National Pollutant Discharge Elimination System PERMIT EVALUATION AND FACT SHEET

Oregon Department of Environmental Quality DEQ Western Region State of OtBgon 750 Front StNE, Suite 120 Department of Salem OR 97301 Environmental (503) 378-8240 Quality

Permittee: Frank Lumber Co., Inc. Drawer 79 Mill City, OR 97360 Current Permit: File Number: 30904 Permit Number: 101583 Expiration Date: April 30,2003 EPA Reference Number: OR000012-4 Source Contact: Randy Walker (503) 897-2371 Environmental Manager Source Location: 47983 Lyons-Mill City Drive Lyons, OR LLID 1230064446868 River Mile 32.5

Receiving Stream North

Proposed Action: Renew Permit Application Number: 985047 Date Received: October 30, 2002

Source Category NPDES Minor - Industrial

Permit Writer: Ben Maynard (503) 378-8240 ext. 282

Natural Resource Specialist INTRODUCTION Frank Lumber, owns and operates a lumber mill that generates process wastewater. The wastewater receives treatment prior to discharge to the North Santiam River in accordance with National Pollutant Discharge Elimination System (NPDES) Permit number 101583.

The existing permit expired on April 30, 2003. The Department received renewal application number 985047 from the Frank Lumber Co., Inc. on November 4, 2002. Because this renewal application was submitted to the Department prior to the expiration date ofthe permit, the permit shall not be deemed to expire until final action has been taken on this renewal application per OAR 340-045-0040.

This permit evaluation report describes the basis and methodology used in developing the permit. The permit is divided into several sections:

Schedule A - Waste discharge limitations Schedule B - Minimum monitoring and report requirements Schedule C - Compliance Condition and Schedule Schedule D - Special conditions Schedule F - General conditions

These sections are discussed in detail in this document.

This permit is a joint federal and state permit and subject to federal and state regulations. The Clean Water Act, the Code of Federal Regulations, and numerous guidelines of the Environmental Protection Agency (EPA) provide the federal permit requirements. The Revised Statutes, Oregon Administrative Rules, and policies and guidelines ofthe Department of Environmental Quality (Department) provide the state permitting requirements.

FACILITY DESCRIPTION The Frank Lumber facility is located in Lyons, Oregon, on" Lyons-Mill City Drive slightly west of Mill City (Figure 1). Its property totals 287 acres, 70 of which are occupied by the lumber mill. It was established in 1955. The mill is comprised of a sawmill, planing mill, log storage pond/firewater pond, log and wood product storage areas, and a fuel storage area with secondary containment. The sawmill and planing mill are dry processes. Water used in the mill is from a well and a spring on the facility property. There are three wastewater outfalls at the facility. Only one - Outfall 002 - discharges process-related water and is regulated under this permit. Outfall OOP. This outfall is for stormwater, primarily from upgradient forestland, and partially from storage and vacant areas at the south end of the facility. No process water discharges through this outfall. This is not covered under this permit, but under a General 1200-Z NPDES stormwater permit (DEQ Water Quality file 30904). The average flow of stormwater runoff is estimated to be 27,000 gallons per day (GPD). Outfall 002: This discharge water is comprised of log pond overflow, vehicle wash water, yard wash water, equipment cooling water, boiler blowdown, kiln condensate, and stormwater. The average flow of this outfall is approximately 425,800 GPD. Vehicle wash water and fuel- containment area runoff flow through oil/water separators prior to combining with the other

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 2 wastewaters for further treatment through a settling basin, a sedimentation structure/oil-water- separator, oil booms, a vegetated swale, then flows approximately 0.5 miles through a stormwater conveyance prior to discharging to river mile 32,5 ofthe North Santiam River. Outfall 003: Stormwater, primarily from upgradient forestland, and partially from storage and vacant areas at the north end of the facility. No process water discharges through this outfall. This is not covered under this permit, but under the stormwater permit. The average flow is estimated to be 58,000 GPD.

Compliance Issues During the permit cycle, Frank Lumber has received two Notices of Noncompliance (NONs) for exceeding the current permit limit for turbidity. However, after further review, these exceedances are assumed to be attributed to inaccuracies of the turbidimeter rather than a violation ofthe permit requirement.

Groundwater Issues Groundwater impacts are not expected from this facility.

