### Fact Sheet for NPDES Permit WA0 002950

Intalco Aluminum Corporation

August 2014

Purpose of this Fact S heet

This fact sheet explains and documents the decisions the Department of Ecology (Ecology) made

in drafting the proposed National Pollutant Discharge Elimination System (NPDES) permit for

Intalco Aluminum Corporation (Intalco)

.

This fact sheet complies with Section 173

- 220

- 060 of the Washington Administrative Code

(WAC), which requires Ecology t o prepare a draft permit and accompanying fact sheet for public

evaluation b efore issuing an NPDES permit.

Ecology makes the draft permit and fact sheet available for public review and comment at least

thirty (30) days before issuing the final permit. Cop ies of the fact sheet and draft permit for

Intalco , NPDES permit WA 0002950 , are available for public review and comment from August

27, 2014 until October 27, 2014 . For more details on preparing and filing comments about these

documents, please see Appendix A

- Public Involvement Information

.

Intalco reviewed the draft permit and fact sheet for factual accuracy. Ecology corrected any

errors or omissions regarding the facility’s location, history, discharges, or receiving water prior

to publishing th is draft fact sheet for public notice

.

After the public comment period closes, Ecology will summarize substantive comments and

provide responses to them. Ecology will include the summary and responses to comments in this

fact sheet as Appendix H

- Respons e to Comments , and publish it when issuing the final

NPDES permit. Ecology will not revise the rest of the fact sheet, but the full document will

become part of the legal history contained in the facility’s permit file.

Summary

Intalco Aluminum Corporatio n operates multiple wastewater treatment plant s that combine and

discharge to the Strait of Georgia . Ecology issued the existing permit for this facility on March

15, 2007

. The facility completed two major projects during the previous permit cycle that

s ignificantly reduced the amount of stormwater discharged from Outfall 002 and significantly

reduced the amount of process wastewater that was discharged from Outfall 001.

Major changes from the previous permit include the implementation of a new sampling point to

monitor the process wastewater effluent without stormwater for Outfall 001, the requirement to

submit discharge monitoring reports electronically, the requirement to develop a fugitive alumina

pollution prevention plan and an Outfall 011 and 012 best management practices eff e c tiveness

study, and the removal of Outfalls 003, 004, and 005.

All of the permit limits and action levels included in the existing permit are maintained in the

proposed permit. The stormwater allocations have been removed due to the addition of a

sampling point for the treated process wastewater before it is combined with stormwater.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 2 of 145



## Table of Contents

I. Introduction

................................ ................................ ................................ ............ 6

II. Background Information

................................ ................................ ....................... 7

A. Facility Description

................................ ................................ ............................... 9

History

................................ ................................ ................................ ................................ 9

Industrial Processes

................................ ................................ ................................ ............. 9

Wastewater Treatment Processes

................................ ................................ ...................... 10

Solids Management

................................ ................................ ................................ ........... 15

Discharge Outfalls

................................ ................................ ................................ ............ 15

B. Description of the Receiving Water

................................ ................................ ... 16

C. Wastewater Characterization

................................ ................................ ............ 18

D. Summary of Compliance with Previous Permit Issued

................................ ... 23

E. State Environmental Policy Act (SEPA) Compliance

................................ ..... 28

III. Proposed Permit Limits

................................ ................................ ........................ 28

A. Design Criteria

................................ ................................ ................................ .... 29

B. Technology

- Based Effluent Limits

................................ ................................ .... 30

C. Surface Water Quality

- Based Effluent Limits

................................ ................. 3 5

Numerical Criteria for the Protection of Aquatic Life and Recreation

............................. 35

Numerical Criteria for the Protection of Human Health

................................ ................... 36

Narrative Criteria

................................ ................................ ................................ .............. 36

Antidegradation

................................ ................................ ................................ ................ 36

Mixing Zones

................................ ................................ ................................ .................... 37

D. Designated Uses and Surface Water Quality Criteria

................................ ..... 42

E. Water Quality Impairments

................................ ................................ ............... 43

F. Evaluation of Surface Water Quality

- Based Effluent Limits for Numeric

Criteria

................................ ................................ ................................ ................. 43

Reasonable Potential Analysis

................................ ................................ .......................... 48

G. Human Health

................................ ................................ ................................ ..... 48

H. Sediment Quality

................................ ................................ ................................ . 50

I. Groundwater Quality Limits

................................ ................................ ............. 50

J. Whole Effluent Toxicity

................................ ................................ ..................... 51

K. Conditionally Authorized Non

- Stormwater Discha rges and Non

- Routine

... 55

L. Comparison of Effluent Limits with the Existing Permit Issued in March

2007

................................ ................................ ................................ ....................... 55

IV. Monitoring Requirements

................................ ................................ .................... 57

A. Wastewater Monitoring

................................ ................................ ...................... 57Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 3 of 145

B. Lab Accreditation

................................ ................................ ............................... 63

C. Effluent Limits which are Near Detection or Quantitation Levels

................ 64

V. Other Permit Conditions

................................ ................................ ...................... 64

A. Reporting and Record Keeping

................................ ................................ ......... 64

B. Operation and Maintenance Manual

................................ ................................ 64

C. Solid Waste Control Plan

................................ ................................ ................... 64

D. Application for Permit Renewal o r Modification for Facility Changes

......... 65

E. Facility Loading

................................ ................................ ................................ .. 65

F. Non

- Routine and Unanticipated Discharges

................................ .................... 65

G. Spill Plan

................................ ................................ ................................ .............. 65

H. Stormwate r Pollution Prevention Plan

................................ ............................ 65

I. Fugitive Alumina Pollution Prevention Plan

................................ ................... 66

J. Sediment Monitoring

................................ ................................ .......................... 66

K. Outfall Evaluation

................................ ................................ ............................... 67

L. Certified Operator

................................ ................................ .............................. 67

M. Acute Toxicity

................................ ................................ ................................ ...... 67

N. Chronic Toxicity

................................ ................................ ................................ .. 68

O. Secondary Wastewater Treatment System Treatment Efficiency Study

...... 69

P. Anode Contact Cooling Water AKART Evaluation

................................ ........ 70

Q. Ground Water Impact Study

................................ ................................ ............. 70

R. Outfall 011 and Outfall 012 BMP Effectiveness Study

................................ .... 71

S. General Conditions

................................ ................................ ............................. 71

VI. Permit Issuance Procedures

................................ ................................ ................ 71

A. Permit Modifications

................................ ................................ .......................... 71

B. Proposed Permit Issuance

................................ ................................ .................. 72

VII. References for Text And Appendices

................................ ................................ .. 72

Appendix A

- Public Involvement Information

................................ ................................ .......... 73

Appendix B

- Your Right to Appeal

................................ ................................ ............................. 74

Appendix C

- Glossary

................................ ................................ ................................ ................. 75

Appendix D

- Summary of DMR Data

................................ ................................ ........................ 83

Appendix E

- Technical Calculations

................................ ................................ ....................... 109

Appendix F

– Wet Test Res ults Summary

................................ ................................ ................. 114Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 4 of 145

Outfall 001 WET Test Results Summary

................................ ................................ ...... 114

Outfall 002 WET Test Results Summary

................................ ................................ ...... 117

Appendix G

– Landfill Groundwater Seeps Monitoring Results

................................ ............. 120

Appendix H

- Response to Comments

................................ ................................ ....................... 121

Attachment 1 : Flow Chart for Agreed Order No. 10887

................................ ......................... 145

Table 1 General Facility Information

................................ ................................ ............................. 7

Table 2 Ambient Background Data

................................ ................................ .............................. 17

Table 3 Outfall 001 Wastewater Characterization

................................ ................................ ........ 18

Table 4 Outfall 002 Wastewater Characterization

................................ ................................ ........ 21

Table 5 Outfall 011 Wastewater Characterization

................................ ................................ ........ 22

Table 6 Outfall 012 Wastewater Characterization

................................ ................................ ........ 22

Table 7 Violations

................................ ................................ ................................ ......................... 24

Table 8 Permit Submittals

................................ ................................ ................................ ............. 24

Table 9 Intalco Design Criteria

................................ ................................ ................................ ..... 29

Table 10 BPT Effluent Limit Guidelines

................................ ................................ ...................... 30

Table 11 BAT Effluent Limit Guidelines

................................ ................................ ..................... 31

Table 12 Outfall 001 Effluent Limits

- Maximum Daily

................................ .............................. 32

Table 13 Effluent Limits

– Average Monthly

................................ ................................ ............... 33

Table 14 Technology Based Limits for the Sanitary Wastewater Treatment Plant

...................... 34

Table 15 Critical Conditions Used to Model the Discharge from Outfall 001

............................. 39

Table 16 Critical Conditions Used to Model the Discharge from Outfall 002

............................. 39

Table 17 Marine Aquatic Life Uses and Associated Criteria

................................ ....................... 42

Table 18 Recreational Uses

................................ ................................ ................................ .......... 43

Table 19 Dilution Factors for Outfall 001

................................ ................................ .................... 46

Table 20 Dilution Factors for Outfall 002

................................ ................................ .................... 46

Table 21 Outfall 001 2010 Acute WET Test Results (Percent survival in 100% effluent)

.......... 52

Table 22 Outfall 001 Chronic Bioassay Results (Reported as Percent Effluent)

......................... 53

Table 23 Comparison of Existing and Proposed Effluent Limits for Outfall 001

........................ 55

Table 24 Comparison of Existing and Proposed Effluent Limits for Outfall 002

........................ 56

Table 25 Comparison of Existing and Proposed Effluent Limits for Sanitary Lagoon Discharges

................................ ................................ ................................ ................................ ....................... 56Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 5 of 145

Table 26 Sanitary Lagoon Monitoring

................................ ................................ .......................... 60

Table 27 Number of Stormwater Treatment Pond Action Level Exceedances

............................ 61

Table 28 Number of SEC Action Level Exceedances

................................ ................................ .. 61

Table 29 Action Levels

................................ ................................ ................................ ................. 62

Table 30 Accredited Parameters

................................ ................................ ................................ ... 63

Figure 1 Facility Location Map

................................ ................................ ................................ ...... 9

Figure 2 Intalco Water Balance (flows are approximate)

................................ ............................. 14

Figure 3 Outfall 001

................................ ................................ ................................ ...................... 44

Figure 4 Outfall 002

................................ ................................ ................................ ...................... 45

Figure 5 Simplified diagram of wastewater streams, outfalls, and monitoring points for Outfalls

001 and 002

................................ ................................ ................................ ................................ ... 58

Figure 6 Aquatic Life and Human Health Reasonable Potential Analysis

................................ . 110

Figure 7 Temperature Analysis

................................ ................................ ................................ ... 113Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 6 of 145



### I. Introduction

The Federal Clean Water Act (FCWA, 1972, and later amendments in 1977, 1981, and 1987)

established water quality goals for the navigable (surface) waters of the United States. One

mechanism for achieving the goals of the Clean Water Act is the National Pollutant Discharge

Elimination System (NPD ES), administered by the federal Environmental Protection Agency

(EPA). The EPA authorized the state of Washington to manage the NPDES permit program in

our state. Our state legislature accepted the delegation and assigned the power and duty for

conducti ng NPDES permitting and enforcement to Ecology. The Legislature defined Ecology's

authority and obligations for the wastewater discharge permit program in 90.48 RCW (Revised

Code of Washington).

The following regulations apply to industrial NPDES permits:

• Procedures Ecology follows for issuing NPDES permits (chapter 173

- 220 WAC)

• Water quality criteria for surface waters (chapter 173

- 201A WAC)

• Water quality criteria for ground waters (chapter 173

- 200 WAC)

• Whole effluent toxicity testing and limits (chapter 173

- 205 WAC)

• Sediment management standards (chapter 173

- 204 WAC)

• Submission of plans and reports for construction of wastewater facilities (chapter 173

- 240

WAC)

These rules require any industrial facility owner/operator to obtain an NPDES permit before

di scharging wastewater to state waters. They also help define the basis for limits on each

discharge and for performance requi rements imposed by the permit.

Under the NPDES permit program and in response to a complete and accepted permit

application

, Ecolog y must prepare a draft permit and accompanying fact sheet, and make them

available for public review before final issuance. Ecology must also publish an announcement

(public notice) telling people where they can read the draft permit, and where to send th eir

comments, during a period of thirty days (WAC 173

- 220

- 050). ( See Appendix A

- Public

Involvement Information for more detail about the public notice and comment procedures ).

After the public comment period ends, Ecology may make changes to the draft NP DES permit in

response to comment ( s )

. Ecology will summarize the responses to comments and any changes to

the permit in Appendix H

.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 7 of 145



### II. Background Information

Table 1 General Facility Information

Facility Information

Applicant: Intalco Aluminum Corporation

Facility Name and Address Intalco Aluminum Corporation

4050 Mountain View Road

Ferndale, WA 98248

- 0937

Contact at Facility Name: Kathryn Mitchell, Environmental and

Laboratory Manager

Telephone #: 360

- 384

- 7206

Responsible Official Name: Barry Hullett

Title: President

Address: 4050 Mountain View Road, Ferndale,

WA 98248

- 0937

Telephone #: 360

- 384

- 7584

Industry Type Primary Aluminum Production

Categorical Industry 40 CFR Part 421 Subpart B

Type of Treatment Industrial : Neutralization, f locculation,

chemical p recipitation and sedimentation

Domestic : Aeration and sedimentation followed

by UV disinfection

SIC Codes 3334

NAIC Codes 33131 3

Facility Location (NAD83/WGS84

reference datum) Latitude: 48.845740

Longitude:

- 122.705956

Discharge Waterbody Name and Location

(NAD83/WGS84 reference datum) Strait of Georgia

Outfall 001 Location Latitude: 48.840778 Longitude: 122.720444

Outfall 002 Location Latitude: 48.839444 Longitude: 122.715583Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 8 of 145

Facility Information

Outfall 011 Location Latitude: 48.842500 Longitude: 122.714722

Outfall 012 Location Latitude: 48.840278 Longitude: 122.714722

Permit Status

Issuance Date of Previous Permit April 01, 2007

Application for Permit Renewal Submittal

Date September 29, 2011

Date of Ecology Acceptance of Application January 31. 2013

Inspection Status

Date of Last Sampling Inspection June 26, 2013

Date of Last Non

- sampling Inspection Date February 7, 2013Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 9 of 145

Figure 1 Facility Location Map

A. Facility D escription

History

The Intalco Aluminum Corporation (Intalco) began operations of a primary aluminum

smelter nea r Ferndale, Washington in 1966. The original owner of the facility was Alumax,

Pechiney and Howmet and the current owner is Alcoa . The facility is currently operating at

approximately two

- thirds capacity and employs around 640 people. The first NPDES permit

was issued to th e smelter in 19 73

. I t is c lassified as a major facility.

Industrial Processes

Intalco is a nonferrous metals manufacturing facility that produces primary aluminum metal

from alumina ore using the Hall

- Heroult reduction process. The Intalco facility includes

three pot lines, which contain a total of 720 side worked, pre

- bake anode r eduction cells and

a casting facility . The smelter is capable of producing approximately 307,000 tons of

aluminum metal per year at full production. All metal produced is cast on

- site into various

sizes and forms: sows, te es, slabs, billets, and ingots.

Intalco’s three potlines (A, B, and C) were operated from 1997

- 2000, with an average of 709

pots operating per day and a maximum monthly average production of 31,228 tons per

month . All production was curtailed from June 2001

– April 2002. Between May 20 02 to

present, production has been continuous but each of the potlines have been operated at

various periods of time . Production has also been gradually decreased due to the fact that

fail ing pots have not been replaced in certain lines. During 2013 , Int alco operatedFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 10 of 145

approximately 589 pots on average with an average monthly produc tion of 20,647 tons per

month.

The facility operates 24 hours a day, seven days per week. Intalco requires a large amount of

energy for the process and they recently signed a 10

- year power contract with Bonneville

Power Administration that will expire in September 2022.

The industrial process consists of many steps includ ing converting alumina ore to molten

aluminum, casting of the molten aluminum, creating carbon anodes from a p aste consisting

of petroleum coke, recycled carbon, and coal tar pitch , and reprocessing of the cathode s

. Wastewater associated with the industrial process includes contact and non

- contact cooling

water for metal casting and anode production and wastewater generated from the wet air

pollution control systems associated with the pot rooms

.

There are a few additional sources of wastewater at the facility

. Wastewater generated from

general operation and maintenance of the facility includes domestic wastewater and

wastewater from steam cleaning at the auto shop and annex. S torm water that has the

potential to come into contact with the industrial process is collected and treated prior to

discharg e.

Wastewater Treatment P rocesses

There are a number of wastewater treatment processes at the Intalco facility. Figure 2 below

shows the various wastewater streams, the treatment plants and two of the outfalls. The five

treatment processes are as follows: 1) Primary Water Treatment System, 2) Secondary Water

Treatment System, 3) Anode Cooling Water Treatment System, 4) Sanitary Water Treatment

Facility, an d 5) Stormwater Settling Pond.

Primary Water Treatment System (PWTS)

Contact cooling water from the aluminum casting process and contaminated water from the

wet air pollution control system (wet scrubbers) are sent to the PWTS for treatment prior to

being discharged . The PWTS consists of a n 800 gallon receiving tank, a polymer addition

system, two clarifiers , t wo filter feed pumps, a mud recycle tank, a vacuum pump, a vacuum

filter drum, a recycle tank, a caustic addition system, and three recycle pumps Intalco has two

clarifiers at the PWT S , one is 680,000 gallons and the other is 250,000 gallons. The

clarifie r s provide treatment in the form of sedimentation to remove solids and to reduce the

turbidity in the wet scrubber wastewater. Most of the treated effluent from the clarifier s is

recycled back into the wet scrubbers after adjusting the pH

, as necessary

. The remainder of

the effluent is routed to the secondary wastewater treatment system for removal of dissolved

fluoride and suspended solids

.

According to the “Water Treatment Plant Operations and Maintenance Plans”, revised April

2008, the PWTS has the cap acity to treat approximately 1,800 gallons per minute (gpm) and

operates continuously concurrent with the potline wet scrubber system

. Typically, 75 gpm is

continuously purged to the equalization tank of the secondary wastewater treatment system

. The wat er is purged to the secondary waste water treatment system to prevent build

- up of

fluoride and sulfates from the scrubber system

.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 11 of 145

Secondary Wastew ater Treatment System ( SEC, formerly SWTS)

The SEC (formerly SWTS) is comprised of a one million gallon equalization tank and two

treatment trains running in parallel

. Each treatment train consists of a 6,909 gallon capacity

reaction tank and a flocculation tank that feed into a single 106,000 gallon clarifier

. Wastewater routed from the PWTS to the SEC f or fluoride treatment is pumped into the

equalization tank where it is combined with leachate from the on

- site landfill leachate

collection system. Pollutants in the PWTS effluent include high concentrations of particulate

and fluoride and t he landfill le achate contains high concentrations of fluoride with occasional

high concentrations of cyanide. This w astewater is then pumped to the c hemical addition

tanks. First is the reaction tank where sulfuric acid is added to adjust the pH. Next is the

floccula tion ta nk where a liquid polymer c oagulant is added to promote settling and calcium

chloride is added as a precipitant. Lastly, the wastewater is sent to a clarifier to allow for

sedimentation of the solid s (floc and precipitate) p rior to being discharged into a pipeline to

Outfall 001

. Solids from the bottom of the clarifier are recycled back to the flocculation tank

to create larger floc which will further promote settling. The system is also equipped to treat

ferro

- cyanide complexes from the landfill leachate if necessary. The clarifier is covered to

prevent free cyanide formation caused by ultraviolet degradation o f the ferro

- cyanide

complexes.

According to the “Water Treatment Plant Operations and Maintenance Plans”, revised April

2008, the SEC has the capacity to treat approximately 300 gpm total (150 gpm in each train)

The system is operated in a batch mode and typically treats between 175 and 240 gpm

depending on the day of the week and recent or anti cipated precipitation events.

Anode Cooling Wat er Treatment System (ACWTS)

Anode contact cooling water is generated during the anode production process. Intalco’s

anodes are made from petroleum coke and coal tar pitch in one of two production lines . The

coke and pitch are mixed together and then shap ed into an anode with a mechanical press

under high temperature and pressure. Next the anodes are sprayed with a strong spray of

cold water in one of two cooling tunnels after removal from the press. During the spray

process, the contact water is contami nated with coke and pitch containing polycyclic

aromatic hydrocarbons (PAHs) [including benzo(a)pyrene (B(a)P)]. The contaminated

contact water is treated in a baffled settling chamber for removal of the carbon part icles. The

treated wastewater then flow s by gravity to a manhole where it is mixed with other process

wastewater before being d ischarged through Outfall 001.

According to the “Water Treatment Plant Operations and Maintenance Plans”, revised April

2008, the ACWTS settling chambers are approximat ely 516 gallons each and ha ve the

capacity to treat approximately 4 0 gpm ( 8 0 gpm total ) with a retention time o f approximately

13 minutes.

Sanitary Water Treatment Facility

Intalco’s sanitary waste water treatment facility provides treatment for the domestic

wastewater generated by the plant personnel at the site. The treatment facility consists of a

collection system, inlet vault , lagoon system, outlet weir box, ultraviolet (UV) disinfection

system and discharge piping to Outfall 001. The inlet vault contains a circulating waterFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 12 of 145

pump , a lagoon bypass valve, and an old lagoon inlet valve. In 2012

, a screen was added to

the inlet vault to filter out manufactured inert solids as required by WAC 173

- 308

- 205

. The

wastewater flows by gravity from the inlet vault to the 3.2 million gallon sanitary lagoon for

primary (settling) and secondary (biological) treatment . The lagoon is approximately 2.5

acres and three to five feet deep. The first cell of the three cell lagoon is 2.3 million gallons,

has two surface a erators , and is uncovered. The other two cells are covered. Effluent from

the lagoon is further treated by ultraviolet (UV) disinfection before being combined with the

process effluent and discharged out Outfall 001. D ischarge volume is continuous and

averaged 0.0 4 MGD during the permit cycle.

The sanitary treatment facility was designed and constructed in 1965. In 1998, the lagoon

inlet was rerouted to the lagoon’s southwest corner and, in 2000, the chlorination syste m was

replaced with a UV disinfection system. The lagoon was designed for 770 plant personnel at

0.08 pounds of biochemical oxygen demand (BOD) per person . The UV system was

designed for a peak hydraulic flow rate of 3 50,000 gallons per day with an effluent total

suspended solids (TSS) concentration less than 30 milligrams per liter (mg/L).

Stormwater Settling Pond and Best Management Practices

Due to the nature of the aluminum smelting process, there is potential for stormwater to

contact raw mater ials, byproduct s , or waste materials as it flows through th e site

. To mitigate

the discharge of pollutants

, the stormwater collected from the industrial portion of the plant

site is routed through a stormwater settling pond in th e southwest corner of the plant. The

stormwater pond provides approximately 1.7 million gallons of capacity. The pond was

constructed in 1992 and is a flow

- through system designed to allow solids to settle from the

stormwater. The stormwater pond is designed to treat maximum sto rmwater flow rates up to

30 cubic feet per second (cfs). The pond was conservatively sized based on the 6

- month, 24

- hour design storm volume of 1.5 million gallons. The hydraulic capacity of the stormwater

system (including diversion structures) was desi gned for a 100

- year, 24

- hour (4.0 inches of

rain) storm. All flow in excess of 28 cfs is diverted around the pond via a series of three

overflow structures.

Stormwater from outside the industrially developed plant site flows through two separate

ditches. The two separate ditches combine with the stormwater pond effluent at the diversion

structure that directs the stormwater to Outfall 001 if there is sufficient hydraulic capacity or

to Outfall 002 during overflow conditions . At this point, the water is t reated to remove oil

with a continuously operated mechanical oil skimmer. Absorbent materials (e.g. socks) are

located immediately prior to the location where the effluent enters the discharge pipe.

There is one additional area where stormwater may potent ially become contaminated from

industrial activities. It is a s ilo storage area near the entrance to the pier. The facility utilizes

best management practices such as good housekeeping to prevent stormwater from

contacting pollutants in th is area.

Non

- st ormwater wastewater is allowed to be discharged to the stormwater treatment pond if

it is approved by Ecology. Examples of such wastewater streams may include , but are not

limited to

, discharges from fire fighting activities, fire protection system flushi ng, testing,

and maintenance, discharges of potable water including water line flushing, provided th eFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 13 of 145

water line flushing is de

- chlorinated prior to discharge, uncontaminated air conditioning or

compressor condensate, and landscape wat ering and irrigation drainage.

Additional Waste water Streams

Intalco operates a steam

- cleaning station in each of three maintenance shops (Automotive,

Central, and Annex). These stations are used to clean various pieces of plant equipment prior

to maintenance activities. The wastewater from these stations is treated with sand filtration

to remove suspended solids and with a coalescing filter to remove oil and grease. The

filtered wastewater is then discharged to the process sewer system without any additional

treatment befor e it is discharged to Outfall 001.

Since the current permit was issued in March 2007 , Intalco eliminated one of the largest

wastewater components discharged from Outfall 001. In September 2010, Intalco installed a

closed

- loop cooling system for their comp ressor to replace the existing once

- through cooling

water system. This project eliminated approximately 2.5 MGD of wastewater from being

discharged to the Strait of Georgia.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 14 of 145

F igure 2 Intalco Water Balance (flows ar e approximate)Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 15 of 145

Sol ids Management

The facility has a solid waste control plan that was updated in September 2011 and submitted

with the permit renewal application . Intalco’s solid waste disposal facility is composed of a

permanently close d double

- lined landfill (September 2007) and a permanently closed triple

lined landfill (July 2011). With no active landfills, all solid and hazardous wastes generated

on

- site which cannot be beneficially reused are sent off

- site to a solid waste landfill or a

permitted hazardous waste t reatment , storage, or disposal facility (TSDF) such as the Waste

Management landfill in Arlington, O regon. The following paragraphs discuss the solids

generated by the wastewater treatment systems.

Soli ds from the clarifiers associated with the PWTS and SEC are sent to a vacuum filter

system that dewaters the sludge and prepares the d r ied solids for disposal at an off

- site

TSDF

. Some of the solids that settle out in the clarifier associated with the SEC are recycled

back into t he flocculation tank to promote larger floc formation

.

The settlings tanks associated with the ACWTS are emptied approximately once per week

and the solids are recycled back int o the anode production process.

Solids also accumulate in the stormwater pond a nd sanitary lagoon. According to the

Sanitary Water Treatment Facility Operations and Maintenance manual, it is estimated that

solids removal will be necessary every 10

- 15 years from the sanitary lagoon. The Intalco

laboratory monitors the sludge depth once per year

. T he last sludge removal activity at the

stormwater pond occurred in 20 11 . The last sludge removal activity for the sanitary lagoon

occurred in 1993.

Discharge O utfall s

Intalco has multiple outfalls that all dischar ge to the Strait of Georgia. Outfall 001

discharges a combination of process wastewater, domestic wastewater, and stormwater

. Outfall 002 is an overflow for stormwater discharges that exceed the hydraulic capacity of

Outfall 001

. Outfalls 011 and 012 di scharge stormwater.

W astewater discharge d from Outfall 001 is a combination of treated process wastewater from

the secondary water treatment system and anode contact cooling water treatment system,

treated domestic wastewater from the sanitary water treatm ent system, filtered wastewater

from the autoshop and annex steam cleaners, and various non

- contact cooling water streams.

Stormw ater collected from the areas where industrial activity occurs at t he site is treated in

the storm water pond and the effluent is combined with stormwater collected from outside of

the active portion of the site. In February 2009 , Intalco completed construction of a

diversion structure to divert stormwater previously discharged through Outfall 002 to O utfall

001. The wastewater discharged from Outfall 001 is conveyed continuously through a 24

- inch diameter fiberglass reinforced plastic pipe and discharged through a 24

- inch diameter,

120

- foot long diffuser.

Whenever the hydraulic capacity of Outfall 001 is exceeded, stormwater is automatically

diverted to Outfall 002. The discharge to Outfall 002 is conveyed through a 30

- inch diameter

fiberglass reinforced pla stic pipe and has no diffuser.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 16 of 145

Outfall 011 and Outfall 012 are stormwater outfalls that are loc ated along the northern and

southern edge of the si lo storage area, respectively.

Outfalls 003, 004, and 005 are part of the existing permit, but are not included in the

proposed permit. These outfalls were included in the existing permit at the request o f the

Permittee. These outfalls are associated with groundwater seeps from three landfills that

have been either remediated or closed and capped. Outfall 003 is associated with an area that

was operated as a landfill between 1966 and 1978

, Outfall 004 is associated with an area that

was operated as a landfill between 1971 and 1984 , and Outfall 005 is associated with a

historic landfill known as the Construction Debris Landfill that was operated between 1966

and 1973. Under the state of Washington’s Model Toxics Control Act (MCTA) and a

Consent Decree entered by Whatcom County Superior Court on February 02, 2007 (Docket

Number 07

- 2

- 00181

- 2), Intalco remediated the landfills associated with Outfall 003 and

Outfall 004 and closed and capped the landfill a sso ciated with Outfall 005. These areas and

outfalls are still regulated under the Consent Decree and the MCTA program at Ecology. See

Appendix G for the results of the monitoring that was required as part of the Consent

Decree.

Since these outfalls are cur rently covered under two regulatory authorities, NPDES and

MTCA, Ecology reviewed the appropriateness of maintaining the outfalls in the proposed

permit. Ecology decided to remove the outfalls from the NPDES permit for two reasons : 1)

the groundwater seep s do not appear to meet the definit ion of a point source, and 2) the

landfills are no longer being actively used and the monitoring/required actions are more

appropriately regulated by the MCTA program. In accordance with WAC 173

- 220, a point

source is de fined as “any discernible, confined and discrete conveyance, including but not

limited to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling

stock, concentrated animal feeding operation, or vessel or other floating craft, from which

pollutants are or may be discharged. ” The drainage from the remediated landfills is

groundwater that exits the bluff and flows i nto the Strait of Georgia. The location of the

groundwater seeps are not discrete discharges of potenti ally contaminated wastewater.

Therefore, an NPDES permit is not required for the discharge and the corresponding outfalls

have been removed from the proposed permit. Future monitoring requirements for the

discharges from the landfills will be determined as part of the MCTA Cons ent Decree

mentioned earlier.

B. Description of the Receiving W ater

A ll outfalls discharge to the Strait of Georgia in Northern Puget Sound . Other nearby point

sources include outfalls at the BP Cherry Point Refinery, Puget Sound Energy Whitehorn

Generating Station, Birch Bay STP (municipal), and Phillips 66 Ferndale Refinery.

The ambient background data used for this permit was obtained from Ecology’s

Environmental Assessment Program (EAP) an d from a receiving water study c onducted in

July

- September 1999. Ecology, through its ambient monitoring program, has collected water

quality data, including temperature, pH, dissolved oxygen, ammonia, and salinity, at various

intervals from the surface down to 201 meters below the water surface in the Strait of

Georgia since November 1989. The name of the ambient monitoring station closest to the

Intal c o outfalls is Georgia Strait

– N. of Patos Island (GRG002)

. T he maximum a ndFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 17 of 145

minimum values associated with the ambient monitoring station are shown below in Table 2.

T he se values are the results of discrete samples collected from the surface down to

approximately 5 meters ( 16.5 feet) below the surface

. T he average values are the averages of

the r esults down to the same depth.

Ambient metals concentrations in the water near the Intalco outfalls were obtained from the

April 2000 report prepared by Eric Crecelius, Battelle Marine Sciences Laboratory entitled

“Concentrations of Me tals in Marine Water Effluent of the Alcoa Intalco Works”. The report

presents the results of a receiving water study conducted in th e Cherry Point area in July

September 1999. The samples for the receiving water study were collected up current of the

In tal c o effluent mixi ng zone. There were a total of ten samples collected twice per day on

five separate days between July and September 1999. Th e samples were analyzed for a

number of parameters including aluminum, cadmium, copper, mercury, lead, zinc, cyanide,

and fluoride. The results presented below are t he average of the ten samples.

The ambient background data used for this permit is presented in Table 2 below.

Table 2 Ambien t Background Data

Parameter Value Used

Temperature ( summer 1

- DADMax) 15.2 o C

Te mperature (winter 1

- DADMax) 10.7 o C

pH (Maximum / Minimum) 8.90 / 6.90 standard units

Dissolved Oxygen 6.2 mg/L

Total Ammonia

- N 16.3 u g/L

Salinity 24.54 g / kg

Lead

, dissolved 0.01 μg/L

Copper , dissolved 0.47 μg/L

Zinc , dissolved 0.57 μg/L

Aluminum, dissolved 5.8 μg/L

Cadmium, dissolved 0.059 μg/L

Mercury, dissolved 0.65 ng/L

Fluoride, dissolved 0.75 mg/LFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 18 of 145

C. Wastewater C haracterization

Intalco reported the concentration of pollutants in the discharge at Outfalls 001, 002, 011

, and 012 in the permit application submitted in September 2011 and updated in September

2013. Additional data was also obtained from the discharge monitoring reports (DMR ) that

are required to be submitted on a monthly basis

. The charac terization data in the application

includes the results from samples collected between August 1, 2010 and July 31, 201 1 for

Outfalls 001 and 002 and between April 2007 and September 2011 fo r Outfalls 0 1 1 and 0 1 2.

The information for Outfalls 001 and 002 reflect the data gathered after the completion of the

Closed Loop Compressor Cooling Project

. Additional data is available between August 2011

and October 2013 from the DMRs and priority po llutant testing. A summary of the DMR

data submitted between April 2007 and October 201 3 is included in Appendix D

. The

wastewater effluent for these outfalls is characterized as follows:

Table 3 Outfall 001 Wastewater Characterization

Parameter Units # of Samples Average Value Maximum Value

Biochemical Oxygen

Demand (BOD 5 ) mg/L 2 N/A <1.0

Chemical Oxygen

Demand (COD) mg/L 1 N/A <3.0

Total Organic Carbon

(TOC) mg/L 2 4.0 5

. 20

Total Suspended Solids

(TSS) mg/L 5 6 8. 45 37

TSS lbs/day 164 107 285

Ammonia (as N) mg/L 1 N/A 0.52

Temperature (winter) o C 1309 8.4 18.9

Temperature (summer) o C 1309 16.1 24.4

Bromide mg/L 2 4.47 8.94

Color mg/L 1 N/A 11

Fluoride mg/L 5 5 7 .73 27.50

Fluoride Lbs/day 163 120.8 810

Nitrate

- Nitrite (as N) mg/L 3 2.36 3.48Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 19 of 145

Table 3 Outfall 001 Wastewater Characterization

Parameter Units # of Samples Average Value Maximum Value

Total Organic Nitrogen

(as N) mg/L 1 N/A 4.49

Oil and Grease mg/L 42 0. 79 4.4

Total Phosphorous (as

P) mg/L 1 N/A 0.111

Total Alpha Particles pCi/L 1 N/A 0

Total Beta Particles pCi/L 1 N/A 11.3

Total Radium mg/L 1 N/A 1.01

Total Radium

- 226 mg/L 1 N/A 1.01

Sulfate (as SO4) mg/L 2 578.5 1108

Total Aluminum mg/L 5 6 1.5 9 7.37

Aluminum Lbs/day 164 25.0 242.7

Total Barium u g/L 1 N/A 74

Total Boron ug/L 1 N/A 210

Total Iron ug/L 1 N/A 140

Total Magnesium mg/L 1 N/A 27.3

Total Molybdenum ug/L 1 N/A 108

Total Manganese ug/L 1 N/A 70

Total Antimony ug/L 9 3.6 17

Total Arsenic ug/L 5 27.4 50

Total Cadmium ug/L 5 0.6 1.5

Total Chromium ug/L 5 0.9 2.0Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 20 of 145

Table 3 Outfall 001 Wastewater Characterization

Parameter Units # of Samples Average Value Maximum Value

Total Copper ug/L 6 4. 0 5.2

Total Lead ug/L 5 0. 3 0.7

Total Mercury ng/L 6 2.5 3.54

Total Nickel ug/L 9 37 90

Total Selenium ug/L 5 3 .0 12

Total Thallium ug/L 5 0.17 1

Total Zinc ug/L 5 53 62

Acenapthene ug/L 5 0.2 5 0. 6

Anthracene ug/L 5 0.0 4 0. 5

Benzo(a)Anthracene ug/L 5 0.5 3 1.6

Benzo(a)Pyrene ug/L 5 0. 75 1

. 9

3,4

- Benzofluoranthene ug/L 6 0.81 2.6

Benzo(ghi)Perylene ug/L 5 0. 43 0.3

Benzo(k)fluoranthene ug/L 5 0. 32 0. 9

4

- Chlorophenyl Ether ug/L 2 N/A 0.08

Chyrsene mg/L 5 0.5 3 1.7

Fluoranthene ug/L 5 1.09 3.3

Fluorene ug/L 5 0.0 7 0. 2

Indeno (1,2,3

- cd)

Pyrene ug/L 5 0. 37 1.6

Methylene Chloride ug/L 2 0.30 0.59

Phenanthrene ug/L 5 0. 25 1 .2Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 21 of 145

Table 3 Outfall 001 Wastewater Characterization

Parameter Units # of Samples Average Value Maximum Value

Pyrene ug/L 5 0. 92 2.8

Parameter Units # of Samples Maximum

Monthly

Geometric

Mean Maximum Daily

Value

Fecal Coliform MPN/100 mL 1 N/A 4.5

Parameter Units # of Samples Minimum

Value Maximum Value

pH standard units 365 6.5 8.3

Table 4 Outfall 002 Wastewater Characterization

Parameter Units # of

Samples Average Value Maximum

Value

Biochemical Oxygen

Demand (BOD 5 ) mg/L 1 N/A 2.0

Chemical Oxygen Demand

(COD) mg/L 1 N/A 37.0

Total Organic Carbon

(TOC) mg/L 1 N/A 7.98

Total Suspended Solids

(TSS) mg/L 15 14.1 21. 2

Ammonia (as N) mg/L 1 N/A 0.07

Temperature (winter) o C 15 15.83 6.61

Temperature (summer) o C 15 19.55 15.19

Fluoride mg/L 15 22.6 33. 2

Aluminum mg/L 15 6.09 9.82Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 22 of 145

Parameter Units # of

Samples Minimum Value Maximum

Value

pH standard units 15 6.4 7.5

T able 5 Outfall 011 Wastewater Characterization

Parameter Units # of Samples Average Value Maximum Value

Biochemical Oxygen

Demand (BOD 5 ) mg/L 1 N/A 2.0

Chemical Oxygen Demand

(COD) mg/L 1 N/A 22.0

Total Organic Carbon

(TOC) mg/L 1 N/A 8.4

Total Suspended Solids

(TSS) mg/L 55 68.80 1157

Ammonia (as N) u g/L 1 N/A 90

Temperature (summer) o C 1 N/A 15.2

Fluoride mg/L 55 6.9 14.2

Aluminum mg/L 55 3. 2 4 65.0

Table 6 Outfall 012 Wastewater Characterization

Parameter Units # of Samples Average Value Maximum Value

Biochemical Oxygen

Demand (BOD 5 ) mg/L 1 N/A 2.0

Chemical Oxygen Demand

(COD) mg/L 1 N/A 33.0

Total Organic Carbon

(TOC) mg/L 1 N/A 3.4

Total Suspended Solids

(TSS) mg/L 50 5 5 .2 468

Ammonia (as N) mg/L 1 N/A 0.17Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 23 of 145

Parameter Units # of Samples Average Value Maximum Value

Temperature (summer) o C 1 N/A 15.7

Fluoride mg/L 50 4.7 11.7

Aluminum mg/L 50 4. 2 43.0

Parameter Units # of Samples Minimum Value Maximum Value

pH standard

units 1 6.85 6.85

D. Summary of C ompliance with P revious P ermit Issued

The existing permit specifies effluent limits for TSS, f luoride, a luminum, b enzo(a) p yrene,

a ntimony, n ickel, o il and g rease, and pH for Outfall s 001 and 002

. In addition, a n effluent

limit for free cyanide is also specified for Outfall 001. In February 2009 , the facility

completed construction of a diversion structure that diverts the stormwater flow from Outfall

002 to Outfall 001 unless the hydraulic capacity of Outfall 001 w ould be exceeded. Th e

diversion of stormwater to Outfall 001 produced additional loadings of certain pollutants

(TSS, fluoride, aluminum, and benzo(a)pyrene) at Outfall 001. St ormwater allocations for

those pollutants are included in the existing permit for those instances when the additional

stormwater causes the effluent from Outfall 001 to exceed established effluent limits.

Whenever the hydraulic capacity of Outfall 001 is exceeded, any additional stormwater is

discharged through Outfall 002. These discharges from Outfall 002 are required to meet the

effluent limits specified for pH, TSS, aluminum, and fluoride. Lastly , the existing permit

specifies effluent limits for BOD 5 , TSS, fecal coliform, minimum number of operating UV

tubes, and pH for the s anitary l agoon effluent.

The existing permit specifies action levels for two internal monitoring points which require

the facility to take certain steps if the effluent pollutant concentrations exceed those levels.

Both the secondary wastewater treatment plant discharge and the stormwater pond discharge

have action levels for TSS and fluoride. The stormwater pond discharge also has action

levels for aluminum and pH. It is not a permit violation if the action levels are exceeded, but

failure to take the required steps when an action level is exceeded is a vi olation of the permit

.

Intalco has generally complied with the effluent limits and permit conditions throughout the

duration of the existing permit issued on April 01, 2007 . Ecology assessed compliance based

on its review of the facility’s information in the Ecology Permitting and Reporting

Information System (PARIS), discharge monitoring reports (DMRs) and on inspections. Al l

of the violations were appropriately addressed by Intalco

.

The following table summarizes the violations that occurred during the permit term.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 24 of 145

Table 7 Violations

Violation

Date Monitoring

Point Parameter Statistical

Base Units Value Max Limit

10/1/2008 Process

WW Nickel Average

Monthly Lbs/Day 2.6 1.9

10/1/2008 Process

WW Nickel Daily

Maximum Lbs/Day 14. 5 2.7

The following table summarizes compliance with report submittal requirements over the

permit term.

Table 8 Permit Submittals

Permit

Section Required Submittal Frequency/Due Date Status

S1.D. Engineering Report for

Outfall 002 Diversion Once/ January 1, 2008 Submitted as

required

S1.D. Plans and Specifications Once/ July 1, 2008 Submitted as

required

S1.D. Revision to O&M Manual

for Diversion As necessary/ December 1,

2008 Submitted as

required

S1.D. Diversion of Stormwater

from Outfall 002 to Outfall

001 Once/ March 1, 2009 Submitted as

required

S1.I. Priority Pollutant Testing Annually/ Within 90 days of

each sampling event Submitted annually

as required

S2.D. Discharge Monitoring Report Monthly/ 15 th day of each

month Submitted a s

required

S3.A. Updated Operations and

Maintenance Manual As necessary/ October 1, 2011 Submitted as

required

S5.C. Updated Solid Waste Control

Plan As necessary/ October 01, 2011 Submitted as

required

S7. Updated Spill Plan As necessary/ April 1, 2008 Submitted as

requiredFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 25 of 145

Table 8 Permit Submittals

Permit

Section Required Submittal Frequency/Due Date Status

S8.A. Acute Toxicity Effluent

Characterization

– Outfall

001 Every other month for one year/

Within 60 after the diversion is

completed and operational

( March 2009 ) Submitted as

required

S8.D. Acute Toxicity Effluent

Characterization

– Outfall

001 Quarterly if Acute Toxicity

Limit is established/ As

determined N/A

S8 .D. Acute Toxicity Tests

–

Outfall 002 Quarterly until completion of

diversion (March 2009) /

Within 60 days of the sample

date Submitted as

required

S8.E. Acute Toxicity TI/TRE Plan As necessary N/A

S8.F. Acute Toxicity Effluent

Characterization

– Outfall

001 Twice if no acute toxicity limit

established/ Summer 2010 and

Winter 2010 Submitted as

required

S9.A. Chronic Toxicity Effluent

Characterization

– Outfall

001 Every other month for one year/

Within 60 after the diversion is

completed and operational

( March 2009) Submitted as

required

S9.D. Chronic Toxicity Tests

–

Outfall 001 Quarterly if chronic toxicity

limit established/ As determined N/A

S9.D. Chronic Toxicity Tests

–

Outfall 002 Quarterly until completion of

the diversion (March 200 9) /

Within 60 days of the sample

date Submitted as

required

S9.E. Chronic Toxicity TI/TRE

Plan As necessary N/A

S9.F. Chronic Toxicity Tests

–

Outfall 001 Twice if no chronic toxicity

limit established/ Summer 2010

and Winter 2010 Submitted as

requiredFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 26 of 145

Table 8 Permit Submittals

Permit

Section Required Submittal Frequency/Due Date Status

S10.B. Treatment Efficiency Study

Plan for the SWTS a Once/ January 1, 2008 Submitted as

required

S10.B. Treatment Efficiency Study

for the SWTS a

– Sampling Once/ Within 90 days of

Ecology’s approval of the plan Not yet required.

Ecology in process

of reviewing plan

S10.B Treatment Efficiency Study

Results for the SWTS a Once/ Within 120 days of

completing the study Not yet required.

Ecology in process

of reviewing plan

S10.B. Updated the O&M plan

required by S3.A. to include

design standards or any

upgrades to the SWTS a as

identified in the Treatment

Efficiency Study and

Engineering Report Once/ Within 90 days of

Ecology’s written determination

that it meets design standards or

90 days after completing

upgrades Not yet required.

Ecology in proce ss

of reviewing plan

S10.B. Engineering Report for

SWTS a Once/ Within 120 days of

receipt of Ecology’s

determination that SWTS does

not meet design standards Not yet required.

