OFFICE OF ENFORCEMENT
E P A-330/2-7 8-006
i
NPDES Compli ante Mo n it or in g
and
Waste Characterization
Crown Simpson Pulp Company
Fairhaven, California
(December 5-1 2, 1 977)
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, COLORADO
AND ^ g%
REGION IX SAN FRANCISCO I
APRIL 1978
t ^
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Environmental Protection Agency
Office of Enforcement
E PA-330/2-78-006
NPDES COMPLIANCE MONITORING AND WASTE CHARACTERIZATION
CROWN SIMPSON PULP COMPANY
FAIRHAVEN, CALIFORNIA
(December 5-12, 1977)
April 1978
National Enforcement Investigations Center - Denver
and
Region IX - San Francisco
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TABLES
1 NPDES Limitations 3
2 NPDES Compliance Monitoring 6
3 BOD and TSS Composite Sampling Data 8
4 pH and Temperature Data 23
5 Oil and Grease Data 24
6 96-Hour Flow-through Survival Data 25
7 Comparison Between Crown Simpson Pulp Company
Future NPDES Limitations and NEIC Data. . . 29
8 Metals, Cyanide, Phenolics and Chlorinated
Hydrocarbons Data 30
9 Priority Pollutants 32
10 General Organics Data 36
11 Comparison of Flows During December 5-12,
1977 37
FIGURES
1 Outfall Locations - Crown Simpson and
Louisiana Pacific Pulp Mills 2
2 Crown Simpson and Louisiana Pacific Mill
Sites 13
3 Crown Simpson Wastewater System 16
4 Dose Response - Crown Simpson Pulp Co.
Effluent 26
5 Process Wastewater Diurnal Flow Variation . . 38
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I. INTRODUCTION
On March 17, 1977, the California State Water Resources Control
Board issued National Pollutant Discharge Elimination System (NPDES)
Permit No. CA0005282 to the Crown Simpson Pulp Company [Appendix A],
authorizing one discharge to the Pacific Ocean in northern California
near Eureka [Figure 1]. The permit granted variances from national
effluent limitations guidelines for BOD and pH, subject to approval
by the Environmental Protection Agency (EPA) Administrator. These
variances were subsequently denied by EPA Administrator Douglas
Costle on September 15, 1977. Effluent limitations effective July 1,
1977 are summarized in Table 1.
On August 25, 1977, the National Enforcement Investigations
Center (NEIC) was requested by EPA Region IX to conduct an NPDES
compliance monitoring and waste characterization study at the Crown
Simpson mi 11.
A notification letter was sent by NEIC to the Company on
October 19, 1977, followed by a presurvey inspection during the week
of October 31-November 4, 1977. From December 5-12, 1977, the NEIC
conducted the requested study with the following objectives:
1. Determine NPDES effluent limitations compliance.
2. Conduct toxic substances monitoring.
3. Document the efforts of the Company over the past three
years to meet established permit limits.
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/
LOUISIANA PACIFIC
OUTFALL
CROWN SIMPSON
OUTFALL
/
/ /
800' piff/js>r Sect
©&$ 16 W
WaterA L«
JflP i
7^6oat Basirf
203' ^iffu
sar
fit '^1' I
iSu'bstati
rff. HCdcKs Beacon
-\f 0G«.,7J|fin
mOU. • R . I —
Mi "Q:'i
¦ IV Disposal
/ AR5AI
¦'> h/i hi
KINSg
.Badro Tower
School
11
MM12
EUREKA
Beacon
MENT
P
Bucksport
eWage Disposal/^
31 ^5A ac
Dolphin
Wells
u: 11 I Si Qc^anvJ
» Water
SCALE 1:24 000
o
1 MILE
»
Figure J. Outfall Locations - Crown Simpson
and Louisiana Pacific Pulp Mills
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3
Table 1
NPDES LIMITATIONS
(EFFECTIVE 7/1/77)
CROWN SIMPSON PULP COMPANY
Consti tuents
Uni ts
30-day Avg,
Daily Max,
F1 ow
BOD5 (pulp)
BOD^ (veneer)
TSS (pulp)a
Oil and Grease
PH
m^/day x 103 (mgd)
kg (lb)/day
kg (lb)/day
kg (1b)/day
mg/1
Standard
Uni ts
114 (30) 168 (44.4)
4,390 (9,660) 8,420 (18,540)
65 (142.5) 194 (427.5)
8,930 (19,680) 16,600 (36,480)
30-day median = 10
90th percentile = 15
within range of 5.0-9.0
a In addition to TSS in raw water supply.
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4
In addition, since the Crown Simpson mill had been selected by
the Effluent Guidelines Division of EPA as a screening site for
Priority Pollutants,* the NEIC sampled and analyzed for these
parameters.
* Priority Pollutants are those derived from the June 7, 1976, Natural
Resources Defense Council (NRDC) vs USEPA Settlement Agreement. For
a listing of the pollutants, see Appendix B.
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II. SUMMARY AND CONCLUSIONS
During December 5-12, 1977, the National Enforcement Investiga-
tions Center (NEIC) conducted an NPDES compliance monitoring and
waste characterization survey at the Crown Simpson Pulp Company pulp
mill in northern California near Eureka. The mill produces approxi-
mately 544 m. tons (600 tons)/day of market-bleached kraft pulp,
primarily for export. Wastewaters generated in the process are
discharged untreated to a Pacific Ocean outfall which terminates
about 730 m (2,400 ft) offshore, through a 62 m (203 ft) diffuser
section 11-12 m (35-40 ft) deep.
INPLANT POLLUTION CONTROL
Crown Simpson has sought to employ inplant controls with no
external treatment to achieve Best Practicable Control Technology
Currently Available (BPT) limitations for TSS and to gain a variance
from BPT limitations for BOD and pH. Except for fiber-saving devices
built into the design of the mill, no major inplant changes were made
prior to January 1978 which resulted in significant TSS removals.
However, after the NEIC December 5-12, 1977 survey, a number of
inplant controls were reported by plant officials to have been in-
stalled during the 1977 Christmas mill shutdown. These controls will
reportedly bring the mill into compliance with BPT TSS limitations.
NPDES EFFLUENT LIMITATIONS COMPLIANCE
Effluent data collected during December 5-12, 1977 [Table 2]
show that Crown Simpson exceeded its NPDES limitations for BOD (pulp)
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Table 2
NPDES COMPLIANCE MONITORING
CROWN SIMPSON PULP COMPANY
December 5-12, 1977
Parameter
NPDES Permit
NEIC Results
30-Day Average
kg/day lb/day
Daily Maximum
kg/day lb/day
Average
Maximum
kg/day lb/day kg/day lb/day
BOD (pulp)
BOD (veneer)
TSS (pulp)a
Oil and Grease
pH
4,390 9,660 8,420 18,540
65 142.5 194 427.5
8,930 19,680 16,600 36,480
30-day median = 10 mg/1
90th percentile = 15 mg/1
within range of 5.0-9.0
11,000 23,000 14,000 31,000
b b
22,000 50,000 42,000 93,000
Average = 6.6
Range = 1.7-15
Range = 2.0-11.0
a In addition to TSS in raw water supply.
b Any contribution from this small source included in process wastewater flow [i.e., "BOD (Pulp)"].
CT>
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7
30-day average (11,000 vs 4,390 kg/day) and TSS (pulp) 30-day average
(22,000 vs 8,930 kg/day). The BOD (pulp) daily maximum (16,600
kg/day) and TSS (pulp) daily maximum (16,600 kg/day) limits were
exceeded on 5 and 3 days, respectively, of the 6 days of reported
results [Table 3]. The Company was also in violation of its NPDES pH
limits (range of 2.0-11.0 vs limits of 5.0-9.0). The Company was in
compliance with the oil and grease limits.
The Crown Simpson effluent was determined to be acutely toxic to
fish. The 96-hour LC50 was calculated to be a 28.5% effluent concen-
tration. Despite this demonstrated acute toxicity, it is estimated
that the Company will be in compliance with the NPDES receiving water
toxicity limitation of 0.05 toxic units at least 90% of the time.
COMPLIANCE WITH FUTURE NPDES LIMITS
Composite sampling data collected by NEIC for three consecutive
days beginning December 6, 1977, indicates that most of the limits
which begin to come into effect July 1, 1978 will be met. Exceptions
include phenolic compounds (NPDES 50%* limit of 0.5 mg/1 vs NEIC
average of 0.8 mg/1), total chromium** (50% limit of 0.005 mg/1 vs
NEIC average of 0.01 mg/1) and total identifiable chlorinated hydro-
carbons (50% limit of 0.002 mg/1 vs NEIC average of 1.8 mg/1). In
addition, if the effluent toxicity remains at levels found during the
NEIC survey, the Company will be in violation of toxicity limits (50%
and 10%*** limits of 1.5 and 2.0 toxic units respectively, vs NEIC
value of 3.5).
* Concentration not to be exceeded more than 50% of the time.
** Unlike other future limits, does not become effective until
July 1, 1983.
*** Concentration not to be exceeded more than 10% of the time.
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Table 3
BOD AND TSS COMPOSITE SAMPLING DATA9
CROWN SIMPSON PULP COMPANY
Fairhaven, California
December 5-12, 1977
h
Flow
BOD
TSS
Date0
m^/day
mgd
mg/1
kg/day
1b/day
Gross
Intake0
Net
Net Loadings
L/CI •
1977
x 103
mg/1
mg/1
mg/1
kg/day
lb/day
6
78.7
20.8
170
13,000
30,000
210
24
186
15,000
32,000
7
78.7
20.8
180
14,000
31,000
550
13
537
42,000
93,000
8
d
-
150
-
-
150
25
125
-
-
9
62.8
16.6
140
8,800
19,000
150
7
143
9,000
20,000
10
64.7
17.1
100
6,500
14,000
470
11
459
30,000
65,000
11
62.8
16.6
170
11,000
24,000
200
3
197
12,000
27,000
12
65.8
17.4
150
9,900
22,000
470
54
416
27,000
60,000
Avg.
68.9
18.2
150
11,000
23,000
310
20
290
22,000
50,000
a Station 3500 - Crown Simpson process wastewater at effluent pumps,
b Compositing period was 0700-0700. Date listed is day period ended,
c Raw water supply sampled at Crown Simpson intake prior to any treatment processes,
d Effluent pump breakdown and flow recorder malfunction precluded measurement of flow.
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9
PRIORITY POLLUTANTS
Effluent composite samples collected December 6-9, 1977 in-
dicated the presence of 13 Priority Pollutants. Two Priority Pol-
lutants, di-n-butyl phthalate and diethyl phthalate, were present in
the raw water supply in low concentrations, 1-3 ppb.
COMPANY FLOWS VS NEIC FLOWS
A comparison between effluent flows estimated by Crown Simpson
based on mill raw water flows and those actually measured by NEIC
indicated the Company method is marginal. The overall CS/NEIC flow
ratio was 1.16; and, on 4 of the 6 days monitored, the Company flow
estimates were approximately 25% higher than NEIC measurements.
SELF-MONITORING EVALUATION
An NEIC evaluation of the permittee's self-monitoring practices
indicated the following deviations from prescribed/recommended
techniques.
Sampling Techniques
1. The instantaneous effluent flow rate varied according to
the number of pumps in service. Composite samples were
collected by automatically collecting equal-volume aliquots
at equal-time intervals, irrespective of the flow rate.
Hence, the samples were not flow proportional as required
by the NPDES permit. Furthermore, these samples were unre-
frigerated during collection, contrary to required refrig-
eration at 4°C.
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10
2. The pH was determined on each of the 24-hour composite
samples, then averaged for the samples collected during the
month, and this one value was reported to the California
Regional Water Quality Control Board, Santa Rosa, Cali-
fornia. The NPDES permit requires a continuous measurement
of pH. The Company has a continuous pH recorder installed,
but does not report this data to the State.
3. Metals samples are collected and transported to Camas,
Washington to the Crown Zellerbach labs without the pre-
scribed acidification.
4. Phenolic compounds and cyanide composite samples are col-
lected in a plastic container, not glass as prescribed, and
not preserved or refrigerated during collection.
5. Oil and grease sampling consisted of a single grab, not an
8-hour composite as required by the NPDES permit. However,
collecting a composite sample for oil and grease is ex-
tremely impractical and is not recommended by EPA.
Flow Monitoring
1. As noted previously, the Company estimates process waste-
water effluent flow with metered raw water flows. This
practice was determined to yield marginal results for daily
flows, and also precludes collecting flow-proportional
effluent composite samples.
2.
Raw water flow monitoring equipment is calibrated approxi-
mately once a year. This should be conducted at least
every six months, or sooner if problems are indicated.
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11
Analytical Procedures*
1. The Company was using a modified procedure for oil and
grease analyses [Appendix C]. No required modification
request had been made, and no data had been collected to
establish comparability with the EPA-approved method.
2. Though not specifically required by the NPDES permit, the
Company had established no formal analytical quality con-
trol program.
Other
Despite the fact that the NPDES permit contains 30-day average
and daily maximum TSS and BOD loading limitations, the Company re-
ports only a monthly average flow and an average pollutant concen-
tration to the State of California.
* Methods observed included BOD, TSS, oil and grease, TSS and pH.
The remainder of the analyses [Appendix C] are performed at Camas,
Washington and could not be observed at the time of the survey.
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III. BACKGROUND
MILL LOCATION AND PROCESS DESCRIPTION
The Crown Simpson Pulp Company mill, a joint venture of Crown
Zellerbach Corporation and the Simpson Timber Company, was built in
1965-66 and is located in northern California near Fairhaven on the
Samoa Peninsula, about 3.6 km (2.3 mi) north of the entrance to
Humboldt Bay [Figure 2]. The mill is on the east side of the penin-
sula, and is one of two pulp mills on the peninsula, the other belong-
ing to the Louisiana Pacific Corporation, about 1.2 km (0.75 mi)
north of the Crown Simpson mill. The peninsula is a low sandy area,
about 13 km (8 mi) long and varying in width from 0.8 to 1.4 km (0.5
to 0.9 mi), which is sparsely populated (population south of Samoa
Bridge is about 700). The mill is only about 20 feet above sea
level.
The Crown Simpson mill produces approximately 544 m. tons (600
tons)/day of market-bleached kraft pulp. Raw materials include
primarily redwood and douglas fir sawdust and chips from nearby
lumber and plywood operations. However, some tan oak residuals are
also used. Chips and sawdust are separated and each blended by wood
species according to the desired grade of pulp. The chip and sawdust
blends are then digested separately in continuous digesters using the
conventional kraft process. The sawdust digester and chip/shavings
digester were designed to produce 90 and 450 m. tons (100 and 500
tons)/day, respectively, of pulp. The digested pulp is washed and
screened and then sent to the bleachery, which has seven stages of
treatment, six of which are followed by a washing stage. All washing
in the bleach plant is skip-stage countercurrent.
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Mad River
MK Areata
MOHTHWCSTOH) PACIFIC
Samoa
Fairhaven
Figure 2- Crown Simpson and Louisiana Pacific Mill Sites
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Following bleaching, the pulp is formed into a continuous sheet
for drying on steam cylinders and in an air drier. Dried pulp is cut
into sheets, baled and then sold, primarily on the export market.
What can't be sold overseas is sold domestically.
Production during the NEIC survey of Crown Simpson was as follows
Dec.
Air Dry
1977
m. ton
ton
5a
391
431
6
493
544
7
578
637
8
540
595
9
288
318
10
607
669
11
612
675
Average
502
553
a Production day runs from
0800 hr of date listed to
0800 hr on following day.
PROCESS WATER
Process water is purchased from the Humboldt Bay Municipal Water
Districts (H6MWD). It is diverted from the Mad River at the Essex
Pumping Station, transported by pipe 19 km (12 mi) to a storage tank
on the Samoa Peninsula, and piped to both the Crown Simpson and
Louisiana Pacific pulp mills. Pretreatment at the Crown Simpson mill
can include prechlorination, physical-chemical clarification and
filtration, and softening. Whether raw process water is subjected to
all these pretreatment processes is determined by use in the mill.
Process water use has declined from 91,000 m3/day (24 mgd) in
early 1976 to 76,000 m3/day (20 mgd) in late 1977. This has primarily
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15
resulted from the severe California drought which raised the specter
of mill closure and stimulated tight controls on mill water use.
