SlATE Of WASH!NGTOf\J 

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PO Box 47600 ° WA 98S04-7600 360-407-6000 

711 for Washington Relay Service 0 Persons with a 

June 11, 2014 

Mike Wetzel 

Sonoco Products 

1802 Steele A venue 

Sumner, WA 98390 

Re: Unannounced Class II Water Inspection 

Dear Mr. Wetzel: 

can call 877-833-6341 

Enclosed is the report of the unannounced Class II Water Inspection conducted on April 

22, 2014. The mill appeared in overall compliance with the terms and conditions ofthe 

NPDES permit. 

I did note that the water supply used at the secondary clarifier for weir washing was not 

available. My understanding was that this line had gone out of service due to freezing 

temperatures several months earlier. My expectation is that this line be repaired as soon 

as reasonably possible and certainly far earlier than several months after going out of 

serv1ce. 

If you have questions, please contact me (360) 407-6954 or at 

Robert.carruthers@ecy. wa.gov. 

Sincerely, 

Robert Carruthers, P .E. 

Industrial Section 

Enc: Water Inspection Report 

® 
United States Environmental Protection Agency Form Approved 

OEPA Washington, D C 20460 OMB No. 2040-0057 

Water Compliance Inspection Report Approval Expires 10-31-95 

Section A: National Data System Coding (i.e., PCS) 

Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 

11_1 21§1 31WIA10101010181814111 1211141014122!17 1al.§l 191.§1 201~1 

Remarks 

2111!1NI81NINI o 11!1NI.QI£1QLIQ.I.!:I81.§1.§LI~LLLLLLLLLLLLLLLLLLLLLLLLLLLiss 

Inspection Work Days Facility Self-Monitoring Evaluation Rating Bl QA --------------------Reserved---------------------

s7LI1isg 7ol_l 711_1 nU 731_1_174 7sLLLLLLUao 

Section B: Facility Data 

Name and Location of Facility Inspected (For industrial users discharging to POTw, Entry Time/Date Permit Effective Date 

also include POTW name and NPDES permit number) 09:30 04/22/14 July 1, 2013 

SONOCO Products 

1802 Steele Avenue Exit Time/Date Permit Expiration Date 

Sumner, WA 98390 11 :30 04/22/14 July 1, 2018 

Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Other Facility Data 

Michael Temons, 253-863-6366 ext 326 

Name, Address of Responsible Official/Title/Phone and Fax Number. 

Jon Febus, Manager, 253-863-6366 ext 335 

Contacted 

DYes X No 

Section C: Areas Evaluated During Inspection (Check only those areas evaluated) 

1811 Permit 1811 Flow Measurement 1811 Operations & Maintenance 01 CSO/SSO (Sewer Overflow) 

1811 Records/Reports 1811 Self-Monitoring Program 0 Sludge Handling/Disposal 01 Pollution Prevention 

1811 Facility Site Review 01 Compliance Schedules 01 Pretreatment 01 Multimedia 

1811 Effluent/Receiving Waters 1811 Laboratory D__storm Water I Other: 

Section D: Summary of Findings/Comments (Attach additional sheets of narrative and checklists as necessary) 

The treatment system consists of a primary clarifier, aeration basin, and a secondary clarifier. The treated wastewater is 

discharged to the White River. The sludge from the clarifiers is used in the paper making process, so there is no 

additional sludge handling or disposal needed. 

The primary clarifier appeared to be operating normally during the inspection although plant growth was evident along 

the interior wall of the clarifier. The aeration basin appeared to be at normal capacity (about 75% of full capacity). All 

three aerators were operating. The secondary clarifier appeared to be operating properly although no water supply was 

available for weir washing. The water supply had not been repaired since a winter freeze months before. The effluent 

going over the weir was clear with a light tan color. 

Records and monitoring appeared in order. Overall the facility was found to be in compliance with the terms and 

conditions of their NPDES permit. 

Name(s) and Signature(s) of lnspector(s) Agency/Office/Phone and Fax Numbers Date 

RyQ,ert Carruthers Ecology, Industrial Section 360-407-6954 6/11/14 

t;r;1. »' ~~~<~-

/\/-~ 

Signature of MaiJJ::!::Jc:/t!e'vv Agency/Office/Phone and Fax Numbers 

Teddy Le p.__ 360-407-6948 & 360-407-6102 Da~j //t -/Y 

EPA Form 3560-3 (Rev. 9/94) Previous editions are obsolete. 
Form Approved 

OMB No 158-R0073 

Sections F thru L: Complete on all inspections, as appropriate. N/A = Not Applicable lPERMITNO. 

