ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-78-007
NPDES Compliance M on i taring
and
Waste Characterization
Louisiana Pacific Corporation
Samoa, California
(December 5 12, 1977]
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER, COLORADO
ST^
AND £ £%
REGION IX SAN FRANCISCO I
APRIL 1978
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Environmental Protection Agency
Office of Enforcement
EPA-330/2-78-007
NPDES COMPLIANCE MONITORING AND WASTE CHARACTERIZATION
LOUISIANA PACIFIC CORPORATION
SAMOA, CALIFORNIA
(December 5-12, 1977)
April 1978
National Enforcement Investigations Center - Denver
and
Region IX - San Francisco, California
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CONTENTS
I INTRODUCTION 1
II SUMMARY AND CONCLUSIONS 5
INPLANT POLLUTION CONTROL 5
NPDES EFFLUENT LIMITATIONS COMPLIANCE 5
COMPLIANCE WITH FUTURE NPDES LIMITS 7
PRIORITY POLLUTANTS 9
COMPANY FLOWS VS NEIC FLOWS 9
SELF-MONITORING EVALUATION 9
III BACKGROUND 13
MILL LOCATION AND PROCESS DESCRIPTION 13
PROCESS WATER 15
PROCESS WASTEWATER DISPOSAL 16
INPLANT POLLUTION CONTROL 18
IV SURVEY METHODS 20
FLOW MEASUREMENT 20
SAMPLING TECHNIQUES AND LOCATIONS 21
BIOMONITORING TECHNIQUES 23
ANALYTICAL PROCEDURES 23
SELF-MONITORING EVALUATION 23
V SURVEY FINDINGS 24
NPDES EFFLUENT LIMITATIONS COMPLIANCE 24
BIOMONITORING 24
COMPARISON WITH FUTURE NPDES LIMITATONS .... 29
PRIORITY POLLUTANTS 32
COMPANY FLOWS VS NEIC FLOWS 32
SELF-MONITORING EVALUATION 39
REFERENCES 44
APPENDICES
A Louisiana Pacific Corporation NPDES Permit
NO. CA0005894
B Priority Pollutants
C Methods, Analytical Procedures and Quality Control
D NEIC Chain-of-Custody Procedures
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TABLES
1 NPDES Limitations 3
2 NPDES Compliance Monitoring 6
3 BOD and TSS Composite Sampling Data 8
4 Oil and Grease Data 25
5 pH and Temperature Date 26
6 96-Hour Flow-Through Survival Data 27
7 Comparison Between Louisiana Pacific Corp.
Future NPDES Limits and NEIC Data 30
8 Louisiana Pacific Corporation 31
9 Priority Pollutants 33
10 General Organics Data 37
11 Comparison of Flows During December 5-12, 1977 . 38
FIGURES
1 Outfall Locations - Crown Simpson & Louisiana
Pacific Pulp Mills 2
2 Crown Simpson & Louisiana Pacific Mill Sites . . 14
3 Louisiana Pacific Corporation 17
4 Process Wastewater Diurnal Flow Variation .... 40
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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. CA0005894 to the Louisiana Pacific Corporation [Appendix
A] authorizing one process wastewater discharge to the Pacific Ocean,
and three noncontact cooling water discharges to Humboldt Bay in north-
ern 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 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 Louisiana Pacific
Corporation pulp mill.
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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SCALE 1:24 000
J 0 l mile
500' Qlff/j#>r Sect
^ PACIFIC
OUTFALL,
IMPSON
OUTFALL
203' /O I ffu s • r
• utostatii
pry j}J (Dock^/
Docks Beacon 7 Oil -
•V Disposal
' KINS O- "
i?adra Tower
airhaven
•//* #/* / / /
/£ 11/
, *./• .-Rolph School
f *// //* /:•• .'ill
/;? ^fcUBcKA I CITY
Beacon,
^Bucksport'/o7»jS^sj=
'Sewage Disposay# fj===ar.v-
1 :;r^
Dolphin
Wells
Water
Fig ur • J. Outfall Locations - Crown Simpson
and Louisiana Pacific Pulp Mills
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3
Table 1
NPDES LIMITATIONS
(EFFECTIVE 7/1/77)
LOUISIANA PACIFIC CORPORATION
Constituents
F1 ow
B0D5 (pulp)
BODr (hydraulic
barker)
TSS (pulp)a
TSS (hydraulic
barker)
Units
m^/day x 10^ (mgd)
kg (1b)/day
kg (lb)/day
kg (1b)/day
kg (lb/day)
30-day Avg.
114 (30)
4,460 (9,821)
680 (1,500)
9,080 (20,008)
3,270 (7,200)
Daily Max.
168 (44.4)
8,560 (18,849)
2,040 (4,500)
16,800 (37,088)
9,780 (21,550)
Oi1 and grease
pH
mg/1
Standard
Uni ts
The discharge of noncontact cooling
water to Humboldt Bay in excess of
the following limits is prohibited:
30-day median = 10
90th percentile = 15
within range of 5.0-9.0
22.0°C
24.0°C
a In addition to TSS in raw water supply.
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4
In addition, since the Louisiana Pacific 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 param-
eters.
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 Louisiana Pacific Corporation pulp
mill in northern California near Eureka. The mill produces approxi-
mately 553 m. tons (610 tons)/day of market-bleached kraft pulp, pri-
marily for export. Wastewaters generated in the pulp mill processes
as well as the hydraulic barker at the adjoining sawmill are dis-
charged untreated to a Pacific Ocean outfall which terminates more
than 610 m (2,000 ft) from shore at low water through a 152 m (500 ft)
diffuser more than 9 m (30 ft) deep.
INPLANT POLLUTION CONTROL
Louisiana Pacific has sought to employ inplant controls with no
external treatment to achieve Best Practicable Control Technology
Currently Available (BPT) limitations for total suspended solids
(TSS) and to gain a variance from BPT limitations for BOD and pH.
Since 1973, the Company has made a number of inplant changes to re-
duce the loss of fiber and remove other suspended matter from waste
streams. As will be noted below, these changes resulted, at least
during the NEIC survey, in compliance with BPT TSS limits.
NPDES EFFLUENT LIMITATIONS COMPLIANCE
Effluent data collected during December 5-12, 1977 [Table 2],
show Louisiana Pacific exceeded its NPDES limitation for BOD (pulp)
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Table 2
NPDES COMPLIANCE MONITORING
LOUISIANA PACIFIC CORPORATION
December 5-12, 1977
Parameter
NPDES
Permit
NEIC Results
30-Day Average
Daily Maximum
Average
Maximum
kg/day
1b/day
kg/day
1b/day
kg/day
lb/day
kg/day
lb/day
BOD (pulp)
4,460
9,821
8,560
18,849
14,000
30,000
18,000
40,000
BOD (hydraulic
barker)
680
1,500
2,040
4,500
190
410
300
600
BOD (veneer)
128
283
385
849
b
b
TSS (pulp)
9,080
20,008
16,800
37,088
3,500
7,700
6,100
13,000
TSS (hydraulic
barker)
3,270
7,200
9,780
21,500
1,300
2,800
1,700
3,800
Oil and grease
30-day Median =
10 mg/1
90th percentile = 15 mg/1
Process wastewater:
Average = 5.1
Range = 0.1-9.3
Hydraulic Barker:
Average = 3.4
Range = 1.2-6.2
PH
within range of 5.0-9.0 standard units
Process wastewater:
Range = 2.3-10.0
Hydraulic Barker:
Range = 1.8-12.3
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)"]
CTi
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7
30-day average (14,000 vs 4,460 kg/day). The BOD (pulp) daily maxi-
mum limit (8,560 kg/day) was exceeded on all seven days of sampling
[Table 3]. The Company was also in violation of its NPDES pH limits
(5.0-9.0) for both the pulp (2.3-10.0) and hydraulic barker (1.8-12.3)
wastewaters. The Company was in compliance with BOD limits for the
hydraulic barker, as well as TSS and oil and grease limits for both
the pulp process and hydraulic barker wastewaters.
NPDES permitted discharges 002 and 003, which resulted from air
compressor cooling, have been eliminated.
On December 8, 1977, at 1430 hr a grab sample was collected from
the Company's once-through condenser discharge, 004, to ascertain
whether any process wastewaters were present. The clear appearance
of the sample and the BOD and TSS values of <3.7 and 17 mg/1, respec-
tively, indicated no process wastewater contamination.
The Louisiana Pacific Corporation effluent was determined to be
acutely toxic to fish. The 96-hour LC50 was calculated to be a 30.4%
effluent concentration. Despite this demonstrated acute toxicity, it
is estimated that the Company will be in compliance with the NPDES
receiving water 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, indicate that most of the limits
which begin to come into effect July 1, 1978, will be met. Excep-
tions include phenolic compounds (NPDES 50%* limit of 0.5 mg/1 vs
NEIC average of 1.0 mg/1), total chromium** (NPDES 50% limit of 0.005
Concentration not to be exceeded more than 50% at the time.
Unlike other future limits, does not become effective until July 1,
1983.
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Table 3
BOO AMD TSS COMPOSITE SAMPLING DATA
LOUISIANA PACIFIC CORP PULP HILL
Samoa , Cal 1 form a
December 5-12, 1977
Sta tion
Loca tion
Da tea
Dec
1977
Flow
UOO
TSS
m^/day
x 103
mgd
mg/1
kg/day
lb/day
Gross
mq/1
Intake'5
mg/1
Net
mg/1
ilet
^g/day
Loadi ntjs
lb/day
Sta tion
6
83 6
22 1
130
11,000
24,000
93
24
69
5,800
13,000
3-100 -
7
89 3
23.6
180
16,000
35,000
57
13
44
3,900
8,700
Louisiana
8
91 6
24 2
140
13,000
28,000
53
25
28
2,600
5,700
Pacific
9
73 4
19.4
130
10,000
21,000
53
7
46
3,400
7,400
process
10
90 8
24 0
200
18,000
40,000
78
11
67
6,100
13,000
wastewater
11
74 9
19.8
220
16,000
36,000
40
3
37
2,800
6,100
at effluent
12
72 3
19 1
170
12,000
27,000
22
54
0
0 0
0 0
pump
Avg.
82.3
21.7
170
14,000
30,000
57
20
42
3,500
7,700
S ta tion
6
_c
_
83
_
_
310
24
206
_
3450 -
7
3 8
1.0
79
300
660
270
13
257
970
2,100
Louisiana
8
4.2
1.1
58
240
530
310
25
285
1 ,200
2,600
Pacific
9
3.8
1 .0
43
180
400
400
7
392
1 ,500
3,300
Hydraul1C
10
3.0
0 8
92
280
610
500
11
569
1 ,700
3,800
Barker
11
1.1
0 3
43
49
110
850
3
847
960
2,100
Wastewater
12
1 .9
0.5
40
76
170
770
54
716
1 ,400
3,000
at Dis-
Avg.
3.0
0.8
63
190
410
500
20
480
1 ,300
2,800
cliarge to
Ocean outfall
pipeline
TOTAL
6
_
_
-
_
_
_
24
.
(Stations
7
93.1
24.6
174
16,300
35,660
66
13
53
4,870
10,800
3400 + 3450
8
95.8
25 3
135
13,240
28,530
64
25
39
3,800
8,300
= Ocean
9
77 2
20.4
1?5
10,180
21 ,400
70
7
63
4 ,900
10.700
Discharge)
10
93.8
24 8
19C
10,280
40,610
92
11
81
7,800
16.800
n
76.0
20 1
215
16,049
36,110
52
3
49
3,760
8,200
12
74.2
19 6
166
12,076
27,170
72
54
18
1 ,400
3,P00
Avg.
85 0
22.5
168
14,000
32,000
'
20
51
4 ,400
9,600
a Conpositing period iazs 0700-0700. Date hated ii> day period ended
b Raw water supply sampled at Crown Simpson Pulp Company intake. Both mills draw from the same water supply
tank on the Samoa Peninsula,
a Flow meter totalizer out 1000-151S, so no flow recorded.
CO
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9
mg/1 vs NEIC average of 0.09 mg/1), and total identifiable chlori-
nated hydrocarbons (50% limit of 0.002 mg/1 vs NEIC average of 2.9
mg/1). In addition, if the effluent toxicity remains at levels found
during the NEIC survey, the Company will be in violation of the toxi-
city limits (50% and 10% limits of 1.5 and 2.0 toxic units respectively
vs NEIC values of 3.3).
PRIORITY POLLUTANTS
Effluent composite samples collected December 6-9, 1977, indi-
cated the presence of 14 and 19 Priority Pollutants in the process
wastewater and hydraulic barker effluent, respectively. 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
A comparison between process wastewater flows estimated by
Louisiana Pacific based on mill raw water flows and those actually
measured by NEIC indicated marginal agreement. The overall LP/NEIC
flow ratio was 0.87. On three days there was greater than 20% dif-
ference between the values, and on three days there was <5% difference.
SELF-MONITORING EVALUATION
An NEIC evaluation of the self-monitoring practices indicated
the following deviations from prescribed/recommended techniques:
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10
Sampling Techniques
1. Composite samples were collected by automatically collec-
ting equal volume aliquots at equal time intervals. Since
the flow rate is not constant and varies according to the
downstream control valve setting, these composites were not
flow proportional as required by the NPDES permit. Further-
more, these samples were not refrigerated during collection
as prescribed.
2. The pH was determined on each of the 24-hour composite samples
collected during the month, then averaged, 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.
3. Settleable solids were collected from the composite samples,
not by grab samples as required by the NPDES permit.
4. 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 extremely
impractical and not recommended by EPA.
5. Phenolic compounds composite samples were collected in a
plastic container, not glass as prescribed, and not pre-
served or refrigerated during collection.
Flow Monitoring
1. As noted previously, the Company estimates process waste-
water effluent flow with metered raw water flows. This
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n
practice was determined to be marginally acceptable for
daily flows, but precludes collecting flow-proportional
effluent composite samples.
2. The location of the flow monitoring site for the hydraulic
barker effluent (i.e., downstream from the clarifier sump
pump) precludes instantaneous flow measurement and conse-
quently flow proportioning of composite samples. The nu-
merous severe fluctuations in flow also make it difficult
to obtain an accurate measurement of total daily flow.
3. The Company did not have an established calibration fre-
quency for the flow measurement systems. Calibrations
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. No required modification request had been
made and no data had been collected to establish compar-
ability with the EPA-approved method.
