UPDATED FACT SHEET FOR NPDES PERMIT WA-000080-9

FACILITY NAME: WEYERHAEUSER NR COMPANY, COSMOPOLIS MILL

Permit Modification for Reduced Monitoring during Mill Closure Phase

September 18, 2009

Page 1 of 38TABLE OF CONTENTS

INTRODUCTION .................................................................................................................. .........3

BACKGROUND INFORMATION ................................................................................................5 DESCRIPTION OF THE FACILITY .................................................................................5 History......................................................................................................................5 Proposed Permit and factsheet .................................................................................5 Industrial Process .....................................................................................................5 Discharge Outfall .....................................................................................................6 Sanitary Wastewaters ...............................................................................................7 PERMIT STATUS ...............................................................................................................7 SUMMARY OF COMPLIANCE WITH THE PREVIOUS PERMIT ...............................7 SEPA COMPLIANCE .........................................................................................................8

PROPOSED PERMIT LIMITATIONS ...........................................................................................8 DESIGN CRITERIA ...........................................................................................................9 TECHNOLOGY-BASED EFFLUENT LIMITATIONS OUTFALL 001 ..........................9 History of effluent guidelines used in previous permits ..........................................9 1998 effluent guidelines .........................................................................................10 The type of treatment required in the guidelines ...................................................10 Type of pulps made by Weyerhaeuser company’s Cosmopolis mill .....................10 Determination of AKART for conventional pollutants .........................................10 Determination of AKART fo r Acetate grade pulp ................................................11 Total chlorine Free (TCF) study ............................................................................15 SURFACE WATER QUALITY-BASE D EFFLUENT LIMITATIONS .........................15 Numerical Criteria for the Pr otection of Aquatic Life ...........................................15 Numerical Criteria for the Pr otection of Hu man Health ........................................16 Narrative Criteria ...................................................................................................16 Antidegradation ......................................................................................................16 Critical Conditions .................................................................................................16 Mixing Zones .........................................................................................................17 Description of the Receiving Water .......................................................................17 Surface Water Quality Criteria ..............................................................................17 Consideration of Surface Water Qu ality-Based Limits for Numeric Criteria ...................................................................................................................18 Fecal coliform extended mixing zone and limit ....................................................19 Water quality analyses outfall 001 .........................................................................20 Whole Effluent Toxicity ........................................................................................22 Human Health ........................................................................................................24 Sediment Quality ...................................................................................................24 PREVIOUS LIMITATIONS FOR OUTFALL 002 ..........................................................25 GROUND WATER QUALITY LIMITATIONS ..............................................................25 COMPARISON OF EFFLUENT LIMITS WITH THE EXISTING PERMIT ISSUED SEPTEMBER 30, 2003 ..........................................................................26

MONITORING REQUIREMENTS ..............................................................................................27

Page 2 of 38LAB ACCREDITATION ..............................................................................................................30

OTHER PERMIT CONDITIONS .................................................................................................30 REPORTING AND RECORDKEEPING .........................................................................30 NON-ROUTINE AND UNANTICIP ATED DISCHARGES ...........................................30 SPILL PLAN .....................................................................................................................30 SOLID WASTE PLAN......................................................................................................30 OUTFALL EVALUATION ..............................................................................................31 TREATMENT SYSTEM OPERATING PLAN ...............................................................31 GENERAL CONDITIONS ...............................................................................................31

PERMIT ISSUANCE PROCEDURES .........................................................................................31 PERMIT MODIFICATIONS ............................................................................................31 RECOMMENDATION FOR PERMIT ISSUANCE ........................................................31

REFERENCES FOR TEXT AND APPENDICES........................................................................32

APPENDIX A--PUBLIC INVOLVEMENT INFORMATION ....................................................33

APPENDIX B--GLOSSARY ........................................................................................................35

APPENDIX C--TECHNICAL CALCULATIONS .......................................................................38

APPENDIX D—STUDIES ...........................................................................................................38

APPENDIX E--RESPONSE TO COMMENTS ............................................................................38

INTRODUCTION
Weyerhaeuser NR Company’s Cosmopolis pulp mill is closed pending sale. Once the facility has been sold, the reduced monitoring requirement s will cease, and the mill will be required to comply with the original permit The permit is being amended to include reduced monitoring requirements while the requirements for m onitoring. Please see page 27 for details.
The Federal Clean Water Act (FCWA, 1972, and later modifications, 1977, 1981, and 1987) established water quality goals for the navigable (s urface) waters of the United States. One of the mechanisms for achieving the goals of th e Clean Water Act is the National Pollutant Discharge Elimination System permits (NPDES permits), which is administered by the Environmental Protection Agency (EPA). The EP A has delegated responsi bility to administer the NPDES permit program to the State of Washington on the basis of Chapter 90.48 RCW which defines the Department of Ecology's aut hority and obligations in administering the wastewater discharge permit program.
The regulations adopted by the St ate include procedures for is suing permits (Chapter 173-220 WAC), water quality criteria for surface and ground waters (Chapters 173-201A and 200 WAC), and sediment management standards (Chapter 17 3-204 WAC). These regulations require that a permit be issued before discharge of wastewat er to waters of the state is allowed. The regulations also establish the basi s for effluent limitations and ot her requirements which are to be included in the permit. One of the require ments (WAC 173-220-060) for issuing a permit under

Page 3 of 38the NPDES permit program is the preparation of a draft permit and an accompanying fact sheet. Public notice of the availability of the draft perm it is required at least thirty days before the permit is issued (WAC 173-220-050). The fact sheet and draft permit are available for review (see Appendix A--Public Involvement of the fact sheet for more detail on the Public Notice procedures).
The fact sheet and draft permit have been revi ewed by the Permittee. Errors and omissions identified in this review have been corrected before going to public no tice. After the public comment period has closed, the Department will summarize the substantive comments and the response to each comment. The summary and respons e to comments will become part of the file on the permit and parties submitting comments will r eceive a copy of the Department's response. The fact sheet will not be revised. Comments and the resultant changes to the permit will be summarized in Appendix E--Response to Comments.

GENERAL INFORMATION Applicant Weyerhaeuser NR Company

Name and Address Cosmopolis Pulp Mill, 1 701 First Street, Cosmopolis, Washington 98537 Type of Facility: Magnesium based sulfite pulp mill

SIC Code 2611 Discharge Locations Outfall 001 Outfall 002 Waterbody's Name: Grays Harbor Chehalis River Latitude: 46 ° 57’ 15" N. 46 ° 57’ 32" N. Longitude: 123 ° 51’ 00" W. 123 ° 45' 20" W. Water Body ID Number WA-22-0030 WA-22-4010

Page 4 of 38BACKGROUND INFORMATION

DESCRIPTION OF THE FACILITY

H ISTORY
The mill is located in Cosmopolis, Washington adj acent to the Chehalis River. The mill was constructed by Weyerhaeuser NR Company (Wey erhaeuser) in 1957 as a paper grade sulfiteprocessed pulp mill. In 1962, Weyerhaeuser began converting the mill to dissolvin g and specialty grade sulfite pulp. With the wa y that Weyerhaeuser operated the m ill including the types of pulp produced, the mill was capable of producing 500 metric tons per day of dissolving and paper grade sulfite pulp. Weyerhaeuser announced the mill’s pending closure in 2005, and stopped production in September 2006.
The mill was mothballed during the shutdown period through part of 2007. During 2006, a group of investors explored a venture to purchase the mill. The new purchasers of the mill have named the Cosmopolis mill “Cocidus High Purity Cellulos (Cocidus).” The Cocidus mill’s owners are expected to rest art operations in July 2007.

P ROPOSED P ERMIT AND FACTSHEET
We divided the descriptions with in the factsheet into two secti ons where appropriate. Section one describes the operations and gives the hist orical view of how We yerhaeuser operated the mill and what requirements the existing laws and the permit(s) imposed upon the mill’s operations. Section two describes the operations and requirements that will apply to Cocidus. Weyerhaeuser submitted the permit application as part of the agreement in the Cocidus’ offer. The permit will be issued to Weyerhaeuser. After the parties execute sale contract, Weyerhaeuser will notify us of the sale and the need to transfer the NPDES permit to Cocidus (the new Permittee). Ecology will change the na me on the permit and Cocidus will become the Permittee of record.

I NDUSTRIAL P ROCESS

Section 1, Weyerhaeuser

The mill used a magnesium bisulfite cooking acid with free sulfur dioxide to produce the pulp in the past. The mill averaged 445 air dried metr ic tons per day (ADMTD) off of the machine products in the period from July 1, 2005 through June 30, 2006. The wood chips used in the pulping process were trucked from both compan y owned and privately-owned timberland. The mill used approximately 365,000 tons of hemlock, alder, and fir to make 191,000 short tons of paper and dissolving grade pulps.

A versatile bleaching process enabled the mill to produce a wide range of specialty pulps. The bleaching stages consisted of chlorine dioxide , oxygen, caustic soda, and hydrogen peroxide. Weyerhaeuser sold the pulp to manufacturers of such things as photographic paper, plastic molding compounds, acetate yarns, ciga rette filters, air laid towels, and sanitary products. About

Page 5 of 38half of the mill production was sold to buyers outside of North America. The mill employed 282 people.

Since 1966 the mill has had secondary wastewater treatment. Weyerhaeuser expanded their secondary wastewater treatment system in 1972 and again in 1980. With the addition of the oxygen bleaching stage in 1990, the mill accepted a dioxin limit of 0.28 mg/day. In 1996, the mill applied for a notice of construction to bu ild the Concentrated Oxygen Extraction Liquor (COEL) project. The project reduced VOC emissi ons to the air by 129 tons per year and reduced the influent biochemical oxygen demand (BOD 5 ) by 40,000 pounds per day into the secondary wastewater treatment system. This reduction of BOD 5 enhanced Weyerhaeuser’s ability to maintain higher oxygen levels within the aerati on basins of the seconda ry activated sludge system.

Section 2, Cocidus

The Cocidus mill will use the same process as de scribed above with the same type of chemicals that Weyerhaeuser used to produce pulp during its tenure. The Cocidus m ill’s operators expect to produce 100 percent acetate grade pulp which they will sell to customers who will use the chemical pulp to make cigarette filter.