WA 000088-4 

SECTION F- Facility and Permit Background 

ADDRESS OF PERMITTEE IF DIFFERENT FROM FACILITY DATE OF LAST PREVIOUS INVESTIGATION BY EPNSTATE 

(Including City, County and ZIP code) 8/20/13 for Class II, 2/7/14 for Class I 

FINDINGS 

In compliance 

SECTION G - Records and Reports 

RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT. [2JYES ONO 0 N/A (Further explanation attached J 

DETAILS: 

(a) ADEQUATE RECORDS MAINTAINED OF: 

(i) SAMPLING DATE, TIME, EXACT LOCATION [8]YES ONO 0 N/A 

(ii) ANALYSES DATES, TIMES [8]YES 0NO D N/A 

(iii) INDIVIDUAL PERFORMING ANALYSIS !2JYES ONO D N/A 

(iv) ANALYTICAL METHODS/TECHNIQUES USED [2JYES DNO D N/A 

(v) ANALYTICAL RESULTS (e.g., consistent with self-monitoring report data) !2JYES ONO 0 N/A 

(b) MONITORING RECORDS (e.g., flow, pH, D.O., etc.) MAINTAINED FOR A MINIMUM OF THREE YEARS [2JYES 0NO 0 N/A 

INCLUDING ALL ORIGINAL STRIP CHART RECORDINGS (e.g., continuous monitoring instrumentation, 

calibration and maintenance records). 

(c) LAB EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT. [8]YES 0NO 0 N/A 

(d) FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT [8]YES ONO 0 N/A 

UNIT. 

(e) QUALITY ASSURANCE RECORDS KEPT. [8]YES ONO D N/A 

(f) RECORDS MAINTAINED OF MAJOR CONTRIBUTING INDUSTRIES (and their compliance status) DYES ONO [2] N/A 

USING PUBLICLY OWNED TREATMENT WORKS. 

SECTION H - Permit Verification 

INSPECTION OBSERVATIONS VERIFY THE PERMIT. [2JYES DNO D N/A (Further explanation attached J 

DETAILS: 

(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE. !2JYES ONO 0 N/A 

(b) FACILITY IS AS DESCRIBED IN PERMIT. [2JYES ONO 0 N/A 

(c) PRINCIPAL PRODUCT(S) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN [2JYES ONO 0 N/A 

PERMIT APPLICATION. 

(d) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION. [2JYES 0NO 0 N/A 

(e) NOTIFICATION GIVEN TO EPNSTATE OF NEW, DIFFERENT OR INCREASED DISCHARGES. !2JYES ONO 0 N/A 

(f) ACCURATE RECORDS OF RAW WATER VOLUME MAINTAINED. [2JYES ONO 0 N/A 

(g) NUMBER AND LOCATION OF DISCHARGE POINTS ARE AS DESCRIBED IN PERMIT. [8]YES 0NO 0 N/A 

(h) CORRECT NAME AND LOCATION OF RECEIVING WATERS. [8]YES ONO 0 N/A 

(i) ALL DISCHARGES ARE PERMITTED. [8]YES ONO D N/A 

SECTION I -Operation and Maintenance 

TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED. !2JYES DNO D N/A (Further explanation attached ) 

DETAILS: 

(a) STANDBY POWER OR OTHER EQUIVALENT PROVISIONS PROVIDED. DYES [81 NO D N/A 

) ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE. !2JYES ONO 0 N/A 

(c) REPORTS ON ALTERNATIVES SOURCE OF POWER SENT TO EPNSTATE AS REQUIRED BY [2JYES 0NO 0 N/A 

PERMIT. 

(d) SLUDGES AND SOLIDS ADEQUATELY DISPOSED. [2JYES ONO 0 N/A 

(e) ALL TREATMENT UNITS IN SERVICE. !2JYES 0NO 0 N/A 

(f) CONSULTING ENGINEER RETAINED OR AVAILABLE FOR CONSULTATION ON OPERATION AND [2JYES 0NO 0 N/A 

MAINTENANCE PROBLEMS. 