PROCESS WASTEWATER DISPOSAL
Process wastewaters are collected by three sewerage systems: an
acid system which transports low pH wastewaters from the bleach
plant, a caustic system which transports high pH wastewaters from the
bleach plant, and a general sewer which transports the remainder of
mill wastewaters, surface runoff, water treatment plant sludge, power
plant wastewater, and minor amounts of wastewater from the Simpson
Timber Company plywood mill [Figure 3]. These sewers, in addition to
a small line carrying septic tank overflow, discharge to a sump where
wastewaters are commingled and pumped to an outfall line. Three
identical constant-speed pumps are rotated in service weekly so that
one is on constantly, one is on standby tied into a sump level in-
dicator, and one is out of service. The pumps discharge to a 15 m
(50 ft) section of 122 cm (48 in) stainless steel pipe followed by
930 m (3,050 ft) of 122 cm (48 .in) wood stave pipe which crosses the
sandspit and connects to the 91 cm (36 in) ocean outfall line. This
line is 736 m (2,414 ft) long and consists of a steel shell, a con-
crete outside layer to provide protection from sea corrosion and
erosion, and a plastic liner inside to protect the shell from in-
ternal corrosion and erosion. It terminates in a 62 m (203 ft)
diffuser section, with discharge about 11 to 12 m (35 to 40 ft) deep
[Figure 1].
INPLANT POLLUTION CONTROL
The Crown Simpson Pulp Company has sought to employ inplant
controls with no external treatment to achieve Best Practicable
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C a u stJcSpwer
Pacific Ocean
Outfa11
General Sewer
Bleach Plant
Acid Filtrate
Bleach Plant
Caustic Filtrate
Sump
-Affluent Pumps
-<3>i
_0_
_/7v .Station
"3500
Pulp Machine Room
Recausticizing
Power and Recovery
Hater Treatment
SIudge
Surface Runoff
Plywood Mill
Digester
Chemical Prepara-
tion
Figure 3. Crown Simpson Wastewater System
Fairhaven, California
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17
Control Technology Currently Available (BPT) limitations for TSS and
to gain a variance from BPT limitations for BOD and pH. With the
exception of fiber-saving devices built into the design of the mill,
no major inplant changes were made prior to January 1978 which re-
sulted in significant TSS removals. However, after the NEIC December
5-12, 1977 survey, a number of controls were reported* by plant offi-
cials to have been installed during the 1977 Christmas shutdown:
1. A larger pump was installed to recycle all excess pulp
drier white water to the bleach plant washers and the brown
stock washers.
2. Undeckered stock was substituted for white water for dilu-
tion after the bleach decker to improve consistency control,
prevent future spills and make more white water available
for reuse on the washers.
3. Floor drainage and stock chest overflow in the pulp mill
brown stock washer area were collected in a spill tank and
recycled to the process.
4. Pulp mill and bleach plant rejects, which were formerly
sewered, are now dewatered and burned in the hog fuel
boiler.
5. Mud washer and green liquor dregs, which were formerly
sewered after they were washed, are now dewatered and
trucked to a landfill for disposal.
These controls will reportedly bring the mill into compliance
with BPT TSS limitations.
* Letter of Jan. 13, 1978 from P.S. Dennon, Crown Simpson to T.
Dahl, NEIC and telephone conversation of Feb. 6, 1978 between M.
LaPointe, Crown Simpson and F. Early, NEIC.
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IV. SURVEY METHODS
FLOW MEASUREMENT
The Crown Simpson Pulp Company conducts no effluent flow moni-
toring of process wastewaters at its Fairhaven, California pulp mill.
Effluent flows are estimated by first measuring raw water entering
the mill with a flow tube (throat diameter 19.4 inches) from which
pressure differential is transmitted to a meter, converted to flow
and continuously recorded and totaled. The assumption is made, based
on past water balance determinations, that inplant water losses due
to evaporation are largely balanced by moisture in the incoming wood
and chemicals used. The Company estimates that the raw water flow
plus 1,100 m3/day (0.3 mgd) is a reasonable approximation of effluent
flows.
Since the Company's assumption that total water-in equals
water-out was untested, and the NPDES permit requires flow-propor-
tional composite samples, it was necessary for NEIC to measure
effluent flow. This was accomplished by using the tracer dilution
technique, with lithium as the tracer [Appendix C].
During December 3-11, 1977, the two constant-speed effluent
pumps being used by the Company (Pumps 1 and 2) were rated by NEIC 9
and 8 times, respectively with the tracer technique:
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19
Rated Flow
Pump 1
Pump 2
m3/day
x 103
mgd
m3/day
x 103
mgd
48.4
12.8
51.9
13.7
49.6
13.1
50.7
13.4
48.1
12.7
44.3
11.7
50.7
13.4
46.2
12.2
47.3
12.5
51.9
13.7
49.6
13.1
51.5
13.6
51.1
13.5
46.6
12.3
52.6
13.9
45.4
12.0
46.6
12.3
Avg.49.2
13.0
Avg.48.4
12.8
These average flows were used during the survey period. Since
Pump 1 was on all the time, its daily incremental flow was 49,200
m3/day (13.0 mgd). A continuous recorder was attached to the Pump 2
electrical circuit, thereby affording a calculation of the fraction
of 48,400 m3/day (12.8 mgd) provided each day. The sum of the two
flows constituted the daily flow.
To facilitate comparisons with the Company's flow estimates,
NEIC requested that the raw water transmitting and recording systems
be calibrated. These calibrations were satisfactorily performed by
Company personnel on Friday, December 2, 1977, in the presence of
NEIC personnel.
SAMPLING TECHNIQUES AND LOCATIONS
During December 5 to 12, 1977, the NEIC collected wastewater
samples at the Crown Simpson pulp mill for a wide range of parameters.
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Established chain-of-custody procedures were followed in the collec-
tion of all samples and field data and in the analysis of all samples
with the exception of the minor deviations noted in Appendix D.
Twenty-four-hour composite samples for BOD and TSS were collected at
the discharge side of the effluent pumps [Figure 3]. Aliquots were
collected each hour and flow-proportioned by noting whether one or
two pumps were on. Grab samples for oil and grease were collected
three times a day at the same location. Temperature and pH were
determined hourly.
To account for allowed solids in the raw water, TSS composite
samples were collected from the Company's intake line prior to all
pretreatment. All raw water composites were formed with equal-volume
aliquots collected hourly.
In addition to monitoring for NPDES compliance, samples were
also collected for three consecutive days, beginning the morning of
December 6 and continuing until December 9, 1977, to ascertain the
presence or absence of Priority Pollutants [Appendix B], A number of
these pollutants, as well as any chlorinated hydrocarbons and phenoli
compounds, are also limited in the future by the Company's NPDES
permit [Appendix A], Composite samples for the Priority Pollutants
were collected in a manner similar to those previously described,
except that all raw water samples for Priority Pollutants were single
grab samples, not composites. In addition, all samples from December
6-7, 1977 were analyzed for general organics.
All samples were stored at 4°C and preserved by techniques
promulgated by USEPA pursuant to Section 304(g) of the Federal Water
Pollution Control Act (FWPCA).
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21
BIOMONITORING TECHNIQUES
Commencing at 1500 hr on December 7, 1977, a 96-hour contin-
uous-flow bioassay was conducted on the final wastewater effluent of
the Crown Simpson pulp mill. The objective of this test was to
determine if the wastewater discharge was acutely toxic to fish.
Three-spined sticklebacks (Gasterosteus aculentas Linnaeus) averaging
approximately 4 cm in total length were used as test organisms.
Detailed methodology of the bioassay procedures are included in
Appendix C.
ANALYTICAL PROCEDURES
All samples were either analyzed in an NEIC mobile laboratory
set up at the Crown Simpson Pulp Company, or air-freighted to the
NEIC laboratory in Denver, Colorado for analyses. Split samples were
provided to Crown Simpson for separate analysis. Pertinent ana-
lytical methodology and quality control statements are included in
Appendix C.
SELF-MONITORING EVALUATION
During the December 5-12, 1977 NEIC study, the Company's
self-monitoring practices were evaluated based on interviews with
Company personnel and observations of monitoring equipment and
procedures.
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V. SURVEY FINDINGS
NPDES EFFLUENT LIMITATIONS COMPLIANCE
Effluent data collected during December 5-12, 1977 [Tables 2
through 5] show Crown Simpson exceeded its NPDES limitations for BOD
(pulp) 30-day average (11,000 vs 4,390 kg/day) and TSS (pulp) 30-day
average (22,000 vs 8,930 kg/day). The BOD (pulp) daily maximum
(8,420 kg/day) and TSS (pulp) daily maximum (16,600 kg/day) limits
were exceeded on 5 and 3 days, respectively, of the 6 days of re-
ported results. The Company also exceeded its NPDES pH limits (range
of 2.0-11.0 vs limits of 5.0-9.0 standard units). The Company was
within the oil and grease limits.
BI0M0NIT0RING
The Crown Simpson effluent was determined to be acutely toxic to
fish [Table 6]. The 96-hour LC50* was calculated to be a 28.5%
effluent concentration (95% confidence limits 23.2 to 35%)
[Figure 4].
It was not within the scope of the bioassay to isolate or iden-
tify the specific toxic components of the wastewater tested. However,
literature sources indicate that approximately 30 compounds have been
identified as toxic contributors to pulp mill waste streams. Major toxic
constituents are acid resins from debarking and kraft pulping processes,
chlorolignins from acid bleaching, and chlorinated phenolics, resin acids
and stearic acids from caustic bleaching.1
* LC50 indicates the concentration (actual or interpolated) at which
50% of the test organisms died or would be expected to die.
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23
Taole 4
pH AND TEMPERATURE DATA
CROWI SItlPSO,' PULP COiiPAtW
Fairhauen, Calx forma
Dec. 5-12, 1977
Time
Dec 5-6
Sta
3500"
Sta
3550c
Dec 6-7
Sta.
3500
Sta
3550
Tec 7-E
Sta.
3500
Sta
3550
Decs-?
Sta
3500
Sta
3550
Dec 9-10
Sta.
3500
Sta
3550
Dec 10-11
Sta. Sta
3500 3550
Dec 1
Sta.
3500
1-12
Sta.
3550
0700 6 7 7 4
0800 5 8 6.9
0900 5 7 6.9
1000 2.6 7.3
1100 2.2 7 2
1200 3.7 7 3
1300 5 2 7.3
1400 7 5 7.2
1500 6 6 7 2
1600 6.1 7.3
1700 6 4 7 1
1800 5.9 7.2
1900 2.9 7 6
2000 3.4 7 5
2100 2.7 6.9
2200 3.2 7.5
2300 2 8 7 5
2400 2.2 7 4
0100 2 2 7 4
0200 7.2 7.4
0300 8 6 7.6
0400 5.1 7 4
0500 5 6 7 3
0600 10.2 7.4
Max 10 2 7 6
Mm 2 2 6 9
Max 48.0 13 0
Min 37 0 110
Avg 43.5 12 0
8.2
7 2
2.0
2 6
7 4
3 8
3.1
7 3
3 6
3.3
7 5
2.5
6.0
7.2
3 4
2.0
7.0
4.7
3.1
7.1
5 3
6.4
7.2
5.7
5 5
7 1
9.4
3.5
7.2
2.7
6.4
7 2
6.3
6.6
7.3
2.2
5.3
8.1
6.1
11.0
7.5
5 5
10.6
7.9
8.2
6.3
7 5
8 2
6 4
7.6
3.0
6.?
7.4
3 8
4 9"
7 6
3.1
5.4
7.5
6 4
4 8
7 5
8.7
3.8
7 4
2.8
6 5
7 2
9.4
5.8
7.7
2 8
11 0
8 1
9.4
2.0
7 0
2.0
45 5
11 5
45 5
36 0
10.5
33 0
43.0
11 5
41 5
EH
7 3
3.5
7 3
7.1
2.9
7.4
7 2
2 6
7.3
7 2
4.8
7.3
7.2
9.7
7 4
7.0
10.1
7.5
7 1
2 8
7.4
7.2
6.5
7.5
7.1
3.3
7 4
-
2 9
7.6
7.1
3.3
7.5
7.2
3 8
7.6
7.6
3 8
7.4
6.9
4.4
7.9
6.6
3.8
7.7
7 7
3.2
7 6
7 8
3.0
7.5
7 1
3.3
7.4
7 8
3 1
7.4
7 6
3.0
7.8
7 7
3 2
7.7
7.7
3 2
7.9
7.8
2.9
7.6
7.6
3.0
7 9
7.8
10 1
7.9
6.6
2 6
7.3
Temperature (
12 0
48.0
10 5
10 0
39 0
8.5
11.5
42 5
10 0
2.2
7.5
2.4
5.1
7.6
3 5
5.2
7 4
3 6
5.3
7 5
4.3
6.8
7.5
2.7
6 7
7.4
2 9
10.1
7.5
3 3
8.5
7 6
5 0
9.9
7 5
4.7
6.5
7 7
5.4
6.3
7.4
3 0
7.7
7.6
6 8
6.1
7 1
3 5
5.8
7 2
4 5
5.2
7.3
4.1
3.3
7.6
4 6
3 5
7 5
7.0
3 9
7.5
4.6
2.4
7.1
5 6
2.3
7.7
3 0
5 0
7.2
3 6
6.2
7 7
2.9
4.9
7.4
5 8
2 8
7 9
3 0
10 1
7.9
7.0
2.2
7.1
2.4
46.0
10 5
46 5
32 5
8 5
35 0
40 0
9.5
42 0
7 4
3.6
7 6
7.6
5.2
7.5
7 7
3.9
7.7
7.6
4.6
7.6
7 5
4.1
7.6
7.6
4.0
7 5
7 7
3 9
7 7
7 3
5.2
7.7
7 5
6.1
7 6
7 5
4.1
7 5
7.7
6.2
7.6
7 6
4.2
7 7
7 8
9.9
7 1
7 6
4 6
7.1
7.9
9 9
6.9
7.9
3.8
7 0
7 7
4.5
7.6
7 7
6 7
7 7
7.7
6.6
7 0
8 0
5 1
7 6
7.7
6.2
7.6
7 8
3 0
7 5
7 8
4 7
7.7
7 8
5.1
7.3
8 0
9.9
7 7
7.3
3.0
6 9
11 0
45 5
12 0
9 5
36 5
10 5
10 5
42.5
11.5
a Suction 3500 - Crohn Sinpson process uasteuater at effluent pimps
o Station «550 - Crown Sinpson ana Louisiana Pacific water supbly at intake to Crown Svnsson before ami
treatment processes ' ' J
-------
24
Table 5
OIL AND GREASE DATAa
CROWN SIMPSON PULP CO.
Fairhaven, California
December 5-12, 1977
Date
Time
Oil
and Grease
Dec.
hr
mg/1
1977
5
1120
8.6
1620
7.8
Average
8.2
6
0235
3.7
0825
5.7
1625
6.7
Average
5.4
7
0120
7.3
0900
1.7
1800
5.9
Average
5.0
8
0015
5.1
1000
6.5
1500
10
2320
7.4
Average
7.2
9
1630
5.2
1930
8.0
2110
4.1
Average
5.8
10
0317
3.1
1715
2.8
1900
15
Average
7.0
11
0307
7.9
0523
9.6
0622
9.1
2011
5.4
Average
8.0
5-11
Average
6.6
a Station 3500 - Crown Simpson process
wastewater at effluent pumps.
-------
Table 6
96-HOUR FLOW-THROUGH SURVIVAL DATA
CROWN SIMPSON EFFLUENT
December 1977
% Survival
Time Period Effluent Concentration (%)
Control
5
9
16
28
37.5
50
24-hour
100
100
100
100
100
80
0
48-hour
100
100
100
100
100
30
0
72-hour
100
100
100
100
100
10
0
96-hour
100
100
100
95
60
0
0
-------
96-hour LC
28.52
Confidence Limits
Upper 35 0%
Lower 23.2%
(Litchfleld-Wilcoson 1949)
Corrected value for 0 or
100% effect
1
)
3
4
5
10
20
lOfl
X Effluent
Figure 4. Dose Response
Crown Simpson Pulp Company Effluent
December 1977
-------
27
The toxicity of pulp mill wastewaters can vary widely within and
between mills. This is principally a result of variations of acid
resin concentrations in the waste stream, which is primarily governed
by the wood species composition. High-resin species such as douglas
fir and various spruce woods generally produce waste streams of
greater toxicity than effluents derived from low-resin woods such as
western red cedar and redwood.2 Wood chip age and geographical
location of the wood source also affect resin acid content, and
therefore toxicity.3
The NPDES permit for Crown Simpson contained no specific ef-
fluent toxicity limitation in effect at the time of the NEIC survey.
