### Fact Sheetfor NPDES PermitWA0000884

Purpose ofthis Fact Sheet Sonoco Products Company Aoril25, 2013

This fact sheet explains and documents the decisions the Depmiment ofEcology (Ecology) made in drafting the proposedNational Pollutant Discharge Elimination System (NPDES) permit for Sonoco Products Company (Sonoco). This fact sheet complies with Section 173-220-060 ofthe WashingtonAdministrative Code (WAC), which requires Ecology to prepare a draft permit and accompanying fact sheet for public evaluationbefore issuing anNPDES 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. Copies ofthe fact sheet and draft permit for Sonoco, NPDES permit WA0000884, are available for public review and comment from March 20, 2013 until April22, 2013. For more details on·preparing and filing comments about these documents, please see AppendixA - Public InvolvementInformation. Sonoco 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 publishingthis 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 andresponses to comments in this fact sheet as Appendix E - Response to Comments, and publish it when issuing the final NPDES permit. Ecology will not revise the rest ofthe fact sheet, butthe full document will become part ofthe legal history contained inthe facility's permitfile. Summary The 2013 proposedpermit decreases the allowances for BOD and TSS from the previous permit term to reflect implementation ofWAC 173-201A-320, which addresses antidegradation. Ecology retained the daily maximum allowance for BOD because it is based onthe White River BOD TMDL. Ecology reintroduced a limit on ammonia, also derived from the total maximum daily load (TMDL), back into the permit. Ecology added a fecal coliform limit to comply with the Puyallup River Watershed Fecal Coliform TMDL published and approved in 2011. Changes in appearance ofthe permit or fact sheet simply reflect changes in the underlying boilerplate format that Ecology uses.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 2 of 61


## Table ofContents I. JnfrOdlLCfiOnoooooooooooo oooooooooooooooooooooooeoooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooo ••••oooooo 

### 4 

### II. BackgroundInforntation
.....................................,.................................................. 6 

### A. Facility Description...........................................· .................................................... 

### 7 Histoty

.................................................................................................................................7 Industrial Processes

.............................................................................................................7 Wastewater Treatment Processes

........................................................................................8 Solid Wastes

........................................................................................................................8 Discharge Outfalls

...............................................................................................................8 

### B. Description ofthe Receiving Water..................................................................... 9 

## c. Wastewater Characterization......**~**..................................................................... 10 

### D. Summary ofNoncompliance with Previous Permit (2007-2012)

.................... 11 

### E. StateEnvironmentalPolicy Act (SEPA) Compliance

..................................... 12 

### III. ProposedPermitLimits
........................................................................................ J2 

### A. Design Criteria

.................................................................................................... 13 

### B. Technology- Based Effluent Limits.................................................................. 14 

## c. SurfaceWater Quality- Based EffluentLimits

..................................,............ 16 Numerical Criteria for the Protection ofAquatic Life and Recreation

............................. 16 Numerical Criteria for the Protection ofHuman Health

................................................... 17 Nan·ative Criteria

.............................................................................................................. 17 Antidegradation

................................................................................................................. 17 Mixing Zones

.................................................................................................................... 19 

### D. Designated Uses and SurfaceWater Quality Criteria

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

### E. Water Quality Impairments............................................................................... 25 

### F. Evaluation ofWater Quality-Based EffluentLimits for Numeric Criteria

.. 26 Reasonable Potential Analysis

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

### G. Human Health..................................................................................................... 32 

### H. Sediment Quality................................................................................................. 32 

### I. Ground Water Quality Limits ........................................................................... 33 

### J. Whole Effluent Toxicity

..................................................................................... 33 K. 

### Comparison ofEffluentLimits with the Previous PermitIssued on May 9, 2007

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

# v. MonitoringRequirements
.................................................................................... 37 

### A. Lab Accreditation

............................................................................................... 38 

### B. Effluent Limits Which are NearDetection or QuantitationLevels

............... 38 VI. OtherPermit Conditions
...................................................................................... 39Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 3 of 61



### VII.

VIII. 

### A. B. 

## c. D. E. F.

G. 

### H.
A. B. Reporting and Record Keeping......................................................................... 39 Spill Plan................................

### ~·····························-··············································· 39 Solid 

### Waste Control Plan................................................................................... 39 Outfall Evaluation............................................................................................... 39 Operation and Maintenance Manual................................................................ 39 Stormwater Prevention Plan.............................................................................. 39 BestManagement Practices (BMPs)

.................................................................................40 Ecology-Approved StormwaterManagement Manuals

....................................................40 Operational Source Control BMPs

....................................................................................40 Structural Source Control BMPs

.......................................................................................41 Treatment BMPs

...............................................................................................................41 Volume/Flow Control BMPs

....'

........................................................................................41 Best Management Practices ............................................................................... 41 General Conditions............................................................................................. 42 PermitIssuance Procedures
................................................................................ 42 Permit Modifications

.......................................................................................... 42 Proposed Permit Issuance.................................................................................. 42 

### References for Test andAppendices

................................................................... 42 AppendixA--PublicInvolvementInformation
........................................................**~**.................. 44 AppendixB--Y ourRiglzttoAppeal
............................................................................................. 45 Appendix C--Glossary
.................................................................................................................. 46 AppendixD--Teclznical Calculations
.......................................................................................... 54 AppendixE--Response to Comments
.......................................................................................... 59

Table 1. General Facility Information ....................................................................................... 6 Table 2. Ambient Background Data........................................................................................... 9 

### Table 3. Process Wastewater Characterization Outfall 001

.................................................. 10 Table4. Stormwater Characterization Outfall 004 (SamplingEvent on 2/2/2012)

............. 11 Table**5~** 

### Summary ofNoncompliance with Previous Permit (2007-2012)

............................ 11 Table 6. Summary ofAllowances WhereDifferent from Previous PermitTerm

............... 13 Table 7. Design Criteria for WastewaterTreatment System

................................................ 13 Table 8. Technology-Based Limits- Based on 40 CFR SubpartE

....................................... 15 Table 9. Potential Technology-- Based Allowances................................................................. 16 

### Table 10. Previous PermitTermLimitAllowances Compared to 2003 Base Year

............. 18Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 4 of 61



### Table 11. Critical Conditions Used to Model the Discharge

.................................................. 21 Table 12. Aquatic Life Uses and Associated Criteria
............................................................. 24 Table 13. Recreational Uses and Associated Criteria
............................................................. 24 Table 14. Fecal Coliform TMDL Wasteload Allocation
......................................................... 25 

### ' Table 15. Dilution Factors 

### (DF)............................•.............................................................•..... 27 Table 16. Summarized Results as Geometric Mean ofSonoco 2010 Fecal Coliform Study28 Table 17. Summarized Historical WET Results ..................................................................... 34 

### Table 18. Comparison ofPrevious and Proposed EffluentLimits

........................................ 36
Figure 1. Sonoco Site Map........................................................................................................... 5 

### Figure 2. Dilution Necessary to Meet Criteria atEdge ofMixing Zone

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



### I. Introduction The Federal CleanWater Act (FCWA, 1972, and later amendments in 1977, 1981, and 1987) established water quality goals for the navigable (surface) waters ofthe United States. One mechanism for achieving the goals ofthe CleanWater Act is the National Pollutant Discharge Elimination System (NPDES), administered by the federal Environmental Protection Agency (EPA). The EPA authorized the state ofWashingtonto manage the NPDES permitprogram in our state. Our state legislature accepted the delegation and assigned the power and duty for conductingNPDES permitting and enforcementto Ecology. The Legislature defined Ecology's authority and obligations for the wastewater discharge permitprogram in 90.48 RCW (Revised Code ofWashington). The following regulations apply to municipal 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 effluenttoxicitytesting and limits (chapter 173-205 WAC)
• Sediment management standards (chapter 173-204 WAC)
• Submission ofplans and reports for construction ofwastewater facilities (chapter 173-240 WAC) These rules require any industrial facility owner/operator to obtain an NPDES permitbefore discharging wastewater to state waters. They also help define the basis for limits on each discharge and for performance requirements imposed by the permit. Underthe NPDES permitprogram and in response to a complete and accepted permit application, Ecology mustprepare a draft permit and accompanying fact sheet, and make themFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 5 of 61

available for public reviewbefore final issuance. Ecology must also publish an announcement (public notice) tellingpeople where they canread the draft permit, and where to send their comments, during a period ofthirty days (WAC 173-220-050). (See AppendixA-Public Involvement 

### Information for more detail about the public notice and commentprocedures). After the public comment period ends, Ecology may make changes to the draft NPDES pe1mit in response to comment(s). Ecology will summarize the responses to comments and any changes to the permit in 

### Appendix E. Figure1. Sonoco Site MapFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 6 of 61



### II. Background Information Table 1. General Facility Information
I 

### FacilityInformation
I Annlicant: Sonoco Products Company

i i I FacilityName and Address 1802 Steele Avenue Sumner WA 98390

Contact at Facility Name: Martin Ryan Telephone#: 253 863 6366 Responsible Official Name: Jon Febus Title: Plant Manager Address: 1802 Steele Avenue Sumner WA 98390 Telephone #253 863 6366

•Industry Type Recycled Paperboard Manufacturing

Categorical Industry 40 CFRPart 430.52 and 430.55 Type ofTreatment Primary Clarification/ Activated Sludge/Secondary Clarification SIC Codes ! 2631 NAIC Codes 322130 Facility Location (NAD83/WGS84 Latitude: 47.20899 reference datum) Longitude: 122.23818 Discharge Waterbody Name and Location White River

- Outfall 001 I (NAD83/WGS84 reference datum) Latitude: 47.213889 Longitude: 122.238889 Ground -Outfall 004 Latitude: 47.21246 Longitude: 122.24139

Permit Status

···········-····-····-·---·--···-----·---·-·----·--······--······--····----·-··-·········--·-------- ···············----·-·······-·····-·...··--······--·-······--·

Renewal Date ofPrevious Permit June 1, 2007 Application for Permit Renewal Submittal January 11, 2012Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 7 of 61

Permit 

### Status Date
Date ofEcology Acceptance ofApplication May 3, 2012
Inspection Status Date ofLast Sampling Inspection August 30, 2012 Date ofLast Non-sampling InspectionDate October 31, 2012

A. Facility Description History The mill is located in Sumner, Washington adjacent to the White River. The mill was constructed byNorthern Paperboard in 1915. Sonoco Products Company purchased the mill in 1980. The mill produced an average of 138 tons/day paperboard from waste paper and recycled cardboard during the period from January 1, 2007 through July, 2012. The paperboardproduced is used inthe pulp and paper industry as core material for paperrolls. Industrial Processes Secondary wood fiber inthe form ofvarious grades ofwastepaper including old corrugated boxes and old newspapers are the primary materials for the paperboard manufacturing process. These materials are blended and forced into a water suspensionusing hydropulpers. The resulting pulp slurry then flows through various cleaning and screening operations to remove contaminants and is further beaten or "refined" to develop bending strength and other characteristics needed in the finished product. Finally, the pulp slurry flows to the wet end forming section ofthe paper machine where a pulp mat is formed and combined into as many eight layers using wire covered cylinder vat formers. Fromthis point in the process, a continuous web approximately 94 inches wide is further processed bypressing, drying, and calendaring, and is then wound onto a reel which is the intermediate product. Occasionally, minor amounts ofsizing agents, colors, wet strength resins, defoamers, slimicides, starch, and alum (for pH adjustment) are added at various points inthe process to impart specific characteristics to the sheet based on customer requirements and specifications. Inthe forming section ofthe cylinder machine, water is removed from the fiber under controlled conditions, leaving a mat offiber at approximately 15% solids (by weight) which is supported by a fabric called a "felt" and carried forward to the press sectionwhere all the remaining free water is removed leaving a mat offiber at approximately 45% solids (by weight). The balance ofwater (downto 6% moisture) is removed inthe dryer sectionusingFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 8 of 61

heat energy to release the water through evaporation. The web ofdried paperboard is then calendared on both surfaces, densified, and given a smooth finish, priorto packaging. Since wet end forming takes place at very low consistencies (0.5% solids), large volumes of water are removed inthe forming section and pressing operations. Sonoco collects and reuses this process wastewater commonlyrefened to as white water. Before reuse, it must treat aportion ofthis wastewater in aprimary settling clarifier to remove some ofthe suspended particles. The process wastewater is pumped to the primary clarifier where the fibers are separated from the water through gravity settling. The fiber fraction is returned to the process as part ofthe raw material and the clarified water is reused for various showers and otherprocesses. Excess water from this system is thenpumped to the aeration pond for biological treatment as required underNPDES permit WA0000884, and then on to a secondary settling clarifier to remove any remaining solids and solids generated in the treatmentprocess priorto discharge. 

### WastewaterTreatmentProcesses The mill's wastewater receives primary and secondary treatment before it is discharged into the White River through a diffuser system. The primary and secondary biological wastewatertreatment systems were built in 1972. The treatment system consists ofprimary clarification followed by activated sludge aeration and then secondary clarification. From May 2007 through December 2011, the wastewater flow averaged 0.14 million gallons per day (MGD) with a maximum flow of.284 MGD, the biochemical oxygen demand (BOD) averaged 24 pounds per day (lbs/day) and the total suspended solids (TSS) averaged 57 lbs/day, The production volume averaged 108 tons per day (tons/day) with a maximum of 122 tons/day during 2007 through 2011. This compares favorably with the 2004 through 2006 timeframe on which the previous permitterin conditions were based. During the 2004 through 2006 timeframe the wastewater flow averaged 0.21 million gallons per day (MGD) with a maximum flow of.298 MGD, the biochemical oxygen demand (BOD) averaged 61 pounds per day (lbs/day) and the total suspended solids (TSS) averaged 97 lbs/day. Ecology basedthe limits inthe current 2007 permit on an average production of 120 tons/day. The company raw stock consisted of75 percent conugated and 25 percentnon-corrugated waste paper. The company indicated that itplans to continue using the same percentage ofraw materials for the foreseeable future. 

### Solid Wastes The facility submitted its mostrecentrevision ofthe Solid Waste Control Plan to Ecology in March 2008. The majority ofthe solid waste generated on-site consists ofpulperrejects (paper, plastic, wire). Approximately 126 tons permonth ofsolid waste is generated at the Sumner facility and disposed ofinthe HiddenValley Landfill. Settled solids generated in the primary clarifier are returned to the papermaking process. Sludges collected in the secondary clarifier are split betweenthe activated sludge aeration basin and papermaking process. 

