EVALUATION REPORT for the Renewal Application for NPDES Wastewater Discharge Permit for the WEYERHAEUSER PAPER COMPANY Containerboard Division Springfield, Oregon

Oregon Department of Environmental Quality Prepared By Gary Andes and Rajeev Kapur

^D) feE rv*> MAR 0 8 200% WESTERN REGION / bUQENI f TABLE OF CONTENTS

Page 1.0 INTRODUCTION . 1 2.0 DESCRIPTION OF CURRENT AND FUTURE PRODUCTION 1 3.0 DESCRIPTION OF WASTEWATER TREATMENT SYSTEM • ...... 2 4.0 HISTORY OF PERMIT VIOLATIONS 4 5.0 OTHER STUDIES AND PROGRAMS UNDERWAY...... 5 6.0 WATER QUALITY ANALYSIS ...... 7 6.1 Dissolved Oxygen 8 6.2 Temperature 9 6.3 Turbidity 10 6.4 pH...... 10 6.5 Bacterial Pollution ..... ll 6.6 Color 11 6.7 Aesthetic Conditions. 11 6.8 Toxic Substances. . . . 12 Q * _7 JNU.T-XrXwiJ.wS • » • • * *• # * • # • * * • *• «• JL 4* 6.10 Total Dissolved Solids...... 13 7.0 NPDES PERMIT DISCUSSION 13 7.1 Schedule A—Waste Discharge Limitations . . .13 7.2 Schedule B—Minimum Monitoring & Reporting. .15 7.3 Schedule C—Compliance Schedules...... 15 7.4 Schedule D—Special Conditions 16 8.0 • PERMIT PROCESSING/PUBLIC COMMENT/APPEAL PROCESS 1.0 INTRODUCTION Weyerhaeuser Paper Company (Weyerhaeuser), Springfield, has filed a renewal application with the Department of Environmental Quality (Department or DEQ) for renewal of its National Pollutant Discharge Elimination System (NPDES) permit. The renewal application was filed on April 2, 1991 prior to the expiration date of the existing permit which was 9/30/91. NPDES permits are issued by the Department pursuant to Section 402 of the Federal Clean Water Act, ORS 468B.050, and rules adopted by the Environmental Quality Commission. This report summarizes the application and subsequent material presented by the applicant and presents the Department's evaluation of the discharges compliance with applicable water quality standards and requirements.

2.0 DESCRIPTION OF CURRENT AND FUTURE PRODUCTION Weyerhaeuser owns and operates a kraft pulp and paper mill at Springfield, Oregon. The mill presently produces around 590,000 tons per year of kraft linerboard. No bleached pulp is produced at the facility. As shown in Table 1, production has increased steadily since the last permit was issued and is anticipated to continue to expand to approximately 650,000 tons/year in 1995. Past production increases have resulted from increased operating efficiencies and throughput on existing equipment at the mill. Currently, pulp for the process is generated by "cooking" wood chips and repulping box plant clippings from box plant manufacturers and recycled white office paper. The relative percentages used are approximately 80%, 18%, and 2% of these materials. Weyerhaeuser has recently announced plans to expand the facility production by constructing an Old Corrugated Container (OCC) recycling facility at the mill and upgrading the paper machines to handle the material. Approximately 5 acres of the existing mill site will be utilized to accept and process (repulp) 450 tons/day of recycled fiber (75% old corrugated containers and 25% mixed waste papers). This facility will replace the recycled box clippings such that overall plant production will initially increase by 150 tons/day. The production percentages in the future of chips, OCC, and white office paper will then be approximately 65%, 33%, and 2%. Increased production will cause an increase in loadings of BOD to the existing wastewater treatment system. Weyerhaeuser is currently studying the additional treatment requirements of the wastewater from this new facility and how best to handle the loadings. Although final design details for either the OCC facility itself or the additional wastewater treatment facilities

MW\WC10\WC10793.5 - 1 - are not yet available, Weyerhaeuser has made a commitment to not increase the overall plant effluent discharges above those levels specified in the existing permit, Thus, no loading increase will occur to the McKenzie River. As design for the new OCC facility becomes finalized, Weyerhaeuser will be required to submit treatment system plans to DEQ for construction approval. Thus, this permit renewal evaluation is being done under the assumption that no additional waste load allocations for the Springfield facility will be requested by Weyerhaeuser. In addition to the pulp and paper operations at the Springfield facility, the site also has a log pond and decking area for log storage, a hydraulic barker, particleboard manufacturing, and chip storage areas. Sawmill and plywood manufacturing operations at the site have been discontinued. Demolition of some of the sawmill is currently underway. In addition, the hog fuel boilers on-site are currently not being used.