However, the permit does control toxicity after initial dilution in
the receiving water, allowing a maximum of 0.05 toxic units [Appendix A].
The toxic unit value used in this context is derived by calculating
the actual toxic unit (100/LCso) for the effluent, and dividing this
value by the initial dilution factor. This factor, as required in
the NPDES permit, is 100:1 at least 50% of the time and 80:1 at least
90% of the time.
Based on data from the NEIC study, the actual toxic unit value
was calculated to be 3.5. Assuming 3.5 toxic units is not exceeded,
the Company will be in compliance with the receiving water limitation
of 0.05 toxic units when initial dilution exceeds approximately 70:1.
This implies that if the Company is meeting the permit limitation
requiring initial dilution to exceed 80:1 at least 90% of the time,
and the toxicity of the effluent does not exceed 3.5 actual toxic
units, the Company will be in compliance with the receiving water
toxicity limitation (0.05 toxic units) at least 90% of the time.
In evaluating the toxicity of the Crown Simpson waste stream,
two additional factors deserve mention: pH and BOD. As detailed in
-------
28
the Methods Section of this report [Appendix C], aeration of the
wastewater was required to maintain dissolved oxygen levels adequate
for fish survival. Without aeration, mortality would have occurred
at the higher effluent concentrations due to dissolved oxygen de-
pletion. The pH of the 24-hour effluent bioassay composites ranged
from 4.6 to 5.5 standard units. This pH range is marginal for the
survival of some fish species.4 However, hourly pH determinations of
the aliquots which comprised the composite samples ranged from approxi-
mately 2 to 11 [Table 4]. Either of these extreme pH conditions
would be acutely toxic to fish.4
COMPLIANCE WITH FUTURE NPDES LIMITATIONS
As indicated in Table 7, a number of other pollutants are also
included in the Company's NPDES permit for future limitations. With
the exception of total 'chromium, which has a compliance date of
July 1, 1983, the limits are not to be exceeded after July 1, 1978.
Composite sampling data collected by NEIC for three consecutive
days beginning December 6, 1977 [Table 8], indicates that most of
these limitations will probably be met, except phenolic compounds
(50% limit of 0.5 mg/1 vs NEIC average of 0.8 mg/1), total chromium
(50% limit of 0.005 mg/1 vs NEIC average of 0.01 mg/1), and total
identifiable chlorinated hydrocarbons (50% limit of 0.002 mg/1 vs
NEIC average of 1.8 mg/1). In addition, if the effluent toxicity
remains at levels found during the NEIC study, the Company will be in
violation of toxicity limits (50% and 10% limits of 1.5 and 2.0 toxic
units, respectively, vs NEIC value of 3.5)[Table 7].
-------
Table 7
COMPARISON BETWEEN CROWN SIMPSON PULP COMPANY
FUTURE NPDES LIMITATIONS AND NEIC DATA
COLLECTED DECEMBER 6-9, 1977
Constituents
Future
NPDES Limits
50% 10%
of time of time
NEIC Averaqes
12/6-9/77
Station 3500
Process Wastewater
mg/1
mg/1
Arsenic
0.01
0.02
<0.010
Cadmium
0.02
0.03
<0.020
Copper
0.2
0.3
0.022
Lead
0.1
0.2
0.021
Mercury
0.001
0.002
<0.001
Nickel
0.1
0.2
<0.1
Silver
0.02
0.04
<0.008
Zinc
0.3
0.5
0.060
Cyanide
0.1
0.2
<0.01
Phenolic Compounds
0.5
1.0
0.80
Total Identifiable
Chlorinated
Hydrocarbons
0.002
0.004
1.8
Toxicity Concen-
L
tration
1.5
2.0
3.5
Total Chromium
0.005
0.01
0.101
a Measured in toxic units
b 96-hour bioassay commenced 1500 hr on December 7, 1977
-------
Table 8
METALS, CYANIDE, PUCtlOLICS Alio CIILORIMATED HYDROCARBONS DATA
CROHN SIMPSON PULP COMPANY
Fairhaven, California
Dec. 6-9, 1977
Parameters"
Station Location O.Ueb Time Flow Sb As Hp Ctl Cr Cu Pb Hn tli Se An T1 7o Cn"|~Thc.ior ic Chlor ...at.-.i ,
• ^ .— Co'"nounds Hyili ot »->ns
CC' hr m /day mgd yg/1 pg/1 vj/l ug/1 wg/1 vg/1 yg/1 ug/l mg/1 pg/1 ug/l rng/1 ug/1 mg/1 mg/1 ,„g/ j
x 103
1977
Station 3500 -
7
78.7
20.8
<30
<10
<0.2
20
10
31
13
<1
<0 1
<10
<8
<5
50
<0 01
1.0
1 3
Crovm Simpson process
a
-d
-
* 30
<10
<0.2
<20
10
12
26
<1
<0 1
<10
¦-!} 'o Symbols SO - antimony; >1s - arsenic, Be - beryllium, Cd - cadinuun, Cr - chromium Cu - carper Pb - Lead-
Hg - mercury, Ui - nickel; Se - selenium; Ag - silver, Tl - thnlliw.t, /.n - :inc, Cn - total cynnule
b Station 3500 data based on 24-hr composites of ahquots collected hourly from 0700-D700. Date listed is Jijk ccr.zcsitii.n
period ended. Station 3550 data based on single grab sample per day since uater supply considered staolc source,
o Data not included as sample suspected of contamumtion
d Effluent pump breakdown and flow recorder naif unction precluded measurement of J lot J
c trom Priority Pollutants sampling. Note concentrations for Station 3500 are largely a result of chlorofor.n [7-iblr -'1
f tW = Hone detected L ' " 1
CO
O
-------
31
PRIORITY POLLUTANTS
As noted previously, samples were also collected December 6-9,
1977 to determine the presence of Priority Pollutants [Table 9]. In
addition, the samples from December 6-7, 1977 were analyzed for
general organics [Table 10]. Thirteen Priority Pollutants were iden-
tified in the effluent samples. The compounds identified are repre-
sentative of the natural wood products and chemicals used or created
in pulping and bleaching processes.
Two priority Pollutants, di-n-butyl phthalate and diethyl phthalate,
were present in the raw-water supply in low concentrations, 1-3 ppb.
COMPANY FLOWS VS NEIC FLOWS
The EPA has established a guideline* of +10% for flow monitor-
ing accuracy. A comparison between the effluent flows estimated by
Crown Simpson and those measured by NEIC indicated the Company method
is marginal [Table 11]. The overall CS/NEIC average was 1.16, and on
4 of the 6 days monitored, the Crown Simpson flows were approximately
25% higher than NEIC values.
Furthermore, the Company practice of using raw-water flows and
then forming composite samples with equal-volume aliquots ignores
diurnal flow rate changes. As noted in Figure 5, depending on whether
1 or 2 pumps were on, the flow rate would vary by approximately 100%.
The EPA recommends** that "If the flow rate does not vary by more
than 15% of the average flow rate, a time intervaled composite...wi11
provide a representative measurement of the wastewater characteristics
and load discharged over the sampling period."
* NPDES Compliance Sampling Manual, June 1977 (p. 57).
** NPDES Compliance Sampling Manual, June 1977 (p. 28).
-------
Table 9
PRIORITY POLLUTANTS3
CROWN SIMPSON PULP COMPANY
Fair-haven, California
December 6-9, 1977
Compound Compound
Number
Station 3500
C.S. Process Wastewater
At Effluent Pumps
12/7* ~
12/8 12/9 Avg.
Station 35501
Rau Water Supply at Intake To
Mill Before any Treatment Processes
12/6 12/7 7 2/0 Avg
@1530 @2000 @1030
Detection
Limi t
1 Acenaphthene 0.2
2 Acrolein "
3 Acrylomtrile ®
4 Benzene J <1 <0.5 2 <1 0 5
5 Benzidene 1 o
6 Carbon tetrachloride 3 0 5
7 Chiorobenzene 3 0 5
0 1 ,2,4-Trichlorobenzene 0 4
9 Hexachlorobenzene 0 3
10 1 ,2-Dichloroethane J . 0 5
11 1 ,1,1 -Trichloroethane 3 0 5
12 Hexacliloroethane 0 2
13 1 ,1-Dichloroethanc1' 0 5
14 1,1 ,2-Trichloroethane7 1
15 1,1,2,2-Tetrachloroethane J 1
16 Cliloroettiane 3
17 Bi s(chloroiuethyl) ether 3
18 Bi s( 2-chl oroethyl) ether 0 2
19 2-Chloi oethylvinyl ether"
20 2-CliloronaphLhalene 0 1
21 2,4 ,6-Trnchlorophenol 84 75 120 93 3
22 para-Chloro-meta-cresol 3
23 Chloroform J 1,200 1,800 1,900 1,600 0 5
24 2-Chlorophenol 13
25 1 ,2-Dichlorobenzene 0 2
26 1 ,3-Dichlorobenzene 0 4
27 1 ,4-Dichlorobenzene 0 4
28 3,3'-0ichlorobenzidine°
29 1 ,1-Dichloroethylene 3 0 5
30 1 ,2-Lrans-Dichloroethylene J 0 5
31 2,4-Dichlorophenol 23 19 36 26 2
32 1 ,2-Dichloropropane 3 0 5
33 1 ,2-Dichloropropylene 3
34 2 ,4-Dimethyl phenol
35 2,4-Di 111 trotoluene ^
CO
ro
-------
Table 9 (Continued)
PRIORITY POLLUTANTS
CROHN SIMPSON PULP CO.
Fairhaven, California
December 6-9, 1977
Compound Compound Slotion 3500
Number C.S. Process Wastewater
At C f f 1 ucnt F'uiiijis
"12/7 12/8 12/9 Avg
36 2,6-Dinitrotoluene
37 1 ,2-Diphenyl hydrazine &
30 Ethyl benzene 3
39 FluoranUiene
40 4-Chlorophenyl phenyl ether ^
11 4-Oromoplienyl phenyl ether
42 Bis(2-chloroisopropyl) ether
43 Bis(2-chloroethoxy) methane
44 Methylene chloride-?
45 Ilethyl chloride J
46 Methyl bromide J
47 Bromoform 3
48 DichlorobromomethaneJ . 3 4 3 3
49 Trichlorofluoromethane «7
50 Di chl orofl uorome tlianeJ
51 Chiorodibromoinethane <7
52 llexachlorobutadiene
53 Hexachlorocyclopentadiene
54 Isophorone
55 Naphthalene
56 Nitrobenzene
57 2-Nitrophenol
58 4-Nitrophenol
59 2,4-Dinitrophenol
60 4 ,6-Dinitro-o-cresol
61 IJ-Ni trosodimethylannne
62 N-Nitrosodiphenyl amine
63 N-Nitrosodi-n-propylamine
64 Pentachlorophenol
65 Phenol 9.9 79 840 310
66 Bls(2-ethylhexyl) phthalate
67 Butyl benzyl phthalate
6B Oi-n-butyl phthalate 10 1.5 1.2 4.2
69 Di-n-octyl phthalate
70 Diethyl phthalate
Station 3550'
Raw Water Supply at Intflle To Detection
ill liolore .my Tim Impnt Processes Limit
12/6 12// 12/U Avg.
PI 530 02000 @1030
0.4
4
0 1
0 4
0 1
0 2
0 5
2
0.5
2
1.5
0.3
1 5
0 1
0 1
0 2
4
100
2
4
0 1
0 2
2
6
11
0 1
<0.1
10 <0 1 <0 4 0 1
0 1
3.0 2.0 2.0 0 1
-------
Table 9 (Continued)
PRIORITY POLLUTANTS
CROIJH SI UPSON PULP CO
Fairhaven, California
December 6-9, 1977
Compound Compound Station 3500
Number C.S. Process Wastewater
At Effluent Pumps
Till 12/8 T2?9 Avg.
71 Dimethyl pfithalate
72 Benzo(a) anthracene
73 Denzo(a)pyrene^
74 3 ,4-0enzof 1 uoranthenek
75 Benzo(u)fluoranthane^
75 Chrysene
77 Acenaphthylene
78 Anthracene5
79 Benzo(g,h,i)perylene^
80 Fluorene
81 Phcnanthrenec
82 Dibenzo(a,h) anthracene^*
83 Indeno (1,2,3-cd)pyrene^
84 Pyrene
85 TetrnchloroethyleneJ
86 Toluene^
87 TrichloroethyleneJ
88 Vinyl chloride^
89 Aldrin
90 D^elchn
91 Chlordane
92 4,4"-DDT
93 4,4'-DDE
94 4,4'-DDD
95 a-Endosulfan-Alpha
96 b-Endosul fan-Beta
97 Endosulfan sulfate^
98 Endrin
99 Endrin aldehyde^1
100 Hcptachlor
101 Hcptachlor epoxide
102 a-GIIC-Alpha
103 b-E!IC-Beta
104 r-BIiC (1 i ndane)-fiamma
105 g-BHC-Del ta
<1 2 2 <2
Station 35501
Raw Water Supply at Intake To Detecti
Mil 1 Before any Treatment Processes Limit
12/6 "12//" "12/8 "Avg"
01530 @2000 31030
0 1
0 2
0 1
0 1
0.1
0.1
1
0 5
1
0 2
0 2
2
0 5
0 1
0 5
0 1
0 2
0.2
0 2
0 2
0 2
0 2
0 2
0 2
-------
Table 9 (Continued)
PRIORITY POLLUTANTS
CROWN SIMPSON PULP CO.
Fairhaven, California
December 6-9, 1977
Compound
Number
Compound
Station 3500
C.S. Process Wastewater
At Effluent Pumps
1277 1 2?8 12/9 Avg.
Station 35507
Raw Water Supply at Intake To
Mi 11_ Before any Treatment Processes
"Y2/6 ~ "12/7 12/8 Avg.
(31530 @2000 01030
Detection
Luni t
2
30
10
106 PCB-1212 1
107 PCB-1254 1
108 PCB-1221 1
109 PCB-1232 1
110 PCB-1218 1
111 PCB-1260
112 PCB-1016 1
113 Toxaphene ^
114 Antimony
115 Arsenic
116 Asbestos^
117 Beryllium _
118 Cadmium
119 Chromium
120 Copper
121 Cyanide
122 Lead
123 Mercury
124 Nickel
125 Selenium
126 Silver
127 Thallium
128 Zinc
129 2,3 ,7 ,8-Tetrachlorodibenzo-
p-d iox i rt>
20
<20
<20
<20
20
10
10
10
10
10
34
12
20
22
4
13
26
24
21
5
1
0.1
10
8
5
50
50
80
60
40
a All concentrations in micrograms per liter (\ig/l). Except thallium and nickel in milligrams
per hL,->r.
b Compound not measured due to analytical difficulties in the methodology or standard availability.
c Dnta jor this parameter for this sample was inadvertantly discarded prior to quantitation,
d I'resencc is urieiplained but iderttification is within criteria established by the method,
e Phenanlhrcne and anthracene cannot be resolved, data reported represents either or both of these
compounds.
f Detection limits for extractable organics are based on a HI extract concentrated to 1.0 ml.
Volatile organics are for 5 ml of sample,
g bis (chloromethyl) ether is not stable in water and cannot be recovered from the standard,
h Cn/serr and bc:nr,o(a)anthracene cannot be resolved, data reported represents either or both of
the c compounds
i I j.tractaole organics were measured at 5 ml extract volume The detection limits for these
.mles for the rrLra''!.ahle organics are therefore 5 tines those reported in the last rohtmi.
