-0-, 

DEQ 

State of Oregon 

Department of 

Environmental 

Quality 

National Pollutant Discharge Elimination System 

PERMIT EVALUATION AND FACT SHEET 

May 28, 2004 

Oregon Department of Environmental Quality 

Western Region 

750 Front St NE, Suite 120 

Salem OR 97301 

(503) 378-8240 

Permittee: 

Current Permit: 

Source Information: 

Source Contact: 

Proposed Action: 

Permit Writer: 

City of Woodbum 

2815 Molalla Road 

Woodbum, OR 97071 

File Number: 98815 

NPDES Permit Number: 101588 

EPA Reference Number: OR002000-1 

Issue Date: March 31, 1998 

Expiration Date: February 28,2003 

Woodbum POTW 

2815 Molalla Road 

Woodburn, Oregon 

Latitude 45° 9.255' North, Longitude 122° 48 418 West 

Frank Sinclair, POTW Superintendent 

Phone: 503-982-5280 

NPDES Major Domestic Permit Renewal 

Application Number: 985228 

Date Received: September 6, 2002 

Mark E, Hamlin 

Phone: 503-378-8240, extension 239 
City of Woodbu m NPDES Renewal Evaluation Repor t 

INTRODUCTION 

The City of Woodbum owns and operates an advanced secondary wastewater treatment facility located 

near Woodbum, Oregon (see Figure 1). Municipal wastewater is treated and discharged to the Pudding 

River in accordance with National Pollutant Discharge Elimination System (NPDES) Permit number 

101588. The Permit for the facility was issued on March 31, 1998 and expired on February 28, 2003. 

Figure 1 

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The Department received a renewal application on September 6, 2002, The permit shall not be deemed 

to expire until final action has been taken on the renewal application as per Oregon Administrative Rules 

(OAR) 340-045-0040. A renewal permit is necessary to discharge to state waters pursuant to provisions 

of Oregon Revised Statutes (ORS) 468B.050 and the Federal Clean Water Act, The Department 

proposes to renew the permit. This permit evaluation report describes the basis and methodology used in 

developing the permit. 

This permit is a joint federal and state permit and subject to federal and state regulations. The Clean 

Water Act, the Code of Federal Regulations, and numerous guidelines of the Environmental Protection 

Agency provide the federal permit requirements. The Oregon Revised Statutes, Oregon Administrative 

Rules, and policies and guidelines of the Department of Environmental Quality provide the state 

permitting requirements. 

PAGE 2 
City of Wooclbur n NPDES Renewa l Evaluatio n Report 

FACILITY DESCRIPTION 

The treatment facility serves the entire City of Woodbum with the exception of some isolated residences. 

Some service is provided to the Oregon Youth Authority outside the City's limits. The completed 

wastewater treatment facility for the design year 2020 is being built in two phases of construction. The 

City completed Phase 1 of the facility upgrade in June 2001. Phase II will be constructed when required 

by increased flow or loading. The previous Rotating Biological Contactor (RBC) facility was mostly 

abandoned during the phase 1 upgrade, 

The facility (see Attachment #1) consists of headworks with screening and degritting, primary 

clarification, anoxic selector activated sludge secondary treatment and clarification, effluent filtration 

and ultraviolet (UV) disinfection with discharge to either the Pudding River or a poplar tree plantation. 

Sludge is anaerobieally digested, stored in facultative sludge lagoons and land applied on the poplar 

plantation. The treatment facility headworks has two mechanical bar screens with a screenings 

compactor. Grit from the two grit chambers is classified with a cyclone grit separator. Four primary 

clarifiers perform primary sedimentation (two for normal operation and two for wet weather operation). 

Secondary treatment is performed by two, anoxic selector activated sludge aeration basins and three 

secondary clarifiers. The effluent is filtered by two continuous backwash filters capable of handling 3.33 

MGD. 

Disinfection is performed by UV light in two UV channels prior to discharge to the Pudding River and 

irrigation of the poplar plantation. Phase I is capable of disinfecting up to 12 MGD. The chlorine 

contact chambers from the old RBC facility were retained for use as an irrigation pump station wet well. 

Sodium hypochlorite is occasionally injected downstream of the irrigation pumps to clean the irrigation 

system. Treated effluent can be discharged to the Pudding River or beneficially reused as Level HI 

reclaimed water on 88 acres of poplar trees, Additional poplar tree acreage (up to 240 acres) can be 

added as needed. Flow monitoring is provided at the influent, effluent and irrigation. The 14,3 acre 

bentonite lined lagoon with a capacity of 37 million gallons is used for reclaimed water storage. 

Digested sludge is pumped from the two primary digesters to two facultative sludge lagoons added 

during Phase I, The sludge lagoons can be dredged into a day tank for land application as biosolids on 

the poplar plantation during the summer. The sludge drying beds from the RBC facility were retained for 

back up operation, A third anaerobic digester can be added when necessary. The facility regularly 

receives septage at a septage receiving station. The Phase I design average dry weather flow (ADWF) is 

3.33 million gallons per day (MGD) while the design average wet weather flow (AWWF) is 4.8 MGD. 

The design loadings are shown in Table I. 

Table 1: Phase I Design Loadings 

CBODs 

TSS 

Dry Weather Design Loading (lb/day) 

Daily Average 

7200 

6500 

Monthly Max 

9500 

8400 

Wet Weather Design Loading (lb/day) 

Daily Average 

6400 

6700 

Monthly Max 

7300 

8300 

In Phase II, an additional bar screen, grit chamber, cyclone separator, primary clarifier, aeration basin, 

secondary clarifier, effluent filter and UV channel will be added. The disinfection capacity will be 

increased to 18 MGD. The peak hydraulic capacity is rated at 16.0 MGD based on the Mill Creek pump 

station pump capacity. The Phase II ADWF will be 5.037 MGD and the design AWWF will be 7.3 

MGD. The design loadings are shown in Table 2 

PAGE 3 
City of Woodburn NPDES Renewal Evaluation Report 

Table 2; Phase II Design Loadings 

CBOD5 

TSS 

Dry Weather Design Loading (lb/day) 

Daily Average 

11400 

10500 

Monthly Max 

14800 

13400 

Wet Weather Design Loading (lb/day) 

Daily Average 

10100 

10800 

Monthly Max 

11500 

13300 

The facility is unmanned at night, but has 24-hour alarm telemetry through the treatment plant. The 

facility has standby electric generation at the treatment plant. All but two lift stations are or will have 

redundant power (fixed or mobile electric generators). This permit includes a requirement to install 

redundant power capability at the two lift stations that cannot currently be served by mobile generators. 

During the last two dry seasons (2002 and 2003 from May 1 through October 31), the plant received an 

average of 1.76 MGD or 53 percent of the Phase I hydraulic capacity. Summer plant loading averaged 55 

percent of the Phase I CBODs organic capacity and 68 percent of the TSS capacity. The maximum 

CBOD5 loading (52.5% of the maximum month design) occurred during July 2003 while the maximum 

TSS loading (79% of the maximum month design) occurred September 2002. 

Plant flows during the winter are weather dependant. During the last two wet weather periods (2002/03 

and 2003/04 from November 1 though April 30), the plant received an average of 2.88 MGD or 60 

percent of the Phase 1 hydraulic capacity. Winter plant loading averaged 70 percent of the Phase I 

CBOD5 organic capacity and 75 percent of the TSS capacity. The maximum CBOD5 loading (73% of the 

maximum month design) occurred during December 2002 while the maximum TSS loading (86% of the 

maximum month design) occurred January 2003, 

Since start up of the Phase I facility, no modifications have been made to the facility, 

Biosolids Management and Utilization 

All waste sludge must be managed in accordance with the Department approved Biosolids Management 

Plan (BMP) to ensure compliance with the federal biosolids regulations (40 CFR Part 503) and the state 

rules (OAR 340-050), The City's BMP was originally approved December 10, 1987. The Department 

proposes to approve a new BMP with this permit action 

The biosolids consistently meet the vector attraction and Class B pathogen reduction requirements in 40 

CFR Part 503, After treatment necessaiy to comply with vector attraction and pathogen reduction 

requirements, the biosolids are beneficially land applied. The updated plan includes site selection criteria 

for land application of Class B biosolids. The site selection criteria includes all of western Oregon, The 

Department is proposing to approve the plan (see Attachment #2), 

Woodbum's treatment works produces biosolids from primary clarifier solids, waste activated sludge, and 

septage. The waste activated sludge is thickened using dissolved air floatation. All three sewage solid types 

are blended together in a blend tank before pumping to the two primary digesters. Sludge is digested for a 

minimum mean cell residence time of between 15 and 60 days at a minimum temperature between 35 and 

55 degrees centigrade. 

Digested solids are stored in two 2.5 acre facultative sludge lagoons (about 24,400,000 total gallons), Solids 

are stored in the lagoons for an average of three years prior to removal. Solids are dredged from the lagoon 

and either dried in sludge drying beds and land applied as a solid, or applied directly to the poplar tree reuse 

system as a liquid. Solid application is by spreader truck or manure spreader while liquid application is by a 

PAGE 4 
City of Woodburn NPDES Renewal Evaluation Report 

self-retrieving hose reel or tractor pulled liquid field spreaders. Biosolids could also be land applied directly 

from the digesters or, potentially, as Class A biosolids after composting, 

The biosolids are beneficially land applied to the 88 acre poplar plantation. The City monitors volatile 

solids reduction to demonstrate compliance with federal vector attraction requirements and fecal coliform 

monitoring to demonstrate compliance with federal pathogen reduction requirements. The City produces 

approximately 900 metric diy tons of biosolids per year. Biosolids applications generally occur during the 

summer. The land application sites have been approved by the Department. 

The City may continue to utilize the previously authorized land application site, The current site is located 

in Marion County, Any future land application site must conform to the site selection criteria in the 

Biosolids Management Plan and must be located in Marion and Clackamas Counties. 

The City conducts yearly chemical testing of removed sludge (see Table 1). Testing includes analyses 

for nutrients and 11 metals, Based on the analyses, there are no known potential impacts from the 

current land application program. 

Parameter 

Arsenic 

Cadmium 

Chromium 

Copper 

Lead 

Mercury 

Table 

Mg/dry Kg 

6,26 

<5,0 

26.1 

39.9 

12.3 

0.170 

1 - Biosolids Metals Results for July 2004 

§503.13 

Tabic 3 Limit 

41 mg/kg 

39 mg/kg 

No limit 

1500 mg/kg 

300 mg/kg 

17 mg/kg 

Parameter 

Molybdenum 

Nickel 

Selenium 

Silver 

Zinc 

Mg/dry 

Kg 

"'" <2.5 

21.4 

<0.50 

3.16 

144 

§503.13 

Table 3 Limit 

No limit 

420 mg/kg 

100 mg/kg 

No limit 

2800 mg/kg 

Inflow and Infiltration (I/I) 

The plant received an average of 1.76 MGD during the last two dry seasons while it received an average 

of 2.88 MGD during the last two wet weather periods. The wet period average flow is less than two 

times the dry period average flow. The maximum daily flow of 8.73 MGD occurred in March 2003. 

The plant experiences significant but not extreme levels of I/I, 

Collection system overflows can result from catastrophic failure of the treatment plant or pump station or 

high flows due to storm events. According to the rules (OAR 340-041-0009(6) and (7)), the City is 

prohibited from discharging raw sewage during the period of November 1 through May 21, except during 

a storm event greater than the one-in-five-year, 24-hour duration storm. In addition, they cannot 

discharge raw sewage during the period of May 22 through October 31, except during a storm event 

greater than the one-in-ten-year, 24-hour duration storm. The City of Woodburn can comply with these 

rules. 

The current permit contains Carbonaceous Biochemical Oxygen Demand (CBODs) and total suspended 

solids (TSS) removal efficiency limits of 85 percent. The City has had no violations of the removal 

efficiency limits. The Department is proposing to retain the existing limits. 

Industrial Pretreatment 

The City of Woodburn implements an industrial pretreatment program originally approved by the 

Department March 26, 1983. The State and Federal pretreatment requirements were included in the 

NPDES permit for this facility when originally issued. In the calendar year 2003, the City permitted 6 

significant industrial users (SIUs). The City currently has 1 categorical industrial user; 3 significant 

industrial users, and 2 non-discharging categorical industries. 

PAGE 5 
City of Woodburn NPDES Renewal Evaluation Report 

The core components of the City's approved pretreatment program are current with the exception of the 

need to re-evaluate local limits. Revisions to the original approved program include: updates to the local 

limits approved by DEQ and incorporated into the NPDES permit by reference on June 26, 1995; 

modifications to the sewer use ordinance approved by DEQ on May 30, 1996, and incorporated into the 

NPDES permit by reference on August 26, 1996; revisions to the Enforcement Response Guide approved 

by DEQ on February 17, 1999, and incorporated into the permit by reference on August 25, 1999; and, 

changes to the pretreatment implementation procedures approved by DEQ and incorporated into the 

NPDES permit by reference on February 17, 1999. 

The City performed a technical evaluation of the need to re-evaluate local limits as part of the NPDES 

renewal process. It was determined that a local limits study is appropriate to further quantify headworks 

loadings, removal efficiencies, and local limits based on the recent improvements to the treatment 

processes. The local limits study is currently in progress. The technically based revised local limits are 

expected to be complete by 2006. Additionally, the City is implementing a management plan to reduce 

mercury and silver from the raw sewage entering the wastewater treatment plant which corresponds to 

reductions in the amounts discharged to the receiving waters. The management plan was approved by 

DEQ on March 27, 1997, and is being implemented on an ongoing basis. 

