STATE OF WASHINGTON 

DEPARTMENT OF ECOLOGY 

PO Box 47600 • Olympia, WA 98504-7600 • 360-407-6000 

711 for Washington Relay Service o Persons with a speech disability can call 877·833·6341 

January 12,2015 

Mr. Craig McKinney 

Cosmo Specialty Fibers, Inc. 

POBox 539 

Cosmopolis, WA 98537 

Re: Class II Wastewater Inspection on July 8-16, 2014 

Dear Mr. McKinney: 

Thank you for your assistance with the Class II Wastewater Inspection conducted at Cosmo 

Specialty Fibers, Inc. (Cosmo) on July 8 and 16, 2014. Depatiment of Ecology (Ecology) 

conducted this routine wastewater inspection to detetmine Cosmo's level of compliance with its 

NPDES permit No. W A 000080-9. Enclosed is a copy of the inspection repott for your files. 

The inspection consisted of a walk-through of Cosmo's wastewater treatment system, which 

includes the biological treatment ponds, clarifiers, Westpoti holding ponds, and discharge 

outfalls. Ecology reviewed Cosmo's in-house lab and operations & maintenance procedure for 

the fecal coliform treatment. Ecology and Cosmo also took wastewater samples at outfall 001 

and 002 for compliance verification. 

No violations were noted as a result of this inspection. If you have any questions, please contact 

me at (360) 407-6064 or ha.tran@ecy.wa.gov. 

~ Ha Tran 

Industrial Section 

Waste 2 Resources Program 

Enclosures 
United States Environmental Protection Agency Form Approved 

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

Water Compliance Inspection Report Approval Expires 10-31-95 

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

Transaction Code NPDES yr/mo/day 'ii Inspection Type Inspector FacType 

1L[ 21§1 31WIA10101010181019111 "1113IOI7111Ql17 1all2l 191§1 2oiZI 

Remarks 

2111!1NI81NINIQI1!1NIQI£1QLIQ11,181l21l2LI2LLLLLLLLLLLLLLLLI'' 

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

67111§1QI6s 7011 711!':!1 niNI 73I_L[74 "LLLLLLIJao 

Section B: Facility Data 

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

a/so include POTW name and NPDES permit number) 8 July, 2014 9AM 1 July, 2007 

Cosmo Specialty Fibers, Inc. 

1701 First Street Exit Time/Date Permit Expiration Date Cosmopolis, WA 98537 

16 July, 2014 1200 AM 30 June, 2012 

Environmental Engineers: Other Facility Data 

Craig McKinney, RCRA & Water Lead 

Arne Peterson, Air Lead 

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

Craig McKinney, Environmental Engineer 

(360) 500-4638 

cmckinney@cosmospecialtyfibers.com 

Contacted 

0Yes 0No 

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

Qgl Permit !8J.I Flow Measurement Qgl Operations & Maintenance 01 CSO/SSO (Sewer Overflow) 

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

Qgl Facility Site Review 01 Compliance Schedules 01 Pretreatment 01 Multimedia 

Qgl EffluenUReceiving Waters Qgl Laboratory Qgl Storm Water 01 Other: 

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

See attachment for detailed inspection report. 

The mill was operating in upset condition. No violation were noted as a result of this inspection. 

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

"""' Ha Tran i(1 ~ Vl / Ecology, Industrial Section 360-407-6064 1 01~-tJI II\ 

' v "' 

Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date 

.. EPA Form 3560-3 (Rev. 9-94) Prev1ous ed1t1ons are obsolete. 
Form Approved 

OMB No 158-R0073 

Sections F thru L: Complete on all inspections, as appropriate. N/A = Not Applicable I PERMIT NO. 

WAOOOOB0-9 

SECTION F - Facility and Permit Background 

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

(Including City, County and ZIP code) April 1, 2014 

FINDINGS 

No violations noted 

SECTION G -Records and Reports 

RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT. ~YES 0NO D N/A (Further explanation attached 

DETAILS: 

(a) ADEQUATE RECORDS MAINTAINED OF: 

(i) SAMPLING DATE, TIME, EXACT LOCATION ~YES D.NO ON/A 

(ii) ANALYSES DATES, TIMES ~YES 0NO ON/A 

(iii) INDIVIDUAL PERFORMING ANALYSIS ~YES ONO ON/A 

(iv) ANALYTICAL METHODS/TECHNIQUES USED ~YES 0NO ON/A 

(v) ANALYTICAL RESULTS (e.g., consistent with self-monitoring report data) ~YES 0NO 0 N/A 

(b) MONITORING RECORDS (e.g., flow, pH, D.O., etc.) MAINTAINED FORA MINIMUM OF THREE YEARS ~YES 0NO 0 N/A 

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

calibration and maintenance records). 

