Port Townsend Paper Corp. is capable of producing leachate or emissions that have the potential to negatively impact soil, groundwater, surface water or air quality and thus the PTPC waste stream cannot satisfy the criteria for inert waste,”

"Port Townsend Paper Corp. no longer qualifies for an inert-waste permit for the landfill at its Port Townsend plant, according to final findings issued by the Jefferson County Public Health Department, and the company plans to appeal the decision.

“The waste stream generated by the pulp and paper mill . . . is capable of producing leachate or emissions that have the potential to negatively impact soil, groundwater, surface water or air quality and thus the PTPC waste stream cannot satisfy the criteria for inert waste,” concluded the report.

Posted on website

The report, signed by Jared Keefer, environmental health and water quality director for the department, and posted on the Health Department's website Monday, was dated Dec. 28.

The final findings underlined earlier county rulings, and Port Townsend Paper officials repeated their intention to appeal it to the state Pollution Controls Hearing Board.

“We believe we have a very strong case,” said Port Townsend Paper President Roger Loney in an email.

“We will continue to pursue a resolution of this issue with the involvement of state and county officials as we seek to operate our facility in an environmentally responsible and economically sound manner,” he wrote.

The Dec. 28 formal denial of the permit starts the 30-day clock of the appeal process to the Pollutions Control Hearing Board.

Loney said the denial was not surprising, since it is largely a restatement of the department's Oct. 17 decision.

Inert-waste permit 

Port Townsend Paper — the county's largest private employer, with nearly 300 workers — requested in September an extension of its inert-waste permit, which had been in effect since 1989.

The county health department said Oct. 17 that the company should be required to attain a more stringent limited-use permit.

The mill appealed the decision Oct. 22, triggering a Nov. 27 hearing to review the decision.

Dr. Tom Locke, public health officer for Jefferson and Clallam counties, issued a denial of the appeal Dec. 3. "

Source and Full Article
http://www.peninsuladailynews.com/article/20130103/NEWS/301039995/jefferson-county-issues-formal-denial-of-port-townsend-paper-permit

National Pollutant Discharge Elimination Systems Permit (NPDES)

National Pollutant Discharge Elimination System (NPDES) Research Links


US Code. 33 USC § 1342 - National pollutant discharge elimination system
http://www.law.cornell.edu/uscode/text/33/1342


Clean Water Act
http://en.wikipedia.org/wiki/Clean_Water_Act


"As authorized by the Clean Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States."
http://cfpub.epa.gov/npdes/



Chapter wac173-220 WAC, National Pollutant Discharge Elimination System Permit Program
https://fortress.wa.gov/ecy/publications/summarypages/wac173220.html


"Permits - Point Source Pollution

The state of Washington, Department of Ecology, Water Quality Program, is delegated by the U.S. EPA as the state water pollution control agency, responsible for implementing all federal and state water pollution control laws and regulations.  Wastewater and stormwater discharges are regulated primarily by wastewater discharge permits, which stipulate specific limits and conditions of allowable discharge.

A wastewater discharge permit is required for disposal of waste material into "waters of the state," which include rivers, lakes, streams, and all underground waters and aquifers.  A wastewater discharge permit is also required for certain industrial users that discharge industrial waste into sanitary sewer systems. A wastewater permit may be required for facilities that have stormwater runoff to surface waters.

This website has information on general permits and individual permits, and other- permit information including the Permit Writer's Manual, car wash guidance manual, water quality data, and wastewater discharge permit fees.

A link to EPA's National Pollutant Discharge Elimination System (NPDES) application forms can be found on the  permit application forms page. You will also find links to Washington's state wastewater discharge permit applications."

Source of Above
http://www.ecy.wa.gov/programs/wq/permits/



EPA Information

"As authorized by the Clean Water Act, the National Pollutant Discharge Elimination System (NPDES) permit program controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Point sources are discrete conveyances such as pipes or man-made ditches. Individual homes that are connected to a municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; however, industrial, municipal and other facilities must obtain permits if their discharges go directly to surface waters.

In most cases, the NPDES permit program is administered by authorized states. Since its introduction in 1972, the NPDES permit program is responsible for significant improvements to our nation's water quality."

Compliance Monitoring

EPA conducts inspections of facilities subject to the regulations to determine compliance. EPA inspections involve:

• reviewing discharge monitoring reports
• interviewing facility personnel knowledgeable of the facility
• inspecting the processes that generate and treat wastewater
• sampling wastewater discharges to navigable waterways and other points in the generation or treatment process
• reviewing how samples are collected and analyzed by the laboratory (More on theQuality Assurance Study Program)

NPDES inspection protocols can be found in Chapters 1 - 7 of the NPDES Compliance Inspection Manual.

The Clean Water Act NPDES Compliance Monitoring Strategy for the Core Program and Wet Weather Sources (PDF) (28 pp, 367K, About PDF) provides inpsection frequency goals for the core NPDES program and for wet weather sources including Combined Sewer Overflows (CSO), Sanitary Sewer Overflows (SSO), Concentrated Animal Feeding Operations (CAFO), and Storm Water.

EPA Memorandum of Understanding with US Coast Guard: Collaboration on Compliance Assistance, Compliance Monitoring, and Enforcement of Vessel General Permit Requirements on Vessels (PDF) (11 pp, 298K, About PDF)"

http://www.epa.gov/compliance/monitoring/programs/cwa/npdes.html





"National Pollutant Discharge Elimination System Compliance Inspection Manual"

The National Pollutant Discharge Elimination System (NPDES) Compliance Inspection Manual (PDF)(802 pp, 9.79MB, About PDF) July 2004 provides guidance on NPDES inspections of wastewater treatment plants, storm water industrial and construction sites, pretreatment facilities, biosolids handling and treatment facilities, Concentrated Animal Feeding Operations (CAFOs), municipal wastewater collection systems (combined and separate from storm water) as well as pollution prevention and multimedia concerns. These procedures are fundamental to the NPDES compliance program and provide inspectors with a method for conducting inspections.

