FACT SHEET FOR NPDES PERMIT WA0040851 

STEELSCAPE, INC. 

2/24/2005 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

TABLE OF CONTENTS

INTRODUCTION ........................................................................................................................................ 1 

BACKGROUND INFORMATION ............................................................................................................. 3 

DESCRIPTION OF THE FACILITY ............................................................................................. 3 

History ................................................................................................................................ 3 

INDUSTRIAL PROCESS ............................................................................................................... 3 

Summary of Production ...................................................................................................... 4 

FACILITY WATER MANAGEMENT .......................................................................................... 4 

Summary of Water Usage................................................................................................... 4 

DESCRIPTION OF WASTEWATER TREATMENT PLANT...................................................... 6 

Oily Waste System.............................................................................................................. 6 

Metal Waste System ........................................................................................................... 7 

Summary of Wastewater Discharge.................................................................................... 8 

DISCHARGE OUTFALL ............................................................................................................... 9

PERMIT STATUS........................................................................................................................... 9 

SUMMARY OF COMPLIANCE WITH THE PREVIOUS PERMIT.......................................... 11 

FLOWS, SOURCES OF POLLUTION, AND TREATMENT PROCESSES.............................. 12 

WASTEWATER CHARACTERIZATION .................................................................................. 15 

PROPOSED PERMIT LIMITATIONS...................................................................................................... 21 

DESIGN CRITERIA ..................................................................................................................... 22 

TECHNOLOGY-BASED EFFLUENT LIMITATIONS .............................................................. 22 

Pickle Line: 40 CFR Part 420 - Subpart I - Acid Pickling Subcategory.......................... 23 

Cold-Rolling Line: 40 CFR Part 420 - Subpart J - Cold Forming Subcategory .............. 24 

Metallic [Zinc] Coating Line: 40 CFR 420 - Subpart L – Hot Coating 

Subcategory ...................................................................................................................... 24 

Paint Line: 40 CFR Part 465 - Subpart B - Galvanized Basis Material 

Subcategory ...................................................................................................................... 25 

Combined Technology-Based Effluent Limitations......................................................... 25 

Arsenic Performance-Based Limitations.......................................................................... 27 

Other Technology-Based Limitations............................................................................... 27 

SURFACE WATER QUALITY-BASED EFFLUENT LIMITATIONS...................................... 27 

Numerical Criteria for the Protection of Aquatic Life...................................................... 27 

Numerical Criteria for the Protection of Human Health................................................... 27 

Narrative Criteria .............................................................................................................. 28 

Antidegradation ................................................................................................................ 28 

Critical Conditions............................................................................................................ 28 

Mixing Zones.................................................................................................................... 28 

Description of the Receiving Water.................................................................................. 28 

Surface Water Quality Criteria ......................................................................................... 29 

Consideration of Surface Water Quality-Based Limits for Numeric Criteria................... 30 

Whole Effluent Toxicity ................................................................................................... 37 

Human Health................................................................................................................... 38 

Sediment Quality .............................................................................................................. 38 

GROUND WATER QUALITY LIMITATIONS.......................................................................... 39 

COMPARISON OF EFFLUENT LIMITS WITH THE EXISTING PERMIT ISSUED 

SEPTEMBER 14, 1998 .................................................................................................... 39 

MONITORING REQUIREMENTS........................................................................................................... 41 

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

EFFLUENT LIMITS BELOW QUANTITATION....................................................................... 41 

EFFLUENT LIMITS BELOW DETECTION............................................................................... 41 

LAB ACCREDITATION .............................................................................................................. 41 

OTHER PERMIT CONDITIONS .............................................................................................................. 41 

REPORTING AND RECORDKEEPING ..................................................................................... 41 

NON-ROUTINE AND UNANTICIPATED DISCHARGES ....................................................... 42 

SPILL PLAN ................................................................................................................................. 42 

SOLID WASTE PLAN.................................................................................................................. 42 

EFFLUENT MIXING STUDY ..................................................................................................... 42 

OUTFALL EVALUATION .......................................................................................................... 42 

TREATMENT SYSTEM OPERATING PLAN............................................................................ 43 

GENERAL CONDITIONS ........................................................................................................... 43

PERMIT ISSUANCE PROCEDURES ...................................................................................................... 43 

PERMIT MODIFICATIONS ........................................................................................................ 43 

RECOMMENDATION FOR PERMIT ISSUANCE .................................................................... 43 

REFERENCES FOR TEXT AND APPENDICES..................................................................................... 43 

APPENDIX A--PUBLIC INVOLVEMENT INFORMATION ................................................................. 45 

APPENDIX B--GLOSSARY ..................................................................................................................... 46 

APPENDIX C--TECHNICAL CALCULATIONS .................................................................................... 49 

APPENDIX D--RESPONSE TO COMMENTS ........................................................................................ 50 

APPENDIX E-- TECHNICAL MEMORANDUM.................................................................................... 51 

2/24/2005 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

INTRODUCTION 

The Federal Clean Water Act (FCWA, 1972, and later modifications, 1977, 1981, and 1987) established 

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

achieving the goals of the Clean Water Act is the National Pollutant Discharge Elimination System 

(NPDES) of permits, which is administered by the Environmental Protection Agency (EPA). The EPA

has authorized the state of Washington to administer the NPDES permit program. Chapter 90.48 Revised 

Code of Washington (RCW) defines the Department of Ecology's (Department) authority and obligations 

in administering the wastewater discharge permit program. 

The regulations adopted by the state include procedures for issuing permits [Chapter 173-220 Washington

Administrative Code (WAC)], water quality criteria for surface and ground waters (Chapters 173-201A 

and 200 WAC), and sediment management standards (Chapter 173-204 WAC). These regulations require 

that a permit be issued before discharge of wastewater to waters of the state is allowed. The regulations 

also establish the basis for effluent limitations and other requirements which are to be included in the

permit. One of the requirements (WAC 173-220-060) for issuing a permit under the NPDES permit

program is the preparation of a draft permit and an accompanying fact sheet. Public notice of the

availability of the draft permit is required at least 30 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 reviewed by the Permittee. Errors and omissions identified in 

this review have been corrected before going to public notice. After the public comment period has 

closed, the Department will summarize the substantive comments and the response to each comment. 

The summary and response to comments will become part of the file on the permit and parties submitting 

comments will receive 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 D--Response to 

Comments. 

Table 1 General Information 

Applicant Steelscape, Inc.

Facility Name and Address Steelscape, Inc. 

222 West Kalama River Road 

Kalama, Washington 98625 

Type of Facility Cold-Rolled and Steel Sheet, Strip, and Bars 

SIC Code 3316 

Discharge Location Waterbody name: Columbia River @ RM 72.2 

Latitude: 46° 02' 40" N 

Longitude: 122° 52' 30" W 

Water Body ID Number WA-CR-1010 

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Figure 1 Topographical map of the facility vicinity; scale 1:50,000

Outfall 

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

BACKGROUND INFORMATION 

DESCRIPTION OF THE FACILITY

The facility name is Steelscape, Inc. (Steelscape). It was formerly know as BHP Coated Steel

Corporation. The facility is located in Kalama, Washington. 

The site is on Port of Kalama property, bordered by Burlington Northern Railroad to the east, West

Kalama River Road to the south, the Columbia River to the west, and Port of Kalama domestic sewage

treatment plant (the POTW) to the north. The legal description of the site is Section 31, Township 7N, 

Range 1 W; Section 36, Township 7N, Range 2W, Willamette Meridian. Steelscape is sharing an outfall

with the Publicly Owned Treatment Works (POTW). 

At this time, Steelscape has no committed future plans, although a request to use effluent discharge for 

dust suppression has been submitted to the Department. 

Approximately 170 operators and 30 managers and engineers work at Steelscape. The company

corporate offices located next door employ 80 people. The production lines operate 24 hours a day, seven 

days a week, in a standard three shift work schedule. Production operations are fairly consistent year 

round with very little seasonal variation. Wastewater flows are also fairly consistent due to the 

continuous operation of the production lines. 

HISTORY

Construction began on the facility in November of 1995. Pickle line operations began March 23, 1997.

Overall plant operations started August 1, 1997. The industrial wastewater treatment facility was

operational when the pickle line operations began. 

INDUSTRIAL PROCESS1

Facility 

Steelscape is a facility for cold rolling and coating of steel strip. The facility is classified under SIC code 

of 3316 and includes four principal production lines: 

1. Pickle Line 

2. Cold Rolling Mill 

3. Metallic [Zinc] Coating Line 

4. Coil Paint Line. 

All four principal production lines generate wastewater. Additional sources of wastewater are boilers,

cooling towers, and water demineralizer. 

 

1 A full description of industrial process is provided in Raytheon’s Engineering Report, 1996. 

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Steelscape, Inc. 

SUMMARY OF PRODUCTION

A summary of Steelscape’s production is listed in Table 2. 

Table 2 Production rates at 100% efficiency 

Line Short tons per 

year 

Tonnes (t) per 

year Tonnes per day Square meters per day 

Pickle Line 500,000 453,592 1340 

Cold Rolling Mill 488,000 442,706 1308 

Metallic Coating 

Line 270,000 244,940 724 155,096 

Coil Paint Line 108,000 97,976 289 73,855 

FACILITY WATER MANAGEMENT2

Design Water Usage and Disposal Overview 

The design total plant water usage was 534,890 gallons per day (gpd) or 371 gallons per minute (gpm) 

from the City of Kalama municipal water supply. Major water uses include cooling towers, steam system

and process areas. The process areas include the pickle line, cold rolling mill, metallic coating line, and 

the paint line. Demineralizers produce 173,280 gpd of demineralized (demin) water to be used in the 

processes and in the boilers to make steam. The boilers (rated for 30,000 lbs per hour) produce the steam 

equivalent of 70,560 gpd of water. Evaporation from the cooling towers accounts for 216,060 gpd of 

water lost to the atmosphere. The processes account for another 128,880 gpd of evaporation. Domestic

waste (8,000 gpd) is treated offsite by the Port of Kalama Municipal Wastewater Treatment System. 

Some water leaves the process with wastes that are transported offsite such as spent pickle liquor. The

remaining water is treated in the industrial waste treatment which consists of an oily waste system and a 

metal wastewater treatment system. All values said above are maximum gallons per day. Instantaneous 

maximums may be higher.

SUMMARY OF WATER USAGE

A summary of Steelscape’s water usage is listed in Table 3. 

 

2 A full description of facility water management is provided in Raytheon’s Engineering Report, 

1996. 

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Steelscape, Inc. 

Table 3: Steelscape water usage 

Water Usage

Activity [gallons per day (gpd)] % of total water usage 

Design total water usage 534,890 100

1) Demineralizers production (water used in 

processes and in the boilers to make steam) 

173,280 32

• Rolling Mill 89,280 17

• Boiler system 70,560 13

a) Pickle Line 17,280 3.2 

b) Zincalume

 Line 28,800 5.4

c) Paint Line 23,040 4.3 

d) Cooling tower 1,440 0.3 

• Paint Line 1,440 0.3

2) Pickle Line 55,730 10 

3) Zincalume

 Line 48,240 9.0

4) Paint Line 15,840 3.0 

5) Cooling tower 219,580 41 

6) Wastewater treatment 15,220 2.8 

• Oily wastewater treatment 500 0.1

• Metal wastewater treatment 14,720 2.8

7) Domestic 8,000 1.5

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

DESCRIPTION OF WASTEWATER TREATMENT PLANT3

Overview 

The industrial waste water treatment plant for the Pacific Northwest Flat Products facility encompasses 

two distinct process systems. The first is an "oily waste" treatment process which pre-treats all plant

waste waters that are potentially contaminated with oils or grease. The second system for "Metal Waste"

is a physical/chemical treatment process for reduction of metals and insoluble contaminants from all

industrial waste water streams (including the pretreated oily waste streams) prior to their discharged to the 

environment. 

All equipment associated with the industrial wastewater treatment plant is located in a common area

within the facility; and with the exception of a waste oil storage tank and two waste blending tanks (one 

for each treatment process), the industrial wastewater treatment system is located indoors in Area 17, the

Utilities Building. The industrial wastewater treatment plant was designed to operate continuously, 24 

hours per day. Equipment redundancy and waste retention capacity was incorporated into the system to

obtain optimum reliability. There are no system bypass provisions; all industrial waste is treated prior to 

discharge to the environment. 

OILY WASTE SYSTEM

The oily waste system treats waste streams from the Cold Roll Mill, Metallic Coating and Coil Paint lines

which are associated with oil processing. This system produces effluent for discharge to the metal waste 

system and also produces oily sludge for off-site disposal. 

