NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT 

Fact Sheet/Permit Evaluation Report 

Oregon Department of Environmental Quality 

2020 SW Fourth Avenue, Suite 400 

Portland, Oregon 97201 

503-229-5263 FAX 503-229-6945 

Permittee: 

Blue Heron Paper Company 

Sources Covered: 

Aerated stabilization basin effluent 

(process wastewater, cooling water, 

storm water) - Outfall 001; 

Filter plant discharge - Outfall 002; 

Miscellaneous effluents 

(storm water and groundwater seepage) - Outfalls 

003, 004 and 005 

Source Category: 

Major Industrial 

File Information: 

WQ-Clackamas County 

File No. 72634 

EPA Reference No.: OR000056-6 

Prepared by: 

Rob Burkhart 

503-229-5566 

Northwest Region - Water Quality 

Facility Location: 

419 Main St. 

Oregon City, Oregon 97045 

Receiving Stream: 

Willamette River 

Proposed Action: 

Issuance of renewal permit 

Source Contact: 

Bruce Martin 

Director, Energy & Environmental 

Department 

(503) 650-4269 

Date Prepared: 1/31/2006 

Updated: 2/2/06 and 4/28/06 
Blue Heron Paper Company 

Permit Evaluation Report/Fact Sheet 

Table of Contents 

Section Page 

3 

3 

9 

18 

22 

24 

24 

34 

34 

42 

42 

Attachment A: 2001 NPDES Permit 

Attachment B: Dissolved Oxygen Analysis 

Attachment C: Reasonable Potential Analysis - Outfall 001 

Attachment D: Reasonable Potential Analysis - Outfall 002 

Attachment E: Chlorine Effluent Limit Calculations - Outfall 002 

Attachment F: Outfall 002 Turbidity Limit Calculations 

Attachment G: Thermal Plume Calculations - Outfall 001 

1.0 

2.0 

3.0 

4.0 

5.0 

6.0 

7.0 

8.0 

9.0 

10.0 

11.0 

Description of Proposed Action 

Facility Description 

Water Quality Issues 

Existing Permit Limits 

Technology Based Limits 

Comparison of 2001 Permit Limits and Technology Based Limits 

Water Quality Analysis 

Compliance History 

Discussion of Proposed Permit 

Next Steps 

Attachments 
Permit Evaluation Report 

Blue Heron Paper Company 

1.0 Description of Proposed Action 

A National Pollutant Discharge Elimination System (NPDES) permit was issued by the 

Department of Environmental Quality (Department) to the Blue Heron Paper Company (Blue 

Heron) on August 1, 2001 (2001 NPDES permit). The permit expires on July 31, 2006. The 

Department received an NPDES permit renewal application on December 22, 2004. The 

Department is now proposing to renew the NPDES permit for Blue Heron. There are four 

primary reasons for permit renewal at this time: 1) Backwash water from the filter plant, which is 

allowed under the current permit to be discharged without treatment, needs to be addressed; 2) 

Modifications are necessary to accommodate the mill's proposed project to reuse (recycle) and 

estimated 20 percent of its wastewater; 3) The permit's effluent limits need to be modified to 

address the new temperature standards; and 4) The turbidity compliance schedule needs to 

address the issues of filter backwash treatment, the expected reuse (recycling) of the plant's 

wastewater, and the scheduled modification of the water quality turbidity rule. 

The Federal Water Pollution Control Act of 1972 and subsequent amendments require an NPDES 

permit for the discharge of wastewater to surface waters. Furthermore, Oregon Revised Statute 

(ORS 468B.050) also requires a permit for the discharge of wastewater to surface waters. This 

proposed permit action by the Department fulfills both federal and state requirements. 

2.0 Facility Description 

2.1 General 

The Blue Heron Paper Company is an employee-owned paper mill in Oregon City, Oregon. The 

facility is located on an east bank of the Willamette River near Willamette Falls (see Fig. 1). 

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FIGURE 1 - SITE MAP 
Permit Evaluation Report 

Blue Heron Paper Company 

The facility manufactures newsprint and other similar types of papers from a mixture of recycled 

newspapers and magazines, wood chips and purchased pulp. Recycled papers are pulped through 

a deinking process and wood chips are pulped thermo-mechanically. The deinking (Dl) process 

involves repulping and deinking recycled paper using water along with mechanical and chemical 

processes. Rejects from this process are either sent to the wastewater treatment system or handled 

as solid waste. In the thermo-mechanical pulp (TMP) process, wood chips received at the 

facility are washed, refined to pulp under pressure and screened. The mill uses hydrogen 

peroxide and other totally chlorine-free processes to bleach pulp as needed, depending on the 

required paper grade. Final paper production occurs with paper machines where the recycled and 

virgin fiber pulps are dewatered, pressed and otherwise processed to produce primarily newsprint 

grades of paper. The paper is wound onto large reels, cut, rewound to meet customers' order 

specifications, and weighed before being wrapped and shipped. 

The average monthly production rate of paper is approximately 640 tons per day. The average 

production rate of pulp from the deinking process is 375 tons per day and from the 

thermomechanical pulping process is 275 tons per day. 

2.2 Wastewater Treatment and Discharge 

Wastewater at Blue Heron is generated in five primary areas: the paper machine process, the 

deinking process, filter plant backwash, the steam plant and the bleach plant. During rainy 

periods stormwater is also collected (and treated) at the site. The process, steam plant and bleach 

plant wastewaters, along with any stormwater runoff, are treated and discharged through outfall 

001. Wastewater from the filter plant is currently discharged through outfall 002. The proposed 

permit includes a requirement for eliminating filter plant discharges from outfall 002 and 

rerouting them to the treatment system for discharge from outfall 001. Outfalls 003, 004 and 005 

may discharge miscellaneous wastewaters under unusual conditions, but are seldom used. The 

locations of these outfalls are presented in figure 2. Each of the wastewater discharges mentioned 

above is discussed in more detail below. 

2.2.1 Outfall 001, Aerated Stabilization Basin Effluent 

Wastewater Generation 

Paper Machines Process Wastewater 

Process wastewater is generated from three paper machines—No. 1, No. 3, and No. 4. Paper 

Machine No. 2 is no longer in service. Paper Machine No. 4 has a rated design capacity of 420 

Mg/d (megagram per day, metric ton) (machine dry). The smaller paper machines, No. 1 and No. 

3, are rated at 220 Mg/d (machine dry) and 160 Mg/d (machine dry), respectively. Although all 

three paper machines were installed prior to 1920, they have been upgraded over the years. 

The paper making process includes six steps: 

1. Pulp System 

2. Forming Section 

3. Wet Press Section 

4. Drying Section 

5. Calender and Reel 

6. Winding 
Permit Evaluation Report 

Blue Heron Paper Company 

Pulp from the Deink and TMP mills is processed through a multi-stage screening and cleaning 

system. A deculator (vacuum) is used to remove entrained air from the pulp. Blended pulp is sent 

to the headbox where, under pressure, the pulp is evenly distributed onto the forming section of 

the paper machine. At this point the pulp consists of roughly 99 percent water and 1 percent pulp. 

The paper machine uses woven fabric with vacuum to form a sheet of paper of approximately 14 

percent solids. The paper then enters the press section where felts, vacuum, and rolls are used to 

squeeze out more water. The fibers now begin to bond and form a smooth surface. The sheet at 

this time contains approximately 45 percent solids. The sheet then enters the dryer section where 

steam is injected into dryer cans to heat the sheet to approximately 82 °C. Water in the sheet 

evaporates and is exhausted by dryer hood fans. The sheet is now approximately 92 percent 

solids. Once the sheet has left the dryer section it is calendered, using steel rolls to increase 

smoothness and to even out the caliper. The sheet is then wound onto reels and transported to the 

winder. The winder is used to create a roll of paper based on customer requirements for width and 

diameter. Finished rolls are then wrapped and shipped by truck or rail car to the customer. 

The paper machines typically generate the bulk of the wastewater— approximately 19,000 cubic 

meters per day (m3/d) (5 MGD) —to be treated in the wastewater treatment system. 

Deinking Process Wastewater 

The deinking process produces approximately 362.9 Mg/d of fiber that is blended with 

thermomechanical pulp (TMP) and purchased pulp to feed the paper machines. The deinking 

process also generates process wastewater from the deink repulpers, the deink plant, and Deink 

Mill "H". Typically, approximately 11,000 m3/d (3 MGD) of wastewater is generated from the 

deinking operations. 

Steam Plant 

The steam plant typically generates 5700 m3/d (1.5 MGD) of boiler blowdown that enters the 

wastewater system. 

Bleach Plant 

The hydrogen peroxide bleach plant typically generates 760 m3/d (0.2 MGD) of wastewater. No 

chlorine is used in the bleaching process. 

Wastewater Treatment 

Process wastewater from the sources described above is conveyed through one of two pump 

stations to one primary clarifier for primary sedimentation. Primary clarifier solids (PCS) are 

dewatered then used as bedding for dairy cattle or are land applied as a soil amendment. The 

primary effluent is conveyed to an aerated stabilization basin (ASB) on the north (also west) side 

of the Willamette River for secondary treatment prior to discharge to the Willamette River. 

Primary Effluent Flow Meter 

The flow reported on the Discharge Monitoring Reports (DMRs) is measured at the effluent from 

the primary clarifier. The primary effluent meter is a Foxboro E96 magnetic meter with flow 

converter and transmitter. 

Aerated Stabilization Basin (ASB) 

The aerated stabilization basin (ASB) is located approximately 2.4 kilometers (km) upstream of 

the mill, on the opposite side of the river. Treated effluent from the ASB is discharged to the 

Willamette River at (approximately) RM 27.5 through a multi-port diffuser. Besides providing 

biological treatment, settling is accomplished in the ASB. When necessary, the ASB is dredged to 

remove accumulated solids. 
Permit Evaluation Report 

Blue Heron Paper Company 

ASB Effluent Flow 

The ASB effluent flow is not measured directly. The primary clarifier effluent flow as recorded 

by the magnetic meter has been determined to be essentially equivalent to the effluent flow by 

less than 1 percent. 

2.2.2 Outfall 002, Filter Plant Effluent 

Water to supply the mill's production processes and supporting services is taken from the 

Willamette River water treatment plant. Water treatment includes settling, flocculationcoagulation, and filtration. The water treatment plant generates an intermittent wastewater 

discharge. This discharge generally occurs three times per day and each occurrence lasts 

approximately 30 minutes. Existing effluent limitations for the filter backwash includes pH and 

monthly average/daily maximum total suspended solids (TSS) aggregated with the other outfalls. 

Outfall 002 is located at approximately RM 26.1, downstream of Willamette Falls. 

2.2.3 Outfalls 003, 004, and 005, Miscellaneous Effluents 

Outfalls 003, 004, and 005 are tailraces under the plant designated Mill H, No. 1, and No. 2, 

respectively. Each of these tailraces has a diversion structure that captures stormwater, 

groundwater and dam seepage to be sent to the plant's treatment system. The tailraces also act as 

containment for any spills that may occur. Previous discharges to the tailraces used to include 

pump seal and air compressor cooling waters. These are no longer discharged to the tailraces. As 

discussed below, discharges from these outfalls could occur only when the diversion structures 

are inundated by the river at high flows. 

Outfall 003 - Mill "H" Tailrace 

Sources include groundwater and seepage from the PGE dam. A small diversion structure in the 

tailrace diverts the flow into the mill's wastewater treatment system which after primary and 

secondary treatment is discharged through outfall 001. Discharge from this outfall is only 

expected to occur about once every two years when high river water submerges the diversion 

structure resulting in the groundwater and seepage collected behind the diversion structure to mix 

with the river water. 

Outfall 004 - #1 Tailrace 

Sources include groundwater and storm water that falls along the Union Pacific rail line through 

the mill, and seepage from the PGE dam. A small diversion structure in the tailrace diverts flow 

into the mill's wastewater treatment system. The area behind the diversion structure is used for 

containment of potential leaks in the mill's wastewater collection piping and pulping processes 

which traverse the tailrace area. As with outfall 003, discharge from this outfall could only occur 

about once every two years when high river water submerges the diversion structure resulting in 

the mixing of river water with the groundwater and seepage collected behind the diversion 

structure. 

Outfall 005 - #2 Tailrace 

Sources include groundwater and seepage from the Union Pacific railroad track bed. A tall 

diversion structure is built across the outfall and the flow is diverted to the mill's wastewater 

treatment system. The area behind the diversion structure is used as containment for the potential 

stock spill or a leak in the wastewater collection piping which traverses the tailrace area. The 

diversion structure is several feet higher than the structures at outfalls 003 and 004 so the 

likelihood of river water submerging the diversion structure - which could result in a discharge -

is extremely low. 
Permit Evaluation Report 

Blue Heron Paper Company 

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FIGURE 2 - DISCHARGE LOCATIONS 

2.3 Solids Management 

The existing NPDES permit (Appendix A) requires (Schedule D, Special Condition 10) that 

sludge (solids) be managed in accordance with an approved sludge management plan. Schedule 

B, as amended, requires monthly and annual reporting of sludge disposal and reuse. Primary 

clarifier solids are dewatered and the solids are used as dairy bedding or as a soil amendment. The 

Department's principal water quality concern is for satisfactory management of the land 

application activities to ensure that the solids are used beneficially and in an environmentally 

acceptable manner. 

2.4 Spill Control 

In 1992 and 1993, major improvements were made to prevent, control, and contain spills and 

unplanned releases of process wastewater from the wastewater collection and conveyance system. 

The centerpiece of the system is a spill control tunnel with an instrumentation and control system. 

If process water increases from the production processes and the water level rises in the primary 

clarifier, effluent pumps start sequentially to maintain the level in the clarifier. If the water level 

becomes too high in the clarifier, output of the pumps in Pump Station No. 1 (PS No. 1) is 

reduced. The same occurs for PS No. 2 if it is on line. Water will then back up into the spill 

tunnel. Staff is notified when a second pump starts in PS No. 1 indicating increased flow to the 

pumping system. An alarm will sound in the spill tunnel at 0.6 m of water depth and procedures 

to start shutting the mill down will be commenced. The wastewater from production processes, 

pump station operation, and wastewater treatment processes are monitored by levels and 

instantaneous and total flow from a control panel in the boiler house. The spill tunnel can store up 

to 300,000 gallons of water before overflowing to the river. The main advantage of the spill 
Permit Evaluation Report 

Blue Heron Paper Company 

tunnel and the control system is to provide time to take corrective action before a release to the 

river might occur. This capability was not available prior to 1993. Overall, the facility has been 

very responsive to reporting and taking action on spills. 

2.5 Sampling Procedures 

Blue Heron uses an ISCO sampler on Outfall No. 001 to collect discrete grab samples from the 

effluent on a set schedule. The sampler discharges to a large plastic carboy over a 24 hour period 

combining the grab samples to represent the required composite sample. 

2.6 Underground Injection Control 

There are no underground injection control activities at this facility. 