3.0 DESCRIPTION OF WASTEWATER TREATMENT SYSTEM Wastewater flows are generated from numerous processes at the facility as shown in Figure 1. Internal recycling and cascading, water usage is practiced significantly, within the facility. Contaminated process waters from the pulp mill area are segregated and routed to a lift station which can then either send the water to the surge pond (if high BOD concentrations) or directly to the primary clarifier. • The surge pond acts as a storage facility to allow slower bleed-in of the higher strength BOD waters to the treatment system. The primary clarifier removes large particles of wood fiber and lime generated in the pulping process. Contaminated water from the paper machines is routed through side-hill screens and a dissolved air flotation unit before joining the clarifier effluent. The combined waste stream then goes to the aeration stabilization basin (ASB) where small nutrient additions are made to promote the biological activity necessary to reduce the BOD loadings in the effluent. The ASB has a 5 to 7 day retention time with the biological activity and mixing promoted by 11 aerators. Baffles in the pond preclude any short-circuiting of water flows. Clean, non-contact process waters and log pond effluent join the ASB effluent and defoamer is added prior to discharge to the Mckenzie River at outfall 001. Non-contact cooling'waters are routed separately through a series of cooling ponds prior to discharge at outfall 002 to the Mckenzie River or outfall 003, an old irrigation ditch leading to Springfield's stormwater system. Previously some of the hot waters were routed to the Ore Aqua fish hatchery facility near Hayden Bridge. However, the facility has been shut down for two years and its restart status is unknown.

MW\WC10\WC10793.5 - 2 - Since the last permit was issued a number of improvements have been made by Weyerhaeuser to the wastewater treatment system as shown in Table 2. These improvements/additions/changes have allowed the facility to better recycle/segregate/treat the wastewater generated at the plant. A number of additional projects and studies are underway at the facility, particularly regarding the OCC expansion, to determine what additional water recycling/segregation/treatment alternatives may be feasible. Table 3 presents a summary of the effluent flows from the facility since the last permit renewal along with some production and McKenzie River data. 001 effluent flows have followed closely with the production increases. 002 effluent flow increases have resulted from the Ore Aqua facility not taking water in recent years. BOD and TSS discharge loadings from 001 have increased at a greater rate than the flow, probably due to the reduction of ASB volume by sludge buildup in the basin. These sludge accumulations were removed in 1991 (1/3) with the remainder removed in 1992 to reestablish the ASB retention time. It is anticipated that the BOD and TSS loading will be reduced in the discharge as the retention time of the ASB is restored. Table 4 presents a comparison of the 001 discharge characteristics with the existing permit limits and the federal effluent guidelines for unbleached kraft mills. As the table shows, the effluent discharge is well below the EPA effluent guidelines and has generally remained well under the current permit limitations.

4.0 HISTORY OF PERMIT VIOLATIONS Although the Weyerhaeuser facility has been in general compliance with existing NPDES permit conditions, a number of minor violations have occurred since the last renewal. Tables 5 and 6 list these violations and their cause. For the most part, these excursions at outfall 001 were of a daily nature, represented plant upset conditions or unavoidable incidents, and were considered minor by the Department. pH excursions at outfall 002 are associated with algal activity in the cooling ponds.

5.0 OTHER STUDIES AND PROGRAMS UNDERWAY Ancillary to the ongoing self-monitoring programs at outfalls 001 and 002, a number of other studies and programs are underway at the Weyerhaeuser facility, either as a result of permit requirements or at Weyerhaeuser's own initiation. These include bioassays utilizing 001 effluent, sludge removal and application to farmland for beneficial use, groundwater monitoring, and in-stream aquatic studies. -,

