Fact Sheet for NPDES Permit W A0000884 

Purpose of this Fact Sheet 

Sonoco Products Company 

Aoril25, 2013 

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

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

Sonoco Products Company (Sonoco ). 

This fact sheet complies with Section 173-220-060 of the Washington Administrative Code 

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

evaluation before issuing an NPDES permit. 

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

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

Sonoco, NPDES permit W A0000884, 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 Appendix A - Public Involvement Information. 

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 publishing this draft fact sheet for public notice. 

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

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

fact sheet as Appendix E - Response to Comments, and publish it when issuing the final 

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

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

Summary 

The 2013 proposed permit decreases the allowances for BOD and TSS from the previous permit 

term to reflect implementation of WAC 173-201A-320, which addresses antidegradation. 

Ecology retained the daily maximum allowance for BOD because it is based on the 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 of the permit or fact sheet simply reflect changes in the underlying boilerplate 

format that Ecology uses. 
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Table of Contents 

I. JnfrOdlLCfiOn oooooooooooo oooooooooooooooooooooooeoooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooo ••••oooooo 4 

II. Background Inforntation .................................... ., .................................................. 6 

A. Facility Description ........................................... · .................................................... 7 

Histoty ................................................................................................................................. 7 

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

Wastewater Treatment Processes ........................................................................................ 8 

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

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

B. Description of the Receiving Water ..................................................................... 9 

c. Wastewater Characterization ...... ~ ..................................................................... 10 

D. Summary of Noncompliance with Previous Permit (2007-2012) .................... 11 

E. State Environmental Policy Act (SEP A) Compliance ..................................... 12 

III. Proposed Permit Limits ........................................................................................ J2 

A. Design Criteria .................................................................................................... 13 

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

c. Surface Water Quality- Based Effluent Limits .................................. , ............ 16 

Numerical Criteria for the Protection of Aquatic Life and Recreation ............................. 16 

Numerical Criteria for the Protection of Human Health ................................................... 17 

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

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

Mixing Zones .................................................................................................................... 19 

D. Designated Uses and Surface Water Quality Criteria ..................................... 24 

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

F. Evaluation of Water Quality-Based Effluent Limits 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 of Effluent Limits with the Previous Permit Issued on May 9, 

2007 ....................................................................................................................... 36 

v. Monitoring Requirements .................................................................................... 37 

A. Lab Accreditation ............................................................................................... 38 

B. Effluent Limits Which are Near Detection or Quantitation Levels ............... 38 

VI. Other Permit Conditions ...................................................................................... 39 
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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 

Best Management Practices (BMPs) ................................................................................. 40 

Ecology-Approved Stormwater Management 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 

Permit Issuance Procedures ................................................................................ 42 

Permit Modifications .......................................................................................... 42 

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

References for Test and Appendices ................................................................... 42 

Appendix A--Public Involvement Information ........................................................ ~ .................. 44 

Appendix B--Y our Riglzt to Appeal ............................................................................................. 45 

Appendix C--Glossary .................................................................................................................. 46 

Appendix D--Teclznical Calculations .......................................................................................... 54 

Appendix E--Response to Comments .......................................................................................... 59 

Table 1. General Facility Information ....................................................................................... 6 

Table 2. Ambient Background Data ........................................................................................... 9 

Table 3. Process Wastewater Characterization Outfall 001 .................................................. 10 

Table 4. Stormwater Characterization Outfall 004 (Sampling Event on 2/2/2012) ............. 11 

Table 5~ Summary of Noncompliance with Previous Permit (2007-2012) ............................ 11 

Table 6. Summary of Allowances Where Different from Previous Permit Term ............... 13 

Table 7. Design Criteria for Wastewater Treatment System ................................................ 13 

Table 8. Technology-Based Limits- Based on 40 CFR Subpart E ....................................... 15 

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

Table 10. Previous Permit Term Limit Allowances Compared to 2003 Base Year ............. 18 
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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 of Sonoco 2010 Fecal Coliform Study28 

Table 17. Summarized Historical WET Results ..................................................................... 34 

Table 18. Comparison of Previous and Proposed Effluent Limits ........................................ 36 

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

Figure 2. Dilution Necessary to Meet Criteria at Edge of Mixing Zone ............................... 32 

I. Introduction 

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

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

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

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

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

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

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

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

Code of Washington). 

The following regulations apply to 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 effluent toxicity testing and limits (chapter 173-205 WAC) 

• Sediment management standards (chapter 173-204 WAC) 

• Submission of plans and reports for construction ofwastewater facilities (chapter 173-240 

WAC) 

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

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

discharge and for performance requirements imposed by the permit. 

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

application, Ecology must prepare a draft permit and accompanying fact sheet, and make them 
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available for public review before final issuance. Ecology must also publish an announcement 

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

comments, during a period of thirty days (WAC 173-220-050). (See Appendix A-Public 

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

After the public comment period ends, Ecology may make changes to the draft NPDES pe1mit in 

response to comment(s). Ecology will summarize the responses to comments and any changes to 

the permit in Appendix E. 

Figure 1. Sonoco Site Map 
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II. Background Information 

Table 1. General Facility Information 

I Facility Information 

I A nnlicant: Sonoco Products Company i i 

I Facility Name 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 A venue Sumner W A 

98390 

Telephone #253 863 6366 

• Industry Type Recycled Paperboard Manufacturing 

Categorical Industry 40 CFR Part 430.52 and 430.55 

Type of Treatment 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 of Previous Permit June 1, 2007 

Application for Permit Renewal Submittal January 11, 2012 
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Permit Status 

Date 

Date of Ecology Acceptance of Application May 3, 2012 

Inspection Status 

Date of Last Sampling Inspection August 30, 2012 

Date of Last Non-sampling Inspection Date October 31, 2012 

A. Facility Description 

History 

The mill is located in Sumner, Washington adjacent to the White River. The mill was 

constructed by Northern 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 

paperboard produced is used in the pulp and paper industry as core material for paper rolls. 

Industrial Processes 

Secondary wood fiber in the form of various grades of wastepaper 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 suspension using 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 of the paper machine where a pulp mat is formed and combined into as many 

eight layers using wire covered cylinder vat formers. From this point in the process, a 

continuous web approximately 94 inches wide is further processed by pressing, drying, and 

calendaring, and is then wound onto a reel which is the intermediate product. 

Occasionally, minor amounts of sizing agents, colors, wet strength resins, defoamers, 

slimicides, starch, and alum (for pH adjustment) are added at various points in the process to 

impart specific characteristics to the sheet based on customer requirements and 

specifications. 

In the forming section of the cylinder machine, water is removed from the fiber under 

controlled conditions, leaving a mat of fiber at approximately 15% solids (by weight) which 

is supported by a fabric called a "felt" and carried forward to the press section where all the 

remaining free water is removed leaving a mat of fiber at approximately 45% solids (by 

weight). The balance of water (down to 6% moisture) is removed in the dryer section using 
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heat energy to release the water through evaporation. The web of dried paperboard is then 

calendared on both surfaces, densified, and given a smooth finish, prior to packaging. 

Since wet end forming takes place at very low consistencies (0.5% solids), large volumes of 

water are removed in the forming section and pressing operations. Sonoco collects and 

reuses this process wastewater commonly refened to as white water. Before reuse, it must 

treat a portion of this wastewater in a primary settling clarifier to remove some of the 

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 of the raw material and the clarified water is reused for various showers 

and other processes. Excess water from this system is then pumped to the aeration pond for 

biological treatment as required under NPDES permit W A0000884, and then on to a 

secondary settling clarifier to remove any remaining solids and solids generated in the 

treatment process prior to discharge. 

Wastewater Treatment Processes 

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 

wastewater treatment systems were built in 1972. The treatment system consists of primary 

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 permit terin 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 

based the limits in the current 2007 permit on an average production of 120 tons/day. The 

company raw stock consisted of75 percent conugated and 25 percent non-corrugated waste 

paper. The company indicated that it plans to continue using the same percentage of raw 

materials for the foreseeable future. 

Solid Wastes 

The facility submitted its most recent revision ofthe Solid Waste Control Plan to Ecology in 

March 2008. The majority of the solid waste generated on-site consists ofpulper rejects 

(paper, plastic, wire). Approximately 126 tons per month of solid waste is generated at the 

Sumner facility and disposed of in the Hidden Valley Landfill. Settled solids generated in 

the primary clarifier are returned to the papermaking process. Sludges collected in the 

secondary clarifier are split between the activated sludge aeration basin and paper making 

process. 

Discharge Outfalls 

The mill's discharge point is to the White River (Outfall 001) about 30 feet upstream ofFryar 

A venue Bridge, at mile marker 1.4. The outfall line extends 10 feet from the south shoreline 
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and ends with a diffuser under the water surface. The effluent is discharged via an 18-foot 

long, seven port diffuser, with a port height of 1 foot above the river bed. The outfall is a 10-

inch pipe designed with seven 3-inch diameter riser pmis spaced at 36-inch centers 

configured to discharge in the direction of river 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 

water to the northwest corner of the facility before discharging to land. There is a shallow 

weir made of rocks and sufficient flow can result in overflow of the weir. This overflow ties 

back in to 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 

water to 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 of the Receiving Water 

I 

Sonoco discharges to the White River with the designated uses of salmonid spawning, 

rearing and migration habitat and primary contact recreation at the point of discharge. Other 

nearby point source outfalls covered under the Industrial Stormwater General Petmit include 

Exide Technologies Sumner, Pasquier Panel Products Inc Sumner, Pacific Northwest Baking 

Co, McConkey & Co Inc, Golden State Foods, Sumner Cedar, Precision Aerospace & 

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 any receiving waterbody impairments. 

The ambient background data used for this permit includes the following from Sonoco' s 

permit renewal 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/L 
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n Value Used 

Total Ammonia-N (Critical AnnualS %tile) 0.14 mg/L 

Fecal Coliform 46/1 00 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 of pollutants in the discharge in the permit application and 

in discharge monitoring reports. The tabulated data represents the quality of the 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 1.39 
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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 (Sampling Event 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 of Noncompliance with Previous Permit (2007-2012) 

Table 5. Summary of Noncompliance with Previous Permit (2007-2012) 

Exceedance Statistical Exceedance Permit 

Date Parameter Base Units Value Limit 

Single 

6/30/2011 TSS Sample Lbs/day 1637 <1487 
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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 self reported 1.34 Lbs/day discharged on 9/29/2010 and 1.3 

Lbs/day discharged on 11/24/2010. 