2. TSS procedures were performed as prescribed, except that
filters were weighed directly out of the oven without des-
iccation. This technique will generally cause low results.
3. Though not specifically required by the NPDES permit, the
Company had established no formal analytical quality con-
trol program.
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12
Other
Despite the fact that the NPDES permit contains 30-day average
and daily maximum loading limitations for both the process waste-
waters (listed as "Pulp" in permit) and hydraulic barker, the Company
reports to the State of California a flow-weighted average concentra-
tion for a combination of the two discharges. No load calculations
are transmitted, thereby precluding a determination of individual
loadings.
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III. BACKGROUND
MILL LOCATION AND PROCESS DESCRIPTION
The Louisiana Pacific pulp mill, which began operation in 1965,
is located on the Samoa Peninsula in northern California, approxi-
mately 5 km (3 mi) north of the entrance to Humboldt Bay [Figure 2].
The mill is on the east side of the peninsula, about 1.2 km (0.75 mi)
south of the town of Samoa and about 1.6 km (1 mi) north of the com-
munity of Fairhaven. It is one of two pulp mills on the peninsula,
the other belonging to the Crown Simpson Pulp Company, approximately
1.2 km (0.75 mi) south of the Louisiana Pacific Mill. The peninsula
is a low sandy area, approximately 13 km (8 mi) long and varying in
width from 0.8 to 1.4 km (0.5 to 0.9 mi); consequently, the mill is
only about 6 m (20 ft) above sea level. The total population on the
peninsula south of Samoa Bridge is approximately 700.
The Lousiana Pacific Corporation mill produces approximately 553
m. tons (610 tons)/day of market-bleached kraft pulp. Raw materials,
including primarily redwood and douglas fir sawdust and chips from
nearby lumber and plywood operations, are chemically digested by the
kraft process in a single digester which was designed to produce 495
m. tons (550 tons)/day of pulp. The digester is reported to have a
maximum capacity of 630 m. tons (700 tons)/day. The digested pulp is
washed and screened, then bleached in six stages with washing follow-
ing each. All washing in the bleach plant is skip-stage countercurrent.
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.
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Mad River
Areata
HOKTHWESTtKH PACIFIC
Manila
Samoa
Foirhoven
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15
What can't be sold overseas is sold domestically. In addition to the
pulp mill and bleach plant, the Company also operates a sawmill, stud-
mill, and plywood mill on adjacent lands.
Production during the NEIC survey of Louisiana Pacific was as
follows:
December Ai r Dry
1977
m. ton
ton
5a
477
526
6
549
605
7
598
659
8
519
572
9
560
617
10
576
635
11
538
593
Average
545
601
a Production day runs fron 0800 hr of date
listed to 0800 hr of following day.
PROCESS WATER
Process water is purchased from the Humboldt Bay Municipal Water
District (HBMWD). 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 Louisiana Pacific and
Crown Simpson pulp mills. Pretreatment at the mill can include pre-
chlorination, physical-chemical clarification and filtration, and
softening. Whether raw process water is subjected to all these pre-
treatment processes is determined by use in the mill.
Process water use has declined from approximately 95,000 m3/d
(25 mgd) in early 1976 to 76,000 m3/d (20 mgd) in late 1977. This
has primarily resulted from the severe California drought which
raised the specter of mill closure and stimulated tight controls on
mill water use.
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16
PROCESS WASTEWATER DISPOSAL
Outfall 001
Process wastewaters are collected by two main sewerage systems:
an acid system which transports low pH wastewaters from the bleach
plant, and an alkaline system which transports near-neutral and high-pH
wastewater from the pulping processes and bleach plant [Figure 3].
In addition, septic tank overflow is discharged to the alkaline sys-
tem. These wastewaters are discharged to a baffled sump, called
"Manhole 5," where they are commingled with water treatment plant
sludge. From the sump, they are delivered to the effluent pipeline
by a single constant-speed pump. The discharge rate is controlled by
a downstream valve which is regulated by the sump level. Just down-
stream of the pump these wastewaters are joined by a 20 cm (8 in)
polyvinyl chloride (PVC) pipe which transports clarified effluent
from the hydraulic barker at the adjoining sawmill, demineralizer
effluent from the power boiler area, and clarified overflow from the
power boiler scrubber. All these commingled wastewaters then flow
through a 122 cm (48 in) woodstave pipe approximately 366 m (1,200 ft)
to the beach, and then through approximately 975 m (3,200 ft) of 122
cm (48 in) reinforced concrete cylinder pipe to the Pacific Ocean
[Figure 1], Discharge is accomplished through a 152 m (500 ft)
diffuser at a depth of over 9 m (30 ft) and more than 610 m (2,000
ft) from the shoreline at low water.
OutfalIs 002 and 003
These discharges included non-contact cooling water from two
compressors located in the loading dock area. Since the issuance of
the NPDES permit in March 1977, the compressors have been removed
from the area, thereby eliminating the discharges.
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Sentic
Tanks (2)
Recovery
Chip Handing
Digester
Recausticizing
Bleach Plant Caustic Filtrate
<
To Pacific Ocean
Outfal1
Manhole #5
Station 3450
U1
"O
U
Sawnn 11-Hvdraulic Barker
CI an f i er
Power Boilers (Demineralizer
and Scruhhpr)
Water Treatment Plant Sludge
Bleach Plant Acid Filtrate
Recovery
Chemical Preparation
Figure 3. Louisiana Pacific Corporation
Samoa, California
Wastewater Sytem
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18
Outfall 004
Cooling for approximately 8 megawatts of the mill's 48 megawatt
capacity is accomplished with once-through condensing water which is
withdrawn from and returned to Humboldt Bay.
INPLANT POLLUTION CONTROL
The Louisiana Pacific Corporation has sought to employ inplant
controls with no external treatment to achieve Best Practicable Con-
trol Technology Currently Available (BPT) limitations for TSS and to
gain a variance from BPT limitations for BOD and pH. The inplant con-
trols, all of which were installed prior to the NEIC survey, included:
1. The screen room floor drain system was modified prior to
1973 to collect all spills and return them to the unscreened
stock chest. Equipment was also installed to dewater the
screen-room rejects for burning in the hog fuel boiler.
2. A sidehill screen was installed in 1974 to dewater machine
room cleaner rejects, which are then returned as fuel.
3. Fiber-bearing streams of the drier wet-end were separated
and recycled in 1976 to the second- and third-stage bleach
washer vats and the brown stock decker.
4.
Brown stock washers were modified in 1977, and a spill
collection system was installed to recycle formerly
wasted fiber to the blow tank for reuse.
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19
The above programs were designed to reduce the loss of fiber and
remove other suspended matter from waste streams. In 1977, the Com-
pany also ceased discharging excess weak black liquor, a source of
BOD and toxic chemicals. When the pulping unit was operated at peak
capacity, in response to favorable market conditions, more black
liquor was produced than could be processed through the recovery
unit. It had been Company policy to sewer this excess weak black
liquor. This policy was changed, allowing the recovery process to be
production-rate limiting.
According to plant officials, the Company plans to make neces-
sary changes to capture spilled fiber in the bleach washer area.
They also plan to air strip sour condensate from the evaporators in
the recovery area if it is determined that this will result in re-
duced effluent toxicity. No time schedules have been established.
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IV. SURVEY METHODS
FLOW MEASUREMENT
Process Wastewaters
The Louisiana Pacific Corporation conducts no effluent flow moni-
toring of process wastewaters at its Samoa, California pulp mill.
Effluent flows are estimated by first measuring raw water entering
the mill with a flow tube (throat diameter 19.020 inches) from which
pressure differential is transmitted to a meter, converted to flow
and continuously recorded and totaled. The assumption is made that
inplant water losses due to evaporation are balanced by moisture in
the wood and chemicals used. Since a portion of the raw water is
delivered to the City of Samoa, California and the adjoining sawmill,
this metered flow is subtracted from total flow, ostensibly leaving
the effluent flow.
Since the Company's assumption that total water-in equals water-
out was untested, and the NPDES permit requires flow-proportional
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].
Commencing the morning of December 5, 1977, flow was measured
once each two hours with this technique. On the morning of December
10, this frequency was increased to once an hour.
To facilitate comparisons with the Company's flow estimates,
NEIC requested that the raw water transmitting and recording systems
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21
be calibrated. These calibrations were satisfactorily performed by
Company employees on Friday, December 2, 1977, in the presence of
NEIC personnel.
Hydraulic Barker Effluent Line
In the hydraulic barker line, immediately upstream of the point
where it joins the outfall line, the Company has installed an orifice
plate (bore = 5.820 inches) to measure flow. Pressure differentials
are transmitted to a meter, converted to flow and continuously re-
corded and totaled. An NEIC inspection of the recording chart indi-
cated numerous peaks and troughs separated by only a few minutes. It
was determined that this resulted from "level-to-level" pumping at
the hydraulic barker clarifier sump, thereby precluding accurate mea-
surement of instantaneous flow. It was decided, however, that a rea-
sonable estimate of total daily flow could be obtained, and the Com-
pany was requested to calibrate the transmitting and recording sys-
tems. These calibrations were satisfactorily performed by Company
employees on Friday, December 2, 1977, in the presence of NEIC per-
sonnel .
SAMPLING TECHNIQUES AND LOCATIONS
During December 5-12, 1977, the NEIC collected wastewater sam-
ples at the Louisiana Pacific pulp mill for a wide range of param-
eters. Established chain-of-custody procedures were followed in the
collection of all samples and field data and in the analysis of all
samples except for minor deviations noted in Appendix C. Twenty-
four-hour composite samples for BOD and TSS were collected from pro
cess wastewaters at the discharge side of the effluent pump and the
hydraulic barker effluent line at a tap where the line joined the
outfall line [Figure 3]. Composite aliquots were collected each hour.
-------
22
In the case of the process wastewater, a flow rate was first deter-
mined by tracer dilution, aliquots were formed proportional to this
flow for two consecutive hours, and the process was repeated. On the
morning of December 10, 1977, the frequency of flow monitoring was
increased to once an hour, affording a flow-proportional aliquot each
hour. For the hydraulic barker effluent, equal-volume aliquots were
collected hourly since, as stated previously, instantaneous flow mea-
surement was impossible. Grab samples for oil and grease were collec-
ted three times a day at the same locations.
TSS composite samples to provide the allowed credit for solids
in the raw water were collected from the intake line at the Crown
Simpson Pulp Company. As noted previously, the same source of raw
water is used by both mills. 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 phenolic
compounds, are also limited in the future in the Company's NPDES Permit
[Appendix A]. Composite samples for these pollutants were collected
in a similar manner to those previously described except that all raw
water samples 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 pro-
mulgated by EPA pursuant to Section 304(g) of the Federal Water
Pollution Control Act (FWPCA).
-------
23
BIOMONITORING TECHNIQUES
Commencing at 1500 hr on December 7, 1977, a 96-hour con-
tinuous-flow bioassay was conducted on a flow-proportional combi-
nation of the Louisiana Pacific Corporation process wastewater dis-
charge and hydraulic barker effluent which constitute the ocean
outfall discharge. The objective of this test was to determine if
the wastewater discharge was acutely toxic to fish. Three-spined
sticklebacks (Gasterosteus aculentas Linnaeus) averaging approxima-
tely 4 cm in total length were used as test organisms. Detailed
methodology of the bioassay procedures are included in Appendix D.
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 pro-
vided to the Louisiana Pacific Corporation for separate analysis.
Pertinent analytical methodology and quality control statements are
included in Appendix D.
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 pro-
cedures.
-------
V. SURVEY FINDINGS
NPDES EFFLUENT LIMITATIONS COMPLIANCE
Effluent data collected during December 5-12, 1977 [Tables 2
through 5], show Louisiana Pacific exceeded its NPDES limits for BOD
(pulp) 30-day average (14,000 vs 4,460 kg/day). The BOD (pulp) daily
maximum (8,560 kg/day) limit was exceeded on all seven days of sam-
pling. The Company also exceeded its NPDES pH limits (5.0-9.0) for
both the pulp (2.3-10.0) and hydraulic barker (1.8-12.3) wastewaters.
The BOD results for the hydraulic barker, as well as TSS and oil and
grease results for both the pulp process and hydraulic barker waste-
waters, were within the permit limits.
On December 8, 1977, at 1430 hr a grab sample was collected from
the Company's once-through condenser discharge, 004, to ascertain
whether any process wastewaters were present. The clear appearance
of the sample and the BOD and TSS values of <3.7 and 17 mg/1, respec-
tively, indicated no process wastewater contamination.
BIOMONITORING
The Louisiana Pacific Corporation effluent was determined to be
acutely toxic to fish [Table 6]. The 96-hour LC50 was calculated to
be a 30.4% effluent concentration.
* lc50 indicates the concentration (actual or interpolated) at which
50% of the test organisms died or would be expected to die.
-------
25
Table 4
OIL AND GREASE DATA9
LOUISIANA PACIFIC CORP. PULP MILL
Samoa, California
December 5-12, 1977
Station
Date
Time
0/G
Station
Date
Time
0/G
Location
Dec.
hr
mg/1
Location
Dec.
hr
mg/1
1977
1977
Station
5
1100
4.6
Station
5
1100
2.5
3400 -
1600
7.6
3450 -
1600
2.3
Louisiana
Avg.
6.1
Louisiana
Avg.
2.4
Pacific
Pacific
Process
6
0212
9.3
Hydraulic
6
0208
5.0
Wastewater
0805
4.3
Barker
0805
1.2
at Effluent
1615
7.9
Wastewater
1600
3.7
Pump
Avg.
7.2
at Outfall
Avg.
3.3
to Ocean
7
0001
3.4
Outfall
7
0125
4.6
1000
7.4
Pipe!ine
0955
5.5
1745
5.0
1740
3.8
2205
5.3
2225
6.2
Avg.
5.3
Avg.
5.0
8
1015
6.5
8
1018
3.6
1530
5.2
1535
5.7
2112
0.1
2133
4.1
Avg.
3.9
Avg.
4.5
9
0115
9.0
9
0125
4.7
1615
6.0
1615
4.6
Avg.
7.5
Avg.
4.6
10
0300
1.6
10
0300
1.6
0600
2.6
0600
1.2
1800
1.9
1800
4.1
2312
3.7
2312
2.2
Avg.
2.4
Avg.
2.3
11
0502
5.0
11
0502
2.2
1615
3.7
1625
2.4
2312
-
1800
-
Avg.
4.4
Avg.