MW\WC10\WC10793.5 . - 3 - 96-hour static acute bioassay tests have been performed on rainbow trout twice a year. Results have indicated 100% survival in 65% effluent samples and usually 100% survival in 100% affluent. DEQ specifications for 80% survival in 65% effluent have always been met. - Sludge from the aeration basin was removed in 1991 and 1992 and beneficially applied to farmland northeast of the plantsite and near Pleasant Hill. The sludge application program was designed by consultants for agronomic rate applications and approved by DEQ. Removal of the sludge from the ASB was necessary to restore the retention time in the ASB. Sludge and solids removed from the surge pond prior to lining the pond were also beneficially applied to farmlands near Coburg in 1991 and 1992. Also approved by DEQ, this sludge application was done at agronomic rates as determined by consultant studies. Weyerhaeuser is currently studying the possibility of utilizing primary sludge generated continuously in the primary clarifier for some beneficial use. Currently, the sludge is disposed of at the Short Mountain Landfill. Weyerhaeuser initiated a preliminary groundwater monitoring program utilizing a consultant in 1991. No results or reports have been developed as a result of the preliminary studies but the new permit will contain requirements and a timetable for implementing more detailed hydrogeologic characterization studies at the facility. Due in part to ongoing concerns raised regarding the Weyerhaeuser effluent by citizens who live along or use the McKenzie River, a cooperative in-stream aquatic study was performed in 1991. Entities involved included DEQ, Weyerhaeuser, Oregon Fish and Wildlife, and local citizens. Benthic samples and water quality samples were obtained at a number of upstream and downstream locations and biological analyses conducted. Based on the September 10, 1991 monitoring data, the benthic invertebrate community data suggest that there are differences among the communities within the effluent plume compared to communities outside the plume. However, the benthic community in the effluent zone in the McKenzie River still have numerous taxa that are considered to be pollution sensitive and the Hilsenhoff Biotic Index values indicated good to fair water quality. The study concluded that there are indications that the communities are under some stress however, conditions have not caused severe alterations in the communities. It is anticipated that the cooperative efforts with local citizens and responsible agencies will continue in this area. Installation of a diffuser at outfall 001 in 1993 will change the effluent mixing characteristics considerably and changes in the in-stream biota mix from its present characteristics can be anticipated.

MW\WC10\WC10793.5 - 4 - _ ' 6.0 WATER QUALITY ANALYSIS Weyerhaeuser's Springfield plant discharges treated process water and log pond effluent through outfall 001 to the McKenzie River at river mile 14.7 just below Hayden Bridge. The facility also discharges non-contact cooling water through outfalls 002 and 003. Outfall 002 discharges into the secondary channel of the McKenzie River just above Hayden Bridge. Outfall 003 discharges into the City's storm water system; some of the cooling water flows into the secondary channel of the McKenzie River and the rest flows through the City of Springfield and discharges to the Willamette River. In 1991, the average discharge flow from outfall 001 was 15.5 mgd and from outfall 002 was 5.7 mgd. For outfall 001, the existing NPDES Permit specifies a mixing zone of 1500 feet for all water quality parameters except turbidity and temperature which have been allotted a 4000 foot mixing zone. The allowable mixing zone for outfall 002 extends from the point of discharge into the secondary channel of the McKenzie River to the main stem McKenzie River at the Hayden Bridge. Outfall 003 is a newly recognized discharge point and did not have a previously defined mixing zone. The discharge points are noted in the attached map. OAR 340-41-442 lists the beneficial uses for which water quality will be protected in the Willamette River Basin, which includes the McKenzie River. The beneficial uses include public domestic water supply, salmonid fish spawning and rearing, water contact recreation and aesthetic quality. The applicable water quality standards for this discharge are specified in OAR 340-41-445; OAR 340-41-455 contains minimum design criteria for treatment and control of wastes. OAR 340-41-445 allows the Department to designate a mixing zone. The Environmental Protection Agency's (EPA's) "Technical Support Document for Water Quality-based Toxics Control" also includes a discussion of mixing zones. The underlying assumption for allowing a mixing zone is that a small area of concentration in excess of acute and chronic criteria can exist without causing adverse effects to the overall water body and, thus, it may not be necessary to meet in-stream water quality standards at the discharge point in order to protect the integrity of the receiving stream. The mixing zones established for the discharges from outfalls 001 and 002 do not meet the criteria defined above. A mixing zone study of the discharge from outfall 001 was conducted in 1986. That study and subsequent aquatic studies indicate that the outfall does not provide rapid mixing of the discharge with the receiving stream and the discharge plume hugs the left bank of the McKenzie River for some distance downstream until the Mohawk River enters