Ecology in process

of reviewing plan

S10.B. Upgrades to SWTS a Once/ Within 2 years of receipt

of Ecology’s written approval

of the engineering report Not yet required.

Ecology in process

of reviewing plan

S10.B. Interim report on progress

toward completion of SWTS

a upgrades Once/ Within 1 year of

Ecology’s written approval of

the engineering report Not yet required.

Ecology in process

of reviewing plan

S10.C. AKART Study Plan for the

ACWTS Once/ January 1, 2008 Submitted as

required.

S10.C. AKART Study Plan for the

ACWTS

- Sampling Once/ Within 90 days of

Ecology’s approval of the plan Not yet required.

Ecology in process

of reviewing plan

S10.C. Engineering Report with the

AKART findings for Once/ Within 120 days of Not yet required.

Ecology in processFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 27 of 145

Table 8 Permit Submittals

Permit

Section Required Submittal Frequency/Due Date Status

ACWTS completion of AKART study of reviewing plan

S10.C. Upgrades to ACWTS Once/ Within 2 years of receipt

of Ecology’s written approval

of the engineering report Not yet required.

Ecology in process

of reviewing plan

S10.C. Interim Report on Progress

Toward Completion of

ACWTS Upgrades Once/ Within 1 year of receipt

of Ecology’s written approval

of the engineering report Not yet required.

Ecology in process

of reviewing plan

S10.C. Update the O&M Plan

required by S3.A. to include

AKART design standards or

any upgrades to the ACWTS

as identified in the AKART

Study and Engineering

Report for the ACWTS Once/ 90 days after Ecology’s

determination that the ACWTS

meets AKART design standards Not yet required.

Ecology in process

of reviewing plan

S11.A. Sediment Sampling and

Analysis Plan Once/ April 1, 2011 Submi tted as

required.

S11.A. Sediment Monitoring Once/ First stable period (mid

August through September)

following Ecology’s approval

of the plan Not yet required.

Ecology in process

of reviewing plan

S11.B. Sediment Data Report Once/ Within 180 days of

completion of monitoring Not yet required.

Ecology in process

of reviewing plan

S12. Outfall Evaluation As necessary/ October 1, 2011 Submitted as

required.

S14.B. Updated Stormwater

Prevention Pollution Plan As necessary/ January 1, 2008 Submitted as

required.

S15.A. Ground Water Impact Study

Plan Once/ March 1, 2010 Submitted as

required.

S15.B. Ground Water Impact Study Once/ Within 180 days of

Ecology’s approval of the plan Not yet required.

Ecology in processFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 28 of 145

Table 8 Permit Submittals

Permit

Section Required Submittal Frequency/Due Date Status

of reviewing plan

S15.C. Ground Water Impact Study

Report Once/ Within 120 days of

completing the study Not yet required.

Ecology in process

of reviewing plan

G5. Engineering Report for

Construction or Modification

Activities As necessary Submitted as

required.

G7. Application for Permit

Renewal Once/ October 1, 2011 Submitted as

required.

a. The acronym for the Secondary Wastewater Treatment System has been changed from SWTS

to SEC in the draft permit

.

E. State E nvironmental P olicy A ct (SEPA) C ompliance

State law exempts the issuance, reissuance or modification of any wastewater discharge

permit from the SEPA process as long as the permit contains conditions that are no less

stringent than federal and state rules and regulations (RCW 43.21C.0383). The exemption

a pplies only to existing discharges, not to new discharges. The proposed permit does not

contain any permit conditi ons that are less stringent than federal or state rules or regulations.

Therefore, SEPA is not required for this action.



### III. Proposed Permit Limits

Federal and state regulations require that effluent limits in an NPDES permit must be either

technology

- or water quality

- based.

• Technology

- based limits are based upon the treatment methods available to treat specific

pollutants. Technology

- based l imits are set by the EPA and published as a regulation, or

Ecology develops the limit on a case

- by

- case basis (40 CFR 125.3, and chapter

173

- 220 W AC).

• Water quality

- based limits are calculated so that the effluent will comply with the Surface

Water Qualit y Standards (chapter 173

- 201A WAC), Ground Water Standards (chapter

173

- 200 WAC), Sediment Quality Standards (chapter 173

- 204 WAC), or the Nationa l Toxics

Rule (40 CFR 131.36).

• Ecology must apply the most stringent of these limits to each parameter of con cern. These

limits are described below.

The limits in this permit reflect information received in the application and from supporting

reports (engineering, WET , etc.). Ecology evaluated the permit application and determined theFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 29 of 145

limits needed to comply wi th the rules adopted by the state of Washington. Ecology does not

develop effluent limits for all reported pollutants. Some pollutants are not treatable at the

concentrations reported, are not controllable at the source, are not listed in regulation, and do not

have a reasonable potential to ca use a water quality violation.

Ecology does not usually develop limits for pollutants not reported in the permit application but

may be present in the discharge. The permit does not authorize discharge of the non

- r eported

pollutants. During the five

- year permit term, the facility’s effluent discharge conditions may

change from those conditions reported in the permit application. The facility must notify

Ecology if significant changes occur in any constituent [40 C FR 122.42(a)] . Until Ecology

modifies the permit to reflect additional discharge of pollutants, a permitted facility could be

violating its permit.

A. Design C riteria

Under WAC 173

- 220

- 150 (1)(g), flows and waste loadings must not exceed approved design

c riteria. There are two treatment systems associated with the Intalco facility that have

approved design criteria, the ultraviolet disinfection (UV) system associated with the sanitary

wastewater treatment plant and the stormwater pond. The facility submi tted a stormwater

pond characterization study in July 2001 spe cifying the maximum storm event that the

stormwater system can properly treat

. The facility also submitted an engineering report for

the ultraviolet disinfection system prior to installation in 2002. Table 9 below shows the

specific design criteria.

Table 9 Intalco Design Criteria

Sanitary Lagoon

Flow through the UV Disinfection

System 350,000 gpd

Stormwater Pond

Influent Flow 30 cfs in any consecutive 10

minute period*

*As determined by measuring stormwater pond effluent and adjusted for

rainfall

Ecology has determined that the system meets AKART requirements based on the

information presented in the Stormwater Pond Characterizatio n Study submitted in July

2001. Ecology understands that the intensity and frequency of all future storm events are

difficult to predict when designing a stormwater treatment system. Ecology also understands

that if the design criterion of the treatment system is exceeded during a storm event, the

treatment efficiency of the system decreases significantly. Therefore, the facility is allowed

to bypa ss the storm water treatment pond for events that exceed the hydraulic design criteria.

Ecology will not con sider these individual bypasses as a violation of the bypass permit

condition or the design criteria condition, as long as the bypass can meet wa ter quality

criteria.

AKART for stormwater is constantly progressing and, as technology advances, facilities wi ll

have more cost effective, more efficient, and higher capacity treat ment system optionsFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 30 of 145

available. Ecology expects Intalco to meet AKART and make the necessary improvements

to its treatment system as th e treatment technology evolves.

B. Technology

- Based Effluent L imits

Process Wastewater

The EPA has established technology

- based limits for a number of industrial categories,

including the nonferrous metals manufacturing industry. These limits are specified in 40

CFR Part 41

. The applicable federal effluent limit guidelines for the primary aluminum

smelting subcategory (Subpart B) were first proposed on March 8, 1984. The se guidelines

c ontain effluent limits based on the degree of pollutant reduction attainable by the application

of the best practic able control technology currently available (BPT) and the application of the

best available technology economically achievable (BAT). Also, new source performance

standards (NSPS) apply to sources constructed after the promulgation of the NSPS, which

occu rred on March 8, 1984

.

The BPT guidelines apply to the total wastewater generated by the aluminum smelting

process, but the BAT effluent limits guidelines apply to the different processes involved in

aluminum smelting. According to the permit renewal app lication, the Intalco aluminum

smelting process includes the following wastewater sources: anode contact cooling and

briquette quenching, potroom wet air pollution control, and direct casting contact cooling.

All of these units were constructed prior to M arch 8, 1984, so the new source performance

standards do not apply to this facility.

EPA periodically reviews its effluent limit guidelines and determines when guidelines for

specific industries need to be updated. The latest review of the nonferrous met als category

occurred during the 2010 review and the results of the evaluation are described in EPA’s

Technical Support Document for the 2010 Effluent Guidelines Program Plan

. Based on

EPA’s review , the nonferrous metals category was not cons idered a prio rity for updating.

The tables below specify the applicable BPT and BAT effluent limit guidelines for Intalco.

T able 10 BPT Effluent Limit Guidelines

Pollutant Maximum for any 1 Day Maximum for monthly

average

l bs/thousand lbs of product

Fluoride 2.0 1.0

Total Suspended Solids 3.0 1.5

pH (1) (1)

(1) Within the range of 6 to 9 at all times.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 31 of 145

Table 11 BAT Effluent Limit Guidelines

Pollutant Anode Contact Cooling

and Briquette Quenching Potroom Wet Air

Pollution Control Direct Chill Casting

Contact Cooling

Maximum

for any 1

Day Maximum

for monthly

average Maximum

for any 1

Day Maximum

for monthly

average Maximum

for any 1

Day Maximum

for

monthly

average

lbs/million lbs of anodes

cast lbs/million lbs of Al

produced from

electrolytic reduction lbs/million lbs of Al

product from direct chill

casting

Benzo(a)

-

pyrene 0.007 0.003 0.056 0.026 (1) (1)

Antimony 0.403 0.180 3.204 1.428 2.565 1.143

Nickel 0.115 0.077 0.913 0.614 0.731 0.492

Aluminum 1.277 0.566 10.140 4.499 8.120 3.602

Fluoride 12.440 5.518 98.770 43.830 79.080 35.090

(1) There shall be no discharge allowance for this pollutant.

The existing permit includes technology based limits for Outfall 001 that were established

using the effluent limit guidelines (B(a) P, antimony, nickel , aluminum ) and best professional

judgment (BPJ) (TSS, fluoride, aluminum)

. The e ff luent limit guidelines presented in Tables

1 1 and 12 above are based on the production of aluminum metal and the pounds of anodes

cast during the aluminum production process. At full production, the facility is able to

produce approximately 31,500 tons of aluminum per month, which is approximately 2.1

million pounds of aluminum metal produced per day. However, the produc tion rate at the

facility may vary during a permit term based on market conditions. To account for this

variability, Ecology established tiered production limits with the higher tier applicable when

production exceeded 15,614 tons per month , t he middle ti er applied to production rates

between 10,305 tons per month and 15,614 tons per month, and the lowe st tier applies

whenever the facility produces le ss than 10,305 tons per month. Tables 1 3 and 1 4 below

present the technology

- based limits calculated usin g the EPA effluent limit guidelines , BPJ,

and tiered production values.

In addition to ensuring that the facility meets the effluent limit guidelines established by

EPA, Ecology must also ensure that facilities provide all known, available, and reasonable

methods of prevention, control, and treatment (AKART) when it issues a permit. As

described in Section I.A above, all of the process wastewater at the facility is treated at a

minimum throu gh settling to remove solids. The primary and secondary wastewate r

treatment plants also provide chemical addition to enhance treatment of solids and promote

treatment of fluoride. The facility reuses the majority of the treated effluent from the primary

treatment system which significantly reduces the amount of wastew ater that is discharged

from the facility. The quality of water needed to allow the water to be reused dictates the

level of treatment necessary at the primary wastewater treatment system. With the exception

of the anode contact cooling water, the facili ty appears to be providing AKART for the

wastewa ter generated by the facility.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 32 of 145

P reliminary sampl ing results from the Anode Contact Cooling Water Study indicate that a

full AKART analysis will need to be performed for that particular wastewater stream. The

sample results demonstrate that the current treatment system is providing between 38% and

68% removal of B(a)P from the wastewater stream

. The results also show that the current

treatment may not be consistently meet ing the effluent limit guidelines specified in Table 1 1

above for that particular wastewater source , even though the Permittee has been able to meet

the final effluent limits for B(a)P. One of the most common improvements to the treatment

system would be to add chemical coagulants to the wastewater stream to enhance solids

settling. Ecology acknowledges that the facility reuses solids that settle out during the

treatment process and that c hemical addition used to enhance the treatment efficiency would

prohib it reuse of the solids. Therefore, t he facility is investigating other options , including

elimination of the discharge. Based on this information, the draft permit requires the

Permittee to co mplete the AKART analysis for the Anode Contact Cooling Water wastewater

stream during the next permit cycle. Ecology will evaluate the results of the analysis to

determine if there are any additional treatment options that must be implemented to

demonstrate that the facility is providing AKART for th e anode contact cooling water.

The limits contained in the existing permit for TSS, fluoride, and aluminum were established

using BPJ during the permitting process for the permit issued on September 1, 1998. The

limits for Outfall 001 were based on the performance of th e process wastewater treatment

system. A statistical analysis was run on two years of representative monitoring data using a

method consistent with EPA and Ecology effluent limit

- setting guidelines. The limits were

established when the facility was opera ting at full production. The TSS limit calculated

using this method (27.5 lbs/day) was appealed and the TSS limit was reverted back to the

limit established in the permit issued on January 15, 1991 (150 lbs/day). The BPJ limits are

more stringent than th e limits calculated using the effluent limit guidelines.

Table 12 Outfall 001 Effluent Limits

- Maximum Da il y

Production TSS Fluoride Aluminum B (a) P Antimony Nickel

Tons/Month lbs/ day lbs/day lbs/day lbs/day lbs/day lbs/day

10,305 2061.0 130.7 13.4 0.043 4.2 1.2

15,614 3122.8 198.1 20.0 0.065 6.4 1.8

23,250 4650.0 294.9 30.3 0.098 9.6 2.7

31,500 6300.0 399.6 41.0 0.132 13.0 3.7

31,500 (BPJ) 185 296 30 N/A N/A N/AFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 33 of 145

Table 13 Effluent Limits

– Average Month ly

Production TSS Fluoride Aluminum B ( a ) P Antimony Nickel

Tons/Month lbs/ day lbs/day lbs/day lbs/day lbs/day lbs/day

10,305 1030.5 58.0 6.0 0.020 1.9 0.8

15,614 1561.4 87.9 9.0 0.030 2.9 1.2

23,250 2325.0 130.9 13.4 0.045 4.3 1.8

31,500 3150.0 177.3 18.2 0.061 5.8 2.5

31,500 (BPJ) 150 68 10.3 N/A N/A N/A

The limits in the existing permit are shown in bold in the tables above. The tiered effluent

limits for B(a)P, antimony, nickel , and aluminum were established using the following

production rates: 23,250 tons/month, 15,614 tons/ month, and 10,305 tons/month. The

average production rate between March 2011 and March 2013 was 20,305 tons per month

and the highest production month during th is time period was 21,576 tons. Based on these

recent production rates, it appears that the technology based permit limits in the current

permit are representative of the operations at the facility and are appropriate to ma intain in

the proposed permit.

Netting Out

The industrial water supplied to Intalco by Whatcom County PUD No.1 is treated Nooksack

River water. The treatment process consists of coagulation/flocculation followed by settling.

The treated water is not filtered and contains concentrations of TSS, al uminum, antimony

and nickel. The TSS and aluminum levels in the incoming source water do not meet the

technology

- based limits for primary aluminum smelters that are based upon the amount of

product produced. Since the TSS, aluminum, antimony, and nickel levels in the effluent at

Outfall 001 are not fully representative of the impacts from the smelter, the NPDES permit

allows Intalco to “net out” incoming pollutants in the intake water. Netting out allows

Intalco to subtract the amount of TSS, aluminum, a ntimony and nickel in the intake water

from the values in the effluent to determine compliance with the effluent limits. The effluent

limits established for Outfall 001 are for the net discharge of TSS, a luminum, antimony, and

nickel.

Netting out is allow ed in federal regulation by 40 CFR 122.45(g). There is a restriction that

the discharge is to the same water body as the intake water unless there is a finding of no

environmental degradation. Ecology policy uses the result s of whole effluent toxicity (W ET)

tests as the criteria for determining environmental degradation. There does not appear to be

environmental degradation associated with the constituents in the intake water at this time

. T he draft permit states that Ecology will notify the Permittee i n writing it if it determines that

netting out is resulting in environmental degrada tion and is no longer allowed.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 34 of 145

Sanitary Wastewater

E PA has not established specific technology based guidelines for privately owned sanitary

wastewater treatment plants

. However, state regulations contain discharge standards for all

domestic wastewater facilities, including privately owned facilities. The effluent from the

sanitary wastewater treatment plant at Intalco must meet the effluent requirements specified

in WAC 173

- 221

- 0 5 0 since they have a waste stabilization pond that treats less than a two

million gallon per day . The effluent limit requirements for the sanitary wastewater treatment

plant are specified in the table below.

Table 14 Tech nology Based Limits for the Sanitary Wastewater Treatment Plant

Parameter Average Monthly

Limit Weekly Average

Limit

Biochemical Oxygen

Demand (BOD) 45 65

TSS 45 65

Fecal Coliform 200 400

Parameter Minimum % Removal

BOD and TSS 65%

Parameter Daily Minimum Daily Maximum

pH 6.0 standard units 9.0 standard units

Stormwater

The EPA has not established technology based effluent limits for stormwater that is

discharged from aluminum smelting facilities , so Ecology used BPJ to establish limits for the

stormwater that is discharged to Outfall 001 and Outfall 002. There are two separate

stormwater streams at the site, one that is collected from the active portion of the site where

industrial activity is o ccurring and one that is collected from the portion of the site where no

industrial activity is occurring. The stormwater from the active portion is treated in the

stormwater treatment pond and then combined with the stormwater from the non

- industrial

are a. In the past, the combined stormwater was discharged from Outfall 002. T he NPDES

permit that was issued to Intalco on September 1, 1998 established limits for th e combined

stormwater using a statistical analysis method consistent with EPA and Ecology e ffluent

limit setting guidelines. Ecology used m onitoring data that was supplied by the Permittee at

that time, which included storm events. These stormwater limits have not been c hanged in

the proposed permit.

As discussed in Section A above, a stormwat er diversion structure was completed in

February 2009 to divert the majority of the stormwater discharge s from Outfall 002 to Outfall

001. The stormwater was combined with the process wastewater streams prior to discharge

and prior to the monitoring point to demonstrate compliance with the permit limits forFact Sheet for NPDES Permit WA 0 002950

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Outfall 001. In order to account for the additional pollutants present in the stormwater

diverted from Outfall 002 , Ecology established stormwater allocations that add to the limits

at Outfall 001. These allocations were based on the effluent limits for Outfall 002. Because

the stormwater streams were no long er separate from the process wastewater streams and

they were sampled as part of the Outfall 001 discharge, the stormwater strea m was not given

any effluent limits. Instead

, Ecology established Action Levels at the stormwater pond

discharge to ensure that the Permittee continued to use Best Management Practices (BMPs)

in managing their stormwater and continued to operate the storm water treatment system as

designed

.

As discussed in Section IV.A below, the Permittee will be installing a separate monitoring

point for the process wastewater stream s prior to combining with the stormwater (Monitoring

Point 101)

. Please see the figure in Section IV.A of this fact sheet for a simplified diagram

of the wastewater streams, outfalls, and monitoring points associated with this permit. T he

monitoring results from Monitoring Point 101 will be used to demonstrate compliance with

the process wast ewater limits at Outfall 001

. S tormwater allocations will no longer be

necessary at Outfall 001

.

Stormwater will be monitored at D

- 10 where stormwater from the treatment pond combines

with stormwater collected from the non

- industrial area, as was the case for Outfall 002. The

l imits for Outfall 002 in the existing permit will be applied to the combined stormwater

discharged at D

- 10. Because the limits for stormwater apply at Monitoring Point D

- 10, they

are the same whether the stormwater is discharged fr om Outfall 001 or Outfall 002. The

Action Levels for the stormwater pond discharge have been maintained in the draft permit to

ensure continued use of best management practices at the facility and proper operation and

maintenance of t he stormwater treatme nt pond.

C. Surface Water Quality

- Based Effluent L imits

The Washington State surface water quality standards (chapter 173

- 201A WAC) are

designed to protect existing water quality and preserve the beneficial uses of Washington's

surface waters. Waste water discharge permits must include conditions that ensure that the

discharge will meet the surface water quality standards (WAC 173

- 201A

- 510). Water

quality

- based effluent limits may be based on an individual waste load allocation or on a

waste load allocati on developed during a basin wide total maximum daily load study

(TMDL).

Numerical Criteria for the Protection of Aquatic L ife and R ecreation

Numerical water quality criteria are listed in the water quality standards for surface waters

(chapter 173

- 201A WAC ). They specify the maximum levels of pollutants allowed in

receiving water to protect aquatic life and recreation in and on the water. Ecology uses

numerical criteria along with chemical and physical data for the wastewater and receiving

water to derive the effluent limits in the discharge permit. When surface water quality

- based

limits are more stringent or potentially more stringent than technology

- based limits, the

discharge must meet the water quality

- based limits.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 36 of 145

Numerical Criteria for the Prote ction of Human H ealth

The U.S. EPA has published 91 numeric water quality criteria for the protection of human

health that are applicable to dischargers in Washington State (EPA

, 1992). These criteria are

designed to protect humans from exposure to pollu tants linked to cancer and other disease s

, based on consuming fish and shellfish and drinking contaminated surface waters. The water

quality standards also include radionuclide criteria to protect humans from the effects of

radioactive substances.

Narrati ve C riteria

Narrative water quality criteria (e.g., WAC 173

- 201A

- 240 (1 ) ; 2006 ) limit the toxic,

radioactive, or other deleterious material concentrations that the facility may discharge to

levels below those which have the potential to:

• Adversel y affect designated water uses.

• Cause acut e or chronic toxicity to biota.

• Impair ae sthetic values.

• Adversely affect human health.

Narrative criteria protect the specific designated uses of all fresh waters

(WAC 173

- 201A

- 200) and of all marine waters (WAC 173

- 201A

- 210) in the state of

Washington.

Antidegradation

Description

-- The purpose of Washington's Antidegradation Policy

(WAC 173

- 201A

- 300

- 330 ; 2006 ) is to:

• Restore and maintain the highest possible quality of the surface waters of Washington.

• Describe situations under which water quality may be lowered from its current condition.

• Apply to human activities that are likely to have an impact on the water quality of surface

water.

• Ensure that all human activities likely to contribute to a lowering of water quality, a t a

minimum, apply all known, available, and reasonable methods of prevention, control, and

treatment (AKART).

• Apply three tiers of protection (described below) for surface waters of the state.

Tier I ensures existing and designated uses are maintained and protected and applies to all

waters and all sources of pollutions. Tier II ensures that waters of a higher quality than the

criteria assigned are not degraded unless such lowering of water quality is necessary and in

the overriding public interest. Tier II applies only to a specific list of polluting activities.

Tier III prevents the degradation of waters formally listed as "outstanding resource waters,"

and applies to all sources of pollution.

A facility must prepare a Tier II analysis when all three o f the following conditions are met:

• The facility is planning a new or expanded action.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 37 of 145

• Ecology regulates or authorizes the action.

• The action has the potential to cause measurable degradation to existing water quality at

the edge of a chronic mixing zone.

Facility Specific Requirements

-- This facility must meet Tier I requirem ents.

• Dischargers must maintain and protect existing and designated uses. Ecology must not

allow any degradation that will interfere with, or become injurious to, existing or

designat ed uses, except as provide d for in chapter 173

- 201A WAC.

Ecology’s analysis described in this section of the fact sheet demonstrates that the proposed

permit conditions will protect existing and designated uses of the receiving water.

Mixing Z ones

A mixing zone is the defined area in the receiving water surrounding the discharge port(s),

where wastewater mixes with receiving water. Within mixing zones the pollutant

concentrations may exceed water quality numeric standards, so long as the discharge doesn’t

interfere with designated uses of the receiving water body (for example, recreation, water

supply, and aquatic life and wildlife habitat, etc.) The pollutant concentrations outside of the

mixing zones must meet water quality numeric standards.

State and f ederal rules allow mixing zones because the concentrations and effects of most

pollutants diminish rapidly after discharge, due to dilution. Ecology defines mixing zone

sizes to limit the amount of time any exposure to the end

- of

- pipe discharge could harm water

quality, plants, or fish.

The state’s water quality standards allow Ecology to authorize mixing zones for the facility’s

permitted wastewater discharges only if those discharges already receive all known,

available, and reasonable methods of prevention, control, and treatment (AKAR T). Mixing

zones typically require compliance with water quality criteria within a specified distance

from the point of discharge and must not use more than 25% of the available width of the

water body for dilution [WAC 173

- 201A

- 400 (7)(a)(ii

- iii)]

.

Ecolo gy uses modeling to estimate the amount of mixing that occurs within the mixing zone.

Through modeling Ecology determines the potential for violating the water quality standards

at the edge of the mixing zone and derive s any necessary effluent limits. St eady

- state models

are the most frequently used tools for conducting mixing zone analyses. Ecology chooses

values for each effluent and for receiving water variables that correspond to the time period

when the most critical condition is likely to occur (se e Ecology’s Permit Writer’s Manual ).

Each critical condition parameter, by itself, has a low probability of occurrence and the

resulting dilution factor is conservative. The term “reasonable worst

- case ” applies to these

values.

The mixing zone analysis p roduces a numerical value called a dilution factor (DF). A

dilution factor represents the amount of mixing of effluent and receiving water that occurs at

the boundary of the mixing zone. For example, a dilution factor of 5 means the effluent is

one

- fifth , or 20 %

, and the receiving water is four

- fifths , or 80 %

, of the total volume of water

at the boundary of the mixing zone. Ecology uses dilution factors with the water quality

criteria to calculate reasonable potentials and effluent limits. Water quality standards includeFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 38 of 145

both aquatic life

- based criteria and human health

- based criteria. The former are applied at

both the acute and chronic mixing zone boundaries; the latter are applied only at the chronic

boundary. The concentration of pollutants at the boundaries of any of these mixing zones

may not exceed the num erical criteria for that zone.

Each aquatic life acute criterion is based on the assumption that organisms are not exposed to

that concentration for more than one hour and more often than one ex posure in three years.

Each aquatic life chronic criterion is based on the assumption that organisms are not exposed

to that concentration for more than four consecutive days and more o ften than once in three

years.

The two types of human health

- based water quality criteria distinguish between those

pollutants linked to non

- cancer effects (non

- carcinogenic) and those linked to cancer effects

(carcinogenic). The human health

- based water quality criteria incorporate several exposure

and risk assumptions. These assumptions include:

• A 70

- year lifetime of daily exposures.

• An ingestion rate for fish or shellfish measured in kg/day.

• An ingestion rate of two liters/day for drinking water

.

• A one

- in

- one

- million cancer risk for carcinogenic chemicals.

This permit authorizes a small acute mixing zone, surrounded by a chronic mixing zone

around the point of discharge (WAC 173

- 201A

- 400). The water quality standards impose

certain conditions before allowing the discharger a mixing zone:

1. Ecology must specify both the allowed size and location in a permit.

The proposed permit specifies the size and location of the allowed mixing zone (as specified

below).

2. The facility must fully apply “all known, available, and reasonable methods of

prevention, control and treatment” (A KART) to its discharge.

Ecology has determined that the treatment provided at Intalco meets the requirements of

AKART (see “Technology

- based Limits”).

3. Ecology must consider critical discharge conditions.

Surface water quality

- based limits are derived for the water body’s critical condition (the

receiving water and waste discharge condition with the highest potential for adverse impact

on the aquatic biota, human health, and existing or designated waterbody uses). The critical

discharge condition is often pollutant

- specific or waterbody

- specific.

Critical discharge conditions are those conditions that result in reduced dilution or increased

effect of the pollutant. Factors affecting dilution include the depth of water, the density

stratification in the wat er column, the currents, and the rate of discharge. Density

stratification is determined by the salinity and temperature of the receiving water.

Temperatures are warmer in the surface waters in summer. Therefore, density stratification

is generally grea test during the summer months. Density stratification affects how far up in

the water column a freshwater plume may rise. The rate of mixing is greatest when anFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 39 of 145

effluent is rising. The effluent stops rising when the mixed effluent is the same density as the

surrounding water. After the effluent stops rising, the rate of mixing is much more gradual.

Water depth can affect dilution when a plume might rise to the surface when there is little or

no stratification. Ecology uses the water depth at mean lowe r low water (MLLW) for marine

waters. Ecology’s Permit Writer’s Manual describes additional guidance on criteria/design

conditions for determining dilution factors. The manual can be obta ined from Ecology’s

website at https://fortress.wa.gov/ecy/publicat ions/SummaryPages /92109.html.

Table 15 Critical Conditions Used to Model the Discharge from Outfall 001

Critical Condition Value

Water depth at MLLW of

- 4. 9 2 feet 15.5 feet

Density profile with a difference of 4

. 7 8 (acute) and 7

. 07

(chronic) sigma

- t units between 23 feet and the surface

10 th percentile current speed for acute mixing zone 0.04 m/sec

50th percentile current speeds for chronic and human health

mixing zones 0.15 m/sec

Maximum average monthly effluent flow for chronic and

human health non

- carcinogen 3.41 MGD

Annual average flow for human health carcinogen 1.61 MGD

Maximum daily flow for acute mixing zone 8.94 million

gallons per day

(MGD)

1 DAD MAX e ffluent temperature 2 2

. 1 degrees C

Table 16 Critical Conditions Used to Model the Discharge from Outfall 002

Critical Condition Value

Water depth at MLLW of

- 4.92 feet 9.1 feet

Density profile with a difference of 4.78 (acute) and 7.07

(chronic) sigma

- t units between 23 feet and the surface

10 th percentile current speed for acute mixing zone 0.04 m/sec

50th percentile current speeds for chronic and human health

mixing zones 0.15 m/secFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 40 of 145

Critical Condition Value

Maximum average monthly effluent flow for chronic and

human health non

- carcinogen 0.362 MGD

Annual average flow for human health carcinogen 0.362 MGD

Maximum daily flow for acute mixing zone 0.418 million

gallons per day

(MGD)

1 DAD MAX effluent temperature 19

. 6 degrees C

Ecology obtained ambient data at critical conditions in the vicinity of the outfall from the

Outfalls 001 and 002 Dilution Ratio S tudy conducted in December 2006.

4. Supporting information must clearly indicate the mixing zone would not:

• Have a reasonable potential to cause the loss of sensitive or important habitat.

• Substantially interfere with the existing or characteristic uses.

• Result in damage to the ecosystem.

• Adversely affect public health.

Ecology established Washington State water quality criteria for toxic chemicals using EPA

criteria. EPA developed the criteria using toxicity tests with numerous organisms and set the

criteria to generally protect the species tested and to fully protect all commercially and

rec reationally important species.

EPA se ts acute criteria for toxic chemicals assuming organisms are exposed to the pollutant

at the criteria concentration for one hour. They set chronic standards assuming organisms are

exposed to the pollutant at the criteria concentration for four days. Dilu tion modeling under

critical conditions generally shows that both acute and chronic criteria concentrations are

reached within minutes of discharge

.

The discharge plume does not impact drifting and non

- strong swimming organisms because

they cannot stay in the plume close to the outfall long enough to be affected. Strong

swimming fish could maintain a position within the plume, but they can also avoid the

discharge by swimming away. Mixing zones generally do not affect benthic organisms

(bottom dwellers) b ecause the buoyant plume rises in the water column. Ecology has

additionally determined that the effluent will not exceed 33 degrees C for more than two

seconds after discharge; and that the temperature of the water will not create lethal conditions

o r bl ockages to fish migration.

Ecology evaluates the cumulative toxicity of an effluent by testing the discharge with whole

ef

fluent toxicity (WET) testing.

Ecology conducted a reasonable potential analysis, using procedures established by the EPA

and by Ecolo gy, for each pollutant and concluded the discharge/receiving water mixture willFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 41 of 145

not violate water quality criteria outside the boundary of the mixing zone if permit limits are

met.

5. The size of the mixing zone and the concentrations of the pollutants must b e

minimized.

At any given time, the effluent plume uses only a portion of the acute and chronic mixing

zone, which minimizes the volume of water involved in mixing. Because tidal currents

change direction, the plume orientation within the mixing zone changes. The plu me mixes as

it rises through the water column therefore much of the receiving water volume at lower

depths in the mixing zone is not mixed with discharge. Similarly, because the discharge may

stop rising at some depth due to density stratification, waters above that depth will not mix

with the discharge. Ecology determined it is impractical to specify in the permit the actual,

much more limited volume in which the dilution occurs as the plume ris es and moves with

the current.

Ecology minimizes the size of mixing zones by requiring dischargers to install diffusers

when they are appropriate to the discharge and the specific receiving water body. When a

diffuser is installed, the discharge is more completely mixed with the receiving water in a

shorter time. Ecology also minimizes the size of the mixing zone (in the form of the dilution

factor) using design criteria with a low probability of occurrence. For example, Ecology uses

the expected 95th percentile pollutant concentration, the 90th percentile backgr ound

concentration, the centerline dilution factor, and the lowest receiving water flow occurring

once in every ten years to perform the reasonable potential analysis.

Because of the above reasons, Ecology has effectively minimized the size of the mixing z one

authorized in the proposed permit.

6. Maximum size of mixing z one.

The authorized mixing zone does not exceed the maximum size restriction.

7. Acute mixing z one.

• The discharge/receiving water mixture must comply with acute criteria as near

to the point of di scharge as practicably attainable.

Ecology determined the acute criteria will be met at 10% of the distance of the chronic

mixing zone.

• The pollutant concentration, duration, and frequency of exposure to the

discharge will not create a barrier to migration or translocation of indigenous

organisms to a degree that has the potential to cause damage to the ecosystem.

As described above, the toxicity of any pollutant depends upon the exposure, the pollutant

concentration, and the time the organism is exposed to that concentration. Authorizing a

limited acute mixing zone for this discharge assures that it will not create a barrier to

migration. The effluent from this discharge will rise as it enters the receiving water, assuring

that the rising effluent will no t cause translocation of indigenous organisms near the point of

discharge (below the rising effluent).

• Comply with size restrictions.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 42 of 145

The mixing zone authorized for this discharge complies with the size restrictions published in

chapter 173

- 201A WAC.

8. Overl ap of mixing z ones.

This mixing zone does not overlap another mixing zone.

D. Designated U ses and Surface Water Quality C riteria

Applicable designated uses and surface water quality criteria are defined in chapter

173

- 201A WAC. In addition, the U.S. EPA has established human health criteria for toxic

pollutants (EPA 1992). The table included below summarizes the criteria applicable to this

facility’s discharge.

• Aquatic life uses are designated using the following general categories. All indigenous

fish and non

- fish aquatic species must be protected in waters of the state.

a. Extraordinary quality salmonid and other fish migration, rearing, and spawning; clam,

oyster, and mussel rearing and spawning; crustaceans and other shellfish (crabs,

shrimp, crayfish, scallops, etc.) rearing and spawning.

b. Excellent quality salmonid and other fish migration, rearing, and spawning; clam,

oyster, and mussel rearing and spawning; crustaceans and other shellfish (crabs,

shrimp, crayfish, scallops, etc.) rearing and spawning.

c. Good quality salmonid migration and rearing; other fish migration, rearing, and

spawning; clam, oyster, and mussel rearing and spawning; crustaceans and other

shellfish (crabs, shrimp, crayfish, scallops, etc.) rearing and spawning.

d. Fair quality salmonid and other fish migration.

The Aquatic Life Uses and the associated criteria for this receiving water are identified

below.

Table 17 Marine Aquatic Life Uses and Associated Criteria

Extraordinary Quality

Temperature Criteria

– Highest 1D MAX 13°C (55.4°F)

Dissolved Oxygen Criteria

– Lowest

1

- Day Minimum 7.0 mg/L

Turbidity Criteria • 5 NTU over background when the

background is 50 NTU or less; or

• A 10 percent increase in turbidity when the

background turbidity is more than 50 NTU.

pH Criteria pH must be within the range of 7.0 to 8.5 with

a human

- caused variation within the above

range of less than 0.2 units.

• To protect shellfish harvesting, fecal coliform organism levels must not exceed a

geometric mean value of 14 colonies/100 mL, and not have more than 10 percent of allFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 43 of 145

samples (or any single sample when less than ten sample points exist) obtained for

calcul ating the geometric mean value exceeding 43 colonies/100 mL.

• The recreational uses for this receiving water are identified below.

Table 18 Recreational Uses

Recreational U se Criteria

Primary Contact

Recreation Fecal coliform organism levels must not exceed a geometric mean

value of 14 colonies/100 mL, with not more than 10 percent of all

samples (or any single sample when less than ten sample points exist)

obtained for calculating the geometric mean value exceeding 43

colonies /100 mL.

• The miscellaneous marine water uses are wildlife habitat, harvesting, commerce and

navigation, boating, and aesthetics.

E. Water Q uality I mpairments

Ecology has not documented any water quality impairments in the receiving water in the

vicinity of the outfall.

The St rait of Georgia is listed on the 201 2 Clean Water Act 303(d) list. It is listed for two

pollutants found in the sediments near the outfalls: phenol and 1, 2 ,4

- Trichlorobenzene.

Both of these pollutants are listed in Category 2 whic h indicates that there is evidence of a

water quality problem, but not enough to require production of a Water Quality Improvement

Project at this time. Based on this ranking, the water/sediment in the receiving water will

continue to be tested in future water quality assessments. In addition, the sediments

surrounding Outfalls 001 and 002 will be required to be sam pled during this permit cycle.

F. Evaluation of Surface Water Quality

- Based Effluent Limits for Numeric C riteria

Pollutants in an effluent may affect the aquatic environment near the point of discharge

(near

- field) or at a considerable distance from the point of discharge (far

- field). Toxic

pollutants, for example, are near

- field pollutants ; their adverse effects diminish rapidly with

mixing in the receiving water. Conversely, a pollutant such as biological oxygen demand

(BOD) is a far

- field pollutant whose adverse effect occurs away from the discharge even

after dilution has occurred. Thus, the method of calculating surface water quality

- base d

effluent limits varies with the point at which the pollutant has its maximum effect.

With technology

- based controls (AKART), predicted pollutant concentrations in the

discharge exceed water quality criteria. Ecology therefore authorizes a mixing zone in

accordance with the geometric configuration, flow restriction, and other restrictions imposed

on mixing zones by chapter 173

- 201A WAC.

The diffuser at Outfall 001 is approximately 120 feet long with a diameter of 24 inches. The

diffuser has a total of 12

, 6

- inch diameter ports. The distance between ports is 8.63 feet on

average . The diffuser depth is assumed to be 6.6 feet above the sea floor

. The mean lower

low water (MLLW) depth is 15.5 feet. Ecology obtained this information from the Dilution

Ratio Study Report submitted on August 7, 2006

.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 44 of 145

30 inch HDPE Outfall Pipe Plan View

Side View

- 8.9 ft MLLW 21.6 ft 0 ft MLLW Acute Mixing Zone

Boundary 432 ft

Chronic Mixing

Zone Boundary

2 1

. 6 ft 2 16 ft 2 16 ft The discharge for Outfall 002 extends 250 feet from the shoreline. The open

- ended pipe is

30 inches in diameter. The pipe is 1.25 feet above the s ea floor. The mean lower low water

(MLLW) depth is 9.1 feet. Ecology obtained this information from the Dilution Ratio Study

Report submitted on August 7, 2006

.

The figures below are mixing zone diagrams for both outfalls.

Figure 3 Outfall 001Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 45 of 145

207 ft

24 inch HDPE Outfall Pipe w/ open end port Plan View

Chronic Mixing Zone

Boundary

Side View

- 7.9 ft MLLW 20.7 ft

0 ft MLLW Acute Mixing

Zone Boundary

C hronic Mixing Zone

-- WAC 173

- 201A

- 400(7)(b) specifies that mixing zones must not

extend in any horizontal direction from the discharge ports for a distance greater than 200

feet plus the depth of water over the discharg e ports and may not occupy more than 25% of

the width of the water b ody as measured during MLLW.

The horizontal distance of the chronic mixing zone is 21 6 feet for Outfall 001 and 20 7 feet

for Outfall 002 . The mixing zone extends from the top of the disc harge ports to the water

surface.

Acute Mixing Zone

-- WAC 173

- 201A

- 400(8)(b) specifies that in estuarine waters a zone

where acute criteria may be exceeded must not extend beyond 10% of the distance

established for the chronic zone. The acute mixing zone f or Outfall 001 extends 21.6 feet in

any direction from any discharge port

. The acute mixing zone for Outfall 002 extends 20.7

feet in any direction from any discharge port.

Ecology determined the dilution factors that occur within these zones at the critical condition

using the information provided in both the “ Outfalls 001 and 002 Dilution Ratio Study ”

submitted in August 2011 and the previous “ Outfalls 0 01 and 002 Dilution Ratio Study”

submitted in November 2006

. Ecology reviewe d the updated study submitted in August

2011 and modeled the effluents using the information provided in the 2006 and 2011 reports.

The dilution factors included in the proposed permit and used in the reasonable potential

Figure 4 Outfall 002Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 4 6 of 145

analysis are those obtained from Ecology ’s modeling efforts using the data provided by

Intalco. The dilution factors are listed below.

Table 19 Dilution Factors for Outfall 001

Criteria Acute Chronic

Aquatic Life 21 52

Human Health, Carcinogen 105

Human Health, Non

- carcinogen 77

Table 20 Dilution Factors for Outfall 002

Criteria Acute Chronic

Aquatic Life 19 33

Human Health, Carcinogen 48

Human Health, Non

- carcinogen 48

Ecology used the dilution factors in the above tables to determine the potential impacts of

pH, ammonia, metals, other toxics , and temperature of the effluent on the receiving water, as

described below

. The results of this analysis determine whether a water quality

- based limit

is required for any of the polluta nts. T he derivation of water quality

- based limits takes into

account the variability of pollutant concentrations in both the eff luent and the receiving

water.

pH

-- Compliance with the technology

- based limits of 6.0 to 9.0 will assure compliance with

the wa ter quality standards of surface waters because of the high buffering capacity of marine

water

.

Turbidit y

-- In accordance with Ecology’s Permit Writers Manual , control of particulates as

TSS in an effluent usually results in low turbidity. The draft permit contains a technology

based TSS limit which results in a small amount of TSS loading compared to the large

amount of dilution occurring in the receiving water at critical conditions. The technology

based limits are considered to be protective of the turb idity cr iteria in the receiving water.

Toxic Pollutants

-- Federal regulations (40 CFR 122.44) require Ecology to place a water

quality

- based limit in an NPDES permit for any toxic chemical in an effluent when there is a

reasonable potential for th at chemica l to cause the receiving water body to exceed the surface

water quality criteria. Ecology does not exempt facilities with technology

- based effluent

limits from meeting the surface water quality standards.

The following toxic pollutants are present in the discharge: ammonia, heavy metals, cyanide,

phenols, and polycyclic aromatic hydrocarbons (PAHs) . Ecology conducted a reasonableFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 47 of 145

potential analysis (See Appendix E ) on these parameters to determine whether water quality

based effluent limits would be required in th e proposed permit.

Ammonia's toxicity depends on that portion which is available in the unionized form. The

amount of unionized ammonia depends on the temperature, pH, and salinity of the receiving

marine water. To evaluate ammoni a toxicity, Ecology used the available receiving water

information for ambient station GRG002 and Ecology spreadsheet tools.

Valid ambient background data w ere available for ammonia, aluminum, cadmium, copper,

lead, mercury, and zinc (See Table 2 ). Ecolog y used all applicable data to evaluate

reasonable potential for this discharge to cause a violation of water quality standards.

Ecology determined that all of the pollutants pose no reasonable potential to exceed the water

quality criteria at the critical condition using procedures given in EPA, 1991 ( Appendix E )

and as described above. Ecology’s determination assumes that this facility meets the other

effluent limits of this permit.

Temperature

-- The state temperature standards (WAC 173

- 201A

- 210 and

- 612) for marine

discharges include multiple elements:

• One day maximum temperature criteria

• Incremental warming restrictions

• Protections against acute effects

Ecology evaluates each criterion independently to determine reasonable pote ntial and derive

permit limits.

• One day maximum temperature criteria

Each water body has an annual maximum temperature criterion [WAC 173

- 201A

- 210(1)(c),

and Table 6 12 ]. These threshold criteria (e.g., 1 3 , 16, 1 9 , 2 2 °C) protect specific categories of

aquatic life by controlling the effect of human actions on summer temperatures.

The threshold criteria apply at the edge of the chronic mixing zone. Criteria for marine

waters and some fresh waters are expressed as the highest 1

- Day annual maximum

temperature (1

- DMax).

• Incremental w arming criteria

The water quality standards limit the amount of warming human sources can cause under

specific situations [WAC 173

- 201A

- 210(1)(c)(i)

- (ii)]. The incremental warming criteria

apply at the edge of the chronic mixing zone.

At locations and tim es when background temperatures are cooler than the assigned threshold

criterion, point sources are permitted to warm the water by only a defined increment. These

increments are permitted only to the extent doing so does not cause temperatures to exceed

e ither the annual maximum or supplemental spawning criteria.

At locations and times when a threshold criterion is being exceeded due to natural conditions,

all human sources, considered cumulatively, must not warm the water more than 0.3°C abov e

the natural ly warm condition.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 48 of 145

When Ecology has not yet completed a TMDL for a water body that is warmer than the

threshold criterion , our policy allows each point source to warm water at the edge of the

chronic mixing zone by 0.3°C. This is true regardless of the ba ckground temperature and

even if doing so would cause the temperature at the edge of a standard mixing zone to exceed

the numeric threshold criteria. Allowing a 0.3°C warming for each point source is reasonable

and protective where the dilution factor is based on 25% or less of the critical flow. This is

because the fully mixed effect on temperature will only be a fraction of the 0.3°C cumulative

allowance (0.075°C or less) for all human sources combined.