The City of Woodburn's industrial pretreatment program was nominated for a National Pretreatment 

Program Excellence Award by DEQ and the USEPA Region 10 in 2000. The most recent federal-level 

pretreatment program audit was performed by DEQ during June 5-6, 2001. The findings of the audit 

resulted in required and recommended actions to improve the program but no violations of the NPDES 

permit Schedule E Pretreatment Activities were documented (i.e Notice of Noncompliance). The 

required and recommended actions identified in the audit were resolved to the satisfaction of the 

Department in a DEQ letter dated July 11, 2001, 

Groundwater Issues 

The treatment plant is constructed entirely of impervious structures except for the bentonite lined storage 

lagoon and the facultative sludge lagoon (FSL). The storage lagoon is used for storage of fully treated 

reclaimed water if the reclaimed water cannot be applied at the time it is generated. The FSL has 40 mil 

poly liner. It is not anticipated that the treatment process itself or the discharge to surface waters will 

cause groundwater impacts. 

The biosolids and reclaimed water applications are performed at agronomic rates or less. Because they 

are applied at agronomic rates or less, the Department's groundwater protection requirements are 

satisfied. 

Prior to the current permit, the City performed groundwater monitoring for level and nitrate due to the 

potential groundwater impacts from the lagoon. No significant impacts to groundwater were noted due to 

the facility although some upgradient (background) nitrate levels were elevated. 

Schedule A of the proposed permit prohibits adverse impacts to groundwater, A condition in Schedule D 

states that no groundwater evaluations will be required during this permit cycle, 

Stormwater Issues 

General NPDES permits for stormwater are required for facilities with a design flow of greater than 1 MGD 

if stormwater is collected and discharge from the plant site. This facility has been assigned a separate 1200-

Z permit that regulates the discharge of stormwater. Stormwater is not addressed in this permit. 

PAGE 6 
City of Woodburn NPDES Renewal Evaluation Report 

Outfalls 

The current NPDES Permit allows the treatment facility to discharge treated effluent into the Pudding River 

southeast of the plant through two outfall pipes at River Mile 21.5. All flow discharges through Outfall 

001A except when discharge flows at the facility exceed about 12 MGD. At that point, treated wastewater 

overflows an internal weir and begins to discharge from both outfalls. All effluent monitoring occurs prior 

to the internal weir. 

The Department's GIS tool identifies the discharge location for Outfall 001A and Outfall 00 IB as River 

Mile 21.4. The renewal permit will include a river mile of 21.4 for both outfalls. Outfall 001A is located at 

approximately Latitude 45° 9.053' North, Longitude 122° 48,232 West. Outfall 001B is located at' 

approximately Latitude 45° 9.071' North, Longitude 122° 48.182 West. Treated, disinfected and 

dechlorinated effluent is discharged through Outfalls 001A and 00IB in accordance with the limits in 

Schedule A, Condition La. Outfall 00IB may not be used until the capacity of Outfall 001A has been 

reached. 

The current NPDES Permit allows the treatment facility to land apply treated and disinfected reclaimed 

water to the 88 acre poplar plantation. The plantation will be expanded in the future as needed. Level HI 

reclaimed water is land applied through Outfall 002. The plantation is located at the wastewater treatment 

facility at approximately Latitude 45° 9.255' North, Longitude 122° 48,418 West. Irrigation must be in 

accordance with the limits in Schedule A, Condition 1 .b. 

The existing Pennit identifies three emergency overflow points at pump stations. The proposed permit 

identifies the same three emergency overflow points, Lift Station #2 at Jansen Way has been replaced 

with the Vanderbeck Lift Station but the overflow point remains the same (Outfall 003). After filling the 

wet well, the system will overflow to an unnamed swale at approximately Latitude 45° 9.654' North, 

Longitude 122° 51.744 West. Lift Station #6 (Outfall 004) overflows to an unnamed swale in a field near 

45° 8.44' North, Longitude 122° 52.36 West. The Mill Creek Pump Station (Outfall 005) overflows 

directly to Mill Creek at approximately Latitude 45° 9,107' North, Longitude 122° 50.776 West. 

Discharges from these overflow points are prohibited except in accordance with the Oregon 

Administrative Rules (OAR). 

Mixing Zone Analysis 

Federal regulations (40 CFR 131.13) allow for the use of mixing zones, also known as "allocated impact 

zones". When using mixing zones acute toxicity to drifting organisms must be prevented and the 

integrity of the waterbody as a whole may not be impaired. Mixing zones allow the initial mixing of 

waste and receiving water, but are not designed to allow for treatment, EPA does not have specific 

regulations pertaining to mixing zones. Each state must adopt its own mixing zone regulations that are 

subject to review and approval by EPA, In States that lack approved mixing zone regulations, ambient 

water quality standards must be met at the end of the pipe. 

The Department has adopted the two-number aquatic life criteria and developed mixing zone regulations 

with respect to that, The regulations are primarily narrative and essentially require the permit writer to 

use best professional judgment in establishing the size of the mixing zone. Based on EPA guidance and 

the Department's mixing zone regulations, two mixing zones may be developed for each discharge that 

reflect acute and chronic effects: 1) The acute mixing zone, also known as the "zone of initial dilution" 

(ZID), and 2) the chronic mixing zone, usually referred to as "the mixing zone". The acute mixing zone 

is designed to prevent lethality to organisms passing through the ZID. The chronic mixing zone is 

designed to protect the integrity of the entire water body as a whole. The allowable size of the mixing 

zone should be based upon the relative size of the discharge to the receiving stream, the beneficial uses of 

the receiving stream, location of other discharges to the same water body, location of drinking water 

PAGE 7 
City of Woodburn NPDES Renewal Evaluation Report 

intakes, and other considerations. More specific guidance is available from EPA regarding criteria used 

in appropriately sizing a ZID. Primarily, the ZID must be designed to prevent lethality to drifting 

organisms. 

The Department's mixing zone regulations state the mixing zone must be less than the total stream width 

as necessary to allow passage offish and other aquatic organisms. Early recommendations regarding the 

size of the zone of passage originated from the Department of Interior (1968). They recommended a 

zone of passage of 75 percent of the cross-sectional area and/or volume of flow of the receiving stream. 

Based on this recommendation, the Department's standard practice is to allow no more than 25 percent of 

, the stream flow for mixing zones. 

The current permit provides for a mixing zone that consists of that portion of the Pudding River 

extending from a point ten (10) feet upstream of Outfall 001A to a point three hundred (300) feet 

downstream from the outfall. The Zone of Immediate Dilution (ZID) shall be defined as that portion of 

the allowable mixing zone that is within thirty (30) feet of the point of discharge. It is likely the effluent 

mixes with more than 25% of the stream flow prior to 300 feet downstream. The proposed permit reduces 

the size of the mixing zone and is described as follows: 

The allowable mixing zones for outfalls 001A and 00IB limit the lateral extent to ten feet upstream and 

200 feet downstream from each respective outfall and restricting the dilution to no more than 25 percent 

of the stream flow. The zone of initial dilution is limited to that portion of the mixing zone that is within 

twenty feet of each outfall. 

At the critical case low flow (7Q10 stream flow and discharge at the design flow of 5.037 MGD), the 

dilution achieved within the ZID and mixing zone defined above is 1.2 at the edge of the ZID and 1.6 at 

the edge of the mixing zone. This dilution is based on the discharge of outfall 001A only because outfall 

001B is only operational under extremely high flow events (both plant and river flows). 

Receiving Stream Water Quality 

The City's discharge is to the Pudding River at River Mile 21.4, The discharge is within the Willamette 

basin and Molalla-Pudding sub-basin. The designated beneficial uses of the receiving stream are: public 

and private domestic water supply, industrial water supply, irrigation, livestock watering, fish and aquatic 

life (including salmonid rearing and passage), wildlife and hunting, fishing, boating, water contact 

recreation, aesthetic quality and hydro Power. The water quality standards for the Willamette Basin 

(OAR 340-041) were developed to protect the beneficial uses of the basin. 

The Pudding River is included on the Department's 2002 List of Water Quality Limited Water Bodies 

(also called the 303(d) List) as water quality limited for temperature in the summer, fecal bacteria yearround and DDT year-round, A Total Maximum Daily Load (TMDL) addressing these parameters should 

be issued during 2006. The TMDL may assign Waste Load Allocations (WLA) to this source, The 

WLA may be incorporated into the permit by modification or during the next permit renewal, 

Previously, the dissolved oxygen standard was violated in the Pudding River from June through October 

most years. The dissolved oxygen violations were due to point source discharges and non-point source 

contributions of oxygen demanding pollutants. In August 1993, the Department established a TMDL to 

bring the river into compliance with the dissolved oxygen standard, The TMDL contains WLA for 

CBOD5, ammonia and dissolved oxygen in the discharged effluent from Woodburn's treatment facility. 

In January 1996, the Environmental Quality Commission (EQC) adopted new dissolved oxygen 

standards. The Department recalculated the TMDL waste load allocations (using the same model) to 

take into account the newly approved water quality standards for dissolved oxygen. In 1998, the revised 

PAGE 8 
City of Woodburn NPDES Renewal Evaluation Report 

WLAs were incorporated into Woodburn's permit. The revised WLA's are flow based (both effluent and 

stream) concentration limits that provided more operational flexibility to the City for split discharges, 

Temperature Issues 

Water temperature affects the biological cycles of aquatic species and is a critical factor in maintaining 

and restoring healthy salmonid populations throughout the state. It is the policy of the Environmental 

Quality Commission (EQC) to protect aquatic ecosystems from adverse temperature changes caused by 

anthropogenic activities. The purpose of the temperature criteria listed in OAR 340-041-0028 is to 

protect designated beneficial uses that are temperature sensitive, including salmonids in waters of the 

State. 

The Department utilizes Fish Use Designation and Salmon and Steelhead Spawning Use Designations 

maps to identify applicable temperature criteria for each basin. The Willamette Basin maps are 

contained in OAR 340-041, Figures 340A and 340B, respectively. According to the newly approved use 

designation maps, salmon and steelhead spawning is designated as salmon and trout rearing and 

migration habitat. Salmon and steelhead spawning is not a designated use. Therefore, the applicable 

numeric temperature criteria is 18 °C during the entire year. 

Summer Period 

The Department's List of Water Quality Limited Water Bodies (also called the 303(d) List) for 2002 

indicates the Pudding River is water quality limited for temperature during the summer. Pursuant to 

OAR 340-04 l-0028(12)(b)(A), prior to the completion of a temperature TMDL, each NPDES point 

source that discharges into a temperature water quality limited water is allowed a "Human Use 

Allowance". Each point source may cause the temperature of the water body to increase up to 0.3 

degrees Celsius above the applicable criteria after mixing with either twenty five (25) percent of the 

stream flow, or at the edge of the mixing zone, whichever is more restrictive. In Woodburn's case, the 

mixing zone is limited to mixing with 25 percent of the stream flow so both criteria above are equivalent. 

Allowing for mixing with 25 percent of the stream under 7Q10 conditions, this discharge has a 

reasonable potential to violate the temperature standard (See attachment 4). Therefore, an Excess 

Thermal Load (ETL) limit must be included in this permit. The proposed limit is 9.2 million kcals per 

day as a weekly average. 

The City may not be able to consistently comply with the proposed excess thermal load limit. The permit 

includes a schedule of improvements the permittee must complete as necessary to comply with the 

temperature standard. 

Winter Period 

The Department's List of Water Quality Limited Water Bodies (also called the 303(d) List) for 2002 

indicates the Pudding River is not water quality limited for temperature during the winter. In order to 

protect cold water, a point source may not increase the stream temperature (at the point of maximum 

impact) by more than 0.5 degrees Celsius above the ambient temperature (OAR 340-041-0028(1 l)(b)). 

Based on the existing discharge (existing facility design flow and maximum effluent temperatures), the 

Department calculated in-stream temperature increases based on the stream's 7Q10 flow (see 

Attachment #3-4), Because the in-stream temperature increase is significantly smaller than the 

allowable increase, this facility has no reasonable potential to violate the temperature standard. 

Therefore, an Excess Thermal Load limit has not been included in this permit. 

The above summer period limit is considered interim and the permit may be reopened and the thermal 

load limit adjusted up or down when more accurate temperature or dilution data becomes available. If 

PAGE 9 
City of Woodburn NPDES Renewal Evaluation Report 

the temperature TMDL for this sub-basin assigns a WLA to this source, this permit may be re-opened to 

establish new thermal load limits and/or new temperature conditions or requirements. 

Fecal Bacteria Issues 

As stated, fecal bacterial levels exceed the standard year-round but no TMDL has been developed. The 

NPDES Permit represents the Bacteria Control Management Plan for the City of Woodburn. As long as 

the discharge remains in compliance with the permit's bacteria limits, the treated effluent discharge will 

not have a negative impact on the water quality of the Pudding River with respect to bacteria. The 

sewage collection system (including portions not owned by the City) has experienced a few raw sewage 

overflows during this permit cycle. These overflows have contributed an unknown amount to the 

violations of the fecal bacteria standard. 

If the bacteria TMDL for this sub-basin assigns a WLA to this source, this permit may be re-opened to 

establish new bacteria limits and/or new bacteria conditions or requirements. 

