/ T ^^~ N 

State of Oregon 

Department of 

Environmental 

Quality 

National Pollutant Discharge Elimination System 

PERMIT EVALUATION AND FACT SHEET 

Oregon Department of Environmental Quality 

Northwest Region 

2020 SW Fourth Ave., Suite 450 

Portland, OR 97202 

(503) 229-5263 

Permittee: 

Existing Permit 

Information: 

Source Contact: 

Source Location: 

LLTD 

Receiving Stream: 

Proposed Action: 

Source Category 

Permit Writer: 

Date Prepared: 

West Linn Paper Company 

4800 Mill Street 

West Linn, Oregon 97219 

File Number: 21489 

Permit Number: 100976 

EPA Reference Number: OR000078-7 

County: Clackamas 

Penny Machinski 

Environmental Engineer 

(503) 557-6687 

4800 Mill Street 

West Linn, Oregon 97219 

1227618456580-27.4-D 

Willamette River 

Renew Permit 

Application Number: 972430 

Date Received: 10/8/08 

NPDES Major - Industrial 

Rob Burkhart 

503-229-5566 

Date: 7/14/10 (updated 8/24/10) 
Table of Contents 

1.0 Introduction ...... ........... 

jum\J JO itvllll V JL^CovrJ.OI'lvlI I iii«i*tiiiit#titi»t«#)iit*iti*itt**»»tM**if«iii>i*<*ii*<*t««i<i»*i<*i»*<*i»tiiit v 

2.1 General... 3 

>••••*•-••*•»-

2.2 Wastewater Treatment and Discharge 

2.3 Changes in Operation 

2.4 Wastewater Characteristics , 

2.5 Storm Water 

2.6 Outfall 

*jNvl XVVVl^IV Ill g VV HIC I IMMIMMI1»lltlfM<l*M>tlMltltlMlfM**IHI*»tM««*ltl M 

3.1 Water Quality Standards 

3.2 Receiving Stream Water Quality 

3.3 Threatened & Endangered Species 

3.4 Regulatory Mixing Zone Analysis. 

*T» \j JL %51 111 1 1 lllll l ltd . li\JII_ i *###**t#*»t##»#»###*##*###**#»*#**t#*«**t****«*»***«*****»*»*»»**tt**»**ti»* 

4.1 Existing Permit Limits 

4.2 Technology-Based Effluent Limits 

4.3 Comparison of 2004 NPDES Permit Limits and Technology Based Limits 

4.4 Water Quality-Based Effluent Limits 

4.5 Whole Effluent Toxicity 

4.6 Antidegradation 

6.0 Permit Draft Discussion 

6.1 Face Page 

6.2 Schedule A - Waste Discharge Limitations , 

6.3 Schedule B - Minimum Monitoring and Reporting Requirements 

6.4 Schedule C - Compliance Schedules and Conditions 

6.5 Schedule D - Special Conditions 

6.6 Schedule F - NPDES General Conditions 

6.7 Permit Processing/Public Comment/Appeal Process 

4 

5 

5 

5 

6 

7 

7 

8 

8 

9 

10 

...10 

...10 

...11 

...12 

...18 

...19 

19 

...20 

...20 

...20 

...22 

...22 

...23 

Attachments 

Attachment A • 

Attachment B -

Attachment C -

Attachment D • 

Attachment E -

Attachment F -

Attachment G • 

- Dissolved Oxygen Analysis 

• Thermal Plume Analyses 

• pH Reasonable Potential Analysis 

- Aquatic Life Reasonable Potential Analysis 

Human Health Reasonable Potential Analysis 

Antidegradation Worksheet 

- Public Notice 
1.0 INTRODUCTION 

A National Pollutant Discharge Elimination System (NPDES) permit was issued by the Department of 

Environmental Quality (Department) to the West Linn Paper Company (WLPC) on May 21, 2004 (2004 NPDES 

permit). The permit expired on April 30, 2009. The Department received a NPDES permit renewal application 

from WLPC on October 8,2008. Since a timely renewal application was submitted to the Department, WLPC has 

continued to operate under the terms and conditions of the 2004 NPDES permit pending Department action on the 

renewal application. The Department is now proposing to renew the NPDES permit for WLPC. 

This permit evaluation report describes the basis and methodology used in developing the permit. The permit is 

divided into several sections: 

Schedule A - Waste discharge limitations 

Schedule B - Minimum monitoring and report requirements 

Schedule D - Special conditions 

Schedule F - General conditions 

The Federal Water Pollution Control Act of 1972 and subsequent amendments require a NPDES permit for the 

discharge of wastewater to surface waters. Furthermore, Oregon Revised Statutes (ORS 468B.050) also require a 

discharger be granted a permit for the discharge of wastewater to surface waters. This proposed permit action by 

the Department complies with both federal and state requirements. 

2.0 FACILITY DESCRIPTION 

2.1 General 

WLPC owns and operates a paper mill in West Linn, Oregon. The facility is located on an island in the Willamette 

River with the Willamette Locks on the western side of the mill and the Willamette River on the eastern side. 

The mill uses purchased dry pulp from outside sources to create high-grade, coated paper products. The mill has 

three paper machines, each with similar production rates when operated at full production. The average daily 

production rate for the mill over the past five years (from April 2005 through March 2010) was 807 tons per day. 

Once it is trucked in to the mill, the purchased diy pulp is placed in a "slusher" where filtered river water is added. 

The "slusher" separates fibers and creates a slurry, which is then routed to the paper machines. The shiny is 

screened in several stages prior to entering the paper machines. The slurry is then sprayed onto a wire, mesh screen, 

where water drains from the pulp, leaving a fiber mat. The fiber mat moves through a series of rollers that remove 

additional water. Several other processes take place to coat, diy, smooth, trim and package the paper prior to sale. 
,,y m&Z2~y>jm 

S -f' >_»• _«__f__ i 

Figure 1: Facility Location 

2,2 Wastewater Treatment and Discharge 

Significant quantities of wastewater are generated during the screening and forming processes. A portion of the 

water is reused and the remainder of the water is pumped to the primary clarifier. Storm water from various areas 

throughout the facility is also collected and pumped to the primary clarifier. An additional source of wastewater is 

backwash water from the water treatment plant (discussed below). Prior to entering the primary clarifier, the 

wastewater is treated with carbon dioxide for pH control and a flocculation aid, The primary clarifier removes 

solids, which are land applied for beneficial use. Primary clarifier effluent is pumped to an aerated stabilization 

basin (ASB) for further treatment. The ASB consists of a 26-acre lagoon, which provides a detention time of about 

10 days. The effluent from the ASB is then discharged to the Willamette River via an outfall (Outfall 001) at river 

mile 27,4. Figure 2 shows the ASB and the discharge location. (Note that the discharge from WLPC is about 0.5 

miles downstream of the discharge from Blue Heron Paper Company, which discharges at RM 27.9.) Effluent flow 

is measured with a Parshall flume just prior to discharge and final effluent monitoring occurs at either the flume's 

stilling well or just upstream. 