• Protections for temperature acute effects

Instanta neous lethality to passing fish: The upper 99 th percentile daily maximum effluent

temperature must not exceed 33°C

, unless a dilution analysis indicates ambient temperatures

will not exceed 33°C two seconds after discharge.

General lethality and migration blockage: Measurable (0.3°C) increases in temperature at the

edge of a chronic mixing zone are not allowed when the receiving water temperature exceeds

either a 1DMax of 23°C or a 7DADMax of 22°C.

Lethality to incubating fish: Human actions must not cau se a measurable (0.3°C) warming

above 17.5°C at locati ons where eggs are incubating.

Reasonable Potential A nalysis

Annual summer maximum, supplementary spawning criterion , and incremental

warming criteria : Ecology calculated the reasonable potential for t he discharge to exceed

the annual summer maximum, the supplementary spawning criterion , and the incremental

warming criteria at the edge of the chronic mixing zone during critical conditions (See

temperature spreadsheets in Appendix E ).

The discharge is on ly allowed to warm the water by a defined increment when the

background (ambient) temperature is cooler or warmer than the assigned threshold criterion.

Ecology allows warming increments only when they do not cause temperatures to exceed

either the annual maximum or supplemental spawning criteria.

The incremental increase for the Outfall 001 discharge is within the allowable amount.

Therefore, the proposed permit does not include a temperature limit.

Outfall 002 only discharges treated stormwat er. Ecology has determined temperature is not a

significant stormwater pollutant parameter. Therefore, the proposed permit does not i nclude

a temperature limit and does not require the facility to monitor temperature in the stormwater

discharges. Ecology may elect to develop procedures and guidance for regulating the effects

of stormwater to comply with temperature water quality criteria in the future.

G. Human H ealth

Washington’s water quality standards include 91 numeric human health

- based criteria that

Eco logy must consider when writing NPDES permits. These criteria were established in

1992 by the U.S. EPA in its National Toxics Rule (40 CFR 131.36). The National Toxics

Rule allows states to use mixing zones to evaluate whether discharges comply with huma n

health criteria.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 49 of 145

Ecology determined the effluent may contain chemicals of concern for human health, based

on data or information indicating the discharge contains regulated chemicals

.

Ecology evaluated the discharge's potential to violate the water quali ty standards as required

by 40 CFR 122.44(d) by following the procedures published in the Technical Support

Document for Water Quality

- Based Toxics Control (EPA/505/2

- 90

- 001) and Ecology's

Permit Writer's Manual to make a reasonable potential determination. The evaluation

showed that the discharge has no reasonable potential to cause a violation of water quality

standards, except as discussed below, and an effluent limit is not needed.

Arsenic

- - In 1992 the EPA adopted risk

- based arsenic criteria for the protection of human

health for the State of Washington. The criterion for marine waters is 0.14 μg/L inorganic

arsenic, and is based on exposure from fish and shellfish tissue ingestion. The freshwater

crit erion is 0.018 μ g/L, and is based on exposure from fish and shellfish tissue and water

ingestion. These criteria have caused confusion in implementation because they differ from

the drinking water maximum contaminant level (MCL) of 10 μg/L, which is not r isk

- based,

and because the human health criteria are sometimes exceeded by natural background

concentrations of arsenic in surface water and ground water.

In Washington, when a natural background concentration exceeds the criterion, the natural

background concentration becomes the criterion, and no dilution zone is allowed. This could

result in a situation where natural groundwater or surface water used as a municipal or

industrial source

- water would need additional treatment to meet numeric effluent limit s even

though no arsenic was added as waste. Although this is not the case for all dischargers, we

do not have data at this time to quantify the extent of the problem.

A regulatory mechanism to deal with the issues associated with natural background

conce ntrations of arsenic in groundwater

- derived drinking waters is currently lacking.

Consequently, the Water Quality Program, at this time, has decided to use a three

- pronged

strategy to address the issues associated with the arsenic criteria. The three str ategy elements

are:

1. Pursue, at the national level, a solution to the regulatory issue of groundwater

sources with high arsenic concentrations causing municipal treatment plant effluent

to exceed criteria. The revision of the drinking water MCL for ars enic offered a national

opportunity to discuss how drinking water sources can affect NPDES wastewater

dischargers, however Ecology was unsuccessful in focusing the discussion on developing

a national policy for arsenic regulation that acknowledges the risk s and costs associated

with management of the public exposure to natural background concentrations of arsenic

through water sources. The current arsenic MCL of 10 μg/L could also result in

municipal treatment plants being unable to meet criteria

- based eff luent limits. Ecology

will continue to pursue this issue as opportunity arises.

2. Additional and more focused data collection . The Water Quality Program will in

some cases require additional and more focused arsenic data collection, will encourage or

r equire dischargers to test for source water arsenic concentrations, and will pursue

development of a proposal to have Ecology's Environmental Assessment Program

conduct drinking water source monitoring as well as some additional ambient monitoringFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 50 of 145

data. A t this time, Washington NPDES permits will contain numeric effluent limits for

arsenic based only on treatment technology and aquatic life protection as appropriate.

3. Data sharing

. Ecology will share data with EPA as they work to develop new risk

based criteria for arsenic and as they develop a strategy to regulate arsenic.

The proposed permit add s total arsenic as one of the parameters to monitor in the PUD

intake water. Total arsenic has been added to the grab sample that is required to be

collected t wice per year.

H. Sediment Q uality

The aquatic sediment standards (chapter 173

- 204 WAC) protect aquatic biota and human

health. Under these standards Ecology may require a facility to evaluate the potential for its

discharge to cause a violation of sediment standards (WAC 173

- 204

- 400). A d ditional

information can be obtained about sediments at the Aquatic Lands Cleanup Unit website.

http://www.ecy.wa.gov /programs/tcp/smu/sediment.html

The existing permit require d the facility to submit a Sediment Sampling and Analysis Plan to

re characteriz e the sediment in the vicinity of Outfalls 001 and 002. This plan was submitted

and is currently being reviewed by Ecology. The proposed permit requires that the facility

conduct sediment sampling during the next stable period (mid

- August through mid

Sep tember) following E cology’s approval of the plan.

In addition to the sediment quality in the vicinity of the outfalls, c oncerns have been raised

about spillage of alumina ore during ship unloading and possible accumulation in sediments

around Intalco’s mar ine terminal. To address this concern, Intalco has implemented best

management practices (BMPs) including upgrading and maintaining the integrity of the seal

on the clamshell and o perating the clamshe l l in way that minimize s the fugitive emissions to

redu ce the amount of fugitive alumina released during unloading activities. Some of these

BMPs have been incorpora ted into the proposed permit. Ecology has also issued an order to

Intalco requiring them to evaluate the impact of historical fugitive alumina e missions on

local benthic communities. The results of the evaluation will be used to assist in the

development of the fugitive alumina pollution prevention plan discussed in Section V.I

below, as well as identify whether there are any significant impacts to benthic communities.

If any significant impacts are identified, Intalco is required to propose actions address those

impacts

.

I. Groundwater Quality L imits

The groundwater quality standards (chapter 173

- 200 WAC) protect beneficial uses of

groundwater

. Permits issued by Ecology must not allow violations of tho se standards (WAC

173

- 200

- 100).

Intalco does not directly discharge wastewater to the ground. No permit limits are required

to protect the ground water at this time. T here are two wastewater trea tment ponds at the

Intalco facility: the stormwater treatment pond and the sanitary lagoon. The stormwater pond

is lined with a PVC liner. The sanitary lagoon consists of an unlined native clay bottom that

could potentia lly discharge to ground water.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 51 of 145

The PVC liner associated with the stormwater pond should prevent leakage from the pond to

the groundwater. But t here is no data available to determine if there is a potential to impact

ground water beneath the sanitary lagoon. As a result, Intalco was requir ed to submit a

ground water impact study plan to Ecology for review and approval during the previous

permit cycle. The plan was submitted in February 2010 and is being reviewed by Ecology.

The proposed permit requires that the facility conduct the study w ithin 180 days of Ecology’s

approval of the plan. The results of the study will be used to determine whether monitoring

wells will need to be installed to determine if there are any actual effects on the ground

water.

J. Whole Effluent T oxicity

The water quality standards for surface waters forbid discharge of effluent that has the

potential to cause toxic effects in the receiving waters. Many toxic pollutants cannot be

measured by commonly available detection methods and some polluta nts may be toxic when

an organism is exposed to them in conjunction with other pollutants in the same wastewater

stream

. L aboratory tests have been developed to measure effluent toxicity directly by

exposing living organisms to the wastewater and measuring their responses. T hese tests

measure the aggregate toxicity of the whole effluent, so this approach is called whole effluent

toxicity (WET) testing. Some WET tests measure acute toxicity and other WET tests

measure chronic toxicity.

• Acute toxicity tests measure mortality a s the significant response to the toxicity of the

effluent. Dischargers who monitor their wastewater with acute toxicity tests find early

indications of any potential lethal effect of the effluent on organisms in the receiving

water.

• Chronic toxicity tests measure various sublethal toxic responses , such as reduced growth

or reproduction. Chronic toxicity tests often involve either a complete life cycle test on

an organism with an extremely short life cycle, or a partial life cycle test during a critical

s tage of a test organism's life. Some chronic toxicity tests also measure organism

survival.

Laboratories accredited by Ecology for WET testing know how to use the proper WET

testing protocols, fulfill the data requirements, and submit results in the corre ct reporting

format. Accredited laboratory staff know about WET testing and how to calculate an NOEC,

LC50, EC50, IC25, etc. Ecology gives all accredited labs the most recent version of Ecology

Publication No. WQ

- R

- 95

- 80, Laboratory Guidance and Whole Ef fluent Toxicity Test

Review Criteria (https://fortress.wa.gov/ecy/publications/SummaryPages/9580.html), which

is referenced in the permit. Ecology recommends that Intalco send a copy of the acute or

chronic toxicity section(s) of its NPDES permit to the l aboratory.

The existing permit does not contain WET limits for Outfall s 001 and 002

. In May 1999, the

stormwater discharge from Outfall 002 failed the acute and chronic toxicity testing required

by the permit at that time. The discharge also failed additional subsequent testing which

triggered the submittal of a Toxicity Identification/Reduction Evaluation (TI/RE) Plan to

Ecology for review and approval. The res ults of Intalco’s Toxicity Identification Evaluation

identified aluminum as the source of toxicity with complicating factors resulting from theFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 52 of 145

presence of fluoride. As a result, Intalco ultimately proposed to divert the stormwater flow

from Outfall 002 t o Outfall 001. This diversion was completed in February 2009

. The

existing permit removed the acute and chronic WET limits for Outfall 002 once the diversion

was operational under the assumption that discharges from Outfall 002 would be infrequent.

The permit also required that Intalco characterize the new discharge from Outfall 001 with

the additional stormwater flow to demonstrate that acute or chronic toxicity did not increa se

in the effluent.

The following sections discuss the results of the combined Outfall 001 WET testing and the

effect of the diversion structure on discharges from Outfall 002.

Outfall 001

The existing permit required Intalco to perform WET testing to characterize the new

discharge that resulted from combining the stormwater from Outfall 002 with the process

wastewater discharges at Outfall 001. The results of this c haracterization showed no

reasonable potential for the combined discharge to cause receiving water acute toxicity or

chronic toxicity (see Appendix F )

. Based on these results, no limits for acute toxicity or

chronic toxicity were established for Outfall 001.

Since there were no WET limits established for Outfall 001, t he existing permit required that

the facility test t he discharge for acute and chronic toxicity once in the last summer and once

in the last winter of the permit term. The results of those WET tests were submitted with the

permit renewal applica tion and are summarized below.

Acute Toxicity

The performance standard for acute toxicity is a median of at least 80% survival in 100%

effluent with no single test showing less than 65% survival in 100% effluent. The acute

WET test results in Table 2 3 provide the percent survival of the testing organ ism in 100%

effluent. All of the survival rates are greater than 80%; therefore, the proposed permit will

not include an acute WET limit for Outfall 001

.

Table 21 Outfall 001 2010 Acute WET Test Results (Percent survival in 100% effluent)

Sample Date Organism Endpoint Percent Survival

08/30/10 Rainbow Trout 96

- Hour Survival 100

08/30/10 Daphnid 48

- Hour Survival 100

10/18/10 Rainbow Trout 96

- Hour Survival 100

10/18/10 Daphnid 48

- Hour Survival 100

12/14/10 Rainbow Trout 96

- Hour Survival 100

12/14/10 Daphnid 48

- Hour Survival 100Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 53 of 145

Chronic Toxicity

The performance standard for chronic toxicity is no toxicity in a concentration of effluent

representing the edge of the acute mixing zone. Based on the mixing zone analysis su bmitted

in November 2006, the acute critical effluent concentration (ACEC) for combined Outfall

001 was predicted to be 3

. 8 % and the chronic critical effluent concentration (CCEC) was

predicted to be 2.5 %. The chronic WET tests were performed using multip le effluent

concentrations (0%, 2.5%, 3.8 %, 10 %, 30 %, and 59.9% for the echinoderms and 0%, 2.5%,

3.8%, 25%, 50%, and 100% for the other species) . Table 2 4 shows the effluent concentration

that had no observable effects (NOEC) on the test species and the lowest effluent

concentration that did show an observable effect on the test species (LOEC).

Table 22 Outfall 001 Chronic Bioassay Results (Reported as Percent Effluent)

Sample Date Organism Endpoint NOEC LOEC

09/13/10 Mysid Shrimp 7

- day Survival 30 100

Biomass 30 100

Weight 30 100

09/13/10 Pacific

Topsmelt 7

- day Survival 100 >100

Biomass 100 >100

Weight 100 >100

09/15/10 Echinoderm Development 59.5 >59.5

Survival 59.5 >59.5

10/18/10 Mysid Shrimp 7

- day Survival 30 100

Biomass 10 30

Weight 30 100

10/18/10 Inland

Silverside 7

- day Survival 100 >100

Biomass 100 >100

Weight 100 >100

10/18/10 Echinoderm Development <2.5 2.5Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 54 of 145

Sample Date Organism Endpoint NOEC LOEC

Survival 61.3 >61.3

12/13/10 Mysid Shrimp 7

- day Survival 100 >100

Biomass a a

Weight a a

12/13/10 Pacific

Topsmelt 7

- day Survival 100 >100

Biomass 100 >100

Weight 100 >100

12/15/10 Echinoderm Development 30 59.9

Survival 59.9 >59.9

a. Test produced anomalous results.

As seen in T able 22 , t he toxicity results from the echinoderm test in October 2010 and the

m ysid s hrimp test in December 2010 failed to meet the whole effluent toxicity performance

standards described above or the results were anomalous and it appears that chronic toxicity

may have increased. Therefore, under WAC 173

- 205

- 060, Intalco must repeat the chronic

effluent characterization for the combined discharge at Outfall 001.

The new characterization will be required to be conducted with the ACEC and CCEC derived

f rom the new dilution factors as discussed in Section III.F

.

O utfall 002

Historically , WET testing of the discharge from Outfall 002 has shown a reasonable potential

for both acute and chronic toxicity. However, monitoring to demonstrate compliance with

th e acute and chronic WET limits was not required once the diversion to Outfall 001 was

complete based on the assumption that discharges from Outfall 002 would be infrequent (i.e.

less than once per year). Looking at flow data during the last permit cycle, Intalco

discharged stormwater 76 times since May 2009 from Outfall 002, with an average of

approximately 17 discharges per year. The average flow rate for these discharges was

approximately 0.55 MGD with a maximum daily discharge of 4.2 MGD. While this i s a

significant reduction in the amount of stormwater that is being discharged from Outfall 002,

there are still a number of substanti al discharge events each year.

In addition to installing the diversion structure, Intalco has also improved their housekee ping

best management practices (BMPs) to reduce the pollutant loading in the stormwater.

Because stormwater is being discharged more frequently than anticipated at Outfall 002 and

there have been other changes in stormwater management at the site, the pro posed permitFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 55 of 145

requir es Intalco to re

- characterize the discharge from Outfall 002 to determine whether WET

limits are necessary. The re

- characterization will be required to be conducted with the

ACEC and CCEC derived from the new dilution facto rs discussed in Section III.F.

K. Conditionally Authorized Non

- Stormwater Discharges and Non

- Routine

Occasionally, Intalco may generate wastewater which was not characterized in the permit

application because it is not a routine discharge and was not anticipated at the time of

application. Permit Condition S 8 of the proposed permit authorizes non

- routine and

unanticipated di scharges from Outfall 001 and non

- stormwater discharges to the stormwater

treatment pond under certain conditions. The facility must characterize these waste waters

for pollutants and examine the opportunities for reuse. Intalco must request prior approv al

for these discharges, and

, depending on the nature and extent of pollutants in th e wastewater

and the opportunities for reuse, Ecology may:

• Authorize the facility to discharge the wastewater.

• Require the facility to treat the wastewater.

• Require the facility to reuse the wastewater.

L. Comparison of Effluent L imits with the E xisting P ermit I ssued i n March 2007

Table 23 Comparison of Existing and Proposed Effluent Limits for Outfall 001

Previous Effluent Limits:

Outfall # 001 Proposed Effluent Limits:

Outfall # 001

Parameter Basis of

Limit Average

Monthly Daily

Maximum Average

Monthly Daily

Maximum

Total

Suspended

Solids (TSS) Technology 150 185 150 185

Fluoride Technology 58/68/68 140/198/296 58/68/68 140/198/296

Aluminum Technology 5.9/9.0/10.3 13.4/20/30 5.9/9.0/10.3 13.4/20/30

Free Cyanide Water

Quality <0.012 0.012 <0.01 2 0.01 2

Benzo(a)

-

Pyrene Technology 0.02/0.03/

0.045 0.043/0.065/

0.098 0.02/0.03/

0.045 0.043/0.065/

0.098

Antimony Technology 1.9/2.9/4.3 4.2/6.4/9.6 1.9/2.9/4.3 4.2/6.4/9.6

Nickel Technology 0.8/1.2/1.9 1.2/1.8/2.7 0.8/1.2/1.9 1.2/1.8/2.7

Oil and

Grease Water

Quality 5 10 5 10

Parameter Basis of Limit Previous Limit Proposed Limit

pH Technology 6.0 to 9.0 6.0 to 9.0Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 56 of 145

Table 24 Comparison of Existing and Proposed Effluent Limits for Outfall 002

Previous Effluent

Limits: Outfall # 002 Proposed Effluent

Limits: Outfall # 002

Parameter Basis of Limit Average

Monthly Maximum

Daily Average

Monthly Maximum

Daily

TSS Technology 35 75 35 75

Fluoride Technology 35 50 35 50

Aluminum Technology 10 15 10 15

Benzo(a)Pyrene Technology <0.01 <0.01

Oil and Grease Technology 5 10 5 10

Parameter Basis of Limit Previous Limit Proposed Limit

pH Technology 6.0 to 9.0 6.0 to 9.0

Table 25 Comparison of Existing and Proposed Effluent Limits for Sanitary Lagoon

Discharges

Previous Effluent

Limits: Sanitary

Lagoon Proposed Effluent

Limits: Sanitary

Lagoon

Parameter Basis of

Limit 30

- Day

Average 7

- Day

Average 30

- Day

Average 7

- Day

Average

Biochemical

Oxygen Demand (5

- day BOD) Technology 45 65 45 65

TSS Technology 45 65 45 65

Minimum Number

of Operating UV

Tubes Technology 12 12

Minimum %

removal of BOD

and TSS Technology 65% 65%Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 57 of 145

Previous Effluent Limits:

Sanitary Lagoon Proposed Effluent

Limits: Sanitary Lagoon

Parameter Basis of

Limit Monthly

Geometric

Mean Limit Weekly

Geometric

Mean Limit Monthly

Geometric

Mean

Limit Weekly

Geometric

Mean Limit

Fecal Coliform

Bacteria Technology 200

organisms/

100 ml 400

organisms/

100 ml 200

organisms/

100 ml 400

organisms/

100 ml

Parameter Basis of Limit Previous Limit Proposed Limit

pH Technology 6.0 to 9.0 6.0 to 9.0



### IV. Monitoring Requirements

Ecology requires monitoring, recording, and reporting (WAC 173

- 220

- 210 and 40 CFR 122.41)

to verify that the treatment process is functioning correctly and that the discharge complies with

the permit’s effluent limits.

If a facility uses a contract laboratory to m onitor wastewater, it must ensure that the laboratory

uses the methods and meets or exceeds the method detection levels required by the permit. The

permit describes when facilities may use alternative methods. It also describes what to do in

certain situ ations when the laboratory encounters matrix effects. When a facility uses an

alternative method as allowed by the permit, it must report the test method, DL, and QL on the

discharge monitoring report or in the required report.

A. Wastewater M onitoring

Monitoring is the primary means of ensuring that the permit limitations are met and

demonstrating that the characteristics of the wastewater stream have not changed

significantly. Chapter XIII of Ecology’s Permit Writer’s Manual provides a detailed

discus sion of monitoring guidelines that permit writer’s use to establish monito ring schedules

for a facility. The monitoring schedule for Intalco is specified in Special Condition S2 of the

proposed permit. Specified monitoring frequencies take into account t he quantity and

variability of the discharge, the treatment method, past compliance, significance of

pollutants, and cost of monitoring. Intalco has a number of monitoring points and the figure

below has been provided to show a simplified diagram of the w astewater streams, outfalls,

and monitoring points.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 58 of 145

Figure 5 Simplified diagram of wastewater streams, outfalls, and monitoring points for

Outfalls 001 and 002Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 59 of 145

Outfalls 001 and 002

Section 1.3.3 of Chapter XIII of Ecology’s Permit Writer’s Manual allows for a reduction in

monitoring frequency for exemplary performance. Reduction of monitoring frequency is

generally granted at the time of a permit renewal by examination of performanc e in the two

years preceding renewal. The amount of reduction is dependent upon the ratio of

performance for the last two years to the monthly average effluent limitation, as specified in

Table XIII

- 1A1. The monitoring frequency was reduced during the la st permit renewal for

B(a)P, antimony, nickel, copper, cyanide, and oil and grease at Outfall 001 and for copper,

cyanide, B(a)P, and oil and grease at Outfall 002. These reductions were implemented based

on reviews of historical monitoring data and the f act that the sources of the respective

pollutants had either been elimin ated or were being controlled.

In February 2009, the facility completed a diversion project to divert stormwater from Outfall

002 to Outfall 001. The combined flow of the treated proc ess wastewater and stormwater at

Outfall 001 was sampled and analyzed to demonstrate compliance with permit limits.

Stormwater allocations were used to account for pollutants introduced by the stormwater

stream. The additional stormwater flow made it dif ficult to determine if the monitoring

results for the process wastewater showed exemplary performance during the past two years.

Therefore, the monitoring frequency in the proposed permit is the same as the existing

permit. The Permittee is installing an additional monitoring point to sample the process

wastewater before c ombining with stormwater. The P ermittee may request a reduced

monitoring frequency after monitoring at the new location for at least 12 months, as specified

in the Permit Condition S2.E o f the proposed permit.

The monitoring frequency for Outfall 002 will be once per discharge event, with no more

than 3 samples required per week. Wastewater is only discharged from Outfall 002 when the

hydraulic capacity of the diversion structure or the Outfall 001 outlet pipe has been exceeded.

Samples collected from the diversion structure (monitoring point D

- 10) will be considered

representativ e of the water being discharged from Outfall 002. A footnote has been added to

the table in S2.A.1 to state that samples collected from monitoring point D

- 10 to demonstrate

compliance with the stormwater pond action levels can be used to satisfy the Outfa ll 002

monitoring requirements as long as the sample was collected less than 24 hours prior to the

dischar ge event.

Sanitary Lagoon

As part of the permit renewal process, Ecology reviewed the sampling results from the past

two years at the sanitary lagoon to determ ine if the facility would qualif y for reduced

monitoring for any of the parameters. Table XIII

- 1A1 in Chapter XIII of Ecology’s Permit

Writer’s Manual was used to determine the appropriate monitoring frequencies for the

qualifying parameters. T he table below shows the pollutant, the long term average (LTA)

concentration from the last two years of monitoring, the ratio of the LTA to the average

monthly limit (AML), and the applicable reduced monitoring.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 60 of 145

Table 26 Sanitar y Lagoon Monitoring

Pollutant LTA LTA

AML Allowable

Monitoring

Frequency Recommended

Min.

Monitoring

Frequency for

POTWs <0.1

MGD Existing

Monitoring

Frequency Proposed

Monitoring

Frequency

BOD 5 15.1

mg/L 34% 2/month 1/week 1/week 2/month

TSS 6.0

mg/L 13% 1/ 2 months 1/week 1/week 2/month

Fecal

Coliform 5/100

mL 2.5% 1/ 2 months 1/week 1/week 2/month

The sanitary lagoon for Intalco is not a POTW, but the recommended minimum monitoring

frequency for a similar plant is included in the table above to provide context. Based on the

allowable monitoring frequency and considering the recommended minimum monitoring

frequency for a similar publicly owned treatment works ( POTW ) , the monitoring frequency

for all of the pollutants (BOD5, TSS and fecal colifor m) is proposed to be reduced to twice

per month. The monitoring frequency was reduced based on the fact that the treated sanitary

wastewater is mixed with process wastewater prior to being discharged, unlike a POTW that

would directly discharge to a surfa ce water body. Any exceedance of the monthly average

permit limits will revert the monitoring frequency back to the baseline monitori ng frequency

of once per week.

The facility also requested that the monitoring frequency for the minimum number of

operati ng UV tubes be reduced to once per week. This request was granted in the proposed

permit. The facility consistently report that 14 UV tubes were operating during inspections.

The facility also has an alarm system that will alert them if power is los t to the UV

disinfection system.

Secondary Wastewater Treatment System and Stormwater Pond Action Levels

Ecology established action levels in the existing permit for TSS, fluoride, and aluminum

discharged from the stormwater pond and for TSS and fluoride discharged from the SEC

. These action levels were placed in the permit to ensure that the Permittee is consistently : 1)

implementing the required BMPs des igned to reduce or eliminate the respective pollutants, 2)

evaluating the cause of any upward trends in pollutant discharges, and 3) taking corrective

action to reverse those trends. Ecology determined the action levels in the existing permit by

analy zing the monthly monitoring data submitted in 2003 and 2004

. The tables below show

the number of exceedances of the action levels between April 2007 and October 2013 for the

stormwater treatment pond and the SEC

.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 61 of 145

Table 27 Number of Stormwater Treatment Pond Action Level Exceedance s

Monthly Average Daily Maximum

TSS 11 2 6

Fluoride 4 8

Aluminum 1 5 1 9

Table 28 Number of SEC Action Level Exceedance s

Monthly Average Daily Maximum

TSS 1 12

Fluoride 0 2

The majority of the TSS exceedances at the SEC occurred between May 2011 and October

2012. The facility appears to have addressed this issue and no changes will be made to the

“ action levels ” in the proposed permit

.

The facility has consistently e xceeded the action levels for TSS and aluminum and

occasionally exceeded the action level for fluoride at the stormwater treatment pond.

However, the facility did not exceed any permit limits at Outfall 001 after stormwater was

diverted from Outfall 002

. It appears that the monitoring data used by Ecology to establish

the action levels at the stormwater treatment pond was the monitoring data for Outfall 002.

Outfall 002 is the discharge point for the stormwater pond, but there is also stormwater

collecte d from non

- process areas that is discharged through Outfall 002. The additional

stormwater could have affected the results for Outfall 002 such that the monitoring data may

not have adequately represented the perfo rmance of the stormwater pond.

Ecology ha s noted during multiple inspections that the facility has made great improvements

in their stormwater BMPs during the previous permit cycle and the data collected during that

time period would be representative of good BMPs for the process stormwater collection and

treatment system. Based on the data provided in the DMRs between April 2007 and October

2013 for the stormwater treatment pond, the facility was able to meet the following discharge

concentrations 90% of the time : 35 mg/L for TSS, 37 mg/L for fluoride, and 13 mg/L for

aluminum. Finally, Ecology notes that the previous monthly average permit limits for

Outfall 002 were 35 mg/l for TSS, 35 mg/l for fluor ide, and 10 mg/l for aluminum.

With these considerations in mi nd, Ecology increased the action levels for the stormwater

pond in the proposed permit. The new action levels for the SEC effluent and the stormwater

pond effluent are as follows:Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 62 of 145

Table 29 Action Levels

TSS Fluoride Aluminum

S econdary Wastewater

Treatment System 120 mg/l 5 0 mg/l N/A

Stormwater Pond 35 mg/l 35 mg/l 10 mg/l

The existing permit requires the P ermittee to monitor the SEC three times per week for TSS

and fluoride. As discussed above, S ection 1.3 of Chapter XIII of Ecology’s Permit Writer’s

Manual allows for reduced monitoring based on exemplary performance. This is usually

demonstrated by comparing the long term monthly average effluent concentration to the

monthly average limit. In t his instance, the long term daily maximum average was compared

to the action level. The long term daily maximum average for TSS is approximately 61% of

the action level and the long term daily maximum average for fluoride is 58% of the action

level. Ther efore, Ecology reduced the monitoring frequency from 3 times per week to 2

times per week for the SEC . The proposed permit also specifies that the 24

- hour sample will

be a flow proportional batch sample based on a request from the facility.

The existing p ermit specifies that the Permittee monitor for PCBs in the SEC discharge after

the material from the Beach and Construction Landfills were moved to the SPL Landfill.

The permit also allowed the Permittee to petition the Department to reduce or eliminate t he

monitoring after two years of testing. The facility has monitored for PCBs since April 2007

and has not detected PCBs in the effluent. Therefore, the monitoring frequency in the

proposed permit has been reduced fr om quarterly to semi

- annually.

The Per mittee has requested to remove the monitoring requirement for aluminum in the SEC

d ischarge . They stated that the levels of aluminum that have been discharged from the SEC

have been consistently low and they requested that Ecology review the data to deter mine if

the monitoring could be eliminated. Based on the DMRs for the past 2 years, the average

aluminum concentration in the SEC discharge was 0.1 mg/L and the maximum concentration

was 1.5 mg/L. At an average flow of 0.1 MGD from the SEC during the sam e time period,

the aluminum loading contribution is approximately 0.08 lbs/day, which is less than 1% of

the monthly loading limit for aluminum at Outfall 001. Ecology also notes that there are no

action levels for aluminum in the SEC effluent. Therefore , Ecology concurs that monitoring

for aluminum in the SEC effluent is not necessary and it has been removed in the proposed

permit.

The proposed monitoring frequency for the stormwater pond (at D

- 10) will remain the same

as the current permit since the a ction levels have been changed. The P ermittee is required to

monitor the stormwater pond effluent (at D

- 10) whenever the average 2

- hour flow from the

stormwater pond is ≥ 3.7 cfs (with a maximum required frequency of 3 days per week).

Outfalls 003, 004, a nd 005

Outfalls 003, 004, and 005 have been removed from the proposed permit. Please refer to

Section II.A above.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 63 of 145

Outfalls 011 and 012

Outfalls 011 and 012 were newly identified outfalls in the last permit renewal application.

Both of the outfalls are located along the shoreline and are difficult to access. T he facility

proposed to collect samples from the catch basins that discharge to these outfalls. Based on

this request, the existing p ermit requires the facility to collect monthly grab samples from the

catch basin sumps for these outfalls when flow is available. The samples are required to be

analyzed for TSS, aluminum, and fluoride. The intent of this sampling was to determine

whethe r BMPs implemented by the facility would sufficiently reduce the pollutant

concentrations in the discharges. However, Ecology has noted during wastewater inspections

that it is difficult to collect representative samples from these locations and questions

whether the results of the samples collected during the last permit term are representative of

the discharge from the se outfalls.

Based on this uncertainty, a BMP effectiveness study for Outfalls 011 and 012 ha s been

included in the proposed permit. The study requires that the facility identify safe, accessible,

and representative sampling locations for these outfalls. The facility will then be required to

begin routine monitoring at the new locations. The facility will also submit a report that will

in clude an assess ment of the current BMPs and whe ther additional BMPs are necessary for

th e drainage area . Ecology will review the results of the routine monitoring during the next

permit renewal process t o establish action levels in the next permit, if nec essary.

B

. Lab A ccreditation

Ecology requires that facilities must use a laboratory registered or accredited under the

provisions of chapter 173

- 50 WAC, Accreditation of Environmental Laboratories, to prepare

all monitoring data (with the exception of certain parameters). Ecology accredited the

laboratory at this facility for the parameters in Table 3 0 below. Their accreditation number is

I629

- 12.

Table 30 Accredited Parameters

General Chemistry

Parameter Name Analyte Code Method Description NELAC Code Matrix a

Total Suspended

Solids 1960 SM 2540 D

- 97 20051201 N

Fluoride 1730 SM 4500

- F E

- 97 20104409 N

pH 1900 SM 4500

- H+ B

- 00 20105219 N

Specific

Conductance 1610 EPA 120.1_1982 10006403 N

a. N= NonpotableFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 64 of 145

C. Effluent Limits which are Near Detection or Quantitation L evels

The water quality

- based effluent concentration limits for benzo(a)pyrene for Outfall 002 and

free cyanide (WAD) for Outfall 001 are near the limits of current analytical methods to

detect or accurately quantify. The method detection level (MDL) also known as detection

level (DL) is the minimum concentration of a pollutant that a laboratory can measure and

report with a 99 percent confidence that its concentration is greater than zero (as determined

by a specific laboratory method). The quantitation level (QL) is the level at which a

laboratory can reliably report concentrations with a specified level of error. Estimated

concentrations are the values between the DL and the QL. Ecology requires permitt ed

facilities to report estimated concentrations. When reporting maximum daily effluent

concentrations, Ecology requires the facility to report “less than X” where X is the required

detection level if the measured effluent concentration fa lls below the de tection level.



### V. Other Permit Conditions

A. R eporting and Record K eeping

Ecology based Special C ondition S3 on its authority to specify any appropriate reporting and

record keeping requirements to prevent and control waste discharges (WAC 173

- 220

- 210).

Special Condition S3 specifies the reporting requirements for the Permittee and is similar to

the current permit, except that the discharge monitoring reports will be required to be

submitted electronically. The draft permit allows the Permittee to subm it the reports in paper

form until December 31, 2014 to allow them time to implement procedures for submitti ng

the reports electronically.

B. Operation and Maintenance M anual

Ecology requires industries to take all reasonable steps to properly operate and maintain their

wastewater treatment system in accordance with state and federal regulations [40 CFR

122.41(e) and WAC 173

- 220

- 150 ( 1)(g)]. The facility has prepared and submitted an

operation and maintenance manual as required by state regulation for the c onstruction of

wastewater treatment facilities (WAC 173

- 240

- 150). Implementation of the procedures in

the operation and maintenance manual ensures the facility’s compliance with the terms and

limits in the permit. Permit Condition S4.A of the proposed pe rmit requires that the

Permittee review the O&M Manual at least annually and confirm the review by letter to

Ecology. The Permittee must also submit any substantial changes or updates to Ecology for

review.

C. Solid Waste Control P lan

Intalco could cause pollution of the waters of the state through inappropriate disposal of solid

waste or through the release of leachate from solid waste.

Permit Condition S5 of the proposed permit requires this facility to update the ir currently

approved solid waste control plan designed to prevent solid waste from causing pollution of

waters of the state. The facility must submit the updated plan to Ecology for approval (RCWFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 65 of 145

90.48.080). Ecology has a guidance document which describes how to develop a Solid

Waste Control P lan, available at: http://www.ecy.wa.gov/pubs/0710024.pdf

D. Application for Permit Renewal or Modification for Facility C hanges

In accord ance with WAC 173

- 220

- 180, any P ermittee that wishes to continue the permitted

activity after the expiration date of t he permit must submit an application for replacement to

an existing permit or continuation of a discharge beyond the expiration date at least 180 days

prior to its expiration. Permit Condition S6 requires the facility to submit their permit

renewal applic ation no later than six months prior to the expiration date of the permit.

Additionally, WAC 173

- 220

- 150 requires that the P ermittee must submit a new application

or supplement to an existing application at least one hundred eighty (180) days prior to

comm encement of discharges resulting from any facility expansions, production increases, or

other planned changes, such as process modifications, which ma y result in permit violations.

E

. Facility Loading

As discussed in Section III. B above, P ermittees are required to provide AKART for their

wastewater effluent before discharging it to a surface water body. These treatment

technologies must be designed t o provide the required treatment efficiencies. The design

parameters generally include a m aximum loading capacity that the treatment system is able

to handle and still provide the desired treatment efficiency. Permit Condition S7 specifies

certain Ecology approved design criteria that Intalco must not exceed. Permit Condition S2

includes appr opriate monitoring parameters to demonstrate that these design cri teria are not

being exceeded.

F. Non

- Routine and Unanticipated Di scharges

Ecology understands that the facility may occasionally generate wastewater that was not

identified in the permit app lication. Permit Condition S8 allows for the discharge of non

routine and unanticipated discharges of wastewater to Outfall 001 and non

- stormwater

discharges to the stormwater pond as long as certain conditions are met, such as

characterization of the was tewater and whether there are any alternatives to discharging the

wastewater.

G. Spill P lan

This facility stores a quantity of chemicals on

- site that have the potential to cause water

pollution if accidentally released. Ecology can require a facility to d evelop best management

plans to prevent this accidental release [Section 402(a)(1) of the Federal Water Pollution

Control Act (FWPCA) and RCW 90.48.080].

Intalco has developed a plan for preventing the accidental release of pollutants to state waters

and f or minimizing damages if such a spill occurs. Permit Condition S9 of the proposed

permit requires the facility to update this plan and submit it to Ecology.

H. Stormwater Pollution Prevention P lan

Special Condition S10 of the proposed permit address e s t he stormwater pollution prevention

measures required for the facility. Special Condition S10 requires the facility to update their

stormwater pollution prevention plan (SWPPP) in accordance with the guidance documentFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 66 of 145

entitled Guidance Manual for Preparing /Updating a Stormwater Prevention Plan for

Industrial Facilities (Ecology Publication No. 04

- 10

- 030) and to submit the update to

Ecology for approval. The SWPPP must identify potential sources of stormwater

contamination from industrial activities and identify how the Permittee plans to mange those

sources of contamination to prevent or minimize contamination of stormwater. Once the

update is approved, the facility will be required to implement the updated SWPPP. Intalco

must continuously review and revise the SWPPP as necessary to assure that stormwater

discharges do not degrade water quality. They must retain the SWPPP on

- site or within

reasonable a ccess to the site and make it a vailable for review by Ecology.

Special Condition S10 also requires the facility to conduct two inspections per year

– once

during the wet season and once during the dry season. The wet season inspection shall be

conducted during a rainfall event by personnel trained by Intalco in the requirements of the

SWP PP to verify that the description of potential pollutant sources required under this permit

are accurate; that the site map required in the SWPPP has been updated or otherwise

modified to reflect current conditions; and that the controls to reduce pollutan ts in

stormwater discharges associated with industrial activity identified in the SWPPP are being

implemented and are adequate. The dry season inspection shall determine the presence of

unpermitted non

- stormwater discharges such as domestic wastewater, no ncontact cooling

water, or process wastewater (including leachate ) to the stormwater drainage system

.

One of the components of the SWPPP is identifying Best Management Practices (BMPs) for

the stormwater generated at the site. BMPs include both pollution prevention measures as

well as treatment technologies. Treatment BMPs include Best Conventional Pollutant

Control Technology (BCT)

, Best Available Technology Economically Achievable (BAT)

, and “all known, available, and reasonable methods of prevention, c ontrol, and treatment”

(AKART) for stormwater discharges

. Special Condition S10 requires the Permittee to update

the BMPs that are curren tly identified in their SWPPP.

I. Fugitive Alumina Pollution Prevention P lan

Ecology has determined that the Permitt ee must use best management practices in unloading

alumina ore to minimize the release of fugitive alumina to the Strait of Georgia. The

Permittee must submit a pollution prevention plan to Ecology for review and approval within

eighteen months after permit issuance. The pollution prevention plan must identify the

points, areas, and activities that would likely generate fugitive alumina emissions, evaluate

potential measures to minimize the discharge of fugitive alumina, identify the measures

selected and the timeframes for implementation, include a training plan for employees that

operate the equipment used to unload the alumina ore, and include the procedures that will be

used to demonstrate compliance with the pollution prevention plan. The Permitt ee must

implement the pollution prevention plan within 60 days of ap proval of the plan by Ecology.

J. Sediment Monitoring

As discussed in Section III.H above, the existing permit required that the facility submit a

Sediment Sampling and Analysis Plan to re

- characterize the sediment in the vicinity of

Outfalls 001 and 002. This plan was submitted and is currently being reviewed by Ecology.

The proposed permit requires that the facility conduct the sediment sampling during the nextFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 67 of 145

stable period (mid

- August through mid

- September) following Ecology’s approval of the

plan. Once the sa mpling has been conducted, the P ermittee is required to submit a report

containing the results of the sediment sampling and analysis within six months of collecting

the samples. Ecology will review the results and determine if additi onal actions will be

required.

K. Outfall E valuation

The proposed permit requires Intalco to conduct an outfall inspection at least once every five

years and submit a report detailing the findings of that inspection (Special Condition S13).

The inspection must evaluate the physical condition of the discharge pipe and diffusers, and

evaluate the extent of sediment accumulations in the vicinity of the outfall. The inspection

report must be submitted to Ecology no later than 90 days after conducting the evaluation.

The first report is due October 1, 2016.

L. Certified Operator

The existing permit classifies the domestic wastewater treatment plant as a Class I treatment

plant. The facility has not modif ied or upgraded their domestic wastewater treatment plant

and the plant is still a Class I treatment plant. Special Condition S1 4 requires that the facility

must be operated by an operator certified by the state of Washington for at least a Class I

plant. Permit Condition S1 4 has been modified to require that an operator certified for at

least a Class I plant must be in charge during all regularly scheduled shift s, as required by

WAC 173

- 230.

M. Acute Toxicity

Outfall 001

As discussed in Section III.J, an acute toxicity limit is not required for Outfall 001. While no

permit limit has been established, the facility will continue to be required to periodically

monitor the acute toxicity of the effluent. Permit Condition S1 5 .F.1 requires that the facility

c onduct acute toxicity testing on the final effluent once in the last winter and once in the last

summer prior to submission of the application for permit renewal. The species specified for

these tests have been changed to saltwater species in the proposed permit to account for

pacific herring, a sensitive species in the Cherry Point area. More discussion regarding

pacif ic herring is provided below.

Outfall 002

As discussed in Section III.J, Outfall 002 must be re

- characterized for acute toxicity. Permit

Condition S1 5 specifies that the P ermittee conduct quarterly acute toxicity tests on the

effluent for one year. The following acute toxicity tests must be performed for each sample:

1) topsmelt 96

- hour static

- renewal test, and 2) myside 48

- hour static tes t , and 3) daphnid 48

-

hour static test

. Saltwater species are specified for two of the tests to account for pacific

herring, a sensitive species in the Cherry Point Area. Daphnid, a freshwater species, is also

specified due to a potential for acute toxicity that was demonstrated in previous tests. A

quarterly written report must be submitted within 45 days of each sampling event and must

provide the results of the sample analysis. The testing must be performed using a dilution

series consisting of a minimum of five concentrations, including the ACEC of 5.3% effluen t,Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 68 of 145

and a control. The results of the tests must be able to demonstrate that the median survival of

any species in 100% effluent is above 80% and none of tests may exhibit less than 65%

su rvival in 100% effluent. If the test results do not meet these criteria, an effluent limit for

acute toxicity will be established for Outfall 002 and quarterly testing will be required to

demonstrate compliance with the acute toxicity limit. If an acute toxicity effluent is not

required, the P ermittee will be required to conduct acute toxicity testing on the final effluent

once in the last winter and once in the last summer prior to submission of the a pplication for

permit renewal.

Herring Toxicity Testin g

Pacific herring, which spawn in the Cherry Point area, have dramatically declined in

abundance in the last 10

- 15 years and remain at record low levels. Over the years, Ecology

has worked with several stakeholders including other state agencies, area ind ustries, and local

tribes to investigate the Cherry Point herring decline. Ecology worked with the Western

Washington University’s Shannon Point Marine Center (SPMC) to develop herring tests to

evaluate effluent toxicity as a source of the decline and to evaluate risks from industrial

discharges to other herring stocks. As a result of these efforts, SPMC developed three

herring tests, all of which were successfully validated.

In November 2005, Ecology approved the regulatory use of the 96

- hour larval acut e survival

test (acute toxicity) and the 10

- day embryo survival and normal develo pment test (chronic

toxicity).

In April 2006, Ecology issued Agreed Order (No. 3192) to five industries, including Intalco,

requiring them to conduct larval acute survival tes ts twice annually at each of their process

wastewater and stormwater outfalls. Ecology would then review the results of the studies

required under the Order and include validated herring or equivalent EPA surrogate test

requirements in the renewed NPDES p ermit.

Intalco completed the required acute toxicity tests for herring and the results demonstrated

that the currently approved EPA tests are as sensitive to the wastewater effluent for Intalco.

Based on this, the EPA approved acute toxicity testing req uired by the proposed permit is

sufficient to measure if the effluent is acutely toxic to herring. The results of the acute

herring tests conducted by Intalco are included in Appendix F

. A copy of the Ecology report

discussing the results of the study is available on the Ecology website at:

http://www.ecy.wa.gov/programs/wq/wet/index.html.

N

. Chronic Toxicity

Outfall 001

As discussed in Section III.J, Outfall 001 must be re

- characterized for chronic toxicity.