2.3
12
0610
2.1
12
0610
1.2
5-12
AVG.
5.1
5-12
AVG.
3.4
-------
Table 5
plI AtiD TEnPERATURE DATA
LOUISrAHA PACIFIC CORP. PULP MILL
Samoa, California
Dec 5-12, 1977
Rec.._iL6 Sf-.n. fi-7 Dec. 7-ft Pec 8-9 Opr. Q-10 Dt'c 10-11 rinr. 11-1?
Time Sta Sta., Sta Sta Sta. Sta Sta Sta Sta Sla 5La Sta Sta. Sta. Sta Sea. Sta. Sta Sta Sta Sta
3-100' 3450 3550^ 3100 3150 3550 3100 3150 3550 3100 3150 3550 3400 3150 3550 3100 3150 3550 3100 3150 3550
Eli
0700
3 5
7 9
7.4
3 8
7.2
7 2
3.3
8.5
7.3
3 4
7.2
7.3
3
6
11 6
7.5
3 4
3 0
7 4
4.0
9 5
7 6
0800
1.9
7 8
6 9
4.0
7.5
7.4
3.1
7 6
7.1
2.7
7.8
7.4
3
6
9 3
7 6
8 0
7.0
7.6
4.1
8 8
7 5
0900
3 8
7.2
6.9
2.8
7.5
7.3
3.2
7 8
7 2
2 3
7.2
7.3
3
5
9 8
7 4
3 6
5 7
7.7
5.3
8 4
7 7
1000
3.7
3.3
7 3
8.2
7.8
7.5
2 6
9 5
7 2
4 5
6 8
7 3
4
7
11.3
7 5
6 1
11 6
7.6
4 7
1 i 1
7 C
1 100
3.6
6.8
7.2
4 9
7.0
7.2
2 8
11.8
7 2
5 8
7 4
7.4
5
.2
9.1
7.5
4.4
9.4
7 5
5 5
10 8
7 6
1200
4 8
6.7
7.3
3 2
7.2
7.0
2.6
8 4
7 0
4.4
9 8
7.5
6
7
7.2
7.4
3 0
9.2
7.6
4.4
2.4
7.5
1300
4 6
11.3
7 3
10.0
7.8
7.1
2.8
2 8
7.1
9 9
9.4
7.4
3
6
9.3
7.5
3 7
,9 0
7.7
6.7
2.4
7.7
1100
2 6
5 2
7.2
4.0
7.0
7 2
3.3
7 3
7 2
-
7 1
7.5
3
.3
8.6
7.6
2.9
9.0
7.3
6.1
4 4
7 7
1500
3.1
8.7
7.2
3.7
11 7
7.1
2.7
7.6
7 1
9.9
7.4
7.4
3
4
8.1
7 5
3 5
8.9
7 5
5.3
5 4
7 6
1600
2.8
8.4
7.3
3.0
10.1
7.2
2.8
9 6
-
4 4
7.2
7 6
4
4
5 5
7.7
2 a
9.1
7.5
5 5
4 0
7 5
1700
2.9
8.7
7 1
4 1
7.8
7 2
3.0
12.1
7.1
7 1
11.5
7.5
3
9
7 7
7 4
3 0
2.5
7 7
5.3
8.5
7 6
1800
2.7
8 1
7.2
3.3
6 3
7 3
2.9
8.3
7.2
10.0
7 6
3
.9
7.1
7.6
2 9
7 9
7 6
5.3
9 3
7.7
1900
4 8
8.0
7 6
3 0
6.9
8.1
3 3
6.9
7 6
5.1
7.1
7.4
4
7
7.4
7 1
6 2
4 3
7 8
6 8
9.7
7 1
2000
5 5
8.5
7 5
4 0
6.9
7.5
3 1
2.3
6 9
3 1
7.6
7.9
6.
,3
9.0
7.2
6 2
2 0
7.6
4.2
9.3
7 1
2100
3 8
9.3
6.9
3.3
10.8
7 9
3 6
11 8
6.6
3 1
2.9
7 7
6
6
9.9
7 3
3.0
5 5
7 9
3.6
1.8
6 9
2200
4.8
7 6
7.5
3 2
9 0
7.5
3.7
2.6
7.7
4 0
7.2
7.6
6
1
8 5
7 6
3 I
8.9
7 9
6 0
1 1 7
7 0
2300
6 3
7.2
7.5
3.1
8 6
7.6
5.0
7.4
7 8
3.7
7.0
7.5
3.
1
9 5
7.5
3 2
9 3
7.7
6.4
2 2
7 6
2400
6.5
7.7
7.4
3.8
7.4
7 4
4 5
7.6
7 1
4.0
7.1
7.4
5
4
7.2
7 5
5 5
9 5
7.7
3.8
9 8
7 7
0100
5 6
7.5
7 4
4.0
7.8
7 6
5.6
7.5
7 8
4 1
2.4
7.4
3
8
9.7
7 1
3 8
9.5
7.7
3.4
12 3
7 0
0200
4.9
8.8
7 4
3.6
7.7
7.5
4.4
7 9
7 6
4.0
6.3
7.8
3
6
7 0
7 7
4.1
11 2
8 0
3.7
10.5
7 6
0300
5.9
9 4
7.6
3.4
7 3
7.5
5.3
2.1
7 7
3.4
2.1
7.7
6
5
0.5
7 2
5 5
2 7
7.7
3 9
9.4
7 6
0400
5 2
8 6
7.4
8.7
4.3
7 4
4.8
7.3
7 7
8 9
6.7
7.9
3.
2
9.5
7.7
3 5
4.0
7 8
3.5
4.2
7 5
0500
6.1
7 1
7.3
6.3
6 3
7.2
4.4
8.2
7.8
3 9
6.4
7.6
6
8
11 9
7.4
3 9
10.5
7 8
3.4
8 4
7 7
0600
3.8
7.2
7.4
4.3
4.3
7.7
6 5
2.3
7 6
4.1
8.9
7.9
4
0
10 9
7.9
9.4
9 5
7.8
3.7
2.3
7.3
Max.
6.5
11.3
7.6
10.0
11.7
8.1
6.5
12.1
7 8
10 0
11 5
7 9
6
8
11 9
7 9
9.4
11 6
8 0
6.8
12.3
7 7
Mi n.
2 6
3 3
6 9
2.8
4.3
7.0
2 6
2.1
6.6
2 3
2.1
7.3
3.
1
5.5
7.1
2.9
2 0
7 3
3 4
1.8
6 9
TRIPE mUKE
CC)
Max.
37.0
31.5
13 0
36.5
31 .5
11.5
36.0
31.0
12.0
35 0
32.0
10.5
36
5
23.5
10.5
35.5
25 0
11 0
41 0
27 0
12 0
Ihn.
31.5
22.5
11 0
28 0
23 0
10.5
20.5
22 5
10.0
23 0
18 0
8.5
23
5
18 0
8 5
30.0
15 0
9 5
30 0
15.0
10 5
Avg.
34.5
26.0
12 0
33.5
27 4
11.5
32.0
25.5
11.5
31 .0
22.0
10.0
35
.0
24.0
9.5
34.0
20 5
10 5
31 0
22.0
11 5
a Louf*inwi Pacific process war.teuatcr at affluent pwnp
b Louisiana Pacific hydraulic bai'ker at di c.charqc to ocean outfall pipehne
c iTau water supply at intake to Crovn Simpson Mill before any treatment processes (conron water supply for fouiahitu laeific at\t Crown Si p -i,)
no
CTt
-------
27
Table 6
96-HOUR FLOW-THROUGH SURVIVAL DATA
LOUISIANA PACIFIC EFFLUENT
December 1977
% Survival
Time Period Effluent Concentration {%)
Control
5
9
16
28
37.5
50
24-hour
100
100
100
100
95
100
70
48-hour
100
100
100
100
95
100
20
72-hour
100
100
100
100
90
95
15
96-hour
100
100
100
100
85
0
0
-------
28
It was not within the scope of this bioassay to isolate or iden-
tify the specific toxic components of the wastewater tested. However,
the literature indicates 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 phenols,
resin acids, and stearic acids from caustic bleaching.1 The toxicity
of pulp mill wastewaters can vary widely within and between mills.
This is principally a result of variations of acid resin concentra-
tions in the waste stream, which is primarily governed by the wood
species composition. Highly resinous species such as douglas fir and
various spruce woods in general produce waste streams of greater toxi-
city 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 are also factors affecting resin acid content and there-
fore toxicity.3 For debarking streams, factors influencing toxicity
can include log size, physical state and moisture content of the bark,
severity of the debarking, and water temperature.1
The NPDES permit for Louisiana Pacific contained no specific
effluent 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 calcula-
ting the actual toxic unit (100/LC5O) for the effluent and dividing
this value by an 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 3.3. Assuming 3.3 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 64:1.
-------
29
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 3.3 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 Louisiana Pacific waste stream,
two additional factors deserve mention: pH and BOD. As detailed in
the Methods Section of this report [Appendix D], 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 5.4 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 wastewater composite sample ranged
from approximately 2 to 12 [Table 5], Either of these extreme pH
conditions would be acutely toxic to fish.4
COMPARISON 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] indicate that most of these
limitations will probably be met, except phenolic compounds (50% limit
of 0.5 mg/1 vs NEIC average of 1.0 mg/1), total chromium (50% limit
of 0.005 mg/1 vs NEIC average of 0.09 mg/1), and total identifiable
chlorinated hydrocarbons (50% limit of 0.002 mg/1 vs NEIC average of
-------
30
Table 7
COMPARISON BETWEEN LOUISIANA PACIFIC CORPORATION
FUTURE NPDES LIMITS AND NEIC DATA
COLLECTED DECEMBER 6-9, 1977
Future
NEIC Data,
Dec. 6-9, 1977
NPDES
Limits
Station 3400
Station 3450
Constituents
50%
10%
LP Process
LP Hydraulic
of time
of time
Wastewater
Barker
mg/1
mg/1
Arsenic
0.01
0.02
<0.010
<0.012
Cadmium
0.02
0.03
<0.020
0.020
Copper
0.2
0.3
0.004
0.031
Lead
0,1
0.2
<0.005
0.042
Mercury
0.001
0.002
<0.001
<0.001
Nickel
0.1
0.2
<0.1
<0.1
Silver
0.02
0.04
<0.008
<0.008
Zi nc
0.3
0.5
0.12
0.087
Cyanide
0.1
0.2
<0.01
0.14
Phenolic
0.5
1.0
1.0
0.075
Compounds
Total Identi-
fiable
Chlorinated
Hydrocarbons
0.002
0.004
2.9
0.003
Toxicity Con-
k
centration
1.5
2.0
3.3
Total Chromium
0.005
0.01
0.09
0.01
a Measured in toxic units
b 96-hour bioassay commenced 1500 on December 7, 1977 on combination
of process wastewater (3400) and hydraulic barker (3450)
-------
Tabic 8
METALS, CYANIDE, PHENOLICS AND CHLOFtII/rtTED HYDROCARBOUES DATA
LOUISIANA PACIFIC CORP.
Samoa, California
Dec 6-9, 1977
Station Location
Da te
Dec
1977
Parameters'1
T i me
br
F1 ow
SI)
As
Be
Cd
Cr
Cu
Pb _llg_ Ml
Se
Ag T1 Zn
CnT PTienolic Clflbrir.iU'il
m /day
x 103
mgd
— tonqound^ IL^nraijuij
ug/) yg/1 |jg/1 ug/1 ug/1 ug/1 ug/1 Jjg/l mg/1 ug/1 u.»/u 'ij Cr - chvonmvn; Cu-coppcr,Pb - lead, hq - rr-.u n
u. - nickel, Sc - selcnuvn, Aq - silver, TL - thulltum, Zn - ;nc, <'>•., - total a.anide
b .'lotions 3100 and J45 0 data based on 24-hr comport ten of aliquot? collected hourly from 0700-0700. Data h-.ted is da.j ccr^po^itir^ period e>W(d
Station 3550 daLa based on single grab sample per day since Mater supply considered stable source
n Data >iot inuludrd as sample suspected of contamination
d ND = Hone detected
c From Priority Pollutant sampling. Note concentrations for Station 3400 are largely a result of chlovojcr;n [_Tablc J]
(jO
-------
2.9 ing/1). In addition, if the effluent toxicity remains at levels
found during the NEIC study, the Company will be in violation of tox-
icity limits (50% and 10% limits of 1.5 and 2.0 toxic units, respec-
tively, vs NEIC value of 3.3) [Table 7],
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 gen-
eral organics [Table 10]. Fourteen and nineteen of the Priority Pol-
lutants were identified in the process wastewater and hydraulic
barker effluent, respectively. The compounds identified are rep-
resentative of the natural wood products and chemicals used or
created in pulping and bleaching processes. The polynuclear aromatic
hydrocarbons [nos. 72-88 on Table 9] detected in the hydraulic barker
effluent probably originate in the power boiler scrubber overflow
since they can result from the combustion of fuels.
Two Priority Pollutants, di-n-butyl phthalate and diethyl
phthalate, were present in the raw water supply in low concentra-
tions, 1-3 ppb.
COMPANY FLOWS VS NEIC FLOWS
A comparison between the effluent flows estimated by Louisiana
Pacific and those measured by NEIC yields marginal agreement [Table 11
The overall LP/NEIC average is 0.87. The EPA has established a
guideline* of +10% for flow monitoring accuracy. As noted in Table 11
* NPDES Compliance Sampling Manual, June 1977 (p. 57).
-------
Table 9
PRIORITY POLLUTANTS3
LOUISIANA PACIFIC CORPORATION
Samoa, Tali forma
December 6-", 1077
Compound
Number Compound
Station 34001
L.P. process waste-
water at effluent
pumps
12/7«12/8
12/9 Avg
Station 3450
L.P. hydraulic barker
wastewater at dischg.
to ocean outfall
pipeline
12/7* 12/8 12/9 Avg.
Station 3550
Raw water supply at
intake to C S. Mill
before any treatment
processes (common
water supply for
L.P. and C.S)
1276 \~2ll 1271 Avg.
@1530 @2000 @1030
Det.
