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43230 Page 1 of 8 Pages NATIONAL POLLUTANT DISCHARGE Fik ,umber: 43230 Page 1 of 8 Pages NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM WASTE DISCHARGE PERMIT REVIEW REPORT Department of Environmental Quality 2146 NE 4th Street, Suite 104 Bend, OR 97701 Telephone: (541) 388-6146 Issued pursuant to ORS 468B.050 and The Federal Clean Water Act ISSUED TO: SOURCES COVERED BY THIS PERMIT: JELD-WEN, inc. Outfall Outfall P.O. Box 1329 Type of Waste Number Location Klamath Falls, OR 97601 Non-contact Cooling Water 001 Klamath Lake Boiler Blowdown, and Storm Water Runoff Storm Water Runoff 003 Klamath Lake Log Deck Sprinkling Water 004 Retention Pond PLANT TYPE AND LOCATION: RECEIVING SYSTEM INFORMATION: Wood Products Manufacturing Plant Basin: Klamath 3922 Lakeport Boulevard Sub-Basin: Upper Klamath Klamath Falls, Oregon Receiving Stream: Upper Klamath Lake LIDD 1218255422538-255-D County: Klamath EPA REFERENCE NO: OR-003101-1 Background: JELD-WEN, inc. (JWi) operates a wood products manufacturing facility north of Klamath Falls, Oregon along the shore of Upper Klamath Lake. At the time this document was drafted, the facility had 530 employees. The facility consists of a sawmill, planer mill, door plant, door skin manufacturing plant, and cutstock. The Company makes doors, door and window parts, door skins and lumber. The facility operates up to seven days a week with up to three shifts per day. Non-process wastewater from the JWi plant discharges into two elongated storage ponds. The second pond discharges into the Upper Klamath Lake at Outfall No. 001. The ponds are also used for settling and conveying storm water from onsite and offsite sources. The wastewater in the ponds may be used for irrigation in Department approved areas, log deck sprinkling, and/or for fire protection, as needed. All process wastewater generated at the facility are treated and recycled for re-use or discharged to the City of Klamath Falls sanitary sewage collection system along with the sewage generated at the facility. The Company only discharges non- process wastewater including non-contact cooling water, boiler blowdown, treated groundwater, and storm water runoff through Outfall No. 001. The Company eliminated Outfall No. 002 when they connected their sanitary wastewater to the City of Klamath Falls. Storm water runoff and snow melt also discharges through Outfall No. 003. Log deck sprinkling water is to be discharged to a retention pond at Outfall No. 004. The retention pond is designed and managed so there is no discharge to surface waters. FileN...iber: 43230 Page 2 of 8 Pages Compliance History: On September 21,1995, the Department and JWi entered into a Mutual Agreement and Order (MAO) to address a series of violations of JWi's NPDES Waste Discharge Permit and Oregon Administrative Rule. At the time this document was written, JWi had complied with the conditions ofthe MAO. The MAO and subsequent addendums have been terminated. On September 17,2003, the Department issued a notice of non-compliance to JWi for exceeding the temperature criteria as identified in their NPDES permit and temperature management plan on June 10, 2003. Approximately 3,000 gallons of water at 26.9°C (80.4°F) discharged to the Upper Klamath Lake. The reason for the heated discharge was due to the failure of a shutoff valve of a pump that regulates the pond level. The shutoff valve has been repaired. Effluent Limitations: The elongated storage ponds (where the non-process wastewater and storm water is held) are located on the west side ofthe facility. Water from these ponds is used for fire suppression, log deck sprinkling makeup water, and/or irrigation, as needed. During the summer months JWi regulates the elevation ofthe ponds by adding groundwater from the JWi Trend-West Well on an as needed basis. During the heavy periods of rainfall, storm water runoff causes the second pond to overflow into the Upper Klamath Lake. The elongated ponds act as a detention a facility that provides settling and cooling for the non-contact cooling water, boiler blowdown, and storm water runoff prior to discharging to the Upper Klamath Lake. Only groundwater from the Trend-West well and approved treated groundwater, non-contact cooling water, boiler blowdown, and storm water runoff are permitted discharges from the ponds to the Upper Klamath Lake. Storm water runoff and snow melt are the main factors that cause discharges to the Upper Klamath Lake from Outfall No. 001 when irrigation and log sprinkling activities are occurring. Boiler blowdown and non-contact cooling water can also result in discharges when irrigation and log sprinkling activities are not in season. The permit effluent limits are established at the Outfall No. 001 where the effluent enters Upper Klamath Lake. The storm water benchmarks apply to both Outfall Nos. 001 and 003 where the storm water enters the Upper Klamath Lake. The log deck sprinkling water limitations