Permit Condition S1 6 .A.1 specifies that the P ermittee must conduct quarterly chronic

toxicity tests on the effluent for one year. The following chronic toxicity tests must be

performed for each sample: 1) mysid shrimp survival and growth, and 2) sea urchin/sand

dollar survival and development. A q uarterly written report must be submitted within 45

days of each sampling event and must provide the results of the sample analysis. The testing

must be performed using a dilution series consisting of a minimum of five concentrations,

including the ACEC o f 4.8% effluent, and a control. The series of dilutions should alsoFact Sheet for NPDES Permit WA 0 002950

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Page 69 of 145

contain the CCEC of 1.9% effluent. The results of the tests must be able to demonstrate that

there is not a significant difference between the control and the ACEC at the 0.05 level of

s ignific ance using hypothesis testing. If the test results do not meet these criteria, an effluent

limit for chronic toxicity will be established for Outfall 001 and quarterly testing will be

required to demonstrate compliance with the chronic toxicity lim it. If a chronic toxicity

effluent is not required, the P ermittee will be required to conduct chronic toxicity testing on

the final effluent once in the last winter and once in the last summer prior to application for

permit renewal.

Outfall 002

As discussed in Section III.J, Outfall 002 must be re

- characterized for chronic toxicity.

Permit Condition S1 6 .A.2 specifies that the P ermittee must conduct quarterly chronic

toxicity tests on the effluent for one year. The chronic toxicity test for Outfall 002 that must

be performed for each sample is the sea urchin/sand dollar survival and development. A

quarterly written report must be submitted for each quarter within 45 days of the sampling

event and must provide the results of the sample analysis. Th e testing must be performed

using a dilution series consisting of a minimum of five concentrations, including the ACEC

of 5.3% effluent, and a control. The series of dilutions should also contain the CCEC of

3.0% effluent. The results of the tests must b e able to demonstrate that there is not a

significant difference between the control and the ACEC at the 0.05 level of significa nce

using hypothesis testing. If the test results do not meet these criteria, an effluent limit for

chronic toxicity will be es tablished for Outfall 002 and quarterly testing will be required to

demonstrate compliance with the chronic toxicity limit. If a chronic toxicity effluent is not

required, the P ermittee will be required to conduct chronic toxicity testing on the final

eff luent once in the last winter and once in the last summer prior to submission of the

application for permit renewal.

Herring Toxicity Testing

As discussed above, Ecology worked with SPMC to develop two chronic herring toxicity

tests. The 10

- day embryo sur vival and normal development test (chronic toxicity) was

approved for regulatory use in November 2005. A 7

- day larval survival and growth test

(chronic toxicity) was validated and approved for re gulatory use in December 2011.

In October 2013, Ecology issu ed Agreed Order No. 10300 to Intalco for the completion of

herring chronic bioassay testing. The basic goal of the testing conducted under this Order is

to determine if existing EPA chronic WET test methods are adequate to determine if

Intalco’s discharge s have unacceptable toxicity to herring. The Order requires the facility to

conduct at least six comparison tests by March 1, 2017. Ecology will then review the results

of these tests and include validated herring or equivalent EPA surrogate test require m ents in

the next NPDES permit.

O

. Secondary Wastewater Treatment System Treatment Efficiency Study

The wastewater from the PWTS and landfill leachate are treated through chemical

precipitation and sedimentation in the SEC

, which consists of several treatment tanks and a

clarifier. As discussed in Sections III.A and III.B, flows or waste loadings to a wastewater

treatment facility must not exceed approved design criteria and the facility must apply allFact Sheet for NPDES Permit WA 0 002950

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known available and re asonable methods of prevention, control, and treatment (AKART) for

the pollutants in the wastewater. Th e existing permit requires the P ermittee to conduct a

treatment efficiency study on the SEC to determine if it is meeting the design criteria and to

pro pose and implement any changes needed to upgrade the system. The facility was first

required to submit a treatment efficiency study plan and schedule to Ecology for review and

approval. This plan was received by Ecology on January 3, 2008. Due to a heav y workload,

Ecology has not yet reviewed or approved this plan. The requirement to conduct the SEC

efficiency study has been included in the proposed permit as Special Condition S1 7 . Since

the plan was submitted about 5 years ago, Ecology is requiring th at the facility review and

update, as necessary, the plan that was previously submitted. This plan must be submitted to

Ecology within six months of permit issuance. Once the plan is approved, the P ermittee is

required to conduct the study and submit the results in an engineering report within 120 da ys

of completing of the study.

P

. Anode Contact Cooling Water AKART Evaluation

Anode contact cooling water is generated during the anode production process. This

wastewater is treated using a baffled settling tank prior to mixing with the other wastewater

streams that are discharged through Outfall 001. As discussed in Section III.B above,

preliminary sampling of the anode contact cooling water indicate that a full AKART analysis

will need to be performed for that particular wastewater stream. Permit Condition S1 8

requires that the P ermittee evaluate whether the current treatment system for the anode

contact cooling water meets AKART requirements for B(a)P, antimony, nickel , aluminum,

and fluoride. The P ermi ttee must provide the results of this AKART analysis, consisting of

an economic analysis, an environmental analysis, and an industry analysis of wastewater

treatment technologies for the anode contact cooling water, in an engineering report no later

than t welve months after permit issuance. The Permittee has communicated to Ecology that

they are evaluating an option that would eliminate the anode contact cooling water discharge

from Outfall 001 . The draft permit includes an alternative to the AKART analys is that

allows the Permittee to submit documentation to demonstrate that the discharge has been

eliminated and an AKAR T evaluation is not necessary.

Q

. Ground Water Impact Study

As discussed in Section III.I above, Ecology has promulgated Ground Water Qual ity

Standards (Chapter 173

- 200 WAC) to protect beneficial uses of ground water. Permits

issued by Ecology shall be conditioned in such a manner so as not to allow violations of

those standards (WAC 173

- 200

- 100).

The sanitary lagoon in Intalco’s wastewater treatment system consists of an unlined native

clay bottom that could potentially discharge to groundwater. There is no data available to

determine if there is a potential for an impact to ground water beneath the sanitary lagoon.

Intalco was required t o submit a ground water impact study plan to Ecology for review and

approval during the previous permit cycle. The plan was submitted in February 2010 and is

being reviewed by Ecology. Permit Condition S 19 of the proposed permit requires that the

facilit y conduct the study within 180 days of Ecolog y’s approval of the plan. The P ermittee

is then required to submit a report detailing the results of the study for review and approval

by Ecology within 120 days of completing the study. If the results indicat e that there is aFact Sheet for NPDES Permit WA 0 002950

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Page 71 of 145

potential for the wastewater to impact the ground water, the report must also include a

monitoring plan. Ecology has guidance regarding preparation of a monitoring plan entitled

Implementation Guidance for the Ground Water Quality Standa rds (Publication #96

- 02

, April 1996).

R

. Outfall 011 and Outfall 012 BMP Effectiveness Study

The storage area for the alumina ore prior to processing is located at the entrance to the pier

and includes three 100

- foot diameter alumina storage silos. The drainage area for the

alumina silo storage area is about 550 feet by 200 feet (2.5 acres) and i s divided into two

watersheds.

The northern portion of the silo storage area drains to a single catch basin and discharges to

Outfall 011. This outfall is embedded deep in the riprap shoreline along the northern edge of

the silo storage area. Major pollu tants include TSS, fluoride, and aluminum. The middle and

southern portion of the silo storage area drain to three catch basins arranged in a north

- south

alignment and are connected in series in a single pipe. The three southern most catch basins

dischar ge to Outfall 012. This outfall is embedded deep in the riprap shoreline along the

southern edge of the silo storage area. Outfall 012 is located in an area that is difficult to

access due to vegetation and is only accessible on foot. Major pollutants i nclude TSS, fecal

coliform, fluoride, and aluminum.

As discussed in Section IV.A above, it is uncertain if the results of the samples collected for

Outfalls 011 and 012 during the previous permit cycle are representative of the discharge

from the silo stor age area. As a result, Permit Condition S2 0 requires the P ermittee to

conduct a BMP effectiveness study for that area. The study requires the facility to evaluate

the area for alternative accessible and representative sampling locations for both outfalls and

conduct an assessment of the best management practices that have been implemented to

reduce the amount of polluta nts discharged from that area.

Ecology has noted during wastewater inspections segments of the curbing for the storage silo

drainage area where collected stormwater may be able to leave the site. An assessment of the

secondary containment for this area and recommendations for repair or additional BMPs are

also requir ed as part of the study.

S

. General C onditions

Ecology bases the standardiz ed General Conditions on state and federal law and regulations.

They are included in all individual industrial NPDES permits issued by Ecology.



### VI. Permit Issuance Procedures

A. Permit M odifications

Ecology may modify this permit to impose numerical limits, if necessary to comply with

water quality standards for surface waters, with sediment quality standards, or with water

quality standards for groundwater s, after obtaining new information from sources such as

inspections, effluent monitoring, outfall studie s, and effluent mixing studies.Fact Sheet for NPDES Permit WA 0 002950

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Page 72 of 145

Ecology may also modify this permit to comply with new or amended state or federal

regulations.

B. Proposed P ermit Issuance

This proposed permit includes all statutory requirements for Ecology to authorize a

wastewater discharge. The permit includes limits and conditions to protect human health and

aquatic life, and the beneficial uses of waters of the s tate of Washington. Ecology proposes

to i ssue this permit for a term of 5 years.



### VII. References for Text And Appendices

Enviro nmental Protection Agency (EPA)

1992. National Toxics Rule. Federal Register, V. 57, No. 246, Tuesday, December 22, 1992.

1991. Technical Support Documen t for Water Quality

- based Toxics Control . EPA/505/2

- 90

-

001.

1988. Technical Guidance on Supplementary Stream Design Conditions for Steady State

Modeling . USEPA Office of Water, Washington, D.C.

1985. Water Quality Assessment: A Screening Procedure for Toxi c and Conventional

Pollutants in Surface and Ground Water . EPA/600/6

- 85/002a.

1983. Water Quality Standards Handbook . USEPA Office of Water, Washington, D.C.

Tsi voglou, E.C., and J.R. Wallace.

1972. Characterization of Stream Reaeration Capacity . EPA

- R3

- 7 2

- 012. (Cited in EPA

1985 op.cit.)

Washington State Department of Ecology.

December 2011

. Permit Writer’s Manual . Publication Number 92

- 109

( https://fortress.wa.gov/ecy/publications/SummaryPages /92109.html)

Laws and Regulations( http://www.ecy.wa.gov/law s

- rules/index.html)

Permit and Wastewater Related Information

( http://www.ecy.wa.gov/pr ograms/wq/permits/guidance.html )

February 2007. Focus Sheet on Solid Waste Control Plan, Developing a Solid Waste

Control Plan for Industrial Wastewater Discharge Permittees , Publication Number

07

- 10

- 024. http://www.ecy.wa.gov/pubs/0710024.pdf

Wright, R.M., and A.J. McDonnell.

1979. In

- stream Deoxygenation Rate Prediction . Journal Environmental Engineering

Division, ASCE. 105(EE2 ). (Cited in EPA 1985 op.cit.)Fact Sheet for NPDES Permit WA 0 002950

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Page 73 of 145



### Appendix A

- Public Involvement Information

Ecology proposes to renew a permit to Intalco . The permit includes wastewater discharge limits

and other conditions. This fact sheet describes the facility and Ecology’s reasons for requiring

permit conditions.

Ecology will place a Public Notice of Draft on August 27, 2014 i n the Ferndale Record to inform

the public and to invite comment on the proposed draft National Pollutant Discharge Elimination

System permit and fact sheet.

The notice:

• Tells where copies o f the draft Permit and Fact Sheet are available for public evaluation (a

local public library, the closest Regional or Field Office, posted on our website).

• Offers to provide the documents in an alternate format to accommodate special needs.

• Urges people t o submit their comments, in writing, before the end of the Comment Period

• Tells how to request a public hearing of comments about the proposed NPDES permit.

• Explains the next step(s) in the permitting process.

Ecology has published a document entitled Freq uently Asked Questions about Effective Public

Commenting which is available on our website at

https://fortress.wa.gov/ecy/publications/SummaryPages /0307023.html.

You may obtain further informa tion from Ecology by telephone, (360) 407

- 6355, or by writing

t o the address listed below.

Water Quality Permit Coordinator

Department of Ecology

Industrial Section

PO Box 47 600

Olympia, WA 98504

- 7600

The primary author of this permit and fact sheet is Stephanie Ogle, P.E.Fact Sheet for NPDES Permit WA 0 002950

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Page 74 of 145



### Appendix B

- Your Right to Appeal

You have a right to appeal this permit to the Pollution Control Hearing Board (PCHB) within 30

days of the date of receipt of the final permit. The appeal process is governed by c hapter 43.21B

RCW and c hapter 371

- 08 WAC. “Date of receipt” is defined in RCW 43.21B.001(2) (see

glossary)

.

To appeal you must do the following within 30 days of the date of receipt of this permit:

• File your appeal and a copy of this permit with the PCHB (see addresses below). Filing

means actual receipt by the PCHB during regu lar business hours.

• Serve a copy of your appeal and this permit on Ecology in paper form

- by mail or in person.

(See addresses below.) E

- mail is not accepted.

You must also comply with other applicable requirements in c hapter 43.21B RCW and c hapter

371

- 08 WAC.

ADDRESS AND LOCATION INFORMATION

Street Addresses Mailing Addresses

Department of Ecology

Attn: Appeals Processing Desk

300 Desmond Drive SE

Lacey, WA 98503 Department of Ecology

Attn: Appeals Processing Desk

PO Box 47608

Olympia, WA 98504

- 7608

Pollution Control Hearings Board

1111 Israel RD SW

STE 301

Tumwater, WA 98501 Pollution Control Hearings Board

PO Box 40903

Olympia, WA 98504

- 0903Fact Sheet for NPDES Permit WA 0 002950

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Page 75 of 145



### Appendix C

- Glossary

1

- DMax or 1

- Day M aximu m T emperature

-- The highest water temperature reached on any

given day. This measure can be obtained using calibrated maximum/minimum thermometers

or continuous monitoring probes having sampling intervals of thirty minutes or less.

7

- DADMax or 7

- Day A ve rage of the Dai ly Maximum T emperatures

-- The arithmetic average

of seven consecutive measures of daily maximum temperatures. The 7

- DADMax for any

individual day is calculated by averaging that day's daily maximum temperature with the

daily maximum temperatures of the thr ee days prior and the three days after that date.

Acute T oxicity

-- The lethal effect of a compound on an organism that occurs in a short time

period, usually 48 to 96 hours.

AKART

-- The acronym for “all known, available, and reasonable methods of prevention , control

and treatment.” AKART is a technology

- based approach to limiting pollutants from

wastewater discharges, which requires an engineering judgment and an economic judgment.

AKART must be applied to all wastes and contaminants prior to entry into wa ters of the state

in accordance with RCW 90.48.010 and 520, WAC 173

- 200

- 030(2)(c)(ii), and WAC 173

-

216

- 110(1)(a).

Alternate Point of C ompliance

-- An alternative location in the groundwater from the point of

compliance where compliance with the groundwater s tandards is measured. It may be

established in the groundwater at locations some distance from the discharge source, up to,

but not exceeding the property boundary and is determined on a site specific basis following

an AKART analysis. An “early warning value” must be used when an alternate point is

established. An alternate point of compliance must be determined and approved in

accordance with WAC 173

- 200

- 060(2).

Ambient Water Q uality

-- The existing environmental condition of the water in a receiving

wat er body.

Ammonia

-- Ammonia is produced by the breakdown of nitrogenous materials in wastewater.

Ammonia is toxic to aquatic organisms, exerts an oxygen demand, and contributes to

eutrophication. It also increases the amount of chlorine needed to disinfect wastewater.

Annual Average Design F low (AADF )

-- A verage of the daily flow volumes anticipated to occur

over a calendar year.

Average Monthly (Intermittent) Discharge L imit

-- The average of the measured values

obtained over a calendar months time taking into account zero discharge days.

Average Monthly Discharge Li mit

-- The average of the measured values obtained over a

calendar month's time.

Background Water Q uality

-- The conce ntrations of chemical, physical, biological or

radiological constituents or other characteristics in or of groundwater at a particular point in

time upgradient of an activity that has not been affected by that activity, [WAC 173

- 200

- 020(3)]. Background wa ter quality for any parameter is statistically defined as the 95%

upper tolerance interval with a 95% confidence based on at least eight hydraulicallyFact Sheet for NPDES Permit WA 0 002950

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upgradient water quality samples. The eight samples are collected over a period of at least

one year, wi th no more than one sample collected during any month in a single calendar year.

Best Management P ractices (BMPs)

-- Schedules of activities, prohibitions of practices,

maintenance procedures, and other physical, structural and/or managerial practices to pre vent

or reduce the pollution of waters of the state. BMPs include treatment systems, operating

procedures, and practices to control: plant site runoff, spillage or leaks, sludge or waste

disposal, or drainage from raw material storage. BMPs may be furth er categorized as

operational, source control, erosion and sediment control, and treatment BMPs.

BOD5

-- Determining the five

- day Biochemical Oxygen Demand of an effluent is an indirect way

of measuring the quantity of organic material present in an effluent that is utilized by

bacteria. The BOD5 is used in modeling to measure the reduction of dissolved oxygen in

receiving waters after effluent is discharged. Stress caused by reduced dissolved oxygen

levels makes organisms less competitive and less able to sustain their species in the aquatic

environment. Although BOD 5 is not a specific compound, it is defined as a conventional

pollutant under the federal Clean Water Act.

Bypass

-- The intentional diversion of waste streams from any portion of a treatment fac ility.

Categorical Pretreatment S tandards

-- National pretreatment standards specifying quantities or

concentrations of pollutants or pollutant properties, which may be discharged to a POTW by

existing or new industrial users in specific industrial subcatego ries.

Chlorine

-- A chemical used to disinfect wastewaters of pathogens harmful to human health. It is

also extremely toxic to aquatic life.

Chronic T oxicity

-- The effect of a compound on an organism over a relatively long time, often

1/10 of an organism's lifespan or more. Chronic toxicity can measure survival, reproduction

or growth rates, or other parameters to measure the toxic effects of a compound or

combi nation of compounds.

Clean Water A ct (CWA )

-- The federal Water Pollution Control Act enacted by Public Law

92

- 500, as amended by Public Laws 95

- 217, 95

- 576, 96

- 483, 97

- 117; USC 1251 et seq.

Compliance Inspection

- without S ampling

-- A site visit for the purp ose of determining the

compliance of a facility with the terms and conditions of its permit or with applicable statutes

and regulations.

Compliance Inspection

- with S ampling

-- A site visit for the purpose of determining the

compliance of a facility with the terms and conditions of its permit or with applicable statutes

and regulations. In addition it includes as a minimum, sampling and analysis for all

parameters with limits in the permit to ascertain compliance with those limits; and, for

municipal faciliti es, sampling of influent to ascertain compliance with the 85 percent removal

requirement. Ecology may conduct additional sampling.

Composite S ample

-- A mixture of grab samples collected at the same sampling point at different

times, formed either by contin uous sampling or by mixing discrete samples. May be "time

composite" (collected at constant time intervals) or "flow

- proportional" (collected either as a

constant sample volume at time intervals proportional to stream flow, or collected byFact Sheet for NPDES Permit WA 0 002950

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Page 77 of 145

increasing the volume of each aliquot as the flow increased while maintaining a constant time

interval between the aliquots).

Construction A ctivity

-- Clearing, grading, excavation, and any other activity, which disturbs the

surface of the land. Such activities may includ e road building; construction of residential

houses, office buildings, or industrial buildings; and demolition activity.

Continuous M onitoring

-- Uninterrupted, unless otherwise noted in the permit.

Critical C ondition

-- The time during which the combination o f receiving water and waste

discharge conditions have the highest potential for causing toxicity in the receiving water

environment. This situation usually occurs when the flow within a water body is low, thus,

its ability to dilute effluent is reduced.

D ate of R eceipt

-- This is defined in RCW 43.21B.001(2) as five business days after the date of

mailing; or the date of actual receipt, when the actual receipt date can be proven by a

preponderance of the evidence. The recipient's sworn affidavit or declarat ion indicating the

date of receipt, which is unchallenged by the agency, constitutes sufficient evidence of actual

receipt. The date of actual receipt, however, may not exceed forty

- five days from the date of

mailing.

Detection L imit

-- The minimum concentr ation of a substance that can be measured and reported

with 99 percent confidence that the pollutant concentration is above zero and is determined

from analysis of a sample in a given matrix containing the pollutant.

Dilution F actor (DF)

-- A measure of the amount of mixing of effluent and receiving water that

occurs at the boundary of the mixing zone. Expressed as the inverse of the percent effluent

fraction, for example, a dilution factor of 10 means the effluent comprises 10% by volume

and the receiving water 90%.

Distribution U niformity

-- The uniformity of infiltration (or application in the case of sprinkle or

trickle irrigation) throughout the field expressed as a percent relating to the average depth

infiltrated in the lowest one

- quarter of the area to the average depth of water infiltrated.

Early Warning V alue

-- The concentration of a pollutant set in accordance with WAC

173

- 200

- 070 that is a percentage of an enforcement limit. It may be established in the

effluent, groundwater, surface water, the vado se zone or within the treatment process. This

value acts as a trigger to detect and respond to increasing contaminant concentrations prior to

the degradation of a beneficial use.

Enforcement L imit

-- The concentration assigned to a contaminant in the ground water at the

point of compliance for the purpose of regulation, [WAC 173

- 200

- 020(11)]. This limit

assures that a groundwater criterion will not be exceeded and that background water quality

will be protected.

Engineering R eport

-- A document that thoroughly examines the engineering and administrative

aspects of a particular domestic or industrial wastewater facility. The report must contain the

appropriate information required in WAC 173

- 240

- 060 or 173

- 240

- 130.

Fecal Coliform B acteria

-- Fecal coliform bacter ia are used as indicators of pathogenic bacteria

in the effluent that are harmful to humans. Pathogenic bacteria in wastewater discharges areFact Sheet for NPDES Permit WA 0 002950

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controlled by disinfecting the wastewater. The presence of high numbers of fecal coliform

bacteria in a water bo dy can indicate the recent release of untreated wastewater and/or the

presence of animal feces.

Grab S ample

-- A single sample or measurement taken at a specific time or over as short a period

of time as is feasible.

Groundwater

-- Water in a saturated zone or stratum beneath the surface of land or below a

surface water body.

Industrial U ser

-- A discharger of wastewater to the sanitary sewer that is not sanitary

wastewater or is not equivalent to sanitary wastewater in character.

Industrial W astewater

-- Water or liquid

- carried waste from industrial or commercial processes,

as distinct from domestic wastewater. These wastes may result from any process or activity

of industry, manufacture, trade or business; from the development of any natural resource; or

from ani mal operations such as feed lots, poultry houses, or dairies. The term includes

contaminated storm water and, also, leachate from solid waste facilities.

Interference

-- A discharge which, alone or in conjunction with a discharge or discharges from

other so urces, both:

• Inhibits or disrupts the POTW, its treatment processes or operations, or its sludge

processes, use or disposal; and

• Therefore is a cause of a violation of any requirement of the POTW's NPDES permit

(including an increase in the magnitude or du ration of a violation) or of the prevention of

sewage sludge use or disposal in compliance with the following statutory provisions and

regulations or permits issued hereunder (or more stringent State or local regulations):

Section 405 of the Clean Water Ac t, the Solid Waste Disposal Act (SWDA) (including

title II, more commonly referred to as the Resource Conservation and Recovery Act

(RCRA), and including State regulations contained in any State sludge management plan

prepared pursuant to subtitle D of the SWDA), sludge regulations appearing in 40 CFR

Part 507, the Clean Air Act, the Toxic Substances Control Act, and the Marine

Protection, Research and Sanctuaries Act.

Local L imits

-- Specific prohibitions or limits on pollutants or pollutant parameters devel oped by

a POTW.

Major F acility

-- A facility discharging to surface wat er with an EPA rating score of > 80 points

based on such factors as flow volume, toxic pollutant potential, and public health impact.

Maximum Daily Discharge L imit

-- The highest allowable daily discharge of a pollutant

measured during a calendar day or any 24

- hour period that reasonably represents the calendar

day for purposes of sampling. The daily discharge is calculated as the average measurement

of the pollutant over the day.

Maximu m Day Design F low (MDDF )

-- The largest volume of flow anticipated to occur during

a one

- day period, expressed as a daily average.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 79 of 145

Maximum Month Design F low (MMDF)

-- The largest volume of flow anticipated to occur

during a continuous 30

- day period, expressed as a daily average.

Maximum Week Design F low (MWDF )

-- The largest volume of flow anticipated to occur

during a continuous 7

- day period, expressed as a daily average.

Method Detection L evel (MDL)

-- See Method Detection Level

.

Minor F acility

-- A facility discha rging to surface water with an EPA rating score of < 80 points

based on such factors as flow volume, toxic pollutant potential, and public health impact.

Mixing Z one

-- An area that surrounds an effluent discharge within which water quality criteria

may be e xceeded. The permit specifies the area of the authorized mixing zone that Ecology

defines following procedures outlined in state regulations (chapter 173

- 201A WAC).

National Pollutant Discharge Elimination S ystem (NPDES)

-- The NPDES (Section 402 of the

Cle an Water Act) is the federal wastewater permitting system for discharges to navigable

waters of the United States. Many states, including the state of Washington, have been

delegated the authority to issue these permits. NPDES permits issued by Washingto n State

permit writers are joint NPDES/State permits issued under both state and federal laws.

pH

-- The pH of a liquid measures its acidity or alkalinity. It is the negative logarithm of the

hydrogen ion concentration. A pH of 7 is defined as neutral and large variations above or

below this value are considered harmful to most aquatic life.

Pass

- T hrough

-- A discharge which exi ts the POTW into waters of the s tate in quantities or

concentrations which, alone or in conjunction with a discharge or discharges from other

sources, is a cause of a violation of any requirement of the POTW's NPDES permit

(including an increase in the magnitude or duration of a violation), or which is a cause of a

violation of State water quality standards.

Peak Hour Design F low (PHD F)

-- The largest volume of flow anticipated to occur during a

one

- hour period, expressed as a daily or hourly average.

Peak Instantaneous Design F low (PIDF)

-- The maximum anticipated instantaneous flow.

Point of C ompliance

-- The location in the groundwater w here the enforcement limit must not be

exceeded and a facility must comply with the Ground Water Quality Standards. Ecology

determines this limit on a site

- specific basis. Ecology locates the point of compliance in the

groundwater as near and directly do wngradient from the pollutant source as technically,

hydrogeologically, and geographically feasible, unless it approves an alternative point of

compliance.

Potential Significant Industrial U ser (PSIU)

-- A potential significant industrial user is defined

as an Industrial User that does not meet the criteria for a Significant Industrial User, but

which discharges wastewater meeting one or more of the following criteria:

a. Exceeds 0.5 % of treatment plant design capacity criteria and discharges <25,000 gallons

per day or;

b. Is a member of a group of similar industrial users which, taken together, have the

potential to cause pass through or interference at the POTW (e.g. facilities which developFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 80 of 145

photographic film or paper, and car washes).

Ecology may determine that a discharger initially classified as a potential significant

industrial user should be managed as a significant industrial user.

Quantitation L evel (QL)

-- Also known as Minimum Level of Quantitation (ML)

– The lowest

level at which the entire analytical system must give a recognizable signal and acceptable

calibration point for the analyte. It is equivalent to the concentration of the lowest calibration

sta ndard, assuming that the lab has used all method

- specified sample weights, volumes, and

cleanup procedures. The QL is calculated by multiplying the MDL by 3.18 and rounding the

result to the number nearest to (1,2,or 5) x 10 n , where n is an integer. (64 F R 30417).

ALSO GIVEN AS:

The smallest detectable concentration of analyte greater than the Detection Limit (DL) where

the accuracy (precision & bias) achieves the objectives of the intended purpose. ( Report of

the Federal Advisory Committee on Detection and Quantitation Approaches and Uses in

Clean Water Act Programs Submitted to the US Environmental Protection Agency December

2007).

Reasonable P otential

-- A reasonable potential to cause a water quality violation, or loss of

sensitive and/or important habi tat.

Responsible Corporate O fficer

-- A president, secretary, treasurer, or vice

- president of the

corporation in charge of a principal business function, or any other person who performs

similar policy

, or decision

- making functions for the corporation, or th e manager of one or

more manufacturing, production, or operating facilities employing more than 250 persons or

have gross annual sales or expenditures exceeding $25 million (in second quarter 1980

dollars), if authority to sign documents has been assigned or delegated to the manager in

accordance with corporate procedures (40 CFR 122.22).

Significant Industrial U ser (SIU)

--

1) All industrial users subject to Categorical Pretreatment Standards under 40 CFR 403.6 and

40 CFR Chapter I, Subchapter N and;

2) Any other industrial user that: discharges an average of 25,000 gallons per day or more of

process wastewater to the POTW (excluding sanitary, noncontact cooling, and boiler blow

down wastewater); contributes a process waste stream that makes up 5 percent or more of

the average dry weather hydraulic or organic capacity of the POTW treatment plant; or is

designated as such by the Control Authority* on the basis that the industrial user has a

reasonable potential for adversely affecting the POTW's operation or f or violating any

pretreatment standard or requirement [in accordance with 40 CFR 403.8(f)(6)].

Upon finding that the industrial user meeting the criteria in paragraph 2, above, has no

reasonable potential for adversely affecting the POTW's operation or for violating any

pretreatment standard or requirement, the Control Authority* may at any time, on its own

initiative or in response to a petition received from an industrial user or POTW, and in

accordance with 40 CFR 403.8(f)(6), determine that such industr ial user is not a significant

industrial user.

*The term "Control Authority" refers to the Washington State Department of Ecology in

the case of non

- delegated POTWs or to the POTW in the case of delegated POTWs.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 81 of 145

Slug D ischarge

-- Any discharge of a non

- routi ne, episodic nature, including but not limited to an

accidental spill or a non

- customary batch discharge to the POTW. This may include any

pollutant released at a flow rate that may cause interference or pass through with the POTW

or in any way violate th e permit conditions or the POTW’s regulations and local limits.

Soil S cientist

-- An individual who is registered as a Certified or Registered Professional Soil

Scientist or as a Certified Professional Soil Specialist by the American Registry of Certified

Pr ofessionals in Agronomy, Crops, and Soils or by the National Society of Consulting

Scientists or who has the credentials for membership. Minimum requirements for eligibility

are: possession of a baccalaureate, masters, or doctorate degree from a U.S. or C anadian

institution with a minimum of 30 semester hours or 45 quarter hours professional core

courses in agronomy, crops or soils, and have 5,3,or 1 years, respectively, of professional

experience working in the area of agronomy, crops, or soils.

Solid W as te

-- All putrescible and non

- putrescible solid and semisolid wastes including, but not

limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, demolition and

construction wastes, abandoned vehicles or parts thereof, contaminated soils and

contaminated dredged material, and recyclable materials.

Soluble BOD 5

-- Determining the soluble fraction of Biochemical Oxygen Demand of an effluent

is an indirect way of measuring the quantity of soluble organic material present in an effluent

that is utilized by bacteria. Although the soluble BOD 5 test is not specifically described in

Standard Methods, filtering the raw sample through at least a 1.2 um filter prior to running

the standard BOD 5 test is sufficient to remove the particulate organic fraction.

State W aters

-- Lakes, rivers, ponds, streams, inland waters, underground waters, salt waters, and

all other surface waters and watercourses within the jurisdiction of the state of Washington.

S tormwater

-- That portion of precipitation that does not naturally percolate into the ground or

evaporate, but flows via overland flow, interflow, pipes, and other features of a storm water

drainage system into a defined surface water body, or a constructed infiltration facility.

Technology

- based effluent limit

-- A permit limit based on the ability of a treatment method to

reduce the pollutant.

Total Coliform B acteria

-- A microbiological test, which detects and enumerates the total

coliform group of bacteria in water samples.

Total Dissolved S olids

-- That portion of total solids in water or wastewater that passes through a

specific filter.

Total Maximum Daily L oad (TMDL)

-- A determination of the amount of pollutant that a

water body can receive and still meet wa ter quality standards.

Total Suspended S olids (TSS)

-- T he particulate material in an effluent. Large quantities of TSS

discharged to a receiving water may result in solids accumulation. Apart from any toxic

effects attributable to substances leached out b y water, suspended solids may kill fish,

shellfish, and other aquatic organisms by causing abrasive injuries and by clogging the gills

and respiratory passages of various aquatic fauna. Indirectly, suspended solids can screen

out light and can promote and maintain the development of noxious conditions through

oxygen depletion.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 82 of 145

Upset

-- An exceptional incident in which there is unintentional and temporary noncompliance

with technology

- based permit effluent limits because of factors beyond the reasonable

con trol of the Permittee. An upset does not include noncompliance to the extent caused by

operational error, improperly designed treatment facilities, lack of preventative maintenance,

or careless or improper operation.

Water Quality

- Based Effluent L imit

-- A limit imposed on the concentration of an effluent

parameter to prevent the concentration of that parameter from exceeding its water quality

criterion after discharge into receiving waters.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 83 of 145



### Appendix D

- Summary of DMR Data

Intalco 2007 Water Pollutant Discharges (April through December)

PARAMETERS

UNITS LIMITS 1 APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

OUTFALL 001

TSS

- MA 2 lbs/day 150 14 0 0 0 7 18 5 68 82 21.6

TSS

- DM 3 lbs/day 185 86 0 0 0 29 44 23 143 149 52.7

FLUORIDE

- MA lbs/day 68 38 41 26 35 21 36 57 41 46 37.9

FLUORIDE

- DM lbs/day 296 57 68.0 36 61 26 74 176 91 120 78.8

ALUMINUM

- MA lbs/day 10.3 0.4 0.0 0.0 0.0 0.0 1.2 0.2 5.0 4.0 1.2

ALUMINUM

- DM lbs/day 30 2.0 0 0 0 0 3 1 11 8.0 2.8

FREE CN

- MA mg/l <0.012 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.0

FREE CN

- DM mg/l 0.012 <0.005 < 0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005

B(a)P

- MA lbs/day 0.06 0.0067 0.01 4/2/2007 0.015 7/5/2007 7/5/2007 0.024 10/11/2007 10/11/2007

B(a)P

- DM lbs/day 0.13 0.0067 0.01 4/2/2007 0.015 7/5/2007 7/5/2007 0.024 10/11/2007 10/11/2007

ANTIMONY

- MA lbs/day 5.7 0.07 0.01 5/15/2007 5/15/2007 0.29 7/16/2007 7/16/2007 7/16/2007 7/16/2007

ANTIMONY

- DM lbs/day 12.8 0.01 5/15/2007 5/15/2007 0.31 7/16/2007 7/16/2007 7/16/2007 7/16/2007

NICKEL

- MA lbs/day 2.5 1.25 0.6 5/15/2007 5/15/2007 0.26 7/16/2007 7/16/2007 7/16/2007 7/16/2007

NICKEL

- DM lbs/day 3.7 0.7 5/15/2007 5/15/2007 0.28 7/16/2007 7/16/2007 7/16/2007 7/16/2007

C0PPER

- MA ug/l none 0 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007

C0PPER

- DM ug/l none <5 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007

O & G

- MA mg/l 5 1 1 <1 <1 1 1 0 1 1

O & G

- DM mg/l 10 1 1 <1 <1 1 1 <1 1 1

pH

- Minimum std units ≥6 7.7 7.7 7.5 7.5 7.6 7.7 7.2 7.3 7.0 7.5

pH

- Maximum std units ≤9 8.2 8.2 8.1 8.1 8.1 8.1 8.0 7.9 8.1 8.1

Temp

- MA o F none 56 60 63 69 68 65 58 52 47.0 59.8

Temp

- DM o F none 64 68 70 73 73 70 63 59 52.0 65.8

Flow

- MA MGD none 3.388 3.574 3.722 3.861 3.836 3.668 3.357 3.511 3.542 3.6

Flow

- DM MGD none 3.624 4.121 4.053 4.162 4.109 3.913 3.667 4.012 3.755 3.9

Al Production 4 tons/day none 618.6 605.3 593.9 581.2 615.5 619.4 614.2 622.9 616.9 609.8

Potdays (average number of pots

operating/day) Number none 533 528 532 533 532 536 535 535 538.0 533.6

% of total number of pots (720)

operating/day % none 74 73 74 74 74 74 74 74 75 74.1

OUTFALL 002: UNITS LIMITS APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

TSS

- MA mg/l 35 8 10 10 13 11 11 9 14 15 11.2

TSS

- DM mg/l 75 13 13 12 24 16 11 10 22 37 17.6

FLUORIDE

- MA mg/l 35 12 15 25 28 34 33 31 29 16 24.8Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 84 of 145

Intalco 2007 Water Pollutant Discharges (April through December)

OUTFALL 002: UNITS LIMITS APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

FLUORIDE

- DM mg/l 50 15 17 29 32 37 35 38 33 18 28.2

Al

- MA mg/l 10 2 3 5 5 6 6 9 9 4 5.4

Al

- DM mg/l 15 3 4 6 8 7 6 11 10 6 6.8

B (a)P

- DM mg/l <0.01 <0.0001 <0.0001 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 <0.0001

Copper

- MA ug/l none 0 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 <20

Copper

- DM ug/l none <20 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 <20

Free CN

- DM mg/l none 0.00 0.00 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007 4/2/2007

O & G

- MA mg/l 5 1 1 <1 1 1 1 1 1 1 1.0

O & G

- DM mg/l 10 1 1 <1 1 1 1 1 1 1 1.0

pH

- Minimum std units ≥6 6.9 6.9 6.7 6.9 7.0 7.2 6.6 6.7 6.6 6.8

pH

- Maximum std units ≤9 7.3 7.4 7.3 7.6 7.4 7.4 7.7 7.1 7.3 7.4

Temp

- MA o F none 52 59 63 67 65 62 51 42 39 55.6

Temp

- DM o F none 61 68 68 73 72 68 59 50 50 63.2

Flow

- MA MGD none 0.349 0.183 0.099 0.083 0.024 0.040 0.360 0.218 1.380 0.3

Flow

- DM MGD none 1.922 3.467 0.488 0.861 0.138 0.110 2.695 1.373 12.0105 2.6

Sanitary Lagoon UNITS LIMITS APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

BOD: 30

- day Avg lbs/day 22.4 4.4 3.1 3.0 3.2 2.0 2.4 0.8 1.6 3.2 2.6

BOD: 7

- day Avg lbs/day 32.4 5.1 6.8 6.8 7.7 6.2 3.7 1.3 2.2 5.5 5.0

BOD: 30

- day Avg mg/l 45.0 17.3 12.5 15.8 8.4 10.2 10.4 3.4 7.6 9.7 10.6

BOD: 7

- day Avg mg/l 65.0 22.0 20.0 34.0 15.0 30.0 21.1 4.9 16 12.0 19.4

% BOD Removal % 65 77 83 78 87 84 86 95 88 86 84.9

TSS: 30

- day Avg lbs/day 22.4 2.8 0.7 1.5 3.2 0.5 0.5 0.6 0.5 2.3 1.4

TSS: 7

- day Avg lbs/day 32.4 3.8 1.4 4.7 7.1 0.8 1.4 0.8 0.8 4.7 2.8

TSS: 30

- day Avg mg/l 45.0 10.8 3.4 7.7 8.6 3.9 1.2 2.4 2 6.5 5.2

TSS: 7

- day Avg mg/l 65.0 16.8 6.1 23.1 13.8 5.5 3 3 3.4 8.0 9.2

% TSS Removal % 65 89 97 93 90 95 99 98 97 94 94.7

Fecal Coli: 30

- day Avg #/100mls 200 0.0 0.0 <2 <5 <2 <2 <2 <2 <4

Fecal Coli: 7

- day Avg #/100mls 400 <2 <2 <2 110 2 2 <2 <2 30

pH

- Min std units ≥6 6.6 6.5 6.6 6.7 6.7 6.5 6.3 6.2 6.5 6.5

pH

- Max std units ≤9 7.1 7.0 7.0 7.0 6.9 7.0 6.9 6.7 7.1 7.0

Flow

- MA MGD none 0.034 0.026 0.024 0.035 0.017 0.037 0.026 0.024 0.039 0.0

Flow

- DM MGD none 0.072 0.070 0.036 0.062 0.034 0.065 0.046 0.068 0.082 0.1

Personnel working onsite # of personnel > 400 591 602 614 607 633 641 636 636 620.0

Date UV Tub es cleaned Date Once/90 days 4/4/07 5/16/07 5/16/07 7/26/07 8/30/07 8/30/07 8/30/07 11/19/07 11/19/07

UV Tubes Operating Number Min. of 12 14 14 14 14 14 14 14 14 14 14.0

Date UV Tubes replaced Date Annually 1/4/07 1/4/07 1/4/07 7/3/2007 7/3/2007 7/3/2007 7/3/2007 7/3/2007 7/3/2007Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 85 of 145

Intalco 2007 Water Pollutant Discharges (April through December)

Stormwat er Pond UNITS Action Level APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

TSS

- DM 5 mg/l 20 11.5 28.8 NS 6 NS NS NS 23.1 NS 42.2 26.4

FLUORIDE

- DM 5 mg/l 35 23.0 26.0 NS NS NS NS 40.2 NS 22.0 27.8

ALUMINUM

- DM 5 mg/l 8 5.7 7.8 NS NS NS NS 13.2 NS 7 8.4

pH

- Min (continuous recording) std units <6.0 6.8 6.7 6.8 6.8 6.7 6.8 6.6 6.4 6.6 6.7

pH

- Max (continuous recording) std units >9.0 7.6 7.3 7.2 7.1 7.1 7.3 7.2 7.5 7.3 7.3

Flow

- MA (continuous recording) MGD none 0.196 0.127 0.101 0.108 0.074 0.076 0.187 0.152 0.471 0.166

Flow

- DM (continuous recording) MGD none 0.802 1.091 0.327 0.524 0.237 0.191 0.761 0.545 3.45 0.881

COMMENTS 1. The SW pond was drained on 09/18/07 and >75 tons of sludge was removed.

2. The sludge levels were surveyed and found to be below storage capacity.

Secondary Wastewater Treatment

Plant UNITS Action Level APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- MA mg/l none 27.6 28.6 20.5 12.5 13.8 17.5 22.0 22.5 30.8 21.8

TSS

- DM mg/l 120 43.7 51.2 36.4 19.8 22.2 25.8 47.8 44.0 52.8 38.2

FLUORIDE

- MA mg/l none 20.4 18.1 15.8 21 18.8 24.6 27.4 40.5 19.9 22.9

FLUORIDE

- DM mg/l 50 26.0 21.0 18.0 31 22.0 48.0 43.0 75.0 32.0 35.1

ALUMINUM

- MA mg/l none 0.1 0.1 0.1 0.4 0.1 0.3 0.6 0.9 0.5 0.3

ALUMINUM

- DM mg/l none 0.2 0.2 0.2 0.8 0.1 0.8 1.1 2.3 0.9 0.7

FREE CN

- MA mg/l none 0.000 0.001 0.002 0.001 0.004 0.002 0.000 0.010 0.003 0.003

FREE CN

- DM mg/l none 0.000 0.005 0.006 0.005 0.007 0.006 <0.005 0.015 0.013

PCBs ppb none <0.1 4/2/2007 4/2/2007 <0.1 7/16/2007 7/16/2007 <0.1 10/11/2007 10/11/2007

Flow

- MA MGD none 0.065 0.067 0.056 0.055 0.047 0.095 0.074 0.049 0.061 0.1

Flow

- DM MGD none 0.243 0.197 0.140 0.184 0.112 0.314 0.185 0.143 0.192 0.2

pH

- Min (continuous recording) std units none 7.4 7.1 6.9 6.9 6.8 6.5 6.6 6.8 7.2 6.9

pH

- Max (continuous recording) std units none 7.8 8.0 7.8 7.8 7.7 7.5 7.5 7.8 7.6 7.7

Outfall 011 UNITS LIMITS APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- Monthly grab when there is flow mg/l none 19.6 0.9 1.0 1.4 2.4 19.6 18.6 24.6 36.7 13.9

FLUORIDE

- Monthly grab when there is

flow mg/l none 7.7 2.8 2.3 0.8 4.3 9.0 6.0 0.8 8.0 4.6

ALUMINUM

- Monthly grab when there is

flow mg/l none 2 0.08 0.1 2.9 0.2 1.5 2.2 3.54 1.2 1.5

Outfall 012 UNITS LIMITS APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- Monthly grab when there is flow mg/l none 85 IF 7 20.7 27.1 29.5 97.7 48.2 28.7 779.1 139.5

FLUORIDE

- Monthly grab when there is

flow mg/l none 2 IF 4.4 0.2 3.8 4.7 2.8 0.68 6.2 3.1

ALUMINUM

- Monthly grab when there is

flow mg/l none 9 IF 1.7 1.1 2 1.4 1.3 2.54 3.1 2.8Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 86 of 145

Intalco 2007 Water Pollutant Discharges (April through December)

1 LIMITS for the renewed NPDES permit issued on March 15, 2007

2 Monthly average (MA) effluent limitation is defined as the highest allowable average of daily discharges over a calendar mont h, calculated as the sum of all daily discharges measured during a calendar month divided by the number of daily

discharges measured during that month.

3 Daily maximum (DM) effluent limitation is defined as the highest allowable daily discharge. The daily d ischarge means the discharge of a pollutant measured during a calendar day. For pollutants with limitations expressed in uni ts of mass,

the daily discharge is calculated as the total mass of the pollutant discharged over the day. For other units of measu rement, the daily discharge is the average measurement of the pollutant over the day. The pH shall not be averaged.