Limit
1 Acenaphthene
2 Acrolein^
3 Acrylomtrileb
4 BenzeneJ
5 Benzidene
6 Carbon tetrachloride J
7 ChlorobenzeneJ
8 1,2,4-Trichlorobenzene
9 Hexachlorobenzene
10 1 ,2-Di chloroethane 3
11 1 ,1,1-Trichloroethane 3
12 Hexachloroethane
13 1 ,1-Dichl oroethane J
14 1 ,1,2-Tnchloroethanej
15 1 ,1,2,2-Tetrachloroethanej
16 ChloroethaneJ
17 Bi s(chl oromethyl) etherg
18 Bis(2-chloroethyl) ether
19 2-Chloroethylvinyl etherb
20 2-Chloronaphthal ene
21 2,4,6-Trichlorophenol
22 para-Chloro-meta-cresol
23 Chlorofomi.7
24 2-Chlorophenol
25 1,2-Dichlorobenzene
26 1 ,3-Dichlorobenzene
27 1 ,4-Dichlorobenzene
28 3,3'-Dichlorobenzidineb
29 1 ,1-DichloroethyleneJ
30 1 ,2-trans-DichloroethyleneJ
31 2,4-Dichlorophenol
32 1 ,2-DichloropropaneJ
33 1 ,2-DichloropropyleneJ
34 2,4-Dimethylphenolb
35 2,4-Dim trotoluene^
<0 5
<2
<0.5 <1
<1 <0.8
12 10
38
20
29 32 25 29
2,600 2,800 2,900 2,800
14 11 <10 <12
0.2
0 5
1.
0.5
0 5
0.4
0 3
0.5
0 5
0.2
0.5
1
1
0.2
0 1
3
3
0 b
13
0.2
0 4
0.4
0.5
0.5
2
0.5
1.5
-------
Table 9 (Continued)
PRIOMTY POLLUTANTS
LOUISIANA PACIFIC CORPORATION
Samoa, Call forma
December 6-9, 1977
Raw water supply at
intake to C.S. Mill
L P. hydraulic barker before any treatment
L P. process waste- wastewater at dischg. processes (common
Compound Compound water at effluent to ocean outfall water supply for Det.
Dumber pumps pipeline L.P and C S.) Limit
12/7 12/8 12/9 Avg. 1277 12/8 12/9 Avg. T2?6 1~277 T2/8 'Avg.
01530 @2000 @1030
36 2,6-Di mtrotoluene 0.4
37 1,2-Diphenylhydrazinei>
38 EthylbenzeneJ 4.
39 Fluoranthene 0.53 1.3 0.33 0.72 0.1
40 4-Chlorophenyl phenyl etherb
41 4-Bromophenyl phenyl ether 0.4
42 Bis(2-chloroisopropyl) ether 0.1
43 Bi s( 2-chloroethoxy) methane 0 2
44 Methylene chloride'^ 0.5
45 Methyl chloride-^
46 Methyl bromide-?
47 Bronioform J . 2
48 Dichlorobromomethane<7 10 <0.5 <0.5 <4 0.5
49 Tri chlorof 1 uoromethane"7 2
50 Dichlorofluoromethane^j J
51 Chiorodibromomethane <7 1.5
52 Hexachlorobutadiene 0.3
53 Hexachlorocyclopentadiene 1.5
54 Isophorone 0.1
55 Naphthalene 26 37 11 25 0.1
56 nitrobenzene 0.2
57 2-Nitrophenol 4
58 4-Nitrophenol 100
59 2,4-Dinitrophenol 2
60 4,6-Dim tro-o-cresol 4
61 N-Nitrosodimethylamine 0.1
62 N-Nitrosodiphenylamine 0 2
63 N-Ni trosodi-n-propylaimne 2.
64 Pentachlorophenol 6
65 Phenol 630 530 350 510 160 730 260 380 11
66 Bis(2-ethylhexyl) phthalate <0.5 <0 5 1.7 <0.9 0 1
67 Butyl benzyl phthalate 0.1
68 Oi -n-butyl phthalate 1.4 0.5 <10c<4 0.31 0.61 0.47 0 46 <0.1 1.0 <0.1 <0.4 0 1
69 Di-n-octyl phthalate 0.1
70 Diethyl phthalate 1.2 <0 5 <0 5 <0.7 0.70 0.55 1.1 0.45 '-0 3-° z-° 2-° 0.1
-------
Table 9 (Continued)
PRIORITY POLLUTANTS
LOUISIANA PACiriC CORPORATION
Samoa, California
December 6-9, 1977
Compound Compound
Number
Station 3400 *-
L P process waste-
water at effluent
pumps
12/7 12/8 12/9 Avg.
Station 3450
L.P. hydraulic barker
wastewater at dischg.
to ocean outfall
3i pel i ne
"12/8 12/9 Avg.
Station 3550
Raw water supply at
intake to C.S Mill
before any treatment
processes (common
water supply for
L P. and C S )
T276 12/7 1175"
T27T
P1530 02000 PI 030
Det
Limit
Avg.
71 Dimethyl phthalate <0.25 <0.1 <0 1 <0.15 0 1
72 Benzo(a) anthracene 0.2
73 Benzo(a)pyrene^
74 3,4-Benzofluoranthene^
75 Benzo(u)fluoranthane ^
76 Chrysene^
77 Acenaphthylene 16521.528 0.1
78 Anthracene® 6 4 9.2 2 5 6 0 0 1
79 Benzo(g,h,i)perylene^
80 Fluorene 0 25 0.42 <0.1 <0.26 0.1
81 Phenanthrenee
82 Oibenzo(a.h) anthracene^
83 Indeno (1,2,3-cd)pyrenek
84 Pyrene 0.65 2.2 0.33 1.1 0 1
85 Tetrachloroethyl ene
-------
. » 9 - J nue-^
PRIORITV POLLUTANTS
LOUISIANA PACIFIC CORPORATION
Samoa, California
December 6-9, 1977
Compound
Number
Compound
Station 3400 1
L.P. process waste-
water at effluent
pumps
12/7 12/8
12/9Avg.
Station 3450
L.P. hydraulic barker
wastewater at dischg.
to ocean outfal1
pi pel ine
T2J1 12/8 12/9 Avg.
Station 3550
Raw water supply at
intake to C.S. Mill
before any treatment
processes (common
water supply for
L.P. and C.S )
1 "2/6 1 Y}1 T27B Avg.
01530 @2000 01030
Det.
Limit
106
107
108
109
110
111
112
113
114
PCB-1242
PCB-1254
PCB-1221
PCB-1232
PCB-1248
PCB-1260
PCB-1016
Toxaphene
Antimony
115
Arsenic
<10
15
<10
<12
116
Asbestos b
117
Beryl 1lum
118
Cadmium
20
20
20
20
119
Chromium
90
90
90
90
10
10
10
10
120
Copper
4
4
4
4
39
24
31
31
121
Cyanide
<10
130
140
<90
122
Lead
46
51
28
42
123 Mercury
124 Nickel
125 Selenium
126 Silver
127 Thallium
128 Zinc
129 2,3 ,7,8-Tetrachlorodibenzo-i>
p-dioxin
80 180
100 120
130
60 60 80
1
1
1
1
1
2
1
5
30
10
0.2
20
10
4
10
5
1
0 1
10
8
5
10
aAll concentrations in micrograms per liter (vg/l).Except thallium and nickel in milligrams
per liter.
b Compound not measured due to analytical difficulties in the methodologij or standard availability,
c Data for this parameter for this sample was inadvertantly discarded prior to quantitation,
d Presence is unexplained but identification is within criteria established by the method,
e Phenanthrene and anthracene cannot be resolved, data reported represents either or both of these
compounds.
f Detection limits for extractable organice are based on a 21 extract concentrated to 1.0 ml.
Volatile organics are for 5 ml of sample,
g bis (chloromethyl) ether is not stable m uater and cannot be recovered from the standard,
h Crysene and benzo(a)anthracene cannot be resolved, data reported represents either or both of
these compounds.
i Extractable organics uere measured at 5 ml extract volume. The detection limits for these
samples for the extractable organics are therefore 5 times those reported m the last column,
j Denotes a non-extractable parameter for organics, e.g. volatile organics
k Station 3400 and 3450 data based on 24-hour composites collected hourly from 0700-0700. Date
listed is day co'npositing period ended. Station 3550 data based on single grab sample per day
oince uater supply considered stable source.
-------
Table 10
GENERAL ORGAN ICS DATA
LOUISIANA PACiriC CORPORATION
Samoa, Call forma
Dec. 6-7, 1977
Compound
3100
L.P process
was tcwa ter
at effluent
pump
Sin tion
"3150
L.P. hydraulic
wastewater at
discharge to
outfall pipeline
3550
Raw water supply
at intake to Crown
Simpson Hi 11 before
any treatment processes
(Common water supply
for C.S. and L.P.)
ug/1
Acenaphthalene 3
Acetovani 11 ina 110
Ally isovaleratea 410
Alpha-pincne 200 12
A1 plia-terpi neol 1,100
Beta-Uiujenea 60
Biphenyl 3
Borneol 700
Camphor 2
Dibenzofuran 1
Dibutylphthalate 1
1.3-dichlorocyclohexane 180
Diethylphthalate 2 1
2.4-diliydroacetophenonea 50
Dimethyl disulfide13 2,400
3,3-dlmethyl-3-phenyl propionic acida 2,500
1 ,4-dimethyl-4-vinylcyclohexenea 290
Fenchyl alcohol0 2
Guaicaol 2,200 6
Limonene 56
Naphthalene 3Jt
Para-cresol MS
Phenol 110
2,3 ,4-tri thiapentane12 30
Vanillin" 12 5
a Idcntijication by comparison to reference apccta only; no pure standard ims available for
direct compartson. Quantities are estimates onl\j
b /lass spcctrometric identification only, belou GC-FID detection limits for quantitation.
CO
-nJ
-------
38
Table 11
COMPARISON OF FLOWS DURING
DECEMBER 5-12, 1977
NEIC vs. LOUISIANA PACIFIC
Flow
Month
Day0
NEIC1
m^/d-
x
mgd
Louisiana Pacific
m^/d,
x 10*
mgd
LA:NEIC
December
Average
5-6
83.6
22.1
71.2
18.8
0.85
6-7
89.3
23.6
70.8
18.7
0.79
7-8
91.6
24.2
71.2
18.8
0.78
8-9
73.4
19.4
72.7
19.2
0.99
9-10
90.8
24.0
69.6
18.4
0.77
10-11
74.9
19.8
71.5
18.9
0.95
11-12
72.3
19.1
71.5
18.9
0.99
82.3
21.7
71.2
18.8
0.87
a Flows were determined 0700-0700.
b NEIC effluent flows determined every two hours from 12/5-12/10.
Beginning 0700 on 12/10, flows determined every hour,
c LP effluent flow estimated by Company as raw water flow minus
City of Samoa, California and sawmill flows.
-------
39
there were four days when this criterion was exceeded and on three
days there was >20% difference between the values. On the other
hand, there were three days when there was close agreement (December
8-9, 10-11, and 11-12) between the two values (<5% difference). It
should also be noted that two of the three days with close agreement
were the last two days of the survey when the NEIC flow monitoring
frequency was increased from once every two hours to once an hour.
It is not known whether this is coincidental or significant.
Although the daily flow values are marginally acceptable, the
Company's practice of using raw water flows and then forming com-
posite samples with equal-volume aliquots is unacceptable since it
does not reflect the diurnal fluctuations in flow. The EPA recom-
*
mends that "If the flow rate does not vary by more than +15% of the
average flow rate, a time-intervaled composite...will provide a rep-
resentative measurement of the wastewater characteristics and load
discharged over the sampling period." As noted in Figure 4, diurnal
flow rate changes were considerably in excess of this criterion.
SELF-MONITORING EVALUATION
The NEIC evaluation of the permittee's self-monitoring practices
indicated the following procedures deviated from the prescribed/
recommended techniques:
Sampling Techniques
1. Composite samples were collected by automatically collect-
ing equal-volume aliquots at equal time intervals. Since
the flow rate is not constant and varies according to the
* NPDES Compliance Sampling Manual, June 1977 (p. 28)
-------
50
•^-Average Flow
10
O I
o
vo
o
o
o
C\J
o
o
o
o
o
o
C\J
-L
o
o
o
o
o
o
C\J
JL
0600 Vi/b/lV 12/6/77 ' 12/7/77 ' 12/8/77
Date
o
o
CM
JL
O
O
O
O
O
O
C\J
X
o
o
o
0
1
o
o
C\J
Jl
o
o
o
o
12/10/77 "12/11/77 12/12/77
Figure 4. Diurnal Flow Variation
Louisiana Pacific Corp., Samoa, California
Dec 5-12, 1977
-------
41
downstream control valve setting, these composites were not
flow-proportional as required by the NPDES permit. Further-
more, these samples were not refrigerated during collection
as prescribed.
2. The pH was determined on each of the 24-hour composite sam-
ples collected during the month, then averaged, and this
one value reported to the California Regional Water Quality
Control Board, Santa Rosa, California. The NPDES permit
requires continuous measurement of pH.
3. Settleable solids were collected from the composite sam-
ples, not by grab samples as required by the NPDES permit.
4. 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.
5. Composite samples for phenolic compounds were collected in
a plastic container, not glass as prescribed, and were not
preserved or refrigerated during collection.
Flow Monitoring
1. As noted previously, the Company estimates process waste-
water effluent flow with metered raw water flows. This
practice was determined to be marginally acceptable for
daily flows, but precludes collecting flow-proportional
effluent composite samples.
-------
42
2. The location of the flow monitoring site for the hydraulic
barker effluent (i.e., downstream from the clarifier sump
pump) precludes instantaneous flow measurement and conse-
quently flow proportioning of composite samples. The nu-
merous severe fluctuations in flow also make it difficult
to obtain an accurate measurement of total daily flow.
3. The Company did not have an established calibration fre-
quency for the flow measurement systems. Calibration
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 re-
quest had been made, as prescribed, and no data had been
collected to establish comparability with the EPA-approved
method.
2. TSS procedures were performed as prescribed, except that
filters were weighed directly out of the oven without desi-
ccation. This technique will generally cause low results.
3. 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 loading limitations for both the process wastewaters
-------
(listed as "Pulp" in permit) and hydraulic barker, the Company
reports to the State of California a flow-weighted average concen-
tration for a combination of the two discharges. No load calcula-
tions are transmitted, thereby precluding a determination of indivi-
dual loadings.
-------
44
REFERENCES
1. 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, Sydney, Australia, October 17-22, 1976.
2. Swan, E.P. (1973), Resin Acids and Fatty Acids of Canadian Pulp-
woods - A Review of the Literature. Information Report VP-X-115
Canadian Forestry Service, Department of the Environment, Ottawa.