(g) QUALIFIED OPERATING STAFF PROVIDED. [8]YES ONO 0 N/A 

(h) ESTABLISHED PROCEDURES AVAILABLE FOR TRAINING NEW OPERATORS. [8]YES 0NO 0 N/A 

(i) FILES MAINTAINED ON SPARE PARTS INVENTORY, MAJOR EQUIPMENT SPECIFICATIONS, AND [8]YES ONO 0 N/A 

PARTS AND EQUIPMENT SUPPLIERS. 

(j) INSTRUCTIONS FILES KEPT FOR OPERATION AND MAINTENANCE OF EACH ITEM OF MAJOR [2JYES DNO D N/A 

EQUIPMENT. 

(k) OPERATION AND MAINTENANCE MANUAL MAINTAINED. [2JYES 0NO 0 N/A 

(I) SPCC PLAN AVAILABLE. !2JYES ONO D N/A 

(m) REGULATORY AGENCY NOTIFIED OF BY PASSING. (Oates ) DYES ONO [2] N/A 

(n) ANY BY-PASSING SINCE LAST INSPECTION. DYES [81 NO D N/A 

(o) ANY HYDRAULIC AND/OR ORGANIC OVERLOADS EXPERIENCED. DYES [81 NO D N/A 

EPA FORM 3560-3 (9-77) PAGE 2 OF 4 
Form Approved 

OMB No. 158-R0073 

I PERMIT NO. 

WA 000088-4 

SECTION J - Compliance Schedules 

PERMITTEE IS MEETING COMPLIANCE SCHEDULE. DYES DNO 1:8] N/A (Further explanation attached ) 

CHECK APPROPRIATE PHASE(S): 

D(a) THE PERMITTEE HAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE AUTHORITIES TO BEGIN 

CONSTRUCTION. 

D(b) PROPER ARRANGEMENT HAS BEEN MADE FOR FINANCING (mortgage commitments, grants, etc.). 

D(c) CONTRACTS FOR ENGINEERING SERVICES HAVE BEEN EXECUTED. 

D(d) DESIGN PLANS AND SPECIFICATIONS HAVE BEEN COMPLETED. 

D(e) CONSTRUCTION HAS COMMENCED. 

D(f) CONSTRUCTION AND/OR EQUIPMENT ACQUISITION IS ON SCHEDULE. 

D(g) CONSTRUCTION HAS BEEN COMPLETED. 

D(h) START-UP HAS COMMENCED. 

D(i) THE PERMITTEE HAS REQUESTED AN EXTENSION OF TIME. 

SECTION K - Self-Monitoring Program 

Part 1 - Flow measurement (Further explanation attached ) 

PERMITTEE FLOW MEASUREMENT MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. ~YES DNO D N/A 

DETAILS: 

(a) PRIMARY MEASURING DEVICE PROPERLY INSTALLED. ~YES DNO D N/A 

TYPE OF DEVICE: DWEIR i:8]PARSHALL FLUME DMAGMETER DVENTURI METER DOTHER: (Specify) 

(b) CALl BRA TION FREQUENCY ADEQUATE. (Date of last calibration) 12113/2013 ~YES DNO D N/A 

(c) PRIMARY FLOW MEASURING DEVICE PROPERLY OPERATED AND MAINTAINED. 1:8]YES DNO D N/A 

(d) SECONDARY INSTRUMENTS (totalizers, recorders, etc.) PROPERLY OPERATED AND MAINTAINED. ~YES DNO D N/A 

(e) FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW ~YES DNO D N/A 

RATES. 

Part 2 - Sampling (Further explanation attached ) 

PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. 1:8JYES DNO D N/A 

DETAILS: 

(a) LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES. 1:8]YES DNO D N/A 

(b) PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT. i:8]YES DNO D N/A 

(c) PERMITTEE IS USING METHOD OF SAMPLE COLLECTION REQUIRED BY PERMIT. i:8]YES DNO D N/A 

IF NO, DGRAB DMANUAL COMPOSITE [x] AUTOMATIC COMPOSITE FREQUENCY 250 ml every 30 minutes 

(d) SAMPLE COLLECTION PROCEDURES ARE ADEQUATE ~YES DNO 0 N/A 

(i) SAMPLES REFRIGERATED DURING COMPOSITING ~YES DNO D N/A 

(ii) PROPER PRESERVATION TECHNIQUES USED ~YES DNO D N/A 

(iii) FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED BY PERMIT DYES DNO 1:8] N/A 

(iv) SAMPLE HOLDING TIMES PRIOR TO ANALYSES IN CONFORMANCE WITH 40 CFR 136.3 ~YES DNO D N/A 

(e) MONITORING AND ANALYSES BEING PERFORMED MORE FREQUENTLY THAN REQUIRED BY DYES ~NO D N/A 

PERMIT. 