MW\WC10\WC10793.5 - 5 - the McKenzie River.j Therefore, for the purpose of this evaluation, the dilution available in the defined mixing zone will not be used to determine whether the discharge complies with applicable water quality standards. The approach which will be used here is to compare the discharge concentration of a parameter and the dilution which is available within a small area around the discharge to determine if the discharge is or has the potential to violate water quality standards. If the concentration of a pollutant in the discharge is well below water quality standards, no effluent limits will be proposed. Water quality based effluent limits and/or monitoring requirements are specified only for those pollutants that have the potential to violate water quality standards. The following is an! analysis of the discharge for compliance with water quality standards: 6.1 Dissolved Oxygen OAR 340-41-445(2)(a) states that no wastes shall be discharged and no activities shall be conducted which either alone or in combination with other wastes or activities will cause a violation of the standards in the waters of the Willamette River Basin. For dissolved oxygen (DO), the applicable standards for this discharge are the standards for the Mckenzie River and the main stem Willamette River from the confluence of the Coast Fork and the Middle Fork (river mile 187.) to Salem, McKenzie River: Salmonid fish producing waters; The DO concentration shall not be less than 90% of saturation at seasonal low or less than 95% of saturation in spawning areas during spawning, incubation, hatching and fry stages of salmonid fishes. Non-salmonid fish, producing waters: The DO concentration shall not be less than^6 mg/l. Main stem Willamette River (from river mile 187 to Salem): The DO concentration shall not be less than 90% of saturation. A Streeter-Phelps evaluation was used to predict the DO deficit downstream of the discharge point. The Streeter-Phelps Dissolved Oxygen Model calculates the critical oxygen deficit from a single source using flow, stream concentration of dissolved oxygen (i.e. background), temperature, reaction rates, re-aeration rates and effluent characteristics. The DO analysis indicates that the resulting maximum DO deficit would be 15 miles below the discharge point (at the mouth of the McKenzie River) and would be ,0.3 mg/l.

MW\WC10\WC10793.5 ' - 6 - This translates to 97% of saturation, which is within water quality standards for both the McKenzie River and the Willamette River. 6.2 Temperature The"Department's temperature standard for fresh water set forth in OAR 340-41-445 (2)(b)(B)(i) states that "no measurable increase shall be allowed outside the assigned mixing zone, as measured relative to a control point immediately upstream from a discharge when stream temperatures are 58 degrees F or greater; or more than 0.5 degrees F increase due to single source discharge when the receiving water temperatures are 57.5 degrees F or less; or more than 2 degrees F increase due to all sources combined when stream temperatures are 56 degrees F or less ". All the discharges from this facility have a thermal component. Table 3 includes information of the discharge temperatures at outfall 001 and 002 and the river temperature as measured by Weyerhaeuser at the water intake. The analysis of the thermal component of the discharge from outfall 001 indicates that immediate dilution of the effluent will not enable Weyerhaeuser to comply with water quality standards for temperature under existing conditions. Previously (circa 1948), the Oregon Department of Fish & Wildlife (ODFW) did not want the discharge to impede the passage of migrating fish due to thermal or chemical barriers. This resulted in a singe port discharge that, hugs the shore and minimizes horizontal mixing. Since that time the characteristics of the discharge have improved significantly due to improvements; in the wastewater treatment plant.

Weyerhaeuser has contracted the services of a consulting firm to. evaluate and design a diffuser for the discharge from outfall 001. A meeting was held on August 7, 1992 with representatives from Weyerhaeuser, DEQ and Oregon Department of Fish & Wildlife (ODF&W). The meeting focused on the proposed change in the outfall configuration and its impact on fish migration. To minimize the impact on fish migration, temperature changes in the McKenzie River need to be minimized. The diffuser that Weyerhaeuser is proposing to install will be designed to accomplish this task. The proposed permit requires Weyerhaeuser to submit plans and specifications for the construction of a diffuser and an analysis of the dilution provided by the diffuser. Weyerhaeuser is proposing to install the diffuser in 1993 and conduct a mixing zone study late in the summer of 1994 after the completion of the new secondary treatment facilities. After completion of the mixing zone study, the Department will incorporate the dimensions of the revised mixing zone into the permit. If the installation of the diffuser does not provide adequate dilution to comply with the temperature standards, Weyerhaeuser will be required to submit a