Stormwater Run-off associated with vehicle wash water and the fuel containment area likely carries oil. However, water from both of these operations runs through oil/water separators, oil booms, and a vegetated swale prior to discharge. As mentioned above, other storm water, which is drainage primarily from facility storage areas and forest land, flows through outfalls 001 and 003 under a General 1200-Z NPDES permit.

Antidegradation An Antidegradation Review was performed for this discharge. The Department has determined the proposed discharge complies with the Antidegradation Policy for Surface Waters found in OAR 340-041-0004 (see Attachment A).

RECEIVING WATER

Receiving Stream Water Quality The North Santiam River is located within the Willamette Basin. State Water Quality rules designate the following beneficial uses for tributaries: public and private domestic water supply, industrial water supply, irrigation, livestock watering, fish and aquatic life, wildlife & hunting, fishing, boating, water contact recreation, aesthetic quality, and hydro power. Water quality standards were developed for the Willamette Basin to protect these beneficial uses (OAR 340-041). The Department is required to evaluate the quality of the state's water bodies every two years. Those water bodies that are found to be violating water quality standards are placed on the State's list of impaired water bodies known as the 303(d) list. The stretch ofthe North Santiam River to which the facility discharges is not on the 303(d) list.

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 3 PERMIT LIMITATIONS Two categories of effluent limitations exist for NPDES permits: 1) Technology-based effluent limits, and 2) water quality-based effluent limits, Technology-based effluent limits are developed by applying the national effluent limitation guidelines (ELGs) established by EPA for specific industrial categories. They were established to require a minimum level of treatment for industrial or municipal sources using available technology. Water quality-based effluent limits are designed to be protective of the beneficial uses of the receiving water and are independent of the available treatment technology.

Technology-Based Effluent Limits Discharge from Frank Lumber Company contains wastewater from one Timber Industry- Subcategory under the Code of Federal Regulations (CFR): Wet Storage (40CFR Part 429, Subpart I). The associated technology-based ELGs are 1) no debris, and 2) a pH within the range of 6,0 to 9.0. These limits are in the current permit, and are retained for the proposed permit.

Water Quality-Based Effluent Limits Temperature: The North Santiam River is designated for salmon and steelhead spawning use from September 1 through June 15 (OAR 340-04 l-0028(4)(a), and Figure 340 B) and core cold- water habitat year-round (OAR 340-04 l-0028(4)(b), and Figure 340A). The applicable temperature criterion for salmon and steelhead spawning use is 13 °C. This is based on a seven-day average maximum temperature. When the stream temperature is below the criteria, there is an allowable increase of 0.5 °C when 60-day average maximum background temperatures are between 10 °C and 12.8 °C or 1.0 °C when background temperatures are less than 10°C (OAR 340-041-0028(1 l)(b)). This allowable increase applies at complete mix with the waterbody. For the remainder of the year, the core cold water habitat temperature criterion applies, which is 16 °C. When the stream temperature is below the criteria, there is an allowable increase of 0.3 °C above background. This provision applies to all point sources taken together at the point of maximum impact. Permitting staff typically do not have the ability or the tools necessary to determine where the point of maximum impact is. This type of analysis is reserved for TMDL development. In lieu of a TMDL, the Department's policy is to apply this 0.3 °C at the edge of the mixing zone for individual point sources. An April 12, 2004 memo describes the temperature analysis to determine whether the discharge complies with the temperature standard (See Attachment B). The conclusion is that there is no reasonable potential to violate the temperature standard. Because no reasonable potential to violate was identified, no temperature limit is included in the proposed permit. However, effluent monitoring requirements are retained. If future effluent temperature data indicate potential to violate, or if a Waste Load Allocation is assigned, then the permit may be re-opened. pH: The permit limits pH to the range of 6.0 to 9.0. This is in the current and proposed permits. It is a wider range than the standard for this basin, which is 6.5 to 8.5, This is due to the