DDT Issues 

The TMDL to be issued in 2006 will address this pollutant but it is not likely this discharge is a 

significant source of these pollutants. However, the Department has little information concerning the 

discharge of these pollutants under this permit. Therefore, the proposed pennit includes the pesticide 

fraction in the monitoring requirement for priority pollutants in Schedule B. If the TMDL for toxic 

pollutants in this sub-basin assigns a WLA to this source, this permit may be re-opened to establish new 

limits on toxic pollutants and/or new toxic pollutant conditions or requirements. 

The Department is not aware of any other water quality violations that may be attributable to this source. 

A future TMDL will determine the corrective actions necessary to bring the Pudding River back into 

compliance. That TMDL may assign one or more pollutant WLA to this point source discharge. This 

permit may be reopened to incorporate any WLA. 

PERMIT HISTORY 

Previous Permit Actions 

NPDES Permit #101558 was issued by the Department on March 31, 1998, The Permit was modified on 

August 5, 1999 to substitute a better description of the Whole Effluent Toxicity (WET) testing protocol. 

The Permit expired on February 28, 2003, A renewal application was received on September 6,2002 and 

the permit shall not be deemed to expire until final action has been taken on the renewal application. 

The March 31, 1998 permit established CBOD5 and TSS concentration and mass limits that vary between 

summer and winter seasons. Limits were also established for CBOD5 and TSS removal efficiency, pH, 

E. coli bacteria and total chlorine residual. During the TMDL period (June through November), there are 

daily maximum limits for CBOD5 and TSS concentration, dissolved oxygen and ammonia. A mixing 

zone and Zone of Immediate Dilution (ZID) was included, 

Two treated effluent outfalls (001A and 00IB) are identified along with two reclaimed water outfalls 

(002 for Level III reuse). Three emergency overflow points were identified. 

An Antidegradation Review was completed with a recommendation to proceed with this permit action 

(see Attachment #5). 

PAGE 10 
City of Woodburn NPDES Renewal Evaluation Report 

Existing Permit Limits 

Schedule A contains the effluent limits for the treatment facility. Some limits are dependent upon the 

season (summer and winter) or month while others are year-round. The existing permit limits are as 

follows: 

Outfall 001 - Treated Effluent 

(1) May 1 -

Parameter 

CBOD5 

TSS 

October 3 1: 

Average Effluent 

Concentrations 

Monthly Weekly 

10 mg/L 15 mg/L 

10 mg/L 15 mg/L 

Monthly 

Average 

lb/day 

420 

420 

Weekly 

Average 

lb/day 

630 

630 

Daily 

Maximum 

lbs 

830 

830 

(2) Novemt 

Parameter 

CBOD5 

TSS 

>er 1 - April 30: 

Average Effluent 

Concentrations 

Monthly Weekly 

25 mg/L 40 mg/L 

30 mg/L 45 mg/L 

Monthly 

Average 

lb/day 

940 

1100 

Weekly 

Average 

lb/day 

1400 

1700 

Daily 

Maximum 

lbs 

1900 

2200 

(3) Other Parameters (year-round) 

Parameters 

E. coli Bacteria 

pH 

CBOD5 and TSS Removal Efficiency 

; 

Limitations 

Shall not exceed 126 organisms per 100 mL monthly 

geometric mean. No single sample shall exceed 406 

organisms per 100 mL 

Shall not be outside the range of 6.0 - 9.0 for more than 

a total of 7 hours and 26 minutes in any calendar 

month; and no individual excursion from this range 

shall exceed 60 minutes 

Shall not be less than 85% monthly average, 

(4) Other Parameters (June 1 - October 31): 

Parameters 

CBOD5 and TSS 

Dissolved Oxygen 

Ammonia-N 

Limitations 

Shall not exceed 2.0 mg/L daily maximum 

Shall not be less than 6.5 mg/L as a daily average 

There are 90 separate ammonia limitation ranging from 

0,1 mg/L to 10 mg/L based on month, effluent flow and 

river flow 

Schedule A also defines the mixing zone, prohibits discharge of chlorine, includes requirements and 

limits for the beneficial reuse of Level (II reclaimed water and restricts discharges from the emergency 

overflow outfalls. 

Compliance History 

This facility was last inspected December 4, 2003 and was found to be operating in compliance with the 

permit. The following Notices of Noncompliance (NON) have been issued for violations documented at 

this facility during this permit cycle: 

PAGE II 
City of Woodburn NPDES Renewal Evaluation Repor t 

Date of 

Enforcement Action 

November 24, 1998 

September 10, 1998 

Type of 

Enforcement Action 

Class 2 NON 

Class 2 NON 

Description of Violation mwmMi$M$ 

Failure to monitor ammonia or nutrients 

Three Class 2 violations and one Class 3 violations 

for exceeding permit limits 

NON's are informal enforcement actions. Formal enforcement actions include Notice of Permit 

Violation (NPV), Civil Penalties (CP) and administrative orders. The City was issued a NPV on 

February 17, 1999 for the permit violations listed above and some that occurred during the previous 

permit cycle. The City responded to the NPV with an appropriate corrective action schedule. 

On October 20, 1992, the City was issued Stipulation and Final Order (SFO) #WQMW-WVR-92-258 

that established a plan and schedule for coming into compliance with the Waste Load Allocation (WLA) 

established by the Pudding River Total Maximum Daily Load (TMDL) for dissolved oxygen. The SFO 

contained interim discharge limitations that the facility could meet until the new facilities were 

completed. 

The SFO required the City to be in compliance with the TMDL established for the Pudding River and the 

acute and chronic criteria for toxic substances two months after start up of the Phase I nitrification 

process. The SFO was terminated 60 days after full compliance was achieved in 2001, 

The above violation or violations are considered to be minor and/or have been corrected. Therefore, the 

Department considers this facility to be in substantial compliance with the terms of the current permit. 

There is no record of any complaints about this facility. 

PERMIT LIMITATIONS 

Two categories of effluent limitations exist for NPDES permits: 1) Technology based effluent limits, and 

2) Water quality based effluent limits. Technology based effluent limits have been established by EPA 

rales. Technology based effluent limits were established to require a minimum level of treatment for 

industrial or municipal sources using available technology. Water quality based effluent limits are 

designed to be protective of the beneficial uses of the receiving water and are independent of the 

available treatment technology, 

In addition, when performing a permit renewal, there are existing permit limits (discussed above). These 

may be technology-based limits, water quality-based limits, or limits based on best professional 

judgment. When renewing a permit, the most stringent of technology-based, water quality-based, and 

existing effluent limits must be applied. 

Technology-Based Effluent Limits 

EPA has established secondary treatment standards for domestic wastewater treatment facilities. The 

standards are found in 40 CFR Part 133. This facility must achieve a biochemical oxygen demand 

(BOD5) monthly average of 30 mg/L and a weekly average of 45 mg/L or a carbonaceous biochemical 

oxygen demand (CBOD5) monthly average of 25 mg/L and a weekly average of 40 mg/L. The facility 

must also achieve a suspended solids (TSS) monthly average of 30 mg/L and a weekly average of 45 

mg/L. The pH must be between 6.0 and 9,0. In addition, the facility must remove at least 85% of the 

influent CBOD5 and TSS, 

PAGE 12 
City of Woodburn NPDES Renewal Evaluation Report 

Oregon Administrative Rules establish minimum design criteria for domestic treatment facilities. In the 

Willamette Basin, the CBOD5 and TSS minimum design criteria is 10 mg/L as a monthly average in the 

summer period and secondary treatment in the winter period. In addition, there are requirements for 

disinfection and dilution of oxygen demanding pollutants. 

Water Quality-Based Effluent Limits 

Pollutant parameters should be limited if there is a reasonable potential for the discharge to cause or 

contribute to an excursion above any state water quality criteria or standard. The future TMDLs may 

assign additional WLAs to this source to address in-stream violations of water quality criteria. 

The Department is required to determine whether the discharge has the reasonable potential to cause or 

contribute to an exceedance of a water quality criterion. EPA has developed a method to make this 

determination for toxic pollutants called a reasonable potential analysis (RPA). An RPA relies on 

statistical probability to determine the likelihood that a discharge will violate an instream criterion based 

on the effluent data, its variability, available dilution, and the receiving water background concentration. 

The Department has developed RPA spreadsheets that employ EPA's methodology. 

No RPA for chlorine was performed during this evaluation. No chlorine is used for disinfection of 

wastewater that is discharged from Outfalls 001A or 00IB. Ammonia during the summer TMDL period 

was extensively evaluated during the 1998 permit action and it was determined that the allowable 

ammonia discharge based on maintenance of instream dissolved oxygen was more stringent than the 

maximums based on toxicity for each flow scenario and season. 

An ammonia RPA was performed for the non-TMDL period (see Attachment #6a) for this permit 

action. The prior permit evaluation report assumed the non-TMDL period ammonia concentrations 

would be consistently below 10 mg/L. However, of the 94 ammonia results evaluated by the Department, 

the highest concentration was 22 mg/L, The RPA indicates this source has a reasonable potential to 

cause an excursion above the state water quality criteria. As a result, the Department is proposing to 

include ammonia limits for the non-TMDL period in the renewal permit 

A RPA for cyanide, metals and toxic organics was performed by evaluating effluent data in the DEQ 

spreadsheets. No organic compounds (including total phenols) were detected in the priority pollutant 

scans. Of the metal pollutants and cyanide, the RPA (see Attachment #6b) indicated that concentrations 

of copper, cyanide, lead, mercury, silver and zinc in the effluent could have a reasonable potential to 

cause an excursion above the state water quality criteria. 

Primarily, this was caused by the small number of in-stream tests performed by the Department and the 

detection levels of those tests. In most eases, the effluent concentration was near or even below the 

minimum detection level for that parameter. In addition, the upstream background concentrations were 

actually above the water quality criteria for several parameters (and were often based on the detection 

limit for that parameter). 

The Department proposes to include permit requirements for special monitoring of the effluent and 

receiving stream using a "clean" sampling method, an "ultra-clean" sampling method, EPA method 1669 

or any other method approved by the Department. Monitoring for mercury shall be conducted in 

accordance with EPA Method 1631. The special monitoring must be conducted on the effluent semiannually for at least two years. After 2 years, the permittee may discontinue special monitoring of the 

effluent unless otherwise notified in writing by the Department, The special monitoring of the receiving 

stream must be conducted semi-annually during 2005, 

PAGE 13 
City of Woodburn NPDES Renewal Evaluation Report 

After special monitoring is complete, the Department will perform a new RPA to determine if the 

discharge has a potential to cause or contribute to an excursion above the state water quality criteria. If 

there is a reasonable potential, the Department may modify the permit as necessary. 

PERMIT DRAFT DISCUSSION 

The proposed permit limits and conditions are described below. Refer to the proposed permit and the 

discussion above when reviewing this section. 

Face Page 

The face page provides information about the permittee, description of the wastewater, outfall locations, 

receiving stream information, permit approval authority, and a description of permitted activities, The 

permittee is authorized to construct, install, modify, or operate a wastewater collection, treatment, control 

and disposal system. Permits discharge of treated effluent to the Pudding River within limits set by 

Schedule A and the following schedules. All other discharges are prohibited. 

In accordance with OAR 340, Division 49 all permitted municipal wastewater collection and treatment 

facilities are to receive a classification based on the size and complexity of the systems. The Department 

has incorporated the classification of the collection and treatment systems into the NPDES discharge 

permit. The treatment system is considered a Class IV system while the collection system is considered 

Class III. Both systems were reevaluated to determine the appropriateness of the current classification 

for operator certification requirements (see Attachment #7), No changes are proposed to the system 

classifications. 

Schedule A, Waste Discharge limitations 

Schedule A contains the effluent limitations proposed for Outfall 001. In addition, there are conditions 

prohibiting raw sewage overflows, the use of chlorine for disinfection purposes and adverse impacts on 

existing or potential beneficial uses of groundwater. 

Outfalls 001A and 00IB - Treated Effluent 

The Department is generally proposing to retain the existing limits shown above with a few exceptions. 

The pH limit will become slightly more restrictive and the number of different ammonia limits during the 

TMDL period will be reduced. In addition, two new limits are being proposed. The new limitations will 

regulate the discharge of thermal load between May I and October 31 and the discharge of ammonia 

between November 1 and May 31 each year. 

CBOD5 and TSS concentration and mass limits 

No changes are being proposed to the existing limits. Below is a description of how they were calculated 

previously. Based on the Willamette Basin minimum design criteria, wastewater treatment resulting in a 

monthly average effluent concentration of 10 mg/L for Carbonaceous Biochemical Oxygen Demand 

(CBOD5) and TSS must be provided from May 1 through October 31, From November 1 through April 

30, a minimum of secondary treatment is required. Secondary treatment in Oregon is defined as a 

monthly average concentration limit of 30 mg/L for BOD5 or 25 mg/L for CBOD5 and 30 mg/L for TSS, 

The City is requesting to maintain its concentration and mass limits based on CBOD5 year-round. The 

Department is proposing concentration limits at least as stringent as the basin minimum design criteria. 

The proposed monthly average summer CBOD5 and TSS concentration limits are 10 mg/L with a weekly 

average limit of 15 mg/L. During the TMDL period (June 1 through October 31), the facility is also 

required to comply with CBOD5 and TSS daily maximum limits of 20 mg/L. The proposed monthly 

average winter CBOD5 concentration limits are 25 mg/L with a weekly average limit of 40 mg/L. The 

PAGE 14 
City of Woodbur n NPDES Renewa l Evaluatio n Report 

proposed monthly average winter TSS concentration limits are 30 mg/L with a weekly average limit of 

45 mg/L. 