E. State Environmental Policy Act (SEP A) Compliance 

State law exempts reissuance or modification of any wastewater discharge permit from the 

SEP A process as long as the permit contains conditions are no less stringent than federal and 

state rules and regulations (RCW 43.21C.0383). The exemption applies only to existing 

discharges, not to new discharges. 

III. Proposed Permit Limits 

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

technology- or water quality-based. 

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

pollutants. Technology-based limits are set by the EPA and published as a regulation, or 

Ecology develops the limit on a case-by-case basis ( 40 CFR 125.3, and chapter 

173-220 WAC). 

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

Water Quality Standards (chapter 173-201A WAC), Ground Water Standards (chapter 

173-200 WAC), Sediment Quality Standards (chapter 173-204 WAC), or the National Toxics 

Rule ( 40 CFR 131.36). 

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

limits are described below. 

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

reports (engineering, hydrogeology, etc.). Ecology evaluated the permit application and 

· determined the limits needed to comply with the rules adopted by the state of Washington. 

Ecology does not develop effluent limits for all reported pollutants. Some pollutants are not 

treatable at the concentrations reported, are not controllable at the source, are not listed in 

regulation, and do not have a reasonable potential to cause a water quality violation. 

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

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

pollutants. During the five-year permit term, the facility's effluent discharge conditions may 

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

if significant changes occur in any constituent [40 CFR 122.42(a)]. Until Ecology modifies the 
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permit to reflect additional discharge of pollutants, a permitted facility could be violating its 

permit. 

The table below summarizes the proposed allowances for the 20 13 pe1mit renewal, where 

changes from the previous pe1mit are proposed, and shows the comparison to the previous permit 

term allowances. The explanations for the derivations of the allowances are found throughout 

the fact sheet under the relevant headings. The BOD daily maximum allowance is set through 

the TMDL process. The remaining BOD and TSS allowances have been increased by no 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 of Allowances Where Different from Previous Permit Term 

.BOD BOD Daily TSS TSS Daily 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 wastewater treatment plant at this facility. Sonoco's system was 

installed before the design criteria requirements were promulgated, however based on the 

original design criteria and results from the last 39 years of operation, Sonoco agrees with the 

following influent waste loadings: 

Table 7. Design Criteria for Wastewater Treatment System 

Parameter Design Quantity 

Daily Maximum Flow to Aeration Basin 0.600 MGD* 
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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 in the original design and cunent monthly average 

effluent limit of 529 pounds/day. 

B. Technology - Based Effluent Limits 

Technology-based limitations are set by regulations or developed on a case by case basis. 

The federal effluent guidelines for practicable control technically available (BPT) is defined 

in Parts 430.52 and 430.55 Subpart E for paperboard from wastepaper subcategory. The 

Environmental Protection Agency (EPA) published these guidelines in the 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 BPT previously defined in March 1983. BCT and BPT 

were defined more than ten years ago. With BCT and BPT being defined longer than ten 

years, Ecology must determine if they are still valid and if it can still consider them 

equivalent to all known and reasonable treatment (AKART) for these categories of paper 

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 in pound per 1000 pound of pulp produced for the above categories were set at the same 

values as the allowances in the effluent guidelines the EPA published in 1982. The 1998 

effluent guidelines took both emissions to air and water into consideration and included 

chlorinated organic compounds. Secondary treatment was the type of wastewater treatment 

required by the effluent guidelines adopted by EPA. 

Throughout the history of the effluent guidelines, secondary treatment has been the accepted 

standard for BOD and TSS removal. It is expected that in the immediate future this trend 

will continue as indicated by the guideline promulgated on April15, 1998. Ecology 

therefore determines that the effluent guidelines for paperboard made from both corrugated 

and non-corrugated wastepaper are equivalent to AKART for the following reasons: 

• The mill has historically generated wastewater from two components of raw 

wastepaper - corrugated and non-corrugated. 

• EPA did not make any changes in the 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. 
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• All permits except those of paper 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 CPR 430.52 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 production prior to 1982 averaged 61 tons per day. Ecology used 40 CPR 430.52 

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 CPR 430.55 and the 

81 tons of production above the historical average of 61 tons per day to calculate technologybased limits for the production increases after 1982. The company indicated the raw furnish 

consisted of75 percent corrugated and 25 percent non-corrugated. The breakout of 

production types and effluents guidelines numbers are given below: 

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 

N oncorrugated 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 4.4 
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Type Maximum Production Monthly Daily Monthly 

Monthly (2010 to Average Maximum Average Production Present) 

Tons paper 1000 lbs Lbs. Lbs. BOD Lbs. 

per day paper per 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. Potential Technology- Based Allowances 

Daily 

Maximum 

Lbs. TSS 

per 

1000 lbs 

paper 

3.5 

BOD Monthly Average BOD Daily TSS Monthly TSS Daily Maximum 

Maximum Average 

614 Lbs./day 1192 Lbs./day 850 Lbs./day 1671 Lbs./day 

However, other factors can come into play when deriving facility specific allowances and 

this is the case for Sonoco where both TMDL and Tier II considerations influence mass 

loading allowances. 

C. Surface Water 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 of Washington's 

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

will meet the surface water quality standards (WAC 173-201A-510). Water quality-based 

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

allocation developed during a basin wide total maximum daily load study (TMDL). 

Numerical Criteria for the Protection of Aquatic 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 of pollutants allowed in 

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

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

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

limits are more stringent or potentially more stringent than technology-based limits, the 

discharge must meet the water quality-based limits. 
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Numerical Criteria for the Protection of Human Health 

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

health that 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 criteria to 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 below those 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 criteria protect the specific designated uses of all fresh waters 

(WAC 173-201A-200, 2006) and of all marine waters (WAC 173-201A-210, 2006) in the 

state of Washington. 

Antidegradation 

Description--The purpose of Washington's Antidegradation Policy 

(WAC 173-201A-300-330; 2006) is to: 

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

• Describe situations under which water quality rimy be lowered from its current 

condition. 

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

surface water. 

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

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

and treatment (AKART). 

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

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

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

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

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

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

and applies to all sources of pollution. 

Facility Specific Requirements--This facility must meet Tier I requirements. 
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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 with the water quality standards. 

• Whenever the natural conditions of a water body are of a lower quality than the 

assigned criteria, the natural conditions constitute the water quality criteria. Where 

water quality criteria are not met because of natural conditions, human actions are not 

allowed to further lower the water quality, except where explicitly allowed in chapter 

173-201A WAC. 

The overall terms and conditions of this permit are designed to collectively achieve Tier I 

requirements. 

A facility must prepare a Tier II analysis when all three of the 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 of a chronic mixing zone. 

Ecology defined "expanded action" in the Water Quality Program Guidance Manual 

publication no. 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 with the current Ecology practice of 

applying new source performance standards to dischargers who increase production by more 

than 10%. Where a permit limit is not based 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 implement the 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 

term 
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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 on the TSS mass loading increase greater than 

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 in the receiving water surrounding the discharge port(s), 

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

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

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

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

mixing zones must meet water quality numeric standards. 

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

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

sizes to limit the amount of time any exposure to the end-of-pipe discharge could harm water 

quality, plants, or fish. 

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

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

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

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

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

water body for dilution [WAC 173-201A-400 (7)(a)(ii-iii)]. 

Ecology uses modeling to estimate the amount of mixing within the mixing zone. Through 

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

edge of the 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's Permit Writer's Manua[). Each 
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critical condition parameter, by itself, has a low probability of occunence 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 of mixing of effluent and receiving water that occurs at 

the boundary of the mixing zone. For example, a dilution factor of 1 0 means the effluent is 

10% and the receiving water is 90% of the total volume of water at the boundary of the 

mixing zone. Ecology uses dilution factors with the water quality criteria to calculate 

reasonable potentials and effluent limits. Water quality standards 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 of pollutants at the boundaries of any of these 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 exposed to 

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

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

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

years. 

The two types of human health-based water quality criteria distinguish between those 

pollutants linked to non-cancer effects (non-carcinogenic) and those linked to cancer effects 

(carcinogenic). The human health-based water quality criteria incorporate several exposure 

and risk assumptions. These assumptions include: 

• A 70-year lifetime of daily exposures . 

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

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

A one-in-one-million cancer risk for carcinogenic chemicals. 

This permit authorizes. a small acute mixing zone, sunounded by a chronic mixing zone 

around the point of discharge (WAC 173-201A-400). The water quality standards impose 

certain conditions before allowing the discharger a mixing zone: 

1. Ecology Must Specify Both the Allowed Size and Location in a Permit. 

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

specified below). 

2. The Facility Must Fully Apply "All Known, Available, and Reasonable Methods of 

Prevention, Control and Treatment" (AKART) to its Discharge. 

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

AKART (see "Technology-based Limits"). 

3. Ecology Must Consider Critical Discharge Conditions. 

Surface water quality-based limits are derived for the water body's critical condition (the 

receiving water and waste discharge condition with the highest potential for adverse 
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impact on the aquatic biota, human health, and existing or designated waterbody uses). 

The critical discharge condition is often pollutant-specific or waterbody-specific. 

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

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

density stratification in the water column, the currents, and the rate of discharge. Density 

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

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

stratification is generally greatest during the summer months. Density stratification 

affects how far up in the water column a freshwater plume may rise. The rate of mixing 

is greatest when 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 when there is little or no stratification. Ecology's Permit 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/921 09 .html. 

Table 11. Critical Conditions Used to Model the Discharge 

Critical Condition Value 

The seven-day-average low river flow with a recurrence interval often 179 cfs 

years (7Q10) 

River depth at the 7Q 10 period 3.5 feet 

River velocity 0.55 ft per second 

Manning roughness 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 MAX Effluent temperature 25 degrees C 

4. Supporting Information Must Clearly Indicate the Mixing Zone Would Not: 

• Have a reasonable potential to cause the loss of sensitive or important habitat. 
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• Substantially interfere with the existing or characteristic uses. 