Process water for the mill is obtained from the Willamette River. About 6 million gallons per day (mgd) of river 

water is directed to a water treatment system prior to use in the mill. The water treatment system consists of eight 

filter beds; the filtered water is then stored in a clearwell for use at the mill. The filters are periodically backwashed 

and this backwash water is discharged to wastewater treatment system at a rate of approximately 0.5 mgd. 
2.3 Changes in Operation 

The 2004 permit required WLPC to divert the discharge of filter backwash from Outfall 002 (which was located at 

the mill) to the wastewater treatment system (and eventual discharge via Outfall 001). This rerouting was 

completed in April of 2005. The facility has also implemented several projects to reduce water use and wastewater 

generation, 

2.4 Wastewater Characteristics 

The 2004 NPDES permit required WLPC to monitor flow, biochemical oxygen demand (BOD), total suspended 

solids (TSS), temperature, turbidity and pH. Annual priority (toxic) pollutant scans were also required. As noted 

above, in April 2005, WLPC instituted rerouted filter backwash water to the wastewater treatment system, Because 

of this modification, data prior to this period may not be representative of current discharge conditions and data 

collected over the past four years (January 2006 to March 2010) were used to characterize the effluent. The 

following table presents average and 95th percentile values for effluent flow, biochemical oxygen demand (BOD), 

turbidity and total suspended solids (TSS). The maximum and 90th percentile values for temperature are also 

provided. Effluent levels of other pollutants of concern, including toxics, are presented in section 7.0, Water 

Quality Analysis, 

TABLE 1: PROCESS WASTEWATER CHARACTERISTICS (OUTFALL 001) 

(JANUARY 2006 - MARCH 2010) 

Parameter 

Flow 

BOD* 

TSS 

Turbidity 

Temperature (daily max.) 

Temperature (7-day avg. of 

dally max.) 

Average 

4.2 MGD 

4.8 mg/L 

7.5 mg/L 

10.2 NTU 

Maximum 

30.6 °C 

30 °C 

95"1 percentile 

5.2 MGD 

7.6 mg/L 

12 mg/L 

17.9 NTU 

90,h percentile 

26.1 °C 

26.1 °C 

*Note: I» the calculation of the average and 95' percentile BOD values, the detection limit was used for 

values reported as non-detectable. This results in calculated BOD statistics higher than actual. 

It should be noted that the recent characteristics of the wastewater represent a significant increase in quality and 

reduction of volume over historical discharges (as noted in Table 2, below), The average wastewater flow has 

decreased by 0.9 MGD (17%) and average TSS concentration has decreased by 5.3 mg/L (even as filter backwash 

water with higher TSS has been added to the treatment system). These positive results reflect the extensive efforts 

by the facility to reduce flows and solids to the wastewater treatment system. 

TABLE 2; HISTORICAL PROCESS WASTEWATER CHARACTERISTICS 

{JULY 2000-JUN E 2003) 

Parameter 

Combined Flow 

(Outfalls 001 and 002) 

BOD 

TSS 

Average 

5.1 MGD 

6.6 mg/L 

12.8 mg/L 

95th percentile 

6.3 MGD 

12 mg/L 

23 mg/L 

2.5 Storm Water 

While a large portion of the site's storm water runoff is directed to the wastewater treatment system, a portion is 

discharged directly to the Willamette River. So in addition to its individual NPDES permit, the facility maintains a 

storm water general permit (1200-Z). 

5 
2.6 Outfall 

The wastewater discharges covered by this permit are all discharged through one outfall, Outfall 001. (WLPC 

previously used a second outfall, Outfall 002, to discharge backwash water from the water treatment plant's filters. 

The backwash water was rerouted to the wastewater treatment system and now discharges through Outfall 001.) 

Outfall 001 originates at the facility's aerated stabilization basin (ASB) as indicated in Figure 2. The outfall 

consists of a 2.5-foot diameter pipe extending about 550 feet from the western bank of the Willamette River at 

approximate river mile 27.4. The outfall ends with a diffuser consisting of 11 diffuser ports, each with a diameter 

of 0,82 feet. The ports are offset from the vertical by an angle of 30 degrees in the direction of river flow. The 

width of the river near the discharge location is 1040 feet with a local water depth of approximately 33 feet. The 

average depth in this area of the river is 25 feet with a maximum depth of 34 feet. 

Figure 2: Outfall Location 
3.0 RECEIVING WATER 

The West Linn Paper Company discharges to the mainstem of the Willamette River just above Willamette Falls, at 

approximate river mile (RM) 27.4. Some of the characteristics of this reach of the Willmette River are discussed 

below. 

3.1 Water Quality Standards 

The water quality standards for all-waterbodies (Oregon Administrative Rules [OAR] 340-41) and specifically the 

Willamette Basin (OAR 340-41-0345) were developed to protect the beneficial uses for the basin. The designated 

beneficial uses of the Willamette River, listed in OAR 340-041 Table 340A, are as follows: 

• Public and Private Domestic Water Wupply, 

• Industrial Water Wupply, 

« Irrigation, 

• Livestock Watering, 

• Fish and Aquatic Life 

• Wildlife and Hunting, 

• Fishing, 

• Boating, 

• Water Contact Recreation, 

• Aesthetic Quality, 

• Hydro Power, and 

• Commercial Navigation and Transportation 

Selected conventional water quality criteria for this segment of the Willamette River are listed in Table 3 below. A 

listing of toxic water quality criteria for pollutants of concern is presented in Section 4.4.5, below. 

TABLE 3 

SELECTED WILLAMETTE RIVER WATER QUALITY CRITERIA FOR CONVENTIONAL 

POLLUTANTS (FROM OAR 340-041) 

Parameter 

Dissolved Oxygen 

pH 

Temperature 

Total Dissolved Solids 

Turbidity 

In-stream Water Quality Criteria 

Cool Water Aquatic Life Criteria (applies in summer): 

> 6.5 mg/L (absolute minimum for surface samples) 

> 6.5 and < 8.5 

The 7-day average maximum temperature of a stream identified as a migration 

corridor may not exceed 20 °C (68 °F) - Insignificant anthropogenic inputs are 

allowed 

The concentrations listed below may not be exceeded unless otherwise specifically 

authorized by DEQ - 100 mg/L 

No more than a ten percent cumulative increase in natural stream turbidities shall 

be allowed, as measured relative to a control point immediately upstream of the 

turbidity causing activity. 
3.2 Receiving Stream Water Quality 

Section 303(d) of the Clean Water Act requires each state to develop a list of water bodies that do not meet state 

surface water quality standards after implementation of technology-based controls. The state is then required to 

complete a Total Maximum Daily Load (TMDL) for water bodies on the 303(d) list. The TMDL must address water 

quality on a basin-wide scale to ensure that overall water quality standards will be met. WLPC discharges 

wastewater to a segment of the Willamette River that is listed as being water quality limited in the Department's 

303(d) list of streams (the most recent listing is the 2004/2006 listing). Table 4 includes the parameters for which ' 

water quality standards in the Willamette River are not met and the season when standards are exceeded. 

TABLE 4; 2004/2006 303(D) LISTING INFORMATION 

Stream Segment 

Willamette River (Mouth to 

Willamette Falls) 

Parameter 

Aldrin 

Bacteria (E.Coli/Fecal Coliform) 

Biological Criteria 

DDT & DDE (DDT metabolite) 

Dieldrin 

Dioxin 

Iron 

Manganese 

Mercury 

Polychlorinated Biphenyls (PCBs) 

Pentachlorophenoi 

Polycyclic Aromatic Hydrocarbons 

(PAHs) 

Temperature 

Season 

Year-around 

Fall/Winter/Spring 

Year-around 

Year-around 

Year-around 

Undefined 

Year-around 

Year-around 

Year-around 

Year-around 

Year-around 

Year-around 

Year-around 

Of the pollutants contained in the 303(d) list, bacteria, iron, mercury, manganese and temperature have the potential 

to be present in the facility's effluent. The maximum bacteria concentration (11 mpn/100 mL of fecal coliform) is 

well below the criterion used for the 303(d) listing. Effluent monitoring indicates that pesticides (DDT, DDE, 

aldrin, and dieldrin), dioxin, PCBs, pentachlorophenoi, and PAHs are not present at detectable levels. A 

temperature TMDL for the Willamette River was finalized in September of 2006. A discussion of the temperature 

issues associated with the discharge is presented in Section 4.4.3. A discussion of the other pollutants of concern is 

also presented in Section 4. 