In accordance with OAR 340-041-0061 (10)(b), the monthly and weekly average and daily maximum 

mass load limits for CBOD5 and TSS for new facilities should be calculated on the estimated capability 

of the treatment plant. Under this rule, the summer mass load limits for a new facility would be based on 

the 2 year recurrence high summer flow and the capability of the facility to treat the wastewater at that 

flow. The 2 year recurrence high summer flow was not determined but the design ADWF is 5.037 MGD. 

The 2 year recurrence high summer flow would be somewhat higher and the facility could consistently 

produce effluent with 10 mg/l of CBOD5 and TSS at those flows. 

However, this would result in discharge limits that would be higher than assigned waste load allocation 

based on 5,0 MGD. This could result in potential instream violations of dissolved oxygen (at some flow 

scenarios and particularly towards the end of the design life of the facility). Therefore, the mass loads 

may not exceed the WLA's assigned by the TMDL. 

The facility's proposed summer mass limits (monthly and weekly average and daily maximum) for 

CBODs and TSS are based on the waste load allocation flow of 5.0 MGD and the monthly average 

CBODj and TSS concentration limit of 10 mg/L, The mass load limitations are rounded to two 

significant figures. No changes are proposed for the summer mass limits. The summer calculations are: 

a) 5,0 MGD x 8.34 lbs/gal x 10 mg/L = 417 (420) lbs/day monthly avg. 

b) 417 lbs/day monthly avg x 1.5 = 625.5 (630) lbs/day weekly avg. 

c) 417 lbs/day monthly avg x 2 = 834 (830) lbs daily maximum 

The winter monthly and weekly average and daily maximum mass load limits for CBODs and TSS 

calculated in accordance with OAR 340-041 -0061 (10)(b) would also be based on the estimated capability 

of the treatment plant. The winter period mass load limits could be based on the design maximum month 

wet weather flow of 8.77 MGD and 25 mg/L and 30 mg/L for CBOD5 and TSS, respectively. The City 

chose not to request a mass load increase for winter mass loads during the last permit issuance. The City 

reserves the right to petition the EQC for an increase in accordance with OAR 340-041-0004(9) at some 

time in the future. 

For this permit renewal, the Department is proposing to retain the wintertime mass load limits based on 

the design AWWF of the previous RBC facility. The proposed winter mass load limits (monthly and 

weekly average and daily maximum) for CBOD5 and TSS have been based on 4.5 MGD and the monthly 

average concentration limits of 25 mg/L and 30 mg/L for CBOD5 and TSS, respectively. The mass load 

limitations are rounded to two significant figures. No changes are proposed for the winter mass limits. 

The winter calculations for CBODs are: 

a) 4.5 MGD x 8.34 lbs/gal x 25 mg/L = 938 (940) lbs/day monthly avg. 

b) 940 lbs/day monthly avg x 1.5 = 1410 (1400) lbs/day weekly avg. 

c) 940 lbs/day monthly avg x 2 = 1880 (1900) lbs daily maximum 

The winter calculations for TSS are: 

a) 4.5 MGD x 8.34 lbs/gal x 30 mg/L = 1126 (1100) lbs/day monthly avg. 

b) 1100 lbs/day monthly avg x 1.5 = 1650 (1700) lbs/day weekly avg. 

c) 1100 lbs/day monthly avg x 2 = 2200 lbs daily maximum 

In accordance with OAR 340-006110(a)(C), the daily mass load limit is suspended on any day in which 

the flow to the treatment facility exceeds 6.66 MGD (twice the design average dry weather flow of the 

PAGE 15 
City of Woodburn NPDES Renewal Evaluation Report 

Phase I facilities), A review of monitoring data (see Attachment #8) for the last two years indicate the 

City is generally able to comply with the permit limits. 

CBOD5 and TSS Percent Removal Efficiency 

A minimum level of percent removal for CBOD5 and TSS for municipal dischargers is required by the 

Code of Federal Regulations (CFR) secondary treatment standards (40 CFR, Part 133). An 85 percent 

removal efficiency limit is included in the proposed permit to comply with federal requirements, A 

review of monitoring data indicates the City should generally be able to comply with the CBOD5 and 

TSS removal efficiency limits, 

pH 

The current effluent limits for pH are 6.0 to 9,0 for the facility. This limit is in accordance with Federal 

wastewater treatment guidelines for sewage treatment facilities (in 40 CFR 133.102(c)) and is applied to 

the majority of NPDES permittee's in the state. The Willamette Basin water quality standards for pH are 

established in OAR 340-041-0345. The allowed ambient range is 6.5 to 8,5. Within the permittee's 

mixing zone, the water quality standard for pH does not have to be met. Previously, the Department 

believed that mixing with ambient water within the mixing zone would ensure that the pH at the edge of 

the mixing zone met the standard 

However, the Department used a new spreadsheet to evaluate the pH of the effluent mixed with ambient 

water within the mixing zone (see Attachment #9). Using 90'1' percentile high and low stream pH and 

the dilution achieved within the mixing zone, it was determined that a lower pH limit of 6.0 would not be 

protective of the water quality standard. Therefore, the Department is proposing new pH limits in this 

permit action. The proposed limits are 6.5 to 9.0, 

Monitoring for pH is continuous. When continuous monitoring is provided, the permit allows the 

discharge to be outside the allowed range for up to 1 percent (7 hours and 26 minutes) of any calendar 

month. No single excursion may last longer than one hour. The Department considers the proposed 

permit limits to be protective of the water quality standard. 

Fecal Bacteria 

The current permit contains limits on E. coli are based on the bacteria standard approved in January 

1996. The limits are a monthly geometric mean of 126 E. coli per 100 mL, with no single sample 

exceeding 406 E. coli per 100 mL. The new bacteria standard allows that if a single sample exceeds 406 

E. coli per 100 mL, then the permittee may take five consecutive re-samples. If the log mean of the five 

re-samples is less than or equal to 126, a violation is not triggered. The new rule states that the resamples should be taken at four hour intervals beginning as soon as practicable (preferably within 28 

hours) after the original sample was taken. 

No changes are proposed to the E. coli permit limits. The E. coli effluent limitations are achievable 

through proper operation and maintenance. 

Dissolved Oxygen 

The Pudding River TMDL assigned CBOD5 and ammonia WLA's based upon a minimum effluent 

dissolved oxygen concentration of 6.5 mg/l, The prior permit included a minimum effluent concentration 

limit for dissolved oxygen of 6.5 mg/L from June 1 through October 31 each year, The renewal permit 

proposes to continue this limit, 

Excess Thermal Load 

As discussed above, this facility has a reasonable potential to violate the temperature standard during the 

summer period. The calculated in-stream temperature increase has a reasonable potential to exceed the 

"Human Use Allowance" using dilution achieved in the mixing zone. Therefore, an Excess Thermal 

PAGE 16 
City of Woodburn NPDES Renewal Evaluation Report 

Load (ETL) limit must be included in this permit. The formula for calculating the ETL limit is as 

follows: 

ETL = 3.7%541QeSATCpp 

Where: 3,78541 = flow conversion from MGD to m'Vday 

Qe = effluent flow in MGD 

S = dilution in mixing zone 

AT = allowable temperature increase in °C 

Cp = specific heat of water (1 cal/g °C) 

p = density of water (1 g/cm") 

Therefore, the limit is; 

ETL = (3.78541)(5.0 MGD)(1,62)(0.3°C)(1.0cal/goC)(l,0g/cm3) = 9.2 Million Kcals/day 

The limit is applied as a weekly average from May 1 through October 31 each year. The ETL limit is 

considered interim and the permit may be reopened and the thermal load limit adjusted up or down when 

more accurate temperature or dilution data becomes available. If the Total Maximum Daily Load 

(TMDL) for temperature for this sub-basin assigns a Waste Load Allocation (WLA) to this source, this 

permit may be re-opened to establish new thermal load limits and/or new temperature conditions or 

requirements. 

The permittee may or may not currently have the ability to comply with the excess thermal load limit. 

Therefore, the Department is proposing to include a schedule of compliance in Schedule C of this permit, 

The City will have to comply with the new limit by no later October 31, 2009. 

The Excess Thermal Load limit may be adjusted if the Permittee chooses riparian improvements as a 

portion of their thermal reduction program. 

Ammonia 

Ammonia is a substance normally found in wastewater, The wastewater treatment processes, particularly 

aeration and biological treatment, can convert a large portion to nitrate and nitrite but the treated effluent 

still contains some ammonia. After discharge, the continued process of oxidizing the ammonia removes 

dissolved oxygen from the ambient water. As part of the Pudding River Total Maximum Daily Load 

(TMDL ammonia waste load allocations (WLA) were assigned to the City for various plant and stream 

flow scenarios. Compliance with the WLAs should ensure compliance with the dissolve oxygen 

standards. 

Unionized ammonia is also a toxic agent and may have to be limited to prevent toxicity. The water 

outside the boundary of the mixing zone must be free of materials in concentrations that will cause 

chronic (sublethal) toxicity while the water outside the ZID must be free of pollutants that will cause 

acute toxicity. 

The 1998 permit included ammonia limits based on the ammonia WLAs. A total of 90 separate permit 

limits were developed and compared with calculated limits based toxicity. In each case, the allowable 

ammonia discharge based on maintenance of instream dissolved oxygen was more stringent than the 

maximums based on toxicity. The Department proposes to retain these limitations except that the limits 

applicable to plant flows between 3,0 MGD and 3.5 MGD have been eliminated, When plant flows are 

within that range, the facility will have to comply with the more stringent limits that apply when plant 

PAGE 17 
City of Woodburn NPDES Renewal Evaluation Report 

flows are between 3,5 MGD and 4.0 MGD. No other changes are proposed to the ammonia limits during 

the TMDL period, 

At the time of the last permit issuance, it was assumed that the non-TMDL period ammonia levels would 

be consistently less than 10 mg/L. Ninety-four effluent ammonia concentration results from the nonTMDL period were reviewed. The highest concentration found was 22 mg/L. Using the critical case 

stream and Phase I effluent conditions and the estimated dilution factors for the non-TMDL period, the 

spreadsheet (see Attachment #6a) calculated that there was a reasonable potential for chronic toxicity 

due to ammonia, Once stream flows exceed 360 cfs, there is no reasonable potential for toxicity and no 

permit limit is needed (see Attachment #10). 

Therefore, the Department is proposing to include 3-tierecl effluent ammonia limits for the non-TMDL 

period in this permit renewal. Using the same critical case stream and effluent conditions and estimated 

dilution factors, new end-of-pipe limits based on the criteria were calculated (sec Attachments #lla and 

#llb). The current permit does not contain a limit on ammonia during the non-TMDL period. The water 

quality based limit is the most restrictive permit limit. The Department is proposing to include the 

following 3-tiered water quality based limits in the permit for the period of November 1 through May 31 

each year: 

lEarairieter. •" 

Ammonia-N (November 1 through May 31 when 

monthly average stream flow is less than 200 cfs) 

Ammonia-N (November 1 through May 31 when 

monthly average stream flow is equal to or 

greater than 200 cfs but less than 360 cfs) 

Ammonia-N (November 1 through May 31 when 

monthly average stream flow is equal to or 

greater than 360 cfs) 

Limitations 

Shall not exceed a monthly average concentration 

of 5.7 mg/L and a daily maximum concentration 

of 13 mg/L (see Note 3) 

Shall not exceed a monthly average concentration 

of 9.6 mg/L and a daily maximum concentration 

of 22 mg/L (see Note 3) 

No limitation 

The ammonia criteria currently in Table 20 are based on EPA's Quality Criteria for Water (1986), which 

is also known as the "Gold Book" criteria. The criteria for ammonia is both pH and temperature 

dependant. The state of Oregon has adopted the newer EPA 1999 criteria for ammonia. The EPA 1999 

acute criterion is also pH dependant and the chronic criterion is both pH and temperature dependant, 

Effluent limitations based on the 1999 criteria were also calculated (see Attachments #lla and #llb). 

The proposed limits are: 

Parameter 

Ammonia-N (November 1 through May 31 

when monthly average stream flow is less 

than 200 cfs) 

Ammonia-N (November 1 through May 31 

when monthly average stream flow is 

equal to or greater than 200 cfs but less 

than 360 cfs) 

Ammonia-N (November 1 through May 31 

when monthly average stream flow is 

equal to or greater than 360 cfs) 

Limitations 

Shall not exceed a monthly average concentration of 

20 mg/L and a daily maximum concentration of 45 

mg/L 

Shall not exceed a monthly average concentration of 

27 mg/L and a daily maximum concentration of 60 

mg/L 

No limitation 

PAGE 18 
City of Woodburn NPDES Renewal Evaluation Report 

The ammonia limits calculated using the EPA Gold Book Criteria are considered interim limits. The 

Department proposes to include final effluent ammonia limitations which are to be effective upon EPA 

approval of the revised water quality toxics criteria for ammonia, 

A file review of effluent monitoring data shows that the ammonia concentrations occasionally exceed 

these limits. The permittee may or may not currently have the ability to reduce ammonia levels in the 

discharge to reduce potential toxic effects on the receiving stream. Therefore, the Department proposes 

to include a schedule of compliance in Schedule C of this permit. The City will have to comply with the 

new limit by no later October 31, 2009, 

Mixing Zone 

The current permit provides for a mixing zone that consists of that portion of the Pudding River 

extending from a point ten (10) feet upstream of Outfall 001A to a point three hundred (300) feet 

downstream from the outfall. The Zone of Immediate Dilution (ZID) is defined as that portion of the 

allowable mixing zone that is within thirty (30) feet of the point of discharge. 