The acetate-grade pulp is the high end of the type s of pulp that the Cocidus pulp mill is capable of making at the Cosmopolis Pulp mill. The Cocidus mill’s operators plan to use a similar feed stock of wood chips (The chip supply is being negotiated at present.) The Cocidus mill’s wastewater treatment system will be basically th e same, but the operators plan to install more aerators or another type of aer ation -- to augment the need for higher level oxygen needed to treat the load due to the increased producti on. The purchasers of the COEL liquor when Weyerhaeuser operated the mill may not be available to Cocidus. Weyerhaeuser is searching for taker of the COEL liquors for Cocidus mill. If no new purchaser or new ways to treat the COEL liquors can be found, the Cocidus mill will have to treat its COEL liquors on site -- putting a strain on the secondary wastewater treatment system. The Cocidus mill will also have to modify the secondary treatment system to accommodate the higher BOD load.

D ISCHARGE O UTFALL

Section 1, Weyerhaeuser

Weyerhaeuser had two outfalls: one discharged th e treated process wastew ater (Outfall 001) and the other discharged stormwater, fresh water- treatment-system backwash, and freshwater overflow (Outfall 002). Outfall 001 discharged into the upper part of the south channel of Grays Harbor. The other outfall, Outfall 002, discharged into the Chehalis River upstream of the mill.

The mill pumped the process wastewater (from the pulping and washing processes) to four earthen aeration basins and to an unaerated storage lagoon when the pulp being produced measured high in BOD. The water from the four aerated basins discharged into two secondary clarifiers, where the secondary sl udge settled. Weyerhaeuser either wasted the sludge and sent it to the recovery furnaces or returned it to the aeration basins. The effluent, about four million gallons per day (MGD), was disinfec ted and was mixed with the bleach plant effluent. The total

Page 6 of 38flow at this point was about 24 MGD. The tr eated wastewater was pumped via a 42 inch i.d. wood stave pipe to the Pond A pump ing station located three miles we st of the mill. The treated effluent was discharged into Grays Harbor through a diffuser system near Pond D.

Section 2, Cocidus

The Cocidus mill will use both outfalls and trea t the wastewater, using the same treatment system.

S ANITARY W ASTEWATERS

All of the sanitary wastewater was and will be discharged into the City of Cosmopolis’ collection system. The sanitary wastewater from the City of Cosmopolis’ collection system was and will be discharged into the City of Aberdeen’s collection system and treated by the City of Aberdeen’s secondary wastewater treatment syst em. The sanitary wastewater discharges under the City of Aberdeen's NPDES permit.

PERMIT STATUS
The Department of Ecology issued the previous permit for this facility on September 30, 2003 and modified it on November 12, 2003. The previ ous permit placed effluent limitations on biochemical oxygen demand (BOD 5 ), total suspended solids (TSS), fecal coliform, and pH; on 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) and on absorbable organic halide (AOX); and it prescribed WET limits for outfall 001; and it limited the twelve chlorinated organics, 2,3,7,8- tetrachlorodibenzo-p-furan (TCDF), and 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) at the bleach plant prior to discharge into the outfall 001 train; and placed limits on BOD 5 , Oil and Grease, pH, and fecal coliform discharged fr om outfall 002. The previous permit required Weyerhaeuser to monitor and record wastew ater flows from outfalls 001 and 002.
An application for permit renewal was submitted to the Department on March 15, 2007 and accepted by the Department.

SUMMARY OF COMPLIANCE WITH THE PREVIOUS PERMIT
Ecology conducted a Class I inspec tion in August 2006 and a Class II inspection on March 28, 2006

. During the history of the previous permit, the Permittee had generally remained in compliance with its NPDES permit based on Discharge Monitoring Reports (DMRs) submitted to the Department. We verified compliance thr ough inspections conducted by the Department. Weyerhaeuser exceeded their permit on few o ccasions when the mill limitations for total suspended solids (TSS), biochemical oxygen demand (BOD), and bioassays.

The mill had two daily maximum limit excursions for TSS in the past four years. One was noted in June 2004 and the other was in April 2005. The June 2004 excursion was due to biological growth in the sample line. The mill revised its schedule for cleaning the line and no further exceptions were noted. The April 2005 excurs ion occurred during a mill planned shut down when they overloaded the ash clar ifier with respect to flow. Phone calls were made to the Permittee. No further action was taken due to th e nature of these excursions. The mill had two

Page 7 of 38BOD exceedances in August 2005. One of these ex ceptions was from outfall 001 and the other was from outfall 002. The mill exceeded their BOD limit from outfall 002 in April 2004. Penalties for these exceedances were issued. Weyerhaeuser found toxicity in their effluent during the whole effluent toxicity (WET) characterization study.

WASTEWATER CHARACTERIZATION
The proposed wastewater discharge was characte rized for the following regulated parameters from the revised permit application:

Table 1: Wastewater Characterization

Outfall 001 Outfall 002

Parameter Concentration Concentration

Color 1,400 Alpha

Color units -

Fecal Coliform 19,069 #/100 ml 3700 #/100 ml

Sulfates 650 mg/L - Aluminum 0.69 mg/L - Barium 0.04 mg/L - Boron 0.07 mg/L - Iron 1.26 mg/L - Magnesium 98.6 mg/L - Manganese 1.26 mg/L - Titanium 0.04 mg/L - Copper 11.8 μ g/L 1.2 μ g/L

Chromium 7.7 μ g/L - Lead 0.8 μ g/L - Zinc 20.0 μ g/L - Nickel 4.0 μ g/L 0.6 μ g/L

SEPA COMPLIANCE
There are no SEPA requirements related to issuance of the proposed permit.

PROPOSED PERMIT LIMITATIONS
Federal and State regulations requ ire that effluent limitations set forth in a NPDES permit must be either technology-based or wa ter quality-based. Technology-based limitations are based upon the treatment methods available to treat specific pollutants. Technology-based limitations are set

Page 8 of 38by regulations or developed on a case-by-ca se basis (40 CFR 125.3, and Chapter 173-220 WAC). Water quality-based limitations are based upon compliance with the Surface Water Quality Standards (Chapter 173-201A WAC) , Ground Water Standards (Chapter 173-200 WAC), Sediment Quality Standards (Chapter 173-204 WAC) or the National Toxics Rule (Federal Register, Volume 57, No. 246, Tuesda y, December 22, 1992). The more stringent of these two limits must be chosen for each of the parameters of concern. Each of these types of limits is described in more detail below.
The limits in this permit are based in part on information received in the application. The effluent constituents in the application were evaluated on a technology- based and/or water quality-basis. The limits necessary to meet the rules and regulations of the State of Washington were determined and included in this permit. Ecology does not develop effluent limits for all pollutants that may be reported on the application form as pres ent in the effluent. Some pollutants are not treatable at the concentrations reported, are not controllab le at the source, are not listed in regulations and do not have a reasonable potential to cause a water quality violation

. Effluent limits are not always developed for pol lutants that may be in the discharge but not reported as present in the appl ication. In those circumstance s the permit does not authorize discharge of the non-reported pollutants. Effl uent discharge conditions may change from the conditions reported in the permit a pplication. If signifi cant changes occur in any constituent, as described in 40 CFR 122.42(a), the Permittee is re quired to notify the Department of Ecology. The Permittee may be in violation of the permit until the permit is modified to reflect additional discharge of pollutants.

DESIGN CRITERIA
In accordance with WAC 173-220-150 (1) (g), flows or waste loadings shall not exceed approved design criteria. The wast ewater treatment system is de signed to treat the wastewater load from the current production of pulp and to meet conditions within the NPDES permit. The future owners are evaluating the treatment system options to treat the proj ected loads. They may modify the system to treat the projected load if the evaluation shows a need for modifications.

TECHNOLOGY-BASED EFFLUENT LIMITATIONS OUTFALL 001

H ISTORY OF EFFLUENT GUIDELINE S USED IN PREVIOUS PERMITS

Technology-based limitations are set by regulations or developed on a case by case basis. The federal effluent guidelines for Best Practicable Control Technically availa ble (BPT) were defined in Part 430 Subpart K for dissolving sulfite sub category in the 1982 effluent guidelines. These guidelines were published in the federal re gister on November 18, 1982 and March 30, 1983. The federal effluent guidelines for best conve ntional pollutants Cont rol Technology (BCT) for these categories were defined on December 17, 1986 to be the same as BPT previously defined in March 1983. BCT and BPT were defined more than ten years ago. With BCT and BPT being defined for more than ten years, it is Ecology policy to determine if they are still valid and if they can still be considered equivalent to all know n and reasonable treatment (AKART) for these categories of paper making.

Page 9 of 381998 EFFLUENT GUIDELINES
On April 15, 1998, the Environmental Protection Agen cy promulgated effluent guidelines for the bleached Kraft Papergrade and Soda subcategor ies and Papergrade Sulfite subcategory. The 1998 allowances for BOD and TSS in pounds per 1000 pounds of pulp produced for the above categories were set at the same values as the allo wances in the effluent guidelines published in 1982.

T HE TYPE OF TREATMENT RE QUIRED IN THE GUIDELINES
Throughout the history of the e ffluent guidelines, secondary tr eatment (1982) has been the accepted standard for BOD and TSS removal. It is expected that in th e immediate future this trend will continue as indicated by th e guidelines promulgated on April 15, 1998.

T YPE OF PULPS MADE BY W EYERHAEUSER COMPANY ’ S C OSMOPOLIS MILL

Section 1, Weyerhaeuser

The permittee’s past production has been 88.9 percent dissolving grad e (acetate (78.7 %), viscose (0%), and cellophane (10.2 %)) and 11.1 % paper grade sulfite pulps. The effluent guidelines for dissolving grade pulp made by th e sulfite pulping process have not been promulgated as of this date. The 1998 efflue nt guidelines added speci alty grade pulp as a subcategory of sulfite paper grad e. The specialty grade of pulp is in between the former paper grade and dissolving sulfite pulp. The specialty gr ades sulfite pulp consists of those papergrade sulfite grade pulps where a significant portion of production is ch aracterized by pulp with a high percentage of alpha cellulose and a high bright ness sufficient to produce end products such as plastic molding compounds, saturating and lami nating products, and photographic papers. Weyerhaeuser revisited the production at Ecology ’s request to determine whether any of its dissolving pulp fits the definition of the specialty grade paper. The resu lt showed that 30% of their production fits the specialty grade definition. The ot her production types are 11% air laid (paper grade) and 59 percent dissolving grade. Ecology established limits for dioxins, furans, and the 12 chlorinated organics as well as the type of bleaching for the mill that produced dissolving grades of pulp.