" Result in damage to the ecosystem. 

• Adversely affect public health. 

Ecology established Washington State water quality criteria for toxic chemicals using 

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

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

commercially and recreationally important species. 

EPA sets acute criteria for toxic chemicals assuming organisms are exposed to the 

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

organisms are exposed to the pollutant at the criteria concentration for four days. 

Dilution modeling under critical conditions generally shows that both acute and chronic 

criteria concentrations are reached within minutes of discharge. 

The discharge plume does not impact drifting and non-strong swimming organisms 

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

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

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

organisms (bottom dwellers) because the buoyant plume rises in the water column. 

Ecology has additionally determined that the effluent will not exceed 33 degrees C for 

more than two seconds after discharge; and that the temperature of the water will not 

create lethal conditions or blockages to fish migration. 

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

whole effluent toxicity (WET) testing. 

Ecology reviewed the above information, the specific information on the characteristics 

of the 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 of sensitive 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 of a Mixing Zone. 

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

EPA and by Ecology, for each pollutant and concluded the discharge/receiving water 

mixture will not violate water quality criteria outside the boundary of the mixing zone if 

permit limits are met. 

6. The Size of the Mixing Zone and the Concentrations of the Pollutants Must be 

Minimized. 

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

zone, which minimizes the volume of water involved in mixing. The plume mixes as it 

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

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

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

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

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

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

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

Ecology uses the expected 95th percentile pollutant concentration, the 90th percentile 

background concentration, the centerline dilution factor, and the lowest flow occurring 

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

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

zone authorized in the proposed permit. 

7. Maximum Size of Mixing Zone. 

The authorized mixing zone does not exceed the maximum size restriction and is smaller 

than the size restrictions due to the use of the 2.5% of the 7Q10 river flow restriction. 

8. Acute Mixing Zone. 

• The Discharge/Receiving Water Mixture Must Comply with Acute Criteria as 

Near to the Point of Discharge as Practicably Attainable. 

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

the chronic mixing zone at the ten year low flow as it will be met after mixing with 

just 2.5% ofthe 7Q10 river flow. 

• The Pollutant Concentration, Duration, and Frequency of Exposure to the 

Discharge Will Not Create a Barrier to Migration or Translocation of 

Indigenous Organisms to a Degree that has the Potential to Cause Damage to the 

Ecosystem. 

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

pollutant concentration, and the time the organism is exposed to that concentration. 

Authorizing a limited acute mixing zone for this discharge assures that it will not 

create a barrier to migration. The effluent from this discharge will rise as it enters the 

receiving water, assuring that the rising effluent will not cause translocation of 

indigenous organisms near the point of discharge (below the rising effluent). 

• Comply with Size Restrictions. 

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

published in chapter 173-201A WAC. 

9. Overlap of Mixing Zones. 

This mixing zone does not overlap another mixing zone. 
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D. Designated Uses and Surface Water Quality Criteria 

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

173-201A WAC. In addition, the U.S. EPA set human health criteria for toxic pollutants 

(EPA 1992). The table included below summarizes the criteria applicable to this facility's 

discharge. 

Aquatic Life Uses are designated based on the presence of, or the intent to provide protection 

for the key uses. All indigenous fish and non-fish aquatic species must be protected in 

waters of the state in addition to the key species. The Aquatic Life Uses for this receiving 

water are identified below. 

Table 12. Aquatic Life Uses and Associated Criteria 

Salmonid Spawning, Rearing, and Migration 

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 • 5 NTU over background when the 

background is 50 NTU or less; or 

• A 10 percent increase in turbidity when 

the background turbidity is more than 50 

NTU. 

Total Dissolved Gas Criteria Total dissolved gas must not exceed 110 

percent of saturation at any point of sample 

collection. 

pH Criteria The pH must measure within the range of 6.5 

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 

Recreational Use ~eria 

Primary Contact Fecal coliform organism levels must not exceed a geometric mean value 

Recreation of 100 colonies 1100 mL, with not more than 1 0 percent of all samples 

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

for calculating the geometric mean value exceeding 200 colonies 1100 

mL. 

• The water supply uses are domestic, agricultural, industrial, and stock watering. 
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• The miscellaneous freshwater uses are wildlife habitat, harvesting, commerce and 

navigation, boating, and aesthetics. 

E. Water Quality Impairments 

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 in the TMDL. Ecology set the WLA for the 

daily maximum for BOD at 673 lbs./day in the TMDL. Ecology placed these WLA values in 

the NPDES permit issued September 25, 2001. These values are included in this permit 

renewal. 

The WLA allocation protects the designated classification of the White River in the vicinity 

of Sonoco' s outfall. These WLA allocations are placed in the proposed permit. The WLA 

from the TMDL contained in the proposed permit ensure that the receiving water is 

protected. The limits contained from the TMDL further ensure that the water quality criteria 

of the receiving water are equal to or above the designations and not degraded. 

In June of2011, Ecology published the Puyallup River Watershed Fecal Coliform Total 

Maximum Daily Load report. The TMDL includes a waste load allocation (WLA) for Sonoco 

which is tabulated below. EPA approved the TMDL in 2011. 

Table 14. Fecal Coliform TMDL Wasteload Allocation 

Wastewater Geomean Less than 10% of the samples greater 

Treatment Plant Limit than 

Sonoco Products 100cfu/100 200cfu/1 OOmL 

mL 

The proposed permit includes a best management practices (BMP) approach to achieve a 

source reduction in fecal coliform contribution to 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 in terms of"numbers of bacteria per day" is 

awkward and challenging to understand. The overall approach is to achieve FC reduction 

from all sources. The goal of the Puyallup River watershed FC TMDL is to reduce FC 

concentrations within the study area to water quality standards by 2022 (page xiii of TMDL 

executive summary). The TMDL repmi goes on to address Sonoco Products directly in the 

following excerpt: 

Within the study area, Sonoco Products is the only industrial facility that discharges 

treated industrial process water to surface waters. In a 2010 study, the facility found 

high concentrations of fecal indicator bacteria (fecal coliform and Escherichia coli) in 

their treated effluent, which discharges to the White River (Sonoco, 2011). Although the 

facility discharges a very small amount of effluent (approximately 0.15 MGD) and a 

relatively small FC load, the concentrations of FC were above water quality standards. 

Given that the White River does not currently meet FC standards in the receiving water 
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segment, there is no additional loading capacity, and Sonoco effluent must meet the 

surface water quality standards at the point of discharge. 

This permit cycle establishes a 5-year compliance schedule for bringing mill effluent into 

compliance with the water quality standards for fecal coliform. 

F. Evaluation of Water Quality-Based Effluent Limits for Numeric Criteria 

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

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

pollutants, for example, are near-field pollutants; their adverse effects diminish rapidly with 

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

(BOD) is a far-field pollutant whose adverse effect occurs away from the discharge even 

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

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

With technology-b~sed controls (AKART), predicted pollutant concentrations in the 

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

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

on mixing zones by chapter 173-201A WAC. 

The outfall was visually inspected in December 2011. The original outfall consisted of seven 

ports. Sloughing in the stream banl<: has resulted in the current 4 functional port outfall 

configuration. The 4-port configuration was evaluated for compliance with applicable water 

quality standards. 

The functional portion of the diffuser at Outfall 001 is 9 feet long with a diameter of 10 

inches. The diffuser has a total of 4 three inch diameter ports. 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 on November 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 greater than 300 feet plus the depth of water 

over the discharge ports or extend upstream for a distance of over 100 feet, not utilize greater 

than 25% of the flow, and not occupy greater than 25% of the width of the water body. 

The horizontal distance ofthe chronic mixing zone is 302.5 feet from the diffuser. The 

mixing zone extends from the top of the discharge ports to the water surface. 

The flow volume restriction resulted in a smaller chronic dilution factor than the distance 

downstream. The chronic dilution factors shown below result from the volume restriction. 

Acute Mixing Zone 

WAC 173-201A-400(8)(a) specifies that in rivers and streams a zone where acute toxics 

criteria may be exceeded must not extend beyond 10% of the distance towards the upstream 
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and downstream boundaries of the chronic zone, not use greater than 2.5% of the flow and 

not occupy greater than 25% of the width of the 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 of dissolved oxygen deficiency, pH, fecal coliform, 

ammonia, metals, and temperature as described below, using the dilution factors in the above 

table. The derivation of surface water quality-based limits also takes into account the 

variability of pollutant concentrations in both the effluent and the receiving water. 

Dissolved Oxygen--BODs and Ammonia Effects--Natural decomposition of organic 

material in wastewater effluent impacts dissolved oxygen in the receiving water at distances 

far outside of the regulated mixing zone. The 5-day Biochemical Oxygen Demand (BODs) 

of an effluent sample indicates the amount of biodegradable material in the wastewater and 

estimates the magnitude of oxygen consumption, the wastewater will generate in the receiving 

water. The amount of ammonia-based nitrogen in the wastewater also provides an indication 

of oxygen 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 ammonia derived 

from completed TMDL. 

pH-- The previous permit required the Permittee to perform a two year study on the 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 of June through 

October. The average upstream pH was 7.45 in 2002 and 7.25 in 2006. The average 

downstream pH was 7.39 in 2002 and 7.18 in 2006. 

Ecology modeled the impact of the effluent pH on the receiving water using the calculations 

from EPA, 1988, and the chronic dilution factor tabulated above. Appendix D includes the 

model results. 

Ecology predicts no violation of the pH criteria under critical conditions. Therefore, the 

proposed permit 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 indicated that ten 

percent of fecal coliform values were greater than 200 colonies/1 00 mL. The data indicated 
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that the White River is of lower water quality than the criteria assigned. These data for 

Sonoco's effluent showed that several tests measured fecal coliform counts greater than 1600 

colonies/1 00 mL. 