(c) LAB EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT. ~YES 0NO ON/A 

(d) FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT ~YES ONO ON/A 

UNIT. 

(e) QUALITY ASSURANCE RECORDS KEPT. ~YES 0NO ON/A 

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

USING PUBLICLY OWNED TREATMENT WORKS. 

SECTION H • Permit Verification 

INSPECTION OBSERVATIONS VERIFY THE PERMIT. ~YES ONO D N/A (Further explanation attached I 

DETAILS: 

(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE. ~YES ONO ON/A 

(b) FACILITY IS AS DESCRIBED IN PERMIT. ~YES ONO ON/A 

(c) PRINCIPAL PRODUCT($) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN ~YES ONO ON/A 

PERMIT APPLICATION. 

(d) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION. ~YES ONO ON/A 

(e) NOTIFICATION GIVEN TO EPNSTATE OF NEW, DIFFERENT OR INCREASED DISCHARGES. DYES ONO ~N/A 

(f) ACCURATE RECORDS OF RAW WATER VOLUME MAINTAINED. DYES 0NO ~ N/A 

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

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

(i) ALL DISCHARGES ARE PERMITTED. ~YES ONO 0 N/A 

SECTION I -Operation and Maintenance 

TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED. ~YES 0NO D N/A (Further explanation attached 

DETAILS: 

(a) STANDBY POWER OR OTHER EQUIVALENT PROVISIONS PROVIDED. ~YES 0NO ON/A 

(b) ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE. ~YES ONO ON/A 

(c) REPORTS ON ALTERNATIVES SOURCE OF POWER SENT TO EPNSTATE AS REQUIRED BY ~YES ONO ON/A 

PERMIT. 

(d) SLUDGES AND SOLIDS ADEQUATELY DISPOSED. ~YES ONO 0 N/A 

(e) ALL TREATMENT UNITS IN SERVICE. ·oYEs ~NO 0 N/A 

(f) CONSULTING ENGINEER RETAINED OR AVAILABLE FOR CONSULTATION ON OPERATION AND ~YES ONO 0 N/A 

MAINTENANCE PROBLEMS. 

(g) QUALIFIED OPERATING STAFF PROVIDED. ~YES 0NO 0 N/A 

(h) ESTABLISHED PROCEDURES AVAILABLE FOR TRAINING NEW OPERATORS. ~YES ONO ON/A 

(i) FILES MAINTAINED ON SPARE PARTS INVENTORY, MAJOR EQUIPMENT SPECIFICATIONS, AND ~YES ONO ON/A 

PARTS AND EQUIPMENT SUPPLIERS. 

0) INSTRUCTIONS FILES KEPT FOR OPERATION AND MAINTENANCE OF EACH ITEM OF MAJOR ~YES 0NO ON/A 

EQUIPMENT. 

(k) OPERATION AND MAINTENANCE MANUAL MAINTAINED. ~YES ONO 0 N/A 

(I) SPCC PLAN AVAILABLE. ~YES 0NO D N/A 

(m) REGULATORY AGENCY NOTIFIED OF BY PASSING. (Oates ) DYES 0NO ~ N/A 

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

(o) ANY HYDRAULIC AND/OR ORGANIC OVERLOADS EXPERIENCED. DYES ~NO 0 N/A 

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

OMB No. 158-R0073 

I PERMIT NO. 

WA0000809 

SECTION J • Compliance Schedules 

PERMITTEE IS MEETING COMPLIANCE SCHEDULE. DYES ONO ~ N/A (Further explanation attached 

CHECK APPROPRIATE PHASE(S): 

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

CONSTRUCTION. 

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

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

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

O(e) CONSTRUCTION HAS COMMENCED. 

D<Q CONSTRUCTION AND/OR EQUIPMENT ACQUISITION IS ON SCHEDULE. 

0(g) CONSTRUCTION HAS BEEN COMPLETED. 