2.7 Wastewater Characteristics 

The 2001 NPDES permit required Blue Heron to monitor flow, BOD, color, mercury, cadmium, 

copper, lead, zinc, bacteria, temperature, turbidity, TSS and pH discharged from outfall 001. For 

outfall 002, filter backwash effluent, flow, TSS and pH were required to be monitored. For 

outfalls 003, 004 and 005, flow, temperature, TSS, pH and oil & grease were required to be 

monitored. 

Since 2001, Blue Heron has instituted several management practices which resulted in a 

reduction of flow, temperature and loading to and from the aerated settling basin (ASB). Data 

prior to this period may not be representative of current discharge conditions. Discharge 

monitoring data collected over the past three years were used to characterize effluent flow, 

turbidity, temperature, BOD and TSS levels in outfall 001 discharges. Table 1, below, presents 

average and 95th percentile values for flow, BOD, and TSS for outfall 001. Table 2 presents the 

average and 95th percentile values for flow and TSS for outfall 002. Effluent levels of other 

pollutants of concern and for outfalls 003, 004 and 005 are discussed in section 7.0, Water 

Quality Analysis. 

TABLE 1: PROCESS WASTEWATER CHARACTERISTICS (OUTFALL 001) 

Parameter 

Flow 

BOD 

TSS 

Average 

8.6 MGD 

55 mg/l 

87 mg/l 

95th percentile 

9.7 MGD 

84 mg/l 

128 mg/l 

TABLE 2: FILTER BACKWASHWATER CHARACTERISTICS (OUTFALL 002) 

Parameter 

Flow 

TSS 

Average 

0.59 MGD 

189 mg/l 

95th percentile 

0.61 MGD 

358 mg/l 

8 
Permit Evaluation Report 

Blue Heron Paper Company 

3.0 Water Quality Issues 

3.1 Applicable Water Quality Standards 

The applicable water quality standards are found in Oregon Administrative Rule (OAR) 340-041. 

They are intended to be protective of the beneficial uses for the basin, which include domestic 

water supply, industrial water supply, irrigation, livestock watering, anadromous fish passage, 

resident fish and aquatic life, salmonid spawning and rearing, wildlife, hunting, fishing, boating, 

water contact recreation, aesthetic quality, and commercial navigation and transportation. A 

summary of selected water quality standards for the Willamette River are presented in Table 3. 

TABLE 3 

SUMMARY OF SELECTED WILLAMETTE RIVER WATER QUALITY 

CRITERIA* 

Parameter 

Dissolved Oxygen 

(OAR 340-041-0016) 

Temperature 

(OAR 340-041-0028) 

pH 

(OAR 340-041-0021) 

Turbidity 

(OAR 340-041-0036) 

Total Dissolved Solids 

(OAR 340-041-0032) 

In-stream Water Quality Criteria 

Cool Water Aquatic Life Criteria (applies in summer): 

> 6.5 mg/L (absolute minimum for surface samples) 

The 7-day average maximum temperature of a stream 

identified as a migration corridor may not exceed 20 °C (68 

°F) - Insignificant anthropogenic inputs are allowed. 

> 6.5 and < 8.5 

No more than a ten percent cumulative increase in natural 

stream turbidities shall be allowed, as measured relative to a 

control point immediately upstream of the turbidity causing 

activity. 

The concentrations listed below may not be exceeded unless 

otherwise specifically authorized by DEQ - 100 mg/L 

* Note: The full texts of the criteria are available online at: www.deq.state.or.us/wq/wqrules/wqrules.htm 

3.2 Water Quality Criteria for Toxic Substances 

Tables 20, 30A and 30B of OAR 340-041 specify water quality criteria for toxic substances. The 

water quality criteria for several metals are based on hardness. For the Willamette River, a 

hardness of 25 mg/L was used to calculate water quality criteria for hardness dependent metals. 

Water quality criteria for the protection of freshwater aquatic life for selected toxic constituents 

are given below: 

9 
Permit Evaluation Report 

Blue Heron Paper Company 

TABLE 4 

WATER QUALITY CRITERIA FOR TOXIC SUBSTANCES 

Parameter 

Aluminuma 

Barium 

Cadmium 

Copper 

Iron 

Lead 

Mercury 

Nickel 

Zinc 

Unit 

Ug/L 

Ug/L 

Ug/L 

Ug/L 

Ug/L 

Ug/L 

Ug/L 

Ug/L 

Ug/L 

Criteria for Protection of Freshwater Aquatic 

Life 

Acute 

750 

N/A 

b

0.9 

b

5.16 

N/A 

b

 15.75 

2.4 

b

469 

b

38.6 

Chronic 

87 

N/A 

b

0.41 

b

3.86 

1000 

b

0.61 

0.012 

b

52 

b

34.95 

a

 Proposed criteria. pH and hardness dependent criterion 

b

 Hardness dependent criteria. A hardness of 25 mg/L was used for the 

Willamette River. 

3.3 303(d) Listing Status 

Section 303(d) of the Clean Water Act requires each state to develop a list of water bodies that do 

not meet state surface water quality standards after implementation of technology-based controls. 

The state is then required to complete a Total Maximum Daily Load (TMDL) program for water 

bodies on the 303(d) list. The TMDL program must address water quality on a basin-wide scale 

to ensure that overall water quality standards will be met. The Clean Water Act prohibits new or 

increased discharges until a TMDL has been established for 303(d) water bodies, unless the 

discharge does not contribute pollutants that cause the stream to violate water quality standards. 

Blue Heron discharges wastewater to the portion of the Willamette River that is listed as being 

water quality limited in the Department's 2002 303(d) list of streams. Table 5 includes the 

parameters for which water quality standards in the Willamette River are not met and the season 

when standards are exceeded: 

10 
Permit Evaluation Report 

Blue Heron Paper Company 

TABLE 5: 2002 303(D) LISTING INFORMATION 

Stream Segment 

Willamette River 

(RM 24.8 to 54.8) 

Parameter 

Aldrin 

Bacteria (fecal coliform) 

Biological Criteria 

DDT & DDE (DDT 

metabolite) 

Dieldrin 

Iron 

Mercury 

Polychlorinated Biphenyls 

(PCBs) 

Temperature 

Season 

Year-around 

Fall/Winter/Spring 

Year-around 

Year-around 

Year-around 

Year-around 

Year-around 

Year-around 

Summer 

The TMDL for the Willamette River is scheduled to be completed in mid to late 2006. As part of 

this permit renewal, the Department will evaluate the potential for the discharge from Blue Heron 

to contribute pollutants in the 303(d) list. 

3.4 Threatened & Endangered Species 

Species of anadromous salmonids that use the lower Willamette River near the Blue Heron site 

include chinook salmon (Oncorhynchus tshawytscha), coho salmon (O. kisutch), steelhead trout 

(O. mykiss), and cutthroat trout (O. clarki). Resident salmonid game species include cutthroat 

trout. Bull trout do not occur in this area of the Willamette River. 

On March 16, 1999, the National Marine Fisheries Service (NMFS) listed chinook salmon in the 

Lower Columbia River Evolutionary Significant Unit (ESU) as a threatened species under the 

Endangered Species Act (ESA). On March 13, 1998, NMFS listed the Lower Columbia River 

ESU steelhead trout stocks as a threatened species under the ESA. These species utilize the 

Willamette River and its tributaries. The Willamette River has been designated as critical habitat 

for listed chinook salmon and steelhead trout by the NMFS. 

The Willamette River near Blue Heron contains little in-stream habitat diversity and has a 

substrate primarily composed of sand and silt. Therefore, this area of the Willamette River does 

not provide spawning habitat for salmonids. The Willamette River near Blue Heron is primarily 

used by salmonids for upstream and downstream migratory purposes, although some rearing and 

feeding activities by juveniles likely occur during their downstream migration. Anadromous 

salmonids can typically be found in the Willamette River near Blue Heron throughout the year as 

indicated in Figure 3, "Anadromous Species Use and Timing in the Willamette River near 

Portland, Oregon". 

11 
Permit Evaluation Report 

Blue Heron Paper Company 

Willamette River (Mouth to Willamette Falls) 

Species Freshwate 

Life phase 

Sprin Upstream Migration 

Chinook 

Salmo 

Juvenile Outmigratio 

Fall Upstream Migration 

Chinook 

Salmo 

Juvenile Outmigratior 

Coho 

Salmo 

Upstream Migration 

Juvenile Outmigratior 

Summe Upstream Migration 

Steelhead 

Trout 

Juvenile Outmigratior 

Winte Upstream Migration 

Steelhead 

Trout 

Juvenile Outmigratior 

Sea- Upstream Migration 

Cutthroat 

Trout 

KeltOutmigration 

Juvenile Outmigratio 

Life Stage Presence 

eak Activity 

ess than Peak Activity 

FIGURE 3: ANADROMOUS SPECIES USE AND TIMING IN THE WILLAMETTE RIVER 

NEAR PORTLAND, OREGON 

Although different juvenile salmonid species emigrate at different times of the year, in general 

there is a peak outmigration in the spring and a smaller peak in the fall. Data from the Portland 

General Electric (PGE) Sullivan Dam elevator study (PGE, 1999) at Willamette Falls shows 

emigration times of juvenile salmonids typically occurring from mid February through June with 

a smaller secondary peak of spring chinook salmon in October through mid-November (Figure 4). 

12 
Permit Evaluation Report 

Blue Heron Paper Company 

•-Wld^Qi n HatchSpChn 

•A- ••- Wld SBfri —•— Hatch SHhd 

Coho • • • Fall Chin 

Jar. Feb. March /April May Jure JUy Ajg Sept Oi. Nfcy Dec 

Sem-MrtlyFteriod 

Figure 4: Juvenile Salmonid Migration Timing at Sullivan Dam 

(Willamette Falls) 

3.5 Mixing Zones (MZ) and Zones of Initial Dilution (ZID) 

OAR 340-041-0053 provides that the Department may suspend all or part of the water quality 

standards in a designated portion of the receiving water to serve as a zone of dilution for wastes 

and receiving waters to mix thoroughly. Water quality standards for all parameters must be met 

at the edge of the defined mixing zone. 

3.5.1 Mixing Zones 

Outfall 001 

Outfall 001 consists of an approximately 152 meter (500-ft.) long, buried 24-inch concrete-coated 

steel pipe extending approximately 107 m. (350 ft.) from the west bank of the Willamette River 

near river mile 27.8 (Figure 5). A diffuser consisting of eight 8-inch ports is spread over the last 

32 m. (105 ft.) of the outfall. The ports are at an angle of 15 degrees above the horizontal and at a 

45° angle relative to the ambient current, oriented away from the west bank. The ports are 

located approximately 0.6 m (2 ft.) above the river bottom. The width of the river under lowflow conditions near the discharge location is 290 m. (950 ft.) with an average depth of 

approximately 25 feet and a maximum depth of 10.4 m. (34 ft.). The local water depth at the 

Blue Heron diffuser at low-flow is approximately 9.8 m. (32 ft.). 

The Department previously established two mixing zones for outfall 001. One mixing zone was 

established prior to the 2001 permit and is used for all parameters regulated by the previous 

permit. The second mixing zone was established by the 2001 permit and is specifically for 

temperature and turbidity. 

13 
Permit Evaluation Report 

Blue Heron Paper Company 

West Linn 

Paper Co.\ 

West Linn 

Paper ASB 

WEST LINN 

Blue Heron 

Paper ASB 

Blue Heron 

Paper 

OREGON CITY 

West Linn Paper 

Outfall and 

Diffuser 

Blue Heron Paper 

Outfall and Diffuser 

Figure 5: Detailed location of Outfall 001 (From 10/02 BH Dilution Study) 

Temperature and Turbidity Mixing Zone 

The temperature and turbidity mixing zone is defined as that portion of the Willamette River 

within a rectangle with a length not to exceed 75 m downstream from the longitudinal centerline 

of the diffuser pipe and a width of 115 m. The west side of the rectangle shall be 46 m from the 

center of the diffuser and the east side of the rectangle shall be 69 m from the center of the 

diffuser. The Department's primary reasons for allowing a mixing zone of this size and location 

are: 

1. The mixing zone will not overlap with the mixing zone for the West Linn Paper 

Company, which is approximately 600 m downstream; 

2. From computer modeling performed for this permit renewal (and based on the Dilution 

Performance Field Verification & Modeling Study prepared by CH2MHill for Blue 

Heron in 2002), the critical condition dilution at 300 meters downstream from the 

diffuser is approximately 127. Therefore, the effluent from Blue Heron is actually 

diluted to less than 1 percent well before it reaches the West Linn Paper Company mixing 

zone; 

3. Completion of initial dilution will occur within the proposed mixing zone; 

4. A zone of at least 47 m wide will be allowed along both banks of the river to avoid 

impact on aquatic life (fisheries agencies have previously indicated that smaller juvenile 

salmonids may migrate within 46 m of the bank at a depth of approximately 5.5 m.); 

5. The stream width of the Willamette River at 7Q10 low flow where Blue Heron 

discharges is approximately 290 meters. Thus, the defined mixing zone occupies less 

than 40% of the width of the Willamette River at low flow and will occupy less at higher 

flows; 

6. A Biological Criteria Study completed by consultants for Blue Heron in the area in and 

around the mixing zone found that there is no critically important habitat, such as coldwater refugia, within the study area; and 

7. Based on the above information, the Department considers that the mixing zone will be a 

small as feasible. 

14 
Permit Evaluation Report 

Blue Heron Paper Company 

In addition, critical condition mixing zone analyses indicate that the effluent plume will not be 

bottom attached. This is due to the location and orientation of the diffuser ports and the buoyant 

nature of the discharge. Figure 6, below, gives a graphical presentation of output from the 

calibrated computer modeling for critical conditions. The bottom of the river at this location (and 

this flow) is at an approximate depth of 9.8 meters. 

1 

2 

3-

4 

|

 5 

o 

6 

7 

8 

9 

C 

Blue Heron Plume Elevation 

mm~^-

1 ; 

' \ • 

3 A 

• ' • 

5 E 7 E 

t 

S 1 

loriz. Distance 

0 11 1 

mm Source (m; 

2 13 1 1 15 1 6 17 18 19 2 

— Centerline 

, Plume Bndry 

0 

Figure 6: Visual Plumes Graphical Output of the Plume Elevation for Outfall 001 

It should be noted that since the 2001 permit was issued, new "Temperature Thermal Plume 

Limitations" have been established under Oregon Administrative Rule (OAR) 340-041-0053 -

Mixing Zones. Compliance with this rule is analyzed in Section 7. 

Blue Heron conducted a mixing zone study to determine mixing characteristics and available 

dilution for the temperature and turbidity mixing zone. The results of the mixing zone study are 

presented in the Dilution Peformance Field Verification & Modeling Study by CH2MHU1 

(October 14, 2002). The mixing zone study consisted of a field dye study and discharge 

modeling using several models. The modeling indicated that the Visual Plumes modeling 

package more closely matched the results of the field dye study. Therefore, the Visual Plumes 

modeling package was used for scenario modeling. A variety of discharge and ambient river 

conditions were modeled. 