Ecology received the results of the fecal coliform study on February 1, 2011. The purpose of 

the study was to determine if fecal coliform counts in the mill effluent will cause a violation 

of the water quality criteria at the edge of the chronic mixing zone and if the 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 maintain the fecal coliform 

Water Quality Standard and Sonoco's Waste Water discharge has occasionally tested high in 

fecal coliform. Confusing this issue is that fecal coliform in an indicator bacterium and not 

necessarily an indication of a hazard. There are non-harmful bacteria such as klebsiella 

associated with paper manufacturing that will test as fecal coliform. Ecology recognizes this 

issue with paper mill effluents so it allows alternative indicator criteria to be used. The water 

quality criteria for fecal coliform bacteria is that it shall not exceed a geometric mean of 100 

cfu/1 OOmL, and not more than 10% of all samples exceed 200 cfu/1 00 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 of Sonoco 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 Implementation Plan 

(Publication No. 11-1 0-040). The White River is a tributary to the Puyallup River. The 

federal Clean Water Act requires that a total maximum daily load (TMDL) be developed for 

each of the water bodies on the state's 303(d) list of polluted waters. The White River has 

experienced fecal coliform (FC) levels higher than the allowed standards for freshwater 

streams. The TMDL identifies pollution problems in the watershed, and then specifies how 

much pollution needs to be reduced or eliminated to achieve clean water. The goal of the 

Puyallup River watershed fecal coliform TMDL is to reduce FC concentrations within the 

watershed to water quality standards by 2022. One of the key action items from each 

effluent contributor is to determine the sources of the pollution to reach the load reductions 

for nonpoint sources. 

Ecology is choosing a BMP and compliance schedule approach for Sonoco to achieve better 

site management of their fecal coliform contribution to the White River. The TMDL 

establishes an overall watershed interim target of 50% reduction from source contributors 
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achieved by 2017. This approach is consistent with the TMDL implementation concerning 

municipal stmmwater discharges. The TMDL summarizes this philosophy as follows: 

Ecology recognizes the difficulty of characterizing the highly variable frequency and 

duration of FC loads in stormwater. Numeric effluent limits for municipal stormwater 

discharges tht are consistent with TMDLs are not often feasible or appropriate when 

expressing waste load allocations in municipal stormwater permits. Ecology intends to 

express the numeric municipal stormwater wasteload allocations, from this TJ"I.1DL, as 

best management practices (BMPs) that will be considered for inclusion in the municipal 

stormwater permits. BMPs are considered an appropriate from of effluent limits in 

permits for control of pollutants in municipal stormwater. 

Ecology is requiring Sonoco to renew their efforts to identify the sources of fecal coliform in 

outfall 001 and to achieve significant reduction in effluent FC by the end of the permit term 

addressed by this fact sheet. 

Turbidity--Ecology evaluated the impact of turbidity based on the range of turbidity in the 

effluent and turbidity of the receiving water. Based on visual observation of the facility's 

effluent, Ecology expects no violations of the turbidity criteria outside the designated mixing 

zone. 

Toxic Pollutants--Federal regulations (40 CFR 122.44) require Ecology to place limits in 

NPDES permits on toxic chemicals in an effluent whenever there is a reasonable potential for 

those chemicals to exceed the surface water quality criteria. Ecology does not exempt 

facilities with technology-based effluent limits from meeting the surface water quality 

standards. 

The following toxic pollutants are present in the discharge: chlorine, ammonia, and specific 

heavy metals. Ecology conducted a reasonable potential analysis (See Appendix D) on these 

parameters to determine whether it would require effluent limits in this permit. The presence 

of the metals lead and copper initially indicate a potential for water quality exceedance but 

this seems to be a function of the statistical variability associated with the sample size. 

Appendix D shows that an increased sample size reduces the assumed variability to the point 

where the spreadsheet indicates there would not be a reasonable potential for lead and copper 

to exceed the water quality criteria. The potential to exceed water quality criteria was noted 

during the 2007-2012 permit term and Sonoco was required to evaluate whether mill effluent 

had a reasonable potential to exceed water quality criteria. The results of the study were 

submitted on February 12, 2009. Sonoco sampled the White River both upstream and 

downstream from the mill's discharge outfall. The results were compared to water quality 

criteria. The study strongly suggests that suspended solids in the White River contribute to 

elevated ambient concentrations of metals during heavy river flows. 

Ammonia's toxicity depends on that portion which is available in the unionized form. The 

amount of unionized ammonia depends on the temperature and pH in the receiving 

freshwater. To evaluate ammonia toxicity, Ecology used the available receiving water 

information for ambient station 1 OC070 and Ecology spreadsheet tools. 
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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 of water 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 of this permit. 

Temperature--The state temperature standards (WAC 173-201A-200-210 and 600-612) 

include multiple elements: 

• Annual summer maximum threshold 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 body has 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 of aquatic life by controlling the effect of human actions on summer temperatures. 

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 of the chronic mixing zone. Criteria for most fresh 

waters are expressed as the highest 7-Day average of daily maximum temperature (7-

DADMax). The 7-DADMax temperature is the arithmetic average of seven consecutive 

measures of daily maximum temperatures. Criteria for marine waters and some fresh waters 

are expressed as the highest 1-Day annual maximum temperature (1-DMax). 

• Incremental wmming criteria 

The water quality standards limit the amount of wmming 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 of the chronic mixing zone. 

At locations and times when background temperatures are cooler than the assigned threshold 

criterion, point sources are permitted to warm the water by only a defined increment. These 

increments are permitted only to the extent doing so does not cause temperatures to exceed 

either the annual maximum or supplemental spawning criteria. 

At locations and times when a threshold criterion is being exceeded due to natural conditions, 

all human sources, considered cumulatively, must not warm the water more than 0.3°C above 

the naturally warm condition. 
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When Ecology has not yet completed a TMDL, our policy allows each point source to warm 

water at the edge of the chronic mixing zone by 0.3°C. This is true regardless of the 

background temperature and even if doing so would cause the temperature at the edge of a 

standard mixing zone to exceed the numeric threshold criteria. Allowing a 0.3°C warming 

for each point source is reasonable and protective where the dilutiol) factor is based on 25% 

or less of the critical flow. This is because the fully mixed effect on temperature will only be 

a fraction of the 0.3°C cumulative allowance (0.075°C or less) for all human sources 

combined. 

• Protections for temperature acute effects 

Instantaneous lethality to passing fish: The upper 99th percentile daily maximum effluent 

temperature must not exceed 33°C, unless a dilution analysis indicates ambient temperatures 

will not exceed 33°C two seconds after discharge. 

General lethality and migration blockage: Measurable (0.3°C) increases in temperature at the 

edge of a chronic mixing zone are not allowed when the receiving water temperature exceeds 

either a lDMax of23°C or a 7DADMax of22°C. 

Lethality to 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 on temperature as required by the current permit. 

Ecology reviewed existing records and found that the White River at the point of Sonoco's 

discharge is below the water quality classification for temperature during a small time frame 

in the 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 summer maximum, the supplementary spawning criterion, and the incremental 

warming criteria at the edge of the chronic mixing zone during critical condition(s). No 

reasonable potential exists to exceed the temperature criterion where: 

(Criterion+ 0.3) > [Criterion+ (Teffluent95- Criterion)/DF]. 

The figure below graphically portrays the above equation and shows the conditions when a 

permit limit will apply. 
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Figure 2. Dilution Necessary to Meet Criteria at Edge of Mixing Zone 

a= Calculation based on: 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 permit requires 

additional monitoring of effluent and ambient temperatures. Ecology will reevaluate the 

reasonable potential during the next permit renewal. Ecology included the temperature 

calculations in Appendix D. 

G. Human Health 

Washington's water quality standards include 91 numeric human health-based criteria that 

Ecology must consider when writing NPDES permits. These criteria were established in 

1992 by the U.S. EPA in its National Toxics Rule ( 40 CFR 131.36). The National Toxics 

Rule allows states to use mixing zones to evaluate whether discharges comply with human 

health criteria. 

Ecology determined the effluent may contain chemicals of concern for human health, based 

on data or information indicating regulated chemicals occur in the 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 in the 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 of water 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. Under these standards Ecology may require a facility to evaluate the potential for its 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

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discharge to cause a violation of sediment 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 of the discharger characteristics and of the effluent characteristics, Ecology 

determined that this discharge has no reasonable potential to violate the sediment 

management standards. During the 1991-1996 permit term, Sonoco was required to 

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

potential in the vicinity of Sonoco' s outfall. The results submitted in 1993 indicated that the 

river velocity, even during low flow, was sufficient to prevent the accumulation of the fine 

sediments possibly present in mill effluent. Even if finer sediments do settle during 

unusually low river flows, they will be eroded away during the average river flow of about 

1,500 cfs and an average stream velocity of about 2.9 ft/s. 

I. Ground Water Quality Limits 

The ground water quality standards (chapter 173-200 WAC) protect beneficial uses of 

ground water. Permits issued by Ecology must not allow violations of those standards (WAC 

173-200-1 00). 

Sonoco does not discharge wastewater to the ground. No permit limits are required to protect 

ground water. 

J. Whole Effluent Toxicity 

The water quality standards for surface waters forbid discharge of effluent that has the 

potential to cause toxic effects in the receiving waters. Many toxic pollutants cannot be 

measured by commonly available detection methods. However, laboratory tests can measure 

toxicity directly by exposing living organisms to the wastewater and measuring their 

responses. These tests measure the aggregate toxicity of the whole effluent, so this approach 

is called whole effluent toxicity (WET) testing. Some WET tests measure acute toxicity and 

other WET tests measure chronic toxicity. 

• Acute toxicity tests measure mortality as the significant response to the toxicity of the 

effluent. Dischargers who monitor their wastewater with acute toxicity tests find early 

indications of any potential lethal effect of the effluent on organisms in the receiving 

water. 

• Chronic toxicity tests measure various sublethal toxic responses, such as reduced 

growth or reproduction. Chronic toxicity tests often involve either a complete life 

cycle test on an organism with an extremely short life cycle, or a partial life cycle test 

during a critical stage of a test organism's life. Some chronic toxicity tests also 

measure organism survival. 