0(h) START-UP HAS COMMENCED. 

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

SECTION K ·Self-Monitoring Program 

Part 1 -Flow measurement (Further exp/anaUon attached 

PERMITTEE FLOW MEASUREMENT MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. DYES ~NO 0 N/A 

DETAILS: 

(a) PRIMARY MEASURING DEVICE PROPERLY INSTALLED. DYES 0NO D N/A 

TYPE OF DEVICE: 0WEIR 0PARSHALL FLUME ~MAGMETER 0VENTURI METER 00THER: (Specify) 

(b) CALIBRATION FREQUENCY ADEQUATE. (Date of last calibration) DYES ~NO 0 N/A 

(c) PRIMARY FLOW MEASURING DEVICE PROPERLY OPERATED AND MAINTAINED. DYES ~NO 0 N/A 

(d) SECONDARY INSTRUMENTS (totalizers, recorders, etc.) PROPERLY OPERATED AND MAINTAINED. DYES ~NO D N/A 

(e) FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW ~YES ONO ON/A 

RATES. 

Part 2 ·Sampling (Further explanation attached 

PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. ~YES 0NO ON/A 

DETAILS: 

(a) LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES. ~YES 0NO ON/A 

(b) PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT. ~YES 0NO ON/A 

(c) PERMITTEE IS USING METHOD OF SAMPLE COLLECTION REQUIRED BY PERMIT. ~YES ONO ON/A 

IF NO, 0GRAB 0MANUAL COMPOSITE ~AUTOMATIC COMPOSITE FREQUENCY 

(d) SAMPLE COLLECTION PROCEDURES ARE ADEQUATE ~YES 0NO ON/A 

(i) SAMPLES REFRIGERATED DURING COMPOSITING ~YES 0NO ON/A 

(ii) PROPER PRESERVATION TECHNIQUES USED ~YES ONO ON/A 

(iii) FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED BY PERMIT DYES 0NO ~N/A 

(iv) SAMPLE HOLDING TIMES PRIOR TO ANALYSES IN CONFORMANCE WITH 40 CFR 136.3 ~YES 0NO ON/A 

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

PERMIT. 

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

Part 3 • Laboratory (Further explanation attached I 

PERMITTEE LABORATORY PROCEDURES MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. DYES 0NO ~ N/A 

DETAILS: 

(a) EPA APPROVED ANALYTICAL TESTING PROCEDURES USED. (40 CFR 136.6) ~YES 0NO 0 N/A 

(b) IF ALTERNATE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN DYES 0NO ~ N/A 

OBTAINED. 

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

(d) SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT. ~YES 0NO 0 N/A 

(e) QUALITY CONTROL PROCEDURES USED. ~YES 0NO 0 N/A 

(Q DUPLICATE SAMPLES ARE ANALYZED. - %OF TIME ~YES ONO 0 N/A 

(g) SPIKED SAMPLES ARE USED. - %OF TIME ~YES ONO 0 N/A 

(h) COMMERCIAL LABORATORY USED. ~YES 0NO D N/A 

(i) COMMERCIAL LABORATORY STATE CERTIFIED. ~YES 0NO 0 N/A 

LAB NAME ALS Laboratorv 

LAB ADDRESS 1317 S 13~ Avenue Kelso WA 98626 

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

OUTFALL NO. OIL SHEEN GREASE TURBIDITY VISIBLE FOAM VISIBLE 

FLOAT SOL 

OUTFALL 001 None None Significant None None 

OUTFALL 002 None None Little to none None None 

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

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

18] GRAB SAMPLES OBTAINED 

18] COMPOSITE OBTAINED 

D FLOW PROPORTIONED SAMPLE 

18] AUTOMATIC SAMPLER USED 

18] SAMPLE SPLIT WITH.PERMITIEE 

18] CHAIN OF CUSTODY EMPLOYED 

18] SAMPLE OBTAINED FROM FACILITY SAMPLING DEVICE 

COMPOSITING FREQUENCY PRESERVATION 

SAMPLE REFRIGERATED DURING COMPOSITING: 18]YES ONO 

SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE 

SECTION N -Analytical Results (Attach report if necessary) 

See attached report for summary 

EPA FORM 3560-3 (9-77) 

PERMIT NO. 