### Discharge Outfalls The mill's discharge point is to the White River (Outfall 001) about 30 feet upstream ofFryar Avenue Bridge, at mile marker 1.4. The outfall line extends 10 feet from the south shorelineFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 9 of 61

and ends with a diffuser under the water surface. The effluent is discharged via an 18-foot long, sevenport diffuser, with a port height of 1foot above the river bed. The outfall is a 10- inchpipe designed with seven 3-inch diameter riser pmis spaced at 36-inch centers configured to discharge in the direction ofriver flow. The outfall inspection conducted during January 2012 found that 4 ports were fully functional, two were covered and one was blocked. Ecology evaluated the proposed dilution ratio and receiving water impact using the actual outfall configuration. The permit also authorizes discharge to ground from outfall 004. Outfall 004 routes storm waterto the northwest corner ofthe facility before discharging to land. There is a shallow weir made ofrocks and sufficient flow canresult in overflow ofthe weir. This overflowties backinto Outfall 001 prior to the diffuser discharge. Discharge has historically been infrequent. Collection points 002 and 003 are not outfalls but receive overland flow from the Sonoco facility and discharge this collected flow directly into the Sumner stormwater collection system. Outfall 002 receives storm water from the Sonoco parking area and routes the storm waterto the Sumner city storm water collection system. Outfall 003 receives storm water from a high vehicle traffic area and routes the effluent through an oil/water separator before discharge to the Sumner city storm water collection system. 

### B. Description ofthe Receiving Water

I Sonoco discharges to the White River withthe designated uses ofsalmonid spawning, rearing and migration habitat and primary contact recreation at the point ofdischarge. Other nearbypoint source outfalls covered under the Industrial Stormwater General Petmitinclude Exide Technologies Sumner, Pasquier Panel Products Inc Sumner, Pacific Northwest Baking Co, McConkey & Co Inc, Golden State Foods, Sumner Cedar, PrecisionAerospace 

### & Composites, and Thermo Fluids Inc. Western Wood Preserving Co and Fleischmanns Vinegar are nearby sources covered under individual NPDES permits. Section III E ofthis fact sheet describes anyreceiving waterbody impairments. The ambient background dataused for this permit includes the following from Sonoco's permitrenewal application: 

### Table 2. Ambient Background Data

...... TT ' TT, ..1**,~.~~** I • •uu..., '-' >3""'-" Temperature (highest annual 1-DADMax) 18.2° 

## c Temperature (mean) 16.2°

## c Temperature (minimum) 13.5°

## c pH (Mean) 7.31 standard units Dissolved Oxygen (Critical Annual 5 %tile) 8.9 mg/LFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 10 of 61

n 

### Value Used
Total Ammonia-N (Critical AnnualS %tile) 0.14 mg/L Fecal Coliform 46/100 mL dry weather Hardness 20.1mg/L as CaC03 Lead (Avg of8 samples) .26 flg/L as TR Copper (Avg of8 samples) 1.94 f.Lg/L as TR Zinc (Avg of8 samples) 1.91 flg/L as TR


### C. Wastewater Characterization Sonoco reported the concentration ofpollutants inthe discharge inthe permit application and in discharge monitoring reports. The tabulated datarepresents the quality ofthe wastewater effluent discharged during the 2007-2012 permit term. The wastewater effluent is · characterized as follows: Table 3. Process Wastewater Characterization Outfall 001 Parameter Units #of Average Value Maximum Samples Value Flow MGD 366 .139 .284 Temperature (summer) 

# oc 245 19 26 TSS mg/L 261 49.5 1266 TSS Lb/day 261 57 1637 BODs mg/L 156 20 166 BODs Lb/day 156 24 215 Ammonia mg/L 14 .42 1.04 Ammonia Lb/day 14 .47 1.39Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 11 of 61



### Parameter Units #of Monthly Samples Geometric Mean

Fecal Coliform #/100 

### ml 16 352



### Parameter Units #of Minimum Value Samples pH standard units 366 5.8 

### 7-Day Geometric Mean

Maximum Value

8.2



### Table 4. Stormwater Characterization Outfall 004 (SamplingEvent on 2/2/2012) Parameter Units #of Result Permit Samples Benchmark Value BODS 

### mg/L 1 <3 30 

### Ammonia mg/L 1 0.082 38 

### Lead (Total) ug/L 1 18 81.6 

### Copper (Total) ug/L 1 10.6 63.6 

### Turbidity NTU 1 45 25 

### Total Oil & 

### Grease mg/L 1 10 15 

### Zinc (Total) ug/L 1

,_ 20.3 117 

### pH 

# su 1 6.75 6-9



### D. Summary ofNoncompliance with Previous Permit (2007-2012)

Table 5. Summary ofNoncompliance with Previous Permit (2007-2012) Exceedance Statistical Exceedance Permit Date Parameter Base Units Value Limit Single 6/30/2011 

### TSS Sample Lbs/day 1637 <1487Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 12 of 61



### Exceedance Statistical ' 

### Exceedance Date Parameter Base Units Value Single 11/24/2009 TSS Sample Lbs/day 1538 

### Permit Limit

<1487 Note: There was no ammonia limit placed in the previous permit. There should have been a limit of 1.1 Lbs/day. Sonoco selfreported 1.34 Lbs/day discharged on 9/29/2010 and 1.3 Lbs/day discharged on 11/24/2010. 

### E. State EnvironmentalPolicy 

### Act (SEPA) Compliance State law exempts reissuance or modification ofany wastewater discharge permitfrom the SEPA process as long as the permit contains conditions are no less stringent than federal and state rules andregulations (RCW 43.21C.0383). The exemption applies only to existing discharges, notto newdischarges.


### III. Proposed Permit Limits Federal and state regulations require that effluent limits in anNPDES permit mustbe either technology- or water quality-based.
• Technology-based limits are based uponthe treatment methods available to treat specific pollutants. Technology-based limits are set bythe 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 WAC).
• Water quality-based limits are calculated so that the effluent will comply withthe Surface Water Quality Standards (chapter 173-201A WAC), Ground Water Standards (chapter 173-200 WAC), Sediment Quality Standards (chapter 173-204 WAC), or the National Toxics Rule ( 40 CFR 131.36).
• Ecologymust apply the most stringent ofthese limits to eachparameter ofconcern. These limits are described below. The limits inthis permitreflect informationreceived in the application and from supporting reports (engineering, hydrogeology, etc.). Ecology evaluated the permit application and

·determined the limits needed to comply withthe rules adopted bythe state ofWashington. 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 areasonable potential to cause a water quality violation. Ecology does not usually develop limits for pollutants not reported inthe permit applicationbut may be present inthe discharge. The permit does not authorize discharge ofthe non-reported pollutants. During the five-year permitterm, the facility's effluent discharge conditions may change from those conditions reported inthe permit application. The facility must notify Ecology ifsignificant changes occur in any constituent [40 CFR 122.42(a)]. Until Ecology modifies theFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 13 of 61
permitto reflect additional discharge ofpollutants, a permitted facility couldbe violating its permit. The table below summarizes the proposed allowances for the 2013 pe1mit renewal, where changes from the previous pe1mit are proposed, and shows the comparisonto the previous permit term allowances. The explanations for the derivations ofthe allowances are found throughout the fact sheet underthe relevant headings. The BOD daily maximum allowance is set through the TMDLprocess. The remaining BOD and TSS allowances have been increased byno more than 10% so that a Tier II evaluation is not necessary. The fecal coliform and ammonia allowances are based on TMDL evaluations.

Table 6. Summary ofAllowances Where Different from Previous PermitTerm .BOD BODDaily TSS TSSDaily Fecal Ammonia Monthly Maximum. Monthly Maximum Coliform Average Average 2003 Baseline 500 Lbs./day 673 Lbs./day 660 Lbs./day 1310 NA 1.1 Lbs/day

Allowance Lbs./day during 2001- 2007 permit term 2007-2012 529 Lbs./day 673 Lbs./day 754 Lbs./day 1487 NA Permit Term Lbs./day 2013 Proposed 550 Lbs/day 673 Lbs./day 726 Lbs/day 1441 < 100 1.1 Lbs/day Permit Lbs/day cfu/100 mL

A. Design Criteria According to WAC 173-220-150 (1)(g), neither flows nor waste loadings may exceed approved design criteria, however, Ecology does not have an engineering report that specifies the design criteria for the wastewatertreatmentplant atthis facility. Sonoco's system was installed before the design criteriarequirements were promulgated, however based onthe original design criteria and results from the last 39 years ofoperation, Sonoco agrees withthe following influent waste loadings: Table 

### 7. Design Criteria for Wastewater Treatment System
Parameter Design Quantity Daily MaximumFlowto Aeration Basin 0.600 MGD*Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 

### 14 of

### 61

Parameter Design Quantity

**~~~~"~** monthly average Aeration Basin daily TBOD5 influent loading 3,527 lb/day** * from original CH2M Hill design criteria, 1973 **based on 85% removal efficiency inthe original design and cunentmonthly average effluent limit of529 pounds/day.

B. Technology

- BasedEffluentLimits Technology-based limitations are set byregulations or developed on a case by case basis. The federal effluent guidelines for practicable control technically available (BPT) is defined inParts 430.52 and 430.55 SubpartE for paperboard from wastepaper subcategory. The Environmental Protection Agency (EPA) published these guidelines inthe federal register on November 18, 1982 and March 30, 1983. The federal effluent guidelines for best conventional pollutants control technology (BCT) for these categories were defined on December 17, 1986 to be the same as BPTpreviously defined in March 1983. BCT and BPT were defined more than tenyears ago. With BCT and BPTbeing defined longerthan ten years, Ecology must determine ifthey are still valid and ifit can still consider them equivalent to all known and reasonable treatment (AKART) for these categories ofpaper making. On April15, 1998, EPA adopted effluent guidelines for the Bleached Kraft Papergrade and Soda subcategories and Papergrade Sulfite subcategory. The 1998 allowances for BOD and TSS inpoundper 1000 pound ofpulp produced for the above categories were set at the same values as the allowances in the effluent guidelines the EPApublished in 1982. The 1998 effluent guidelines took both emissions to air and water into consideration and included chlorinated organic compounds. Secondarytreatment was the type ofwastewater treatment required bythe effluent guidelines adopted by EPA. Throughoutthe history ofthe effluent guidelines, secondarytreatment has beenthe accepted standard for BOD and TSS removal. Itis expectedthat inthe immediate future this trend will continue as indicated by the guideline promulgated on April15, 1998. Ecology therefore determines thatthe effluent guidelines for paperboard made from both corrugated and non-corrugated wastepaper are equivalentto AKART for the following reasons:
• The mill has historically generated wastewater from two components ofraw wastepaper

- corrugated and non-corrugated.
• EPA did not make any changes inthe 1998 guidelines for BOD and TSS for the type of paper making conducted at Sonoco.
• EPA based the most recent guidelines on secondary treatment which Ecology expects will not change in the near future.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 15 of 61

• All permits except those ofpaper grade sulfite and Kraft subcategories have been drafted and issued with the 1982 effluent guidelines being determined to be equivalent toAKART. Therefore, Ecology used 40 CPR430.52 and 40 CPR 430.55 for paperboard from wastepaper subcategory to determine technology-based limits. Ecology based the limits on best practicable control technology (BPT) for production levels that occurred prior to 1982 and based limits on new source performance standards (NSPS) for the production increases after 1982. Past productionprior to 1982 averaged 61 tons per day. Ecology used 40 CPR430.52 BPT effluent guideline allowances to determine technology-based limits for production up to 61 tons per day. Production during the 2007-2011 timeframe averaged 108 tons per day. The highest annual average production of 142 tons per day occurred during 2008 and Ecology used this value to determine technology-based limits for this permit cycle. Ecology used new source performance standards (NSPS) guidelines values contained in 40 CPR430.55 andthe 81 tons ofproduction above the historical average of61 tons per day to calculate technologybased limits for the production increases after 1982. The company indicatedthe raw furnish consisted of75 percent corrugated and 25 percent non-corrugated. The breakout of productiontypes and effluents guidelines numbers are givenbelow: Table 8. Technology-Based Limits- Based on 40 CFR Subpart E Type Maximum Production Monthly Daily Monthly Daily Monthly (2010 to Average Maximum Average Maximum Production Present) Tons paper 1000 lbs Lbs. Lbs.BOD Lbs. Lbs. TSS

per day paper per BOD per per TSS per per day 1000 lbs 1000 lbs 1000 lbs 1000 lbs paper paper paper paper Non-NSPS 61 122 Fraction Corrugated 0.75 91.5 2.8 5.7 4.6 9.2 Noncorrugated 0.25 30.5 1.5 3 2.5 5

NSPS 81 162 Fraction Corrugated 0.75 121.5 2.1 3.9 

### 2.3 4.4Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 16 of 61



### Type Maximum Production Monthly Daily Monthly Monthly (2010 to Average Maximum Average Production Present) Tons paper 1000 lbs Lbs. Lbs. BOD Lbs.

per day paperper BOD per per TSS per day 1000 lbs 1000 lbs 1000 lbs paper paper paper 

### N

oncorrugated 0.25 40.5 1.4 2.6 1.8
The technology effluent limits would be calculated using the production and allowances indicated. Potential technology-based effluent limits are summarized below:



### Table 9. PotentialTechnology- Based Allowances Daily Maximum

Lbs. TSS per 1000 lbs

paper

3.5



### BOD MonthlyAverage BOD Daily TSS Monthly TSS DailyMaximum Maximum Average 614 Lbs./day 1192 Lbs./day 850 Lbs./day 1671 Lbs./day
However, other factors can come into playwhen deriving facility specific allowances and this is the case for Sonoco where both TMDL and Tier II considerations influence mass loading allowances. 

### C. 

### SurfaceWater Quality- Based Effluent Limits The Washington State surface water quality standards (chapter 173-201A WAC) are designed to protect existing water quality and preserve the beneficial uses ofWashington's surface waters. Waste discharge permits must include conditions that ensure the discharge will meetthe 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 allocation developed during a basin wide total maximum daily load study (TMDL). 