4 The monthly average of daily production.

5 Sampled when the stormwater pond discharge exceeds 3.7 cfs over any consecutive 120 minute period.

6 NS

= Not sampled because the stormwater pond discharge did not exceed 3.7 cfs over any consecutive 120 minute period.

7 IF

= Insufficient flow to collect a representative sample.

Intalco 2008 Water Pollutant Discharges

OUTFALL 001 UNITS LIMITS 1 JAN FEB MARCH APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- MA 2 lbs/day 150 25 25 10 60 65 63 29 1 5 5 28 61 31.4

TSS

- DM 3 lbs/day 185 51 64 40 78 135 105 58 5 26 21 47 157 65.6

FLUORIDE

- MA lbs/day 58 4 /68 5 /68 6 34 39 36 39 31 44 33 35 27 17 23 20 31.5

FLUORIDE

- DM lbs/day 140 4 /198 5 /296 6 41 44 45 59 47.0 77 61 62 58 37 28 32 49.3

ALUMINUM

- MA lbs/day 5.9 4 /9.0 5 /10.3 6 2.9 1.8 0.4 3.5 1.3 2.7 1.1 0.4 0.5 0.2 0.1 2.3 1.4

ALUMINUM

- DM lbs/day 13.4 4 /20 5 /30 6 5 3.0 1 5.0 3.6 6 3.8 1.4 2.6 1.3 0.3 7.2 3.4

FREE CN

- MA mg/l <0.012 0.000 0.000 0.000 ND 7

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005)

FREE CN

- DM mg/l 0.012 <0.005 <0.005 <0.005 ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005)

B(a)P

- MA lbs/day 0.02 4 /0.03 5 /0.045 6 10/11/07 10/11/07 <0.002 ND

(<0.002) 04/01/08 0.0031 0.06 07/15/08 07/15/08 0.009 10/24/08 10/24/08

B(a)P

- DM lbs/day 0.043 4 /0.065 5 /0.098 6 10/11/07 10/11/07 <0.002 ND

(<0.002) 04/01/08 0.0031 0.13 07/15/08 07/15/08 0.024 10/24/08 10/24/08

Mercury ug/l none ND

(<0.0002) ND

(<0.005)

ANTIMONY

- MA lbs/day 1.9 4 /2.9 5 /4.3 6 07/16/07 07/16/07 0.01 03/14/08 03/14/08 ND

(<0.00001) 06/04/08 06/04/08 06/04/08 0.024 10/24/08 10/24/08

ANTIMONY

- DM lbs/day 4.2 4 /6.4 5 /9.6 6 07/16/07 07/16/07 0.01 03/14/08 03/14/08 ND

(<0.00001) 06/04/08 06/04/08 06/04/08 0.066 10/24/08 10/24/08

NICKEL

- MA lbs/day 0.8 4 /1.2 5 /1.9 6 07/16/07 07/16/07 1.31 03/14/08 03/14/08 0.3140 06/04/08 06/04/08 06/04/08 2.643 10/27/08 10/27/08

NICKEL

- DM lbs/day 1.24 4 /1.85 5 /2.76 6 07/16/07 07/16/07 1.31 03/14/08 03/14/08 0.3140 06/04/08 06/04/08 06/04/08 14.472 10/27/08 10/27/08

C0PPER

- MA ug/l none 04/02/07 04/02/07 04/02/07 ND

(<0.020) 04/01/08 ND

(<0.00002) 06/04/08 06/04/08 06/04/08 ND

(<0.003) 10/24/08 10/24/08

C0PPER

- DM ug/l none 04/02/07 04/02/07 04/02/07 ND

(<0.020) 04/01/08 ND

(<0.00002) 06/04/08 06/04/08 06/04/08 ND

(<0.003) 10/24/08 10/24/08

O & G

- MA mg/l 5 0 0 0 ND

(<1) ND

(<1) ND

(<1) ND

(<1) ND

(<1) ND

(<1) ND

(<1) ND

(<1.4) ND

(<1.4)

O & G

- DM mg/l 10 <1 <1 <1 ND ND ND ND ND ND ND ND NDFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 87 of 145

Intalco 2008 Water Pollutant Discharges

(<1) (<1) (<1) (<1) (<1) (<1) (<1) (<1.4) (<1.4)

pH

- Daily Min std units ≥6 7.3 7.1 7.3 7.6 7.4 7.4 7.4 7.1 7.6 7.3 7.2 7.2 7.3

pH

- Daily Max std units ≤9 8.2 8.1 8.2 8.1 8.0 7.8 10.0 7.9 8.0 8.0 8.1 8.0 8.2

Temp

- MA o F none 46 48 50 53 55 58 64 64.5 62 55.8 53 46.0 54.6

Temp

- DM o F none 52 54 54 59 62 66 69 72.7 67 63 58 56.0 61.1

Flow

- MA MGD none 3.544 3.654 3.622 3.628 3.483 3.783 3.709 3.853 3.815 3.623 3.628 3.540 3.7

Flow

- DM MGD none 3.726 3.856 3.816 4.107 3.833 4.005 3.899 4.310 4.117 4.117 3.843 4.147 4.0

Al Production 8 tons/day none 634.1 638.1 648.3 653.8 658.9 675.7 668.0 666.1 667.2 676.6 596.1 540.1 643.6

Number of days in the

month none 31 29 31 30 31 30 31 31 30 31 30 31 30.5

Al Production

-

Maximum tons/mont

h none 19657 18505 20097 19614 20426 20271 20708 20649 20016 20975 17883 16743 19629

OUTFALL 002 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- MA mg/l 35 7.1 9.3 8.4 7.6 16.4 29.4 12 16.8 13.3 15.5 15.1 4.2 12.9

TSS

- DM mg/l 75 11.7 16.3 12.9 11.4 19.8 64.9 17.6 31 15.6 22.8 32.2 5.3 21.8

FLUORIDE

- MA mg/l 35 12.4 13.5 13.8 13.4 19.0 25.1 25.8 32.5 28 32.3 22.6 14.2 21.1

FLUORIDE

- DM mg/l 50 17.0 16 17 18 24.3 30.2 29 37.3 31 33 33.7 16 25.2

ALUMINUM

- MA mg/l 10 2.8 2.8 3.3 2.6 4.7 6.2 3.4 7 6.3 9.1 5.6 3.1 4.7

ALUMINUM

- DM mg/l 15 3.7 3.9 4.7 3.6 7.1 10.0 4.5 9.1 7.7 9.4 9.4 3.4 6.4

B (a)P

- DM mg/l <0.01 12/11/07 12/11/07 12/11/07 ND

(<0.0001

) 04/01/08 0.0002 06/04/08 06/04/08 06/04/08 06/04/08 06/04/08 06/04/08

Copper

- DM ug/l none 12/11/07 12/11/07 12/11/07 ND

(<0.020) 04/01/08 ND

(<0.00002) 06/04/08 06/04/08 06/04/08 06/04/08 06/04/08 06/04/08

Free CN

- DM mg/l none 04/02/07 04/02/07 04/02/07 ND

(<0.005) 04/01/08 ND

(<0.005) 06/04/08 06/04/08 06/04/08 06/04/08 06/04/08 06/04/08

O & G

- MA mg/l 5 0 0 0 ND

(<1) ND

(<1) 2.3 ND

(<1) 1 1 ND

(<1) ND

(<1.4) ND

(<1.4)

O & G

- DM mg/l 10 <1 <1 <1 ND

(<1) ND

(<1) 2.3 ND

(<1) 1 1 ND

(<1) ND

(<1.4) ND

(<1.4)

pH

- Daily Min std units ≥6 6.6 6.8 6.7 6.7 6.8 6.8 7.1 6.4 6.9 6.5 6.4 6.5 6.7

pH

- Daily Max std units ≤9 7.2 7.1 7.1 7.4 7.4 7.4 7.6 7.4 7.3 7.3 7.3 7.3 7.3

Temp

- MA o F none 38 40 44 50 58 60 65.9 64.1 59 51.1 47 38 51.3

Temp

- DM o F none 45 46 54 55 66 71 88 82.4 68 59.6 53 49 61.4

Flow

- MA MGD none 1.075 0.641 0.795 0.157 0.264 0.163 0.091 0.292 0.102 0.197 1.179 3.093 0.671

Flow

- DM MGD none 5.131 2.074 3.988 0.652 2.533 1.167 0.125 1.512 0.574 1.189 7.474 25.610 4.336

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

BOD: 30

- day Avg lbs/day 22.4 3.0 4.6 3.3 3.1 3.0 2.2 1.5 4.0 2.7 1.8 2.1 3.0 2.9

BOD: 7

- day Avg lbs/day 32.4 5.3 6.4 5.3 5.5 5.8 3 2.4 9.9 4.9 5.7 3.4 4.3 5.2Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 88 of 145

Intalco 2008 Water Pollutant Discharges

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

BOD: 30

- day Avg mg/l 45.0 10.4 15.3 18.4 13.6 11.8 7.5 7.4 18.4 10.3 8.5 7.0 11.6 11.7

BOD: 7

- day Avg mg/l 65.0 14.0 22.0 30.0 19.0 18.0 10.0 9.2 29.0 14.0 18 12 16.0 17.6

TSS: 30

- day Avg lbs/day 22.4 3.1 6.5 4.2 4.6 4.2 0.9 2.6 1.5 0.5 0.8 1.1 1.8 2.7

TSS: 7

- day Avg lbs/day 32.4 6.4 11.4 7.1 7.9 6.6 1.8 7.0 3.8 1.0 1.5 2.4 5.0 5.2

TSS: 30

- day Avg mg/l 45.0 10.4 22.5 19.4 32.4 16.5 3.1 12.6 8.2 1.6 4.2 3.8 6.2 11.7

TSS: 7

- day Avg mg/l 65.0 15.6 26.3 22.5 24.9 21.1 6.2 25.5 18.1 2.9 6.1 8.8 12.9 15.9

Fecal Coli: 30

- day Avg #/100mls 200 7 <5 <2 ND

(<2) 2.3 3.8 2 ND

(<2) ND

(<2) ND

(<2) ND

(<2) ND

(<2)

Fecal Coli: 7

- day Avg #/100mls 400 30 23 <2 ND

(<2) 4.0 4.0 2 ND

(<2) ND

(<2) ND

(<2) ND

(<2) 2

pH

- Daily Min std units ≥6 6.7 6.7 6.7 6.8 6.5 6.6 6.6 6.5 6.6 6.5 6.4 6.5 6.6

pH

- Daily Max std units ≤9 6.9 7.1 7.0 7.0 7.1 6.9 6.9 6.8 7.0 7.0 7 6.9 7.0

Flow

- MA MGD none 0.034 0.03 0.031 0.022 0.027 0.034 0.024 0.028 0.024 0.020 0.036 0.026 0.028

Flow

- DM MGD none 0.083 0.072 0.052 0.044 0.042 0.039 0.039 0.041 0.042 0.038 0.048 0.047 0.049

% BOD Removal

- MA % 55%/65% 9 80 81 75 80 87 91 93 77 88 92 91 89 85

% TSS Removal

- MA % 55%/65% 9 89 83 79 82 88 97 93 92 98 97 96 96 91

# of personnel

working onsite Number

none 636 644 641 657 647 641 663 665 661 658 614 587 643

Date UV Tubes were

cleaned Date 90 days 11/19/07 02/04/08 02/04/08 04/16/08 05/28/08 06/17/08 07/09/08 07/09/08 09/02/08 10/28/08 11/05/08 11/05/08

UV Tubes Operating 7 day avg Minimum of 12 14 14 14 14 14 14 14 14 14 14 14 14 14

Date UV Tubes were

replaced Date Annually

07/03/07 01/03/08 01/03/08 01/03/08 01/03/08 01/03/08 07/09/08 07/09/08 07/09/08 07/09/08 07/09/08 07/09/08

Stormwater Pond UNITS Action Level JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 20 19.1 NS 10 16.0 NS 15.7 50.2 NS 27.2 NS 12.3 27.2 18.1 23.2

FLUORIDE

- DM mg/l 35 25.1 NS 21.2 NS 28.0 36.3 NS 44.3 NS 38.8 31.7 27.0 31.6

ALUMINUM

- DM mg/l 8 7.8 NS 6.3 NS 8.6 15 NS 14.1 NS 9.4 11.5 7.2 10.0

pH

- Daily Min std units <6.0 6.6 6.8 6.8 6.8 6.6 6.6 6.6 6.4 6.4 6.4 6.0 6.6 6.6

pH

- Daily Max std units >9.0 7.4 7.3 7.3 7.5 7.5 7.2 7.2 7.2 7.0 7.0 7.3 7.7 7.3

Flow

- MA MGD none 0.340 0.246 0.302 0.129 0.158 0.122 0.083 0.217 0.107 0.137 0.242 0.146 0.186

Flow

- DM MGD none 2.135 0.681 1.339 0.374 1.308 0.703 0.145 0.991 0.280 0.443 1.534 0.836 0.897

Secondary

Wastewater

Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 120 43.9 67.3 72.1 52.7 56.8 78.1 53.8 26.6 41.0 132.6 65.2 135.6 68.8

FLUORIDE

- DM mg/l 50 25.0 24 25 39.0 30.0 38.3 32.3 44.0 34.8 34.0 24.8 28.5 31.6

ALUMINUM

- DM mg/l none 0.9 0.3 1.0 0.4 1.1 0.4 0.4 1.4 1.2 0.5 0.3 0.7 0.7Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 89 of 145

Intalco 2008 Water Pollutant Discharges

Secondary

Wastewater

Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

FREE CN

- DM mg/l none 0.006 <0.005 <0.005 ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) 0.005 0.005 ND

(<0.005) ND

(<0.005) ND

(<0.005)

PCBs ppb none 10/11/07 <0.1 2/20/2008 ND

(<0.1) 04/01/08 ND

(<0.1) 06/04/08 07/15/08 07/15/08 07/15/08 <0.01 10/30/08

Flow

- MA MGD none 0.072 0.056 0.055 0.061 0.062 0.061 0.054 0.058 0.064 0.031 0.059 0.034 0.056

Flow

- DM MGD none 0.125 0.131 0.180 0.154 0.165 0.178 0.191 0.186 0.185 0.142 0.125 0.155 0.160

Outfall 011 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS mg/l none 105.9 103.2 29.1 19.7 14.0 1.2 3.0 14.9 43.3 51.8 20.2 24.5 35.9

FLUORIDE mg/l none 8.7 8.2 14.2 6.2 6.2 6.2 5.8 7.5 12.0 9.3 5.3 10.0 8.3

ALUMINUM mg/l none 3.8 2.7 4.5 1.3 0.5 0.2 0.4 0.5 1.4 1.8 1.0 2.1 1.7

Outfall 012 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS mg/l none 31.8 39.2 21 30.1 9.4 16.1 37.0 40.8 5.1 27.1 5.6 10.6 22.8

FLUORIDE mg/l none 4.8 5.5 8.2 3.7 4.8 6.2 8.0 4.2 2.7 6.5 2.2 3.0 5.0

ALUMINUM mg/l none 2.0 2.0 5.1 4.5 1.2 4.5 3.7 1.3 1.2 4.1 0.9 2.5 2.8

1 LIMITS for modified NPDES permit issued on June 15, 2008 (effective July 15, 2008).

2 Monthly average (MA) effluent limitation is defined as the highest allowable average of daily dischar ges over a calendar month, calculated as the sum of all daily discharges measured during a calendar month divided by the

number of daily discharges measured during that month.

3 Daily maximum (DM) effluent limitation is defined as the highest allowable daily discharge. The daily discharge means the di scharge of a pollutant measured during a calendar day. For pollutants with limitations

expressed in units of mass, the daily disch arge is calculated as the total mass of the pollutant discharged over the day. For other units of measurement, the daily dis charge is the average measurement of the pollutant over the

day. The pH shall not be averaged.

4 Tiered limit, applies when mon thly aluminum production is less than or equal to 10,305 tons.

5 Tiered limit, applies when monthly aluminum production is greater than 10,305 and less than or equal to 15,614 tons.

6 Tiered limit, applies when monthly aluminum production is greater than 15,614 tons.

7 ND = Nondetect.

8 The monthly average of daily production.

9 The limit is 55 % if there are <400 people working onsite and the limit is 65% if there are > 400 people working on site.

10 NS

= Not sampled because the stormwater pond discharge never exceeded 3.7 cfs over any consecutive 120 minute period.

I ntalco 2009 Water Pollutant Discharges

PARAMETERS

UNITS LIMITS 1 JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG OUTFALL 001

TSS

- MA 2 lbs/day 150 30 34 97.2 9.7 71.4 1.2 22.1 36.5 20.3 45.2 329.5 111.4

TSS

- Stormwater Allocation

(SWA) 3 lbs/day Calculated 3 DNTA 4 DNTA DNTA DNTA DNTA DNTA DNTA DNTA DNTA DNTA 696.0 DNTAFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 90 of 145

I ntalco 2009 Water Pollutant Discharges

OUTFALL 001 UNITS LIMITS 1 JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- DM 5 lbs/day 185 62 43 134.6 29.6 142.4 4.0 41.1 329 60.7 169.8 1144.4 217.3

TSS

- Stormwater Allocation

(SWA) 6 lbs/day Calculated 6 DNTA DNTA DNTA DNTA DNTA DNTA DNTA 1897.5 DNTA DNTA 2910.0 1391.3

FLUORIDE

- MA lbs/day 58 7 /68 8 /68 9 30 31 121.3 50.1 122.4 53.9 40.2 73.3 44.9 110.3 288.6 101.5

FLUORIDE

- SWA 3 lbs/day Calculated 3 DNTA DNTA 339.6 DNTA 517.7 DNTA DNTA 143.9 DNTA 348.3 614.0 333.7

FLUORIDE

- DM lbs/day 140 7 /198 8 /296 9 42 33 176.2 66.5 197.4 157.8 58.4 585.1 84.6 306.2 766.7 203.7

FLUORIDE

- SWA 6 lbs/day Calculated 6 DNTA DNTA DNTA DNTA DNTA DNTA DNTA 1340.6 DNTA 1198.8 2016.1 1002.8

ALUMINUM

- MA lbs/day 5.9 7 /9.0 8 /10.3 9 1.8 2.0 23.7 3.9 26.8 0.7 1.4 12.9 4.6 29.8 81.3 21.3

ALUMINUM

- SWA 3 lbs/day Calculated 3 DNTA DNTA 87.5 DNTA 136.8 DNTA DNTA 30.6 DNTA 88.7 164.2 84.5

ALUMINUM

- DM lbs/day 13.4 7 /20 8 /30 9 4.9 3.2 42.9 7.0 55.3 2.2 4.3 120.7 11.6 95.5 243.1 57.4

ALUMINUM

- SWA 6 lbs/day Calculated 6 DNTA DNTA 273.8 DNTA 310.0 38.8 38.8 362.5 DNTA 320.0 565.0 261.3

FREE CN

- MA mg/l <0.012 ND 10

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005)

FREE CN

- DM mg/l 0.012 ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005)

B(a)P

- MA lbs/day 0.02 7 /0.03 8 /

0.045 9 10/24/08 0.005 02/23/09 02/23/09 0.005 05/12/09 05/12/09 05/12/09 0.009 09/14/09 09/14/09 0.030

B(a)P

- SWA 3 lbs/day Calculated 3 10/24/08 DNTA 02/23/09 02/23/09 DNTA 05/12/09 05/12/09 05/12/09 DNTA 09/14/09 09/14/09 0.030

B(a)P

- DM 4 lbs/day 0.043 7 /0.065 8 /0

.098 9 10/24/08 0.005 02/23/09 02/23/09 0.005 05/12/09 05/12/09 05/12/09 0.009 09/14/09 09/14/09 0.034

B(a)P

- SWA 6 lbs/day Calculated 6 10/24/08 DNTA 02/23/09 02/23/09 DNTA 05/12/09 05/12/09 05/12/09 DNTA 09/14/09 09/14/09 DNTA

ANTIMONY

- MA lbs/day 1.9 7 /2.9 8 /4.3 9 10/24/08 0.04 02/23/09 02/23/09 0.00 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 0.11

ANTIMONY

- DM lbs/day 4.2 7 /6.4 8 /9.6 9 10/24/08 0.04 02/23/09 02/23/09 0.00 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 0.11

NICKEL

- MA lbs/day 0.8 7 /1.2 8 /1.9 9 10/27/08 1.71 02/23/09 02/23/09 0.00 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 0.06

NICKEL

- DM lbs/day 1.2 7 /1.8 8 /2.7 9 10/27/08 1.71 02/23/09 02/23/09 0.00 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 0.06

C0PPER

- MA ug/l none 10/24/08 <0.02 02/23/09 02/23/09 ND

(<0.24) 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09

C0PPER

- DM ug/l none 10/24/08 <0.02 02/23/09 02/23/09 ND

(<0.24) 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09 05/12/09

O & G

- MA mg/l 5 1.9 <1.4 <1.4 <1.4 ND (<1.4) ND (<1.4) ND (<1.4) ND (<1.4) ND

(<1.4) ND (<1.4) 2.0 ND

(<1.4)

O & G

- DM mg/l 10 1.9 <1.4 <1.4 <1.4 ND (<1.4) ND (<1.4) ND (<1.4) ND (<1.4) ND

(<1.4) ND (<1.4) 2 ND

(<1.4)

pH

- Daily Min std units ≥6 7.2 6.7 7 6.6 6.5 7.1 7.2 6.7 7.1 6.5 6.6 6.8 6.8

pH

- Daily Max std units ≤9 8.2 8.7 7.9 8.1 7.9 7.9 8.0 8.0 8.0 7.9 7.9 8.1 8.1

PARAMETERS UNITS LIMITS 1 JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

Temp

- MA o F none 47 48 48 54 57 62 67 67 63 55 50 44.0 55.2

Temp

- DM o F none 52 53 53 63 65 71 74 72 69 60 64 51.0 62.3Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 91 of 145

I ntalco 2009 Water Pollutant Discharges

PARAMETERS UNITS LIMITS 1 JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

Flow

- MA MGD none 3.666 3.602 3.885 3.646 3.549 3.631 3.832 3.838 4.116 5.057 5.742 4.482 4.1

Flow

- DM MGD none 4.022 4.342 5.231 7.142 6.135 4.367 4.416 5.946 4.645 7.865 8.619 7.088 5.8

Al Production 11 tons/day none 532.6 521.9 514.6 506.8 495.4 481.4 485.3 485.8 485.2 487.7 497.6 499.3 499.5

Number of days in the month none 31 28.0 31.0 30 31 30 31.0 31 30 31 30 31 30.4

Al Production

- Maximum tons/mo

nth none 16511 14613 15953 15204 15357 14442 15044 15060 14556 15119 14928 15478

OUTFALL 002 12 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- MA mg/l 35 3 7.3 NA 13 NA NA NA NA 13.8 NA 10.4 11.9 NA 9.3

TSS

- DM mg/l 75 5.6 11.2 NA NA NA NA NA 13.8 NA 15.7 18 NA 12.9

FLUORIDE

- MA mg/l 35 12.4 12.5 NA NA NA NA NA 30.2 NA 25.6 21.1 NA 20.4

FLUORIDE

- DM mg/l 50 15.7 14.3 NA NA NA NA NA 30.2 NA 30.2 25.2 NA 23.1

ALUMINUM

- MA mg/l 10 1.9 3.1 NA NA NA NA NA 8.2 NA 7.1 5.5 NA 5.2

ALUMINUM

- DM mg/l 15 2.6 4.2 NA NA NA NA NA 8.2 NA 9.0 6.8 NA 6.2

B(a)P

- MA mg/l none <0.0001 01/14/09 NR 14 NR NR NR NR 01/14/09 NR 01/14/09 01/14/09 NR

B(a)P

- DM mg/l <0.01 <0.0001 01/14/09 NR NR NR NR NR 01/14/09 NR 01/14/09 01/14/09 NR

Copper

- MA ug/l none <0.003 01/14/09 NR NR NR NR NR 01/14/09 NR 01/14/09 01/14/09 NR

Copper

- DM ug/l none <0.003 01/14/09 NR NR NR NR NR 01/14/09 NR 01/14/09 01/14/09 NR

Free CN

- MA mg/l none <0.005 01/14/09 NR NR NR NR NR 01/14/09 NR 01/14/09 01/14/09 NR

Free CN

- DM mg/l none <0.005 01/14/09 NR NR NR NR NR 01/14/09 NR 01/14/09 01/14/09 NR

O & G

- MA mg/l 5 <1.4 <1.4 NR NR NR NR NR NR 14 NR NR NR NR

O & G

- DM mg/l 10 <1.4 <1.4 NR NR NR NR NR NR NR NR NR NR

pH

- Minimum std units ≥6 6.1 6.7 NA NA NA NA NA 6.6 NA 6.3 6.4 NA 6.4

pH

- Maximum std units ≤9 7.1 7.2 NA NA NA NA NA 7.6 NA 7.2 7.2 NA 7.3

Temp

- MA o F none 39 40 NA NA NA NA NA 65 NA 51 46 NA 48.2

Temp

- DM o F none 46 46 NA NA NA NA NA 75 NA 59 50 NA 55.2

Flow

- MA MGD none 2.510 0.711 NA NA NA NA NA 0.256 NA 0.955 1.868 NA 1.3

Flow

- DM MGD none 14.427 3.829 NA NA NA NA NA 2.74 NA 3.93 6.84 NA 6.4

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

BOD: 30

- day Avg lbs/day 22.4 8.3 3 6.4 3.9 2.8 1.2 0.5 0.8 0.7 1.6 3 3.1 2.9

BOD: 7

- day Avg lbs/day 32.4 17.1 5.3 11.7 5.3 6.1 2.1 0.6 1.6 1.1 2.5 5.3 4.7 5.3

BOD: 30

- day Avg mg/l 45.0 14.8 17.8 25 14.4 8.2 5.2 4.3 3.2 4.8 4.6 9.8 11.5 10.3

BOD: 7

- day Avg mg/l 65.0 34.0 31.0 32.0 17.0 11.0 8.3 5.3 3.4 8.0 5.2 25 18.0 16.5

TSS: 30

- day Avg lbs/day 22.4 7.9 3.3 5.4 4.2 6.4 1.6 0.7 1.9 1.7 2.2 4.1 2.7 3.5

TSS: 7

- day Avg lbs/day 32.4 15.6 4.0 7.2 6.2 12.4 2.8 1.2 3.6 4.6 3.5 6.5 3.8 6.0

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS: 30

- day Avg mg/l 45.0 12.9 20 22.4 16.5 16.6 7.1 6.1 7.9 9.3 6.4 11.4 9.6 12.2Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 92 of 145

I ntalco 2009 Water Pollutant Discharges

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS: 7

- day Avg mg/l 65.0 19.3 25.3 28.9 24.2 23.2 11.1 10.9 10.6 13.7 7.3 14.6 13.9 16.9

Fecal Coli: 30

- day Avg #/100ml

s 200 2.3 2.0 2.8 5.9 2.0 2 2.0 2.0 2.0 2.0 2.4 4.2 2.6

Fecal Coli: 7

- day Avg #/100ml

s 400 4 < 2 8.0 23 2 4 2 2 ND (<2) ND (<2) 4 8

pH

- Daily Min std units ≥6 6.6 6.8 6.7 6.7 6.7 6.8 6.7 6.7 6.6 6.6 6.6 6.6 6.7

pH

- Daily Max std units ≤9 7.3 7.2 7.1 7.1 7.1 7.1 7.0 7.0 7.0 6.9 6.8 7.0 7.1

Flow

- MA MGD none 0.060 0.026 0.028 0.030 0.026 0.023 0.013 0.021 0.013 0.038 0.039 0.03 0.029

Flow

- DM MGD none 0.097 0.077 0.075 0.043 0.067 0.031 0.016 0.059 0.040 0.07 0.057 0.046 0.057

% BOD Removal

- MA % 55%/65% 15 86 68.6 93.8 88.4 88.4 89.5 90.9 94.7 91.7 91.1 82.6 86 87.6

% TSS Removal

- MA % 55%/65% 15 95 80.7 97.4 94.2 89.2 93.0 94.9 95.3 94.2 97.1 94.2 93.7 93.2

# of personnel working onsite Number none 545 535 526 516 515 509 503 500 517 529 530 525 521

Date UV Tubes were cleaned Date 90 days 11/05/08 02/03/09 3/12/2009 4/17/09 5/29/09 6/24/09 6/24/09 8/13/09 8/13/09 10/14/09 10/14/09 12/17/09

UV Tubes Operating 7 day

avg Minimum of

12 14 14 14 14 14 14 14 14 14 14 14 14 14

Date UV Tubes were replace d Date Annually 01/15/09 01/15/09 01/15/09 01/15/09 01/15/09 01/15/09 07/02/09 7/2/09 7/2/09 7/2/09 7/2/09 7/2/09

Stormwater Pond UNITS Action Level JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 20 18.9 NS 16 14.1 12.2 13.7 NS NS 12.3 22.1 22.3 14.1 NS 16.2

FLUORIDE

- DM mg/l 35 23.2 NS 19 17.3 21.0 NS NS 32.8 33.2 26.8 23.8 NS 24.6

ALUMINUM

- DM mg/l 8 7.3 NS 5.6 4.4 6.4 NS NS 7.6 8.1 8.1 7.7 NS 6.9

pH

- Daily Min std units <6.0 6.5 6.8 6.6 6.4 6.7 6.9 7.1 6.7 6.6 6.4 6.8 6.9 6.7

pH

- Daily Max std units >9.0 7.8 7.7 7.5 7.6 7.7 7.6 7.5 7.4 7.3 7.2 7.7 7.7 7.6

Flow

- MA MGD none 0.260 0.066 0.372 0.365 0.352 0.054 0.071 0.132 0.127 0.693 1.084 0.336 0.3

Flow

- DM MGD none 1.714 0.437 1.360 3.631 2.194 0.437 0.409 2.337 0.679 2.749 4.212 1.503 1.8

Secondary Wastewater

Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 120 42.4 61.5 89.3 59.7 50.7 65.3 48.6 120 63.2 46.5 50.2 63.3 63.4

FLUORIDE

- DM mg/l 50 22.0 22.5 30.3 17.8 19.5 21.5 24.8 19.5 22.0 18.5 19.3 23.0 21.7

ALUMINUM

- DM mg/l none 0.2 0.3 0.2 0.1 0.3 10 6.3 0.5 0.2 0.4 0.3 0.1 1.6

FREE CN

- DM mg/l none <0.005 0.006 <0.005 0.006 0.006 0.005 0.005 0.006 ND

(<0.005) ND

(<0.005) ND

(<0.005) ND

(<0.005)

PCBs ppb none 10/30/08 <0.1 2/23/2009 2/23/2009 ND

(<0.08) 5/21/2009 5/21/2009 5/21/2009 ND

(<0.08) 9/14/2009 9/14/2009 ND

(<0.08)

Flow

- MA MGD none 0.0558 0.065 0.060 0.063 0.065 0.062 0.071 0.056 0.071 0.074 NR 0.078 0.066

Flow

- DM MGD none 0.140 0.117 0.134 0.121 0.122 0.118 0.135 0.118 0.118 0.149 NR 0.195 0.133

TSS mg/l none 256.1 37.3 74.5 59.3 1.1 278.6 10.4 12 49.9 2.8 1.7 42.2 68.8

FLUORIDE mg/l none 8.7 8.8 8.0 9.8 2.3 1.2 7.5 6.7 6.5 9.5 6.3 6.7 6.8Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 93 of 145

I ntalco 2009 Water Pollutant Discharges

Secondary Wastewater

Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

ALUMINUM mg/l none 7.0 1.7 3.0 1.4 0.10 3.3 2.2 0.8 0.6 0.9 0.3 0.7 1.8

Outfall 012 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS mg/l none 72.6 33.7 22.4 29.9 3.6 71.7 50.3 18.8 21.9 10.4 26.3 400.5 63.5

FLUORIDE mg/l none 3.8 11.7 3.8 10.3 3.0 1.7 3.1 1.9 4.5 3.7 8.7 5 5.1

ALUMINUM mg/l none 5.4 6.2 4.7 5.1 1.9 2.9 1.2 0.6 2.3 1.2 6.4 4.3 3.5

1 LIMITS for modified NPDES permit issued on June 15, 2008 (effective July 15, 2008).

2 Monthly average (MA) effluent limitation is defined as the highest allowable average of daily dischar ges over a calendar month, calculated as the sum of all daily discharges measured during a calendar month divided by the

number of daily discharges measured during that month.

3 SW allocation Monthly Average limit.

4 DNTA: Did not take stormwater allocation.

5 Daily maximum (DM) effluent limitation is defined as the highest allowable daily discharge. The daily discharge means the di scharge of a pollutant measured during a calendar day. For pollutants with limitations

expressed in units of mass, the daily discharge is calculated as the total mass of the pollutant discharged over the day. For other units of measurement , the daily discharge is the average measurement of the pollutant over the

day. The pH shall not be averaged.

6 SW allocation Daily Max limit.

7 Tiered limit, applies when monthly aluminum production is less than or equal to 10,305 tons.

8 Tiered limit, applies when monthly aluminum production is greater than 10,305 and less than or equal to 15,614 tons.

9 Tiered limit, applies when monthly aluminum production is greater than 15,614 tons.

10 ND = Nondetect.

11 The monthly average of daily production.

12 Intalco notified Ecology (in a letter dated February 27, 2009) that they had completed the diversion structure to divert all flow from Outfall 002 into Outfall 001.

13 NA

= No discharge through outfall 002 because the hydraulic capacity at 001 was not exceeded.

14 NR

= After the diversion Intalco is not required to monitor this parameter at Outfall 002.

15 The limit is 55 % if there are <400 people working onsite and the limit is 65% if there are > 400 people working on site.

16 NS

= Not sampled because the stormwater pond discharge never exceeded 3.7 cfs over any consecutive 120 minute period.

Intalco 2010 Water Pollutant Discharges

PARAMETERS

UNITS LIMITS 1 JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG OUTFALL 001

TSS

- MA 2 lbs/day 150 335.8 57.4 156.3 326.1 14.4 40.2 16.8 214.1 140.5 42.8 168.0 84.6

TSS

- Stormwa ter Allocation

(SWA) 3 lbs/day Calculated 3 573.4 DNTA 4

401.1 263.9 DNTA DNTA DNTA 283.7 DNTA DNTA 507.4 DNTA

TSS

- DM 5 lbs/day 185 713.4 203.8 597.8 410.1 68.5 146.4 67.0 1053.6 277.5 144.3 393.2 208.8Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 94 of 145

Intalco 2010 Water Pollutant Discharges

OUTFALL 001 UNITS LIMITS 1 JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- Stormwater Allocation

(SWA) 6 lbs/day Calculated 6 4097.5 1816.3 2328.8 291.3 DNTA DNTA DNTA 1616.3 785.0 DNTA 2666.3 1947.5

FLUORIDE

- MA lbs/day 58 7 /68 8 /68 9 284.9 125.1 140.3 48.7 46.7 63.5 6.3 187.5 174.7 53.1 157.9 109.6

FLUORIDE

- SWA 3 lbs/day Calculated 3 491.4 301.6 319.1 DNTA DNTA DNTA DNTA 201.7 117.8 DNTA 169.6 162.4

FLUORIDE

- DM lbs/day 140 7 /198 8 /296 9 654.4 267.9 378.1 32.4 149.6 150.6 19.9 809.8 349.2 149.6 342.7 258.6

FLUORIDE

- SWA 6 lbs/day Calculated 6 2906.4 1286.4 1726.3 DNTA DNTA DNTA DNTA 1250.9 696.3 DNTA 1951.5 DNTA

ALUMINUM

- MA lbs/day 5.9 7 /9.0 8 /10.3 9 77.6 20.9 36.4 13.5 6.3 11.0 0.3 42.7 37.6 8.6 30.5 9.0

ALUMINUM

- SWA 3 lbs/day Calculated 3 130.7 75.4 81.7 42.7 DNTA 47.7 DNTA 48.3 60.1 DNTA 111.9 DNTA

ALUMINUM

- DM lbs/day 13.4 7 /20 8 /30 9 184.5 55.7 117.7 18.2 27.7 26.0 0.0 213.7 85.0 30.0 64.3 75.7

ALUMINUM

- SWA 6 lbs/day Calculated 6 812.5 346.3 458.8 DNTA DNTA DNTA DNTA 316.3 150.0 115.0 526.3 382.5

FREE CN

- MA mg/l <0.012 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 < 0.005

FREE CN

- DM mg/l 0.012 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005

B(a)P

- MA lbs/day 0.02 7 /0.03 8 / 0.045 9 0.028 1/25/10 1/25/10 1/25/10 0.008 5/26/10 5/26/10 5/26/10 0.023 9/16/10 9/16/10 0.009

B(a)P

- SWA 3 lbs/day Calculated 3 DNTA 1/25/10 1/25/10 1/25/10 DNTA 5/26/10 5/26/10 5/26/10 DNTA 9/16/10 9/16/10 DNTA

B(a)P

- DM 4 lbs/day 0.043 7 /0.065 8 /0.098 9 0.028 1/25/10 1/25/10 1/25/10 0.008 5/26/10 5/26/10 5/26/10 0.023 9/16/10 9/16/10 0.009

B(a)P

- SWA 6 lbs/day Calculated 6 DNTA 1/25/10 1/25/10 1/25/10 DNTA 5/26/10 5/26/10 5/26/10 DNTA 9/16/10 9/16/10 DNTA

ANTIMONY

- MA lbs/day 1.9 7 /2.9 8 /4.3 9 0.060 1/25/10 1/25/10 1/25/10 0.00 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 0.1

ANTIMONY

- DM lbs/day 4.2 7 /6.4 8 /9.6 9 0.060 1/25/10 1/25/10 1/25/10 0.00 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 0.1

NICKEL

- MA lbs/day 0.8 7 /1.2 8 /1.9 9 1.52 1/25/10 1/25/10 1/25/10 3.78 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 1.7

NICKEL

- DM lbs/day 1.2 7 /1.8 8 /2.7 9 1.52 1/25/10 1/25/10 1/25/10 3.78 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 5/26/10 1.7

C0PPER

- DM ug/l none <0.003 1/25/10 1/25/10 1/25/10 1/25/10 1/25/10 1/25/10 1/25/10 1/25/10 1/25/10 1/25/10 1/25/10

O & G

- MA mg/l 5 <1.0 <2.5 <0.87 <2.5 <0.87 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <0.6

O & G

- DM mg/l 10 <1.0 <2.5 <0.87 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <0.6

pH

- Daily Min std units ≥6 6.9 7.0 6.9 7.1 6.7 6.8 7.6 7.2 6.8 6.9 6.8 6.5 6.9

pH

- Daily Max std units ≤9 8.0 8.7 8 8.0 8.0 8.0 8.1 8.2 8.3 8.2 8.0 8.1 8.1

Temp

- MA o F none 47 49 52 54 57 60 65 67 63 58 47 45 55.3

Temp

- DM o F none 52 52 56 59 6.805 65 74 74 70 67 59 53 57.3

Flow

- MA MGD none 5.238 3.602 4.765 4.325 4.452 4.349 3.030 1.018 1.312 0.889 1.480 2.301 3.1

Flow

- DM MGD none 10.125 4.746 7.784 5.198 6.805 6.877 4.343 3.531 4.012 2.789 5.105 8.937 5.9

Al Production 10 tons/day none 513.2 526.8 533.4 538.3 550.4 561.1 544.7 540.6 548 547 551 542 541.4

Number of days in the month none 31 28 31 30 31 30 31 31 30 31 30 31 30.4

Al Production

- Maximum tons/month none 15909 14750 16535 16149 17062 16833 16886 16759 16440 16957 16530 16802 16467.7

OUTFALL 002 11 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

TSS

- MA mg/l 35 9.5 12.1 NA 12 NA 19.3 NA NA 18.6 10.1 13.1 12.2 21.2 14.5

OUTFALL 002 11 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVE

TSS

- DM mg/l 75 9.5 12.1 NA NA 19.3 NA NA 18.6 12.3 13.1 12.5 21.2 14.8Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 95 of 145

Intalco 2010 Water Pollutant Discharges

OUTFALL 002 11 UNITS LIMITS JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVE

FLUORIDE

- MA mg/l 35 16.3 18.7 NA NA 29.5 NA NA 33.2 28.3 27.3 26.7 18.7 24.8

FLUORIDE

- DM mg/l 50 16.3 18.7 NA NA 29.5 NA NA 33.2 28.7 27.3 27.7 18.7 25.0

ALUMINUM

- MA mg/l 10 4.8 4.8 NA NA 9.6 NA NA 9.9 7.8 6.5 7.4 5.8 7.1

ALUMINUM

- DM mg/l 15 4.8 4.8 NA NA 9.6 NA NA 9.9 8.0 6.5 8.0 5.8 7.2

pH

- Minimum std units ≥6 6.5 6.8 NA NA 6.7 NA NA 7.0 6.6 6.9 6.9 6.3 6.7

pH

- Maximum std units ≤9 7.2 7.3 NA NA 7.7 NA NA 7.8 7.2 7.7 7.4 7.3 7.5

Temp

- MA o F none 43 44 NA NA 56 NA NA 65 NR 59.3 51.7 46.3 45.7

Temp

- DM o F none 48 50 NA NA 64 NA NA 73 66 60.5 53.7 47.8 57.9

Flow

- MA MGD none 1.448 0.8 NA NA 0.540 NA NA NR NR 0.321 0.788 1.818 0.7

Flow

- DM MGD none 6.26 2.61 NA NA 3.52 NA NA 2.29 3.80 2.01 3.97 8.18 4.1

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

BOD: 30

- day Avg lbs/day 22.4 8.5 6.6 7.2 4.1 1.6 2.0 1.7 0.6 2.1 1.2 0.9 7.1 3.6

BOD: 7

- day Avg lbs/day 32.4 16.2 9.7 8.6 5.7 3.1 3.6 2.5 1 3.6 1.5 1.2 8.3 5.4

BOD: 30

- day Avg mg/l 45.0 23.5 29.8 28.2 15.3 9.5 9.1 5.1 6.3 5.7 3.9 3.4 11.8 12.6

BOD: 7

- day Avg mg/l 65.0 33.0 44.0 32.0 20.0 13.0 13.0 6.1 7.8 10.0 4.8 4.4 14.0 16.8

TSS: 30

- day Avg lbs/day 22.4 7 5.3 4.3 3 0.4 1.6 2.2 0.5 8.6 0.5 1.000 3.4 3.2

TSS: 7

- day Avg lbs/day 32.4 10.3 9.4 6.6 5.2 0.9 4.1 4.7 1.7 18.6 0.9 2 4.4 5.7

TSS: 30

- day Avg mg/l 45.0 20.4 24 16.7 12.6 2.3 6.7 6.3 4.6 20.7 1.5 3.9 6.0 10.5

TSS: 7

- day Avg mg/l 65.0 25.3 42.7 24.4 27.9 3.2 9.5 11.4 12.5 52.1 1.9 7.9 8.2 18.9

Fecal Coli: 30

- day Avg #/100mls 200 27.6 5.7 2.0 2.6 3.1 5 2.3 2.0 3.9 2.0 5.0 25.4 7.2

Fecal Coli: 7

- day Avg #/100mls 400 50 130 <2 4 11 60 4 <2 7 2 80 50

pH

- Daily Min std units ≥6 6.52 6.61 6.67 6.7 6.7 6.71 6.67 6.61 6.60 6.91 6.73 6.53 6.7

pH

- Daily Max std units ≤9 7.07 6.97 7.00 7.00 7.1 7.0 6.9 7.00 7.82 7.59 7.30 7.36 7.2

Flow

- MA MGD none 0.042 0.025 0.031 0.033 0.024 0.027 0.038 0.036 0.183 0.135 0.047 0.065 0.1

Flow

- DM MGD none 0.061 0.030 0.051 0.049 0.045 0.0363 0.054 0.065 0.269 0.203 0.17 0.11 0.1

% BOD Removal

- MA % 55%/65% 13 88.2 85.5 89.8 84.3 87.6 91.6 89.9 88.3 85.0 91.1 98.3 87.9 89.0

% TSS Removal

- MA % 55%/65% 13 89.9 93.0 93.6 88.9 97 95.3 90.9 92.5 78.5 96.9 99.1 93.7 92.4

# of personnel working

onsite Number

none 526 521 521 520 530 529 520 526 522 522 526 526 524.1

Date UV Tubes were cleaned Date once every 90 days 01/07/10 02/08/10 03/15/10 04/20/10 05/26/10 06/23/10 07/22/10 08/24/10 09/26/10 10/25/10 10/28/10 12/16/10

UV Tubes Operating 7 day avg Minimum of 12 14 14 14 14 14 14 14 14 14 14 14 14 14

Date UV Tubes were

replaced Date Annually

07/02/09 02/11/10 02/11/10 02/11/10 02/11/10 02/11/10 07/01/10 07/01/10 07/01/10 07/01/10 07/01/10 12/29/10

Stormwater Pond UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

TSS

- DM mg/l 20 15.9 17.9 19.0 14.8 23.6 15.9 NS 14 28.5 35.6 20.3 15.4 32.4 21.8

FLUORIDE

- DM mg/l 35 19 21.2 22.2 21.3 25.8 25.2 NS 35.0 30.5 26.7 27.8 18.5 24.8Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 96 of 145

Intalco 2010 Water Pollutant Discharges

Stormwater Pond UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

ALUMINUM

- DM mg/l 8 6.8 5.1 6.2 5.1 8.3 7.1 NS 12.7 10.6 7.3 8.1 7.8 7.7

pH

- Daily Min std units <6.0 6.8 6.9 7.0 7 6.8 6.8 6.9 6.9 6.6 6.7 6.8 6.5 6.8

pH

- Daily Max std units >9.0 7.4 7.4 7.5 7.5 7.4 7.3 7.6 7.6 7.1 7.3 7.6 7.5 7.4

Flow

- MA MGD none 0.772 0.461 0.499 0.253 0.348 0.302 0.059 0.141 0.542 0.224 0.435 0.820 0.4

Flow

- DM MGD none 3.160 1.547 1.845 0.654 1.979 1.432 0.065 1.984 2.391 1.722 2.750 4.322 2.0

Secondary Wastewater

Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

TSS

- DM mg/l 120 83.2 42.4 104.5 91.2 44.8 17.4 38.6 28.1 33.2 21.7 75.0 40 51.7

FLUORIDE

- DM mg/l 50 30.8 22.5 21.5 23.3 24.8 20.5 24.8 23.3 20.0 19.0 22.3 23.5 23.0

ALUMINUM

- DM mg/l none 0.2 0.1 0.1 0.6 0.3 0.2 0.2 0.4 0.1 0.2 0.3 1.9 0.4

FREE CN

- DM mg/l none <0.005 <0.005 0.006 0.005 <0.005 <0.005 0.007 <0.005 0.006 <0.005 0.006 <0.005

PCBs ppb none <0.1 1/25/10 1/25/10 1/25/10 1/25/10 5/26/10 5/26/10 5/26/10 <1 9/16/10 9/16/10 <3.36

Flow

- MA MGD none 0.084 0.060 0.086 0.060 0.073 0.081 0.069 0.066 0.066 0.061 0.061 0.071 0.1

Flow

- DM MGD none 0.190 0.184 0.199 0.202 0.209 0.230 0.215 0.19 0.173 0.172 0.159 0.201 0.2

Outfall 011 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

TSS

- Monthly grab when

there is flow mg/l none 68.3 13.5 56.3 16.1 82.2 4.1 0.6 48.5 43.3 9.7 4.6 125.3 39.4

FLUORIDE

- Monthly grab

when there is flow mg/l none 8.0 6.0 5.2 8.2 8.7 7.3 2.2 6.8 8.5 8.0 7.1 7.0 6.9

ALUMINUM

- Monthly

grab when there is flow mg/l none 3.0 0.7 1.5 1.5 2.0 0.8 0.1 5.6 1.2 2.1 1.2 12.0 2.6

Outfall 012 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC AVG

TSS

- Monthly grab when

there is flow mg/l none 11.3 5.6 49.9 11 31.0 12.2 IF 15 145.1 8.6 4.3 1.6 111.7 35.6

FLUORIDE

- Monthly grab

when there is flow mg/l none 3.0 4.5 1.5 2.2 2.3 3.8 IF 2.4 3.3 10.4 7.0 3.6 4.0

ALUMINUM

- Monthly

grab when there is flow mg/l none 2.5 6.2 4.3 1.5 2.1 1.9 IF 2.9 0.8 5.8 2.9 12.0 3.9

1 LIMITS for modified NPDES permit issued on June 15, 2008 (effective July 15, 2008).

2 Monthly average (MA) effluent limitation is defined as the highest allowable average of daily discharges over a calendar month, calculated as the sum of all daily discharges measured during a calendar month divided by

the number of daily discharges measured during that month.

