ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-3 30/2-7 8 -00!
Compliance Monitoring
Scott Pap er Company
Oconto Falls, Wisconsin
November 1977)
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER,COLORADO
a n ° /A**
REGION V. CHICAGO f
JANUARY 1978
-------
ENVIRONMENTAL PROTECTION AGENCY
Office of Enforcement
EPA-330/2-78-001
COMPLIANCE MONITORING
SCOTT PAPER COMPANY
Oconto Falls, Wisconsin
[November 1977]
January 1978
National Enforcement Investigations Center - Denver
and
Region V - Chicago
-------
CONTENTS
I INTRODUCTION 1
II SUMMARY AND CONCLUSIONS 4
WASTEWATER TREATMENT FACILITIES 4
FLOW MONITORING 5
SAMPLING TECHNIQUES 5
ANALYTICAL TECHNIQUES 6
WPDES PERMIT COMPLIANCE 6
III RECOMMENDATIONS 8
IV SURVEY METHODS 10
OUTFALL 001 10
OUTFALL 002 11
OUTFALL 003 11
OUTFALL 004 12
LAGOON UNDERDRAIN FLOW 12
OUTFALLS 005, 007, 008 and 009 13
OCONTO RIVER 13
V SURVEY RESULTS 14
TEMPERATURE, pH AND FLOW 14
BOD AND TSS 16
DISSOLVED OXYGEN 18
FIGURE
1 Discharge Locations 2
TABLES
1 Summary of Field Analysis and
Analytical Results 15
2 Summary of Field Analysis and
Analytical Results, Oconto River
and Cooling Water Discharges 17
3 Biochemical Oxygen Demand Loads 19
4 Total Suspended Solids Load 20
APPENDICES
A Presurvey Reconnaissance
B Chain-of-Custody procedures
-------
I. INTRODUCTION
In September 1977, the Environmental Protection Agency (EPA),
Region V requested the National Enforcement Investigations Center (NEIC)
to conduct a survey of Scott Paper Company, Oconto Falls, Wisconsin, to
determine compliance with its Wisconsin Pollutant Discharge Elimination
System (WPDES) permit. A reconnaissance inspection was conducted
October 17 and 18, 1977, to evaluate process operations, wastewater
treatment facilities, monitoring locations, permit schedule compliance,
and the self-monitoring and laboratory procedures [Appendix A].
The Scott Paper Company operates an ammonia-base acid sulfite pulp
mill and paper mill producing 120 tons/day of bleached sulfite pulp.
Wood is debarked, chipped, chemically digested, and bleached. Most of
the resulting pulp, as well as some purchased pulp, is processed into
paper. A portion of the pulp is transferred to other Scott Paper Company
mills.
All wastewater is discharged directly into the Oconto River which
subsequently enters the Green Bay of Lake Michigan [Figure 1]. Stream
temperature is monitored at a bridge (Central Avenue) approximately
0.4 km (1/4 mile) upstream of the plant discharges. Stream dissolved
oxygen concentration is monitored six miles downstream at the power
generation station, Stiles Pond, and river flow measurements are taken
from the USGS gaging station at Gil let, Wisconsin.
On December 27, 1974, with the concurrence of EPA Region V, the
Wisconsin Department of Natural Resources (DNR) issued a WPDES Permit
No. WI-0000531. The permit was modified by DNR, with the concurrence of
EPA Region V, on November 7, 1975 and expired on June 30, 1977. On
September 19, 1977, the DNR modified the permit applying limitations
-------
-N-
008
009
005
LAGOON
STILES POND
PULP M ILL
C LA R IF IER
Figure 1. Discharge Locations Scott Paper Company, Oconto Falls, V/i scons in rv>
-------
3
which represented best practicable control technology currently available
(BPT) and which was designed to maintain the DO level in the Oconto
River at a minimum of 3.0 mg/1. Scott Paper Company filed a petition on
November 7, 1977, requesting a review of the reasonableness of and
necessity for the terms and conditions set forth in the modified permit.
A public hearing was held to review the permit on December 13, 1977.
The hearing examiner found that the BPT limitations are applicable to
the Scott Paper Company and ruled that DNR does not have the authority
to extend the date for compliance with these limitations beyond July 1,
1977, the statutory final compliance date. The examiner ordered that
the following permit final effluent limitations be effective July 1,
1977 through May 30, 1978.
+ Applied to the total of the four process wastewater discharges,
tt Reduced to 4,380 lb/day maximum daily allowable from the facility
in order to maintain a minimum DO of 3.0 mg/1 in the Oconto
River as required by Section NR 104.04(3) of the Wisconsin
Administrative Code.
* English and metric values are specified in the permit; the
conversion value used (English to metric) in the permit is
All other provisions of the permit issued September 19, 1977, are
effective as originally issued. Specifically, the permit prohibits
discharge of floating solids or visible foam in other than trace amounts.
Effluent Characteristics
PH
Limitations *
Quantity-kg/day (lb/day)
Average Maximum
1,964 (4,380) 3,767 (8,400)++
2,970 (6,624) 5,537 (12,348)
5.0 (minimum) 9.0 (maximum)
0.448.
Compliance monitoring was conducted by NEIC personnel during the
period November 7-14, 1977. Results of this monitoring are discussed
herein.
-------
II. SUMMARY AND CONCLUSIONS
As a follow up to the presurvey reconnaissance inspection conducted
October 17-18 at Scott Paper Company, Oconto Falls, Wisconsin, a full
scale compliance monitoring survey was conducted November 7-14, 1977.
The findings and conclusions of these two evaluations are discussed
below.
WASTEWATER TREATMENT FACILITIES
Wastes consisting of process water from the paper machines, bleach
washer, decker, cleaners and screens, and the woodroom are treated in a
primary clarifier prior to discharge through Outfall 001. Spent sulfite
liquor and strong wash from the pulp mill are held in a 0.8 ha (2 acre)
lagoon.
Construction of a new activated sludge treatment facility to treat
all plant wastewaters has started and is scheduled for completion in
July 1978 [Appendix A]. This treatment methodology is secondary treatment,
in conformance with EPA recommended BPT for pulp and paper mills. This
construction program was initiated in 1972 and included plans for a
joint treatment system with the City of Oconto Falls. Delays were
encountered in getting necessary funding for the City portion of the
plant. In March 1977, Scott Paper Company decided not to proceed with
the joint venture and to construct its own on-site waste treatment
system. The DNR denied approval of construction plans because of specific
design deficiencies. Subsequent to start of construction, Company
officials indicated that these deficiencies had been corrected and the
modified plans were resubmitted to DNR. However, DNR policy is not to
approve plans once construction has started.
-------
5
FLOW MONITORING
The Company monitors flow from Outfalls 001 and 003 by means of
Parshall flumes and head recorders. A V-notch weir, used to monitor the
underdrain flow from the lagoon, was submerged during the monitoring
survey.
Measurements made during the presurvey reconnaissance showed the
Parshall flumes to be installed as recommended by the Water Measurement
i
Manual. Head measurements were made during the monitoring survey and
compared to the recorder. These readings showed the flumes to be measuring
flow accurately. Company calibration procedures for these devices were
observed and were found to be adequate. Flow from the underdrain of the
lagoon was calculated based on the time required to fill the pump well,
an adequately accurate measuremert.
SAMPLING TECHNIQUES
The Company obtains daily composite samples at Outfalls 001 and 003
by means of DeZurik piston-type automatic samplers; these samplers
collect samples flow proportionally. Composite samples were not being
collected from the lagoon underdrain flow.
The Company samples obtained by the DeZurik samplers were not
stored under refrigerated conditions during the compositing period.
They were collected in a metal pot which is exposed to the ambient
temperature of the sampler shed. This deviation from EPA standard
procedures^ could significantly decrease the concentration of BOD^ and
TSS found in these samples. Therefore, all DNR data should be considered
low.
1 Water Measurement Manual, U.S. Department of Interior, Bureau of
Reclamation, Second Edition, Revised Reprint, 1974.
t Requires refrigerating samples to <4.0°C during collection.
-------
6
ANALYTICAL TECHNIQUES
A laboratory evaluation was made during the presurvey reconnaissance
[Appendix A]. Discrepancies were noted in the BOD analysis; these
discrepancies included holding times (48 hours) exceeding the recom-
mended <6 hours and dilution water not being incubated at 20°C for at
least 24 hours prior to initiating analysis. As a result of not incubating
the dilution water, the initial blank readings were either higher or
lower than those for 20°C.
WPDES PERMIT COMPLIANCE
Spent sulfite liquor (SSL) was not being discharged through Outfall 004
during the monitoring survey. However, an underdrain system, installed
to relieve pressure on the lagoon floor caused by a natural spring, was
discharging during both the presurvey reconnaissance inspection and the
monitoring survey. Although this discharge is not authorized by the
permit, composite samples were collected.
The permit limits the total daily discharge of BOD and TSS from
Scott Paper Company to 1,964 kg (4,380 lbs) and 5,537 kg (12,348 lbs)/day,
respectively. Survey results show that the Company was discharging from
Outfalls 001, 003 and the lagoon underdrain 16,000 to 25,000 kg (35,200 to
55,000 lbs)/day and 2,130 to 4,370 kg (4,690 to 9,630 lbs)/day BOD and
TSS, respectively. These data show the Company is discharging 8 to 12
times the allowable BOD loading.
The permit limits the pH of the discharge to a range of 5.0 to 9.0.
During the monitoring period, the pH ranged from 2.0 to 7.0 and 3.1 to
3.9 at Outfalls 003 and the lagoon underdrain, respectively. Of the 167
measurements made at each outfall, 108 at Outfall 003, and 167 at the
lagoon underdrain were below 5.0.
-------
7
Since there is very little difference in the BOD concentration
between the plant intake water and the intake screen wastewater and
cooling water discharges (Outfalls 005, 007, 008, and 009), it is con-
cluded that these discharges are in compliance with permit limitations.
Foam is not to be discharged in other than trace amounts. Foam
layers were observed in Outfalls 001 and 003.