Ont.
3. Rogers, I.H. (1973), Isolation and Chemical Identification of
Toxic Components of Kraft Mill Wastes Pulp Paper Maq Can 74
T303-T308. a '
4. Water Quality Criteria (1972) EPA-R3-73-033.
-------
APPENDIX A
LOUISIANA PACIFIC CORPORATION
NPDES PERMIT NO. CA0005894
-------
FX. iUTT U
.rvi'K mAtl*; re, ,jurci:s cu itrol dov.d
3RD! •> N'0. 77-0
NPDJS .\0. CA000':>S!94
WASTL D.SCHARCE REQUJ *EMEMTS
TOR
lou i si a': '\-P * ci nc co ^ ' or at i o:s
Hu-rbolut Cou-^\
TK_ Ca.lform a State Natei Resources Control Board (State Hoard)
finds tlat:
1. Louioi d.-. a-Pacif ic Corporation rud its predec. essor ,
Georcia-Pacif i^_ Corporation, hrvc sub-nitLed npolicotiors
for federal permits, a tecnriral report pursuant to the
Water Quality Control Plan for Ocean Usters of California
(Ocean Plan), ana supplemental information in letters
and petitions which describe the corporation's discharges
to th; Pacific Ocean and Hupboldi. Bay.
2. Lou:sinne-Pacific Corporation cischargss effluents
contairing pollutants from krai't pulping processo.., pul-
blesc-iinq processes, and pulp crying processes located
in its bleacpcd kraft narket pulp mill; frcn j;s . ater
trejt"cnt p]a"t processes, and from a hjOrauixC Oi';kur
ac its sawmill irto the Pacific Ocean, a water of tic
United States. Minor airounis o: stea.T, vaulc Iiruors from
sof t\ ood veneer r.anufPotdnng processor which use
direct steaming for the conditioning of logs, ooi.c , r;i s~ t
wastewslcrs, '/astebeanncj stcr'vwater runoff, and
domestic sevage are contained :n tne discrnrge.
These effluent' , \.hich flov
at up to 30 .iCD, r>re discharger through diffusers located
near Latitude ^0°47'S.( Longitude 124®1i'W., fro.i a
3000-foot outfall at a depth ot 35 to 40 feet. This
diso.arge is nerebv designated 001.
The discharger has eliminated oisch^rgc of incjstrial _
process wastes to Humboldt Bay, ho.ievor, the prcrimiiy
of hill opcrnljom to the ba> fay result, in disc!"! led OO1^ <.nd OG_i, aro a
poweroljr:t hcreDV designated 00 1, to Hunboldt Or.y ot
points located near latitude 40°47'..'. Lon->iludc
12j°13'W.
Mill nctivitus rr.v result ir dtoch.irqc of uaste or
leac'Tite from chipo oi fuel to 'jroundvrt or of the Su oa
Per: .ir.u 1 n.
-------
3. The Rccjionnl Board r.aoptcd the Water Quality Control
Plan for the north Constnl in.tn (iln.in Plan) or 'larch ?0,
19 7'j, and adopted revision^ thereto oil Mnrc.h 25, 10 76.
The Da-.in Plan incorporates the Ocean Pl.ri and the '..atcr
Quality Control Policy Cor the Enclosed Hays and -otunnes
of California. It contains cfluent Limitations -inu
water quality objectives for Pacific Ocean di^chprges
and pronibits nost discharge^ to Humboldt Bay.
4. The berefitical uses of Pacific Ocean and Hupboldt Bay
include:
a.
industrial water supply
b.
navigation
c.
water contact recreation
d.
noncontact water recreation
e.
ocean commercial and sport fishing
f.
marine habitat
g-
fish migration
h.
fish spawning
1.
shellfish harvesting
5. The beneficial uses of shallow fresh grounduater on the
Samoa Peninsula include donestic ¦ ater sapply. T1-,. uncer-
tainty of supply and the susceptibility of this water to
degradation from over purapirg, percolation of sewsge,
by salinity fron dredged material disposal and ot^^r
activities has e^co^rrgcd dev c '.op-iont by the Ilumooldc
Bay Muincippl Hater District (.IDrl.'D) of a water s\sten
utilizing Mad pover supply. Groundwater in areas relyirg
upon its ise should be protected v.ith minimum risk of
degradation from waste discharges.
6. The discharger has requested exemptions fron:
a. Ocean Plan Table 1\ effluent limitations on:
floating particulates
Suspended solids
Scttlenble solids
Turbidity, and
p!I,
b. Ocean Plan Table B effluert limtations on chromium
c. the time schedule provision of State Board Pesolution
Ko 7-'-3; and
d. EP'\ Effluent Limitations Guidelines based limita-
tions on.
BOD and pit.
-------
7 Regarding the exempt ions fror.i Ocean l ian effluent
limitations requesti < by I. he oischorgcr:
a. floating Pnrticulat c s. The absence of any limi-
tations on floating purticjlalco will not interfere
with conpl] anco with the i ntcr rrualitv oojocti\cs
set forth in Chapter II of the Ocean PI.m and will
not interfere with compl i.- nee with the effluent
quality requncir.ent s set torlh in Chapter XV,
Table B of the Ocean Plan.
b. Suspended Solid.. Dischoi^e 01 suspended solid*,
at the rates specified hciJin will not interfere
with compliance with the water quality objective;;
set forth in Chanter II or the Ocean Pirn ->nd '/ill
not interfere nth complin ice with the effluent
quality requirements set forth in Cnaptor IV,
'laole 3 of the Ocean Plan. Since the suspended
solids fron the water trca'ment plant consist of
silt from the Mad River that would normally be
discharged to the ocean, K is appropriate that
the limitations on suspended solids oe on a r.et
basis. Thus, the moniton.ig requu ements will be
established so as to aivc credit /or suspended
solids resulting fron water treatment plant operators.
c. Sett 1eable Solaris. The absence of cny Imitations
on s i'ho uischaiyer has pi csenr<-a
svb ">t .in 11 ol evidence ta.it r oinp 11 a a<. e with ^hroruu'n
limitations based on Ch.iploi IV, Table 13 ot I ne
Ocean Plan J s not posr.ibLr thrciqh application ol
source controls and tlu bv- t practicable control
techi.o]oqy currertjy avail '*le.
-------
14. The disd.-.Vgc-r is currently d] -.chare *<] imdci w,vtf
discharge roqmrcnoi ts issued by the kccjioi.,i) Uonrcl
oil September *, 196< , and i.s monitoring .nut reporting
uncicr Monitoring oik1 Reporting I'royr.im No. 7".-'I?
adopted by the Regional board on December t] , 19 74.
XT IS ilEREBY ORDERED THAT Louisiana-Paciflc Corporation, in
order to meet the provisions contained in Division "* o." tine
California Water Code and regulations and guidelines adopted
thereunder, shall comply wito the following.
A. ProhibiUors
1. The discharge of waste to Humboldt Day, e\ceut ds
provided under B. 4. of this order, i;» prolibited.
2. The discharge of waste to shallow groundwaters of the
Samoa Temr.sula, except in whicn groundi fiLer is
unsuitrble for domestic use, is prohibited.
3. The discharge of waste to the Pacific Occai, except
as provided under D. 2. of this order, is» prohibited.
4. Discharge of radioactive materials in excess of the
limits prescribed in Section 30269 of the California
Administrative Code is prohibited.
5. Discharge of any wastewater pollutants resulting fro-i plyu
inanuf acturinq uhi'cn utilizes veneer as a raw notorial is
prohibited.
B Effluent Limitations
1. The discharge of an effluent to the Pacific Ocean
which exceeds the follouing is prohibited:
, 30-day-7
30-day- 30-day- 90th Daily
Constituents Unit s Average Med] not exceeded in 90 percent of the s.^raples in
— any 30 co.nocu Li ve day period. Conp] i.T,ce will r.ot be astennned
if fciicr thin four sr.nples are rnaly/ed.
d/ linked on 610 tons per day average annual production.
-------
Cop^M tiiont
BOD
(Hyd. narker
bod5
(Veneer)
Suspended
Solids c/
(pulp)
Suspended
Solids cj
(Hyd. Barker)
Uni t >->
lbc/cu.ft^
lbs/day
lbs/cu .ft
lbs/day
/ 90-day—
30-c1 30-day— 90 th
Ave ¦ nqc fee!i nn
0.03
1.500
0.015
283
lbs/day-/ 20,000
lbs/ft. 0.14-1
lbs/day 7,200
%tilc
Dai ly
Maxj mun'
0.09
4, 500
0.0-15
049
37,080
0.431
21,550
Grease & Oil
pii
mg/l
10
within the limits 5.0 and 9.0
15
2. The discharge of an effluent m excess of the
following linits is prohibited, ji/\J
50%
io?;
Cons 11tuent s
Unit s
of time
of time
Arsenic
rag/1
0.01
0.02
Cadrniu.T
mg/l
0.02
0.03
Copper
mg/l
0.2
0.3
Lead
mg/l
0.1
0.2
Mercury
mg/l
0.001
0.002
Nickel
mg/l
0.1
0 . 2
o/ In addition to Ll'e suspended ..olids in the raw water supply
1/ Pounds of HOD- or suspended solids per cubic foot of wood
procrssod through the hydraulic barker.
rj Pounds of DOD^ per cubic foot of production jn terms of veneer,
if that i'; the final product of this r.icitity, or per cubic foot
of plyvood if the veneer is further processed into plywood at
this facility
h/ The n'.'MB'i'f,; alio; rble daily mnL.s emit.:,ion rnte for each coistituent
listed in Item 2 above shall bo calcul.it e.l froi.i the total waste
flow orcurrinq encn specific day and the concentration specified
(coUtiucd on no\t page).
-6-
-------
0. On Juno 21, 1976, th" discharger submitted lo the
Regional P.oard a req'it st for variance from KPA
effluent limits baseu on fundarcntrlly different
factors. The request was supplemented by testimony
and evidence presented by the discharger durir-j the
course of public hearings before both the Regional
Board and the State Board.
Based upon said testimony and evidence, the State Board
finds that effluent exceeding tnc EPA guideline Imita-
tions for BOD and pH has substa itlally no adverse
effect on the marine environraen when properly diffused;
that there wall be few if any wter quality benefits
associated with treatment for >i >D or p'l, that there
will bo substantial environment il and energy costs
associated with treatment for ROD and'or pH; and that,
therefore, under the precedent established by the
U. S. Court of Appeals (Fourth Circuit) m its
decision in the case of Appalachian Poi>ec Co-.panv vs.
Train, a variance front the EPA guideline limitations
is warranted. The State Board therefore grants herein
a variance from effluent limitations from CPA guide-
line limitations for pH and for BOD generated in the
pulp mill, subject to final app.oval of the variarce
by the Administrator of EPA.
9. EPA has not promulgated an effluent guideline for hydraulic
barVi^g oper?tions associated with saw mills. Thp State
Board finds that Epplication of a separate li.-nit based cn
the l-PA Guidelines for the Baring Suocategory of the Timber
Products Processing Point Source Category (40 CfR h29.12)
for DOD and suspended solids contributed by the sawmill
hydraulic barker is appropriate.
10. Except as provided ip Findirg 6, above, effluent limita-
tions pursuant to Section 301 of the federal Water
Pollution Control Act and amendments thereto are
applicrble to the discharge. Tne limits are contaired
in Code of federal Regulations.
11. Tnc discharger has requested that limits for BOD as
established in Code of Federal Regulations be deleted
from requirement> for disclurgc to open oc?nn waters by
diffusers. The State Board finds that adoption of BOD
limit r)tions is appropriate to its regulation of
discharge.; to the Pacific Ocear.
12. The State Doard has notified the discharger and interested
agencies and oersons of its mli.nt to prescribe waste
discharge requirements for the discharge and has provided
then1 with an opportunity to sub."it their written vie' s
and reco.nmondat ions.
13. The State Doard m a public hearing heard and considered
all comnontc pertaining to the discharge.
-------
Co i'.t] Lnonrs
Sjl 1 ver
Zinc
Cyanide
Phenolic Conpounds
Total ChJorine Residual
Amnonia (c.\ >rcssed as nitrogen)
Total ident ifiable Chlorinated
ilydrccarb^ns j_/
Toxicity Co 'contration
t*? o' lpio o r i i mo
mg/1 0.02 0.04
mg/J 0.3 0.5
mg/1 0.1 0.2
mg/1 0.5 ].0
mg/1 1.0 ?.0
mg/1 40.0 60 0
mg/1 0.002 0.004
tu 1.5 - 2.0
3. The discharge of an effluent in excess of the following
limits is prohibited: h/j_/
50% 10%
Constituent Units of time of t^c
Total Chromium mg/1 0.005
0.01
4. The discharge of noncontact cooling water to !-'umboldt
Bay m excess of the following limits is prohibited:
30-day Daily
Average Ha/imuin
2 2.0°C 24.0°C
5. Upon approval by the Administrrtor of of the finding
of "fundpmontal difference" cited in rinding 8, above
the fell o'.'i rg limitations shall apply ir. iici. of the
Imitations in U. 1., above, for the following parameters
The lin.itatiors cont Pined in D. 1. shall cortinue to apply
for alj. other parameters. Should the Administrator approve
a variance but fird that limitations other than the following
are appropriate, the Regional Board sh?ll revise these
waste discharge requirements comstent with the limitations
approved by the Administrator.
h/ in waste discharge requirements as that not to be exceeded nore
than 10 percent of the time. The mass emission rate of the
discharge during any 24-hour period shall not exceed the maximum
allowable daily mass emission rate.
i_/ The maxirrun allowable monthly miss emission rate for ctIi
cor.stitue.it listed in Iten 2 above shall be calculated fro:i the
total waste floi occurring in each specific month and the con-
centration specified in waste discharge rcquircr.ents as that not
to bo exceeded irorc than 50 percent of the tine Tne na-ss
omission rate of the discharge during any monthly period shall
not exceed the maximi.n allowable monthly mass emission rate.
2/ Total Identifiable Clilori aated I'ydrocaroons shall be measured
by summing the individual concentration - of DDI', DDD, DDH, ahlnn,
BHC, chlordano, endnn, heptachloi, lindane, dieldnr, polvchlori.iatcd
biphenylf., and other identifiable chlorinated hydrocarbons.
-7-
-------
-|St] I'K'Ilt
Uni ts.