,j i' > u tes_a jion-rxtroc Luble parameter for organic;, e.n volatile orqanics
'-1'itiOn 3500 data busrd on 24-hour compost les <,ollectt>r. hourly from 0700-0700. Dale (j-f
it t'd is dan c>-" t-i > q period ended. Station SiioO r'-.ta based on single grab s-rnplr prr day
'jLnce water supply considered stable source.
-------
36
Table 10
GENERAL ORGANICS DATA
CROWN SIMPSON PULP COMPANY
Fairhaven, California
December 6-7, 1977
Station
Compound
3500
3550
Process waste-
Raw water supply
water at
at intake to mill
effluent
before any treat-
pumps
ment processes
yg/1
Acetovanil1 in 46
Alpha-pinene 83
A1pha-terpineol 1,600
Borneol 970
Camphor 110
Dibutylpthalate 1
Diethylphthalate 1
2.4-dihydroacetophenone 32
2.5-dimethyl-2-cyclopentanone 9
Dimethyl disulfide 50
Endo-fenchyl alcohol 240
Guaiacol 2,200
Nerolidol 65
a Identification by comparison to reference specta only; no pure
standard was available for direct comparison. Quantities are
estimates only.
-------
37
Table 11
COMPARISON OF FLOWS DURING
DECEMBER 5-12, 1977
NEIC vs. CROWN SIMPSON
Flow
Month
Daya
NEICb
Crown Simpson0
m3/d-
x 10J
mgd
m3/d~
x lO"3
mgd
CS:NEIC
December
5-6
78.7
20.8
82.5
21.8
1.05
6-7
78.7
20.8
80.6
21.3
1.02
7-8
-
_d
78.0
20.6
8-9
62.8
16.6
78.3
20.7
1.25
9-10
64.7
17.1
80.6
21.3
1.25
10-11
62.8
16.6
78.3
20.7
1.25
11-12
65.8
17.4
81.4
21.5
1.24
Average
68.9
18.2
80.2
21.2e
1.16
a Flows were determined 0700-0700.
b NEIC effluent flows determined every hour.
c CS effluent flows estimated by Company as (Influent Flow + 0.3 mgd).
d Effluent pump breakdown and flow recorder malfunction precluded
measurement of flow,
e Average excluding 12/7/77.
-------
30.0
25.0
Flow Record
20.0
10.0
o
o
C\J
o
o
o
o
o
o
C\J
o
o
o
o
o
o
C\J
o
o
o
o
o
o
CM
o
o
o
o
o
o
CVI
o
o
o
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o
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C\J
o
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o
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o
12/6/77
1 12/10/77• 12/11/77
12/8/77
12/9, 77
12/7/77
Date
Figure 5. Process Wastewater Diurnal Flow Variation
Crown Simpson Pulp Company
Fairhaven, Cal lforma
December 5-1?, 1P77
-------
39
As can be seen in Figure 5, diurnal flow rate changes were consider-
ably in excess of this criterion.
SELF-MONITORING EVALUATION
The NEIC evaluation of the Company's self-monitoring practices
indicated the following procedures were contrary to prescribed/recom-
mended techniques:
Sampling Techniques
1. The instantaneous effluent flow rate varied according to
the number of pumps in service. Composite samples were
collected by automatically collecting equal-volume aliquots
at equal-time intervals, irrespective of the flow rate.
Hence, the samples were not flow-proportional as required
by the NPDES permit. Furthermore, these samples were unre-
frigerated during collection, contrary to required re-
frigeration at 4°C.
2. The pH was determined on each of the 24-hour composite
samples, then averaged for the samples collected during the
month, and this one value was reported to the California
Regional Water Quality Control Board, Santa Rosa,
California. The NPDES permit requires a continuous
measurement of pH. The Company has a continuous pH
recorder installed, but does not report this data to the
State.
3.
Metals samples were collected and transported to Camas,
Washington to the Crown Zellerbach labs without the
prescribed acidification.
-------
40
4. Phenolic compounds and cyanide composite samples were
collected in a plastic container, not glass as prescribed
and not preserved or refrigerated during collection.
5. Oil and grease sampling consisted of a single grab, not an
8-hour composite as required by the NPDES permit. However,
collecting a composite sample for oil and grease is ex-
tremely impractical and is not recommended by EPA.
Flow Monitoring
1. As noted previously, the Company estimates process waste-
water effluent flow with metered raw water flows. This
practice was determined to yield marginal results for daily
flows, and also precludes collecting flow-proportional
effluent composite samples.
2. Raw water flow monitoring equipment is calibrated approxi-
mately once a year. This should be conducted at least
every six months, or sooner if problems are indicated.
Analytical Procedures*
1. The Company was using a modified procedure for oil and
grease analyses [Appendix C]. No formal modification
request had been made, as prescribed, and no data had been
collected to establish comparability with the EPA-approved
method.
* Methods observed included BOD, TSS, oil and grease, SS and pH.
The remainder of the analyses [Appendix C] are performed at Camas,
Washington and could not be observed at the time of the survey.
-------
2. Though not specifically required by the NPDES permit, the
Company had established no formal analytical quality con-
trol program.
Other
Despite the fact that the NPDES permit contains 30-day average
and daily maximum TSS and BOD loading limitations, the Company re-
ports only a monthly average flow and an average pollutant concen-
tration to the State of California.
-------
REFERENCES
Leach, J.U. and Thakore, A.M. (1976), Compounds Toxic to Fish in
Pulp Mill Waste Streams. Proceedings of the 8th International
Conference of the International Association of Water Pollution
Research, Sidney, Australia, October 17-22, 1976.
Swan, E.P. (1973), (Resin Acids and Fatty Acids of Canadian
Pulpwoods - A Review of the Literature. Information Report
VP-X-115 Canadian Forestry Service, Department of the Environment.
Ottawa, Ont.
Rogers, I.H. (1973), Isolation and Chemical Identification of
Toxic Components of Kraft Mill Wastes Pulp Paper Maq Can 74
T303-T308. a L
Water Quality Criteria (1972) EPA-R3-73-033.
-------
APPENDIX A
CROWN SIMPSON PULP COMPANY
NPDES PERMIT NO. CA0005282
-------
FJ.'-r LT A
SVATC WATER RKSC. .ioui.vei , th<-* pro\-jruty
I ~ r.ill opCiTStJur,s to t' o bay hut re uJ t in di:chaiTj
rf npills, iO-jc?nrr •jfor'.i/'1 et ri.i.off or Jeachoro
fron c'-.t^s or iuiJ ;c. H.mcoJoL I'iv.
II ^ 11 nclivitic. ioj result in d - • <. ii.irgc- or i... te or
lenchrtc i com chips or fuel to gi undw tcr oi the Srnoa
I-Vnr. it. Id
-------
Ihc Rc.qional 30drd adopted thf Water Quality Control
Plan Cor the Horth Cojitill IKi.m I'jaiin ?l,iu) on Marcn 20
19 75, and adopted revisions thereto on Mnrch ?S 19 IC>
Tho B.nsin Pljn incoraocotm li e Occin I'lan and the w.n'cr
Qualj iy_Conrrc J t'oluy for th^ fficlcj^d r!;,y^ dncl ..Lu'ric*,
Cjli£ornia. It contnir.j eit'liipnc limitJtiom and
water quality objectives for Pacific Ocean iliiChargas
a"-d prohibits most discharges to Ilur.boJdt Bo-/.
Provisions of the Ea^in Plan, including Ocecm Plan
effluent limitations, ore applicable to the discharge.
Tne benefitical uses of Pacific Ocean and Hu^bolct 3gv
include:
a. industrial water supply
b. navigation
c. water contact recreation
d. noncontact water recrention
e. ocean commercial and sport fishing
f. maiinp hrbitnt
g. fish migration
h. fish spawning
i. shellfish harvesting
The beTeficial uses of shplJov fresh ground /filer on the
Samoa Peninsula irclude donescic water supply. The uncer-
tainty of supply and the susctotibi1itv of this water to
degradation fron over nu-npi-g, percolation of sevagp,
by salmi cy fron dredged "latenal disposal and ether
activities h?s encouraged dewlopr.it.Rt Ly the Humboldt
Bay Municipal Vai.cr District (}ID>'.VD) of a .Jster system
utilizing -•'3d 3i\er supply. C ronnd'.«?ter in area^ rsl/irg
upr- its use snould be protected '/ivh mini"' n risk of
dsc—diiti on fro;r> waste discharges.
Tr.e di^Ciisrycr has requested c-^eTptions froi'',:
5. ~ceen Plan Table A effluert limitations on:
Floating particulates
Sjsppnded solids
SettloabJe soliris
Turbidity, and
Ph;
b. Ocean Plan Tjble B effluerc limitations cn ciro-niu.i
c. the 13 vie schedule provision of Slate Boord Re^oluL'.on
Ho. 7^1— 5;
d. FPA Cfflu""'1. 13 vi t ?tions Guidelines based linulE,-
tjcir1: on:
BCD and rii.
-------
7. Regarding the exempt "nj from orean Pijn effluent
limitations requester by the dilc!i irgcr :
a. Floating Porticuja res. Trio absence of any limi-
tations on floating pjrticulutcs will not interfere
with compliance "i:h the v.itcr aaality objectives
set forth in Chapter TI of the Occ^n Plan and w11
not interfere with coTpliaacc with the effluent
quality reqiurcments set forth in Chapter IV,
Table B of th** Ocean Plan.
k- Sui.po-idecl Solids. Discharge of suspended solids
at tno rates specified heroi-i will not interrerc
with coinnliance with the w.itcr quality objectives
set foctn ii Chapter II of the Occor ^ia". and will
not interfere with compiler ce with the efiluc-nt
quality requirements set forth ±n Chapter IV,
Table B of the Ocean Plan. Since the suspended
soljdo from the water treatment plant consist of
silt from the Mad River that would norrslly oe
discharged to the ocean, it is appropriate znni
the limitations on suspencvd solids De on a n^t
baois Thu~, the monitoring rcquj rcincnto will bfi
est3D]ished so as to give credit for suspended solids
resulting fro^i water treatnent plant operations.
c* Settleablo Solids The ;ib;t.nc; of any limitation:]
on settlesblo. so J ids will not interfere with
l_ = nre with tie water ::ualitv objectives set
frrtr. m Chapter II of the Ocean ?ia~ and Mil nc-
lntcrfere with coanJianco i.itn tre effluent qjality
requjrencnts set forth n Chapter IV( Tacle 3 of
the Ocean Plan
d. T-i^Vn dity. The absence of any limitations oi turbidity
will not interfere with co pliance with the water quality
objectives set forth in Chapter II of the Ocean Plan and
will not interfere uith corplidiice witn the effluent
quality requirements set forth in Chapter IV, Table 3
of the Ocean Plan m tnat the turbidity from the water
treatment plant consists of silt and clay from tne Had
River that would normally t-e discnargcd to the ocean
e. £H. Discharge- of effluent:, with .) pi! within the
range specified herein will not interfere with
coupliance with f e water quaJitv objectives -,et
forth in Chapter II of t^o Oce^n Plar and will not
l t erf er o wifi conpliancj .it'n the effl'jjn! qj.jlitv
require merits :n forth n Chapter IV, Table B of
the Ocean Plan.
f. Ch cct ] lit .md Tiin'a .S-hed"lr Provision or SI,if.-- Ilj i r j
Resolution "In 74-'' Tne t.j-.rhaigi-r hj., present'ij
substantial cviocrci" that c orvl i jri'.o with c'lrrsriu-i
limitation, basrd on Chcpti r IV, Taolc- H of tne
Oc. i'dn Plan is not possible* through nrn11 c .it lor. o-
.source ro'itro1 j aid the be 1 practicable conttol
tcchnolon" c'rrc"'"l,, avail
-------
8. Oi Juii,. 7 1, 1075( i! di'ich.ifci'.r subm 11 rci to th^
^egio^ttl 3ocirc a reo.-est For v irumcc from K'A
effluent lnzt; ^nsLa on Tunc!. 'entally different,
factor".. Th'3 request vas lamented by t c ¦> 11. na rv
ard evidence cre^ented by thi. -Ij^rhargcr dur. q t'-io
course of public hearings bofeic both the Hegioruil
Doard and tne Stave Board.
Da'ied upon said tostinony and vidtnee, the State doard
find6; that effluent exceeding 'ho EP^ guideline limita-
tions for BOD and pH has subsl mtmlly no adverse
effect, on the marine environment when pj operlv diffused;
that there will be few if any 'atci quality benefits
associated with treatment for !0D or pH, that t^cr;
will be substantial onvironne'i; al ard energy costs
associated with trcatTent fOi. 'iOD and/or ph; and chat,
therefore, under the precedent estaolishfd by the
U, S. Court or Appeal'". (fourth Circuit) m its
decision in the case of ? pnal .'-hi rn Po"f.r Conocnv vs.
Train, a variance from the EPA guideline limitations
is warranted. The State 3oard therefore grants herein
a variance froT effluent limit -tions froir EP'i guide-
line Imitation', for pH and fo.- BOD generated in the
pulp mill, subject to final ap-roval of the variance
by the ^dninistrator of EPA.
9 . H.xcsp: Si provided in rinding !', above, cfflj;/'r 1. aira-
ticr.i -vrsu?n'c to Section 301 i.' the l'ed'iral Water
? r L_-i~L o-i ConvroJ Act ^nd amen< _,.cnt i thereto arc
epp— "Is to the discharge. 'i,ie limits are con', ai-sd
ir. ";de of rcdei^) Regulations
10. The ci'jci.srgcr has rec'jjs^ed tu. .. limits lor BOD ai
ei tabli?rsed m Cod? of feaeral ' igul ,tj ons se deleted
from rer'^iromenrs for discnarre to op-n oc.-an wato;s by
dLffu iers. Tnt: State Hoard £i->'s th.-t adoption o~ BCD
limtj-t' OTiS is approprute to l.i regulation of ciic::;rgci
to the P:.c;Lfjn: Oca an.
T ,j 5-"zu Board n ?s pftir.ee ~'i diner.:'r cr: nr-d lpi^restcc
and perjon1; o~ its intent Lo prc.sr:ni;2 unst1:
ciistr.—ri rtsquj.-(.•napis for tha r"j scrarco <;-c. hi": provided
t!w,-i v:-.i an cp^.ai tu.u ty to ^ubpit trcir written vica
ar.c r::c.,r.end:.t:or,5.
!-• The Board in a public heajipg heard and conMcinrcd
all puitainjng to tne c~ascnrrv3^.
'¦'IR' d.idM^er is ci'irnQ; cU'.l' irgirq irid'-r >vte
di -L.na.c,j r>:a.:ri" opc.s LSj.jed -j> i!ie l'.;.qicir,al iJoarc:
o "i S(,pt. Lsr JiJoO, i', raoni'orino and rtf.crti'ig
unt'er 'on1 Lor_ "Cj uMd R^nov ; n.^ Pv nji jri
-------
T—if IS O'iD.'ilvEP !_nat 111'"- Crown iiirp-.on 1'illn Con.-ny,
i" ore ir to iTStft: th^ prov triors c.ontjjn't1 in ~l of > ha
CsU.cr-'ii i;ater Code and regulations ot'o, Loci tiVi r^v "dsr .lricl the
dtvj jicnG of the Federal Hacur FoLlunon Control -^-ct, ,md re-c^la-
Liors ."rid cjuii2li"!>s adocted thereunder, i »•• a 11 coi.pW with t.-a
folio., ma-
rt . Prohibitions
1. The discharge of waste to Hu-nbolot Bay is prohibited
2. The discharge of waste to snallo" ground'Mrere oj the
Sar?oa Peninsula, except iii v.nich groundwater is
unsuitable for dorr.ectic use, is prohibited.
3. The discharge of Wciste to the Pacific Ocean, except
as provided under D. 2. of tr.ib ojdor, is pro uoiUd.
4. Discharge of radioactive natcrials m excess of tnp
lmits prescribed in Section 3020 of tn? California
?dEinistrut:ve Code is pronabicej.