The system is designed to receive both intermittent and continuous flows. Although only a portion of the

waste streams flow continuously, the waste treatment process will operate continuously. A blending tank 

allows for mixing of continuous and intermittent streams prior to treatment. The oily waste treatment 

system was designed to process a combined oily waste stream having the characteristics presented in

Table 4 at a design service rate of 60 gpm (86,400 gpd). 

Table 4 Design criteria for the oily waste treatment system 

Constituent Units Concentration 

Flow Gallons per minute (gpm) 

Gallons per day (gpd) 

60 

86,400 

NaOH Milligrams per liter (mg/L) 12,250 

Oil mg/L 3,025

Zn mg/L 2

Al mg/L 35

 

3 A full description of wastewater treatment plant is provided in Raytheon’s Engineering 

Report, 1996. 

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Constituent Units Concentration 

Fe mg/L 460

Cr mg/L 0.1

PO4 mg/L 38

TSS mg/L 15

The oily waste system consists of the following principle components: 

• Oily Waste Collection System

• Oily Waste Blending System

• Oil Water Separation System Stage 1 and 2 

• Waste Oil Holding and Discharge System 

• Treated Oily Waste Holding and Discharge System

• Hydrochloric Acid Feed System

• De-emulsifier Feed System 

• Coagulant Feed System

• Polymer Feed System

METAL WASTE SYSTEM

The metal waste system treats waste streams from the Pickle line, Metallic Coating line, Coil Paint line 

and miscellaneous facility auxiliary waste (demineralizer regenerant waste and cooling tower 

blowdowns). It also processes the clear effluent from the oily waste system. This system produces liquid 

effluent for discharge to the Columbia River and solids (filter cake) for removal from the site. 

The system is designed to receive both intermittent and continuous flows. Although only a portion of the

waste streams flow continuously, the waste treatment process will operate continuously. A blending tank 

allows for mixing of continuous and intermittent streams prior to treatment. The metal waste is 

chemically reduced, neutralized, oxidized, coagulated, precipitated, clarified, filtered, and the resultant

sludge dewatered into a cake for disposal. The metal waste treatment system was designed to process the 

combined industrial waste stream having the characteristics presented in Table 5. 

Table 5 Design criteria for the metal waste treatment system

Constituent Units Concentration 

Flow 

Gallons per minute (gpm) 

Gallons per day (gpd) 

125 

180,000 

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

HCl Milligrams per liter (mg/L) 3,440 

NaCl mg/L 15,000

Oil mg/L 10

Zn mg/L 5

Al mg/L 24

Fe mg/L 390

Cr mg/L 25

PO4 mg/L 55

TSS mg/L 100

The metal waste process consists of the following: 

• Metal Waste Collection System

• Metal Waste Blending System

• Chromium Reduction System

• Neutralization/Oxidation System

• Flocculation and Clarification System

• Filtering System

• Sludge Dewatering System 

• Treated Waste Holding and Discharge System

• Sodium Hydroxide Feed System

• Sodium Meta-bisulfite Feed System

• Polymer Dilution and Delivery System

SUMMARY OF WASTEWATER DISCHARGE

Summary of Steelscape wastewater discharge is listed in Table 6. Evaporation of 345,000 gpd from the 

cooling towers and processes accounts for 64 percent of the water usage. Thirty four (34) percent of the 

water, or 180,000 gpd, is treated in the industrial wastewater treatment system and then discharged to the

Columbia River. The remaining two percent of the water leaves the plant with the domestic sewage or

the liquid wastes such as spent pickle liquor that will be transported off site for treatment and disposal. 

2/24/2005 Page 8 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Table 6: Steelscape wastewater discharge 

Wastewater discharge 

Activity/Wastewater Type

[gallons per day (gpd)] % of total water usage 

1) Metal wastewater treatment 180,000 34 

2) Water lost to evaporation 344,140 64 

• Pickle Line 4,320 0.8

• Rolling Mill 88,480 17

• Zincalume

 Line 23,040 4.3

• Paint Line 12,240 2.3

• Cooling tower 216,060 40

3) Net loss of water with spent pickle liquor 2,450 0.5 

4) Domestic waste (treated offside by the Port 

of Kalama Municipal Wastewater 

Treatment System) 

8,000 1.5

DISCHARGE OUTFALL

Treated effluent from the facility is discharged to the Columbia River via a submerged outfall pipe with a

diffuser. A four-port, submerged diffuser is positioned 200 feet from shore at the south end of a wharf. 

The outfall is shared with the Port of Kalama sewage treatment plant. The two treated wastewater

streams are combined and then discharged to the Columbia River @ RM 72.2 through the shared outfall. 

PERMIT STATUS 

The previous permit for this facility was issued on September 14, 1998. The previous permit placed

effluent limitations as listed in Table 7. 

Table 7: Previous permit effluent limitations 

EFFLUENT LIMITATIONS: OUTFALL # 001 

Parameter Average Monthly1,5,6 Maximum Daily2,4,6

Flow, MGD [millions of gallons per 

day] ---- 0.180

pH, std. units Between 6.0 and 9.0 

TSS [total suspended solids], kg/day

[kilograms per day] 11 23

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

EFFLUENT LIMITATIONS: OUTFALL # 001 

Parameter Average Monthly1,5,6 Maximum Daily2,4,6

Oil and Grease, kg/day 4.6 11 

Temperature, °C [degree Celsius] ---- 35

Chromium (Total), kg/day 0.024 0.060 

Copper, kg/day 0.034 0.072 

Cyanide, kg/day 0.013 0.032 

Iron, kg/day 0.10 0.20 

Lead, kg/day 0.045 0.14 

Mercury, kg/day 0.0010 0.0020 

Silver, kg/day 0.014 0.029 

Zinc, kg/day 0.13 0.34 

Naphthalene, kg/day ---- 0.0022(3,4)

Tetrachloroethylene, kg/day ---- 0.0031(3,4)

WET [whole effluent toxicity] (acute) 

WET (chronic) 

The permittee should note that there also may be additional 

effluent limits in section S5. Acute Toxicity and S6. Chronic 

Toxicity. 

Footnotes for Table 7: 

(1) The average monthly effluent limitation is defined as the highest allowable average of daily 

discharges over a calendar month, calculated as the sum of all daily discharges measured during a 

calendar month divided by the number of daily discharges measured during that month. 

(2) The maximum daily effluent limitation is defined as the highest allowable daily discharge. 

(3) The MDL for naphthalene is 1.6 μg/L using gas chromatography/mass spectrometry and 

method number 625 from 40 CFR Part 136. The quantitation level (QL) for naphthalene is 10

μg/L. 

The MDL for tetrachloroethylene is 4.1 μg/L using gas chromatography/mass spectrometry and 

method number 624 from 40 CFR Part 136. The quantitation level (QL) for tetrachloroethylene 

is 10 μg/L. 

These QLs will be used for assessment of compliance with these effluent limits. If the Permittee 

is unable to attain the MDL and QL in its effluent due to matrix effects, the Permittee shall

submit a matrix specific MDL and QL to the Department by July 1, 1997. The matrix specific 

MDL and QL shall be calculated as follows: 

MDL = 3.14 x (standard deviation of 7 replicate spiked samples). This corresponds to

the calculation of the method detection limit, as defined in 40 CFR Part 136, Appendix B,

with the provision that the MDL be calculated for a specific effluent matrix. 

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

The QL = 5 x MDL 

Check standards at concentrations equal to the QL shall be analyzed alongside all compliance 

monitoring samples. Check standards shall be produced independently of calibration standards 

and maintained as a part of the Permittee's records. All check standard recovery data and 

duplicate measurements shall be submitted to the Department in the discharge monitoring report. 

The Department's precision goal is +/- 20 percent. 

(4) If the measured effluent concentration is below the QL, the Permittee shall report NQ for nonquantifiable. 

(5) Average values shall be calculated as follows: measurements below the MDL = 0;

measurements greater than the MDL = the measurement. 

(6) When sample measurements for compliance with mass-based limits fall below the MDL, the 

average loading shall be calculated using a concentration value of zero. When sample

measurements for compliance with mass-based limits fall above the MDL, the average loading 

shall be calculated using the measured concentration. 

An application for permit renewal was submitted to the Department on December 26, 2001, and accepted 

by the Department on January 18, 2002.

SUMMARY OF COMPLIANCE WITH THE PREVIOUS PERMIT 

The facility last received an inspection on August 3, 2001. 

Table 8 summarizes Steelscape’s compliance with the previous permit. 

Table 8 Summary of compliance 

Parameter Units Type Value Min Limit Max Limit DMR Date 

Iron, total (as 

Fe) 

Kilograms 

per day 

(kg/day)

Average 

monthly 0.14 0.1 1-Feb-99

Iron, total (as 

Fe) kg/day

Maximum 

daily 0.36 0.2 1-Feb-99

Iron, total (as 

Fe) kg/day

Maximum 

daily 0.277 0.2 1-Jun-99

Mercury, total 

(as Hg) kg/day Average monthly 0.006 0.001 1-Jan-99

Mercury, total 

(as Hg) kg/day

Maximum 

daily 0.018 0.002 1-Jan-99

Naphthalene kg/day Maximum 0.002 0.002 1-Mar-99

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Parameter Units Type Value Min Limit Max Limit DMR Date 

daily

Oil & grease kg/day

Maximum 

daily 14.7 11 1-May-00

pH Standard 

units (S.U.) RAN 5.7 6.0 9.0 1-Mar-99

pH S.U. RAN 5.6 6.0 9.0 1-Sep-00

Temperature Degree 

Celsius (oC) 

Maximum 

daily 37.4 35 1-Oct-00

Temperature oC Maximum 

daily 36 35 1-Jan-01

Temperature oC Maximum 

daily 38.4 35 1-Jul-01

FLOWS, SOURCES OF POLLUTION, AND TREATMENT PROCESSES 

Table 9 Sources of pollution, flows, and treatment processes 

Operations Contributing Flow Treatment

Outfall 

Number Operation Average Flow Description 

Codes From 

001 Pickle Line Oily Waste 600 

Steelscape, 

2001, section 

1.1.1 & 3.2 

2-K,2-C,2-

D,1-G,1-H 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Pickle Line Metal 

Waste 35000 

Steelscape, 

2001, section 

1.1.1 & 3.3 

 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Cold Mill Oily Waste 800 

Steelscape, 

2001, section 

1.1.2 & 3.2 

2-K,2-C,2-

D,1-G,1-H 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Roll Shop Oily Waste 1400 

Steelscape, 

2001, section 

1.1.2 & 3.2 

2-K,2-C,2-

D,1-G,1-H 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

Table 10

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Steelscape, Inc. 

Operations Contributing Flow Treatment

Outfall 

Number Operation Average Flow Description 

Codes From 

Table 10

001 Metal Coating Line 

Oily Waste 35000 

Steelscape, 

2001, section 

1.1.3 & 3.2 

2-K,2-C,2-

D,1-G,1-H 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Metal Coating Line 

Metal Waste 700 

Steelscape, 

2001, section 

1.1.3 & 3.3 

 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Paint Line Oily Waste 4400 

Steelscape, 

2001, section 

1.1.4 & 3.2 

2-K,2-C,2-

D,1-G,1-H 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Paint Line Metal Waste 5400 

Steelscape, 

2001, section 

1.1.4 & 3.3 

 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Utilities Oily Waste 4300

Steelscape, 

2001, section 

2.2.7 & 3.2 

2-K,2-C,2-

D,1-G,1-H 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

001 Utilities Metal Waste 12000 

Steelscape, 

2001, section 

2.2.7 & 3.3 

 

2-L,2-K,2-

C,2-D,1-U,1-

P,4-A,5-R,1-

C,5-Q 

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Steelscape, Inc. 