The effluent plume likely mixes with more than 25 percent of the receiving stream prior to 300 feet 

downstream while Outfall 001B is located less than 300 feet downstream from Outfall 001A, Therefore, 

the Department is proposing to revise the existing mixing zone. In order to avoid overlapping mixing 

zone, the Department proposes to reduce the size of the mixing zone to that portion of the Pudding River 

where the effluent mixes with 25 percent of the stream flow but in no case shall it extend farther than ten 

(10) feet upstream of the outfall to a point two hundred (200) feet downstream from the outfall. The Zone 

of Immediate Dilution (ZID) shall be defined as that portion of the allowable mixing zone that is within 

twenty (20) feet of the point of discharge, The new mixing zone is applied to each outfall. 

Chlorine 

The facility uses ultraviolet light to disinfect the treated wastewater prior to discharge. The permit 

prohibits the use of chlorine as a disinfecting agent and states that no chlorine residual shall be allowed 

in the discharged effluent due to chlorine used for maintenance purposes. 

Outfall 002 

The proposed NPDES Permit allows the treatment facility to continue land application of treated and 

disinfected Level III reclaimed water to the poplar plantation (Outfall 002). The utilization of treated 

effluent for agricultural purposes is regulated under OAR 340-055. 

Irrigation must be in accordance with the limits in Schedule A, Condition l.b. Prior to irrigation of the 

reclaimed water, the discharge must comply with total coliform limits based on protection of human 

health due to human pathogens. For Level III reclaimed water, the limits include a weekly median of 2.2 

total coliform per 100 mis with no more than 23 organisms per 100 mis in any sample. 

The application of reclaimed water must be managed in accordance with the approved Reclaimed Water 

Use Plan, All reclaimed water shall be distributed on land, for dissipation by evapotranspiration and 

controlled seepage by following sound irrigation practices so as to prevent: 

Prolonged ponding of treated reclaimed water on the ground surface. 

Surface runoff or subsurface drainage through drainage tile. 

The creation of odors, fly and mosquito breeding or other nuisance conditions. 

The overloading of land with nutrients, organics, or other pollutant parameters. 

Impairment of existing or potential beneficial uses of groundwater. 

PAGE 19 
City of Woodburn NPDES Renewal Evaluation Report 

Specific crops, application rates and buffers are approved by the Department within the Reclaimed Water 

Use Plan. The bacterial effluent limitations are achievable through proper operation and maintenance. 

Outfalls 003 through 005 (Emergency Overflows) 

The permit identifies three emergency overflow points. The City has experienced infrequent raw sewage 

overflows from the sewage collection system. Schedule A contains a condition prohibiting discharges 

from these outfalls unless the cause of the overflow is a large storm event in accordance with OAR 340-

041-0009(6) and (7). 

Groundwater 

Based on the Department's current information, this facility has a low potential for adversely impacting 

groundwater quality. Therefore, the permit includes a condition in Schedule A that prohibits any adverse 

impact on groundwater quality. In addition, Schedule D of the proposed permit states that no 

groundwater evaluations will be required during this permit cycle, 

Schedule B - Minimum Monitoring and Reporting Requirements 

Schedule B describes the minimum monitoring and reporting necessary to demonstrate compliance with 

the conditions of this permit. The authority to require periodic reporting by permittees is included in 

ORS 468,065(5), Self-monitoring requirements are the primary means of ensuring that permit limitations 

are being met, However, other parameters need to be monitored to collect information when insufficient 

information exists to establish a limit, but where there is a potential for a water quality concern. 

In 1988, the Department developed a monitoring matrix for commonly monitored parameters. The 

matrix was updated in 2004, Proposed monitoring frequencies for all parameters are based on this matrix 

and, in some cases, may have changed from the current permit. The proposed monitoring frequencies for 

all parameters correspond to those of facilities of similar size and complexity in the state. 

The permittee is required to have a laboratory Quality Assurance/Quality Control program. The 

Department recognizes that some tests do not accurately reflect the performance of a treatment facility 

due to quality assurance/quality control problems. These tests should not be considered when evaluating 

the compliance of the facility with the permit limitations. Thus, the Department is also proposing to 

include in the opening paragraph of Schedule B a statement recognizing that some test results may be 

inaccurate, invalid, do not adequately represent the facility's performance and should not be used in 

calculations required by the permit, 

Below is a discussion of some of the minimum monitoring requirements contained in the proposed 

permit: 

Influent and Outfall 001 (Treated Effluent) 

Daily monitoring of influent and effluent flow and calibration of the flow meters every six months is 

retained in this permit. 

The City has requested that all BODs effluent limits (concentration, mass and percent removal) be 

changed to CBOD5. Monitoring of the influent and effluent for CBOD5 and TSS is retained at twice per 

week. Pounds of effluent CBOD5 and TSS must be calculated at the same frequency. Ammonia 

monitoring is required year-round both because CBOD5 replaces BOD5 and to determine compliance 

with ammonia limits. Monitoring must be performed on the same samples as CBOD5 so twice per week 

monitoring frequency is proposed. 

PAGE 20 
City of Woodburn NPDES Renewal Evaluation Report 

Federal secondary treatment standards require municipal sources to achieve a specific CBOD5 and TSS 

removal efficiency as a monthly average. Reporting of the removal efficiencies is required in the current 

permit and no changes are proposed, 

The proposed permit requires monitoring of the effluent for UV Radiation Intensity on a daily basis to 

confirm consistent performance of the disinfection system. Bacteria monitoring of the effluent for E. coli 

has been retained at twice per week. Monitoring for E. coli must be performed in accordance with one of 

the methods approved by the Department. Monitoring of the influent and effluent for pH has been 

retained at three times per week. 

In order to fully characterize the facility's contribution of nutrients to the receiving stream, the 

Department is proposing to require monitoring of the treated effluent for nutrients, Weekly monitoring 

of Total Kjeldahl Nitrogen (TKN), nitrate plus nitrite and total phosphorus is proposed for the period 

from May through October each year. 

The current permit required the City to monitor the effluent for dissolved oxygen twice per week from 

May through October. The proposed permit includes a requirement to continue this monitoring. 

Continuous temperature monitoring of the effluent is required year round. In addition, the permittee will 

be required to calculate the weekly average of the daily maximum effluent temperatures and the weekly 

average excess thermal load discharged from May through October. These are new requirements. 

The current permit required the City to monitor the influent and effluent for 11 metals and cyanide semiannually for three consecutive days. The proposed permit continues this monitoring requirement. 

Monitoring results are to be submitted in the annual pretreatment report and are not required to be 

submitted with the monthly DMR. 

The permittee must perform "priority pollutant" scans in order to complete Part D of EPA Form 2A for 

the next renewal application. Three scans are required during the 4 Vi years after permit issuance, Two 

of the three scans must be performed no fewer than 4 months and no more than 8 months apart. As stated 

above, the proposed pennit requires that the pesticide fraction be included in the monitoring of priority 

pollutants. 

The Department has required annual whole effluent toxicity (WET) tests using three species in the 

proposed permit. If the results of the first four tests show that the effluent is not toxic, no further WET 

testing will be required during this permit cycle, WET tests are to be conducted in accordance with EPA 

test methods and procedural requirements as defined in Schedule D, 

For the first two years after permit issuance, the City must perform special toxics monitoring for copper, 

cyanide, lead, mercury, silver and zinc in the effluent. The special toxics monitoring shall be conducted 

using a "clean" sampling method, an "ultra-clean" sampling method, EPA method 1669 or any other test 

method approved by the Department with a detection limit of 0.1 ug/L or less. Monitoring for mercury 

shall be conducted in accordance with EPA Method 1631. The effluent shall be sampled for hardness 

when metals are sampled. 

After two years, the City may eliminate the special monitoring of the effluent unless otherwise notified 

by the Department, The Department will base its determination upon the ability of the permittee to 

consistently comply with the water quality criteria. 

PAGE 2: 
City of Woodburn NPDES Renewal Evaluation Report 

Biosolids 

OAR 340, Division 50, "Land Application of Domestic Wastewater Treatment Facility Biosolids, 

Biosolids Derived Products, and Domestic Septage" requires monitoring and reporting of specific sludge 

parameters under Section 35, These parameters are identified in Schedule' B under "Biosolids 

Management" and include: Total solids, Volatile solids, Nitrogen, eleven metals (Ag, As, Cd, Cr, Cu, 

Pb, Hg, Mo, Ni, Se & Zn), Phosphorus, Potassium and pH, 

In order to demonstrate compliance with pathogen reduction requirements, the proposed permit requires 

monitoring of the duration and temperature of biosolids digestion, In order to demonstrate compliance 

with vector attraction requirements, the proposed permit requires monitoring of volatile solids reduction. 

The City must also record information about the beneficial use of biosolids that are land applied. 

Outfall 002 (Reclaimed Water) 

The proposed permit includes monitoring of the reclaimed water for volume, chlorine used and residual, 

pH, nutrients and total coliform. When irrigating Level III reclaimed water, the monitoring frequency for 

total coliform is three times per week, All monitoring frequencies are in accordance with Department 

rules and guidance. Schedule B also requires an annual report describing the effectiveness of the 

reclaimed water system. 

Outfalls 003 through 005 (Emergency Overflows) 

The estimated duration and volume of each overflow from the emergency outfalls must be recorded. 

There is no change in this requirement except for the deletion of one overflow point and the addition of 

six new overflow points. 

Receiving Stream 

The Department does not have adequate information on the background concentration of certain metals 

in the Pudding River and cannot perform a complete reasonable potential analysis. For the first year after 

permit issuance, the City must perform special toxics monitoring for copper, cyanide, lead, silver and 

zinc in the receiving stream. The special toxics monitoring shall be conducted using a "clean" sampling 

method, an "ultra-clean" sampling method, EPA method 1669 or any other test method approved by the 

Department with a detection limit of 0.1 pg/L or less. The receiving stream shall be sampled for 

hardness when metals are sampled. After one year of this special toxics monitoring, the requirement to 

monitor the receiving stream will be eliminated. 

Reporting 

The reporting period is the calendar month. Discharge monitoring reports must be submitted to the 

Department monthly by the 15th day of the following month. The monitoring reports need to identify the 

principal operators designated by the Permittee to supervise the treatment and collection systems. The 

reports must also include records concerning application of biosolids and all applicable equipment 

breakdowns and bypassing. 

Schedule B of the permit includes the requirement for the submittal of four annual reports. The 

conditions are standard language requirements concerning: 

Annual report which details progress towards reducing inflow and infiltration 

Annual report of solids handling activities if biosolids are land applied 

Annual report on the effectiveness of the reclaimed water system 

Annual report on temperature monitoring results 

PAGE 22 
City of Woodburn NPDES Renewal Evaluation Repor t 

Schedule C, Compliance Schedules and Conditions 

The permit contains four compliance conditions with deadlines: 

1, Within 180.days of permit issuance, the permittee must submit an updated program and time 

schedule for identifying and reducing inflow. 

2. Within 90 days after permit issuance, the permittee must submit a report which identifies known 

sewage overflows. 

3, By no later than June 30, 2005, the permittee must submit for Department approval a plan and 

schedule to provide redundant power to two lift stations. 

4. The permittee must evaluate the alternatives necessary to comply with the new winter period 

ammonia limit and the new excess thermal load limit. All improvements must be completed by no 

later than October 31, 2009. 

The final condition requires the permittee to meet the compliance dates established in this schedule or 

notify the Department within 14 days following any lapsed compliance date. 

Schedule D - Special Conditions 

The permit contains eight special conditions. The requirements include: 

1. Schedule D of this permit includes conditions requiring biosolids be managed in accordance with 

the approved biosolids management plan. All new biosolids application sites must meet the site 

selection criteria. Sludge may be disposed of in a Department approved landfill. 

2, The permit may be modified to incorporate changes in federal biosolids standards. 

3. The requirements for Whole Effluent Toxicity (WET) testing are specified. 

4. Schedule D includes a condition requiring the permittee to comply with the rules concerning the 

use of reclaimed water and the Reclaimed Water Use Plan approved by the Department. 

5, A condition is included in Schedule D that requires the permittee to keep a cover crop on the 

irrigation site at all times unless otherwise approved by the Department in the Reclaimed Water 

Use Plan, The Department has approved the City's Plan to grow poplar trees. 

6. The permittee must have the facilities supervised by personnel certified by the Department in the 

operation of treatment and/or collection systems. 

7, The permittee must notify the Department of malfunctions, 

8, The permittee shall not be required to perform a hydrogeologic characterization or groundwater 

monitoring due during the term of this permit. 

Schedule E - Pretreatment 

The current permit contains a Schedule E which requires the City to conduct and enforce an industrial 

waste pretreatment program as approved by the Department and the General Pretreatment Regulations 

(40 CFR Part 403), The Department is proposing to include similar but updated conditions in the new 

permit, 

PAGE 23 
City of Woodburn NPDES Renewal Evaluation Repor t 

Schedule F, NPDES General Conditions 

All NPDES permits issued in the State of Oregon contain certain conditions that remain the same 

regardless of the type of discharge and the activity causing the discharge, These conditions are called 

General Conditions. These conditions can be changed or modified only on a statewide basis, The latest 

edition of the NPDES General Conditions is December 1, 1995 and this edition is included as Schedule F 

of the draft permit. 