3.3 Threatened & Endangered Species 

Species of anadromous salmonids that use the lower Willamette River near WLPC include chinook salmon 

{Oncorhynchus tshmvytscha), coho salmon (O. kisutch), steelhead trout (O. mykiss), and cutthroat trout (O. clarki). 

Resident salmonid game species include cutthroat trout. Bull trout do not occur in tliis area of the Willamette 

River. 

On March 16,1999, the National Marine Fisheries Service (NMFS) listed chinook salmon in the Lower Columbia 

River Evolutionary Significant Unit (ESU) as a threatened species under the Endangered Species Act (ESA). On 

March 13, 1998, NMFS listed the Lower Columbia River ESU steelhead trout stocks as a threatened species under 

8 
the ESA. These species utilize the Willamette River and its tributaries. The Willamette River has been designated 

as critical habitat for listed chinook salmon and steelhead by the NMFS. 

Based on the fish use and spawning use maps contained in OAR 340-041 (Figures 340A and 340B), the designated 

fish use for this segment of the Willamette River is as a salmon and Steelhead migration corridor with no 

designated spawning uses. 

3.4 Regulatory Mixing Zone Analysis 

OAR 340-041-0053 provides that the Department may suspend all or part of the water quality standards in a 

designated portion of the receiving water to serve as a zone of dilution for wastes and receiving waters to mix 

thoroughly. Water quality standards for all parameters must be met at the edge of the defined mixing zone. 

Mixing Zone 

As described in the 2004 permit, the mixing zone from Outfall 001 is defined as that portion of the Willamette 

River within 65 feet from the point of discharge, (See Section 2.6, above, for a description of the outfall.) 

WLPC conducted a mixing zone study to determine mixing characteristics and available dilution. The results of the 

mixing zone study are presented in the Revised Mixing Zone Study Report by Secor International Incorporated 

(November 13, 2003). The mixing zone study consisted of a field dye study and modeling of variety of different 

discharge and ambient river conditions. The lowest predicted dilution was 67:1 during 7Q10 low flow1 conditions, 

high stream temperature, and maximum effluent temperature. This dilution is considered the critical dilution at the 

edge of the mixing zone and was used in the water quality analyses. The 7Q10 low flow for the Willamette River 

at this point was estimated at 5300 cubic feet per secont (cfs). 

Zone of Immediate Dilution 

A zone of immediate dilution (ZID) within the mixing zone is being proposed as allowed by OAR 340-041-0053. 

Compliance with acute toxicity standards must be met at the edge of the ZID. EPA guidance states that the ZID 

should be the most restrictive of the following criteria: 

1) Within 10% of the distance from the edge of the outfall structure to the edge of the regulatory mixing zone. 

This would result in a ZID of 6,5 feet, 

2) Within a distance of 50 times the discharge length scale in any spatial direction. The discharge length scale 

is the square root of the cross-sectional area of the port. In the case of a multi-port diffuser, this 

requirement must be met for each port using the appropriate discharge length scale of that port. This would 

result in a ZID of 36,3 feet. 

3) Within 5 times the local water depth in any horizontal direction from any discharge outlet. This would 

result in a ZID of 168 feet, 

The most stringent of the three criteria is 10% of the distance from the edge of the regulatory mixing zone, which 

results in a ZID of 6.5 feet. The ZID is defined as an area within 6.5 feet in any direction of the diffuser. Modeling 

predicts that the critical dilution at the edge of the ZID is 5:1. 

1

 The 7Q10 low flow is the'lowest 7-day average river flow with a 10 year return period. 

9 
4.0 PERMIT LIMITATIONS 

Two categories of effluent limitations exist for NPDES permits: 1) Technology based effluent limits, and 2) Water 

quality based effluent limits. Technology based effluent limits are developed by applying the national effluent 

limitation guidelines (ELGs) established by EPA for specific industrial categories. Technology based effluent 

limits are established to require a minimum level of treatment for industrial or municipal sources using available 

technology. Water quality based effluent limits are designed to be protective of the beneficial uses of the receiving 

water and are independent of the available treatment technology. In addition, when performing a permit renewal, 

there are existing permit limits. These may be technology-based limits, water quality-based limits, or limits based 

on best professional judgment. In general, when renewing a permit, the most stringent limits from each of these 

three categories apply. 

4.1 Existing Permit Limits 

The existing (2004) NPDES permit includes effluent limits for outfall 001 (Discharge from Aerated Stabilization 

Basin to Willamette River) as listed in Table 5, below. 

Table 5: Current Outfall 001 Effluent Limits 

Parameter 

BOD5(May-Oct) 

(Nov-April) 

TSS 

PH 

Excess Thermal Load 

(May - Oct) 

Turbidity 

(May-Oct) 

(Nov- April) 

Daily Max 

3800 lbs/day 

8015 lbs/day 

9000 lbs/day 

Monthly Ave 

2870 Ibs/day 

4210 lbs/day 

6000 lbs/day 

Within the range of 5.0 - 9.0 at all times 

175 x 10H Kcal/day (7-day moving average of daily 

maximum excess thermal load) 

31 NTU 

77 NTU 

N/A 

N/A 

In addition to the limits for Outfall 001, the 2004 permit also includes effluent limits for Outfall 002, the filter 

backwash discharge. Since this discharge was eliminated in 2005, these effluent limits are no longer applicable. 

The 2004 prmit also included interim turbidity limits which are no longer applicable. 

4.2 Technology-Based Effluent Limits 

EPA has developed effluent limitation guidelines (ELGs) for many types of industries. These ELGs are codified in 

the Code of Federal Regulations (CFR). The ELGs are typically expressed in terms of mass of a particular 

pollutant allowed per unit of production or unit of flow. ELGs are also expressed as concentration in which case 

the production is not relevant. 

For existing industry types where EPA has established ELGs, three categories of effluent limitations may be 

developed. These categories are: Best Practicable Control Technology Currently Available (BPT), Best 

Conventional Pollutant Control Technology (BCT), and Best Available Technology Economically Achievable 

(BAT). BPT represents the minimum technology level and applies to all existing point sources discharges for 

which ELGs have been published. BCT replaces BPT for conventional pollutants, and BAT replaces BPT for nonconventional and toxic pollutants. BPT limitations must be met upon publication of the ELGs. EPA allows 

additional time for facilities to comply with BCT and BAT limitations. 

The technology based standards in 40 CFR 430 - Pulp, Paper & Paperboard Point Source Categoiy apply to the 

WLPC. WLPC manufactures fine and light papers from purchased pulp (Subpart K - Fine and Lightweight Papers 

10 
from Purchased Pulp Subcategory). This subpart specifies BPT limitations (no BCT limitations promulgated) and 

BAT limitations based on production. 40 CFR 430.0l(n) defines production as the annual off-the-machine 

production (including off-the-machine coating where applicable) divided by the number of operating days during 

that year. Paper and paperboard production shall be measured at the off-the-machine moisture content. Review of 

production data over the past 5 years (April 2005 through March 2010) indicates that the average production rate 

during this period was 807 tons/day. So this value (807 tons or 1,614,000 pounds per day) will be used to calculate 

the technology based effluent limits. The production-based BPT factors from 40 CFR 430.112 that apply to WLPC 

are presented in the following table. 