Table 10 Codes for treatment units 

PHYSICAL TREATMENT PROCESSES 

1-A ...................Ammonia Stripping 

1-B ...................Dialysis 

1-C ...................Diatomaceous Earth Filtration 

1-D ...................Distillation 

1-E....................Electrodialysis

1-F....................Evaporation 

1-G ...................Flocculation 

1-H ...................Flotation 

1-I.....................Foam Fractionation 

1-J.....................Freezing 

1-K ...................Gas-Phase Separation 

1-L....................Grinding (Comminutors 

1-M....................Grit Removal 

1-N ....................Microstraining 

1-O ....................Mixing 

1-P .....................Moving Bed Filters 

1-Q ....................Multimedia Filtration 

1-R.....................Rapid Sand Filtration 

1-S .....................Reverse Osmosis (Hyperfiltration)

1-T.....................Screening 

1-U ....................Sedimentation (Settling)

1-V ....................Slow Sand Filtration 

1-W....................Solvent Extraction 

1-X ....................Sorption 

CHEMICAL TREATMENT PROCESSES 

2-A ...................Carbon Adsorption 

2-B ...................Chemical Oxidation 

2-C ...................Chemical Precipitation 

2-D ...................Coagulation 

2-E....................Dechlorination 

2-F....................Disinfection (Chlorine) 

2-G ....................Disinfection (Ozone)

2-H ....................Disinfection (Other)

2-I......................Electrochemical Treatment 

2-J......................Ion Exchange

2-K ....................Neutralization 

2-L.....................Reduction 

BIOLOGICAL TREATMENT PROCESSES 

3-A ...................Activated Sludge 

3-B ...................Aerated Lagoons 

3-C ...................Anaerobic Treatment 

3-D ...................Nitrification-Denitrification 

3-E.....................Pre-Aeration 

3-F.....................Spray Irrigation/Land Application 

3-G ....................Stabilization Ponds 

3-H ....................Trickling Filtration 

OTHER PROCESSES 

4-A ...................Discharge to Surface Water 

4-B ...................Ocean Discharge Through Outfall 

4-C ....................Reuse/Recycle of Treated Effluent 

4-D ....................Underground Injection 

SLUDGE TREATMENT AND DISPOSAL PROCESSES 

5-A ...................Aerobic Digestion 

5-B ...................Anaerobic Digestion 

5-C ...................Belt Filtration 

5-D ...................Centrifugation 

5-E....................Chemical Conditioning 

5-F....................Chlorine Treatment 

5-G ...................Composting 

5-H ...................Drying Beds 

5-I.....................Elutriation 

5-J.....................Flotation Thickening 

5-K ...................Freezing 

5-L....................Gravity Thickening 

5-M....................Heat Drying 

5-N ....................Heat Treatment 

5-O ....................Incineration 

5-P .....................Land Application 

5-Q ....................Landfill 

5-R.....................Pressure Filtration 

5-S .....................Pyrolysis 

5-T.....................Sludge Lagoons 

5-U ....................Vacuum Filtration 

5-V ....................Vibration 

5-W....................Wet Oxidation 

2/24/2005 Page 14 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

WASTEWATER CHARACTERIZATION 

The proposed wastewater discharge is characterized for the regulated by the permit parameters in 

 and to . The proposed wastewater discharge is also characterized for number of

unregulated by the permit parameters in the permit application. 

Table

11 Figure 2 Figure 27

A detailed spreadsheet of all the data and copy of the permit application can be requested from: 

Industrial Unit Permit Coordinator 

Department of Ecology 

Southwest Region - Water Quality

P.O. Box 47775 

Olympia, WA 98504-7775

Table 11 Wastewater characterization 

Permit limitations 

Maximum (and minimum for pH) 

Number Reported in Data Monitoring 

Reports (DMRs), November 1998—

October 2003 Parameter 

Average 

Monthly1,5,6

Maximum 

Daily2,4,6

Average 

Monthly Maximum Daily

Flow, millions of gallons 

per day (MGD) ---- 0.180 ---- 0.16

pH, std. units Between 6.0 and 9.0 5.6-8.92 (5.6 is below the limitation) 

Arsenic, micrograms per 

liter (μg/L) ---- ---- 1.56 5

Total suspended solids 

(TSS), kg/day

11 23 6 15.9

Oil and Grease, 

kilograms per day 

(kg/day)

4.6 11 4.01 14.7 (excided

limitation) 

Temperature, °C ---- 35 ---- 38.4 (excided

limitation) 

Chromium (Total), 

kg/day

0.024 0.060 0.013 0.03

Copper, kg/day 0.034 0.072 0.034 (at 

limitation) 0.066 

Cyanide, kg/day 0.013 0.032 0.011 0.022 

Iron, kg/day 0.10 0.20 0.14 (excided

limitation) 

0.36 (excided

limitation) 

Lead, kg/day 0.045 0.14 0.02 0.08

Mercury, kg/day 0.0010 0.0020 0.006 0.018 

Silver, kg/day 0.014 0.029 0.006 0.006 

Zinc, kg/day 0.13 0.34 0.061 0.241 

2/24/2005 Page 15 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Permit limitations 

Maximum (and minimum for pH) 

Number Reported in Data Monitoring 

Reports (DMRs), November 1998—

October 2003 Parameter 

Average 

Monthly1,5,6

Maximum 

Daily2,4,6

Average 

Monthly Maximum Daily

Naphthalene, kg/day ---- 0.0022(3,4) ---- 0.002

Tetrachloroethylene, 

kg/day ---- 0.0031(3,4) ---- 0.001

Footnotes for Table 11:

(1) The average monthly effluent limitation is defined as the highest allowable average of daily 

discharges over a calendar month, calculated as the sum of all daily discharges measured during a 

calendar month divided by the number of daily discharges measured during that month. 

(2) The maximum daily effluent limitation is defined as the highest allowable daily discharge. 

(3) The MDL for naphthalene is 1.6 μg/L using gas chromatography/mass spectrometry and method 

number 625 from 40 CFR Part 136. The quantitation level (QL) for naphthalene is 10 μg/L. 

The MDL for tetrachloroethylene is 4.1 μg/L using gas chromatography/mass spectrometry and 

method number 624 from 40 CFR Part 136. The quantitation level (QL) for tetrachloroethylene is 10 

μg/L. 

These QLs will be used for assessment of compliance with these effluent limits. If the Permittee is

unable to attain the MDL and QL in its effluent due to matrix effects, the Permittee shall submit a

matrix specific MDL and QL to the Department by July 1, 1997. The matrix specific MDL and QL 

shall be calculated as follows: 

MDL = 3.14 x (standard deviation of 7 replicate spiked samples). This corresponds to the

calculation of the method detection limit, as defined in 40 CFR Part 136, Appendix B, with

the provision that the MDL be calculated for a specific effluent matrix. 

The QL = 5 x MDL 

Check standards at concentrations equal to the QL shall be analyzed alongside all compliance

monitoring samples. Check standards shall be produced independently of calibration standards and

maintained as a part of the Permittee's records. All check standard recovery data and duplicate 

measurements shall be submitted to the Department in the discharge monitoring report. The 

Department's precision goal is +/- 20 percent. 

(4) If the measured effluent concentration is below the QL, the Permittee shall report NQ for nonquantifiable. 

(5) Average values shall be calculated as follows: measurements below the MDL = 0; measurements

greater than the MDL = the measurement. 

2/24/2005 Page 16 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

(6) When sample measurements for compliance with mass-based limits fall below the MDL, the 

average loading shall be calculated using a concentration value of zero. When sample measurements

for compliance with mass-based limits fall above the MDL, the average loading shall be calculated

using the measured concentration. 

Figure 2 Flow—maximum daily Figure 3 pH—minimum and maximum daily

Flow

0

0.05

0.1

0.15

0.2

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

mg

d

Maximum Daily Limit Trendline

pH

5

6

7

8

9

10

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

S.U.

Effluent Upper Limit Lower Limit Trendline

Figure 4 Total suspended solids (TSS)—average 

monthly mass load 

Figure 5 Total suspended solids (TSS)—

maximum daily mass load 

Total Suspended Solids (TSS)

0

5

10

15

20

25

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Trendline

Total Suspended Solids (TSS)

0

5

10

15

20

25

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Trendline

2/24/2005 Page 17 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Figure 6 Oil and Grease (O&G)—average 

monthly mass load 

Figure 7 Oil and Grease (O&G)—maximum daily

mass load 

Oil and Grease (O&G)

0

5

10

15

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Trendline

Oil and Grease (O&G)

0

5

10

15

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Trendline

Figure 8 Temperature—maximum daily Figure 9 Arsenic (As)—maximum daily 

concentration 

Temperature

25

30

35

40

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

oC

Maximum Daily Limit Trendline

Arsenic

0

2

4

6

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

μg/

L

Average Monthly Maximum Daily Trendline

Figure 10 Chromium (Cr) —average monthly 

mass load 

Figure 11 Chromium (Cr)—maximum daily mass 

load 

Chromium

0

0.02

0.04

0.06

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Tredline

Chromium

0

0.02

0.04

0.06

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Tredline

2/24/2005 Page 18 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Figure 12 Copper (Cu)—average monthly mass 

load 

Figure 13 Copper (Cu)—maximum daily mass 

load 

Copper

0

0.02

0.04

0.06

0.08

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Tredline

Copper

0

0.02

0.04

0.06

0.08

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Tredline

Figure 14 Cyanide (CN)—average monthly mass 

load 

Figure 15 Cyanide (CN)—maximum daily mass 

load 

Cyanide

0

0.01

0.02

0.03

0.04

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Tredline

Cyanide

0

0.01

0.02

0.03

0.04

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Tredline

Figure 16 Iron (Fe)—average monthly mass load Figure 17 Iron (Fe)—maximum daily mass load 

Iron

0

0.1

0.2

0.3

0.4

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Tredline

Iron

0

0.1

0.2

0.3

0.4

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Tredline

2/24/2005 Page 19 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Figure 18 Lead (Pb)—average monthly mass load Figure 19 Lead (Pb)—maximum daily mass load 

Lead

0

0.05

0.1

0.15

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Trendline

Lead

0

0.05

0.1

0.15

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Trendline

Figure 20 Mercury (Hg)—average monthly mass 

load 

Figure 21 Mercury (Hg)—maximum daily mass 

load 

Mercury

0

0.005

0.01

0.015

0.02

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Trendline

Mercury

0

0.005

0.01

0.015

0.02

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Trendline

Figure 22 Silver (Ag)—average monthly mass 

load 

Figure 23 Silver (Ag)—maximum daily mass load 

Silver

0

0.01

0.02

0.03

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Trendline

Silver

0

0.01

0.02

0.03

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Trendline

2/24/2005 Page 20 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Figure 24 Zinc (Zn)—average monthly mass load Figure 25 Zinc (Zn)—maximum daily mass load 

Zinc

0

0.1

0.2

0.3

0.4

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Average Monthly Limit Trendline

Zinc

0

0.1

0.2

0.3

0.4

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/d

a

y

Maximum Daily Limit Trendline

Figure 26 Naphthalene—average monthly mass 

load 

Figure 27 Tetrachloroethylene —maximum

daily mass load 

Naphthalene

0

0.001

0.002

0.003

0.004

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/

d

a

y

Maximum Daily Limit Trendline

Tetrachloroethylene

0

0.001

0.002

0.003

0.004

Nov-98 Nov-99 Nov-00 Nov-01 Nov-02 Nov-03

Time

kg/

d

a

y

Maximum Daily Limit Trendline

 

PROPOSED PERMIT LIMITATIONS 

Federal and state regulations require that effluent limitations set forth in a NPDES permit must be either 

technology- or water quality-based. Technology-based limitations are based upon the treatment methods 

available to treat specific pollutants. Technology-based limitations are set by regulation or developed on 

a case-by-case 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, Tuesday, 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- and water quality-basis. The limits 

necessary to meet the rules and regulations of the state of Washington were determined and included in

this permit. The Department does not develop effluent limits for all pollutants that may be reported on 

the application as present in the effluent. Some pollutants are not treatable at the concentrations reported, 

2/24/2005 Page 21 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

are not controllable at the source, are not listed in regulation, and do not have a reasonable potential to 

cause a water quality violation. Effluent limits are not always developed for pollutants that may be in the

discharge but not reported as present in the application. In those circumstances the permit does not 

authorize discharge of the non-reported pollutants. Effluent discharge conditions may change from the 

conditions reported in the permit application. If significant changes occur in any constituent, as described 

in 40 CFR 122.42(a), the Permittee is required to notify the Department. 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 design criteria for this treatment facility are taken from updated December 2001 engineering report

prepared by Raytheon Engineers and Constructors and are listed in Table 4 and Table 5. 

TECHNOLOGY-BASED EFFLUENT LIMITATIONS 

The Pickle Line, Cold Rolling Mill, Metallic [Zinc] Coating Line, and the Paint Line all generate

wastewater that must meet technology-based effluent limitations. Each production line is subject to a 

specific federal effluent limitation. All technology based limitations for the Steelscape facility are 

derived from the applicable New Source Performance Standards (NSPS), since the Steelscape facility was 

built after the standards were enacted. The federal effluent limitations are based on the amount of 

production from a particular process. With the exception of the fume scrubbers, the technology-based

limitations that apply to the Steelscape facility are calculated by multiplying the federal limitation by the 

applicable production rate. 

The following NSPSs were reviewed by the Department and found not applicable to the facility: 

9 40 CFR 420.114(a) Alkaline cleaning subcategory— Steelscape has an alkaline cleaning section 

on the metallic [zinc] coating line that is presently not used. Because of the use of synthetic 

rolling oil on the cold mill line there is no need to use the alkaline cleaning section. 