### Numerical Criteria for the ProtectionofAquatic Life and Recreation Numerical water quality criteria are listed in the water quality standards for surface waters (chapter 173-201A WAC). They specify the maximum levels ofpollutants allowed in receiving water to protect aquatic life and recreation in and onthe water. Ecology uses numerical criteria along with chemical and physical data for the wastewater and receiving water to derive the effluent limits inthe discharge permit. When surface water quality-based limits are more stringent or potentially more stringentthantechnology-based limits, the discharge must meetthe water quality-based limits.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 17 of 61

Numerical Criteria for the Protection ofHuman Health The U.S. EPA has published 91 numeric water quality criteria for the protection ofhuman healththat are applicable to dischargers in Washington State (EPA, 1992). These criteria are designed to protect humans from exposure to pollutants linked to cancer and other diseases, based on consuming fish and shellfish and drinking contaminated surface waters. The water quality standards also include radionuclide criteriato protect humans from the effects of radioactive substances. Narrative Criteria 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 belowthose which have the potential to:
• Adversely affect designated water uses.
• Cause acute or chronic toxicity to biota.
• Impair aesthetic values.
• Adversely affect human health. Narrative criteriaprotectthe specific designated uses ofall fresh waters (WAC 173-201A-200, 2006) and ofall marine waters (WAC 173-201A-210, 2006) in the state ofWashington. Antidegradation Description--The purpose ofWashington's Antidegradation Policy (WAC 173-201A-300-330; 2006) is to:
• Restore and maintainthe highestpossible quality ofthe surface waters ofWashington.
• Describe situations under which water quality rimy be lowered from its current condition.
• Applyto human activities that are likelyto have an impact onthe water quality of surface water.
• Ensure that all human activities likelyto contribute to a lowering ofwater quality, at a minimum, apply all known, available, and reasonable methods ofprevention, control, and treatment (AKART).
• Apply three tiers ofprotection (described below) for surface waters ofthe state. Tier I ensures existing and designated uses are maintained and protected and applies to all waters and all sources ofpollutions. Tier II ensures that waters ofa higher quality thanthe criteria assigned are not degraded unless such lowering ofwater quality is necessary and in the overridingpublic interest. Tier II applies only to a specific list ofpolluting activities. Tier III prevents the degradation ofwaters formally listed as "outstanding resource waters," and applies to all sources ofpollution. Facility Specific Requirements--This facility must meet Tier I requirements.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 18 of 61
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 designated uses, except as provided for in chapter 173-201A WAC. For waters that do not meet assigned criteria, or protect existing or designated uses, Ecology will take appropriate and definitive steps to bring the water quality back into compliance withthe water quality standards.
• Whenever the natural conditions ofa water body are ofa lower quality than the assigned criteria, the natural conditions constitute the water quality criteria. Where water quality criteria are not met because ofnatural conditions, human actions are not allowed to further lowerthe water quality, except where explicitly allowed in chapter 173-201AWAC. The overall terms and conditions ofthis permit are designed to collectively achieve Tier I requirements. A facility mustprepare a Tier II analysis when all three ofthe following conditions are met:
• The facility is planning a new or expanded action.
• Ecology regulates or authorizes the action.
• The action has the potential to cause measurable degradation to existing water quality at the edge ofa chronic mixing zone. Ecology defined "expanded action" inthe Water Quality Program Guidance Manual publicationno. 11-10-073 which addresses Tier II antidegredation. Ecology uses a 10% mass loading increase as a trigger for defining what is considered an expanded action. Ecology considers this interpretation as consistent withthe current Ecology practice of applying new source performance standards to dischargers who increase productionby more than 10%. Where a permit limit is notbased on a facility's design capacity, it is necessary to track the changes that occur in effluent mass loading over successive permit cycles, in order to implementthe 10% trigger for an existing facility. WAC 173-201A-320, which addresses Tier II, became effective in 2003. Therefore the production allowance during 2003 is considered the base year allowance. The table below compares production-based emission factor derived allowances to the 2003 base year allowance.

Table 10. Previous Permit Term Limit Allowances Compared to 2003 Base Year BOD Monthly BOD Daily TSS Monthly TSS Daily Average Maximum Average Maximum 2003 Baseline 500 Lbs./day 673 Lbs./day 660 Lbs./day 1310 Lbs./day

Allowance during 2001- 2007 permit termFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 19 of 61

2007-2012 529 Lbs./day 673 Lbs./day 754 Lbs./day permit term Increase from 6% 0% 14% Baseline 2013 Proposed 613 Lbs/day NA 850 Lbs/day

TechnologyBased Allowance Increase from 23% 0% 29% Baseline 1487 Lbs./day

13.5%

1671 Lbs/day

28%

Sonoco would trigger a Tier II analysis based onthe TSS mass loading increase greaterthan 10% from the base year allowance. Sonoco has voluntarily accepted a mass loading increase cap of 10% rather than conduct a Tier II evaluation.
Mixing Zones A mixing zone is the defined area inthe receiving water surrounding the discharge port(s), where wastewater mixes withreceiving 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~he** receiving waterbody (for example, recreation, water supply, and aquatic life and wildlife habitat, etc.) The pollutant concentrations outside ofthe mixing zones must meet water quality numeric standards. State and federal rules allow mixing zones because the concentrations and effects ofmost pollutants diminishrapidly after discharge, due to dilution. Ecology defines mixing zone sizes to limitthe amount oftime 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 ifthose discharges already receive all known, available, and reasonable methods ofprevention, control, and treatment (AKART). Mixing zones typically require compliance with water quality criteria within a specified distance from the point ofdischarge and must not use more than 25% ofthe available width ofthe water body for dilution [WAC 173-201A-400 (7)(a)(ii-iii)]. Ecology uses modeling to estimate the amount ofmixing withinthe mixing zone. Through modeling Ecology determines the potential for violating the water quality standards at the edge ofthe mixing zone and derives any necessary effluent limits. Steady-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 (see Ecology'sPermit Writer's Manua[). EachFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 20 of 61

critical conditionparameter, by itself, has a lowprobability ofoccunence and the resulting dilution factor is conservative. The term "reasonable worst-case" applies to these values. The mixing zone analysis produces a numerical value called a dilution factor (DF). A dilution factor represents the amount ofmixing ofeffluent and receiving water that occurs at the boundary ofthe mixing zone. For example, a dilution factor of 10 means the effluent is 10% and the receiving water is 90% ofthe total volume ofwater at the boundary ofthe mixing zone. Ecologyuses dilution factors withthe water quality criteriato calculate reasonable potentials and effluent limits. Water quality standards include 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 ofpollutants at the boundaries ofany ofthese mixing zones may not exceed the numerical criteria for that zone. Each aquatic life acute criterion is based on the assumption that organisms are not exposedto that concentration for more than one hour and more oftenthan one exposure in three years. Each aquatic life chronic criterion is based onthe assumption that organisms are not exposed to that concentration for more than four consecutive days and more oftenthan once in three years. The two types ofhuman health-based water quality criteria distinguish between those pollutants linked to non-cancer effects (non-carcinogenic) and those linked to cancer effects (carcinogenic). The humanhealth-based water quality criteria incorporate several exposure andrisk assumptions. These assumptions include:


### • A 70-year lifetime ofdaily exposures. 

### • Aningestionrate for fish or shellfishmeasured inkg/day

. An ingestion rate oftwo liters/day for drinking water. A one-in-one-million cancerrisk for carcinogenic chemicals. This permit authorizes.a small acute mixing zone, sunoundedby a chronic mixing zone around the point ofdischarge (WAC 173-201A-400). The water quality standards impose certain conditions before allowing the discharger a mixing zone: 

### 1. Ecology Must Specify Both theAllowed Size andLocation in a Permit. The proposedpermit specifies the size and location ofthe allowed mixing zone (as specified below). 

### 2. TheFacility MustFully Apply "AllKnown, Available, and Reasonable Methods of Prevention, Control and Treatment" (AKART) to its Discharge. Ecology has determined that the treatmentprovided at Sonoco meets the requirements of AKART (see "Technology-basedLimits"). 

### 3. Ecology Must Consider CriticalDischarge Conditions. Surface water quality-based limits are derived for the waterbody's critical condition (the receiving water and waste discharge condition withthe highestpotential for adverseFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 21 of 61
impact onthe aquatic biota, humanhealth, and existing or designated waterbody uses). The critical discharge condition is oftenpollutant-specific or waterbody-specific. Critical discharge conditions are those conditions that result in reduced dilution or increased effect ofthe pollutant. Factors affecting dilution include the depth ofwater, the density stratification inthe water column, the currents, and the rate ofdischarge. Density stratification is determined by the salinity and temperature ofthe receiving water. Temperatures are warmer in the surface waters in summer. Therefore, density stratification is generally greatest during the summer months. Density stratification affects how far up inthe water column a freshwater plume mayrise. The rate ofmixing is greatest when an 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 whenthere is little or no stratification. Ecology'sPermit Writer's Manual describes additional guidance on criteria/design conditions for determining dilution factors. The manual can be obtained from Ecology's website at: http:/ /www.ecy.wa.gov/biblio/92109.html.

Table 11. Critical Conditions Used to Model the Discharge Critical Condition Value The seven-day-average lowriver flow with a recurrence interval often 179 cfs years (7Q10) River depth at the 7Q10 period 3.5 feet River velocity 0.55 ft per second Manningroughness coefficient .03 Channel width 92 feet Maximum average monthly effluent flow for chronic and human health .19MGD non-carcmogen Annual average flow for human health carcinogen .14 MGD Maximum daily flow for acute mixing zone .28 MGD 7-DAD MAXEffluenttemperature 25 degrees C

4. Supporting Information Must Clearly Indicate the Mixing Zone Would Not:
• Have a reasonable potential to cause the loss ofsensitive or importanthabitat.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 22 of 61

• Substantially interfere withthe existing or characteristic uses. " Result in damage to the ecosystem.
• Adversely affect public health. Ecology established Washington State water quality criteriafor toxic chemicals using EPA criteria. EPA developed the criteriausing toxicity tests with numerous organisms and setthe criteriato generally protect the species tested and to fully protect all commercially and recreationally important species. EPA sets acute criteria for toxic chemicals assuming organisms are exposedto the pollutant at the criteria concentration for one hour. They set chronic standards assuming organisms are exposed to the pollutant at the criteria concentrationfor four days. Dilutionmodeling under critical conditions generally shows that both acute and chronic criteria concentrations are reached within minutes ofdischarge. The discharge plume does not impact drifting and non-strong swimming organisms because they cannot stay inthe plume close to the outfall long enoughto be affected. Strong swimming fish could maintain a positionwithinthe plume, but they can also avoid the discharge by swimming away. Mixing zones generally do not affect benthic organisms (bottom dwellers) because the buoyant plume rises inthe water column. Ecologyhas additionally determined that the effluent will not exceed 33 degrees C for more than two seconds after discharge; and thatthe temperature ofthe water will not create lethal conditions orblockages to fish migration. Ecology evaluates the cumulative toxicity ofan effluent bytesting the discharge with whole effluenttoxicity (WET) testing. Ecology reviewed the above information, the specific information onthe characteristics ofthe discharge, the receiving water characteristics and the discharge location. Based on this review, Ecology concluded that the discharge does not have a reasonable potential to cause the loss ofsensitive or important habitat, substantially interfere with existing or characteristics uses, result in damage to the ecosystem, or adversely affect public health if the permit limits are met. 

### 5.

.The Discharge/Receiving Water Mixture Must Not Exceed Water Quality Criteria Outside the Boundary ofa Mixing Zone. Ecology conducted a reasonable potential analysis, using procedures established bythe EPA and byEcology, for eachpollutant and concludedthe discharge/receiving water mixture will not violate water quality criteria outside the boundary ofthe mixing zone if permit limits are met. 6. The Size ofthe Mixing Zone and the Concentrations ofthe Pollutants Must be Minimized. At any given time, the effluentplume uses only a portion ofthe acute and chronic mixing zone, which minimizes the volume ofwater involved in mixing. The plume mixes as it rises through the water columntherefore much ofthe receiving water volume at lower depths inthe mixing zone is not mixed with discharge. Similarly, because the dischargeFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 23 of 61

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 rises and moves withthe current. Ecology minimizes the size ofmixing zones byrequiring dischargers to install diffusers whenthey are appropriate to the discharge and the specific receiving waterbody. When a diffuser is installed, the discharge is more completely mixed withthe receiving water in a shorter time. Ecology also minimizes the size ofthe mixing zone (in the form ofthe dilution factor) using design criteriawith a lowprobability ofoccurrence. For example, Ecology uses the expected 95thpercentile pollutant concentration, the 90thpercentile background concentration, the centerline dilution factor, and the lowest flow occurring once in every ten years to perform the reasonable potential analysis. Because ofthe above reasons, Ecology has effectively minimized the size ofthe mixing zone authorized inthe proposedpermit. 

### 7. Maximum Size ofMixing Zone. The authorized mixing zone does not exceedthe maximum size restriction and is smaller than the size restrictions due to the use ofthe 2.5% ofthe 7Q10 river flow restriction. 

### 8. Acute Mixing Zone.
• TheDischarge/ReceivingWaterMixtureMust Complywith Acute Criteria as Nearto the Point ofDischarge as PracticablyAttainable. Ecology determined the acute criteriawill be met at less than 10% ofthe distance of the chronic mixing zone at the ten year lowflow as it will be met after mixing with just 2.5% ofthe 7Q10 river flow.


### • ThePollutant Concentration, Duration, and Frequency ofExposure to the DischargeWillNot Create a Barrierto Migration orTranslocation of Indigenous Organisms to a Degreethathas thePotentialto Cause Damage to the Ecosystem. As described above, the toxicity ofany pollutant depends upon the exposure, the pollutant concentration, and the time the organism is exposedto that concentration. Authorizing a limited acute mixing zone for this discharge assures that it will not create a barrierto migration. The effluent from this discharge will rise as it enters the receiving water, assuring that the rising effluent will not cause translocation of indigenous organisms nearthe point ofdischarge (belowthe rising effluent).


### • Complywith Size Restrictions. The mixing zone authorized for this discharge complies withthe size restrictions published in chapter 173-201A WAC. 

### 9. Overlap ofMixing Zones. This mixing zone does not overlap another mixing zone.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 24 of 61



### D. Designated Uses and SurfaceWater Quality Criteria Applicable designated uses and surface water quality criteria are defined in chapter 173-201A WAC. In addition, the U.S. EPA set humanhealth criteria for toxic pollutants (EPA 1992). The table included below summarizes the criteria applicable to this facility's discharge. Aquatic Life Uses are designated based on the presence of, or the intentto provide protection for the key uses. All indigenous fish and non-fish aquatic species must be protected in waters ofthe state in addition to the key species. The Aquatic Life Uses for this receiving water are identifiedbelow.



### Table 12. Aquatic Life Uses and Associated Criteria

Salmonid Spawning, Rearing, andMigration Temperature Criteria- Highest 7-DAD 17.5°C (63.5°F) MAX Dissolved Oxygen Criteria- Lowest 1-Day 8.0 mg/L Minimum Turbidity Criteria • 5NTU 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. Total Dissolved Gas Criteria Total dissolved gas must not exceed 110 percent ofsaturation at any point ofsample collection. pH Criteria The pH must measure withinthe range of6.5 to 8.5 with a human-caused variation within the above range ofless than 0.5 units.

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

### Table 13. Recreational Uses and Associated Criteria RecreationalUse



### ~eria Primary Contact Fecal coliform organism levels must not exceed a geometric mean value Recreation of 100 colonies 1100 mL, withnot more than 10percent ofall samples (or any single sample when less than ten sample points exist) obtained for calculatingthe geometric mean value exceeding 200 colonies 1100 mL.

• The water supply uses are domestic, agricultural, industrial, and stock watering.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 25 of 61

• The miscellaneous freshwater uses are wildlife habitat, harvesting, commerce and navigation, boating, and aesthetics.



### E. Water QualityImpairments In June 1993 and July 1994, Ecology finalized the ammonia and biochemical oxygen demand total maximum daily loads (TMDL) for the White River. Ecology set the waste load allocation (WLA) at 1.1 lbs./day for ammonia inthe TMDL. Ecology setthe WLA for the daily maximum for BOD at 673 lbs./day in the TMDL. Ecologyplaced these WLA values in the NPDES permit issued September 25, 2001. These values are included inthis permit renewal. The WLA allocationprotects the designated classification ofthe White River in the vicinity ofSonoco's outfall. These WLA allocations are placed inthe proposedpermit. The WLA from the TMDL contained inthe proposed permit ensure thatthe receiving water is protected. The limits contained from the TMDL further ensure that the water quality criteria ofthe receiving water are equal to or above the designations and not degraded. InJune of2011, Ecology published the Puyallup River WatershedFecal Coliform Total Maximum DailyLoadreport. The TMDL includes a waste load allocation (WLA) for Sonoco which is tabulated below. EPA approved the TMDL in2011. 