TABLE 6: BPT EFFLUENT LIMITATIONS FOR NON-INTEGRATED MILLS 

(FINE PAPER FROM PURCHASED PULP) - WOOD FIBER FURNISH 

Parameter 

BOD - 5 day 

TSS 

pH 

Kg/kkg (or pounds per 1,000 lb) of product 

Maximum for any 1 day 

8.2 

11.0 

Average of daily values for 30 

consecutive days 

4,25 

5.9 

5.0-9.0 S.U. 

Based on the production rate reported in the NPDES permit application, the following technology based BPT 

effluent limitations apply to the WLPC, 

TABLE 7: BPT EFFLUENT LIMITATIONS FOR WLPC 

Parameter 

BOD - 5 day 

TSS 

PH 

Daily Maximum 

13,235 Ibs/day 

17,754 Ibs/day 

Monthly Average 

6,860 Ibs/day 

9,523 Ibs/day 

5.0-9,0 S.U. 

40 CFR 430.114 specifies the BAT limitations. This portion of the ELGs allows facilities that do not use 

chlorophenolic biocides (pentachlorophenoi and trichlorophenol) to provide certification that they are not using 

these biocides, WLPC has previously provided certification that no chlorophenolic biocides are used at the facility. 

The Department is proposing to include a condition in the renewal permit requiring WLPC to provide a new 

certification that chlorophenolic biocides are not used. 

4.3 Comparison of 2004 NDPES Permit Limits and Technology Based Limits 

This section presents a comparison of the 2004 NPDES Permit limits with the technology-based limitations from 

EPA's effluent limitation guidelines. Since WLPC did not request a mass load increase, the proposed limits to be 

used for water quality analysis will be the more stringent of either the 2004 NPDES Permit limits or the 

technology-based limitations calculated above. 

TABLE 8: COMPARISON OF EXISTING AND TECHNOLOGY BASED LIMITS 

Parameter 

BOD-5 

day 

TSS 

PH 

Technology-Based Limits 

Daily Maximum 

13,235 Ibs/day 

17,754 Ibs/day 

Monthly Average 

6,860 Ibs/day 

9,523 Ibs/day 

5.0-9.0 S.U. 

2004 Limits 

May - Oct 

Nov-April 

Daily Maximum 

3800 lbs/day 

8015 Ibs/day 

9000 ibs/day 

Monthly Average 

2870 lbs/day 

4210 lbs/day 

6000 lbs/day 

5.0-9.0 S.U. 

11 
For BOD and TSS at outfall 001, the 2004 NPDES Permit limits are more stringent than the limits calculated using 

the technology-based standards. Therefore, the 2004 NPDES permit limits for these parameters will be used for the 

water quality analysis. 

4.4 Water Quality-Based Effluent Limits 

This section determines pollutants of concern and evaluates each parameter to determine whether the concentration 

of the pollutant in the discharge represents a "reasonable potential to exceed" water quality standards. If the 

discharge concentration of a particular pollutant has a reasonable potential to exceed water quality standards, then 

water quality based effluent limits are established for that pollutant, To determine whether the discharge has a 

reasonable potential to exceed water quality standards for toxic pollutants, a spreadsheet that simulates the 

approach in EPA's Technical Support Document for Water Quality Based Toxics was used. 

Pollutants of Concern 

Using effluent data from discharge monitoring reports, 303(d) parameters, and monitoring conducted for the 

NPDES permit application, the pollutants of concern being discharge from the facility were determined. 

As explained in Section 3.2, above, the Willamette River is listed as water quality limited for several parameters. 

Of these listed parameters, mercury, manganese, iron and temperature are pollutants of concern in the effluent of 

WLPC. In addition to these pollutants, biochemical oxygen demand (BOD), pH, turbidity, arsenic, selenium, and 

bromoform were detected in the facility's effluent and are considered pollutants of concern. Analytical results for 

dioxin (2,3,7,8 TCDD), all volatile compounds (with the exception of bromoform), all acid compounds, all 

base/neutral compounds and all pesticides were below detection limits and are thus not included as pollutants of 

concern. 

4.4.1 Dissolved Oxygen 

The 2004 NPDES Permit includes a biochemical oxygen demand (BOD) limit for the discharge from outfall 001. 

BOD is a measure of the oxygen demand exerted by the wastewater. BOD can affect dissolved oxygen levels in the 

receiving stream. For the 2004 permit, a detailed analysis was developed of the impacts due to WLPC effluent on 

dissolved oxygen levels in the Willamette River. Since the effluent and receiving stream characteristics have not 

changed significantly, this analysis is still considered valid. The following is the dissolved oxygen analysis 

developed for the 2004 permit: 

Dissolved oxygen (DO ) analysis has both a near-field component, which is primarily influenced by mixing, and a 

far-field component, which is primarily influenced by the oxygen demand exerted by the wastewater. Since the 

travel time to the edge of the mixing zone is quite short compared to the time required for the BOD to exert an 

oxygen demand, the near-field analysis is primarily influenced by dilution within the mixing zone. A mass balance 

equation is used to determine the resulting dissolved oxygen levels at the edge of the mixing zone. The calculation 

is as follows: 

DO„lz = (DOe * Qe+ DOs * Qs) / (Qlllz) 

Where: 

DOmz is the dissolved oxygen level at the edge of the mixing zone; 

DOe is the dissolved oxygen level in the effluent (3 mg/L -10th percentile of effluent data); 

DOs is the dissolved oxygen level in the Willamette River upstream of the discharge (8.0 mg/L, Canby Ferry 

monitoring station at RM 34.5) 

Qs is the portion of the Willamette River available for mixing (66) 

QnKis the dilution at the edge of the mixing zone (67) 

Qe is the effluent flow as a ratio to river flow (1) 

12 
The resulting DO levels at the edge of the mixing zone would be 7.93 mg/L, about 0.07 mg/L lower than upstream 

levels. Thus, the discharge would not reduce dissolved oxygen levels below the cool-water dissolved oxygen 

criteria of 6.5 mg/L at the edge of the mixing zone. 

A "Streeter-Phelps" dissolved oxygen analysis was conducted to determine the far-field effects on in-stream 

dissolved oxygen levels in the Willamette River as a result of the discharge from the WLPC facility. The permitted 

summer BOD load (3800 lbs/day) along with critical stream flow conditions were used in the simplified StreeterPhelps analysis. This analysis is primarily a screening analysis to determine whether a more detailed dissolved 

oxygen analysis is necessaiy. This screening analysis does not account for other discharges downstream of WLPC 

nor does it account for re-aeration that occurs at Willamette Falls and the additional flow from the Clackamas River 

just downstream of Willamette Falls. This simplified analysis indicates that the resulting maximum dissolved 

oxygen deficit as a result of the permitted summer BOD load from WLPC is about 0.12 mg/L (Attachment A). 