30-dny
Average
D.nly
lUynnun-
)D5 (pulp)
lbs/day—^
''.S ,000
97,GOO
within the limits 3.0 and 10.0
Receiving Water Limitations
1. The discharge shall not cau^o floating particulates,
foam, or grease and oil to be visible.
2. The discharge shall not cause aesthelicn]ly undesirable
discoloration of the ocean surface.
3. The transmittance of natural lic,ht shall not be
significantly reduced at any point outside tno initial
dilution zone.
4. The discharge shall not cause the dissolved ovygen concen
tration outside the initial dilution zone at anj tine
to be depressed more than 10 percent from that whic^
occurs naturally.
5. The discharge shall not cause the pll outside the initial
dilution zone to bo changed at any tme more thn 0.2
units fron that uhxch occurs naturally.
6. The discharger shall not cause a violation of ?rv
other applicable existing water qualify stardcra'Tor
the receiving uatcr adopted pursuant to the Tcderal
Water Pollution Control Act and implementing regulations.
If wore or less stringent applicable uarer qualitv
standards are promulgated or approved pursuart to*
Section 303 of the federal Water Pollution Control Act
and implementing regulations, the Reaional Board shall
revise or modify this order in accordance with such
more or less stringent standards.
7. In areas where shellfish are harvested, the discharge
shall not cause the median total coliforn organise
concentration to exceed 70 per 100 ml nor shall t"e total
col]form organism concentration exceed 230 per 10 3 ml
10 percent of the time.
8. The conccntrnuon of organic materials in marine
5edi-.,e"ts snail not be increased above that which '/ould
degrade marine life.
9.
The discharge shall not cause loxic conditions to exist
in the receiving water.
-------
10. The dj s-ch arge shall not c:,u-,o the foJ lowing limits
to be exceeded after initial dilution:
Cor .ti tucits
Grease and Oil
rioating Particulates
Toxicity
Uni ts
2
mg/m
2
mg dry wt/in
Toxicity Units
50 Per- 90 Per-
centile CL'r.tiln Ha\'inum
10
1.0
20
1.5
0.05
D. Provisions
Neitner the treatment nor the discharge of pollutants
shall create a pollution or a nuisance as defined by
the California Water Code.
The discharge s'^all achieve rapid initial dilution
and effective dispersion to minimize concentrations
of pollutants not removed by treatment. The diffusion
system shall provide an initial dilution of effluent
with seawater exceeding 100:1 c>t least 50 percent of
the tirae and exc.eeding 80.1 at least 90 percent of the
time.
The discharge of noncontact cooling waters shall not
elevate the temperature of liu^ooldt Bay to the dctrment
of beneficial uiei of riumooldt Bay.
The discharger sl'all comply with the following ti-ne
schedules to assure compliance with Effluent Limitatiors
B. l.( B. 2., B. 3., and D. 5. All other provisions
of this permit shall be applicable upon adoption.
Task
Limitations 13. 1. and
D- 5.
Commence preparation of
plan'; find specif j call ons
for control fjcilitjos
Cor.pli ancc
I^if1 L at ion*; B . ? .
Progress report
Commence construction of
control faciJiLj.cs
Comolijnco
Compliance Date
Report of
Corrol] ance Due
April 1, 1977
July 1, 1977
May 1, 19 7 7
January 1, 1978
July 1, 1970
April 15, 1977
July 15, 1977
May 15, 19 77
January 15, 19 78
July 15, 197G
-------
T;vA i
l,j mil iiHOiis 0 3 .
Prog) c.ss report
Progress report
Progress report
Progress report
Commence preparation of
plans and specifications
for control facilities
Progress report
Commence construction of
control facilities
Progress report
Compliance
C u.TO 1 1 an. |JT i
October J, 19 77
July 1, 19 IS
April 1, 19 79
January 1, 1980
July 1, 1930
April 1, 1901
January 1, 1982
October 1, 1982
July 1, 1983
li |
-------
The di-.ch.u'qcr shall >ubmit l"0 ihe Keijiunal Hoard
each month with the lonlhly effluon! mom loring
report a nummary of I no quantity of chromium contained
in any chemicals used which reach the waste stream or
which might roach the waste stream in the event of aa
upset or breakdown.
0. The requirements prescribed herein do not authori'/c the
con'iu.s-.ion of any act causing injury to the property of
another, nor protect tne discharger from his liaoilities
under federal, state, or local laws other than those
adopted pursuant to the federal Water Pollution Control
Act, nor guarartee the discharqer a capacity right in
the receiving waters.
9. The discharge of any radiological, chemical, or
biological warfare agent is prouibited.
1(X The discharger shall permit the Regional Board:
a. entry upon premises (durinq nornal business hours)
in A'hich an effluent source is located or in which
any required records arc kept,
b. access to copy any records required to be kept
under terirs and conditions of this oraer;
c. inspection of monitoring equipment or records; and
d. sampling of any discharge
11. All discharges authorized by this order shall be
consistent with the terms and conditions of this order.
The discharge of any pollutant more frequently than or
at a level m excess of that identified and authorized
by tins order shall constitute a violation of the terms
and conditions of this order.
12. The discharger shall comply with a Monitoring and
Reporting Program issued by the Regional Doard Executive
Officer aid the General Provisions for Monitoring and
Reportirg and a.iy modification,!, to these documents as
specified by the Regional Board executive Officer.
JSomtonnq resorts shall be submitted to the Regional
Boaid and U. S. Tnvi romiont al Protection T'qencv for
each month, by the 15th day of the following month,
beginning not later than the drte specified in the
Hon: torng and Reporting Proyr,"-i issued by the Regional
Doaici Executive Officer Mo'ntoriug ard Rcccrtmg
I'rogi an No. 7<1-?12 shall remain in effect until super-
seded or revoked.
13. The discharger shall maintain m good working order and
operate as of Cicj cut ]y as po-.siblo tiny facility or
control sy.len installed by the discharger to achieve
co-ip] lancc with the waste discharge requirements.
-11-
-------
14 Collected crooning , sludq, , .ind other solids romm od
i roiii Jjijuid wn-ilc si >11 bo ;li ,po cd 01 nl ,i log.il p more stringent ci?n
any Imitation upon such poJlutant in this order, the
Regional Board shall conduct a public hearing and
consider revising or modifying this order in accordance
with such toxic effluent standard or prohibition and so
notify the discharger.
In the event the discharger is urable to complv with
any of the conditions of this order due to:
a. breakdown of waste treatment equipment,
b. accidents caused by human error or negligence, or
c. other caures sucn as acts of nature;
the discharger shall notify the Region.il Hoard L'nocuLivo
Officer by telephone ns soon a:* he or his ago.its naw
kroiledge of the incident and conrir.n this notification
in ur;tj.nq within two . co'ss of the telephone no 11 f i c ."it ion .
Ihc ''til ten notification shall include pertinent infor-
mation oxplainiry reasors for the noncompliance and shall
indicate what Mops i ore- t.iken to correct the problcn
and the date;, thereof, and w'l.it .^tcp^ are being taken
to picAonl the orobluii from recurring.
a.
b.
c.
-12-
-------
as
in .iccordnnco wiih T.'in vi r-,] r >--is-to Di'.ch.irgc
Codo, not later ha inn , ' CilJlfornin ^Inu ,u s t r .u i v.-
;;q;T^;r -
19 * Sn?! eVCn.t °f any chan0° m control or owner-,hio of
Taitor
r zi'oL:TJ^r" r oirarv,c thc
ror.ard.d to ^ BoX " "hlCh 'hal1 b*
. 20'
ssssrjsjssts: ^rh^rMtr
e^;°nS "1^"»cha«gerSi«rtLtS\%?ian?r?or°n
of tho1?WPCAS°suchnternth0TrOVtS10nS °f SCCtl0n '2Gllc>
subGrtt1drCqUlr0d bY aPP^^lo regulations1 fh
submitted to the Regional Board by July 1, 1980.
iSr!.125W
•*»«™ pro"d<,d «•*
22' d^ih,™'° '¦" requirements suoersodc tlie ..as-,,
S.plSr 5?q;'50rsm°ntS 1 = SU°d by the "°"d on
Coirtif lc.ition
thot the foregoi\g\f ad^nXe^r%0^flCCr' ?° Certlfy
adopted bv the California State Wate^R COrrOCt 0r nn °rder
on ,.<,R 1 vV.77 lrornla State hater Resources Control Qoard
4 &.
J 1 liT D<_ ;ic:v ~j~
executive Officer 1
-13-
-------
t.i]iiorr.u -tccior.. 1 !' i'.ir Qwlity Cciti cl Coord
ilcrtti Cc,.ict l'e^ion
C'M.IR i.O. 77-110
Fon
jorxm \nA-PAcinc conFoiv/iro i pulp
£'«oiDin ko jSc'-'/v-cc or a titt, sch^dult.
The ..-.lifcrrm I!eKiPii. 1 './jter Qurlity Contiol Bonid, Kca in Coast :>egicr., f.rds
1. Th- State Mrirr 'I'scr rc:j Cr>n::ol Boaru o- i'.^roi 17, 1977 ntooted
Order I-o. 77-' ("Jl'D.-'.S ;';tli t j f.H'i;'! Percr.t
ho. ever, cc-^iliarcc co'iaot be ocVc.cc ."_c.r^i:g tc tho ctiopf „ ti-c
scl:e«ulc.
I'i m!o,itiic rci-,u\if,"nt3 on >-'orch 17. \o •-;« is '
fortlic&u"fc.
3. The Scard hj3 notified tnc_ disencr-cr ci.d lntci^cicd c,~ -.cies a-d ptrsr.i3
of ita ntrat to adopt a tiirc ached ,le for ccLlxoice : ;r tue iiD-hrr;;. r.
4. The Lonrd \ii ij p.i^'lc hearing hcira nr.d ccnal'lerec all i-.-.-r-uCnt s pci-Taj. -
lr~ to t-.e dicciiur^er's coility to acnieve ccr;ii;_"cc.
IT 13 l'~r '0/ ulOi.r'.'T that, ir pecordarce with V'otcr CoJc Ecctio- 'i;;00, the
loulriona-raeiixc Co-^rat' c-i Pulp Jill shall co~d3" \n.\* ".'OH ai! pi I—iVi c?
t^j.-'d it iir^nt J i-i'.atien U. 1 of State r.ianJ CrJor io. 77-6 _:coi\r-- co '.b:
xolln.ir,,; aliir '»t dril^nctcd tin? frcco f^lLci'ii^ t' ruling
Alth r.'0.:rd to ttic yL^xOniil Ao-unistrctor's citerrl-atic i o* \c.i -zrrt.
T
!'¦ r^r\'Ticc pio-aratior of pirns
an- "P'jeir Li uns fc cc-.ti'ol
CcwilJ ticc.
Crirplc,.-j yrevaral icr of plara
.'•.ci .recj.: .ra wj c-j loi control
l'rcilitiiic.
Corrlfi- cp.iitruclioii of co"trol
laci5 tl) >j"
ii. r.iil cr^.r!!,-" c?
Cenpl^ijice rc^:o.l
2 tenths
6 Toitr^
12 uoit'.:
2 ror ii-
i^
i_f p -i
c,j o ;-Mo \.\z
c.~T;-lc' oa cf each
¦».r.r .
Total ti-c clc; I -
22 Mi.t!:a
-------
Crikr No. 77-110
-2-
Thi'; Order ohnll take effect at tiio end of ten d^ys /ron the date 01 adoption
prowed the Rogior.il Adminstr-itor iws no objections. This oracr e. circs or.
(to to dctcrnircd).
This Board declares that it dees rot intend to ji dertai.e further .-nfcrcc-:-^t
action to bi tl'e c.ischrrger into ccnplir.ncc wi^h Affluent Linutvtion^ E.i ^.nd
B.b as contained m State Board Order Mo. 77-C {I'PDIS 10. CA OCO^fr'i) pro/ided"
1. The discharger conplies fully with all tirns of the tvno schedule
cOi^tair.ed n this orner,
2. The ditchcu^t-i corrplicc fully with all L,..i.,s of the perr.it except pc
affected by the provisior.s of this ordc: ;
3. Circimstancns do rot occur i 'nch i oulc1 warrant an nctior. ur.cc-r
Section ^Ok of Die Federal \.'alcr Pollution Co'itrol Act.
The rction tPkcn by tnis Board pertainirr, to t;io tine schedule doos not pr3-
clude the possibility of actiors to enforce the permit by third parlies pursuant
to Section 505 of the Federal Uater Pollution Control Act.
Cert \ •irif.o"
I, Dwi\id C. Joseph, Dyeculive Officer, do
hereby certify trie forego}n£ is a fall, true,
and correct copy of ar order adopted by the
California Regional ''ater O.uality Control
Board, North Coast Hegion, on June 23, 1977.
•. cir '-n nf
-iy ->•••¦ — ——— 1 ¦ - — ¦ ¦
David C. Joscp'i
Executive Officer
-------
wc o» c'urcri< \ p,souiccs accncy
IDVUND C BROWN jk Covers
CAI' OfJfllA PC-'ONAL WATER QUALITY CONTROL (L.tfD-
NORiH CG'iS. REG'CU
IOOO 'UtDINGIOl ' I CC JIC1
5/ N TA .'OSA CAI i .,-NIA 9J401
i«t 707—JJJ26J0
/.- , \
Ji:i
, 1977
"'x. Ore;; fishei
U.C l>n l.-onncr.t'l iVot'.otion A~crcj
If.O -i 2
Sm i-rr> ,o_.cc, C- 34111
j)iur "'r. Fisher
^ t l-r'iod ~rc co;]'." cf tic 'oi'j 1 jri _ jt.u ro^or' '.:t, r.v^r?''; '•"! ¦> •
at iiic;cby t. vj d, sc'-i?rt.,t.i
T'.1iT'ti r* r.lc- vhi c.v. rvp,1 -ix 1 he ti. t the pice".; '"3 • 07 e t: c no
lo'i ,cr apnljtr.blr, t'iu. V'c pTCcm 5 mc liii 0 3 - va' r^' ..V' In ; isoi .1
in ^r>'i,ic!'^tion o_ a r.i^or jo/i'-ic .
G.u~.£ncG ? cr In"1 ir.visiO'1 Eicti.if : l.cludcc,.
1. o.r^n Or :.z :"o. -'/-e,
?. eU'Gj': —
3. "cc'iuc...! Litciiturf frof. V , ..1 (o.-i.-in aV cl.-r,rr;
4. Cocano;. ..'¦:c st^c> .or;: -.,n-utic; 1 >¦ VjriboKTa, it'.o ¦ '.cr
AuVio—7/.