Continuous DO monitoring at a depth of 3.0 to 4.6 m (10 to 15 ft)
is required at Stiles Pond dam. Observations and calibration checks
made during the monitoring survey showed that the monitoring is done at
a depth of 1.5 m (5 ft), and that the Company meter was reading con-
sistantly higher than actual measured levels by 1 to 2 mg/1. The Company
is required to curtail discharges in order to maintain the DO in the
Oconto River at Stiles Pond at >3.0 mg/1; thus the error in readings
could be significant when the lower DO levels are approached (i.e., the
actual DO of the pond could be 1 mg/1 before curtailment occurred).
Measurement of river flow based on a 24-hour average is required.
These flow values also determine daily BOD loadings which can be dis-
charged into the river. The Company receives measurements only once/day
(between the hours of 9:00 a.m. to 11:00 a.m.) from the USGS gaging
station at Gillet, Wisconsin for this determination. Heavy rainfalls or
other runoff events upstream will affect a single reading, thus an
instantaneous flow reading is not considered to be representative of a
24-hour flow average. Therefore, the Company is in violation of this
Special Condition of their permit.
-------
III. RECOMMENDATIONS
The following measures are recommended to correct the deficiencies
found during the presurvey reconnaissance and monitoring survey.
1. Initiate interim procedures (water recycle, curtail production,
storage, etc.) as required to reduce the BOD loads discharged to
the Oconto River. Take the steps necessary to complete construction
and startup of the activated sludge wastewater treatment facility
as soon as possible.
2. Provide neutralization of wastewaters discharged through Outfall 003
such that the pH is within the permited ranged of 5 to 9.
3. Reduce the amount of foam being discharged through Outfalls 001 and
003 to trace amounts as specified in the WPDES permit. Possible
methods available for meeting this requirement are the use of water
sprays, surfactants, reduction of turbulence, etc.
4. Refrigerate or ice the sample collection containers so that the
sample temperature is held at <_4°C during the compositing period.
5. Revise the maximum BOD sample holding time between sample collection
and set up for incubation to 6 hours after collection. Incubate
the BOD dilution water at 20°C for 24 hours to reduce the apparent
errors in blank samples.
6. Relocate the DO monitor at Stiles Pond to a depth of 3.0 to 4.6 m
(10 to 15 ft). Perform daily calibration of the DO monitor using
the Azide-Winkler method to eliminate the current 1 to 2 mg/1
calibration error.
-------
9
7. Calculate daily average river flows on the basis of a minimum of 24
measurements taken hourly.
It is further recommended that the Company upgrade its laboratory
quality control program including the analysis of replicate TSS samples
and use of blanks in these analysis. The Company should also routinely
participate in EPA and/or other check sample programs.
-------
IV. SURVEY METHODS
During the presurvey reconnaissance, the adequacy of the Company
effluent monitoring and flow measurement procedures were determined at
each outfall. All wastewater discharges were monitored November 7-14,
1977. Established chain-of-custody procedures were followed in the
collection of all samples and field data and in the analysis of all
samples, with the exception of the minor deviations noted in Appendix B.
Duplicate and reference samples were also analyzed daily to insure the
accuracy of the data. The Company sampling locations, the adequacy of
the Company effluent flow measurement procedures, and the NEIC monitoring
procedures used during the survey are discussed below by outfalls.
OUTFALL 001
The Company sampling location for Outfall 001 is at the discharge
from the primary clarifier. The Company samples this discharge by means
of a DeZurik automatic flow proportional sampler located beside the
Parshall flume inlet contraction. Inspection by NEIC personnel revealed
that Company samples were not preserved by refrigeration, but were
stored at ambient conditions during collection. Measurements of the
Parshall flume were taken during the presurvey reconnaissance and the
flume was found to be installed according to recommendations of the
l
Water Measurement Manual. A recording device was properly located at
this outfall to continuously measure and record head levels. Periodic
checks made during the survey found this device to be measuring accurately.
Samples were collected by means of a SERCO automatic sampler during
the survey at the Company sampling location. This sampler was iced to
provide a temperature reduction of the samples to <4.0°C. Samples were
-------
11
collected each hour and analyzed on site for pH and temperature. Flows
were determined by means of hourly readings obtained from the Company
flow recorder.
OUTFALL 002
Wastewaters originating from the debarking and chipping operation
in the woodroom were previously discharged through Outfall 002. These
wastes were monitored with a Parshall flume and DeZurik automatic sampler.
During the entire NEIC survey period these wastes were being treated in
the primary clarifier and the residual discharged through Outfall 001.
OUTFALL 003
Spent sulfite liquor (SSL) and acid evaporator condensate is dis-
charged through this outfall. Company monitoring is done by a Parshall
flume and DeZurik automatic sampler located approximately 10 m (30 ft)
upstream from the end of the discharge pipe and beside the converging
section of the flume. Observations during the survey showed the flow
was being recorded using the top of the foam, instead of the reference
head. This was pointed out to the Company and corrective action was
taken.
During the NEIC survey, samples were collected by hand each hour,
aliquoted proportionally to flow into a 9.5 liter (2.5 gallon) cubitainer
and stored in ice. Grab samples were collected each hour and analyzed
on site for pH and temperature. Flow volumes were determined each hour
from the recorder installed on the Parshall flume.
-------
12
OUTFALL 004
Concentrated SSL is held in a 0.8 ha (2 acre) lagoon for discharge
during the cold weather, high river flow period (November-June). This
discharge was identified by the Company as Outfall 004. At the time of
the NEIC survey the normal wastewater discharge had been curtailed.
According to Company officials, this curtailment was due to low DO
levels at Stiles Pond.
LAGOON UNDERDRAIN FLOW
Lagoon leakage collected in an underdrain system is discharged into
the Oconto River through an open channel. A pumping system had been
installed on this channel to return this flow back to the lagoon and
prevent any discharge. The pump was not being used during the survey;
the flow was entering the receiving water (Oconto River). The Company
had a 90° V-notch weir on the discharge from the pump wet well. As the
flow exceeded the weir's capacity the device could not be used to measure
flow.
Flow was measured during the survey by pumping out the wet well and
measuring the required time to fill. A head reference point was estab-
lished and readings were taken hourly to determine any change in the
flow. This measurement procedure was repeated during the course of the
study and the results show that the discharge flow rate was constant
throughout the survey.
A 200 ml portion of sample was collected at approximately the same
location as the head measurement point hourly and composited in an iced
9.5 liter (2.5 gallon) container. Temperature and pH measurements were
made hourly on this grab sample.
-------
13
OUTFALLS 005, 007, 008 and 009
Discharges from Outfalls 005, 007, 008 and 009 consist of intake
screen wastewater, and gas evaporator cooling water. Grab samples for
BOD and TSS were collected twice from Outfalls 005 and 008 and once from
Outfalls 007 and 009. Measurements of pH and temperature were made each
time a sample was collected. The samples were collected from each
individual discharge point just prior to the common header box.
OCONTO RIVER
The temperature and pH of the Oconto River at Central Avenue Bridge
[Figure 1] were measured daily between the hours of 9:00 a.m. to 11:00 a.m.
(i.e. the time specified in the permit). In addition, two grab samples
.ere collected for BOD analysis.
Samples for DO were collected just upstream of the power dam operated
by Oconto Electric Cooperative at Stiles, Wisconsin at the location and
depth Scott Paper Company monitors for DO levels and also at the depth
~
required by the permit. All samples were collected with an A.P.H.A.
dissolved oxygen sampler and manganous sulfate and alkali-iodide-azide
reagent added on site. Titration with sodium thiosulfate solution was
performed at the NEIC mobile laboratory located in Oconto, Wisconsin,
within one hour of collection.
Inspection of Company records revealed that an instantaneous flow
reading from the USGS gaging station at Gil let, Wisconsin, is being
collected daily during the hours of 9:00 a.m. to 11:00 a.m. The permit
requires that 24 hourly readings be taken to calculate the daily average
flow.
* The Company samples from a depth of 1.5 m (5 ft), the permit requires
samples to be collected at a depth of from 3 to 4.6 m (10 to 15 ft).
-------
V. SURVEY RESULTS
TEMPERATURE, pH AND FLOW
During the NEIC survey, at Outfall 001 the pH ranged from 5.4 to
8.0, temperature from 11.5° to 17.5°C, and flows from 30.9 m3 x 103
(8.2 mgd) to 37.1 m3 x 103 (9.8 mgd) [Table 1]. Foam layers, as re-
corded in the field data record log book, were present in the discharge
throughout the monitoring survey.
As noted before, Outfall 002 was not discharging at the time of the
monitoring survey.
During the survey, at Outfall 003 the pH ranged from 2.1 to 7.3
with 108 of the 167 measurements below the minimum permit limitation of
5.0 [Table 1]. The temperature ranged from 12.0° to 52.0°C and the flow
from 2,100 m3 to 3,320 m3 (0.56 to 0.88 mgd). Foam layers, as recorded
in the field data record log book, were present in the discharge.
Outfall 004 was not discharging during either the presurvey recon-
naissance or the monitoring survey.
A discharge from the lagoon underdrain was noted during the presurvey
reconnaissance and monitored during the survey. The pH ranged from 3.1
to 3.9 and temperature from 10.5° to 13.°C [Table 1]. The flow remained
constant at 770 m /day (0.20 mgd). This discharge, according to Company
and DNR records, has been discharging since September 26, 1977. As
discussed previously this discharge was not included in the permit.