MW\WC10\WC10793.5 : - 7 - proposal which would reduce the thermal load to the river. An interim temperature limit of 100 degrees F at outfall 001 is included in the permit. The thermal load in the existing permit was based on the total assimilative capacity of the river and not on the available dilution within the mixing zone. No thermal load limits are included in this permit. Outfall 002, which discharges into the secondary channel of the McKenzie River, also has a thermal component to the discharge. The proposed permit requires Weyerhaeuser to evaluate the mixing characteristics of this discharge and conduct a benthic survey below the outfall to determine the impact of the discharge. If the survey indicates that the discharge is having a significant impact on the benthic community or if evaluation of mixing below the outfall indicates that the discharge has the potential to violate water quality standards for temperature, the permittee is required to submit a plan and schedule to address the impacts of the discharge. The Department may, if appropriate, specify a revised mixing zone for outfall 002. Outfall 003, which discharges to the City of Springfield's stormwater system, !also has a thermal component. This discharge resulted from a leak through a gate valve at the inlet to the cooling ponds. This leak has since been fixed. However, Weyerhaeuser has received numerous requests from downstream users to continue the flow through outfall 003. Thus, Weyerhaeuser has requested that this additional discharge location be included in the permit. A portion of the discharge from outfall 003 has the potential to end up in the secondary channel of the McKenzie River. Thus, the permit requires Weyerhaeuser to take into consideration the additional flow and thermal load from outfall 003 when conducting the studies on the discharge from outfall 002. 6,3 Turbidity OAR 340-41-445(2) (c) states that "No more than a 10% cumulative increase in turbidity shall be allowed as measured relative to a control point immediately upstream of the turbidity causing activity". Compliance with*this standard is to be measured at the edge of the defined mixing zone. The current length of the mixing zone and the lack; of background data precludes a meaningful analysis of this standard. Once Weyerhaeuser installs the diffuser, determines the available dilution within the mixing zone, and monitors for background turbidity levels, compliance with the turbidity standards will be determined by the Department. Turbidity limits are not proposed at the other discharge locations since they contain only non-contact cooling water.

MW\WC10\WC10793.5 • - 8 - 6.4 pH OAR 340-41-445(2)(d)(B) states that pH values shall be within the range of 6.5 to 8.5. Compliance with this standard is to be measured at the edge of the defined mixing zone. The existing permit specifies a pH range of 6.0 - 9.0 at outfalls 001 and 002. For outfall 001, there is adequate dilution for the discharge to comply with the basin standards at the edge of the mixing zone. The discharge from outfall 002 occasionally exceeds the pH levels established in the existing permit as a result of algal blooms in the cooling ponds during the summer months. Weyerhaeuser has requested that a wider range for pH (6.0 - 9.5) be established for the discharge of cooling water from outfall 002. To comply with water quality standards, a minimum dilution ratio of 10:1 is required at the edge of the mixing zone. Based on the current dimensions of the mixing zone, there is adequate dilution to meet the basin standards for pH. The pH limit at outfall 003 is 6.0 - 9.0, since no algal blooms are associated with the discharge at this location. 6.5 Bacteria/Bacterial Pollution Sanitary wastewaters are discharged into the City of Springfield's collection system. Bacteria is not associated with the discharge of process water and cooling water from the facility. 6.6 color OAR 340-41-445 (2)(k) states that objectionable discoloration, scum, oily sleek or floating solids or coating of aquatic life with oil shall not be allowed. The existing permit required Weyerhaeuser to monitor the discharge from outfall 001 for color. The facility has reduced the color of the discharge from an annual average of 455 CU in 1987 to around 200 CU at present. The reduction in color is partially due to changes in the testing procedures to EPA approved methods. The permittee is proposing to install a diffuser which would maximize initial dilution and further reduce discoloration in the river. The proposed permit requires that color at outfall 001 be monitored three times per week. Effluent concentration of oil & grease reported in the permit renewal application would not cause an oily sleek or coat aquatic life.

MW\WC10\WC10793.5 - 9 - 6.7 Aesthetic Conditions OAR 340-41-445 (2)(1) states that aesthetics conditions offensive to human senses of sight, taste, smell or touch shall not be allowed. As mentioned above, installation of the diffuser would further reduce discoloration in the river. 6.8 Toxics Substances A review of EPA form 2C submitted along with the NPDES Permit renewal application indicates that toxic, substances in amounts which may be harmful to aquatic life are either not present in the discharge or are present in such small quantities that water quality standards are easily met. Therefore, no effluent limits are proposed for these parameters. However, the Department is requiring quarterly bioassay testing as a periodic check of the potential toxicity of the effluent. The permit renewal application indicates a sulfide concentration at outfall 001 of 0.84 mg/l. According to EPA's "Quality Criteria for Water", "when soluble sulfides are added to water they react with hydrogen ions to form hydrosulfide, HS"' or H2S, the proportion of each substance depending on the pH. The toxicity of sulfides is primarily from H2S rather than from hydrosulfide or the sulfide ions". The water quality standard for H2S is as follows: "2 micrograms/liter undissociated H2S for fish and other aquatic life, fresh and marine water". Weyerhaeuser retested the effluent for this parameter using a different methodology because Weyerhaeuser believed that significant interferences were occurring when the EPA methodology was used. The retesting showed a sulfide concentration of 0.008 mg/l. Discharging at this level would not be detrimental to water quality in the McKenzie River. Therefore, no monitoring requirements or effluent limits are proposed for this parameter. 6.9 Nutrients The renewal application states that the discharge concentration of total phosphorus in the process water is 0.6 mg/l. EPA has proposed 0.1 mg/l total phosphorus in free flowing stream as the nutrient concentration below which nuisance algal growths are limited. With the installation of a diffuser which would maximize dilution immediately below the discharge point, the phosphorus levels would be reduced below the 0.1 mg/l level specified by EPA within a short distance of the outfall. Background concentration for phosphorus was obtained from the Hayden Bridge site just upstream of the discharge from outfall 001.