(f) IF (e) IF YES, RESULTS ARE REPORTED IN PERMITTEE'S SELF-MONITORING REPORT. DYES DNO ~ N/A 

Part 3 - Laboratory (Further explanation attached ) 

PERMITTEE LABORATORY PROCEDURES MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. ~YES DNO D N/A 

DETAILS: 

(a) EPA APPROVED ANALYTICAL TESTING PROCEDURES USED. (40 CFR 136.6) i:8]YES DNO D N/A 

(b) IF ALTERNATE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN i:8]YES DNO D N/A 

OBTAINED. 

(c) PARAMETERS OTHER THAN THOSE REQUIRED BY THE PERMIT ARE ANALYZED. DYES ~NO D N/A 

(d) SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT. 1:8JYES DNO D N/A 

(e) QUALITY CONTROL PROCEDURES USED. DYES ~NO D N/A 

(f) DUPLICATE SAMPLES ARE ANALYZED. 100 % OF TIME for BOD DYES ~NO D N/A 

(g) SPIKED SAMPLES ARE USED. 0 %OF TIME DYES ~NO D N/A 

(h) COMMERCIAL LABORATORY USED. ~YES DNO D N/A 

(i) COMMERCIAL LABORATORY STATE CERTIFIED. ~YES DNO D N/A 

·'' 

LAB NAME Analytical Resources (for ammonia) 

LAB ADDRESS Tukwila, WA 

EPA FORM 3560-3 (9-77) PAGE 30F 4 
SECTION L- Effluent/Receiving Water Observations (Further explanation attached 

OUTFALL NO. OIL SHEEN GREASE TURBIDITY VISIBLE FOAM VISIBLE 

FLOAT SOL 

001 no no no no no 

(Sections M and N: Complete as appropriate for sampling inspections) 

SECTION M -Sampling Inspection Procedures and Observations (Further explanation attached 

1:81 GRAB SAMPLES OBTAINED 

1:81 COMPOSITE OBTAINED 

D FLOW PROPORTIONED SAMPLE 

1:81 AUTOMATIC SAMPLER USED 

1:81 SAMPLE SPLIT WITH PERMITTEE 

1:81 CHAIN OF CUSTODY EMPLOYED 

1:81 SAMPLE OBTAINED FROM FACILITY SAMPLING DEVICE 

) 

PERMIT NO. 

Form Approved 

OMB No. 158-R0073 

WA 000088-4 

COLOR OTHER 

Very light tan 

) 

COMPOSITING FREQUENCY every % hour 250 ml PRESERVATION Yes, refrigerated 

SAMPLE REFRIGERATED DURING COMPOSITING: [8JYES 0NO 

SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE Yes 

SECTION N - Analytical Results (Attach report ifnecessary) 

SamQiing results: Permit Limits 

pH 8.1 (composite based on April 21 sample), 7.9 (grab from April22, 2014) 5.1 <pH<9.0 

Composite TSS 54 lbs/day (38 mg/1) note 1. 1,487 

Grab TSS 41 lbs/day (28 mg/1) note 2. 1,487 

Composite BOD 57 lbs/day (40 mg/1) note 1. 673 

Grab BOD 20 lbs/day (14 mg/1) note 2. 673 

Grab Fecal Coliform 27 #/1 00 ml as MF %Kieb 15 NA 

_Note 1. From composite sample of secondary effluent before noncontact cooling water. Mass based on average 

secondary effluent flow of .171 mgd on April 21, 2014. 

Note 2. Based on grab sample of secondary effluent before noncontact cooling water. Mass based on average 

secondary effluent flow of .17 4 mgd April 22, 2014. 

Metals as TR from composite sample on April 21, 2014. 

Silver NO ug/1, Arsenic 2.16 ug/1, Beryllium NO ug/1, Cadmium 0.13 ug/1, Chromium 2.00 ug/1, Copper 5.56 ug/1, 

Mercury 0.0070 ug/1, Nickel 3.04 ug/1, Lead 1.64 ug/1, Selenium 0.82 ug/1, Thallium NO ug/1, Zinc 28.6 ug/1, Antimony 

1.18 ug/1. 

EPA FORM 3560-3 (9-77) PAGE 4 OF 4