-------
Table 1
SUMMARY OF FIELD ANALYSIS AND ANALYTICAL RESULTS
SCOTT PAPER COMPANY
November 7-13, 1977
Station
Date+
November
1977
- Flow
m /daw mgd
lO"3
pH Range
(S.U )
No. of Readings
<5.0/total Rdgs
Temp °C
(Range)
Biochemical Oxyqen Demand
mg/1 kg/day lbs/day
Total
mg/1
Suspended Solids
kg/day lbs/day
Outfall 001
7-8
37.1-9.79
5.4-7.6
0/24
lb.0-16.0
150
5,560
12,200
61
2,260
4,980
8-9
35 4-9 35
5.6-8.0
0/24
15.0-17.5
190
6,730
14,800
76
2,690
5,930
9-10
33.6-8 86
5.8-6.8
0/24
14.0-17.0
220
7,380
16,300
72
2,410
5,320
10-11
33 1-8.75
6.5-7.1
0/24
14 5-16.0
150
4,970
11,000
85
2,810
6,200
11-12
32.9-8.69
6.4-7 2
0/24
12 5-15.0
170
5,600
12,300
93
3,060
6,740
12-13
33 3-8.80
6.4-7 2
0/24
13 0-14.5
140
4,670
10,300
130
4,330
9,540
13-14
30.9-8.16
6.4-7.0
0/24
11 5-15 0
150
4,640
10,200
70
2,030
4,470
Outfall 003
7-8
2.31-0.610
2.5-7.1
6/24
13.0-47.0
1300
3,000
6,620
54
125
270
8-9
2.22-0.587
2.5-7.3
7/24
12.0-20 0
ht
tt
tt
l-t
U
tt
9-10
2 10-0.555
2.1-7.0
3/24
12.0-17 0
720
1,510
3,330
47
100
220
10-11
3.04-0.803
2 2-6 2
22/24
14.0-38.0
2600
7,910
17,400
69
210
460
11-12
3 06-0.809
2.3-4.8
24/24
21.0-38.0
2600
7,970
17,600
14
40
90
12-13
2.99-0.790
2.1-5.7
22/24
21.0-52.0
3100
9,280
20,400
6
18
40
13-14
3 32-0.876
2 6-3.6
24/24
20 0-35.0
3100
10,300
22,700
25
80
180
Lagoon
7-8
0.772-0.204
3.1-3.9
24/24
11.5-12.5
13,000
10,030
22,100
21
16
36
Underdrain
8-9
0 772-0.204
3 2-3.7
24/24
11 5-12.0
12,000
9,260
20,400
28
22
48
Flow
9-10
0.772-0.204
3.2-3 8
24/24
10 5-12.0
10,000
7,720
17,000
21
16
36
10-11
0.772-0.204
3.2-3.8
24/24
11.0-13.0
11,000
8,490
18,700
32
25
54
11-12
0 772-0 204
3.3-3.7
24/24
10 5-12.5
12,000
9,260
20,400
20
15
34
12-13
0.772-0.204
3.2-3.6
24/24
11.0-12 0
10,000
7,720
17,000
27
21
46
13-14
0.772-0.204
3.2-3 9
24/24
11.0-12.0
13,000
10,030
22,100
24
19
41
t Samples collected during the hours 0800-0800.
tt Sample contaminated during collection, therefore, results not reported.
-------
16
Grab samples for pH collected from Outfalls 005, 007, 008 and 009
were compared with samples collected from the Oconto River at the Central
Avenue Bridge just upstream of the mill at the plant water intake. As
Table 2 shows, there is very little difference between the intake pH and
cooling water discharge pH.
BOD AND TSS
During the reconnaissance inspection, Company officials, when
questioned, explained that the lagoon underdrain discharge consisted of
spring water and estimated the BOD concentration at 60 mg/1. The
appearance of the discharge was very similar to the contents of the SSL
storage lagoon (dark brown) and had a strong sulfur odor. A grab sample
was collected during the reconnaissance and shipped to NEIC laboratory
in Denver, Colorado for BOD analysis. The results of the analysis
(8,800 mg/1) indicate that this discharge was not wholly spring water
but lagoon wastewater [Appendix A].
A system present on this outfall to pump any leakage back to the
lagoon when a continuous conductivity monitor indicates that leakage is
taking place was not operating during either the presurvey reconnaissance
or the monitoring survey. According to Company officials this system is
operable, however, it has not been Company policy to return these wastes
to the lagoon unless the DO at Stiles Pond is less than 3.0 mg/1. An
inspection of Company records showed that monitoring personnel had been
aware of this discharge since September 26, 1977. The Wisconsin DNR
have stated that they had been notified of the discharge and that they
consider this an unpermitted discharge.
As previously noted, Outfalls 002 and 004 were not discharging
during the survey.
-------
Table 2
SUMMARY OF FIELD ANALYSIS AND ANALYTICAL RESULTS
OCONTO RIVER AND COOLING WATERS DISCHARGES
SCOTT PAPER COMPANY
November 7-13} 197?
Station
Date
1977
Time of
Col lection
PH
(s.u.)
Temp.
°C
B0D5
mg/T
*
Flow
(cfs)
Outfall 005
11/7
1150
6.4
7.0
<
2.0
_
11/8
1315
6.6
7.5
<
2.0
-
Outfall 007
11/7
1155
6.3
15.5
<
2.0
-
Outfall 008
11/7
1155
6.3
15.0
<
2.0
-
11/8
1317
6.6
10.0
<
2.0
-
Outfall 009
11/7
1156
6.6
40.0
<
2.0
-
Oconto River
11/7
1100
6.3
6.0
<
2.0
836
at Central
11/7
1200
6.3
6.0
-
-
Avenue
11/8
1050
6.2
6.0
<
2.0
830
11/8
1330
6.6
6.5
-
-
11/9
0925
6.0
6.0
-
830
11/10
0925
6.6
6.5
-
819
11/11
0935
7.2
5.0
-
802
11/12
0933
7.1
3.0
-
755
11/13
0930
7.5
2.0
720
* Flow taken from USGS gaging station near Gillet, Wisconsin at 9:00 a.
to 10:00 a.m. daily.
-------
18
The total BOD waste loads discharged from Outfalls 001, 003 and the
lagoon underdrain flow ranged from 16,000 kg (35,200 lbs) to 25,000 kg
(55,000 lbs)/day [Table 3]. This is 8 to 12 times the permitted loading
of 1,964 kg (4,380 lbs)/day. The total TSS load ranged from 2,130 kg
(4,690 lbs) to 4,370 kg (9,630 lbs)/day [Table 4]. These loads meet the
daily maximum limitation (5,537 kg to 12,348 lbs/day).
As Table 2 shows, there is very little difference between the
intake water (Oconto River) and cooling water discharges for BOD.
DISSOLVED OXYGEN
As previously mentioned, the permit requires Scott Paper Company to
continuously monitor DO concentrations at Stiles Pond. In order to
evaluate the accuracy of these measurements, discrete samples were
collected from depths of 1.5 m (5 feet) and 3.0 m (10 feet)^ and com-
pared with the Beckman DO analyzer installed at Stiles Pond. Results of
these comparisons are shown below.
Scott
Time Paper Co. NEIC NEIC
Date Collected 5' depth 5'depth 10'depth
11/11/77 1330 8.80 7.65
11/12/77 1400 10.40 8.30 8.40
11/13/77 1400 10.40 8.35 8.35
The Company instrument department reportedly calibrates the DO
monitor Thursday of each week. The normal calibration was accordingly
performed by Scott Paper Company personnel on November 10, 1977.
Calibration was made by referencing the monitor to a portable Yellow
+ The Company collects samples from a depth of 1.5 m (5 feet)3 the
permit requires a sample depth from 3.0 to 4.5 m (10-15 feet) be used.
-------
19
Table 3
BIOCHEMICAL OXYGEN DEMAND LOADS
SCOTT PAPER COMPANY
November 7-13, 1977
Date+
Outfall 001
Outfall 003
Lagoon Underdrain
Flow
Total I
Di scharge
November
kg/day
1bs/day
kg/day
1bs/day
kg/day
lbs/day
kg/day
lbs/day
7-8
5,560
12,200
3,000
6,620
10,030
22,100
18,600
40,900++
8-9
6,730
14,800
ttt
9,260
20,400
16,000
35,200++
9-10
7,380
16,300
1,510
3,330
7,720
17,000
16,600
36,600++
10-11
4,970
11,000
7,910
17,400
8,490
18,700
21,400
47,100++
11-12
5,600
12,300
7,970
17,600
9,260
20,400
22,800
50,300++
12-13
4,670
10,300
9,280
20,400
7,720
17,000
21,700
47,700++
13-14
4,640
10,200
10,300
22,700
10,030
22,100
25,000
55,000++
7-Day Ave.
5,650
12,400
6,670
14,700
8,940
19,700
20,000
44,700
t Sample collected between the hours of 0800-0800.
tt Exceeds maximum permit limitation of 1,964 kg (4,380 lbs)/day.
ttt Sample contaminated during collection, therefore, results not reports.
-------
20
Table 4
TOTAL SUSPENDED SOLIDS LOAD
SCOTT PAPER COMPANY
November 7-13, 1977
Date+
Outfall 001
Outfall 003
Lagoon Underdrain
Flow
Total 1
Discharge
November
kg/day
lbs/day
kg/day
1bs/day
kg/day
lbs/day
kg/day
lbs/day
7-8
2,260
4,980
125
270
16
36
2,400
5,290
8-9
2,690
5,930
tt
22
48
2,710
5,980
9-10
2,410
5,320
100
220
16
36
2,530
5,580
10-11
2,810
6,200
210
460
25
54
3,040
6,710
11-12
3,060
6,740
40
90
15
34
3,120
6,860
12-13
4,330
9,540
18
40
21
46
4,370
9,630
13-14
2,030
4,470
80
180
19
41
2,130
4,690
7-Day Ave.
2,800
6,170
95
210
19
42
2,900
6,390
t Scanples collected between the hours of 0800-0800.
tt Sample contaminated during collection, therefore} results not reported.
-------
APPENDIX A
PRESURVEY RECONNAISSANCE
-------
21
Springs Instrument Company DO analyzer. During an interview with Company
personnel, it was discovered that the continuous monitor at Stiles Pond
is located at a depth of 1.52 m (5 ft) rather than 3.05 to 4.57 m (10-15
ft) required by the permit. The Company acknowledged the discrepancy
and indicated that they intend to relocate the monitor to the proper
depth sometime during the summer of 1978.