D ETERMINATION OF AKART FOR CONVENTIONAL POLLUTANTS
Weyerhaeuser appealed the BOD effluent allowa nces for dissolving acetate grades of pulp promulgated in 1982. Weyerhaeuser won and the BOD allowances were remanded back to EPA for reconsideration. As of this date, EPA has not acted on these guidelines. The acetate effluent guidelines for BOD cannot be used as guidelines to determine the limits for BOD without agreement with Weyerhaeuser. However, we are able to use the acetate effluent guidelines in determining AKART.

To determine AKART, we compared the type of treatment the wastewater underwent then and now, the pollution loading on the wa stewater treatment system, and its capability of meeting the effluent guidelines. We were not able to se parate the acetate grad e pulp production from the other grades with respect to the treatment syst em performance. However, we compared the

Page 10 of 38overall performance of the treatment system with the calculated limits with the acetate-grade pulp included from the 1982 effluent guidelines. If the mill could meet the calculated limits at their current production rate and treatment performance level, th en we can determine that the calculated limits are vali d and are reasonable.

In 2001, Weyerhaeuser proposed that the allowa nces for conventional pollutants in the 1982 guidelines’ allowances be used in the guidelines then being pr oposed by EPA. These pollutant allowances included the acetate-grade pulp allo wances. The reasons that Weyerhaeuser was ready to accept the allowance for BOD define d in the 1982 guidelines was as follows: In 1978 when the Weyerhaeuser appealed, they were bl eaching their pulp with elemental chlorine, hypochlorite, and other chemicals and using an ae rated lagoon to treat th eir wastewater. At present the mill uses Elemental Chlorine Free bleaching (ECF) methods -- with oxygen bleaching/delignification on the produced pulp, a nd an activated sludge wastewater treatment plant (which provides be tter operational control) to treat its wastewater. Also, with the construction of the COEL projec t, the operators reduced the in fluent BOD into the secondary treatment system by 40,000 lbs. /day. The reduc tion is approximately 33 percent of the former influent BOD released to the secondary treatment system.

As the mill produced 88.9 percent dissolving grade pulps:

• Weyerhaeuser has been in compliance with their TSS limit except for two times during the terms of the permit.

• Weyerhaeuser met the BOD limit except for one time.

• The mill wastewater treatment system met th e limits more than 99 % of the time.

Therefore, Ecology concludes that the di scharge limits were reasonable.

D ETERMINATION OF AKART FOR A CETATE GRADE PULP

Applying our best professional j udgment we used the allowan ces for conventional pollutants (BOD, TSS, and pH published as the 1982 guideli nes in 40 CFR Part 430 subpart K) for the dissolving grade of pulp. Further applying our be st professional judgment, we determined that the allowances for BOD and TSS (also published in the 1982 effluent guidelines) for the acetate dissolving sulfite pulp producti on is equivalent to AKART for the following reasons:

• New effluent guidelines published on Apr il 15, 1998 changed none of the conventional pollutants allowances for pulps made by the mill.

• Secondary treatment has been and is expected to remain the level of treatment that the effluent guidelines are based on.

• The mill proposed that the acetate pulp allowances for BOD in the dissolving pulp subcategory be used the new efflue nt guidelines being published by EPA.

Page 11 of 38• All other permits that have been issued or drafted by Ecology where the guidelines were not current determined that the 1982 effluent guide lines were equivalent to AKART for other categories of pulp production.

• The mill can comply with the proposed limits for all conventional pollutants.

Determination of AKART for the bl eaching process used at the mill
EPA has indicated that it would not promulgate th e effluent guidelines for the dissolving grades pulp mills in 2004. The EPA still have not prom ulgated any new guideli nes in 2007. Without the effluent guidelines to help de termine the type of process and treatment to be used in defining AKART, Ecology made the AKART determination fo r the dissolving sulf ite pulp production with the aid of the 1998 effluent guidelines fo r the sulfite and Kraft paper grade, and in consultation with EPA staff at Region X and h eadquarters during the drafting of the current NPDES permit.
Available effluent guidelines define best av ailable technology, economically achievable (BAT) for several processes similar, but not iden tical, to the process used by Weyerhaeuser’s Cosmopolis pulp mill.

• Specialty paper-grade (sulfite mills producing pulp with an ISO brightness of 91) must use elemental chlorine free bleaching.

• Other papergrades of pulp made through the sulfite-pulping process must use totally chlorine free (TCF) bleaching.

• Pulp produced at Weyerhaeuser Cosmopolis m ill consists of 30 % specialty grade pulp, 11 % air laid pulp with an ISO brightness of 91, and 59 % dissolving grade.
In establishing ECF as a standard for specialty grade pulp, the EPA determined that the desired quality of the final product c ould not be economically achiev ed by TCF technology. Dissolving grade pulp (almost pure alpha-cellulose) must ha ve fewer impurities than specialty grade, a standard not likely to be achieved with TCF. And according to EPA, there were no other mills producing the mix of products output as th e Cosmopolis mill, using TCF technology.
While Ecology would use no new or untried tech nology to define AKART, we did consider the existing oxygen delignification t echnology currently in use to supplement ECF technology. This process helps to reduce the amount of chlorine needed to achieve the desired product quality, which in turn, reduces the amount of chlorinated organics contamin ation in the final effluent. Ecology therefore defined AKAR T for Weyerhaeuser Company pulp mill at Cosmopolis, Washington as “ECF with oxygen bleaching/delignifi cation” for all categories of pulp currently made there.
The 1998 guidelines specified monitoring and li mitations for chlorinated organic compounds including dioxin for the sulfite specialty pa per grade pulp made with ECF bleaching. The previous NPDES permit placed a mass limit of 0.28 mg/day on dioxin. [This mass limit was derived from a TMDL performed on the receiving water with the non-detect concentration of 10 ppq (pictogram per liter) showing compliance.] The 0.28 mg/day mass limit equates to a measured concentration below th e detection limit for dioxin.

Page 12 of 38The 1998 guidelines placed a limit of 10 ppq on dioxins and furans (2,3,7,8 TCDD and 2,3,7,8- TCDF) for mills producing specialty grade pulp. The guidelines require compliance in the bleach plant effluent for 2,3,7,8 TCDD and 2,3,7,8-TC DF. We used the 1998 effluent guidelines limit (with the non-detect of 10 ppq) for 2,3,7,8 TCDD. We also kept the waste load allocation (WLA) mass limit in the proposed permit. The comp liance point is at the bleach plant effluent. Meeting the nondetect at the ble ach plant shows compliance with the final effluent mass limit.
There was no limit for 2,3,7,8-TCDF in the prev ious permit. The EPA and Weyerhaeuser sampled and analyzed for both 2,3,7,8 TCDD an d 2,3,7,8-TCDF in the bleach plant effluent during the sampling for promulgating the sulfite pul ping subcategory. In c onversations with the EPA we heard that Weyerhaeuser’s pulp mill at Co smopolis was the best performer in the sulfite subcategory. At this time the mill cannot m eet the nondetect limit of 10 ppq for 2,3,7,8-TCDF at the bleach plant discharge point. The 31.9 ppq limit for 2,3,7,8-TCDF in the bleached Kraft paper subcategory is the only other limit established for this compound in the 1998 effluent guidelines. Weyerhaeuser can meet the 31.9 ppq limit for 2,3,7,8-TCDF. Therefore, since Weyerhaeuser was the best performer of all sulfite mills, the limit of 31.9 ppq for 2,3,7,8-TCDF is placed in the proposed permit with complia nce measured at the bleach plant effluent.

The 1998 effluent guidelines for the specialty gr ade of pulp production did not place limits on absorbable organic halides (AOX), but reserved a placeholder in the guidelines. The previous permit placed a performance limit on AOX. The previous permit placed a monthly average AOX limit of 2,180 lbs/day and a daily maxi mum AOX limit of 2,720 lbs/day based on the performance of the pulping process and the seco ndary wastewater treatment system. Ecology based the monthly average AOX limit on 99 perc entile and the daily maximum AOX limit on 95 percentile from data submitted by the Permittee. Ecology considers the limits still valid and placed these limits in the proposed permit. When the EPA publishes the dissolving grade sulfite effluent guidelines, Ecology may reopen the permit and modify the limits for AOX.
The previous permits assigned limits for fecal coli form. Since the effluent is highly colored with light absorbing chemicals, the wa ter has to be disinfected with chlorine containing compounds. Use of any type of light source does not disinfect the effluent because of it absorption by the colored chemicals within the effluent water. In fact it is unknow n how much disinfection actually occurs since the final effluent show s a high BOD although within the permit limit. AOX can be formed during the disinfection with ch lorine containing chemical used to control fecal coliform. So the proposed permit reta ins the monitoring requirements for 2,3,7,8 TCDD and for 2,3,7,8 TCDF. The frequency is yearl y. Monitoring for 2,3,7,8 TCDD and TCDF in the sludge at the sludge lagoon was been eliminated in the current permit. In lieu of this, a condition was placed in the current permit requiring the Permittee to monitor the secondary sludges for 2,3,7,8 TCDD and 2,3,7,8 TCDF yearly.
The 1998 effluent guidelines did not limit chloroform in the bleach plant effluent. However, the guidelines had placeholder for chloroform. Sin ce EPA 1998 effluent do not set allowances for chloroform, so the proposed permit only requ ires monthly monitoring for chloroform.
The 1998 effluent guideline placed limits for 12 chlorinated phenolic pollutants, dioxins, and furans for paper and specialty grades of pulp produced by sulfite mills. Chlorinated phenolic pollutants limited for the specialty grade and paper grade produced at sulfite mills are as follows:

Page 13 of 38Compounds Method Limit
Trichlorosyringol 1653 < 2.5 μ g/L
3,5,6-Trichloroguaiacol 1653 < 5.0 μ g/L

3,4,5-Trichlorocatechol 1653 < 2.5 μ g/L

3,4,6-Trichlorocatechol 1653 < 2.5 μ g/L
3,4,5-Trichloroguaiacol 1653 < 2.5 μ g/L
3,4,6-Trichloroguaiacol 1653 < 2.5 μ g/L
2,4,5-Trichlorophenol 1653 < 2.5 μ g/L
2,4,6-Trichlorophenol 1653 < 2.5 μ g/L

Tetrachlorocatechol 1653 < 5.0 μ g/L
Tretachloroguaiacol 1653 < 5.0 μ g/L
2,3,4,6-Tetrachlorophenol 1653 < 2.5 μ g/L
Pentachlorophenol 1653 < 5.0 μ g/L The proposed permit imposes chlorinated phenolic pollutants limits because Weyerhaeuser made these types of pulp in significant quantity.

