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 SpecialtyFibers, Inc. POBox 539 Cosmopolis, WA 98537


### Re: Class IIWastewater Inspection on July 8-16, 2014

Dear Mr. McKinney:

Thank you for your assistance withthe Class II Wastewater Inspection conducted at Cosmo Specialty Fibers, Inc. (Cosmo) onJuly 8 and 16, 2014. DepatimentofEcology (Ecology) conducted this routine wastewater inspection to detetmine Cosmo's level ofcompliance withits NPDES permitNo. W A 000080-9. Enclosed is a copy ofthe inspection repott for your files.

The inspection consisted ofa walk-through ofCosmo'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 ofthis inspection. Ifyou have any questions, please contact
me at (360) 407-6064 orha.tran@ecy.wa.gov.

# ~ HaTran Industrial Section Waste 2 Resources Program

EnclosuresUnited 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 (Forindustrialusers discharging to POTw, Entry Time/Date Permit Effective Date a/so include POTWname andNPDESpermitnumber) 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 1200AM 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 (Checkonly 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 additionalsheets ofnarrative andchecklists 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 = NotApplicable 

# 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, CountyandZIPcode) 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 (Furtherexplanation 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 andmaintenance 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 theircompliance status) DYES ONO**~N/A** USING PUBLICLY OWNED TREATMENT WORKS. SECTION H • Permit Verification INSPECTION OBSERVATIONS VERIFY THE PERMIT.**~YES** ONO D N/A (Furtherexplanation 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) NUMBERAND 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 (Furtherexplanation 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 SENTTO 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 4Fonn Approved OMB No. 158-R0073 

# IPERMIT NO. 

### WA0000809 SECTION J • Compliance Schedules PERMITTEE IS MEETING COMPLIANCE SCHEDULE. DYES ONO**~** N/A (Furtherexplanation attached

CHECKAPPROPRIATE PHASE(S): 0(a) THE PERMITTEE HAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE AUTHORITIES TO BEGIN CONSTRUCTION. O(b) PROPERARRANGEMENT 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 (Furtherexp/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 oflast 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 (Furtherexplanation 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 (Furtherexplanation 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 4SECTION L - Effluent/Receiving Water Observations (Furtherexplanation 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 (Furlherexplanation 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 ifnecessary)

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 4DEPARTMENT OF 

## ECOLOGY State ofWashington 

## Industrial Section Water Quality Compliance Inspection Report

FacilityName & 

### Address: Cosmo Specialty Fibers, LLC (Cosmo) 1701 First Street Cosmopolis, WA 98537 NPDES PermitNo. : WA000080-9 Inspection Date: July 8 and 16,2014 Ecology Representative: Ha Tran, Industrial Section FacilityRepresentatives: CraigMcKinney, Environmental Engr. (Water, RCRA) Arne Peterson, Environmental Engr. (Air Quality) Report by: 

### Ha Tran ReportDate: See EPA Form Purpose oflnspection: To evaluate the facility's level ofcompliance 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 withthe inspection. Ecology's Hazardous Waste Program Lynn Coleman also accompanied me on the site walkthrough. I returned onJuly 16,2010 and completedthe inspection with Mr. McKinney's assistance. I left the facility around !2:00PMonthe same day.

FACILITYBACKGROUND 

### 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 inpreparation ofselling the mill. Cosmo purchasedthe mill in August 20I0 and resumed full operation inthe summer of2011. The mill
nowproduces dissolving pulp ofthe 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 inits 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 8and 16, 2014: Cosmo SpecialtyFibers, Inc. 

## IPage I of6bleaches the pulp using caustic, oxygen, chlorine dioxide, and hydrogenperoxides. The pulp machine processed the bleachedpulp into the final product. The mill burns spent cooking liquor (red liquor) inthreerecoveryboilers. The boilers' flue gas enters the multiclonesto capture magnesium oxides (MgO). Magnesium oxides from the multiclones go into a slaking tank for conversioninto magnesiumhydroxide 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 acidplantbums sulfurto form the quality ofcooking acid needed for the digesters. Cosmo producesmost ofits energy from the combustion ofspent liquorinthe 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 ofGrays Harbor. Outfall 002 discharges into the ChehalisRiverupstream ofthe mill.

WASTEWATERSYSTEMDESCRIPTION Cosmo wastewater system includes bothprimary and secondarytreatment. The mill constructed the secondarytreatment system in 1966 and expanded it in 1972 and 1980. Cosmo wastewater system includes bothprimary and secondarytreatment. Description offour primary treatmentunits 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 huckwash
area overflow Outfall 00I, via sour Dewater with filter
sewer press and shipped offsite as fill material Outfall 00I, via sour Bum in hogged fuel
sewer boiler or sold offsite

Outfall 00I, via sour Dewater and bum in
sewer hogged fuel boiler Outfall 002 None

*Wastewater enter a settlingbasin prior to setting basin is prior to the sweet sewer
The secondarytreatment system handles high-BOD process wastewater, including thatfrom the pulping process, 2A filtrate from the bleachplant, and evaporator systems. The biologicaltreatment

Water Inspection Repmt for July 8and 16, 2014: Cosmo Specialty Fibers, Inc. 