Section A contains standard conditions which include compliance with the permit, assessment of 

penalties, mitigation of noncompliance, permit renewal application, enforcement actions, toxic 

discharges, property rights and referenced rules and statutes. Section B contains requirements for 

operation and maintenance of the pollution control facilities. This section includes conditions for proper 

operation and maintenance, duty to halt or reduce activity in order to maintain compliance, bypass of 

treatment facilities, upset conditions, treatment of single operational events, overflows from wastewater 

conveyance systems and associated pump stations, public notification of effluent violation or overflow, 

and disposal of removed substances. Section C contains requirements for monitoring and reporting. This 

section includes conditions for representative sampling, flow measurement, monitoring procedures, 

penalties of tampering, reporting of monitoring results, additional monitoring by the permittee, averaging 

of measurements, retention of records, contents of records, and inspection and entry. Section D contains 

reporting requirements and includes conditions for reporting planned changes, anticipated 

noncompliance, permit transfers, progress on compliance schedules, noncompliance which may endanger 

public health or the environment, other noncompliances, and other information. Section D also contains 

signatory requirements and the consequences of falsifying reports. Section E contains the definitions 

used throughout the permit. 

PERMIT PROCESSING/PUBLIC COMMENT/APPEAL PROCESS 

The beginning and end date of the public comment period to receive written comments regarding this 

permit, and the contact name and telephone number are included in the public notice. The permittee is 

the only party having standing to file a permit appeal. If the Permittee is dissatisfied with the conditions 

of the permit when issued, they may request a hearing before the EQC or its designated hearing officer, 

within 20 days of the final permit being mailed. The request for hearing must be sent to the Director of 

the Department. Any hearing held shall be conducted pursuant to regulations of the Department, 

PAGE 24 
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Attachment 2 

September 2004 

Biosolid Management Plan 

for 

The City of Woodburn 

File Number: 98815 

Permit Number: 101558 

I. Treatment Facility 

Introduction: 

The City of Woodburn (population approximately 23,000) owns and operates a municipal sewage 

collection and treatment system under National Discharge Elimination System (NPDES) permit 

number (101558). Wastewater processed by the sewage treatment works is principally of domestic 

origin. Phase I of the new activated sludge secondary treatment facility was placed into operation in 

June 2001. Septage is accepted at this wastewater treatment facility. Treated effluent from the 

treatment plant is discharged to the Pudding River, in Marion County, Oregon, 

The City of Woodburn implements a Department approved industrial pretreatment program, In 2003, 

the City permitted 6 significant industrial users (SIUs) including 1 categorical industrial user; 3 

significant industrial users, and 2 non-discharging categorical industries, 

A) Wastewater Processing: 

Woodburn operates a selector activated sludge plant with anaerobic digesters. The designed average 

dry weather flow of Phase I is 3.33 million gallons per day (MGD) Influent passes through the 

headworks with two mechanical bar screens, screenings compactor, two grit chambers and cyclone 

grit separator. From the headworks, flow enters two primary clarifiers (170,000 gallons (gal.) each) 

prior to entering two, anoxic selector activated sludge aeration basins, The aeration basins are 

930,000 gal, each. From the activated sludge basins mixed liquor is transferred to three secondary 

clarifiers (158,000 gal.) each. Two continuous backwash filters filter clarified effluent. Filtered 

effluent is directed to ultra-violet disinfection and discharged to Pudding River at river mile 21.4. 

A percentage of the solids from the secondary clarifiers are returned to the activated sludge basins and 

a percentage is wasted to the anaerobic digesters, The activated sludge is pre-thickened to about 5% 

solids in two dissolved air flotation-thickening units prior to pumping into a 12,000-gallon sludge 

blend tank. From the blend tank sludge is routed to two primary anaerobic digesters (digester #1 is 

48,400 gallons and digester #2 is 45,200 gallons. In Phase II of construction digester #3 will be 

73,900 gallons). At the maximum months sludge loading the digester detention time is 21 days, 

B) Solids Processing: 

Woodburn's treatment works produces solids utilizing primary clarifiers, activated sludge, and 

septage, All three sewage solid types are blended together in a blend tank before pumping to primary 

digesters. Digester sludge under goes a minimum mean cell residence time of between 15 and 60 days 

at a minimum temperature between 35 and 55 degrees centigrade. After treatment and prior to 

removal from the digester volatile solids reduction calculations are performed. 
September 2004 

City of Woodburn 

Biosolid Management Plan 

Page 2 of 10 

Four (4) potential end routes for biosolids include: 

1) Biosolids removed from the anaerobic digester, 

2) Biosolids from the facultative sludge storage lagoons, 

3) Biosolids from the air-drying beds, and 

4) Biosolids from Static aerated pile compost 

C) Solids Storage Structure: 

Primary digested solids are stored in two, two and a half acre facultative sludge lagoons (total 

gallons of about 24,400,000.) Solids are stored in the lagoons for an average of three years prior 

to removal. Solids are dredged from the lagoon and either dried in sludge drying beds and land 

applied as a solid, or applied directly to the poplar tree reuse system as a liquid. Solid application 

is by spreader truck or manure spreader and liquid application is by a self-retrieving hose reel or 

tractor pulled liquid field spreaders, 

D) Septage Receiving Facility: 

Septage from Clackamas and Marion County pumpers are received at the Woodburn wastewater 

treatment facility. All septage is processed using a lakeside septic treatment system employing a 

fine screen, screw conveyer, dewatering screw and screen press. The facility has a 7000 gallon 

twin-cell holding tank system. 

F) Pretreatment Program: 

The City has a Department approved industrial wastewater pretreatment program that complies 

with all CFR403 requirements, Enforcement of pretreatment standards has produced a biosolid 

with low metal concentrations compared to the EPA 40CFR Part 503 biosolid standards. 

II Solid Treatment Processes 

The Code of Federal Regulations (CFR) Part 503 and DEQ's OAR340-50 allow permittees to use 

EPA approved alternatives to satisfy Class A and B biosolids pathogen and vector attraction 

reduction criteria. The permittee must notify the Department in writing and get approval prior to 

any process change that would utilize pathogen reduction or vector attraction reduction 

alternatives other than their primary reduction alternatives contained in this management plan. 

The permittee must also certify that the alternatives used are EPA approved and that sampling and 

monitoring conforms to the 40 CFR 503 and OAR 340-050 regulations. 

Pathogen Reduction 

The City is required to meet pathogen reduction before or at the same time as vector attraction 

reductions and comply with CFR Part 503, 
September 2004 

City of Woodburn 

Biosolid Management Plan 

Page 3 of 10 

Class A Biosolids 

Class A alternatives require microbial monitoring for fecal coliforms or Salmonella sp, as 

described in sections A and B below. This management plan describes the primary alternatives 

and options employed by the permittee to meet Class A and B biosolids criteria. 

A) Monitoring for Fecal Coliform or Salmonella sp. 

Monitoring for Fecal Coliform or Salmonella sp, is required to detect the growth of bacterial 

pathogens. Because Class A biosolids may be used without site restrictions, all Class A 

material must be tested to show that microbial requirements are met at the time when it is 

ready to be used, disposed, sold or given away. In addition to meeting process requirements, 

Class A biosolids must meet one of the following requirements: 

• Either the density of the fecal coliforms in the biosolids be less than 1,000 MPN per 

gram total solids (dry gram weight), 

t Or the density of Salmonella sp. Bacteria in the biosolids be less than 3 MPN per 4 

grams of total solids (dry weight basis). 

Unlike Class B biosolids, Class A requirements are not based on an average value. Sampling 

for Class A biosolids consists of at least seven (7) discrete samples taken over a 2-week 

period. Test results are required before Class A material is released for use or disposal. The 

microbial requirement that a Class A biosolids must meet is either: 

At the time of use or disposal, or 

At the time the biosolids are prepared for sale or given away in a bag or other 

container for land application, or 

• At time the biosolid or material derived from the biosolid is prepared to meet the 

requirements in 503.10(b), 503.10 (c), 503.10 (e) or 503.10 (f). 

B) Class A Pathogen Reduction Alternatives 

Alt. 3) Sewage Sludge treated in known Processes 503.32(a) (5) 

This requirement relies on comprehensive monitoring of bacteria, enteric viruses and viable 

helmith ova to demonstrate adequate reduction of pathogens: 

• Either the density of the fecal coliforms in the sewage sludge is less than 1,000 MPN 

per gram total solids (dry gram weight), Or the density of Salmonella sp. Bacteria in 

the sewage is less than 3 MPN per 4 grams of total solids (dry weight basis). 

• The density of enteric viruses in the sewage sludge must be tested prior to pathogen 

reduction treatment and then again after pathogen treatment at which time the enteric 

viruses must be less than 1 PFU per 4 grams of total solids (dry weight basis). 

• Testing for the density of viable helmith ova in the sewage sludge must occur before 

pathogen reduction treatment and then again, after pathogen treatment. The final test 

for viable helmith ova must be less than 1 PFU per 4 grams of total solids (dry weight 

basis). 
September 2004 

City of Woodbum 

Biosolid Management Plan 

Page 4 of 10 

503.32 (a) (7) Alt. 5) Either the density of fecal coliform in the sewage sludge shall be less 

than 1000 Most Probable Number per gram of total solids (dry weight basis), or the density of 

Salmonella, sp. Bacteria in the sewage sludge shall be less than three Most Probable Number 

per four grams of total solids (dry weight basis) at the time the sewage sludge is used or 

disposed. 

Sewage sludge that is used or disposed shall be treated in one of the Processes to Further 

Reduce Pathogens described in Appendix B of CFR 503. 

Class B Biosolids 

Class B biosolids can be met by using one of three alternatives, the two primary alternatives 

used by this facility are Alt. 1) Monitor sewage sludge for fecal coliform 503.32(b)(2), and 

Alt. 2) Use Process to Significantly Reduce Pathogen (PSRP) 503.32(b)(3). 

Alt. 1) Monitor sewage sludge for fecal coliform 503.32(b) (2) requires that seven samples of 

treated sewage sludge (biosolids) be collected and that the geometric mean fecal coliform 

density of these samples be less than 2 million MPN per dry gram biosolid (dry weight basis). 

Alt. 2) Use Process to Significantly Reduce Pathogen (PSRP) 503.32(b)(3) considers sludge 

treated in one of the PSRPs listed in Appendix B of the 40 CFR Part 503 to meet Class B 

biosolid criteria for pathogen reduction, 

For this facility the following PSRPs are primarily used: 

• #2 Air Drying, sludge air dried on beds for minimum of 3 months (ambient temperature 

above 0C (32F) 2 out of the 3 months, 

• #3 Anaerobic digestion, sludge is treated in the absence of air/oxygen for a specified 

residence time at a specified temperature. Values of the mean cell residence time and 

temperature shall be between 15 days at 35C to 55C (13 IF) and 60 days at 20C (68F) 

• #4 Composting, the temperature of the sewage sludge is raised to 40C (104F) or higher 

and remains at 40C or higher for 5 days. For 4 hours during the 5-day period, the 

temperature in the compost pile must exceed 55C (13 IF), and 

• #5 Lime stabilization, sufficient lime is added to the sewage sludge to raise the pH of the 

sewage sludge to 12 with no further addition of alkali agent, and maintain sludge pH of 

12 active-mix for 2-hours, 

B) Vector Attraction 

This facility primarily uses vector attraction reduction Option # 1 to satisfy their 40 CFR 503 

volatile solids reduction requirements. 

Opt. 1) The % volatile solid reduction calculation to use for anaerobic digester that is decanted 

and that does not have appreciable grit accumulation would be the Van Kleeck or Approximate 

Mass balance (AMB) equation depending upon the percent solids in the decantante. (see 

Attachment 2A) 
September 2004 

City of Woodburn 

Biosolid Management Plan 

Page 5 of 10 

To meet the biosolid vector attraction reduction requirements an aerobic digester must provide a 

40 day detention time at 20C in a completely mixed high rate digester in order to achieve a 

volatile solids reduction of 38 % or more. There are alternative volatile solid reduction methods 

that are deemed equivalent to the 38% volatile solid reduction criteria under the EPA's and the 

DEQ's regulations. 

Opt, 2) When the 38% volatile solids reduction can not be met for anaerobically treated solids 

vector attraction reduction can be demonstrated by showing a less than 17% additional volatile 

solid loss during bench-scale anaerobic batch digestion of the sewage sludge for 40 additional 

days at 30 to 37C. 

Opt. 4) The Specific Oxygen Uptake Rate (SOUR) for sewage sludge treated in an aerobic 

process shall be equal to or less than 1.5 milligrams (mg) of oxygen per hour per gram of total 

solids (2% or less total solids, dry weight basis) at a temperature of 20 C. 

Opt.5) Aerobic treatment of sludge for at least 14 days at over 40C (104F), during the process the 

average temperature must be over 45C (Compost), 

Opt, 6) The pH of the sewage sludge shall be raised to a pH of 12 or higher by the addition alkali 

agent and without the addition of more alkali agent. The batch shall remain at a pH of 12 or, for 

two hours or more active mix; and at a pH of 11,5 of higher for an additional 22 hours. 