Section 2, Cocidus

Cocidus will make acetate-grade of pulp (a di ssolving grade of pulp), exclusively. Ecology’s arguments for using the effluent guidelines in determining AKART for the dissolving grades of pulp apply to the Cocidus mill since Weyerhaeuse r operated the mill as a significant producer of acetate pulp. To make acetate grade of pulp, Coci dus will use the bleaching process already in place at Weyerhaeuser’s mill. Therefore, th e present bleaching process uses all known and reasonable treatment (AKART) dur ing production. Further, Ecol ogy rolled all of the monitoring and limits in the current permit into proposed permit with the same fr equency, included the requirement for a best management practices (BMP) - CFR 430.03 - for spent pulping liquor.

The proposed permit provides a compliance date of three years after the e ffective date of the permit for complying with CFR 430.03 requirement s. Ecology considers these proposed permit limits are close to the expected limitation of the effluent guidelines requirements (if and when they are promulgated). The e ffluent guidelines required Weye rhaeuser to be in with the bleaching requirements three years after the efflue nt guidelines are promulgated. Because so few sulfite mills are operating at the time, we don’t e xpect the effluent guidelines to be promulgated in the near future. Therefore, Ecology will requi re that the Cocidus Mill’s bleaching system to meet the existing Subpart S requirements three years after the effective date of the permit. Order Number 2484 required Weyerhaeuser to be in compliance with the bleaching requirements of 40 CFR Part 63, Subpart S on or before November 12, 2006. Order Number 2484 will be modified

Page 14 of 38to require the new owner to be in compliance wi th the bleaching requirements three years after the effective date of the proposed permit. Si nce the 12 chlorinated phe nolic pollutants, dioxin, and furan limits and the type of bleaching th at was in placed in the current permit when Weyerhaeuser operated the mill related to the production of specialty grade of pulp, it would be backsliding to relax these limits.

The monthly average and the daily maximum limit for BOD and TSS using the forecasted production of 550 air dried short tons and the effluent guidelines proposed permit will be:

Monthly Average Daily Maximum BOD 5 29,040 Lbs/day 55,880 Lbs/day TSS 41,855 Lbs/day 77,935 Lbs/day

The effluent guidelines for acetate grade pul p – pounds of pollutants per 1000 pounds production

- are:

Monthly Average Daily Maximum BOD 5 26.4 Lbs/1000 lbs Production 50.8 Lbs/1000 lbs Production TSS 38.05 Lbs/1000 lbs Production 70.85 Lbs/1000 lbs Production

T OTAL CHLORINE F REE (TCF) STUDY

Even though AKART in this proposed permit is defined as elemental chlorine free (ECF) bleaching, the Permittee is required to complete a total chlorine free (TCF) study to fulfill Ecology’s commitment to determine whether requ iring further reduction of chlorinated organic chemicals is reasonable. The proposed permit requires Cocidus to submit the TCF study three years after the effectiv e date of the permit.

SURFACE WATER QUALITY-BASED EFFLUENT LIMITATIONS

In order to protect existing water quality and preserve the designated beneficial uses of Washington's surface waters, WAC 173-201A-060 stat es that waste discharge permits shall be conditioned such that the discharge meets esta blished Surface Water Quality Standards. The Washington State Surface Water Quality Sta ndards (Chapter 173-201A WAC) is a state regulation designed to protect the beneficial uses of the surface waters of the state. Surface water quality-based effluent limitations may be based on an individual waste load allocation (WLA) or on a WLA developed during a basin wide total maximum daily loading study (TMDL).

N UMERICAL C RITERIA FOR THE P ROTECTION OF A QUATIC L IFE "Numerical" water quality criteria are numerical values set forth in th e State of Washington's Water Quality Standards for Surface Waters (Chapt er 173-201A WAC). They specify the levels of pollutants allowed in receiving water while re maining protective of aquatic life. Numerical criteria set forth in the Water Quality Standards are used along with chemical and physical data for the wastewater and receiving water to derive the effluent limits in the discharge permit.

Page 15 of 38When surface water quality-based limits are more stringent or potentially more stringent than technology-based limitations, they must be used in a permit.

N UMERICAL C RITERIA FOR THE P ROTECTION OF H UMAN H EALTH The U.S. EPA has promulgated 91 numeric water quality criteria for th e protection of human health that are applicable to Washington State (EPA 1992). These criteria are designed to protect humans from cancer and other disease and are primarily applicable to fish and shellfish consumption and drinking water from surface waters.

N ARRATIVE C RITERIA

In addition to numerical criter ia, "narrative" water quality criteria (WAC 173-201A-030) limit toxic, radioactive, or deleterious material concentrations below t hose which have the potential to adversely affect characteristic water uses, cause acute or chronic toxici ty to biota, impair aesthetic values, or adversely affect human heal th. Narrative criteria protect the specific beneficial uses of all fresh (WAC 173-201A- 130) and marine (WAC 173-201A-140) waters in the State of Washington.

A NTIDEGRADATION
The State of Washington's Antidegradation Policy requires that discharges into receiving water shall not further degrade the ex isting water quality of the water body. In cases where the natural conditions of the receiving water are of lower quality than the criteria assigned, the natural conditions shall constitute the wa ter quality criteria. Similarly, when the natural conditions of the receiving water are of higher quality than th e criteria assigned, the natural conditions shall constitute the water quality criteria. More information on the State Antidegradation Policy can be obtained by referring to WAC 173-201A-070.
Ecology completed a total maximum daily load (TMDL) for fecal coliform in the receiving water 2003 and on January 30, 2004 the Environmental Prot ection Agency approved our findings. The fecal coliform bacteria limits in the NPDES pe rmit we issued to Weyerhaeuser Cosmopolis in 2003, coordinated with the waste load allocations (WLA) in the TMDL for the Chehalis River and Grays Harbor to ensure that the fecal colifor m levels met the water quality criteria for these water bodies. The NPDES permit limits and the TMDL WLAs for fecal coliform ensured that the mill’s discharges would not degrade these water bodies outside the mixing zone. We found no indications that the water bod ies would be degraded by any ot her pollutant discharged from the mill - except the whole effluent toxicity re quirements – discussed later in the factsheet.

C RITICAL C ONDITIONS
Surface water quality-based limits are derived for the waterbody's critical condition, which represents the receiving water and waste discharge condition with the highest potential for adverse impact on the aquatic bi ota, human health, and existi ng or characteristic water body

uses.

Page 16 of 38M IXING Z ONES
The Water Quality Standards allow the Department of Ecology to authorize mixing zones around a point of discharge in establis hing surface water quality-based effl uent limits. Both "acute" and "chronic" mixing zones may be au thorized for pollutants that can have a toxic effect on the aquatic environment near the point of discharge. The concentration of pollutants at the boundary of these mixing zones may not exceed the numerical criteria for that type of zone. Mixing zones can only be authorized for discha rges that are receiving all kn own, available, and reasonable methods of prevention, control, and treatment (AKART) and in accordance with other mixing zone requirements of WAC 173-201A-100. The wa stewater treatment system at the mill is considered to be at AKART. Therefore, the mill is allowed to have a mixing zone(s).
The National Toxics Rule (EPA, 1992) allows the ch ronic mixing zone to be used to meet human health criteria.

D ESCRIPTION OF THE R ECEIVING W ATER The facility discharges to the Grays Harbor (Outfall 001) designa ted as a Class B marine water and the Chehalis River (Outfall 002) designated as a Class A fresh water respectively in the vicinity of the respective outfall. Other ne arby point source outfalls includes the City of Hoquiam, Grays Harbor Paper Company, and the City of Aberdeen. Significant nearby nonpoint sources of pollutants includes log yards, stormwater discharges from Aberdeen and Hoquiam, farming and cattle ranches up river. Ch aracteristic uses include the following: water supply (industrial, agricultural) ; stock watering; fish migration; fish and shellfish rearing, spawning and commercial harvesting; wildlife habitat; secondary cont act recreation; sport fishing; boating and aesthetic en joyment; commerce and navigation. Water quality of this class shall meet or exceed the requirements for most uses.

S URFACE W ATER Q UALITY C RITERIA
Applicable criteria are defined in Chapter 173-20 1A WAC for aquatic biot a. In addition, U.S. EPA has promulgated human health criteria for toxic pollutants (EPA 1992). Criteria for this discharge are summarized below for the marine waters:

Fecal Coliforms 100 colonies/100 mL ma ximum geometric mean and not have more than 10 % of the all samples obtained for calculating the geometric mean value exceeding 200 colonies/100 mL Dissolved Oxygen 5 mg/L minimum Temperature 19 degrees Celsius maximum pH 7.0 to 8.5 standard units Turbidity less than 10 NTU above background

Toxics No toxics in toxic amounts (s ee Appendix C for numeric criteria for toxics of concern for this discharge)

and below for the freshwater:

Page 17 of 38Fecal Coliforms 100 colonies/100 mL ma ximum geometric mean and not have more than 10 % of the all samples obtained for calculating the geometric mean value exceeding 200 colonies/100 mL Dissolved Oxygen 8 mg/L minimum Temperature 18 degrees Celsius maximum pH 6.5 to 8.5 standard units Turbidity less than 10 NTU above background

Toxics No toxics in toxic amounts (s ee Appendix C for numeric criteria for toxics of concern for this discharge)

C ONSIDERATION OF S URFACE W ATER Q UALITY -B ASED L IMITS FOR N UMERIC C RITERIA If any pollutant concentrations in the proposed discharges exceed wate r quality criteria with technology-based controls that the Department has determined to be AKART a mixing zone is authorized in accordance with the geometric confi guration, flow restriction, and other restrictions for mixing zones in chapter 173- 201A WAC and is defined as follows for outfall 001: The chronic dilution zone is 210 feet upstream and do wnstream of the diffuser except for the fecal coliform extended mixing zone. For fecal colifo rm the extended mixing zone is 1300 meters (4300 feet). The acute mixing zone is 21 feet upstream and downstream of the diffuser.
The dilution factors of effluent to receiving water that occur within these zones have been determined at the critical condition by the use of UDKHDEN computer model:

Acute Chronic Extended Percentile receiving water speed 50 percentile 50 percentile (far field)

Aquatic Life 9:1 74:1 83:1 Human Health, Carcinogen 74:1

Human Health, Non-carcinogen 74:1

Extended mixing factor 250:1

The dilution ratio of 74:1 was used in the reason able potential for chroni c water quality and 83:1 for health quality criteria and temperature. We yerhaeuser re-evaluated the dispersion factor and the tidal averaging used in the mathematical mode l to obtain the 83:1 dilu tion ratio. The dilution ratio of 83:1 was used for the temperature criteria . The acute factor was used to determine the ACEC. The 50 percentile (far field) was used to determine the CCEC.
For outfall 002 the chronic dilution zone is 210 feet and the acute mixing zone is 21 feet upstream and downstream of the discharge point. The dilution factors for the acute and chronic dilution factors are 4:1 and 34:1, respectively.