Laboratories accredited by Ecology for WET testing know how to use the proper WET 

testing protocols, fulfill the data requirements, and submit results in the correct reporting 

format. Accredited laboratory staff know about WET testing and how to calculate an NOEC, 

LC50, EC50, IC25, etc. Ecology gives all accredited labs the most recent version of Ecology 

Publication No. WQ-R-95-80, Laboratory Guidance and Whole Effluent Toxicity Test 

Review Criteria (http://www.ecy.wa.gov/biblio/9580.html), which is referenced in the permit. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

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Ecology recommends that Sonoco send a copy of the 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 permit renewal. 

• If this facility makes process or material changes which, in Ecology's opinion, increase 

the potential for effluent toxicity, then Ecology may (in a regulatory order, by permit 

modification, or in the permit renewal) require the facility to conduct additional 

effluent characterization. Sonoco may demonstrate to Ecology that effluent toxicity 

has not increased by performing 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 consider the demonstration 

adequate to support a decision to not require an additional effluent characterization. 

• If WET testing conducted for submittal with a permit application fails to meet the 

performance standards in WAC 173-205-020, Ecology will assume that effluent 

toxicity has increased. 

WET testing conducted during the previous permit term showed a reasonable potential for 

the effluent to cause chronic toxicity in the receiving water. The proposed permit 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 of effluent at the boundary of the 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 in compliance with the chronic toxicity limit if there is no 

statistically significant difference in test organism response between the CCEC sample and 

the control sample. · 

Table 17. Summarized Historical WET Results 

IV. SONOCO Chronic WET Test Results as NOEC/LOEC in % Effluent 

Collected Start Date 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% 
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IV. SONOCO Chronic WET Test Results as NOECILOEC in % Effluent 

Collected Start Date 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% 
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IV. SONOCO Chronic WET Test Results as NOECILOEC in % Effluent 

Collected Start Date 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 Permit Issued on May 9, 2007. 

Table 18. Comparison of Previous and Proposed Effluent Limits 

·,, Previous Effluent Proposed Effluent Limits: 

Limits: Outfall# 001 Outfall# 001 

Parameter Basis of Average Maximum Average Maximum 

Limit Monthly Daily Monthly Daily 
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Previous Effluent Proposed Effluent Limits: 

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 Ammonia N daily - - - 1.llbs/day 

maximum 

Basis of Monthly Weekly Monthly 

Parameter Limit Geometric Geometric Geometric Weeldy 

Mean Mean Mean Geometric 

Limit Limit Limit Mean Limit 

NA but will NA but will 

Fecal Coliform TMDL reqmre reqmre 

Bacteria - - 1/month 1/month 

monitoring monitoring 

Previous Effluent Proposed Effluent Limits: 

Limits: Outfall # 001 Outfall# 001 

Parameter Basis of Limit Limit Limit 

Daily minimum is equal Daily minimum is equal to 

pH Technology to or greater than 6.0 and or greater than 6.0 and the 

the daily maximum is daily maximum is less than 

less than or equal to 9. 0 or equal to 9.0. 

V. Monitoring Requirements 
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Ecology requires monitoring, recording, and reporting (WAC 173-220-210 and 40 CFR 122.41) 

to verify that the treatment process is functioning correctly and that the discharge complies with 

the permit's effluent limits. 

The monitoring schedule is detailed in the proposed permit under Special Condition S.2. 

Specified monitoring frequencies take into account the quantity and variability of the discharge, 

the treatment method, past compliance, significance of pollutants, and cost of monitoring. 

A. Lab Accreditation 

Ecology requires that facilities must use a laboratory registered or accredited under the 

provisions of chapter 173-50 WAC, Accreditation of Environmental Laboratories, to prepare 

all monitoring data (with the exception of cetiain parameters). Ecology accredited the 

laboratory at this facility for: biochemical oxygen demand (BODO, total suspended solids 

(TSS), pH, and dissolved oxygen. Ammonia samples and all WET testing 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 of a pollutant that a 

laboratory can measure and report with a 99 percent confidence that its concentration is 

greater than zero (as determined by a specific laboratory method). The quantitation level is 

the level at which a laboratory can reliably report concentrations with a specified level of 

error. Estimated concentrations are the values between the MDL and the QL. Ecology 

requires permitted facilities to report estimated concentrations. When reporting maximum 

daily effluent concentrations, Ecology requires the facility to report "less than X" where X is 

the required detection level if the measured effluent concentration falls below the detection 

level. When calculating average monthly concentrations, the facility must use all the effluent 

concentrations measured below the quantitation level but above the method detection level. 
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VI. Other Permit 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 173-220-21 0). 

B. Spill Plan 

This facility stores a quantity of chemicals on-site that have the potential to cause water 

pollution if accidentally released. Ecology can require a facility to develop best management 

plans to prevent this accidental release [Section 402(a)(1) of the Federal Water Pollution 

Control Act (FWPCA) and RCW 90.48.080]. 

Sonoco developed a plan for preventing the accidental release of pollutants to state waters 

and for minimizing damages if such a spill occurs. The proposed permit requires the facility 

to update this plan and submit it to Ecology. 

C. Solid Waste Control Plan 

Sonoco could cause pollution of the waters of the state through inappropriate disposal of 

solid waste or through the release of leachate from solid waste. 

This proposed permit requires this facility to update the approved solid waste control plan 

designed to prevent solid waste from causing pollution of waters of the state. The facility 

must submit the updated plan to Ecology for approval (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/071 0024.pdf 

D. Outfall Evaluation 

The proposed permit requires Sonoco to conduct an outfall inspection and submit a report 

detailing the findings of that inspection (Special ConditionS. 13). The inspection must 

evaluate the physical condition of the discharge pipe and diffusers, and evaluate the extent of 

sediment accumulations in the vicinity of the outfall. 

E. Operation and Maintenance Manual 

Ecology requires industries to take all reasonable steps to properly operate and maintain their 

wastewater treatment system in accordance with state and federal regulations [ 40 CFR 

122.41(e) and WAC 173-220-150 (1)(g)]. The facility will prepare and submit an operation 

and maintenance manual as required by state regulation for the modification of existing or 

construction of additional wastewater treatment facilities (WAC 173-240-150). 

Implementation of the procedures in the operation and maintenance manual ensures the 

facility's compliance with the terms and limits in the permit. The facility will submit an 

update to the existing O&M manual within one year of the effective permit renewal date. 

F. Stormwater Prevention Plan 

In accordance with 40 CFR 122.44(k) and 40 CFR 122.44 (s), the proposed permit includes 

requirements for the update and implementation of a SWPPP along with BMPs to minimize 

or prevent the discharge of pollutants to waters of the state. BMPs constitute Best 
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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 of prevention, 

control, and treatment" (AKART). A SWPPP requires a facility to implement actions 

necessary to manage stormwater to comply with the state's requirement under chapter 90.48 

RCW to protect the beneficial uses of waters of the state. 

The SWPPP must identifY potential sources of storm water contamination from industrial 

activities and identifY how it plans to mange those sources of contamination to prevent or 

minimize contamination of stormwater. 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 or within reasonable access to the site and available for 

review by Ecology. 

Best Management Practices (BMPs) 

BMPs are the actions identified in the SWPPP to manage, prevent contamination of, and treat 

storm water. BMPs include schedules of activities, prohibitions of practices, maintenance 

procedures, and other physical, structural and/or managerial practices to prevent or reduce 

the pollution of waters of the state. BMPs 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 stmmwater management manuals. Many of these "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 proposed permit requires the facility to 

implement BMPs contained in the Stormwater Management Manual for Western Washington 

(2005 edition), or any revisions thereof, or practices that are demonstrably equivalent to 

practices contained in stormwater technical manuals approved by Ecology. This should 

ensure that BMPs will prevent violations of state water quality standards, and satisfY the state 

AKART requirements and the federal technology-based treatment requirements under 40 

CPR part 125.3. The SWPPP must document that the BMPs selected provide an equivalent 

level of pollution prevention, compared to the applicable Storm water Management Manuals, 

including: The technical basis for the selection for all stormwater BMPs (scientific, technical 

studies, and/or modeling) which support the performance claims for the BMPs selected. 

An assessment of how the BMPs will satisfY AKART requirements and the applicable 

technology-based treatment requirements under 40 CPR part 125.3. 

Operational Source Control BMPs 

Operational source control BMPs include a schedule of activities, prohibition of practices, 

maintenance procedures, employee training, good housekeeping, and other managerial 

practices to prevent or reduce the pollution of waters of the state. These activities do not 

require construction of pollution control devices but are very important components of a 
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successful SWPPP. Employee training, for instance, is critical to achieving timely and 

consistent spill response. Pollution prevention is likely to fail if the employees do not 

understand the importance and objectives of BMPs. Prohibitions might include eliminating 

outdoor repair work on equipment and cetiainly would include the elimination of intentional 

draining of crankcase oil on the ground. Good housekeeping and maintenance schedules help 

prevent incidents that could result in the release of pollutants. 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, when training 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 intended to prevent pollutants from entering stormwater. Examples of source 

control BMPs include erosion control practices, maintenance of stormwater facilities (e.g., 

cleaning out sediment traps), construction of roofs over storage and working areas, and 

direction of equipment wash water 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 compared to cleaning up pollutants after they have entered stormwater. 

Treatment BMPs 

Operational and structural source control BMPs are designed to prevent pollutants from 

entering stormwater. However, even with an aggressive and successful program, stormwater 

may still require treatment to achieve compliance with water quality standards. Treatment 

BMPs remove pollutants from stormwater. Examples of treatment BMPs are detention 

ponds, oil/water separators, biofiltration, and constructed wetlands. · 

Volume/Flow Control BMPs 

Ecology recognizes the need to 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 implement the requirements for peak 

runoff rate and volume control identified by volume 1 of the Western Washington SWMM 

and chapter 2 in the Eastern Washington SWMM as applicable to their development. .Chapter 

3 of volume 3 Western Washington SWMM and chapter 6 in the Eastern Washington SWMM 

lists BMPs to accomplish rate and volume control. Existing facilities in western Washington 

should also review the requirements of volumes 1 (Minimum Technical Requirements) and 

chapter 3 of volume 3 in the Western Washington SWMM. Chapter 2 (Core Elements for 

New Development and Redevelopment) in the Eastern Washington SWMM contains the 

minimum technical requirements for facilities east of the Cascades. Although not required to 

implement these BMPs, controlling rate and volume of stormwater discharge maintains the 

health of the watershed. Existing facilities should identify control measures that they can 

implement over time to reduce the impact of uncontrolled release of storm water. 