9 40 CFR 420.124(c) Hot coating subcategory—fume scrubbers; 40 CFR 420.124(c) does not apply

because a process that requires a scrubber is operated less than two weeks a year (none between

January 1, 2004, and August 18, 2004).

9 40 CFR 465.13 Coil coating4

, steel basis material subcategory; 40 CFR 465.13 does not apply to the 

wastewater discharges from the metallic coating line. The metallic coating line discharges waste

waters resulting from the operations in which steel is coated with zinc by the hot dip process;

therefore 40 CFR 420.124(a)(1) applies to the wastewater discharges from the metallic coating

line. 

The following is a list of applicable NSPSs: 

 

4“Coil coating ” means the process of converting basis material strip into coated stock. Usually 

cleaning, conversion coating, and painting are performed on the basis material. This regulation 

covers processes which perform any two or more of the three operations.

2/24/2005 Page 22 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

9 Pickle Line; 40 CFR 420.94(b)(2) and 40 CFR 420.94(b)(4) are applicable including limitations

for O&G [oil and grease] because acid pickling waste waters are treated with cold rolling waste 

waters. 

9 Cold Rolling Mill; 40 CFR 420.104(a)(1) is applicable including limitations for chromium and 

nickel in lieu of those for lead and zinc because cold rolling waste waters are co-treated with acid

pickling waste waters. 

9 Metallic (Zinc) Coating Line; 40 CFR 420.124(a)(1) is applicable including limitations for 

hexavalent chromium because Steelscape has galvanizing operations which discharge

wastewaters from the chromate rinse step. 

9 Coil Paint Line; 40 CFR 465.23 

The following tables present the applicable federal effluent limitations and the resultant production-based

effluent limitations for each of the production lines. 

PICKLE LINE: 40 CFR PART 420 - SUBPART I - ACID PICKLING SUBCATEGORY

Wastewater discharges from the hydrochloric acid pickling line must meet the technology-based effluent

limitations as specified in 40 CFR Part 420 - Iron and Steel Manufacturing Point Source Category. The 

pickle line processes maximum of 1,340 tonne per day and is subject to the effluent limitations listed in 

Table 12. 

Table 12: 40 CFR 420.94(b)(2) - Hydrochloric acid pickling effluent limitations (strip, sheet, and plate). 

Pollutant Maximum Daily

(kg/t5 of product) 

Average Monthly 

(kg/t of product) 

Maximum Daily

(kg/day6) 

Average Monthly 

(kg/day) 

Total Suspended 

Solids (TSS) 1.17E-02 5.01E-03 1.57E+01 6.71E+00

Oil and Grease 

(O&G) 5.01E-03 1.67E-03 6.71E+00 2.24E+00

Lead 7.51E-05 2.50E-05 1.01E-01 3.35E-02

Zinc 1.00E-04 3.34E-05 1.34E-01 4.48E-02

pH within the range of 6.0 to 9.0 at all times 

Wastewater discharges from any fume scrubber that supports a hydrochloric acid pickling line must meet 

the technology-based effluent limitations as specified in 40 CFR Part 420 - Iron and Steel Manufacturing

Point Source Category. The effluent limitations for wastewater from the single fume scrubber in the 

pickle line are subject to the effluent limitations in Table 13. 

 

5 Kilograms per ton 

6 Kilograms per day 

2/24/2005 Page 23 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Table 13: 40 CFR 420.94(b)(4) - Fume Scrubbers. 

Pollutant Maximum Daily

(kg/scrubber) 

Average Monthly 

(kg/scrubber) 

Maximum Daily

(kg/day7) 

Average Monthly 

(kg/day) 

TSS 5.72E+00 2.45E+00 5.72E+00 2.45E+00

O&G 2.45E+00 8.19E-01 2.45E+00 8.19E-01

Lead 3.68E-02 1.23E-02 3.68E-02 1.23E-02

Zinc 4.91E-02 1.64E-02 4.91E-02 1.64E-02

pH within the range of 6.0 to 9.0 at all times 

COLD-ROLLING LINE: 40 CFR PART 420 - SUBPART J - COLD FORMING SUBCATEGORY

Wastewater discharges from the cold-rolling line must meet the technology-based effluent limitations as 

specified in 40 CFR Part 420 - Iron and Steel Manufacturing Point Source Category. The cold-rolling 

line processes a maximum of 1,308 tonne per day and is subject to the effluent limitations listed in 

. 

Table 

14

Table 14: 40 CFR 420.104(a)(1) - Cold-rolling mills. Recirculation -- single stand. 

Pollutant Maximum Daily

(kg/t8 of product) 

Average Monthly 

(kg/t of product) 

Maximum Daily

(kg/day9) 

Average Monthly 

(kg/day) 

TSS 1.25E-03 6.26E-04 1.63E+00 8.19E-01

O&G 5.22E-04 2.09E-04 6.83E-01 2.73E-01

Chromium 2.09E-05 8.40E-06 2.73E-02 1.10E-02

Nickel, total 

recoverable 1.88E-05 6.30E-06 2.46E-02 8.24E-03

Naphthalene 2.10E-06 N/A 2.75E-03 N/A

Tetrachloroethylene 3.10E-06 N/A 4.05E-03 N/A

pH within the range of 6.0 to 9.0 at all times 

METALLIC [ZINC] COATING LINE: 40 CFR 420 - SUBPART L – HOT COATING SUBCATEGORY

Wastewater discharges from the metallic coating line must meet the technology-based effluent limitations

as specified in 40 CFR Part 420 - Iron and Steel Manufacturing Point Source Category. The metallic 

coating line processes a maximum of 724 tone per day and is subject to the effluent limitations listed in

Table 15. 

 

7 Kilograms per day 

8 Kilograms per ton 

9 Kilograms per day 

2/24/2005 Page 24 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

Table 15: 40 CFR 420.124(a)(1)- (a) Galvanizing, terne coating and other coatings—(1) Strip, sheet, 

and miscellaneous products. 

Pollutant Maximum Daily

(kg/t of product) 

Average Monthly 

(kg/t of product) 

Maximum Daily

(kg/day) 

Average Monthly 

(kg/day) 

TSS 4.38E-02 1.88E-02 3.17E+01 1.36E+01

O&G 1.88E-02 6.26E-03 1.36E+01 4.53E+00

Lead 2.82E-04 9.39E-05 2.04E-01 6.79E-02

Zinc 3.76E-04 1.25E-04 2.72E-01 9.05E-02

Chromium +6 3.76E-05 1.25E-05 2.72E-02 9.05E-03

pH within the range of 6.0 to 9.0 at all times 

PAINT LINE: 40 CFR PART 465 - SUBPART B - GALVANIZED BASIS MATERIAL SUBCATEGORY

Wastewater discharges from the paint line must meet the technology-based effluent limitations as 

specified in 40 CFR Part 465 - Coil Coating Point Source Category. The paint line processes an average 

of 74,000 m2

/day of coated steel strip and is subject to the effluent limitations listed in Table 16. 

Table 16: 40 CFR 465.23 - Coil coating, galvanized basis material subcategory. 

Pollutant 

Maximum Daily

(mg/m2 of 

product)10

Average Monthly 

(mg/m2 of 

product) 

Maximum Limit 

(kg/day11) 

Average Monthly 

(kg/day) 

TSS 5.15E+00 4.12E+00 7.61E-01 6.09E-01

O&G 3.43E+00 3.43E+00 5.07E-01 5.07E-01

Chromium 1.30E-01 5.20E-02 1.92E-02 7.68E-03

Copper 4.40E-01 2.10E-01 6.50E-02 3.10E-02

Cyanide 7.00E-02 2.80E-02 1.03E-02 4.14E-03

Zinc 3.50E-01 1.50E-01 5.17E-02 2.22E-02

Iron 4.30E-01 2.20E-01 6.35E-02 3.25E-02

pH within the range of 7.5 to 10.0 at all times 

COMBINED TECHNOLOGY-BASED EFFLUENT LIMITATIONS

Table 12, Table 13, Table 14, Table 15, and Table 16 show the technology-based effluent limitations that 

apply to the individual production lines. Wastewater from the four production lines is combined and

 

10 Milligrams per square meter of product 

11 Kilograms per day 

2/24/2005 Page 25 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

treated in the industrial wastewater treatment plant. The effluent limitations that apply to the combined

wastewater discharge are derived by summing the individual effluent limitations. Table 17 gives the 

technology based effluent limitations for the combined industrial wastewater discharge. Limitations in 

μg/L12 are calculated for the 0.180 mgd13 flow. 

Table 17: Combined technology-based effluent limitations based . 

Maximum Daily Limit Monthly Average Limit 

Pollutant 

kg/day

14 μg/L kg/day μg/L 

Flow, millions of 

gallons per day 

(mgd) 

1.80E-01 

pH within the range of 6.0 to 9.0 at all times 

Total suspended 

solids (TSS) 5.55E+01 8.14E+04 2.42E+01 3.55E+04

Oil and grease 

(O&G) 2.40E+01 3.52E+04 8.37E+00 1.23E+04

Chromium, total 

recoverable 4.65E-02 6.83E+01 1.87E-02 2.74E+01

Hexavalent 

chromium, total 

recoverable 

2.72E-02 3.99E+01 9.05E-03 1.33E+01

Copper, total 

recoverable 6.50E-02 9.54E+01 3.10E-02 4.55E+01

Cyanide 1.03E-02 1.52E+01 4.14E-03 6.07E+00

Iron, total 

recoverable 6.35E-02 9.32E+01 3.25E-02 4.77E+01

Lead, total 

recoverable 3.41E-01 5.01E+02 1.14E-01 1.67E+02

Nickel, total 

recoverable 2.46E-02 3.61E+01 8.24E-03 1.21E+01

Zinc, total 

recoverable 5.07E-01 7.44E+02 1.74E-01 2.55E+02

Naphthalene 2.75E-03 4.03E+00 N/A N/A

Tetrachloroethylene 4.05E-03 5.95E+00 N/A N/A

 

12 Micrograms per liter 

13 Millions of gallons per day 

14 Kilograms per day 

2/24/2005 Page 26 
Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

ARSENIC PERFORMANCE-BASED LIMITATIONS

The technology-based effluent limitations for arsenic (Table 18) are calculated based on Steelscape

performance during most recent three years prior to drafting this permit. 

Table 18: Arsenic performance-based limitations 

Maximum Daily Limit Monthly Average Limit 

Pollutant 

μg/L 

Arsenic 4.8 2.4

OTHER TECHNOLOGY-BASED LIMITATIONS

The technology-based effluent limitation for temperature (Table 19) was established for the previous

permit and is retained in this permit. 

Table 19: Other technology-based limitations 

Maximum Daily Limit Monthly Average Limit 

Pollutant 

Degree Celsius (oC) 

Temperature 35 N/A

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 states that waste discharge permits shall be conditioned such that the 

discharge will meet established Surface Water Quality Standards. The Washington State Surface Water

Quality Standards (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). 

NUMERICAL CRITERIA FOR THE PROTECTION OF AQUATIC LIFE

"Numerical" water quality criteria are numerical values set forth in the state of Washington's Water 

Quality Standards for Surface Waters (Chapter 173-201A WAC). They specify the levels of pollutants 

allowed in a receiving water while remaining 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. When surface water quality-based limits are 

more stringent or potentially more stringent than technology-based limitations, they must be used in a 

permit. 

NUMERICAL CRITERIA FOR THE PROTECTION OF HUMAN HEALTH 

The U.S. EPA has promulgated 91 numeric water quality criteria for the protection of human health that

are applicable to Washington State (EPA 1992). These criteria are designed to protect humans from 

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cancer and other disease and are primarily applicable to fish and shellfish consumption and drinking

water from surface waters. 

NARRATIVE CRITERIA

In addition to numerical criteria, "narrative" water quality criteria (WAC 173-201A-030) limit toxic, 

radioactive, or deleterious material concentrations below those which have the potential to adversely

affect characteristic water uses, cause acute or chronic toxicity to biota, impair aesthetic values, or

adversely affect human health. 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. 

ANTIDEGRADATION 

The state of Washington's Antidegradation Policy requires that discharges into receiving water shall not 

further degrade the existing water quality of the water body. In cases where the natural conditions of 

receiving water are of lower quality than the criteria assigned, the natural conditions shall constitute the 

water quality criteria. Similarly, when the natural conditions of receiving water are of higher quality than 

the criteria assigned, the natural conditions shall be protected. More information on the State 

Antidegradation Policy can be obtained by referring to WAC 173-201A-070. 

The Department has reviewed existing records and is unable to determine if ambient water quality is

either higher or lower than the designated classification criteria given in Chapter 173-201A WAC;

therefore, the Department will use the designated classification criteria for this water body in the proposed 

permit. The discharges authorized by this proposed permit should not cause a loss of beneficial uses. 