Page 18 of 38Pollutants in an effluent may affect the aquati c environment near the poi nt of discharge (near field) or at a considerable dist ance from the point of discharge (far field). Toxic pollutants, for example, are near-field pollutants--their advers e effects diminish rapidly with mixing in the receiving water. Conversely, a pollutant such as BOD is a fa r-field pollutant whose adverse effect occurs away from the discharge even af ter dilution has occurred. Thus, the method of calculating surface water quality-based effluent limits varies with the point at which the pollutant has its maximum effect.
The derivation of surface water qual ity-based limits also takes into account the variability of the pollutant concentrations in both the effluent and the receiving water.

F ECAL COLIFORM EXTENDED MIXING ZONE AND LIMIT

Weyerhaeuser outfall line (outfall 001) discha rged wastewater upstream from commercial oyster beds. Ecology, Weyerhaeuser, Weyerhaeuser’s c onsultants, and the Department of Health worked together to determine a fecal coliform limit to be placed into the Weyerhaeuser mill’s latest permit. We derived the limit based on a die off study, using experimental data on the fate of the fecal coliform once discharged into Gray s Harbor, and on a state of the art far field dilution model. The die-off study was perfor med by IEH, Inc. and the dilution study was performed by CH2MHill, Inc. The dilution model chosen was ADCIRC from the U S Army Corps of Engineers.

These studies, the depressions of the economy of Grays Harbor County due to mill closures, and with due considerations of the water quality a nd the total maximum daily load (TMDL) allowed to enter the Chehalis River and Grays Harbor estuary, an extended mixing zone with the corresponding dilution ratio helped us determine th e amount of fecal coliform that Weyerhaeuser could safely discharged by vi a outfall 001. The extended mixing zone boundary was determined to be 4300 feet with a diluti on ratio of 250:1. The correspo nding permit limit was a 30 days geometric mean of 42,000 count/100 ml with no more than 10 percent exceeding 128,000 count/100 ml. These limits will continue in th e proposed permit. Within the preceding four years, Weyerhaeuser has not violated the permit lim it. There have been no indications that the oyster beds have been affected except for two one week closures. The Department of Health closed the harvesting of oysters within the ar ea twice when Weyerhaeuser fecal coliform count exceeded their criteria – 113,000 count/100 ml.

Best management plan to control fecal coliform

During startup of the wastewater treatment system and of the mill, Weyerhaeuser filled the bioponds with fresh water before adding wastewat er. Starting the bioponds with wastewater cause odors to be generated in the pond by anaer obic decomposition of the wastewater and high fecal counts in the effluent from the bioponds . To prevent odors and high fecal count, Weyerhaeuser was allowed to pump fresh water fr om the earth settling ar ea near the bioponds preceding outfall 002 as needed before adding wa stewater to any biopond at any time. The location of the pumps was confined to their pr operty and primary treatment system. The water so pumped was discharged via outfall 001 instead of outfall 002. The amount of the water was insignificant as compared to the water normally discharged by either outfall 001 and/or outfall 002. This condition is kept in the proposed permit.

Page 19 of 38W ATER QUALITY ANALYSES OUTFALL 001

BOD 5 --Under critical conditions ther e is no predicted violation of the Water Quality Standards for Surface Waters. Therefore, the technology-based effluent limitation for BOD 5 was placed in the permit.
The BOD limits in the current permit were place d in the permit after a dissolved oxygen study was done while Rayonier, Inc. was operating and discharging wastewater with a high BOD. Since the study was done, Rayonier, Inc. ceas ed operating the pulp mill at Hoquiam, Washington. At this time Grays Harbor Paper, LP operates the paper mill. The main difference is that presently, the BOD limits for the paper mill is about 25 percent of the pulp and paper mill limit during Rayonier, Inc. tenure. The proposed permit will have a BOD daily maximum of 55,880 lbs/day. The Grays Harbor Paper, LP BOD daily maximum limit is 7,800 lbs/day. The total load would be 63,880 lbs/day. Outfall 001 is located in the south channel and Grays Harbor Paper Company, LP outfall is located in the Nort h Channel. The two channels come together near the point of discharge during high tide. The dissolved oxygen was monitored downstream of the outfalls for many years without showi ng any depressions while Rayonier, Inc. and Weyerhaeuser were both operating their respective mills; namely, after both Weyerhaeuser and Rayonier, Inc. installed secondary wastewater tr eatment. Table 2 shows the monthly average and daily maximum limits for BOD when both Weyerhaeuser and Rayonier, Inc. were discharging and the discharge limits when bot h Cocidus and Grays Harbor Paper would be discharging. In 2006, Grays Harbor Paper, LP maximum BOD discharge was less than 3,000 lbs/day. Weyerhaeuser permit that was in effect during ITT Rayonier oper ations restricted the daily maximum BOD limit to 35,000 lbs/day during ev ents when the receiving water flow was less than 2,000 cfs. Table 2 s hows that combining the 35,000 lb s/day daily maximum limit with ITT Rayonier daily maximum limit for river flow s less than 2,000 cfs wo uld be less than the Cocidus projected limit plus Gr ays Harbor current BOD limit or a total of 63,880 lbs BOD/day. These numbers are practicably the same numbers. The technology limits will be placed in the permit without restrictions to the river flow. The difference in the daily maximum BOD limits for the two river flows is only 1.2 percent.
After Weyerhaeuser and ITT Rayonier installe d secondary treatment, the mills noted no problems with dissolved oxygen during the years of monitoring dissolved oxygen in the Harbor. Therefore, it is very unlikely that the combined discharges of Cocidus and Grays Harbor Paper, LP would depress the dissolved oxygen low enough to harm fishes in Grays Harbor since the load would be approximately equal to the combined Weyerhaeuser and Rayonier.

Table 2. Discharge limits comparison River flow <2000 cfs River flow >2000 cfs River flow <2000 cfs River flow >2000 cfs 2006 – Past 2007- Future Monthly Average Daily Maximum Daily Maximum Monthly Average Daily Maximum Daily Maximum ITT Rayonier 14,580 27,923 27,923 Weyerhaeuser Mill 23,900 35,000 45, 791 29,040 55,123 55,880 Grays Harbor 4,000 7,800 7,800 38,480 62,923 73,714 33,040 62,923 63,680

Page 20 of 38The daily maximum technology limit for BOD and daily maximum allowed when both Weyerhaeuser and Rayonier, Inc. were operating is essentially the same for all river flows. Therefore, the technology limit is placed in the pe rmit without any restriction due to river flows.
Temperature --The impact of the discharge on the te mperature of the receiving water was modeled by simple mixing analysis at the critical condition. The receiving water temperature at the critical condition is 19.0 o C and the effluent temperature is 38 o C. We predict resultant temperature at the boundary of th e chronic mixing zone is 19.22 o C. Ecology treats temperature criteria as a chronic criterion using the 50-percentile velocity of the receiving water current’s speed, measured over one tidal cycle. Ecol ogy approved treating temp erature as a chronic criterion with the use of 50th percentile current ve locity. Analyses of acute effects showed that salmonid smolts are very unlikely to be adversely affected by the short term increase in temperature within th e receiving waters.

• Critical conditions results in no measurable temperature increase. The calculated increase of temperature is less than the 0.3 o C; Chapter 173-201A WAC, water quality rules, allows the be nign increase.

• The dilution factor of the rece iving water/effluent, calculated at 2 second after leaving the plume, is 5.7:1. The temperature of th e receiving water at this point is 21.8 o C. The temperature of the receiving water is less than 33 o C.
Therefore, no effluent limitation for temper ature was placed in the proposed permit. The Permittee is required to monitor and to report th e measured daily maximum temperature of the effluent on its monthly discharge monitoring reports.
pH --Because of the high buffering capacity of ma rine water, compliance with the technologybased limits of 5 to 9 assures compliance with the Water Quality Standards for Surface Waters. The 1 SU exceptions to the pH in the current permit is placed in the proposed permit with the current permit time limitation.
Turbidity --The impact of turbidity was evaluated on the turbidity in the effluent and turbidity of the receiving water. Due to the large degree of dilution, we determin ed that the turbidity criteria would not be violated outsid e the designated mixing zone.

Toxic Pollutants --Federal regulations (40 CFR 122.44) require NPDES permits to contain effluent limits for toxic chemicals in an efflue nt whenever there is a reasonable potential for those chemicals to exceed the surf ace water quality criteria. This process occurs concurrently with the derivation of technology-based effluent li mits. Facilities with technology-based effluent limits defined in regulation are not exempted from meeting the Water Quality Standards for Surface Waters or from having surface water quality-based effluent limits.
To determine the reasonable potential for copper, zinc, nickel, manganese, and lead to exceed the water quality criteria we used evaluation with procedures defi ned by EPA, 1991 at the critical conditions. All of the detected chemicals met the water quality criteria. The dioxin measured below the detection limit. We analyzed the reason able potential for copper to exceed the criteria using the river samples taken by Grays Harbor Pa per, L. P. in 2000 for dissolved copper and Weyerhaeuser Company’s data for dissolved copper from August 1994. The proposed permit

Page 21 of 38has a waste load allocation limit for dioxin, a nonde tected chemical species. The limit for dioxin at the bleach plant placed in the proposed permit fulfills the WLA for dioxin.