apply to where the water enters the detention pond at Outfall No. 004. Effluent limits in waste discharge permits must meet two basic criteria. The first criterion is that all discharges must meet technology-based standards as established by federal rale or state rale whichever is more stringent. The second criterion states that the discharge of wastewater cannot cause a violation of in-stream water quality standards (outside a defined mixing zone). Limitations more stringent than technology-based standards may be imposed if necessaiy to assure that water quality standards will not be violated. In addition, Oregon Administrative Rule (OAR) 340-041-0026(6) prohibits discharges to lakes unless otherwise granted an exception by the Department, In granting such an exception, the Department must make findings pursuant to OAR 340-041-0026(3). By issuance of this permit, the Department giants the exception based upon the following findings: 1. The Department finds, as further discussed below, that water quality standards will not be violated and, as a result, beneficial uses will be protected. 2. Although Upper Klamath Lake is water quality limited for pH, dissolved oxygen and chlorophyll, the Department finds that the discharges covered by this permit will not contribute to the problems for which the lake is listed. \ J Fill .umber: 43230 Page 3 of 8 Pages 3. Based upon the relative insignificance of the heat discharged under this permit, the Department finds that there will be no significant reduction in assimilative capacity ofthe lake. Other pollutants contained in the discharges are also insignificant and will not adversely affect the assimilative capacity ofthe lake. As stated above, the Upper Klamath Lake has been water quality limited for pH, dissolved oxygen and chlorophyll a (algal biomass) in Oregon's 1999 303(d). On August 7,2002, the USEPA approved the total phosphorus TMDL in the Upper Klamath Lake. The total phosphorus TMDL is intended to be a surrogate for addressing the parameters listed above. The JWi Company received a zero waste load allocation in the approved total phosphorus TMDL. The JWi discharges are not impacted by the approved TMDL since they do not have a significant source of nutrients. Non-contact Cooling Water & Boiler Blowdown Total Phoshorus The problems relative to total phosphorus, dissolved oxygen, and excessive algae are the result ofthe lake's eutrophication and, again, since the source is not discharging any significant nutrients, JWi is not believed to be contributing to the water quality standards violations of Upper Klamath Lake. pH The pH standard for the Klamath basin is 6.5 - 9.0. As mentioned above, the Upper Klamath Lake is eutrophic, at least in part due to natural conditions. In any case, the wastewater should not contain any significant levels of nutrients that would contribute to the eutrophication and, therefore, should not contribute to the high pH values ofthe lake. Historical monitoring ofthe non-contact cooling water discharges show that those discharges have been within the pH range between 6.0 and 9.0 standard units (s.u.). The boiler blowdown, on the other hand, has been documented to have a pH as high as 11.9 s.u.. The pH ofthe boiler blowdown discharge is adjusted prior to entering the storage pond. The pH monitoring and limitation is intended to apply to the boiler blowdown discharge where it enters the storage ponds. Due to the pH adjustment, available dilution, and detention available in the storage ponds, the boiler blowdown will not cause the pH levels to exceed 9.0 s.u. at Outfall No. 001. The permit also includes a storm water benchmark for pH at Outfall No. 001. Temperature Upper Klamath Lake is not currently listed water quality limited for temperature. The temperature standard for Upper Klamath Lake is 64°F because the basin has salmonid fish rearing designated as a recognized beneficial use to be protected. Two federally listed endangered species (the Lost River Sucker and Short Nose Sucker) also occupy the Upper Klamath River. Because JWi does discharge boiler blowdown and non-contact cooling water, the Department's technical staff ran CORMLX1, CORMLX3, and, PDS models to simulate a discharge of 75°F when the Upper Klamath Lake was at or above 64°F. The modeling concluded that adequate dilution exists to assure the discharge would not have the potential to add or contribute to violations ofthe Department's temperature standard outside the allowable mixing zone. In addition, the United States Interior, Fish and Wildlife Service summarized in a letter dated May 10,2001, to JWi that current data does not indicate that a discharge of 75°F would have a direct impact to the Lost River or Short Nose Suckers residing in the Upper Klamath Lake. Generally, discharge from outfall 001 can be controlled during the irrigation so that there are no discharges when Upper Klamath Lake exceeds the salmonid rearing standard of 64°F.
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