A water quality analysis using the QUAL-2E model of the Willamette River was conducted of the Blue Heron 

Paper Company's discharge, which is located just upstream of WLPC's discharge. This analysis accounts for other 

discharges including WLPC, re-aeration that occurs at Willamette Falls and Clackamas River and other tributary 

flows. The QUAL-2E model predicts that the resulting dissolved oxygen deficit in the lower Willamette River 

would be less than 0.10 mg/L at RM 10. The QUAL-2E model over predicts dissolved oxygen deficit downstream 

of RM 14 due to longitudinal dispersion caused by tidal fluctuations and Columbia River water interactions. The 

actual dissolved oxygen impacts in this region (i.e. downstream of RM 14) are expected to be less than those 

predicted by the QUAL-2E model. 

Based on these evaluations, the Department is proposing to include the currently permitted summer BOD load of 

3800 lbs/day in the NPDES permit. 

4.4.2 Turbidity 

The water quality standard for turbidity is dependent on background stream turbidity measurements. The standard 

states that no more than a 10% cumulative increase in stream turbidity levels is allowed relative to a control point 

immediately upstream of the turbidity causing activity. Effluent limits for turbidity addressing this standard were 

developed for the 2004 permit. In the period since the 2004 permit renewal, WLPC has significantly reduced the 

turbidity in its effluent (see Table 9), even after rerouting filter backwash water to the treatment system, 

TABLE 9: WILLAMETTE RIVER AND EFFLUENT TURBIDITY LEVELS 

Parameter 

Previous Effluent Turbidity 

(12/02-1/04) 

"Current" Effluent Turbidity 

(1/06-3/10) 

River Turbidity 

Season 

May 1 - Oct. 31 

Nov. 1-April 30 

May 1 - Oct. 31 

Nov. 1 -April 30 

May 1 - Oct. 31 

Nov. 1 -April 30 

Median Turbidity 

(NTU) 

23 

29 

6 

11 

4 

10 

95,h percentile Turbidity 

(NTU) 

39 

56 

12 

22 

-

--

The summer background turbidity levels in the table above are an estimate based on Willamette River data 

collected at Canby Ferry (RM 34.5) and Tualatin River at Weiss Bridge (RM 0.2). Tualatin River turbidity levels 

are not expected to measurably impact Willamette River turbidity levels during the winter months. Thus, the winter 

background turbidity levels in the table above are based only on Willamette River data at Canby Ferry. Median 

turbidity levels are presented in the table above rather than average because average values tend to be biased based 

on a small number of very high or very low measurements. 

13 
For outfall 001, a mass balance equation was used to determine the resulting increase in turbidity levels at the edge 

of the mixing zone. The calculation is as follows: 

Turbidityinz = (Turbidity, * Qe+ Turbidity, * Qs) / (Qwz) 

Where: 

Turbidity,„z is the turbidity level at the edge of the mixing zone; 

Turbiditye is the turbidity level in the effluent; 

Turbidity, is the turbidity level in the Willamette River upstream of the discharge 

Qs is the portion of the Willamette River available for mixing (66) 

Qinz is the dilution at the edge of the mixing zone (67) 

Qe is the effluent flow as a ratio to river flow (1) 

Using the median turbidity levels, the resulting turbidity increase is 0.03 NTU during the dty season (May 1 -

October 31) and 0.02 NTU during the wet season (November 1 - April 30). Both these values are less than a 10% 

increase from background turbidity levels, With the 95th percentile effluent turbidity levels, the resulting turbidity 

increase at the edge of the mixing zone is 0,12 NTU during the dry season (May 1 - October 31) and 0,18 NTU 

during the wet season (November 1 - April 30). Both these values are also less than a 10% increase from 

background turbidity levels. 

Based on this analysis, it is determined that the discharge from outfall 001 has no reasonable potential to exceed the 

water quality standard for turbidity. However, since a effluent limit for turbidity already exists in the 2004 permit, 

this limit will be retained in the renewal permit. 

4.4.3 Temperature 

This segment of the Willamette River serves as a migration corridor for salmonids. OAR 340-04 l-0028(4)(d) states 

that the 7-day average maximum temperature of a stream identified as a migration corridor may not exceed 20 °C 

(68 °F). As noted in Section 3.3, this segment of the Willamette River does not meet water quality standards for 

temperature during the summer months. For streams that do not meet water quality standards, OAR 340-041-

0028(12) states the following: 

"Following a temperature TMDL or other cumulative effects analysis, waste load and load allocations will 

restrict all NPDES point sources and nonpoint sources to a cumulative increase of no greater than 0.3 degrees 

Celsius (0.5 Fahrenheit) above the applicable criteria after complete mixing in the water body, and at the point 

of maximum impact," 

Since a temperature TMDL has been completed for the Willamette River (September 2006), the above provision 

from OAR 340-041-0028(12) applies. The TMDL gave a wasteload allocation (an "Excess Thermal Load") of 197 

million Kcals/day (based on a 7-day moving average of the daily maximum excess thermal loads). Since the current 

(2004) permit has an excess thermal load limit of 175 million Kcal/day, the Department is proposing to retain the 

existing limit. (It should be noted that WLPC has had difficulty meeting the existing limit. If continuing efforts on 

the part of WLPC to meet the limit fail, it is expected that the facility may request a permit modification to increase 

the limit to that allowed under the TMDL.) 

Thermal Plume Criteria 

The Department's water quality standards include temperature thermal plume limitations in OAR 340-041-0053(d). 

This section of the rules contains criteria to prevent potential adverse impacts that may result from thermal plumes. 

The temperature thermal plume limitations that the Department has adopted are similar to the recommendations in 

the April 2003 EPA Region 10 Temperature guidance. The criteria as they apply to the WLPC discharge are 

discussed below: 

14 
• OAR 340-041-0053(d)(A): Impairment of an active salmonid spawning area where spawning redds are 

located or likely to be located. 

WLPC discharge; There is no salmonid spawning in this segment of the Willamette River. This segment 

of the Willamette River selves as a migration corridor for salmonids. 

OAR 340-041-0053(d)(B): Acute impairment or instantaneous lethality is prevented or minimized by 

limiting potential fish exposure to temperatures of 32 °C or more to less than 2 seconds. 

WLPC discharge: Based on temperature data collected over the past four years using a continuous 

recording device, the maximum instantaneous effluent temperature at outfall 001 was 30.6 °C (recorded 

on July 31, 2009). Thus, the discharge is not expected to cause an acute impairment or instantaneous 

lethality. 

OAR 340-041-0053(d)(C): Thermal shock caused by a sudden increase in water temperature is prevented 

or minimized by limiting potential fish exposure to temperatures of 25 "C or more to less than 5% of the 

cross-section of 100% of the IQlOflow of the waterbody. 

WLPC discharge: The approximate cross-sectional area of the Willamette River near the outfall at 7Q10 

low flows is 26,000 ft2. Five percent of this area is 1300 ft2. An analysis of the temperature impacts of 

the effluent indicates that when the effluent plume reaches 5% of the river's cross-sectional area, the 

plume's temperature will never be over 25°C unless the ambient river conditions approach 25°: 

At an ambient river temperature of 24,8°C, the increase in river temperature at the point where the plume 

reaches 5% of the river cross-sectional area is approximately 25.1°C (See calculations in Attachment B). 

This portion of the thermal plume rule is based primarily on the USEPA guidance document, EPA Region 

10 Guidance for Pacific Northwest State and Tribal Temperature Water Quality Standards (April 2003), 

Section V.3. of the document gives guidance on protecting salmonids from thermal plume impacts and 

provides the following discussion on thermal shock: 

Thermal shock leading to increased predation can occur when salmon and trout exposed to near optimal 

temperatures (e.g., 15°C) experience a sudden temperature increase to 26 - 30°Cfor a short period of time 

(Coufant, 1973). Therefore, EPA suggests that thermal plumes be conditioned to limit the cross-sectional 

area of a river that exceeds 25°C to a small percent of the river (e.g., 5 percent or less). 