Form Approved 

OMB No. 158-R0073 

WA 003867-9 

COLOR OTHER 

Reddish 

brown 

PAGE4 OF 4 
DEPARTMENT OF 

ECOLOGY 

State of Washington 

Industrial Section 

Water Quality Compliance Inspection Report 

Facility Name & Address: Cosmo Specialty Fibers, LLC (Cosmo) 

1701 First Street 

Cosmopolis, WA 98537 

NPDES Permit No. : W A000080-9 

Inspection Date: July 8 and 16,2014 

Ecology Representative: Ha Tran, Industrial Section 

Facility Representatives: Craig McKinney, Environmental Engr. (Water, RCRA) 

Arne Peterson, Environmental Engr. (Air Quality) 

Report by: Ha Tran 

Report Date: See EPA Form 

Purpose oflnspection: To evaluate the facility's level of compliance with its 

NPDES permit 

Ecology an·ived at Cosmo for the Water Quality Sampling Inspection at 9:00AM on July 8, 2014. I 

met with environmental leads Craig McKimiey and Ame Peterson who assisted with the inspection. 

Ecology's Hazardous Waste Program Lynn Coleman also accompanied me on the site walkthrough. I returned on July 16,2010 and completed the inspection with Mr. McKinney's assistance. 

I left the facility around !2:00PM on the same day. 

FACILITY BACKGROUND 

Weyerhaeuser constructed the mill in 1957. The company later convetted the mill to add dissolving 

and specialty grade pulp to its product line. Weyerhaeuser operated the mill until its shut down in 

September 2006. The equipments were mothballed in preparation of selling the mill. Cosmo 

purchased the mill in August 20 I 0 and resumed full operation in the summer of 2011. The mill 

now produces dissolving pulp of the acetate, viscose and ether grades with a pennitted capacity of 

about 550 tons per day. 

Cosmo uses a magnesium bisulfite, Mg(HS03)2, cooking acid in its pulping process. The mill has 

nine batch digesters to which wood chips are manually loaded. The pulp from the digesters goes 

into dump tanks and through a multi-stage, countercutTent brown stock washer system. Cosmo 

Water Inspection Report for July 8 and 16, 2014: Cosmo Specialty Fibers, Inc. I Page I of6 
bleaches the pulp using caustic, oxygen, chlorine dioxide, and hydrogen peroxides. The pulp 

machine processed the bleached pulp into the final product. 

The mill burns spent cooking liquor (red liquor) in three recovery boilers. The boilers' flue gas 

enters the multiclones to capture magnesium oxides (MgO). Magnesium oxides from the 

multiclones go into a slaking tank for conversion into magnesium hydroxide slu11'y. Cosmo sends 

the slurry to absorptions towers to react with sulfur dioxide from the recovery boilers' flue gas to 

reform cooking acid. The mill receives additional magnesium and sulfur from truck deliveries. The 

acid plant bums sulfur to form the quality of cooking acid needed for the digesters. 

Cosmo produces most of its energy from the combustion of spent liquor in the recovery boilers and 

a hogged fuel in the power boiler. 

DISCHARGE 0UTFALLS 

The mill has two permitted outfalls. Outfall 001 discharges sour sewer flow into the upper part of 

the south channel of Grays Harbor. Outfall 002 discharges into the Chehalis River upstream of the 

mill. 

WASTEWATER SYSTEM DESCRIPTION 

Cosmo wastewater system includes both primary and secondary treatment. The mill constructed the 

secondary treatment system in 1966 and expanded it in 1972 and 1980. 

Cosmo wastewater system includes both primary and secondary treatment. Description of four 

primary treatment units is in Table 1. The. mill constructed the secondary treatment system in 1966 

and expanded it in 1972 and 1980. 

TABLE 1. 