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 4 available dilution within the mixing zone. The stream provides ample dilution and buffering capacity to meet the pH standard at the edge ofthe mixing zone. Turbidity: The Department's existing turbidity standard prohibits an increase by more than 10% when comparing upstream concentrations to downstream concentrations. The current permit has this requirement at the edge of the mixing zone. Three years of turbidity data for this facility were reviewed. Some upstream/downstream differences were more than 10%, However, the turbidity levels in upstream and downstream samples were low, creating conditions in which very slight variations in turbidity measurements exceeded the limit. The magnitude of these variations was less than the ability of the instrument to measure accurately. Portable turbidity units are typically unable to measure below 1 nephelometric turbidity unit (NTU) accurately. The highest turbidity reading was 3.5 NTU. The highest upstream/downstream difference was 0.9 NTU, which is likely a reflection ofthe instrument's inability to measure low turbidity levels accurately rather than actual upstream/downstream differences. No actual upstream/downstream turbidity differences are apparent in the effluent data reviewed. No reasonable potential to violate the existing turbidity rule was identified. Because there is no reasonable potential, and the accuracy of turbidity meters makes it difficult to determine compliance under the turbidity levels found in the receiving stream, turbidity limits have been removed for the proposed permit. Turbidity monitoring requirements are retained though, Like for the other parameters, monitoring is to occur at the compliance point (immediately downstream of the vegetated swale). The Department is currently developing a new turbidity standard. When the new turbidity standard is established, the Department may evaluate whether the permit should be modified.

Floating Solids: The current limit does not allow visible discharge of this parameter, This limit is retained for the proposed permit. BOD and TSS: There are BOD and TSS monitoring requirements in the current permit, which are retained for the proposed permit.

Other Effluent Limits Flow: The proposed limit is for flow to be as low as practicable. This is in the current permit as well, and is adopted from the general NPDES permit for wet storage of lumber. The permittee requested an elimination of the limit and daily monitoring requirement. However, a review of the last three years of DMRs indicates the flow is significant and variable enough to necessitate a limit and monitoring/reporting requirement. The monitoring frequency in the proposed permit is daily, with an exemption for days the facility is not operating. Oil and Grease: A limit of 10 mg/l oil and grease is proposed for this facility's permit. The limit is in the current permit as well, It is slightly below the concentration at which oil and grease are visible on water as a sheen.

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 5 PERMIT DRAFT DISCUSSION

Face Page The face page of the permit describes the legal name of the facility, the type of wastewater generated at the facility, and the facility's outfall location where the wastewater enters into the State's receiving waters.

Schedule A, Waste Discharge Limitations The existing permit limits are summarized as follows: i FAisting Discharge Limits Outfall 002 Parameter 1 in i it Oil and Grease 10 milligrams per liici i.mg/1) Floating Solids No visible discharge permitted Debris* No discharge permitted pH Shall not be outside the range of 6.0 to 9.0 Flow As low as practicable as necessitated by rainfall Turbidity The effluent shall not cause the turbidity in the Santiam River to increase more than 10% as measured at the edge ofthe mixing zone. *Debris is defined as anyt ling that will be retained by a 5 mesh screen.

Proposed Permit Limits The proposed permit limits differ from the current ones in that the turbidity limit is eliminated. The proposed limits are tabulated below.

Proposed Discharge Limits Outfall 002 Parameter Limit Oil and Grease 1 :i pr'IIW.iii.s per liUT (:;:i-/|) Floating Solids No visible discharge permitted Debris* No discharge permitted pH Shall not be outside the range of 6.0 - 9.0 Flow As low as practicable+ *Debris is defined as anyt ling that will be retained by a 5 mesh screen. +Precipitation, operating conditions, and other circumstances permitting

Schedule B - Minimum Monitoring and Reporting Requirements Schedule B describes the minimum monitoring and reporting that is required to demonstrate compliance with the conditions of this permit.

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 6 The authority for the Department to require periodic reporting by permittees is included in ORS 468.065(5). The proposed monitoring frequencies for all parameters correspond to those of facilities of similar size and complexity in Oregon.

The proposed monitoring and reporting requirements differ from existing ones in that the turbidity requirements are eliminated. The following table lists the minimum monitoring and reporting that are contained in the proposed permit.

Proposed Minimum Monitoring; and Reporting Requirements Outfall 002 Item or Parameter Minimum Frequency Type of Sample Oil and Grease 1/week Visual Observation (Note 1) Floating Solids 1/week Visual Observation Debris 1 /week Visual Observation (Note 2) pH 1/week Grab Flow 1/day (Note 3) Measurement Turbidity 1/month Grab Temperature 1/month Measurement Biochemical Oxygen Demand 1/quarter Grab Total Suspended Solids 1/quarter Grab Note 1: If a visible sheen is present, a grab sample will be collected and analyzed for oil and grease. Note 2: Debris is defined as anything that will be retained by a 5 mesh screen. Note 3: An exemption from this requirement applies for days the mill is not operating unless an automated measuring device is installed.