CRITICAL CONDITIONS

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 

biota, human health, and existing or characteristic water body uses. 

MIXING ZONES

The Water Quality Standards allow the Department to authorize mixing zones around a point of discharge 

in establishing surface water quality-based effluent limits. Both "acute" and "chronic" mixing zones may

be authorized 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 discharges that are 

receiving all known, available, and reasonable methods of prevention, control and treatment (AKART) 

and in accordance with other mixing zone requirements of WAC 173-201A-100. 

The National Toxics Rule (EPA, 1992) allows the chronic mixing zone to be used to meet human health

criteria. 

DESCRIPTION OF THE RECEIVING WATER

The facility discharges to Columbia River which is designated as a Class A receiving water in the vicinity

of the outfall. Other nearby point source outfalls include Noveon Kalama and the City of Kalama sewage 

treatment plant. Characteristic uses include the following: water supply (domestic, industrial, 

agricultural); stock watering; fish migration; fish and shellfish rearing, spawning and harvesting; wildlife

habitat; primary contact recreation; sport fishing; boating and aesthetic enjoyment; commerce and

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navigation. Water quality of this class shall meet or exceed the requirements for all or substantially all 

uses. 

A special condition for the Columbia River in the vicinity of the outfall is that the receiving water 

temperature shall not exceed 20°C due to human activities. This is above the Class A standard of 18°C. 

When natural conditions exceed 20.0°C, no temperature increase will be allowed which will raise the

receiving water temperature by greater than 0.3°C; nor shall such temperature increases, at any time,

exceed 0.3°C due to any single source. 

SURFACE WATER QUALITY CRITERIA

Applicable criteria are defined in Chapter 173-201A WAC for aquatic biota. In addition, U.S. EPA has 

promulgated human health criteria for toxic pollutants (EPA 1992). The surface water quality criteria 

applicable to the combined discharge from Steelscape and the Port of Kalama are summarized below: 

Table 20: Surface Water Quality Criteria. 

Parameter Criteria 

Fecal Coliform 100 colonies/100 mL maximum geometric mean 

Dissolved Oxygen 8 mg/L minimum

Temperature

Shall not exceed 20.0°C due to human activities. 

Note: Ambient temperature monitoring in the vicinity of the outfall has 

detected temperatures as high as 22.5°C. 

pH 6.5 to 8.5 standard units 

Turbidity Less than 5 NTU above background 

Toxics 

No toxics in toxic amounts (see Appendix C for numeric criteria for

toxics of concern for this discharge) 

Note: Ambient monitoring in the Columbia River has determined that 

arsenic is present at a concentration of 1 μg/L. This is above the human 

health standard of 0.018 μg/L, therefore, as is consistent with the state’s 

policy, 1 μg/L will be the standard used to determine compliance with 

the human health standards. 

The Columbia River (WRIA15 27) is listed as impaired on the latest CWA16 303(d) list for the following 

parameters: 

1. 4,4’-DDE (category 217); Steelscape believes that 4,4’-DDE is absent and did not test for the

pollutant; the permit requires Steelscape to test for 4,4’-DDE and submit the data with the permit

renewal application 

 

15 Water Resource Inventory Area 

16 Clean Water Act 

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2. Ammonia-N (category 2); according to the permit application ammonia concentration in effluent is 

4.4 milligrams per liter (mg/L); that’s approximately on the level of the calculated acute water quality 

criteria and several times higher than the calculated chronic water quality criteria; the permit requires 

Steelscape to conduct receiving water and effluent study for ammonia, mixing zone study, AKART

analysis for ammonia, and summarize findings in an engineering report 

3. Arsenic, inorganic (category 2); performance-base limitations set in the permit 

4. Bis(2-ethylehexyl) phthalate (category 2); Steelscape believes that bis(2-ethylehexyl) phthalate is 

absent; however Steelscape tested for the pollutant because testing was required; bis(2-ethylehexyl) 

phthalate was not found in one tested sample. 

5. Dieldrin (category 518); Steelscape believes that dieldrin is absent and did not test for the pollutant; 

the permit requires Steelscape to test for dieldrin and submit the data with the permit renewal

application 

6. Dioxin (category 4A19); Steelscape believes that dioxin is absent and did not test for the pollutant; the

permit requires Steelscape to test for dioxin and submit the data with the permit renewal application 

7. Total PCBs (category 5); Steelscape believes that PCBs are absent and did not test for PCBs; the 

permit requires Steelscape to test for total PCBs and submit the data with the permit renewal

application 

8. Temperature; the permit limit is based on an existing performance based limit and meets water quality

criteria at the edge of chronic mixing zone 

9. Total dissolved gas (category 4A); Steelscape is not a source that would contribute to the surface

water quality criteria violation 

The Columbia River TMDL20 to assign waste load allocations for pollutants has not been done yet. 

CONSIDERATION OF SURFACE WATER QUALITY-BASED LIMITS FOR NUMERIC CRITERIA

 17 Waters should be placed in Category 2 if there are data and information that meet the requirements of the State's 

assessment and listing methodology that support a determination that some, but not all, designated uses are attained

and none are threatened. Attainment status of the remaining designated uses is unknown because data are 

insufficient to categorize water consistent with the State's listing methodology.

18 This category constitutes the Section 303(d) list that EPA will approve or disapprove under the CWA. Waters 

should be placed in Category 5 when it is determined, in accordance with the State's assessment and listing 

methodology, that a pollutant has caused, is suspected of causing, or is projected to cause an impairment or threat. If 

that impairment or threat is due to a pollutant, the water should be placed in Category 5 and the pollutant causing

the impairment identified. A water is considered impaired when one or more designated uses are not attained. 

19 Waters should only be placed in Category 4A when all TMDLs needed to result in attainment of all applicable

WQSs have been approved or established by EPA. Once the TMDLs have been approved or established, the State

should implement the TMDL as soon as practicable. Additionally, EPA encourages States to provide monitoring 

schedules for these waters to ensure that sufficient data are obtained to document progress of the implementation 

actions toward the attainment of WQSs, and that progress is reasonably consistent with the projected time of 

attainment included in the TMDL. 

20 Total Maximum Daily Load

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Pollutant concentrations in the proposed discharge exceed water quality criteria with technology-based

controls which the Department has determined to be AKART. A mixing zone was previously authorized 

by the Department. The mixing zone was authorized in accordance with the geometric configuration, 

flow restriction, and other restrictions for mixing zones in Chapter 173-201A WAC and are defined as 

follows: 

The acute mixing zone will be to a maximum of 9.7 meters downstream of the diffuser. The chronic 

mixing zone will be a maximum of 97 meters downstream and 30 meters upstream 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 the EPA computer program PLUMES. The dilution factors have been 

determined to be (Raytheon, 1996) and a listed in Table 21. 

Table 21: Dilution factors 

Acute Chronic 

Aquatic Life 46 150

Human Health N/A 150

Human Health; 

inorganic arsenic N/A 1

The dilution factors were reviewed and approved by the Department before construction of facility was 

finished. The Department recognizes that revaluation of the factors is necessary and therefore the mixing

zone study is required by the permit. 

Pollutants in an effluent may affect the aquatic environment near the point of discharge (near field) or at a 

considerable distance from the point of discharge (far field). Toxic pollutants, for example, are near-field

pollutants--their adverse effects diminish rapidly with mixing in the receiving water. Conversely, a 

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

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

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

The derivation of surface water quality-based limits also takes into account the variability of the pollutant 

concentrations in both the effluent and the receiving water. 

The critical condition for the Columbia River in the vicinity of the discharge is the seven-day average low

river flow with a recurrence interval of ten years (7Q10). The receiving stream ambient data used for this 

permit includes the following from USGS data: 

Table 22: Ambient Data. 

Parameter Value used 

7Q10 low flow 2,300 m3

/s 

Velocity 0.3 m/s and 0.1 m/s for acute and chronic respectively

Depth 12.2 m

Width 732 m 

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Parameter Value used 

Temperature 22°C 

pH (high) 7.9 

Total Ammonia-N 0.10 mg/L 

Hardness 46 mg/L as CaCO3 

Arsenic (Total) 1.0 μg/L 

Copper 2.0 μg /L 

Iron 46 μg/L 

Zinc 2.0 μg /L 

All Other Metals 0.0 (below detection limits) 

The impacts of temperature, pH, ammonia, metals, and other toxics were determined as described below,

using the dilution factors at critical conditions described above. 

BOD21--This discharge with technology-based limitations results in a small amount of BOD loading 

relative to the large amount of dilution occurring in the receiving water at critical conditions. Technologybased limitations will be protective of dissolved oxygen criteria in the receiving water. 

Temperature and pH--The impact of pH and temperature were modeled using the calculations from EPA, 

1988. The input variables were dilution factor (chronic) of 150, upstream temperature 22.5°C, upstream 

pH 8.03, upstream alkalinity 46 (as mg CaCO3/L), effluent temperature 35°C, effluent pH of 6, effluent 

pH of 9, and effluent alkalinity 10 (as mg CaCO3/L). 

Under critical conditions there is no predicted violation of the Water Quality Standards for Surface 

Waters. Therefore, the technology-based effluent limitations for temperature and pH are placed in the 

permit. 

Turbidity-- Due to the large degree of dilution, it was anticipated that the turbidity criteria would not be

violated outside the designated mixing zone. 

Toxic Pollutants--Federal regulations (40 CFR 122.44) require NPDES permits to contain effluent limits 

for toxic chemicals in an effluent whenever there is a reasonable potential for those chemicals to exceed

the surface water quality criteria. The process of evaluating reasonable potential occurs concurrently with

the derivation of technology-based effluent limits. 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. 

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 

 

21 Biochemical oxygen demand

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(EPA/505/2-90-001) and the Department's Permit Writer's Manual (Ecology Publication 92-109, July,

1994). 

The determination of the reasonable potential for parameters listed in Table 23 and Table 24to exceed the

water quality criteria was evaluated (see Appendix C) at the critical condition. The critical condition in 

this case occurs during the periods of low flow in the summer. The parameters used in the critical

condition modeling are as follows: acute dilution factor of 46, chronic dilution factor of 150 and 1 for 

inorganic arsenic, and background concentration of pollutants listed in (aquatic life) and 

 (human health). 

Table 23 Table

24

Table 23: Background concentration of pollutants used in the critical condition modeling (aquatic life) 

Ambient 

Concentration22

Parameter 

μg/L23

Aluminum, total recoverable 024

Ammonia, unionized 3.07E+01 

Arsenic, dissolved 1.53E+00 

Hexavalent chromium, dissolved 025

Trivalent chromium, dissolved 026

Copper, dissolved 1.29E+00 

Cyanide 027

Iron, dissolved 8.00E+0128

Lead, dissolved 7.06E-02 

Mercury, dissolved 029

Nickel, dissolved 8.42E-01 

Silver, dissolved 030

Zinc, dissolved 2.76E+00 

 

22 Calculated as a geometric mean of all detected values multiplied by 1.74 to estimate the 90th percentile for 1-20 data

points. 

23 Micrograms per liter 

24 No valid ambient background data was available.

25 No valid ambient background data was available.

26 No valid ambient background data was available.

27 No valid ambient background data was available.

28 Background data obtained from the previous fact sheet with assumption that it represented dissolved iron. 

29 Not detected 

30 Not detected 

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Ambient 

Concentration22

Parameter 

μg/L23

Hardness 4.10E+04 

Table 24: Background concentration of pollutants used in the critical condition modeling (human health) 

Ambient 

Concentration31

Parameter 

μg/L32

Arsenic, inorganic 033

Bis(2 chloroisopropyl)ether 034

Cyanide 035

Iron, total recoverable 036

Mercury, total recoverable 037

Nickel, total recoverable 1.15E+00 

Tetrachloroethylene 038

A determination of reasonable potential resulted in no reasonable potential for all parameters listed in

Table 23 and Table 24 except inorganic arsenic. Since the reasonable potential determination indicated 

that the discharge has no reasonable potential to cause a violation of water quality standards, thus water 

quality-based effluent limitations are not warranted. 

The Permittee is required in section 9 of the proposed permit to collect background concentrations near

the point of discharge for all parameters limited in the permit plus ammonia. This information may result

in a permit modification or modification of the permit limitations in the next renewal. 

Water quality criteria for metals in Chapter 173-201A WAC are based on the dissolved fraction of the

metal. 

The Permittee may provide data clearly demonstrating the seasonal partitioning of the dissolved metal in 

the ambient water in relation to an effluent discharge. Metals criteria may be adjusted on a site-specific

 

31 Calculated as a geometric mean of all detected values multiplied by 1.74 to estimate the 90th percentile for 1-20 data

points. 