### Table 14. Fecal Coliform TMDL Wasteload Allocation Wastewater Geomean Less than 10% ofthe samples greater TreatmentPlant Limit than
Sonoco Products 100cfu/100 200cfu/1OOmL mL The proposed permit includes a best management practices (BMP) approach to achieve a source reduction in fecal coliform contributionto the White River. The TMDL study acknowledges that waste load allocations as pollutant loading does not always work well for bacteria TMDL studies because bacteria loading interms of"numbers ofbacteriaper day" is awkward and challenging to understand. The overall approach is to achieve FC reduction from all sources. The goal ofthe Puyallup River watershed FC TMDL is to reduce FC concentrations within the study areato water quality standards by 2022 (page xiii ofTMDL executive summary). The TMDL repmi goes onto address Sonoco Products directly inthe following excerpt: Within the study area, Sonoco Products is the only industrial facility that discharges treated industrialprocess water to surface waters. In a 2010 study, thefacilityfound high concentrations of fecal indicator bacteria (fecal coliform andEscherichia coli) in their treatedeffluent, which discharges to the White River (Sonoco, 2011). Althoughthe facility discharges a very small amountof effluent (approximately 0.15 MGD) anda relatively smallFC load, the concentrations of FCwere above water quality standards. Given that the White River does not currently meetFCstandards in the receivingwaterFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 26 of61

segment, there is no additional loading capacity, andSonoco effluent mustmeet the surface water quality standards at thepointof discharge. This permit cycle establishes a 5-year compliance schedule for bringing mill effluent into compliance withthe water quality standards for fecal coliform.



### F. Evaluation ofWater Quality-Based Effluent Limits for Numeric Criteria Pollutants in an effluent may affect the aquatic environment near the point ofdischarge (near-field) or at a considerable distance from the point ofdischarge (far-field). Toxic pollutants, for example, are near-field pollutants; their adverse effects diminishrapidly with mixing inthe 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 ofcalculating surface water quality-based effluent limits varies withthe point at which the pollutanthas its maximum effect. With**technology-b~sed** controls (AKART), predictedpollutant concentrations inthe discharge exceed water quality criteria. Ecology therefore authorizes a mixing zone in accordance withthe geometric configuration, flow restriction, and other restrictions imposed onmixing zones by chapter 173-201AWAC. The outfall was visually inspected inDecember 2011. The original outfall consisted ofseven ports. Sloughing inthe stream banl<: has resulted inthe current 4 functional port outfall configuration. The 4-port configuration was evaluated for compliance with applicable water quality standards. The functional portion ofthe diffuser at Outfall 001 is 9 feet long with a diameter of 10 inches. The diffuser has a total of4 three inch diameterports. The distance between ports is 3 feet. The diffuser depth is 2.5 feet. The mean lower low water (MLLW) depth is 3.5 feet. Ecology obtained this information from the Dilution Ratio Study Report submitted on June 15, 1993 and amended onNovember 13, 1995. The dilution ratios presented in Table 9 below are from the 1995 Dilution Ratio Study amendment. Chronic Mixing Zone WAC 173-201A-400(7)(a) specifies that mixing zones must not extend in a downstream direction from the discharge ports for a distance greaterthan 300 feet plus the depth ofwater over the discharge ports or extend upstream for a distance ofover 100 feet, not utilize greater than 25% ofthe flow, and not occupy greater than 25% ofthe width ofthe water body. The horizontal distance ofthe chronic mixing zone is 302.5 feet from the diffuser. The mixing zone extends from the top ofthe discharge ports to the water surface. The flow volume restrictionresulted in a smaller chronic dilution factor thanthe distance downstream. The chronic dilution factors shown belowresult from the volume restriction. Acute Mixing Zone WAC 173-201A-400(8)(a) specifies that inrivers and streams a zone where acute toxics criteria may be exceeded must not extend beyond 10% ofthe distance towards the upstreamFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 27 of 61

and downstream boundaries ofthe chronic zone, not use greater than 2.5% ofthe flow and not occupy greaterthan 25% ofthe width ofthe water body.

Table 

### 15. Dilution Factors (DF)
Criteria Al'ntf' Chronic Aquatic Life [I 15 130 Human Health, Carcinogen 130 Human Health, Non-carcinogen 130 Ecology determined the impacts ofdissolved oxygen deficiency, pH, fecal coliform, ammonia, metals, and temperature as described below, using the dilution factors inthe above table. The derivation ofsurface water quality-based limits also takes into account the variability ofpollutant concentrations in both the effluent and the receiving water. Dissolved Oxygen--BODs and Ammonia Effects--Natural decomposition oforganic material inwastewater effluent impacts dissolved oxygen inthe receiving water at distances far outside ofthe regulated mixing zone. The 5-day Biochemical Oxygen Demand (BODs) ofan effluent sample indicates the amount ofbiodegradable material in the wastewater and estimates the magnitude ofoxygen consumption, the wastewater will generate inthe receiving water. The amount ofammonia-based nitrogen inthe wastewater also provides an indication ofoxygen demand in the receiving water. Ecology completed a dissolved oxygen and ammonia TMDL for the Puyallup River in 1993, and established mill effluent limits for biochemical oxygen demand (BODs) and ammonia. The proposed permit includes daily maximum effluent limits for BODs and ammoniaderived from completed TMDL. pH-- The previous permitrequired the Permittee to perform a two year study onthe pH of the receiving water. Receiving water data was collected upstream and downstream from the outfall in 2002 and again in 2006 during the critical summer months ofJune through October. The average upstreampH was 7.45 in 2002 and 7.25 in 2006. The average downstreampHwas 7.39 in 2002 and 7.18 in 2006. Ecologymodeled the impact ofthe effluentpH on the receiving water using the calculations from EPA, 1988, and the chronic dilution factor tabulated above. Appendix D includes the model results. Ecologypredicts no violation ofthe pH criteriaunder critical conditions. Therefore, the proposedpermit includes technology-based effluent limits for pH which should protect water quality standards. Fecal Coliform-- The previous permit required the Permittee to perform a two year study on fecal coliform. The fecal coliform data gathered during the two year study indicatedthat ten percent offecal coliform values were greater than 200 colonies/100 mL. The data indicatedFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 28 of 61

that the White River is oflower water quality than the criteria assigned. These data for Sonoco's effluent showed that several tests measured fecal coliform counts greater than 1600 colonies/100 mL. Ecology received the results ofthe fecal coliform study on February 1, 2011. The purpose of the study was to determine iffecal coliform counts inthe mill effluent will cause a violation ofthe water quality criteria at the edge ofthe chronic mixing zone and ifthe measured fecal coliform are from the pulping processing. There are several issues causing Ecology to require this study. The White/Stuck River has shown inability to maintainthe fecal coliform Water Quality Standard and Sonoco's Waste Water discharge has occasionally tested high in fecal coliform. Confusingthis issue is that fecal coliform in an indicator bacterium and not necessarily an indication ofa hazard. There are non-harmful bacteria such as klebsiella associated withpaper manufacturing that will test as fecal coliform. Ecology recognizes this issue withpaper mill effluents so it allows alternative indicator criteriato be used. The water quality criteria for fecal coliform bacteria is that it shall not exceed a geometric mean of 100 cfu/1OOmL, and notmore than 10% ofall samples exceed 200 cfu/100 mL. The results of the study are summarized below and indicate that while Sonoco's effluent contributes to fecal count it is inconclusive as an explanation for the downstream fecal count.

Table 16. Summarized Results as Geometric Mean ofSonoco 2010 Fecal Coliform Study Effluent 410 Bridge (downstream) Tacoma Bridge (upstream) Fecal E Coli Klebsiella Fecal E Coli Klebsiella Fecal E Coli Klebsiella Coli Coli Coli

352 208 148 62 50 40 46 41 18

In June 2011, Ecology completed the Puyallup River Watershed Fecal Coliform Total Maximum Daily Load Water Quality Improvement Report and ImplementationPlan (PublicationNo. 11-10-040). The White River is a tributary to the Puyallup River. The federal CleanWater Actrequires that a total maximum daily load (TMDL) be developed for each ofthe water bodies onthe state's 303(d) list ofpolluted waters. The White River has experienced fecal coliform (FC) levels higherthanthe allowed standards for freshwater streams. The TMDL identifies pollutionproblems inthe watershed, and then specifies how muchpollution needs to be reduced or eliminatedto achieve clean water. The goal ofthe Puyallup River watershed fecal coliform TMDL is to reduce FC concentrations withinthe watershed to water quality standards by 2022. One ofthe key action items from each effluent contributor is to determine the sources ofthe pollutionto reachthe load reductions for nonpoint sources. Ecology is choosing a BMP and compliance schedule approach for Sonoco to achieve better site management oftheir fecal coliform contributionto the White River. The TMDL establishes an overall watershed interim target of50% reductionfrom source contributorsFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 29 of 61

achieved by 2017. This approach is consistent withthe TMDL implementation concerning municipal stmmwater discharges. The TMDL summarizes this philosophy as follows: Ecology recognizes the difficulty of characterizing the highly variablefrequency and duration of FC loads in stormwater. Numeric effluent limits for municipalstormwater discharges thtare consistentwith TMDLs are notoften feasible or appropriate when expressingwasteloadallocations in municipalstormwaterpermits. Ecology intends to express the numeric municipalstormwater wasteloadallocations,from this TJ"I.1DL, as bestmanagementpractices (BMPs) thatwill be considered for inclusion in the municipal stormwaterpermits. BMPs are consideredan appropriatefrom of effluent limits in permits for control of pollutants in municipalstormwater. Ecology is requiring Sonoco to renew their efforts to identify the sources offecal coliform in outfall 001 and to achieve significantreduction in effluent FC bythe end ofthe permitterm addressedbythis fact sheet. Turbidity--Ecology evaluated the impact ofturbidity based on the range ofturbidity inthe effluent and turbidity ofthe receiving water. Based onvisual observation ofthe facility's effluent, Ecology expects no violations ofthe turbidity criteria outside the designated mixing zone. 

### Toxic Pollutants--Federalregulations (40 CFR 122.44) require Ecology to place limits in NPDES permits ontoxic chemicals in an effluent wheneverthere is areasonable potential for those chemicals to exceedthe surface water quality criteria. Ecology does not exempt facilities withtechnology-based effluent limits from meeting the surface water quality standards. The following toxic pollutants are present inthe discharge: chlorine, ammonia, and specific heavymetals. Ecology conducted a reasonable potential analysis (See Appendix D) onthese parameters to determine whether itwould require effluent limits inthis permit. The presence ofthe metals lead and copper initially indicate a potential for water quality exceedance but this seems to be a function ofthe statistical variability associated with the sample size. Appendix D shows that an increased sample size reduces the assumed variabilityto the point where the spreadsheet indicates there would not be a reasonable potential for lead and copper to exceedthe water quality criteria. The potential to exceed water quality criteria was noted during the 2007-2012 permitterm and Sonoco was required to evaluate whether mill effluent had a reasonable potential to exceed water quality criteria. The results ofthe study were submitted onFebruary 12, 2009. Sonoco sampled the White River bothupstream and downstream from the mill's discharge outfall. The results were compared to water quality criteria. The study strongly suggests that suspended solids inthe White River contribute to elevated ambient concentrations ofmetals during heavyriver flows. Ammonia's toxicity depends onthat portion which is available inthe unionized form. The amount ofunionized ammonia depends on the temperature and pHinthe receiving freshwater. To evaluate ammonia toxicity, Ecology used the available receiving water information for ambient station 1OC070 and Ecology spreadsheet tools.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 30 of 61

Valid ambient background data were available for ammonia, copper, lead, selenium, and zinc. Ecology used all applicable data to evaluate reasonable potential for this discharge to cause a violation ofwater quality standards. Ecology dete1mined that chlorine, ammonia, copper, and lead pose no reasonable potential to exceed the water quality criteria at the critical condition using procedures given in EPA, 1991 (Appendix D) and as described above. Ecology's dete1mination assumes that Sonoco meets the effluent limits ofthis permit. Temperature--The state temperature standards (WAC 173-201A-200-210 and 600-612) include multiple elements:
• Annual summer maximumthreshold criteria (June 15 to September 15)
• Supplemental spawning and rearing season criteria (September 15 to June 15)
• Incremental wmming restrictions
• Protections against acute effects Ecology evaluates each criterion independently to determine reasonable potential and derive permit limits.
• Annual summer maximum and supplementary spawning/rearing criteria Each water bodyhas an annual maximum temperature criterion [WAC 173-201A-200(1)(c), 210(1)(c), and Table 602]. These threshold criteria (e.g., 12, 16, 17.5, 20°C) protect specific categories ofaquatic life by controllingthe effect ofhuman actions on summertemperatures. Some waters have an additional threshold criterion to protect the spawning and incubation of salmonids (9°C for char and 13°C for salmon and trout) [WAC 173-201A-602, Table 602]. These criteria apply during specific date-windows. The threshold criteria apply at the edge ofthe chronic mixing zone. Criteria for most fresh waters are expressed as the highest 7-Day average ofdaily maximumtemperature (7- DADMax). The 7-DADMax temperature is the arithmetic average ofseven consecutive measures ofdaily maximum temperatures. Criteria for marine waters and some fresh waters are expressed as the highest 1-Day annual maximumtemperature (1-DMax).
• Incremental wmming criteria The water quality standards limit the amount ofwmming human sources can cause under specific situations [WAC 173-201A-200(1)(c)(i)-(ii), 210(l)(c)(i)-(ii)]. The incremental warming criteria apply at the edge ofthe chronic mixing zone. At locations and times when background temperatures are coolerthanthe assigned threshold criterion, point sources are permitted to warmthe water by only a defined increment. These increments are permitted only to the extent doing so does not cause temperatures to exceed eitherthe 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 warmthe water more than 0.3°C above the naturally warm condition.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 31 of 61

WhenEcology has not yet completed a TMDL, our policy allows each point source to warm water at the edge ofthe chronic mixing zone by 0.3°C. This is true regardless ofthe background temperature and even ifdoing so would cause the temperature at the edge ofa standard mixing zone to exceed the numeric threshold criteria. Allowing a 0.3°C warming for eachpoint source is reasonable andprotective where the dilutiol) factor is based on 25% or less ofthe critical flow. This is because the fully mixed effect ontemperature will only be a fraction ofthe 0.3°C cumulative allowance (0.075°C or less) for all human sources combined.
• Protections for temperature acute effects Instantaneous lethalityto passing fish: The upper 99th percentile daily maximum effluent temperature mustnot 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 intemperature at the edge ofa chronic mixing zone are not allowed when the receiving watertemperature exceeds either a lDMax of23°C or a 7DADMax of22°C. Lethalityto incubating fish: Human actions must not cause a measurable (0.3°C) warming above 17.5°C at locations where eggs are incubating. Reasonable Potential Analysis The Permittee completed a two year study ontemperature as required bythe current permit. Ecology reviewed existing records and found that the White River at the point ofSonoco's discharge is belowthe water quality classification for temperature during a small time frame inthe late summer months. Annual Summer Maximum, Supplementary Spawning Criterion, and Incremental Warming Rriteria: Ecology calculated the reasonable potential for the discharge to exceed the annual summermaximum, the supplementary spawning criterion, and the incremental warming criteria at the edge ofthe chronic mixing zone during critical condition(s). No reasonable potential exists to exceed the temperature criterionwhere: (Criterion+ 0.3) > [Criterion+ (Teffluent95- Criterion)/DF]. The figure below graphically portrays the above equation and shows the conditions when a permitlimit will apply.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 32 of 61


### Figure 2. Dilution 

### Necessary to Meet Criteria atEdge ofMixing Zone

a= Calculation basedon: 17,5 (Criterion+ 0.3) > Crit:erion + (Te.ffb.ten.t:

## ::F- Crft:ln"ian) 0 WQ Criteria 

### =18 

# I'-------------------,-,J
0 WQ Criteria = 19

(17.5 

### +0.3) > (17.5 

### + (27.8- 17.5)/130). 31 33

Therefore, the proposed permit does not include a temperature limit. The permitrequires additional monitoring ofeffluent and ambient temperatures. Ecology will reevaluate the reasonable potential during the nextpermitrenewal. Ecology included the temperature calculations in Appendix D.