Reporting The reporting period is the calendar month. Discharge monitoring reports must be received at the DEQ Regional office by the 15th day of the following month. Analytical results below the level of detection should be reported as not detected and the detection limit listed (e.g., a non- detect at a detection level of 2,0 mg/l would be reported as "<2.0 mg/l").

Schedule C - Compliance Schedule

The proposed permit requires the permittee to upgrade its flow measuring equipment within 12 months of permit issuance, to provide data that is representative of actual discharge,

Schedule D - Special Conditions 1, The proposed permit includes a requirement for sanitary waste to be disposed of/treated in the facility's on-site septic system, 2, There is a requirement for a contingency plan for preventing and handling spills and unplanned discharges, 3, There is also a requirement for the permittee to properly notify the Department in the event a spill or unplanned discharge occurs,

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 7 4. There is a requirement for the permittee to obtain Department approval prior to modifying its wastewater treatment system. 5. There is a requirement for the permittee to continue to follow its Stormwater Pollution Control Plan, and submit any modifications to the Plan to the Department. 6. If effluent temperature data indicate potential to violate criteria, or if a Waste Load Allocation is assigned, then the permit may be re-opened to included new permit limits, monitoring, or other requirements.

Schedule F, NPDES General Conditions All NPDES permits issued in the State of Oregon contain certain conditions that remain the same regardless of the type of discharge and the activity causing the discharge. These conditions are called General Conditions. These conditions can be changed or modified only on a statewide basis. The latest edition ofthe NPDES General Conditions is December 1, 1995 and this edition is included as Schedule F ofthe draft permit.

Section A contains standard conditions which include compliance with the permit, assessment of penalties, mitigation of noncompliance, permit renewal application, enforcement actions, toxic discharges, property rights and referenced rules and statutes. Section B contains requirements for operation and maintenance ofthe pollution control facilities. This section includes conditions for proper operation and maintenance, duty to halt or reduce activity in order to maintain compliance, bypass of treatment facilities, upset conditions, treatment of single operational events, overflows from wastewater conveyance systems and associated pump stations, public notification of effluent violation or overflow, and disposal of removed substances. Section C contains requirements for monitoring and reporting. This section includes conditions for representative sampling, flow measurement, monitoring procedures, penalties of tampering, reporting of monitoring results, additional monitoring by the permittee, averaging of measurements, retention of records, contents of records, and inspection and entry. Section D contains reporting requirements and includes conditions for reporting planned changes, anticipated noncompliance, permit transfers, progress on compliance schedules, noncompliance which may endanger public health or the environment, other noncompliances, and other information, Section D also contains signatory requirements and the consequences of falsifying reports. Section E contains the definitions of terms used throughout the permit.

PERMIT PROCESSING/PUBLIC COMMENT/APPEAL PROCESS The beginning and end date ofthe public comment period to receive written comments regarding this permit, and the contact name and telephone number are included in the public notice. The permittee is the only party having standing to file a permit appeal. If the Permittee is dissatisfied with the conditions of the permit when issued, they may request a hearing before the EQC or its 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 ofthe Department.

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 8 Attachment A: Antidegradation Review Sheet FOR A PROPOSED INDIVIDUAL NPDES DISCHARGE

1. What is the name of Surface Water that receives the discharge? North Santiam River Briefly describe the proposed activity:

Is this review for a renewal OR new (circle one) permit application? Go to Step 2.

2. Is this surface water an Outstanding Resource Water or upstream from an Outstanding Resource Water? Yes. Go to Step 5. No. Go to Step 3.

3. Is this surface water a High Quality Water? Yes. Go to Step 8. No. Go to Step 4.

8. Will the proposed activity result in a Lowering of Water Quality in the High Quality Water? Yes. Go to Step 9. No. Proceed with Permit Application, Applicant should provide basis for conclusion. Go to Step 24.

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 9 24. On the basis of the Antidegradation Review, the following is recommended: _XX_ Proceed with Application to Interagency Coordination and Public Comment Phase. Deny Application; return to applicant and provide public notice.