The October 2002 dilution study was reviewed by the Department and approved dilutions were 

given in a Departmental letter to Blue Heron dated February 27, 2003. The approved predicted 

dilutions at the edge of the mixing zone for critical chronic discharge conditions are: May/June 

period- 100; July/Aug. period - 90, and Sept./Oct. period - 102. 

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Blue Heron Paper Company 

Mixing Zone for Parameters Other Than Temperature and Turbidity 

The second mixing zone for Outfall 001 is for all regulated parameters other than turbidity and 

temperature. The mixing zone was defined in the previous permit a s that portion of the 

Willamette River within 15.2 meters of the point of discharge. 

Since the effluent plume does not extend upstream of the diffuser, this mixing zone has been 

modified to include only that portion of the river downstream of the diffuser. This will allow for 

a mixing zone with a width of 62.4 m and a length of 15.2 m. The Departments primary reasons 

for allowing a mixing one of this size are the same as those noted for the temperature and 

turbidity mixing zone given above. This mixing zone is smaller because a need for a larger 

mixing zone has not been demonstrated. 

Based on the modeling results from the dilution study mentioned above, calculated minimum 

dilution for this mixing zone is 70. 

Outfall 002 

Intermittent discharges of filter plant wastewater currently occur through outfall 002. The outfall 

consists of a single 18 inch port that discharges at an approximate depth of 54 feet at a location 

near the mill downstream of the Willamette Falls at approximate river mile (RM) 26.0. The 

regulatory mixing zone was established for outfall 002 under the previous permit and is defined 

as that portion of the Willamette River within 10 m of the center of the diffuser. An estimate of 

the dilution at the mixing zone boundary was achieved through computer modeling (using 

CORMIX - graphical output presented in Figure 7). The estimated dilution at the mixing zone 

boundary for the critical low-flow period (7Q10) is 14. The proposed permit includes the 

requirement (described below) to eliminate all discharges from this outfall with the exception of 

those composed solely of river water. 

Figure 7: Outfall 002 Modeled Plume with Downstream MZ Boundary (10 meters) 

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Blue Heron Paper Company 

Outfalls 003, 004 & 005 

As noted above, outfalls 003, 004 and 005 discharge infrequently and only at very high river 

stages/flows. The regulatory mixing zones were established for outfalls 003, 004 and 005 under 

the previous permit and are defined as those portions of the Willamette River extending 3 m 

toward the center of the river and extending 10 m downstream of the junction of the respective 

tailrace and the river bank. 

3.5.2 Zone of Immediate Dilution 

A zone of immediate dilution (ZID) within the mixing zone for outfall 001 has been established 

as allowed by OAR 340-041-0053(2)(a)(A). Compliance with acute toxicity standards must be 

met at the edge of the ZID. A Zone of Immediate Dilution (ZID) was previously established for 

the Blue Heron discharge at Outfall 001 and is defined as the zone within a radius of 6.8 m from 

the center of each diffuser port. 

The establishment of this ZID was based on EPA guidance (Technical Support Document for 

Water Quality-Based Toxics Control, 1991 [TSD]) on selecting the size of ZIDs. The diffuser, 

with an initial velocity of greater than 3 m/s, is considered a high velocity discharge. The TSD 

indicates that for high velocity discharges the acute toxicity criteria (or criteria maximum 

concentration - CMC) will be met within a few minutes under practically any conditions with a 

ZID of 50 times the discharge length scale. (The discharge length scale is defined as the square 

root of the cross-sectional area of any discharge pipe.) The diameter of the diffuser ports is 

approximately 150 mm, which results in a ZID of 6.8 m. This will ensure the acute criteria, if 

met at the edge of the ZID, will expose drifting organisms to acute pollutant concentrations for a 

far shorter time than the toxicity standards allow. (The acute toxic criteria are designed to protect 

organisms at exposures of one hour or less.) 

The ZID for outfall 001 is defined as that portion of the regulatory mixing zone within 6.8 m of 

the center of each diffuser port. Since both mixing zones for outfall 001 are defined as a portion 

of the river downstream of the diffuser, the ZID also only extends downstream. 

The October 2002 dilution study referenced above gave predicted dilutions at the edge of the 

ZID. The approved predicted dilutions at the edge of the ZID for critical acute discharge 

conditions are: May/June period- 35; July/Aug. period - 33, and Sept./Oct. period - 35. 

3.6 Antidegradation Review 

The Department's antidegradation policy in OAR 340-041-0004 requires that a review of 

discharges to surface waters be conducted to ensure that existing water quality is not lowered 

unless there are no reasonable alternatives available and the lowering of water quality is 

necessary for economic and social benefit. 

The NPDES permit for Blue Heron is a permit renewal with no increase in discharge load (in fact, 

this permit will result in substantial reductions in discharge load). Permit renewals with no 

increase in discharge load are not considered to lower water quality from existing water quality. 

Thus, the Department finds that the discharge is not subject to an in-depth antidegradation 

review. (Antidegradation Policy Implementation Internal Management Directive for NPDES 

Permits and Section 401 Water Quality Certifications, ODEQ March 2001). 

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Blue Heron Paper Company 

4.0 Existing Permit Limits 

Existing Limits for Outfall 001 

The 2001 NPDES permit includes the following effluent limits and notes for outfall 001 (from 

Schedule A. 1.). 

TABLE 6: EXISTING EFFLUENT LIMITS AT OUTFALL 001 - PART 1 

Outfall 001 

Aerated Stabilization Basin Effluent 

Parameter 

flow 

BOD5 

BOD5 

TSS (Note 1) 

temperature 

(Note 2) 

E. coli bacteria 

(Note 3) 

turbidity 

turbidity 

zinc 

pH 

Season 

Jun 1 -Sep 31 

Junl-Oct31 

Nov 1 -May 31 

Jan 1 - Dec 31 

Loadings 

Monthly 

Average 

~ 

3625 kg/d 

4275 kg/d 

5525 kg/d 

Daily 

Maximum 

~ 

4350 kg/d 

6800 kg/d 

10275 kg/d 

Maximum 

7-Day Moving 

Average 

0.460 m3/s 

~ 

~ 

~ 

See Condition A8 

Jan 1 -Dec 31 

May 1 -Oct 31 

Nov 1 - Apr 30 

Jan 1 - Dec 31 

Jan 1 - Dec 31 

126/100 mL 

40 NTU 

115 NTU 

— 

406/100 mL 

~ 

~ 

50 kg/d 

~ 

70 NTU 

200 NTU 

~ 

shall be within the range of 6.0 to 8.5 

Notes for Condition Al (Outfall 001): 

1. During periods when dredging is conducted in accordance with an approved Dredging 

Project Management Plan, effluent limitations for TSS shall be as specified in the approved 

plan. 

2. The temperature effluent limitations are set forth in Condition A8 and will vary based on the 

Temperature Management Plan as described in Condition A8. 

3. Monthly limitation shall be calculated as 30-day log mean. If the daily maximum is exceeded 

in any month, the permittee may take at least five consecutive re-samples at four-hour 

intervals beginning no later than 28 hours after the original sample was taken, or 4 hours 

after the permittee is notified of the exceedence if notification was made more than 28 hours 

after the original sample was taken. If the log mean of the five or more re-samples is less 

than or equal to 126/100 mL, no violation of the daily maximum shall be deemed to have 

occurred. For a month in which an exceedence of the daily maximum occurred and the 

permittee performed re-sampling, the re-samples shall replace the exceedence sample in 

calculating the monthly average, if the log mean of the re-samples is less than or equal to 

126/100 mL. If the log mean of the re-samples is greater than 126/100 mL, then the monthly 

average shall be calculated as a log mean of all samples for the month. 

18 
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Blue Heron Paper Company 

In addition, Schedule A8 of the 2001 permit included requirements pertaining to a temperature 

management plan and temperature effluent limits related to outfall 001. Schedule A8 of the 2001 

permit is given below. 

A8 Temperature Management Plan 

The effluent limitations and other conditions in this permit related to temperature shall constitute 

the surface water temperature management plan (temperature management plan) required by 

OAR 340-41-0026(3)(a)(D) applicable to the permittee. Provided that the permittee complies 

with this temperature management plan, the permittee shall be deemed to be in compliance with 

the state temperature water quality standard and not be deemed to be causing or contributing to 

a violation of the water quality standards for temperature, not withstanding Condition A6 

(Mixing Zones and Dilutions Defined). 

Temperature Effluent Limits and Heat Load Reduction Program: The permittee shall reduce the 

effluent temperature and heat load discharged from Outfall 001 according to the schedules given 

in Tables A8-1 and A8-2: 

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Blue Heron Paper Company 

TABLE 7: EXISTING EFFLUENT LIMITS AT OUTFALL 001 - PART 2 

Temperature and Excess Heat Load Limitations 

January 1 - December 31 

Effective 

Date 

Upon 

Issuance 

24 months 

after issuance 

48 months 

after issuance 

Upon 

Issuance 

Temperature Limitations 

Maximum 7-Day Average Effluent 

Temperature After Effective Date 

°C 

33.8 

33.0 

30 

Maximum Monthly Average 

Effluent Temperature After Effective 

Date 

°C 

32.2 

29.9 

27.2 

Excess Heat Load Limitations 

Maximum 7-Day Average Excess 

Heat Load Discharged After 

Effective Date 

MW 

31.6 

Maximum Monthly Average Excess 

Heat Load Discharged After 

Effective Date 

MW 

27.2 

Relative Heat Load Limitations 

Effective 

Date 

Upon 

Issuance 

24 months 

after issuance 

48 months 

after issuance 

Upon 

Issuance 

24 months 

after issuance 

48 months 

after issuance 

Upon 

Issuance 

24 months 

after issuance 

48 months 

after issuance 

Maximum 7-Day Average Effluent 

Temperature After Effective Date 

MW 

Monthly Average Relative Heat 

Load Discharged After Effective 

Date 

MW 

May 1-June 30 

24.9 

22.9 

19.9 

21.5 

19.5 

16.5 

July 1 - August 31 

22.5 

20.5 

17.5 

18.6 

16.6 

13.6 

September 1 - November 30 

24.4 

22.4 

19.4 

20.8 

18.8 

15.8 

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Permit Evaluation Report 

Blue Heron Paper Company 

The heat load discharged shall be calculated using the following formula: 

f 

H'=p CpQ(AT) 

f L 

1000 

V nr J , J 

V s J 

f

\MW^ 

where: 

FT = heat load discharged (see below for definition of relative and excess) 

p= density of water, 1.0 kg/L 

Cp = specific heat of water, 4182 J/(kg»°C) 

Q = effluent flowrate in cubic meters per second (m3/s) 

AT = difference in temperature between effluent temperature and stipulated condition (see below 

for definition of relative and excess) 

Heat load is stipulated as relative or excess, as defined below. Relative heat load for each day 

shall be determined by subtracting average ambient intake water temperature from the average 

effluent temperature for that day. Excess heat load for each day shall be determined by 

subtracting a water quality standard criterion (20 °C) from the average effluent temperature for 

that day. The water quality standard criterion for the period July 1 to September 15 shall be 

20°C. 

Heat loads shall be calculated on a daily basis. The 7-day moving average heat load shall be 

calculated as the 7-day moving average of the calculated heat load for the individual days. The 

monthly average heat load shall be calculated as the monthly average of the heat load for the 

individual days of each calendar month (or period if less than a full month). If a calculation 

results in a heat load value of less than zero, the result shall be recorded as zero. Individual 

values of zero shall be included in calculating average values. Seven-day moving averages shall 

be reset on May 1 annually. The seven-day moving average for the first six days of the season 

beginning July 1 shall be subject to the heat-load limits for the preceding season. 

In any designated period (7-day, month), if the temperature effluent limit has been achieved, the 

permittee shall be deemed in compliance with this condition without consideration of relative 

heat load. In any designated period, if the effluent temperature limit has been exceeded but the 

relative heat load limitation has not been exceeded, the permittee shall be deemed in compliance 

with this condition. Otherwise the permittee shall be deemed out of compliance with this 

condition for the designated period. 

Existing Limits for Outfall 002 

The 2001 NPDES permit includes the following effluent limits and notes for outfall 002 (from 

Schedule A.2). 

TABLE 8: EXISTING EFFLUENT LIMITS AT OUTFALL 002 

Outfall 002 

Filter Plant Backwash Effluent 

Parameter 

pH 

Limitations 

shall be within the range of 5.5 to 8.5 

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Blue Heron Paper Company 

Existing Limits for Outfall 003, 004, 005 

The 2001 NPDES permit includes the following effluent limits and notes for outfall 002 (from 

Schedule A.3). 

TABLE 9: EXISTING EFFLUENT LIMITS AT OUTFALL 003, 004 & 005 

Outfalls 003, 004, and 005 

Miscellaneous Effluents 

Parameter 

oil & grease (individual outfalls) 

pH (individual outfalls) 

temperature (individual outfalls) 

visible discharge events 

(individual outfalls) 

Loadings 

Daily Maximum 

10 mg/L 

Limitations 

shall be within the range of 6.5 to 8.5 

pump seal water and compressor cooling water shall 

not be discharged at any time that the ambient river 

temperature exceeds 20 °C 

shall not exceed 8 events per calendar year for all 

outfalls combined and 8 hours duration for any event 

Other Existing Limits for All Outfalls 

The 2001 NPDES permit also includes the following effluent limits for combined TSS loadings 

from all outfalls (from Schedule A.4). 

TABLE 10: EXISTING EFFLUENT LIMITS - COMBINED TSS 

Outfalls 001, 002, 003, 004, and 005 

Combined Total of All Effluents Aerated Stabilization Basin Effluent 

Parameter 

TSS 

(combined 

total) 

Season 

Jan 1 - Dec 31 

Loadings 

Monthly Average 

6855 kg/d 

Daily Maximum 

13175 kg/d 

5.0 Technology Based Limits 

Development of effluent limitations for a surface water discharge involves first determining 

applicable technology based limits and then determining water quality based limits. The NPDES 

permit contains the more stringent of the two limits. 

The U.S. Environmental Protection Agency (EPA) has developed effluent limitation guidelines 

(ELGs) for many types of industries. The ELGs are typically expressed in terms of mass of a 

particular pollutant allowed per unit of production or unit of flow. ELGs are also expressed as 

concentration in which case the production is not relevant. If ELGs are not published for a 

particular industry, DEQ follows federal guidelines and develops equivalent technology based 

limits using best professional judgment. 

For existing point source discharges, ELGs have been developed for three categories: Best 

Practicable Control Technology Currently Available (BPT), Best Conventional Pollutant Control 

Technology (BCT), and Best Available Technology Economically Achievable (BAT). BPT 

represents the minimum technology level and applies to all existing point sources discharges for 

which ELGs have been published. BCT replaces BPT for conventional pollutants, and BAT 

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Blue Heron Paper Company 

replaces BPT for non-conventional and toxic pollutants. BPT limitations must be met upon 

publication of the ELGs. EPA allows additional time for facilities to comply with BCT and BAT 

limitations. 