G. Human Health Washington's water quality standards include 91 numeric humanhealth-based criteriathat Ecology must consider when writing NPDES permits. These criteriawere 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 withhuman health criteria. Ecology determinedthe effluent may contain chemicals ofconcern for human health, based on data or information indicating regulated chemicals occur inthe discharge. Ecology evaluated the discharge's potential to violate the water quality standards as required by 40 CFR 122.44(d) by following the procedures published inthe Technical Support Document for Water Quality-Based Taxies Control (EPA/505/2-90-001) and Ecology's Permit Writer's Nfanual to make a reasonable potential determination. The evaluation showed that the discharge has no reasonable potential to cause a violation ofwater quality standards, and an effluent limit is not needed. H. Sediment Quality The aquatic sediment standards (chapter 173-204 WAC) protect aquatic biota and human health. Underthese standards Ecology mayrequire a facility to evaluate the potential for itsFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 33 of 61
discharge to cause a violation ofsediment standards (WAC 173;-204-400). You can obtain additional information about sediments at the Aquatic Lands Cleanup Unit website. http://www.ecy.wa.gov/programs/tcp/smu/sediment.html Through a review ofthe discharger characteristics and ofthe effluent characteristics, Ecology determined that this discharge has no reasonable potential to violate the sediment management standards. During the 1991-1996 permitterm, Sonoco was required to

. complete a sediment analysis study to evaluate sediment deposition and accumulation

potential inthe vicinity ofSonoco's outfall. The results submitted in 1993 indicated that the river velocity, even during lowflow, was sufficient to prevent the accumulation ofthe fine sediments possiblypresent in mill effluent. Even iffiner sediments do settle during unusually lowriver flows, they will be eroded away during the average river flow ofabout 1,500 cfs and an average stream velocity ofabout 2.9 ft/s. 

### I. Ground Water Quality Limits The ground water quality standards (chapter 173-200 WAC) protectbeneficial uses of ground water. Permits issued by Ecology must not allow violations ofthose standards (WAC 173-200-100). Sonoco does not discharge wastewaterto the ground. No permit limits are required to protect ground water. J. 

### Whole Effluent Toxicity The water quality standards for surface waters forbid discharge ofeffluentthat has the potential to cause toxic effects inthe receiving waters. Many toxic pollutants cannot be measured by commonly available detection methods. However, laboratory tests canmeasure toxicity directly by exposing living organisms to the wastewater and measuring their responses. These tests measure the aggregate toxicity ofthe 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 as the significant response to the toxicity ofthe effluent. Dischargers who monitor their wastewater with acute toxicity tests find early indications ofany potential lethal effect ofthe effluent on organisms inthe 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 organismwith an extremely short life cycle, or apartial life cycle test during a critical stage ofa test organism's life. Some chronic toxicity tests also measure organism survival. Laboratories accredited by Ecology for WET testing knowhowto use the proper WET testing protocols, fulfill the data requirements, and submitresults inthe correct reporting format. Accredited laboratory staffknow about WET testing and howto calculate an NOEC, LC50, EC50, IC25, etc. Ecology gives all accredited labs the most recent version ofEcology PublicationNo. WQ-R-95-80, Laboratory Guidance and Whole Effluent Toxicity Test Review Criteria (http://www.ecy.wa.gov/biblio/9580.html), which is referenced inthe permit.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 34 of 61
Ecology recommends that Sonoco send a copy ofthe acute or chronic toxicity sections(s) of its NPDES permit to the laboratory. WET testing conducted during effluent characterization showed no reasonable potential for effluent discharges to cause receiving water acute toxicity. The proposed permit will not include an acute WET limit. Sonoco must retest the effluent before.submitting an application for permitrenewal.
• Ifthis facility makes process or material changes which, inEcology's opinion, increase the potential for effluent toxicity, thenEcologymay (in aregulatory order, by permit modification, or inthe permitrenewal) require the facility to conduct additional effluent characterization. Sonoco may demonstrate to Ecologythat effluenttoxicity has not increased byperforming additional WET testing and/or chemical analyses after the process or material changes have been made. Ecology recommends that the Permittee check with it first to make sure that Ecology will considerthe demonstration adequate to support a decision to not require an additional effluent characterization.
• IfWET testing conducted for submittal with a permit applicationfails to meetthe performance standards in WAC 173-205-020, Ecology will assume that effluent toxicity has increased. WETtesting conducted during the previous permit term showed a reasonable potential for the effluentto cause chronic toxicity in the receiving water. The proposedpermit will include a chronic toxicity limit. The effluent limit for chronic toxicity is: No toxicity detected in a test sample representing the chronic critical effluent concentration (CCEC). The CCEC is the concentration ofeffluent at the boundary ofthe mixing zone during critical conditions. The CCEC equals 0.77% effluent. Compliance with a chronic toxicity limit is measured by a chronic toxicity test comparing the test organism response in effluent diluted to the CCEC, to test organism response in nontoxic control water. Sonoco is incompliance withthe chronic toxicity limit ifthere is no statistically significant difference intest organismresponse betweenthe CCEC sample and the control sample. ·

Table 17. Summarized Historical WET Results IV. SONOCO Chronic WET TestResults as NOEC/LOEC in % Effluent Collected StartDate Organism Endpoint NOEC LOEC PMSD 11/13/200 11/14/200 Ceriodaphni 7-day 0 0 a dubia Survival 6.3 

### > 6.3 Reproductio n 6.3 

### > 6.3 16.6% Ceriodaphni 7-day 2/26/2001 2/27/2001 a dubia Survival 6.3 

### > 6.3 Reproductio n 6.3 

### > 6.3 32.1% 2/26/2001 2/27/2001 fathead 7-day 6.3 

### > 6.3 18.0%Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 35 of 61



### IV. SONOCO Chronic 

### WETTestResults as NOECILOEC in % Effluent Collected 

### StartDate Organism Endpoint NOEC LOEC PMSD mmnow Survival Biomass 6.3 

### > 6.3 25.8% Weight 6.3 

### > 6.3 22.2% fathead 7-day 5/7/2001 5/8/2001 mmnow Survival 0.76 6.3 6.3% Biomass < 0.76 0.76 11.9% Weight 6.3 

### > 6.3 34.8% Ceriodaphni 7-day 5/7/2001 5/8/2001 a dubia Survival 6.3 

### > 6.3 Reproductio n 6.3 

### > 6.3 31.2% Ceriodaphni 7-day 1/7/2002 1/8/2002 a dubia Survival 6.3. 

### > 6.3 Reproductio n < 0.76 0.76 15.3% fathead 7-day ' 1/7/2002 1/8/2002 mmnow Survival 6.3 

### > 6.3 9.5% Biomass 6.3 

### > 6.3 14.5% Weight 6.3 

### > 6.3 13.3% Ceriodaphni 7-day 6/24/2002 6/25/2002 a dubia Survival 12 

### > 12 Reproductio n 0.77 3 20.3% Ceriodaphni 7-day 5/12/2006 5/13/2003 a dubia Survival 12 

### > 12 Reproductio n 12 

### > 12 28.7% 11/10/200 11/11/200 fathead 7-day 3 3 mmnow Survival 12 

### > 12 11.3% Biomass 12 

### > 12 15.8% Weight 12 

### > 12 16.8% Ceriodaphni 7-day 5/17/2004 5/18/2004 a dubia Survival 12 

### > 12 Reproductio n 12 

### > 12 22.6% fathead 7-day 11/8/2004 11/9/2004 mmnow Survival 0.35 0.77 32.0% Biomass 0.77 3 33.5% Weight 12 

### > 12 28.5% Ceriodaphni 7-day 6/6/2005 6/7/2005 a dubia Survival 12 

### > 12 Reproductio 12 

### > 12 28.4%Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 36 of 61



### IV. SONOCO ChronicWET TestResults as NOECILOEC in % 

### Effluent Collected 

### StartDate Organism Endpoint NOEC LOEC

. PMSD n 12/14/200 12/15/200 fathead 7-day 5 5 mmnow Survival 12 

### > 12 7.1% Biomass 12 

### > 12 9.9% Weight 12 

### > 12 7.8% fathead 7-day 6/5/2006 6/6/2006 mmnow Survival 12 

### > 12 9.0% Biomass 6.3 12 21.0% Weight 6.3 12 19.7% 12/18/200 12/19/200 Ceriodaphni 7-day 6 6 a dubia Survival 12 

### > 12 Reproductio n 12 

### > 12 26.8% 10/22/200 10/23/200 Ceriodaphni 7-day 7 7 a dubia Survival 12 

### > 12 Reproductio n 0.77 3 20.6% 11/26/200 11/27/200 fathead 7-day 7 7 mmnow Survival 12 

### > 12 21.9% Biomass 12 

### > 12 24.9% Weight 12 

### > 12 22.9% fathead 7-day 5/4/2009 5/5/2009 mmnow Survival 12 

### > 12 17.8% Biomass 12 

### > 12 18.8% Weight 12 

### > 12 16.3% fathead 7-day 5/10/2010 5/11/2010 mmnow Survival 12 

### > 12 18.2% Biomass 12 

### > 12 15.0% Weight 12 

### > 12 15.6%



### K. Comparison ofEffluentLimits with the Previous PermitIssued on May 9, 2007.

Table 18. ComparisonofPrevious and Proposed Effluent Limits

·,, 

### PreviousEffluent Proposed EffluentLimits: Limits: Outfall#001 Outfall#001 Parameter Basis of Average Maximum Average Maximum Limit Monthly Daily Monthly DailyFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 37 of 61

PreviousEffluent ProposedEffluentLimits: Limits: Outfall# 001 Outfall# 001 Parameter Basis of Average Maximum Average Maximum Limit

__**M~nt!!_!y_** ___ **!?~!!Y** _____ --

**~~~!hl.Y**___ ----- Dal!Y______

- ······--..--······-····-········--··--··---

**----·-···-·---~---··········-** Technology Biochemical for monthly Oxygen average, 529 673 550 lbs/day 673 lbs/day TMDLfor lbs/day lbs/day Demand (5-day) daily maximum Technology Total Suspended for monthly 754 1487 Solids average and lbs/day lbs/day 726lbs/day 1441lbs/day daily maximum TMDLfor Total AmmoniaN daily

- 

## - - 1.llbs/day maximum

Basis of Monthly Weekly Monthly Parameter Limit Geometric Geometric Geometric Weeldy Mean Mean Mean Geometric Limit Limit Limit MeanLimit NAbut will NA but will Fecal Coliform TMDL reqmre reqmre Bacteria 

### - 

## - 1/month 1/month monitoring monitoring

PreviousEffluent ProposedEffluentLimits: Limits: Outfall# 001 Outfall# 001 Parameter Basis of Limit Limit Limit Daily minimum is equal Dailyminimum is equal to pH Technology to or greaterthan 6.0 and or greaterthan 6.0 and the the daily maximumis daily maximum is less than less than or equal to 9.0 or equal to 9.0.



### V. Monitoring RequirementsFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 38 of 61
Ecology requires monitoring, recording, and reporting (WAC 173-220-210 and 40 CFR 122.41) to verify that the treatmentprocess is functioning correctly and that the discharge complies with the permit's effluent limits. The monitoring schedule is detailed in the proposedpermit under Special Condition S.2. Specified monitoring frequencies take into accountthe quantity and variability ofthe discharge, the treatment method, past compliance, significance ofpollutants, and cost ofmonitoring. A. Lab Accreditation Ecology requires that facilities must use a laboratory registered or accredited under the provisions ofchapter 173-50 WAC, Accreditation ofEnvironmental Laboratories, to prepare all monitoring data (withthe exception ofcetiainparameters). Ecology accreditedthe laboratory at this facility for: biochemical oxygen demand (BODO, total suspended solids (TSS), pH, and dissolved oxygen. Ammonia samples and all WETtesting is sent to certified laboratories for analysis. B. Effluent Limits Which are Near Detection or Quantitation Levels The method detection level (MDL) is the minimum concentration ofa pollutantthat 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 is the level at which a laboratory can reliablyreport concentrations with a specified level of error. Estimated concentrations are the values betweenthe MDL and the QL. Ecology requires permitted facilities to report estimated concentrations. Whenreporting maximum daily effluent concentrations, Ecology requires the facility to report "lessthan X" where X is the required detectionlevel ifthe measured effluent concentration falls belowthe detection level. When calculating average monthly concentrations, the facility mustuse all the effluent concentrations measured belowthe quantitation level but above the method detection level.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 39 of 61



### VI. OtherPermit Conditions A. Reporting and Record Keeping Ecology based Special Condition S3 on its authority to specify any appropriate reporting and record keeping**requirement~** to prevent and control waste discharges (WAC 173-220-210). 

### B. Spill Plan This facility stores a quantity ofchemicals on-site that have the potential to cause water pollution ifaccidentally released. Ecology can require a facility to develop best management plans to prevent this accidental release [Section 402(a)(1) ofthe Federal Water Pollution Control Act (FWPCA) and RCW 90.48.080]. Sonoco developed a plan for preventingthe accidental release ofpollutants to state waters and for minimizing damages ifsuch a spill occurs. The proposed permitrequires the facility to update this plan and submit itto Ecology. 

### C. Solid Waste Control Plan Sonoco could cause pollution ofthe waters ofthe state through inappropriate disposal of solid waste orthroughthe release ofleachate from solid waste. This proposed permit requires this facility to update the approved solid waste control plan designed to prevent solid waste from causingpollution ofwaters ofthe state. The facility must submitthe updated planto Ecology for approval (RCW 90.48.080). You can obtain an Ecology guidance document, which describes how to develop a Solid Waste Control Plan, at: http://www.ecy.wa.gov/pubs/0710024.pdf 

### D. OutfallEvaluation The proposedpermitrequires Sonoco to conduct an outfall inspection and submit a report detailing the findings ofthat inspection (Special ConditionS. 13). The inspectionmust evaluate the physical condition ofthe discharge pipe and diffusers, and evaluate the extent of sediment accumulations inthe vicinity ofthe outfall. 