## IPage 2 of6plant consists offour aeration lagoons (also called "bioponds") operating inparallel andtwo clarifiers also operating inparallel. The bottoms ofthe clarifier returns to the biopond as recycled activated sludge. To better control BOD loading to the bioponds, the mill installed an 11 milliongallon wastewater storagepond. Cosmo centrifugesthewaste sludge andprocesses it in the evaporator systems along withthe weak red liquor. Recovery boilers no. 1 and no. 2 burnthe sludge, along withthe red liquor, for energy recovery. The biologicaltreatmentplant effluent flows to the soursewer. Wastewaterfrom the som' sewer flows through a wood stavepipe, whichruns underground tlll'ough southAberdeen toward the Westportponds on a noncontiguousproperty abouttln·ee miles west ofthe mill proper. Priorto the construction ofthe bioponds, the Westportponds served as settling basins. The mill nowuses these ponds as surge basins. The four Westportponds are designated A, B, C, andD. The line changed from wood stave to concrete about 1500 ft upstream ofthe Westport pond D. The discharge gate to' outfall 001 is located atpondD. The gate is automated to openonly whenthe wastewaterpH is between 5.2 and 8.8. Cosmo can impoundthe wastewater bymanually closing the gate, or dive1ting the wastewaterto pondA, which overflowtoponds B and then C. Ponds B and C are not connected to D. Altematively, the mill can also close the pondA valve and direct all wastewater flow to pondD. Cosmo also operates a series ofaerators at thepondsto maintain aerobic conditions and minimize odors. The filter plant backwash and st01m water collected in a settlingbasin, which flows to a conveyance system designated as the "sweet sewer." The sweet sewer also contains st01mwater from the surrounding areas and truck wash overflowfrom the Weyerhaeuserparking lot. Water from the sweet sewer flows tln·ough a weirinto the slough and then outto the Chehalis River.

SITEINSPECTION The inspectionfocused on the wastewatertreatment operations, sto1m water discharge, sampling procedures, and laboratoryprocedures. The inspection consisted ofthe pre-inspection meeting, records review, and walk-tln·ough ofthe areas listed below. Ecology'sreview ofthese units/areas are detailed in the subsequent sections.

· o Ash clarifier o St01mwater collectionsystem

o Storm water collection systems

o Disinfection system

o Bioponds and clarifiers o Outfalls 00I and 002

o Westportponds

o In-house laboratory
Ash Clarifier: The ash clarifierprocesses wastewaterfrom the recovery andpowerboilers. Staff addedpolymer to improve settling. Sludge settled atthe bottom is removed by a rake and runs to a press for dewatering. The ash clarifier failed on July 4, 2014, four days priorthe inspection. The failure was due to the malfunction in the instrumentpin, whichregister zero torque on the bottom rake. As a result, staff did not detectthe excessive torque on the rake and the rake broke. Upon discovery, stafftookthe clarifier offline for emergencyrepair andnotified Ecology. I reviewed the logbook and noted that torque reading, the failure, and the repair work were consistent with Cosmo'srep01i. Cosmo completed the repair and put the clarifier backinto service bythe time ofthe inspection. Ecology observed the clarifier appeared to be functioning normally. I noted thepolymerpump ruffiling at 3.6 strokes per minute, while the influentto 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 of6

### the design criteria of 1.5 MGD average flow and 2 MGD maximum flow. I noted an accumulation offines onthe surface ofthe clarifier. Bioponds: Odor at the bioponds appeared to minimal at the time ofJuly 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 notnote visible filaments orcanyovers 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 ofeither clarifier. Disinfection system: The facility monitors for fecal coliform through the process, including at the secondary clarifier, the Westport PondA, and the discharge. Aspart ofthe nonnal operating procedures, Cosmo continuously added hypochlorite secondary clarifier #1 to keep the fecal coliform level down. Ifthere significant a fecal coliform growth as the effluenttravel from the clarifier to the outfall, staffmay also close the outfall gate and flushed the wood stave line with hypochlorite, sulfuric acid, or caustic. Outfall 001: Outfall 001 and the Westportponds are secured fencing and locked gates. Ecology noted the temperature inside outfall 001 compositor at 1 °C. ThepH meter showed reading between 6.6 to 6.7. Staffmaintains a logbook documenting the activities and observations at least twice a day. Documented actions include disinfection, repairs, and the status ofthe 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 anemergency diesel-powered generator located atpond

### A. Outfall 002: At the time ofthe inspection, Cosmo maintains the boom and the aerator at outfall 002. Cosmo uses a Delta Controls Corp. Model668 flow meter. Ecology tookreadings ofthe continuous monitoring instruments: flow rate was at 6.9 MGD, temperature was 27.1

# oc, and pH
was at 6.9. The pH was. withinpermit 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 Repmtfor July 8and 16, 2014: Cosmo Specialty Fibers, Inc. 

## IPage 4 of6

### drew equal volume from discharge every 15 minutes. The compositorfridge was at 3°C and within the acceptable holding temperature. Staffmaintains 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 atthe weir. Laboratory: Cosmo's lab perfotmed analyses for bothproduct quality and NPDES permit compliance. Lab personnel maintain the QA/QC manual inthe lab and updated it on Jan 22,2013. They also maintain a log documenting the sample collection and analysis time and name ofthe 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. ForBOD5 analysis, the lab uses method 5210. Staffmaintained the incubator temperature at 2o.o·c. There was no residual chlorine in the effluent, therefore staffdo not dechlorinate with Na2S03. I observedthatBOD5 samples were stored away from light. Staffused seed from the City ofAberdeentreatment's raw sewage. Review ofthe standard check appeared to bewithin 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,withinthe range prescribed bythe method. Lab technicians noted that all samples were sterilized and wrapped in foil to prevent contamination. Cosmo sends wastewater samples to ALS Laboratory inKelso for analysis ofremaining 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 ofAOX. TestAmericaperformed the analysis for AOX using Method 1650. All samplingresults were withinpermitlimits.

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

## IPage 5 of6