Blue Heron produces newsprint and other paper grades using both deink and thermomechanical 

(TMP) pulps, which are produced on-site. Accordingly, discharges from the mill are subject to 

the effluent limits contained in 40 CFR Part 430, Subparts G—Mechanical Pulp (production 

through the application of the thermomechanical process) and Subpart I—Secondary Fiber Deink. 

Because the mill is an existing source, it is subject to the "best practicable control technology 

currently available" (BPT) effluent limits set forth in 40 CFR § 430.72(a) for mills using the 

thermomechanical process and in 40 CFR § 430.92 for deink mills. The "best available 

technology economically achievable" (BAT) limits under 40 CFR §§ 430.74 and 430.94 do not 

apply to the mill because it does not use zinc hydrosulfite as a bleaching agent or chlorophenoliccontaining biocides. 

TABLE 11 - TECHNOLOGY-BASED EFFLUENT LIMITS 

Technology-Based Effluent Limits 

Production (from application) 

TMP 

250 Mg/d 

(275 Tons/d) 

Deink 

341 Mg/d 

(375 Tons/d) 

Effluent Limitation Guidelines 

Parameter 

BOD5-Monthly Avg 

BOD5-Daily Max 

TSS-Monthly Avg 

TSS-Daily Max 

TMP 

kg/Mg 

5.55 

10.60 

8.35 

15.55 

Deink 

kg/Mg 

9.40 

18.10 

12.95 

24.05 

Effluent Limitations 

Parameter 

BOD5-Monthly Avg 

BOD5-Daily Max 

TSS-Monthly Avg 

TSS-Daily Max 

TMP 

kg/d 

1388 

2650 

2088 

3888 

Deink 

kg/d 

3205 

6172 

4416 

8201 

Total 

kg/d 

4593 

8822 

6504 

12089 

The categorical effluent limits for BOD for the forecast production levels would exceed the 

current NPDES permit limits for these parameters. The existing effluent limits for BOD cannot be 

increased to the calculated effluent limits based on forecasted production and the technologybased effluent limitation guidelines. This is prohibited by the anti-backsliding provision of the 

Clean Water Act, which prohibits subsequent effluent limitations that are less stringent than the 

comparable effluent limitations in the previous permit. The categorical effluent limits for pH (5.0 

to 9.0 standard units) are not production-based. The categorical effluent limits for TSS are lower 

than the total TSS loads for the facility (from all outfalls) allowed under the 2001 permit. 

Therefore, the maximum technology-based effluent limitations for conventional pollutants 

applicable to the Blue Heron facility are the existing effluent limitations for BOD5 and pH, and 

the effluent limitations for TSS presented in table 11 for TSS. The BCT limitations for TMP and 

Deink subcategories are the same as the BPT limitations, so the BPT limitations apply directly. 

The BAT limitations for pentachlorophenol, trichlorophenol, and zinc do not apply to the Blue 

23 
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Blue Heron Paper Company 

Heron facility because these chemicals are not used. The permit will include a condition 

prohibiting use of pentachlorophenol, trichlorophenol, and zinc compounds. 

For the filter backwash discharge from the water treatment plant, there are no technology-based 

effluent limitations. 

6.0 Comparison of 2001 Permit Limits and Technology-based Limits 

This section presents a comparison of the 2001 NPDES Permit limits with the technology-based 

limitations from EPA's effluent limitation guidelines. Since Blue Heron did not request a mass 

load increase, the proposed limits to be used for water quality analysis will be the more stringent 

of either the 2001 NPDES Permit limits or the technology-based limitations calculated above. 

For BOD and TSS at outfall 001, the 2001 NPDES Permit limits are more stringent than the 

limits calculated using the technology-based standards. However, the technology-based limitation 

for TSS is more stringent than the combined TSS effluent limitation for all outfalls. Therefore, 

the 2001 NPDES permit limits will be used for the water quality analysis with the exception of 

the TSS effluent limits for the combined outfalls, where the more stringent technology-based 

limits will be used. 

7.0 Water Quality Analysis 

This section determines pollutants of concern and evaluates each parameter to determine whether 

the concentration of the pollutant in the discharge represents a "reasonable potential to exceed" 

water quality standards. If the discharge concentration of a particular pollutant has a reasonable 

potential to exceed water quality standards, then water quality based effluent limits are 

established for that pollutant. To determine whether the discharge has a reasonable potential to 

exceed water quality standards for these pollutants, a spreadsheet that simulates the approach in 

EPA's Technical Support Document for Water Quality Based Toxics was used. Maximum 

effluent concentrations, water quality criteria, and mixing zone data are used to determine 

whether the discharge has a reasonable potential to exceed water quality standards. 

7.1 Pollutants of Concern 

Using effluent data from discharge monitoring reports, 303(d) parameters, and monitoring 

conducted for the NPDES permit application, the pollutants of concern at each outfall were 

determined. 

Outfall 001 

Based on an analysis of monitoring data, the pollutants of concern are BOD, TSS, pH, color, 

temperature, turbidity, aluminum, arsenic, chromium, copper, lead, mercury, nickel, and zinc. 

Analytical results for volatile, semi-volatile, and base-neutral organic compounds were below 

detection limits. Analytical results for pesticides/PCBs were also below detection limits. Thus, 

organic compounds and pesticides/PCBs are not included as pollutants of concern. 

Outfall 002 

For the filter backwash discharge, the pollutants of concern, based on materials added to the 

water used for backwashing water as well as effluent monitoring, are TSS, turbidity, pH, chlorine 

and aluminum. 

Outfalls 003, 004 & 005 

The pollutants of concern for outfalls 003, 004 and 005 are pH, TSS, oil & grease, and turbidity. 

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Blue Heron Paper Company 

7.1.1 Dissolved Oxygen/BOD 

The 2001 NPDES Permit includes a biochemical oxygen demand (BOD) limit for the discharge 

from outfall 001. BOD is a measure of the oxygen demand exerted by the wastewater. BOD can 

affect dissolved oxygen levels in the receiving stream. Dissolved oxygen analysis has both a 

near-field component, which is primarily influenced by mixing, and a far-field component, which 

is primarily influenced by the oxygen demand exerted by the wastewater. Since the travel time to 

the edge of the mixing zone is quite short compared to the time required for the BOD to exert an 

oxygen demand, the near-field analysis is primarily influenced by dilution within the mixing 

zone. 

The 2001 Permit effluent limits for BOD were based on achieving the applicable water quality 

standard for dissolved oxygen in water bodies providing cool-water aquatic life. In the permit 

evaluation report for the 2001 permit renewal, the Department presented the analyses indicating 

that water quality-based effluent limitations for BOD are not needed for the Blue Heron 

discharge. These analyses are presented in Appendix B of this report. The conclusions of the 

2001 analyses related to BOD and DO also hold true for the current applicable water quality 

standard for dissolved oxygen (OAR 340-041 -0016(l)(c)). 

Based on these evaluations, the Department is proposing to include the currently permitted BOD 

loads in the renewal NPDES permit. 

7.1.2 Turbidity 

The water quality standard for turbidity is dependent on background stream turbidity 

measurements. The current standard states that no more than a 10% cumulative increase in 

stream turbidity levels is allowed relative to a control point immediately upstream of the turbidity 

causing activity. To establish permit limits and to determine compliance with this standard, it is 

necessary to conduct in-stream monitoring upstream of the discharge over a broad time period as 

well as to gather effluent discharge monitoring data for the same broad time period. 

Outfall 001 

Turbidity effluent limits for outfall 001 were developed for the 2001 NPDES Permit. These 

limits were designed to achieve the current water quality standard allowing no more than a 10% 

increase over background turbidity values. The dilution values used to derive the turbidity 

effluent limits in the 2001 Permit are lower than the refined dilution values noted in Section 3.5, 

above. 

The 2001 Permit gave a compliance schedule for meeting the turbidity limits in Schedule C4. As 

explained in Section 9.5 below, the proposed renewal permit includes a new compliance schedule 

to address three issues: 1) The renewal permit requires Blue Heron to reroute the effluent from 

the filter backwash operations through the treatment system and to outfall 001. This will have an 

impact on engineering design efforts aimed at achieving the final effluent limits; 2) Blue Heron 

plans on implementing a project to reuse wastewater at the plant. This project is expected to 

significantly reduce the plant's use of energy (natural gas) and is also expected to result in a 

decrease in effluent flow (with associated reductions in pollutant loadings). This also will have 

an effect on engineering design for meeting the final effluent limits; and 3) A new turbidity rule 

is scheduled to be presented to the Oregon Environmental Quality Commission later this year that 

may have a significant impact on this limit. 

The rerouting of filter plant discharges and the reuse of plant effluent, both of which are expected 

to have significant environmental benefits, are expected to change the character of the wastewater 

going to the plant's treatment system. This necessitates a review of the turbidity feasibility study 

and engineering design previously completed. These changes will take two or more years to fully 

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Permit Evaluation Report 

Blue Heron Paper Company 

implement; therefore, additional time will be needed to assess the impact of these changes on the 

performance of the ASB and turbidity. 

Outfall 002 

The discharges from outfall 002 are short-term and intermittent. The discharges are 30 minutes 

in duration and occur 3 times per day (at 8 hour intervals). An analysis (Appendix F) was 

performed to determine the turbidity effluent limitations necessary to meet the turbidity standard. 

The resulting effluent limitations - a daily maximum of 94 NTU for the summer and a daily 

maximum of 234 NTU for the winter - are included in the proposed permit. 

Outfalls 003, 004 and 005 

Outfalls 003, 004 and 005 are expected to have minimal discharges that could occur only during 

high river flows when background turbidity will be at its highest. It is expected that the mixing 

that will occur by the time any discharge reaches the edge of the 10 meter mixing zone will 

provide the dilution to meet the turbidity water quality standard. Since there is no reasonable 

potential for these discharges to violate the turbidity water quality standard, the Department is 

proposing to not include turbidity effluent limits for these outfalls. 

7.1.3 Total Suspended Solids 

For TSS, there are no water quality standards. The effluent limits from the 2001 NPDES permit, 

which are more stringent than the technology based effluent limits, will be applied at outfall 001. 

TSS is also a parameter of concern in the filter backwash discharge at outfall 002 and for the 

discharges from outfalls 003, 004 and 005. The 2001 NPDES permit included combined effluent 

limits for TSS covering all five outfalls. These limits were 6855 kg/d as a monthly average and 

13175 kg/d as a daily average. These limits are less stringent than the technology based limits for 

TSS given in Table 11 above. The combined TSS limits in the proposed permit therefore reflect 

a reduction to meet the technology based limits of 6504 kg/d as a monthly average and 12089 

kg/d as a daily average. 

7.1.4 Temperature 

The temperature effluent limits for this permit are derived from each of the following three areas: 

1) Compliance with the temperature standard (OAR 340-041-0028), 2) Compliance with the 

temperature thermal plume limitations (OAR 340-041-0053(2)(d)), and 3) Comparison with the 

temperature effluent limits in the 2001 permit. The more stringent limits from each of these will 

be used to determine the final temperature effluent limits. 

7.1.4.1 Temperature Water Quality Standard 

Oregon's temperature standard has been revised substantially since the issuance of the 2001 

permit. These changes necessitated a review and reevaluation of the temperature and heat load 

limits in the existing permit. 

Based on the fish use designations for the Willamette Basin set out in Figure 340A of OAR 340-

041-340, this segment of the Willamette River serves as a salmon and steelhead migration 

corridor. OAR 340-04l-0028(4)(d) states that, unless superseded by the natural conditions criteria 

described in the rule, the 7-day average maximum temperature of a stream identified as a 

migration corridor may not exceed 20 °C (68 °F). In addition, the temperature standard calls for 

the protection of coldwater refugia to allow for salmon and steelhead migration. A Biological 

Criteria Study of the area surrounding the outfall found no coldwater refugia. Also, the mixing 

zone size and location is designed to be protective of salmonid migration (see Section 3.5). 

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Blue Heron Paper Company 

As noted above, this segment of the Willamette River does not meet water quality standards for 

temperature during the summer months. For streams that do not meet water quality standards, 

OAR 340-041-0028(12) states the following: 

"Prior to completion of a temperature TMDL or other cumulative effects analysis, no 

single NPDES point source that discharges into temperature water quality limited water 

may cause the temperature of the water body to increase more than 0.3 degrees Celsius 

(0.5 degrees Fahrenheit) above the applicable criteria after mixing with either twentyfive(25) percent of the stream flow or the temperature mixing zone, whichever is more 

restrictive. " 

Since a temperature TMDL has not been finalized for the Willamette River, the above provision 

from OAR 340-041-0028(12) applies. Mass balance analyses were conducted to determine 

whether the discharge would cause a temperature increase greater than 0.3 °C at either at the edge 

of the established temperature mixing zone or after mixing with twenty-five percent of the stream 

flow. 

Temperature increase at the edge of the mixing zone 

The calculation to determine temperature after mixing with the available temperature mixing zone 

is as follows: 

Te=[(Tmz*Qinz)-(Qs*Ts)]/Qe 

Where: 

Te is the allowable temperature of the effluent; 

Tinz is the allowable temperature at the edge of the mixing zone (20.3 °C); 

Qmz is the dilution at the edge of the mixing zone; 

Qs is the portion of the Willamette River available for mixing (Qmz - 1); 

Ts in the water quality standard for the Willamette River (20 °C); and 

Qe is the effluent dilution factor when compared to the stream (by definition, the value of Qe is 

one [1]). 

Estimated dilutions at the edge of the mixing zone with effluent flows at the maximum permitted 

value of 10.5 MGD are: 

Seasonal Period 

May/June 

July/August 

Sept/Oct 

Estimated Dilution at the Mixing Zone 

Boundary (MZB) 

100 

90 

102 

The mass balance analyses based on the available dilution within the mixing zone indicates that 

for the river temperature at the edge of the mixing zone to be increased by 0.3 °C the discharge 

temperature for the facility would have to be 50.0 °C for May/June, 46.9 °C for July/August, and 

50.6 °C for September/October. 

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Blue Heron Paper Company 

Temperature increase after mixing with 25% of the river flow 

The calculation to determine temperature after mixing with twenty-five percent of the stream flow 

is as follows: 

Te= KQPS + QR/4)* (Tmz)]-[( QRI A)* T s ] - (QS*TS)]/ QPS 

Where: 

Te is the allowable temperature of the effluent; 

Tinz is the allowable temperature after mixing with twenty-five percent of the stream flow (20.3 

°C); 

QPS is the maximum effluent flow; 

QR is the seasonal 7Q10 Willamette River low flow; and 

Ts in the water quality standard for the Willamette River (20 °C). 