-------
APPENDIX A
PRESURVEY RECONNAISSANCE
SCOTT PAPER COMPANY
Oconto Falls, Wisconsin
October 17 and 18, 1977
PARTICIPANTS
D. A. Cusano, Scott Paper Company
Michael Goodnough, Scott Paper Company
John Schmitt, Scott Paper Company
Bob Meyer, Scott Paper Company
Danforth Bodien, EPA, Region X
William Miner, EPA, Region V
Francis Early, NEIC, Denver
David Vietti, NEIC, Denver
Laurence Walz, NEIC, Denver
GENERAL
The Scott Paper Company, Oconto Falls, Wisconsin, operates an
ammonia-base acid sulfite pulp mill and paper mill producing 120 tons/day
of bleached sulfite pulp. The principal raw material is eight-foot
softwood and hardwood logs. The softwoods include balsam and hemlock;
the hardwoods are generally aspen, poplar or birch. The usual mixture
is 60% softwood and 40% hardwood with no control over the wood species
within each category.
Other raw materials include liquid sulfur, liquified ammonia (NH^)
liquid sulfur dioxide (SO2), liquid chlorine, burned lime (CaO), and
various resins, surfactants, and cleaners. The liquid sulfur and liquified
ammonia are used to make cooking acid. The sulfur is pumped into hot
storage. The ammonia is dissolved in water to form ammonium hydroxide
(NH^OH) which is then placed in storage. A supply of liquid SO2 is
maintained so that pulp production can continue when repairs are made
-------
A-2
on the sulfur burner or acid gas cooler. Bleach liquor (CaOCl) is made
from the liquid chlorine and burned lime.
Wood is debarked, chipped, and fed along with cooking acid into
digestors. The digested pulp is bleached, washed, and processed either
into lap pulp or toweling paper. The lap pulp is shipped to other Scott
Paper Company Mills or stored for later use on site.
The Company discharges approximately 12 mgd of wastewater to the
Oconto River through four outfalls. The Wisconsin Department of Natural
Resources (DNR) issued a National Pollutant Discharge Elimination System
(NPDES) permit which was subsequently modified September 19, 1977. The
Company requested a hearing to review the reasonableness of the September 19,
1977 modified permit. Following the hearing, by a stipulation between
DNR and Scott Paper Company dated December 13, 1977, the permit was re-
modified as contained in Attachment 1.
WATER SUPPLY
Process water for the pulp mill and paper mill is obtained from the
Oconto River. Water purchased from the City of Oconto Falls is used for
domestic purposes and for the paper machines during the summer months
when turbidity in the Oconto River does not allow this source to be used
for certain applications. Well water is used solely in the acid plant.
WASTE TREATMENT
Sanitary wastes are conveyed to the Oconto Falls wastewater treat-
ment plant for disposal.
Process water from the paper machines, bleach washer, brown stock
washer, decker, screens and cleaners, and the wood room are treated in a
-------
A-3
clarifier prior to discharge to the Oconto River. This treatment consists
of mechanical bar-screen and a 125 foot diameter center-feed up-flow
clarifier with a sidewall depth of 12 feet. The clarified wastewater is
discharged through outfall 001. The sludge removed is dewatered in a
Byrd centrifuge and hauled to a landfill licensed by the State of Wisconsin.
Spent sulfite liquor (SSL) and strong wash from the pulp mill are
discharged into a 0.8 ha (2-acre) lagoon. The purpose of this lagoon is
to hold this high-BOD wastes (approximately 10,000 mg/1 BOD) for discharge
during the cold weather, high river flow months of November through
June, as required by the NPDES permit.
Construction has begun on new wastewater treatment facilities
designed to meet the permit limits. This treatment system was not
approved by the DNR because of preliminary design deficiencies. Ac-
cording to Company officials these design deficiencies were corrected
subsequent to start of construction. DNR's policy is not to approve
plans after construction has started.
SELF-MONITORING
Effective July 1, 1977, the Company was required to monitor its
waste discharge in accordance with Part II, Page la of the permit as
modified [Attachment 1]. Observations made of the monitoring procedures
and the discharges are discussed below.
DeZurik Automatic Samplers have been installed on outfalls 001 and
003. These samplers are flow proportional, but refrigeration is not
provided for the sample as required by the permit. Therefore, analytical
results (BOD, TSS) are considered to be questionable.
-------
A-4
Flow measurement devices were evaluated arid found to be meeting
design criteria. The devices in use were as follows:
001 discharge - Two-foot Parshall flume and circular chart recorder
002 discharge - Six-inch Parshall flume and circular chart recorder
003 discharge - Six-inch Parshall flume and totalizing circular chart
recorder
004 discharge - Orifice meter and circular chart recorder (not evaluated)
A discharge from the lagoon underdrain, which is not included in the
permit, was discovered during the inspection. Company officials related
that the discharge was spring water and they estimated the BOD concentration
at 60 mg/1. Since the lagoon was constructed on top of a natural spring,
an underdrain system had been installed to relieve pressure on the
lagoon floor. A pumping system was installed on this drain to pump any
leakage back to the lagoon. According to Scott monitoring personnel,
this system was functional, however, it has been Company policy not to
return leakage to the lagoon unless the DO monitor located at Stiles
Pond indicated low readings (<3.0 mg/1). Because the visual appearance
of the "spring" discharge was very similar (dark brown, characteristic
of sulfite liquor) to the lagoon contents and carried a noticeable SSL
odor, a grab sample for BOD was collected and iced, and the flow rate was
estimated. The sample was transported to the NEIC laboratory, Denver,
Colorado. Due to available air transportation the recommended holding
time (6 hours for BOD analysis) was exceeded by one hour and ten minutes.
The high concentration found (8,800 mg/1) may have actually been slightly
higher, but is substantially greater than the 60 mg/1 estimated by the
Company. The Wisconsin DNR was contacted by NEIC personnel and DNR
personnel confirmed that they had been notified of the existence of this
discharge on September 26, 1977.
An evaluation of laboratory procedures used by Scott for monitoring
purposes was conducted and results are summarized in Attachment 2.
-------
A-5
RECOMMENDED NEIC FOLLOW-UP MONITORING
NPDES Permit Compliance Monitoring
Monitoring will be conducted at Outfalls 001, 002, 003, 004, and
for any lagoon seepage for a minimum of seven consecutive days. In
addition grab samples will be collected at Outfalls 005, 007, 008 and
009 to ascertain the presence or absence of process wastes. Twenty-four
hour composite samples for BOD and TSS will be collected using hourly
flow-weighted aliquots. SERCO automatic samplers will be used at the
001 discharge. The remaining samples will be collected by hand. Temperature
and pH measurements will be performed during the course of the survey.
Temperature measurements at the Center Street Bridge and the DO of the
Oconto River at Stiles Pond will be performed during the monitoring
survey.
Sample collection and analysis will be performed with Chain-of-
Custody procedures (i.e., each sample will be tagged, custody sheet
completed, field data recorded in bound log book, etc.). Quality assurance
procedures will be followed for all phases of the survey.
-------
ATTACHMENT 1
WPDES PERMIT
-------
/^/4-X /: Permit Ho. HI- CW531
Application Ho. HI-070
2-7
PERMIT TO DISCHARGE UNDER THE
WISCONSIN POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of Chapter 147, Wisconsin Statutes,
SCOTT PAPER COMPANY
/
is permitted to discharge from a fa^fwty located at
OCOHTD FALLS, WISf.OHSJtf
to the Hconto River
in accordance with the effluent limitations, monitorinq requirements and
conditions set forth in Parts I and II heresf.
This permit shall become effective on the date of signature.
This permit to discharge shall expire at midnight, Novenber 30, 1979
Permittee shall not discharge after the date of expiration. If the pertn
wishes to continue to discharge after this expiration date he shall file
application for reissuance of hi; perrrit in accordance with the require™
of Chapter f.R 200, Wisconsin Administrative Code, at least 180 days prioi
this expiration date.
State of Wisconsin OeMrtrosnt of natural Resources
For the^Secretary Yj
Thonas A. Kroehn
Arininistrator
Division of fnvironnental Standards
Orinlnally issued on the 27th d?«v of December, 1974
Itodlfied this 19 day of September, 1977
Modified by Order on December 20, 1977
cs vr-
-n ^
o
o t-O
r"
*
^ —;
rn
? O
O CD
o ZX
50
•V _
o c
^ ¦-
cr>
—K ,'
rn .
r- t
-o
rn
o
rn
¦X.
Hi"
*
f 4
rn
30
-------
ttiYt 1, Pete i of 5
Wisconsin Permit Ho. V3-0G0D531;
G£K£RAL CONDITIONS
1, Ccmpllance
All tfTscHFrei? Authorized herein shall be consistent with the terns and
wmditlons of this permit, The discharge of my pollutant Identified in this
penr.it nare fre^eMly than or at a level 1n excess of that authorized shell
constitute a violation of the'pettriit«
?. Adverse I^ct
The permittee shiTTl take ell reasonable steps to minimize gj\y adverse iispact
on waters of the State results fro* nweeopliftnot Kith any effluent limita-
tions specified in this permit, including such special or additional fconltorir^
es ray be rcqyirc-d by the Dfpsrtrsent &r may be necessary to determine the
nature and intact of the nonc&pplylng discharge,
3. Reaped Substances
Solids, sludge-Si filter backlash or other pollutants reeved frora or resultir.3
from treatrent or control of wastewaters or Intake waters shall be stored &r>d
disposed of in a marvr^t- such as to prevent any pollutant from such Arterial s
frts catering t^e water? of the SUte. Und of treatment plant solids
and sludges shall be either at a site or operation licsreed by the Department
imder Chapter ffii )$!< Wisconsin Administrative Code* or 1n accordance with a
sludge disposal plan approved by the Department.
4. Right of Entry
The permittee shall &11c^f ai/thoriied representatives of the De^rtp>ent of
Katvral Resources, end the AAMMstratDr of the United SUtes Envirorssental
Protection Agency or Ms authorised representatives, upon the presentation
of credentials
a, To wtwr upon the permittee's prenises where an effluent source is
located or 1n wMeh any records &re retired to be kept under the
terras and conditions of. this permit; and
b. At reasonable fines to have access to and copy tny records required to
be kept under the terns end conditions of this penr.it; to inspect Any
t®n1terin$ equiprent or monitoring trathod required 1ft Ihii permit; and
to any wastewater*.