MW\WC10\WC10793.5 - 10 - This was compared to the phosphorus concentration below the discharge point at river mile 7.1. The attached plot (attachement 4) shows the comparison of phosphorus levels between the upstream and the downstream sites. Although the concentration of phosphorus downstream increased from a median of 0.04 mg/l to 0.05 mg/l, this increase by itself would not promote algal growth. Therefore, no effluent limit for phosphorus is proposed. However, a monitoring requirement for this parameter is included in the permit to determine the discharges contribution of phosphorus. The renewal application reports a ammonia-nitrogen concentration of 0.73 mg/l and nitrate-nitrogen concentration of <0.05 mg/l. These levels are well below water quality standards. Therefore, no limits or monitoring for these, parameters are proposed in the permit. 6.10 Total Dissolved Solids (TDS) The guideline concentration of TDS in the Willamette River and its tributaries is 100 mg/l. Effluent concentration of TDS in the discharge from outfall 001 ranges from 600 to 900 mg/l. Background TDS concentration in the McKenzie River is thought to be below 40 mg/l. Using a simple mass balance calculation, the TDS concentration in the McKenzie River downstream of the outfall would increase by about 12 mg/l at critical low flow conditions and assuming complete mix. The resulting TDS concentration is well within Department guidelines. 7.0 NPDES Permit The following is a discussion of the proposed NPDES Permit for this facility. 7.1 Schedule A - waste Discharge Limitations Outfall 001: The existing permit specifies the following effluent limitations for BOD and TSS at outfall 001: Weekly Average Monthly Average Daily Maximum lb/day lb/dav lb/day Jun 1 - Oct 31: BOD ' 3,000 4, 500 TSS 10,000 20 ,000 Nov 1 - May 31: BOD 4,000 6 ,000 TSS 11,960 28 ,000

MW\WC10\WC10793.5. , - 11 The permittee had requested that the summer limit for BOD be specified as a monthly average instead Of a weekly average. A review of previously issued permits and; the evaluation reports does not provide a justification for a weekly average limit. A monthly average limit is consistent with EPA requirements and is being proposed in the renewal permit. The BOD and TSS limits are well below EPA effluent limitation guidelines for existing and new facilities. The existing permit also includes a condition which allows Weyerhaeuser to discharge higher BOD loads (5500 lb/day monthly average and 10,000 lb/day daily maximum) while dredging solids in the aeration basin or when the aeration basin temperature drops below 70 degrees F. Since the permit already recognizes that biological treatment facilities do not function as well at lower temperatures by including higher winter effluent limits for BOD and TSS, no additional allowance for BOD is included in the proposed permit. When dredging solids from the aeration basin, the Department recognizes that the potential to exceed effluent limits in the proposed permit does exist. However, a review of discharge monitoring reports Over the periods during which Weyerhaeuser has dredged the aeration basins do not show exceedances of the effluent limits in the proposed permit. Unless Weyerhaeuser demonstrates that higher BOD effluent limits are necessary for operating the aeration basins when dredging solids and that these higher loads would not contribute to water quality standards violations, no additional allowance for BOD will be included in the proposed permit. Other limits at outfall 001 include pH, temperature and turbidity. The pH limit is consistent with the. existing permit. For temperature, an interim limit of 100 degrees F is proposed. The permittee is required to address compliance with the temperature standards upon installation of the diffuser. A final effluent limit for temperature will be established after installation of the diffuser and completion of the mixing zone study. The turbidity limit in the permit reiterates the Department's standards which does not allow more than a 10% increase over background levels. Compliance with this standard will be determined at the edge of the mixing zone. The current dimensions of the mixing zone precludes a meaningful analysis of this standard. Once Weyerhaeuser installs the diffuser and determines the available dilution within the mixing zone, compliance with the turbidity standards will be determined. The permittee is required to monitor the stream to determine background turbidity levels.