The mass balance analyses based mixing with twenty-five percent of the river flow indicates that 

for the river temperature to be increased by 0.3 °C the discharge temperature for the facility 

would have to be 51.8 °C for May/June, 46.9 °C for July/August, and 52.4 °C for 

September/October. The proposed renewal permit includes a maximum temperature effluent 

limit of 35°C and a 7-day average of the daily maximum temperature limit of 33°C. (These 

values are based on values observed while operating under the 2001 permit.) Thus, the discharge 

is not expected to increase temperature at the edge of the mixing zone or after mixing with 25% 

of the river by more than 0.3 °C. 

Allowable Excess Thermal Load 

To determine the excess thermal load for the facility, the Department used the allowed maximum 

permitted 7-day average of the daily maximum effluent temperature (33°C) along with a 

maximum permitted effluent flow of 0.46 m3/d (10.5 mgd). The excess thermal load is calculated 

using the following equation: 

ETL = p C Q(AT)\ 1000 

\W 

m 

V S J 

1 MW 

10

 6 W 

Where: ETL = Excess thermal load (MW) 

p = Density of water, (1.0 kg/L) 

Cp = Specific heat of water, (4182 J/kg-°C) 

Q = Discharge flow, (meters3/sec) 

AT = Effluent Temp. (°C) minus applicable criterion 

The calculated excess thermal load limit for Blue Heron is 25 MW. The excess heat (thermal) 

load given in the 2001 permit - while not utilized as a compliance condition - was 31.6 MW as a 

7-day average and 27.2 MW as a monthly average (see Table 7). The excess thermal load in the 

proposed permit is therefore more stringent. 

7.1.4.2 Temperature Thermal Plume Limitations 

The Department's water quality standards include temperature thermal plume limitations in OAR 

340-041-0053(d). This section of the rules contains criteria to prevent potential adverse impacts 

that may result from thermal plumes. The criteria as they apply to Blue Heron are discussed 

below: 

• OAR 340-041-0053(d)(A): Impairment of an active salmonid spawning area where spawning 

redds are located or likely to be located. 

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Blue Heron Paper Company 

Blue Heron discharge: There is no salmonid spawning in this segment of the Willamette River. 

This segment of the Willamette River serves as a migration corridor for salmonids. 

• OAR 340-041-0053(d)(B): Acute impairment or instantaneous lethality is prevented or 

minimized by limiting potential fish exposure to temperatures of 32 °C or more to less than 2 

seconds. 

Blue Heron discharge: The permit proposes a maximum effluent temperature at outfall 001 of 35 

°C. The maximum measured river temperature in the area of the outfall is 24.8°C. Based on 

modeling of near-field mixing for conditions considered to be critical for acute impairment near 

the diffusers, the centerline dilution just prior to two seconds is 2.6. A mass balance analysis 

(provided in Attachment G) gives an effluent plume temperature of 28.7°C after a travel time of 2 

seconds. Therefore, under a worst case scenario, the temperature at the centerline of the plume as 

it moves downstream of each individual diffuser port drops from 35°C to 28.7°C within 2 

seconds. Fish exposure to temperatures over 32°C will be for less than 2 seconds. 

• OAR 340-041-0053(d)(C): Thermal shock caused by a sudden increase in water temperature is 

prevented or minimized by limiting potential fish exposure to temperatures of 25 °C or more to 

less than 5% of the cross-section of 100% of the 7Q10 flow of the waterbody. 

Blue Heron discharge: The approximate cross-sectional area of the Willamette River near the 

outfall at 7Q10 low flows is 24,000 ft2. Five percent of this area is 1200 ft2. The effluent 

limitations in the Blue Heron permit ensure that when the effluent plume reaches 5% of the 

river's cross-sectional area, the plume's temperature will never be over 25°C unless the ambient 

river conditions approach 25°. At an ambient river temperature of 24.8°C, the increase in river 

temperature at the point where the plume reaches 5% of the river cross-sectional area is 

approximately 25.1°C (See calculations in Attachment G). 

This portion of the thermal plume rule is based primarily on the USEPA guidance document, EPA 

Region 10 Guidance for Pacific Northwest State and Tribal Temperature Water Quality 

Standards (April 2003). Section V.3. of the document gives guidance on protecting salmonids 

from thermal plume impacts and provides the following discussion on thermal shock: 

Thermal shock leading to increased predation can occur when salmon and trout exposed 

to near optimal temperatures (e.g., 15°C) experience a sudden temperature increase to 

26 - 30°Cfor a short period of time (Coutant, 1973). Therefore, EPA suggests that 

thermal plumes be conditioned to limit the crosssectional area of a river that exceeds 

25°C to a small percent of the river (e.g., 5 percent or less). 

It is clear that thermal shock occurs when ambient river conditions are suddenly increased from 

relatively low temperatures (the example of 15°C is given) to temperatures above 25°C. It is also 

clear that this element is intended to apply when ambient river temperatures are much lower than 

25°C. 340-041-0053(d)(C) provides one method to ensure thermal shock does not occur, but at 

higher ambient river temperatures additional exposure timing restrictions may be developed to 

prevent thermal shock. One such restriction is to ensure river temperatures are not increased by 

more than a deminimis amount when the effluent plume reaches 5% of the river's cross-sectional 

area. 

For the Blue Heron discharge, the expected increase in river temperatures when the effluent 

plume reaches 5% of the river's cross-sectional area and the river temperature approaches 25°C is 

approximately 0.3°C. An increase this small does will not result in thermal shock and is 

considered deminimis. 

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Blue Heron Paper Company 

• OAR 340-041-0053(d)(D): Unless ambient temperature is 21°C or greater, migration blockage 

is prevented or minimized by limiting potential fish exposure to temperatures of 21 °C or more to 

less than 25% of the cross-section of 100% of the 7Q10 flow of the waterbody. 

Blue Heron discharge: This rule is also based primarily on the USEPA guidance document, EPA 

Region 10 Guidance for Pacific Northwest State and Tribal Temperature Water Quality 

Standards (April 2003). Section V.3. of the document gives guidance on protecting salmonids 

from thermal plume impacts and provides this discussion on migration blockage: 

Adult migration blockage conditions can occur at 21°C... Therefore, EPA suggests that 

the cross-sectional area of a river at or above 21 °C be limited to less than 25% or, if 

upstream temperature exceeds 21°C, the thermal plume be limited such that 75% of the 

cross-sectional area of the river has less than a de minimis (e.g., 0.25°C) temperature 

increase. 

The effluent limitations in the Blue Heron permit ensure that when the ambient river temperature 

approaches 21°C (20.9°C), the resulting temperature of effluent plume when it reaches 25% of 

the river's cross-sectional area will be 21°C (see calculations in Attachment G of the PER). This 

is clearly a deminimis increase which prevents or minimizes migration blockage. 

7.1.4.3 Existing Permit Limits for Temperature/Thermal Loads and Anti-backsliding 

The 2001 permit contained effluent limitations related to temperature, excess heat load and 

relative heat load (see pages 19 through 21, above). Compliance with these limits was 

demonstrated through meeting either the temperature limit or the relative heat load limit: 

In any designated period (7-day, month), if the temperature effluent limit has been 

achieved, the permittee shall be deemed in compliance with this condition without 

consideration of relative heat load. In any designated period, if the effluent temperature 

limit has been exceeded but the relative heat load limitation has not been exceeded, the 

permittee shall be deemed in compliance with this condition. Otherwise the permittee 

shall be deemed out of compliance with this condition for the designated period. (From 

Schedule A. 8 of 2001 permit) 

In Schedule A. 1 of the proposed permit, relative thermal (heat) load limits have been included for 

periods when the maximum 7-day Average effluent temperature exceeds 30°C and when the 

maximum monthly average effluent temperature exceeds 27.2°C. These limits are as stringent as 

those in the 2001 permit and ensure there is no backsliding associated with the temperature limits 

in the new permit. It should be noted that the excess thermal load values presented in the 2001 

permit were not used for compliance purposes and did not limit loads. Even so, the proposed 

permit contains a lower excess thermal load limit (25 MW as a 7-day average) than the 2001 

permit (31.6 MW 7-day and 27.2 MW monthly averages). 

With the combination of new maximum daily temperature limits, average temperature limits 

applicable regardless of load, new excess thermal limits, and relative thermal load limits 

comparable to the 2001 limits, the proposed permit limits are significantly more restrictive than 

the 2001 limits. 

7.1.5 pH 

As noted in Section 3.1, Applicable Water Quality Standards, the water quality standard for pH 

for the Willamette River is 6.5 - 8.5. The pH limit in the 2001 NPDES permit was 6.0 - 8.5 at 

outfall 001. The technology based limit for outfall 001 is a less stringent 5.0 - 9.0. With the 

dilution available within the mixing zone, discharges from the Blue Heron facility at the existing 

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Blue Heron Paper Company 

pH limits will be able to meet the water quality standard at the edge of the mixing zone. Thus, a 

pH limit based on the current (and more stringent) limit of 6.0 - 8.5 is proposed for the discharge 

from outfall 001. 

For outfall 002, the 2001 NPDES permit specified a pH limit of 5.5 to 8.5 for the filter backwash 

discharge. There is no technology-based limit in the federal regulations for filter backwash 

discharge. Due to the limited dilution available at the mixing zone boundary, the Department is 

proposing to modify the permit to include a more stringent pH limit of 6.0 to 8.5 for this outfall. 

With these limits and the dilution available within the mixing zone, the discharge is expected to 

be able to meet the water quality standard for pH at the edge of the mixing zone. 

For outfalls 003, 004 and 005, the Department is proposing to keep the current pH limits of 6.5-

8.5, which is the water quality standard for pH. 

7.1.6 Toxic Pollutants 

Outfall 001 

Based on a review of the analytical data submitted with the NPDES permit application, the toxic 

pollutants of concern at outfall 001 are aluminum, arsenic, chromium, copper, lead, mercury, 

nickel, and zinc. An evaluation was conducted to determine whether the levels of these 

pollutants in the discharge have a "reasonable potential to exceed" water quality standards. The 

following table specifies the aquatic life and human health water quality standards, the maximum 

effluent concentration, and the number of samples collected for each pollutant. 

TABLE 12: TOXIC POLLUTANTS OF CONCERN AT OUTFALL 001 

Metals 

Parameter 

Aluminum* 

Arsenic (+3) 

Cadmium 

Chromium (total) 

Copper 

Iron 

Lead 

Mercury 

Nickel 

Silver 

Zinc 

Aquatic Freshwater 

Criteria 

Acute 

Ug/L 

750 

360 

0.78 

556 

4.62 

N/A 

13 

2.4 

424 

0.35 

35 

Chronic 

Ug/L 

87 

190 

0.37 

75 

3.49 

1000 

0.5 

0.012 

47 

0.12 

32 

Human Health 

Criteria 

Ug/L 

N/A 

N/A 

10 

N/A 

N/A 

300 

50 

144 

13.4 

50 

N/A 

Effluent 

Maximum 

Measured 

Ug/L 

0.27 

10.0 

0.50 

6.29 

11.6 

387 

7.60 

0.10** 

16.0 

0.10 

284 

Maximum 

Probable 

Ug/L 

3.6 

19.0 

1.20 

12.58 

29.0 

5108 

19.0 

0.22 

25.6 

0.29 

369 

* Note that the aluminum criteria have not been adopted. The proposed criteria apply only at 

pH<6.6 and hardness<12 mg/L (as CaC03), values not observed in the receiving water. 

** Mercury was not detected in any sample. A value of one-half the detection limit was used to 

estimate a maximum probable value. 

Currently, the Department has not adopted a water quality criterion for aluminum. An aluminum 

criterion has been developed by EPA and DEQ is proposing to adopt it. The aluminum criterion 

presented in the table above is the water quality criterion which the Department is proposing to 

adopt. In addition, the proposed aluminum criterion applies at pH values below 6.6 and hardness 

values below 12 mg/L (as CaC03). These values are not observed in this section of the 

Willamette River. Therefore, there is no reasonable potential for the discharge to exceed the 

3 1 
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Blue Heron Paper Company 

water quality standard for aluminum and the aluminum is not considered a toxic substance in this 

discharge. 

When determining whether a discharge has the potential to exceed water quality standards, the 

Department accounts for the variability of the effluent. A multiplier is used to account for 

effluent variability in accordance with the methods outlined in EPA's Technical Support 

Document for Water Quality Based Toxics Control (March 1991). To determine whether the 

discharge has a reasonable potential to exceed water quality standards for these pollutants, a 

spreadsheet that simulates the approach in EPA's Technical Support Document for Water Quality 

Based Toxics was used. Maximum probable effluent concentrations (based on the multiplier), 

water quality criteria, and mixing zone dilution data are used to determine whether the discharge 

has a reasonable potential to exceed water quality standards. 

Some background data for metals are available above the discharge location. However, the high 

detection limits associated with some of these data make them of limited value. The City of 

Portland has been collecting high resolution metals data in the lower portion of the Willamette 

River. Because the City of Portland data is developed using state-of-the-art analytical techniques 

and is of high quality, the Department is using these data, when available for specific parameters, 

in the water quality analysis. The data collected from 2001 - 2003 at the Waverly County Club 

(RM 17.9) were used in the analysis. 

The results of the reasonable potential analysis for outfall 001 are included in Attachment C. The 

results indicate that the discharge has no reasonable potential to exceed the water quality 

standards for any of the pollutants of concern identified in Table 12. The previous permit 

included an effluent limit for zinc based on the ZID dilution values applicable for that permit. 

The proposed permit also retains the effluent limit for zinc. 

Outfall 002 

Based on an analysis of monitoring data, the toxic pollutants of concern at outfall 002 are 

chlorine and aluminum. Blue Heron has collected data to characterize levels of aluminum and 

chlorine in the effluent at outfall 002. The following table specifies the aquatic life and human 

health water quality standard, the maximum effluent concentration, and the number of samples 

collected. 

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Blue Heron Paper Company 

TABLE 13: TOXIC POLLUTANTS OF CONCERN AT OUTFALL 002 

Parameter Unit Aquatic Life Criteria 

Acute 

Criterion 

Chronic 

Criterion 

Human 

Health 

Criteria 

Max Effluent 

Concentration 

Water & 

Fish 

Ingestion 

Number 

of 

Samples 

Aluminum* Ug/L 750 N/A 19300 

Chlorine mg/L 0.019 0.011 N/A 0.34 

* Note that the aluminum standard has not been adopted. The criterion is also pH and 

hardness dependent. 

As noted above, the aluminum criterion presented in Table 13 is the water quality criterion which 

the Department is proposing to adopt. In addition, the proposed aluminum criterion applies at pH 

values below 6.6 and hardness values below 12 mg/L (as CaC03). These values are not observed 

in this section of the Willamette River. Therefore, there is no reasonable potential for the 

discharge to exceed the water quality standard for aluminum. 

The reasonable potential analysis for chlorine from outfall 002 is presented in Attachment D. 

Discharges from outfall 002 are limited to 30 minutes and only occur once every eight hours. 