5. Eertrlt Verification
After notice and opportunity for a hearing ss provided in Section 147.031
Wisconsin Statutes, this permit may be isodificd, susper4ed, or revoked in
trfrcle or in part during its term fc>r cayse including, but not limited to,
the folloKth$;
a. Violation of any tews or conditions of this permit;
-------
Part I. Page 2 of 5
b. Obtaining this pervit by misrepresentation or failure to disclose fully
ell relevant facts; or
c. A charge in any condition that reouires either a temporary or peroanent
reduction or elimination of the permitted discharge.
6, Toxic Pollutants
Nothing in this pemit shall be construed to authorize the discharge of any
toxic pollutant or corrbi nation of pollutants in anounts or concentrations
which exceed any applicable toxic effluent standard or prohibition, including
eny schedule of compliance specified in eny such effluent standard or prohibi-
tion, promulgated under Section 147.07(1), Wisconsin Statutc-s.
If I toxic effluent standard or prohibition* including any schedule of
cotrplisnce specified 1n such effluent standard or prohibition, is prorogated
under Section 1<7,C7(1), Wisconsin Statutes, for a toxic pollutant or
cosnbination of pollutants which is present in the discharge and such standard
or prohibition is nore strincent than eny limitation for such pollutant in
this perr.it, this permit shall be revised or nodified in accordance with
the toxic effluent standard or prohibition,
7, Civil and Criminal Liability
Except as provided in perr.it conditions on "Bypassing" (Part 1,23) and "Pover
Failures" (Part 1,24), nothir.o in this permit shall be construed to relieve
the permittee from civil or criminal penalties under Section 147 21, Wisconsin
Statutes, for noncompliance with the teras and conditions of this pemit.
OiT and Hazardous Substance Liability
Ilothina in mis c-errit shall be construed to preclude the institution of any
legal action or relieve the permittee fron any responsibilities, liabilities,
or penalties to which the remittee is or nay be subject under Section 311 of
the Federal Water Pollution Control Ac': (33 U.S,C. Section 1321).
9. State Laws
Nothing in this pemit shall be construed to preclude the institution of any
legal action or relieve the permittee fron any responsibilities, liabilities,
or penalties established pursuant to any other applicable State law or regula-
tion.
10. Property Rights
The issuance of this permit does not convey env property riphts in eilher real
or personal property, or ar.y exclusive privileges, nor does it authorize any
injury to private property or any invasion of personal rights, nor any infringe-
ment of Federal, State or local laws or regulations.
11. Severability
The provisions of this perr.it ere severable, and if any provision of this pemit,
or the application of any provision of this pemit to any circurst2r>ce, is held
invalid, the application of tveh provision to other circumstances, and the
remainder of this pernit, shall not be affected thereby.
-------
12. Schedule of Corrli?rcc Progress Reports
Ho later than 14 calendar days foUowinc a dote Identified 1n any schedule of
compliance in Part H, the pemittee shall subrit either a report of prooress
or* in the esse of specific actions being reoyired by identified dates, a
written notice of co.-rpliar.ee or noncompliance. In the letter case, the notice
shall include the cause of noncoroliance, any rer^dial actions taken, and the
probability of nesting the next scheduled requirements.
13. Test Procedures
Test procedures used for the analysis of pollutants shall be those listed in
Chapter !,R 219* Wisconsin Administrative Code, or an alternate method authorized
in Part II.
14. Recor-dinc of Pesults
For each neasurerent or sairple taken pursuant to the retiuirenjents of this pemit,
the permittee shell record the followino infomation:
a. The exact place, date, and tine of sampling;
b. The dates the analyses were performed;
c. The person(s) who perforoed the analyses;
d« The analytical technioues or methods*used; and
e. The results of all required analyses.
15. Additional £ of three (3) years, or longer if
requested by the Departnent of Natural Resources.
17. Construction of Onshore or Offshore Structures
This penr.U does not authorize or approve the construction of any onshore or
offshore physics! structure of facilities or the undertaking of any work in any
navigable waters.
18. Confidential lnforration
Except for data deterrcined to be confidential under Section 147,G8(2){cK Wisconsin
Statutes, all nonitoring reports required t>y this penr.it shall be available for
public inspection at the headquarters of U.S, EPA. Reoion V and the Deoartrent of
Katural Resources. 'Knowingly sr,akino any false stat«-€r>t on any such report ray
result in the imposition of criminal penalties as provided for in Section 147.21,
Wisconsin Statutes,
19. Transfer of Control of Operation
In the event of a transfer of control of operation of the facility fron which
the permitted discharoes eranate to a person not naned on naoe one (1) of
this pemit, the permittee prior to such transfer shall notify his successor
by letter that this oerr.it is not transferase and that prior to any discharge
after such transfer, a new WPDES pemit rust he obtained. A cony of this
letter shall be forwarded to the Denartnent of Natural Resources, WPDtS Pemit
Section, Box 4$0, Madison, Wisconsin $3701,
-------
Prirt J. Pace 4 o<" 5
20, Ch?r.ce in Pi scarce
Any anticipated facility expansions, production ircrcasos or orccess
ratifications which will result in new, different, or increased discharges
of pollutants nust be reported in accordance with Chanter fc'ft ?0fl, Wisconsin
Administrative Code, by scission of a new l/PHES anolicp.tion or, if such
chances will not exceed the effluent liniutions specified In this remit,
by notice to the Deoartrent of Natural Resources of such chances. Following
such notice, the cerr.it rsy be notified to specify and linit any pollutants*
not previously lirited.
214 iionconsliar-ce ?ictification
If, "for any reas.cn, tne ntrmttee does not cor ply with or will be unable to
comply with any daily rexi-ryn effluent Unite tier, specified in this rsrrcit, he
Shall provide the Cfc'partnent of !s and conditions of this permit is prohibited, except (i) an inadver-
tent bypass lasting no longer than one hour ard resulting fron ecuiprant damage
or te-.porary paver interruption, or (i 1} an up^voiiahle bypass necessary to
prevent loss of life or severe proocrty danace, or (iii) & bypass of excessive
ston? drainage or runoff vhicb wc/id darraoe any facilities necessary for
compliance with the effluent limitations and rrohibit the facility.
-------
25. Definition Terns
(i) For these tcrrs used in Parts I and II which are defined in Section
147.015, Wisconsin Statutes, the reeninas of that Section shall apply.
(ii) As used in Daily Effluent limitations* Part II:
(1) "Average" neans the srithnetic rsen of daily rconitorino test results
obtained during a calendar month for the Qiven paraneter; that is
the total of such daily results, in pounds per day, Riliicrants per
liter, or other appropriate unit divided by the nursber of days for
which results are totaled. For examle, if a facility operates or
discharges and irenitors 30 days riurir.o a ronth the daily averaoe is
the sun of daily values in pounds oer day, rillipranis per liter, or
other appropriate unit divided by 30 for each paraneter, but 1f one
day's result is nissinq for any parameter the divisor in that case
is 29.
(2) "Kaxirctrci" neans the hichest daily ronitorino test result, in pounds
per day, rcillipr&cis per liter, or other appropriate unit durina the
calendar nonth for the given pararieter,
(3) "Minimum" neans the lowest daily nonitoring test result, in the
appropriate unit, during the calendar nonth for the given parameter.
(4) The "average" for fecal colifom bacteria shell be the oeornetric
ffce&n of the sables collected in s rcportinp period.
-------
A. Effluent Limitations and Monitoring Requirements
* u»* i t-1 hi;. ,UL/i
- f i*.v. NovcM'k/cr «t 197Lr
Modified: December 3, 1970
(1) Ouring the period beginning on the effective date of this permit arid lasting until June 30, 1977
the permittee 1s authorized to discharge from outfalls serial numbers 001. 002, and 003.
(2) Each of these discharges shall be individually limited and monitored by the permittee as specified
brlow, and individually reported in accordance with Part II, F, except a limitation under "Quantity®
applies to the total for each characteristic of the individual discharges.
(a) There shall he no discharge of floating solids or visible foam in other than trace amounts.
(b) Samples taken 1n compliance with the monitoring requirements specified below shall be taken
at the following locations: From outfalls 001 & 003 prior to discharge to the river and from
outfall 002 prior to combination with discharge in outfall 008.
EFFLUEMT CHARACTERISTIC
Flow - M3/Day (HGD)
Temperature
0OP5 July-September
OOD5 October-June
Suspended Sol Ids
pH 001
pH 002
pH 003
Mercury (2)
uanti ty-fc
veraqe
DAILY EFFLUENT LIMITATIONS
Eg/Jay (\bs/cta.y) 6tWer limitations (SpccTfy tfriits)
Maximum Minimum Average Maximum
MONITORING REQUIREMENTS
Sample Sample
Frequency Type
Daily Total Daily
Daily Grab
Daily 24 hr. composite
Daily 24 hr. composite
Daily 24 hr. composite
SXGaily Grab
2X0oily Grab
EXDaily Grab
Monthly 24 hr. composite
NOTE: (1) For the month of Septetaber, 1975, the average BOO limitation shall be 46,000 Instead of 35,000 pounds per day.
(2) Monitoring for mercury required commencing 1n January 1977 monthly as specified for outfall 003 and once using
a grab sample for each period of discharge from outfall 004.
B. Mixing Zone - The temperature of these effluents shall be limited so that the temperature of the receiving water shall
be increased not more than 5°F {2.75&C) above the natural temperature at the edge of the plant mixing zone. This
mUing zone shall extend downstream not more than 1,000 feet below outfall 001.
... - See Condition B
15,900(35,000)*'' 47,000(105,000) -
27,200(60,000) 47,700(105,0^0) -
4,530(9,500) 13,600(28.500) -
4,6
6.0
2.0
pM units
pii units
pi! units
9.0
9.0
9.0
-------
311 ari. Pc at. „
Wisconsin Permit No. WI-000053J
Added on September 19, 1977
C. Effluent Limitations and Monitoring Requirements Modified on December 20, 1977
(1) During the period beginning on July 1, 1977 and lasting until May 30, 1978
the permittee is authorized to discharge from outfalls serial numbers 001, 002* 003 and 004*.