MW\WC10\WC10793.5 - 12 - The mixing zone defined in the existing permit has been retained until the permittee completes construction of the proposed diffuser and conducts a mixing zone study. At such time, the Department will modify the defined mixing zone. Outfalls 002 and 003: These outfalls discharge non-contact cooling water. A monthly average flow limitation of 15 mgd and a daily maximum of 25 mgd for the combined discharge from outfalls 002 and 003 is included in the permit. For outfall 003, an monthly average flow of 3 mgd and a daily maximum of 5 mgd is specified. The permit includes a temperature limit at outfall 002 of 100 degrees F (monthly' average) and 115 Degrees F (daily Maximum) . These limits are the same as those in the existing permit. The upper pH limit was-i changed to 9.5 to acknowledge the impact of algal activity. The mixing zone defined in the existing permit has been retained until the permittee conducts a mixing zone study. At such time, the Department may modify the defined mixing zone. Outfall 003 discharges into the City of Springfield's storm water system. A pH limit of* 6,0 - 9.0 is specified at this outfall. Schedule A also specifies monitoring locations for each outfall and includes a re-opener clause which would enable the Department to modify effluent limits for temperature and turbidity, and the dimensions of the mixing zone at outfalls 001 and 002. 7.2 Schedule B - Minimum Monitoring & Reporting Requirements Monitoring for Flow, BOD, TSS, Color, Turbidity, Temperature, total phosphorus and pH are required at outfall 001. The frequency of monitoring for flow, pH, BOD, TSS, Color, temperature and turbidity are unchanged from, the existing permit. A monthly monitoring requirement for total phosphorus has been added. Whole Effluent Toxicity (WET) testing is also required at outfall 001. WET testing frequency , has been increased from semi-annually to quarterly. The existing permit required monitoring for settleable solids. This requirement has been deleted. Monitoring for TSS provides an adequate measure of the particulate matter in the effluent. Monitoring for flow, pH, and temperature are required at outfall 002 and 003. The permit also requires Weyerhaeuser to monitor the flow, temperature and turbidity in the McKenzie River. Weyerhaeuser is also required to report production data.

MW\WC10\WC10793.5 - 13 - 7.3 Schedule C - Compliance Schedules and Conditions Condition 1 in Schedule C requires the permittee to submit plans and specifications to the Department for the construction of a diffuser to increase mixing and dilution immediately below outfall 001;- The permittee is also required to submit an analysis of the dilution provided by the diffuser. Condition 2 requires the permittee to submit a benthic survey of the secondary channel of the McKenzie River below outfall 002 to determine the impact of the discharge on the benthic community. The permittee is also required to submit an evaluation of mixing below outfall 002 during low flow conditions to determine the mixing characteristics and available dilution. If the survey indicates that discharge "is having a significant impact on the benthic community or if evaluation of mixing below the outfall indicates that the discharge has the potential to violate water quality standards, the permittee is required to submit a plan and schedule to address the impacts of the discharge. Condition 3 requires Weyerhaeuser to provide a plan and schedule to the Department for preventing the discharge from outfall 003 from entering the secondary channel of the McKenzie River. Condition 4 requires the permittee to submit a plan and schedule to either eliminate the discharge of the wastewater from the hydraulic barker and the washdown from the particle board facility from the log pond or pretreat these wastestreams prior to discharge to the log pond. A final compliance date shall be established upon review of the selected alternative and the plan and schedule for implementation of the selected alternative. Condition 5 outlines the bioassay testing requirements for the discharge from outfall 001. Bioassay tests are to be conducted on a quarterly basis using three species and the dual end-point testing procedure. This condition also states that the Department may reduce the testing frequency after the evaluation of the testing results from a two-year period. Condition 6 outlines the groundwater monitoring requirements and Condition 7 requires the permittee to submit a management plan for land application of sludge in accordance with Department guidelines. 7.4 Schedule D - Special Conditions Condition 1 requires Weyerhaeuser to discharge sanitary wastewater into the City of Springfield's collection system.