Due to this short-term and intermittent nature of the discharge (as well as the dilution at the edge 

of the mixing zone), there is no reasonable potential to exceed the chronic criteria for chlorine. 

There is a potential to exceed the acute criteria for chlorine. The acute standards are based on 

meeting the criteria as an average over a one hour period. Therefore, an effluent limit has been 

developed for chlorine which account for the short-term nature of the discharge. The effluent 

limit for chlorine included in Schedule A of the proposed permit is 0.04 mg/l as a daily maximum 

(Attachment E). 

7.2 Whole Effluent Toxicity Testing 

The 2001 NPDES Permit required Blue Heron to conduct whole effluent toxicity (WET) testing 

of the discharge from outfall 001. WET testing was conducted quarterly each year on 

Pimephales promelas (fathead minnow), Raphidocelis subcapitata (green algae) and 

Ceriodaphnia dubia (water flea). An acute WET test is considered to show toxicity if the "No 

Observed Effect Concentration" (NOEC) occurs at dilutions greater than that which is found at 

the edge of the zone of immediate dilution (ZID). A chronic WET test is considered to show 

toxicity if "a significant difference in survival, growth or reproduction" occurs at dilutions greater 

than that which is known to occur at the edge of the mixing zone. WET test results from 2001 -

2005 were reviewed indicating the facility has been in compliance with this provision of the 

permit. Because of the size and complexity of the discharge, the Department is proposing to 

continue requiring WET testing at the same frequency as required by the 2001 permit. The 

Deparatment is also modifying the permit language to allow the use of Oncorhynchus mykiss 

(rainbow trout) for the acute WET test. 

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Blue Heron Paper Company 

8 Compliance History 

A review of Discharge Monitoring Reports (DMRs) over the past four years (2001-2005) 

indicates that Blue Heron has met effluent limits in its NPDES permit with the exception of one 

violation of the monthly average turbidity effluent limit in February 2003. In addition to this, the 

facility received a notice of non-compliance for the late submittal of a report in August, 2002. 

Because the mill is located over bed rock in the Willamette River and because of the age of the 

facility, spill prevention and control are major issues for Blue Heron. Several spills have 

occurred at the facility over the last four years. Many of these spills do not reach the river, but 

are contained and cleaned up. In December of 2003, a spill of sulfuric acid to the river resulted in 

a notice of violation. The cause of the spill was addressed by the facility. In April of 2004 a spill 

to the Willamette of clarifier effluent resulted in a notice of non-compliance. The cause of this 

spill was a leaking pipe that was subsequently repaired. 

The proposed permit requires Blue Heron to have a contingency plan for prevention and handling 

of spills. As part of the contingency plan, Blue Heron is required to maintain a continuing 

program of employee orientation and education for good in-plant control and quick and proper 

action in the event of a spill or accident. 

Blue Heron is required to submit an annual report summarizing each spill event during the 

previous calendar year along with the actions taken to address the spill. Blue Heron is also 

required to update the contingency plan for prevention and handling of spills and unplanned 

discharges on an annual basis. 

9 Discussion of Proposed NPDES Permit 

9.1 NPDES Permit Outline 

The proposed NPDES permit is organized into a cover page and several schedules that are 

discussed further in this section. The schedules include: 

• Schedule A - Waste Discharge Limitations 

• Schedule B - Minimum Monitoring and Reporting Requirements 

• Schedule C - Compliance Conditions and Schedules 

• Schedule D - Special Conditions 

• Schedule E - Not Applicable (this schedule is reserved for federal pretreatment 

requirements for publicly owned treatment works and is not applicable to this permit) 

• Schedule F - General Conditions 

9.2 Cover Page 

The face page of the NPDES permit identifies that Blue Heron is permitted to discharge process 

wastewater to the Willamette River through outfall 001 at RM 27.5. Blue Heron is also currently 

permitted to discharge wastewaters from the filter plant to the Willamette River through outfall 

002 at RM 26.1 (Schedule D of the proposed permit includes the requirement to eliminate this 

discharge). In addition, Blue Heron is also permitted to discharge miscellaneous effluents 

through outfalls 003, 004 & 005 at approximately RM 26.3. The permit will be issued for a 

period not to exceed five years from the date of issuance. 

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Blue Heron Paper Company 

9.3 Schedule A 

For Outfall 001, effluent limits are proposed for TSS, BOD, pH, turbidity, E. coli bacteria, zinc 

and temperature. The limits for TSS, BOD, E. coli bacteria, flow, turbidity, zinc and pH are the 

same as those in the 2001 NPDES permit. Due to system modifications planned by the plant and 

required by this permit, and because the turbidity rule is slated for modification later this year, the 

Department is proposing to retain the current permit's interim turbidity limits and to establish a 

new turbidity compliance schedule. This is further explained in Section 7.1.2, above and Section 

9.5, below. Also, as explained in Section 7.1.4 above, the Department is proposing to modify the 

temperature effluent limits to address the new temperature rule. 

The proposed effluent limits at outfall 001 are presented in the table below: 

Table 14: NPDES Permit Limits at Outfall 001 

Parameter 

Flow 

BOD5 

BOD5 

TSS (Note 1) 

E. coli bacteria 

(Note 3) 

Lead 

Turbidity (Interim) 

Turbidity 

(Interim) 

Turbidity (Final) 

Turbidity 

(Final) 

Zinc 

PH 

Season 

Jun 1-Sep 31 

Jun 1-Oct 31 

Nov 1 -May 31 

Jan 1 - Dec 31 

Jan 1-Dec 31 

Jan 1-Dec 31 

May 1 -Oct 31 

Nov 1 - Apr 30 

May 1 -Oct 31 

Nov 1 - Apr 30 

Jan 1 - Dec 31 

Jan 1 - Dec 31 

Limitations 

Monthly 

Average 

— 

3625 kg/d 

4275 kg/d 

5525 kg/d 

(12,181 

lb/d) 

126/100 

mL 

9.5 ug/L 

200NTU 

200 NTU 

40 NTU 

115 NTU 

— 

Daily 

Maximum 

— 

4350 kg/d 

6800 kg/d 

10275 kg/d 

(22,652 lb/d) 

406/100 mL 

20.5 ug/1 

— 

— 

— 

— 

50 kg/d 

Maximum 

7-Day Moving Average 

0.460 m3/s (10.5 MGD) 

— 

— 

— 

— 

70 NTU 

200 NTU 

— 

shall be within the range of 6.0 to 8.5 

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Permit Evaluation Report 

Blue Heron Paper Company 

Table 14 (continued): NPDES Permit Limits at Outfall 001 

Temperature and Heat Load Limitations 

Temperature Limitations 

January 1 - December 31 

7-Day Average of the Daily Maximum 

Effluent Temperature 

Daily Maximum Effluent Temperature 

33 °C 35 °C 

Excess Thermal Load (ETL) Limitations 

January 1 - December 31 

Maximum 7-Day Average Excess Thermal Load Discharged 

25 MW 

Relative Thermal Load (RTL) Limitations 

For Periods Where the Maximum 7-Day 

Average Effluent Temperature Exceeds 30°C, 

the Maximum 7-Day Average Relative 

Thermal Load Discharged (MW) are as 

follows 

For Periods Where the Maximum Monthly 

Average Effluent Temperature Exceeds 27.2 

°C, the Monthly Average Relative Thermal 

Load Discharged (MW) are as follows 

May 1-June 30 

19.9 16.5 

July 1 - August 31 

17.5 13.6 

September 1 - November 30 

19.4 15.8 

The effluent limits at outfall 002 are presented in the table below: 

Table 15: NPDES Permit Limits at Outfall 00 2 

Parameter 

Chlorine 

Turbidity (May 1 - Oct. 31) 

Turbidity (Nov.l -April 30) 

pH 

Daily Maximum 

40 ug/1 

94 NTU 

234 NTU 

Within the range of 6.0 to 8.5 

The 2001 NPDES permit contained a "bubble" TSS load for all of the outfalls. The Department 

is proposing to retain this effluent limit. 

The NPDES permit specifies the mixing zones and ZIDs for each outfall. The mixing zone and 

ZID definitions for all outfalls are the same as those in the 2001 NPDES permit. The one 

exception is that the mixing zone for regulated parameters other than turbidity and temperature 

has been modified to only include the portion of the river downstream of the diffuser. This 

modification also reduces the size of the ZID (see discussion in Section 3.5). It should be noted 

that the proposed permit also complies with the temperature thermal plume limitations as noted in 

Section 7.1.4 above. 

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Blue Heron Paper Company 

9.4 Schedule B - Minimum Monitoring and Reporting Requirements 

9.4.1 Monitoring Requirements 

The proposed NPDES Permit requires the reporting of paper production data in the table below. 

Table 16: Reporting Requirement for Production Data 

Parameter 

Pulp Production 

Units 

Tons/day 

Minimum 

Frequency 

Monthly 

Production is defined as average air-dry tons of each type of pulp produced per day of production 

during the reporting period reporting period (i.e. month) divided by the number of operating days 

during the reporting period. 

The monitoring frequencies and the parameters to be monitored at outfall 001 are specified in 

Table 17. Various notes to the monitoring requirements are included in the permit at Schedule 

B.l. 

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Blue Heron Paper Company 

Table 17: Monitoring Requirements for Outfall 001 

Parameter 

Flow: average daily, 7-day 

moving average, monthly 

average 

BOD5 

TSS 

Color 

pH 

Temperature: ASB effluent 

daily maximum , 7-day average 

of daily maximums, 7-day 

average and grab at time of 

mercury monitoring (Note 2) 

Excess Thermal Load - daily 

and 7-day average (Note 3) 

Relative Thermal Load - daily, 

7-day average and monthly 

average (Note 3) 

ASB sludge depth 

Pulp production 

Paper production 

Whole effluent toxicity 

E. coli bacteria 

Total Mercury 

Methylmercury 

Hardness 

Dissolved Organic Carbon 

Total Organic Carbon 

Sulfate 

Redox 

Dissolved Oxygen 

cadmium 

copper 

lead 

zinc 

turbidity: ASB effluent; daily 

value, 7-day moving average, 

monthly average 

Units 

m7s 

mg/L, kg/d 

mg/L, kg/d 

color units (cu.) 

standard units 

(s.u.) 

°C 

MW 

MW 

m 

t/d 

t/d 

toxicity report 

counts/100 mL 

ng/L 

ng/L 

mg/L 

mg/L 

mg/L 

mg/L 

mV 

mg/L 

Ug/L 

Ug/L 

Ug/L 

Ug/L 

NTU 

Minimum 

Frequency 

1/day 

3/week 

3/week 

3/week 

3/week and with 

each mercury 

sample 

1/day and with each 

mercury sample 

1/day 

1/day 

1/6 months 

1/month 

1/month 

2/year 

5/month 

1/quarter 

1/quarter 

1/quarter 

1/quarter 

1/quarter 

1/quarter 

1/quarter 

1/quarter 

1/month 

1/month 

1/month 

1/month 

1/day 

Type of 

Sample 

continuous 

meter/calculate 

d 

composite 

composite 

grab 

grab 

continuous 

recorder/grab 

calculated 

calculated 

measurement 

calculation 

calculation 

composite 

grab 

grab 

grab 

grab 

grab 

grab 

grab 

grab 

grab 

composite 

composite 

composite 

composite 

composite 

3 8 
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Blue Heron Paper Company 

The proposed monitoring frequency for flow, BOD, TSS and pH are the same as in the 2001 

NPDES permit. Daily monitoring of effluent temperature using a continuous recording device is 

being proposed as recommended in the Department's guidance for temperature management 

plans. Blue Heron has already installed a continuous recording device to collect temperature 

data. The proposed permit also includes monitoring requirements for mercury using clean 

techniques for collection and analysis which will result in very low (0.5 ng/L) detection limits for 

total mercury. 

As discussed in Section 7.2, the Department is proposing to continue requiring WET testing at a 

frequency of four times a year. To ensure that the outfall diffuser is functioning as designed, the 

permit requires Blue Heron to visually inspect the outfall at least once during the permit cycle. 

At outfall 002, the filter backwash discharge, the monitoring requirements are as follows: 

Table 18: Outfall 002 Monitoring Requirements 

Parameter 

Flow 

TSS 

Chlorine 

Turbidity 

pH 

Units 

m7s 

mg/L, kg/d 

ug/L 

NTU 

s.u. 

Minimum Frequency 

1/week 

1/week 

1/month 

1/month 

1/week 

Type of Sample 

Estimate during 

Discharge 

Composite during 

Discharge 

Composite during 

Discharge 

Composite during 

Discharge 

Grab during 

Discharge 

At outfalls 003, 004 and 005 the monitoring requirements are as follows: 

Table 19: Monitoring Requirements for Outfalls 003, 004 & 005 

Parameter 

Visual Observation 

Number of Events 

Total Daily Flow 

Temperature 

TSS 

pH 

Oil & Grease 

Minimum Frequency 

3/day 

Monthly 

1/discharge event 

1/discharge event 

1/day 

1/day 

1/day 

Type of Sample 

Observation 

Calculation 

Estimate 

Grab 

Composite 

Composite 

Composite 

3 9 
Permit Evaluation Report 

Blue Heron Paper Company 

9.4.2 Reporting Requirements 

The proposed NPDES permit requires monitoring reports to be submitted on a monthly basis. 

Monthly reports must be submitted by the 15th day of the following month. 

Blue Heron land applies solids from its primary clarifier for beneficial use. On a monthly basis 

with the discharge monitoring report, the permit requires Blue Heron to report the quantity of 

solid delivered to each land application site, and the quantity utilized for beneficial uses other 

than land application. On an annual basis Blue Heron is required to submit an updated 

wastewater solids management plan and to submit an annual report 

This portion of the NPDES permit specifies how "non-detect" sample results should be reported; 

requires that monitoring records be prepared in ink; specifies the procedures for calculating the 7-

day moving average; and defines continuous monitoring. 

9.5 Schedule C - Compliance Conditions and Schedules 

This portion of the proposed NPDES Permit includes compliance conditions and schedules. 

Schedule C, Condition 1 requires that Blue Heron install a flow monitoring and recording device 

at the overflow structure of their aerated stabilization basin, or use such other method as 

accurately determines and records the flow at the overflow structure, in the event the permittee 

changes the flow pattern so that the primary clarifier meter is no longer representative of the flow 

rate discharged. 

Schedule C, Condition 2 includes a schedule for addressing turbidity issues. As noted above, the 

Department is currently reviewing its turbidity standard. If the turbidity standard is modified, 

Blue Heron may submit a modification request for recalculation of turbidity limits. The 

compliance schedule requires Blue Heron to continue with its efforts undertaken under the 2001 

Permit to achieve the final turbidity effluent limits given in Schedule A. The first component of 

the schedule is to modify the feasibility study completed under the 2001 permit to address issues 

relating to increased flow and solids being diverted from outfall 002 to the wastewater treatment 

system (as required under Schedule D). This feasibility study also will need to reflect the effects 

of the wastewater reuse project on the performance of the ASB. The second component of this 

schedule is to complete engineering design of treatment system modifications to achieve the final 

effluent limits. The final component is to achieve the final effluent limits given in Schedule A. 