(2) Each of these discharges shall be individually limited and monitored by the permittee as specified
Ihtlit**repo[te2 in acc?rdonce with Part II, I, except a limitation under "Quantity"
applies to the total for each characteristic of the individual discharges.
(a) There shall be no discharge of floating solids or visible foam 1n other than trace amounts.
(b) Samples taken in compliance with the monitoring requirements specified below shall be taken
at the following locations: Outfalls 001, 002, 003 and 004 prior to discharge.
... , f I; .¦ LIMITATIONS MONITORING REQUIREMENTS
pfhiifnt rHflRflrrwr^TTr g"antity-kq/day Qbs/day) Other Limitations (Specify Units) Sample Sample '
EFFLUENT CHARACTERISTIC AverageMaximumMinimumAverageMaximum Frequency Type
bod5 ^ ^ 1964(4380) 3767(8400)** - I I irhLr^nnroosI
Total Suspended Solids 2970(6624) 5537(12348) - - - 0an*
p" 5.0 g.O Daily Grab***
* permittee discontinues the use of one or more of the outfalls 001, 002, 003 and 004, the
discontinued outfalls? TOnitor*"5 re<^reiner*s set forth on this page are no longer applicable to any of the
** See pages 1c and Id of 3 for additional effluent limitations for daily maximum BGDc that are imposed to insure
that the dissolved oxygen concentration 1n the Oconto River 1s maintained at all times at or above 3.0 mg/1 as
required by Section NR 104.04(3) of the Wisconsin Administrative Code.
***Upon completion and operation of the new tre«tment facility this sample type for the main process waste outfall
siiQi I 06 continuous.
-------
isc. . i P_ . i IL. ..I-C 31
Added on September 19, 1977
Modified on December 20, 1977
0. Effluent Limitations and Monitoring Requirements
(1) During the period beginning on June 1, 1978 and lasting until November 30, 1979
the permittee is authorized to discharge from outfalls serial numbers 001, 002, 003, and 004*.
(2) Each of these discharges shall be individually limited and monitored by the permittee as specified
below, and Individually reported 1n accordance with Part II, I, except a limitation under "Quantity"
applies to the total for each characteristic of the Individual discharges.
(a) There shall be no discharge of floating solids or visible foam In other than trace amounts.
(b) Samples taken 1n compliance with the monitoring requirements specified below shall be taken
at the following locations: Outfalls 001, 002, 003 and 004 prior to discharge.
PAILY EFFLUEttT LIMITATIONS MONITORING REQUIREMENTS
Quantlty-kq/day (lbs/dav) Other Limitations (Specify Units) ' Sample Sample
EFFLUENT CHARACTERISTIC Average
Maximum frTfrTi mum Average Maximum Frequency Type
Flow - (MGD) Dally Total Dally
BOOg 1681(3748) 3216(7172)** - Dally 24-hour composl
Total Suspended SolIds 2462(5491) 4602(10262) - Dally 24-hour compos1
PH - - 5.0 - 9.0 Dally Crab***
* In the event the permittee discontinues the use of one or more of the outfalls 001, 002, 003 and 004, the
effluent limitations and sionitoring requirements set forth on this page are no longer applicable to any of the
discontinued outfalls.
** See pages lc and Id of 3 for additional effluent limitations for daily maximum BODc that are Imposed to Insure
that the dissolved oxygen concentration 1n the Oconto River is maintained at all times at or above 3.0 mg/1 as
required by Section NR 104,04(3) of the Wisconsin Administrative Code.
***Upon completion and operation of the new treatment facility this sample type for the main process waste outfall
shall be continuous.
-------
Part II, Page lc of 3
Wisconsin Permit No, WI-C000531-1
Added on September 19, 1977
Modified on December 20, 1977
SPECIAL CONDITIONS
0. EFFLUENT LIMITATIONS AKO KO/IITORING REQUIREMENTS
(3) In addition to the final effluent limitations in Part II, Page la
and lb the permittee shall not exceed the daily poundages indicated in
the following table, based on the flow, temperature and dissolved
oxygen (0.0.) of the receiving stream.
Haxinarm Allowable Daily
Temperature, °C Stream Flow, cfs 0,0. (mq/Q 600s Load, pounds per day
^24° C
24.10 to 25°
25.1° to 26°
26.1° to 27°
27,1° to 29°
290
All
All
3748*
£ 210
£3.2
3000
£ 210
>3.2
3748*
>210
All
3748*
^210
£3.2
1500
£ 210
>3.2
3748*
210 to 230
£3.2
3000
210 to 230
>3.2
3748*
> 230
AH
3748*
4210
£3.2
100
3 210
>3.2
3748*
210 to 230
4*3.2
1500
210 to 230
>3.2
3748*
> 230 to 250
£3.2
3000
> 230 to 250
. > 3.2
3748*
> 250
All
3748*
^ 230
£3,2
100
£230
> 3.2
3748*
230 to 250
£3.2
1500
230 to 250
>3.2
3748*
> 250 to 280
£3.2
3QOO
> 250 to 280
>3.2
3748*
> 280
A11
3748*
£ 280
$3.2
100
£ 280
>3.2
3748*
280 to 310
< 3.2
1500
280 to 310
>3.2
3748*
>310
All
3748*
(a) The streamflo* to be used for determining effluent quality shall be
that value passing 1n the Oconto River at the U.S. Geological Survey station
located near county highway "BB".
* For the period of July 1, 1977 until Hay 30, 1978 the maximum allowable
daily BOD5 load is 4380 pounds per day rather than 3748 pounds per day.
P— (-» » t 7 dl * Ps
- r.ivu 1 c:v\Wi
I ^ v V/
fn, rtivjiwix Y
-------
Paae Id of 3
SPECIAL CONDITIONS Wisconsin Pernit !!o. HI-0000531
Added on September 19, 1977
D. EFFLUENT LIMITAIOMS AND MONITORING REQUIREMENTS
(b) The flow upon which the daily effluent Quality is to be controlled
shall be the averaoe daily value fron the 24-hour period endino at nidnioht
prior to the discharge nonitorina period.
(c) The tenperature upon which the daily effluent quality is to be con-
trolled shall be neasured at the Central Avenue (County Hiohway UC") bridae
in rconto Falls, in a free-flowino portion of the strean approxinately
equidistant fron each bank. The tenDerature upon which the effluent 1$
controlled shall be the value neasured sonetf'ne between 7 a.n. and 11 a.n.
in the prior 24-hour period.
(d) The D.O. upon which the daily effluent quality is to he controlled
shall be by neasurenent directly upstrear frcr> and not rx?re th?n 50 feet above
the power dan on the Oconto River operated by Oconto Electric Cooperative
located at Stiles, Wisconsin. Sanples shall be taken or draw fron not
less than 10 nor nore than 15 feet fron the norral water surface, and
shall reflect the D.O, present in the water at the point of drawoff.
(e) The sarple taken shall be ronitored for terperature, as well as D.O.,
both on a continuous readout takino into account routine day-to-day nain-
tenance (no data oap nore than G hours). Standby equipnent shall be provided
for tenperature and P.O. neasurenent.
(f) The daily nininun, naxinun and averaoe should be reported for both D.O.
and tenperature.
-------
Part II. Page 2 (
SPECIAL cononioris Permit flo. WI-OC'
Modified tlovcrrbc
Modified: Oecc^bc
Effluent Limitations and Monitoring Requirements Modified: Septemfc
(1) During the period beginning on the effective date of this pcrnlt and lasting until June 30, 1977
the permittee is authorized to discharge fron outfall serial number 004.
(2) This discharge shall be United by the permittee to periods of high river flow in the cold weather
months of November through June and controlled to maintain a mininum of 3 ma/1 of dissolved oxygen
in the river at all tir.es. Prior to each period oT discharge the permittee shall notify the Lake
Michigan District office of the Department for its information at least AG hours prior to commencing
the discharge.
Effluent Limitations and Monitoring Requirements
(1) During the period beginning on the effective date of this permit and lasting until November 30, 1979
the permittee is authorized to discharge from outfalls 005 and 006.
(2) Any solid material physically renoved by the intake screens shall not be returned to the river but
shall be burned or disposed of at a land fill site licensed in accordance with chapter MR 151,
Wisconsin Administrative Code.
Effluent Limitations and Monitoring Requirements
(1) During the period beginning July 1, 1975 and lastino until November 30, 1979
the permittee is authorized to discharge from outfall serial number 007.
(2) Discharge fron outfall 007 shall be monitored weekly using grab samples for Temperature* pM, and
total daily flow. Temperature shall be United in accordance with Condition 8.
Effluent Limitations and Monitoring Requirements
(1) During the period beginning September 1, 1975 and lasting until Wov '30>11979 the permittee is authorizi
discharge gas cooler water through 8n outfall designated as 008 discharging through outfall 002 and evai
condensate through an outfall designated as 009 discharging through outfall 005.
(2) Discharges from outfalls 008 and 009 shall be sampled prior to combination with other discharges in out
and 005 respectively! monitored weekly using grab samples for temperature, pfl and total daily flow, and
as discharges from outfalls 008 and 009 respectively, commencing in January 1977.
-------
>1. MONITORING AND RECORDING
Part II. Page 3 of 3
Hi scons in Permit No. HI-0000531
Modified Mover.ber 7, 1975
1 Modified September 19, 1977
Sailing Requirements
;s specified otherwise herein, samples shall be taken in accordance with
jpter l«'R 213 of the Wisconsin Administrative Code.
•Monitoring reports and reports required by Sections 12, 20, 21 and 23
rt I of this permit shall be signed;
0) for a corporation by a principal executive officer of at least the
evel of Vice President or his duly authorized representative having
verall responsibility for the operation of the facility for which this
perait is issued,
2) for a partnership by a general partner, and
'3) for a sole proprietorship by the proprietor, except that
i4) in the case of reports required by Sections 21 and 23 the Individual
squired"to sign in accordance with this subsection may authorize
lother individual to sign such reports 1n his absence.