3 SW allocation Monthly Average limit.

4 DNTA: Did not take stormwater allocation.

5 Daily maximum (DM) effluent limitation is defined as the highest allowable daily discharge. The daily discharge means the di scharge of a pollutant measured during a calendar day. For pollutants with limitations

expressed in units of mass, the daily disch arge is calculated as the total mass of the pollutant discharged over the day. For other units of measurement, the daily dis charge is the average measurement of the pollutant over the

day. The pH shall not be averaged.

6 SW allocation Daily Max limit.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 97 of 1 45

Intalco 2010 Water Pollutant Discharges

7 Tiered limit, applies when monthly aluminum production is less than or equal to 10,305 tons.

8 Tiered limit, applies when monthly aluminum production is greater than 10,305 and less than or equal to 15,614 tons.

9 Tiered limit, applies when monthly aluminum production is greater than 15,614 tons.

10 The monthly average of daily production.

11 Intalco notified Ecology (in a letter dated February 27, 2009) that they had completed the diversion structure to divert all flow from Outfall 002 into Outfall 001.

12 NA = No discharge through outfall 002 because the hydraulic capacity at 001 was not exceeded.

13 The limit is 55 % if there are <400 people working onsite and the limit is 65% if there are > 400 people working on site.

14 NS

= Not sampled because the stormwater pond discharge never exceeded 3.7 cfs over any consecutive 120 minute period.

15 IF

= Insufficient flow to collect a representative sample.

Intalco 2011 Water Pollutant Discharges

PARAMETERS

UNITS LIMITS 1 JAN FEB MAR APR MAY JUNE JULY AUG SEPT OCT NOV DEC AVG

OUTFALL 001

TSS

- MA 2 lbs/day 150 158.5 50.1 51.1 259.4 113.3 9.1 0.0 28.0 15.8 99.1 70.8 37.8

TSS

- Stormwater Allocation

(SWA) 3 lbs/day Calculated 3 784.2 DNTA 4

309.4 777.8 DNTA DNTA DNTA DNTA DNTA DNTA DNTA DNTA

TSS

- DM 5 lbs/day 185 634.2 165.8 148.1 762 386.9 32.2 0.0 140.2 63.0 337.4 105.7 79.2

TSS

- Stormwater Allocation

(SWA) 6 lbs/day Calculated 6 4847.5 DNTA DNTA 4272.5 1491.3 DNTA DNTA DNTA DNTA 497.5 DNTA DNTA

FLUORIDE

- MA lbs/day 58 7 /68 8 /68 9 180.5 94.3 83.1 235.8 101.7 42.2 32.1 66.8 26.7 93.4 97.6 50.3

FLUORIDE

- SWA 3 lbs/day Calculated 3 248.3 125.8 113.3 246.5 125.1 DNTA DNTA DNTA DNTA 118.8 161.4 DNTA

FLUORIDE

- DM lbs/day 140 7 /198 8 /296 9 562.7 143.7 180.8 617.8 195.7 44.8 7.8 115.2 62.9 261.5 141.6 89.7

FLUORIDE

- SWA 6 lbs/day Calculated 6 3406.8 DNTA DNTA 3023.2 DNTA DNTA DNTA DNTA DNTA DNTA DNTA DNTA

ALUMINUM

- MA lbs/day 5.9 7 /9.0 8 /10.3 9 42.8 11.5 14.4 77.4 26.2 1.1 0.3 4.2 1.5 14.9 19.3 8.0

ALUMINUM

- SWA 3 lbs/day Calculated 3 190.6 66.8 55.6 188.8 67.4 DNTA DNTA DNTA DNTA 24.7 36.9 29.4

ALUMINUM

- DM lbs/day 13.4 7 /20 8 /30 9 162.6 31.0 49.4 206.5 94.5 4.7 0.0 8.7 5.2 62.1 33.6 19.9

ALUMINUM

- SWA 6 lbs/day Calculated 6 962.5 161.3 167.5 847.5 291.3 DNTA DNTA DNTA DNTA 92.5 87.5 DNTA

FREE CN

- MA 2 mg/l <0.012 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.001 0.0 <0.005 <0.00 <0.0024

FREE CN

- DM 3 mg/l 0.012 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 0.004 0.005 <0.0024 <0.005 <0.0024

B(a)P

- MA lbs/day 0.02 7 /0.03 8 / 0.045 9 12/15/10 12/15/10 0.002 3/15/11 0.009 0.002 5/18/11 5/18/11 0.007 0.015 10/3/11 10/3/11

B(a)P

- SWA 3 lbs/day Calculated 3 12/15/10 12/15/10 DNTA 3/15/11 DNTA DNTA 5/18/11 5/18/11 DNTA DNTA 10/3/11 10/3/11Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 98 of 145

Intalco 2011 Water Pollutant Discharges

OUTFALL 001 UNITS LIMITS 1 JAN FEB MAR APR MAY JUN JULY AUG SEPT OCT NOV DEC AVG

B(a)P

- DM 4 lbs/day 0.043 7 /0.065 8 /0.098

9 12/15/10 12/15/10 0.002 3/15/11 0.009 0.002 5/18/11 5/18/11 0.007 0.015 10/3/11 10/3/11

B(a)P

- SWA 6 lbs/day Calculated 6 12/15/10 12/15/10 DNTA 3/15/11 DNTA DNTA 5/18/11 5/18/11 DNTA DNTA 10/3/11 10/3/11

ANTIMONY

- MA lbs/day 1.9 7 /2.9 8 /4.3 9 0.010 1/10/11 1/10/11 1/10/11 0.017 0.04 0.03 7/18/11 7/18/11 0.02 10/3/11 10/3/11

ANTIMONY

- DM lbs/day 4.2 7 /6.4 8 /9.6 9 0.010 1/10/11 1/10/11 1/10/11 0.017 0.04 0.03 7/18/11 7/18/11 0.02 10/3/11 10/3/11

NICKEL

- MA lbs/day 0.8 7 /1.2 8 /1.9 9 0.38 1/10/11 1/10/11 1/10/11 0.4268 0.77 0.71 7/18/11 7/18/11 0.30 10/3/11 10/3/11

NICKEL

- DM lbs/day 1.2 7 /1.8 8 /2.7 9 0.38 1/10/11 1/10/11 1/10/11 0.4268 0.77 0.71 7/18/11 7/18/11 0.30 10/3/11 10/3/11

C0PPER

- DM 3 ug/l none 0.00 1/10/11 1/10/11 1/10/11 1/10/11 4.5 6/22/11 6/22/11 6/22/11 3 10/3/11 10/3/11

O & G

- MA 2 mg/l 5 <0.6 <1.4 <2.9 3.1 2.2 <1.4 <1.4 <1.4 <1.40 <1.4 <1.0 3.3

O & G

- DM 3 mg/l 10 <1.4 <1.4 <2.9 3.1 4.4 <1.4 <1.4 <1.4 <1.40 <1.4 <1.0 3.3

pH

- Daily Min std units ≥6 6.6 6.6 7.0 7.1 6.9 7.5 7.1 7.2 7.1 7.04 6.8 7.0 7.0

pH

- Daily Max std units ≤9 8.2 8.3 8.2 8.2 8.2 8.2 8.2 8.2 8.3 8.1 8.0 7.8 8.2

Temp

- MA o F none 42 43 47 51 56 60 62 66 64 56 48 43 53.2

Temp

- DM o F none 49 49 56 64 62 68 73 72 76 64 57 51 61.8

Flow

- MA MGD none 3.405 1.688 1.779 2.024 1.675 0.906 1.045 1.008 1.047 1.071 1.483 1.133 1.5

Flow

- DM MGD none 8.604 5.486 8.633 8.370 5.698 1.648 3.094 1.273 2.431 2.001 4.938 3.483 4.6

Al Production 10 tons/day none 536 557 640.0 650 668 662 662 662 671 655 650 637 637.5

Number of days in the month none 31 28 31 30 31 30 31 31 30 31 30 31 30.4

Al Production

- Maximum tons/mont

h none 16616 15596 19840 19500 20708 19860 20522 20522 20130 20305 19500 19747 19403.

8

OUTFALL 002 11 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- MA mg/l 35 11.8 12.9 16.7 15.8 NA 12 NA 17 NA NA NA 34.3 NA 18.1

TSS

- DM mg/l 75 15.7 12.9 17.4 15.8 NA NA 17 NA NA NA 34.3 NA 18.9

FLUORIDE

- MA mg/l 35 16.4 16 19.4 16.7 NA NA 29.7 NA NA NA 29.7 NA 21.3

FLUORIDE

- DM mg/l 50 25.5 16 22.3 16.7 NA NA 29.7 NA NA NA 29.7 NA 23.3

ALUMINUM

- MA mg/l 10 4.3 3.5 5.8 3.6 NA NA 6.8 NA NA NA 12.9 NA 6.2

ALUMINUM

- DM mg/l 15 6.0 3.5 5.9 3.6 NA NA 6.8 NA NA NA 12.9 NA 6.5

pH

- Minimum std units ≥6 6.5 6.2 6.8 6.8 NA NA 6.5 NA NA NA 6.4 NA 6.5

pH

- Maximum std units ≤9 7.2 7.4 7.4 7.3 NA NA 7.4 NA NA NA 7.2 NA 7.3

Temp

- MA o F none 47.8 43.3 49.8 52.1 NA NA 69.2 NA NA NA 42.5 NA 50.8

Temp

- DM o F none 46.5 45.1 53.9 99 NA NA 70.8 NA NA NA 47.9 NA 60.5

Flow

- MA MGD none 2.700 1.004 0.936 1.091 NA NA 0.23 NA NA NA 0.670 NA 1.1

Flow

- DM MGD none 8.06 4.13 7.72 6.54 NA NA 1.97 NA NA NA 4.55 NA 5.5

BOD

- MA lbs/day 22.4 8.3 8.6 8.3 9.2 6.3 3.2 2.1 1.2 1 1.8 2.0 4.0 4.7Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 99 of 145

Intalco 2011 Water Pollutant Discharges

Saintary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

BOD

- DM lbs/day 32.4 16.8 12.8 15.1 12.6 10.8 9.0 3.2 1.8 1.9 2.2 3.0 8.6 8.2

BOD

- MA mg/l 45.0 12.2 16 18.4 19.5 13.8 12.1 9.6 5.3 6.1 5.7 11.1 11.8

BOD

- DM mg/l 65.0 22.0 20.0 24.0 29.0 26 18 12.0 7.2 7.6 8.3 8.4 15.0 16.5

TSS

- MA lbs/day 22.4 7.3 6.8 6.9 8.2 7.9 1.7 2.3 2.1 0.7 2.4 1.5 2.5 4.2

TSS

- DM lbs/day 32.4 13.7 8.6 14.3 15.7 22.6 4 3.7 5.2 0.9 3.3 3.0 5.2 8.4

TSS

- MA mg/l 45.0 10.9 13.1 15.1 17.9 18.0 9.6 10.3 10.9 4 7.9 3.7 9.7 10.9

TSS

- DM mg/l 65.0 17.9 15.5 22.7 36.2 54.5 20.9 13.4 27.9 6.2 12.3 6.5 19.6 21.1

Fecal Coli.

- MA #/100mls 200 36.2 21.0 4.3 4.0 24.1 11.5 2.0 2.0 2.0 2.0 2.0 2.0 9.4

Fecal Coli.

- DM #/100mls 400 300 110 22 8 240 240 <2 <2 <2 <2 <2 <2

pH

- Minimum std units ≥6 6.68 6.68 6.54 6.58 6.54 6.16 6.10 6.32 6.14 6.25 6.22 6.27 6.4

pH

- Maximum std units ≤9 7.44 7.26 7.47 7.36 7.3 7.0 6.91 6.93 7.00 6.76 6.50 7.10 7.1

Flow

- MA MGD none 0.069 0.056 0.050 0.055 0.053 0.027 0.029 0.025 0.022 0.034 0.037 0.037 0.0

Flow

- DM MGD none 0.09 0.090 0.08 0.07 0.070 0.06 0.08 0.050 0.03 0.04 0.08 0.08 0.1

% BOD Removal

- MA % 55%/65% 13 82.7 79.8 89.1 79.8 81.1 82.8 85.6 90.9 88.3 88.4 89.6 80.8 84.9

% TSS Removal

- MA % 55%/65% 13 87.1 78.4 91.7 87.3 83.7 81.0 86.0 87.8 93.1 89.1 95.5 85.0 87.1

Personnel Onsite # of

personnel > 400 572 582 604 616 604 608 611 620 614 614 597 603 603.8

Date UV Tubes were cleaned Date once/90 days 01/17/11 02/09/11 03/03/11 04/20/11 05/03/11 06/21/11 06/21/11 06/21/11 09/06/11 10/05/11 06/21/11 12/13/11

UV Tubes Operating Number 12.0 14 14 14 14 14 14 14 14 14 14 14 14 14.0

Date UV Tubes were replaced Date Annually 12/29/10 12/29/10 12/29/10 12/29/10 12/29/10 06/21/11 06/21/11 06/21/11 06/21/11 06/21/11 06/21/11 06/21/11

Stormwater Pond UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 20 21.1 22.6 22.8 16.9 24.4 NS 14 39.0 NS NS 14.1 51.0 5 28.4

FLUORIDE

- DM mg/l 35 17.3 19.3 19.5 17.9 29.0 NS 35.0 NS NS 38.3 40.8 28.2 31.1

ALUMINUM

- DM mg/l 8 7.1 5.9 7.8 5.7 8.9 NS 11.4 NS NS 9.2 17 8.8 10.4

pH

- Daily Min std units <6.0 6.6 6.8 6.8 6.7 6.8 6.8 6.8 6.9 6.6 6.7 6.4 6.6 6.7

pH

- Daily Max std units >9.0 7.5 7.6 7.4 7.4 7.2 7.5 7.4 7.3 7.0 7.3 7.3 7.2 7.3

Flow

- MA MGD none 0.949 0.332 0.45 0.536 0.476 0.106 0.158 0.103 0.071 0.186 0.401 0.223 0.3

Flow

- DM MGD none 2.808 1.399 3.631 3.079 2.414 0.585 1.524 0.322 0.072 0.965 2.964 1.431 1.8

Secondary Wastewater

Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 120 70.4 37.8 66.0 42.1 129.0 96.2 64.8 137.9 131.4 86.4 58.0 59.2 81.6

FLUORIDE

- DM mg/l 50 23.0 28.5 26.8 24.5 27.5 30.3 23 29.0 24.3 23.3 25.0 27.5 26.1

ALUMINUM

- DM mg/l none 0.8 0.8 14.0 5.8 0.2 0.2 0.2 0.1 0.1 0.0 0.1 0.2 1.9

FREE CN

- DM mg/l none <0.005 0.005 0.007 <0.005 <0.005 <0.005 <0.005 <0.005 0.007 0.006 0.007 0.013

PCBs ppb none 12/15/10 12/15/10 1/5/11 1/5/11 <0.7 5/18/11 5/18/11 5/18/11 <0.1 9/8/11 <0.1 11/2/11

Flow

- MA MGD none 0.081 0.079 0.062 0.062 0.075 0.076 0.057 0.061 0.079 0.070 0.055 0.059 0.1Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 100 of 145

Intalco 2011 Water Pollutant Discharges

Secondary Wastewater

Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

Flow

- DM MGD none 0.208 0.177 0.225 0.188 0.199 0.193 0.174 0.184 0.200 0.203 0.174 0.137 0.2

Outfall 011 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- Monthly grab when

there is flow mg/l none 5.7 49.0 1157.4 100.7 424.7 169.6 15.7 19.6 27.0 251.3 101.5 230.5 212.7

FLUORIDE

- Monthly grab

when there is flow mg/l none 5.9 6.8 13.9 9.3 6.4 6.2 6.4 9.7 6.7 10.0 7.8 12.6 8.5

ALUMINUM

- Monthly grab

when there is flow mg/l none 0.7 0.9 65.0 6.1 14.0 1.5 1.3 2 0.9 25.7 10.0 28.3 13.0

Outfall 012 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- Monthly grab when

there is flow mg/l none 32.1 79.7 468.2 32 57.0 169.6 227.5 18.6 6.4 55.6 24.2 29.7 100.1

FLUORIDE

- Monthly grab

when there is flow mg/l none 10.7 5.2 11.7 8.3 2.5 6.2 2.4 11.7 2.3 3.2 1.1 5.1 5.9

ALUMINUM

- Monthly grab

when there is flow mg/l none 4.9 7.5 43.0 8.1 3.8 1.5 2.7 6.2 1.5 12.2 6.7 1.8 8.3

1 LIMITS for modified NPDES permit issued on June 15, 2008 (effective July 15, 2008).

2 Monthly average (MA) effluent limitation is defined as the highest allowable average of daily discharges over a calendar mont h, calculated as the sum of all daily discharges measured during a calendar month divided by the

number of daily discharges measured during that month.

3 SW allocation Monthly Average limit.

4 DNTA: Did not take stormwater allocation because they were in compliance with the respective permit limit.

5 Daily maximum (DM) effluent limitation is defined as the highest allowable daily discharge. The daily discharge means the di scharge of a pollutant measured during a calendar day. For pollutants with limitations

expressed i n units of mass, the daily discharge is calculated as the total mass of the pollutant discharged over the day. For other uni ts of measurement, the daily discharge is the average measurement of the pollutant over the

day. The pH shall not be averaged.

6 SW allocation Daily Max limit.

7 Tiered limit, applies when monthly aluminum production is less than or equal to 10,305 tons.

8 Tiered limit, applies when monthly aluminum production is greater than 10,305 and less than or equal to 15,614 tons.

9 Tiered limit, applies when monthly aluminum production is greater than 15,614 tons.

10 The monthly average of daily production.

11 Intalco notified Ecology (in a letter dated February 27, 2009) that they had completed the diversion structure to divert all flow from Outfall 002 into Outfall 001.

12 NA = No discharge through outfall 002 because the hydraulic capacity at 001 was not exceeded.

13 The limit is 55 % if there are <400 people working onsite and the limit is 65% if there are > 400 people working on site.

14 NS

= Not sampled because the stormwater pond discharge never exceeded 3.7 cfs over any consecutive 120 minute period.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 101 of 145

Intalco 2012 Water Pollutant Discharges

PARAMETERS

UNITS LIMITS 1 JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

OUTFALL 001

TSS

- MA 2 lbs/day 150 107.5 82.6 86.2 68.1 109.3 40.5 31.9 52.2 29.2 189.3 140.9 116.6

TSS

- Stormwater Allocation (SWA) 3 lbs/day Calculated 3 DNTA 4 DNTA DNTA DNTA DNTA DNTA DNTA DNTA DNTA 429.2 DNTA DNTA

TSS

- DM 5 lbs/day 185 278 156.0 134.5 136.5 219.5 81.3 87.4 182.6 84.8 464.6 477.6 226.5

TSS

- Stormwater Allocation (SWA) 6 lbs/day Calculated 6 803.8 DNTA DNTA DNTA 728.8 DNTA DNTA DNTA DNTA 1853.8 1647.5 3197.5

FLUORIDE

- MA lbs/day 58 7 /68 8 /68 9 112.4 187.2 210.5 134.5 107.5 58.8 78.7 33.1 78.1 319.4 249 225.6

FLUORIDE

- SWA 3 lbs/day Calculated 3 241.4 368.8 544 257.2 131.5 DNTA 113.6 DNTA 90.6 347.2 452 686.3

FLUORIDE

- DM lbs/day 140 7 /198 8 /296 9 151.5 428.3 519.1 205.3 249.1 90.1 177.4 87.2 154.0 665.4 427.2 350

FLUORIDE

- SWA 6 lbs/day Calculated 6 DNTA 1342.7 2122.5 DNTA DNTA DNTA DNTA DNTA DNTA 1409.4 1271.8 2305.9

ALUMINUM

- MA lbs/day 5.9 7 /9.0 8 /10.3 9 20.4 41.6 42.8 17.8 14.8 3.600 9.3 2.3 2.4 77.4 60.2 55.5

ALUMINUM

- SWA 3 lbs/day Calculated 3 59.6 95.8 145.6 64.1 28.4 10.3 DNTA DNTA DNTA 89.6 119.4 186.1

ALUMINUM

- DM lbs/day 13.4 7 /20 8 /30 9 36.6 124.8 121.8 39.9 55.4 7.4 37.3 4.3 7.0 176.8 123.1 109.2

ALUMINUM

- SWA 6 lbs/day Calculated 6 153.8 343.8 577.5 168.8 138.8 DNTA 90.0 DNTA DNTA 363.8 322.5 632.5

FREE CN

- MA 2 mg/l <0.012 0.001 0.0 ND 10

<0.0024 0.001 ND

<0.0024 ND

<0.0024 ND

<0.0024 ND

<0.0024 ND

<0.0024 0.0 ND

<0.0024 ND

(<0.0024)

FREE CN

- DM 3 mg/l 0.012 0.006 0.005 ND

<0.0024 0.005 ND

<0.0024 ND

<0.0024 ND

<0.0024 ND

<0.0024 ND

<0.0024 0.01 ND

<0.0024 ND

(<0.005)

B(a)P

- MA lbs/day 0.02 7 /0.03 8 /

0.045 9 0.003 01/09/12 0.008 0.012 04/24/12 04/24/12 04/24/12 0.006 08/06/12 0.019 10/15/12 10/15/12

B(a)P

- SWA 3 lbs/day Calculated 3 DNTA 01/09/12 DNTA DNTA 04/24/12 04/24/12 04/24/12 DNTA 08/06/12 0.048 10/15/12 10/15/12

B(a)P

- DM 4 lbs/day 0.043 7 /0.065 8 /0

.098 9 0.003 01/09/12 0.008 0.024 04/24/12 04/24/12 04/24/12 0.006 08/06/12 0.019 10/15/12 10/15/12

B(a)P

- SWA 6 lbs/day Calculated 6 DNTA 01/09/12 DNTA DNTA 04/24/12 04/24/12 04/24/12 DNTA 08/06/12 DNTA 10/15/12 10/15/12

ANTIMONY

- MA lbs/day 1.9 7 /2.9 8 /4.3 9 0.020 01/09/12 0.00 0.00 04/24/12 04/24/12 ND

(<0.004) 07/30/12 07/30/12 07/30/12 07/30/12 07/30/12

ANTIMONY

- DM lbs/day 4.2 7 /6.4 8 /9.6 9

0.020 01/09/12 4.30 0.00 04/24/12 04/24/12 ND

(<0.001) 07/30/12 07/30/12 07/30/12 07/30/12 07/30/12

NICKEL

- MA lbs/day 0.8 7 /1.2 8 /1.9 9 0.62 01/09/12 0.00 0.43 04/24/12 04/24/12 0.00 07/30/12 07/30/12 07/30/12 07/30/12 07/30/12

NICKEL

- DM lbs/day 1.2 7 /1.8 8 /2.7 9 0.62 01/09/12 9.60 0.43 04/24/12 04/24/12 0.00 07/30/12 07/30/12 07/30/12 07/30/12 07/30/12

C0PPER

- DM 3 ug/l none 10/3/11 ND

(<0.003) 3 03/12/12 03/12/12 03/12/12 03/12/12 03/12/12 03/12/12 03/12/12 03/12/12 03/12/12

O & G

- MA 2 mg/l 5 <1.0 ND

(<1.4) ND (<1.0) ND

(<1.0) ND

(<1.0) ND

(<1.0) ND

(<1.0) 3.1 ND

(<1.4) ND

(<1.4) ND

(<1.4) ND (<1.4)Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 102 of 145

Intalco 2012 Water Pollutant Discharges

OUTFALL 001 UNITS LIMITS 1 JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

O & G

- DM 3 mg/l 10 <1.0 ND

(<1.4) ND (<1.0) ND

(<1.0) ND

(<1.0) ND

(<1.0) ND

(<1.0) 3.1 ND

(<1.4) ND

(<1.4) ND

(<1.4) ND (<1.4)

pH

- Daily Min std units ≥6 6.8 6.8 6.9 6.8 7.2 7.1 6.9 7.5 7.5 6.8 6.9 6.7 7.0

pH

- Daily Max std units ≤9 7.8 7.8 7.9 7.9 8.2 8.1 8.1 8.2 8.5 8.5 8.2 8.0 8.1

Temp

- MA o F none 41 44 45 52 57 59 63 66 62 55 50 43 53.1

Temp

- DM o F none 50 52 52 59 63 66 71 73 69 66 57 50 60.7

Flow

- MA MGD none 1.880 2.294 2.506 1.810 1.145 1.282 1.140 1.017 1.123 2.099 1.623 3.153 1.8

Flo w

- DM MGD none 4.406 7.367 6.102 4.737 2.180 3.092 3.988 1.245 1.389 7.069 4.388 7.218 4.4

Al Production 11 tons/day none 641 663 665 666 665 669 673 651 674 676 688 687 668.2

Number of days in the month none 31 29 31 30 31 30 31 31 30 31 30 31 30.5

Al Production

- Maximum tons/mont

h none 19871 19227 20615 19980 20615 20070 20863 20181 20220 20956 20640 21297 20377

.9

OUTFALL 002 12 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- MA mg/l 35 NA 13 8.6 8.6 27.6 NA NA 15.7 NA NA 10.7 16.7 4.2 13.2

TSS

- DM mg/l 75 NA 11.8 10.1 27.6 NA NA 15.7 NA NA 11.5 41.2 4.7 17.5

FLUORIDE

- MA mg/l 35 NA 18.4 16.6 20.5 NA NA 27 NA NA 29.5 20.4 17.3 21.4

FLUORIDE

- DM mg/l 50 NA 19.7 17.7 20.5 NA NA 27 NA NA 32.8 26.5 19.2 23.3

ALUMINUM

- MA mg/l 10 NA 4.4 4.0 6.5 NA NA 7.2 NA NA 8.2 6.2 4.9 5.9

ALUMINUM

- DM mg/l 15 NA 4.4 4.0 6.5 NA NA 7.2 NA NA 8.4 8.9 5.3 6.4

pH

- Daily Min std units ≥6 NA 6.6 6.1 6.6 NA NA 6.9 NA NA 6.4 6.6 6.5 6.5

pH

- Daily Max std units ≤9 NA 7.2 7.2 7.2 NA NA 7.3 NA NA 7.6 7.1 7.2 7.3

Temp

- MA o F none NA 41.5 43.2 53.3 NA NA 65.4 NA NA 46.1 45.9 41.6 48.1

Temp

- DM o F none NA 47.2 49.3 58.5 NA NA 71.5 NA NA 58.9 53.6 46.9 55.1

Flow

- MA MGD none NA 1.194 1.411 0.781 NA NA 0.245 NA NA 1.080 0.994 2.150 1.1

Flow

- DM MGD none NA 5.33 4.38 3.76 NA NA 2.39 NA NA 7.47 3.52 7.85 5.0

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

BOD

- MA lbs/day 22.4 11.8 13.9 11.0 6.8 4.4 7.7 2.6 1.5 1 1.4 6.1 5.3 6.1

BOD

- DM lbs/day 32.4 17.5 18.1 11.9 7.7 8.6 10.7 3.4 1.7 1.5 1.8 9.8 10.4 8.6

BOD

- MA mg/l 45.0 21.4 26.2 21.0 13.8 11.8 18.5 11.2 5.2 3.4 5.7 15 9.1 13.5

BOD

- DM mg/l 65.0 25.0 30 24.0 14.0 19.0 27 14.0 5.9 4.9 7.8 29 15.0 18.0

TSS

- MA lbs/day 22.4 3.9 10.8 14.0 5.0 1.4 0.8 0.9 0.5 0.5 0.5 6.8 1.4 3.9

TSS

- DM lbs/day 32.4 7.6 15.6 19.5 5.5 2.7 1.3 1.4 0.7 1.3 0.7 27.5 3.0 7.2

TSS

- MA mg/l 45.0 6.6 22.1 26.7 10.2 5.4 2.1 3.7 1.6 1.5 1.9 19.3 2.6 8.6

TSS

- DM mg/l 65.0 13.9 38.8 40.3 12.0 8.0 3.2 6.6 2.1 4 3 41.9 4.7 14.9

Fecal Coli.

- MA #/100mls 200 79.3 5.8 2.0 ND (<2) 2.0 3.0 2.0 2.0 2.0 5.0 2.0 2.0Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 103 of 145

Intalco 2012 Water Pollutant Discharges

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

Fecal Coli.

- DM #/100mls 400 300 17.0 2.0 ND (<2) ND (<2) 8 2.0 2.0 ND (<2) 80.0 ND (<2) ND (<2)

pH

- Daily Min std units ≥6 6.27 6.45 6.46 6.55 6.69 6.98 6.91 6.7 6.80 6.50 6.48 6.36 6.6

pH

- Daily Max std units ≤9 7.04 6.88 7.07 7.02 7.2 7.3 7.11 7.02 7.33 7.01 6.81 7.10 7.1

Flow

- MA MGD none 0.063 0.061 0.066 0.056 0.034 0.055 0.025 0.034 0.035 0.04 0.061 0.07 0.050

Flow

- DM MGD none 0.09 0.080 0.08 0.07 0.070 0.06 0.05 0.040 0.04 0.12 0.12 0.09 0.1

% BOD Removal

- MA % 55%/65% 14 90.8 93.8 93.4 92.7 93.4 96.5 98.6 98.9 98.1 97.0 96.3 98.4 95.7

% TSS Removal

- MA % 55%/65% 14 94.5 97.2 98.0 97.0 98.7 99.7 99.9 99.6 99.7 99.2 96.0 99.1 98.2

Personnel Onsite # of

personnel > 400 597 590 595 614 603 609 584 599 608 622 622 620 605.3

Date UV Tubes were cleaned Date once/90 days 01/12/12 02/18/12 02/22/12 04/18/12 04/18/12 06/14/12 07/10/12 08/18/12 08/18/12 10/20/12 10/20/12 02/12/12

UV Tubes Operating Number 12.0 14 14 14 14 14 14 14 14 14 14 14 14 14.0

Date UV Tubes were replaced Date Annually 01/12/12 01/12/12 01/12/12 01/12/12 01/12/12 06/14/12 06/14/12 06/14/12 06/14/12 06/14/12 06/14/12 12/28/12

Stormwater Pond UNITS Action Level JAN FEB MAR APR MAY J UN JUL AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 20 6.6 28.7 29.6 6.2 NS 15 32.8 14.1 NS NS 33.6 20.4 21.3 21.5

FLUORIDE

- DM mg/l 35 21.3 21.7 19 20.0 NS 31.8 26.3 NS NS 39.5 23.5 22.7 25.1

ALUMINUM

- DM mg/l 8 6.8 6.0 7 5.2 NS 10.0 7.3 NS NS 12.6 10 8.4 8.1

pH

- Daily Min std units <6.0 6.7 6.8 6.8 6.6 6.9 6.7 6.8 7.2 6.8 6.3 6.7 6.7 6.8

pH

- Daily Max std units >9.0 7.3 7.4 7.3 7.4 7.5 7.3 7.3 7.5 7.7 7.8 7.3 7.3 7.4

Flow

- MA MGD none 0.443 0.586 0.67 0.407 0.164 0.262 0.176 0.07 0.109 0.767 0.657 1.114 0.5

Flow

- DM MGD none 1.573 2.437 2.097 2.191 0.769 1.628 1.832 0.089 0.332 4.575 3.905 3.66 2.1

Secondary Wastewater Treatment

Plant UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- DM mg/l 120 198.9 205.8 57.2 262.7 172.0 71.6 70.8 232.8 144.3 119.9 48.7 57.5 136.9

FLUORIDE

- DM mg/l 50 27.5 27.3 23.5 44.5 26.3 24.0 28.5 40.3 37.8 34.5 43.3 34.8 32.7

ALUMINUM

- DM mg/l none 1.5 0.2 0.1 0.7 0.1 0.2 0.1 0.1 0.1 0.1 0.2 0.1 0.3

FREE CN

- DM mg/l none 0.009 0.007 0.007 0.006 0.007 0.006 0.009 0.01 0.010 0.008 0.006 0.009 0.0

PCBs ppb none <0.05 01/09/12 01/09/12 ND

(<0.05) 04/25/12 04/25/12 ND

(<0.05) 07/24/12 07/24/12 07/24/12 07/24/12 ND (<0.1)

Flow

- MA MGD none 0.049 0.053 0.056 0.066 0.044 0.06 0.055 0.037 0.035 0.056 0.055 0.041 0.1

Flow

- DM MGD none 0.159 0.276 0.207 0.211 0.188 0.211 0.248 0.225 0.223 0.258 0.204 0.258 0.2

Outfall 011 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- Monthly grab when there is flow mg/l none 26 201.3 630.2 IF 16 17.3 25.6 306.9 IF IF 142.9 694.9 41.7 231.9

FLUORIDE

- Monthly grab when there

is flow mg/l none 13.8 15.0 6.5 IF 8.3 11 7.4 IF IF 11.3 5.9 8.3 9.7

ALUMINUM

- Monthly grab when

there is flow mg/l none 5.8 26.8 45.8 IF 2.6 3.4 16.8 IF IF 14.0 35.2 6.8 17.5Fact Sheet for NPDES Permit WA 0 002950

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Page 104 of 145

Intalco 2012 Water Pollutant Discharges

Outfall 012 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC AVG

TSS

- Monthly grab when there is flow mg/l none 4.4 46.8 154.5 IF 12.5 32.7 141.5 IF IF 23.0 95.2 31.3 60.2

FLUORIDE

- Monthly grab when there

is flow mg/l none 5.1 8.6 2.1 IF 2.2 2.1 1.9 IF IF 4.6 3.5 8.0 4.2

ALUMINUM

- Monthly grab when

there is flow mg/l none 1.9 10.6 13.8 IF 2.6 6.1 10.5 IF IF 3.3 6.5 5.0 6.7

1 LIMITS for modified NPDES permit issued on June 15, 2008 (effective July 15, 2008).

2 Monthly average (MA) effluent limitation is defined as the highest allowable average of daily discharges over a calendar month, calculated as the sum of all daily discharges measured during a calendar month divided by t he

number of daily discharges measured during that month.

3 SW allocation Monthly Average limit.

4 DNTA: Did not take stormwater allocation because they were in compliance with the respective permit limit.

5 Daily maximum (DM) effluent limitation is defined as the highest allowable daily discharge. The daily discharge means the di scharge of a pollutant measured during a calendar d ay. For pollutants with limitations

expressed in units of mass, the daily discharge is calculated as the total mass of the pollutant discharged over the day. Fo r other units of measurement, the daily discharge is the average measurement of the pollutant over the

day. The pH shall not be averaged.

6 SW allocation Daily Max limit.

7 Tiered limit, applies when monthly aluminum production is less than or equal to 10,305 tons.

8 Tiered limit, applies when monthly aluminum production is greater than 10,305 and less than or equal to 15,614 tons.

9 Tiered limit, applies when monthly aluminum production is greater than 15,614 tons.

10 ND = Nondetect.

11 The monthly average of daily production.

12 Intalco notified Ecology (in a letter dated February 27 , 2009) that they had completed the diversion structure to divert all flow from Outfall 002 into Outfall 001.

13 NA

= No discharge through outfall 002 because the hydraulic capacity at 001 was not exceeded.

14 The limit is 55 % if there are <400 people working onsite and the limit is 65% if there are > 400 people working on site.

15 NS

= Not sampled because the stormwater pond discharge never exceeded 3.7 cfs over any consecutive 120 minute period.

16 IF

= Insufficient flow to collect a representative sample.

Intalco 2013 Water Pollutant Discharges

PARAMETERS

UNITS LIMITS 1 JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT AVG

OUTFALL 001

TSS

- MA 2 lbs/day 150 109.4 47.3 142.9 56.4 105.2 68.5 12.0 35.6 65.8 160.2

TSS SW allocation Monthly Average limit 3 lbs/day Calculated 3 DNTA 4 DNTA DNTA DNTA DNTA DNTA DNTA DNTA DNTA 257.3

TSS

- DM 5 lbs/day 185 289.1 76.0 420.6 161.4 272.5 211.4 51.0 83.8 130.2 956.2Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 105 of 145

Intalco 2013 Water Pollutant Discharges

OUTFALL UNITS LIMITS 1 JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT AVG

TSS SW allocation Daily Max limit 6 lbs/day Calculated 6 3128.8 DNTA 841.3 DNTA 1235 438.1 DNTA DNTA DNTA 1441.3

FLUORIDE

- MA lbs/day 58 7 /68 8 /68 9 165.4 85.1 152.9 118.4 153.6 94.5 43.0 73.8 83.7 158.6

FLUORIDE

- SWA 3 lbs/day Calculated 3 487.3 180.4 275.3 263.6 243.2 114.6 DNTA 86.3 100.7 175.3

FLUORIDE

- DM lbs/day 140 7 /198 8 /296 9 441.4 94.2 286.9 259.5 363.1 143.5 64 152.7 187.8 585.7

FLUORIDE

- SWA 6 lbs/day Calculated 6 2260.1 DNTA DNTA DNTA 996.6 DNTA DNTA DNTA DNTA 1134.2

ALUMINUM

- MA lbs/day 5.9 7 /9.0 8 /10.3 9 37.3 8.6 18.9 14.6 31.8 7.9 0.0 1.4 11.1 39.9

ALUMINUM

- SWA 3 lbs/day Calculated 3 129.5 DNTA 69.2 65.9 60.1 DNTA DNTA DNTA 19.6 40.8

ALUMINUM

- DM lbs/day 13.4 7 /20 8 /30 9 132.2 13.6 34.6 59.7 93.9 30.7 0.0 7.0 40.2 242.7

ALUMINUM

- SWA 6 lbs/day Calculated 6 618.8 DNTA 161.3 277.5 240 80.6 DNTA DNTA 68.8 281.3

FREE CN

- MA 2 mg/l <0.012 0.002 0.0 0.003 0.0 0.0 0.0 0.0 0.005 ND 10

(<0.003) 0.004

FREE CN

- DM 3 mg/l 0.012 0.007 0.007 0.007 0.005 0.007 0.006 0.008 0.007 ND

(<0.010) 0.007

B(a)P

- MA lbs/day 0.02 7 /0.03 8 / 0.045 9 10/15/12 0.005 2/4/13 0.010 4/15/13 0.004 6/25/13 6/25/13 0.004 9/9/13

B(a)P

- SWA 3 lbs/day Calculated 3 10/15/12 DNTA 2/4/13 DNTA 4/15/13 DNTA 6/25/13 6/25/13 DNTA 9/9/13

B(a)P

- DM 4 lbs/day 0.043 7 /0.065 8 /0.098

9 10/15/12 0.005 2/4/13 0.010 4/15/13 0.007 6/25/13 6/25/13 0.004 9/9/13

B(a)P

- SWA 6 lbs/day Calculated 6 10/15/12 DNTA 2/4/13 DNTA 4/15/13 DNTA 6/25/13 6/25/13 DNTA 9/9/13

ANTIMONY

- MA lbs/day 1.9 7 /2.9 8 /4.3 9 0.00 1/7/13 1/7/13 1/7/13 1/7/13 0.02 6/25/13 6/25/13 6/25/13 6/25/13

ANTIMONY

- DM lbs/day 4.2 7 /6.4 8 /9.6 9 0.00 1/7/13 1/7/13 1/7/13 1/7/13 0.03 6/25/13 6/25/13 6/25/13 6/25/13

NICKEL

- MA lbs/day 0.8 7 /1.2 8 /1.9 9 0.57 1/7/13 1/7/13 1/7/13 1/7/13 0.30 6/25/13 6/25/13 6/25/13 6/25/13

NICKEL

- DM lbs/day 1.2 7 /1.8 8 /2.7 9 0.57 1/7/13 1/7/13 1/7/13 1/7/13 0.41 6/25/13 6/25/13 6/25/13 6/25/13

C0PPER

- DM 3 ug/l none ND (<3) 1/21/13 1/21/13 1/21/13 1/21/13 5.2 6/25/13 6/25/13 6/25/13 6/25/13

O & G

- Minimum mg/l none ND

(<0.54) ND

(<1.1) ND

(<2.5) ND

(<1.1) ND

(<1.1) ND

(<1.1) ND (<1.1) ND (<2.5) ND (<1.1) 2.2

O & G

- MA 2 mg/l 5 ND

(<0.54) ND

(<1.1) ND

(<2.5) ND

(<1.1) ND

(<1.1) ND

(<1.1) ND (<1.1) ND (<2.5) ND (<1.1) 2.2

O & G

- DM 3 mg/l 10 ND

(<0.54) ND

(<2.5) ND

(<2.5) ND

(<1.1) ND

(<1.1) ND

(<1.1) ND (<1.1) ND (<2.5) ND (<1.1) 2.2

pH

- Daily Min std units ≥6 6.9 6.9 6.9 7.0 7.1 7.0 7.5 7.4 6.9 6.8 7.0

pH

- Daily Max std units ≤9 8.1 8.1 8.1 8.1 8.2 8.3 8.1 8.2 8.1 8.2 8.2

Temp

- MA o F none 41 46 48 52 58 62 67 67 63 56 56.0

Temp

- DM o F none 47 51 56 60 65 69 73 73 73 61 62.8

Flow

- MA MGD none 2.528 1.603 2.361 2.031 1.213 1.175 1.070 1.051 1.363 1.208 1.6Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 106 of 145

Intalco 2013 Water Pollutant Discharges

OUTFALL UNITS LIMITS 1 JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT AVG

Flow

- DM MGD none 9.865 5.900 6.332 5.248 2.379 3.227 1.38 1.622 4.02 5.068 4.5

Al Production 11 tons/day none 689 697 696 691 688 679 684 691 691 696 690.2

Number of days in the month none 31 28 31 30 31 30 31 31 30 31 30.4

Al Production

- Maximum tons/month none 21359 19516 21576 20730 21328 20370 21204 21421 20730 21576 20981.0

OUTFALL 002 12 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT AVG

TSS

- MA mg/l 35 5.5 11.0 NA 13 9.2 NA 8.4 NA NA 35 NA 13.8

TSS

- DM mg/l 75 5.5 11.0 NA 9.2 NA 8.4 NA NA 35 NA 13.8

FLUORIDE

- MA mg/l 35 17.3 19.0 NA 17.8 NA 24.5 NA NA 33.3 NA 22.4

FLUORIDE

- DM mg/l 50 17.3 19.0 NA 19.2 NA 24.5 NA NA 33.3 NA 22.7

ALUMINUM

- MA mg/l 10 5.0 6.7 NA 4.6 NA 5.5 NA NA 13.2 NA 7.0

ALUMINUM

- DM mg/l 15 5.0 6.7 NA 4.8 NA 5.5 NA NA 13.2 NA 7.0

pH

- Daily Min std units ≥6 6.6 6.7 NA 6.8 NA 6.9 NA NA 6.7 NA 6.7

pH

- Daily Max std units ≤9 7.3 7.4 NA 7.3 NA 7.3 NA NA 7.2 NA 7.3

Temp

- MA o F none 38.8 42.0 NA 51.3 NA 64.1 NA NA 62.1 NA 51.7

Temp

- DM o F none 44 46.4 NA 59.3 NA 70.9 NA NA 71 NA 58.3

Flow

- MA MGD none 1.68 0.035 NA 0.843 NA 0.13 NA NA 0.264 NA 0.6

Flow

- DM MGD none 4.71 0.05 NA 3.98 NA 1.87 NA NA 2.46 NA 2.6

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT AVG

BOD

- MA lbs/day 22.4 7.8 7.3 5.8 4.7 4.2 2.1 1.9 1.7 2.3 4.9 4.3

BOD

- DM lbs/day 32.4 11.5 12.7 7.8 8.0 12.4 2.5 2.5 7 4.6 6 7.5

BOD

- DM mg/l 65.0 28.0 32.0 14.0 13.0 47.0 9.5 6.4 34 14.0 14 21.2

TSS

- MA lbs/day 22.4 1.9 2.6 4.5 0.9 0.3 0.2 0.0 0.0 0.0 0.0 1.0

TSS

- DM lbs/day 32.4 3.1 4.4 7.4 1.6 1.6 0.5 0.0 0.0 0.0 0.0 1.9

TSS

- MA mg/l 45.0 3.9 8.5 8.2 1.9 0.9 0.7 0 0.0 0.0 0.0 2.4

TSS

- DM mg/l 65.0 5.3 11.1 11.9 2.7 3.8 2.1 0.0 0.0 0.0 0.0 3.7

Fecal Coli.

