File Number: 2142 Page 1 of 10 Pages
NPDES WASTE DISCHARGE PERMIT EVALUATION May 10, 1993
Department of Environmental Quality 811 Southwest Sixth Avenue, Portland, OR 97204 Telephone: (503) 229-5630
FACILITY: SOURCES COVERED BY THIS PERMIT:
The Amalgamated Sugar Company Outfall P.O. Box 1766 Type of Waste Number Location Nyssa, OR 97913 Beet Sugar Process 001(»)(b)" R.M. 387.0 Wastewater
* 001a Discharge of process wastewater to Snake River * 001b Discharge of process wastewater by seepage from ponds.
PLANT TYPE AND LOCATION: RECEIVING SYSTEM INFORMATION:
Beet Sugar Basin: Malheur River Processing and Refining Plant Sub-Basin: Snake River Nyssa, OR Stream: Snake River Hydro Code: 30=SNAK 2 387 D County: Malheur
EPA REFERENCE NO: OR-200252-6
Contents 1.0 Summary
2.0 Background *v 2.1 Facility Description 2.2 Wastewater Ponds 2.3 Solids Management and Utilization ^m X 3.0 Compliance History
3.1 NPDES Permit History 3.2 Effluent Limitations, Schedule A 3.3 Monitoring and Reporting, Schedule B 3.4 Compliance Conditions and Schedules, Schedule C 3.5 Special Conditions File Number: 2142 Page 4 of 10 Pages
2.2.1 Flume Pond Containment Unit
The Flume Pond Containment Unit covers an area of 17.2 acres. An estimated 7 MGD of process wastewater is discharged into the pond each day. The pond is used as a settling basin for wastewater solids removal from the closed loop product wash system. Solids are carry over farm soils and beet by-products.
2.2.2 Cooling Pond Containment Unit
The Cooling Pond Containment Unit covers an area of 44.44 acres. An estimated 8.5 MGD of process wastewater is discharged into the pond each day during the process season. The pond functions as an evaporative cooling basin for process water from the closed loop condenser cooling system. The pond also serves to contain the initial water inventory prior to the startup of the processing season.
2.2.3 Lime Pond Containment Unit
The Lime Pond Containment Unit has an area of 53.86 acres. Approximately 0.75 MGD of wastewater is discharged into the pond. The unit functions as a settling basis for solids (CaCOs) removal from the closed loop process water system. It also contains boiler and drier scrubber solids. Surge and excess water ponds are used for flow equalization and safety backup, respectively.
2.2.4 Ash Ponds Containment Unit
The Ash Ponds Containment Unit consists of two ponds having a total area of 2.5 acres. The ponds serve as settling basins for boiler ash and receive a daily discharge of 0.75 MGD.
2.3 Wastewater Discharge to Groundwater
The TASCO facility utilizes ponds to treat wastewater generated during the processing of the beets. These ponds are unlined and are located adjacent to the Snake River. It is estimated that a significant discharge of wastewater occurs as seepage from the ponds to the underlying aquifer.
2.4 Solids management and Utilization
The methods employed to process the beets generate a significant quantity of waste solids including, lime solids, dry beet pulp, and soil. The dry beet pulp has a beneficial use and is sold as animal feed. At this time, the lime solids and soil are staged on-site, however, management of the waste soEds is being re-evaluated by TASCO. File Number: 2142 Page 5 of 10 Pages
3.0 COMPLIANCE HISTORY
3.1 NPDES Permit History
The existing permit expired on June 30, 1991. The Department received a permit renewal application from TASCO on December 14, 1990. NPDES permit actions which have occurred for this facility are as follows:
Effective Date Action
December 4, 1973 Permit Issuance, Discharge limits were as follows: biochemical oxygen demand (BOD) 5,000 lbs/day monthly average (7,500 lbs/day daily maximum) through July 1, 1977, then changed to 4,500 lbs/day monthly average (6,200 lbs/day daily maximum).
Total Suspended Solids (TSS) 2,000 lbs/day monthly average and 3,000 lbs/day daily maximum. pH limits ranged between 6.5 to 8.5 Expiration Date: April 1, 1978
November 16, 1978 Permit Renewal. Outfall 001 discharge limits were as follows: BOD 4,500 lbs/day monthly average (6,700 lbs/day daily maximum) TSS 2,000 lbs/day monthly average (3,000 lbs/day daily maximum) In addition, pH limits were not to exceed 6.0 to 9.0, temperature not to exceed 32°Celsius, and fecal coliform 400/100 mis. Expiration Date: May 13, 1983
November 26, 1986 Permit Renewal. No changes in permit discharge limits. Schedule C conditions were revised to require hydrogeologic assessment and development of ground water monitoring plan. Expiration Date: June 30, 1991 File Number: 2142 Page 6 of 10 Pages
COMPLIANCE-EFFLUENT LIMITATIONS-MONITORING AND REPORTING
3.2 Effluent limitations, Schedule A
On October 29, 1991 a Notice of Noncompliance (NON) was issued for violations of effluent limitations. A leak in the lime pond caused wastewater from the TASCO facility to be discharged into the Snake River.