It is clear that thermal shock occurs when ambient river conditions are suddenly increased from relatively 

low temperatures (the example of 15°C is given) to temperatures above 25°C. It is also clear that this 

element is intended to apply when ambient river temperatures are much lower than 25°C. 340-041-

0053(d)(C) provides one method to ensure thermal shock does not occur, but at higher ambient river 

temperatures additional exposure timing restrictions may be developed to prevent thermal shock. One such 

restriction is to ensure river temperatures are not increased by more than a minimal amount when the 

effluent plume reaches 5% of the river's cross-sectional area. 

For the WLPC discharge, the expected increase in river temperatures when the effluent plume reaches 5% 

of the river's cross-sectional area and the river temperature approaches 25°C is approximately 0.2°C. An 

increase this small will not likely result in thermal shock. 

15 
• OAR 340-041-0053 (d)(D): Unless ambient temperature is 21 "C or greater, migration blockage is 

prevented or minimized by limiting potential fish exposure to temperatures of 21 °C or more to less than 

25% of the cross-section of 100% of the 7Q10flow of the waterbody. 

WLPC discharge: This rule is also based primarily on the USEPA guidance document, EPA Region 10 

Guidance for Pacific Northwest State and Tribal Temperature Water Quality Standards (April 2003). 

Section Y.3. of the document gives guidance on protecting salmonids from thermal plume impacts and 

provides this discussion on migration blockage: 

Adult migration blockage conditions can occur at 21°C ... Therefore, EPA suggests that the cross-sectional 

area of a river at or above 21°C be limited to less than 25% or, if upstream temperature exceeds 21°C, the 

thermal plume be limited such that 75% of the cross-sectional area of the river has less than a de minimis 

(e.g., 0.25°C) temperature increase. 

For a critical scenario related to the WLPC discharge, as the river temperature approaches 21°C (20,9°C), 

the resulting temperature of effluent plume when it reaches 25% of the river's cross-sectional area will be 

20.96°C (see calculations in Attachment B). This is clearly a de minimis increase which prevents or 

minimizes migration blockage. 

Thus, the analysis indicates that the discharge from the WLPC facility meets the temperature thermal plume 

limitations in OAR 340-041 -0053(d). 

4.4.4 pH 

As noted in Section 3.1, Applicable Water Quality Standards, the water quality standard for pH for the Willamette 

River is 6.5 - 8.5. The pH limit in the 2004 NPDES permit is 5.0 - 9.0 at Outfall 001. The technology based limit 

for pH in 40 CFR 430.112 for outfall 001 is also 5.0 - 9.0. A reasonable potential analysis has been performed to 

determine the potential for the effluent to cause violation of the pH water quality standard at the edge of the mixing 

zone and is presented in Attachment C. This analysis indicates that the lower limit of 5.0 would have a reasonable 

potential to violate the lower water quality pH criterion of 6,5 at the edge of the mixing zone. The analysis also 

indicates that a pH lower limit of 5.5 would not have a reasonable potential to violate the criterion. Thus, a lower 

pH effluent limit of 5.5 (as opposed to the 2004 permit's limit of 5.0) is appropriate. A pH limit of 5.5 - 9.0 is 

proposed for the discharge from outfall 001. 

4.4.5 Toxic Pollutants 

Based on a review of the analytical data submitted with the NPDES permit application, the toxic pollutants of 

concern at outfall 001 are arsenic, bromoform, iron, mercury, manganese, and selenium. An evaluation was 

conducted to determine whether the levels of these pollutants in the discharge have a "reasonable potential to 

exceed" water quality standards. The following table specifies the aquatic life and human health water quality 

standards, the maximum effluent concentration, and the number of samples collected for each pollutant. 

16 
Table 10: Toxic Pol 

Parameter 

Total 

Arsenic 

Arsenic V 

Arsenic III 

Bromoform 

Iron 

Mercury 

Manganese 

Selenium 

Unit 

Mg/L 

Mg/L 

pg/L 

pg/L 

pg/L 

M9/L 

pg/L 

Mg/L 

Aquatic Life Criteria 

Acute 

Criterion 

N/A 

850 

360 

N/A 

N/A 

2.4 

N/A 

260 

Chronic 

Criterion 

N/A 

48 

190 

N/A 

1000 

0.012 

N/A 

35 

utants of Concern at Outfall 001 

Human Health Criteria 

Water& 

Fish 

Ingestion 

0.0022 

N/A 

N/A 

4.3 

300 

(Dissolved) 

0.144 

50 

(Dissolved) 

10 

Fish 

Consumption 

0.0175 

N/A 

N/A 

140 

N/A 

0.146 

100 

(Total) 

4200 

Max Effluent 

Concentration 

2.75 

2.75 

(Total Arsenic) 

2.75 

(Total Arsenic) 

1.01 

22.7 

(Total Iron) 

0.00176 

47.7 

(Total Mn) 

26.8 

Number 

of 

Samples 

6 

6 

6 

6 

5 

8 

5 

6 

When determining whether a discharge has the potential to exceed water quality standards, the Department 

accounts for the variability of the effluent. A multiplier is used to account for effluent variability in accordance 

with the methods outlined in EPA's Technical Support Document for Water Quality Based Toxics Control (March 

1991). To determine whether the discharge has a reasonable potential to exceed water quality standards for these 

pollutants, a spreadsheet that simulates the approach in EPA's Technical Support Document for Water Quality 

Based Toxics was used (for Arsenic, please see the discussion below). Maximum probable effluent concentrations 

(based on the multiplier), water quality criteria, and mixing zone dilution data are used to determine whether the 

discharge has a reasonable potential to exceed water quality standards. The results of the reasonable potential 

analyses are included in Attachments D and E. The results indicate that, with the exception of arsenic, the 

discharge does not have a reasonable potential to exceed water quality criteria for the pollutants of concern 

identified in Table 10. Thus, water quality based effluent limits are not proposed for these pollutants at outfall 001, 

Arsenic: Arsenic is found at naturally occurring elevated levels in many of the streams in Oregon, including the 

Willamette River. WLPC's process water is withdrawn from the Willamette River where the total arsenic 

concentrations have been measured at approximately 1 ug/L. Of the six total arsenic analyses performed for the 

facility, four had non-detectable concentrations, one sample was measured at 2.18 ug/L and the measured 

maximum value was 2.75 pg/L. These concentrations may reflect only the concentration of arsenic through 

evaporation of river intake water, rather than any addition of arsenic by the facility. 

The Department is currently in the process of revising its human health arsenic criterion and will be proposing a 

criterion to better reflect the more toxic speciations of arsenic (inorganic arsenic) using a regionally appropriate 

health-risk calculation method. This will result in a shift of the standard from "total" to the "inorganic" fraction, 

and re-valuation to better reflect regional health risks. Given these imminent changes, the facility is being directed 

to ensure that current treatment facilities are being operated at the highest and best extent practicable and that they 

develop and implement an arsenic monitoring plan. These requirements are discussed below: 

Discussions with the facility indicate that there are no known introduced anthropogenic sources used in the 

processes contributing to the wastewater flow. There are no federally mandated Technology-based Effluent 

Limits for arsenic for the facility's industrial category. There are no aquatic toxicity criteria for total arsenic 

and discharges from the facility are well below the aquatic toxicity criteria for other forms of arsenic (i.e., 

17 
Arsenic III and Arsenic V). The facility is currently treating effluent with primary clarification and an aerated 

stabilization basin. This treatment is most likely removing a portion of the arsenic associated with particulates. 