MW\WC10\WC10793.5 •' - 14 - Condition 2 requires an adequate contingency plan for the prevention and handling of spills and unplanned discharges. Condition 3 requires Weyerhaeuser to manage sludge in accordance with the approved sludge management plan. Condition 4 requires the submittal of detailed plans and specifications for Department approval prior to constructing or modifying treatment facilities. Condition 5 is a statement regarding the proposed Old Corrugated Container facility. 8.0 Permit Processing/Public Comment/Appeal Process The beginning and end date of the public comment period, the date, time, and location, of the public hearing to be held to receive testimony regarding this permit, and the contact name and telephone number are included in the public notice shown as Attachment # 5. The permittee is the only party having standing to file a permit appeal. If Weyerhaeuser is dissatisfied with the conditions of the permit when issued, they may request a hearing before the Environmental Quality Commission or it's designated hearing officer, within 20 days of the final permit being mailed. The request for hearing must be sent to the Director of the Department. Any hearing held shall be conducted pursuant to regulations of the Department. Attachments

Figure 1 "* xrx^oc©ss i. jL.ow scnsiuSuic Table 1 - Production Data Table 2 .- Summary of wastewater treatment plant improvements Table 3 - Summary of annual discharge data Table 4 - Comparison of discharge characteristics with permit limits and federal effluent limitation guidelines Table 5 - NPDES Permit.violations at outfall 001 Table 6 - NPDES Permit violations at outfall 002 Attachment 1 - USGS location map Attachment 2 - Critical low flow in the McKenzie River Attachment 3 - Streeter-Phelps dissolved oxygen model Attachment 4 - McKenzie River Total Phosphorus Attachment 5 - Public Notice

MW\WC10\WC10793.5 - 15 ••WEYERHAEUSER SPRINGFIELD WATER FLOWS ALL FLOWS IN GPM 500 PROPOSED 13000+ EVAPORATOR 7000+ 003 OUTFALL icKENZIE. & TURBINE IVER COOLING COOLING 002 OUTFALL PONDS 1 3700+ 4300

AOUACULTURE ~1 r (future) RECYCLE 200 "^ ]_1 3500 " PAPER SCREEN, OAF EVAPORATION 2100

CLEAN, NON-CONTACT PROCESS WATER 800 STORM WATER

700 SEDIMENTATION f 7000 PULP I ASB CLARIFIER

400 WOOD 2100 RECOVERY

600 HYDRAULIC 200 BARKER 2900 J PARTICLE80ARD r SAWMILL 1p g 1 ii PLY-VENEER :tf FOREST PRODUCTS EVAPORATION JUS OCT -5 1992

WATER QUALITY DIVISION _n J OEPT, EMVIHOMMENTAL QUALIT' LOG POND 1800 ORM i 11200 »TER STORMWATER STORMWATER DITCHES DISCHARGES 001 OUTFALL

LOG STORAGE

MUNICIPAL ^j SANITARY SPRINGFIELD MUNICIPAL SEWER TREATMENT SYSTEM WATER ^ TABL1 1 Weyerhaeuser Paper Company Springfield Facility

Year Linerboard Production (tons/year)

1987 509,000 1988 516,000 1989 518,000 1990 541,000 1991 567,000 1992* 593,000 *Anticipated TABLE 2 Wastewater Treatment System Improvements

roveroents Completion Date Purpose ation basin baffles 1986 Increase retention time

rient addition and f986 Provide sufficient nutrient itaring for optimal operations

ation basin ^ flowmeter 1988 Monitor and increase flow cier improvements and capacity 'to ASB

tewater filters in 1989 Miter Whitewater to allow er mi 11 more recycle

trol charting of key 1989 Timely response to upsets, rating parameters following trends

bined effluent sump 1990 Allow more • recycle of piping effluent, system flexibility

boat 1990 Clean baffle, keep from sinking

d, nutrient, defoamer 1990 Spill containment itainment

i recovery sump, 1990 Better system balance, 'ker pipe relocation operation

i D.o. meter 1990 More reliable BOO- determinations

ration basin dredging 1991 Restore ASS retention time

san, line surge pond 1991 Restore capacity

i log pond sump station 1991 Upgraded control, capacity

'ge pond flowmeter 1991 Manage loading to ASB

: control of treatment 1991/92 Improved operation, item monitoring of treatment system

:uunt pump water removed 1992 Reduced hydraulic load to ASB aatraent system

3 outlet flowmeter 1992 Improved system management stall aerator #2 pond 1992 Prevent anaerobic conditions, odor 3 meter on ASB influent 1992 Manage BOD loading to ASB generation chemical reroute 1992 treatment system Remove flow from log pong w piping and pumping for 1992 itewater to pulping Increased Whitewater recycle

B dredging (continuing) 1992 Restore ASB retention time