Action Approved

Section:

Review Prepared By: Ben Maynard Phone: (503) 378-8240, ext. 282_ Date Prepared: April 9, 2004

Please provide the following information and submit with the completed application form to: Department of Environmental Quality Water Quality Division-—Surface Water Management 811 SW Sixth Avenue Portland, Oregon 97204-13 90

Name: Randy Walker Name of Company: Frank Lumber Co., Inc., Address: Drawer 79 Mill City. OR 97360

Phone: (503)897-2371. Fax:

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 10 Attachment B

^m^. Oregon Department of Environmental Quality Memorandum

To: Ben Maynard Date: April 12,2004 From: Steve Schnurbuseh DEQ Subject: Frank Lumber Temperature Analysis State of Oregon Department of Environmental Quality I performed a temperature analysis to determine whether Frank Lumber's discharge complied with the Department's temperature standard. Frank Lumber discharges to the N. Santiam River near Mill City. Two numeric temperature criteria apply to the N. Santiam depending on the time of year. From June 16 - August 31, the core cold water habitat criterion of 16°C applies, The remainder of the year, September 1 - June 15, the spawning criterion of 13°C applies. The river is currently meeting both these criteria.

The temperature standard allows for slight increases in stream temperaturewhe n the stream is in compliance with the temperature criteria. When the core cold water criterion applies, a 0.3°C increase above background is allowed for all sources taken at maximum impact. Determining where the maximum impact occurs from all sources is typically a TMDL exercise and permitting staff do not have the expertise or the tools available to perform this type of analysis. In lieu of this, the Department's policy is to apply the 0.3°C increase at the edge ofthe mixing zone. In the case of Frank Lumber's discharge, there are no significant discharges of thermal load within at least five miles upstream or downstream from their discharge. There are a few general storm water, filter back wash, and WPCF permits within several miles of Frank Lumber, but none of these would contain significant sources of heat. When the spawning criterion applies, the rule allows the entire stream to increase by 0.5°C when the background temperature is between 10- 12°C and 1°C when the temperature is below 10°C.

There was a limited amount of data for the temperature analysis so some conservative assumptions were made. Daily stream flow data was available from a USGS stream gage near Mehama, a few miles downstream from the site. This flow data was used to calculate critical low flows for applying the standard. The monthly 7Q10 critical low flow was used for the months of June - August when the core cold water criterion applied because this criterion is based on a seven-day average temperature. The monthly harmonic mean flows were used the remainder of the year because the spawning criteria is based on a longer term average - on the order of a month or more. Daily effluent flow data was available from the facility's discharge monitoring reports. Grab sample temperature data was available for the N. Santiam River at Gates, a few miles upstream from the site. A single grab sample was available for each month dating back to 1997, The data indicates the river meets the temperature criteria year round. Only a single effluent temperature measurement was available for this analysis. This value was taken during the summer and was 21°C. The facility also measured upstream and downstream

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 11 temperature. These results demonstrated there was no measurable change in stream temperature at the edge ofthe mixing zone.

Using the data described above, an analysis was performed to determine the increase in stream temperature on a monthly basis at various dilution ratios. The minimum monthly stream temperature was used to provide the most conservative analysis. The effluent temperature was assumed to be 10°C higher than the stream temperature. There was only one effluent temperature measurement available and it was measured in the summer. The temperature was 21°C and the river is typically around 13°C during the summer. This equates to an 8°C difference. Based on this, a conservative value of 10°C above background was used to estimate effluent temperature year round. This temperature data was combined with daily effluent and stream flow data to calculate the temperature increase. Allowing the discharge to mix with 10% ofthe stream flow resulted in calculated increases in stream temperature of no more than 0.2°C. Allowing the effluent to mix with 25% ofthe stream flow resulted in a maximum increase of about 0.08°C.

The temperature standard allows for an increase of a minimum of 0.5°C at complete mix when the spawning criteria apply. It allows for an increase of 0.3°C at the edge of the mixing zone when the core cold water criteria apply. Based on the analysis above, a mixing zone that allowed mixing with 10% ofthe stream flow not cause a reasonable potential to violate the temperature standard, A mixing zone that allowed for mixing with 10% ofthe stream would meet our mixing zone rule and be protective ofthe beneficial uses within the N. Santiam River.

Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 12 Figure 1

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Permit Evaluation Report and Fact Sheet Frank Lumber Co., Inc. Page 13