Ash 

clarifier 

Disco 

strainer 

screen 

Three recove1y boiler areas 

and hogged fuel boiler area 

Pulping area trenches, bleach 

plant reject Jines, paper 

machine room sewers, and 

roadways 

Pulping area overflow 

Sweet sewer Stonnwater, filter plant 

settling basin* backwash, and huck wash 

area overflow 

Outfall 00 I, via sour Dewater with filter 

sewer press and shipped 

offsite as fill material 

Outfall 00 I, via sour Bum in hogged fuel 

sewer boiler or sold offsite 

Outfall 00 I, via sour Dewater and bum in 

sewer hogged fuel boiler 

Outfall 002 None 

*Wastewater enter a settling basin prior to setting basin is prior to the sweet sewer 

The secondary treatment system handles high-BOD process wastewater, including that from the 

pulping process, 2A filtrate from the bleach plant, and evaporator systems. The biological treatment 

Water Inspection Repmt for July 8 and 16, 2014: Cosmo Specialty Fibers, Inc. I Page 2 of 6 
plant consists of four aeration lagoons (also called "bioponds") operating in parallel and two 

clarifiers also operating in parallel. The bottoms of the clarifier returns to the biopond as recycled 

activated sludge. To better control BOD loading to the bioponds, the mill installed an 11 milliongallon wastewater storage pond. Cosmo centrifuges the waste sludge and processes it in the 

evaporator systems along with the weak red liquor. Recovery boilers no. 1 and no. 2 burn the 

sludge, along with the red liquor, for energy recovery. 

The biological treatment plant effluent flows to the sour sewer. Wastewater from the som' sewer 

flows through a wood stave pipe, which runs underground tlll'ough south Aberdeen toward the 

Westport ponds on a noncontiguous property about tln·ee miles west of the mill proper. Prior to the 

construction of the bioponds, the Westport ponds served as settling basins. The mill now uses these 

ponds as surge basins. The four Westport ponds are designated A, B, C, and D. The line changed 

from wood stave to concrete about 1500 ft upstream of the Westport pond D. The discharge gate to' 

outfall 001 is located at pond D. The gate is automated to open only when the wastewater pH is 

between 5.2 and 8.8. Cosmo can impound the wastewater by manually closing the gate, or 

dive1ting the wastewater to pond A, which overflow to ponds B and then C. Ponds B and C are not 

connected to D. Altematively, the mill can also close the pond A valve and direct all wastewater 

flow to pond D. Cosmo also operates a series of aerators at the ponds to maintain aerobic 

conditions and minimize odors. 

The filter plant backwash and st01m water collected in a settling basin, which flows to a conveyance 

system designated as the "sweet sewer." The sweet sewer also contains st01mwater from the 

surrounding areas and truck wash overflow from the Weyerhaeuser parking lot. Water from the 

sweet sewer flows tln·ough a weir into the slough and then out to the Chehalis River. 

SITE INSPECTION 

The inspection focused on the wastewater treatment operations, sto1m water discharge, sampling 

procedures, and laboratory procedures. The inspection consisted of the pre-inspection meeting, 

records review, and walk-tln·ough of the areas listed below. Ecology's review of these units/areas are 

detailed in the subsequent sections. 

· o Ash clarifier o St01mwater collection system 

o Storm water collection systems 

o Disinfection system 

o Bioponds and clarifiers 

o Outfalls 00 I and 002 

o Westport ponds 

o In-house laboratory 

Ash Clarifier: The ash clarifier processes wastewater from the recovery and power boilers. Staff 

added polymer to improve settling. Sludge settled at the bottom is removed by a rake and runs to a 

press for dewatering. 

The ash clarifier failed on July 4, 2014, four days prior the inspection. The failure was due to the 

malfunction in the instrument pin, which register zero torque on the bottom rake. As a result, staff 

did not detect the excessive torque on the rake and the rake broke. Upon discovery, staff took the 

clarifier offline for emergency repair and notified Ecology. I reviewed the logbook and noted that 

torque reading, the failure, and the repair work were consistent with Cosmo's rep01i. Cosmo 

completed the repair and put the clarifier back into service by the time of the inspection. Ecology 

observed the clarifier appeared to be functioning normally. I noted the polymer pump ruffiling at 

3.6 strokes per minute, while the influent to the clarifier was 1800 gpm (2.6 MOD) compared to 

Water Inspection Repmt for July 8 and 16, 2014: Cosmo Specialty Fibers, Inc.! Page 3 of 6 
the design criteria of 1.5 MGD average flow and 2 MGD maximum flow. I noted an accumulation 

of fines on the surface of the clarifier. 

Bioponds: Odor at the bioponds appeared to minimal at the time of July 8, 2014 inspection. I 

recorded the following parameters: 

TABLE2. 

Biopond influent 

*Design 

While the dissolved oxygen level in the bioponds were elevated, the system appeared to be 

operating with no issues. 