Vv lotc,'. r.rciil-' to our f:Ic, a c > . r "p Y"'r. ani'2 - • f;.i t- i!' cc'"t"i ] nc "
il ! i-ie'v.i an I'v , ".ijtiifi ->1 of x'-rr.c, i-- ill c„. i^cyo'. . '0 i-'o aule
Cr' ;i \' ic.i ' ao r,, „uja lc-a ot Ju."iC 2, 1D77.
II vcu Vvc any ';u.btio.13 or rtcoivji "vauon',, iii 30 aii/ise.
Sir.corfly,
a f 'F'
& «"oni p. » ni
a< r up»).r
Jllv II r lO, .
t.c '». Jo: ^\o) , * :;pj
-------
Dcccr-Jjur 31, 197'»
I'd', llormr. /.ruorn, Director of 'iivlrorEOrt^l Soi'vlcca
Civvn-'iollcrrach
90't i.'.'.f. Dmlco direct
Car-ns, W.chinrjton 9&j07
Bear Ilr. Ari!>o_-rr:
Enclosed hcrr.nth la I'-onitorinf, w.d Ucpoi'tlrr; rVo.-^nri V.o. 7'.-VJL.
This 1'opJ.torin^ nr"l Itoportin; SVo'jriri '.iII hi con"!cored pr.rl of
Scpixvber lit ixri Decor'jcjf k, ','c:Lo Dl cc:c:'-c i
In AiOu of t w.lia fiMJ'.S pDivit. \o you nrolriblj' '.nvj: tho \"Tu.Ti
nomit contoAncl in Oi-dor i.'o. 7£,-212 i~ not -.a.lid because
objected to t\o r.o.-jio-v.l fcoa-.d'o cction D)D ard Sua-
poi-Jcd Solado effluent requirements.
Plcfoo noto t^it t|io pro^ivwi ia to bi^in on "ebrujiry 1, 1976. 12
you iavo c.i7j crvn-tlona or cc r~cnt3, p?saoo ccntacv u3.
3^;coro!!y,
Bavid C. Joacrh
xi:cci;i,ivo OiTicor
Snclonu.ro
cc; D±-. nLjiolr'1. Eosid-m;
Frits Ca'-ff, Cr^ni-S unpc^ i, raar'rvcn
CIU:jf "
^ f
« y Sf/'OL" S< i-/c fa folJois in? of o'^sr smc
plcasc pj'msh scnvicucs) irjpuao oy checked ciock(S)
(.t-i/i iOi «' t! irets w i ir »** MrdiJ
iv f; :pt
R\,cztvcd 4l: runbct<*<' attic\ dt.ct bcfo"»
ftCtilUt.O l 5
Cinu.* i«.> ,
.szSfV
6
ffwl. LI
JyS'C'V.IUPE Oil r'.Vi.E 0' ;DU"LSSi£ t *<•«/» t» i u*j w
,'\ r* f'.t.vL-'iu—
- / sit.-M1 iEne";o6'i;iss£s .v.i'ir, ir~.\f ^
L*-:- <-)'j .i< C ^1
-------
California Regional Uater Quality Control Board
North Coast Region
HQNITOnillG AND ItETOKTUlG PROCllAIt 110. 74-213
for
IQUISIAHA-PACIFIC COITORATIOH PULP MILL ALT)
BUILDING PRODUCTS DIVISION, SAiDA
Humboldt County
EFFLUENT IIOrJITOmrCr
A 3anplang station shall bo located where the representative tuples of effluent
can bo obtained from outfall 001.
1'dninun
Tvdp of
Constituent
Tla\j
BOD
Suspended Solids (NFR)
Fecal Colifom
pH
Grease and Oil
Settleable Solids
TitrDidity
Arsenic.
Cad.iu.ura
Copper
Total Chrerau:a
Lead
Mercury
Nickel
Silver
Zinc
Cyanide
Phenolic Compounds
Ainronia
Total Identifiable
Chlorinated Hydrocarbons mg/l
Toxicity Concentration Toxicity Units
Radioactivity PCi/L
WATER TPEATi'SiT PIAliT '.'VSTE SOLIDS i'QUITO ITP'G
A sampling station shall be located iihere tho representative samples of waste
solids can be obtained.
Units
KGD
mgA
mg/l
HPiJ/lOO ml
pH Units
tug/l
nl/l
JTU
mg/l
rag/1
mg/l
mg/l
mg/l
mg/l
mg/1
mg/l
mg/l
ng/l
mg/l
mg/l
Type of
Frequency of
Sample
Analvsis
Continuous
24-hr composite
2/./eek
24-hr conposite
2/v'cok
grab
monthly
Continuous
6-hr composite
2/..-eek
grab
daily
24-hr composite
daily
24-hr composite
quarterly
24-hr composite
annually
24-hr composite
annually
24-hr composite
quarterly
24-hr conposite
quarterly
24-hr composite
annually
24-hr composite
annuaUy
24-hr composite
annually
24-hr composite
annually
24-hr composite
quarterly
24-hr conposite
quarterly
grab
annually
grab
annually
8-hr composite
monthly
grab
once every 5 years
Constituent
Turbidity
Flo,;
Suspended Solids
Settleable Solids
Coagulant
Un\l i
JTU
KGD
ml/1
ml/1
lbs/day
Type of
Sanvl o
24-hr composite
Continuous
grab
grab
Continuous
Minimum
Frequency of
Amlv3i3
daily
2/,;eek
2/.,*ock
-------
2!onitoriig oad Itrporting
Prog-na Ko. 74-213
2-
stoti wrrn tauncrm
~ --
stasia::; ¦nail be a", o; .ajrj.'?". :i. -.
rr^-irc tasre is a disc-ur^e of Eton water ;a t-j i,ji;r3 oi 3t;t2.
Co-ust^jsat
Volatile Solids
Ssttleable Solifls
pa
Toxic} ty
Eamfoll
tlnlt-a
ns/1
tal/1
pH Units
TV
inches/day
Type of
5saplc
grab
grab
grab
grab
filamua
Frequency of
Active i-s
2/
daily Oct. 1 Through
Aoril 1
\J Curing every store of intensity greater thaa 0.5"/2-!- hrs but act nora thaa o:x2
a week. '
2/ Burxag every atora of intensity greater than 1.0"/24 hrs tut not dots than.
once a coath.
C00X.IHC wa.TCR rjcrrrcoa dig
Constituent
Tespsraturo
Units
°C
Type of
SaTolo
Crab
l.Mpi-n -i
?reQj23cy of
Ami vsis
2/mek
A station shall bo located vtiere the representative sa^oles of coolxng
rater con 'jl> obtained. A second oanplia^ stctio-i shall bs located at least
50 feat off shore rihere a repreaaatative oasplc of Kusboldt Bay can be obtained.
RECEIVING TfATEH l.'OirTTORI^G
St-ltl03 TTq.
J-1
A-2
A-3
£-1
3-2
5-3
C-1
C-2
C-3
D^gr-iatioa
surface, on the outfall
~id--<3opth, on the outfoll
bottoa, on th
-------
-3-
Monitoring and Ileportins
Program Ho. 74-213
Station '-'o.
Deacritrtion
D—l^r
ourf sample on pipeline
D-2*'
ourf sample 500 ft north of pipeline
D-3"
surf sample 5C0 ft south of pipeline
E-l
curfcco, 500 ft vest of outfall, perpendicular to shore
E-2
mid -depth, 500 ft west of outfall, porpendicular to shore
E-3
bottom, 500 ft vest of outfall, pcrpondicular to shore
^ All D a ample3 are surface camples taken from shore
flfinnt-it.imti,
Coliforn
Oreaao and Oil
Floating Particulates
Transmttanco
PH
Dissolved Oxygen
Radioactivity
Current Diroction
Units
1-IPN
mg/rn^
dry ut/m^
pH Units
mg/l
pciA
Station Ho.
All stations
A-l, B-l, C-l, E-l
A-l, B-l, C-l, E-l
A-2, B-2, C-2, E-2
All stations
All stations
All stations
A-l
Typo of
Sanole
grab
grab
grab
grab -
Grab
Frequency of
Analvcis
quarterly
quarterly
quarterly
quarterly
quarterly
quarterly
once every
quarterly
5 ycai
Tho ocean outfall and diffuscr shall bo iromtored weekly for leaks, breakago, and
malfunction. A statement on the sufficiency of tho outfall system shall oo included
in every nemtorang report.
Monitoring roports shall bo submitted to tho Board for each ronth by the 15th day
of tho follo-.dng nonth, begiaung not later than February 1, 1976.
Ordered by
David C. Joseph
Executivo Officer
December 30, 197K
-------
APPENDIX B
PRIORITY POLLUTANTS LISTING
-------
PRIORITY WATER POLLUTANTS LISTED IN NRDC v. TRAIN
I 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)
*Ch1orinated benezenes (other than
dichlorobenzenes)
7. chlorobenezene
8. 1,2,4-trichlorobenzene
9. hexachlorobenzene
*Chlorinated ethanes (including 1,2-
di chloroethane, 1,1,1-trichloro-
ethane and hexachloroethane)
*Ch1oroalkyl e.hers (chloromethyl,
chloroethyl and mixed ethers)
17. bis(chloromethyl) 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-chlorophenol
*Dich1orobenzenes
1.2-dichlorobenzene
1.3-dichlorobenzene
1.4-dichlorobenzene
*Dich1orobenzidine
3,3'-dichlorobenzidine
*Dichloroethylenes (1,1-dichloroethy-
lene and 1,2-dichloroethylene)
1.1-dichloroethylene
1.2-trans-dichloroethylene
*2,4-dichlorophenol
~Dichloropropane and dichloropropene
1»2-dichloropropane
1,2-dichloropropytene (1,3-di-
chloropropene)
*2,4-dimethyl phenol
*Dinitrotoluene
2,4-dinitrotoluene
2,6,-dinitrotoluene
1,2-diphenylhydrazine
ethyl benzene
f1uoranthene
*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
11isted 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
*Ni trophenols (including 2,4-dini-
trophenol and dinitrocresol)
57. 2-nitrophenol
58. 4-nitrophenol
59. *2,4-dinitrophenol
60. 4,6-dinitro-o-cresol
*Nitrosamines
61. N-nitrosodimethylamine
-------
62. N-nitrosodiphenylamine
63. N-nitrosodi-n-propylamine
64. *pentachlorophenol
65. *phenol
~Phthalate esters
66. bis(2-ethy1hexyl) phthalate
67. butyl benzyl phthalate
68. di-n-butyl phthalate
69. di-n-octyl phthalate
70. diethyl phthalate
71. dimethyl phthalate
*Polynuclear aromatic hydracarbons
72. berizo(a )ar.thracene
(1,2-benzanthracene)
73. benzo (a) pyrene (3,
4-benzopyrene)
74. 3,4-benzofluoranthene
75. benzo(k)f1uoranthane (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. *viny1 chloride (chloroethylene)
Pesticides and Metabolites
89. *aldrin
90. *dieldrin
91. *chlordane (technical mixture
& metaboli tes)
*DDT and metabolites
92. 4,41-DDT
93. 4,4'-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 (1 indane)-Garrma
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-dioxin (TCDD)
~Specific compounds and chemical classes as listed
1n the consent degree.
**This compound was specifically listed in the consent
degree. Because of the extreme toxicity (TCDD). We are recommending
that laboratories not acquire analytical standard for
this compound.
-------
APPENDIX C
METHODS, ANALYTICAL PROCEDURES AND QUALITY CONTROL
-------
FLOW MONITORING TECHNIQUE - LOUISIANA PACIFIC CORP.
SAMOA, CALIFORNIA
December 1977
Flow monitoring at Louisiana Pacific 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 conditions:
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.
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
conducted 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:
o = q cq F
^ C-C
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 A5 x lq-6 m"'n " \
\jau.4b x iu day-1iter '
-------
BIOASSAY METHODS
Toxicity testing consisted of a 96-hour bioassay performed
according to standardized methods.1'2'3 A continuous flow pro-
portional 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 liter 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 stickelback) used were purchased
through a commercial dealer (Alax Fish Company, San Rafael, California).
The dealer provides indigenous wild fish, therefore no data are avail
able on the specific life stage of these organisms. Fish were accli-
mated for 48-hours prior to testing at four different salinities.
The salinity gradient ranged from fresh water to sea water concentra-
tions equal to 25, 50, and 100%. Test fish used in the bioassay were
selected from the specific salinity which most closely 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
dilution water was stored in 1,100 liter (300 gal) expoxy coated reser-
voirs and was replenished every twenty-four hours.
Bioassay test water from the process wastewater discharge was
collected at the discharge side of the effluent pump at Station 3400
by flow proportional 24-hour composites. Since this waste stream did
-------
not include the discharge from the hydraulic barker, a second equal
volume composite was collected from it. The two composites were com-
bined proportional to their respective daily flows and the resulting
composite was used for the bioassay. Composites were replenished
daily. Prior to introduction into the diluter system, the wastewater
was prediluted to a 50% effluent concentration. Makeup water for
predilution consisted of unfiltered Mad river water collected at the
intake to the Crown Simpson mill (Station 3550).
Each test chamber was monitored daily for pH, temperature and
dissolved oxygen concentration [Table 1]. 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 recircula-
ting water bath.
The BOD of the effluent was sufficiently high such that at a 50%
effluent concentration, dissolved oxygen levels were reduced to less
than 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 computerized tape program4
rather than the Litchfield-Wilcoxon method because of the limited
number of test concentrations that evoked a partial response of the
test organisms.
-------
Office of Research and Development, July 1973. Biological Field
and Laboratory Methods. Cincinnati: EPA-670/4-73-001.
National Environmental Research Center, April 1975. Methods for
Acute Toxicity Tests with Fish, Macroinvertebrates, and Amphibians.
Corvallis, Oregon: EPA-660/3-75-009.
Water Control Criteria 1972. EPA-R3-73-003, March 1973.
Spearman-Karber Analysis 1972 Wang SWAP Program Library No. S-173-7.7.