Vonitonng results obtained during each month shall be sunjuarized and
ed on Discharge Monitoring Report Forms, postmarked no later than the
ay of the month following the completed reporting period. The first
rt is due on February 28, 1975. Duplicate signed copies of these, and
-"¦her reports required herein, shall be submitted to the:
igdule of Compliance
>errciues shall achieve compliance with the efflusnt limitations contained
II in accordance with the following schedule:
Reporting
Wisconsin Department of Natural Resources
WPDES Pernit Section
Post Office Box 450
Madison, Wisconsin 53701
Submit progress reports
March 31, 1975
$2pte?r.ber 30, 1975
March 31. 1976
September 30, 1976
torch 31, 1977
Subnit final report
Attain operational level
July 1, 1977
June 30, 1977
-------
ATTACHMENT 2
LABORATORY EVALUATION
-------
Scott Paper - Oconto Falls, Wisconsin
October 17 and 18, 1977
Inspection Attendees
Aff11 nation
John Schmitt
Bob Meyer
David Vietti
Technical Services Manager, Scott Paper
Technical Services Dept., Scott Paper
Chemist, US EPA-NEIC
The analytical laboratory used for NPDES testing is well equipped. Ap-
proved EPA procedures are being used for BOD and TSS analyses. Two YSI
dissolved oxygen meters are being used to measure DO's in the stream and
the initial and final BOD values. The meters are standarized daily against
the Winkler titration method.
Some quality control procedures are being used with three dilutions being
set up on every sample for BOD analysis. Duplicates should be analyzed
periodically (one every ten samples) for TSS analysis as well as a blank
everytime the parameter is analyzed. Glass Fiber Filters 934 AH, 5.5 cm,
were being used for solids testing.
The composites are not being cooled during sample collection. The practice
of refrigeration while compositing should be implemented immediately. Also
the composites that come off on Saturday are not being set up until Monday.
This is a holding time of 48 hours and exceeds the recommended holding for
BOD's by 24 hours. Since the composites are not being cooled during col-
lection and part of the composite is 24 hours old after the compositing is
completed, the BOD's should be set up immediately after the composites
come off on Saturday.
The dilution water used for BOD analysis is not being incubated prior to
BOD testing and this is causing inconsistent blanks. When the temperature
of the laboratory is above 29°C, the initial readings are too low and
when the temperature is below 20°C, the initial readings are too high.
Consequently, when the temperature in the laboratory is not 20°C, erroneous
BOD data is resulting. Therefore, the BOD dilution water should be in-
cubated at 20°C for at least 24 hours prior to the set up of the BOD
dilutions.
Along with upgrading their quality control program by running a duplicate
every tenth sample for TSS analysis along with a blank, their quality as-
surance procedures should be documented. Also, NBS thermometers and
Class "S" weights should be purchased in order to monitor the temperatures
of their ovens and document the weights of their analytical balance.
-------
SELF-MONITORING PROGRAM
On the followinq items, code 1 = yes, 2 = no, 3 = undetermined,
4 = not applicable.
RECORDS AND REPORTS
1. Prooerly maintained records of date, exact place and time of
sampli nq.
Z]7 2- Properly maintained records of the dates samples were analyzed.
/ I 3. ProDerly maintained records of who performed the analyses.
Zi' Properly maintained records of the analytical techniques and
methods used.
/1/ 5. Properly maintained records of the results of analyses.
/17 6. Records maintained for a minimum of three years including all
original strip chart recordings (continuous monitoring instru-
mentation calibration, maintenance records).
, ^7 7. Plant operating records kept including operating logs of each
treatment unit.
/1/ 8. Results of sample analyses correctly calculated and recorded.
/ 1/ 9. Self-monitoring frequency and oarameters conform to permit
reguirements.
Z37 10. Laboratory records consistent with DMR data.
Z_4/ 11. Records maintained of major contributino industries usinq
publicly owned treatment works.
/V 12. Records maintained of major contributing industries' compliance/
non-compliance status.
/J/ 13. Quality assurance records kept including spiked samples, laboratory
equipment calibration, etc.
Other Comments on Records and Reports:
-------
FLOW MEASUREMENT
/ 1. Primary measurinq device (weir, parshall flume, magmeter, etc.)
properly installed.
Type of device
_/ 2. Calibration frequency adequate.
Date of last calibration
_/ 3. Flow measurement records properly maintained.
Method (automatic, manual, etc.)
f_J 4. Primary flow measurement device properly operated and maintained.
/_/ 5. Secondary instruments (totalizers, records, etc.) properly
operated and maintained.
rj 6. Flow measurement equipment adequate to handle expected ranqes of
flow rates.
Other Comments on Flow Measurement:
SAMPLING
l_V 1. Locations adequate for representative samples.
/ 1/' 2. Parameters and frequency agree with permit.
[V 3. Method of sample collection: Manual
Automatic
' 1 4. SamDle collection method is adequate.
_4* 5. Water intake sampled and analyzed, if required by permit.
L2: 6. Additional monitorinq and analyses beincj performed more
frequently than required by permit.
-------
' 4' 7. When answer to No. 6 is yes, results are beina reported in
permittee's Discharge Monitonna Form (EPA No. 3320-1 ).
/_2j 8- When necessary during compositinq, samples are properly iced.
. 2/ 9. Proper preservation techniques used.
10. Flow proportioned samples obtained where required by permit.
' 2 H. Sample holdina times prior to analyses in conformance with 40
CFR 136.3 requlations. The composites that come off on Saturday
are not being set up until the following Monday.
Other Comments on Sampling Techniques:
LABORATORY PROCEDURES
/]7 1. EPA approved analytical testing orocedures used (40 CFR 136.3).
/4/ 2. If alternate analytical procedures are used, proper approval
has been obtained.
/27 3. Parameters other than those required by the permit are analyzed.
fl/ 4. Commercial laboratory utilized.
Name
Address
/ 4' 5. Commercial laboratory State certified.
\• 6- Satisfactory calibration and maintenance of instruments and
equi pment.
Zl7 7. Quality control procedures used.
/]7 8. Duplicate samples are analyzed. 50 % of time, only for
BOD's.
-------
/ 4' 9. Spiked samples are used. % 0f time.
/ 1' 10. Laboratory records properly maintained.
/ 1 11. Laboratory employees qualified.
General Comments on Laboratory Procedures:
Results of NEIC Quality Control Check Samples Analyzed by Laboratory
Suspended Solids B.O.D.
Scott Paper Values 47 mg/1 124 mg/1
True Values 51 mg/1 146 mg/1
-------
APPENDIX B
CHAIN-OF-CUSTODY PROCEDURES
-------
APPENDIX B
ENVIRONMENTAL PROTECTION AGENCY
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
CHAIN OF CUSTODY PROCEDURES
June 1, 1975
GENERAL
T.he evidence gathering portion of a survey should be characterized by the minimum
number of samples reauired to give a fair representation of the effluent or water body
from which taken. To the extent possible, the quantity of samples and sample loca-
tions will be determined prior to the survey.
Chain of Custody procedures, must be followed to maintain the documentation necessary
to trace sample possession from the time taken until tne evidence is introduced into
court. A sample is in your "custody" if:
1. It is in yc ir artjal physical possession, or
2. It is in your view, after being iri your physical possession, or
3. It v-as in your physical possession and then you locked it up in a manner so
that no one could tamper with it.
All survey participants will receive a copy of the survey study plan and will be
knowledgeable of its content: prior to the survey. A pre-survey briefing will be held
to re-appraise all participants of the survey objectives, sample locations and Chain
of Custody procedures. After all Chain of Custody samples are collected, a de-briefing
will be held ir. tna field to determine adherence to Chain of Custody procedures and
whether additional evidence type samples are required.
SAMPLE COLLECTION
1. To the maximum extent achievable, as few people as possible should handle
the sample.
2. Stream and effluent samples shall be obtained, using standard field sampling
techniques.
3. Sample-tags (Exhibit I) shall be securely attached to the sample container
at the time the complete sample is collected and shall contain, at a minimum,
the following information: station number, station location, data taken,
time taken, type of sample, sequence number (first sample of the day -
sequence No. 1, second sample - sequence No. 2, etc.), analyses required and
samplers. The tags must be legibly filled out in ballpoint (waterproof ink).
4. Blank samples shall also be taken with preservatives which will be analyzed
by the laboratory to exclude the possibility of container or preservative
contamination.
5. A pre-printed, bound Field Data Record logbook shall be maintained to re-
cord field measurements and other pertinent information necessary to refresh
the sampler's rieinory in the event he later takes the stand to testify re-
garding his actions during the evidence gathering activity. A separate
set of field notebooks shall be maintained for each survey and stored in a
safe place where they could be protected and accounted for at all times.
Standard formats (Exhibits II and III) have been established to minimize
field entries and include the date, time, survey, type of samples taken,
volume of each sample, type of analysis, sample numbers, preservatives,
sample location and field measurements such as temperature, conductivity,
-------
B-2
DO, pH, flow and any other pertinent information or observations. The
entries shdll be signed by the held sampler. The preparation and conser-
vation of the field logbooks during the survey will be the responsibility
of the survey coordinator. Once the survey is complete, field logs will be
retained by the survey coordinator, or his designated representative, as a
part of the permanent record.
6. The field sampler is responsible for the care and custody of the samples
collected until properly dispatch-d to the receiving laboratory or turned
over to an assigned custodian. He must assure that each container is in his
physical possession or in his view at all times, or locks., ir, such a place
and manner that no one can tamper uith it.
7. Colored slides or photographs should be takpn which would visually shovi the
outfall sample location and any vtusr pollution to substantiate any con-
clusions of the investigation. W-itten documentation on the back of the
photo should include the signature of the photographer, time, date and site
location. Photographs of this nature, which m?.y bo used as evidi'iice, snail
be handled recognizing Chain of Custody procedures lo prevent alteration.