- MA #/100mls 200 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0

Fecal Coli.

- DM #/100mls 400 ND (<2) ND (<2) ND (<2) ND (<2) ND (<2) ND (<2) ND (<2) ND (<2) ND (<2) ND (<2)

pH

- Daily Min std units ≥6 6.44 6.28 6.61 6.64 6.85 6.69 6.75 6.54 6.42 6.51 6.6

pH

- Daily Max std units ≤9 7.04 7.09 7.09 7.00 7.3 7.1 7.07 7.01 7.03 7.21 7.1

Flow

- MA MGD none 0.058 0.035 0.052 0.061 0.032 0.039 0.041 0.014 0.031 0.055 0.0

Flow

- DM MGD none 0.07 0.050 0.08 0.08 0.050 0.06 0.06 0.030 0.04 0.07 0.1

% BOD Removal

- MA % 55%/65% 14 99.0 97.1 97.2 96.2 98.2 99.0 98.2 94.9 93.2 95.6 96.9

% TSS Removal

- MA % 55%/65% 14 99.6 99.2 97.7 99.3 99.9 99.9 100.0 100.0 100.0 100.0 99.6

Personnel Onsite # of

personnel > 400 612 612 604 601 594 594 604 598 592 586 599.7Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 107 of 145

Intalco 2013 Water Pollutant Discharges

Sanitary Lagoon UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT AVG

Date UV Tubes were cleaned Date once/90 days 12/12/12 02/19/13 02/19/13 04/24/13 04/24/13 06/11/13 07/10/13 08/31/13 08/31/13 08/31/13 41413.1

UV Tubes Operating Number 12.0 14 14 14 14 14 14 14 14 14 14 14.0

Date UV Tubes were replaced Date Annually 12/28/12 12/28/12 12/28/12 12/28/12 12/28/13 06/11/13 06/11/13 06/11/13 06/11/13 06/11/13

Stormwater Pond UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEP OCT AVG

TSS

- DM mg/l 20 9.7 15.8 6.9 14.1 15.7 22.4 NS 15 NS 44.8 25.9 19.4

FLUORIDE

- DM mg/l 35 18.3 20.8 19 19.0 21.8 26.3 NS NS 36.5 19.5 22.7

ALUMINUM

- DM mg/l 8 6.4 7.2 5.1 5.1 5.1 9.5 NS NS 18.0 11.2 8.5

pH

- Daily Min std units <6.0 6.7 6.9 6.7 6.7 6.9 6.7 6.8 7 6.2 6.6 6.7

pH

- Daily Max std units >9.0 7.5 7.5 7.4 7.4 7.5 7.5 7.5 7.6 7.4 7.3 7.5

Flow

- MA MGD none 0.794 0.323 0.596 0.48 0.265 0.183 0.066 0.094 0.311 0.209 0.3

Flow

- DM MGD none 5.890 2.356 2.332 2.263 1.109 1.529 0.071 0.428 2.400 2.736 2.1

Secondary Wastewater Treatment Plant UNITS Action Level JAN FEB MAR APR MAY JUN JUL AUG SEP OCT AVG

TSS

- DM mg/l 120 70.8 47.5 64.1 46.6 57.6 59.6 49.4 78.8 52.7 48.7 57.6

FLUORIDE

- DM mg/l 50 25.3 21.5 19.3 22.8 22.3 28.8 18.5 16.8 19.0 21.3 21.6

ALUMINUM

- DM mg/l none 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.015 0.1 0.1 0.1

FREE CN

- DM mg/l none 0.009 0.009 0.028 0.006 0.010 0.007 0.016 0.015 NQ 16

(<0.010) 0.010

PCBs ppb none 12/12/12 12/12/12 ND

(<0.1) ND

(<0.1) 4/15/13 ND

(<0.1) 6/25/2013 6/25/2013 ND (<0.1) 09/10/13

Flow

- MA MGD none 0.096 0.113 0.129 0.125 0.143 0.124 0.119 0.139 0.121 0.102 0.1

Flow

- DM MGD none 0.401 0.433 0.473 0.435 0.442 0.463 0.302 0.310 0.316 0.346 0.4

Outfall 011 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT AVG

TSS

- Monthly grab when there is flow mg/l none 198.4 78.1 412.1 48.5 42.6 102.8 IF 17 26.1 25.5 36.2 107.8

FLUORIDE

- Monthly grab when there is

flow mg/l none 14.4 19.5 12.2 6.4 9.9 10.7 IF 14.3 13.7 2.2 11.5

ALUMINUM

- Monthly grab when there is

flow mg/l none 31.1 33.1 29.5 5.0 5.5 2.1 IF 3.9 8.3 0.1 13.2

Outfall 012 UNITS LIMITS JAN FEB MAR APR MAY JUN JUL AUG SEP OCT AVG

TSS

- Monthly grab when there is flow mg/l none 21 45.0 170.4 10.9 75.7 45.6 IF 12.5 48.7 56.7 54.1

FLUORIDE

- Monthly grab when there is

flow mg/l none 3.3 8.7 5.7 3.6 4.6 5.9 IF 14.6 5.5 2.3 6.0

ALUMINUM

- Monthly grab when there is

flow mg/l none 2.9 11.9 17.7 3.0 4.8 6 IF 14.2 10.5 0.6 8.0

1 LIMITS for modified NPDES permit issued on June 15, 2008 (effective July 15, 2008).

2 Monthly average (MA) effluent limitation is defined as the highest allowable average of daily discharges over a calendar month, calculated as the sum of all daily dis charges measured during a calendar month divided

by the number of daily discharges measured during that month.

3 SW allocation Mon thly Average limit.Fact Sheet for NPDES Permit WA 0 002950

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Page 108 of 145

Intalco 2013 Water Pollutant Discharges

4 DNTA: Did not take stormwater allocation because they were in compliance with the respective permit limit.

5 Daily maximum (DM) effluent limitation is defined as the highest allowable daily discharge. The daily discharge means the di scharge of a pollutant measured during a calendar day. For pollutants with limitations

expressed in units of mass, the daily disch arge is calculated as the total mass of the pollutant discharged over the day. For other units of measurement, the daily dis charge is the average measurement of the pollutant over

the day. The pH shall not be averaged.

6 SW allocation Daily Max limit.

7 Tiered limit, applies when monthly aluminum production is less than or equal to 10,305 tons.

8 Tiered limit, applies when monthly aluminum production is greater than 10,305 and less than or equal to 15,614 tons.

9 Tiered limit, applies when monthly aluminum production is greater than 15,614 tons.

10 ND = Nondetect.

11 The monthly average of daily production.

12 Intalco notified Ecology (in a letter dated February 27, 2009) that they had completed the diversion structure to divert all flow from Outfall 002 into Outfall 001.

13 NA = No discharge through outfall 002 because the hydraulic capacity at 001 was not exceeded.

14 The limit is 55 % if there are <400 people working onsite and the limit is 65% if there are > 400 people working on site.

15 NS

= Not sampled because the stormwater pond discharge never exceeded 3.7 cfs over any consecutive 120 minute period.

16 NQ = Special Condition S2.D. of the permit defines Non

- Quantifiable (NQ) as values above the Method Detection Level (MDL) but below the Practical quantitation limit (PQL). The sample results were between the

PQL and MDL (between 0.003 mg/L and 0.010 mg/L).

17 IF

= Insufficient flow to collect a representative sample.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 109 of 145



### Appendix E

- Technical Calculations

Several of the Excel® spreadsheet tools used to evaluate a discharger’s ability to meet

Washington State water quality standards can be found on Ecology’s Water Quality Permit

Guidance page under Permit Tools at

http://www.ecy.wa.gov/programs/wq/permits/gu idance.html .

Simple Mixing:

Ecology uses simple mixing calculations to assess the impacts of certain conservative pollutants,

such as the expected increase in fecal coliform bacteria at the edge of the chronic mixing zone

boundary. Simple mixing uses a mass balance approach to proportionally distribute a pollutant

load from a discharge into the authorized mixing zone. The approach assumes no decay or

generation of the pollutant of concern within the mixing zone. The predicted concentration at the

edge of a mixing zone (MC) is based on the following calculation:

MC

= [EC + (AC X ( DF

- 1) )]/DF

where:

EC

= Effluent Concentration

AC Ambient Concentration

DF Dilution Factor

Reasonable Potential Analysis:

The spreadsheets REASPOT.XLS, and LIMIT.XLS in Ecology’s TSDCALC Workbook

determine reasonable potential (to violate the aquatic life water quality standards) and calculate

effluent limits. The spreadsheet HUMAN

- H.XLS determines reasonable potential and ca lculates

effluent limits for human health pollutants. The process and formulas for determining reasonable

potential and effluent limits in these spreadsheets are taken directly from the Technical Support

Document for Water Quality

- based Toxics Control , (E PA 505/2

- 90

- 001). The adjustment for

autocorrelation is from EPA (1996a), and EPA (1996b).Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 110 of 145

Figure 6 Aquatic Life and Human Health Reasonable Potential AnalysisAMMONIA, Criteria as Total NH3ACENAPTHENE 83329 1BALUMINUM, total recoverable, pH6.5-9.0 7429905ANTHRACENE 120127 3BANTIMONY (INORGANIC) 74403601MARSENIC (dissolved) 74403822MARSENIC (inorganic)BENZO(a)ANTHRACENE 565535BBENZO(a)PYRENE 50328 6BBENZO(b)FLUORANTHENE205992 7BBENZO(k) FLUORANTHENE207089 9B

1 5 56 5 9 5 5 5 5 5 5

0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6

520 0.6 7370 0.5 17 50 50 1.6 1.9 2.6 0.9

16.000

Acute 5,505

- - - - 69

- - - - -

Chronic 827

- - - - 36

- - - - -

- 990

- 110000 4300

- 0.14 0.031 0.031 0.031 0.031

Acute

- - - - - 1

- - - - -

Chronic

- - - - - - - - - - -

N N N N N Y Y Y Y Y Y

Aquatic Life Reasonable Potential

0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950

s 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555

Pn 0.050 0.549 0.948 0.549 0.717 0.549 0.549 0.549 0.549 0.549 0.549

6.20 2.32 1.00 2.32 1.81 2.32 2.32 2.32 2.32 2.32 2.32

Acute 169 0.066 350.952 0.055 1.466 5.534 5.534 0.177 0.210 0.288 0.100

Chronic 78 0.027 141.731 0.022 0.592 2.235 2.235 0.072 0.085 0.116 0.040

NO n/a n/a n/a n/a NO n/a n/a n/a n/a n/a

Human Health Reasonable Potential

s 0.555 0.55451 0.5545 0.5545 0.5545 0.5545 0.5545 0.5545 0.554513 0.5545 0.55451

Pn 0.050 0.549 0.948 0.549 0.717 0.549 0.549 0.549 0.549 0.549 0.549

2.490 0.93363 0.4061 0.9336 0.7276 0.9336 0.9336 0.9336 0.933632 0.9336 0.93363

77 77 77 77 77 105 105 105 105 105 105

16.812 0.00728 38.874 0.0061 0.1606 4.4E-01 ###### 0.0142 0.016894 0.0231 0.008

n/a NO n/a NO NO n/a YES NO NO NO NO WQ Criteria for Protection of

Human Health, ug/L

Multiplier

Max concentration (ug/L) at edge of...

Reasonable Potential? Limit Required? Pn=(1-confidence level) 1/n s 2 =ln(CV 2 +1)

Multiplier

Dilution Factor s 2 =ln(CV 2 +1)

Pn=(1-confidence level)1/n Effluent percentile value Effluent Data # of Samples (n)

Effluent Concentration, ug/L

(Max. or 95th Percentile) Pollutant, CAS No. &

NPDES Application Ref. No.

Aquatic Life Criteria,

ug/L

Carcinogen? Water Quality Criteria Coeff of Variation (Cv)

Calculated 50th percentile

Effluent Conc. (when n>10)

Receiving Water Data 90th Percentile Conc., ug/L

Geo Mean, ug/L

Metal Criteria

Translator, decimal

Max Conc. at edge of Chronic Zone, ug/L

Reasonable Potential? Limit Required?Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 111 of 145CADMIUM - 7440439 4MHardness dependentCHROMIUM(HEX) 18540299CHRYSENE 218019 18BCOPPER - 744058 6M HardnessdependentCYANIDE 57125 14MFLUORANTHENE 206440 31BFLUORENE 86737 32BINDENO(1,2,3-cd)PYRENE 19339537BLEAD - 7439921 7M Dependenton hardnessMANGANESE 7439965METHYLENE CHLORIDE 7509222V

5 5 5 6 2 5 5 5 5 1 2

0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6

1.5 2 1.7 5.2 0.7 3.3 0.2 1.6 0.7 70 0.59

0.47 0.012 0.0007

Acute 42 1100

- 4.8 9.1

- - - 210

- -

Chronic 9.3 50

- 3.1 2.8

- - - 8.1

- -

- - 0.03

- 2E+05 370 14000 0.031

- 100 1600

Acute 0.994 0.993

- 0.83

- - - - 0.951

- -

Chronic 0.994 0.993

- 0.83

- - - - 0.951

- -

N N Y N N N N Y N N Y

Aquatic Life Reasonable Potential

0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950

s 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555

Pn 0.549 0.549 0.549 0.607 0.224 0.549 0.549 0.549 0.549 0.050 0.224

2.32 2.32 2.32 2.14 3.79 2.32 2.32 2.32 2.32 6.20 3.79

Acute 0.165 0.220 0.636 0.440 0.126 0.365 0.022 0.189 0.074 20.659 0.107

Chronic 0.067 0.089 0.537 0.178 0.051 0.148 0.009 0.083 0.030 8.343 0.043

NO NO n/a NO NO n/a n/a n/a NO n/a n/a

Human Health Reasonable Potential

s 0.5545 0.5545 0.55 0.5545 0.555 0.5545 0.5545 0.5545 0.5545 0.5545 0.5545

Pn 0.549 0.549 0.549 0.607 0.224 0.549 0.549 0.549 0.549 0.050 0.224

0.9336 0.9336 0.93 0.8603 1.524 0.9336 0.9336 0.9336 0.9336 2.4895 1.5242

77 77 105 77 77 77 77 105 77 77 105

0.0182 0.0243 0.02 0.0581 0.014 4.0E-02 2.4E-03 0.0142 0.0085 2.2632 0.0086

n/a n/a NO n/a NO NO NO NO n/a NO NO Receiving Water Data 90th Percentile Conc., ug/L

Geo Mean, ug/L

Water Quality Criteria

Metal Criteria

Translator, decimal

Multiplier

Max concentration (ug/L) at edge of...

Reasonable Potential? Limit Required? Pollutant, CAS No. &

NPDES Application Ref. No.

Effluent Data # of Samples (n)

Coeff of Variation (Cv)

Effluent Concentration, ug/L

(Max. or 95th Percentile)

Calculated 50th percentile

Effluent Conc. (when n>10)

Aquatic Life Criteria,

ug/L

WQ Criteria for Protection of

Human Health, ug/L

Carcinogen?

s 2 =ln(CV 2 +1)

Pn=(1-confidence level) 1/n Effluent percentile value

s 2 =ln(CV 2 +1)

Pn=(1-confidence level)1/n

Multiplier

Dilution Factor

Max Conc. at edge of Chronic Zone, ug/L

Reasonable Potential? Limit Required?Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 112 of 145MERCURY 7439976 8MNICKEL - 7440020 9M -Dependent on hardnessPYRENE 129000 45BSELENIUM 7782492 10MSILVER - 7740224 11Mdependent on hardness.SOLIDS,SUSPENDED ANDTURBIDITYTHALLIUM 7440280 12MZINC- 7440666 13M hardnessdependentPHENOL 108952 10A

6 9 5 5 5 56 5 5 2

0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6 0.6

0.0035 90 2.8 12 0.03 37000 1 62 25

0.57

0

Acute 1.8 74

- 290 1.9

- - 90

- #N/A #N/A

Chronic 0.025 8.2

- 71

- - - 81

- #N/A #N/A

0.15 4600 11000 4200

- - 6.3

- 5E+06 #N/A #N/A

Acute 0.85 0.99

- - 0.85

- - 0.946

- #N/A #N/A

Chronic

- 0.99

- - - - - 0.946

- #N/A #N/A

N N N N N N N N N #N/A #N/A

Aquatic Life Reasonable Potential

0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950 0.950

s 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555 0.555

Pn 0.607 0.717 0.549 0.549 0.549 0.948 0.549 0.549 0.224 #DIV/0! #DIV/0!

2.14 1.81 2.32 2.32 2.32 1.00 2.32 2.32 3.79 #DIV/0! #DIV/0!

Acute 0.000 7.685 0.310 1.871 0.003 ###### 0.111 6.492 4.517 #N/A #N/A

Chronic 0.000 3.104 0.125 1.095 0.001 711.538 0.045 2.622 1.824 #N/A #N/A

NO NO n/a NO NO n/a n/a NO n/a #N/A #N/A

Human Health Reasonable Potential

s 0.5545 0.55451 0.5545 0.5545 0.5545 0.5545 0.5545 0.5545 0.5545 0.5545 0.5545

Pn 0.607 0.717 0.549 0.549 0.549 0.948 0.549 0.549 0.224 #DIV/0! #DIV/0!

0.8603 0.72756 0.9336 0.9336 0.9336 0.4061 0.9336 0.9336 1.5242 #DIV/0! #DIV/0!

77 77 77 77 77 77 77 77 77 #N/A #N/A

4E-05 0.8504 0.034 0.1455 0.0004 2.0E+02 1.2E-02 0.7518 0.4949 #DIV/0! #DIV/0!

NO NO NO NO n/a n/a NO n/a NO #N/A #N/A Receiving Water Data 90th Percentile Conc., ug/L

Geo Mean, ug/L

Water Quality Criteria Aquatic Life Criteria,

ug/L

Metal Criteria

Translator, decimal

Carcinogen? Effluent Data # of Samples (n)

Coeff of Variation (Cv)

Effluent percentile value

Reasonable Potential? Limit Required? Multiplier

Max concentration (ug/L) at edge of...

Dilution Factor Effluent Concentration, ug/L

(Max. or 95th Percentile)

Calculated 50th percentile

Effluent Conc. (when n>10)

WQ Criteria for Protection of

Human Health, ug/L

s 2 =ln(CV 2 +1)

Pn=(1-confidence level) 1/n

s 2 =ln(CV 2 +1)

Pn=(1-confidence level)1/n Pollutant, CAS No. &

NPDES Application Ref. No.

Max Conc. at edge of Chronic Zone, ug/L

Reasonable Potential? Limit Required? MultiplierFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 113 of 145

Figure 7 Temperature Analysis

INPUT May-Sep Oct-Apr

1. Chronic Dilution Factor at Mixing Zone Boundary 52 52

2. Annual max 1DADMax Ambient Temperature (Background 90th percentile) 15.2 °C 10.7 °C

3. 1DADMax Effluent Temperature (95th percentile) 23.5 °C 19.4 °C

4. Aquatic Life Temperature WQ Criterion 13.0 °C 13.0 °C

OUTPUT

5. Temperature at Chronic Mixing Zone Boundary: 15.36 °C 10.83 °C

6. Incremental Temperature Increase or decrease: 0.16 °C 0.17 °C

7. Incremental Temperature Increase 12/(T-2) if T < crit:

--- 1.39 °C

8. Maximum Allowable Temperature at Mixing Zone Boundary: 15.50 °C 12.05 °C

A. If ambient temp is warmer than WQ criterion

9. Does temp fall within this warmer temp range? YES NO

10. Temp increase allowed at mixing zone boundary, if required: NO LIMIT

---

B. If ambient temp is cooler than WQ criterion but within 12/(T amb -2) and within 0.3 °C of the criterion

11. Does temp fall within this incremental temp. range?

--- NO

12. Temp increase allowed at mixing zone boundary, if required:

--- ---

C. If ambient temp is cooler than (WQ criterion-0.3) but within 12/(T amb -2) of the criterion

13. Does temp fall within this Incremental temp. range?

--- NO

14. Temp increase allowed at mixing zone boundary, if required:

--- ---

D. If ambient temp is cooler than (WQ criterion - 12/(T amb -2))

15. Does temp fall within this Incremental temp. range?

--- YES

16. Temp increase allowed at mixing zone boundary, if required:

--- NO LIMIT

RESULTS

17. Do any of the above cells show a temp increase? NO NO

18. Temperature Limit if Required? NO LIMIT NO LIMIT 

### Marine Temperature Reasonable Potential and Limit Calculation

Based on WAC 173-201A-200(1)(c)(i)--(ii) and Water Quality Program Guidance. All Data inputs must

meet WQ guidelines. The Water Quality temperature guidance document may be found at:

http://www.ecy.wa.gov/biblio/0610100.htmlFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 114 of 145



### Appendix F

– Wet Test Results Summary

Outfall 001 WET Test Results Summary

Intalco Combined Outfall 001

Acute WET Test Results as % Survival in 100% Effluent

Sample Date Start Date Organism Endpoint %Survival

20

- Apr

- 09 21

- Apr

- 09 Rainbow Trout 96

- Hour Survival 100.00%

20

- Apr

- 09 21

- Apr

- 09 Daphnid 48

- Hour Survival 80.00%

15

- Jun

- 09 16

- Jun

- 09 Rainbow Trout 96

- Hour Survival 100.00%

15

- Jun

- 09 16

- Jun

- 09 Daphnid 48

- Hour Survival 85.00%

31

- Aug

- 09 1

- Sep

- 09 Rainbow Trout 96

- Hour Survival 100.00%

26

- Aug

- 09 27

- Aug

- 09 Daphnid 48

- Hour Survival 100.00%

9

- Nov

- 09 10

- Nov

- 09 Rainbow Trout 96

- Hour Survival 100.00%

9

- Nov

- 09 10

- Nov

- 09 Daphnid 48

- Hour Survival 100.00%

22

- Feb

- 10 23

- Feb

- 10 Rainbow Trout 96

- Hour Survival 100.0%

22

- Feb

- 10 23

- Feb

- 10 Daphnid 48

- Hour Survival 100.0%

30

- Aug

- 10 31

- Aug

- 10 Rainbow Trout 96

- Hour Survival 100.0%

30

- Aug

- 10 31

- Aug

- 10 Daphnid 48

- Hour Survival 100.0%

18

- Oct

- 10 19

- Oct

- 10 Rainbow Trout 96

- Hour Survival 100.0%

18

- Oct

- 10 19

- Oct

- 10 Daphnid 48

- Hour Survival 100.0%

14

- Dec

- 10 18

- Dec

- 10 Rainbow Trout 96

- Hour Survival 100.00%

14

- Dec

- 10 16

- Dec

- 10 Daphnid 48

- Hour Survival 100.00%

Intalco Combined Outfall 001

Acute WET Test Results as NOEC/LOEC in % Effluent

Sample Date Organism Endpoint NOEC LOEC PMSD

20

- Apr

- 09 Rainbow Trout 96

- Hour Survival 100 >100 3%

20

- Apr

- 09 Daphnid 48

- Hour Survival 50 100 19%

15

- Jun

- 09 Rainbow Trout 96

- Hour Survival 100 >100 3%

15

- Jun

- 09 Daphnid 48

- Hour Survival 50 100 11%

31

- Aug

- 09 Rainbow Trout 96

- Hour Survival 100 >100 2.50%

26

- Aug

- 09 Daphnid 48

- Hour Survival 100 >100 11.30%

9

- Nov

- 09 Rainbow Trout 96

- Hour Survival 100 >100 2.50%

9

- Nov

- 09 Daphnid 48

- Hour Survival 100 >100 9.20%

22

- Feb

- 10 Rainbow Trout 96

- Hour Survival 100 >100 4.02%

22

- Feb

- 10 Daphnid 48

- Hour Survival 100 >100 5.00%

30

- Aug

- 10 Rainbow Trout 96

- Hour Survival 100 >100 2.50%

30

- Aug

- 10 Daphnid 48

- Hour Survival 100 >100 5.00%Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 115 of 145

Sample Date Organism Endpoint NOEC LOEC PMSD

18

- Oct

- 10 Rainbow Trout 96

- Hour Survival 100 >100 2.50%

18

- Oct

- 10 Daphnid 48

- Hour Survival 100 >100 5.00%

14

- Dec

- 10 Rainbow Trout 96

- Hour Survival 100 >100 2.50%

14

- Dec

- 10 Daphnid 48

- Hour Survival 100 >100 9.20%

Intalco Outfall 001 Combined

Chronic WET Test Results as NOEC/LOEC in % Effluent

Sample

Date Start Date Organism Endpoint NOEC LOEC PMSD

20

- Apr

- 09 21

- Apr

- 09 Pacific

Topsmelt 7

- Day

Survival 10 30 20.00%

Biomass 100 >100 27.60%

Weight 100 >100 16.50%

20

- Apr

- 09 21

- Apr

- 09 Mysid

Shrimp 7

- Day

Survival 10 30 14.20%

Biomass 100 >100 16.40%

Weight 100 >100 18.10%

20

- Apr

- 09 21

- Apr

- 09 Sea Urchin Development 10 30 2.80%

Survival 51.5 >51.5 14.20%

15

- Jun

- 09 16

- Jun

- 09 Pacific

Topsmelt 7

- Day

Survival 100 >100 19.60%

Biomass 100 >100 24.60%

Weight 100 >100 19.80%

15

- Jun

- 09 16

- Jun

- 09 Mysid

Shrimp 7

- Day

Survival 100 >100 16.90%

Biomass 100 >100 24.10%

Weight 100 >100 16.90%

15

- Jun

- 09 16

- Jun

- 09 Echinoderm Development 57.8 >57.8 1.63%

Survival 57.8 >57.8 7.13%

26

- Aug

- 09 27

- Aug

- 09 Pacific

Topsmelt 7

- Day

Survival 100 >100 9.74%

Biomass 100 >100 17.00%

Weight 100 >100 18.50%

26

- Aug

- 09 27

- Aug

- 09 Mysid

Shrimp 7

- Day

Survival 100 >100 14.80%

Biomass 100 >100 19.40%

Weight 100 >100 15.00%

26

- Aug

- 09 27

- Aug

- 09 Echinoderm Development 30 58.5 6.86%

Survival 58.5 >58.5 23.70%Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 116 of 145

Sample

Date Start Date Organism Endpoint NOEC LOEC PMSD

26

- Oct

- 09 27

- Oct

- 09 Inland

Silverside 7

- Day

Survival 100 >100 7.46%

Biomass 100 >100 10.40%

Weight 100 >100 10.90%

26

- Oct

- 09 27

- Oct

- 09 Mysid

Shrimp 7

- Day

Survival 30 100 14.60%

Biomass 30 100 17.60%

Weight 100 >100 13.00%

28

- Oct

- 09 29

- Oct

- 09 Echinoderm Development 48.8 >48.8 1.02%

Survival 48.8 >48.8 5.91%

22

- Feb

- 10 23

- Feb

- 10 Pacific

Topsmelt 7

- Day

Survival 100 >100 23.30%

Biomass 100 >100 36.70%

Weight 100 >100 23.30%

22

- Feb

- 10 23

- Feb

- 10 Mysid

Shrimp 7

- Day

Survival 100 >100 17.00%

Biomass 100 >100 18.00%

Weight 100 >100 14.50%

22

- Feb

- 10 23

- Feb

- 10 Echinoderm Development 50 >50 4.05%

Survival 50 >50 23.00%

31

- Aug

- 10 13

- Sept

10 Pacific

Topsmelt 7

- Day

Survival 100 >100 17.50%

Biomass 100 >100 19.00%

Weight 100 >100 17.50%

13

- Sept

10 14

- Sept

10 Mysid

Shrimp 7

- Day

Survival 30 100 15.40%

Biomass 30 100 16.60%

Weight 30 100 15.30%

15

- Sept

10 16

- Sept

10 Echinoderm Development 59.5 >59.5 13.20%

Survival 59.5 >59.5 16.50%

18

- Oct

- 10 19

- Oct

- 10 Inland

Silverside 7

- Day

Survival 100 >100 8.75%

Biomass 100 >100 13.90%

Weight 100 >100 15.70%

18

- Oct

- 10 19

- Oct

- 10 Mysid

Shrimp 7

- Day

Survival 30 100 18.90%

Biomass 10 30 18.70%

Weight 30 100 14.00%Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 117 of 145

Sample

Date Start Date Organism Endpoint NOEC LOEC PMSD

18

- Oct

- 10 19

- Oct

- 10 Echinoderm Development <2.5 2.5 10.30%

Survival 61.3 >61.3 30.90%

13

- Dec

- 10 14

- Dec

- 10 Pacific

Topsmelt 7

- Day

Survival 100 >100 9.74%

Biomass 100 >100 16.30%

Weight 100 >100 17.40%

13

- Dec

- 10 14

- Dec

- 10 Mysid

Shrimp 7

- Day

Survival 100 >100 18.50%

Biomass 10 30 20.90%

Weight 2.5 3.8 15.40%

15

- Dec

- 10 16

- Dec

- 10 Echinoderm Development 30 59.9 5.59%

Survival 59.9 >59.9 2.10%

Outfall 002 WET Test Results Summary

Intalco Outfall 002

Acute WET Test Results as % Survival in 100% Effluent

Sample Date Start Date Organism Endpoint %Survival

30

- Mar

- 07 31

- Mar

- 07 Fathead

Minnows 96

- Hour

Survival 100.0%

9

- May

- 07 10

- May

07 Daphnid 48

- Hour

Survival 60.0%

12

- Nov

- 07 13

- Nov

07 Daphnid 48

- Hour

Survival 25.0%

14

- Nov

- 07 15

- Nov

07 Fathead

Minnows 96

- Hour

Survival 92.5%

19

- Feb

- 08 20

- Feb

- 08 Fathead

Minnows 96

- Hour

Survival 97.5%

11

- Aug

- 08 12

- Aug

08 Fathead

Minnows 96

- Hour

Survival 97.5%Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 118 of 145

Intalco Outfall 002

- Acute WET Test Results as NOEC/LOEC in % Effluent

Sample Date Start Date Organism Endpoint NOEC LOE

C PMSD

30

- Mar

- 07 31

- Mar

- 07 Fathead

Minnows 96

- Hour

Survival 100 >100 2.50%

9

- May

- 07 10

- May

07 Daphnid 48

- Hour

Survival 50 100 14.88%

12

- Nov

- 07 13

- Nov

07 Daphnid 48

- Hour

Survival 25 50 25.80%

14

- Nov

- 07 15

- Nov

07 Fathead

Minnows 96

- Hour

Survival 100 >100 8.16%

19

- Feb

- 08 20

- Feb

- 08 Fathead

Minnows 96

- Hour

Survival 100 >100 9.14%

11

- Aug

- 08 12

- Aug

08 Fathead

Minnows 96

- Hour

Survival 100 >100 6.45%

Intalco Outfall 002

Chronic WET Test Results as NOEC/LOEC in % Effluent

Sample

Date Start Date Organism Endpoint NOEC LOEC PMSD

2/28/2007 3/1/2007 Mussel Development 63.3 >63.3 6.75%

Survival 25 50 4.55%

05/09/07 05/10/07 Pacific

Topsmelt 7

- Day

Survival 100 >100 11.85%

Biomass 100 >100 19.38%

05/09/07 05/10/07 Bivalve 7

- Day

Survival 55.2 >55.2 10.30%

Biomass 3 16.7 12.40%

11/12/07 11/13/07 Pacific

Topsmelt 7

- Day

Survival 100 >100 10.60%

Biomass 100 >100 17.70%

Weight 100 >100 13.90%Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 119 of 145

Sample

Date Start Date Organism Endpoint NOEC LOEC PMSD

05/09/07 05/10/07 Echinoderm 7

- Day

Survival 50 55.2 10.30%

Biomass 3 16.7 12.20%

11/14/2007 11/15/2007 Mussel Development 52.35 >52.35 13.10%

Survival 52.35 >52.35 3.93%

08/11/08 08/12/08 Echinoderm 7

- Day

Survival 50 >50 16.10%

Biomass 25 50 3.80%Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 120 of 145



### Appendix G

– Landfill Groundwater Seeps Monitoring Results

Outfall 003 Fluoride

(mg/L) Fluoride

(mg/L) Total

Cyanide/WAD

Cyanide

(mg/L) Total

Cyanide/WAD

Cyanide

(mg/L) Total

PCBs

(ug/L) Total

PCBs

(ug/L)

2/23/2007 15.9 14.1 0.01 / NA 0.177 / NA 0.177 0.161

2/17/2009 10.1 9.2 0.03 / 0.0005 0.03/ 0.0005 0.062 0.057

8/10/2009 8.3 8.9 0.03/0.01 0.07/0.009 0.032 0.031

1/26/2011 11.6 11.7 0.028/0.0037 0.03 J / 0.0047 0.16 0.16

7/28/2011 7.64 8.53 0.017/0.005 0.016/0.0047 0.071 0.08

Outfall 004 Flouride (mg/L) Cyanide (Total/WAD) (mg/L) Total PCBs

(ug/L)

2/23/2007 11.1 0.01 6.1

2/17/2009 Dry Dry Dry

8/10/2009 Dry Dry Dry

1/26/2011 9.44 0.01/0.0047 0.28

7/28/2011 Dry Dry Dry

Outfall 005 Fluoride Cyanide (Total/ WAD) PCBs

mg/L mg/L ug/L

2/23/2007 20.2 N/A N/A

2/17/2009 14.8 0.01/ 0.0005 0.14

8/10/2009 11.3 N/A N/A

1/26/2011 20.8 N/A N/A

7/28/2011 13.7 N/A N/AFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 121 of 145



### Appendix H

- Response to Comments

Ecology published notice of an opportunity to comment on the renewal of the NPDES Permit

No. WA000 2950 in the Ferndale Record on Aug ust 27, 2014 . The proposed permit will allow

the Intalco Aluminum Corporation (Intalco) to discharge process wastewater and stormwater to

the Strait of Georgia. In the notice, Ecology invited pu blic review of the proposed permit and

provided a 62

- day public comment period. The deadline for submittal of written comments was

October 27 , 201 4

.

Ecology received written comments from four entities through email during the public comment

period. T hree of the entities submitted their comments together as a group. Changes were made

to the permit, where appropriate, to improve clarity and address the comments. Ecology also

made additional administrative change to improve clarity. The c omments and t he response to

comments are presented below. Comments appear in regular text, followed by Ecology’s

response in italicized text.

Ecology will send a copy of this response to comments to each individual who provided

comments. A copy of the final permit will be sent to all interested parties upon issuance and

posted on the Industrial Section website at http://apps.ecy.wa.gov/industrial/

.

Comments from Puget Soundkeeper Alliance/Friends of the Earth/ RE Sources for

Sustainable Communities (Comments 1

– 5)

1. Fugitive Alumina Emissions Impacts

Soundkeeper is concerned about the impacts of fugitive emissions of alumina ore released

into the environment via aerial deposition during ship unloading. As such, Soundkeeper

strongly supports the imposition of a req uirement for Intalco to conduct a study to determine

the nature and scale of effects on benthic communities in the marine environment of the

Strait of Georgia from fugitive emissions associated with the loading/unloading of alumina

ore at Intalco’s pier. (Agreed Order No. 10887, August 19, 2014) Soundkeeper also

supports the requirement for Intalco to create and submit a Fugitive Alumina Pollution

Prevention Plan. (Draft Permit Condition S11, page 40)

Soundkeeper is, however, concerned that the plan lai d out in Agree Order No. 10887 falls

short of adequately protecting Puget Sound because it contains too much ambiguity. The

agreed order states that “It is understood that should this Study identify significant impacts to

benthic communities, Ecology will require Intalco to propose actions to address the impact.”

(Agreed Order, page 2) How does Ecology define “significant impacts”? Does Ecology’s

definition align with how Intalco defines “significant impacts”? Does Ecology’s definition

align with how I ntalco defines “significant impacts”? Do these definitions adequately protect

water quality and the marine environment in the Strait of Georgia? If there is an

understanding between Intalco and Ecology about what rises to the level of “significant

impact s”, that should be written into the agreed order so that it is enforceable.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 122 of 145

It appears that tiers 2 and 3 of the assessment will only be required if Ecology determines

“the need” for these assessments. By these terms, Intalco is only required to move fo rward if

Ecology takes affirmative action to instruct them to do so. Soundkeeper is concerned about

the risk of delay inherent in the way this is written. Instead, Intalco should be required to

move forward with subsequent tiers of the assessment unless Ecology decided they are not

required for specific reasons. To prevent undue delays, and maintain compliance with the

18

- month deadline for Fugitive Alumina Pollution Prevention (Draft Permit, page 40),

Ecology should amend the agreed order to include spe cific deadlines for Tiers 2 and 3.

Soundkeeper is concerned that the plan ultimately provides for impermissible “self

regulation.” By the terms of the agreed order, Intalco would decide for itself whether it’s

fugitive alumina emissions harm Puget Sound, and if so, what they are willing to do to

address it. Federal case law cautions against “self

- regulatory schemes” like this for strong

policy reasons. See Waterkeeper Alliance v. EPA, 399 F.3d 486, 500 (2nd Cir. 2005);

Environmental Defense Center v. EP A, 344 F3.3d 832, 855 (9th Cir. 2003) (“...stormwater

management programs that are designed by regulated parties must, in every instance, be

subject to meaningful review by an appropriate regulating entity to ensure that each such

program reduced the dischar ge of pollutants” to meet applicable standards”). How will

Ecology ensure that Intalco’s plan will effectively reduce the discharge of fugitive alumina

ore to the Strait of Georgia?

In addition, Soundkeeper is concerned that alumina dust is very lightwei ght and likely travels

by wind and/or water current to a wide area surrounding Intalco’s loading dock. Does

Ecology contemplate this broad range of impact? Or, is Ecology’s concern narrowly focused

on the area immediately surrounding Intalco’s dock? Sou ndkeeper urges Ecology to consider

the wider range of impacts to the Strait of Georgia. Ecology should require Intalco, as part of

its Fugitive Alumina Emissions Impacts Study, to evaluate how far the dust travels from the

dock both at the surface of the water and at the bottom. Intalco’s response to address its

fugitive alumina dust discharges must consider the full range of impacts.

Response to Comment 1: The public comment period was for the proposed NPDES permit

only. Agreed Order #10887 has alread y been issued to Intalco. No changes have been

made to the permit based on this comment.

However, Ecology will provide a response to the questions presented in the comment.

Ecology notes that Attachment 1 of the Agreed Order was mistakenly not included in the

version that was posted on our website. It has been attached to this Response to Comments

to provide additional clarity on the Agreed Order.

Comment #1: The agreed order states that “It is understood that should this Study

identify significant impacts to benthic communities, Ecology will require Intalco to

propose actions to address the impact.” (Agreed Order, page 2) How does Ecology

define “significant impacts”? Does Ecology’s definition align with how Intalco

defines “significant impacts”? Does Ecology’s definition align with how IntalcoFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 123 of 145

defines “significant impacts”? Do these definitions adequately protect water quality

and the marine environment i n the Strait of Georgia? If there is an understanding

between Intalco and Ecology about what rises to the level of “significant impacts”,

that should be written into the agreed order so that it is enforceable.

Condition V.2 of the Agreed Order requires that Washington State regulations,

protocols, and guidance must be used in the Study, including the Sediment

Sampling and Analysis Plan Appendix (SAPA): Guidance on the Development of

Sediment Sampling and Analysis Plans Meeting the Requirements of the Sediment

Management Standards (Chapter 173

- 204 WAC). Publication #03

- 09

- 043. Revised

February 2008. Available at www.ecy.wa.gov/biblio/0309043

. What is considered

to be a si gnificant impact is specified in that document.

Comment #2: Instead, Intalco should be required to move forward with subsequent

tiers of the assessment unless Ecology decided they are not required for specific

reasons. To prevent undue delays, and maintain compliance with the 18

- month

deadline for Fugitive Alumina Pollution Preve ntion (Draft Permit, page 40), Ecology

should amend the agreed order to include specific deadlines for Tiers 2 and 3.

While Ecology understands the concerns about delays, it is important that Ecology

review the sample results and conclusions at the end of each tier to ensure that the

steps taken in the next tier, when applicable, will be necessary and appropriate to

adequately assess the potential impacts. Without the results of each tier, it is

difficult to determine everything that might be required dur ing the next phase of

the assessment.

A flow chart that was included as an attachment to the Agreed Order has been

included as an attachment (Attachment 1) to this Response to Comments to provide

additional clarity about the process.

Comment #3: S oundkeeper is concerned that the plan ultimately provides for

impermissible “self

- regulation.” By the terms of the agreed order, Intalco would

decide for itself whether it’s fugitive alumina emissions harm Puget Sound, and if so,

what they are willing to do to address it. Federal case law cautions against “self

regulatory schemes” like this for strong policy reasons. See Waterkeeper Alliance v.

EPA, 399 F.3d 486, 500 (2nd Cir. 2005); Environmental Defense Center v. EPA, 344

F3.3d 832, 855 (9th Cir. 2003) (“...stormwater management programs that are

designed by regulated parties must, in every instance, be subject to meaningful review

by an appropriate regulating entity to ensure that each such program reduced the

discharge of pollutants” to meet applicable standards”). How will Ecology ensure

that Intalco’s plan will effectively reduce the discharge of fugitive alumina ore to the

Strait of Georgia?

The Agreed Order requires Intalco to conduct the study and for Ecology to assess

the information provided in each tier of the study. As such, Intalco is not the oneFact Sheet for NPDES Permit WA 0 002950

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making a decision about whether the sediments are being impacted; Ecology will be

making that determination. And as stated in the last sentence of Condition V.6,

“Ecology will determine the need for follow up action including source control and

monitoring, mitigation, or remediation”.

As the commenter noted, the permit includes a requirement to develop a fugitive

alumina pollution prevention plan to effectively reduce the discharge of fugitive

alum ina to the Strait of Georgia. This plan is required irrespective of the findings

of the fugitive alumina impact study. Ecology will review and approve the pollution

prevention plan and Intalco will be required to implement it.

Comment #4: In addition, Soundkeeper is concerned that alumina dust is very

lightweight and likely travels by wind and/or water current to a wide area surrounding

Intalco’s loading dock. Does Ecology contemplate this broad range of impact? Or, is

Ecology’s concern narrowly focus ed on the area immediately surrounding Intalco’s

dock? Soundkeeper urges Ecology to consider the wider range of impacts to the

Strait of Georgia. Ecology should require Intalco, as part of its Fugitive Alumina

Emissions Impacts Study, to evaluate how far the dust travels from the dock both at

the surface of the water and at the bottom. Intalco’s response to address its fugitive

alumina dust discharges must consider the full range of impacts.

Ecology concurs with this statement that there is a potential for the fugitive

alumina to travel by wind and water currents to a wider area and be deposited both

horizontally and vertically . That’s why the third bullet in Condition V.4 requires

the facility to “identify the likely fate of these emissions

– spatially (x and y) and

temporally”.

2. Increased Stormwater Pond Action Levels

Soundkeeper notes that the stormwater pond action levels for total suspended solids (TSS)

and aluminum at monitoring point STRMP are higher in the draft permit than they were in

the 20 07 permit. (Draft Permit, Condition S1.D.1 page 12) However, in the Fact Sheet,

Ecology identifies that Intalco exceeded the previous TSS and aluminum stormwater pond

action levels many times (11 for TSS, 15 for aluminum) between April 2007 and October

2 013. (Fact Sheet, page 61) How can Ecology justify raising the action levels when the

facility’s track record demonstrated a pattern of exceedences?