G. Best Management Practices 

Best management practices (BMPs) are the actions identified to manage, prevent 

contamination of, and treat stormwater. BMPs include schedules of activities, prohibitions of 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

Page 42 of 61 

practices, maintenance procedures, and other physical, structural and/or managerial practices 

to prevent or reduce the pollution of waters 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 permit to impose numerical limits, if necessary to comply with 

water quality standards for surface waters, with sediment quality standards, or with water 

quality standards for ground waters, after obtaining new information from sources such as 

inspections, effluent monitoring, outfall studies, and effluent mixing studies. 

Ecology may also modify this permit to comply with new or amended state or federal 

regulations. 

B. Proposed Permit Issuance 

This proposed permit includes all statutory requirements for Ecology to authorize a 

wastewater discharge. The permit includes limits and conditions to protect human health and 

aquatic life, and the beneficial uses of waters of the state of Washington. Ecology proposes 

to issue this permit for a term of 5 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 Support Document for Water Quality-based Taxies Control. EPA/505/2-90-

001. 

1988. Technical Guidance on Supplementary Stream Design Conditions for Steady State 

Modeling. USEPA Office of Water, Washington, D.C. 

1985. Water Quality Assessment: A Screening Procedure for Toxic and Conventional 

Pollutants in Surface and Ground Water. EPA/600/6-85/002a. 

1983. Water Quality Standards Handbook. USEPA Office of Water, Washington, D.C. 

Tsivoglou, E.C., and J.R. Wallace. 

1972. Characterization of Stream Reaeration Capacity. EPA-R3-72-012. (Cited in EPA 

1985 op.cit.) 

Washington State Department of Ecology. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

Page 43 of 61 

November 2010. Permit Writer's Manual. Publication Number 92-109 

(http://www.ecy. wa.gov/biblio/921 09 .html) 

2007. Focus Sheet on Solid Waste Control Plan, Developing a Solid Waste Control Plan 

for Industrial Wastewater Discharge Permittees. Publication Number 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 Control Plan, Developing a Solid Waste 

Control Plan for Industrial Wastewater Discharge Permittees, Publication Number 

07-10-024. http://www.ecy.wa.gov/pubs/0710024.pdf 

Wright, R.M., and A.J. McDonnell. 

1979. In-stream Deoxygenation Rate Prediction. Journal Environmental Engineering 

Division, ASCE. 105(EE2). (Cited in EPA 1985 op.cit.) 
Fact Sheet for NPDES Permit 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 Public Notice of Draft on March 20. 2013 in the Bonney Lake & Sumner 

Courier-Herald to inform the public and to invite comment on the proposed draft National 

Pollutant Discharge Elimination System permit and fact sheet. 

The notice: 

• Tells where copies of the draft Permit and Fact Sheet are available for public evaluation (a 

local public library, the closest Regional or Field Office, posted on our website). 

• Offers to provide the documents in an alternate format to accommodate special needs. 

• Urges people to submit their comments, in writing, before the end of the Comment Period 

• Tells how to request a public hearing of comments about the proposed NPDES permit. 

• Explains the next step(s) in the permitting process. 

Ecology has published a document entitled Frequently Asked Questions about Effective Public 

Commenting which is available on our website at http://www.ecy.wa.gov/biblio/0307023.html. 

You may obtain further information from Ecology by telephone, 360 407-6954, or by writing to 

the address listed below. 

Water Quality Permit Coordinator 

Department of Ecology 

Industrial Section 

PO Box 47600 

Olympia, WA 98504-7600 

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

Page 45 of 61 

Appendix B--Your Right to Appeal 

You have a right to appeal this permit to the Pollution Control Hearing Board (PCHB) within 30 

days of the date of receipt of the final permit. The appeal process is governed by chapter 43.21B 

RCW and chapter 371-08 WAC. "Date of receipt" is defined in RCW 43.21B.001(2) (see 

glossary). 

To appeal you must do the following within 30 days of the date of receipt of this permit: 

• File your appeal and a copy of this permit with the PCHB (see addresses below). Filing 

means actual receipt by the PCHB during regular business hours. 

• Serve a copy of your appeal and this permit on Ecology in paper form - by mail or in person. 

(See addresses below.) E-mail is not accepted. 

You must also comply with other applicable requirements in chapter 43 .21B RCW and chapter 

371-08 WAC. 

ADDRESS AND LOCATION INFORMATION 

Street Addresses Mailing Addresses 

Department of Ecology Department of Ecology 

Attn: Appeals Processing Desk Attn: Appeals Processing Desk 

300 Desmond Drive SE PO Box 47608 

Lacey, WA 98503 Olympia, WA 98504-7608 

Pollution Control Hearings Board Pollution Control Hearings Board 

1111 Israel RD SW PO Box 40903 

STE 301 Olympia, W A 98504-0903 

Tumwater, WA 98501 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

Page 46 of 61 

. Appendix C--Glossary 

1-DMax or 1-Day Maximum Temperature-- The highest water temperature reached on any 

given day. This measure can be obtained using calibrated maximum/minimum thermometers 

or continuous monitoring probes having sampling intervals of thirty minutes or less. 

7-DADMax or 7-DayAverage of the Daily Maximum Temperatures-- The arithmetic 

average of seven consecutive measures of daily maximum temperatures. The 7-DADMax 

for any individual day is calculated by averaging that day's daily maximum temperature with 

the daily maximum temperatures of the three days prior and the three days after that date. 

Acute Toxicity --The lethal effect of a compound on an organism that occurs in a short time 

period, usually 48 to 96 hours. 

AKART -- The acronym for "all known, available, and reasonable methods of prevention, 

control and treatment." AKART is a technology-based approach to limiting pollutants from 

wastewater discharges, which requires an engineering judgment and an economic judgment. 

AKAR T must be applied to all wastes and contaminants prior to entry into waters of the state 

in accordance with RCW 90.48.010 and 520, WAC 173-200-030(2)(c)(ii) and WAC 173-

216-110(1)(a). 

Alternate Point of Compliance -- An alternative location in the ground water from the point of 

compliance where compliance with the ground water standards is measured. It may be 

established in the ground water at locations some distance from the discharge source, up to, 

but not exceeding the property boundary and is determined on a site specific basis following 

an AKART analysis. An "early warning value" must be used when an alternate point is 

established. An alternate point of compliance must be determined and approved in 

accordance with WAC 173-200-060(2). 

Ambient Water Quality -- The existing environmental condition of the water in a receiving 

water body. 

Ammonia -- Ammonia is produced by the breakdown of nitrogenous materials in wastewater. 

Ammonia is toxic to aquatic organisms, exerts an oxygen demand and contributes to 

eutrophication. It also increases the amount of chlorine needed to disinfect wastewater. 

Annual Average Design Flow (AADF) --Average of the daily flow volumes anticipated to 

occur over a calendar year. 

Average Monthly Discharge Limit-- The average of the measured values obtained over a 

calendar month's time. 

Background Water Quality -- The concentrations of chemical, physical, biological or 

radiological constituents or other characteristics in or of ground water at a particular point in 

time upgradient of an activity that has not been affected by that activity, [WAC 173-200-

020(3)]. Background water quality for any parameter is statistically defined as the 95% 

upper tolerance interval with a 95% confidence based on at least eight hydraulically 

upgradient water quality samples. The eight samples are collected over a period of at least 

one year, with no more than one sample collected during any month in a single calendar year. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

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Best Management Practices (BMPs) -- Schedules of activities, prohibitions of practices, 

maintenance procedures and other physical, structural and/or managerial practices to prevent 

or reduce the pollution of waters of the state. BMPs include treatment systems, operating 

procedures and practices to control: plant site runoff, spillage or leaks, sludge or waste 

disposal, or drainage from raw material storage. BMPs may be further categorized as 

operational, source control, erosion and sediment control and treatment BMPs. 

BODs -- Determining the five-day Biochemical Oxygen Demand of an effluent is an indirect 

way of measuring the quantity of organic material present in an effluent that is utilized by 

bacteria. The BODs is used in modeling to measure the reduction of dissolved oxygen in 

receiving waters after effluent is discharged. Stress caused by reduced dissolved oxygen 

levels makes organisms less competitive and less able to sustain their species in the aquatic 

environment. Although BODs is not a specific compound, it is defined as a conventional 

pollutant under the federal Clean Water Act. 

Bypass -- The intentional diversion of waste streams from any portion of a treatment facility. 

Categorical Pretreatment Standards-- National pretreatment standards specifying quantities 

or concentrations of pollutants or pollutant properties, which may be discharged to a POTW 

by existing or new industrial users in specific industrial subcategories. 

Chlorine -- A chemical used to disinfect wastewaters of pathogens hannful to human health. It is 

also extremely toxic to aquatic life. 

Chronic Toxicity -- The effect of a compound on an organism over a relatively long time, often 

1/10 of an organism's lifespan or more. Chronic toxicity can measure survival, reproduction 

or growth rates, or other parameters to measure the toxic effects of a compound or 

combination of compounds. 

·Clean Water Act (CWA) --The federal Water Pollution Control Act enacted by Public Law 

92-500, as amended by Public Laws 95-217, 95-576, 96-483, 97-117; USC 1251 et seq. 

Compliance Inspection-Without Sampling -- A site visit for the purpose of determining the 

compliance of a facility with the terms and conditions of its permit or with applicable statutes 

and regulations. 

Compliance Inspection-with Sampling -- A site visit for the purpose of determining the 

compliance of a facility with the terms and conditions of its permit or with applicable statutes 

and regulations. In addition it includes as a minimum, sampling and analysis for all 

parameters with limits in the permit to ascetiain compliance with those limits; and, for 

municipal facilities, sampling of influent to ascertain compliance with the 85 percent removal 

requirement. Ecology may conduct additional sampling. 