Disch?rge of ?ny wastewater polJrtnnls rpsultini ^»*cri "A wood
rctunpq i hie'- utilizes vcicsr ns a rr, , r.rteri?! i"s" prohl
£f f1m-~ t.itio'is
1- '*">=¦ iiscnsrge of an effluent to tne Pacific Ocean
v»hi_r. exceeds the follcving is piohibited:
n/ !V 30-day—^
30-day- 30-dr,y- 90 th Daily
•"> -11 tuent s ~ : l s Average Medi^ila Pa i-li-.
fICD 30 -- -- 4/1.4
'C5 (pvlr,! lbs/dcnv y 9,660 __ __ 1R(3a)
W
TH
i-v-riijo of v a1 ue
i 11 not bo oeteri lined
Tl-,o \ .ilu<- 'ohich i 'j
rj.'v !0 tn->t,c(.uti'«'
l r , i?r than fouL
~~iZ < "¦ Imo 'vhich i
a.iy JO coi;rculno
ii •:/ Lh 'nil pot. ba d'e t c —i ,-,.d
r.aTiplv.s frc r^alved.
on GOO '.oi3 per day rvern^e m.vir1!. ,n odcrion.
-------
./ • / D0-«.ioy-^
Cot, ¦ t -t- U,ut 3°" ^ 30-J'y_ 901 h Dailv
ir Li iiut, _£ZilLne Nodj.in_ yui,; IU
iri)
C" lbs/ft [_/ 0-0J5 -- -- 0.0-15
lbs/day 142. f. — -- /?7_ 5
Sj^rr "acd
iolics ry
d
'•erevr}
Nickpl
mg/1
mg/1
ng/1
mg/1
mg/1
mg/1
0.01
0.02
0.2
0.1
0.001
0.1
C.C2
0.03
0.3
0.2
0.002
0.2
£/ In addition to the suspended solids in i iio raw .vavcr sunplv.
t/
'i/
po.ro': of HOD- pet runic Lcot of produt
i- th.-r i, the fii'l product or t'us L -•
0 pIv'-ooc : [ the vcrit;pr ir> furrhor pre
1 !i l 1 f in I i ty
J!i.' sin.i ' .ilioi/nalc d.u ]y no ,.s ctii'jSl.
li tc.n ir Ii.cn ? rioovtj vi.iil bo crlc-l,.
CLoi. occ Jrr;no rtcii ^ icj ci , q ~iy G nd t 11
di£0* - "j-i rrnui r fMcri 11 a*"> thr',
t!" .in 10 ji-rr.cr>t uf the. tun.. The mi.-, ,
" ' ' . " in i • ii. | Mil'/ / 11, ill I ] j. I I . i. i ,i, ,
inn in icr'Tj of vr net1 r f
iljLy, or pc-.r c.ibic Coot
'"¦'.bed into plywood r>L
n rate Cor e.nrli ro i: til\:
v'd f ro i tre total
coi i cr.t ration spprifi.01:
not to bo overoc'oa
m i . i on r.i* « oi ; nv
' I y '»> i . t i.u 11}ji
ri'!') ib I " mo n i h J y
• i I I 'i / ii 111 11
l'ii 1 rna '; 'i 'iii
Cul'i I I t l''MI t ll , t cd in
lot ? I i^sti' f lev orcj:
rc '!r;r; op sriec1 r j c d ;
I M< 11
•...I I
ul I n 11 .!]»
I t L II 2
riny ir:
n tPsie
to ii.: i u .\-iii d mo; c tnan "0 p.
i 1 ¦ 1 r»ion rili"4 oi tJio dl > o.i rc"j.,
• >" > i .u.r ,i 1 1 ci ;,v
¦> n r
i il <
111*1'.'. OM1 J
Ijovi! <,h .i I
1 jc'i :;rv (
c' i. -charqc
icort o." ,
c.n ri nti .-
i • "
. i, i
i "ii i t I (• i n i ii li
be I'Mi'i11 -tfd f lo.i th"
lie mo"th jnd the ccn-
'•ccuirr 'cni', .is tn.-t "o*
ic 11ro. The nn:,;>
v iiio:T-hlv .nriod si-.-,'1.
I .1 ¦ ¦ < 111 *¦ ¦ i rt i i iic .
-------
Const ] tuent
Um t'-
50%
Of Un«-
10%
of t j
i> 1 ' v - c
'i.rc
Cypr.i.-
c Corpounda
Tot."1. CI :nriT> Rosjdiinl
'T.^onci i c pres jcd no nitrogen)
Total icontirlable Chlorinated
Syrfrocorbon-5 x/
TomciL ' Career tr a tion
mg/l 0".02 0.04
mg/! 0.3 0.5
mg/l 0.1 0. T
mg/l 0.5 1.0
tnc/l 1.0 2.0
inq/1 40.0 o0.0
mg/1 O.OC2 0.004
tu 1.5 2.0
3. The; discnarge of ^n effluent in excess of tho following
l:-nits is prohibited. Q/ ^/
507i 10%
Constituent llnito oC 11'pe of 11r~ia
Total Chromium mg/1 0.005 0.01
4 Upon approval jy the Admin: str;' or of EPA of the finding
of "fu.-d.'menta 1 di-ffere.icc" cj L ~d in 1'incinq 8, above, the
folloui-,g limitations. shall app y in lic-u of ttie limita-
tions in 3. 1., aoc-vc, for tho cllowir.g pircT3torj. The
li.iii t stions contained in B 1. hall cori.ir.uc to apply for
all other parameters. Should t >e Ad-.unistrai.or aporo^e a
variance but find tnal limitations otner tnan the following
are aporoon at e, the Regional I.v.ard shall revise these
ucslp discharge requirements co 'Sistent nth the limitations
approved by the Admnis traior .
30-dr,y Daily
Co" U'-nt- Unit s Average "ia\isir
HOi), (pulo) lbs/day—^ 40,000 96,000
p.!
wiLhm the Jinuts 3 0 and 10.0
lor-1 tdi-Tti ru'e.1 Chlorm?Li".l tjci >w> «.h.ill be jir.T.i'ro'l
by '"-..g tri*1 i r"i l ^ l iJu a I rcnccnti.'.ooi' of DI1T, HU'J, 1)"', , .'lori'i,
r ' '>' i"1' i"l "> n o, ori'ili, ho-jl- icliloi , 11 r .no, c'l .r'rj n , oc \ \ ch ] l j. a-. <-c
.-"J c t er identifiable r lo- anted d roc r roorL .
-------
l ">c '.htur I., -'-tat ions
1. Tno riischarqs shall not cause Gloating particulates,
foa-u, or gr?nsa ard oil to be visible.
2. T.ie discharge; shall not cause aesthetically undesirable
discoloration of the ocean surface.
3. The trar.smtta ice of natural I i oh t -nail not be
sign! 1 can t Iv red^coil at any rjint oulsida lr. totrl coli-oin cr^;'iicn.
concentration to e-.ceea 70 ptJ" 100 ml roc shall the total
colifor'.1- organism cciccnti atic ee life.
The ai <;ch arcji- sr.all not cause l')\ic conJi L ion > to c>'ist
in the rccciv: ig salcr.
-------
10. The discharge ihal L not cauje < 'k> following linuLt,
lo be exceeded acter initial dilution.
Cot iti t-uan ts
Crease and Oil
Floating Particulates
Tomci ty
Urn ts
2
mg/m
2
mg dry wt/m
Toxicity Unit:
50 Per- 90 Pojr-
t enti ] e centi 1 > Ma^ir-.um
10
1.0
20
1.5
0 .0^
Provirions
1. Mcit1-'"'- the treatment nor ths nscharge of pollutr-its
shall Croats 3 pollution or a nuisance as deTined bv
the California Water Code.
2. The discharge .shall achieve raj-trl initial dilation
and eficctive dispersion to mirmize concentrations
of pollutants not removed by treatment. The duiusion
sviten snail provide an initial dilution of effluent
with secwatcr e\'coeding 100*1 rt least 50 percent of
the time arid exceeding 80:1 at least 90 percent of the
tiiiid.
3. The Crosn Simpson Pulp Company 'hall comply with the
following time ^chcdulco tc ass..re compliance .\itl~i
Effluent Limitations B.l, B.2 , B.3., and B. 4. Ml other
provisions of this permit shall oe applicable upon
adopta on.
Tas <
Co"~t)li ance Cqte
P. 1. and
B 4.
Conirence preparation of
plans and specifications
for conlrol facilities
Corpl.jrcc
Li - ¦? ,,t io.' ~> !i. 2 .
Progresi report
Cn-n-.ni-p ron',lrucllon of
co.'lroi facilities
Com 1 j ."HV1
April 1, 19". 7
July 1, 19 7 7
(lay 1, 19/7
January 1, 1073
July 1, 19/"-'
Report of
COT.pl 3 anc Du;
fipril 15, 19 77
July 15, 1977
Hay 15, 19 77
January 15, 19 IS
Julv' 15, 1973
-------
T.-'sk
Lin l t.j; lor'j U. 3 .
Cc i-)]unc{» O.ito
Report of
Connli.jncc D 10
Progress report
Progress report
Progress report
Progress report
Cov,:ncc preparation of
pltjns and specificatlons
for control facilities
Progress report
Coti?t)ncc construction of
control facilitjes
Progress report
ComDliance
Oclooer 1, 19 77
July 1, 19 73
Apri1 1, 19 7i
Janjary 1, l'J80
July 1, 1980
April 1, 195l
January 1, 1°82
October 1, 1932
July 1, 1983
October 15, 1977
July ]5, 19 78
April 15, 1979
January 15, 1980
July 15, 1980
Aprij. 15, 193l
January 15, 1S82
October 15, 1932
July 15, 1933
The discharger shall sucmt to the Regional 3oard or.
or before each corrp] l ance report date, a report
---2 — = n:s co.'Dli.Tce or noncompliance with tha
sp- ~ - schedule date and task.
-or.conpli arce is b&ing reported, the reasons for
s-=. =onconpliance snail bp sta.ed, plus an estimate
c= date when the discharger will be in compliance.
Tzzscr.arger -.hall notify the Regional Board by
let-rsr v.ncn lie has returned to > oniplJ d'icc with the time
4. The cjischargtr shall notify tno Regional Boord not
later tnan 180 days in advance of implementation of
any plans to alter production c .pacity of the product
xj nc or tne m?nuf act'jrmg, producing or processing
fPCllity bx/ r.». - c . -r
thill i "fludc !>ub \i 11 ** 1 ol in-w Kopoit of
Dur'n^jo and appropriate* fili.ig fee.
5. f h i di < r.'i argor snail TlIc with the Regional P.onrd a
Re,-oi r of Uo^t<- Discharge at le i-,l I'O dnyi beio:c
m.-kng any material change.1 or p-c.poscd chd-ao in the
character, looatjon or volume of the duchargs.
6. The dli,ch.*>ig^r shall submit to ihe Rcgionsl Board b*'
January 30 of cacn year, cn anr.i' il MiTiiu.r/ of the
quantities of all chCT.ic.iU, li ted by both tr.-d? and
chcTic jl nan.Fs which are u^ed f'.r cooling ard/or
boiler uater troatrent and which arc di sch ciror-d.
-------
7 . The requirements prescribed ho cm do not authorise the
corr.nu'/;ion of any ac.t casing -nj'iry to the property of
another, nor protect the disch.irger from hi"s liabilities
under federal, state, or local laws otnetr Lhon those
adopted pursuant to the Todora1 Water Pollution Control
Act, nor guarantee the dj sch.ir-,?r a capacity right in
the rsc:ivng waters.
8 . The discharge oE any raaiologi- cl, cnenical, or
biological warfare agent is prohibited.
9 . Tne discharger shall permit th Regional BOc;rd:
a. entry upon pratiises (durinc normal busiress hours)
m which a" effluent sourc- is located or m v.nich
any rsquired records ore kcDt;
b. access to copy any records roainrcd to be kept
under terms and conditions of tins order;
c. inspection of T.onitoring ec. jipment or records; and
d. of cnv discharge.
10 . All discharges suthonzed by t! is order shall be
cc-. = i = :snt Mth tne tcrj'.s ana (.nnditiois or mis oraer.
"1--. ijL.-cnsrej^ of any pollutant more: frequently than or
at a level in e\c?ss of tnat identified rnd authorised
by "i.: order shall constitute a violation of tne ter-ns
a~d :i-.citions of th: s order.
11 . Tne discharger shalJ comply wj I n a 'lorjtoring and
Fepcr-i~.g Progian issued by the Regional Foard l>acutivG
Officer and the General Provisions for 'lonilortng and
Reporting and ar.v nodiflcntioiv to the c docunentG as
uy the Regional Boarr F.^ecvnve Officer.
Monitoring reports .shall be sulmittcd to the R-,onth, by the 15tn day oC the follov-iry ronth,
beginning not later tnan the d, ic specified in the
Monitoring and Kcportirg Piogr, .. is^uoc by the Regioiol
Board L\e<_vaiv-2 Oificer. Monitoring a~f kcporting
Program Ho. 7-1-211 snill rt-in.ir la e-f>ct until super-
seded ot revoked.
12 • The di-.charger shall iraintmn l i good i.cirl:j rg ouer and
operate as efficiently as posn.ole any fccility or
contro] system installed by th^ di;chargar cc r.chiev.;
compliance ith the w;ste discharge reguirr.Tf-'its .
-------
Colluded rcrconi-g. -Oudqo,, ,.,.J otnoi :,oL,n_; rc.ovo-l
fro.n JiquLd waste shall wo d i ...Wotid of at d loyal point
o, disposa ana in accordance with the proviMons of
Division ,.5 01 the California Water Codo. For tee
purpose or this requirement, .1 legal pomt of dLMOsrJ
is de.inea as one for which .;,.ste discnarge requirements
have been pi-scribed by a Regional Water Quality Control
Board and wnich is ir. full co.mliance therewith.
After notice and opportunity ror a hearing iVi ordc-
may be terminated or rr.odifiec Cor cause include
but not limited to: "
a. violation of any tern or condition contained in th* «•
order,
b. obtaining this ordor by r.i-represent nticn or
failure to disclose fully all relevant facts;
c. a change m any conation that re-jircs eithe- a
teirporary or pernane"t reduction o'r elimination
of the authorized disch^r^j.
If a toxic errluent standard or pronbition (inc!udi"c
any scnenule of compliance sp'.a/ied in sucn effluent
standard or prohibition) is established under
Section 307(d) of tnc Federal ..ater Pollunon Control
Act, or a-iend.-rents thereto, for toxj c polluta-t which
is present in me 2: sc.a;cs rctii.ijiLEd r'erej-: and
s^--^.-T.".csrd or prohibition more srnngent t"an
ar--" —'-r'itntion upon such polli>i^rit in this order, tne
^'r=—--al Board shall conduct a public hearing and
revising or modifying tins order in accordance
V"1_si'ch tone effluent standard or prohibition and so
r.o-^rv the discharger.
I- event the discharger is u-ublo to cor ply with
a--.' — conditions of this ordcjr duo> to:
a. crsakdo m of waste treatpent equipnent;
b. accident's caused by hi'nan error or nr-g 1 igonco; 0r
c. Other cajSu'j sue 1 as acts of nature,
the d;scharger shall notify tn ; Regional Poard executive
Oinccr by telephone ds sooi , ho or hi.-, iyonco have;
KPOhlccge of the incident ann confirm ihu notifj canop
WrlLlry wlt-hin t' o weok;-. oi Die- telephone notif1 <-->• in-,
notification r.hatl include p-rtjnent intor- '
.'nation txpl.u n:r:; reasons i or 1 he noncompliance d ^ci shs'l
ndicaLe \*h.M sle->s srro tifcon to coir^ei th~ prob'en'
and the dat-.-s thereof. and wh.n steps arc being taken
to prevent the- problr"i f- rm rc urnng.