32 Micrograms per liter 

33 No valid ambient background data was available.

34 No valid ambient background data was available.

35 No valid ambient background data was available.

36 No valid ambient background data was available.

37 Not detected 

38 No valid ambient background data was available.

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basis when data is available clearly demonstrating the seasonal partitioning in the ambient water in

relation to an effluent discharge. 

Metals criteria may also be adjusted using the water effects ratio approach established by USEPA, as 

generally guided by the procedures in USEPA Water Quality Standards Handbook, December 1983, as 

supplemented or replaced. 

Water quality limits were calculated (see Appendix C) for comparison purposes for parameters listed in

Table 25. 

Table 25: Surface water quality-based effluent limitations 

Aquatic life Human 

health 

Aquatic 

life 

Human 

health 

Average Monthly Limit 

(AML) 

Maximum Daily Limit 

(MDL) 

PARAMETER 

Micrograms per liter (μg/L) 

Arsenic, total recoverable 8,220 16,491

Hexavalent chromium, total 

recoverable 350 703

Copper, total recoverable 140 281

Cyanide 504 105,000 1012 286,239

Iron, total recoverable 113,055 45,000 226,810 122,674

Lead, total recoverable 230 461

Mercury, total recoverable 2.0 21 3.0 52

Nickel, total recoverable 9,005 91,328 18,066 158,227

Silver, total recoverable 28 40

Zinc, total recoverable 1,176 2,359

Tetrachloroethylene 120 327

Aluminum, total recoverable 17,197 34,500

Ammonia, unionized 83,496 167,508

Arsenic, inorganic 0.018 0.018

Bis(2 chloroisopropyl)ether 210,000 306,351

Trivalent chromium, total recoverable 19,184 38,486

The following parameters are not evaluated beyond this point: 

1. Mercury, total recoverable 

2. Silver, total recoverable 

3. Aluminum, total recoverable 

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4. Ammonia, unionized 

5. Arsenic, total recoverable 

6. Bis(2 chloroisopropyl)ether

7. Trivalent chromium, total recoverable 

In 1992 the USEPA adopted risk-based arsenic criteria for the protection of human health for the state of

Washington. The criterion for marine waters is 0.14 μg/L inorganic arsenic, and is based on exposure

from fish and shellfish tissue ingestion. The freshwater criterion is 0.018 μg/L, and is based on exposure

from fish and shellfish tissue and water ingestion. These criteria have caused confusion in 

implementation because they differ from the drinking water maximum contaminant level (MCL) of 50

μg/L, which is not risk-based, and because the human health criteria are sometimes exceeded by natural 

background concentrations of arsenic in surface water and ground water. 

In Washington, when a natural background concentration exceeds the criterion, the natural background 

concentration becomes the criterion, and no dilution zone is allowed. This could result in a situation 

where natural groundwater or surface water used as a municipal or industrial source-water would need 

additional treatment to meet numeric effluent limits even though no arsenic was added as waste. 

Although this is not the case for all dischargers, we do not have data at this time to quantify the extent of

the problem. 

A regulatory mechanism to deal with the issues associated with natural background concentrations of 

arsenic in groundwater-derived drinking waters is currently lacking. Consequently, the Water Quality

Program, at this time, has decided to use a three-pronged strategy to address the issues associated with the 

arsenic criteria. The three strategy elements are: 

1. Pursue, at the national level, a solution to the regulatory issue of groundwater sources with high

arsenic concentrations causing municipal treatment plant effluent to exceed criteria. The

upcoming revision of the MCL for arsenic offers a national opportunity to discuss how drinking water 

sources can affect NPDES wastewater dischargers. This discussion should focus on developing a

national policy for arsenic regulation that acknowledges the risks and costs associated with

management of the public exposure to natural background concentrations of arsenic through water 

sources. 

2. Additional and more focused data collection. The Water Quality Program will in some cases 

require additional and more focused arsenic data collection, will encourage or require dischargers to 

test for source water arsenic concentrations, and will pursue development of a proposal to have the 

Department's Environmental Assessment Program conduct drinking water source monitoring as well 

as some additional ambient monitoring data. At this time, Washington NPDES permits will contain 

numeric effluent limits for arsenic based only on treatment technology and aquatic life protection as 

appropriate. 

3. Data sharing. The Department will share data with USEPA as they work to develop new risk-based

criteria for arsenic and as they develop a strategy to regulate arsenic. 

This permit sets performance based limits for inorganic arsenic. 

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WHOLE EFFLUENT TOXICITY

The Water Quality Standards for Surface Waters require that the effluent not cause toxic effects in the

receiving waters. Many toxic pollutants cannot be detected by commonly available detection methods. 

However, toxicity can be measured directly by exposing living organisms to the wastewater in laboratory 

tests and measuring the response of the organisms. Toxicity tests measure the aggregate toxicity of the

whole effluent, and therefore this approach is called whole effluent toxicity (WET) testing. Some WET 

tests measure acute toxicity and other WET tests measure chronic toxicity. 

Acute toxicity tests measure mortality as the significant response to the toxicity of the effluent. 

Dischargers who monitor their wastewater with acute toxicity tests are providing an indication of the 

potential lethal effect of the effluent to organisms in the receiving environment. 

Chronic toxicity tests measure various sub lethal toxic responses such as retarded growth or reduced 

reproduction. Chronic toxicity tests often involve either a complete life cycle test of an organism with an 

extremely short life cycle or a partial life cycle test on a critical stage of one of a test organism's life 

cycles. Organism survival is also measured in some chronic toxicity tests. 

Accredited WET testing laboratories have the proper WET testing protocols, data requirements, and

reporting format. Accredited laboratories are knowledgeable about WET testing and capable of 

calculating an NOEC, LC50, EC50, IC25, etc. All accredited labs have been provided the most recent 

version of the Department of Ecology Publication # WQ-R-95-80, Laboratory Guidance and Whole 

Effluent Toxicity Test Review Criteria which is referenced in the permit. Any Permittee interested in

receiving a copy of this publication may call the Department Publications Distribution Center (360)

407-7472 for a copy. The Department recommends that Permittees send a copy of the acute or chronic 

toxicity sections(s) of their permits to their laboratory of choice. 

An effluent characterization for acute and chronic toxicity was conducted during the previous permit term 

(Appendix C). In accordance with WAC 173-205-060, the Permittee must repeat chronic effluent 

characterization for the following reason: 

Chronic WET testing in February 200239 was not conducted on samples handled as required in WAC 173-

205-080. The results of this WET testing cannot be used to characterize effluent toxicity or make the 

regulatory determination required in Chapter 173-205 WAC. Therefore, the Permittee is required to 

conduct another effluent characterization for chronic whole effluent toxicity. 

Acute toxicity was measured during effluent characterization in the previous permit term (Appendix C). 

Acute toxicity was found to be at levels that, in accordance with WAC 173-205-050(2)(a), have a 

reasonable potential to cause receiving water toxicity. An acute toxicity limit is therefore required. The 

acute toxicity limit is no statistically significant difference in test organism survival between the acute

critical effluent concentration (ACEC), 2.2 percent of the effluent, and the control. 

The acute toxicity limit is set relative to the zone of acute criteria exceedance (acute mixing zone) 

established in accordance with WAC 173-201A-100. The acute critical effluent concentration (ACEC) is 

the concentration of effluent existing at the boundary of the acute mixing zone during critical conditions. 

 

39 Steelscape might have had chronic toxicity at 2.2% effluent in February 2002, but the ACEC 

was not included in the test. The NOEC was 1.6% effluent in this test and the LOEC was 3.7% 

effluent. It is impossible to know if 2.2% effluent would have been toxic when 3.7% was toxic 

and 1.6% wasn't toxic. 

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Monitoring for compliance with an acute toxicity limit is accomplished by conducting an acute toxicity

test using a sample of effluent diluted to equal the ACEC, 2.2 percent of the effluent, and comparing test 

organism survival in the ACEC to survival in nontoxic control water. The Permittee is in compliance

with the acute toxicity limit if there is no statistically significant difference in test organism survival 

between the ACEC and the control. 

Steelscape was ranked #4 (Washington State Department of Ecology, 1994). The ranking requires the 

Permittee to characterize effluent for acute toxicity quarterly and for chronic toxicity semiannually 

(Appendix C). Monitoring shall be conducted using each of the species listed below on a rotating basis: 

• One fish 

• One invertebrate 

HUMAN HEALTH

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 (Federal Register, Volume 57, No. 246, Tuesday, December 22, 1992). 

The Department has determined that the effluent is likely to have chemicals of concern for human health. 

The chemicals of concern for human health are listed in Table 24. The discharger's high priority status is 

based on the following: 

1. The discharger’s status as a major discharger, 

2. Knowledge of data or process information indicating regulated chemicals occur in the discharge, 

and 

3. The applicant discharges to a waterbody that is 303(d) listed for a regulated chemical, and that 

chemical is known or expected to be in the effluent. 

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 potential to cause a violation of

water quality standards, thus effluent limitations based on human health health-based criteria are not

warranted. However, the limitations were calculated for comparison purposes and they are listed in 

. None of them became the permit limitation. 

Table 

25

SEDIMENT QUALITY

The Department has promulgated aquatic sediment standards (Chapter 173-204 WAC) to protect aquatic 

biota and human health. These standards state that the Department may require Permittees to evaluate the 

potential for the discharge to cause a violation of applicable standards (WAC 173-204-400). 

The Department has determined, for the previous permit, through a review of the discharger 

characteristics and effluent characteristics that this discharge has no reasonable potential to violate the

Sediment Management Standards. 

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GROUND WATER QUALITY LIMITATIONS 

The Department has promulgated Ground Water Quality 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 violations of those standards (WAC 173-200-100). 

Steelscape applied to discharge an average of 29,000 gallons per day (gpd) of wastewater as a dust 

suppressant over 24 acres of their site. Currently Steelscape applies City of Kalama water as a dust

suppressant. 

The Department believes the discharge of wastewater as a dust suppressant has the potential to cause a

violation of the Ground Water Quality Standards and therefore the Department imposes the following 

conditions in the proposed permit: 

1. Steelscape may discharge wastewater at an average of 1500 gpd as a dust suppressant from June

through September as long as the total discharge does not exceed 183,000 gallons for an 

application season. Steelscape would not be subject to the requirements of the ground water

quality standards but the following conditions should apply:

a. the volume of the discharge should be measured, recorded and reported 

b. the discharge should be applied uniformly over 24 acres 

c. chloride and TDS concentrations in the wastewater should be determined monthly during

times of discharge 

2. If Steelscape wants to discharge wastewater to ground at higher rates than 1500 gpd or greater 

than 183,000 gallons per year, they will need to provide site-specific hydrogeologic information 

that demonstrates that the discharge will be in compliance with the Washington State’s ground 

water quality standards (Chapter 173-200 WAC). 

Bases for the above conditions is explained in details in Appendix E.

COMPARISON OF EFFLUENT LIMITS WITH THE EXISTING PERMIT ISSUED SEPTEMBER 14, 1998 

Table 26: Comparison of effluent limits with the existing permit 

Existing Limits Proposed Limits 

Average 

Monthly 

Limit 

(AML) 

Maximum 

Daily 

Limit 

(MDL) 

PARAMETER 

kg/day41

Units40

Average 

Monthly 

Limit 

(AML) 

Maximum 

Daily 

Limit 

(MDL) 

Limit Origin 

Flow, millions of 

gallons per day 

(mgd) 

---- 0.18 mgd N/A 0.18 Existing from the 

engineering report 

 

40 Units in this column are for values in two columns to the right from the units column. 

41 In kilograms per day unless otherwise defined in the parameter column.

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Existing Limits Proposed Limits 

Average 

Monthly 

Limit 

(AML) 

Maximum 

Daily 

Limit 

(MDL) 

PARAMETER 

kg/day41

Units40

Average 

Monthly 

Limit 

(AML) 

Maximum 

Daily 

Limit 

(MDL) 

Limit Origin 

pH, S.U.42 Between 6.0 and 9.0 S.U. Within the range of 

6.0 to 9.0 Existing, 40 CFR 

Total suspended 

solids (TSS) 11 23 kg/day 11 23 Existing, 40 CFR 

Oil and grease 

(O&G) 4.6 11 kg/day 4.6 11 Existing, 40 CFR 

Temperature, oC43 ---- 35 oC N/A 35 Existing, water 

quality-based 

Arsenic, total 

recoverable N/A N/A μg/L 2.4 4.8 New, performancebased 

Chromium, total 

recoverable 0.024 0.060 kg/day 0.019 0.047 Changed, 40 CFR 

Hexavalent 

chromium, total 

recoverable 

N/A N/A kg/day 0.0090 0.027 New, 40 CFR 

Copper, total 

recoverable 0.034 0.072 kg/day 0.031 0.065 Changed, 40 CFR 

Cyanide 0.013 0.032 kg/day 0.004 0.010 Changed, 40 CFR 

Iron, total 

recoverable 0.10 0.20 kg/day 0.03 0.06 Changed, 40 CFR 

Lead, total 

recoverable 0.045 0.14 kg/day 0.045 0.14 Existing, 40 CFR 

Mercury, total 

recoverable 0.0010 0.0020 μg/L None None Removed, no 

reasonable potential 

Nickel, total 

recoverable N/A N/A kg/day 0.0082 0.025 New, 40 CFR 

Silver, total 

recoverable 0.014 0.029 μg/L None None Removed, no 

reasonable potential 

Zinc, total 

recoverable 0.13 0.34 kg/day 0.13 0.34 Existing, 40 CFR 

Naphthalene ---- 0.0022 kg/day N/A 0.0022 Existing, 40 CFR 

 

42 Standard units

43 Degree Celsius 

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Existing Limits Proposed Limits 

Average 

Monthly 

Limit 

(AML) 

Maximum 

Daily 

Limit 

(MDL) 

PARAMETER 

kg/day41

Units40

Average 

Monthly 

Limit 

(AML) 

Maximum 

Daily 

Limit 

(MDL) 

Limit Origin 

Tetrachloroethylene ---- 0.0031 kg/day N/A 0.0031 Existing, 40 CFR 

MONITORING REQUIREMENTS 

Monitoring, recording, and reporting are required (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.1. Specified monitoring 

frequencies take into account the quantity and variability of the discharge, the treatment method, past 

compliance, significance of pollutants, and cost of monitoring. The monitoring frequencies of parameters 

required to be monitored by the existing permit are retained in this permit. 