Composite Sample -- A mixture of grab samples collected at the same sampling point at 

different times, formed either by continuous sampling or by mixing discrete samples. May 

be "time-composite" (collected at constant time intervals) or "flow-proportional" (collected 

either as a constant sample volume at time intervals proportional to stream flow, or collected 

by increasing the volume of each aliquot as the flow increased while maintaining a constant 

time interval between the aliquots). 
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Construction Activity -- Clearing, grading, excavation and any other activity, which disturbs 

the surface of the land. Such activities may include road building; construction of residential 

houses, office buildings, or industrial buildings and demolition activity. 

Continuous Monitoring -- Unintenupted, unless otherwise noted in the permit. 

Critical Condition -- The time during which the combination of receiving water and waste 

discharge conditions have the highest potential for causing toxicity in the receiving water 

environment. This situation usually occurs when the flow within a water body is low, thus, 

its ability to dilute effluent is reduced. 

Date of Receipt- This is defined in RCW 43 .21B.OO 1 (2) as five business days after the date of 

mailing; or the date of actual receipt, when the actual receipt date can be proven by a 

preponderance of the evidence. The recipient's sworn affidavit or declaration indicating the 

·date of receipt, which is unchallenged by the agency, constitutes sufficient evidence of actual 

receipt. The date of actual receipt, however, may not exceed forty-five days from the date of 

mailing. 

Detection Limit -- See Method Detection Level. 

Dilution Factor (DF) -- A measure of the amount of mixing of effluent and receiving water that 

occurs at the boundary of the mixing zone. Expressed as the inverse of the percent effluent 

fraction, for example, a dilution factor of 10 means the effluent comprises 1 0% by volume 

and the receiving water 90%. 

Distribution Uniformity -- The uniformity of infiltration (or application in the case of sprinkle 

or trickle inigation) throughout the field expressed as a percent relating to the average depth 

infiltrated in the lowest one-quatier of the area to the average depth of water infiltrated. 

Early Warning Value -- The concentration of a pollutant set in accordance with WAC 

173-200-070 that is a percentage of an enforcement limit. It may be established in the 

effluent, ground water, surface water, the vadose zone or within the treatment process. This 

value acts as a trigger to detect and respond to increasing contaminant concentrations prior to 

the degradation of a beneficial use. 

Enforcement Limit -- The concentration assigned to a contaminant in the ground water at the 

point of compliance for the purpose of regulation, [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. 

Engineering Report -- A document that thoroughly examines the engineering and 

administrative aspects of a particular domestic or industrial wastewater facility. The report 

must contain the appropriate information required in WAC 173-240-060 or 173-240-130. 

Fecal Coliform Bacteria-- Fecal coliform bacteria are used as indicators of pathogenic bacteria 

in the effluent that are harmful to humans. Pathogenic bacteria in wastewater discharges are 

controlled by disinfecting the wastewater. The presence ofhigh numbers of fecal coliform 

bacteria in a water body can indicate the recent release of untreated wastewater and/or the 

presence of animal feces. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

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Grab Sample -- A single sample or measurement taken at a specific time or over as short a 

period of time as is feasible. 

Ground Water-- Water in a saturated zone or stratum beneath the surface ofland or below a 

surface water body. 

Industrial User-- A discharger of wastewater to the sanitary sewer that is not sanitary 

wastewater or is not equivalent to sanitary wastewater in character. 

Industrial Wastewater-- Water or liquid-carried waste from industrial or commercial 

processes, as distinct from domestic wastewater. These wastes may result from any process 

or activity of industry, manufacture, trade or business; from the development of any natural 

resource; or from animal operations such as feed lots, poultry houses, or dairies. The term 

includes contaminated storm water and, also, leachate from solid waste facilities. 

Interference -- A discharge which, alone or in conjunction with a discharge or discharges from 

other sources, both: 

• Inhibits or disrupts the POTW, its treatment processes or operations, or its sludge 

processes, use or disposal; and 

• Therefore is a cause of a violation of any requirement of the POTW's NPDES permit 

(including an increase in the magnitude or duration of a violation) or of the prevention of 

sewage sludge use or disposal in compliance with the following statutory provisions and 

regulations or permits issued there under (or more stringent State or local regulations): 

Section 405 of the Clean Water Act, the Solid Waste Disposal Act (SWDA) (including 

title II, more commonly referred to as the Resource Conservation and Recovery Act 

(RCRA), and including State regulations contained in any State sludge management plan 

prepared pursuant to subtitleD of the SWDA), sludge regulations appearing in 40 CFR 

Part 507, the Clean Air Act, the Toxic Substances Control Act, and the Marine 

Protection, Research and Sanctuaries Act. 

Local Limits -- Specific prohibitions or limits on pollutants or pollutant parameters developed 

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. 

Major Facility-- A facility discharging to surface water with an EPA rating score of> 80 points 

based on such factors as flow volume, toxic pollutant potential, and public health impact. 

Maximum Daily Discharge Limit -- The highest allowable daily discharge of a pollutant 

measured during a calendar day or any 24-hour period that reasonably represents the calendar 

day for purposes of sampling. The daily discharge is calculated as the average measurement 

of the pollutant over the day. 

Maximum Day Design Flow (MDDF) -- The largest volume of flow anticipated to occur during 

a one-day period, expressed as a daily average. 

Maximum Month Design Flow (MMD F) -- The largest volume of flow anticipated to occur 

during a continuous 30-day period, expressed as a daily average. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

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Maximum Week Design Flow (MWDF) --The largest volume of flow anticipated to occur 

during a continuous 7 -day period, expressed as a daily average. 

Method Detection Level (MDL)-- The minimum concentration of a substance that can be 

measured and reported with 99 percent confidence that the pollutant concentration is above 

zero and is dete1mined from analysis of a sample in a given matrix containing the pollutant. 

Minor Facility -- A facility discharging to surface water with an EPA rating score of< 80 points 

based on such factors as flow volume, toxic pollutant potential and public health impact. 

Mixing Zone -- An area that surrounds an effluent discharge within which water quality criteria 

may be exceeded. The permit specifies the area of the authorized mixing zone that Ecology 

defines following procedures outlined in state regulations (chapter 173-201A WAC). 

National Pollutant Discharge Elimination System (NPDES) --The NPDES (Section 402 of 

the Clean Water Act) is the federal wastewater permitting system for discharges to navigable 

waters of the United States. Many states, including the state of Washington, have been 

delegated the authority to issue these permits. NPDES permits issued by Washington State 

permit writers are joint NPDES/State permits issued under both state and federal laws. 

NOEC --Means the "no observed effect concentration" which is the highest concentration of 

effluent in a toxicity test shown to have no statistically significant adverse effects when 

compared to an appropriate control. 

pH-- The pH of a liquid measures its acidity or alkalinity. It is the negative logarithm of the 

hydrogen ion concentration. A pH of 7 is defined as neutral and large variations above or 

below this value are considered harmful to most aquatic life. 

Pass-Through -- A discharge which exits the POTW into waters of the State in quantities or 

concentrations which, alone or in conjunction with a discharge or discharges from other 

sources, is a cause of a violation of any requirement of the POTW's NPDES permit 

(including an increase in the magnitude or duration of a violation), or which is a cause of a 

violation of State water quality standards. 

Peak Hour Design Flow (PHDF) -- The largest volume of flow anticipated to occur during a 

one- period, expressed as a daily or hourly average. 

Peak Instantaneous Design Flow (PIDF) -- The maximum anticipated instantaneous flow. 

Percent Minimum Significant Difference (PMSD) -- Given the number of replicates used in a test 

and the variability in test organism response across those replicates, the PMSD is an estimate of 

the minimum difference needed between a test concentration and a control in order for that 

difference to be considered significantly different when subjected to a statistical comparison. 

Point of Compliance -- The location in the ground water where the enforcement limit must not 

be exceeded and a facility must comply with the Ground Water Quality Standards. Ecology 

determines this limit on a site-specific basis. Ecology locates the point of compliance in the 

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 

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Potential Significant Industrial User (PSIU) --A potential significant industrial user is defined 

as an Industrial user that does not meet the criteria for a Significant Industrial user, but which 

discharges wastewater meeting one or more of the following criteria: 

a. Exceeds 0.5 %of treatment plant design capacity criteria and discharges <25,000 gallons 

per day or; 

b. Is a member of a group of similar industrial users which, taken together, have the 

potential to cause pass through or interference at the POTW (e.g. facilities which develop · 

photographic film or paper, and car washes). 

·Ecology may determine that a discharger initially classified as a potential significant 

industrial user should be managed as a significant industrial user.· 

Quantitation Level (QL) --Also known as Minimum Level ofQuantitation (ML)- The lowest 

level at which the entire analytical system must give a recognizable signal and acceptable 

calibration point for the analyte. It is equivalent to the concentration of the lowest calibration 

standard, assuming that the lab has used all method-specified sample weights, volumes and 

cleanup procedures. The QL is calculated by multiplying the MDL by 3.18 and rounding the 

result to the number nearest to (1,2,or 5) x IOn, where n is an integer. (64 FR 30417). 

ALSO GIVEN AS: 

The smallest detectable concentration ofanalyte greater than the Detection Limit (DL) where 

the accuracy (precision & bias) achieves the objectives of the intended purpose. (Report of 

the Federal Advisory Committee on Detection and Quantitation Approaches and Uses in 

Clean Water Act Programs Submitted to the US Environmental Protection Agency December 

2007). 

Reasonable Potential -- A reasonable potential to cause a water quality violation, or loss of 

sensitive and/or important habitat. 

Responsible Corporate Officer-- A president, secretary, treasurer or vice-president of the 

corporation in charge of a principal business function, or any other person who performs 

similar policy- or decision-making functions for the corporation, or the manager of one or 

more manufacturing, production, or operating facilities employing more than 250 persons or 

have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 

dollars), if authority to sign documents has been assigned or delegated to the manager in 

accordance with corporate procedures (40 CFR 122.22). 