Opt. 7) The sewage sludge must achieve 75% solid by drying prior to mixing with other materials. 

Sewage sludge treated in aerobic or anaerobic process (i.e. Sewage sludge that does not contain 

unstabilized solids generated in secondary wastewater treatment), 

Opt. 8) The sewage sludge must achieve 90% solid by drying prior to mixing with other materials. 

Sewage sludge treated in aerobic or anaerobic process (i.e. Sewage sludge that contains unstabilized solids generated in primary wastewater treatment). 

Opt 10) Sewage sludge land applied and shall be incorporated into the soil within six hours of 

land application, 

C) Batch Processes 

Class A Biosolids 

Alt. 5, PFRP Compost, compost pile must meet PFRP) of 3 consecutive days at a minimum pile 

temperature of 55C. (Note: Class A PFRP must be met within the Class B PSRP treatment 

parameter, EPA requirement). 

Class B Biosolids 

Alt. 3, # 4 PSRP) Compost, Process that Significantly Reduces Pathogens (PSRP) showing an 

average pile temperature of 45C and minimum temperature of 40C in the pile within 14 

consecutive days. 
September 2004 

City of Woodburn 

Biosolid Management Plan 

Page 6 of 10 

Note: Class B compost (PSRP) has to be demonstrated through aerobic (time and temperature) 

before or at the same time vector attraction reduction satisfied the PSRP composting process. 

Ill Biosolid Characteristics 

Woodburn generates approximately 900 metric dry tons of biosolids. Woodburn land applied 

(940) dry metric tons of Class B biosolid in 2003. 40 CFR 503,16 requires Woodburn to sample 

and monitor their biosolids four times per year. Monitoring frequency depends on the amount of 

biosolids the facility generates (metric tons) that is sold or given away, land applied and/or 

surface disposal. After the sewage sludge has been monitored for two years at the frequency in 

Table 1 of 503.16, the City may petition the Department to reduce the monitoring of metals and 

pathogen to once a year. 

Sampling : Refer to Biosolid Sampling Plan developed in accordance with Test Methods for 

Evaluating Solid Waste, Volume 2; Field Manual, Physical/Chemical Methods, November 1986, 

Third Edition, Chapter 9. 

Biosolid Analysis: 

Biosolid Chemical Analysis: 

The City of Woodburn operates wastewater treatment plant off highway 211. The facility is 

situated on 150 acres. 90 acres of the 150 to the north and east of the facility are used for biosolid 

land application and effluent use. From the Woodburn's 2003 biosolid analysis the following is a 

representative sampling of the biosolid metal concentration. 

Metal mg/kg 

Arsenic (As) 5,93 

Cadmium (Cd) 0,431 

Chromium (Cr) 23,4 

Copper (Cu) 32,5 

Lead(PB) 10,7 

Mercury (Hg) 0.228 

Molybdenum (Mo) 2.16 

Nickel (Ni) 18.3 

Selenium (Se) 0.431 

Zinc(Zn) 138 

The site life would be limited to (851) years based on the arsenic loading Woodburn's 2003-

biosolid analysis (Attachment 2B). 

Biosolid Nutrient Analysis: 

For the year 2003, the biosolid contained about (2273) pounds (lb.) total nitrogen (N) of which 

about (1061) lb. was in the nitrate form (N03-N02) and (788) lb. was in the ammonia form 

(NH3). From the analysis the Woodburn needs approximately (23) acres to land apply on poplar 

trees (260 lb, PAN/ac-yr) to handle their annual biosolid nitrogen production. 

#/acre-yr. 

0.003 

0.0002 

0.0126 

0.0175 

0.0058 

0.0001 

0.0012 

0.0099 

0.0002 

0,0743 

site lif 

851 

1144 

6316 

5684 

3453 

9182 

4276 

2827 

28574 

2499 
September 2004 

City of Woodbum 

Biosolid Management Plan 

Page 7 of 10 

IV Biosolids Beneficial Reuse Program 

Transportation and Land Application: 

Biosolids are offloaded into city owned (10 yard.) spreader truck at the plant. The biosolids 

loading areas are impounded in case of accidental spillage of biosolids during the truck loading 

process. During the summer months, Woodburn's biosolids are land applied on several City 

owned sites. For the year 2003 Woodburn land applied to several DEQ authorized sites totaling 

about 72-acres. The biosolid land application sites are capable of assimilating Woodburn's 

annual total nitrogen production. The agronomic biosolid land application rate for poplar trees is 

260 lb. available N per acre-yr. 

Land application: Woodburn land applies on authorized poplar reuse sites. All DEQ site 

authorizations for Woodburn are part of Woodburn's Biosolid Management Plan, The City of 

Woodburn currently has a total of 90 acres authorized for land application. The sites are located 

on the Woodburn wastewater facility compound. 

Woodburn Biosolids Site Management Information: 

Site 

#1 

#2 

#3 

U 

#5 

#6 

#7 

#8 

#9 

#10 

#11 

#12 

Total 

Use/ acres 

7 

7 

7 

7 

7 

7 

7 

7 

7 

6,3 

7 

3.3 

80 

lb. "N/acre 

260 

260 

260 

260 

260 

260 

260 

260 

260 

260 

260 

260 

lb. N/site 

1820 

1820 

1820 

1820 

1820 

1820 

1820 

1820 

1820 

1638 

1820 

858 

20696 

Long term biosolid application rates and site restrictions are contained in the biosolid site 

authorization letter. References to the OAR 340-50, The 40 CFR Part 503, site setbacks, site 

agronomic loading rates, land application restrictions and site restrictions are also detailed out in 

the site authorization letter. 

V Contingency Options 

In the event biosolids are spilled between the treatment facility and the land application site, 

Woodburn's sewage treatment works shall contain the spill with lime or absorbent (for example 

sand) and remove spilled sludge solids with a front-end loader or shovels. The biosolids will be 

disposed of at a DEQ authorized site. All spills into waters of the state or spills on the ground 
September 2004 

City of Woodburn 

Biosolid Management Plan 

Page 8 of 10 

surface that are likely to enter waters of the state shall be reported immediately to Oregon 

Emergency Response System (OERS) at 1-800-452-03 11 and your regional biosolids coordinator 

at (541) 440-3338, All spills of 25 gallons or more on the ground surface shall be report to the 

regional biosolids coordinator at (541) 440-3338. 

VI Reporting 

Daily Reporting and Recordkeeping: 

Each year before the land application of biosolids, the source operators shall check to see if 

contiguous property owners have changed. The operators shall keep a record of contact (date, 

and/or written log of phone/letter call w/ name and number, and/or xerox of postcard w/ name and 

address, etc,,) with all contiguous land application property owners, and notify any new neighbor 

at the beginning of the land application season of the city's intent to land apply biosolid. 

Operator shall provide this documentation in the annual biosolid report. 

Annual Reporting 

The Annual Biosolid Report is due February 19, of each year for the previous years land applied 

biosolids. Part of this report is the submittal of the daily site logs, which have the date, time, and 

quantity gal-lb. N/acre land applied for each clay-tank-batch land applied. Site logs shall have a 

scaled map showing the site and the land application location that coincides with the daily site 

loading methods (truck spreader'bar, irrigation cannon). Daily records should clearly show the 

location of daily biosolid loading site log. 

The Annual Report shall contain a signed copy of the certification statements for pathogen 

reduction, vector attraction reduction and biosolids has been land applied at approved agronomic 

loading. The person signing the statements should be the operator of record at the treatment plant. 

The operator shall show how the vector attraction reduction was met i.e., volatile solids reduction 

was achieved by time and temperature, the Van Kleeck equation filled out with digester records 

(MCRT), bench scale test, sour test or any other EPA approved alternative method appropriated 

for biosolid generated at your facility. Certification of pathogen reduction is required and is 

satisfied by submittal of test results in the Annual Biosolid Report AM the previous year's 

biosolids sampling and analysis that is required by the permit shall be included in Woodburn's 

Annual Biosolid Report (in the year's annual report appendix). 

VII Certification Statement 

Woodburn's facility is capable of meeting their primary alternatives for achieving Class A or B 

biosolid pathogen and vector attraction reduction criteria. As required under 40CFR 503.17 a 

signed Class A and/or B biosolid and vector attraction certification statements shall accompany 

all biosolids that are land applied (see Attachment 2C). For Class A or B biosolid annual 

biosolid analysis must be provided upon request. Certification statements must also show 

conformance with nutrient and land application loading rates where applicable. 
September 2004 

City of Woodbum 

Biosolid Management Plan 

Page 9 of 10 

Attachment 2A: 

Calculation of the % volatile solids reduction for the aerobic digesters is to be based on comparison of 

a representative grab sample of total and volatile solids entering the digestion process (a weighted 

blend of the primary and secondary clarifier solids) and a representative composite sample of the 

solids existing the sludge holding tanks. 

Typically in the past we've used the Van Kleeck equation for digesters. The assumption is that there 

is no grit accumulation in the digester. This volatile solids equation assumes the fixed solids input 

equals the fixed solids output. The Van Kleeck equation is appropriate if the digester decatante is 

low in total solids. The Van Kleeck equation can be used to calculate the volatile solids reduction for 

a digester that decants provided VSb equal VSd 

FVSR: Fractional Volatile Solids Reduction 

FVSR = 1 - VSb * (1 -VSf) / VSf (I - VSb) 

VSf Feed Sludge Fractional Volatile Solid, (kg/kg) 

VSb Digested Sludge (digester bottom) Fractional Volatile Solids, (kg/kg) 

VSd Decantate Fractional Volatile Solids 

For this equation to be valid VSb must equal VSd. 

For digesters with decant withdrawal (decant high in solids) and no grit accumulation, where the 

volatile and fixed concentrations are known for all streams as well as the volumetric flow rates for the 

decant and digester sludge then the Approximate Mass Balance equation should be used. 

FVSR: Fractional Volatile Solids Reduction 

FVSR = Fyb - Byb - Dyd / Fyb 

Fyb (F) Feed Sludge Volumetric Flow Rate (m3/d) 

(yb) Feed Sludge Volatile Solids Concentration (kg/ m3) 

Byb (B) Digester Sludge (bottom) Volumetric Flow Rate (m3/d) 

(Bb) Digester Sludge (bottom) Volatile Solids Concentration (kg/ m3) 

Dyd (D) Decantate Volumetric Flow Rate (m3/d) 

(yd) Decantate Volumetric Solids Concentration (kg/ m3) 

Assumptions: Fixed Solids and Volatile Flows Streams, 
September 2004 

City of Woodburn 

Biosolid Management Plan 

Page 10 of 10 

Attachment 2C: 

"I certify, under penalty of law, that the pathogen requirements in [insert either 503.32(a) or 

503.32(b)], the management practices in 503.14 and the vector attraction reduction requirements in 

[insert 503.33(b) (1) through 503.33(b) (10)] have been met. This determination has been made under 

my direction and supervision in accordance with the system designed to ensure that qualified 

personnel properly gather and evaluate the information used to determine that the pathogen 

requirements and vector attraction reduction requirements have been met, 1 also certify that all 

biosolids were land applied at the approved agronomic loading rate noted in the respective 

Department site authorization letter, I am aware that there are significant penalties for false 

certification including the possibility of fine and imprisonment," 

Signature,.,......,.,,,.. Date. 
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Attachment 5 

Appendix B: Antidegradation Review Sheet 

ANTIDEGRADATION REVIEW SHEET 

FOR A PROPOSED INDIVIDUAL NPDES DISCHARGE 

1. What is the name of Surface Water that receives the discharge? Pudding River 

Briefly describe the proposed activity: Municipal Wastewater Treatment 

Is this review for a ^renewal) OR new (circle one) permit application? 

Go to Step 2. 

2. Is this surface water an Outstanding Resource Water or upstream from an 

Outstanding Resource Water? 

No. Go to Step 3, 

3. Is this surface water a High Quality Water? 

No, Go to Step 4, 

4. Is this surface water a Water Quality Limited Water? 

Yes. Go to Step 14, 

14, Will the proposed activity result in a Lowering of Water Quality in the Water 

Quality Limited Water? [see OAR 340-041 -0004(3)-(5) for a description in rule 

of discharges that do not result in lowering of water quality or do not constitute a 

new and/or increased discharge or are otherwise exempt from antidegradation 

review; otherwise see "Is an Activity Likely to Lower Water Quality?" in 

Antidegradation Policy Implementation Internal Management Directive for NPDES 

Permits and Section 401 Water Quality Certifications.} 

No, Proceed with Permit Application. Applicant should provide basis for 

conclusion. Go to Step 21, 
21, On the basis of the Antidegradation Review, the following is recommended: 

_X Proceed with Application to Interagency Coordination and Public 

Comment Phase. 

Deny Application; return to applicant and provide public notice. 

Action Approved 

Section: DEQ Western Region WQ 

Review Prepared By: Mark E. Hamlin 

Phone: (503) 378-8240, ext. 239 

Date Prepared: September 10. 2004 

Please provide the following information and submit with the completed application form 

to: 

Department of Environmental Quality 

Water Quality Division—Surface Water Management 

811 SW Sixth Avenue 

Portland, Oregon 97204-1390 

Name: 

Name of Company: 

Address: 

Phone: 

Fax: 
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Wastewater System Classification Worksheet for Operator Certification 

OAR 340-049-0020 

General Requirements {OAR 340-049-0015) - Each owner of a regulated wastewater system must have its 

system supervised by one or more operators who hold a valid certificate for the type of system, wastewater 

treatment or collection, and at a grade equal to or greater than the wastewater system classification as defined 

in OAR-340-049-0020 and 0025. DEQ will advise system owners of the classification of their systems as a 

permit action. As the classification establishes the operator certificate type and grade required for 

compliance, it needs to be set prior to "start-up" of a new or upgraded and/or expanded facility. 