-------
17. This, orcior Cvpuf:.i C -e vears ."com the d.ite of adoption
and the discharger nuiot f11 c .< Keport ot" Kjsto Discharge
in accordance wuh Title ,!1, Cilifornu Adi.n n l.-. t r at i vc
Code, not IflLer than LOO ilriy:, , n advance of ,uch date
as application for i ,sur 4, 19G8.
reqi'n cacntc issued Lv tne Region.¦! Boaid on
I, 3. Dcdy, Executive Of; icor, do hereby certify
tn i. the LOrc.-cjoi7ig )s a full, true, and correct copy of an order
adopted by the California State hater Kc-.ourccs Control Board
on fw-i 1 71977
/^'/yf n a
-------
Calif crna regional Vator Quality Control Board
North Coast fiction
0!?D£H iJO. 77-109
rOH
CuO.'r, SIMrOOI PbLP cc:f
E.To:;cf3^;.T ora^R 103 is.yjv.ci c a i'i;s raieduLS
^|'c^aj 1 u"' ^°3:lor'>i Water Quo] it j Control Dcnrd, Worth Cors'- Ro!jicn1 f<.-ios
1. T"o State './oter Socources Ceitrol Boirl on [larch 17, 197V adopted
0idor ;.')..ever, compliance cannot bt> achieved accer'jirg to tr.c adopted nrr.o
schedule.
I-. adopt ir.~ req Jire-iorts on "arch 17, 1S77 the State Ecr.rd fc -d a fu-ia-
rc'ital difference in facto-s cc.cti :,:i ¦; th? .-astc diGc'--i:Ge rru -rdn'.c 1
a ipqjrst for variance f:or /oc.-ral iTjfli'crt Limitation: for i.ochcr.icil
Sor.--d ard p.1.. Tl.c .triar.co subject to aoprc-r.i X ch;
Adumstrctor of E.F.A. 7m fini'i^tr'-tor's :Llin£ on tnc u-i ic.ce i-,
forthccarj;.
3- Tnc Board hi.3 notified the di=charper Ki intei:ntod or-_,ielo3 crc t:r=cr.o
oi its intent to cdopt n tiac Ger.eJjlc for cc-jpliancc for t.ne h
?!:c 12c? rd in n public us:r- heard cor.au,cr^ all co--icrit- ocrtain—
to 'J* .charger's abilit/- to nehievt! coTi,li^ncu.
ll1 IS i'V: ;• Tii'T it nccorO-.-ce vrith Y.atcr Code Section 'i33CO. tic Crcv.-n
Sj D. ) - nip * c" >. ahull (1) corpl. .\ith IiO]) and p'i ca.i* ¦'lrci n Sfflurnt
lorn J., c, jtato Board Or>i !'o, 77-C ac^or::in~ ,o ¦ ->c fo'.iov-ir- \,"ic>3 ~-d
.itur xr.o <>=l(...at?<] tic, frf.-.c foilo.-mjj ^ f^al -ltc . , 'j ^0~inc'
to-ioaal '.i' 'i ¦. t-iitor1.- I'oler-ci.-i iti vi of •. ar: -5i-.ee.
I!epor>, of
Co'irlI'--rc r~. Conf' - -~~c j ;'i p
r_,- ,r ^ Ji.'o folloiinr
; (1! "" fCr CC,l-fil 2 no-lthi; con.'lr".ion of ca=\
r. Co-'-2"C" orcpai Hioi of
r.-d "perlfi
fic-lli t; c..
b. Couplets -*i Lp'ir-iti^ • of plips
oni npi «. licaticrt, for co'iucl 6 n,ont\',
c. Cc lel,r '.oi'cLinctica of co . rol
fiv-illii'jc 12 rontnd
d. iuUco-oHn-.ee ? no.-tna
ttlD.C
Toin icc eln ed - 77 uo-t>s
-------
0] c. r No. .7-109
-2-
(2) I' .e CrDT.n Sirpaia Co-jj.w/ chill co.ply \rit'\ totil pc.-rtci solida
ljiltc, contained In Ciflae.-u Ian Italian h. 1 or St.it" OcnrJ Orior Do.
77-6 oa or tcfora Jani^iry 1, 1970.
Tl' Order shall tni I'lt'i all lorio of the ti-u ich.\:ulc
co'itaircd in thio order;
2. The diEc.vrijcr roi.jjlicc full; all tcr.r.i. ci the por.u ONCCpt as
aifcctcd by tlio provisions of t;ua ortloi,
3. Circndo iot occur uhic1'' vdi.1.1 «.u »'•action under
Scctior JO'i of tne foilirol '' Ui J'ollation Cc-.trol ?ct.
The Dctici taken bj t'.io Ec..'.rd to the ti.T.e schedule .iocs pr;-
clu'c t'-e pnr.i.ibiiitj of octio-'j to c-:c;co the doi r.it cy third parties pu'.-ua
to Action JjJ? of t'v- Tedcr^l .;.'it'jr P^lli.Uon Co- trol Act.
Cc 11\ c 't:w
I, amd C. Joseph, '->ccuti/e Olficcr, ao
he rets certify tic fo:oftOi'i* is ¦" fuJi, true,
Sii!1 correct copy ol iin on;: dJopced hy th-1
Caluornio ",nt.~r C'i."l:ly Ccrtrol
Eifi. ¦ , .lorth CciiGt Pe^i.ri, 011 2h, 19??-
cj.s'.j'i irdit) l>'
L) ,'1L ^ - JOLL»pll
C.\ccu' ivi> 0:ficcr
-------
STATE O. C>iltfO* .A—R£SO» t K AGP.CY
CD/'UMO C L70. 'N jr C
C/iL!rO.\'N[A !i.CWL WATER QUALITY CONTROL B„.\RD-
NCRfH COAS' REGIOil
IOOO rooOlNCTOV/.l CENTfR
5AN1A ROiA, CALIFORNIA 93*0'
J»honc 707—S»5 26-J
Jjm 1 Si 2:1! T
Ju. • C, 1°'7
iir, j.": ,iio3
U.'. I'ivj.:"mcr'¦eI 1-Tottctiii 'i^ercv
1"v Ca]\^ a '.net
Sc- Fi-omoi-co, CA 04111
Ecr i'.r. Fj.s'rcr
At ic'-ed ' c ctvies ci' toe ¦ o ni.arr-^ ?•:lf- 1 I-jch r>f.rvcd £t 1lie ti. >c the r.icc-">- ' c~c "joopted nc ro
lo ,or o^-^jcrilp, tnuo t1-; r^ra.-; arc bcinj. i- d 'it1" i1".!- Circl-n.^rs
lr \ntxc'; -tioii of a major jpvi'io.i.
G.1 V-nco 'ir tr."- j'tviojn irtjc inclvXci.
1. "-11011 Giccr To, ''.Q. 77-6,
?. Jt^naoic .'othsc;-: — E-.itiC",
3 <;cirrus! liter'tuif iro^ "i¦* ic« e." ; ilcr
4. (. stu-j .-c-jort"; oucrust(.J i" ; vi-.l'cik't lav 'c.otc.-.itcr
/ulhority.
Tl lctcL'. sddji _* to o\*r e. ci\>y of H-'1*! ' ,•¦ S'i, "iST" , Tc-cor'-t :.iloc
?»' cf the m-iT.it tintrr To '':nc.nfo I'iju t i?1 cc -tm. ] , 'p-vr o-
v iueici. o'i tiv .-DC il",1, 7:"'^ic. c, as '-11 ru. i.'-cc'.l- ?i\e >'r':Ci!uj.
Ci rr v: c : "rc tajculnteJ £'¦ Jujip ?, "i3" 7.
1J vou li^vo u-ly fiUk,'otiO".i; or iecoi,rei i£>, ;>li\ pg/icc.
rdrcerrly,
Of >)C,'
^ J O'lll '1. 1 ?I 'Ik"1!
Scii.--i r.t-r . -""u-trol Vif irtsr
lc " Jo'vlo' , 7 VCB
-------
\
Dccc-.b.-r 31, 197't
for. I'orran Apborn, Director of 'iivlrcnEcn^'l Sor'Icca
Crcr.'n-ZoLlcrbo.ch
90'> i!.U. Draku Ctroct
Ci.nao, Washington 93607
Dear liv. Anbcrjr:
Enc\o^iJ hcrc-.-i-th In "omtorinr; a:xi Rcporbi:.^ Pro^ror, '!o,
TisIg ilorjtorm^ c:"l Roportinj lYn^ran irill ba con-ic'c.-cd p.rt of
September U, ttrd Decc-bar / , 1%i) '..'c.oto DIschav-c nc-uvlr-r'—ia,
i*> Lioo, of c. HiAo you woVably 'r.o'i tho
critdt conlon cl in Ordor l.o. 71-211 is r.ot vai:'-d bcc^MO IS'V
objcctra to 'u'10 Hc^jo-il Bcird'o octlon rofcrdir^ !);D and Sus-
p;rdcl Solid- ofilucr.t rjcyArc^untn.
lie;oc nobo fcr.i'm t[io p"or;r.-jT: i;j to bi^ki cn rcbruasy 1, 1976. IT
you Ivsvc WT7 q-j;;tloriD or plciao contact U3.
Ojjiccroly,
IXwld C, Joseph
I^:cr^.i,ivo Office
^nclonuro
cc; Er. P.uiolp'11 I3.;ciar.r,
Fritz Grafi', Cr^..''i-Si.np;c"i, I'm^'avon
' J St/Dr.l 2c uic io Ic'hw i-il j:'uii oi o1': line
PLLA5E SCVIcrtC) ,r,,L\C.«.eD CY CHCC!.£0 III GC;(5)
(/'¦i/t io/ e1 ti ir?t "t ' /•>' f*<'e ifruei*)
51 f\( - M CO I—I Dc, -c or'iv
~ 51 f>v " M CO | | PCi '» mi.j W
cTnifi'i; *' ^
5*|l I I <• '13 s\ *.lit I •' 'iy V '»I| |'" "'I' 1 '• < /<" C»a«i
^ 'i
-------
California. Uo£io, 1 I'ater PurlLty Control Hoard
North Coast Potion
irwrroRTi'G a>j» HF.roruiiiO frocitn ;o. 74-211
for
crowi cii-'eorf pul? co:pa;ey i
Comtitucit
Units
Sar.-'lc
An? V, -^3
Flo.;
3-jJO
Ccatin
iUOUG
BCD
rs/l
24-hr
composite
2/,-cc':
Sj^perded Solids (HFn)
nc/1
24-hr
COTpCSito
2/. ee c
Fo;al Colifoi"i
M1V,/I00 inl
Grab
ro-.laly
P'1
1)H Unito
Co-Lir
mo-a
.
Crcr.sc a-v1 Oil
K'S/l
S-nr ccrrpcoite
2/\ ec'-:
Seutlciblc Solids
nl/l
r;rab
cai] v
Tin bitux./
JTU
2',-lu-
cc-^prci^c
dail/
Ai 3cmc
ma/i
2/,-'¦> r
COTpOMtC
quarterly
Caursj u 1
T,/l
24-hr
ccxsitc
anr ^I?lly
Ccpp;r
n-^/1
24-hr
CO-iJO^ltO
qalrte-i.y
Total Cnrcnrun
wg/i
27t-.hr
eorpcsi^e
q_lr;:crLy
Lc?d
"e/i
24-,lr
C0\ip03\tC
qi^rterly
Kcrcury
p?/i
21,-nr
CCTiOCeito
anr-all ¦
I\ic':el
*'SA
24-hr
co-posito
quarterly
Silver
r.fi/1
2'r-hr
CCTCCSltC
a-irxally
Zinc
ir^/l
24-l^r
cen-corcc
? np i' -1"» ¦
Cyr mclo
r-cA
24-hr
CCT00311-C
quarterly
Phenolic Co-'poar.da
nc/l
24-hr
coripooito
. cuirtc: ly
A/rnonid.
ma/i
grab
c rrxilly
To til Identifiable
Cnlo.-irated H;-'"ocarbop*j n\j,/l
Grab
ciruul.* /
Tc:~city Concctr.i~ lor
Toxicity Urats
fi-hr i
:onpo3itc
noTtnly
Hacho-etivicy
i'Ci/1
gjao
C"CO C -ZTJ
vca r3
1/7'TE" Tr
''U'nT uSTi" 5?LTDG 'JTO^TifCV
solids rrn be ootrirc
Cot:! vlieit
Tjroidlt/
Flo*:
Surcc-'icd Solid3 ( !F?0
Srttlcanlc Colv-e
Cov-leit
'ted irrc
t'-c rep ecc"trtivc
ear pice of -aete
Type o<
Ficcarcv of
Ur.iti
5r **** * * *
/tjI'-s-'.s
JTo
cc:TTC3itc
daily
;ro
Cent .'0_3
n^/1
Srro
2/vcc'c
ml/1
¦* I
b-b
2/.:cc<
-------
Komtormo; c-"<3. Honoring
Pro^ri-i Vo. 7'i-211
-2-
imr.KTVH G HATKit MI TORI KG
Sta'"oi I'o,
Dcjcrnrtion
A-l
A-2
A-3
avirfaeo, on the outfall
md--tkly
far Itako
, breakage, a
r-alfi-'ctian. A state-cat on the aaffici^icy of the out'all ayatca shall be included
an ever/ izon^tori^e i-ocorl.
l!o uto.-x"; rcaoria aha 11 be Cw'tnittcd to t^e Ucard To:' each r.^ntli cy trc l,,th day
of the. i'ollou; nontn, oe^injanL, not later t>an Tcbi-aiy 1, 197&.
Ordered by .
Daviu C. Jojc,'h
Executive Officer
Dcctriber 30, 197^.
-------
CniTIITrS HiR
Docc-t-rr 30, 19lh
Dr. C. 'yV.w.x: Toylor, C.sloncl-rc I rt'JUirtd /« (hrf «< r I Us »
frClSUI t,C
flY.IULl) 1.3
6533't7
ll.iLlr. U I 3
-------
APPENDIX B
PRIORITY POLLUTANTS LISTING
-------
PRIORITY WATER POLLUTANTS LISTED IN NRDC v. TRAIN
CONSENT DECREE
Compound Naw?
10.
1,2-dichloroethane
1. *acenaphthene
11.
1,1,1-trichloroethane
2. *acrolein
12.
hexachloroethane
3. *acrylonitrile
13.
1,1-dichloroethane
4. *benzene
14.
1,1,2-trichloroethane
5. benzidine
15.
1,1,2,2-tetrachloroethane
6. *carbon tetrachloride (tetrachloro-
16.
chloroethane
methane)
*Chlorinated benezenes (other than
dichlorobenzenes)
7. chlorobenezene
8. 1,2,4-trichlorobenzene
9. hexachlorobenzene
*Chlorinated ethanes (including 1,2-
dichloroethane, 1,1,1-trichloro-
ethane and hexachloroethane)
*Chloroalkyl e.hers (chloromethyl,
chloroethyl and mixed ethers)
17. bis(chloromcthyl) ether
18. bis(2-chloroethly) ether
19. 2-chloroethyl vinyl ether (mixed
^Chlorinated naphtalene
20. 2-chloronaphthalene
^Specific compounds and chemical classes as listed
1n the consent degree.