W HOLE E FFLUENT T OXICITY

The current permit required the Permittee to perf orm both acute and chronic characterization of their effluent. Weyerhaeuser appealed the WET requirements. Ecology issued an agreed compliance order on February 3, 2005 settling the a ppeal of the WET testing requirements in the NPDES permit. The settlement ordered Weyerhaeuser to perform a TI/RE. The results of the TI/RE revealed no reasonable methods of treatments that could remove enough toxicity from the effluent that would allow the mill to be in compliance with the chronic WET limit in their permit, i.e., that is, with respect to growth of oyster larvae. In the future, new technology may be discovered that could remove sufficient toxicity from dissolving sulfite effluent to allow compliance of the WET rules for sulfite mills. We will issue a compliance order when we issue the proposed NPDES permit.

The acute critical effluent concentration (ACEC) is 11.11 percent and the chronic critical effluent concentration (CCEC) is 1.35 percent. The pr oposed permit contains both acute and chronic WET testing requirements and limits at the percen t effluents, respectively. The Permittee must investigate ways to be in compliance with the WET rule during the term of the permit and/or permitting process.

Table 3 WET Test Results Sample

Date Start Date Lab Organism Endpoint NOEC LOEC

7/21/92 Weyerhaeuser Testing Ceriodaphnia dubia 7-day Survival 100 > 100 Reproduction 25 50

7/21/92 Weyerhaeuser Testing fathead minnow 7-day Survival 100 > 100 Biomass 100 > 100 Weight 100 > 100

9/28/92 9/29/92 CH2MHill Ceriodaphnia dubia 7-day Survival 100 > 100 Reproduction 50 75

9/29/92 Weyerhaeuser Testing fathead minnow 7-day Survival 100 > 100 Biomass 100 > 100 Weight 100 > 100

1/19/93 Weyerhaeuser Testing Ceriodaphnia dubia 7-day Survival 75 100 Reproduction 12.5 25

1/20/93 Weyerhaeuser Testing fathead minnow 7-day Survival 50 75 Biomass 25 50 Weight 25 50

5/4/93 Weyerhaeuser Testing Ceriodaphnia dubia 7-day Survival 100 > 100 Reproduction 50 100

Page 22 of 385/4/93 Weyerhaeuser Testing Fathead minnow 7-day Survival 100 > 100 Biomass 50 75 Weight 50 75

5/23/94 5/25/94 Northwestern Aquatic Sciences Pacific oyster Proportion Normal 2 4 Survival 9 18

9/19/94 9/20/94 Northwestern Aquatic Sciences Pacific oyster Proportion Normal 1 2 Survival 70 > 70

11/29/94 11/29/94 Northwestern Aquatic Sciences mussel Proportion Normal 2 4 Survival 35 70

2/28/95 3/1/95 Northwestern Aquatic Sciences mussel Proportion Normal 2 4 Survival 70 > 70

1/14/04 1/14/04 Nautilus Environmental mussel Proportion Normal 1.35 6.25 Survival 50 > 50

6/14/04 6/15/04 Nautilus Environmental Pacific oyster Proportion Normal < 1.35 1.35 Survival 1.35 6.25

9/27/04 9/28/04 Nautilus Environmental Ceriodaphnia dubia 7-day Survival 100 > 100 Reproduction 100 > 100

9/27/04 9/28/04 Nautilus Environmental Atlantic mysid 7-day Survival 25 50 Biomass 11.1 25 Weight 11.1 25

9/27/04 9/28/04 Nautilus Environmental fathead minnow 7-day Survival 100 > 100 Biomass 100 > 100 Weight 100 > 100

9/27/04 9/28/04 Nautilus Environmental top smelt 7-day Survival 25 50 Biomass 25 50 Weight 25 50

10/18/04 10/19/04 Nautilus Environmental mussel Proportion Normal 0.1 0.5 Survival 50 > 50

10/27/04 10/28/04 Nautilus Environmental top smelt 7-day Survival 25 50 Biomass 11.11 25 Weight 50 > 50

10/27/04 10/28/04 Nautilus Environmental Atlantic mysid 7-day Survival 25 50 Biomass 11.11 25 Weight 11.11 25

Page 23 of 3811/17/04 11/18/04 Nautilus Environmental mussel Proportion Normal 0.1 0.5 Survival 50 > 50

5/11/05 5/12/05 Nautilus Environmental Atlantic mysid 7-day Survival 50 100 Biomass 25 50 Weight 25 50

1/23/06 1/24/06 Nautilus Environmental Atlantic mysid 7-day Survival 50 100 Biomass 25 50 Weight 25 50

1/25/06 1/26/06 Nautilus Environmental mussel Proportion Normal 1.35 > 1.35 Survival 1.35 6.25

5/23/06 5/23/06 Nautilus Environmental Atlantic mysid 7-day Survival 25 50 Biomass 11.11 25 Weight 25 50

7/24/06 7/25/06 Nautilus Environmental Atlantic mysid 7-day Survival 25 50 Biomass 25 50 Weight 25 50

H UMAN H EALTH Washington’s water quality standards now include 91 numeric health-based criteria that must be considered in NPDES permits. These criteria were promulgated for the state by the U.S. EPA in its National Toxics Rule (Fed eral Register, Volume 57, N o. 246, Tuesday, December 22, 1992). The Department has determined that the appli cant's discharge does not contain chemicals of concern based on existing data or knowledge. The discharge will be re-evaluated for impacts to human health at the next permit reissuance.
A determination of the discharge's potential to cause an exceedance of the water quality standards was conducted as required by 40 CFR 122.44(d). The reasonable potential determination was evaluated with procedures given in the Technical Support Document for Water Quality-Based Toxics Control (EPA/505/ 2-90-001) and the Department's Permit Writer's Manual (Ecology Publication 92-109, July, 1994) . The determination indicated that the discharge has no reasonable potentia l to cause a violation of wate r quality standards, thus an effluent limit is not warranted. The dioxin and furan limits are technology limitations.

S EDIMENT Q UALITY

Sediment sampling was conducted on September 9, 1993. The Department has determined that this discharge has a low potential to cause a violation of the se diment quality standards based on a screening-level evaluation of the discharge(s) that shows th e potential to cause sediment contamination is unlikely. Therefore, no sediment monitoring is required.

Page 24 of 38PREVIOUS LIMITATIONS FOR OUTFALL 002

Stormwater, fresh water-treatment-system-backwa sh, and freshwater overflow are discharged through Outfall 002. The previous permit had the following limitations:

EFFLUENT LIMITATIONS: OUTFALL # 002

Parameter Minimum Maximum pH 5 SU - 1 SU for ≤ 60 minutes 2 9.0 SU + 1 SU for ≤ 60 minutes 2

Parameter Monthly Average Daily Maximum Biochemical oxygen demand (BOD 5 ) - 500 Lbs./day

Oil and grease 10 mg/L 15 mg/L

Fecal coliform* 6,000 #/100 mL. - *With no more than 10 % of the samples used in calculating the geometric monthly mean to exceed 14,000 #/100 mL.

The proposed permit retains the BOD limit. Th e Fecal coliform limits are taken out of the proposed permit. The oil and grease limit was ta ken out since testing for over ten years has not detected the parameter. Copper, zinc, and lead measured a great deal less than the bench marks for these chemicals in the general stormwater permit. No ammonia is intr oduced into the treatment system for outfall 002. Primary treatment is considered AKART for stor mwater. Because the stormwater collected and discharged through outfall 002 receives prim ary treatment and is limited by the above limitations, no further stormwater te sting is required. The discharg e is mostly filter backwash from the water treatment plant. Therefor e, the stormwater pollution prevention plan requirements are not placed in the permit since the permit has limits for BOD. Weyerhaeuser is required to monitor for BOD daily. The WET tes ting requirements are taken out of the proposed permit since there is very little process discha rged via outfall 002. Th ere was no toxicity found during the WET character ization monitoring.

GROUND WATER QUALITY LIMITATIONS
The Department has promulgated Ground Water Qu ality Standards (Chapter 173-200 WAC) to protect beneficial uses of ground water. Permits issued by the Department shall be conditioned in such a manner so as not to allow viola tions of those standa rds (WAC 173-200-100).
This Permittee has the potential to discharge to groundwater fr om the bioponds. However, the ponds are close to surface waters that discharg ed into the Permittee receiving waters. If the water in the bioponds discharged into ground water, the water would end up in the receiving water. Therefore, no limitations are required based on potential effects to ground water. The solid waste landfills near pond D are regulated by the county.

Page 25 of 38COMPARISON OF EFFLUENT LIMITS WIT H THE EXISTING PERMIT ISSUED SEPTEMBER 30, 2003

Existing Limits Proposed limits

BOD 5

Monthly Average 23,800 lbs./day 29,040 lbs./day Daily Maximum 45,800 lbs./day 55,880 lbs./day

TSS

Monthly Average 36,100 lbs./day 41,855 lbs./day
Daily Maximum 67,000 lbs./day 77,935 lbs./day

Fecal coliform

Monthly Geometric

mean 42,000 count /100 ML 1 42,000 count /100 ML 1

Daily Maximum - - pH

Minimum w. exception 5 SU - 1 SU for ≤ 60 minutes 2 5 SU - 1 SU for ≤ 60 minutes 2

Maximum w. exception 9 SU + 1 SU for ≤ 60 minutes 2 9 SU + 1 SU for ≤ 60 minutes 2

Dioxin 3 10 ppq at Bleach plant effluent 10 ppq at Bleach plant effluent
2,3,7,8-TCDF 31.9 ppq at Bleach plant efflue nt 31.9 ppq at Bleach plant effluent

AOX
Monthly Average 2180 lbs/day 2180 lbs./day
Daily Maximum 2720 lbs./day 2720 lbs./day

12 chlorinated phenolics DL at Bleach plant effluent DL at Bleach plant effluent

1 With no more than 10 percent of the sa mples used in calculating the monthly geometric mean to exceed 128,000 count/100 mL.

2 Total exceptions ≤ 7 hours 26 minutes per month

3 Compliance Nondetect at 10 ppq at final effluent

Page 26 of 38MONITORING REQUIREMENTS
Monitoring, recording, and reporting are re quired (WAC 173-220-210 and 40 CFR 122.41) to verify that the treatment process is functioning correctly and the effluent limitations are being achieved. The monitoring schedule is detailed in the proposed permit under Condition S.2. Specified monitoring frequencies take into accoun t the quantity and variability of the discharge, the treatment method, past compliance, significa nce of pollutants, and cost of monitoring.
Reduced Monitoring:

The proposed permit modification describes under what conditions the facility may suspend monitoring of the required parameters during mill outages. The following tables detail the reduced monitoring schedule when the facility is closed and no longer producing pulp. The facility must follow the original permit monitoring schedule u pon start up of the facility.