Based upon calculations using past monitoring data, the anticipated limit of operational performance for the 

facility is 6 pg/L2 of total arsenic, For the purposes of the Departments' arsenic interim implementation policy 

and this permit, the combination of the processes equals or exceeds the "Best Available Treatment," as well as 

the requirement for the facility to continue to operate these processes at the highest and best extent practicable 

in the proposed permit. As a performance measure, if the quarterly average concentration of total arsenic is 

above 6 pg/L, the facility will be required to submit a report to the department detailing the conditions that 

resulted in the elevated value. The Department will use the report, monitoring information and operational 

records to assist in the determination of whether or not the facility was in compliance with the narrative 

operational requirements. 

The strategy to address arsenic in the facility's effluent is as follows: 

1. The proposed permit includes the requirements (in Schedule D) for the facility to develop and submit for 

approval, within 60 days of permit issuance, an Arsenic Monitoring Plan showing how the facility will 

collect ambient and effluent data to identify the arsenic source and speciation and to quantify the mass 

loading of arsenic, This will include proposed sample locations, frequency, seasonality data sources, 

analytic methods and applicable quantification limits. 

2. The proposed permit requires that the facility begin implementation of the approved monitoring plan within 

two weeks of Departmental approval. 

3. After 2.5 years the Department intends to conduct a "Pre-Application Review Conference" with the facility 

with the purpose of evaluating the collected data to determine if there might be an affirmative Reasonable 

Potential Analysis (RPA) finding for the applicable arsenic (total/inorganic) criteria. 

4. If the preliminary data indicate the potential for an affirmative RPA finding, the Department may reopen 

the permit to include any additional arsenic requirements that may be appropriate. 

4.5 Whole Effluent Toxicity 

In addition to analyzing the effluent for individual pollutants, the effluent is also tested to determine it's aggregate 

effect on aquatic organisms. These tests are known as whole effluent toxicity (WET) tests. Effluent samples are 

collected and aquatic organisms are subjected to various effluent concentrations in controlled laboratory 

experiments. EPA has developed WET test protocols using both freshwater and marine and estuarine test species. 

EPA recommends running tests using an invertebrate, vertebrate and a plant. Organisms used in WET tests are 

indicators or surrogates for the aquatic community to be protected, and a measure of the real biological impact from 

exposure to the toxic pollutants, To protect water quality, WET tests are used in NPDES permits together with 

requirements based on chemical-specific water quality criteria. 

WET tests are used to determine the percentage of effluent that produces an adverse effect on a group of test 

organisms. The measured effect may be fertilization, growth, reproduction, or survival. EPA's methodology 

includes both an acute test and a chronic test. An acute WET test is considered to show toxicity if adverse affects 

occur at effluent concentrations less than that which is found at the edge of the zone of immediate dilution (ZID). 

A chronic WET test is considered to show toxicity if adverse affects occur at effluent concentration less than that 

which is known to occur at the edge of the mixing zone. 

2

 The benchmark of 6 pg/L was calculated as a statistical estimate of the performance limit of the treatment facility. The 

benchmark was calculated using historical discharge data and estimating the maximum expected effluent concentration at the 

95% confidence level and the 95% probability basis. For this treatment system, there were no other performance-based 

effluent limits, including technology, aquatic toxicity and pretreatment, available to reflect more established best available 

treatment performance measures. 

18 
Wet tests have been conducted twice per year on WLPC's effluent. No acute or chronic toxicity was shown by any 

of the tests. 

4.6 Antidegradation 

An Antidegradation Review was performed for this discharge. The permit is being renewed without any increase in 

discharge loadings. Permit renewals with the same discharge loadings as the previous permit are hot considered to 

lower water quality from the existing condition. Based on the antidegradation review, the Department determined 

the proposed discharge complies with the Antidegradation Policy for Surface Waters found in OAR 340-041-0026 

(see Appendix F). 

5.0 COMPLIANCE HISTORY 

The most recent inspection of this facility was made on June 10, 2010. The facility was found to be operating in 

compliance with its permit. 

The facility is in compliance with all conditions in Schedule C, "Compliance Conditions and Schedules", of the 

2004 permit. 

The Department issued six warning letters during the term of the current permit for violations. The violations are 

listed below: 

Ta 

Date of 

Violation 

5/25/2006 

1/16/2007 

9/18/2007 

12/19/2007 

7/7/2009 

10/15/2009 

Violation Class* 

ll/Il 

II 

II 

II 

I 

UI 

ble 11: Permit Violations 

Description of violation 

Thermal Load violation/Monitoring violation 

Pulp spill 

Sump Overflow 

Outfall damage 

Effluent turbidity exceedance 

Effluent pH exceedance 

*Class I violations are the most serious; Class III are the least serious 

Due to the location and age of the facility, spills to the river were previously a common occurrence. In recent years 

the number and extent of the spills have been reduced. Notable effort has been made to limit the possibility of 

spillage due to power failure at the facility. Since pumps are used to move wastewater up the hillside for treatment, 

power failure results in wastewater draining back down to the facility's primary effluent sump with potential to 

overflow into the "courtyard", which acts as an auxiliary sump. Leakage from the "courtyard" has been the source 

of previous spills. Along with the continuing sealing of the "courtyard" process and operations modifications 

have been made to limit the amount of wastewater routed to the sumps during a power outage. The most recent 

significant power outage (16 hours) resulted in full containment of wastewater with no release to the Willamette. 

The warning letter related to the damage of the outfall, while citing a permit violation, noted that the damage was 

beyond the facility's control. The damaged outfall pipe has been fixed. The violation related to the exceedance of 

the facility's excess thermal load limit has resulted in a continuing effort by WLPC to minimize heat load. 

The more recent violations for turbidity and pH exceedances both appear to be due to aquatic growth in the 

facility's lagoon (ASB), The turbidity was traced to the presence of Cerodaphnia, a water flea. Ironically, 

Cerodaphnia growth is usually an indicator of positive aquatic health. The pH exceedances appear to be due to 

algal and/or vegetative growth in the lagoon, For both of these issues, the facility has been closely watching 

indicators and is experimenting with various operational modifications. 

19 
6.0 PERMIT DRAFT DISCUSSION 

6.1 Face Page 

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

receiving stream infonnation, permit approval authority, and a description of permitted activities, The permittee is 

authorized to construct, install, modify, or operate a wastewater collection, treatment, control and disposal system. 

The permit allows discharge to the Willamette River within limits set by Schedule A and the following schedules. 

All other discharges are prohibited. The previous permit's reference to Outfall 002 - Water Treatment Plant (Filter 

Backwash) - has been removed. 

6.2 Schedule A - Waste Discharge Limitations 

The permit includes waste discharge limitations for BOD, TSS, pH, Excess Thermal Load, and Turbidity. All 

limitations are the same as those in the 2004 permit, with the exception of the limitations for pH. The pH 

limitations have changed from 5.0 - 9.0 to 5.5 - 9.0 as explained in Section 4.4.4, above. The interim turbidity 

limitations and the note related to this limitation have also been removed from the renewal permit as they are no 

longer applicable, 

A note has been added to Schedule A explaining that the Department may allow for exceedances of the excess 

thermal load as provided by Oregon Administrative Rule (OAR) 340-041-0028(12). This "air temperature 

exception" rule states: "A water body that only exceeds the criteria set out in this rule when the exceedance is 

attributed to daily maximum air temperatures that exceed the 90th percentile value of annual maximum seven-day 

average maximum air temperatures calculated using at least 10 years of air temperature data, will not be listed on 

the section 303(d) list of impaired waters and sources will not be considered in violation of this rule." 