EFFLUENT LIMITS BELOW QUANTITATION 

The Quantitation Level (QL) is the level at which concentrations can be reliably reported with a specified

level of error. For maximum daily effluent limits, if the measured effluent concentration is below the QL, 

the Permittee reports NQ for non-quantifiable in addition to the QL numerical value. For average 

monthly effluent limits, all effluent concentrations below the Quantitation Level but above the Method

Detection Level are used as reported for calculating the average monthly value. 

EFFLUENT LIMITS BELOW DETECTION 

The Method Detection Level (MDL) is the minimum concentration of an analyte that can be measured

and reported with a 99 percent confidence that it's concentration is greater than zero as determined by a 

specific laboratory method. For maximum daily limits, if the concentrations are below the MDL the 

Permittee reports ND for non-detectable in addition to the MDL numerical value. For average monthly 

limits, all values above the MDL are used as reported and all values below the MDL are calculated as 

zero. 

LAB 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. 

OTHER PERMIT CONDITIONS 

REPORTING AND RECORDKEEPING 

The conditions of S2 are based on the authority to specify any appropriate reporting and recordkeeping 

requirements to prevent and control waste discharges (WAC 173-220-210). 

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NON-ROUTINE AND UNANTICIPATED DISCHARGES 

Occasionally, this facility may generate wastewater which is not characterized in their permit application 

because it is not a routine discharge and was not anticipated at the time of application. These typically are 

waters used to pressure test storage tanks or fire water systems or leaks from drinking water systems.

These are typically clean waste waters but may be contaminated with pollutants. The permit contains an 

authorization for non-routine and unanticipated discharges. The permit requires a characterization of 

these waste waters for pollutants and examination of the opportunities for reuse. Depending on the nature 

and extent of pollutants in this wastewater and opportunities for reuse, the Department may authorize a 

direct discharge via the process wastewater outfall or through a stormwater outfall for clean water, require

the wastewater to be placed through the facilities wastewater 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 Department has the authority to require the Permittee 

to develop best management plans to prevent this accidental release under section 402(a)(1) of the Federal

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 review and 

update the Spill Plan, as needed, at least annually. Changes to the plan shall be sent 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. 

This proposed permit requires, under the authority of RCW 90.48.080, that the Permittee update, if

necessary, the solid waste plan designed to prevent solid waste from causing pollution of the waters of the

state. The plan must be submitted to the local permitting agency for approval, if necessary, and to the 

Department. 

EFFLUENT MIXING STUDY

The Department has estimated the amount of mixing of the discharge within the authorized mixing zone 

to determine the potential for violations of the Water Quality Standards for Surface Waters (Chapter 173-

201A WAC). Condition S7 of this permit requires the Permittee to more accurately determine the mixing 

characteristics of the discharge. Mixing will be measured or modeled under conditions specified in the 

permit to assess whether assumptions made about dilution will protect the receiving water quality outside 

the allotted dilution zone boundary. 

OUTFALL EVALUATION 

Proposed permit Condition S11 requires the Permittee to conduct 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. 

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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). 

An operation and maintenance manual is required by state regulation for the construction of wastewater 

treatment facilities (WAC 173-240-150). 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. 

GENERAL CONDITIONS 

General Conditions are based directly on state and 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 impose 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 information obtained from sources such as inspections, effluent

monitoring, outfall studies, and effluent mixing studies. 

The Department may also modify this permit as a result of new or amended state or federal regulations. 

RECOMMENDATION FOR PERMIT ISSUANCE

This proposed permit meets all statutory requirements for authorizing a wastewater discharge, including

those limitations and conditions believed necessary to control toxics, protect human health, aquatic life, 

and the beneficial uses of waters of the state of Washington. The Department proposes that this proposed 

permit be issued according to the Columbia Gorge Basin (Basin 5) schedule with expiration day of

June 30, 2008. 

REFERENCES 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 Water Quality-based Toxics Control. EPA/505/2-90-001. 

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

USEPA Office of Water, Washington, D.C. 

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

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

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

2/24/2005 Page 43 
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Steelscape, Inc. 

Raytheon Engineers and Constructors, Philadelphia, Pennsylvania 

1996. Engineering Report for Industrial Wastewater Treatment Facility. Prepared for BHP Coated 

Steel Corporation, Kalama, Washington; approved by the Department on April 19, 1996; updated 

by Steelscape on December 2001 and August 2004 

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 

Washington State Department of Ecology.

Laws and Regulations( http://www.ecy.wa.gov/laws-rules/index.html ) 

Permit and Wastewater Related Information 

(http://www.ecy.wa.gov/programs/wq/wastewater/index.html 

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.) 

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APPENDIX A--PUBLIC INVOLVEMENT INFORMATION 

The Department has tentatively determined to reissue a permit to the applicant listed on page 1 of this fact

sheet. The permit contains conditions and effluent limitations which are described in the rest of this fact 

sheet. 

Public notice of application was published on May 15, 2004, and May 23, 2004, in The Daily News to 

inform the public that an application had been submitted and to invite comment on the reissuance of this

permit. 

The Department will publish a Public Notice of Draft (PNOD) on __________ ,in The Daily News to

inform the public that a draft permit and fact sheet are available for review. Interested persons are invited 

to submit written comments regarding the draft permit. The draft permit, fact sheet, and related

documents are available for inspection and copying between the hours of 8:00 a.m. and 5:00 p.m. 

weekdays, by appointment, at the regional office listed below. Written comments should be mailed to: 

Industrial Unit Permit Coordinator 

Department of Ecology 

Southwest Region - Water Quality 

P.O. Box 47775 

Olympia, WA 98504-7775

Any interested party may comment on the draft permit or request a public hearing on this draft permit 

within the 30-day comment period to the address above. The request for a hearing shall indicate the 

interest of the party and reasons why the hearing is warranted. The Department will hold a hearing if it

determines there is a significant public interest in the draft permit (WAC 173-220-090). Public notice

regarding any hearing will be circulated at least 30 days in advance of the hearing. People expressing an 

interest in this permit will be mailed an individual notice of hearing (WAC 173-220-100). 

Comments should reference specific text followed by proposed modification or concern when possible.

Comments may address technical issues, accuracy and completeness of information, the scope of the

facility’s proposed coverage, adequacy of environmental protection, permit conditions, or any other 

concern that would result from issuance of this permit. 

The Department will consider all comments received within 30 days from the date of public notice of 

draft indicated above, in formulating a final determination to issue, revise, or deny the permit. The 

Department's response to all significant comments is available upon request and will be mailed directly to 

people expressing an interest in this permit. 

Further information may be obtained from the Department by telephone, (360) 407-6280, or by writing to

the address listed above. 

This permit and fact sheet were written by Jacek Anuszewski, P.E. 

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APPENDIX B--GLOSSARY 

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

usually 48 to 96 hours. 

AKART-- An acronym for “all known, available, and reasonable methods of treatment”. 

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

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

is toxic to aquatic organisms, exerts an oxygen demand, and contributes to eutrophication. It also

increases the amount of chlorine needed to disinfect wastewater. 

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, structural and/or managerial practices to prevent or reduce the

pollution of waters of the State. BMPs include treatment systems, operating procedures, and practices 

to control: plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material 

storage. BMPs may be further categorized as operational, source control, erosion and sediment

control, and treatment BMPs. 

BOD5--Determining the Biochemical Oxygen Demand of an effluent is an indirect way of measuring the 

quantity of organic material present in an effluent that is utilized by bacteria. The BOD5 is used in 

modeling to measure the reduction of dissolved oxygen in a receiving water after effluent is 

discharged. Stress caused by reduced dissolved oxygen levels makes organisms less competitive and 

less able to sustain their species in the aquatic environment. Although BOD is not a specific 

compound, it is defined as a conventional pollutant under the federal Clean Water Act. 

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

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 organism over a relatively long time, often 1/10 of an

organism's lifespan or more. Chronic toxicity can measure survival, reproduction or growth rates, or 

other parameters to measure the toxic effects of a compound or combination of compounds. 

Clean Water Act (CWA)--The Federal Water Pollution Control Act enacted by Public Law 92-500, as

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

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

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

Compliance Inspection - With Sampling--A site visit 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 ascertain compliance with those limits; and, for municipal facilities, sampling 

of influent to ascertain compliance with the 85 percent removal requirement. Additional sampling

may be conducted. 

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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 proportional to stream flow, or collected by increasing the volume of 

each aliquot as the flow increased while maintaining a constant time interval between the aliquots. 

Construction Activity--Clearing, grading, excavation and any other activity which disturbs the surface of

the land. Such activities may include road building, construction of residential houses, office

buildings, or industrial buildings, and demolition activity. 

Continuous Monitoring –Uninterrupted, unless otherwise noted in the permit.

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

conditions have the highest potential for causing toxicity in the receiving water environment. This

situation usually occurs when the flow within a water body is low, thus, its ability to dilute effluent is 

reduced. 

Dilution Factor--A measure of the amount of mixing of effluent and receiving water that occurs at the

boundary of the mixing zone. Expressed as the inverse of the percent effluent fraction e.g., a dilution 

factor of 10 means the effluent comprises 10% by volume and the receiving water 90%. 

Engineering Report--A document which thoroughly examines the engineering and administrative 

aspects of a particular domestic or industrial wastewater facility. The report shall contain the 

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

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

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

disinfecting the wastewater. The presence 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 development of any natural resource, or from animal

operations such as feed lots, poultry houses, or dairies. The term includes contaminated storm water

and, also, leachate from solid waste facilities. 

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

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

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

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

of sampling. The daily discharge is calculated as the average measurement of the pollutant over the

day. 

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. 

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Minor Facility--A facility discharging to surface water with an EPA rating score of < 80 points based on 

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

Mixing Zone--An area that surrounds an effluent discharge within which water quality criteria may be 

exceeded. The area of the authorized mixing zone is specified in a facility's permit and follows 

procedures outlined in state regulations (Chapter 173-201A WAC). 

National Pollutant Discharge Elimination System (NPDES)--The NPDES (Section 402 of the Clean

Water Act) is the Federal wastewater permitting system for discharges to navigable waters of the 

United States. Many states, including the State of Washington, have been delegated the authority to

issue these permits. NPDES permits issued by Washington State permit writers are joint 

NPDES/State permits issued under both State and Federal laws. 

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 are 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, treasurer, or vice-president of the corporation in 

charge of a principal business function, or any other person who performs similar policy- or decisionmaking functions for the corporation, or the manager of one or more manufacturing, production, or

operating facilities employing more than 250 persons or have gross annual sales or expenditures 

exceeding $25 million (in second quarter 1980 dollars), if authority to sign documents has been

assigned or delegated to the manager in accordance with corporate procedures (40 CFR 122.22). 

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 material in an effluent. Large 

quantities of TSS discharged to a receiving water may result in solids accumulation. Apart from any

toxic effects attributable to substances leached out by water, suspended solids may kill fish, shellfish, 

and other aquatic organisms by causing abrasive injuries and by clogging the gills and respiratory

passages of various aquatic fauna. Indirectly, suspended solids can screen out light and can promote

and maintain the development of noxious conditions through oxygen depletion. 