In the Fact Sheet, Ecology justifies raising the stormwater pond action levels by looking at

the Facility’s “great improvements” in stormwater BMPs and ability to meet outfall effluent

limits. (Fact Sheet, page 61) Soundkeeper is not persuaded that these are adequate reasons

to increas e these numbers. Aren’t the action levels designed to gauge the effectiveness of

stormwater source control BMPs? How can Ecology conclude that Intalco’s stormwater

source control BMPs are adequate when it consistently exceeded previous action lev els?

Even if Ecology observed “ great improvements”, the lower action lev els should be retained

so that Intalco continues to improve its sources control BMPs. Aren’t the action levels alsoFact Sheet for NPDES Permit WA 0 002950

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designed to alert the facility of potential spills to the stormwater drainage system in time to

prevent discharge of the spill to surface w ater? How does raising the action levels maintain

protection against the discharge of a spill to surface water?

Soundkeeper also notes that the time period during which an inspection of the drainage area

is required following an action level exceedence w as increased from 48 hours in the 2007

permit, to 72 hours in the current draft. (Draft Permit, page 12) How does Ecology justify

loosening this requirement? If one purpose of an inspection is to prevent ongoing

exceedences, wouldn’t the loosening of th is requirement increase the likelihood of ongoing

exceedences? And, wouldn’t this revision render an inspection less useful because as the

period of time from exceedence increases, information to explain the exceedence may

become less available?

Soundkee per further notes that the 2007 permit requirement for Intalco to produce a report in

the event that it exceeded an action level more than 5 times in a 12 month period is missing

from the current draft. (2007 Permit, Condition S.1.C.2(d), page 15) Why wa s this

requirement removed from the permit?

Response to Comment 2: There are many questions and comments presented in this

comment. They have been divided below with the associated response.

1. How can Ecology justify raising the action levels when the faci lity’s track

record demonstrated a pattern of exceedences? Aren’t the action levels

designed to gauge the effectiveness of stormwater source control BMPs?

How can Ecology conclude that Intalco’s stormwater source control BMPs are

adequate when it consiste ntly exceeded previous action levels? Aren’t the

action levels also designed to alert the facility of potential spills to the

stormwater drainage system in time to prevent discharge of the spill to surface

water? How does raising the action levels maintai n protection against the

discharge of a spill to surface water?

There are two reasons the action levels were adjusted in the proposed

permit: 1) the sample point for the stormwater stream changed during the

permit cycle and 2) the fact that the previous action levels were established

using best professional judgment (BPJ) based on the data collected during

the previous permit cycle. As discussed in the fact sheet, there have been a

number of changes to the discharges at the facility during the last permi t

cycle. During the previous permit cycle, stormwater from the stormwater

treatment pond combined with stormwater that was collected from the non

process areas of the site. The combined stormwater was discharged from

Outfall 002 and the sample results fr om that stormwater were used to

establish performance based action levels, using BPJ, in the previous permit

renewal process. In 2010, the facility diverted the stormwater that was

originally discharged from Outfall 002 to Outfall 001. After the diversio nFact Sheet for NPDES Permit WA 0 002950

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structure was operational, the facility began collecting their stormwater

samples directly from the stormwater pond effluent, instead of the combined

stormwater. Since the stormwater stream was no longer the same stream as

the stormwater stream that was used to establish the previous action levels,

Ecology decided that new action levels should be established for the new

stormwater stream.

In order to establish new action levels, Ecology evaluated the sample results

from a time period where inspections noted implementation of good BMP

practices. As noted in the fact sheet, inspections of the facility during the

permit cycle demonstrated greatly improved BMPs and Ecology did not

identify any areas where additional improvement was necessary. Therefore,

the sample results from the previous permit cycle were used to establish the

new action levels for the stormwater pond effluent. Please refer to the fact

sheet for more details about how the action levels were established. The

action levels are still con sidered to be sufficient to detect a spill to the

stormwater pond.

Finally, the permit now includes permit limits for the stormwater at the

diversion structure in addition to the action levels at the stormwater pond

discharge. An exceedance of the permit limits will be a violation of the

permit.

2. Soundkeeper also not es that the time period during which an inspection of the

drainage area is required following an action level exceedence was increased

from 48 hours in the 2007 permit, to 72 hours in the current draft. (Draft

Permit, page 12) How does Ecology justify lo osening this requirement? If

one purpose of an inspection is to prevent ongoing exceedences, wouldn’t the

loosening of this requirement increase the likelihood of ongoing exceedences?

And, wouldn’t this revision render an inspection less useful because a s the

period of time from exceedence increases, information to explain the

exceedence may become less available?

While the maximum amount of time allowed before an inspection must be

conducted has been increased, t he requirement still states the inspectio n

must be done as promptly as possible after receipt of sampling results.

Ecology increased the timeframe within which to conduct an inspection

from 48 hours to 72 hours to be consistent with a similar notification

requirement in the Industrial Stormwater General Permit (ISGP). Ecology

did not feel it was necessary to be more stringent at the Intalco facility,

especially considering that they have a treatment system for their

stormwater.Fact Sheet for NPDES Permit WA 0 002950

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In addition , the permit now includes permit limits for the stormwater at the

diversion structure. This provides additional incentive for the facility to

conduct the inspection as soon as possible to ensure that they don’t exceed

their permit limit and to prevent ong oing exceedances as well.

3. Soundkeeper further notes that the 2007 permit requirement for Intalco to

produce a report in the event that it exceeded an action level more than 5

times in a 12 month period is missing from the current draft. (2007 Permi t,

Condition S.1.C.2(d), page 15) Why was this requirement removed from the

permit?

The aforementioned requirement has been retained in the draft permit. It is

now located in Permit Condition S1.D.3 Action Level Exceedances Report.

Item d is the same r equirement from the existing permit. The Action Level

Exceedances Report was created to provide a better place for such analyses

to be tracked and documented.

No changes to the permit have been made to the permit in response to these comments.

3. Remova l of requirement to monitor for Aluminum in Secondary Wastewater Treatment

System (SEC) Discharges

Intalco’s 2007 permit required it to monitor its SEC discharges for TSS, Flouride,

Aluminum, Free Cyanide, PCBs and Flow. The draft permit eliminates the re quirement to

monitor SEC discharges for the latter four constituents. While the Fact Sheet identifies

specific circumstances to justify removal of the PCB monitoring requirement, it does not

adequately justify removal of the other three constituents.

In particular, Soundkeeper patently disagrees that Intalco should be relieved of the

requirement to monitor for Aluminum based purely on two years of low discharge levels.

Ecology has clear authority under RCW 90.48.260(1)(a) to require Intalco to continue

m onitoring its SEC discharges for the discharge of pollutants to the Strait of Georgia, and it

should exercise that authority despite pressures from Intalco to scale back monitoring

requirements.

That an aluminum smelter, capable of producing approximatel y 307,000 tons of aluminum

metal each year, would be relieved of the requirement to monitor its SEC discharges for

aluminum is baffling.

Response to Comment 3: First, aluminum is the only monitoring requirement that has

been removed in the proposed permit . As specified by Permit Condition S2.A.1(12),

Intalco is still required to monitor for flow, free cyanide, and PCB’s, in addition to TSS

and fluoride. The frequency of monitoring for PCBs was decreased, as discussed in the

fact sheet. Second, the monit oring required at the effluent is to demonstrate complianceFact Sheet for NPDES Permit WA 0 002950

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with action levels for TSS and fluoride and as a potential indicator of a leak from one of

the landfills for free cyanide and PCBs. The action levels were developed to ensure that

the Permittee w as consistently implementing the required BMPs designed to reduce or

eliminate the respective pollutants, evaluating the cause of any upward trends in pollutant

discharges, and taking corrective action to reverse those trends. The previous permit did

not have an action level for aluminum and it was not being used as an indicator of a leak

from the landfills. As part of the permit renewal process, Ecology evaluated whether action

levels should be developed for aluminum and determined that it was not necessa ry. As a

result, Ecology felt that the monitoring the SEC effluent for aluminum was no longer

necessary.

Please note that aluminum is still required to be monitored in the combined process

wastewater effluent (monitoring point 101) before it is discharged from Outfall 001. There

is a limit for aluminum at this point and an exceedance of this limit would be a violation of

the permit.

No change was made to the permit in response to this comment.

4. Whole Effluent Toxicity (WET) Provisions

Intalco’s 2007 permit did not even contain WET limits for Outfalls 001 and 002.

Soundkeeper supports the inclusion of WET limits in this permit. Simply including WET

limits is a substantial improvement over the previous permit. However, Soundkeeper has

some concerns about the WET requirements as laid out in draft conditions S15 and S16.

Soundkeeper was a party to the 2012 appeal of the BP Cherry Point Refinery permit and

Pollution Control Hearings Board (PCHB) proceedings resulting in the PCHB’s decision on

the acute WET effluent limitation (order on summary judgment, July 26, 2013). The Court

of Appeals granted direct rev iew of that decision in February 2014. The pending Court of

Appeals case is fully briefed, and a hearing is expected this winter. Soundkeeper has also

appealed the December 2, 2013, modification to the BP permit to the PCHB. Soundkeeper

also appealed th e 2014 Phillips 66 permit to the PCHB.

For the following reasons, Soundkeeper asserts that the WET provisions in Intalco’s draft

permit, specifically conditions S15 and S16, are inadequate to comply with either state law of

the terms of the July 26, 2013 PCHB order in the BP Appeal.

a. The Permit Should Prohibit Toxic Discharges

The August 2014 fact sheet issued along with Intalco’s draft permit did not mention the

July 26, 2013 PFHB order in the BP appeal or address whether Ecology purports to

comply with t hat order with this draft permit. As noted above, that order has been

appealed to the Court of Appeals. As part of this ongoing legal debate, Soundkeeper

insists that the order reflects a faulty interpretation of state law on WET effluent

limitations.Fact Sheet for NPDES Permit WA 0 002950

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S oundkeeper maintains that the permit may not authorize a discharge that fails the

compliance test for acute or chronic WET, thus violation the effluent limit for acute of

chronic toxicity. Washington’s water quality standards prohibit the discharge of tox ic

substances that cause acute or chronic toxicity in the receiving waters. WAC 173

-

3201A

- 240. The following prohibition is found in state statue: “In no event shall the

discharge of toxicants be allowed that would violate any water quality standard, in cluding

toxicant standards, sediment criteria, and dilution zone criteria.” RCW 90.48.520. The

purpose of the WET testing under WAC 173

- 205 is to determine whether a discharge is

toxic and subject to the prohibition. This regulation describes monitoring for compliance

with WET limits, and states that the compliance test “shall be considered to be a

maximum daily discharge permit limitation.” WAC 173

- 205

- 070(1)(d) and 173

- 205

- 070(2)(d).

The test for permit compliance must be the same as the compliance t est for acute and

chronic toxicity, as defined by the regulation. The permit may not authorize a toxic

discharge, which is one that fails the acute of chronic toxicity compliance test. Sections

15 and 16 already provide procedures for Intalco to demonstr ate that a failing WET test is

an anomaly to invalidate it. There is not legal, practical, or rational basis for

interpretation of these state laws and regulations that would allow authorization of any

discharge that fails a WET compliance test. Sections 15 and 16 should be rewritten to

effect the prohibition on toxic discharges be equating and failure of the compliance test

with violation of the acute of chronic WET effluent limitation and the permit.

b. The Anomaly Allowance Should be Singular, Not Quarter ly

Even assuming acceptance of the PCHB’s interpretation in its July 2013 order in the BP

case, the proposed provisions in Intalco’s draft permit are problematic. These provisions

as drafted make violation of the permit contingent on the failure of a follow

- up WET test

for each regularly scheduled acute and chronic WET compliance test failure. In other

words, no failure of a regularly scheduled WET test would constitute a permit violation

unless a subsequent test is also failed. This is unacceptable. Repeated failures of

regularly scheduled WET test indicate an ongoing pattern of toxicity regardless of the

results of each follow

- up test. S15 and S16 should clarify that any failure of any WET

test following the first failure recorded during the permi t constitutes a permit violation.

Soundkeeper recognizes that the proposed language represents a minor improvement over

similar language in other permits, including BP’s. Specifically, S15.C. and S16.C.

include mention of a situation where a toxicity test may be “a violation of the permit”.

However, the language still fails for lack of clarity, and the provisions still suffer from

the fundamental problems noted above.

Soundkeeper would point to the WET limit language that Ecology’s Northwest Regional

O ffice incorporated into NPDES Permit No. WA0031968 for Seattle Iron & MetalsFact Sheet for NPDES Permit WA 0 002950

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Corporation as a more appropriate permit drafting response to the PCHB’s order on WET

Limitations.

Response to Comment 4: With respect to part a of the comment, the WET language in

Conditions S15. and S16. is consistent with the PCHB’s decision regarding

exceedances of WET limitations. The Board deferred to Ecology’s determination that

a single WET limit exceedance does not indicate a pattern of toxicity. Instead, it

triggers ad ditional testing aimed at determining if there is continued toxicity and a

violation of the toxicity standard in the permit. If any of the subsequent tests fail the

WET limit, that test failure is a violation of the permit.

Ecology does intend to follo w the decision made by the Court of Appeals if the PCHB

ruling is overturned. How that decision will be implemented in the permit will be based

upon the Court’s direction to Ecology.

With respect to part b of the comment, while the proposed permit langua ge may not

cover the exact scenario described in the comment, the permit is not the only tool that

Ecology has to address this situation. Follow up testing for repeated failures in

compliance monitoring would be a very costly scenario for any permittee. As such, the

permittee would have an incentive to initiate the TI/RE process on their own accord, in

accordance with WAC 173

- 205

- 090(4). An additional incentive is the ability for

Ecology to reduce compliance monitoring during the TI/RE process if the con ditions of

WAC 173

- 205

- 100(4) are met.

WAC 173

- 205

- 090(2) requires that any permittee failing the compliance test for a

whole effluent toxicity limit shall take all reasonable actions to achieve compliance

including conducting a TI/RE. If the described scenario occurred and the permittee

did not initiate the TI/RE on their own accord, Ecology would have the authority to

issue an order requiring the facility to conduct a TI/RE.

5. Creosote Pilings

Intalco’s dock, which was built in 1971, is supported by creosote

- treated wood piling. This

concerns Soundkeeper because it is well

- established that creosote is highly toxic to forage

fish, including the genetically unique stock of Cherry Point Pacific Herring. Soundkeeper is

especially worried by reports that the artificial surface lighting on Intalco’s dock attracts

herring to the pilings, and that the polycyclic aromatic hydrocarbon (PAHs) in the creosote

cause Herring spawning failure. Given that creosote leached into the environment and

contributes to the decline of the Cherry Point Pacific Herring stock, Intalco should be

required to eliminate its discharge of creosote to the Strait of Georgia. Soundkeeper urges

Ecology to create a schedule to require Intalco to either replace or encapsulate its creosote

pillions with a more benign material. Ecology should look at t h e Squamish Streamkeepers

work in Howe Sound as a cost

- effective example of piling encapsulation.

http://www.sqterminals.com/community/involvement/squamish

- streamkeepers/Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

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Response to Comment 5 : While Ecology understands the concern expressed in this

comment, the transfer of pollutants from the pilings to the surface water is not considered

to be within the scope of this permit, which regulates the point source discharge of

pollutants. The Department of Natural Resources (DNR), the Army Corps of Engineers,

or an other agency that regulates the dock may be able to require the measures that you

propose and you should contact them for more information.

No change was made t o the permit based on this comment.

Comments received from Intalco (Comments 6

– 36)

6. S1.D.3 Action Level Exceedance Report (pg. 13 of 79): Intalco is requesting the

following language clarification to ensure the semi

- annual action level Exceedance report

can be completed on time with all of the necessary data. The semi

- annual report

requirement in the draft permit does not clearly define the time

- periods for each of the

semi

- annual reports. Accordingly, Intalco requests that Ecology include the fo llowing

additional language in permit condition S1.D.3:

“The Permittee shall submit an Action Level Exceedance Report no later than July 15 th

and January 15 th of each year. The semi

- annual reports shall represent January through

June and July through Dec ember, respectively. The semi

- annual report shall include...”

Response to Comment 6: Ecology concurs that the suggested language provides clarity

to the requirements of Permit Condition S1.D.3. The changes were made as requested.

7. S1.D.4 Visual Inspections of the Stormwater Discharges (pg.14 of 79): Intalco requests

to continue to use facility specific Best Management Practices (BMPs) and remove the

more generalized S1.D.4 language from the permit.

Response to Comment 7: The visual inspections required by permit Condition S1.D.4

are necessary to evaluate the effectiveness of the BMPs associated with the discharge.

The visual inspections are essential to ensure that the stormwater is being

appropriately managed prior to discharge. However , whe n Ecology compared the new

language in the proposed permit to the inspection language in the existing permit, we

noted that the proposed language specifically requires inspection of the stormwater

discharge. In this case, the term discharge can either be interpreted as the discharge

point or, more specifically, the flow of stormwater from the discharge point. Ecology

recognizes that there will be some months during the year where stormwater is not

discharged, but it is still important to inspect the storm water discharge points to

identify illicit discharges or other pollutants that could indicate that the BMPs need to

be evaluated.

The first two sentences of Permit Condition S1.D.4 have been modified as follows:

“ The Permittee must conduct monthly inspe ctions of the stormwater pond dischargeFact Sheet for NPDES Permit WA 0 002950

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point (Monitoring Point STRMP), Outfall 011, and Outfall 012. The inspections must

be conducted by qualified personnel.

Each inspection must include visual observations of the stormwater sampling locations

and are as where stormwater is discharged to waters of the state for the presence of

potentially deleterious pollutants, such as floating materials, visible sheen,

discoloration, turbidity, odor, or presence of illicit discharges, such as domestic

wastewater, nonc ontact cooling water, process wastewater, etc. “

8. S2.A.1 Monitoring Schedule, MP51 (pg. 17 of 79): Intalco has an extensive set of data

documenting the consistent nature of the pH from the sanitary lagoon, which

demonstrates that since 2011 the pH has very low variability. Minimum pH since 2011:

6.10 Maximum pH since 2011: 7.63. From October 2013 to October 2014: pH

variability: pH Max: 7.63, pH Min: 6.44. Thus, Intalco requests a reduction in

minimum sampling frequency from 3 times per week to 1 ti me per week.

Response to Comment 8: Based on the information provided in this comment, the

monitoring frequency for pH in the sanitary effluent has been reduced from three

times per week to one time per week, as requested.

An additional footnote (footnote aa) has been added to the monitoring table associated

with all the parameters that have received reduced monitoring during the previous

permit renewal process and this permit renewal process. The footnote states “The

monit oring frequency for this parameter has been reduced based on exemplary

performance. To remain eligible for these reductions, the Permittee may not have any

violations off effluent limitations or exceedances of the action level for this parameter

or fail t o submit DMRs. Violations of the effluent limit or exceedance of the action

level for the parameter, failure to submit DMRs, or any other formal enforcement

action may require increased monitoring. If such increased monitoring is deemed

necessary by Ecol ogy, the new monitoring frequency will be established by a minor

permit modification or an Administrative Order.”

9. S2.A.1 Monitoring Schedule (11) Stormwater Pond Action Level Monitoring MP

STRMP (pg. 20 of 79):

- pH grab sample

- The facility continuously m onitors pH of the

stormwater at the STRMP monitoring point, during a storm event Intalco is required to

collect a grab sample and measure pH. Intalco requests the ability to use pH data from

the calibrated continuous monitoring pH probes, which collects d ata from the same

stormwater flow, to meet this requirement in lieu of collecting grab samples. This pH

characterization method meets the intent of the requirement and offers equivalent

environmental protection.

Response to Comment 9: Ecology concurs th at continuous monitoring for pH will

demonstrate compliance with the action levels for the Stormwater Pond. The permit

has been modified to require continuous pH monitoring during the storm event and toFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 133 of 145

require that the instantaneous maximum and minimum b e recorded once per storm

event.

10. S2.A.1 Monitoring Schedule, MP SEC (pg. 21 of 79): Intalco requests addition of a new

footnote for the potential of a Natural Engineering Waste water Treatment (NEWT)

system, designed to treat free cyanide. With comple tion of the project, Ecology may

approve discontinuation of free cyanide testing at the SEC upon written request.

Response to Comment 10: Ecology concurs that the addition of the NEWT system has

the potential to address the concern that free cyanide may possibly be discharged to the

SEC from the closed landfills. However, Ecology will need to evaluate the monitoring

data before allowing a reductio n in the monitoring frequency at the SEC for free

cyanide. A new footnote has been added to the monitoring table to reflect this

possibility. Footnote bb states “ The Permittee may request a reduction in the

monitoring frequency of free cyanide at the SEC once the Natural Engineering

Wastewater Treatment (NEWT) system has been operational for at least 12 months.

Based on the free cyanide results at the SEC for a 12 month period, the monitoring

frequency may be reduced upon written not ification from the D epartment.”

11. S2.A.1 (14) Monitoring Schedule, Production Data (pg. 21 of 79): Intalco is requesting

the units be changed from “People on

- site/Day” to “monthly personnel count.” This

change would make the units consistent with the language in S1.A. footno te (c) for

Monitoring Point 51: “monthly average of personnel working on site...”.

Response to Comment 11: Ecology concurs that language between the limits table in

Permit Condition S1.A and the monitoring table in Permit Condition S2.A.1for a

specific pa rameter should be the same. The units and specification column for

“personnel” has been modified to “personnel working onsite”, as specified by

footnote(c) for Permit Condition S1.A.

12. S2.A.1 Footnote (i) (pg. 22 of 79): Footnote (i) requires continu ous monitoring

instruments to achieve an accuracy of 0.2 degrees C. This provision appears to be a

typographical error which is inconsistent with temperature calibration and tolerance

requirements as specified by the EPA Code of Federal Regulations (40 CF R 136) and

standard methods for the examination of water and waste water.

Preamble language to the CFR mentioned above suggests that the EPA has adopted the

National Environmental Laboratory Accreditation Committee (NELAC) requirement for

temperature req uirements. The NELAC standard provides 4 ± 2 oC for sample

preservation temperature. Moreover, the EPA has proposed a ≤6.00 oC (unfrozen)

sample preservation temperature because maintenance of a 4 ± 2 oC temperature requires

an active refrigeration syste m (which will raise sample shipping costs), and because EPA

is not aware of any evidence to suggest that allowing refrigeration below 2 oC (the lower

limit of NELAC standard) will adversely affect samples.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 134 of 145

Based on the above, Intalco respectfully reques t that the agency change the language of

this requirement to require that continuous monitoring instruments be maintained to +/

- 2

degrees C, or to the manufacturer’s recommended tolerance.

Response to Comment 12: The referenced NELAC standard is for the preservation

temperature required for storage of samples prior to analysis; it is not referring to the

accuracy of temperature gauges for measuring the temperature of the wastewater

effluent. An accurate measureme nt of the temperature of the effluent is important to

be able to demonstrate that there is not a reasonable potential for the effluent to

degrade the water quality of the receiving water. However, since the permit does not

include any limits for temperatu re at any of the outfalls, the footnote has been revised

to state “continuous monitoring instruments must achieve an accuracy of 0.2 degrees

C (or as otherwise approved by Ecology)”.

13. S2.A.1 Monitoring Schedule, MP D10, Footnote (r) (pg. 23 of 79): The requirement to

sample at MP D10 shall trigger based on a storm event defined in footnote (r) except that

the required monitoring frequency should be changed in the footnote to not to exceed

once per week.

Response to Comment 1 3 : The footnote for the par ameters in this section should have

been (v). This has been corrected in the final permit

14. S2.A.1 Footnote (n) (pg. 23 of 79): Intalco requests the third sentence of footnote (n) be

removed. The sanitary lagoon system only treats facility sanitary wastewater in a

continuously operating passive system. As a 24/7 facility Intalco’s sanitary operations

have a very low level of variability week to week, with limited inputs to the system. The

required 24 hour composite samples will be similar irrespect ive of which week of the

month is sampled. Data analysis and review demonstrates that in the past year the

maximum TSS discharge was 7.4 lbs/day, which is only 22% of the weekly maximum

limit. Similarly, the BOD maximum discharge was 15.5 lbs/day, which is 48% of the

weekly maximum limit. All other results were below these values, with average TSS of

1.26 lbs/day (1.73 lbs/day std dev) and average BOD at 5.41 lbs/day (4.5 lbs/day std dev).

Response to Comment 1 4 : Because the information provided with t he comment

demonstrat es the low variability of BOD in the sanitary effluent, Ecology has made the

change as requested.

Please note that Permit Condition S2.B requires that sampling be represent ative of the

discharge, including an y unusual discharge or discharge condition.

15. S2.A.1 Monitoring Schedule, PUD Intake Water: S2A.1 Footnote (z) (pg. 24 of 79):

Intalco requests that Ecology replace the second sentence of footnote (z) with the

following: “Sampling is required at the PUD inlet only when I ntalco nets out pollutants.”Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

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Response to Comment 1 5 : Permit Condition S1.A.1 allows the facility to net out certain

pollutants that are present in the water that is supplied to the facility. In order to be

able to net out, the facility must be able to characterize the intake water appropriately.

As such, E cology considers sampling of the influent water to be required sampling for

the facility. However, Ecology understands that the facility may choose not to net out

the pollutants at certain times, and indicated that sampling is not required during those

in stances in Footnote (z) for Permit Condition S2A.1

. The comment does not describe

the concern with the proposed language in the draft permit and does not provide a

justification for the changed language. Without an explanation as to how the facility

woul d be able to predict when sampling of the intake water would not be necessary,

Ecology has retained the requirement for sampling the intake water.

While reviewing this comment, Ecology noted that the language was specific to the

months when the facility does not net out, which does not represent all of the sampling

periods. The language has been modified as follows: “ Sampling is not required

during a respective sampling period if Intalco does not plan to net out during that

sampl ing period for that pol lutant.”

Ecology also noted that the reporting requirements specified in the Monitoring

Requirements condition (Permit Condition S2) did not include a requirement to report

the net loading rate for the pollutants that are allowed to net out. A requireme nt to

report the calculated net loading rate has been added for TSS, aluminum, nickel, and

antimony. Language has also been added to Footnote a to specify how the net loading

rate should be calculated. In addition, the language in Permit Condition S1.A.1

describing the information that must be included in the DRM summary sheets has been

removed. This data will be required to be submitted with the electronic DMR instead of

on a summary sheet.

16. S2.A.2 Temporary Curtailment Reduced Monitoring Frequencies , MP 101 (pg. 24 of

79): Intalco recommends adding fluoride and free cyanide to the table for Outfall 001

(monitoring Point 101) at a monitoring frequency of once per month. Curtailment

activity will similarly lead to reduced risk of contamination from t hese pollutants, thus

justifying a reduction to a once per month monitoring frequency.

Response to Comment 1 6 : While Ecology understands that curtailment activity will

lead to reduced risk of contamination from fluoride and free cyanide generated by

production activities at the facility, production activities are not the only source of

fluoride and free cyanide to Outfall 001. The leachate collection systems for the closed

landfills at the facility are also sources of these contaminants to the wastewater

generated by the facility and discharged from Outfall 001. The leachate from the

closed landfills will not be affected by curtailment activities and monitoring for these

contaminants in the discharge at the same frequency as when the plant is fully

operational is still considered to be necessary during curtailment periods. The facility

can petition for a reductio n in monitoring in accordance with Permit Condition S2.E ifFact Sheet for NPDES Permit WA 0 002950

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sufficient data is gathered to demonstrate that the specified frequency is no longer

necessary.

No changes have been made to the permit.

17. S2.A.2 Temporary Curtailment Reduced Monitoring Freq uencies, MP STRMP (pg. 24 of

79): Intalco is requesting a reduction in the stormwater pond action level monitoring if

the facility enters a curtailment scenario. The facility requests sampling for all

parameters listed in the table occur a maximum of onc e per week. The potential

concentration of stormwater pollutants will be reduced with the reduction in operations

during a curtailment.

Response to Comment 17: As specified by Permit Condition S2.A.2(3), monitoring for

TSS, Fluoride, and Aluminum has already been reduced to once per week during

curtailment and only if there is a storm event. The heading for this subsection was

changed to “Stormwater Pond Action Level Monitoring (Monitoring Point STRMP)”

to better distinguish this requirement. The onl y monitoring that continues to be

required during curtailment is flow and pH, both of which are continuously monitored.

Flow is required to determine if a storm event has occurred and pH is an indicator of a

potential spill to the stormwater pond.

No c hange has been made to the permit with respect to the comment.

18. S2.A.2 Temporary Curtailment Reduced Monitoring Frequencies, Footnote (a) (pg. 25 of

79): Footnote (a)

– Intalco recommends adding to the footnote “Monthly means once

every calendar month, a lternating weeks within the month when practicable.”

Response to Comment 18: Ecology has made the change as requested.

19. S2.C.3.b Flow Measurement, Field Measurement and Continuous Monitoring Devices

(pg. 26 of 79): This calibration requirement is inconsistent with calibration based on

manufacturer’s recommendations. Intalco recommends changing the language to the

following:

“The Permittee shall calibrate the continuous monitoring probes using a 2 point

calibration with standard pH buffers or per the manufacturer’s recommendations.”

Calibrating the continuous monitoring probes in the manner is consistent with

manufacturer’s recommendations and better meets the intent of the requirement.

Response to Comment 19: Ecology has made the change as requested.

20. S3.A.1. Reporting (pg. 27 of 79): Intalco requests that a secondary process be established

in the permit to submit the DMR data if there are unforeseen circumstances. For

example, if the Department of Ecology website is down, then there sho uld be an

alternative procedure for timely submittal of DMRs. Intalco recommends the followingFact Sheet for NPDES Permit WA 0 002950

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language be added: “If unable to submit electronically, the Permittee may submit paper

or email copies of results to their industrial section contact along wit h documentation of

the reason for submitting the alternate copies. The facility will resubmit the data to the

Ecology web system as soon as practicable, when it again becomes available.”

Response to Comment 20: Ecology is requiring the electronic submit tal of DMRs in

response to EPA’s proposed NPDES Electronic Reporting Rule. It is expected that the

final rule will have language to address the concern presented in this comment.

Ecology does not want to include language, suc h as the proposed language, in NPDES

permits at this time in case it is less stringent than the final rule. Ecology will have

enforcement discretion if such a violation were to occur and would take the unforeseen

circumstances i n to account. T he permit does not preclude Intalco from t aking the

actions described in the above comment. Ecology would also take such actions into

consideration. No changes have been made to the permit

.

21. S3.A.5.b. Reporting (pg. 27 of 79): Intalco believes that the methods of averaging data

identified in this section could inadvertently bias data. Accordingly, Intalco is

recommending adding the language, “or by the agency”, to allow for increased agency

flexibility in order to accommodate unanticipated circumstances that could unduly bias

results.

“Calcu late average values (unless otherwise specific in the permit, or by the agency )

using:

a. The reported numeric value for all parameters measured between the agency

- required

detection value and the agency

- required quantitation value....

b. One

- half the detection va lue (for values reported below detection) if the lab detected

the parameter in another sample from the same monitoring point for the reporting

period.”

Response to Comment 21: Calculating an average value for pollutants that are

detected in one sampling e vent but not in another during the same monitoring

period will always create a potential bias, no matter what method you use to

calculate the average (i.e. assuming zero or assuming half of the detection level).

However, the detection of the analyte in ano ther sample during the same

monitoring period provides evidence that the analyte is present in the effluent

stream. As such, the agency is establishing a standard procedure for all permittees

so that everyone is performing the calculation in a consistent way. Adding the

requested language would potentially create an inconsistency between your facility

and other permitted facilities around the state and the comment does not provide

sufficient information to demonstrate that such an inconsistency is necessa ry for

this facility.

No change has been made to the permit based on this comment.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

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22. S3.A.3 Reporting (pg. 27 of 79): The permit states that if values are reported as below

the detection level, the Permittee should document the method detection level o f the

method used. However, due to the high level of variability or inaccuracy of values below

the method quantitation level, data below the quantitation level should not be used for

compliance purposes. As a result Intalco recommends that all values bel ow the

quantitation and detection levels should be treated as zero.

Response to Comment 22: As stated in Section 4.3 of Chapter VI in Ecology’s Permit

Writer’s Manual, “an analytical result that falls between the method detection limit

(MDL) and the quantitation level (QL) means there is a level of certainty that the

analyte is in the sample”. A s such, assuming a value of zero for such samples is

inappropriate.

No change has been made to the permit.

23. S3.E.2 Reporting Permit Violations (pg. 29 of 79): Intalco is requesting that when repeat

sampling and analysis is required per this section, results of the analysis be submitted in

the applicable monthly DMR, rather than within 30 days. Reporting of permit violations

is already triggered in the 24 hour reporting requirements, which also includes a

requirement to submit a 5 day follow

- up report . Section S3.E.e also requires information

submittal with the applicable monthly DMR. This will make the information more easily

traceable and reports more complete.

Response to Comment 23: Ecology concurs that submitting any repeat sampling and

analys is with the applicable monthly DMR will make it easier to track. The change has

been made as requested.

24. S4 Operations and Maintenance (pg. 31 of 79): Paragraph 1

- Replace the sentence

“Proper operations and maintenance also includes keeping operationa l logbooks (paper or

electronic)’ with “Proper operation and maintenance also includes, but is not limited to,

operational logbooks (paper or electronic), laboratory controls, and quality assurance

procedures.”

Response to Comment 24: The requested chang e has been made to the permit.

25. S4 Operations and Maintenance (pg. 32 of 79): Paragraph 2

– Intalco conducts both

scheduled and unscheduled maintenance activities. Intalco has systems in place which

are designed to minimize and to the greatest extent possible, avoid discharges which

degrade effluent quality to waters of the state. These pr actices meet the intent of this

provision and therefore Intalco requests the removal of paragraph 2 from the draft permit.

Response to Comment 25: Meeting the intent of a requirement is not sufficient reason

to delete the requirement from the permit. N o change has been made to the permit.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

Page 139 of 145

26. S4.B. Bypass Procedures (pg. 33 of 79): Intalco requests addition of the following

underlined language to clarify the intent of this provision: “this permit prohibits a

bypass, which is the intentional diversion o f waste streams from any portion of a

treatment facility, unless the bypass meets the conditions listed below .”

Response to Comment 26: As stated in the third paragraph of Permit Condition S4.B,

“Ecology may take enforcement action against a Permittee fo r a bypass unless one of

the following circumstances (1, 2, or 3) applies”. The bypass is still prohibited

. The

conditions only indicate the circumstances under which Ecology will not enforce on

the violation. This is a federal rule as specified by 40 C FR 122.41(m)(4). No change

has been made to the permit.

27. S4.B.3 Bypass Procedures (pg. 34 of 79): Intalco recommends the following language

for S4.B.3.a: “The Permittee must notify Ecology at least thirty (30) days before the

planned date of bypass, i f possible.” While Intalco intends to notify Ecology 30 days in

advance of any planned or anticipated bypass scenarios, there may be other

circumstances, such as emergencies, that arise that could make 30

- day advance

notification impossible.

Response to Comment 27: Emergency situations as described in the comment are

covered by S4.B.2. No change has been made to the permit.

28. S10. Stormwater Pollution Prevention (pg. 38 of 79): Intalco recommends removal of the

language “Comply with applicable federal technology

- based treatment requirements

under 40 CFR 125.3.” The remaining three conditions already meet the intent of this

provision.

Response to Comment 28: The specified language was originally included because it is

part of the Industrial Stormwater General Permit (ISGP). With stormwater being

included as part of the Intalco’s individual NPDES permit, Ecology evaluated whether

Intalco was applying technology

- based treatment for the stormwater generated on site.

Ecology has determined that the stormwater pond is providing all known, available,

and reasonable treatment technologies (AKART) for the facility stormwater

. As such,

Ecology concurs that the referenced language is not necessary for th is permit. The

permit has been modified as requested.

29. S10.A Stormwater Pollution Prevention Plan Update (pg. 39 of 79): Intalco requests that

the requirements referenced in bullet #3 for Permit Condition S3.B.1 of the Industrial

Stormwater General Pe rmit be added into the Intalco NPDES Permit for ease of

reference.

Response to Comment 29: The permit has been modified as requested.

30. S15.A. Acute Toxicity

– Outfall 002 Effluent Characterization (pg. 42 of 79): Intalco

requests elimination of the re quirement to conduct quarterly acute toxicity testing startingFact Sheet for NPDES Permit WA 0 002950

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in 4 th Quarter 2014. Rather, quarterly acute toxicity testing should begin the first quarter

after permit issuance, to be consistent with other toxicity characterization stated in the

permit.

Response to Comment 30: Comment noted. The permit has been revis ed to include the

correct quarter to begin the effluent characterization for Outfall 002

.

31. Throughout Permit: Intalco has reviewed the timing of the study plans, studies, reporting

requirements and other water related improvement projects at the facili ty and request the

following changes to the project due dates to levelize project planning and execution and

ensure quality outcomes. Specifically, Intalco is proposing to move 2 of these project

timelines to manage the project load. The first project is the SEC Efficiency Study Plan

(From the Summary of Permit Report Submittals (pg. 6 of 79)). Intalco requests

changing the submittal of the plan from “within 6 months of Permit Issuance” to “Within

24 months of permit issuance.” The second project is the Ground Water Impact Study

(S19.1 (pg. 56 of 79)). Intalco requests changing “Conduct a Ground Water Impact

Study within 180 days of Ecology’s approval of the Ground Water Impact Study Plan

Submitted by Intalco dated February 26, 2010” to “Conduct a Groun d Water Impact

Study within 180 days of Ecology’s approval of the Ground Water Impact Study Plan

Submitted by Intalco dated February 26, 2010, beginning no earlier than January 2017.”

Response to Comment 31: Many of the studies included in the draft perm it are studies

that were required in the previous permit. Ecology wants to ensure that the plans for

these studies, where applicable , and the study itself are conducted during this permit

cycle. At least some of the studies will require time to collect r epresentative samples or

may include schedules for implementing the results of the study. Therefore, the two

requirements mentioned were scheduled to provide sufficient time to conduct the

studies, provide the results, and implement any necessary actions, if applicable, before

the next permit renewal application is due.

The SEC Efficiency Study Plan will need to include a schedule for conducting the

study. The facility may propose a schedule that takes into account the various other

studies that will be occurring at the same time.

No change has been made to the permit in response to this comment.

32. Intalco Fact Sheet, Solids Management, (pg. 15 of 121) paragraph 4: In this paragraph,

it is mentioned that Intalco will require removal of solids from the Sanitary Lagoon every

10 to 15 years. The population of employees at the facility is approximately one half of

the population used to develop the estimate, therefore the time between solids removal

should be doubled to 20

- 30 years.

33. Permit Fact Sheet: Technology based effluent limits (pg. 32 of 121 ): To remain

consistent between the Permit and Fact Sheet documents, Intalco is recommending theFact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

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following change to the language in paragraph 1, which discusses the anode cooling

preliminary sampling results: Remove: “..., the draft permit requires the Permittee to

complete the AKART analysis...” with, “if Intalco AKART analysis during the next

permit cycle.”

34. Intalco Fact Sheet, (pg. 54 of 121): Intalco requests that the statement referencing Table

22, regarding the whole effluent toxicity (WET) results from December 2010, be

corrected. As enumerated in the Draft Permit and affirmed by Ecology, the December

2010 WET results were anomalous. The refore it is not correct to state that results from

this test fail to meet the requirements of the WET performance standards. If Ecology

elects to Comment, then an accurate statement would be that the 2010 WET results were

inconclusive.

35. Intalco Fact Shee t, (pgs. 68 & 69 of 121): Intalco requests that the herring embryo test

duration be restated as 16 days, rather than 10 days, to be c onsistent with the

requirements specified in Washington State Department of Ecology guidelines.

Response to comments 3 2 through 3 5 : Comments 3 2 through 3 5 are on the fact sheet,

which provides information on how the permit conditions were established. The fact

sheet is provided for informational purposes only and is not a legally enforceable

document. As stated on Page 1 of the Fact Sheet, Ecology does not revise the fact sheet

in response to public comments. Occasionally, Ecology will revise the fact sheet if

there are significant changes made to the permit and it is necessary for the fact sheet to

be revised to explain the changes or there is incorrect information in the fact sheet.

Comments 32 through 34 do not require any changes be made to the permit and they

did not identify errors in the fact sheet.

Comment 35 does identify an error. Intalco is correct that th e chronic toxicity test for

herring is a 16

- day test embryo development test and a 7

- day larval survival and growth

test, rather than a 10

- day embryo survival and normal development test. However, the

herring WET tests are not included as part of the NPDE S permit and the facility is

required by an order to follow the appropriate protocols when conducting the tests.

The fact sheet is not a legal document and, therefore, does not affect the requirements

for the herring testing.

T

he fact sheet has not be en revised based on these comments . These comments will be

included in Appendix H of the fact sheet to document the observations made by Intalco

about the contents of the fact sheet.

Comment received from the Department of Health (Comment 3 6 )

36. The Health Department contact phone numbers are wrong on the top of page 30 on the

permit (Section S3.E.a. Immediate Reporting). The numbers you have listed gets you

our NW Regional Office for the Drinking Water Program (both business and after

hours). The correct numbers are (360) 236

- 3330 (business hours) and (360) 789

- 8962Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

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(after hours). The latter number goes to our rotating on

- call smart phone. Alternately,

you call also e

- mail us at sf.growingarea@doh.wa.gov , which will also connect with

whoever is carrying the smart phone. Thank you for your attention to this matter.

Response to Comment 3 6 : Ecology appreciates the comment. The correct phone

numbers and the email address have been included in the final permit.

Internal Review Comments and O ther Administrative Changes

As part of t he permit finalization process, the proposed permit is reviewed by our permit

database coordinator. She identified a few administrative changes that will provide

clarity to the permit and assist in setting up the electronic DMR submittal forms. The

changes that were made based on her review are as follows:

• The following changes were made to the Summary of Permit Report Submittals

table on Page 5 of 80:

o The “First Submittal Dates” were updated to include specific dates, where

applicable,

o Three discharge monitoring reports were added to clarify that there are

monthly, quarterly, semi

- annual, and annual discharge monitoring reports

associated with this permit. The first submittal dates were included to

specify whe n the first discharge monitoring report is due for each

applicable monitoring report,

o The toxicity test results required by Permit Condition S15.F and S16.F

were split into the winter and summer submittals (4 submittals total) and

the first submittal dat e for each of the submittals was updated to indicate

the results are due within 45 days of sampling. The first submittal date

also now includes a “no later than” due date to further clarify when the

samples must be collected (i.e. no later than November 1 5, 2018 for the

final summer samples and no later than May 1, 2019 for the final winter

samples).

The proposed permit indicated that the WET test results should be

submitted with the permit renewal application, but that may be too late to

address potent ially anomalous results. Submitting the test results within

45 days of sampling will provide Ecology the opportunity to review the

results and alert the facility if there are any issues with the test results.Fact Sheet for NPDES Permit WA 0 002950

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o Permit Condition S18 was modified to indica te that the facility is required

to submit either an AKART evaluation or documentation of elimination of

the anode contact cooling water discharge.

• Permit Condition S1.A.1 was modified to remove the language about how to

calculate the net loading rates for certain pollutants and how to report the results

of those calculations. The language on how to calculate the net loading rates was

moved to footnote a of the monitoring in Permit Condition S2.A.1. And the same

monitoring table specifies the reporting requirements for those pollutants.

• The following changes were made to the monitoring table for Permit Condition

S2.A.1:

o Added the requirement to report the calculated net loading rate in lbs/day

on a monthly basis for TSS and aluminum and on a semi

- annu al basis for

nickel and antimony.

o Added the requirement to monitor the flow of the PUD Intake Water (13).

The parameter was added because the flow rate is necessary to calculate

the lbs/day loading rate required for the pollutants monitored in the PUD

in take water.

o As discussed above, footnote a was modified to include the method for

calculating the net loading rate for those pollutants that are required to

report a net loading rate.

• Permit Condition S3.A.8.d has been modified to indicate that the priority pollutant

monitoring results must be included with the annual DMR.

• Permit Condition S3 was modified to indicate that submittals must be submitted

through the Water Quality Permitting Portal

– Permit Submittals application.

This requirement was a dded as Permit Condition S3.B and the existing Permit

Condition S3.B was renumbered as S3.C, S3.C was renumbered as S3.D, etc. All

requirements to submit a paper copy and PDF copy of a submittal were removed

throughout the permit.

• Permit Conditions S 15.F.1.ii, S15.F.2.ii, S16.F.1.ii, and S16.F.2.ii were modified

to indicate that the results of the toxicity tests required at the end of the permit

cycle must be submitted within 45 days of collecting the sample, instead of with

the permit renewal applica tion. A “no later than” due date was also included toFact Sheet for NPDES Permit WA 0 002950

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clarify when the samples should be collected. These changes were implemented

so that Ecology may review the results as soon as possible and identify any issues

with the results. That way, if issues a re indentified, the facility will have time to

address those issues.

Two additional changes were made during the permit finalization process:

• Intalco realized after the close of the comment period that the proposed permit

changed the sample type from gra b samples to 24

- hour composite samples for the

priority pollutant testing and for the toxicity testing at the Outfall 001 discharge.

In order to maintain consistency with past sampling events, they requested that

the priority pollutant testing and the tox icity testing be changed back to a grab

sample. Even though this request was made after the end of the comment period

and Ecology was not required to consider the request, we acknowledge the

consistency will allow for better comparison of past and future s ampling results.

Ecology made the changes as requested.

• Based on internal discussions about the permit renewal application, Ecology

modified Permit Condition S6 to clarify the forms that will be required to be

submitted with the new permit renewal appl ication.Fact Sheet for NPDES Permit WA 0 002950

Intalco Aluminum Corporation

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### Attachment 1 : Flow C hart for Agreed Order No. 10887