Compliance Assistance | Compliance Monitoring | Compliance Incentives

Civil Investigations

Civil investigations are defined as an extraordinary, detailed assessment of a regulated entity’s compliance status, which requires significantly more time to complete than a typical compliance inspection (i.e., several weeks, as compared with one or a few days). Investigations may be warranted when an inspection or record review suggests the potential for serious, widespread, and/or continuing civil or criminal violations, from a continuing pattern of citizen complaints, referrals from another agency, or from studies conducted by the regulating agency inferring a potential compliance problem.

NPDES Permit Program Basics

• Overview
• Water Permitting 101 (PDF) (11 pp, 41K) - Overview of the NPDES permitting process
• NPDES Strategic Plan (PDF) (19 pp, 785K) - The Water Permits Division's Strategic Plan of goals and key actions on protecting the nation's waters through effective NPDES permits - FY 2001 and beyond.

• Statutes and Regulations
• Clean Water Act - Text of the Clean Water Act
• NPDES Regulations - Explanation of Federal regulations and links to the NPDES regulations
• Other Federal authorities - An overview of the primary federal laws that also apply to the NPDES permit program

• Program and Permit Review
• Permit Quality Review (PQR) - Assess state or regional implementation of the NPDES program.
• Permitting for Environmental Results (PER) Strategy - Presents a coordinated and integrated management system that when fully implemented will produce a nation-wide NPDES program that is more efficient and focuses on environmental results.

• Water Quality and Technology-Based Permitting:
• Overview - Describes both approaches to developing limits in NDPES permits, as well as an overview of the standards-to-permits process
• Watershed Permitting - Describes NPDES permitting within the context of larger watershed efforts.
• Water Quality Trading Policy - EPA’s Water Quality Trading Policy describes flexible approaches to meeting water quality requirements
• Water Quality Trading Toolkit for Permit Writers - Provides detailed information on how to apply the Trading Policy when designing and implementing water quality trading programs.
• Web-based Water Quality Trading Training - Provides Web-based presentations covering the material presented in the one-day water quality trading training workshops.
• Whole Effluent Toxicity (WET) - Draft National Whole Effluent Toxicity (WET) Implementation Guidance (PDF) (109 pp, 1.09MB), Overview of WET



• Secondary treatment - Describes the technology-based requirements for municipal sewage treatment facilities
• Effluent guidelines - Describes the technology-based requirements for industrial and other non- municipal facilities

Roger Hagan new president of Port Townsend Paper Corp. - National Pollutant Discharge Elimination Systems Permit (NPDES)

"Hagan arrives at an interesting time, but then again, the last several years have been interesting all around. Clear challenges await him and the mill. From the mill’s perspective, increasing efficient production, building market share and making the profits that keep the doors open and 300 families directly employed are at the top of the list.

For both the mill and the surrounding community, environmental issues are also front and center.

Current attention is on the 33 acres of treatment ponds that address the mill’s ample wastewater – about 12 million gallons per day, eventually flowing into Port Townsend Bay. The ponds are responsible for most of the mill’s singular smell.

Last week, PT Paper announced it would invest $1 million to install an auto-dredging system that should, over time, dredge out the odoriferous sludge and otherwise assist in the decomposition process.

Both that project and the broader conditions of a new National Pollutant Discharge Elimination Systems Permit (NPDES) are under scrutiny, with the 54-page draft permit now open to public review until June 21.

A debate over the proper level of regulation of the mill’s 25-acre solid waste site – a huge ash pile – has gone legal with administrative and court reviews in the future.

These reviews come on the heels of a lengthy local public debate over PT Paper’s $55 million proposal to rebuild and expand the biomass-burning ability of Power Boiler 10 into a cogeneration plant (producing heat and electricity).

The burning of additional tons of biomass would have reduced the burning of petroleum as an energy source, but would have increased particulate matter and some gases. But the mill also proposed a $10 million upgrade to its air pollution scrubbing equipment that would have, according to the mill, produced a 70 percent reduction in the current level of particulates that reach the air.

While there was an environmental outcry, it appears that energy economics are primarily responsible for pushing the biomass project to the back shelf, if not into the waste bin. For economic reasons related mostly to cheap natural gas and California regulations, the number of potential customers for the exported electricity has dissipated. Of course that also delays the proposed investment in new air pollution control equipment.

Still, the mill is moving ahead with other green efforts, including a 2012 reduction of fuel oil consumption by 1.85 million gallons, with more cuts expected this year, according to PT Paper’s environmental director, Kevin Scott. And, as outgoing president Loney always reminded people, PT Paper remains one of the largest recyclers and reusers in Washington state, processing tons of old cardboard daily into new containerboard or unbleached pulp for resale, and reusing tons of wood waste as fresh wood fiber.

Regarding the profit-and-loss statement, hard information is hard to come by, as the mill’s books are no longer public. But the signs should be positive: Chip supply is cheaper, thanks to busier sawmills; weaker competing pulp mills have washed out of the market; prices for packaging are picking up across the board."

Source and Full Article
http://www.ptleader.com/main.asp?SectionID=5&SubSectionID=5&ArticleID=33488