Category Parameter Units Sample Point Minimum Sampling Frequency Sample Type

Wastewater

Effluent outfall 001 Flow MGD Final effluent (a) 24 hr integrated

“ BOD 5 mg/l “ (b) 24 hr composite

“ TSS mg/l “ (b) “

“ pH Standard Units “ (a) Instantaneous

“ Temperature Degree Centigrade “ (d) Instantaneous

“ AOX mg/l “ (d) 24 hr composite

“ 2,3,7,8-TCDD pg/L - ppq “ (d) “

“ 2,3,7,8-TCDF pg/L - ppq “ (d) “

“ Fecal coliform by MF method #/100 mls “ (c) Grab

“ Chemical oxygen demand (COD) mg/l “ (d) 24 hr composite

Page 27 of 38Category Parameter Units Sample Point Minimum Sampling Frequency Sample Type

Pulp machine

room Production Tons/day Off the machine (d) Calculated

Bleach plant effluent 2,3,7,8-TCDD pg/L - ppq Final Bleach plant effluent (d) 24 hr composite

“ 2,3,7,8-TCDF pg/L - ppq “ (d) “

“ Trichlorosyringol μ g/l “ (d) “

4,5,6- Trichloroguaiacol μ g/l “ (d) “

“ 3,4,5- Trichlorocatechol μ g/l “ (d) “

“ 3,4,6- Trichlorocatechol μ g/l “ (d) “

“ 3,4,5- Trichloroguaiacol μ g/l “ (d) “

“ 3,4,6- Trichloroguaiacol μ g/l “ (d) “

“ 2,4,5- Trichlorophenol μ g/l “ (d) “

“ 2,4,6- Trichlorophenol μ g/l “ (d) “

“ Tetrachlorocatechol μ g/l “ (d) “

“ Tretachloroguaiacol μ g/l “ (d) “

“ Pentachlorophenol μ g/l “ (d) “

“ 2,3,4,6- Tetrachlorophenol μ g/l “ (d) “

“ Chloroform mg/l “ (d) 24 hr composite WET Testing (e)

(a) Continuous monitoring as long as there is flow.

Page 28 of 38(b) Daily monitoring for two weeks after ceasi ng pulp production. Weekly for week three through week six after ceasing pulp pr oduction and quarterly thereafter. (c) Daily monitoring for two weeks after ceasing pu lp production. Weekly for week three through week six after ceasing pulp production. Monthl y thereafter until aeration ponds 1-4 and spent sulfite storage ponds are flushed out and quarterly thereafter. If fecal co liform membrane filter test show more than 50,000 count/100 mL, the facil ity must resume daily testing until results are less than 50,000 count/100 mL for three consecutive days. (d) No further monitoring afte r ceasing pulp production. (e) Wet testing characterization for Acute and Chronic must be performed once between November 1, 2006, to December 15, 2006.

Category Parameter Units Sample Point Minimum Sampling Frequency Sample Type

Outfall 002 Flow MGD Final Effluent (g)(k)

“ Fecal Coliform by FF method #/100 mls “ (h)(k) Grab

“ BOD 5 mg/l “ (i)(k) 24 hour composite

“ Oil & Grease Mg/l : (d) Grab

“ pH SU “ (j)(k) Instantaneous WET Testing (d)

(d) No further monitoring from date of ceasing pulp production. (g) Continuous monitoring for one year following date of ceasing pulp production. (h) No further monitoring afte r two months following date of ceasing pulp production. (i) No further monitoring afte r one month following date of ceasing pulp production. (j) Continuous monitoring for pH following th e date of ceasing pulp production. (k) No monitoring for any parameter require d from 0:00 hours September 25, 2006, to 24:00

hours September 29, 2006, for outfall 002.

Category Parameter Units Sample Point Minimum Sampling Frequency Sample Type

Secondary

sludge 2,3,7,8- TCDD ng/L - ppt Waste sludge line (d) Grab

(d) No further monitoring from date of ceasing pulp production.

Page 29 of 38LAB ACCREDITATION
With the exception of certain parameters the permit requires all monitoring data to be prepared by a laboratory registered or accredited under the provisions of Chapter 173-50 WAC, Accreditation of Environmental Laboratories. The laboratory at this faci lity is accredited for: BOD, Fecal coliform membrane and MPN, pH , TSS, and dissolved oxygen membrane and Winkler methods.

OTHER PERMIT CONDITIONS

REPORTING AND RECORDKEEPING

The conditions of S3 are based on the author ity to specify any a ppropriate reporting and recordkeeping requirements to prevent and control waste discha rges (WAC 173-220-210).

NON-ROUTINE AND UNANTI CIPATED DISCHARGES
Occasionally, this facility may ge nerate wastewater which is not characterized in their permit application because it is not a routine discha rge and was not anticip ated at the time of application. These typically are waters used to pr essure test storage tanks or fire water systems or leaks from drinking water systems. Thes e are typically clean wastewaters but may be contaminated with pollutants. The permit c ontains an authorizati on for non-routine and unanticipated discharges. The permit requires a characteriza tion of these wastewaters for pollutants and examination of the opportunities for reuse. Depending on the nature and extent of pollutants in this wastewater and opportunities for reuse, Ecology may authorize a direct discharge via the process wastewater outfall or through a stormwater outfall for clean water, require the wastewater to be pl aced through the facilities wastewat er treatment process or require the water to be reused.

SPILL PLAN
The Department has determined that the Permittee stores a quantity of chemicals that have the potential to cause water pollution if accidentally released. The De partment has the authority to require the Permittee to develop best management plans to prevent this accidental release under section 402(a)(1) of the Fede ral Water Pollution Control Act (FWPCA) and RCW 90.48.080. The Permittee has developed a plan for preventing the accidental release of pollutants to state waters and for minimizing damages if such a spill occurs. The proposed permit requires the Permittee to update this plan and submit it to the Department.

SOLID WASTE PLAN
The Department has determined that the Permittee has a potential to cause pollution of the waters of the state from leachate of solid waste. Th is proposed permit require, under the authority of RCW 90.48.080, that the Permittee update the solid waste plan designed to prevent solid waste from causing pollution of the waters of the stat e. The plan must be submitted to the local permitting agency for approval, if necessary, and to the Department.

Page 30 of 38OUTFALL EVALUATION
Proposed permit requires the Permittee to conduc t an outfall inspection and submit a report detailing the findings of that inspection. The purpose of the inspection is to determine the condition of the discharge pipe and diffusers and to evaluate the extent of sediment accumulations in the vicinity of the outfall.

TREATMENT SYSTEM OPERATING PLAN
In accordance with state and federal regulations, the Permittee is required to take all reasonable steps to properly operate and maintain the treatment system (40 CFR 122.41(e)) and WAC 173- 220-150 (1)(g). It has been determined that the implementation of the procedures in the Treatment System Operating Plan is a reasonable measure to ensure compliance with the terms and limitations in the permit. The Permittee must submit the Treatment System Operating Plan. The permit requires that the plan be updated.

GENERAL CONDITIONS
General Conditions are based directly on state an d federal law and regulations and have been standardized for all individual industrial NPDES permits issued by the Department.

PERMIT ISSUANCE PROCEDURES

PERMIT MODIFICATIONS
The Department may modify this permit to impo se numerical limitations, if necessary to meet Water Quality Standards for Surface Waters, Sediment Quality Standards, or Water Quality Standards for Ground Waters, based on new info rmation obtained from sources such as inspections, effluent monitoring, outfall studies, and efflue nt mixing studies.
The Department may also modify this permit as a result of new or am ended state or federal regulations.

RECOMMENDATION FOR PERMIT ISSUANCE

This proposed permit meets all st atutory requirements for author izing a wastewater discharge, including those limitations and conditions believe d necessary to control toxics, protect human health, aquatic life, and the be neficial uses of waters of the State of Washington. The Department proposes that this proposed permit be issued for 5 years.

Page 31 of 38REFERENCES FOR TEXT AND APPENDICES
Environmental Protection Agency (EPA)

1992. National Toxics Rule. Federal Register, V. 57, No. 246, Tuesday, December 22, 1992.

1991. Technical Support Document for Wa ter Quality-based Toxics Control . EPA/505/2- 90-001.

1988. Technical Guidance on Supplementary St ream Design Conditions for Steady State Modeling . US EPA Office of Wa ter, Washington, D.C.

1985. Water Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in Surface and Ground Water . EPA/600/6-85/002a.

1983. Water Quality Standards Handbook. US EPA Office of Water, Washington, D.C.
Tsivoglou, E.C., and J.R. Wallace.

1972. Characterization of Stream Reaeration Capacity . EPA-R3-72-012. (Cited in EPA 1985 op.cit.)
Washington State Department of Ecology.

1994. Permit Writer’s Manual . Publication Number 92-109
Wright, R.M., and A.J. McDonnell.

1979. In-stream Deoxygenation Rate Prediction . Journal Environmental Engineering Division, ASCE. 105(EE2). (Cited in EPA 1985 op.cit.)