As noted in Section 7.1.2 above, the reasons for this compliance schedule are: 1) Schedule C2 of 

the permit is requiring the filter backwash water to be rerouted to the treatment system, thereby 

altering the characteristics of the waste stream and necessitating a revised feasibility study and 

impacting the engineering design, and 2) The permittee is undertaking a major project to reuse 

approximately 20 percent of its wastewater, which will affect the performance of the ASB, and 3) 

A new turbidity standard is scheduled to be presented to the Oregon Environmental Quality 

Commission later this year that may have an impact on this limit. If the turbidity standard is 

modified, Blue Heron may apply to the Department for a permit modification to recalculate its 

turbidity limits. If the standard is not modified, Blue Heron will be required to modify the 

feasibility study to identify mechanisms to achieve the final effluent turbidity limits and to 

implement selected mechanisms to reduce turbidity, as required by this schedule. 

Schedule C, Condition 3 includes a default period regarding Departmental responses. 

40 
Permit Evaluation Report 

Blue Heron Paper Company 

9.6 Schedule D - Special Conditions 

The following Special Conditions are included in Schedule D of the proposed NPDES permit. 

• Blue Heron land applies solids from its primary clarifier for beneficial use. The permit 

includes a condition stating that solids must be land applied in accordance with a Department 

approved industrial wastewater solids management plan. Prior to land applying solids from 

the ASB, Blue Heron must submit a Dredging Project Management Plan (DPMP) for 

Department review and approval. The permit specifies the elements of the DPMP. 

• Sanitary wastes from the facility must remain routed to the Oregon City sanitary sewage 

system. 

• Pentachlorophenol and trichlorophenol shall not be used for biocides. Zinc hydrosulfite shall 

not be used as a bleaching agent. 

Schedule D of the NPDES permit also includes conditions regarding re-opening of the NPDES 

permit to include Willamette River TMDL WLAs, a contingency plan for spills and unplanned 

discharges, designation of an environmental supervisor, and implementation of a pollution 

prevention program. 

Schedule D13, in particular, relates to the inclusion of TMDL wasteload allocations (WLAs). 

The Draft Willamette TMDL is currently out for a second round of public review. The public 

comment period closes on May 18, 2006. Following the close of the public comment period, the 

Department will review and consider all comments received during the public comment period. 

Following this review, DEQ will modify the TMDL if necessary and approve it as an order. DEQ 

will then submit the documents to EPA for approval. Since there is the potential for the TMDL to 

be modified during this process, this permit has not been assessed with regard to the draft TMDL. 

Schedule D13 states that the permit shall be reopened and modified or reissued to incorporate one 

or more wasteload allocations (WLAS) and associated implementation schedules (if any) 

resulting from a TMDL for any of the parameters associated with the permittee's discharge. 

Schedule D14 of the permit requires that, within two years of permit issuance, Blue submit to the 

Department the results of a physical inspection of the diffuser for outfall 001. This inspection 

shall consist of visually inspecting the diffuser ports by diving to ensure that they are intact and 

functional, and measuring the height of each diffuser port above the river bottom. 

9.7 Schedule F - General Conditions 

These conditions are standard to all NPDES permits and include language regarding operation 

and maintenance of facilities, monitoring and record keeping, and reporting requirements. 

41 
Permit Evaluation Report 

Blue Heron Paper Company 

10 Next Steps 

10.1 Public Comment 

The proposed NPDES permit will be made available for public comment. The public notice, 

proposed permit and this evaluation report will also be posted on the Department's web page. 

Public notice of the proposed permit will be mailed to parties on the Department's public notice 

mailing lists (WQ: PN State, WQ: Clackamas County and WQ: All Permits). The Department 

will also place notice in the Oregonian in the legal notice section. 

10.2 Public Hearing 

A public hearing will be scheduled to provide information and to seek comments. An 

information session will be provided at the beginning of the hearing with the opportunity for the 

public to ask any questions they may have about the permit. The Department will accept written 

or oral comment at the public hearing. 

10.3 Response to Comments 

The Department will respond to comments received during the comment period. All those 

providing comment will receive a copy of the Department's response. Interested parties may also 

request a copy of the Department's response. Once comments are received and evaluated, the 

Department will decide whether to issue the permit as proposed or make changes to the permit or 

deny the permit. 

10.4 Modifications to Fact Sheet and Permit 

Depending on the nature of comment and any changes made to the permit as result of comment, 

this fact sheet and evaluation report may be modified. The Department may also choose to 

update the fact sheet and evaluation report through a memorandum responding to comments on 

the proposed NPDES permit. 

11.0 Attachments 

Attachment A: 2001 NPDES Permit 

Attachment B: Dissolved Oxygen Analysis 

Attachment C: Reasonable Potential Analysis - Outfall 001 

Attachment D: Reasonable Potential Analysis - Outfall 002 

Attachment E: Chlorine Effluent Limit Calculations - Outfall 002 

Attachment F: Outfall 002 Turbidity Limit Calculations 

Attachment G: Thermal Plume Calculations - Outfall 001 

42 
Permit Evaluation Report 

Blue Heron Paper Company 

Attachment A: 2001 NPDES Permit 
Permit Evaluation Report 

Blue Heron Paper Company 

Attachment B: Dissolved Oxygen Analysis 
Without BH 

Streeter-Phelps Dissolved Oxygen Model 

o. 

••<-' . Effluent 

Temp (C) 

DO(mg/L) 

BOD5(mg/L) 

NH3(mg/L) 

Q (mgd) 

^(©2 0 C) 

f (calculated) 

34.5 

1 

110 

0 

0 

0.10 

2.5 

:**uiV '.'..'River*-r *V.. 

Temp (C) 

DO 

BOD5 

NH3 

Q(cfs) 

Kd 

Ks 

Kr 

Depth(ft) 

U (fps) 

U (mpd) 

Ka 

24 

7.5 

0.3 

0.03 

5300 

0.07 

0 

0.07 

30 

0.18 

2.95 

0.03 

note: 

Calculations 

K i 

Kr 

fmix 

Tmix 

Ka 

UBODe 

UBODr 

Lo 

Dosat mix 

DO mix 

DOo 

black entered values 

blue = calculated values 

0.177 

1.705 

0.082 

2.976 

2.976 

24.0 

0.037 

187.6 

1.030 

1.0 

8.4 

7.5 

0.9 

T correct 

T correct 

297.2 

BH Discharge 

Tcrit 

Docrit 

Xc 

8.93 

1.11 

26.29 

days 

mg/L 

mi 

Mouth WR 

RM 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

Deficit 

0.9 

0.9 

1.0 

1.0 

1.0 

1.0 

1.0 

1.0 

1.0 

1.0 

1.0 

1.1 

1.1 

lsl 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

1.1 

Page 1 L-f 
With BH 

Streeter-Phelps Dissolved Oxygen Model 

Effluent 

Temp (C) 

DO(mg/L) 

BOD5(mg/L) 

NH3(mg/L) 

Q (mgd) 

Kx(@20 C) 

f (calculated) 

m .' X River 

Temp (C) 

DO 

BOD5 

NH3 

Q(cfs) 

Kd 

Ks 

Kr 

Depth(ft) 

U (fps) 

U (mpd) 

Ka 

34.5 

1 

110 

0 

12.5 

0.10 

2.5 

24 

7.5 

0.3 

0.03 

5300 

0.07 

0 

0.07 

30 

0.18 

2.95 

0.03 

note: 

Calculations 

K, 

Kr 

fr 

fmix 

Tmix 

Ka 

UBODe 

UBODr 

Lo 

Dosat mix 

DO mix 

DOo 

black =, entered values 

blue = calculated values 

0.177 

1.705 

0.082 

2.976 

2.469 

24.0 

0.037 

187.6 

1.030 

1.7 

8.4 

7.5 

0.9 

T correct 

T correct 

297.2 

BH Discharge 

Tcrit 

Docrit 

Xc 

11.92 

1.44 

35.12 

days 

mg/L 

mi 

Mouth WR 

; RM 

0 

l 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

. 13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

Deficit 

0.9 

1.0 

1.0 

1.0 

1.1 

1.1 

1.1 

1.1 

1.2 

1.2 

1.2 

1.2 

1.3 

1*3 

1.3 

1.3 

1.3 

1.3 

1.3 

1.4 

1.4 

1.4 

1.4 

1.4 

1.4 

1.4 

1.4 

1.4 

1.4 

1.4 

1.4 

Page 1 L-2. 
Without BH 

DO 

7.50 

7.48 

7.47 

7.45 

7.44 

7.43 

7.41 

7.40 

7.39 

7.38 

7.37 

7.36 

7.36 

7.35 

7.34 

7.34 

7.33 

7.33 

7.32 

7.32 

7.32 

7.32 

.7.31 

7.31 

7.31 

7.31 

7.31 

7.31 

7.31 

7.31 

7.31 

^R/tMETERS ^ '- - -': ">• m'Y •,.<."•••... 

Cs 

Co 

Kd 

Ka 

Ks 

Kr 

X 

U 

Lo 

Qr 

Qe 

NH3 

Temp 

f 

Kx 

DOo 

DO saturation (mg/L) 

initial DO (mg/L) 

effective deoxygenation rate (/day) 

reaeration rate (/day) 

settling rate (/day) 

Kd+Ks (/day) 

distance (ft) 

velocity (fps) 

initial BOD (mg/L) BOD5/(l-eA-5Kl)^-l 

flow (cfs) 

flow (mgd) 

ammonia (mg/L) 

degrees C 

ratio of UBOD/BOD5 p. 272 

CBOD reaction rates (bottle rate) 

Initial DO deficit (after mixing) 

Page 2 t-2. 
With BH 

DO 

7.48 

7.44 

7.41 

7.38 

7.35 

7.32 

7.29 

7.27 

7.24 

7.22 

7.20 

7.18 

7.16 

7.14 

7.12 

7.11 

7.09 

7.08 

7.07 

7.06 

7.04 

7.04 

7.03 

7.02 

7.01 

7.00 

7.00 

6.99 

6.99 

6.99 

6.98 

PARAM 

Cs 

Co 

Kd 

Ka 

Ks 

Kr 

X 

U 

Lo 

Qr 

Qe 

NH3 

Temp 

f 

Ki 

DOo 

EFERS :• * 'r' - - '* .: 

DO saturation (mg/L) 

initial DO (mg/L) 

effective deoxygenation rate (/day) 

reaeration rate (/day) 

settling rate (/day) 

Kd+Ks (/day) 

distance (ft) 

velocity (fps) 

initial BOD (mg/L) BOD5/(l-e^-5Kl)A-l 

flow (cfs) 

flow (mgd) 

ammonia (mg/L) 

degrees C 

ratio of UBOD/BOD5 p. 272 

CBOD reaction rates (bottle rate) 

Initial DO deficit (after mixing) 

Page 2 L~1 
Permit Evaluation Report 

Blue Heron Paper Company 

Attachment C: Reasonable Potential Analysis - Outfall 001 
Attachment C - Reasonable Potential Analysis for Outfall 001 

Dilution Values? (Y/N) 

Dilution @ ZID 

Dilution @ MZ 

Y 

33 

70 

If no dilution values enter info below 

Facility Effluent Flow 

7Q10 

1Q10 

% dilution at ZID 

% dilution at MZ 

Fresh Water? (Y/N) 

* 

* 

* 

* 

* 

Y 

calculated 

* 

* 

MGD 

CFS 

CFS 

% 

% 

Hardness 

Effluent 

Stream 

Mixed 

ZID 

MZ 

mg/L caco3 

140 

25 

28 

27 

(Hardness values should 

be >25 and <400 mg/L) 

Confidence Level 

Probability Basis 

99% 

99% 

PARAMETER 

ALUMINUM (Total) 

ARSENIC III (inorganic) 

CADMIUM + 

COPPER + 

LEAD + 

MERCURY 

NICKEL + 

SILVER + 

ZINC + 

IRON 

TOTAL CHROMIUMt 

# o f 

Samples 

1 

20 

11 

11 

49 

1 

11 

11 

36 

1 

11 

Highest 

Cone. 

MQ/I 

0.27 

10.00 

0.50 

11.60 

7.60 

0.00025 

16.00 

0.10 

284.00 

387.00 

6.29 

Coef. of 

Varienee 

0.60 

0.45 

0.47 

0.50 

0.73 

0.60 

0.25 

0.59 

0.20 

0.60 

0.37 

Maximum 

Effluent 

Cone. 

MQ/I 

3.60 

19.00 

1.20 

29.00 

14.44 

0.00330 

25.60 

0.29 

369.20 

5108.40 

12.58 

Background 

Cone. 

MQ/i 

0.40 

0.6 

0.010 

1.3 

0.30 

0.00064 

0.52 

0.01 

3.32 

539.00 

0.60 

Maximum 

Cone, at 

ZID 

MO/! 

0.50 

1.14 

0.05 

2.14 

0.73 

0.00072 

1.28 

0.02 

14.41 

677.47 

0.96 

Maximum 

Cone, at 

MZ 

MQ/I 

0.45 

0.84 

0.03 

1.70 

0.50 

0.00 

0.88 

0.01 

8.55 

604.28 

0.77 

WQ CRITERIA 

IHour 

(CMC) 

M9/I 

750.00 

360 

0.88 

5.43 

16.51 

2.40 

490.2 

0.47 

40.38 

* 

555.60 

4 Day 

(CCC) 

M9/I 

87.00 

190 

0.40 

3.82 

0.64 

0.012 

54.5 

0.12 

34.56 

1000.00 

75.32 

REASONABLE 

POTENTIAL ? 