State Waters--Lakes, rivers, ponds, streams, inland waters, underground waters, salt waters, and all other 

surface waters and watercourses within the jurisdiction of the state of Washington. 

Stormwater--That portion of precipitation that does not naturally percolate into the ground or evaporate,

but flows via overland flow, interflow, pipes, and other features of a storm water drainage system into

a defined surface water body, or a constructed infiltration facility.

Upset--An exceptional incident in which there is unintentional and temporary noncompliance with

technology-based permit effluent limitations because of factors beyond the reasonable control of the 

Permittee. An upset does not include noncompliance to the extent caused by operational error,

improperly designed treatment facilities, lack of preventative maintenance, or careless or improper 

operation. 

Water Quality-based Effluent Limit--A limit on the concentration of an effluent parameter that is 

intended to prevent the concentration of that parameter from exceeding its water quality criterion after 

it is discharged into a receiving water. 

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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.ecy.wa.gov. 

All calculations of permit limits are in a spreadsheet named application data.xls. The spreadsheet is

available upon request from: 

Industrial Unit Permit Coordinator 

Department of Ecology 

Southwest Region - Water Quality 

P.O. Box 47775 

Olympia, WA 98504-7775

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APPENDIX D--RESPONSE TO COMMENTS 

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APPENDIX E-- TECHNICAL MEMORANDUM

 

WASHINGTON STATE DEPARTMENT OF ECOLOGY 

Water Quality Program

Southwest Regional Office 

Technical Memorandum

January 28, 2004 

To: Jacek Anuszewski, Permit Manager 

From: Denis Erickson, Hydrogeologist 

Subject: Steelscape Inc. Permit Application, NPDES Permit No. WA004085 - Request to Use 

Wastewater for Dust Suppressant 

At your request I reviewed the Steelscape permit application regarding their proposal to discharge an

average of 29,000 gallons per day (gpd) of wastewater as a dust suppressant over 24 acres of their site.

Currently Steelscape applies City of Kalama water as a dust suppressant. This memorandum is my

response to your request. 

Wastewater Quality 

Three analyses of the wastewater are included in the permit application. Based on these analyses the 

constituents of concern in the effluent are total dissolved solids (TDS) and chloride. The average 

concentrations and ground water quality standard criteria for the constituents of concern are listed in

Table 1. 

Table 1. Constituents of Concern, Concentrations and Criteria. 

 Effluent Effluent Effluent Ground Water 

 Sample 1 Sample 2 

Sample 

3 Average Quality

Sampling Date 11/3/98 8/8/00 8/14/01 Concentration Criteria

Parameter 

Chloride 980 1400 860 1080 250

Total Dissolved 

Solids 1900 2300 1448 1883 500

Note: Concentrations in mg/L. 

The average concentrations for chloride and TDS concentrations are 1080 mg/L and 1883 mg/L, 

respectively, however the samples show considerable variation, and there is some concern about the

representative ness of these average values. As you will see later in this memorandum I rely fairly

heavily on these average values to evaluate the potential for ground water contamination. 

The permit application does not describe the site hydrogeology or soil conditions at the facility and there 

is no evaluation of the potential effects of the discharge on ground water quality.

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To understand the site hydrogeologic conditions, at least in a general way, and to evaluate the

susceptibility of the site to ground water contamination I reviewed the following: 

• the soil survey for the Cowlitz survey 

• regional geologic reports for the area, and 

• well logs for wells in the site vicinity in Ecology Well Log Database (Ecology, 2003). 

These sources are readily available on the Department’s website and as GIS coverages. The site 

conditions are summarized below. 

 

Geology, Soils, and Hydrogeology 

The site is underlain by floodplain alluvial deposits of the Columbia River that consist of sand, gravel and

silt (Meyers, 1970 and Walsh, et al, 1987). The soils consist mostly of silt loam and silty clay loam (Call, 

1970). All soils are subject to seasonal high water tables of 1 to 3 feet below the ground surface. A well 

log for two resource protection wells drilled on the “BHP Steel” site to a depth of 20 feet showed 18 feet

of sand overlying two feet of silt. The water level was not recorded on the log. One generalized log for 

20 cone penetrometer tests at the “BHP” site encountered sand and silty sand to 90 feet with an organic 

silt and clay layer at a depth interval of 9 to 19 feet. The regional water table was logged at a depth of 13 

feet and water perched about the organic silt and clay layer at a depth of seven feet. Two wells near the 

facility were test wells drilled by the Port of Kalama to depths of 67 and 101.5 feet. The wells 

encountered sand and silty sand with occasional silt layers. Generally below a depth of 50 feet the 

material consisted of fine-medium and coarse sand. The water level in the 67-foot well was about 23 feet 

but was not recorded for the 101.5-foot well. 

Regional ground-water flow beneath the site is likely toward the Columbia River. The local flow pattern 

in the uppermost water-bearing zone will be influenced by discharge activities at the ground surface and 

infiltration variability and may be complex. Because of the flat-lying topography the hydraulic gradient is 

likely to be low. 

Estimated Effects on Ground Water Quality 

Based on hydrogeologic conditions at the site, the proposed discharge of wastewater will likely affect

ground water quality. To estimate this effect I used a water balance model combined with a simple mass

balance model. The water balance model estimates the amount of recharge to ground water. For this 

model, evapotranspiration was estimated using the method by Thornthwaite and Mather (1957) and

Palmer and Havens (1958) using normal monthly temperature data for the City of Kalama. The monthly

recharge was estimated using the method described by Fenn (1985). The amount of runoff from the site

was assumed to be negligible. The climatological data and estimated ground water recharge rate are 

summarized as follows: 

Annual Precipitation 56.344 inches 

Annual Evapotranspiration 25.9 inches 

Annual Estimated Recharge 30.4 inches 

The mass balance model is used to calculate an average ground water concentration for selected loading 

rates and site-specific aquifer conditions. The basic characteristics of this model are described in the 

 

44 45.7 inches 

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Appendix45 VIII in the Permit Writers Manual. I modified the model so that the water component of the

wastewater did not contribute to the concentration calculation. This is based on the assumption that the

water component of the wastewater being applied as a dust suppressant under dry conditions would be 

evaporated and not infiltrated. I also modified the model to account for seasonal applications. The 

original model assumed annual loading only.

Other model assumptions are listed as follows: 

• Wastewater is applied uniformly over 24 acres 

• Infiltrated water and ground water mix instantaneously

• Contaminants were not attenuated by sorption or losses from biodegradation or volatilization 

• Hydrodynamic dispersion and diffusion are disregarded. 

Assumed aquifer properties are listed as follows: 

• Hydraulic Conductivity 3 feet/day

• Hydraulic Gradient 0.0020 feet/feet 

• Aquifer and Depth of Mixing Thickness 20 feet 

• Porosity 0.30

• Site width perpendicular to ground-water flow 1600 feet 

• Background concentration for TDS 100 mg/L 

• Background concentration for chloride 10 mg/L 

In my opinion, these input values are fairly conservative for the site conditions. The estimated

concentrations for chloride and TDS for three discharge scenarios are shown in Table 2. 

Table 2. Estimated Chloride and TDS Concentrations for Three Discharge Scenarios. 

 Chloride 

Total Dissolved 

Solids 

 Estimated Estimated

 Number of Aquifer Aquifer 

 Discharge Discharge Concentration Concentration

Discharge Scenarios (gpd) Days (mg/L) (mg/L)

 Background (Assumed) ---- ---- 10 100 

1. Steelscape Permit Request 29000 365 562 1006 

2. Steelscape Summer Discharge 

Only 29000 122 188 336

3. Steelscape Summer Discharge 

Only 1500 122 10 20

From Table 2, an annual discharge of 29,000 gpd would exceed ground water quality criteria for both 

chloride and TDS (Scenario 1). The estimated average concentration in ground water is 562 mg/L for 

chloride and 1006 mg/L for TDS, over two times the ground water quality criteria. This discharge would 

violate the ground water quality standards (Chapter 173-200) and is not allowable. 

Ground Water Quality Standards 

 

45 Chapter 

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The goal of the ground water quality standards is to maintain a high quality of ground water and to protect

existing and future beneficial uses. This goal is achieved by three mechanisms: 

1. AKART- all known, available and reasonable methods of prevention, control and treatment 

2. An antidegradation policy which mandates the protection of background water quality and 

prevents degradation of ground water quality that would harm beneficial use. 

3. Numerical and narrative standards. 

Assuming that AKART has been achieved for the wastewater, the mechanism to establish enforcement

limits under the antidegradation policy is to determine background concentrations for the constituents of 

concern. This requires a ground water monitoring program. The process to define enforcement limits is

described in the Implementation Guidance for Ground Water Quality Standards (Ecology, 1996). 

Basically, we must know background concentrations before we can determine ground water limits. 

Additional Discharge Scenarios 

It seems unlikely that dust suppression would be needed at the facility on a year round basis as requested 

by the Steelscape. Most likely the discharge would only be needed during the summer. The estimated 

effects of discharging 29,000 gpd of wastewater from June through September, 122 days, are shown in 

scenario 2 in Table 2. Again the estimated concentrations in ground water for chloride (188 mg/L) and

TDS (336 mg/L) are much greater than assumed background levels. However, as shown in Scenario 3, if 

the discharge to ground is about 1500 gpd during June through September, the chloride concentration is 

equal to the assumed background level. Because chloride is the limiting water quality parameter, the TDS

concentration is reduced to below the background level. 

Conclusions

1. The Steelscape site is underlain by alluvial deposits consisting mostly of sand and silty sand with 

a shallow water table. The uppermost aquifer is susceptible to contamination from surface 

activities. 

2. The constituents of concern in the wastewater are chloride and TDS with average concentrations 

of 1080 mg/L and 1883 mg/L, respectively. These averages are based on three samples that show 

considerable variation and additional testing should be considered to provide a better estimate of 

the average. 

3. The proposed discharge of 29,000 gpd to ground as a dust suppressant would exceed the ground 

water quality criteria for chloride and TDS and is not allowable under the ground water quality

standards (Chapter 173-200 WAC). 

4. Steelscape may discharge wastewater an average of 1500 gpd as a dust suppressant from June 

through September as long as the total discharge does not exceed 183,000 gallons for an 

application season. Steelscape would not be subject to the requirements of the ground water

quality standards but the following conditions should apply:

• the volume of the discharge should be measured, recorded and reported 

• the discharge should be applied uniformly over 24 acres 

• chloride and TDS concentrations in the wastewater should be determined monthly during

times of discharge 

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Fact Sheet for NPDES Permit No. WA0040851 

Steelscape, Inc. 

2/24/2005 Page 55 

5. If Steelscape wants to discharge wastewater to ground at higher rates than 1500 gpd or greater 

than 183,000 gallons per year, they will need to provide site-specific hydrogeologic information 

that demonstrates that the discharge will be in compliance with the Washington State’s ground 

water quality standards (Chapter 173-200 WAC). 

References 

Call, W.A., 1974. Soil Survey of the Cowlitz Area, Washington. US Department of Agriculture Soil 

Conservation Service. 112p +maps 

Ecology, 1990. Water Quality Standards for Ground Waters of the State of Washington, Chapter 173-200 

WAC. 8p. 

Ecology, 1996. Implementation Guidance for the Ground Water Quality Standards, Ecology publication 

#96-02, http//www.ecy.wa.gov/pubs/96002.pdf. 

Ecology, 1999. Permit Writer's Manual, Appendix VIII, July 1999 

Ecology Well Log Home Page, 2003. November 19, 2003 

Fenn, D.G. et al., 1975. Use of the Water Balance Method for Predicting Leachate Generation from Solid 

Waste Disposal Sites. US EPA/530/SW-168. 40p. 

Myers, D.A., 1970. Availability of Ground Water in Western Cowlitz County, Washington. Washington 

Department of Ecology Water-Supply Bulletin No.35. 

63 p. 

Palmer, W.C. and A.V. Havens, 1958. A Graphical Technique for Determining Evapotranspiration by the 

Thornthwaite Method. Monthly Weather Review, pp. 123-128. 

Walsh, T.J., M.A. Korosec, W.M. Phillips, R.L. Logan, H.W. Schasse, 1987. Geologic Map of 

Washington -- Southwest Quadrant. Division of Geology and Earth Resources Geologic Map GM-34. 

Thornthwaite, C.W. and J.R. Mather, 1957. Instructions and Tables for Computing Potential 

Evapotranspiration and the Water Balance. Drexel Institute of Technology, Publications in Climatology, 

Volume X, Number 3.