Page 32 of 38APPENDIX A--PUBLIC INVOLVEMENT INFORMATION
The Department of Ecology proposes to reissue a pe rmit to the applicant listed on page 1 of this fact sheet. The permit contains conditions and effluent limitati ons, and monitoring and reporting requirements with which the Permittee must comply to protect the quality and preserve the uses of Washington’s public waters. We described the legal and technical bases for the conditions and requirements in the rest of this fact sheet.
The Department will send Notices by postal mail and by e-mail to interested persons; and we will publish a Public Notice of Draft (PNOD) on October 12, 2009 edition of The Daily World to inform the public that the dr aft permit and the fact sheet are available for evaluation, at the Aberdeen branch of the Timberland Library System, and on Ecology’s Industrial web page: http;//apps.ecy.wa.gov/industrial/ (click on “Pro posed Permits”). Ecology invites submittal of written comments regarding the draft permit.
The draft permit, fact sheet, a nd related documents are also av ailable for inspection and copying between the hours of 8:00 a.m. and 5:00 p.m. weekdays. Phone Kathy Vermillion, 360/407-6916 to schedule an appointment. Deliver written comments to our Ecology’s headquarters building, in Lacey (call for directions) or send them to the postal address listed below: Department of Ecology c/o Marc Crooks, Industrial Section P. O. Box 47600 Olympia, WA 98504-7600
Any interested party may comment on the draft pe rmit or request a public hearing on this draft permit within the thirty-one (31) day comment period, October 12, 2009 to November 13, 2009, to the address above. Any request for a hearing mu st describe the interest of the filing party and the reasons why such a hearing would serve the public interest. The De partment will conduct a public hearing of comments abou t short-coming of the draft if Ecology determines there is significant public interest in it (WAC 173-220-090). Ecology will post a public notice containing details about the time and place of any sc heduled hearing, at least thirty (30) days in advance of the event. Ecology will also mail an individual notice of hearing (WAC 173-220- 100) to any person who expressed an interest in this permit.
Comments should refer to speci fic text in the proposed pe rmit and factsheet, followed by proposed modified language or a specific concer n. Comments may address technical issues; the accuracy and completeness of the information, the scope of the facility’s proposed coverage, the adequacy of environmental protection afforded by the permit conditions, or any other concern that would result from issuance of this permit.
The Department will consider all comments received within thirty-one (31) days from the date of public notice of draf t indicated above, in forming a final decision to issue, revise, or deny the permit. Copies of the Department's summar y of, and response to, and to all significant comments will be available upon request. Ecology will mail a copy of the summary and response directly to people who expr essed an interest in this permit.

Page 33 of 38The permit and factsheet were written by Don Ne lson, and revised by Marc Crooks. For further information call Marc Crooks at 360-407-6934, write him at the address listed above, or e-mail him at mcro461@ecy.wa.gov

.

Page 34 of 38APPENDIX B--GLOSSARY Acute Toxicity --The lethal effect of a compound on an or ganism that occurs in a short period of time, usually 48 to 96 hours.

AKART -- An acronym for “all known, available, a nd reasonable methods of treatment.” Ambient Water Quality --The existing environmental conditi on of the water in a receiving water body.

Ammonia --Ammonia is produced by the breakdown of nitrogenous materials in wastewater. Ammonia is toxic to aquatic organisms, exerts an oxygen demand, and contributes to eutrophication. It also increases the amount of chlorine needed to disinfect wastewater. Average Monthly Discharge Limitation --The average of the measured values obtained over a calendar month's time. Best Management Practices (BMPs) --Schedules of activities, prohibitions of practices, maintenance procedures, and other physical, st ructural, and/or mana gerial practices to prevent or reduce the pollution of waters of the State. BMPs include treatment systems, operating procedures, and practices to control: plan t site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. BMPs may be further categorized as operational, source control, erosion and sediment control, and treatment BMPs.

BOD 5 --Determining the Biochemical Oxygen Demand of an effluent is an indirect way of measuring the quantity of organic ma terial present in an effluent that is utilized by bacteria. The BOD 5 is used in modeling to measure the reduction of dissolved oxygen in a receiving water after effluent is discharged. Stress cau sed by reduced dissolved oxygen levels makes organisms less competitive and less able to sustai n their species in the aquatic environment. Although BOD is not a specific compound, it is defi ned as a conventional pollutant under the federal Clean Water Act. Bypass --The intentional diversion of waste stream s from any portion of a treatment facility.

Chlorine --Chlorine is used to disinfect wastewaters of pathogens harmful to human health. It is also extremely toxic to aquatic life.

Chronic Toxicity --The effect of a compound on an orga nism over a relatively long time, often 1/10 of an organism's lifespan or more. Chr onic toxicity can measure survival, reproduction or growth rates, or other parameters to measure the toxic effects of a compound or combination of compounds. Clean Water Act (CWA) --The Federal Water Pollution Control Act enacted by Public Law 92- 500, as amended by Public Laws 95-217, 95-576, 96-483, 97-117; USC 1251 et seq. Compliance Inspection - Without Sampling --A site visit for the purpose of determining the compliance of a facility with the terms and conditi ons of its permit or with applicable statutes and regulations.

Page 35 of 38Compliance Inspection - With Sampling --A site visit to accomplish the purpose of a Compliance Inspection - Without Sampling and as a minimum, sampling and analysis for all parameters with limits in the permit to asce rtain compliance with those limits; and, for municipal facilities, sampling of influent to ascertain compliance with the 85 percent removal requirement. Additional sa mpling may be conducted. Composite Sample --A mixture of grab samples collected at the same sampling point at different times, formed either by continuous sampling or by mixing discrete samples. May be "timecomposite"(collected at constant time intervals) or "flow-proportional" (collected either as a constant sample volume at time intervals pr oportional to stream fl ow, or collected by increasing the volume of each aliquot as the flow increased while maintaining a constant time interval between the aliquots. Construction Activity --Clearing, grading, excava tion and any other activity which disturbs the surface of the land. Such activities may include road building, constr uction of residential houses, office buildings, or industrial buildings, and demolition activity.
Continuous Monitoring –Uninterrupted, unless otherw ise noted in the permit.

Critical Condition --The time during which the combination of receiving water and waste discharge conditions have the highest potential for causing toxicity in the receiving water environment. This situation usually occurs wh en the flow within a water body is low, thus, its ability to dilute effluent is reduced.

Dilution Factor --A measure of the amount of mixing of e ffluent and receiving water that occurs at the boundary of the mixing zone. Expressed as the inverse of the percent effluent fraction e.g., a dilution factor of 10 m eans the effluent comprises 10 % by volume and the receiving water 90%. Engineering Report --A document which thoroughly ex amines the engineering and administrative aspects of a particular domestic or industrial wastewater facility. The report shall contain the appropriate informati on required in WAC 173-240-060 or 173-240-130.

Fecal Coliform Bacteria --Fecal coliform bacteria are used as indicators of pathogenic bacteria in the effluent that are harmful to humans. Pa thogenic bacteria in wast ewater discharges are controlled by disinfecting the wastewater. Th e presence of high numbers of fecal coliform bacteria in a water body can indicate the recent release of untreated wastewater and/or the presence of animal feces. Grab Sample --A single sample or measurement taken at a specific time or over as short period of time as is feasible.

Industrial Wastewater --Water or liquid-carried waste from industrial or commercial processes, as distinct from domestic wastewater. These wastes may result from any process or activity of industry, manufacture, trade or business, from the developmen t of any natura l resource, or from animal operations such as feed lots, poultry houses, or dairies. The term includes contaminated storm water and, also, l eachate from solid waste facilities. Major Facility-- A facility discharging to surface water w ith an EPA rating score of > 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact.

Page 36 of 38Maximum Daily Discharge Limitation --The highest allowable dail y discharge of a pollutant measured during a calendar day or any 24-hour period that reas onably represents the calendar day for purposes of sampling. The daily discharg e is calculated as the average measurement of the pollutant over the day. Method Detection Level (MDL)-- The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is above zero and is determined from analysis of a sample in a given matrix containing the analyte. Minor Facility-- A facility discharging to surface water with an EPA rating score of < 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact. Mixing Zone --An area that surrounds an effluent disc harge within which wa ter quality criteria may be exceeded. The area of the authorized mi xing zone is specified in a facility's permit and follows procedures outlined in st ate regulations (Cha pter 173-201A WAC). National Pollutant Discharge Elimination System (NPDES) --The NPDES (Section 402 of the Clean Water Act) is the Federal wastewater pe rmitting system for discharges to navigable waters of the United States. Many states, in cluding the State of Washington, have been delegated the authority to issue these permits . NPDES permits issued by Washington State permit writers are joint NPDES/ State permits issued under both State and Federal laws. pH --The pH of a liquid measures its acidity or alkalinity. A pH of 7 is defined as neutral, and large variations above or below this value ar e considered harmful to most aquatic life. Quantitation Level (QL)-- A calculated value five times the MDL (method detection level). Responsible Corporate Officer -- A president, secretary, treasure r, or vice-president of the corporation in charge of a principal busine ss function, or any other person who performs similar policy- or decision-mak ing functions for the corporati on, or the manager of one or more manufacturing, production, or operating facilities employing more than 250 persons or have gross annual sales or expenditures ex ceeding $25 million (in second quarter 1980 dollars), if authority to sign documents has b een assigned or delegated to the manager in accordance with corporate procedures (40 CFR 122.22). Technology-based Effluent Limit --A permit limit that is based on the ability of a treatment method to reduce the pollutant. Total Suspended Solids (TSS) --Total suspended solids is the particulate materi al in an effluent. Large quantities of TSS discharged to a receiv ing water may result in solids accumulation. Apart from any toxic effects attr ibutable to substances leached out by water, suspended solids may kill fish, shellfish, and other aquatic organisms by causing abrasive injuries and by clogging the gills and respiratory passages of various aquatic fauna. Indirectly, suspended solids can screen out light and can promote and maintain the development of noxious conditions through oxygen depletion.

State Waters --Lakes, rivers, ponds, streams, inland wate rs, underground waters, salt waters, and all other surface waters and watercourses within the jurisdiction of the state of Washington.

Stormwater --That portion of precipitation that does not naturally percolate into the ground or evaporate, but flows via overland flow, interflow, pipes, and other features of a storm water drainage system into a defined surface water body, or a constructed infiltration facility.

Page 37 of 38Page 38 of 38 Upset --An exceptional incident in which there is unintentional and temporary noncompliance with technology-based permit effluent limitati ons because of factors beyond the reasonable control of the Permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment f acilities, lack of preventative maintenance, or careless or improper operation. Water Quality-based Effluent Limit --A limit on the concentration of an effluent parameter that is intended to prevent the concentration of th at parameter from exceeding its water quality criterion after it is discharged into a receiving water.

APPENDIX C--TECHNICAL CALCULATIONS

Several of the Excel ® spreadsheet tools used to evaluate a discharger’s ability to meet Washington State water quality standards can be found on the Department’s homepage at http.www:wa.gov.ecology.

APPENDIX D—STUDIES

1. Analysis of the Available Scientific and Public health Data Regarding the Cosmopolis Mill’s Effluent: The Public Health Significance of the Effluent, and its Impact on Water Quality in Grays Harbor, Shellfish Growing Waters, and Shellfish, IEH, Inc. 2002

2. Grays Harbor Hydrodynamic & Water Quality Modeling Report, CH2MHill, 2002

APPENDIX E--RESPONSE TO COMMENTS

No comments were submitted for this permit amendment.