### E. Operation and MaintenanceManual Ecology requires industries to take all reasonable steps to properly operate and maintaintheir wastewatertreatment system in accordance with state and federal regulations [ 40 CFR 122.41(e) and WAC 173-220-150 (1)(g)]. The facility will prepare and submit an operation and maintenance manual as required by state regulation for the modification ofexisting or construction ofadditional wastewatertreatment facilities (WAC 173-240-150). Implementation ofthe procedures in the operation and maintenance manual ensures the facility's compliance withthe terms and limits inthe permit. The facility will submit an update to the existing O&M manual within one year ofthe effective permitrenewal date. 

### F. StormwaterPrevention Plan In accordance with 40 CFR 122.44(k) and 40 CFR 122.44 (s), the proposedpermit includes requirements for the update and implementation ofa SWPPP along withBMPsto minimize or prevent the discharge ofpollutants to waters ofthe state. BMPs constitute BestFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 40 of 61

Conventional Pollutant Control Technology (BCT) and Best Available Technology Economically Achievable (BAT) for stormwater discharges. Ecology has determined that Sonoco must develop and maintain a SWPPP and implement adequate BMPs in order to meet the requirements of"all known, available, and reasonable methods ofprevention, control, and treatment" (AKART). A SWPPP requires a facility to implement actions necessaryto manage stormwater to comply with the state's requirement under chapter 90.48 RCWto protectthe beneficial uses ofwaters ofthe state. The SWPPP must identifY potential sources ofstormwater contamination from industrial activities and identifY howitplans to mange those sources ofcontaminationto prevent or minimize contamination ofstormwater. Sonoco must continuously review and revise the SWPPP as necessary to assure that stormwater discharges do not degrade water quality. It must retain the SWPPP on-site orwithin reasonable access to the site and available for reviewbyEcology. Best Management Practices (BMPs) BMPs are the actions identified inthe SWPPP to manage, prevent contamination of, and treat storm water. BMPs include schedules ofactivities, prohibitions ofpractices, maintenance procedures, and other physical, structural and/or managerial practices to prevent or reduce the pollution ofwaters ofthe state. BMPs also include treatment systems, operating procedures, and practices used to control plant site runoff, spillage or leaks, sludge or waste disposal, and drainage from raw material storage. Sonoco must ensure that its SWPPP includes the operational and structural source control BMPs listed as "applicable" in Ecology's stmmwatermanagement manuals. Many ofthese "applicable" BMPs are sectorspecific or activity-specific, and are not required at facilities engaged in other industrial sectors or activities. Ecology-Approved Stormwater Management Manuals Consistent with RCW 90.48.555 (5) and (6), the proposedpermit requires the facility to implement BMPs contained inthe Stormwater Management Manual for Western Washington (2005 edition), or anyrevisions thereof, or practices that are demonstrably equivalentto practices contained in stormwater technical manuals approved by Ecology. This should ensure that BMPs will preventviolations ofstate water quality standards, and satisfY the state AKARTrequirements and the federal technology-based treatment requirements under 40 CPRpart 125.3. The SWPPP must document that the BMPs selected provide an equivalent level ofpollutionprevention, comparedto the applicable Storm water Management Manuals, including: The technical basis for the selection for all stormwater BMPs (scientific, technical studies, and/or modeling) which supportthe performance claims for the BMPs selected. An assessment ofhowthe BMPs will satisfY AKARTrequirements and the applicable technology-based treatmentrequirements under 40 CPRpart 125.3. Operational Source Control BMPs Operational source control BMPs include a schedule ofactivities, prohibition ofpractices, maintenance procedures, employee training, good housekeeping, and other managerial practices to prevent or reduce the pollution ofwaters ofthe state. These activities do not require construction ofpollution control devices but are very important components ofaFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 41 of 61

successful SWPPP. Employee training, for instance, is critical to achieving timely and consistent spill response. Pollutionprevention is likely to fail ifthe employees do not understand the importance and objectives ofBMPs. Prohibitions might include eliminating outdoor repair work on equipment and cetiainly would include the elimination ofintentional draining ofcrankcase oil onthe ground. Good housekeeping and maintenance schedules help prevent incidents that could result inthe release ofpollutants. Operational BMPs represent a cost-effective way to control pollutants and protect the environment. The SWPPP must identify all the operational BMPs and how and where they are implemented. For example, the SWPPP must identify what training will consist of, whentraining will take place, and who is responsible to assure that employee training happens. Structural Source Control BMPs Structural source control BMPs include physical, structural, or mechanical devices or facilities intendedto preventpollutants from entering stormwater. Examples ofsource control BMPs include erosion control practices, maintenance ofstormwater facilities (e.g., cleaning out sediment traps), construction ofroofs over storage and working areas, and direction ofequipment washwater and similar discharges to the sanitary sewer or a dead end sump. Structural source control BMPs likely include a capital investment but are cost effective comparedto cleaning up pollutants after they have entered stormwater. Treatment BMPs Operational and structural source control BMPs are designed to preventpollutants from entering stormwater. However, even with an aggressive and successful program, stormwater may still require treatmentto achieve compliance with water quality standards. Treatment BMPsremove pollutants from stormwater. Examples oftreatment BMPs are detention ponds, oil/water separators, biofiltration, and constructed wetlands. · Volume/Flow Control BMPs Ecology recognizes the needto include specific BMP requirements for stormwater runoff quantity control to protect beneficial water uses, including fish habitat. New facilities and existing facilities undergoing redevelopment must implementthe requirements for peak runoffrate and volume control identified by volume 1 ofthe Western Washington SWMM and chapter 2 inthe Eastern Washington SWMMas applicable to their development. .Chapter 3 ofvolume 3 Western Washington SWMMand chapter 6 inthe Eastern Washington SWMM lists BMPs to accomplish rate and volume control. Existing facilities inwestern Washington should also review the requirements ofvolumes 1 (Minimum Technical Requirements) and chapter 3 ofvolume 3 inthe Western Washington SWMM. Chapter 2 (Core Elements for NewDevelopment and Redevelopment) in the Eastern Washington SWMMcontains the minimumtechnical requirements for facilities east ofthe Cascades. Although notrequired to implement these BMPs, controlling rate and volume ofstormwater discharge maintains the health ofthe watershed. Existing facilities should identify control measures thatthey can implement over time to reduce the impact ofuncontrolled release ofstormwater. G. Best Management Practices Best managementpractices (BMPs) are the actions identified to manage, prevent contamination of, and treat stormwater. BMPs include schedules ofactivities, prohibitions ofFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 42 of61
practices, maintenanceprocedures, and otherphysical, structural and/or managerial practices to prevent or reduce the pollution ofwaters ofthe state. BMPs also include treatment systems, operating procedures, and practices used to control plant site runoff, spillage or leaks, sludge or waste disposal, and drainage from raw material storage. H. 

### General Conditions Ecology bases the standardized General Conditions on state and federal law and regulations. They are included in all individual industrial NPDES permits issued by Ecology.


### VII. Permit Issuance Procedures A. Permit Modifications Ecology may modify this permitto impose numerical limits, ifnecessary to comply with water quality standards for surface waters, with sediment quality standards, or with water quality standards for ground waters, after obtaining newinformation from sources such as inspections, effluent monitoring, outfall studies, and effluent mixing studies. Ecologymay also modify this permitto comply withnew or amended state or federal regulations. 

### B. Proposed Permit Issuance This proposed permit includes all statutoryrequirements for Ecologyto authorize a wastewater discharge. The permit includes limits and conditions to protect human health and aquatic life, and the beneficial uses ofwaters ofthe state ofWashington. Ecologyproposes to issue this permit for a term of5 years.


### VIII. References for Test and Appendices Environmental Protection Agency (EPA) 1992. National Toxics Rule. Federal Register, V. 57, No. 246, Tuesday, December 22, 1992. 1991. Technical SupportDocument for Water Quality-based Taxies Control. EPA/505/2-90- 001. 1988. Technical Guidance on Supplementary Stream Design Conditionsfor SteadyState Modeling. USEPA Office ofWater, Washington, D.C. 1985. Water QualityAssessment:A ScreeningProcedurefor Toxic and Conventional Pollutants in Surface andGround Water. EPA/600/6-85/002a. 1983. Water Quality Standards Handbook. USEPA Office ofWater, Washington, D.C. Tsivoglou, E.C., and J.R. Wallace. 1972. Characterization of Stream Reaeration Capacity. EPA-R3-72-012. (Cited in EPA 1985 op.cit.) Washington State Department ofEcology.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 43 of 61

November 2010. Permit Writer's Manual. PublicationNumber 92-109 (http://www.ecy.wa.gov/biblio/92109.html) 2007. Focus Sheet on Solid Waste Control Plan, Developing a Solid Waste Control Plan for Industrial Wastewater Discharge Permittees. PublicationNumber 07-10-024 Laws and Regulations( http://www.ecy.wa.gov/laws-rules/index.html) Permit and Wastewater Related Information (http://www.ecy.wa.gov /programs/wq/wastewater/index.html) February 2007. Focus Sheet on Solid Waste ControlPlan, Developing a Solid Waste ControlPlan for Industrial Wastewater Discharge Permittees, PublicationNumber 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 inEPA 1985 op.cit.)Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 44 of 61 

### Appendix A--Public Involvement Information Ecology proposes to reissue a pe1mit to Sonoco Products Company. The permit includes wastewater discharge limits and other conditions. This fact sheet describes the facility and Ecology's reasons for requiring pmmit conditions. Ecology will place a PublicNotice ofDraft onMarch 20. 2013 in the Bonney Lake & Sumner Courier-Herald to inform the public and to invite comment onthe proposed draftNational Pollutant Discharge Elimination Systempermit and fact sheet. The notice:
• Tells where copies ofthe 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.
• Urgespeople to submittheir comments, in writing, before the end ofthe Comment Period
• Tells howto request a public hearing ofcomments about the proposed NPDES permit.
• Explains the next step(s) in the permitting process. Ecology has published a document entitled FrequentlyAskedQuestions aboutEffective Public Commenting which is available on our website at http://www.ecy.wa.gov/biblio/0307023.html. You may obtain further information from Ecology bytelephone, 360 407-6954, or by writing to the address listed below. Water Quality Permit Coordinator Department ofEcology Industrial Section PO Box 47600 Olympia, WA 98504-7600

The primary author ofthis permit and fact sheet is Robert Carruthers.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 45 of 61 

### Appendix B--YourRight to Appeal You have a right to appeal this permitto the Pollution Control Hearing Board (PCHB) within 30 days ofthe date ofreceipt ofthe final permit. The appeal process is governed by chapter 43.21B RCW and chapter 371-08 WAC. "Date ofreceipt" is defined in RCW 43.21B.001(2) (see glossary). To appeal you must do the following within 30 days ofthe date ofreceipt ofthis permit:

• File your appeal and a copy ofthis permit with the PCHB (see addresses below). Filing means actual receipt by the PCHB during regular business hours.

• Serve a copy ofyour appeal and this permit on Ecology inpaperform

- by mail or inperson. (See addresses below.) E-mail is not accepted. Youmust also comply with other applicable requirements in chapter 43 .21B RCW and chapter 371-08 WAC.

ADDRESS AND LOCATIONINFORMATION



### StreetAddresses MailingAddresses

Department ofEcology DepartmentofEcology Attn: Appeals Processing Desk Attn: Appeals Processing Desk 300 Desmond Drive SE PO Box 47608 Lacey, WA 98503 Olympia, WA 98504-7608 

### Pollution ControlHearings Board Pollution Control Hearings Board 1111 Israel RD SW PO Box 40903 STE 301 Olympia, W A 98504-0903 Tumwater, WA 98501Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 46 of61



### . Appendix C--Glossary 1-DMax or 1-Day Maximum Temperature-- The highest water temperature reached on any given day. This measure can be obtained using calibrated maximum/minimum thermometers or continuous monitoring probes having sampling intervals ofthirty minutes or less. 

### 7-DADMax or7-DayAverage ofthe Daily Maximum Temperatures-- The arithmetic average ofseven consecutive measures ofdaily maximum temperatures. The 7-DADMax for any individual day is calculated by averaging that day's daily maximum temperature with the daily maximum temperatures ofthe three days prior and the three days after that date. 

### Acute Toxicity --The lethal effect ofa 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 ofprevention, control and treatment." AKART is a technology-based approach to limiting pollutants from wastewater discharges, whichrequires an engineeringjudgment and an economicjudgment. AKAR T must be applied to all wastes and contaminants priorto entry into waters ofthe state in accordance withRCW 90.48.010 and 520, WAC 173-200-030(2)(c)(ii) and WAC 173- 216-110(1)(a). 

### AlternatePoint ofCompliance

-- An alternative location inthe ground water from the point of compliance where compliance withthe ground water standards is measured. Itmay be established in the ground water at locations some distance from the discharge source, up to, but not exceedingthe 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 ofcompliance must be determined and approved in accordance with WAC 173-200-060(2). 

### AmbientWater Quality

-- The existing environmental condition ofthe water in areceiving waterbody. 

### Ammonia

-- Ammonia is produced bythe breakdown ofnitrogenous materials in wastewater. Ammonia is toxic to aquatic organisms, exerts an oxygen demand and contributes to eutrophication. Italso increases the amount ofchlorine needed to disinfect wastewater. 

### Annual Average Design Flow (AADF) --Average ofthe daily flow volumes anticipated to occur over a calendar year. 

### Average Monthly Discharge Limit-- The average ofthe measured values obtained over a calendar month's time. 

### BackgroundWater Quality

-- The concentrations ofchemical, physical, biological or radiological constituents or other characteristics in or ofground water at a particularpoint in time upgradient ofan activity that has not been affected by that activity, [WAC 173-200- 020(3)]. Background water quality for any parameter is statistically defined as the 95% upper tolerance interval with a 95% confidence based on at least eighthydraulically upgradient water quality samples. The eight samples are collected over a period ofat least one year, withno more than one sample collected during any month in a single calendar year.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 47 of 61



### Best ManagementPractices (BMPs)

-- Schedules ofactivities, prohibitions ofpractices, maintenance procedures and otherphysical, structural and/or managerial practices to prevent or reduce the pollution ofwaters ofthe state. BMPs include treatment systems, operating procedures and practices to control: plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from rawmaterial storage. BMPs may be further categorized as operational, source control, erosion and sediment control and treatment BMPs. 

### BODs

-- Determining the five-day Biochemical Oxygen Demand ofan effluent is an indirect way ofmeasuring the quantity oforganic material present in an effluent that is utilized by bacteria. The BODs is used inmodeling to measure the reduction ofdissolved oxygen in receiving waters after effluent is discharged. Stress caused byreduced dissolved oxygen levels makes organisms less competitive and less able to sustaintheir species inthe aquatic environment. Although BODs is not a specific compound, it is defined as a conventional pollutant underthe federal CleanWater Act. 

### Bypass

-- The intentional diversion ofwaste streams from any portion ofa treatment facility. 

