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. However, since discharges at Outfall No. 001 can be caused by large storm water runoff events, sometimes it is impossible to contain all water within the storage ponds. In addition, it is impracticable to establish a flow rate limitation during periods of discharge because ofthe potentially highly fluctuating flows. In turn, this makes establishing a thermal load veiy difficult and impracticable for the permittee. !, File A ..iber: 43230 Page 4 of 8 Pages

Therefore, the Department proposes to limit discharges to 75°F or less, except when storm events or other circumstances cause the storage capacity to be exceeded. When a discharge is necessary, the Department proposes a temperature limit for Outfall 001 not to exceed 75°F on a weekly average or the temperature of Upper Klamath Lake, whichever is greater. This is consistent with the temperature management plan proposed by the JWi Company. The Department believes that generally a storm water runoff would have a cooling effect on the discharge, but because, the storage canal could be thermally stratified, it is likely that the initial discharge will come from the surface ofthe pond which could easily exceed 75°F. The Department's temperature rule states that a discharge or other anthropogenic activity cannot cause a measurable increase in temperature when the lake is at or above 64* The Department has modeled the discharge and concluded tha. mere will be no measurable increase in temperature at the edge ofthe mixing zone when the discharge is 75°F. Further, obviously there will be no increase in temperature at the edge ofthe mixing if, when the effluent temperature exceeds 75°F, if effluent temperature does not exceed the lake temperature.

The permit requires that temperature be monitored during the most critical periods ofthe day between 2:00 p.m. and 4:00 p,m. Temperature measurements are not required if there are no discharges during the specified critical period ofthe day. The temperature ofthe lake shall be collected during the same time of day as the discharge when comparing effluent and lake temperatures.

Domestic Sewage & Process Wastewater

Domestic and process wastewater is currently discharged to the City of Klamath Falls Sewage Treatment Plant for treatment and disposal.

Log Deck Sprinkling Water Runoff (Retention Pond)

The facility recently began sprinkling their logs during dry months. A large retention pond has been constructed to re-circulate the water from the log deck for sprinkling. The facility will use the non-process wastewater from their storage ponds as make-up water for the log deck sprinkling. No discharge from the retention pond to surface water is currently allowed. A permit modification may be requested to authorize a discharge if JWi purchases or trades for an existing phosphorus waste load allocation from another point source in the basin or removes phosphorus from the log sprinkling water. Currently, there are only two point sources in the basin that have waste load allocations for phosphorus. These permitted sources are the Chiloquin Sewage Treatment Plant and the ODFW Klamath Hatchery. The retention pond shall not be dredged or drained without written Department approval on water quality controls. The general operation ofthe log pond shall be managed in a manner that prevents the creation of nuisance conditions and/or violations ofthe Department's groundwater quality rules (OAR 340-040).

Storm Water Runoff

The Company's current NPDES permit covers storm water runoff discharges at the facility. The storm water conditions will retain the benchmark values concept. The Department uses the concept of "benchmarks" that has been developed by the U.S. Environmental Protection Agency (USEPA) in their Multi-Sector NPDES Storm Water permit. The benchmark values are pollutant concentrations determined to represent a level of concern. The level of concern is a concentration at which a storm water discharge could potentially impair, or contribute to impairing water quality, or affect the designated beneficial uses including the protection of human health and aquatic life. The proposed benchmark concentrations are not effluent limitations and should not be interpreted as such. These values are merely levels which the Department uses to determine if a storm water discharge from the permittee merits further monitoring to insure that the facility has been successful in implementing the Best Management Practices (BMPs) in their Storm Water Pollution Control Plan (SWPCP). The benchmark values (, ; Fill , umber: 43230 Page 5 of 8 Pages are also viewed by the Department as a level, that if below, the permittee represents little potential for water quality concern.

The benchmark values were determined based upon existing standards or other sources to represent a level above which water quality concerns could arise. The renewed permit will retain the benchmarks values in the current permit. The following benchmarks are being proposed for the JWI permit:

Oil & Grease The current permit contains a 10 mg/l limitation for oil & grease. The new permit will retain the 10 mg/I as a benchmark value. pH The current permit contains a benchmark range between 6.0 and 9.0 standard units for pH. The new permit will retain the pH range as a benchmark.