3.3 Monitoring and Reporting, Schedule B
On November 30, 1988 a NON was issued for failure to report the flow, BOD5, TKN, and pH of the influent to each pond and failure to report the monthly production of crystallized refined sugar.
On April 27, 1989 a NON was issued for failure to submit monitoring reports for the months of February and March, 1989.
On January 12, 1993 a NON was issued for late submittal of discharge monitoring reports (DMR) for the months of January, February, October, and November 1992. In addition, the DMR's for the months of October and November 1992 were incomplete, and a portion of the monitoring data was not submitted on Department approved forms.
3.4 Compliance Conditions and Schedules, Schedule C
On November 30, 1988 a NON was issued for failure to submit the results of a ground water monitoring program.
A NON was issued on March 4, 1992 for failure implement alternatives to control discharges of contaminants to ground water within the required compliance schedules.
3.5 Special Conditions
On January 31, 1992, a NON was issued for failure to address the requirements of the October 29, 1991, NON.
A NON was issued on March 4, 1992 in response to a multi-media inspection of the TASCO facility. The NON cited violations of ORS 468B.025(l)(a), ORS 468B.015(3), and ORS 459.215 for past releases into waters of the state and the imminent threat of a future release into the surface water and ground water from the pond wastewater system.
In addition, A Notice of Violation and Intent to Assess Civil Penalty was issued agabst TASCO on June 2, 1992 for violations documented in the NON's dated February 21, 1992 and March 4, 1992.
As a result of the March 4, 1992, Notice of Noncompliance TASCO and Department staff agreed to develop a Stipulation and Final Order (SFO) to resolve the timelines and necessary actions to bring TASCO into compliance with Oregon's water quality laws. A SFO was issued by DEQ on August 6, 1992 after reaching mutual agreement with the terms of the Order. The SFO established a compliance schedule and requirements for TASCO to submit an Engineering Feasibility Plan to address ground water contamination, waste treatment and disposal improvements at the Nyssa facility. The Department chose not to assess a civil penalty based on the agreement to develop and implement the terms of the SFO. At this time, TASCO has complied with the File Number: 2142 Page 7 of 10 Pages requirements of the compliance schedule established by the SFO. The Department believes that compliance with the SFO actions will significantly enhance TASCO's ability to attain regulatory compliance.
4.0 WATER QUALITY
4.1 Applicable Standards
TASCO discharges process wastewater through outfall 001a into the Snake River and through outfall 001b into the underlying aquifer. Facility monitoring records indicate that no wastewater discharges have occurred through outfall 001a during the preceding 12 years.
OAR 340-41-802 lists the beneficial uses for which water quality will be protected in the Malheur River Basin, which includes the Snake River. The beneficial uses include public domestic water supply, salmonid fish spawning and rearing, water contact recreation and aesthetic quality.
4.2 Temperature
Outfall 001 contains a temperature limit of 32° Celsius (90° Fahrenheit). No discharges of wastewater have occurred during the preceding 12 years.
4.3 Ammonia and Nutrients
No Waste Discharge Limitations are established for Ammonia and Nutrients;however, TASCO is required to monitor for Total Kjeldahl Nitrogen (TKN) on a weekly basis. Ammonia and Nutrient Waste Discharge Limitations may be established based on the results of the SFO required Engineering Feasibility Study.
4.4 Toxic Substances
The existence of toxic substances in the waste discharge is unknown. This issue is addressed in the proposed NPDES permit by requiring a study of the waste stream characteristics and the receiving stream to determine compliance with water quality basin standards .including toxic substances. The study is due December 31, 1994.
4.5 Mixing Zone and Zone of Immediate Dilution
OAR 340-4 l-805(4)(a) allows the Department to designate a portion of the receiving stream water to serve as a zone of dilution for wastewaters and receiving waters to mix. OAR 340-41-805(4)(b) allows the Department to suspend all or part of the water quality standards, or set less restrictive standards, in the defined mixing zone, provided that a number of conditions are met.
The existing NPDES permit for this facility specifies a mixing zone consisting of that portion of the Snake River contained in a 50 foot wide strip adjacent to the Oregon shore and extending from the point of discharge 1000 feet downstream. TASCO has not discharged wastewater through outfall 001 during the preceding 12 years and consequently the dimensions of the mixing zone have not been revised for outfall 001. Prior to the discharge of wastewater at outfall 001, TASCO must conduct a mixing zone study for Department review and approval. Based on the mixing zone study, the Department may modify the permitted mixing zone and zone of immediate dilution dimensions, as appropriate. File Number: 2142 Page 8 of 10 Pages
4.6 Bacteria/Bacterial Pollution
Outfall 001a and 001b contains a Fecal Coliform limit of 400/100 mis. This limit is based on the BCT guidelines for Beet Sugar Product Code of Federal Regulations (CFR) 409.12. Sanitary wastewater is discharged into the City of Nyssa municipal system.