TRANSFER OF CUSTODY AND SHIPMENT
1. Samples will be accompanied by a Chain of Custody Record v.'hic.i includes the
name of the survey, samplers' signatures, station number, station location,
date, time, type of sample, sequence number, number of containers and analy-
ses required (Fig. IV). When turning over the possession of samples, the
transferor and transferee will sign, date and time the sheet. This record
sheet allows transfer of custody of a group of samples in the field, to the
mobile laboratory or when samples are dispatched to the NEIC - Denver labora-
tory. When transferring a portion of the samples identified on the sheet to
the field mobile laboratory, the individual samples must be noted in the
column with the signature of the person relinquishing the samples. The field
laboratory person receiving the samples will acknowledge receipt by signing
in the appropriate column.
2. The field custodian or field sampler, if a custodian has not been assigred,
will have the responsibility of properly packaging and dispatching samples
to the proper laboratory for analysis. The "Dispatch" portion of the "Chain
of Custody Record shall be properly filled out, dated, and signed.
3. Samples will be properly packed in shipment containers such as ice chests, to
avoid breakage. The shipping containers will be padlocked for shipment to
the receiving laboratory.
4. All packages will be accompanied by the Chain of Custody Record showing iden-
tification of the contents. The original will accompany the shipment, and a
copy will be retained by the survey coordinator.
5. If sent by mail, register the package with return receipt requested. If sent
by common carrier, a Government Bill of Lading should be obtained. Receipts
from post offices, and bills of lading will be retained as part of the perma-
nent Chain of Custody docunentution.
6. If samples are delivered to the laboratory when appropriate personnel are not
there to receive them, the samples must be locked in a designated area within
the laboratory in e nunner so that no one can tamper with them. The S3me per-
son must then return to the laboratory and unlock the samples and deliver
custody to the appropriate custodian.
-------
B-3
LABORATORY CUSTODY PROCEDURES
1. The laboratory shall designate a "sample custodian." An alternate vnll be
designated in his absence. In addition, the laboratory shall set aside a
"sample storage security area." This should be a clean, dry, isolated room
which can be securely locked from the outside.
2. All samples should be handled by the minimum possible number of persons.
3. All incoming samples shall be received only by the custodian, who will in-
dicate receipt by signing the Chain of Custody Sheet accompanying the samples
and retaining the sheet as permanent records. Couriers picking up samples at
the airport, post office, etc. shall sign jointly with the laboratory custodian.
4. Immediately upon receipt, the custodian will place the sample in the sample
room, which will be locked at all times except when samples are removed or
replaced by the custodian. To the maximum extent possible, only the custo-
dian should be permitted in the sample room.
5. The custodian shall ensure that heat-sensitive or light-sensitive samples,
or other sample materials having unusual physical characteristics, or re-
quiring special handling, are properly stored and maintained.
6. Only the custodian will distribute samples to personnel who are to perform
tests.
7. The analyst will record in his laboratory notebook or analytical worksheet,
identifying information describing the sample, the procedures performed
and the results of the testing. The notes shall be dated and indicate who
performed the tests. The notes shall be retained as a permanent record in
the laboratory and should note any abnormalties which occurred during the
testing procedure. In the event that the person who performed the tests is
not available as a witness at time of trial, the government may be able to
introduce the notes in evidence under the Federal Business Records Act.
8. Standard methods of laboratory analyses shall be used as described in the
"Guidelines Establishing Test Procedures for Analysis of Pollutants,"
38 F.R. 28758, October 16, 1973. If laboratory personnel deviate from
standard procedures, they should be prepared to justify their decision dur-
ing cross-examination.
9. Laboratory personnel are responsible for the care and custody of the sample
once it is handed over to them and should be prepared to testify that the
sample was in their possession and view or secured in the laboratory at all
times from the moment it was received from the custodian until the tests
were run.
10. Once the sample testing is completed, the unused portion of the sample to-
gether with all identifying tags and laboratory records, should be returned
to the custodian. The returned tagged sample will be retained in the sample
room until it is required for trial. Strip charts and other documentation
of work will also be turned over to the custodian.
11. Samples, tags and laboratory records of tests may be destroyed only upon the
order of the laboratory director, who will first confer with the Chief,
Enforcement Specialist Office, to make certain that the information is no
longer required or the samples have deteriorated.
-------
B-4
EXHIBIT I
EPA, NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Station No.
Dato
Time
Sequence No.
Station Location
Gr;ik
Comp.
.BOD
_Solidj
Jeofail
.Oil tnd Gr2rjo
Rarcar laj Presarv alivs:
COD no
Nutrient ... _ Bdrt.
Ollisr
Samplers:
Front
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER.
DENVER, COLORADO 80225
>
g \
Back
-------
EXHIBIT II
FOR SURVEY, PHASE DATE
,,rt- w' ANALYSES
E Q U 1
R
D
STATION
NUMBER
STATION DESCRIPTION
TOTAL VOLUME
TYPE CONTAINER
PRESERVATIVE
i NUTRIENTS
| BOD
COD |
TOC 1
TOTAL SOLIDS
SUSPENDED SOLIDS |
ALKALINITY |
o
Q
t
X
o.
•
>•
>
~—
U
3
O
2
O
o
•
Uf
a:
Z)
~—
<
ex
LJJ
O
5
UJ
TOTAL COIIFORM |
FECAL COLIFORM |
TURBIDITY 1
OIL AND GREASE |
METALS 1
BACTI |
PESTICIDES |
HERO I
0
z
<
o
az
o
UJ
u
<
CC
PHCNOL |
u
C
7
<
>
P. EM ASKS
I
-------
EXHIBIT III
Samplort:
FIELD DATA RECORD
STATION
NUMBER
DATE
TIME
TEMPERATURE
°C
CONDUCTIVITY,
^ mhos/cm
PH
S.U.
D.O.
mg/l
Gage Ht.
, or Flow
Ft. or CFS
i
1
1
-------
B-7
EXHIBIT IV
ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcement
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Building 53, Bo* 25227, Denver Federal Center
Denver, Colorado 80225
CHAIN OF CUSTODY RECORD
SURVEY
SAMPLERS: fSignaluro)
STATION
NUMBER
STATION LOCATION
Date
TIME
Sample tvpe
NO OF
CONTAINERS
analysis
REQUIRED
Woter
SEQ
NO
Camp
Gfab
Relinquished by: {5tgna/uraJ
Received by: fSignah/reJ
Date/Time
Relinquished by: (S.gncfu«j
Relinquished by: (Signature)
Relinquished by: (StgnalurcJ
Received by: (Signature)
Received by: fs>gnaivre;
Received by Mobile Laboratory for field
analysis: fSignoturt}
Date/T
ime
Date/Time
Dale/Time
Dispatched by: (Sigoaturej
Method of Shipment:
Dale/Ti
ime
Received for Laboratory by:
Date/Time
Distribution: Orig. — Accompany Shipment
1 Copy— Survey Coordinofor Field filet
-------
REVIEW OF CHAIN-OF-CUSTODY PROCEDURES
Scott Paper Company
Oconto Falls, Wisconsin
Records pertaining to the Scott Paper Company presurvey re-
connaissance and monitoring survey were evaluated against the established
NEIC chain-of-custody procedures. Specifically, field data records, log
books, sample tags, and chain-of-custody records were reviewed to determine
the nature and scope of any deviations to the NEIC chain-of-custody
procedures. If a deviation was discovered, an assessment was made of
the impact of the deviation on the survey results. The following is the
result of this evaluation.
The field chemist on the survey maintained a laboratory notebook in
which to note any pertinent information and/or abnormalities in analytical
results. He did not record the daily calibration for accuracy of the
analytical balance used for TSS weights, although he conducted the
practice daily. Nor did he record the absence of chlorine in BOD samples,
although he checked each sample for chlorine content prior to conducting
a BOD analysis.
The field chemist followed the standard method for BOD analysis,
with the exception of not checking the pH of the samples prior to initiating
analysis. In the technical judgment of this chemist, experienced in BOD
analysis, such a deviation is justified because of: (1) the large dilution
of the samples (>50 fold), and (2) the buffering capacity of the dilution
water.
Five other items, which are not considered to be deviations to
established NEIC chain-of-custody procedures, do require the following
clarification.
Samples taken on October 19, 1977, of the clarifier effluent and
SSL lagoon underdrain flow during the reconnaissance inspection were
brought back to the NEIC laboratory, Denver, Colorado, and analyzed for
TSS. The original white copy of the Chain-of-Custody Record, which was
signed by the chemist who received and analyzed the sample, has not been
found. The yellow duplicate copy containing all necessary information
is contained in the Scott project file.
During the presurvey reconnaissance, a BOD sample of the lagoon
underdrain flow was collected, iced, and sent to the NEIC laboratory,
Denver, Colorado. Due to available air transportation, the recommended
holding time (6 hours for BOD analysis) was exceeded by one hour and ten
minutes. The concentration in the sample was found to be 8,800 mg/1.
Since concentrations for a given BOD sample decrease over time, the
-------
actual concentration of the sample analyzed may have been greater, but
not less, than 8,800 mg/1 if the recommended holding time had not been
exceeded.
On the morning of November 9, 1977, at 0400, a portion of the
sample from Station 3010 was poured into the container in which the
sample from Station 3003 was to be composited. Because of this con-
tamination, the sample for Station 3003 for 0800 November 8 to 0800
November 9, 1977, was invalidated. Analysis of this sample was per-
formed, however, the sample results are not included in this report.
DO samples were collected at the Oconto River Station in standard
size DO bottles. Samples were not tagged, but remained in the sampler's
custody at all times. Analyses of the samples were performed by the
sampler at the NEIC mobile laboratory within one hour of their collection.
The analytical results were recorded in a log book and the sample dis-
carded. This procedure is consistent with established NEIC chain-of-
custody procedures, since field measurements do not require sample tags.
Sample bottles and content were discarded after all analytical
results had been recorded. Prior to discarding them, the sample tags
were removed and filed.
All of these deviations to established NEIC chain-of-custody pro-
cedures, and the items requiring clarification are considered to be
minor and, thereby, are considered to have no impact on the results,
conclusions, and/or recommendations contained in this report.
------- |