-------
^Chlorinated phenols (other than
those listed elsewhere; includes
trichlorophenols and chlorinated
cresols)
2,4,6-trichlorophenol
parachlorometa cresol
^chloroform (trichloromethane)
*2-chloropheno1
*Dichlorobenzenes
1.2-dichlorobenzene
1.3-dichlorobenzene
1.4-dichlorobenzene
*Dich1orobenzidi ne
3,3'-dichlorobenzidine
*Dichloroethylenes (1,1-dicbloroethy-
lene and 1,2-dichloroethylene)
1.1-dichloroethylene
1.2-trans-dichloroethylene
*2,4-dichlorophenol
*Dichloropropane and dichloropropene
1,2-dichloropropane
1,2-dichloropropylene (1,3-di-
chloropropene)
*2,4-dimethyl phenol
*Dinitrotoluene
2,4-dinitrotoluene
2,6,-dinitrotoluene
*1,2-diphenyl hydrazine
*ethylben2ene
*fluoranthene
*Haloethers (other than those listed
elsewhere)
40. 4-chlorophenyl phenyl ether
41. 4-bromophenyl phenyl ether
42. bis(2-chloroisopropyl) ether
43. bis(2-chloroethoxy) methane
*Halomethanes (other than those
llisted elsewhere)
44. methylene chloride (dichlorome-
thane)
45. methyl chloride (chloromethane)
46. methyl bromide (bromomethane)
47. bromoform (tribromomethcne)
48. dichlorobromomethane
49. trichlorofluoromethane
50. dichlorodifluoromethane
51. chlorodibromomethane
52. *hexachlorobutadiene
53. *hexachlorocyclopentadiene
54. *isophorone
55. *naphthalene
56. *nitrobenzene
*Nitrophenols (including 2,4-dini-
trophenol and dinitrocresol)
57. 2-nitrophenol
58. 4-nitrophenol
59. *2,4-dinitrophenol
60. 4,6-dinitro-o-cresol
*Nitrosami nes
61. N-nitrosodimethylamine
-------
62. N-ni trosodi phenyl amine
63. N-ni trosodi-n-propyl amine
64. *pentachlorophenol
65. *phenol
*Phthalate esters
66. bis(2-ethylhexyl} phthalate
67. butyl benzyl phthalate
68. di-n-butyl phthalate
69. di-n-octyl phthalate
70. diethyl phthalate
71. dimethyl phthalate
*Po1ynuclear aromatic hydracarbons
72. benzo(a )ar,thracene
(1,2-benzanthracene)
73. benzo (a) pyrene (3,
4-benzopyrene)
74. 3,4-benzofluoranthene
75. benzo(k)fluoranthane (11,
12-benzofluoranthene)
76. chrysene
77. acenaphthylene
78. anthracene
79. benzo(ghi)perylene (1,
12-benzoperylene)
80. fluroene
81. phenathrene
82. dibenzo (a,h)anthracene (1,2,
5,6-dibenzanthracene)
83. indeno (1,2,3-cd)pyrene (2,
3-o-phenylenepyrene)
84. pyrene
85. *tetrachloroethylene
86. *toluene
87. *trichloroethylene
88. *vinyl chloride (chloroethylene)
Pesticides and Metabolites
89. *aldrin
90. *dieldrin
91. *chlordane (technical mixture
& metabolites)
*DDT and metabolites
92. 4,4'-DDT
93. 4,41-DDE (p.p'-DDX)
94. 4,4'-DDD (p.p'-TDE)
*endosulfan and metabolites
95. a-endosulfan-Alpha
96. b-endosulfan-Beta
97. endosulfan sulfate
*endrin and metabolites
98. endrin
99. endrin aldehyde
*heptachlor and metabolites
100. heptachlor
101. heptachlor epoxide
*hexachlorocyclohexane (all isomers)
102. a-BHC-Alpha
103. b-BHC-Beta
104. r-BHC (1indane)-Gamma
105. g-BHC-Delta
-------
~polychlorinated biphenyls (PCB's)
118.
~Cadmium (Total)
106.
PCB-1242 (Arochlor 1242)
119.
~Chromium (Total)
107.
PCB-1254 (Arochlor 1254)
120.
~Copper (Total)
108.
PCB-1221 (Arochlor 1221)
121.
~Cyanide (Total)
109.
PCB-1232 (Arochlor 1232)
122.
~Lead (Total)
110.
PCB-1248 (Arochlor 1248)
123.
~Mercury (Total)
111.
PCB-1260 (Arochlor 1260)
124.
~Nickel (Total)
112.
PCB-1016 (Arochlor 1016)
125.
~Selenium (Total)
113.
~Toxaphene
126.
~Silver (Total)
114.
~Antimony (Total
127.
~Thallium (Total)
115.
~Arsenic (Total)
128.
~Zinc (Total)
116.
~Asbestos (Fibrous)
129.
*~2,3,7,8 -tetrachlorodibenzo
117.
~Beryllium (Total)
-p-d1oxin (TCDD)
~Specific compounds and chemical classes as listed
in the consent degree.
**This compound was specifically listed in the consent
degree. Because of the extreme toxicity (TCDD). We are reconmending
that laboratories rurt acquire analytical standard for
this compound.
-------
APPENDIX C
METHODS, ANALYTICAL PROCEDURES, AND QUALITY CONTROL
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FLOW MONITORING TECHNIQUE - CROWN SIMPSON PULP COMPANY
FAIRHAVEN, CALIFORNIA
December 1977
Flow monitoring at Crown Simpson was accomplished with the tracer
dilution technique, using lithium as the tracer. The concept employed
is that mass is conserved (i.e., mass of tracer in equals mass of tracer
out). Fundamental to the use of this technique are the following con-
ditions:
1. A conservative tracer.
2. A constant tracer injection rate and an accurate measurement
of the rate.
3. An accurate measurement of the tracer concentrate, background
tracer levels, and diluted tracer in the flow stream to be
measured.
4. Complete mixing in the flow stream to be measured.
It was determined that all these respective criteria could be met
by:
1. Using lithium (Li) in the form of lithium chloride as a
tracer. Preliminary studies included spiking the wastewater
with known amounts of lithium and analyzing for % recovery.
Overall average recovery was 100%.
2. Metering the injected tracer solution with low flow rate,
high precision pumps. During the survey, injection rate
was checked at least twice/day with a graduated cylinder
and stop watch.
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3. Measuring Li concentration with a Perkin-Elmer Model 403
Atomic Absorption Spectrophotometer. This instrument was
calibrated before each use with lithium standards of known
concentration. Concentrate samples were analyzed at least
once/day during the survey. Background samples were collected
and analyzed each time a flow measurement was performed.
4. Injecting the lithium chloride concentrate solution into the
suction side of the effluent pump and monitoring the diluted
Li tracer on the discharge side. Preliminary studies con-
ducted on site indicated the tracer reached the discharge
monitoring site in less than one minute and reached a steady
state condition. During the survey, three minutes of tracer
dosing was allowed to provide a factor of safety.
Flow was calculated with the following equation:
n = q cq F
^ r_r
b
where Q is unknown flow (mgd)
q is injection rate (1/min)
Cq is lithium concentration of injection solution (mg/1)
C is lithium concentration downstream of injection (mg/1)
C^ is background concentration of lithium (mg/1)
F is factor to convert 1/min to mgd
<380'45 * ,0"6 Sly-liter'
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TABLE 2-
PHYSICAL-CHEMICAL CHARACTERISTICS OF DILUTED EFFLUENT
CROWN SIMPSON
December, 1977
Effluent Concentration (%)
Control
Parameter (Sea Water) 5 9 16 28 37. 5 50
24-hour
DO ir.g/1 8.0 7.5 7.5 7.0 7.0 6.5 6.0
pH 7.7 7.6 7.4 7.3 7.2 7.0 6.6
temp °C 16.0 16.5 16.5 16.5 16.5 17.0 17.0
NH mg/1 0.05
48-hour
DO mg/1 6.5 6.5 6.5 6.0 6.0 6.0 6.0
PH 7.2 7.2 7.1 7.0 6.9 6.6 6.5
temp °C 16.0 16.5 16.5 17.0 17.0 17.5 17.5
NH mg/1 0.12 0.76
72-hour
DO rag/1 8.0 6.5 6.5 6.0 6.5 6.5 6.0
pH 7.7 7.5 7.3 7.2 7.1 6.9 6.8
temp °C 16.5 17.0 16.5 17.0 17.0 18.0 17.5
NH3 mg/1 0.12 0.61
96-hour
DO mg/1 8.0 7.0 6.5 6.0 6.0 6.0 5.5
pH 7.5 7.3 7.1 7.1 6.8 6.8 6.5
temp °C 17.0 17.5 17.5 18.0 18.0 18.0 18.0
NH^ mg/1 0.14 0.57
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BIOASSAY METHODS
Toxicity testing consisted of a 96-hour bioassay performed
according to standardized methods.1 a '3 A continuous flow
proportional diluter was used which provided a series of six effluent
concentrations and a 100% dilution water control. Test chambers were
of all glass construction and of 8 liters capacity. Flow rates were
regulated to provide a minimum of nine volumetric exchanges of test
water for each test chamber for each 24-hour period.
The test fish (three-spined stickleback) used were purchased
through a commercial dealer (Alax Fish Company, San Rafael,
California). This dealer provides indigenous wild fish, therefore no
data are available on the specific life stage of these organisms.
Fish were acclimated for 48-hours prior to testing at four different
salinities. The salinity gradient ranged from fresh water to sea
water concentrations equal to 25, 50, and 100%. Test fish used in
the bioassay were selected from the specific salinity which most
clo-sely approximated the salinity of the test water.
Dilution water used was filtered sea water obtained from the
Humboldt Marine Laboratory, located at Trinidad, California. The di-
lution water was stored in 1,100 liter (300 gallon) epoxy coated re-
servoirs and was replenished every twenty-four hours.
Bioassay test water was collected at the discharge side of the
effluent pump at Station 3500 by flow weighted 24-hour composites and
replenished daily. Prior to introduction into the diluter system,
the wastewater was prediluted to a 50% effluent concentration. Make-
up water for predilution consisted of unfiltered Mad river water col-
lected at the intake to the Crown Simpson mill (Station 3550).
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Each test chamber was monitored daily for pH, temperature and
dissolved oxygen concentration [Table 2]. In addition, the high and
low concentrations were analyzed for total ammonia with an Orion
Model 901 microprocessor. Temperature variation of the test water
was restricted to +1°C utilizing a constant temperature recirculating
water bath.
The BOD of the effluent was sufficiently high such that at a 50%
effluent concentration, dissolved oxygen levels were reduced to less
that 2 ppm within 24 hours. To maintain adequate dissolved oxygen
levels, mild aeration was utilized in all test chambers.
Mortalities in each test chamber were recorded at 24-hour inter-
vals. The LC50 value was calculated by a probit analysis method.4
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REFERENCES
1. Office of Research and Development, July 1973. Biological Field
and Laboratory Methods. Cincinnati: EPA-670/4-73-001.
2. National Environmental Research Center, April 1975. Methods for
Acute Toxicity Tests with Fish, Macroinvertebrates, and
Amphibians. Corvallis, Oregon: EPA-660/3-75-009.
3. Water Control Criteria 1972. EPA-R3-73-003, March 1973.
A. Litchfield, J. T. Jr. and F. Wilcoxon. 1949. A Simplified
Method of Evaluating Dose-Effect Experiments. J. Pharm. Exp.
Ther. 96799-113.
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CHEMISTRY
-------
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
TO
Chief
Chemistry Branch
DATE
January 17, 1978
from Technical Coordinator
Inorganics and Air
SUBJECT
Results of BOD, TSS, Oil and Grease, Total Cyanides, and Phenol Analyses
Attached is a summary of the BOD, TSS, oil and grease, cyanides, and phenol
results.
Constituent
DO
BOD
TSS
Cyanides
Phenols
Analytical Procedure
Membrane electrode probe
Reference
Standard Methods, "I4th
Ed., 1978, p, 450
Standard Methods, 14th
Cel., 1975, p. 543
Standard Methods, 14th
lid., 1975, p. 94
Standard Methods, 14th
Ed., 1975, pp. 365, 367,
and 370
Standard Methods, 14th
Ed., 1975, pp. 576, 577,
and 580
Due to the processes involved in the pulp and paper mills, sulfides and sul-
fites v/ere suspected as possible interferences. Sulfides interfere negatively
in the color development steps of both total cyanides and phenol procedures.
In the phenol samples very few, if any, sulfur compounds such as hydrogen sul-
fide and sulfur dioxide would remain in the samples collected because of
H3PO4 and CuSO^ used as preservatives.
The total cyanide reflux distillation method liberates the sulfur during the
procedure and the sulfides and sulfites are trapped within the sodium hydrox-
ide catch solutions. Since sulfides were suspected in all the samples, they
were checked by adding one gram of cadmium carbonate to each of the diluted
sodium hydroxide catch solutions. A yello,/ precipitate indicates that
sulfides are present. The cadmium removes the sulfides from the catch
solutions as cadmium sulfide so that it cannot interfere with the color
development part of the test. However, sulfides can react with cyanides at
Full bottle dilution technique with
settled raw sewage used as seed
Gravimetric, mi 11ipore filter -
Whatman GFC
Total, reflux distillation with
the testing of the catch solution
for sulfides and sulfites
4-AAP with distillation, extraction,
and testing of the distillates for
sulfites
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- 2 -
a high pH to form thiocyanates and give low cyanide results. Therefore,
the cyanide values reported for those samples where precipitates we re ob-
served may be lower than originally present.
The catch solutions yielded a yellow precipitate for samples 3400-30-1207
and 3500-01-1207.
Sulfites present in the samples also interfere negatively in the color de-
velopment steps of the phenol and total cyanide methodologies. Each dis-
tillate and catch solution was tested for the presence of sulfites. To
an aliquot of each was added one drop of hydrogen peroxide and three drops
of barium perchlorate. The formation of a precipitate would indicate the
presence of sulfites. No precipitates were found in the aliquots from the
catch solutions or distillates thus indicating that sulfites were not
present in the samples.
A number of reference samples were also analyzed along with the survey
samples. These results are summarized below:
Reference Theoretical Concentration
Constituent Source Value, mg/1 Found, mq/1
BOD EPA 14-34 17
BOD ERA 65-87 68
TSS ERA 34-40 35
Oil and Grease ERA 16-20 15
Oil and Grease NEIC 100 98
EPA reference standard supplied by EMSL-Cincinnati.
ERA reference standards supplied by Environmental Resource Associates.
NEIC reference standard for oil and grease prepared by adding 100 mg of
vacuum pump oil to one liter of distilled water.
D. David Vietti
Attachments
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Cnief
Chemistry Branch
January 20, 1973
W. L. Abbott
Technical Coordinator, Trace Metals
California Pulp Mills
Attached is a Hst of results of metals analysis of subject samples for
priority pollutants. Except for mercury, cadmium, and zinc, all samples
were analyzed by flame!ess atomic absorption using the Perkln-Elrcer graphite
furnace and auto sampler. Mercury was analyzed by the automated cold vapor
technique as described by El-Awady et al.l* Only zinc was present in con-
centrations above flame detection limits permitting the use of flame AA
for analysis of this parameter. Cadmium was also analyzed by flame AA
showing levels below the detection limit. Since percent recoveries were
good and the flame detection limit was one tenth that proposed for effluent
limitations, rerunning using the graphite furnace was deemed unneccessary.
Preparation procedures followed those described in the manual, "Sampling
and Analysis Procedures for Screening Industrial Effluents for Priority
Pollutants," published by the Effluent Guidelines Division of EPA. It was
found during the analysis for lead and copper thair nonreproducible results
often were obtained when the samples contained chloride ions. During the
char cycle metal chlorides apparently volatilized. The addition of phos-
phoric acid to the samples permitted the volatilization of the chloride as
HC1, leaving the more stable metal phosphate which would then volatilize at
the desired atomization temoerature. This procedure was subsequently fol-
lowed for silver and chromium analysis in the expectation that a similar
increase in reproducibility would result. This produced a slightly larger
signal, but repeatability was not improved.
Since the method of standard additions was followed except for mercury and
zinc, concentrations were normalized for spike recoveries; therefore, percent
recovery data do not apply. For the other metals, however, spike recovery
data are listed below:
Sample Mo.
|lq
Zn
Cd
3400-30-1208
103%
937,
3400-30-1209
8-^
...
3500-30-1203
84?:
3500-30-1209
cm
o
923
1/ Analytical Chemistry, Vol. 43, Ho. 1, January 1976.
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- 2 -
These values are within quality control guidelines. Since the replicate data
were at or below detection limits, precision estimators could not be used.
However, no analytical anomalies were observed.
As can be seen, the lowest concentrations of all elements were found in the
raw water (samples numbered 3550). The Louisiana-Pacific debarker water
(3450) displayed elevated concentrations of copper and lead which did not
appear in significant concentrations in the LP process wastewater (3400),
but did appear in the Crown-Simpson process wastewater (3500). Levels of
zinc up to about four tiroes the detection Unit were found in all waste
streams. The greatest amount beinq tn the LP process wastewater durinq
one composite period. Chromium levels were all low but above the detection l::;:;
limit 1n the LP process waste stream.
Please note that all values are reported in micrograms per liter (ug/1)
except nickel and thallium which are expressed in milligrams per liter (mg/1).
Attachment
William L. Abbott
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DEN-'ER FEDERAL CENTER
DENVER, COLORADO 80225
TO £hief . DATE March 8, 1978
Chemistry Branch
FROM W. L. Abbott
SUBJECT _ , _ , . _ „ ,
Eureka California Pulp Mills
Our normal procedure of sample preparation for flameless AA analysis employs
the EPA mild digestion technique. This technique was used to prepare sam-
ples for five elements (Ni, Pb, Cu, Cr, and Tl), contrary to the "instructions
given in Sampling and Analysis Procedures for Screening of Industrial
Effluents. This change in procedure was done in the interest of expediting
the analyses. The preparation procedure, however, had no material effect on
the results as reported.