-------
CHEMISTRY
-------
TABLE 1
Physical-Chemical Characteristics of Diluted Effluent
Louisiana Pacific
December, 1977
Effluent Concentration (%)
Control
Parameter (Sea Water) 5 9 16 28 37.5 50
24-hour
DO mg/1 8.0 7.5 7.5 7.5 7.5 7.5 6.5
pH 7.6 7.5 7.3 7.1 6.9 6.7 6.6
temp °C 16.0 16.5 17.0, 16.5 17.0 17.0 17.5
NH^ mg/1 0.05 0.90
48-hour
DO mg/1 7.0 6.5 6.0 6.0 6.5 6.0 6.0
pH 7.2 7.1 7.1 6.9 6.7 6.4 6.1
temp °C 16.5 17.5 17.5 17.5 17.5 17.5 17.5
NH mg/1 0.12 0.59
72-hour
DO mg/1 7.5 6.5 7.0 6.5 7.0 6.5 6.5
pH 7.7 7.2 7.3 7.1 7.0 7.0 6.9
temp °C 16.5 17.0 17.5 17.0 17.5 17.5 18.0
NH mg/1 0.11 0.72
96-hour
DO mg/1 7.5 7.0 7.0 7.0 6.5 6.0 6.0
pH 7.5 7.3 7.3 7.0 6.8 6.7 6.7
temp °C 17.0 17.5 17.0 18.0 18.0 18.0 18.0
NH mg/1 0.12 0.58
-------
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
Chief DATE January 17, 1978
Chemistry Branch
from Technical Coordinator
Inorganics and Air
subject Resuits 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.
Consti tuent
DO
BOD
TSS
Cyanides
Phenols
Analytical Procedure
Membrane electrode probe
Full bottle dilution technique with
settled raw sewage used as seed
Gravimetric, irvillipore 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
Reference
Standard Methods, 14th
Ed, , 1978, p. 450
Standard Methods, 14th
fid. , 1975, p. 543
Standard Methods, 14th
Ed., 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 CUSO4 usec' 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 yellow 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
-------
- 2 -
a high pH to form thiocyanates and give low cyanide results. Therefore,
the cyanide values reported for those samples where precipitates were 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, mq/1 Found, mg/1
BOD EPA 14-34 T7
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 mq of
vacuum pump oil to one liter of distilled water.
D. David Vietti
Attachments
-------
Cnief
Chemistry Branch
January 20, 1978
W. L. Abbott
Technical Coordinator, Trace Metals
California Pulp Mills
Attached is a list of results of metals analysis of subject samples for
priority pollutants. Except for mercury, cadmium, and zinc, all samples
were analyzed by flarneless atomic absorption using the Perkin-Elmer graphite
furnace and auto sampler. Mercury was analvzed 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
fcr 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, rerunninq using the graphite furnace was deemed unnecessary.
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 that nonreproducible results
oft-M 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
MCI, leaving tiie more stable metal phosphate which would then volatilize at
the desired atomlzation terraerature. This procedure was subsequently fol-
lowed for silver and chromium analysis in the expectation that a similar
increase in reoroducibility 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, oercent
recovery data do not apoly. For the other metals, however, spike recovery
data are listed below:
Sample ?!o.
flq
Zn
Cd
3-100-30-1208
--
103%
932
3400-30-1209
8-U
—
—
3500-30-1203
WZ
—
--
3500-30-1209
—
102%
92%
1/ Analytical Chemistry, Vol. 43, No. 1, January 1976.
-------
- 2 -
These values are within quality control guidelines. Since the replicate data
were at or below detection Units, precision estimators could not be usacl.
However, no analytical anomalies were observed.
As can be seen, the lowest concentrations of all elements were found 1n 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 1n the Crown-Simpson process wastewater (3500). Levels of
zinc up to about four times the detection Unit were found in all waste
streams. The greatest amount beinq tn the LP process wastewater durlnq
one composite period. Chromium levels were all low but above the detection
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'mllUgrams per liter (rog/1).
Attachment
William L. Abbott
-------
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
Chemistry Branch
FROM W. L. Abbott
object 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.
Chief
DATE March 8, 1978
William L. Abbott
-------
ORGANICS
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. nOne 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 Finniqan 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 the retention time to those of a pure standard. Once identified,
the compound was quantitated by comparina 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
(d,Q anthracene) as an internal standard. Analysis was then performed by
GC/Hs as described in the EPA priority pollutants 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-jQ 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.
-------
- 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-fluorotriphenylphosphitie (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 Ch^C^. The acid extracts were concentrated and
screened as with the base-neutral extracts. The extracts were then spiked
with 20 ng/ul of d-|g 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 using 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 FC-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% Ho0 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 orgamcs. The extracts were analyzed by GC-FID usinq
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 usinq 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/^S. 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 comoarison 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 Cl^Clp. Any emulsions formed during the extractions
were broken with the addition of NaoS04. 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 chromatooraphy-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 trosamine, methyl propylni trosamine, ethyl propylni trosami ne,
diethylnitrosamine, di-n-propylnitrosamine, ethyl butylnitrosamine, methyl-
ethyl ni trosamine, propyl butylnitrosamine, methyl amylm trosamine, di-n-
butylnitrosamine, nitrosopiperidine, nitrosopyrrolidine, nitrosomorpholine,
and diamylnitrosamine.
1/ Anal. Chem., 47, 995 (1975).
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Laboratory Visited: Louisiana-Pacific Corporation
Samoa, California
Pulp Laboratory
Date of Visit:
December 9, 1977
Parameters:
B0D5, TSS, O&G, SS, pH, phenols, turbidity, and
trace metals
Monitoring Sites:
Process wastewater discharge and hydraulic debarker
effluent
Personnel Contacted: Georqe Kruse, Environmental Technician
Lab Facilities:
The lab was built in 1965 and the approximate dimen-
sions are 50' x 60'. The overall impression per-
ceived was that of an orderly, clean, working lab.
Analytical methods/sampling: The EPA approved methods for B0D5, SS, phenols,
pH, turbidity, and trace metals are used. The B0D5's are analyzed using the
azide modification of the Winkler titration. Seeded blank corrections
appeared to be within normal range limitations.
The standard method for non-filterable residue is used except that the
filters are weighed directly out of the oven without desiccation. This
technique will generally cause lower results.
The EPA method for Oil and Grease is followed up to the point where the
extract is taken to dryness. The freon is distilled down to about 10 ml
and transferred into a tared aluminum weighing pan. The dish is then
placed on a hotplate, and the solvent is evaporated. The pan is placed
in a 105°C oven for 15 minutes, and weighed directly from the oven without
desiccation. The analytical balance used is a Mettler model H6T.
Because the evaporation temperature used is 25°C higher than the EPA approved
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 Direct Photometric Method for measurement of phenols as described in
14th ed. Standard Methods is followed without exception. The Nephelometric
Method for determination of turbidity is used. All trace metals are ana-
lyzed according to the atomic absorption methods in EPA Methods Manual.
All elements except lead are digested by the total metals procedure. The
Special Extraction Procedure is used for lead.
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- 2 -
The chemists contacted had a very good working knowledge of the analytical
procedures used. A one gallon plastic juq was used for most of the com-
posite samples, and a one quart glass jar with Teflon liner for oil and
grease, and phenols. Oil and Grease samples were preserved with 5 ml 50%
HC1, and cooled to 4°C. Phenols were preserved with H3PO4, CuSO*, and
refrigerated at 4°C. Trace metals were preserved with HNO3. AIT other
samples were refrigerated only. Analyses were performed well within the
recommended holding time.
Equipment and Supplies: A Corning digital pH meter is used for making pH
measurements. The meter is calibrated daily with pH 4 and 10 buffers.
The weighing is done on a Mettler model H6T analytical balance. The in-
strument is checked monthly with class S weiqhts, and yearly by a Mettler
serviceman. Turbidity is analyzed with a Hach model 2100 turbidimeter.
Phenols are measured on a Bausch and Lomb Spectronic 20 spectrophotometer.
The instrument used for trace metals analysis is a Varian Atomic Absorption
Spectrophotometer. The AA is serviced yearly by a Varian serviceman. A
supply of good quality distilled water is on hand.
Data Handling: All raw data is recorded on individual worksheets, and
tabulated on DMR forms.
AQC Program: There is no participation in EPA or any other cross-check pro-
gram. Blind samples are not tested. This lab has not been certified by
the state of California. No replicates or standard additions are analyzed,
and blanks are tested only for B0D5, and Oil and Grease. There was not an
NBS thermometer available for calibrations.
Recommendations:
1) Institute an active quality control program consisting of blanks,
replicates, standard additions, etc. performed on a routine basis.
2) Desiccate TSS filters before weighing. Or provide comparative
data to prove there is no appreciable difference in methods.
3) Since the 0&G method does not comply with the EPA-approved method,
comparative tests should be performed and the data submitted for alternate
test procedure approval.
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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 a 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 procedures and
whether additional evidence type samples are required.
SAMPLE COLLECTION
1. To the maximum extent achievable, as few people as possible should handle
the sample.
2. Stream and effluent samples shall be obtained, using standard field sampling
techniques.
3. Sample-tags (Exhibit I) shall be securely attached to the sample container
at the time the complete sample is collected and shall contain, at a minimum,
the following information station number, station location, data taken,
time taken, type of sample, sequence number (first sample of the day -
sequence No. 1, second sample - sequence No. 2, etc.), analyses required and
samplers. The tags must be legibly filled out in ballpoint (waterproof ink).
4. Blank samples shall also be taken with preservatives which will be analyzed
by the laboratory to exclude the possibility of container or preservative
contamination.
5. A pre-printed, bound Field Data Record logbook shall be maintained to re-
cord field measurements and other pertinent information necessary to refresh
the sampler's memory m the event he later takes the stand to testify re-
garding his actions during the evidence gathering activity. A separate
set of field notebooks shall be maintained for each survey and stored in a
safe place where they could be protected and accounted for at all times.
Standard formats (Exhibits II and III) have been established to minimize
field entries and include the date, time, survey, type of samples taken,
volume of each sample, type of analysis, sample numbers, preservatives,
sample location and field measurements such as temperature, conductivity,
-------
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 rf containers and analy-
ses required (Fig. IV). When turning over the possession of samples, the
transferor and transferee will sign, date and time the sheet. This record
sheet allows transfer of custody of a group of samples in the field, to the
mobile laboratory or when samples are dispatched to the NEIC - Denver labora-
tory. When transferring a portion of the samples identified on the sheet to
the field mobile laboratory, the individual samples must be noted in the
column with the signature of the person relinquishing the samples. The field
laboratory person receiving the samples will acknowledge receipt by signing
in the appropriate column.
2. The field custodian or field sampler, if a custodian has not been 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 cheet 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 ui th 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
o
*
Station No.
Date
Time
Sequence No.
Station Location
.Grab
_Comp.
_BOD
_5olicJj
_COD
^Nutrients
\
Samplers:
.Metals
_Oil ancl Grease
_D.O.
_Bact.
_Other
Remarks J Preservative:
Front
/
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
J*9"4**
$ \
Back
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EXHIBIT II
FOR
SURVEY, PHASE.
DATE
TYPE OF SAMPLE.
ANALYSES
STATION
NUMBER
STATION DESCRIPTION
TOTAL VOLUME
TYPE CONTAINER
PRESERVATIVE
NUTRIENTS
BOD
COD I
TOC
TOTAL SOLIDS
SUSPENDED SOLIDS |
ALKALINITY 1
O
a
»
X
a
CONDUCTIVITY* 1
TEMPERATURE* 1
TOTAL COLIFORM 1
FECAL COLIFORM 1
TURBIDITY
OIL AND GREASE 1
METALS
BACTI
PESTICIDES |
HERB J
TRACE ORGANICS
PHENOL
CYANIDE |
t
REQUIRED
REMARKS
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Samplers:
FIELD DATA RECORD
EXHIBIT ill
STATION
NUMBER
DATE
TIME
TEMPERATURE
°C
CONDUCTIVITY
/x mhos/cm
pH
S.U.
D.O.
fng/l
Gage H».
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
Walef
Air
Comp
Grob
Relinquished by: (Signatu tej
Received by: (Signoture)
Date/Time
Relinquished by: (Srgna/yreJ
Received by. (SignafureJ
Date/Time
Relinquished by: [Signature}
Received by: (Signature)
Date/Time
Relinquished by: [Signature}
Received by Mobile Laboratory for field
QnalySIS. {Signature}
Date/Time
Dispatched by: fs.gnoiorej
Dafe/Ti
me
Received for Laboratory by:
Dale/Ti
me
Method of Shipment.
Distribution- Orig — Accompany Shipment
1 Copy—Survey Coordinator Field Files
GPO S 34 - I
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REVIEW OF CHAIN-OF-CUSTODY PROCEDURES
LOUISIANA PACIFIC CORPORATION
Samoa, California
December 5-12, 1977
Records pertaining to the Louisiana Pacific Corporation pre-
survey reconnaissance and monitoring survey were evaluated against
the established NEIC chain-of-custody procedures. Specifically, field
data records, log books, sample tags, and chain-of-custody records
were reviewed to determine the nature and scope of any deviations
from the NEIC chain-of-custody procedures. If a deviation was dis-
covered, an assessment was made of the impact of the deviation on the
survey results. The following is the result of this evaluation.
During the December 6-9, 1977 screening sampling for Priority
Pollutants, four grab samples for volatile organics (Sequence Nos. 01
and 02 from Stations 3400 and 3450 on December B, 1977) were mis-
placed at the mobile laboratory and not shipped to Denver for analy-
sis. The protocol for Priority Pollutants samples calls for collect-
ing at least one volatile organic grab/day to accompany the composite
sample. Since NEIC was collecting 4 grabs/day, the loss of two grab
samples from each station did not jeopardize adhering to the protocol.
At 1430 hr on December 8, 1977, a grab sample of once-through
condensing water effluent (Permit Discharge No. 004) was collected to
ascertain the presence or absence of process wastewaters. This
sample was properly tagged and entered in a field log book. However,
no Chain-of-Custody Sheet was prepared. The sample was hand-carried
to the NEIC mobile laboratory and transferred to a chemist for analy-
sis. The sample was entered into the lab records and analyzed.
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The TSS and BOD composite samples from Stations 3400 and 3450
for December 9, 1977 were properly collected, tagged and delivered to
the mobile laboratory for analysis. The samples were received by the
field analysts, logged in and analyzed. However, no entries were
made for these samples on the formal chain-of-custody sheets. Bio-
assay samples were not kept under custody during collection because
of the large volume of water required for the tests [up to 600 1 (160
gal}]. However the sample containers were kept next to the monitoring
locations 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 items 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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