11.586 142555 204606
2017 Feb. 8.195 11.17 130573 191640
2017 Mar. 7 11.198 119330 209410
2017 Apr. 8.512 11.316 128002 210375
2017 May 7.887 11.235 117331 211370
2017 June 7.223 11.171 96194 149143
2017 July 7.151 11.226 73874 109807
2017 Aug. 7.386 11.329 95501 122313
2017 Sep. 7.386 11.227 99174 180017
2017 Oct. 9.27 11.193 115245 197371
2017 Nov. 5.179 11.723 106240 189877
2017 Dec. 7.154 11.23 104127 190072
2018 Jan. 7.042 11.163 111850 175587
2018 Feb. 7.022 11.229 103576 165556
2018 Mar. 8.766 11.172 102195 156564
2018 Apr. 7.501 11.038 112883 178182
2018 May 6.973 11.031 69179 138547
2018 June 6.385 11.097 98471 166735
2018 July 7.325 11.122 116036 192163
2018 Aug. 7.615 11.213 114231 168012
2018 Sep. 8.299 11.735 102303 169608
2018 Oct. 8.58 11.249 102799 181412
2018 Nov. 7.026 11.244 107025 171951
Min Max Average Max
5.179 11.735 106388 211370
MMADF
142555
Year Month
Appendix D:
Engineer’s Opinion of Project Cost for Sewer System Improvements from Solvay’s Pipe Rack to Discharge Manhole in Weber Avenue
CITY OF LONGVIEW ‐ Solvay Chemicals, Inc. SewerOpinion of Construction Cost
Item Solvay Chemicals, Inc. Sewer Unit
No. Item Description Quantity Units Cost Amount
1 Mobilization 1 LS $16,000 $16,000
2 Erosion Control Measures 1 LS $1,500 $1,500
3 Selective Demolition 1 LS $10,000 $10,000
4 Temporary Project Traffic Control 1 LS $5,000 $5,000
5 Sewage Bypass Pumping 0 LS $10,000 $0
6 Shoring 1 LS $10,000 $10,000
7 Crushed Surfacing Top Coarse ‐ CSTC 630 Ton $40 $25,200
8 8" HDPE Sewer Pipe 675 LF $100 $67,500
8 8" PVC Sewer Pipe 30 LF $110 $3,300
9 Manhole 48" 1 EA $5,000 $5,000
10 HMA ‐ 6 Inch Thick 5 TON $250 $1,250
11 Concrete Curb 10 LF $50 $500
12 CDF 1 CY $320 $320
*Costs do not include onsite improvements along pipe rack or upstream of pipe rack. $146,000
Contingency @25% $37,000
Engineering @20% $29,000
$15,000
$227,000Total
Prepared by: Gibbs & Olson, Inc.
Date: February 2019
Gibbs & Olson Project No. 0788.0189
Subtotal*
Sales [email protected]%
December 2018 ‐ ENR Seattle Construction Cost Index ‐ 11,537.66