5.0 NPDES PERMIT
The following is a discussion of the proposed NPDES Permit for this facility,
5.1 Face Page
TASCO discharges wastewater into the Snake River through surface discharge (outfall 001a) and' seepage from wastewater treatment ponds (outfall 001b).
5.2 Schedule A - Waste Discharge Limitations
Outfall 001a and 001b:
The proposed permit specifies the following effluent limitations for BOD and TSS at Outfall 001a and 001b:
Monthly Average Daily Maximum lb/day lb/day
BOD 4,924(a) 7,386(b) TSS 4,924(a) 7.386(b)
The proposed permit limitations for BOD and TSS are based on the BCT guidelines for Beet Sugar Product 40 CFR 409.12 with a processing level of 2,238,065 pounds per day (Ibs/d). The plant has a capacity of 2,800,000 lbs/d. Table 1 presents the average monthly sugar production for the years 1988 through 1992. File Number: 2142 Page 9 of 10 Pages
Calculations:
Effluent Limitations Monthly Average , Daily Maximum
BOD lb/1000 lb of raw product 3.3
TSS lb/1000 lb of raw product ii. * JL 3.3
(a) 2,238,065 lb x 2.2/1000 lb = 4,924 lb/day monthly average BOD and TSS (b) 2,238,065 lb x 3.3/1000 Ib - 7,386 lb/day daily maximum BOD and TSS
Other outfall limits include fecal coiiform, pH, and temperature.
The mixing zone as defined in the existing permit has been letained until the permittee conducts a mixing zone study. At such time, the Department may modify the existing mixing zone.
5.3 Schedule B - Minimum Monitoring & Reporting Requirements
Monitoring for flow, BOD, TSS, pH, temperature, fecal coliform are required at outfall 001a. The frequency of monitoring is unchanged from the existing permit.
Monitoring for flow, TSS, BOD, TKN, and pH are required for outfall 001b. These parameters are evaluated in the influent to the wastewater ponds.
The permit also requires TASCO to report the estimated volume of recirculated wastewater and of monthly sugar production. The permit requires TASCO to report the results of dike inspections conducted around the ponds three times daily.
Groundwater monitoring is included in the permit, although this monitoring will not become effective until the facility has an approved groundwater monitoring plan as required in Schedule C.
5.4 Schedule C - Compliance Schedules and Conditions
The Schedule C conditions have been written to incorporate the requirements of the SFO issued by the Department on August 6, 1992.
Condition 8 requires the permittee to commence groundwater monitoring upon Department approval of a Groundwater Monitoring Plan.
Condition 10 requires the permittee to submit a schedule of compliance to implement the approved wastewater treatment alternatives, groundwater contamination mitigation measures, and methods of solids management and disposal.
Condition 11 states that the schedule of compliance will be incorporated into Schedule C of the permit as a modification and/or Stipulation and Final Order. File Number: 2142 Page 10 of 10 Pages
5.5 Schedule D - Special Conditions
Condition 1. requires the facility to obtain Department approval prior to constructing or modifying the wastewater treatment facilities and/or groundwater monitoring system.
Condition 2. requires that sanitary wastewater be disposed into the City of Nyssa municipal system.
Condition 3. requires an adequate contingency plan for the prevention and handling of spills and unplanned discharges.
Condition 4. requires that waste solids be handled in an environmentally responsible manner to prevent the pollution and degradation of surface and groundwater.
Condition 5. requires an environmental supervisor be designated to coordinate and carry out all necessary functions related to maintenance and operation of waste collection, treatment, and disposal facilities.
Condition 6, requires the permittee to notify the Department's Eastern Region Office in accordance with the response times noted in the General Conditions of the permit, in the event of any malfunction so corrective action can be coordinated.
Prepared by: '^UA^JJ Date: 6^-^jf^
N^glu Hammond Eastern Region
Prepared by: /Vk^- C? J%%*n** Date: J~/sV /£?. / / Wayne C. Thomas Eastern Region
Attachment
Table 1 - Average Monthly Sugar Production 1988 - 1992 TABLE 1
THE AMALGATED SUGAR COMPANY AVERAGE SUGAR PRODUCTION LBS/DAY
1 ———••• " •'" "" —— »...••.••.' •••— ——.-»..—•—* •—-• • • ,,.»».•...«.». YEAR MONTH 1988 tm 1990 1991 1992 JAN - 1,990,900 1,349,567 *5,809,400 2,312,177 FEB - - _ 1,616,900 1,869,655 MARCH - - - - - APRIL - . . - - - MAY - - - - - JUNE - - - - _ JULY - - - - . - AUGUST - - - - - SEPT - - . - -
OCT 2,261,042 2,090,588 j£r}j£li.£/y J 1 *3 2,256,972 2,489,197 NOV 2,558,670 2,499,653 2,267,094 2,436,305 2,599,472 | ^ DEC 2,413,161 2,433,435 2,181,041 2,436,561 2,501,133 [ TOTAL 7,232,873 9,014,576 8,010,475 8,731,738 11,771,634
* not included in total as plant does not have capabilities to produce this quantity
Average Production of Sugar:
44,761,296 lbs / 20 = 2.238.065 Ibs/dav
93025