Metals The current permit contains monitoring requirements for total copper, total lead, and total zinc. Based on the review of storm water data presented by the U.S. Environmental Protection Agency (USEPA) in the USEPA's Executive Summmy, Results ofthe Nationwide Urban Runoff Program, December 1983, the Department has concluded that copper, lead and zinc are metals of concern. The data showed that other metals did not exceed water quality standards, or when other metals had high values, copper, lead or zinc were also high. The USEPA's Executive Summary, Remits of the Nationwide Urban Runoff Program, December 1983, concluded that copper, lead and zinc were the most prevalent priority pollutants constituents found in runoff. Therefore, the proposed permit retains the existing benchmarks for copper, lead, and zinc. hi establishing the metal benchmarks, the Department used the chronic water quality standards and provided an allowance of 5:1 dilution. Chronic standards were chosen over acute standards because storm water discharges are commingling with the non-contact cooling water and boiler blowdown prior to discharging to the Upper Klamath Lake. A 5:1 dilution was factored into the chronic standard because the Upper Klamath Lake will provide additional dilution at Outfall No. 001. This allows for some dilution ofthe storm water discharge. The new permit contains benchmark values of 0.06 mg/l for total copper, 0.02 mg/l for total lead, and 0.5 mg/l for total zinc.

TSS TSS is a parameter of concern in storm water discharges because of its negative impact on receiving streams. TSS can cause turbidity and siltation problems that decrease fish spawning habitat. Its presence can also decrease oxygen and sunlight availability to aquatic life. In addition, metals toxic to aquatic life are often associated with TSS.

Being a parameter of concern as well as one ofthe few storm water parameters that is readily visible and controllable, the Department is maintaining the current TSS benchmark of 130 mg/l. This benchmark is based on a best management practice approach since there is no TSS water quality standard

Visual Observations The current visual obseivation requirements are proposed to be retained in the renewed permit.

In the current permit, if benchmarks are exceeded, the permittee shall submit to the Department at the time of monthly reporting a schedule for evaluating the cause ofthe exceedance for Department approval. Once the \ ; File Is. .tber: 43230 Page 6 of 8 Pages cause ofthe exceedance has been determined, the permittee shall submit a schedule for implementation of additional procedures to reduce storm water pollution. The permittee shall implement additional BMPs when existing BMPs are not adequate in reducing pollutant concentrations to below levels of concern. When existing BMPs are to be changed, the permittee shall submit a revised SWPCP to the Department that includes an implementation schedule for new or additional BMPs,

If benchmarks are exceeded as a result of off site storm water runoff entering the facility, the permittee shall collect up gradient storm water samples to demonstrate the exceeded benchmark value was outside their reasonable control. The pH benchmark will not be considered to be exceeded when the discharge is greater than 9.0 but less than the pH ofthe Upper Klamath Lake. Otherwise, the permittee shall implement additional BMPs when existing BMPs are not adequate in reducing pollutant concentrations to below levels of concern. The Department will document a violation for failing to adequately implement BMPs and housekeeping measures described in the SWPCP if a benchmark is exceeded on three consecutive sampling events at a permitted outfall.

Pentachlorophenol

Several years ago, JWi developed leaks in its wood treatment dip tanks, at their JELD-WEN of Oregon and Pelican Bay buildings, which were used to apply a pentachlorophenol distillate solution to some of its wood products. JWi is currently conducting a remedial investigation and feasibility study (RI-FS) as required by the Department's Environmental Cleanup Program, The resulting releases have been addressed through the cleanup program and are not covered under this permit There has been some concern that pentachlorophenol could migrate to JWi's wastewater system and be discharged through Outfall No. 001. This concern is being adequately addressed in the Department's Voluntary Cleanup Program.

Proposed Condition: ' Domestic and process wastewater shall be discharged to the City of Klamath Falls Sewage Treatment Plant for treatment and disposal. No process wastewaters shall be discharged directly to any surface waters. Process wastewater does not include non-contact cooling water, material storage yard runoff (either raw material or processed wood storage), boiler blowdown, treated groundwater from approved activities, and fire control water (40 CFR, Part 429.11(c).

Basis: This permit does not authorize the permittee to dispose of treated or untreated domestic waste or process wastewater at the JELD-WEN, inc., facility. All Domestic and process wastewater is to be discharged to the City of Klamath Falls Sewage Treatment Plant for treatment and disposal.

Monitoring and Reporting:

The Department proposes to retain the discharge monitoring at Outfall No. 001 for daily for flow, temperature,. pH, and floating solids and debris during days of discharge. Pentachlorophenol shall be monitored at Outfall No. 001 at a frequencyo f once per quarter.

Oil and Grease, pH, total copper, total lead, total zinc, total suspended solids and floating solids and debris are to be monitored once every two months throughout the year from each storm water outfall. The two months to be monitored once during the calendar year are: January & February; March & April; May & June; July & August; September & October; and, November & December. Storm water runoff monitoring shall be conducted at Outfall Nos. 001 and 003 and other storm water discharge points that are associated with industrial activities at this facility. All storm water discharge and monitoring points shall be identified in the SWPCP. JWi will continue to be required to report "No Discharge" for those periods when Outfall Nos. 001 and/or 003 do not discharge into the Upper Klamath Lake. Fill .timber: 43230 Page 7 of 8 Pages

The Department proposes to monitor the retention pond at Outfall No. 004 for pond freeboard and pH.