In addition to the discharge limitations included in the 2004 permit, the proposed permit includes a benchmark for 

arsenic as explained in Section 4,4.5, above. 

Also included in Schedule A are descriptions of the mixing zone and zone of initial dilution for Outfall 001. These 

descriptions are the same as those in the 2004 permit. Reference to the mixing zone and zone of initial dilution for 

Outfall 002 have been removed. 

6.3 Schedule B - Minimum Monitoring and Reporting Requirements 

Schedule B includes the minimum monitoring and reporting requirements for the facility. The proposed monitoring 

requirements for temperature and paper production remain unchanged from the 2004 permit and are as follows: 

Parameter 

Fine & Lightweight Paper Production 

Units 

ADMT/day 

Minimum Frequency 

Monthly 

Parameter 

Temperature (dally maximum) 

Temperature (7-day average of 

daily maximums) 

Excess Thermal Load (Daily 

Maximum) 

Excess Thermal Load (7-day 

Average of Daily Maximums) 

Minimum Frequency 

Daily 

Daily 

Daily 

Daily 

Units 

T 

op 

Kcal/day 

Kcal/day 

Sample 

Type 

Calculate 

Calculate 

Calculate 

Calculate 

20 
The proposed monitoring requirements for other parameters remain unchanged from the 2004 permit with the 

following exceptions: 1) hi order to fully characterize the effluent, requirements have been included to monitor 

dissolved oxygen and total dissolved solids for the first year of the permit 2) The minimum frequency for BOD and 

TSS monitoring has been reduced from 3 times per week to twice per week, 3) The addition of language specific to 

the monitoring of industrial wastewater solids, and 4) The priority pollutant scan monitoring is broken down 

between metals and other parameters, with the metals monitoring frequency set at once per year and the other 

parameters required to be monitored once eveiy other year. The reduced monitoring frequency for BOD and TSS is 

considered adequate for discharge characterization and for determining compliance with the effluent limits3. The 

priority pollutant scan monitoring change is based on the monitoring requirements recommended by an internal 

management directive developed by the Department. The internal management directive recommended that 

effluent be characterized by a certain size of data set (depending on pollutant type). With the proposed monitoring, 

the data set characterizing WLPC's effluent will be adequate to fully assess potential impacts to the Willamette 

River. 

Parameter 

Flow 

BOD5 

TSS 

Dissolved Oxygen 

Total Dissolved Solids 

pH 

Turbidity 

Temperature 

Whole Effluent Toxicity 

Metals (including total 

arsenic), inorganic arsenic, 

cyanide, total phenols, 

alkalinity and hardness 

Volatile compounds, acidextractable compounds, 

and pesticides 

Outfall condition 

Minimum 

Frequency 

Daily 

2/week 

2/week 

2/week 

2/week 

3/week 

3/week 

Daily 

2/year 

1/year 

Once Every Other 

Year 

3

rd

 year 

Units 

mgd 

mg/L & Ibs/day 

mg/L & Ibs/day 

mg/L 

mg/L 

S.U. 

NTU 

•F 

N/A 

pg/L 

(unless otherwise 

warranted) 

pg/L 

(unless otherwise 

warranted) 

Narrative 

Sample Type 

Continuous Recorder 

24-hour composite 

24-hour composite 

Grab or Continuous 

Grab or composite 

Grab or Continuous 

24-hour composite 

Continuous Recorder 

24-hour composite 

24-hour composite 

24-hour composite 

Visual Inspection 

Various notes related to monitoring are included in the permit. These explain how samples are to be collected and 

analyzed, that dissolved oxygen and total dissolved solids monitoring is only required for the first year of the 

permit, and that certain toxics monitoring of individual parameters may be suspended after two years if all data are 

non-detectable and other monitoring details (please see the proposed permit for details). 

The reporting requirements in Schedule B remain unchanged from the 2004 permit with the exception of 

certain specifics in the reporting of non-detect results and the addition of reporting requirements related to 

industrial solids. 

3

 The daily maximum BOD loading during the period of 1/2006 through 3/2010 was 714 Ibs/day, far below the most stringent 

permit limit of 3800 lbs/day. The daily maximum TSS loading during the period of 1/2006 through 3/2010 was 1430 lbs/day, 

also far below the most stringent permit limit of 9000 lbs/day. 

21 
6.4 Schedule C - Compliance Schedules and Conditions 

Schedule C has been eliminated from the proposed permit. No compliance schedule is proposed for the permit and 

the biocide certification and industrial solids management plan requirements have been moved to Schedule D. 

6.5 Schedule D - Special Conditions 

Schedule D of the proposed permit retains the same conditions as the 2004 permit except for the following: 

• The condition related to the Willamette River Temperature TMDL (which has been addressed in the 

permit) has been eliminated 

• The condition related to flow measurement (which is addressed in Schedule F, General Conditions) has 

been eliminated. 

• The WET (bioassay) test language was updated to include a new dilution series that would reflect mixing 

zone and ZID dilutions. The WET language also includes updated and corrected references to guidance 

documents and other information. 

• A new condition has been added requiring the permittee to develop an Arsenic Monitoring Plan. This plan 

is required to be implemented until notification by the Department that further implementation is 

unwarranted. 

• A new condition has been added requiring the permittee to update its mixing zone study. 

• The section on Industrial Wastewater Solids has been updated. 

The following are the topics addressed in Schedule D: 

• WET Testing 

• Spills and Unplanned Discharges 

• Environmental Supervision and Management 

• Pollution Prevention Program 

• Industrial Wastewater Solids 

• Biocide Certification 

• Arsenic Management Plan 

• Mixing Zone Study Update 

6.6 Schedule F - NPDES General Conditions 

These conditions are standard to all NPDES permits and include language regarding operation and maintenance of 

facilities, monitoring and record keeping, and reporting requirements. 

The General Conditions were revised in 2010. A summary of the changes is as follows: 

• There are additional citations to the federal Clean Water Act and CFR, including references to 

standards for sewage sludge use or disposal. 

• There is additional language regarding federal penalties. 

• Bypass language has been made consistent with the CFR. 

• Overflow language has been eliminated. 

• Requirements regarding emergency response and public notification plans have been made more 

explicit. 

• Language pertaining to duty to provide information has been made more explicit. 

• Confidentiality of information is addressed. 

• A definition of CBOD has been added. 

22 
6.7 Permit Processing/Public Comment/Appeal Process 

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

the contact name and telephone number are included in the public notice (See Attachment G). The permittee is the 

only person with the right to request a contested case hearing to review the Department's permitting decision. If the 

permittee is dissatisfied with the conditions of the permit when issued, they may request a hearing before the EQC 

or its designated hearing officer within 20 days of the final permit being mailed. The request for hearing must be 

sent to the Director of the Department. Any hearing held will be conducted pursuant to regulations of the 

Department and will be before an administrative law judge. The administrative law judge will issue a proposed 

decision and that a final decision will be issued by the EQC. If a contested case hearing is held, other persons may 

be given the right to participate in the hearing. Other persons who are adversely affected or aggrieved by the 

permit decision may have the right to judicial review under ORS 183.484. 

23