ACUTE 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

~ 

NO 

CHRONIC 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 
Permit Evaluation Report 

Blue Heron Paper Company 

Attachment D: Reasonable Potential Analysis - Outfall 002 
Attachement D - Reasonable Potential Analysis for Outfall 002 

Dilution Values? (Y/N) 

Low Flow Dilution @ ZID (1Q10) 

Low Flow Dilution @ MZ (7Q10) 

Low Flow Dilution @ MZ (30Q5) 

High Flow Dilution <§! ZID (1Q10) 

High Flow Dilution @ MZ (7Q10) 

High Flow Dilution @ MZ (30Q5) 

Y 

2 

14 

14 

2 

14 

14 

o'SllUlafeiO; 

1.1 

1.2 

1.2 

1.1 

1.2 

1.2 

Enter data below if no dilution data is available 

Data to estimate dilution 

Effluent Flow (mgd) = 

1Q10 (CFS) = 

7Q10 (CFS) = 

30Q5 (CFS) = 

% dilution at MZ = 

% dilution at ZID = 

Summer 

1 

1 

1 

1 

25 

10 

Winter 

1 

1 

1 

1 

25 

10 

Confidence Level = 

Probability Basis = 

99% 

95% 

Summer data 

pH* = 

Temp * = 

Alkalinity = 

Salmonids Present? (Y/N) 

Salmonid Spawning? (Y/N) 

Fresh Water ? (Y/N) 

Salinity (ppt) 

wiptifeiaiij ^ 

pH* = 

Temp * = 

Alkalinity = 

Salmonids Present? (Y/N) 

Salmonid Spawning? (Y/N) 

Fresh Water ? (Y/N) 

Salinity (ppt) 

Effluent 

7 

20.5 

25 

0 

7 

18.5 

25 

0 

Stream 

7.5 

20 

25 

y 

y 

y 

0 

7.5 

18 

25 

y 

y 

y 

0 

Mixed 

ZID 

7.2 

20.3 

0.0 

7.2 

18.3 

0.0 

MZ 

7.4 

20.0 

0.0 

7.4 

18.0 

0.0 

( 6.5-9 ) 

°C 

( 6.5-9 ) 

°C 

PARAMETER 

Low Flow Season 

CHLORINE 

AMMONIA - Existing* 

AMMONIA - Proposed lhr/4day* 

AMMONIA - Proposed 30day* 

High Flow Season 

CHLORINE 

AMMONIA - Existing* 

AMMONIA - Proposed lhr/4day* 

AMMONIA - Proposed SOday* 

# of 

Samples 

2 

* 

* 

* 

2 

* 

* 

* 

Highest 

Cone. 

mg/l 

0.340 

0.000 

0.000 

0.000 

0.340 

0.000 

0.000 

0.000 

Coef. of 

Variance 

0.60 

* 

* 

* 

0.60 

* 

* 

* 

Calculated 

Maximum 

Cone. 

mg/l 

1.734 

* 

* 

* 

1.734 

* 

* 

* 

Background 

Cone. 

mg/l 

0.00 

* 

* 

* 

0.00 

* 

* 

* 

Maximum 

Cone, at 

ZID 

mg/l 

0.867 

* 

* 

n/a 

0.867 

* 

* 

n/a 

Maximum 

Cone, at 

MZ 

mg/l 

0.124 

* 

* 

* 

0.124 

* 

* 

* 

WQ CRITERIA 

Acute 

(CMC) 

mg/l 

0.019 

16.5 

20.1 

n/a 

0.019 

17.0 

20.1 

n/a 

Chronic 

(CCC) 

mg/l 

0.011 

1.23 

8.1 

3.2 

0.011 

1.4 

9.2 

3.7 

REASONABLE 

POTENTIAL ? 

ACUTE 

YES 

* 

* 

n/a 

YES 

* 

* 

n/a 

CHRONIC 

YES 

* 

* 

* 

YES 

* 

* 

* 

-NOTES : 

Temperature must be between 0 and 30 ° C 

pH must be between 6.5 and 9 

Ammonia is total ammonia as N 

Proposed ammonia criteria note: As of February 2005, continue to use the existing criteria. 

The proposed criteria are there for comparison - the proposed standard has a lhr and 4 day criterioi 

iike the existing standard. In addition the proposed standard also contains a 30 day average criterion. 

The saltwater criteria remains unchangea 

For outfall 002, the discharge is intermittent (once every 8 hours) and 30 minutes in duration. The acute standards, including the standard for chlorine, state 

that the numeric criteria are average one-hour concentrations. A dilution of 2 is given as the dilution at the ZID to average the concentration over a one-hour 

period (60 min/30 min). Since no ZID is defined at outfall 002, no additional dilution is given and the standard must be met at the end of the discharge pipe. 
Permit Evaluation Report 

Blue Heron Paper Company 

Attachment E: Chlorine Effluent Limit Calculations - Outfall 002 
Attachment E - Outfall 002 Chlorine Effluent Limitation 

Dilution Values? (Y/N) 

Low Flow Dilution @ ZID (1Q10) 

Low Flow Dilution @ MZ (7Q10) 

Low Flow Dilution @ MZ (30Q5) 

High Flow Dilution @ ZID (1Q10) 

High Flow Dilution @ MZ (7Q10) 

High Flow Dilution @ MZ (30Q5) 

If no dilution values 

Enter flow rates here 

Effluent Flow (MGD) 

1Q10 (CFS) 

7Q10 (CFS) 

30Q5 (CFS) 

% dilution at MZ 

% dilution at ZID 

probability basis 

(WLA multipliers) 

Y 

2 

14 

14 

2 

14 

14 

Summer 

1 

1 

1 

1 

25 

10 

99% 

calculated 

1.1 

1.2 

1.2 

1.1 

1.2 

1.2 

Winter 

1 

1 

1 

1 

25 

10 

Summer data 

p H * = 

Temp * = 

Alkalinity = 

Salmonids Present? (Y/N) 

Salmonid Spawning? (Y/N) 

Fresh Water ? (Y/N) 

Salinity 

)piigjrajg|a;:.,,,..,. 

p H * = 

Temp * = 

Alkalinity = 

Salmonids Present? (Y/N) 

Salmonid Sapwning (Y/N) 

Fresh Water ? (Y/N) 

Salinity 

Effluent 

7 

22.5 

25 

0 

7 

18.5 

25 

0 

Stream 

7.5 

22 

25 

y 

y 

y 

20 

7.5 

18 

25 

y 

y 

y 

20 

Mixed 

ZID 

7.2 

22.3 

MZ 

7Q10 

7.4 

22.0 

MZ 

30Q5 

7.4 

22.0 

( 6.5-9 ) 

°C 

10.0 

7.2 

18.3 

18.6 

7.4 

18.0 

18.6 

7.4 

18.0 

( 6.5-9 ) 

°C 

10.0 18.6 

PARAMETER 

Low Flow Season 

CHLORINE 

AMMONIA - 1986 

AMMONIA - 1999 

High Flow Season 

CHLORINE 

AMMONIA - 1986 

AMMONIA -1999 

WATER QUALITY 

CRITERIA 

IHour 

(CMC) 

mg/l 

0.019 

14.3 

20.1 

0.019 

17.0 

20.1 

4 Day 

(CCC) 

mg/l 

0.011 

1.1 

7.1 

0.011 

1.4 

9.2 

30 Day 

(CCC) 

mg/l 

n/a 

n/a 

2.8 

n/a 

n/a 

3.7 

Background 

mg/l 

0.00 

* 

* 

0.00 

* 

* 

Allocations 

Acute 

mg/l 

0.04 

* 

* 

0.04 

* 

* 

4 Day 

mg/l 

0.15 

* 

* 

0.15 

* 

* 

30 Day 

mg/L 

n/a 

n/a 

* 

n/a 

n/a 

* 

CV 

0.6 

* 

* 

0.6 

* 

* 

# 

Samples 

/Mo 

1 

* 

* 

1 

4 

4 

Acute 

LTA 

mg/l 

0.01 

* 

* 

0.01 

* 

* 

4 day 

LTA 

mg/l 

0.08 

* 

* 

0.08 

* 

* 

30 day 

LTA 

mg/L 

n/a 

n/a 

* 

n/a 

n/a 

* 

Min 

LTA 

mg/l 

0.01 

0.00 

0.00 

0.01 

0.00 

0.00 

APPLICABLE 

PERMIT LIMITS 

CONCENTRATION 

95% 

Monthly 

mg/l 

n/a 

* 

* 

n/a 

* 

* 

99% 

Daily 

mg/l 

0.04 

* 

* 

0.04 

* 

* 

NOTES : Temperature must be between 0 and 30 ° C 

pH must be between 6.5 and 9 

Ammonia is mg/l ammonia as N. 

For outfall 002, the discharge is intermittent (once every 8 hours) and 30 minutes in duration. The acute standards, including the standard for chlorine, state that the 

numeric criteria are average one-hour concentrations. A dilution of 2 is given as the dilution at the ZID to average the concentration over a one-hour period (60 

min/30 min). Since no ZID is defined at outfall 002, no additional dilution is given and the standard must be met at the end of the discharge pipe. 
Permit Evaluation Report 

Blue Heron Paper Company 

Attachment F: Outfall 002 Turbidity Limit Calculations 
Attachment F - Blue Heron Outfall 002 Turbidity Effluent Limits Calculations 

Allowable Effluent Turbidity 

From mass balance equation: 

Where: 

Ce is the allowable turbidity of the effluent (NTU); 

Cmz is the allowable turbidity at the edge of the mixing zone (10% above 

background)(NTU); 

Ca is the ambient (background) turbidity (NTU) 

Background Turbidity 

Background values are based on median values of monitoring data at the Willamette 

River @ Canby Ferry site (from the West Linn Paper Co. PER [p. 13]) 

Summer (5/1 - 10/31): Ca= 4 NTU 

Winter (11/1 - 4/30): Ca= 10 NTU 

Accounting for intermittent discharges 

Assuming a discharge duration of 30 min. every 8 hrs, the allowable turbidity levels at 

the MZB (Cmz) resulting in a time averaged increase of 10% over background would be: 

Cmz(0.5 hr) + Ca(7.5 hr) = Ca(l.l)(8 hr) 

Summer: Ca=4NTU 

Cmz = 10.4 NTU 

Winter: Ca=10NTU 

Cmz = 26 NTU 

Effluent Limits 

^ e (.^mz ^ay & """ L'a 

Summer: S = 14 

Ca=4NTU 

Cmz = 10.4 NTU 

Ce = 94 NTU (as a daily max) 

Winter: (Assume) S = 14 

Ca=10NTU 

Cmz =26 NTU 

Ce = 234 NTU (as a daily max) 
Permit Evaluation Report 

Blue Heron Paper Company 

Attachment G: Thermal Plume Analyses - Outfall 001 
Blue Heron Thermal Plume Analyses 

The following are the analyses and calculations supporting the determination of permit 

compliance with the Temperature Thermal Plume Limitations OAR 340-041-0053(d)(B) 

through (D). 

OAR 340-041-0053(d)(B) Analysis 

• OAR 340-041-0053(d)(B): Acute impairment or instantaneous lethality is prevented or 

minimized by limiting potential fish exposure to temperatures of 32 °C or more to less than 2 

seconds. 

Critical conditions 

o Ambient flow (7Q10) = 5789 cfs 

o Daily maximum effluent temperature (Tps) = 35 °C 

o Effluent flow = 6.8 MGD (low flow for summer season - critical immediate dilution is 

minimized at lower effluent flows/velocities. From figure 3-1 of 5/05 BH turbidity 

study) 

o Daily maximum ambient temperature at diffuser (TR )= 24.8 °C (measured on 7/25/03 -

From B.H. monitoring) 

The visual plumes/UM3 model output for these conditions gives a centerline dilution of 2.6 at 

1.97 seconds. 

Tmi x = [(Qp S *Tp s)+(Qentram*TR)]/( Q p s + Qentram ) 

=[(1*35)+(1.6*24.8)]/(1+1.6) 

= 28.7°C 

After two seconds of travel the centerline (spatial peak) temperature downstream of the diffuser is 

28.7 °C. (Temperatures away from the centerline will be lower.) 

Therefore, under a worst case scenario, the temperature at the centerline of the plume as it moves 

downstream of each individual diffuser port drops from 35°C to 28.7°C within 2 seconds. Fish 

exposure to temperatures over 32°C will be for less than 2 seconds. 

OAR 340-041-0053(d)(C) Analysis 

• OAR 340-041-0053(d)(C): Thermal shock caused by a sudden increase in water temperature is 

prevented or minimized by limiting potential fish exposure to temperatures of 25 °C or more to 

less than 5% of the cross-section of 100% of the 7Q10 flow of the waterbody. 

Critical conditions 

o Ambient flow (7Q10) = 5789 cfs 

o Daily maximum effluent temperature (Tps) = 35 °C 

o Effluent flow =10.5 MGD (critical dilution is at maximum flow) 

o Daily maximum ambient temperature at diffuser (TR )= 24.8 °C (measured on 7/25/03 -

From B.H. monitoring) 

o Approximate river cross-sectional area at 7Q10 low flow: 24,000 ft2 (based on date from 

Table 5-1 of the Dilution Peformance Field Verifications & Modeling Study, CH2MHH1, 

10/2002). 

Five percent of the 7Q10 low flow cross-sectional area is 1200 ft2 (112 m2). This equates to an 

individual plume diameter of 4.2 m2 
From Visual Plumes/UM3 modeling output for the critical conditions, the dilution at this plume 

diameter is 33.2. (This occurs at 6.9 m downstream and 1.365 m up from the diffuser, just prior 

to plume merging). 

Based on these data, the temperature of the plume at 5% of 7Q10 low flow cross-sectional area is: 

Tmi x = [(Qp S *Tp s)+(Qentram*TR)]/( Q p s + Qentram ) 

=[(l*35)+(32.2*24.8)]/(l+32.2) 

= 25.1°C 

Therefore, when the plume area is 5% of 7Q10 low flow cross-sectional area and the river and 

discharge are at critical conditions, the expected increase in river temperature is 0.3 °C. As 

explained in Section 7.1.4, an increase this small will not result in thermal shock and is 

considered deminimis. 

OAR 340-041-0053(d)(D) Analysis 

• OAR 340-041-0053(d)(D): Unless ambient temperature is 21 °C or greater, migration blockage 

is prevented or minimized by limiting potential fish exposure to temperatures of 21 °C or more to 

less than 25% of the cross-section of 100% of the 7Q10 flow of the waterbody. 

Critical conditions 

o Ambient flow (7Q10) = 5789 cfs 

o 7 day average of the daily maximum effluent temperature (Tps) = 33 °C (The 7 day 

average of the daily maximum effluent temperature is considered the appropriate metric 

for migration considerations.) 

o Effluent flow =10.5 MGD (critical dilution is at maximum flow) 

o 7 day average of the daily maximum ambient temperature (TR )= 20.9°C (Critical 

maximum ambient temperature is assumed to be 20.9°C [just prior to attaining 21 °C]) 

o Approximate river cross-sectional area at 7Q10 low flow: 24,000 ft2 (based on date from 

Table 5-1 of the Dilution Peformance Field Verifications & Modeling Study, CH2MHH1, 

10/2002). 

25 percent of the 7Q10 low flow cross-sectional area is 6000 ft2 (558 m2). Assuming the plume is 

fully mixed vertically across the 9.2 m average local depth (this is a conservative assumption), the 

approximate width at this area is 60.7 m (558m/9.2m). 

From Visual Plumes/UM3 modeling output for the critical conditions, the dilution at this plume 

width is 113.5. 

Based on these data, the temperature of the plume at 25% of 7Q10 low flow cross-sectional area 

is: 

Tmix = [(Qps*Tps)+(Qentram*TR)]/( Qps + CVam) 

=[(1*33)+(112.5*20.9)]/(1+112.5) 

= 21.0°C 

Therefore, when the plume area is 25% of 7Q10 low flow cross-sectional area and the river and 

discharge are at critical conditions, the expected increase in river temperature is 0.1 °C. As 

explained in Section 7.1.4, an increase this small will not result in migration blockage and is 

considered deminimis.