The Department proposes to monitor the retention pond at Outfall No. 004 for pond and pH.

Compliance Conditions and Schedules:

JWi will be required to be update their current storm water pollution control plan (SWPCP) to address changes in the storm water permitting conditions. The Department believes that 90 days after permit issuance is sufficient time to make modifications to the SWPCP and submit the plan for approval.

Special Conditions:

The Department proposes the following special conditions.

Proposed Condition: The Storm Water Pollution Control Plan shall include procedures for meeting any Oregon Administrative Rules (OARs) for storm water control specific to the applicable river basin. These procedures shall include a schedule of steps and key milestone dates for implementing materials management practices, and SWPCP plan components not already in place at the time the permit is issued.

Basis: Requires JWi to include requirements in their SWPCP that are specified for the Klamath Basin in the Oregon Administrative Rules.

Proposed Condition: Prior to constructing or modifying any wastewater control facilities, detailed plans and specifications must be approved in writing by the Department.

Basis: This is a requirement of state law ORS 468B.050.

Proposed Condition: An adequate contingency plan for prevention and handling of spills and unplanned discharges shall be in force at all times. A continuing program of employee orientation and education shall be maintained to ensure awareness ofthe necessity of good in-plant control and quick and proper action in the event of a spill or accident.

Basis: This condition is a standard condition included in most permits for industrial sources. This one is particularly important because storm water at the source will likely drain through the Company's Outfall Nos. 001 and 003 into the Upper Klamath Lake. The Company needs to be prepared to respond quickly and effectively to spills in order to maintain compliance with effluent limitations and to avoid significant impact on the beneficial uses ofthe Upper Klamath Lake.

Proposed Condition: Nothing in this permit shall constitute approval to dispose of substances defined as hazardous waste under Oregon Administrative Rule 340, Divisions 100 to 109 relating to hazardous waste or hazardous substances management. \ •' Filerv iber: 43230 Page 8 of 8 Pages

Basis: This condition is intended to make sure that hazardous wastes are not disposed of into the Company's wastewater control system that is covered by this permit.

Proposed Condition: Nothing in this permit prevents DEQ under other authority from requiring different monitoring locations, duration, frequency,an d parameters regarding pollutants and hazardous substances in the ponds, in groundwater and at Outfall No. 001.

Basis: This condition makes clear that nothing in this NPDES permit prevents the Department's environmental cleanup program, under separate authority, from requiring different monitoring locations, duration, frequency, and parameters regarding pollutants and hazardous substances in the ponds, in groundwater and at Outfall No. 001.

Proposed Condition: Treated groundwater may be discharged to the storage ponds. The treated groundwater discharges to the storage ponds shall comply with a Department Order issued by the Department's Cleanup Program. No groundwater discharges that violate water quality standards shall be discharged at Outfall No. 001.

Basis: This condition authorizes treated groundwater to be discharged into the storage ponds and at Outfall No. 001. No water quality standards shall be violated at Outfall No. 001. The Department's Cleanup Program will regulate the discharge to the storage ponds through a Department Order. %< <•-

TEMPERATURE MANAGEMENT PLAN JELD-WEN, inc. September 18,2003

Background:

JELD-WEN, inc. (JWi) operates a wood products manufacturing facility north of Klamath Falls, Oregon along the shore of Upper Klamath Lake. The JWi facility discharges non-contact cooling water, boiler blowdown and storm water runoff into the Upper Klamath Lake through a single one (1) foot diameter pipe discharge. The pipe is near the lake surface and at times above the surface approximately one (1) foot. The pipe discharges to an embayment ofthe lake that is approximately four (4) feet deep near the outfall. The mixing zone defined in the NPDES permit is that portion ofthe Upper Klamath Lake within 100 feet ofthe outfall

Effluent Characteristics:

Effluent discharges to the Upper Klamath Lake vary based on storm water runoff from no discharge up to 2 MGD during winter months. During the summer, however, the discharges to the lake is controlled and prevented by using the effluent for irrigation and make-up water for the log deck sprinkling yard. However, summer discharge could occur as a result of heavy rainfall event. Effluent temperatures are also highest during the summer; the highest value allowed to be discharged is 75°F or 23.8°C.

Upper Klamath Lake Characteristics:

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. 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. The letter from the U.S. Interior, Fish and Wildlife Service is attached.

Mixing Zone Analysis:

The Department ran CORMLX1, CORMIX3, and, PDS models to simulate a discharge of 75 °F when the Upper Klamath Lake was at or above 64 °F. The modeling suggested that adequate dilution likely 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 fact it is likely that adequate dilution is achieved closer to 60 feet from the outfall instead of at the edge ofthe regulatory mixing zone of 100 feet. A copy of a DEQ memorandum discussing the model outputs is attached.