### Categorical Pretreatment Standards-- National pretreatment standards specifying quantities or concentrations ofpollutants orpollutant properties, whichmay be discharged to a POTW by existing ornewindustrial usersin specific industrial subcategories. 

### Chlorine

-- A chemical used to disinfectwastewaters ofpathogens hannful to human health. Itis also extremely toxic to aquatic life. 

### Chronic Toxicity

-- The effect ofa compound on an organism over arelatively longtime, often 1/10 ofan organism's lifespan ormore. Chronic toxicity canmeasure survival, reproduction or growthrates, or other parameters to measure the toxic effects ofa compound or combination ofcompounds. 

### ·CleanWaterAct (CWA) --The federal Water Pollution Control Act enacted by Public Law 92-500, as amended byPublic Laws 95-217, 95-576, 96-483, 97-117; USC 1251 et seq. 

### Compliance Inspection-Without Sampling

-- A site visit for the purpose ofdetermining the compliance ofa facility withthe terms and conditions ofits permit or with applicable statutes and regulations. 

### Compliance Inspection-with Sampling

-- A site visit for the purpose ofdeterminingthe compliance ofa facility withthe terms and conditions ofits permit or with applicable statutes and regulations. In addition it includes as a minimum, sampling and analysis for all parameters with limits inthe permitto ascetiain compliance withthose limits; and, for municipal facilities, sampling ofinfluentto ascertain compliance with the 85 percentremoval requirement. Ecology may conduct additional sampling. 

### Composite Sample

-- A mixture ofgrab samples collected at the same sampling point at different times, formed either by continuous sampling orbymixing discrete samples. May be "time-composite" (collected at constant time intervals) or "flow-proportional" (collected either as a constant sample volume attime intervals proportional to stream flow, or collected by increasing the volume ofeach aliquot as the flow increased while maintaining a constant time interval betweenthe aliquots).Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 48 of61



### Construction Activity

-- Clearing, grading, excavation and any other activity, which disturbs the surface ofthe land. Such activities may include road building; construction ofresidential houses, office buildings, or industrial buildings and demolition activity. 

### Continuous Monitoring

-- Unintenupted, unless otherwise noted inthe permit. 

### Critical Condition

-- The time during whichthe combination ofreceiving water and waste discharge conditions have the highestpotential for causingtoxicity inthe receiving water environment. This situationusually occurs when the flow within a waterbody is low, thus, its ability to dilute effluent is reduced. 

### Date ofReceipt- This is defined inRCW 

### 43.21B.OO 1(2) as five business days after the date of mailing; orthe date ofactual receipt, whenthe actual receipt date can be proven by a preponderance ofthe evidence. The recipient's sworn affidavit or declarationindicating the ·date ofreceipt, which is unchallenged bythe agency, constitutes sufficient evidence ofactual receipt. The date ofactual receipt, however, maynot exceed forty-five days from the date of mailing. 

### Detection Limit

-- See MethodDetectionLevel. 

### Dilution Factor (DF)

-- A measure ofthe amount ofmixing ofeffluent and receiving waterthat occurs at the boundary ofthe mixing zone. Expressed as the inverse ofthe percent effluent fraction, for example, a dilution factor of 

### 10 means the effluent comprises 

### 1 0% by volume and the receiving water 

### 90%. Distribution Uniformity

-- The uniformity ofinfiltration (or application in the case ofsprinkle ortrickle inigation) throughoutthe field expressed as a percent relating to the average depth infiltrated inthe lowest one-quatier ofthe areato the average depth ofwater infiltrated. 

### EarlyWarningValue

-- The concentration ofa pollutant set in accordance with WAC 

### 173-200-070 that is a percentage ofan enforcement limit. Itmay be established in the effluent, ground water, surface water, the vadose zone or withinthe treatmentprocess. This value acts as a triggerto detect and respond to increasing contaminant concentrations priorto the degradation ofa beneficial use. 

### EnforcementLimit

-- The concentration assigned to a contaminant inthe ground water at the point ofcompliance for the purpose ofregulation, [WAC 

### 173-200-020(11)]. This limit assures that a ground water criterion will not be exceeded and that background water quality will be protected. 

### EngineeringReport

-- A document that thoroughly examines the engineering and administrative aspects ofa particular domestic or industrial wastewater facility. The report must contain the appropriate information required inWAC 

### 173-240-060 or 

### 173-240-130. Fecal Coliform Bacteria-- Fecal coliform bacteria are used as indicators ofpathogenic bacteria in the effluentthat are harmful to humans. Pathogenic bacteria in wastewater discharges are controlled by disinfecting the wastewater. The presence ofhighnumbers offecal coliform bacteria in a water body can indicate the recent release ofuntreated wastewater and/or the presence ofanimal feces.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 49 of 61



### Grab Sample

-- A single sample or measurement taken at a specific time or over as short a period oftime as is feasible. 

### Ground Water-- Water in a saturated zone or stratum beneath the surface ofland or below a surface water body. 

### IndustrialUser-- A discharger ofwastewaterto the sanitary sewer that is not sanitary wastewater or is not equivalentto sanitary wastewater in character. 

### IndustrialWastewater-- Water or liquid-carried waste from industrial or commercial processes, as distinct from domestic wastewater. These wastes mayresult from anyprocess or activity ofindustry, manufacture, trade or business; from the development ofany natural resource; or from animal operations such as feed lots, poultry houses, or dairies. The term includes contaminated storm water and, also, leachate from solid waste facilities. 

### Interference

-- A discharge which, alone or in conjunctionwith a discharge or discharges from other sources, both:

• Inhibits or disrupts the POTW, its treatmentprocesses or operations, or its sludge processes, use or disposal; and

• Therefore is a cause ofa violation ofany requirement ofthe POTW'sNPDES permit (including an increase inthe magnitude or duration ofa violation) or ofthe prevention of sewage sludge use or disposal in compliance with the following statutoryprovisions and regulations orpermits issuedthere under (or more stringent State or local regulations): Section 405 ofthe Clean Water Act, the Solid Waste Disposal Act (SWDA) (including title II, more commonlyreferred to as the Resource Conservation and Recovery Act (RCRA), and including State regulations contained in any State sludge managementplan prepared pursuant to subtitleD ofthe SWDA), sludge regulations appearing in 40 CFR Part 507, the CleanAir Act, the Toxic Substances Control Act, and the Marine Protection, Research and Sanctuaries Act. 

### LocalLimits

-- Specific prohibitions or limits onpollutants orpollutantparameters developed by aPOTW. 

### LOEC-- (lowest observed effects concentration)- The LOEC is the lowest concentration in a toxicity test which shows a statistically significant difference from the control. 

### MajorFacility-- A facility discharging to surface water with an EPArating score of> 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact. 

### Maximum Daily Discharge Limit

-- The highest allowable daily discharge ofa pollutant measured during a calendar day or any 24-hourperiod that reasonably represents the calendar day for purposes ofsampling. The daily discharge is calculated as the average measurement ofthe pollutant overthe day. 

### Maximum Day Design Flow (MDDF)

-- The largest volume offlow anticipated to occur during a one-dayperiod, expressed as a daily average. 

### Maximum MonthDesign Flow (MMDF)

-- The largest volume offlow anticipated to occur during a continuous 30-dayperiod, expressed as a daily average.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 50 of61

Maximum WeekDesign Flow (MWDF) --The largest volume offlow anticipated to occur during a continuous 7-day period, expressed as a daily average. Method Detection Level (MDL)-- The minimum concentration ofa substance that can be measured and reported with 99 percent confidence that the pollutant concentration is above zero and is dete1mined from analysis ofa sample in a givenmatrix containing the pollutant. MinorFacility

-- A facility discharging to surface water with an EPArating score of< 80 points based on such factors as flow volume, toxic pollutantpotential and public health impact. Mixing Zone

-- An area that surrounds an effluent discharge within which water quality criteria may be exceeded. Thepermit specifies the area ofthe authorized mixing zone that Ecology defines following procedures outlined in state regulations (chapter 173-201AWAC). National PollutantDischargeElimination System (NPDES) --TheNPDES (Section 402 of the CleanWaterAct) is the federal wastewaterpermitting system for discharges to navigable waters ofthe United States. Many states, includingthe state ofWashington, have been delegated the authority to issue these permits. NPDES permits issued by Washington State permit writers arejointNPDES/State permits issued under both state and federal laws. NOEC --Means the "no observed effect concentration" which is the highest concentration of effluent in a toxicitytest shown to have no statistically significant adverse effects when comparedto an appropriate control. pH-- The pH ofa liquid measures its acidity or alkalinity. Itis the negative logarithm ofthe hydrogen ion concentration. A pH of7 is defined as neutral and large variations above or belowthis value are considered harmful to most aquatic life. Pass-Through

-- A discharge which exits the POTW into waters ofthe State in quantities or concentrations which, alone or in conjunctionwith a discharge or discharges from other sources, is a cause ofa violation ofany requirement ofthe POTW'sNPDES permit (including an increase inthe magnitude or duration ofa violation), or which is a cause ofa violation ofState water quality standards. PeakHour Design Flow (PHDF)

-- The largest volume offlow anticipatedto occur during a one- period, expressed as a daily orhourly average. PeakInstantaneous Design Flow (PIDF)

-- The maximum anticipated instantaneous flow. PercentMinimum Significant Difference (PMSD)

-- Given the number ofreplicates used in atest and the variability in test organism response across those replicates, the PMSD is an estimate of the minimum difference needed between atest concentration and a control in order for that difference to be considered significantly different when subjected to a statistical comparison. Point ofCompliance

-- The location inthe ground water where the enforcement limit must not be exceeded and a facility must comply withthe Ground Water Quality Standards. Ecology determines this limit on a site-specific basis. Ecology locates the point ofcompliance inthe ground water as near and directly downgradient from the pollutant source as technically, hydrogeologically, and geographically feasible, unless it approves an alternative point of compliance.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 51 of 61

Potential Significant Industrial User (PSIU) --Apotential 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 ofthe following criteria:
a. Exceeds 0.5 %oftreatmentplant design capacity criteria and discharges <25,000 gallons per day or; b. Is a member ofa group ofsimilar industrial users which, takentogether, have the potential to cause pass through or interference atthe POTW (e.g. facilities which develop · photographic film orpaper, and car washes). ·Ecologymay determine that a discharger initially classified as a potential significant industrial user should be managed as a significant industrial user.· Quantitation Level (QL) --Alsoknown as Minimum Level ofQuantitation (ML)- The lowest level at whichthe entire analytical systemmust give arecognizable signal and acceptable calibrationpoint for the analyte. Itis equivalentto the concentration ofthe lowest calibration standard, assuming that the lab has used all method-specified sample weights, volumes and cleanup procedures. The QL is calculated by multiplying the MDL by 3.18 and rounding the result to the number nearest to (1,2,or 5) x 

### IOn, where n is an integer. (64 FR 30417). ALSO GIVEN AS: The smallest detectable concentration ofanalyte greaterthanthe Detection Limit (DL) where the accuracy (precision & bias) achieves the objectives ofthe intendedpurpose. (Report of the Federal Advisory Committee on Detection and QuantitationApproaches and Uses in Clean Water Act Programs Submitted to the US Environmental ProtectionAgency December 2007). Reasonable Potential

-- A reasonable potential to cause a water quality violation, or loss of sensitive and/or important habitat. Responsible Corporate Officer-- A president, secretary, treasurer orvice-president ofthe corporation in charge ofa principal business function, or any otherperson who performs similarpolicy- or decision-making functions for the corporation, or the manager ofone 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), ifauthority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures (40 CFR 122.22). Significant Industrial User (SIU)

-- 1) All industrial users subjectto Categorical Pretreatment Standards under 40 CFR 403.6 and

40 CFR Chapter I, SubchapterN and; 2) Any other industrial userthat: discharges an average of25,000 gallons per day or more of

process wastewaterto the POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater); contributes a process waste streamthat makes up 5 percent or more of the average dry weather hydraulic or organic capacity ofthe POTWtreatmentplant; or is designated as such bythe Control Authority* onthe basis that the industrial user has a reasonable potential for adversely affecting the POTW's operation or for violating any pretreatment standard or requirement [in accordance with 40 CFR 403.8(±)(6)].Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 52 of 61
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 petitionreceived from an industrial user or POTW, and in accordance with 40 CFR 403.8(±)(6), determine that such industrial user is not a significant industrial user. *The term "Control Authority" refers to the Washington State Department ofEcology in the case ofnon-delegated POTWs or to the POTW in the case ofdelegated POTWs. Slug Discharge

-- Any discharge ofa non-routine, episodic nature, including but not limited to an accidental spill or a non-customary batch discharge to the POTW. This may include any pollutantreleased at a flow rate that may cause interference orpass through withthe POTW or in any way violate the permit conditions or the POTW's regulations and local limits. Soil Scientist

-- Anindividual who is registered as a Certified or Registered Professional Soil Scientist or as a Certified Professional Soil Specialist bythe AmericanRegistry ofCertified Professionals inAgronomy, Crops, and Soils or by the National Society ofConsulting Scientists or who has the

**cn~dentials** for membership. Minimumrequirements for eligibility are: possession ofabaccalaureate, masters, or doctorate degree from a U.S. or Canadian institutionwith a minimum of30 semesterhours or 45 quarter hours professional core courses in agronomy, crops or soils, and have 5,3,or 1years, respectively, ofprofessional experience working inthe area ofagronomy, crops, or soils. Solid Waste

-- Allputrescible and non-putrescible solid and semisolid wastes including, butnot limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, demolition and construction wastes, abandoned vehicles orparts thereof, contaminated soils and contaminated dredged material, and recyclable materials. Soluble BODs-- Determiningthe soluble fraction ofBiochemical Oxygen Demand ofan effluent is an indirect way ofmeasuring the quantity ofsoluble organic material present in an effluentthat is utilizedby bacteria. Althoughthe soluble BODs test is not specifically described in Standard Methods, filtering the raw sample through at least a 1.2 urn filter prior to running the standard BOD5 test is sufficient to remove the particulate organic fraction. State Waters-- Lakes, rivers, ponds, streams, inland waters, underground waters, salt waters and all other surface waters and watercourses withinthejurisdiction ofthe state of Washington. Stormwater

-- That portion ofprecipitationthat does not naturallypercolate into the ground or evaporate, but flows via overland flow, interflow, pipes and other features ofa storm water drainage system into a defined surface water body, or a constructed infiltration facility. Technology-Based Effluent Limit

-- A permit limit based onthe ability ofa treatment method to reduce the pollutant. Total Coliform Bacteria

-- A microbiological test, which detects and enumerates the total coliform group ofbacteria in water samples. Total Dissolved Solids-- That portion oftotal solids in water or wastewater thatpasses through a specific filter.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 53 of 61



### Total Suspended Solids (TSS)

-- Total suspended solids is the particulate material in an effluent. Large quantities ofTSS discharged to a receiving water may result in solids accumulation. Apart from any toxic effects attributable to substances leached out by water, suspended solids may kill fish, shellfish and other aquatic organisms by causing abrasive injuries and by clogging the gills and respiratorypassages ofvarious aquatic fauna. Indirectly, suspended solids can screen out light and canpromote and maintainthe development ofnoxious conditions through oxygen depletion. 