Wastewater treatment system classifications will be derived from the total points assigned based on criteria 

shown in OAR 340-049-0025 (see Classification Worksheet). Collection system classifications are based on 

design population or population equivalent to be served by a wastewater treatment system (see Worksheet). 

Upon written notice to the wastewater system owner, DEQ may classify a wastewater treatment system higher 

than the classification based on accumulated points if the complexity of a treatment system is not reflected in 

the criteria(see Worksheet examples). If deemed appropriate, DEQ may classify a wastewater collection 

system higher than the classification based on population when a Class I by population will have significant 

pumping of sewage including S TEP or other pumping that may warrant a Class II designation. In either case, 

designation must be consistent with the intent of the classification system (see OAR 340-049-0020(4) & (5)). 

Classification of Wastewater Systems (OAR 340-049-0020) All wastewater systems regulated under OAR 

340-049 will be classified by DEQ as wastewater treatment systems and/or wastewater collection systems, as 

appropriate, in accordance with the following classification system: 

Wastewater Treatment Systems 

Class I - 30 total points or less 

Class II - 31-55 total points 

Class HI - 56-75 total points 

Class IV - 76 or more points 

Wastewater Collection Systems 

Class I -1,500 or less design population 

Class II -1,501 to 15,000 design population 

Class III -15,001 to 50,000 design population 

Class IV - 50,001 or more design population 

Definitions used in these regulations unless otherwise required by context (see OAR 340-049-0010): 

"Average Dry Weather Flow" (ADWF) means the design average dry weather flow capacity of the wastewater treatment 

system in gallons per day or Million Gallons per Day (MGD), as approved by the Department. 

"Industrial Waste" means liquid wastes from an industrial or commercial process discharged into a wastewater system for 

conveyance and treatment. 

"NPDES Permit" means a waste discharge permit issued in accordance with requirements and procedures of the National 

Pollutant Discharge Elimination System authorized by Section 402 of the Federal Clean Water Act and OAR 340, Division 

45. 

"Population" means the design population of the wastewater system represented as the number of people or the population 

equivalent the system is designed to serve. Equivalent population ordinarily is determined based on 70 gallons per person 

per day average dry weather flow (ADWF) or 0.17 lbs. BODS per person per day, whichever is greater. 

"Wastewater" or "sewage" means the water-carried human or animal waste from residences, buildings, industrial 

establishments or other places, together with such groundwater infiltration and surface water as may be present. The 

admixture of domestic and industrial waste or other by-products, such as sludge, is also considered wastewater or sewage. 

"Wastewater Treatment System" or "Sewage Treatment System" means any structure, equipment or process for treating 

and disposing of, or recycling or reusing wastewater and sludge (including industrial waste) that is discharged to the 

wastewater system, 

"Wastewater Collection System" or "Sewage Collection System" means the trunks, arterials, pumps, pump/lift stations, 

piping and other appurtenances necessary to collect and cany away wastewater or other liquid waste treatable in a 

community or private wastewater treatment facility, 

"Wastewater System" means "Sewage Treatment Works" defined in ORS 448.405 as any structure, equipment or process 

required to collect, carry away and treat domestic waste and dispose of sewage as defined in ORS 454.010. Typically, 

components of a wastewater system include a wastewater collection system and a wastewater treatment system. 

"WPCF Permit" means a Water Pollution Control Facilities permit to construct and operate a collection, treatment and/or 

disposal system with no discharge to navigable waters. 
Wastewater System Classification Worksheet for Operator Certification 

OAR 340-049-0020 

WW System Common Name: Woodburn Wastewater Treatment Facility 

Facility ID: 98815 Location: 2815 Molalla Road 

Total Points (from page 3): 95_ 

Design Population1: 47500 

Design ADWF load (Influent MGD) 3.33 

Classified by: Mark E. Hamlin 

Date this classification filed with the Operator Certification office: 

WWT Class (check): Q l D II D HI S IV 

WWC Class (check): D l D II IS III • IV 

Design BOD load (Influent Ibs./day) 7200 

Date: 9/10/04 

System start-up date for this classification (new, upgrade or expansion): 

Is this a change from a prior classification? (check): • Yes {El No 

Criteria for Classifying Wastewater Treatment Systems (OAR 340-049-0025) 

(1) Design Population or Population Equivalent Points (10 Points 

• Less than 750 

• 751 to 2000 

• 2001 to 5000 

• 5001 to 10,000 

[x] Greater than 10,000 

Point subtotal 

laximum) 

0,5 points 

1 point 

1.5 points 

2 points 

3 points EJUS 1 per 10,000 

(2) Average Dry Weather Flow (Design Capacity) Points (10 points Maximum) 

• Less than 0,075 MGD 

• Greater than 0.075 to 0.1 MGD 

• Greater than 0.1 to 0.5 MGD 

• Greater than 0.5 to 1.0 MGD 

LE Greater than 1,0 MGD 

(3) Unit Process Points (Check all that apply) 

Preliminary Treatment and Plant Hydraulics: 

• Comminution (includes shredders, grinders, etc.) 

Q Grit Removal, gravity 

IEl Grit Removal, mechanical 

tEl Screen(s), in-situ or mechanical 

• Pump/Lift Station(s) (pumping of main flow) 

• Flow Equalization (any type) 

Primary Treatment: 

• Community Septic Tank(s) 

fX] Clarifier(s) 

n Flotation Clarifier(s) 

• Chemical Addition System 

• Imhoff Tank (or similar) 

Point subtotal 

Point subtotal 

0,5 point 

1 point 

1.5 points 

2 points 

3 points plus 1 per 1 

6.3 

1 point 

1 point 

2 points 

1 point 

2 points 

1 point 

3 

1GD 

Point subtotal 

Total Points Page 1 

2 po 

5 po 

7 po 

2 po 

3 po 

5 

22 

!

nts 

'nts 

ints 

'nts 

'nts 

Page 1 of 3 

1

 See "Population" definition. Use the design average daily per person load for Influent Flow or Influent BODS, whichever 

is greater. This value is also used to determine the Collection System Classification. 
Wastewater System Classification Worksheet 

Unit Process Points - Continued (Check all that apply) 

Secondary, Advanced, and Tertiary Treatment: 

• Low Rate Trickling Filter(s) (no recirculation) 

• High Rate Trickling Filter(s) (recirculation) 

• Trickling Filter - Solids Contact System 

[El Activated Sludge (any type) 

D Pure Oxygen Activated Sludge 

• Activated Bio Filter Tower less than 0,1 MGD 

D Activated Bio Filter Tower greater than 0.1 MGD 

• Rotating Biological Contactors 1 to 4 shafts 

D Rotating Biological Contactors, 5 or more shafts 

D Stabilization Lagoons, 1 to 3 cells without aeration 

• Stabilization Lagoons, 1 or more cells with primary aeration 

• Stabilization Lagoons, 2 or more cells with full aeration 

Q Recirculating Gravel Filter 

• Chemical Precipitation Unit(s) 

IE! Gravity Filtration Unit(s) 

• Pressure Filtration Unit(s) 

IE] Nitrogen Removal, Biological or Chemical/Biological System 

• Nitrogen Removal, Designed Extended Aeration Only 

• Phosphorus Removal Unit(s) 

• Effluent Microscreen(s) 

• Chemical Flocculation Unit(s) 

• Chemical Addition System(s) (6 points maximum) 

Point subtotal 

Solids Handling: 

• Anaerobic Primary Sludge Digester(s) w/o Mixing and Heating 

(El Anaerobic Primary Sludge Digester(s) with Mixing and Heating 

• Anaerobic Primary and Secondary Sludge Digesters 

[El Sludge Digester Gas reuse 

• Aerobic Sludge Digester(s) 

IEl Sludge Storage Lagoon(s) (or tanks, basins etc.) 

• Sludge Lagoon(s) with aeration 

• Sludge Drying Bed(s) 

IEl Sludge Air or Gravity Thickening 

• Sludge Composting, In Vessel 

• Sludge Belt(s) or Vacuum Press/Dewatering 

• Sludge Centrifuge(s) 

• Sludge Incineration 

• Sludge Chemical Addition Unit(s) (alum, polymer, etc.) 

• Non-Beneficial Sludge Disposal 

IEl Beneficial Sludge Utilization 

Point subtotal 

Disinfection: 

• Liquid Chlorine Disinfection 

• Gas Chlorine Disinfection 

• Dechlorination System 

IEl Other disinfection systems incl. u traviolet and ozonation 

Point subtotal 

7 points 

10 points 

12 points 

15 points 

20 points 

6 points 

12 points 

7 points 

12 points 

5 points 

7 points 

9 points 

7 points 

3 points 

2 points 

4 points 

4 points 

2 points 

4 points 

2 points 

3 points 

2 points 

21 

5 points 

7 points 

10 points 

3 points 

8 points 

2 points 

3 points 

1 point 

3 points 

12 points 

5 points 

5 points 

12 points 

2 points 

1 point 

3 points 

15 

2 points 

5 points 

4 points 

5 points 

5 

Total Points Page 2 41 

Page 2 of 3 

OpCertClassWorksheet. rev5 (10/9/03) 
Wastewater System Classification Worksheet 

(4) Effluent Permit Requirement Points (Check as applicable): 

• Minimum of secondary effluent limitations for BOD and/or TSS 2 points 

• Minimum of 20 mg/L BOD and/or Total Suspended Solids 3 points 

[X] Minimum of 10 mg/L BOD and/or Total Suspended Solids 4 points 

• Minimum of 5 mg/L BOD and/or Total Suspended Solids 5 points 

[X] Effluent limitations for effluent oxygen 1 point 

Point subtotal 5 

(5) Variation in Raw Waste Points. (6 points maximum) Points in this category will be 

awarded only when conditions are extreme to the extent that operation and handling 

procedure changes are needed to adequately treat waste due to variation of raw waste 

• Recurring deviations or excessive variations 100% to 200% 2 points 

• Recurring deviations or excessive variations of more than 200% or 

conveyance and treatment of industrial wastes by Pretreatment program 4 points 

[El Septage or other hauled waste (control and/or preliminary treatment) 2 points 

Point subtotal 2 

(6) Sampling and Laboratory Testing Points (check as applicable - maximum 11 points) 

• Sample for BOD, Total Suspended Solids performed by outside lab 2 points 

IE] BOD or Total Suspended Solids analysis performed at treatment plant 4 points 

• Bacteriological analysis performed by outside lab 1 point 

IE] Bacteriological analysis performed at WWT plant lab 2 points 

• Nutrient, Heavy Metals or Organics analysis performed by outside lab 3 points 

[El Nutrient, Heavy Metals or Organics analysis performed at WWT plant 5 points 

Point subtotal Ij . 

(7) Points For Other Complexities Not Reflected Above: (see OAR 340-049 0020(4) & (5)) 

• Odor Control (2 points maximum) 1 to 2 points 

IEl Standby Power Units @ 1 point 

• Solids Composting or Land Application of Biosolids 10 points 

• Alkaline Stabilization (3 points maximum) 2 to 3 points 

[E3 Other Effluent Limits [ammonia, CI2, temp,, etc. (list or attach list)1 @ 1 point 

IEl Pond(s) (advanced treatment polishing or irrigation holding) 2 points 

G Effluent Land Disposal - Evaporation (surface or subsurface) 2 to 4 points 

IEl Effluent direct Reuse or Recycle 6 points 

IEl SCADA or similar for data (limited to extensive total process operation) 2 to 6 points 

• Chemical/Physical advanced waste treatment following secondary 10 points 

• Chemical/Physical advanced waste treatment w/o secondary 15 points 

• Biological or Chemical/Biological advanced waste treatment 12 points 

• Reverse Osmosis, Electro-dialysis or Membrane Filtration techniques 15 points 

• Other complexities (list or attach list): 

Point subtotal j_4 

Total Points Page 3 32 

Total Accumulated Points (3 pages) 95 

A COPY OF THIS COMPLETED WORKSHEET IS TO BE FILED WITH THE OPERATOR 

CERTIFICATION PROGRAM, WATER QUALITY DIVISION, PRIOR TO SYSTEM START-UP 

Page 3 of 3 

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

Attachment #9 

INPUT ' Lower pH -

1. DILUTION FACTOR AT MIXING ZONE BOUNDARY 

1. UPSTREAM/BACKGROUND CHARACTERISTICS 

Temperature (deg C): 

pH: 

Alkalinity (mg CaC03/L): 

2. EFFLUENT CHARACTERISTICS 

Temperature (deg C): 

pH: 

Alkalinity (mg CaC03/L): 

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1. IONIZATION CONSTANTS 

Upstream/Background pKa: 

Effluent pKa: 

2. IONIZATION FRACTIONS 

Upstream/Background Ionization Fraction: 

Effluent Ionization Fraction: 

3. TOTAL INORGANIC CARBON 

, Upstream/Background Total Inorganic Carbon (mg CaCO 

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Temperature (deg C): 

Alkalinity (nig CaC03/L): 

Total Inorganic Carbon (mg CaC03/L): 

pKa: 

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