Secondary Clarifiers: Ecology did not note visible filaments or canyovers at either clarifier. The 

overflow at the clarifiers was highly colored, making it difficult to visually estimate the sludge 

depth. There was no foaming on the surface of either clarifier. 

Disinfection system: The facility monitors for fecal coliform through the process, including at the 

secondary clarifier, the Westport Pond A, and the discharge. As part of the nonnal operating 

procedures, Cosmo continuously added hypochlorite secondary clarifier #1 to keep the fecal 

coliform level down. If there significant a fecal coliform growth as the effluent travel from the 

clarifier to the outfall, staff may also close the outfall gate and flushed the wood stave line with 

hypochlorite, sulfuric acid, or caustic. 

Outfall 001: Outfall 001 and the Westport ponds are secured fencing and locked gates. Ecology 

noted the temperature inside outfall 001 compositor at 1 °C. The pH meter showed reading 

between 6.6 to 6.7. Staff maintains a logbook documenting the activities and observations at least 

twice a day. Documented actions include disinfection, repairs, and the status of the discharge gate. 

The discharge gate is set to close upon power outage. The systems at the outfall and the Westport 

ponds are backed up by an emergency diesel-powered generator located at pond A. 

Outfall 002: At the time of the inspection, Cosmo maintains the boom and the aerator at outfall 

002. Cosmo uses a Delta Controls Corp. Model668 flow meter. Ecology took readings of the 

continuous monitoring instruments: flow rate was at 6.9 MGD, temperature was 27.1 oc, and pH 

was at 6.9. The pH was. within permit limit and all the readings were consistent with the range 

reported to Ecology. I did not observe any sheen, visible solids, or elevated turbidity at the flow 

exiting the weir. 

Ecology reviewed the composite sampler, a Manning unit, at the outfall 002. The compositor 

Wastewater Inspection Repmt for July 8 and 16, 2014: Cosmo Specialty Fibers, Inc. I Page 4 of 6 
drew equal volume from discharge every 15 minutes. The compositor fridge was at 3°C and 

within the acceptable holding temperature. Staff maintains a logbook similar to the logbook at 

outfall 001 to document flow, pH, any sheen observed, and compositor temperature. Cosmo 

monitored flow rate by recording the depth at the weir. 

Laboratory: Cosmo's lab perfotmed analyses for both product quality and NPDES permit 

compliance. Lab personnel maintain the QA/QC manual in the lab and updated it on Jan 22,2013. 

They also maintain a log documenting the sample collection and analysis time and name of the 

responsible staff. I viewed Cosmo's accreditation certificate. The lab is accredited for fecal 

colifmm (membrane filter method), BOD5, TSS, pH, and dissolved oxygen. The lab ID no. is 

I970-13. The accreditation will expire on Oct 23,2014. 

For BOD5 analysis, the lab uses method 5210. Staff maintained the incubator temperature at 

2o.o·c. There was no residual chlorine in the effluent, therefore staff do not dechlorinate with 

Na2S03. I observed that BOD5 samples were stored away from light. Staff used seed from the 

City of Aberdeen treatment's raw sewage. Review of the standard check appeared to be within the 

acceptable range. 

For TSS analysis, the lab uses method 2540. Unicorp calibrated the balance on 5/5/14. Ecology 

noted the oven temperature at 104•c and within acceptable range. No issues were found during 

this inspection. 

For fecal coliform analysis, the lab uses standard method 9222. I noted an incubation temperature 

at 44.5•c, within the range prescribed by the method. Lab technicians noted that all samples were 

sterilized and wrapped in foil to prevent contamination. 

Cosmo sends wastewater samples to ALS Laboratory in Kelso for analysis of remaining 

parameters required by the permit. ALS is accredited for the following parameters: 

TABLE3. 

SAMPLING & RESULTS 

Ecology split the 24-hour composite samples from outfall 001 and 002 with Cosmo. I also 

collected a grab sample at outfall OOlfor fecal coliform analysis. Manchester Lab analyze 

Ecology's sample, with the exception of A OX. TestAmerica performed the analysis for AOX 

using Method 1650. All sampling results were within permit limits. 

Wastewater Inspection Report for July 8 and 16, 2014: Cosmo Specialty Fibers, Inc. I Page 5 of6