While the method of standard additions was required for all graphite furnace
analyses, three parameters—namely nickel, thallium, and antimony—all
yielded absorbance readings that would give less than detectable' concentra-
tions in the unspiked samples regardless of the corrections that could be
made under the method. The spiked portions were therefore not analyzed in
the interest of conserving time. This shortcut can in no way alter the re-
ported results.
William L. Abbott
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Laboratory Visited: Crown-Simpson Pulp Company
Fairhaven, California
Main Laboratory
Date of visit:
December 8, 1977
B0D5, TSS, O&G, SS, pH
Combined process wastewater discharge
Parameters:
Monitoring Site:
Personnel contacted: Harold Campbell, Assistant Chemist
Lab Faci1ities:
The lab was built in 1965 and the approximate dimen-
sions are 25' by 50'. The overall impression per-
ceived was that of an orderly, clean, working lab.
Analytical methods/sampling: The EPA approved methods for B0D5, TSS, SS,
and pH are used. The B0D51s are titrated using the azide modification of
the Winkler Method.
Seeded blank corrections appeared to be within normal ranqe limitations.
The CPA method for Oil and Grease is followed up to the point where the
extract is drained off. At this time the extract is drained into a tube
and cer.trifuged for two minutes. The water layer is then vacuumed off.
A small sediment layer and the freon are then rinsed through a Whatman
GF/A 11 cm glass fiber filter paper into a distilling flask. The above
procedure is repeated two additional times. At this time the filter
paper is rinsed with 20 ml freon. The distilling flask is then placed
in a heating mantle, and the extract is distilled down to about 10 ml.
The freon is rinsed into a tared aluminum weighinq pan which is then
placed in a 105°C oven for 20 minutes. The aluminum pan is placed in a
desiccator for 4 minutes and weighed on a Mettler model H4 analytical
Because the evaporation temperature used is 25°C higher than the EPA ap-
proved method, volatile oils may be driven off, causing lower results.
The analyst stated that to his knowledqe, no comparative data was available
to show that this procedure was acceptable.
The chemists contacted had a very good workinq knowledge of the analytical
procedures used. A one gallon plastic jug was used For the composite
samples, and a one quart glass jar with Teflon liner for Oil and Grease.
Oil and Grease samples were preserved with 5 ml 50% HC1, and cooled to 4°C.
All others were refrigerated only. Analyses were performed well within
the recommended holding time.
balance.
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- 2 -
Equipment and Supplies: A Corning model 110 digital pH meter is used for
making pH measurements. The meter is calibrated daily with pH 7 buffer,
and weekly with pH 4 and 10 buffers. The weighing is done on a Pettier
model H4 analytical balance. The balance is serviced yearly by a Mettler
serviceman. No standard weights were available for calibration. All
reagents and standards are supplied by Crown-ZeHerbach Environmental
Services of Camas, Washington, which is one of the parent companies of
Crown-Simpson. A supply of good quality deionized water is on hand.
Data Handling: One log book is used to record bench data for all parameters.
Final results are then tabulated on DMR reportinq forms.
AQC Program: There is no participation in EPA or any other cross-check
program. Blind samples are not run. This lab has not been certified by
the state of California. No standard additions are analyzed, and replicates
are only done occasionally on TSS samples. The only blanks tested are those
for B0D5. There are no NBS thermometers or Class S weights available for
calibration.
Recommendations:
1) Institute an active quality control program consisting of blanks,
replicates, standard additions, etc. performed on a routine basis.
2) Since the 0&G method does not comply with the EPA-approved proce-
dure, comparative tests should be performed and the data submitted for
alternate test procedure approval.
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ORGAN ICS
Analytical Methodology
Priority Pollutants:
Samples for priority pollutant analysis were treated as described in the
EPA document "Sampling and Analysis Procedures for Screening of Industrial
Effluents for Priority Pollutants" March 1977 revised April 1977. Specific
information about each method follows.
Volatile Organics:
Grab samples were composited in the laboratory with gas-tight syringes
to avoid contamination. "One ug each of bromochloromethane and 1,4-dichloro-
butane were added as internal standards to each 5 ml composited sample.
This aliquot was then purged with helium for 12 minutes and the organics
trapped on a Tenax resin trap. This trap was then heated to 180°C for
4 minutes and the organics desorbed onto the gas chromatographic (GC)
column for analysis. The GC column was 8 feet x 1/8 inch stainless steel
packed with 0.2% Carbowax 1500 on 60/80 mesh Carbopack C. The column was
held at room temperature during the desorbtion cycle, then held at 60°C
for 4 minutes followed by temperature programming at 8°/minute to 170°C.
The mass spectra were collected using a Finnigan 1015 electron impact
ionization quadrupole mass spectrometer (MS) interfaced to a Systems In-
dustries System 150 data system. Identifications were made by comparing
the relative intensities of three selected ions for each compound of in-
terest and t.ie retention time to those of a pure standard. Once identified,
the compound was quantitated by comparing the compound's ion intensity in
the sample to that in the standard. The stability of the instrument and
the sample purging efficiency were monitored by comparing the response of
the internal standards. The percent relative standard deviations of the
selected ion intensities from the bromochloromethane and 1,4-dichlorobutane
internal standards were 16 and 20 percent respectively at the 200 ppb
concentration level.
Neutral-Base Extractables:
24-hour composite samples were analyzed by extraction with dichloromethane
(CHnClo) at a pH greater than 11. The neutral-basic fraction was then con-
centrated to 1 or 5 ml, depending on the expected concentrations of pollu-
tants and screened by injection onto a GC equipped with a flame ionization
detector (FID) (described in the general organics procedure). Samples
containing peaks were then spiked with 20 ng/ul of per-deuteroanthracene
(din anthracene) as an internal standard. Analysis was then performed by
GC/MS as described in the EPA priority DOllutants document using a 6 foot
x 2 mm glass column packed with 3% 0V-17 on 80-100 mesh GC-Q.
Pollutants that were identified by GC/MS were then quantitated by comparing
the response of the ion of interest in the sample to the response of the
pure compound. The d-jg anthracene was used to accurately relate the in-
strument responses of Both the sample and standard. This procedure is known
as the Internal Standard Method and is described in detail in the EPA document.
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- 2 -
The quality of the data was monitored by a number of checks. Solvent
recovery was used to monitor the extraction procedure. Recoveries aver-
aged: 80% +_ 8%, low = 67%, high = 91%. GC/MS performance and sensitivity
were measured by analyzing 20 ng of deca-fluorotriphenylphosphine (DFTPP)
and meeting the specifications outlined by Eichelberger, et.al.i' In addi-
tion, a standard containing 40 ng of benzidine was analyzed to prove the
ability to chromatograph low level basic compounds.
Acid Extractables:
After base-neutral extraction, the samples were acidified to pH^2 and
extracted again with C^C^. The acid extracts were concentrated and
screened as with the base-neutral extracts. The extracts were then spiked
with 20 ng/ul of d10 anthracene as an internal reference standard and
analyzed by GC/MS using a 6 foot x 2 mm glass column packed with 60/80
mesh Tenax. Pollutants identified were quantitated as described in the
base-neutrals procedure.
Solvent recoveries averaged 89% + 7% with 74% and 97% being the low and
high recoveries respectively. The GC/MS was monitored by chromatographing
100 ng of penta-chlorophenol.
Pesticides:
Each sample was extracted and concentrated usinq the methodology recom-
mended for priority pollutant pesticide analysis, i.e. extraction with
3 x 60 ml of 15% methylene chloride in hexane and concentration using the
Kuderna-Danish evaporative concentrator. The samples were then analyzed
with an EC-GC fitted with a 3% 0V-101 column. Any suspicious peaks were
checked by rerunning the sample on a 5% 0V-210 column.
Six of the samples contained too many interferences to be analyzed directly
These samples (#3500-12/7, 3400-12/8, 3400-12/9, 3500-12/9, 3500-12/8, and
3400-12/7) were cleaned up with a 15 cm basic alumina column, deactivated
with 3% HpO and eluted with eight 50 ml volumes of 10% ethyl ether in hexane
and one 150 ml volume of benzene. The individual fractions were then
analyzed for pesticides.
General Organics:
Screening the extracts on GC-FID showed the samples from each station to
be very similar. Therefore, samples from the first survey day (12/7) were
analyzed for general orqanics. The extracts were analyzed by GC-FID using
a Varian 1400 GC equipped with a 10 foot x 2 mm glass column packed with
6% 0V-101 on 60/80 mesh GC-Q. The column was programmed from 80 to 220°C
at 6°/minute. Helium was the carrier gas at a flow of 20 ml/minute.
The extracts were then analyzed by GC/MS using the same column conditions
as used for screening. The data were reduced and analyzed by comparison of the
sample spectra to reference spectra contained in the following libraries:
Eight Peak Index of Mass Spectra, Mass Spectrometry Data Centre,
AWRE, Aldermaston, Reading, U.K. 1974.
Registry of Mass Spectral Data, John Wiley & Sons, New York, 1974.
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- 3 -
In addition, manual interpretation based on known ion fragmentation path-
ways supplemented the data evaluation.
Some of the compounds tentatively identified in the samples were available
at NEIC and these standards were then analyzed by GC/MS. In these cases,
the spectra and retention times could be matched and the identities unam-
biguously confirmed. Compounds not confirmed have been footnoted in the
data table.
The compounds identified by GC/MS were then quantitated by comDarison of
the sample GC-FID responses to the GC-FID responses of pure standards at
known concentrations. Where pure standards were not available, the con-
centrations were estimated based on the responses of similar compounds
at similar retention times.
Nitrosamines:
Approximately 1 liter of the sample was serially extracted with two
50 ml portions of C^Clo. Any emulsions formed during the extractions
were broken with the addition of NapSO^. The extracts were dried with
Na2S04 and concentrated to between 1 and 2 ml in a Kuderna-Danish evaporative-
concentrator at 58-60°C. Approximately, 0.75 ml of isooctane was added to
the extract before concentration to act as a "keeper."
The extracts were analyzed by gas chromatography-thermal energy analysis
(GC-TEA). The gas chromatographic column used was 20 feet x 1/8 inch
stainless steel packed with 10% Carbowax 20 M with 1% K0H on 60/80 mesh
Chromosorb WAW at 165°C with an injector temperature of 200°C.
The following nitrosamines can be measured by this procedure:
dimethylni trosami ne, methyl propylni trosami ne, ethyl propylm trosami ne,
diethylnitrosamme, di-n-propylnitrosamme, ethyl butyl ni trosami ne, methyl-
ethyl ni trosami ne, propyl butylnitrosamine, methyl amy!nitrosamine, di-n-
butylnitrosamine, nitrosopiperi dine, nitrosopyrrolidine, nitrosomorpholine,
and diamylnitrosamine.
1/ Anal. Chem., 47, 995 (1975).
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APPENDIX D
NEIC CHAIN-OF-CUSTODY PROCEDURES
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ENVIRONMENTAL PROTECTION AGENCY
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
CHAIN OF CUSTODY PROCEDURES
June 1, 1975
GENERAL
The evidence gathering portion of a survey should be characterized by the minimum
number of samples required 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 the evidence is introduced into
court. A sample is in your "custody" if:
1. It is in your actual physical possession, or
2. It is in your view, after being in your physical possession, or
3. It was 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 copy of the survey study plan and will be
knowledgeable of its contents 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 in the field to determine adherence to Chain of Custody procec'ires and
whether additional evidence type samples are required.
SAMPLE COLLECTION
1. To the maxirraim 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 memory 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 tines.
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,
-------
2
DO, pH, flow and any other pertinent information or observations The
entries shall be signed by the field 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 dispatched 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 locked in such a place
and manner that no one can tamper with it.
7. Colored slides or photographs should be taken which would visually show the
outfall sample location and any water pollution to substantiate any con-
clusions of the investigation. Written documentation on the back of the
photo should include the signature of the photographer, time, date and site
location. Photographs of this nature, which may be used as evidence, shall
be handled recognizing Chain of Custody procedures to prevent alteration.
TRANSFER OF CUSTODY AND SHIPMENT
1. Samples will be accompanied by a Chain of Custody Record which includes the
name of the survey, samplers' signatures, station number, station location,
date, time, type of sample, sequence number, number of containers end 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. Th° 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 assigned,
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 documentation.
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 a manner so that no one can tamper with them. The same per-
son must then return to the laboratory and unlock the samples and deliver
custody to the appropriate custodian.
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3
LABORATORY CUSTODY PROCEDURES
1. The laboratory shall designate a "sample custodian." An alternate will 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 abnormal ties 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.
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EXHIBIT I
EPA, NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Station No.
Date
Time
Sequence No.
Station Location
Tnmp
\
_BOD
.Solids
_COD
JJutrienJs
_Metafj
.Oil Ami Grease
.D.O.
_Bad.
.Other
Sampler*
\
Remarks / Preservative:
Front
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
Back
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EXHIBIT II
FOR
SURVEY, PHASE.
DATE
TYPE OF SAMPLE.
ANALYSES REQUIRED
STATION
NUMBER
STATION DESCRIPTION
TOTAL VOLUME
TYPE CONTAINER
PRESERVATIVE
NUTRIENTS
BOD
COD I
TOC
TOTAL SOLIDS |
SUSPENDED SOLIDS
ALKALINITY |
O
Q
•
I
a
| CONDUCTIVITY* |
t
LLJ
Q£
3
<
a:
LU
a
5
LU
TOTAL COLIFORM
FECAL COLIFORM |
TURBIDITY
OIL AND GREASE
METALS
BACTI
PESTICIDES
HERB |
TRACE ORGAN1CS
PHENOL |
CYANIDE |
fiCMARKS
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EXHIBIT III
Samplers:
FIELD DATA RECORD
STATION
NUMBER
DATE
TIME
TEMPERATURE
#C
CONDUCTIVITY
fx mhos/cm
pH
S.U.
DO.
mg/l
Gaga Ht.
or Flow
Ft. or CFS
'
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EXHIBIT IV
ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcement
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Building 53, Box 25227, Denver Federal Center
Denver, Colorado 80225
CHAIN OF CUSTODY RECORD
SURVEY
SAMPLERS: (Signature)
STATION
NUMBER
STATION LOCATION
DATE
TIME
SAMPLE TYPE
SEQ
NO
NO OF
CONTAINERS
ANALYSIS
REQUIRED
Waler
Air
Comp
Grab
Relinquished by: (Signature]
Received by: (Signature)
Date/Time
Relinquished by: (Signature)
Received by: (Signature)
Date/Time
Relinquished by: /Signature)
Relinquished by: (Signature^
Received by. (stature)
Received by Mobile Laboratory for field
QnolySIS: (SignatureJ
Date/Ti
me
Date/T
ime
Dispatched by: (SignatureJ
Method of Shipment.
Date/Time
Received for Laboratory by:
Date/Time
Distribution Orig — Accompany Shipment
1 Copy—Survey Coordinator Field Files
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REVIEW OF CHAIN-OF-CUSTODY PROCEDURES
CROWN SIMPSON PULP COMPANY
Fairhaven, California
December 5-12, 1977
Records pertaining to the Crown Simpson Pulp Company presurvey
reconnaissance and monitoring survey were evaluated against the es-
tablished 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 from the
NEIC chain-of-custody procedures. If a deviation was discovered, an
assessment was made of the impact of the deviation on the survey re-
sults.
Bioassay samples were not kept under custody during collection
because of the large volume of water required for the tests — up to
600 liters (160 gal). However, the sample containers were kept next
to the monitoring location and checked at least hourly for tampering.
There was no evidence of tampering. Dilution water for the
flow-through bioassay was stored in epoxy-coated wooden reservoirs
outside of the mobile laboratory at the Crown Simpson mill site.
There was no evidence of tampering.
The evaluation conducted, including the item referenced above,
indicated that deviations from established NEIC chain-of-custody pro-
cedures were insignificant and, thereby, are considered to have had
no impact on the results, conclusions, and/or recommendations con-
tained in this report.
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