Significant Industrial User (SIU) --

1) All industrial users subject to Categorical Pretreatment Standards under 40 CFR 403.6 and 

40 CFR Chapter I, Subchapter N and; 

2) Any other industrial user that: discharges an average of25,000 gallons per day or more of 

process wastewater to the POTW (excluding sanitary, noncontact cooling and boiler blowdown wastewater); contributes a process waste stream that makes up 5 percent or more of 

the average dry weather hydraulic or organic capacity of the POTW treatment plant; or is 

designated as such by the Control Authority* on the basis that the industrial user has a 

reasonable potential for adversely affecting the POTW's operation or for violating any 

pretreatment standard or requirement [in accordance with 40 CFR 403.8(±)(6)]. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

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Upon finding that the industrial user meeting the criteria in paragraph 2, above, has no 

reasonable potential for adversely affecting the POTW's operation or for violating any 

pretreatment standard or requirement, the Control Authority* may at any time, on its own 

initiative or in response to a petition received from an industrial user or POTW, and in 

accordance with 40 CFR 403.8(±)(6), determine that such industrial user is not a significant 

industrial user. 

*The term "Control Authority" refers to the Washington State Department of Ecology in 

the case of non-delegated POTW s or to the POTW in the case of delegated POTW s. 

Slug Discharge -- Any discharge of a non-routine, episodic nature, including but not limited to 

an accidental spill or a non-customary batch discharge to the POTW. This may include any 

pollutant released at a flow rate that may cause interference or pass through with the POTW 

or in any way violate the permit conditions or the POTW' s regulations and local limits. 

Soil Scientist -- An individual who is registered as a Certified or Registered Professional Soil 

Scientist or as a Certified Professional Soil Specialist by the American Registry of Certified 

Professionals in Agronomy, Crops, and Soils or by the National Society of Consulting 

Scientists or who has the cn~dentials for membership. Minimum requirements for eligibility 

are: possession of a baccalaureate, masters, or doctorate degree from a U.S. or Canadian 

institution with a minimum of 30 semester hours or 45 quarter hours professional core 

courses in agronomy, crops or soils, and have 5,3,or 1 years, respectively, of professional 

experience working in the area of agronomy, crops, or soils. 

Solid Waste -- All putrescible and non-putrescible solid and semisolid wastes including, but not 

limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, demolition and 

construction wastes, abandoned vehicles or parts thereof, contaminated soils and 

contaminated dredged material, and recyclable materials. 

Soluble BODs-- Determining the soluble fraction of Biochemical Oxygen Demand of an 

effluent is an indirect way of measuring the quantity of soluble organic material present in an 

effluent that is utilized by bacteria. Although the soluble 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 within the jurisdiction of the state of 

Washington. 

Stormwater -- That portion of precipitation that does not naturally percolate into the ground or 

evaporate, but flows via overland flow, interflow, pipes and other features of a storm water 

drainage system into a defined surface water body, or a constructed infiltration facility. 

Technology-Based Effluent Limit -- A permit limit based on the ability of a treatment method 

to reduce the pollutant. 

Total Coliform Bacteria -- A microbiological test, which detects and enumerates the total 

coliform group of bacteria in water samples. 

Total Dissolved Solids-- That portion of total solids in water or wastewater that passes through 

a specific filter. 
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Page 53 of 61 

Total Suspended Solids (TSS) -- Total suspended solids is the particulate material in an 

effluent. Large quantities of TSS discharged to a receiving water may result in solids 

accumulation. Apart from any toxic effects attributable to substances leached out by water, 

suspended solids may kill fish, shellfish and other aquatic organisms by causing abrasive 

injuries and by clogging the gills and respiratory passages of various aquatic fauna. 

Indirectly, suspended solids can screen out light and can promote and maintain the 

development of noxious conditions through oxygen depletion. 

Upset-- An exceptional incident in which there is unintentional and temporary noncompliance 

with technology-based permit effluent limits because of factors beyond the reasonable 

control of the Permittee. An upset does not include noncompliance to the extent caused by 

operational error, improperly designed treatment facilities, lack of preventative maintenance, 

or careless or improper operation. 

Water Quality-Based Effluent Limit-- A limit imposed on the concentration of an effluent 

parameter to prevent the concentration of that parameter from exceeding its water quality 

criterion after discharge into receiving waters. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

Page 54 of 61 

Appendix D--Technical Calculations 

Several of the Excel® spreadsheet tools used to evaluate a discharger's ability to meet 

Washington State water quality standards can be found on Ecology's homepage at 

http://www. ecy. wa. gov /programs/ eap/pwspread/pwspread.html. 

Calculation of Receiving Water pH at Edge of Mixing Zone. 

INPUT .. 

1. DILUTION FACTOR AT 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/Background pKa: 

Effluent pKa: 

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 AT MIXING 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 

7.48 
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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 =Upstream Background 90th percentile, t = allowable temperature 

rise 

The Water Quality temperature guidance document may be found at: 

INPUT. 

1. Chronic Dilution Factor at Mixing Zone Boundary 

2. 7DADMax Ambient Temperature (T) (Upstream 

Background 90th percentile) 

3. 7DADMax Effluent Temperature (95th percentile) 

4. Aquatic Life Temperature WQ Criterion in Fresh Water 

OUTPUT·· 

5. Temperature at Chronic Mixing Zone Boundary: 

6. Incremental Temperature Increase or decrease: 

7. Incremental Temperature Increase 28/(T+7) ifT:::; criteria: 

8. Maximum Allowable Temperature at Mixing Zone 

Boundary: 

· A. If ambient temp is warmer than W criterion 

9. Does temp fall within this warmer temp 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 · ··· · 

of the criterion 

11. Does temp fall within this 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. If ambient temp is cQoler .thau(WQ criterion-0.3} but 

within 28/(T+?) of the criterion 

13. Does temp fall within this Incremental temp. range? ---

14. Temp increase allowed at mixing zone boundary, if 

required: ---

D .. If ambient temp is cooler than (WQ criterion -

28/(T+7)) . 

15. Does temp fall within this 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 Limit if Required? NO LIMIT 

NO 

---

. 

T '"· 

YES 

NO 

LIMIT 

. 

NO 

NO 

LIMIT 
Fact 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. Th

calculations are done per the procedure in Technical Support Document for Water Quality-based Toxics Control, U.S. EPA, Mar

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 ~ 0 ~ 0 

0 0 ~t"" !>) (I) 

Q..l>l2 

o..gJ2 ~a~ n g ;;;<· n ;;; . ~ 

(I) 0 !>) (I) !>) > 

Ef N(i) s· Ef t:'j,... 

0"'- 0"'- "'(l) (I) 

<;;" s (I) < 

§. 5l n §.- n 0 ~ 0 0 § ~ ,0~ 

::l. ..., ~~::t :::: 0 (fq 0 e;gEB~ 

...... ..., 

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Ammonia as N 1.0 1.0 100.0 18613 1473 195 111 NO 0.8 1040 0.6 0.6 

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 

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 

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 

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 

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 

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 

This spreadsheet calculates the reasonable potential to exceed water quality standards established by WAC 173-

substances which have the potential either singularly or cumulatively to adversely affect characteristic water use

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

department. (Metals in effluent as total metal). 
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Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

Page 59 of 61 

Appendix E--Response to Comments 

The 30-day public comment period 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 of electronic data submission after the close of the 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 each respective 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 per permit cycle in the third and fifth 

year of the permit, similar to the other additional specific pollutants. 

Ecology has defined the cyanide sampling frequency in S2.A as twice per permit 

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 1 day per month only during the dry season 

of July 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. The fecal monitoring is now defined in 

S2.A as lday/month during July 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 of Sonoco'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 of any drinking water sources downstream from outfall 001. 

4. Section 14- Sonoco request the Fecal Coliform Monitoring Plan be 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 with the project as well as the development of a facility wide 

sampling program. Sonoco also request a clause be added that states if the monitoring 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

Page 60 of 61 

plan shows Sonoco's effluent to be below the waste load allocation, effluent will continue 

to be monitored per the approved Fecal Coliform Monitoring Plan in Phase1, but Phase 2 

of the Fecal Coliform Study will not be required. 

Ecology has adjusted the Fecal Coliform Monitoring Plan submittal date to August 

1, 2013. This date adjustment gives Sonoco more time to prepare the plan while still 

preserving the possibility of sampling during the first dry season of the permit. 

Sonoco's request that Phase 2 be dropped if sampling results are below the waste 

load allocation has been granted by defining the waste load allocation: as the 

geometric mean of each given dry season. Wording triggering Phase 2 if the 

geometric mean of the dry season exceeds the waste load allocation has been added 

to 814. 

Citizens for a Healthy Bay Comments: 

1. S 1. Discharge Limits and Benchmarks. The proposed permit decreased the allowances 

for BOD and TSS from the previous permit term to reflect implementation of WAC 173-

201A-320, which addresses antidegradation. Ecology reintroduced a limit on ammonia, 

which was derived from the total maximum daily load (TMDL) on the White River. 

Ecology added a fecal coliform limit to comply with the 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 of mixing zones as they allow areas where potentially toxic 

chemicals are allowed to exceed water quality standards. Certain chemicals such as 

copper may pose long term hazards as they have the potential for build up in the 

sediments. This is a special concern as the treated effluent no longer discharges directly 

into the river, but into sediments on shore. Has the Department of Ecology considered 

the potential of toxic buildup ofheavy metals in the outfall sediments along the White 

River? 

Ecology reviewed the description of the outfall to make sure it was clear that the 

effluent is discharged into the river and not into sediments on shore. Ecology has 

also reviewed the impact to sediments. There is ~o indication of sediment buildup in 

the vicinity of the outfall due to the characteristics of the sediment itself coupled 

with the seasonal high velocity scouring of the river flow. 

Ecology Notes on WA Web DMR Requirement: 

Ecology is transitioning away from physically man~ging and storing paper toward 

electronic data submittal and management. The boilerplate wording in use when the 

Sonoco NPDES renewal effort began encouraged but did not require this transition. 
Fact Sheet for NPDES Permit WA0000884 Sonoco Products Company 

Page 61 of 61 

Ecology asked Sonoco, after the close of the formal public comment period, to 

voluntarily agree to transition to electronic data submittal. Sonoco stated they did not 

object to the cunent permit boilerplate language addressing electronic data submittals. 

Ecology has incorporated a more cunent version of Permit Condition S3.A into the 

reissued permit.