### Upset-- An exceptional incident in which there is unintentional and temporary noncompliance withtechnology-based permit effluent limits because offactors beyond the reasonable control ofthe Permittee. Anupset does not include noncompliance to the extent causedby operational error, improperly designed treatment facilities, lack ofpreventative maintenance, or careless or improper operation. 

### Water Quality-Based EffluentLimit-- A limit imposed on the concentration ofan effluent parameterto prevent the concentration ofthatparameter from exceeding its water quality criterion after discharge into receiving waters.Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 54 of 61 

### Appendix D--Technical Calculations Several ofthe Excel® spreadsheet tools used to evaluate a discharger's ability to meet Washington State water quality standards can be found on Ecology's homepage at http://www.ecy.wa.gov/programs/eap/pwspread/pwspread.html. 

### Calculation ofReceiving Water pH atEdge ofMixing Zone. 

## INPUT

.. 1. DILUTION FACTORAT MIXING ZONE BOUNDARY
2. UPSTREAM/BACKGROUND CHARACTERISTICS Temperature (deg C): pH: Alkalinity (mg CaC03/L):
3. EFFLUENT CHARACTERISTICS Temperature (deg C): pH: Alkalinity (mg CaC03/L):

1. IONIZATION CONSTANTS Upstream/BackgroundpKa: EffluentpKa: 

### OUTPUT

2. IONIZATION FRACTIONS Upstream/Background Ionization Fraction: Effluent Ionization Fraction:
3. TOTAL INORGANIC CARBON Upstream/Background Total Inorganic Carbon (mg CaC03/L): Effluent Total Inorganic Carbon (mg CaC03/L): 4. CONDITIONS ATMIXING ZONE BOUNDARY Temperature (deg C): Alkalinity (mg CaC03/L): Total Inorganic Carbon (mg CaC03/L): pKa: pH at Mixing Zone Boundary: 130.000

25.00

7.50 50.00

20.00

7.30 390.00

6.35 6.38

0.93 0.89

53.54 437.10

24.96 52.62 56.49

6.35
7.48Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 55 of 61

Sonoco Spreadsheet for Calculating Reasonable Potential and Limits for Temperature T-MixFresh is based on WAC 173-201A-200(l)(c)(i)--(ii) and Water Quality Program Guidance. All Data inputs must meet WQ guidelines. T =UpstreamBackground 90th percentile, t = allowable temperature rise The Water Quality temperature guidance document may be found at:


## INPUT.
1. Chronic Dilution Factor at MixingZone Boundary
2. 7DADMax Ambient Temperature (T) (Upstream Background 90thpercentile)
3. 7DADMax Effluent Temperature (95thpercentile)
4. Aquatic Life Temperature WQ Criterion inFresh Water 

### OUTPUT··
5. Temperature at Chronic MixingZone Boundary:
6. Incremental Temperature Increase or decrease:
7. Incremental Temperature Increase 28/(T+7) ifT:::; criteria:
8. MaximumAllowable Temperature at Mixing Zone Boundary:



### · A. If

### ambient temp iswarmerthan W 

### criterion 9. Does temp fall withinthis warmertemp range?
10. Temp increase allowed at mixing zone boundary, if required:



### .JtifalP.J:,ient temp is coolertltanWQcriteriollJ>ltt

### within 28/(T+7)and

### within 0.3

# oc · ··· · ofthe criterion 11. Does temp fall withinthis incremental temp. range?
12. Temp increase allowed at mixing zone boundary, if required: http://www.ecy.wa.gov/bibli o/0610100.html Criteria

130

19.9

## oc
27.8 

## oc
17.5 

## oc

20.0

## oc
0.1 

## oc

20.2

## oc

YES

NO LIMIT Criteria**Septl5~** Jut 1

130

15.5 

## oc
19.0

## oc
17.5 

## oc

15.5 

## oc
0.0

## oc
1.24

## oc

16.7

## oc

NO

NO

# I Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 56 of 61



### C. Ifambient temp 

### is cQoler.thau(WQcriterion-0.3}but 

### within 28/(T+?) 

### ofthe criterion
13. Does temp fall withinthis Incremental temp. range?



### --- 14. Temp increase allowed at mixing zone boundary, if required:



### --- D.. Ifambienttemp is cooler than (WQ criterion

- 28/(T+7)) 

### . 15. Does temp fall withinthis Incremental temp. range?



## --- 16. Temp increase allowed at mixing zone boundary, if required:



### ---
'' . .: 

### .. .:·
.. 

## ..· . :. 17. Do any ofthe above cells show a temp increase? NO

18. Temperature LimitifRequired? NO LIMIT NO



### ---

. 

## T '"· YES NO LIMIT

. 

### NO
NO LIMITFact Sheet for NPDES Permit WA0000884 Sonoco Products Company

Page 57 of 61 This spreadsheet calculates the reasonable potential to exceed state water quality standards for a small number of samples. The procedure and

calculations

are done per the procedure in Technical Support Document for Water Quality-based Toxics Control, U.S. EPA, March, 1991 (EPA/505/2-90-

001)

on page 56. User input columns are shown with red headings. Corrected formulas in col G and H on 5/98 (GB)

State Water concentration
Quality Standard at edge of

...

**~~ ~~**  n > **~** o n n

**~** 0

**~** 0 ::tt:: >

0 0 **~t""** !>) (I) **~** ::r

Q..l>l2 o..gJ2 **~a~** n g ;;;<· n ;;; . **~** 0 '"riO 'Tiel

(I) 0 !>) (I) !>) > Ef N(i) s· Ef t:'j,... >-+, :::: !>) g

0"'- 0"'- "'(l) (I) <;;" s

(I) < "' ;:::;:' !>) 0

§. 5l n §.- n 0 **~** 0 0 §

**~ ,0~**  !>) 0 (I) 0 -·

::l.

..., **~~::t** :::: 0 (fq 0 **e;gEB~** s % co ...... 0

...... ..., ...... 0 N 8. **tS~**

s; g

P:> 0 1--'• p:J 0 -- c

**~d-.** (I) (';" (i) 8: **§:~§**

"g. -. .=..::

_.-.(t ---:ct 0 0 **·~** (I)

!>) ..., !>) ..., 0 0 0 a -. P -· (I) ..., 0-

"' -· en p)" 0 (fq (I) .......__, ('!) r-+ 0 "' 0-

!>) 0.. 0

Parameter Acute Chronic ug/L

**u~L** ug/L ug/L

**u~L** Pn ug/L cv s n

Chlorine (tot res) 1.0 1.0 19.0 11.0 12.0 1.4 NO 0.2 50.0 0.6 0.6 2.0 3.8 15 130

Ammonia as N 1.0 1.0 100.0 18613 1473 195 111 NO 0.8 1040 0.6 0.6 14 1.5 15 130

Che

Copper (total) 1.0 1.0 1.8 4.6 3.5 7.1 2.4 ck 0.4 28.6 0:6 0.6 3.0 3.0 15 130

Copper (total) 1.0 1.0 1.8 4.6 3.5 4.6 2.1 NO 0.8 28.6 0.6 0.6 12 1.6 15 130

Che

Lead (total) 1.0 1.0 0.2 14.0 0.5 6.8 1.0 ck 0.1 16.7 0.6 0.6 1.0 6.2 15 130

Lead (total) 1.0 1.0 0.2 14.0 0.5 2.5 0.5 NO 0.6 16.7 0.6 0.6 6.0 2.1 15 130

Selenium (total) 1.0 1.0 0.1 20.0 5.0 4.0 0.6 NO 0.1 10.0 0.6 0.6 1.0 6.2 15 130

Zinc (total) 1.0 1.0 1.8 35.0 32.0 17.4 3.6 NO 0.1 40.0 0.6 0.6 1.0 6.2 15 130

This spreadsheet calculates the reasonable potential to exceed water quality standards established by WAC 173-201A-240(1) for toxic

substances which have the potential either singularly or cumulatively to adversely affect characteristic water uses, cause acute or

chronic toxicity to the most sensitive biota dependent upon those waters, or adversely affect public health, as determined by

department. (Metals in effluent as total metal).>. c 

### ro 0.. E 0 

### u C/) 

### t5 ::J "'0 

# e D.. 0 u 0 c 0 (/) "¢ co co 0 0 0 0

# ~ :t= E



### .... Q) D.. (/) 

## w 0 D.. 

## z '-...- 

## .E<D

...... 

### ..._ Q) 0 Q)co .CL() C/)Q) 

### t50> ro ro LLD.. Dilution Factor Cone. (When n>lO) Multiplier
W 111\.Al tt ill l-Ul. _I'\._ W a;::, taken

Coeff Variation

cone. measured

EstimatedPercentile at 95% Confidence EFFLUE NT LIMIT EFFLUE NT LIMIT Compliance Samples perMonth LIMIT REQ'D? Max concentration at edge ofchronic

miximr zone. Water Quality Criteria for Protection of Human Health

Revised 3/00 Concentrat ion (Geometri rJl**~** CJ**~** :::!

1::: 0...**~** :::!**~ ~**  0 0 0 0 0**~ ~** **~** 0 0 0 0 (<) (<) (<) (') 

# --
0**~** 0 0\ 0\ 0 0\ '<t**~** 0J**~** C'i N N**~** '-0 '-0**~** 0 00 0
0 0 0 0**~~~** '-0 0 0 0 0

0 0 0 0**~** ....-;**~** 0 0 

# - 00 0 N 01 N

tn If\ t-- If\**~~"':** 0 000 0

0 0 0 0 If) If\ If\ If) 0 0 0 0

### ~~~~ 0000 

## zzzz**~ ~~~**  

## zzzz 0000 

## zzzz

0 0 0 0 0 0 0 00 0 0000 

## zzzz
ooo-0\ '<t'<tON**:::~ooc--io**

0 :::! 0

1-< Q)

..... Q)

# ~**~** 0**~** 1-<

...... <!,) 

### "' <!,) § 0 0 0 0 '-0 0 t-;0

1-< 

## .§ Q) bJ) 0..**~** § §"**~ ~uJS** Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 59 of 61



### Appendix E--Response to Comments The 30-day public commentperiod ran from March 20 and ended April22, 2013. Comments were received from Sonoco and from the interest group called Citizens for a Healthy Bay. Ecology raised the issue ofelectronic data submission after the close ofthe public comment period. Sonoco voluntarily agreed to transition to electronic data submission. This issue is also addressed in this response to comments. The comments are presented below. Ecology's responses to comments are balded and follow eachrespective comment. 

### Sonoco Comments: 1. In Section S.2, the table has no minimum sampling frequency for Cyanide. Sonoco would expect this sampling frequency to be twice perpermit cycle inthe third and fifth year ofthe permit, similar to the other additional specific pollutants. 

### Ecology has defined the cyanide sampling frequency in S2.A as twice perpermit cycle in the third and fifth year.
2. Sonoco requests that the minimum frequency for the fecal coliform sampling reflect the discharge limit in Section S.1 and be required 1daypermonth only during the dry season ofJuly through October. With the additional Fecal Coliform Study required in S.l4., Sonoco will already be sampling the effluent once per week during the critical season of July through October. Allowing these two sampling requirements to coincide will help Sonoco better manage these requirements. 

### Ecology has made the requested change. Thefecal monitoring is now defined in S2.A as lday/month duringJuly through October.
3. Section S3.E.(a). Immediate Reporting Requirements- since the facility uses no disinfection system and there are no drinking water supplies downstream ofSonoco's outfall 001, Sonoco requests this clause to be removed to avoid operator confusion. 

### Ecology has made the requested change. Sonoco does not disinfect the process effluent. Sonoco does not treat and discharge sanitary effluent. Ecology is not aware ofany drinkingwater sources downstream from outfall 001.
4. Section 14- Sonoco request the Fecal Coliform Monitoring Planbe submitted 90 days after the permit is issued. This timing would allow Sonoco the required time to develop a comprehensive sampling plan while still allowing Sonoco to initiate the sampling plan during the dry season. There will be some required research into the appropriate indicator criteria for paper mill effluents to minimize false positive results in order to maintain quality assurance withthe project as well as the development ofa facility wide samplingprogram. Sonoco also request a clause be added that states ifthe monitoringFact Sheet for NPDES Permit WA0000884 Sonoco Products Company Page 60 of61
plan shows Sonoco's effluent to be belowthe waste load allocation, effluent will continue to be monitored per the approved Fecal Coliform Monitoring Plan in Phase1, but Phase 2 ofthe Fecal Coliform Study will not be required. 

### Ecology has adjusted the Fecal Coliform MonitoringPlan submittal date to August 1, 2013. This date adjustment gives Sonoco more time to prepare the planwhile still preserving the possibility ofsampling during the first dry season ofthe permit. Sonoco's request that Phase 2 

### be dropped ifsamplingresults are below the waste load allocation has been granted by defining thewaste load allocation: as the geometric mean ofeach given dry season. Wording triggeringPhase 2 

### ifthe geometric mean ofthe dry season exceeds the waste load allocation has been added to 814.

Citizens for a Healthy Bay Comments: 1. S1. Discharge Limits and Benchmarks. The proposedpermit decreased the allowances for BOD and TSS from the previous permittermto reflect implementation ofWAC 173- 201A-320, which addresses antidegradation. Ecology reintroduced a limit on ammonia, which was derived from the total maximum daily load (TMDL) onthe White River. Ecology added a fecal coliform limitto comply withthe Puyallup River Watershed Fecal Coliform TMDL published and approved in 2011. Citizens for a Healthy Bay applauds Ecology for applying limits which address antidegradation. 

### Ecology Notes Comment 1.
2. CHB contests the general use ofmixing zones as they allow areas where potentially toxic chemicals are allowed to exceed water quality standards. Certain chemicals such as copper maypose long term hazards as theyhave the potential for build up in the sediments. This is a special concern as the treated effluentno longer discharges directly into the river, but into sediments on shore. Has the Department ofEcology considered the potential oftoxic buildup ofheavymetals inthe outfall sediments along the White River? 

### Ecology reviewed the description ofthe outfall to make sureitwas clear thatthe effluentis discharged into the river and not into sediments on shore. Ecology has also reviewed the impactto sediments. Thereis**~o** 

### indication ofsediment buildup in thevicinity ofthe outfall due to the characteristics ofthe sediment itselfcoupled with the seasonal high velocity scouring ofthe river flow. Ecology Notes on WAWeb DMRRequirement: Ecology is transitioning away from physically**man~ging** and storingpaper toward electronic data submittal and management. The boilerplate wording in use when the Sonoco NPDES renewal effortbegan encouraged but did notrequire this transition.Fact Sheet 

### for NPDES Permit WA0000884 Sonoco Products Company Page 61 of 61
Ecology asked Sonoco, after the close ofthe formal public comment period, to voluntarily agree to transition to electronic data submittal. Sonoco stated they did not object to the cunentpermitboilerplate language addressing electronic data submittals. Ecology has incorporated a more cunent version ofPermit Condition S3.A into the reissued permit.